As president of NASC I am very familiar with this issue and the committee examining the safety of garlic, lutein, and evening primrose oil. While I was not a member of the committee, I was asked to make presentations to the committee and submit information regarding the objectives commissioned by CVM. While I believe that certain conclusions of the committee are technically correct with respect to safety under the current system of evaluation and approval for feed ingredients, horse owners should realize this is a complex issue and the oversimplification in your recent article may cause undue and unfair concern. Readers may have the impression that there is no effort by the industry to monitor product quality, safety, and risk, which is not true.

The NASC was established in 2002 because current laws were developed prior to the widespread use of animal supplements. There is agreement by most stakeholders that applying drug laws or feed laws under existing regulations to animal supplements simply does not work (human supplements faced this same issue until Congress created a specific category under the law in 1994). NASC's mission is to work constructively and cooperatively with state and federal regulatory agencies to ensure that animal owners maintain continued access to these important products, while creating rigorous systems to ensure quality and risk management.

Helping to ensure, manage, and effectively monitor risk of use for products and ingredients is one of NASC's primary objectives. In 2003 NASC established an adverse event reporting system (AERS, which is available to FDA-CVM) that has worked effectively when issues have arisen. When melamine contamination was discovered in pet food, NASC proactively searched the entire database of products on the market that contained grain-based protein sources and was able to alert both companies with potentially affected products and FDA as to its findings (there were no instances where supplements contained melamine).

NASC continuously tracks over 6,000 products containing some 850 ingredients for adverse events that might indicate a safety issue. Over 100 companies belong to NASC (about half supply equine supplements and half canine), representing over 90% of the industry. Our database of product usage contains over 14 billion bits of data through which we help monitor the safe use of the products our members provide. Further, we have introduced the NASC Seal as an indicator to consumers that products bearing the seal are being monitored through this system. This level of oversight far exceeds that of human supplements.

Additionally, we have accomplished the following to help ensure that the animal supplement industry is conducting itself responsibly and pursuing objectives that are in the best interests of all stakeholders:

  1. Established the AERS to continuously track, trend, and assess AERs associated with either products or ingredients (August 2003);
  2. Established current good manufacturing practices (cGMPs) for our industry in July 2004, with several major revisions and improvements since then;
  3. Established product labeling guidelines;
  4. Established a scientific advisory committee, providing independent oversight for ingredients;
  5. This committee submitted risk stratification recommendations to FDA-CVM for all ingredients in our members' products. Over 850 ingredients were reviewed; and
  6. Established an independent quality audit program to verify implementation by member companies.

While this isn't a comprehensive list, it highlights a few of our accomplishments. When the recalls affected pet food in 2007 NASC received high praise for the AERS.

While the conclusions of the National Institutes of Health (the FDA-CVM research group operated under this agency) may be accurate on a very broad application, I feel it unfairly represents the conduct of the majority of the equine industry and what has been done to ensure horse owners receive products from companies they can have confidence in. Further information regarding our organization and members can be found at

The Committee on Examining the Safety of Dietary Supplements for Horses, Dogs, and Cats, sponsored by the Center for Veterinary Medicine (CVM) of the Food and Drug Administration (FDA), addressed a perceived need for a comprehensive, publicly available adverse event reporting system for supplements. To address this issue it created an eight-member committee to examine published scientific reports, evaluating whether feeding lutein, evening primrose oil, or garlic to horses, dogs, or cats was associated with significant adverse health effects (see article #12679 on Bill Bookout, president of the National Animal Supplement Council (NASC), comments.

About the Author

Bill Bookout

Bill Bookout is president of the National Animal Supplement Council.

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