CRN Testifies Before DC City Council Public Hearing on Food Regulations and Dietary Supplements

WASHINGTON, D.C., June 29, 2001 — The Council for Responsible Nutrition’s (CRN) president and chief executive officer, John Cordaro, testified today before the Washington, DC City Council during a public roundtable of the Committee on Human Services for the Food Regulation Act of 2001 of the D.C. city government.

John Cordaro testified during the public hearing to express the industry’s concern over the dietary supplement language included in the District of Columbia’s Food Regulation Act of 2001. His testimony follows:

Testimony of John Cordaro
President and Chief Executive Officer of
The Council for Responsible Nutrition
On the District of Columbia’s introduction of the
Food Regulation Act of 2001
Friday, June 29, 2001

My name is John Cordaro and I am the president and chief executive officer of the Council for Responsible Nutrition—more commonly referred to as CRN. CRN is the leading trade association representing 100 major dietary supplement manufacturers and suppliers.

In addition to complying with all legal requirements, our members adhere to a strict code of ethics, comply with dosage limits and manufacture dietary supplements to high quality standards under good manufacturing practices.

CRN has advocated on behalf of dietary supplements for the last 28 years. We have been the primary association behind the passage of all major dietary supplement legislation since 1976, including the Dietary Supplement Health and Education Act of 1994. We have worked closely with the Food and Drug Administration, Congress and other partners and allies over the years.

We appreciate the chance to comment on the Food Regulation Act of 2001. As stated in Mayor Williams’ letter introducing the legislation, it is clear that the purpose of the bill is to ensure that food establishments, which include restaurants, food vendors and people involved in preparation and vending of food are preparing and providing safe food to the public. This is good and beneficial for the citizens of the District of Columbia.

However, we are concerned by the language relating to dietary supplements.

The legislation specifically excludes an establishment that offers only prepackaged foods from the definition of "food establishment." Thus, there is no obvious explanation why dietary supplements, which are prepackaged foods, should be singled out in this bill.

The legislation consolidates the various regulatory schemes for different food products into one regulation applying to food generally. For example, the legislation is repealing the separate laws that each regulate candy, ice cream, and horsemeat products. We feel that singling out dietary supplements as a unique category within the general food regulation is not appropriate and to some degree duplicative. It could also lead to a consumer misimpression that there is some unique characteristic of dietary supplements requiring special mention regarding their safety.

All of the requirements that this bill attempts to implement with regard to dietary supplements are already requirements under the Federal Food, Drug and Cosmetic Act. The Federal Act has been protecting public health since 1938. The statutory framework established there is better suited to regulating foods such as dietary supplements.

Indeed, one must ask if the District of Columbia has sufficient discretionary funds to duplicate what the U.S. Food and Drug Administration already does for the district.

Consumers use dietary supplements for a variety of reasons - to complement a specific restricted diet, for convenience, and for general health maintenance. Our members are dedicated to providing safe and beneficial products to consumers. This legislation could hamper those efforts, by creating unnecessary regulatory burdens, while doing nothing to further the public health.

I respectfully request that the language specific to dietary supplements be dropped from the legislation, so that consumers in the District of Columbia who rely on our products like: folic acid, to reduce the risk of neural tube birth defects; calcium, to reduce the risk of osteoporosis and vitamin E, to reduce the risk of heart disease, continue to have access to these products.

Other supplements and their benefits:

• glucosamine to relieve the symptoms of osteoarthritis and slow progression of this disease.

• multivitamins for improved immune function.

• antioxidants for cataract prevention, as well as cancer prevention.

• carotenoids like lutein to help against macular degeneration.

• dietary fiber to help combat heart disease and cancer.

• omega-3 fatty acids to help fight heart disease.

This is only a small portion of the dietary supplements available on the market and their benefits.

I am making available a copy of the executive summary of the Benefits of Supplements in Promoting Health and Protecting Against Disease for the record. It details the health and economic value of maintaining access to dietary supplements that the language within this bill would seriously curtail. I am also providing a copy of the book, Benefits of Supplements in Promoting Health and Protecting Against Disease, to the Council for your review.

I thank you for your time and consideration of this request.

I will be happy to answer any questions you might have.

The Council for Responsible Nutrition (CRN) is a science-based, trade association founded in 1973 and represents more than 100 companies in the dietary supplement industry, including ingredient suppliers and manufacturers. CRN members adhere to a strong code of ethics, comply with dosage limits and manufacture dietary supplements to high quality standards under good manufacturing practices.