The Council for Responsible Nutrition’s Supplement Online Wellness Library marked its fourth anniversary recently.
Two members of the Supplement OWL advisory board – Guru Ramanathan, industry consultant and president of Guru Ramanathan LLC, and Russ Michelson, Reckitt Benckiser Group’s global regulatory head for vitamin, mineral and supplement products – answered HBW Insight questions about the site’s progress and the potential for mandatory registration for dietary supplements sold in the US.
Below are portions of Ramanathan's and Michelson's remarks submitted via email on 8 July . (See related story for more of their insights about VMS product registration in the US.)
HBW Insight: When you began working in the dietary supplement industry, what would you have thought about the idea of on internet listing of supplement products like Supplement OWL?
Guru Ramanathan: “Discussions of an industry-run registry of product labels initially started in 2014, but it was in 2015 when concerns raised by the New York State Attorney General’s office brought new attention to the self-regulatory initiative. The environment was a bit more troubled at the time as it was immediately following these misguided inquiries into the industry. So the value of the public-facing aspect was very critical to restore consumer and regulator confidence. Prior to that, some of the best sources of product level and structure-function information was specialty retailer websites such as GNC.com and Vitaminshoppe.com.”
Russ Michelson: “Honestly, having started my career about 15 years ago working on international dietary supplement requirements, the idea of a listing process for a dietary supplement was not novel. Or even intimidating. Many markets around the world have anywhere from a label notification process to a full-on dossier with market pre-approval. I knew that the US market was (and still is) the most established market in the world and you never really got the sense that a listing, notification, or registry was in the cards for the US market.”
Was it something you expected the industry would need? Or something that could possibly be done?
Ramanathan: “I think this was inevitable as our industry continues to grow and mature. With continuous good manufacturing practices come increasing expectations for traceability and transparency. I certainly knew it could get done and recognized how it could make a stronger supplement marketplace.”
What were your thoughts when CRN proposed developing Supplement OWL?
Michelson: “I transitioned into my first US role right about the same year that the Supplement OWL launched, and at the time I wasn’t sure the role the OWL may have in this industry. But through engagement with CRN staff and members, and through CRN’s thorough OWL promotional campaigns following the launch, I quickly understood that not only did this move the industry in the right direction and serve as a transparency tool for consumers, but it also helped fill a critical gap with FDA. FDA, whose role it is to ensure safety and compliance of these products, was admittedly blind to a majority of dietary supplement products on the market. And with no parties eager to go down a pre-market approval pathway for this category, here came CRN and its industry-wide OWL Advisory Board, who were able to create a simple and manageable database that serves industry, consumers and regulators.”
Ramanathan: “GNC recognized the Supplement OWL’s value and how this self-regulatory initiative offered the opportunity to advance the industry’s credibility. The timing was opportune, as a number of industry self-regulatory initiatives, such as AHPA’s efforts with the botanical GACP/GMPs and NPA’s work with SSCI, were also moving forward to restore and enhance consumer confidence in the wake of the NY AG episode. From the outset of the Supplement OWL, GNC was committed to working with CRN to develop this self-regulatory registry. The company worked closely alongside CRN and other industry leaders, to develop the mechanics of the searchable registry, offered suggestions for technical improvements, test-drove the early versions of the registry with its own labels, and continued to express support among the vendors in its stores. GNC was also among the first nine companies to beta test the Supplement OWL in 2016.” ()
Were you already thinking that industry should voluntarily offer consumers access to list all products the industry is selling in the US?
Ramanathan: “Not necessarily, however, we weren’t in a position to leave any stones unturned when it came to reassuring consumers. It was clear that change was needed in the industry to increase transparency and accountability. When the registry first launched, we immediately recognized how the Supplement OWL could serve as a resource for regulators, retailers, and ultimately consumers. As the registry continued to evolve, take on a new design, and become even easier to use, the Supplement OWL Advisory Board recognized an even greater opportunity to promote accountability for consumers. Supplement users today have the ability to use the OWL to easily identify products, their ingredients and the companies behind them.”
Michelson: “It didn’t really occur to me until I saw how scattered and inconsistent other sources of labels were. As I do competitive intelligence in my day-to-day work, do you know how hard it can be to just simply find a Supplement Facts panel for a product? What ingredients are in a product I’m evaluating, at what levels, what are they calling it and saying about it on the label, how does it compare to another product, etc.? Sometimes between Amazon and the product’s own website, you can piece this information together, but so many times this is left to simply product images and marketing claims. So if I can’t find what I want to know about a given product, where is a consumer to go other than the physical store with the physical product present? So while it wasn’t top of mind originally, over time I grew to understand the value the OWL could have to a shopper, or just someone interested in researching supplement products, in the way that it provides accurate, clear, and up-to-date information in a simple and searchable platform.”
If you’ve had reservations about compiling such a list and offering it to consumers, what are those?
Michelson: “I did have reservations at first; not necessarily about consumer access but just in general, similar to what many of us voiced at the early stages regarding the value such a registry would have for our industry. But for consumers, with education and awareness, the OWL can serve not only as just a database to find labels, but as a place to find products you have a reason to trust; companies that are willing to put their products in a voluntary database have demonstrated a commitment to transparency. They have nothing to hide. And that should put consumers at ease if they choose to make purchases as a result.”
Ramanathan: “For the industry as a voluntary matter, most of the senior leaders have had no reservations. The challenge is always when there is talk about working with governments on such an initiative - how do you satisfy the needs of all stakeholders.”
Why do you think industry members outside of CRN have been slow to add to their products to Supplement OWL? What will it take to convince more of them to participate?
Michelson: “While the OWL is easy to use, it still requires ‘work’ to put labels in. It’s not a full time job by any means, but there was some initial hesitancy by some companies about how many man hours it might take to upload labels, QC check them, keep them updated, etc. A large majority of companies quickly overcame that and found a nice cadence to the upload process, and recent improvements to the system itself have made things even easier. I think that with more awareness of the ease of use (tutorials, screen shots of the process, anecdotal evidence, etc.) as well as the overall value the tool brings, you may be able to encourage some companies that the barrier to enter labels is not so high. I use it as an excellent searchable database for certain ingredients or claims that I may be researching. And beyond that, I even use it to find clear pictures of my own brand labels sometimes!”