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	<title>Comments on: Who pays for product safety and quality?</title>
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	<description>Arnstein &#38; Lehr LLP</description>
	<lastBuildDate>Wed, 15 Feb 2012 13:17:50 +0000</lastBuildDate>
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		<title>By: Paul</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2106</link>
		<dc:creator>Paul</dc:creator>
		<pubDate>Tue, 07 Jul 2009 14:32:20 +0000</pubDate>
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		<description>Where is the independent testing of pharmaceuticals taking place?  Oh yeah, it&#039;s not.</description>
		<content:encoded><![CDATA[<p>Where is the independent testing of pharmaceuticals taking place?  Oh yeah, it&#8217;s not.</p>
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		<title>By: Christine Frisbee</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2099</link>
		<dc:creator>Christine Frisbee</dc:creator>
		<pubDate>Thu, 02 Jul 2009 14:55:18 +0000</pubDate>
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		<description>How is one to choose an independent testing lab? Do the stores believe any lab?</description>
		<content:encoded><![CDATA[<p>How is one to choose an independent testing lab? Do the stores believe any lab?</p>
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		<title>By: Product quality: the never-ending frontier of GMP &#124; The Nutritional and Dietary Supplement Law Blog</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2094</link>
		<dc:creator>Product quality: the never-ending frontier of GMP &#124; The Nutritional and Dietary Supplement Law Blog</dc:creator>
		<pubDate>Wed, 01 Jul 2009 20:46:08 +0000</pubDate>
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		<description>[...] up on a post from June 30, the question of consumer confidence in nutritional supplements arises again. The [...]</description>
		<content:encoded><![CDATA[<p>[...] up on a post from June 30, the question of consumer confidence in nutritional supplements arises again. The [...]</p>
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		<title>By: Hugo Ottolenghi</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2093</link>
		<dc:creator>Hugo Ottolenghi</dc:creator>
		<pubDate>Wed, 01 Jul 2009 13:31:02 +0000</pubDate>
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		<description>You are right, Jim, that a combination of forces is more likely to bring about changes. It would be great if industry members challenged each other, as they do through AHPA and other trade associations. I think, though, that consumers will view the associations with skepticism as they are funded and answerable to their members, not to the general public.</description>
		<content:encoded><![CDATA[<p>You are right, Jim, that a combination of forces is more likely to bring about changes. It would be great if industry members challenged each other, as they do through AHPA and other trade associations. I think, though, that consumers will view the associations with skepticism as they are funded and answerable to their members, not to the general public.</p>
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		<title>By: Hugo Ottolenghi</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2092</link>
		<dc:creator>Hugo Ottolenghi</dc:creator>
		<pubDate>Wed, 01 Jul 2009 13:27:50 +0000</pubDate>
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		<description>Good point, Dan, about manufacturers saying that they produce quality products. But the conflict of interest remains: the manufacturer is paying for test and, probably, choosing the testing lab. Can the consumer trust the results? An independent third party is needed.</description>
		<content:encoded><![CDATA[<p>Good point, Dan, about manufacturers saying that they produce quality products. But the conflict of interest remains: the manufacturer is paying for test and, probably, choosing the testing lab. Can the consumer trust the results? An independent third party is needed.</p>
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		<title>By: Jim Prochnow</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2091</link>
		<dc:creator>Jim Prochnow</dc:creator>
		<pubDate>Tue, 30 Jun 2009 22:18:16 +0000</pubDate>
		<guid isPermaLink="false">http://nutrisuplaw.com/?p=830#comment-2091</guid>
		<description>I am  a lawyer who specalizes in the development, labeling, distribution and marketing of dietary supplements. In my opinion, there is no ready, comprehensive or  feasible solution to the safety and effectiveness frustration expressed by Ms. Hart. Similar frustrations are frequently expressed about other products that we do not fully understand, such as automobiles or computers. I do, however, understand the special attention of consumers about their own health The issuance, in 2007, of the  federal regulations concerning current Good Manufacturing Practices, along with the FDA&#039;s increased attention to imported finished food products and food ingredients, will, in my opinion,  result in a more reliable supply of safe and effective  dietary supplements.  Two other non-governmental efforts also contribute to the awareness of dietary supplement companies of the need to have reliable products. One is the program of periodic publication of analytical test results by consumerlab.com of various classes of dietary supplements ;the other consists of the NAD and ERSP national advertising challenge procedurtes and  programs of the Better Business Bureau. The NAD and ERSP programs continually challenge dietary supplement, as well as other consumer product companies, to present evidence of the effectiveness of their products. In summary, the quick fix or the fix that Ms. Hart is looking for will not occur. Rather, the coming together of these measures , as well as the increased exhortations of the trade organizations such as the American Herbal Prodcuts Association, the NPA, and the American Botanical Council to their members, will result in more food products whose contents match their labels, both in terms of ingredient presence and claimed benefits.</description>
		<content:encoded><![CDATA[<p>I am  a lawyer who specalizes in the development, labeling, distribution and marketing of dietary supplements. In my opinion, there is no ready, comprehensive or  feasible solution to the safety and effectiveness frustration expressed by Ms. Hart. Similar frustrations are frequently expressed about other products that we do not fully understand, such as automobiles or computers. I do, however, understand the special attention of consumers about their own health The issuance, in 2007, of the  federal regulations concerning current Good Manufacturing Practices, along with the FDA&#8217;s increased attention to imported finished food products and food ingredients, will, in my opinion,  result in a more reliable supply of safe and effective  dietary supplements.  Two other non-governmental efforts also contribute to the awareness of dietary supplement companies of the need to have reliable products. One is the program of periodic publication of analytical test results by consumerlab.com of various classes of dietary supplements ;the other consists of the NAD and ERSP national advertising challenge procedurtes and  programs of the Better Business Bureau. The NAD and ERSP programs continually challenge dietary supplement, as well as other consumer product companies, to present evidence of the effectiveness of their products. In summary, the quick fix or the fix that Ms. Hart is looking for will not occur. Rather, the coming together of these measures , as well as the increased exhortations of the trade organizations such as the American Herbal Prodcuts Association, the NPA, and the American Botanical Council to their members, will result in more food products whose contents match their labels, both in terms of ingredient presence and claimed benefits.</p>
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		<title>By: Dan</title>
		<link>http://nutrisuplaw.com/pays-product-safety-quality/comment-page-1/#comment-2090</link>
		<dc:creator>Dan</dc:creator>
		<pubDate>Tue, 30 Jun 2009 21:41:45 +0000</pubDate>
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		<description>Most internet and brick and mortar operations in the retail supplement business often have their &quot;mission statement&quot; in prominence, hopefully they think you may not pay much attention to it, yet the say they only sell products that stand up to their standards. The solution is simple, retailers state that if they decide to stock your item, than they can select that item off any order and randomly test it. That is the terms you agree to if you want to sell to them.
Manufacturers can foot the bill-they brought it upon themselves.</description>
		<content:encoded><![CDATA[<p>Most internet and brick and mortar operations in the retail supplement business often have their &#8220;mission statement&#8221; in prominence, hopefully they think you may not pay much attention to it, yet the say they only sell products that stand up to their standards. The solution is simple, retailers state that if they decide to stock your item, than they can select that item off any order and randomly test it. That is the terms you agree to if you want to sell to them.<br />
Manufacturers can foot the bill-they brought it upon themselves.</p>
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