August 31, 2022
We are writing to express our views on the Office of Dietary Supplements (ODS) proposed draft of their Strategic Plan for next five years (2022-2026) regarding research and innovation.
The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
NCHR supports the efforts to improve research in the ODS proposed strategic plan. Research on dietary supplements is needed so that patients are able to make informed decisions about their safety and effectiveness. We especially support the proposed research and initiatives to reduce disparities and to disseminate information about the research results. Partnering with minority-serving organizations and institutions throughout the research process is vital.
While we support the plan in general, we strongly recommend several major revisions, primarily focusing on the “Addressing Health Disparities and Advancing Health Equity” section. While there are overarching goals in place, the proposed plan lacks specific, measurable milestones and a defined timeframe for each of these goals and subgoals. For example, ODS should explicitly explain how it plans to achieve continuing “to offer opportunities for academic faculty members to work at ODS during their sabbaticals,” with clear targets showing whether that goal is achieved. The research goals and achievements need to be explicit and made available to the public. In addition, given the increase in the sale of dietary supplements during the pandemic, we agree with the December 2021 recommendation of the Center for Science in the Public Interest (CSPI) that there should be more emphasis on examining how the promotion of these dietary supplements and their sales affect COVID-19 (1) and the health of the public during the pandemic.
In the “Addressing Health Disparities and Advancing Health Equity” section, ODS states the need for “training, career development, or funding junior and mid-level scientists…”, which we support, but we also recommend that ODS provides these opportunities for senior-level scientists. In addition, ODS should require that researchers and manufacturers perform studies in an ethical manner that includes and respects minority communities, possibly incorporating community consultants in their process. As is well-documented, there is sometimes mistrust and reluctance to participate in research in some communities (3). These concerns must be addressed in order to collect accurate data that appropriately represents members of these groups
References:
- Lurie P & Jose J. Comments of Center for Science in the Public Interest on Office of Dietary Supplements’ Strategic Plan. 2021
- Crawford C et al. Analysis of Select Dietary Supplement Products Marketed to Support or Boost the Immune System. JAMA Network Open. 2022; 5(8):e2226040. doi:10.1001/jamanetworkopen.2022.26040
- Scharff DP, et al. More than Tuskegee: Understanding Mistrust about Research Participation. Journal of Health Care for the Poor and Underserved. 2015; 21(3): 879-897. doi: 1353/hpu.0.0323