DANA POINT, Oct. 5, 2023 – CRN President & CEO Steve Mister addressed the attendees of CRN’s Now New Next annual conference at the Ritz-Carlton, Laguna Niguel, with his president's address. The following is the complete text of his speech.
Good morning. Welcome back from the break. It’s great to see all the networking going on out there in the lobby during the break.
50 years—wow! What a fitting moment for celebration. I think it’s worth taking a few minutes to honor the legacy of CRN, and examine how we got here.
It’s so good to have you here. All of you, you are CRN. You ought to know where we came from.
Some years ago, on CRN’s 35th anniversary, we asked Dr. Annette Dickinson, who was my predecessor as president of CRN, to document the history of the organization. For those of you who don’t know Annette, she was hired as the first employee of CRN as the Director of Washington Affairs, shortly after the organization was established in 1973. It would take her 27 years to get the title of President, but she broke that glass ceiling and held the role until 2005. She is now retired and living outside Minneapolis and I’m hoping to visit with her when I’m there meeting with Target next week.
So we asked Annette about the origin story of CRN—what happened that led to its creation?
It was in the early 1970s and FDA was trying to over-regulate this fledging market of vitamins, minerals and herbs that consumers were starting to demand. Sound familiar?
In January 1973, FDA published a tentative final rule establishing a Standard of Identity for vitamin and mineral supplements. Anything greater than the Daily Value would be regulated as a drug. The National Nutritional Food Association already existed, as did a health freedom group called the National Health Federation. But three companies decide a new organization was called for. I want to start with a salute to our three founders:
- William T. Thompson, II, of the W.T. Thompson Company;
- George Crawford, of Archon Pure Products Corporation; and
- Nolan Draney, of Plus Products Corporation.
These three gentlemen were the force behind CRN’s creation. And while none of these companies still exists today, many of their products and brands still do, just under different ownership.
But why CRN was created is the more interesting question.
Annette Dickinson writes, “Philosophically, CRN’s goal was to establish a moderate, rational, scientifically-based voice on dietary supplement issues at a time when most of the organizations speaking on the subject tended to be somewhat extreme. Practically, its goal was to bring some high-caliber legal and public relations talent into the effort to counter FDA. ”
In the original Articles of Incorporation, the Council was established to:
- Educate the public about scientific discoveries in human nutrition and the government’s regulation of nutrition practices;
- Inform its members about relevant legislative and administrative developments;
- Provide a forum for its members to examine and review governmental actions;
- Develop legislative and administrative proposals concerning nutritional regulation; and
- Represent the interests of its members on the subject of vitamin and mineral regulations.
Doesn’t sound much different from the critical role we play for the industry today. And it didn’t take long for the association to grow. By 1983, it had 33 Voting members. There are over 120 today.
More remarkable than the objectives are the enduring values that have permeated CRN from the beginning.
In addition to Annette’s history, I’ve also had the opportunity over the past 18 years to participate in 5 separate strategic planning retreats with CRN’s leadership at the time. All of these sessions begin with a similar question: What is it that defines us? And what strikes me is that even though the members of the Executive Committee change over time, the answers are always similar. We are an organization that knows who we are with a strong appreciation for our mission. Here is what our current Executive Committee said this past July about our core values:
- We value an unwavering commitment to science as the basis for decision making
- We recognize that reasonable regulation is necessary to foster consumer confidence and continued industry growth
- Responsible self-regulation is preferable to government involvement and necessary to demonstrate a mature industry
- Integrity must underly all we do—both as an industry and as an association
- Our passion for wellness guides us—we are committed to better nutrition and health for all.
These five principles haven’t really changed for 5 decades.
Maybe that’s why, for the past 50 years, CRN has been at the forefront of every issue impacting the industry. Just consider some of these accomplishments in the first 20 years:
- CRN was a leader in enacting the Proxmire amendment in 1976 that put an end to FDA’s Rulemaking and set into law the requirement that vitamins could be sold at any dosage that was demonstrated to be safe.
- In the late 1970s, the Federal Trade Commission proposed a rule that protein products would have to include a label telling people there was no need for such products. It was withdrawn, thanks in part, to CRN.
- Long before Vitamin Angels came on the scene, in the 1970s, CRN donated one million capsules of vitamin A to an international blindness prevention program.
- When the Consumer Product Safety Commission began to require virtually all iron-containing products to be packaged with child-resistant closures, CRN encouraged dietary supplements manufacturers to comply with those requirements, as a matter of good product stewardship. Because of widespread voluntary compliance, FDA did not find it necessary to issue a separate rule specifically covering dietary supplements.
- By the early ‘80s, CRN adopted a voluntary dosage limit for Vitamin A. So several years later, when California required a Prop 65 warning for dosages above 10,000 International Units —our members’ products were already within that limit. Soon CRN adopted voluntary dosage limits for other vitamins. And eventually CRN would issue the Vitamin & Mineral Safety manual with voluntary upper levels for most all essential nutrients.
- By 1985, the association had developed a Code of Ethics for members laying out expectations for fair trade practices, truthful labeling and advertising, and serving consumer needs for safe and beneficial dietary supplements.
- In 1988, U S Pharmacopeia established an expert committee with a mandate to establish quality monographs for dietary supplement ingredients and products. CRN brought its members to the table, and that paved the way for five separate expert committees today that deal with dietary supplement matters today, along with Monographs and the General Chapters applicable to our products.
- But there was tragedy for the industry too. In late 1989, there was an outbreak of eosinophilia myalgia syndrome related to the consumption of L-tryptophan. Before it was over, the CDC identified over 1,500 cases internationally, including numerous deaths. CRN supported a nationwide recall of the product and offered assistance in tracing so-called “hot lots.” Our members helped fund a consumer hotline and case registry and participated in scientific conferences convened on an emergency basis to probe the cause of the syndrome.
- On a more positive note, the Public Health Service issued an advisory in 1992 encouraging women of childbearing age to obtain 400 mcg of folic acid daily to reduce their risk of having a baby with a neural tube birth defects. CRN participated in workshops sponsored by CDC to prepare for this policy statement and actively encouraged FDA to follow suit by approving a health claim for folic acid. It would take FDA another 4 years, to issue final rules and to require enrichment of grain products with folic acid. But CRN kept the pressure on the agency throughout.
So CRN had already been protecting the industry for 20 years before DSHEA.
And then came the multi-year effort — and massive grassroots and lobbying initiative—to revise the Food Drug & Cosmetic Act and recognize dietary supplements as a unique category.
As Annette recalls the events, in the final midnight hours of tough negotiations among key staffers in the House, CRN’s legal counsel Daniel Marcus, was the only industry representative allowed by the Congressional staff to participate directly in the process.
In that negotiation, Congressman Waxman insisted on the now-ubiquitous “disclaimer” that appears on dietary supplement labels bearing structure/function claims. The next day, CRN’s Board of Directors came within a hair of deciding to oppose the bill with these amendments, but Marcus persuaded them there was no other option, unless they were prepared to give up the legislation altogether. And so on October 25, 1994, President Clinton signed DSHEA into law.
But the work of CRN was just getting started.
As the industry took off, so did CRN’s role in shaping it:
- CRN soon developed a list of grandfathered ingredients to memorialize what was in the market when the law was enacted.
- CRN began pushing for Good Manufacturing practices regulations as called for by the statute. In 2004, the draft regulations were published based largely on the CRN proposal. They were not finalized until 2007 and became fully effective in 2010, fully 16 years after the law passed.
- CRN also took note in the 1990s of negative statements about dietary supplements that appeared in various editions of the Dietary Guidelines for Americans. CRN repeatedly objected to these statements and periodically met with USDA and HHS officials to explore alternatives. By 2005, with much urging from CRN, the Guidelines identified several nutrient shortfalls that exist in the U.S. population and recognized that some people may benefit from some nutritional supplements. With each iteration, we get more acknowledgement of the role supplements can play for special populations, even if they don’t yet recommend our products for all Americans.
- In 2008, CRN created an Advertising Review Program with the Council of Better Business Bureaus that has become a model other industries have followed.
- From 2008 to 2013 CRN managed Life Supplemented reaching tens of millions of consumers. Other organizations tried, but CRN’s campaign worked with a simple message: Your pursuit of a healthy lifestyle includes diet, exercise and supplements—be proud of the supplements you take. Backed by a series of healthcare practitioner surveys, the campaign had another message too: your doctor is probably using dietary supplements, and you should too.
- Since 2000, CRN has successfully supported passage of the Anabolic Steroid Control Act, the Designer Anabolic Steroid Control Act, and the Adverse Event reporting law. I remember when the AER law was enacted in the wee hours of the morning in December 2006, as the next to the final vote of the 108th Congress, CRN’s lobbyists were the only industry voice in the Capitol still whipping the votes.
- Then in 2015, New York Attorney General and the front-page New York Times article used faulty DNA testing to allege that the majority of herbal supplements were fraudulent. It was the closest to an existential crisis that I can remember. Again, CRN turned to our credibility as a truth-telling, science-backed voice to counter the message and fight back. We were relentless in our defense of an industry unfairly maligned.
- We also launched a healthcare cost savings study that year that documented the cost saving impact of various supplement regimens can have to reduce healthcare costs. Not only was the original study well-received and cited in this country, but it has become a template for other countries with at least 8 other national trade associations replicating our model to demonstrate savings in other countries too. And or course we just updated that study last year.
It hard to think of a significant industry event, a significant stakeholder organization, a significant change in public policy, that CRN has not been engaged with under the same mantra: sound science, reasonable regulation and industry responsibility.
You know there was a lot of talk in Washington over the past week about who is essential. You see, when the federal government is facing a potential shutdown, most federal employees get furloughed but the ones that are deemed essential—like air traffic controllers and border security agents—they stay on the job. So everyone asks, am I essential?
As I think about this list of accomplishments, it’s clear to me that CRN is essential. What would this industry be like without CRN? Our board said as much in a discussion last year of the future of the trade associations, after extensive discussion, one member stated bluntly that if CRN didn’t exist, companies would have to create it all over again. And there was complete agreement.
So let’s spend the remainder of my time looking forward: what does the future hold? What’s ahead for us? Two items on that agenda are updating the law and broadening access to our products.
There’s a lot of discussion these days about DSHEA reform.
But here’s the thing: Fundamentally, as Maren Morris sings, the bones are good. DSHEA struck a balance between assuring consumers that they will have access to a wide range of health-supporting products and establishing some minimal guardrails to provide them safe, quality products. And this must be preserved.
But like any law that is approaching 30 years old, it needs some sprucing up. What does the industry need to continue its growth and keep building consumer trust? Through our committees, our staff and our board members, and working with the other industry organizations and stakeholders, we are developing the opening proposition for the next iteration of DSHEA.
But a caution too: be careful what you wish for. Wild demands for changes that would fundamentally change the balance would be dead on arrival. Or worse, they would be met with demand for changes from our critics too, leading to an ugly game of tradeoffs), leave the industry worse off, and set back our efforts. A successful maneuver of the politics and the policy will mean the industry must come together, just as it did during the passage of DSHEA. And we must demonstrate the strength of this industry as we have done in the past.
The preparations for this legislative initiative are one of the reasons we are embarking on a new study to document the economic footprint of the industry. We are documenting our economic impact as a way to increase our political impact. We did this about 10 years ago and it has been immensely helpful…to be able to tell a Member of Congress how many jobs we support in her District, or a state legislator how much the supplement industry contributes to the tax base in that state. Please be sure to look for these emails from our government relations team and to respond quickly and thoroughly to their requests.
And finally, I want to pick up on one of the themes of Tara’s speech—our focus on increasing access.
We must give more than lip service to this desire to improve health and nutrition for those who need it most.
Many of the specific ways to do this involve changes in policy: inclusion of supplements in FSAs and HSAs, getting Congress to include multivitamins in SNAP coverage, persuading policymakers to add vitamins to supplements in Meals on Wheels or school breakfast programs. These conversation are already happening but policy shifts like this take years.
There is much we can do in the meantime to provide our products to the people who need them most and can least afford them. CRN’s access initiatives, as Tara laid out, will help us demonstrate the health benefits to our critics and get better nutrition to critical communities. I want to urge every CRN member to internalize this mission in your own company and to be enthusiastic supporters and generous givers when we ask—and we will ask. Work with us to make greater access to nutrition and healthier lifestyles a reality.
But is all starts with belonging to CRN.
Today there is more pressure than ever on firms to deliver profit in the next quarter. Pressure to let someone else pay the bills. Pressure to be a free rider.
If we believe CRN is charting the right course, then every one of us has an opportunity to grow our ranks by encouraging your vendors, your customers, your competitors to join CRN.
What if everyone joined a trade association to do their part in creating a desired future?
What if everyone selected that trade association based on what it’s delivering for the industry?
What if we joined an association based on the values it espouses and lives each day?
The one with a clear vision of the future we want to create?
What if we supported the organization that the industry just couldn’t do without?
And just think of how much more we could accomplish as an industry if we spoke with one voice grounded in those CRN values. Yes, it’s an investment for the long haul—but we are also investing for the next crisis that could happen tomorrow.
As I said earlier—you are CRN: companies and individuals committed to your consumer and to putting the best products possible into the market.
You are passionate about self empowerment, about prevention over treatment, about healthier lifespans over late-stage intervention, about changing the fundamental assumptions of healthcare. These things have driven CRN for 50 years and they drive us today.
And I think those are some pretty good reasons to celebrate!