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Dietary supplements: FDA may have opportunities to expand its use

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Appendix I: Objectives, Scope, and<br />

Methodology<br />

In addition, <strong>to</strong> address all of our objectives, we reviewed relevant studies<br />

related <strong>to</strong> dietary <strong>supplements</strong>, adverse event reporting, industry<br />

compliance, and using poison center data for public health surveillance,<br />

among others. We reviewed the methodology for each of these studies<br />

and assessed them for reasonableness in accordance with our<br />

objectives. We also interviewed officials from several <strong>FDA</strong> offices,<br />

including <strong>FDA</strong>’s Center for Food Safety and Applied Nutrition (CFSAN)<br />

who receive and analyze AERs, officials from <strong>FDA</strong>’s Division of <strong>Dietary</strong><br />

Supplements Program, officials from the Office of Regula<strong>to</strong>ry Affairs<br />

familiar with <strong>FDA</strong>’s field operations and regula<strong>to</strong>ry actions related <strong>to</strong><br />

dietary <strong>supplements</strong>, and officials from the Center for Drug Evaluation<br />

and Research. We interviewed a wide range of stakeholders, including<br />

officials from federal agencies, industry and trade organizations, and<br />

consumer advocacy groups. At the federal level outside of <strong>FDA</strong>, we met<br />

with officials from the Department of Health and Human Services’ (HHS)<br />

Centers for Disease Control and Prevention, the National Institutes of<br />

Health, and the Federal Trade Commission. At the industry level, we<br />

spoke with representatives from the American Herbal Products<br />

Association, the Council for Responsible Nutrition, and the Natural<br />

Products Association. At the consumer advocacy level, we met with<br />

representatives from the Center for Science in the Public Interest,<br />

Consumers Union, and Public Citizen. We also spoke with<br />

representatives from the American Association of Poison Control Centers.<br />

We conducted this performance audit from December 2011 <strong>to</strong> March<br />

2013 in accordance with generally accepted government auditing<br />

standards. Those standards require that we plan and perform the audit <strong>to</strong><br />

obtain sufficient, appropriate evidence <strong>to</strong> provide a reasonable basis for<br />

our findings and conclusions based on our audit objectives. We believe<br />

that the evidence obtained provides a reasonable basis for our findings<br />

and conclusions based on our audit objectives.<br />

Page 51<br />

GAO-13-244 <strong>Dietary</strong> Supplements

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