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FDA educational content on dietary supplements biased, misses opportunity to promote public health

This is an article I wrote for the CRN Daily Supplement member newsletter, covering a project I led—providing feedback to FDA on its mischaracterization of dietary supplements.

Pushing back on a lack of balance and overemphasis of potential risk, CRN last week wrote to FDA identifying concerns with the agency’s “Supplement Your Knowledge” educational content released earlier this year. In addition, CRN’s comments to FDA addressed the mischaracterization of dietary supplements throughout its website content in general.

CRN’s recommendations, highlighted in a presentation to the association’s board of directors, address ways that FDA’s content:

  • Overstates the potential risks of taking supplements, while downplaying their benefits
  • Fails to convey the robust regulatory framework that gives the agency authority over dietary supplements—downplaying areas of existing authority and drawing attention to ways FDA lacks authority
  • Misses opportunities to address public health issues like nutrition gaps, shortfalls in nutrients of concern, and nutritional needs of specific populations
  • Could be enhanced by collaboration with the dietary supplement industry

CRN’s Communications and Media Outreach Committee received a detailed update on FDA’s campaign following a CRN staff meeting with FDA Office of Dietary Supplements Director Cara Welch, Ph.D., and a team of CRN staff representing regulatory, government relations, and communications perspectives collaborated on the association’s feedback.

“This feedback is just one part of CRN’s long-term, ongoing effort to engage the FDA and be an active participant in the regulatory process. CRN regularly comments to the agency on technical matters in proposed regulations,” said Gretchen Powers, CRN VP, marketing and member experience, who curated CRN’s recommendations, in coverage from Nutrition Insight. “For example, CRN petitioned FDA on NAC (n-acetyl cysteine) and CBD and has commented every step of the way on New Dietary Ingredient (NDI) notifications.”

“Our recent letter on FDA’s communications is unique in that the agency did not publicly solicit the comments,” explained Powers. “CRN and its members found the educational content so problematic, and the process behind its development so non-transparent, that we felt it was our duty to push back.”

“CRN hopes that by sharing this feedback with FDA, we put the agency on notice that dietary supplement stakeholders, such as our responsible member companies, have seen this content and won’t allow negative bias to stand,” said Powers.

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Case studies

Case study: New member welcome

CRN’s onboarding of new member contacts was patchy and the association was not optimizing the opportunity to deepen engagement from the start.

I developed a quick reference—adaptable for email and webleading new members on a simple 5-step pathway through the most impactful ways to make the most of their benefits right away.

Committee, working group, and task force participation has grown substantially so far in 2021, in conjunction with the new member welcome launch—supported by new technical infrastructure in place enabling members to self-select to key groups.



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Case studies

Case study: Promoting a conference with no agenda

A common challenge smaller organizations can face with events marketing is needing to start promotion while concurrently building the agenda and securing speakers. This challenge was exacerbated during the pandemic when speakers and attendees alike were non-committal when it came to the prospect of travel, or weighing the value of virtual conference engagement.

The CRN trade association tapped into its longstanding reputation to entice event registrants in uncertain times and minimize loss.

Amplifying our best member testimonials, we called on others to share and gathered authentic marketing content from more of our satisfied attendees.



We created a marketing video used in emails, social media, and more—and even used excerpted quotes in text treatments to get the most mileage from our testimonials while we developed a full agenda to market.

Eventually the event agenda was secured and the association’s marketing got a second wind. Leveraging CRN events’ reputation for providing value, as shared through trusted industry peer testimonials delivered through the Gather Voices platform, allowed the association to acquire a comfortable baseline of early registrations to help establish momentum.

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Case studies

Case study: Self-service portal and mobile app support increased member engagement

Additional details coming soon!

Learn how a trade association increased member engagement in its committees by empowering contacts to self-select participation in key groups of interest and stay updated and organized via a mobile app.

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Case studies

Case study: ‘Daily Supplement’ newsletter helps association members in their jobs

The CRN Daily Supplement is a newsletter I created for the Council for Responsible Nutrition, a trade association of the dietary supplement and functional food industry, now managed by staff, with my regular contributions.

Identifying a need for a daily touchpoint with our dietary supplement and functional food industry executive members, we leveraged our longstanding biweekly newsletter content pipeline, re-assessed the cadence, and enhanced our editorial standards to deliver quick, easily-digestible, “need-to-know” updates and inspirational insights to support them in their jobs.



We utilized the Axios HQ platform to institutionalize the new data-driven editorial standards adopted and help ensure we stay up to date.

A key vehicle for content marketing to the association’s broadest client base—its existing members—the CRN Daily Supplement includes stories on the association’s opportunities for engagement in its committees, educational offerings via webinars and conferences, and staff expertise.

A quarterly “unlocked” digest made available to non-members through the association’s website and social media promotion extends the Daily Supplement’s value to prospective members as well. The content also comprised sell pieces used in one-on-one connections, as leave-behinds, and more.



The newsletter also provides a platform for spotlighting associate members—such as consultants, law firms, laboratories, third-party certifiers—and contract manufacturers that provide services to the voting categories of members.