Seal of approval for animal supplements
The NASC seeks to protect and enhance the integrity of the animal health product industry.
In today's crowded and sometimes confusing marketplace, brand recognition is a major marketing advantage. Recognizing a familiar name provides a sense of safety and security—you know the company, its history and products. Many of the brand-name companies we immediately recognize have earned that status by consistently producing good-quality products and standing behind them.
Moreover, consumer organizations such as the Better Business Bureau and Good Housekeeping (with its seal of approval) evolved as means of providing the public with another method of evaluating companies and products with an eye on quality and safety. These organizations have consistently scored brand-name companies highly in their reviews, and, over time, these companies and products have earned our trust and consumer dollars.
The National Animal Supplement Council (NASC) was created because of widespread desire within the supplement industry to produce a safer, more ethical marketplace—similar to what the above-mentioned consumer watchdog groups have done for consumer products. Membership in the NASC and the ability to display the NASC seal on an animal health product requires the manufacturer to sign and adhere to a 13-page formal code-of-conduct contract. Following is a brief history of NASC, why it was established and what it does for both the supplement industry and animal owners.
A need identified
The animal supplement industry is an area that, until relatively recently, had little to no quality control. In the feed or tack store, in catalogs or online, today's horse owners are exposed to marketing messages about a tremendous array of supplement products. The makers of some of these products make all sorts of claims. Moreover, some supplements are made of questionable ingredients and often have no scientific evidence of efficacy or safety. It's often been difficult for owners and their veterinarians to make sense of all of these offerings, and the agencies that typically offer guidelines and standards for such products haven't always been helpful.
Why is there no official regulation of the animal supplement market? Because in 1994 these products fell through a bureaucratic crack. The human supplement market was rapidly growing through the late 1980s and early 1990s, paralleling where the animal supplement market now finds itself. Because of consumer demand and a need for some type of regulation and control of the expanding human supplement sector, the U.S. Congress passed the Dietary Supplement Health Education Act (DSHEA) in 1994.
This legislation created a category of products called dietary supplements as a subset of food and allowed for their labeling and marketing for human use. Because the animal supplement market at that time was small in comparison, there was no provision in the DSHEA to allow products for companion animals to be similarly categorized. The only regulations that applied to animals classified products as either a food or a drug. Indeed, this categorization and distinction continues today.
But animal supplements have remained an emerging group of products that don't really fit into either category. Their current regulation falls to the Food and Drug Administration, Center for Veterinary Medicine (FDA-CVM), which works closely with state and federal agencies and tries to ensure that companies producing animal foods and drugs follow all relevant laws.
As the animal supplement market continued to increase over the years, authorities at the FDA-CVM became concerned that existing regulations were not sufficient or broad-based enough to cover the array of new products and the number of companies producing them. A notice was published by the FDA-CVM in May 2002 stating: "Dietary supplements for animals, such as vitamin and mineral products, have been marketed for many years. Most of these products include ingredients that are approved feed additives, generally recognized as safe substances or ingredients listed in the Official Publication of the Association of American Feed Control Officials.... Many products marked for animals contain ingredients that may be unsafe food additives or unapproved new animal drugs. CVM is concerned about these products, because we do not have scientific data to show they are safe or even contain the ingredients listed on the label."
By the late 1990s, it was clear the problem was coming to a head, and the existing agencies and regulations were not going to be able to safely, effectively and fairly control the animal supplement industry.
Because of the public's increasing demand for animal supplements and the government's inability to find a place to fit these products into current legislation, the NASC came into existence in 2001. The NASC council is a nonprofit trade organization whose board is composed of executives from about 20 companies in the animal health field.
"It's better to help shape your own destiny than to have it defined for you," says William Bookout, NASC president, when explaining the organization's formation. "The individuals who started the council knew the animal supplement industry, understood the challenges facing companies producing these products and wanted to try to produce a more fair and ethical marketplace."
NASC's goals include finding ways to allow responsible companies to provide products to animal owners and to "evaluate, define and implement regulations that are fair, reasonable and nationally consistent."
Kenneth Kopp, DVM, a technical service veterinarian for Arenus, a company that produces animal nutritional supplements and a founding member of the council, notes, "The NASC is not a perfect solution. If the government were regulating the industry, it might not be perfect either. And though we'd love the FDA or USDA to step in and take this over, they're not going to do it. We simply fall into a gray zone."
Bookout says the NASC immediately provided help to consumers at its inception and continues to help by providing a pathway for the introduction of legislation into Congress that eventually will address animal supplements specifically.
As noted, members can display the NASC seal on a product if they adhere to a code-of-conduct contract. These companies must undergo an onsite, independent audit and must maintain strict compliance in areas including labeling claims, adverse product reporting, random product testing, quality control and risk management. NASC guidelines require that compliant companies have product claims related to supporting the normal health, structure and function of the animal only.
Bookout cautions consumers, "If a product [supplement] mentions disease, arthritis, cancer, dermatitis or claims that it will cure or treat a disease, then the company responsible for that product is breaking the law." He also advises horse owners to never buy a product that doesn't contain a lot number on the container. "Without the most basic of information, there's no traceability and no way of judging quality standards," he says, echoing the truism: If it sounds too good to be true, it probably is—and don't buy it.
Adverse-event reporting is a particularly important NASC requirement, so problems with products (e.g., unwanted side effects, reactions) can be tracked and addressed in an open forum that fosters trust and responsibility. Companies are re-audited every two years to maintain membership, and, according to Kopp, "The standards the NASC sets and the auditing and review process are rigorous and costly."
Violators of the code of conduct are subject to fines, and companies are (and have been) expelled from the organization. More than 100 companies producing about 6,000 products currently belong to the NASC, and they represent 90 percent of the animal supplement market, which is heavily weighted toward equine and canine products.
"Arenus is an ethical company trying to do business in an often unethical marketplace," says Kopp. "And we welcome the tough standards set by the NASC as a means of providing better industry standards and more consumer confidence."
Some companies that produce quality equine supplements do not belong to the NASC, however. Many of these companies produce products that either are much closer to foods or to drugs, and they cite the numerous state and federal agencies that already regulate them. Trying to be members in all the various alliances and organizations can be difficult for smaller companies that often have to pick and choose based on the particular products they produce. That these companies are forced into this type of decision-making process is further proof of the need for broader-based, more uniform legislation designed to regulate the animal supplement market.
As the number of animal nutritional and supplement products continues to grow, this need will become even more critical. Until that time, the NASC will serve as an industry watchdog of sorts, and its seal will hopefully provide horse owners with an additional means of evaluating products. "I feel confident that when people see the NASC seal, they can have a good level of trust in the product that carries it," says Kopp.
They can also be assured that companies belonging to the NASC have committed to improving their industry for the good of the consumer, for business (since educated consumers are more likely to select and use better products)—and ultimately for the benefit of animals.
Dr. Marcella is an equine practitioner in Canton, Ga.