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Humphrey Taylor
Harris Interactive
New York, NY 10003
References
First, the manufacturer does not have to disclose to the FDA or to consumers what evidence it has to back up its claims about the product or its safety. Second, the manufacturer is not required to record, investigate, or forward to the FDA any reports of adverse events. Finally, the manufacturer establishes its own manufacturing practice guidelines to ensure that the dietary supplements are safe and contain the ingredients listed on the label. The FDA does not routinely analyze the content of dietary supplements. The only notification that the FDA may receive is that a dietary supplement contains a "new dietary ingredient." However, it is up to the manufacturer to determine whether an ingredient is "new," since there is no authoritative list of "old" dietary ingredients.
I hope most consumers are aware of these caveats.
Mario L. de Lemos, Pharm.D.
British Columbia Cancer Agency
Vancouver, BC V5Z 4E6, Canada
mdelemos{at}bccancer.bc.ca
Under this act, manufacturers must submit safety documentation for new ingredients, which the FDA may disallow at will. Existing products that prove to be hazardous can also be prohibited. These requirements strike a fair balance between laboratory science and human experience. The safety of common herbs is as well established by traditional knowledge as is the safety of many vegetables, spices, and beverages with presumed fitness for consumption that is unsupported by rigorous American studies in animal models or clinical studies. Indeed, arguments against the act carry the bizarre implication that dual-use botanicals, such as ginger, may be safe when eaten as vegetables but hazardous when taken as supplements.
Wendy L. Applequist, Ph.D.
Missouri Botanical Garden
St. Louis, MO 63166-0299
wendy.applequist{at}mobot.org
Jeffrey M. Drazen, M.D.
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