1. Are there arguments for regulating speech about drugs more comprehensively than, for example, about dietary supplements? What must an administrative record contain to sustain such a position? In particular, could FDA sustain a position that certain promotional speech about drugs is inherently misleading, unless it complies with FDA requirements? Does anything turn on whether the speech is made to learned intermediaries or to consumers? What is the evidentiary basis of such a distinction?
I believe that the restrictions concerning statements that there are definite health benefits from certain scientifically proven glyconutritional and phytonutritional products, should be lifted. FDA should allow the proven health benefits of these products to be advertised as such for the promotion of better health. Do not negate the benefits of the DSHEA act.