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NPA Files Comments,
Calls for Rewrite of NDI Draft Guidance
NPA members
can call in during upcoming "Ask the ED" for more information
Dear Natural Products Association
Members:
As we promised earlier, the
NPA submitted comments today to the Food and Drug Administration (FDA)
on its New Dietary Ingredient (NDI) draft guidance. You
can read our comments here.
We
identify serious problems with the draft, including a number of provisions
that significantly overstep the authority granted by Congress in the Dietary
Supplement Health and Education Act (DSHEA). As a result, we call on the
FDA to substantially rewrite the guidance and, in the meantime,
refrain from making enforcement decisions based on the draft.
The industry needs clarity
for the rules governing the NDI process, but those rules must be consistent
with DSHEA. Our comments provide the FDA with the information necessary
to achieve that goal, and NPA stands ready to work with FDA on this important
task. We will seek a meeting with the agency to discuss our comments.
Dr. Cara Welch, NPA's vice
president of scientific and regulatory affairs, led the drafting of these
comments. She worked with the NPA ComPLI Committee and our counsel, Scott
Bass of Sidley Austin, LLP, and included input from numerous NPA members.
Thanks to all for their hard work in creating such a strong document.
In addition to working with
NPA members, we collaborated with the other trade associations representing
the supplement industry. As a result, the comments we all submit will demonstrate
industry unity on the key issues.
We will soon meet with our
Congressional champions to review our comments and discuss next steps.
Appropriate NDI guidance
is needed to provide our industry with clarity and certainty. The industry
cannot accept, however, the draft guidance as it is written, and NPA will
continue to lead the fight for the necessary changes.
Additionally, to provide
a more thorough understanding of this comment document, NPA will hold "Ask
the ED" sessions for both suppliers and retailers, on Wednesday, December
7.
Call in to "Ask the ED"
- NDI Comments Information for Suppliers
Wednesday, December 7
3-3:30 p.m. ET
Call in to "Ask the ED"
- NDI Comments Information for Retailers
Wednesday, December 7
4-4:30 p.m. ET
To register: Email
your name, company name and number of participants at your site to natural@npainfo.org.
Registrants will be sent the dial-in information the Monday before the
event. Registration is free, though restricted to the first 25 sites that
register for each call.
After presenting a brief
overview, Dr. Welch and I will take questions about the NDI draft guidance
comments.
We will keep you informed
on the next phase of this issue.
Sincerely,
John Gay, CAE
Executive Director and CEO
NPA
East's President's Letter:
By John Garvey
Once
again, I'm proud to be a part of what I believe is the most effective regional
volunteer organization supporting the natural products industry.
Having worked both sides of the business, on the supply side and most recently
as a retailer, I have the honor to lead a group of volunteers who work
tirelessly on your behalf.
The most important contribution
NPA East makes is protecting you from potential legislative actions by
state houses that, had they become laws, would have had dire consequences
for all retailers throughout our region. From forcing manufacturers
and suppliers in New York to re-label all supplements sold in the state
to the creation of the state's own supplement regulatory agency, the results
had the potential to be devastating to our ability to do business. (Please
read
the Advocacy Update column in this issue for more details.)
Fortunately, NPA East's Advocacy
Committee managed to stop all five of these bills from reaching a vote
in the legislature. Thanks to their efforts, we can all breathe a
little more easily for the moment. Unfortunately, when the legislatures
meet again in a few months, all five bills could be resurrected again.
So far, we've held them off for five years! That's why constant diligence
is always required, and your support is always necessary to help ensure
these bills never become laws we are forced live with on a daily basis.
This is an expensive, time-consuming,
and ongoing process. It never really stops. With one paid staffer
and a handful of volunteers, we can't always do it alone. Please
consider joining our fight against restrictive legislation by volunteering
your help and continuing to support our cause with your dues dollars and
financial contributions to our advocacy efforts.
For more information on how
you can help, please contact NPA East's Executive Director, Paul Kushner,
at 856-985-5446, or contact Paul by email at pkushner@comcast.org.
You can also sign up to help on our website: www.npaeast.org.
I look forward to another
great year helping to support and protect natural products retailers within
our region and the businesses that support them.
P.S. Please join us
at Expo East for NPA East's annual member meeting on Thursday, September
22nd, in Baltimore. To register and for more information, please
go to www.expoeast.com.
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NPA
East Welcomes New Board Members:
Theresa Bessette
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Erika Dworkin
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NPA
EAST WELCOMES TWO MORE NEW BOARD MEMBERS
We
are proud to announce the addition of two additional members to the
NPA East's Board of Directors. Erika Dworkin is a principal at her family
business, Manchester Parkade Health Shoppe in Manchester, Connecticut.
As a former litigator, Erika is an excellent and welcome addition to NPA
East's Advocacy efforts, the single most valuable service we provide to
our membership. As the future owner of a 55 year-old health food store,
Erika has an intimate knowledge of our industry and an enormous passion
for protecting free and safe access to nutritional supplements and other
natural products. As a member of the NPA East Board of Directors, she looks
forward to working with like-minded individuals to make a positive difference
for our industry.
Theresa
Bessette is currently the supplement and HABA buyer for Fiddleheads Natural
Food Cooperative in Westerly, Rhode Island. She holds an undergraduate
degree in nutritional biochemistry and a graduate degree in public health.
Prior to joining Fiddleheads, Theresa spent 25 years working in the health
care industry as a clinical laboratory scientist, owner of a health food
store, buyer for a retail pharmacy chain, and as a nutritional consultant.
As a member of the NPA East Board of Directors, Theresa's goal is to put
her skills, knowledge, and experience to work to support and promote the
natural products industry in a responsible and credible manner.
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NPA
East Retailer Spotlight:
Q&A Retail
Spotlight: Erika Dworkin
By Paul Kushner
Executive Director, NPA
East
Erika
is a principal at Manchester Parkade Health Shoppe, a 55 year-old family
owned business located in Manchester, Connecticut. As the future
owner of her store, Erika has intimate knowledge of our industry and an
enormous passion for protecting free and safe access to nutritional supplements
and other natural products.
Q: You're licensed
to practice law in Connecticut, New York, and Washington, DC. What
got you interested in natural products?
A. I started chewing liver
pills for my immunity when I was four, and I literally grew up in my family's
health food store. I have used natural products to live a healthy
lifestyle, because I was taught that aging does not have to cause
pain and suffering. I always wanted to grow older gracefully, to
feel 30 when I'm 40, 40 when I'm 50, and so forth. I have resolved
various health problems over the years with diet, nutritional supplements,
lifestyle modifications, and spiritual/energy work. Prescription
medications have generally only exacerbated my health conditions.
Q: How long have
you been working at Manchester Parkade Health Shoppe?
A. I worked in our family's
stores, both our drug store and health food store, throughout high school.
After college and law school, I lived in New York City and Washington,
DC, for 21 years. I returned to Connecticut to work with my father
in September 2009.
Q: What are the
challenges of working in a well-established family business?
A. I came with my own vision
for our future. I have a passion for reaching as many people as possible
to help them optimize their health. But what they say is true; don't
try to fix what isn't broken. I have needed to be careful to freshen,
rather than tarnish, my father's masterpiece with my branding and marketing
efforts. Part of our charm is our old- fashioned, intensively service-oriented
approach to our customers. So meshing old fashioned ways with cutting edge
technology in the marketing and operations areas has been one of the biggest
challenges.
Q. Tell me about
your store and your product mix: how much is supplements, how much is food.
Which is your primary focus and why?
A. As nutrition experts,
we primarily focus on helping each customer achieve his or her optimal
level of wellness through the appropriate selection of vitamins, herbs,
cutting-edge nutraceuticals, homeopathic remedies, and sports nutrition
supplements. We also offer books to enable our customers to empower
themselves by providing them with knowledge of their bodies, health conditions,
and the nutrients that may help them., We offer our customers a wide selection
of food, including macrobiotic, frozen, and refrigerated items. We
focus on carrying unique and hard-to-find products. Our customers
relish our knowledge of the large array of gluten-free dairy, nuts, yeast,
and soy.
Our body care consultant
does a fabulous job stocking our store with a wide variety of the best
natural body care products in the industry. She aims to carry items
not readily available from our local competitors, including those that
are gluten, cruelty, and chemical-free.
Q. Do you have a
formal business plan or an informal one, and can you share the key elements
that have helped drive your success?
What drives our success
is the following:
1. Intensive
customer care. Our staff members, most of whom have been with us for
many years, listen, devote ample time, and always try to find answers
to customers' questions
2. Great reputation.
We have a reputation for being trustworthy, knowledgeable nutrition experts
with unquestioned integrity and competitive prices.
3. Convenience.
Our location provides ample parking and easy in-and-out shopping
4. My father's credentials.
Michael Dworkin has a Master's Degree in Clinical Nutrition and a Doctorate
in Pharmacy, and a wonderful reputation as a healer.
5. Local Support.
Our customers support us because we show personal concern and have a stake
in their well-being, attributes that you just don't find in a large, corporate
store.
Q. We've recently gone
through, some would say we're still going through, the worst downturn since
the Great Depression. How did you weather it, and what steps are
you taking to ensure you'll get through?
A. First and foremost, we
haven't devoted energy to worrying about it. Instead, we do what
we have always done in the face of potential adversity: we press on and
keep improving our formula for success:
-
Education. We write monthly
articles, lecture at colleges and in public forums. We also reach
consumers through our website www.cthealthshop.com,
and social media (Twitter, Face book, Linked-In, Yelp, and Google.
-
Advertising. We look for strategic,
affordable publications, like a free magazine focused on alternative health.
-
My Store My Flyer. This
is a customized flyer from Tree of Life that helps us polish our image
and provides customers with discounts on items they frequently buy.
-
Participation in health fairs.
We donate to community auctions for fund raising efforts.
-
Networking. Nothing works better
than giving the community an opportunity to know me personally and to learn,
first hand, what our store offers the community.
-
Attention to customers. We maintain
a high level of customer care, solving individual problems through research,
special orders, and access to my father.
-
Pricing: We pass along
discounts from manufacturers and suppliers whenever possible.
Q. Many independent
retailers say that the key to success is finding good employees and holding
on to them once they've been trained. What kind of environment do
you foster at your store to keep employees happy and productive?
A. Absolutely.
Our employees are a critical part of our success. Our full-time
employees have been with us for as long as25 years, and they are part of
our family. We strive to meet all of our employees' financial
needs and try to make them feel appreciated. We recognize special
efforts beyond the call of duty and celebrate their life milestones.
We are flexible where needed and strive to give each employee the leeway
to do his or her work in a way the employee determines is most productive.
Q. Thinking ahead,
what will independent retailers need to do in the next five to ten years
to continue to survive and prosper?
A. When the going gets tough,
they will need to do more strategic marketing that clearly communicates
their brand, especially virtual marketing and participation in social media.
-
Make sure they hang on to their
key employees by treating them well and educating them through manufacturer
presentations and other affordable means
>Determine what they can give
their customers that their competitors don't or can't, and make sure they
provide those services
>Learn what their competitors
are doing that may be helping them succeed and match (or better, beat!)
them at their own game.Q: What advice would you give someone thinking
about opening up a natural products retail store?
This is a loaded question
since I did this in 1994 and ran my business (Naturally Yours Foods &
Vitamins) in Nanuet, NY, for 2 years. At that point, Robert Haft
recruited me to build Vitamins.com in the Washington, DC, metropolitan
area from the ground up (a 10-store vitamin chain that was sold for 103.5M
to HealthCentral after only 4 years) with a laptop and cubicle. I
could probably write an entire book on this topic, but I'll try to be brief:
1) Do a tremendous
amount of research on the desired location (e.g., traffic, local competition,
demographics, geographic reach, parking needs/availability)
2) Research your competitors
extensively and develop your unique selling proposition BEFORE YOU OPEN!
Make sure you really know retail and are up for multi-tasking, being the
chief cook and bottle washer; be prepared to work non-stop for the first
2-3 years
3) Work with the distributors,
brokers & mfrs to get their help, guidance, and support, both financial
and otherwise
4) Even if you don't need
financing, develop and follow business and marketing plans... hit the ground
running by shouting to your community that you're there... research free
marketing opportunities
5) Study Danny Wells' approach
to retailing
6) Cherry-pick your employees
and do what's needed to keep them >> think about the community you will
be serving and strive for staff diversity
7) Really study the products
that will be your focus... knowledge is key in our industry
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NPA East Increases
Membership
Your membership counts
- and we are counting every one! In 2009, membership in NPA East
grew 20% and, the good news is, 2010 is even topping those numbers.
Current Members Are the
Best Endorsement
While we continue to reach
out to potential members throughout the year, the most effective way to
recruit is through our existing members. We believe we have a proven
that we provide value to our members - - strong advocacy -- your personal
endorsement sends an even stronger message to independent retailers about
the benefits of joining and participating in the only regional organization
dedicated exclusively to the growth and continued success of natural products
retailers and the companies that support them. Our organization is
there for YOU, and our members are there for EACH OTHER.
Advocate At Expo East
Expo East is the perfect
venue to talk to your colleagues about the importance of supporting your
Association. While in Boston, please take a few minutes to encourage
fellow retailers, suppliers, manufacturers, and brokers who work in our
region to join with you to protect our rights to do business. We
are proud of the work we've done to advocate for you throughout the year.
With the support of our members, we have been able to stop potentially
damaging bills that would have severely hurt your ability to compete as
independent retailers. We need more strong voices advocating for
our industry. Please consider joining the fight by helping us keep
track of the hundreds of bills that come up each year that have the potential
to hurt us. It will take very little of your time but it can make
an enormous difference in our effectiveness.
Attend the Annual Meeting
And make sure to attend
our Annual Meeting at Expo East on Thursday, October 14th from 4:00
- 5:00pm. Click here for
more details.
Every time a new member joins NPA East,
our voice gets stronger and our ability to influence legislation both locally
and nationally grows exponentially.
For more information on how
you can help us protect your business, please contact NPA East Executive
Director, Paul Kushner at 856-985-5446. E-mail: info@npaeast.org.
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| We
Keep Your Doors Open. Our Mission: to preserve access to, and facilitate
markets for natural products. For more information and to join NPA East,
please contact the executive director. |
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©
2011 Natural Products Association East
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