AHPA reiterates encouragement for voluntary submission of labels to federal database
The American Herbal Products Association (AHPA) submitted recommendations to improve the federal government's Dietary Supplement Label Database (DSLD) to better inform supplement consumers.
The DSLD is a joint project of the Office of Dietary Supplements (ODS) and the National Library of Medicine (NLM) of the National Institutes of Health (NIH) and provides images of supplement product labels and information about the listed products in numerous fields.
"AHPA continues to encourage members that market dietary supplement products under their own brands to submit labels for inclusion in the Dietary Supplement Label Database because so many AHPA members have a strong interest in the database functioning effectively to provide users with accurate labels and other information about dietary supplements," said AHPA President Michael McGuffin. "To better inform consumers, AHPA recommends improvements be made to the accuracy of database entries and that the database be redesigned to provide only currently marketed labels."
AHPA recommends several changes to improve numerous database functions.
Organization and content
AHPA provides several recommendations to improve the organization and content of the DSLD, including:
- Archiving labels for products that are no longer available for purchase in the U.S.
- Removing any labels identified by the brand owner as erroneous
- Providing simple and readily accessible mechanism to indicate product forms when conducting a search of the labels
- Revising information on intended users to be more accurate and clear
AHPA recommends that the disclaimer on the DSLD website be modified to make it consistent with FDA's Online Label Repository. The Online Label Repository conveys that it has not "verified," "checked for conformance," or "approved" the labels and label information available on the site, and acknowledges that the labels on the website may not be the most current. But, unlike the disclaimer on the DSLD site, repository disclaimers do not make any statement to the effect that the labels "may not have met the then current nor meet current" FDA regulations.
"The current disclaimer could confuse consumers by unnecessarily calling into question regulatory compliance of labels included in the DSLD," McGuffin said.
Several DSLD webpages provide images or screenshots of Internet sites on which products were offered for sale or otherwise presented. AHPA recommends the DSLD only display actual product labels and to remove product obtained from other sources.
According to the DSLD homepage the database contains the label content from a sample of "dietary supplement products marketed in the U.S," but AHPA has identified several DSLD-listed products not labeled for marketing in the U.S. To ensure information is not misleading, AHPA recommends the DSLD refrain from listing products not labeled for marketing in the U.S., or make it clear when listed products are not labeled for marketing in the U.S.
Labels submitted by supplement marketers
AHPA believes that a supplement label submitted to the DSLD by the brand owner will necessarily be most accurate and current and recommends that the DSLD include a field to identify the source of the label. AHPA also recommends new fields be created that allows dietary supplement brand owners to provide additional information that is not included on product labels, but may be useful to DSLD's users.