Trade groups comment on ODS’ Strategic Plan for 2022-2026


In response to NIH’s ODS request for comments, industry stakeholders such as the American Herbal Products Association and The Council for Responsible Nutrition, and The Consumer Healthcare Products Association submitted comments on Aug. 31.

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In early August 2022, the Office of Dietary Supplements (ODS) at the National Institutes of Health (NIH) began accepting comments on the draft version of its ODS Strategic Plan for 2022-2026. In response to NIH’s ODS request for comments, industry stakeholders such as the American Herbal Products Association (AHPA; Silver Spring, MD) and The Council for Responsible Nutrition (CRN; Washington, D.C.), and The Consumer Healthcare Products Association (CHPA; Washington, D.C.) submitted comments on Aug. 31.

The core input offered by AHPA was the encouragement of greater involvement from members of the dietary supplement community in ODS activities. Many of the strategies suggested by ODSP would benefit from collaboration from industry stakeholders, says AHPA. The association also requested ODS directly communicate new or updated ODS tools, educational activities, and research outcomes to dietary supplement industry associations as a standard part of dissemination activity. 

“These suggestions reflect the herbal community’s shared interest in the ever-growing evidence base for herbal supplements,” AHPA director of regulatory affairs Robert Marriott said in a press release. “Greater participation from private and public stakeholders will help the office identify research opportunities and sources of insight that might otherwise be missed.”

The call for greater collaboration with industry was echoed by CRN as well. “As industry is an important stakeholder in the dietary supplement space, we recommend specific language be created in the strategic plan on how to develop and maintain two-way communication and potential partnerships with industry members,” said Andrea Wong, PhD, senior vice president of scientific and regulatory affairs at CRN, in a press release. “Much of the language is one-way, coming from ODS to industry, but does not appear to be encouraged from industry to ODS, beyond commenting on the strategic plan. Having an industry advisory council with members from companies of all sizes, along with trade associations, could support two-way communication.”

CRN also made suggestions about potential knowledge gaps ODS should address. Here, Wong mentioned the lack of research for the use of dietary supplement use in contributing unique nutritional needs to lactating women. “ODS could conduct or support research in this area and educate consumers and healthcare providers on the different nutritional requirements during the post-partum period compared to during pregnancy,” she explained. Additionally, CRN also encouraged developing a research paradigm that would investigate defined outcome measures associated with health promotion, which CRN argues is the purpose of dietary supplements, not disease prevention, as current research typically assessed them.

CHPA too encouraged ODS to collaborate more closely with industry, such as including industry stakeholders in the Federal Working Group on Dietary Supplements. Acknowledging the potential for mandatory product listings being implemented in the near future for dietary supplements, the trade group recommended that the NIH’s Dietary Supplement Label Database (DSLD) be used as a model for a listing database. Considering the "significant effort and expense that ODS has invested in building, improving, and maintaining the DSLD," it would be a "missed opportunity if FDA did not lean on the technical knowledge gained by the development and improvement of the DSLD."

Updated on September 19, 2022, at 12:40 PM EST

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