Case Studies

FDA educational content on dietary supplements biased, misses opportunity to promote public health

This is an article I wrote for the CRN Daily Supplement member newsletter, covering a project I led—providing feedback to FDA on its mischaracterization of dietary supplements

Pushing back on a lack of balance and overemphasis of potential risk, CRN last week wrote to FDA identifying concerns with the agency’s “Supplement Your Knowledge” educational content released earlier this year. In addition, CRN’s comments to FDA addressed the mischaracterization of dietary supplements throughout its website content in general.

CRN’s recommendations, highlighted in a presentation to the association’s board of directors,address ways that FDA’s content:

  • Overstates the potential risks of taking supplements, while downplaying their benefits
  • Fails to convey the robust regulatory framework that gives the agency authority over dietary supplements—downplaying areas of existing authority and drawing attention to ways FDA lacks authority
  • Misses opportunities to address public health issues like nutrition gaps, shortfalls in nutrients of concern, and nutritional needs of specific populations
  • Could be enhanced by collaboration with the dietary supplement industry

CRN’s Communications and Media Outreach Committee received a detailed update on FDA’s campaign following a CRN staff meeting with FDA Office of Dietary Supplements Director Cara Welch, Ph.D., and a team of CRN staff representing regulatory, government relations, and communications perspectives collaborated on the association’s feedback.

“This feedback is just one part of CRN’s long-term, ongoing effort to engage the FDA and be an active participant in the regulatory process. CRN regularly comments to the agency on technical matters in proposed regulations,” said Gretchen Powers, CRN VP, marketing and member experience, who curated CRN’s recommendations, in coverage from Nutrition Insight. “For example, CRN petitioned FDA on NAC (n-acetyl cysteine) and CBD and has commented every step of the way on New Dietary Ingredient (NDI) notifications.”

“Our recent letter on FDA’s communications is unique in that the agency did not publicly solicit the comments,” explained Powers. “CRN and its members found the educational content so problematic, and the process behind its development so non-transparent, that we felt it was our duty to push back.”

“CRN hopes that by sharing this feedback with FDA, we put the agency on notice that dietary supplement stakeholders, such as our responsible member companies, have seen this content and won’t allow negative bias to stand,” said Powers.