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OTCS, Switch, and the Impact of Dietary Supplements

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Abstract

As recently as five years ago, ‘consumer self-care’ was almost exclusively the province of over-the-counter (OTC) medicines. Today, with the advent of the Dietary Supplement Health and Education Act of 1994, dietary supplements provide expanded consumer self-care opportunities. Foods are also claiming health benefits. Sensible health care policy requires that the Food and Drug Administration (FDA) take account of this new self-care product continuum in its prescription (Rx)-to-OTC switch decision making. It is well recognized that consumers want to be and can be educated to care for themselves in a variety of health care situations using foods or dietary supplements. The same principle should be presumed to hold true for an OTC drug in parallel health care situations, where the drug is properly tested and labeled for consumer use through FDA’s comprehensive drug review process.

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References

  1. Final Rule, Requirements for Nutrient Content Claims, Health Claims, and Statements of Nutritional Support for dietary Supplements. 62 Federal Register 49859, at 49860, September 23, 1997.

  2. 63 Federal Register 23624 (1998).

  3. 63 Federal Register 23627 (1998).

  4. 21 U.S.C. § 321 (g)(1).

  5. 51 Federal Register 16258 (1986); 21 CFR § 330.1 (c).

  6. 51 Federal Register 16259 (1986).

  7. 64 Federal Register 13254 (1999).

  8. 63 Federal Register at 23626 (1998).

  9. 21 CFR § 330.10(a)(4)(v).

  10. 21 CFR § 101.75.

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Bachrach, E.E. OTCS, Switch, and the Impact of Dietary Supplements. Ther Innov Regul Sci 33, 805–810 (1999). https://doi.org/10.1177/009286159903300321

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  • DOI: https://doi.org/10.1177/009286159903300321

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