NDI Groundhog Day: Let’s Start a New Day!

NDI Groundhog Day: Let’s Start a New Day!

Whistleblower Lawsuit Puts Spotlight On FDA Technical Reviews - ScienceInsider

Whistleblower Lawsuit Puts Spotlight On FDA Technical Reviews - ScienceInsider

Hershey Will Offer Certified Chocolate Following Consumer-Driven Campaign

Company announces new commitment to buying Rainforest Alliance certified cocoa after hearing from over 100,000 consumers; takes first step to addressing child labor

WASHINGTON, D.C.///February 1, 2012/// The Hershey Company announced yesterday that it will make its first commitment to sourcing independently certified cocoa for its Bliss line by the end of 2012. The announcement was made days before International Labor Right Forum was scheduled to run a Super Bowl ad highlighting Hershey’s use of child labor and follows a multi-year campaign that generated over 100,000 letters to Hershey, including from 50,000 supporters on Change.org asking Hershey to improve its cocoa sourcing practices.

The “Raise the Bar, Hershey! Coalition”, a group of responsible cocoa advocates led by Global Exchange, Green America, and International Labor Rights Forum, started the campaign after identifying Hershey as behind its competitors on addressing child labor, forced labor, and other abuses in the cocoa industry.

"We are heartened to see Hershey's taking this first step towards accountability in their supply chain and we will continue to dialogue with them about how to ensure they no longer depend on forced child labor," said Judy Gearhart, executive director of the International Labor Rights Forum. "The threat of a Super Bowl ad forced the announcement, but Hershey’s new moves are really the result of thousands of consumers, students, church congregations and community groups writing to them over the past two years.”

The Raise the Bar, Hershey Coalition has been increasing pressure on Hershey, including launching a petition on Change.org, creating “brand-jamming” photos and videos of Hershey products, blanketing the company’s Facebook wall in messages, organizing rallies at Hershey flagship stores, and delivering more than 100,000 letters from concerned consumers to Hershey’s corporate headquarters on Halloween.

“The Raise the Bar, Hershey! Coalition is excited to see Hershey listening to consumer demand for ethically sourced cocoa,” said Elizabeth O’Connell, fair trade campaigns director for Green America, “but we also recognize there is much more work to be done to fight child labor and other abuses in the cocoa industry, and we will continue to encourage Hershey to develop ethical sourcing practices.”

“The growth and ultimate success of Raise the Bar, Hershey’s petition on Change.org is incredible,” said Change.org Director of Organizing Amanda Kloer. “Hershey responded to consumer pressure with a significant improvement in cocoa sourcing transparency. It has been empowering to watch this group of concerned organizations and individuals use Change.org’s tools to fight for changes at the Hershey Company.”  

In response to Hershey’s announcement, eighth grader Jasper Perry-Anderson has created a follow-up campaign on Change.org asking the Hershey Trust to ensure the Hershey Company expands its commitment to certified cocoa to all its products in the future.

Journalists interested in contacting Hershey’s public relations staff should try:

Andy McCormick, Vice President, Public Affairs
717-534-5739
anccormick@hersheys.com

Kirk Saville, Spokesperson
800-468-1714
ksaville@hersheys.com

The Raise the Bar, Hershey! Coalition is led by the following organizations:

GREEN AMERICA is the nation’s leading green economy organization. Founded in 1982, Green America (formerly Co-op America) provides the economic strategies, organizing power and practical tools for businesses and individuals to solve today's social and environmental problems. http://www.GreenAmerica.org

GLOBAL EXCHANGE is a membership-based international human rights organization dedicated to promoting social, economic and environmental justice around the world.http://www.GlobalExchange.org

INTERNATIONAL LABOR RIGHTS FORUM is an advocacy organization dedicated to achieving just and humane treatment for workers worldwide.http://www.LaborRights.org

ABOUT CHANGE.ORG

Change.org is the world’s fastest-growing platform for social change — growing by more than 500,000 new members a month, and empowering millions of people to start, join, and win campaigns for social change in their community, city and country. For more information on Change.org, please visit: http://www.change.org/about

Good fats and vitamins keep the brain young!

By James J. Gormley

“Get rid of all trans fats in your diet!” is the main takeaway message from a December 28 study on vitamins and the brain in the journal Neurology.

According to lead author Gene Bowman ND MPH, an assistant professor of neurology at the NIA-Layton Center for Aging & Alzheimer Research at Oregon Health and Science University in Portland, the study, entitled “Nutrient biomarker patterns, cognitive function, and MRI measures of brain aging,” looked at the relationship between nutrient status, cognitive function and brain health in 104 elderly participants, 62 percent of whom were women.

Utilizing eight distinct nutrient biomarker patterns (NBPs) out of 30 that were originally developed, the authors were able to see, by using psychological and cognitive tests, blood tests and nuclear magnetic resonance imaging (MRI) which participants had less brain shrinkage, or atrophy, and what these nutrient profiles suggest as to what dietary practices may be associated with better cognitive health as we age.

The nutrient biomarker pattern (NBP) was first tested and validated against food frequency questionnaire studies by Bowman and his colleagues in an earlier 2011 study which appeared in the journal, Alzheimer’s Disease & Related Disorders.

“What we’re doing is picking up on the plasma signatures of different nutrient combinations, which will help us come up with better nutritional and public health recommendations,” said Bowman, in a December 29 phone interview.

The results indicated that those who had the highest blood (plasma) levels of vitamins B, C, D and E and omega-3 fats (good fats) did the best on cognitive tests and had the healthiest brains; those who had the most bad fat, specifically trans fat, in their blood did the worst on cognitive tests and had the least healthy brains – meaning their brains showed some initial signs of volume loss, or shrinkage, an early warning for potential dementia or Alzheimer’s disease down the road.

According to Jeffrey Blumberg PhD, director of the Jean Mayer USDA Human Nutrition Research Center on Aging at Tufts University in Boston, the results of “the Bowman study are consistent with several of the studies completed by Martha Clare Morris (and her colleague, Christy Tangney).

“They are also consistent with those showing a beneficial relationship of B vitamins (especially B12) and brain volume published a couple years ago (from a British group). Similarly, observational studies have shown an inverse correlation between folate [folic acid] intake/status and risk for age-related dementias. The Physicians Health Study found beta-carotene is associated with less cognitive decline in aging. And some (but not all) studies have found a benefit of vitamin E supplementation on cognitive performance and/or rate of decline in Alzheimer’s disease.”

It is known that trans fats, which are found in deep-fried foods and as partially hydrogenated oils found in packaged snack and other processed foods, are bad. This study, however, is “the first study to look at trans fats in the context of brain health and functioning,’ added Bowman.

This study, said Bowman, was funded by the U.S. National Center for Complementary and Alternative Medicine (NCCAM). A future study, one that is in the works, will look at the impact of diet on cognition in people over many years or even decades, which is called a longitudinal study.

“Is all that frozen pizza really worth it?,” asked Bowman, who suggests, on the positive side, that people should consider eating more “fish, beans, citrus fruits [and] dark green leafy vegetables.”

Gormley Files Take-Away: Is pizza bad? No, it can be pretty healthy, and frozen pizza at your local health-food store is probably very healthy! But the takeaway here is the very real science that shows that diets drenched in nasty, oxidized trans fats and saturated fats, and low in nutrients makes the brain atrophy, or shrink. Diets rich in omega-3 fats, B vitamins and antioxidants (and low in the bad stuff) keep the old neuroprocessor between our ears healthy and peppy!

Avoiding Avoidance; The Skinny on Weight-Loss Supplements

By James J. Gormley

[Note: Adapted from an article which originally appeared in Natural Products INSIDER Supplement Perspectives]

In marketing geared to weight loss supplements, avoidance language and strategies have been ubiquitous. These “Don’t eat this!” or “Don’t do that!” messages are also dis-empowering for consumers, at best, and dangerous, at worst.

Some industry members will remember the mid-1990s thermogenic ads on double-page spreads in leading consumer magazines promoting products with ma huang and chromium. Other ads touted extracts of Garcinia cambogia and guarana (i.e., avoiding energy loss or fatigue) --- while there were also the “water pill herbal formula” diuretics (i.e., avoiding water retention), as well.

We all know how well inappropriate use of stimulants and diuretics went, now don’t we?

Today, falsely marketed as a “new” ingredient in body-building circles, Beta-PEA (Beta-Methoxy- Phenylethylamine) was originally featured in mid-1990s weight loss ads as a thermogenic “feel good” compound.

While some ads seemed to suggest that nothing else needed to be done lifestyle-wise to lose weight, other products (such as meal replacements) were geared to restore nutrients for people who were on severely calorie-restricted diets (i.e., avoiding food!).

Avoidance diets targeting specific food groups also became greatly popular, including the Atkins’ low-carb/high-protein revolution in the early 2000s. These carb-avoidance diets, often inexpertly followed, led to cases of hyperproteinemia and ketosis.

Today, there are still a number of avoidance diets and products on the market, most of which are almost exclusively sold online or via TV promotions, and feature such questionable approaches as:

• master cleanse diet (avoiding toxins and food!);
• cabbage soup diet (avoiding almost all nutrients; are they kidding?);
• salt-free diet (avoiding a critical electrolyte);
• the HCG [human chorionic gonadotropin] diet (avoiding most food and taking a fertility hormone); and    other water-based or juice-based diet scams.

I won’t even hazard a guess as to how long the FDA will allow a fertility hormone (HCG) to be sold as a weight-loss supplement, but probably until there is a tragedy (or 100).

Of course underlying (or offsetting) all of these weight-loss ads are the following truths:

• People prefer positive calls-to-action and affirmations to negative, avoidance messages, e.g. “Eat healthy!” versus“ Don’t eat that ice cream, you pig!”
• Avoidance messages are turn-offs, and make us feel like we are missing out on something (or a lot of somethings, given the above diets), so we feel (or we are) deprived.
• Avoidance diets are often misguided and dangerous.
• Think: improved body composition instead of “weight loss.”

Takeaway? All of us who manufacture or sell weight loss, or improved body composition, products or ingredients should keep the above in mind as we develop and market these products.

Because what consumers will gain by properly sourced, manufactured, and marketed “weight loss” products is of hefty value, indeed: an opportunity to complement a full, lifestyle approach to healthier body composition and improved self-esteem.

That’s not something to avoid, now is it.  

IPA founder: EU probiotic approach is “dirty pool”

IPA founder: EU probiotic approach is “dirty pool”

Inaccurate media coverage and misguided attempts at regulation? A year in consumer health advocac...

Inaccurate media coverage and misguided attempts at regulation? A year in consumer health advocac...

Citizens for Health NDI guidance withdrawal petition signatures approach 15,000

Citizens for Health NDI guidance withdrawal petition signatures approach 15,000

You Did It!!!!!

You Did It!!!!!

10,000 Americans Tell FDA: Withdraw the “NDI Draft Guidance”!!

10,000 Americans Tell FDA: Withdraw the “NDI Draft Guidance”!!

10,000 Signatures in 10 Days; We Can Do It!

By James J. Gormley
With Citizens for Health supporters already having generated over 11,000 letters to Congress demanding that the FDA’s NDI Draft Guidance be withdrawn, the organization is now on a mission to collect 10,000 petitions in 10 days calling for Congress to withhold FDA appropriations until this unaccountable agency is held to account: by adjuring the FDA to withdraw the supplement-killing NDI Guidance and to cease and desist from reviewing and enforcing against dietary supplements and nutritional ingredients according to its willfully adversarial re-interpretation of the laws governing dietary supplements.

To help us in this effort, Australian truth rapper and activist Jody Lloyd, aka Trillion, has re-mastered CFH’s “10,000 Signatures” video to make our call-to-arms that much more impactful!
Please sign the petition today and send out the link (and video!) to all of your contacts, friends and family, work colleagues, in short, everyone in your personal universe who cares about their rights to high-quality, innovative dietary supplements!

Petition to Demand that the FDA Withdraws the NDI Draft Guidance!

By James J. Gormley

Let's call on Congress to demand that the FDA summarily withdraws the NDI Draft Guidance and goes on the record stating that the agency will not, now or ever, review, consider, surveil or engage in enforcement activities according to the re-interpretation of the Dietary Supplement Health and Education Act of 1994 (DSHEA) evident in its Guidance document but, instead, will honor the law that the American people gave to the FDA (via Congress) to uphold via regulation according to both the spirit, letter, and plain and intended meaning of DSHEA.

That's why we created a petition to The United States House of Representatives, The United States Senate and President Barack Obama, which says:

"I hereby join with Citizens for Health (CFH) and its over 100,000 citizen supporters in calling on Congress to withhold funding appropriations for the FDA until the agency summarily withdraws its NDI Draft Guidance and goes on the record stating that the agency will not, now or ever, review, consider, surveil or engage in enforcement activities according to the re-interpretation of the Dietary Supplement Health and Education Act of 1994 (DSHEA) evident in the NDI Draft Guidance, but, instead, will honor the law that the American people gave to that agency to uphold via regulation according to both the spirit and letter of DSHEA."

Will you sign this petition? Please click here.

Thanks!

A Defining Moment for the Dietary Supplement Industry

By James J. Gormley

The Federal Register states that the New Dietary Ingredient (NDI) Draft Guidance, “when finalized, will represent the Agency’s current thinking on NDIs and dietary supplements that contain NDIs.”

Although this same notice observes that the Guidance is not binding, the U.S. Food and Drug Administration’s (FDA) new dietary supplements’ director and erstwhile industry representative, Daniel Fabricant, PhD, made it clear that the FDA believes that the guidance contains “no surprises” (It, in fact, contains many) and merely provides “clarity” (Yes and no: it makes it clear that the FDA is willfully re-interpreting DSHEA is several key areas but is fuzzy on specifics).

And while Dr. Fabricant and his new employer may persist in believing that the Guidance contains no rabbits pulled out of a proverbial hat, a chief architect and co-author of DSHEA, Sen. Orrin Hatch (R-Utah), is alarmed by the Guidance.

Recently, at least one industry opinion leader has suggested that playing nice with the FDA on the Guidance would be the way out of the NDI quagmire since the FDA supposedly has such a stellar track record of working collaboratively with industry.

Nothing could be further from the truth. Every major victory won by the natural products industry has been always bloody, sometimes ugly and never cordial.

War seldom is.

In 1966, the FDA announced plans that it was going to ban nutrient potencies over the RDAs by reclassifying them as drugs, along with labeling restrictions that would have forbidden the inclusion of any useful information about supplements.

When this, the health-food industry’s, first defining conflict was waged in the late 1960s and 1970s, the battle cry that the great, and recently departed, Max Huberman rallied the industry and consumers around was, “No surrender! No retreat!”

The battle cry was not “Let’s play nice,” of that I can assure you.

In the early 1990s, when the industry and consumers were fed up with FDA raids on health-food stores and efforts by the agency to use food additive provisions of existing law to go after supplements and companies for which the agency bore a deep-seated animus, a dramatic response was needed, and aggressive, coordinated grassroots action was with what consumers and the industry fought back: black, funereal fabric was used to cover dietary supplements in health food stores, a major public service announcement was aired and millions of Americans demanded the passage of the Dietary Supplement Health and Education Act of 1994 (DSHEA).

And we won.

Offering an olive branch to the FDA at the time would have led to the destruction or gutting of the dietary supplements industry before many of us were even a part of it.

So for our industry to offer concessions on the Guidance while the battle has just begun is diametrically opposed to what the greatest debaters have known since the time of Cicero: being unattached to the outcome.Master negotiator Herb Cohen said this often: “I care, I really do … but not that much.”

Modern-day Cicero, Jeff Schneider explains this to mean that whichever party has the greater need to get the deal done is the party that is at a competitive disadvantage. He says that the moment we start making concessions prematurely is the moment we lose our leverage.

“It is unwise to assume that the person [or Agency] you are negotiating with maintains the same commitment to Win-Win outcomes that you have,” writes Schneider. He advises negotiators to “establish your line in the sand. […] You must vow not to cross the established line in the sand for any reason.”

Do those industry experts and pundits applauding accomodationist approaches to the NDI Draft Guidance know that the FDA is not our industry’s friend, and that the agency bears an institutional resentment (some might say hatred) against our marketplace and its products and has shown this since the 1960s with raids, illegal wiretaps, improper seizures and a boatload of adversarial rulings and decisions?

Do those self-appointed savants know that the legal duty of any agency is to solely regulate and enforce according to the law given to it by the American people through Congress, and agencies do not have the power to devise policy and are not allowed to issue regulations or enforce one millimeter outside of the express letter of the law?

They should.

When any agency, in this case the FDA, violates the law by re-interpreting the plain and intended letter and meaning of it, in this case DSHEA, it must be called on it.

We must not stand for side-door efforts to cripple or maim our industry, and we have no obligation to give one inch on this, especially when dealing with an out-of-control agency that is, through stated intent, itself violating the law with which it was entrusted by the American people to uphold.

For those who have not yet taken action on the issue, there are only about 20 days left to so, given the current deadline of December 2nd. Please write to Congress here (http://salsa.democracyinaction.org/o/750/p/dia/action/public/?action_KEY=8252) and to FDA Dockets here (https://secure3.convio.net/aahf/site/Advocacy?cmd=display&page=UserAction&id=833), and circulate these links via all of your lists.

Let no one in our industry fall victim to the romance of “having a seat at the table” as a representative of the regulated industry.

Because that plate in front of them might well be empty.

Senate Vote Puts Net Neutrality Rules in Jeopardy

Consumers Union Urges Senators to Support an Open Internet
WASHINGTON, D.C. - As the Senate gears up to vote on a proposal to repeal the Federal Communication Commission’s (FCC) Open Internet rules, Consumers Union, the policy and advocacy division of Consumer Reports, sent a letter to Capitol Hill yesterday urging lawmakers to reject the proposal and keep the Internet open for consumers.

“The FCC’s Open Internet rules simply make it harder for internet providers to play favorites by speeding up or slowing down content over their networks. Consumers expect and deserve to be able to freely surf the internet. To do away with these rules goes against the very nature of the Internet’s open marketplace,” said Parul P. Desai, policy counsel for Consumers Union.

The Congressional Review Act before the Senate (S.J. Res. 6) would eliminate the current FCC rules and hobble the FCC when it comes to keeping the Internet open. President Obama yesterday announced that he would veto the Senate legislation, saying an open Internet is critical to job creation, economic growth, and global competitiveness.

Desai said, “The overwhelming majority of stakeholders -- consumers, small businesses, unions, religious organizations and minority groups -- agree that the Open Internet rules are needed and that the FCC has the authority to implement and enforce these rules. We urge the Senate to vote no on this proposal. Rejecting this measure would ensure consumers could continue to use the Internet equally.”

For a full copy of the letter, please contact David Butler or Kara Kelber of Consumers Union.

### Contact:
David Butler or Kara Kelber, 202-462-6262

NHRI Symposium Heralds A New Era for Dietary Supplements

 By James J. Gormley

The ballroom was packed at the Natural Health Research Institute (NHRI) 6^th Annual Scientific Symposium in Schaumburg, Illinois on October 28^th, as well it should have been not only considering the event title, which was “Cutting Healthcare Costs Through Prevention: Measuring the Efficacy, Safety, and Cost Savings of Dietary Supplements,” but also given the stellar lineup of world-class experts.

The speakers were:

• Meg Jordan, PhD, RN, Department Chair and Professor of Integrative Health Studies at the California Institute of Integral Studies, and Director of Integrative Practice at the Health Medicine Institute;
• Mark Blumenthal, Founder and Executive Director of the American Botanical Council (ABC) and Founding Member of the American Herbal Products Association (AHPA)
• Allen Dobson, PhD, Health Economist and President of Dobson DaVanzo and Associates;
• Artemis Simopoulos, MD, Founder and President of the Center for Genetics, Nutrition and Health; and
• Russell Jaffe, MD, PhD, Fellow of the Health Studies Collegium and Founder of PERQUE.

Meg Jordan

Dr. Jordan, whose presentation was entitled “Let Sanity Reign: The Undeniable Health-Wealth Connection for a Happier, Healthier Society,” electrified the audience with what could have been an indictment of how unhealthy the U.S. is but, instead, pointed the ways we can build a well-being society that takes into account: spirituality, nutrition-food, physical health, social belonging, intimacy and love, financial well-being and occupation-livelihood.

Mark Blumenthal

Mark Blumenthal’s talk was entitled: “Review of Safety and Benefits of Numerous Herbs and Phytomedicinal Dietary Supplements as Demonstrated by Systematic Reviews and Meta-Analyses of Controlled Clinical Trials.” Mr. Blumenthal stunned many attendees with the statement that over a 3-year period, the annual number of herbal medicine papers rose from 739 in 1977 to 6,364 in 2007, most of which were scientific reviews and randomized controlled trials. 

He compared thenumber of studies with the imbalanced, typicaly negative coverage of herbal studies by the mainstream press, especially noticeable in journals that have the highest ratio of pharmaceutical ads, and reviewed the worldwide research on a wide range of medicinal plants.

Allen Dobson

Dr. Dobson’s presentation, “Discussion of Methods Used to Study the Reduction in Health Care Cost Through Dietary Supplements,” reviewed the billions of dollars in healthcare savings that could be achieved by widespread public-health promotion of a number of nutrients (including: calcium with vitamin D; folic acid; omega-3 fats; and lutein with zeaxanthin). Of great interest to many in attendance, he punched a number of holes in the recent multivitamin and vitamin E studies that have achieved such infamy.

Artemis Simopoulos

Dr. Simopoulos’ talk was entitled: “Economic and Health Implications of Changing America’s Oil: The Omega-3 Opportunity.” She outlines the many downsides of the dramatic decrease in omega-3 fat consumption over the past 150 years due to agribusiness and food processing and the reasons why it is utterly imperative that we, as a society, significantly increase our consumption of omega-3 fats and decrease our intake of omega-6 fats.

Dr. Jaffe closed out the presentations with a talk entitled, “Evidence of Savings Through Application of Supplements to Treat Dietary Deficiencies.” He explained how by our correcting essential nutrient deficits relating to diabetes alone could save $135 billion each year, and that supplements for other health areas can save America an additional $50-100 billion annually, all while improving quality of life.

Russ Jaffe

With the event having been organized by the NHRI and the American Nutrition Association, the NHRI is an independent, non-profit organization that supports science-based research on natural health and wellness. It is “committed to informing consumers, scientists, the media, policymakers and legislators about scientific evidence on the efficacy and cost-effectiveness of diet, supplements and a healthy lifestyle in order to improve health and wellness, and reduce disease, around the world.”

Coffee Consumption Associated With Decreased Risk for Basal Cell Carcinoma

Coffee Consumption Associated With Decreased Risk for Basal Cell Carcinoma

The Next Ephedra is Ephedra?

[Note: Adapted from an article which originally appeared in Natural Products INSIDER Supplement Perspectives]

By James J. Gormley

It would seem so based on recent ads in the musclehead magazines.

In a recent issue of one mag, there are double-page ad spreads from a company that one would think has had enough enforcement actions against it to last several lifetimes. The ads feature images and cartoons of women who look either like Vegas strippers or hookers along with ad language screaming that these products have 25 mg of ephedra extract, but with caveats that say "we're not breaking the law, folks; these things are perfectly legal."

The only way these products could not be in direct and flagrant violation of the law is if: 1.) they are not dietary supplements but are instead special classes of OTC remedies (which they are not); or 2.) the so-called ephedra is not really ephedra but some other botanical.

Well, there are a few big problems here. If the main active is not ephedra, then the FTC could slam the company for false and deceptive advertising and for claiming their products have a banned ingredient. If the flagship ingredient is ephedra, well the enforcement pathway on that is pretty clear!

If, however, the so-called ephedra extract is actually derived from the Acacia rigidula plant (as one of the ads suggests), it may not contain ephedra alkaloids but it may well contain methamphetamine, mescaline and nicotine, not the safest profile, to say the very least.

Seeing these ads really got me mad, and I wound up calling Marc Ullman, who was equally incensed. I sent these ads to the FTC, FDA and the USDA import-export officials, in addition to copying the trade associations.

Precisely because the vast majority of supplement manufacturers are responsible and ethical, it behooves us as an industry to do everything we can to not only protect consumers from misinformation and harm but to also shine a light on gray-market profiteers who are taking advantage of the DSHEA regulatory pathway yet whose products are merely masquerading as nutritional supplements.

It’s hard for us to stand tall when these bottom-feeders are muddying the waters for all of us.

There have been astounding advances in athletic-performance-related nutritional research along with the introduction of powerful, science-based sports supplements, but until we call out, shame and shun these jokers, we will have our treadmill set to “uphill” for a long time.

Natural Products Foundation – John R. Carlson Memorial

Natural Products Foundation – John R. Carlson Memorial

Citizens for Health: NDI guidance ‘contravenes spirit and letter of DSHEA'

Citizens for Health: NDI guidance ‘contravenes spirit and letter of DSHEA'

Citizens for Health Launches Campaign Against FDA’s NDI Guidance

Citizens for Health Launches Campaign Against FDA’s NDI Guidance