Keeping Up with Agency Regulations

November Vitamin Consultancy eNewsletter
Keeping Up with Changing Regulations

http://systemsprocessingintegration.com

[1] FDA on "Natural"

https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/LabelingNutrition/ucm456090.htm

"Although the FDA has not engaged in rulemaking to establish a formal definition for the term "natural," we do have a longstanding policy concerning the use of "natural" in human food labeling. The FDA has considered the term "natural" to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food. However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation. The FDA also did not consider whether the term "natural" should describe any nutritional or other health benefit."

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[2] FDA GMPs -- TEN YEARS OLD

The Natural Products Association is engaging in a tenth year review of the FDA dietary supplement GMPs.  Some valuable information is being developed.  One bottom-line point:  there is a new FDA emphasis on adequate Quality Assurance, which means specific staff members tasked with that role.  QA must sign off on all product batches and the person signing off must not be the person overseeing the production.  This applies to both manufacturers and to the label-owner who is expected to "be in a state of control."

For example, a recent warning letter to a label owner which was sent to me for review cited two violations of QA

"1. Your quality control operations did not include determining whether each finished batch conforms to established product specifications.

2. Your quality control operations did not include approving and releasing, or rejecting, each finished batch for distribution."

Remember, these points were raised directly with the label-owner, not the manufacturer.  Bottom line:  Do you have Product Specifications? Do you have a person responsible for QA?  Is QA included in your SOPs.

My retainer clients are compliant. Are you?  www.SystemsProcessingIntegration.com

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[3] FDA Mandatory Food Recall Authority

November 5, 2018 - The U.S. Food and Drug Administration has released a final guidance regarding the agency’s mandatory recall authority under the FDA Food Safety Modernization Act (FSMA).

"The 2011 food safety law gave FDA mandatory recall authority for foods if there is a reasonable probability that the food is adulterated or misbranded under certain FDA authorities, and that the food could cause serious illnesses or death. FDA must give the responsible party an opportunity to conduct a voluntary recall before ordering a mandatory recall. Prior to the enactment of FSMA, FDA could only rely on manufacturers to voluntarily recall certain potentially harmful food products.

https://www.federalregister.gov/documents/2018/11/06/2018-24247/guidance-questions-and-answers-regarding-mandatory-food-recalls

Comment: you may recall that Dr. Laibow and I fought hard in 2010 and 2011 to preserve Section 1011 of the food "safety" bill, a section that exempted DSHEA dietary supplements from the "enhanced" authority of the law.  We were denigrated when we worked through one late-nights weekend to get over 150,000 emails to the congressional conference committee, assuring that the exemption clause would stay in the law.  Now we see the results:  "mandatory" recalls based on mere "reasonable probability..." will become the norm for most foods, but not for DSHEA products!

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[4] TWO IMPORTANT STORIES YOU WON'T SEE ANYWHERE ELSE!

[1] What Happened to that Sore on My Chest?

I love to tell my list about success stories in the natural products market.  Dr. Walter Wolf is one of those geniuses that I've had the privilege to know.  He is an alchemist and naturopath.  His new product, Divine Wellness, is amazing!

Ethically harvested ovine placenta, CBD hemp oil and Nano Gold.  This is an immune boosting rejuvinater nutrient combination.

But I want to tell you about an "off label" use of the product.  A few months ago I noticed a "beauty mark" on my chest had begun to enlarge and become lesion-like. That was concerning so I started putting a varying combination of CBD hemp oil, apricot seed extract, tea tree oil and nano silver on it.  The growth stopped, but it remained.  Then, a few days ago, I begin putting Divine Wellness on the spot.

As the series of images show, it quickly puffed-up, became quite dark, and is now flaking-off.

Amazing!  Learn more about this natural product as a dietary supplement here:  https://www.divinewellnessclub.com/idevaffiliate/idevaffiliate.php?id=103  -- yes, you can join the affiliate program.

[2] Horizon v Jonuzi et al. This may be the most important lawsuit pending in the USA regarding Insurance Industry reimbursement for holistic and integrative treatments and therapies... including dietary supplements as Medical Foods.  This pending litigation can construe the Affordable Care Act to forbid insurance carrier discrimination against holistic and integrative practitioners, permitting proper insurance coding for such therapies.

From the standpoint of the Mission of the Institute, this change would facilitate retrospective research into holistic and integrative modalities (through coding statistics). That's why I've helped to set up a crowdfunding effort.

Read more here: http://www.inhere.org/2018/11/06/making-health-insurers-follow-the-rules/

Please read about it, and help our crowdfunding effort.  This case is quite important! 

Donate here:  https://fundly.com/support-natural-therapies

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And while you are at it... remember the Institute is now sponsoring a holistic and integrative IRB program for all you researchers.  http://www.inhere.org/institutional-review-board/

My experience will strengthen your company!  I provide private and confidential, competent electronic professional consulting to my Dietary Supplement and advanced healthcare ("CAM") modality clients, for the purpose of compliance with International, State and Federal (including FTC and FDA) standards for communicating about the advertising and sale of dietary supplements (including medical foods) and/or providing of health care services and information. You should consider my SOP / cGMP Certification Course, allowing start-up and established vitamin companies and practitioners who own their own private labeled products to meet with new FDA procedural regulations.

TIME RAN OUT

If you think you have enough time to get ready for California's new, tougher, Proposition 65 warning rules, you are wrong. The new rules 2 months ago. If you think your product does not get into California, think again. If you think no one will notice, remember that Prop 65 is enforced by a hoard of private lawyers looking to grab fees and penalties from your company.

More information on how Dr. Goodman and I can help:  www.ProfessionalSafetyDossier.com

Here is my article about all this, posted at Open Source Truth: http://www.opensourcetruth.com/proposition-65-california-ratchets-up-cancer-repro-harm-warning-rules/

May 2018 eNewsletter: What We Can Learn from FDA Court Order

WHAT WE CAN LEARN
FROM FDA COURT ORDER

What Companies Can Learn From the Riddhi Vitamins' Cease and Desist Order*

Riddhi USA is a wholesale dietary supplement manufacturing company.  It manufactures products for label-owning marketing companies, like many of the Companies that receive the Vitamin Consultancy Newsletter.

After an inspection the violations were considered so egregious that a Federal Judge was asked to order Riddhi to stop all activities until it could meet GMP requirements.  Needless to say, all of its customers, Companies like yours, are scrambling to find new manufacturers.

What are the lessons we need to take from this regulatory action?

Let's start by listing what FDA thought were the most serious violations:

"-[1] failing to establish product specifications
    -- for the identity, purity, strength and composition of the finished dietary supplements

-[2] inadequate master manufacturing and batch production records

-[3] lack of quality control procedures

-[4] lack of procedures to investigate product complaints

-[5] products’ labeling failed to declare dietary ingredients, allergens and place of business."

These are nearly all Standard Operating Procedures violations. 

Either Riddhi did not have the written procedures or failed to implement them.  That also means the customers of Riddhi failed to "be in a state of control" -- the requirement that applies to all label-owners.

Specifications. Records. Procedures...

You need to have them. You need to implement them.  FDA publicized the Riddhi case as a warning to all companies that the agency can shut you down if you fail to adopt SOPs, train employees in their use, and actually implement them.

The Vitamin Consultancy provides up-to-day procedures and the OPS 4 SOPs system that enables you to implement the specifications, records and procedures required.

It is up to the Company's senior management to take the lead in careful implementation.

The SOP introduction indicates:

"The following Positions in the Company are listed in these SOPs: the CEO, COO, Quality Control Manager (QCM), Emergency Manager (EM), SOP & CCDS Manager, Customer Service Manager and Warehouse Manager. The COO or (where one is not designated) the CEO shall hold these Manager Positions unless the Positions are filled by appointment by the CEO..."

That is:

CEO/COO
QCM
EM
SOP/CCDA Manger
Customer Service Manager
Warehouse Manager

The Vitamin Consultancy offers "refresher" training sessions where staff members assigned to the different positions mentioned in the SOPs can recommit to following the SOP procedures.

More information here: http://vitaminconsultancycertification.weebly.com/ops-4-sops.html

*  https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm603111.htm
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Practice Note: Reading the FDA Regulation changing the way conventional food labels are configured.  The new Regulation is being delayed until 2020 (good news!).

     Yes, I was reading down the hundreds of Comments in the Regulation, and FDA's Responses. This one, #431, got a raised eyebrow, since it is contrary to what FDA has said elsewhere: "We agree there is a difference in biological activity between synthetic and naturally derived β-carotene. "

     In the past FDA would object if any vitamin company said "natural" was better than "synthetic." Does that irrational rule still hold? If your naturally derived nutrient ingredient has been shown to be better than synthetic versions, it seems the old rule may no longer hold.

https://www.federalregister.gov/documents/2018/05/04/2018-09476/food-labeling-revision-of-the-nutrition-and-supplement-facts-labels-and-serving-sizes-of-foods-that

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Proposition 65 Coming at YOU!
www.ProfessionalSafetyDossier.com
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Need Transcription Services?
Try this: https://www.rev.com/ 

You Must Adhere to GMPs

It's been over two months since my last newsletter... View this email in your browser

FDA Injunction: You Must Adhere to GMPs Doesn't matter who the president may be; the FDA continues on its bureaucratic way. As does Congress.  Just last month we faced a failed health care reform that could have restricted dietary supplement access. See more here: http://drrimatruthreports.com/health-care-reform-threatens-your-access-to-supplements/ . While Congress flounders, see this about an FDA warning letter that led to a Court Order Permanent Injunction that the company immediately cease all operations: “Companies that market their products with unproven health claims and also continue to violate manufacturing regulations put consumers’ health in jeopardy,” said Melinda Plaisier, FDA associate commissioner for regulatory affairs. “The FDA will take the enforcement actions necessary to protect consumers from this undue risk.” "The FDA inspected X’s businesses, which shared a location, four times since 2012. Despite assurances from X that the deficiencies noted during the inspections would be corrected, follow-up FDA inspections revealed that X repeatedly failed to make the necessary corrections." "Because X’s businesses failed to follow cGMP regulations, their dietary supplements are adulterated under the Federal Food, Drug, and Cosmetic Act. Some of the supplements were also mis-branded because X’s businesses failed to properly list on the products’ label the number of servings per container and the correct serving size per container. Additionally, they failed to list each ingredient contained in the dietary supplements and identify the part of the plant each botanical dietary ingredient was derived from...." Bottom line: companies that market their own products that they manufacture or label will be held to all manufacturing, holding and shipping GMPs. They will be expected to document compliance. Standard Operating Procedures are an essential element to remain in business. I have continued to upgrade and update the SOP and training system from The Vitamin Consultancy. Here is how I can help your company: 1. Preparing SOPs that reflect your actual business practices and that conform to GMPs 2. Designing Control Systems that implement the SOPs 3. Training your staff in implementing the SOPs (FDA says it is not enough to have standard procedures, they must be written and your staff must be trained in using them). 4. Auditing your procedures and your contract manufacturer's GMP compliance. July 2017 Update:OPS 4 SOPs  http://vitaminlawyerarchives.blogspot.com/2017/07/ops-for-sops.html  More here: http://vitaminconsultancycertification.weebly.com/  GMP Audits here: http://www.RegulatoryComplianceNetwork.com Contact me any time. I'm available to set your mind at ease. Ralph Fucetola JD --------------------- A personal note, for those of you who don't know already. My friend and mentor, General Bert Stubblebine, died on 6 February 2017, his 87th birthday, after 158 days in hospital. We recount his and Dr. Laibow's struggle to save his life against the expectations of the medical system here: http://drrimatruthreports.com/general-bert-rest-in-peace/ --------------------- Full FDA announcement here: https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm546620.htm

Investing in Regulatory Compliance RoI

Memorandum from Ralph Fucetola JD

Re: Investing in Regulatory Compliance

Date: November 7, 2013

  

To: All Potential Natural Product Company Investors

This Memorandum is to acquaint you with the benefits to your Company raising sufficient capital to comply fully with FDA/FTC SOP/ GMP & Clinical Study Guidelines.

Good Studies lead to good claims; good claims lead to increased ROI!
    Properly Structured Standard Operating Procedures and
    Trained Employees lead to significant regulatory savings.

Getting Ready for the FDA & FTC -- www.VitaminIndustryCompliance.com

Even more evidence that the agencies are serious about nutrient & natural product claims; this from the Natural Products Association in March 2011:

“A new and completely different type of safety website is now open for business. Almost anyone can post information on SaferProducts.gov about a consumer product they believe might be dangerous or has already caused a safety problem. Not only will this database of consumer comments be public, it also will be searchable. "Through this database consumers will have open access to product safety information that they’ve never seen before, and this information will empower them to make safer choices," said Inez Tenenbaum, chairman of the U.S. Consumer Product Safety Commission.”

What does that mean? It means your Company reputation can be ruined by willful false posters; it means the govt will be trolling the site to find companies to harass…

And consider these “data points” from the last two editions of my Vitamin Lawyer Update eMemo: the UK advertising agency, the ASA now states, according to WINSH.org, “research on the ingredients was not the same as research on the product itself…”

Let’s repeat the key phrase: “…research on the ingredients was not the same as research on the product itself…” – and “research on the product itself” means a Clinical Trial, of course! The substantiation generated by the Clinical Trial is the legal basis for making product claims.

The Natural Products Association (NPA) said in February ‘11 – “Time's Up: FDA has begun real enforcement of dietary supplement GMPs. Companies of all sizes are being inspected.  Are you ready?”

Is your Company ready? What does it take to be ready? See Below.

The above Red Letter warnings from the NPA & ASA urgently restate what I’ve been telling my perceptive clients regarding the vitamin or natural products companies. Are you ready for the FDA inspectors?  Below are the 4 essential steps you must take with estimates of the investments these essential steps require from your Company. You need to budget this investment now and start to do what you can to be prepared; in this way you will outperform the competition who will not be so prepared.

HHS Secretary Sibelius admitted a couple years ago that she has a $16 Billion slush fund under Obamacare that can be used to fund activities like the FDA’s 4,000 new inspectors… and FDA has already dramatically increased inspections, without those new bureaucrats! SOP Certification Training is what your company needs.

Says FDA - "...documentation of employee training is necessary to track which employees have been trained in which operations. Therefore, final Sec. 111.14(b)(2) requires you to keep documentation of training, including the date of the training, the type of training, and the person(s) trained." Federal Register, page 34811

What do you need to survive an FDA inspection? Go here: www.VitaminIndustryCompliance.com

1.       Standard Operating Procedures – in place and up-to-date. GMP compliant detailed SOP documentation not only satisfies FDA & FTC, but also helps you organize your business!

2.       Product Substantiation Notebook – in place and up-to-date; this Notebook is a MUST if you get inspected! The Notebook should includs copies of the Structure and Function Claims Notices companies are required to file with the FDA within 30 days of marketing any claim.

3.       Your ROI can be strongly enhanced by copy-writers who know how to avoid Red Flag claims & Illegal Testimonials!

4.       A Third-Party Clinical Trial of your product; you can no longer fully rely on published science about isolated ingredients.

The Dietary Supplement and Natural Remedies market is at a unique moment in its recent history.

The market has grown from under a billion dollars when the Dietary Supplement Health and Education Act (DSHEA) passed in 1994 (the first law allowing claims to be made for such products) to about $50 billion in 2009. The current recession is only having a marginal effect on the nutrient market and one survey shows that 51% of the purchasers would cut back on food purchases rather than vitamin purchases. At the same time, significant regulatory initiatives have occurred during the past years with potential impact on the market. After 14 years, FDA finally issued Good Manufacturing Practice (GMP) regulations for the industry during June, 2007 which became completely effective in June 2009.

All of these factors contribute to a growing industry that typically sees, after initial investment, a cost of goods, for start-ups, at about 20 to 25% of retail, rapidly moving down to 10% as new companies are able to order product runs in the hundreds of thousands of capsules.

Bottom line: savvy investors, seeking reasonably assured ROI, will find in the natural products market potential opportunity, if the Company invests in in Regulatory Compliance!

 © 2013

www.VitaminIndustryCompliance.com

The Vitamin Lawyer.com Consultancy

Ralph.Fucetola@usa.net - www.VitaminLawyer.com

Notary Public of the State of New Jersey #2398815
Attorney at Law in NJ – 1971 - 2006 – All Rights Reserved.

02/14/12 - The Cost of GMP Compliance

Welcome to the Update eMemo... helping the natural products and services industry comply with lawful regulatory standards...
 
[1] The Cost of GMP Compliance
[2] Social Networking
[3] Yes, You do Need Clinical Trials…
[4] Vitamin Lawyer Connections: All the Links You Need!
 
New Service for EU Cosmetics Dossiers: You can sell in the EU without prior governmental approval, if you have a Dossier from NCT! Please take a look at our new Webinar linked from this web page: http://www.naturalclinicaltrials.com/NCT-EU-Cosmetics.php.
 
Announcement: For information about the SEC-filed Fund for Natural Solutions: wwwFundforNaturalSolutions.org (offering only by Private Placement Memorandum, available upon request: just email me at ralph.fucetola@usa.net with “Fund” in the subject line). Our first proposed investment: an off-shore (Panama/Hong Kong) compounding pharmacy. Doing good while doing well… think about the possibilities!
 

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[1] The Cost of GMP Compliance!

This from the Natural Products Association’s recent article on the costs of complying with FDA GMP rules.
“…FDA likely underestimated the cost very small- and small companies (fewer than 500 employees) would face to achieve compliance. In its 2003 proposal, FDA estimated this cost to be about $100,000 per year, but many industry members disagreed, especially in the area of testing ingredients and finished products. In its final supplement GMP rule issued years later, FDA in fact amended its cost estimates to $46,000 per year for very small companies (fewer than 20 employees) and $184,000 per year for small companies (more than 20, fewer than 500 employees).
“Another change FDA made in its cost analysis in the final rule was to amend its estimates for the average number of batches per year per company size category; industry heavily criticized FDA's 2003 estimates as too low in each category and illogical in estimating more batches for small companies (554 batches) than for large companies (309). FDA changed this to 444 for very small; 2,436 for small; and 1,164 for large firms. The reason for the persistent discrepancy between small and large estimates, according to FDA, was information from self-proclaimed small companies that said they produce more batches of smaller size than do large firms, due to differences in equipment capacity. This increase in batch estimates across the board is one reason why overall cost estimates rose, as testing batches is a primary cost in GMP compliance. 
 
“In amending its projections, FDA acknowledged numerous comments submitted by industry detailing the "burdensome" testing requirements and warning the GMPs, as proposed in 2003, would drive small companies out of business and push the price of supplements up possibly over the price of some drugs. In the final rule, the agency also noted compliance efforts may steal companies' resources from areas such as worker safety, product development, marketing and voluntary product testing. This is an often overlooked cost of becoming GMP compliant, especially for companies on tight and small budgets, which includes just about every company in this current economy…”
http://www.naturalproductsinsider.com/articles/2012/02/the-cost-of-gmp-compliance.aspx
Are you prepared for the inevitable FDA inspection?

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[2] Social Networking is the New “Google”!

From a savvy marketing mavin: “With Facebook now receiving more traffic than Google, it is arguably one of the most important marketing tools for any business. In fact, CNN says 43% of businesses are using custom Facebook pages to gain new business.”
 
So I looked on the Internet for further information about the power of social networks.
“The most influential news-sharers, and the group which shared 87% of the stories in the survey, only accounted for 27% of all the users - tallying with previous definitions of a minority of highly active web web users that contribute a majority of content online.
 
“The big social networks - Facebook Twitter, YouTube and MySpace, accounted for 43% of all links shared, email 30%, SMS 15% and instant messenger 12%. “Researchers identified three primary motivations for sharing, which differed around the world. In Europe and North America, users had more altruistic reasons for sharing stories that would be useful to friends or family, European users tend to share more work-related stories and Asia-Pacific readers were more likely to 'status' broadcast - share things that underline or reinforce their own knowledge and identity.” http://www.guardian.co.uk/media/pda+cnn
“Google, the monolithic search engine that spreads traffic across the web like Congress spreads stimulus funds, now gets less traffic than that stupid website you joined so you could see what your kids are doing when they're not home. Of course, smart marketers know that neither of those characterization is correct anymore. Google is still a huge source of traffic, but the web is now bigger than just Google. And while Facebook may have started on college campuses it long since graduated. Hitwise's numbers reflect this change. According to their report, the market share of visits to Facebook.com increased 185% last week from the same week in 2009. And Google? Well, they grew, but only 9%.
 
Marketers, ignore Facebook at your own peril.”
Read more: http://blog.hubspot.com/blog/tabid/6307/bid/5739/What-Gets-More-Traffic-Than-Google-Now-Facebook.aspx#ixzz1gXNrsBUl

Website Online Marketing Services Available For Your Business

I know you are ready to take your business to the next level using SEO, SEM, Social Networking, and other online marketing techniques for your website tailored to your business’s requirements.  I know you are looking to dramatically increase your client, patient, or customer base and profits in an exponential way!

I urge you to call is Virtually Local.  Virtually Local, a premier Internet Marketing business, is owned and operated by Lynda Leibowitz.  She is also the author of “Lynda A Leibowitz’s Guide To Marketing Your Business: Harness the Power of the Internet to Boost Your Profits”.*  

She is one of the good folk who have helped Natural Solutions achieve the high Google ranking and strong social networking that put it among the top fifteen thousand web sites world-wide.

Affordable with real ROI. What choice do you have?

Visit Virtually Local today or call (973) 498-8497.

Direct URL: http://www.virtually-local.com

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[3] Yes, you do need clinical trials!
 
Several clients are raising funds to invest in Clinical Trials or Clinical Studies; I was asked to prepare a “Comfort Letter” for the clients to use with their potential investors. If you would like a copy addressed to your Company, to raise the funds you need to invest to stay in the market, please email me!
The Red Letter warnings I sent you in recent months from the NPA & ASA urgently restate what I’ve been telling my perceptive clients regarding the vitamin or natural products companies. Are you ready for the FDA inspectors?  I told you the 4 essential steps you must take in the last issue of the VL Update. Here, I add estimates of what these essential steps will cost your company. You need to budget now and start to do what you can to be prepared. The FDA has already dramatically increased inspections, without those new bureaucrats!
 
What do you need to survive an FDA inspection? I’ve told you several times!
 

1. Standard Operating Procedures – in place and up-to-date -from $500. The SOP document not only satisfies FDA, but also helps you organize your business!
2. Product Substantiation Notebook – in place and up-to-date –from $500 plus your research time; this Notebook is a MUST if you get inspected! Part of the Notebook includes copies of the Structure and Function Claims Notices companies are required to file with the FDA within 30 days of marketing any claim. The cost for these notices is from $340.
3. Copy-writers who know how to avoid Red Flag claims & Illegal Testimonials! My webinar on these issues is inexpensive. $99 for the archived CAM Webinar; a private copywriter webinar just for your company copywriters will cost above $500 (the webinar includes an eBook specially written for your company).
4. A Third-Party Clinical Trial of your product; you can no longer fully rely on published science about isolated ingredients – This can cost up to several hundred thousand dollars. NCT offers a Minimal Clinical Trial from $35,000.

www.NaturalClinicalTrials.net

WHAT SHOULD YOU DO? Contact me NOW!  973.300.4594

The longer you put off addressing any of the above issues,
the more at-risk is your company!

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[4] Vitamin Lawyer Connections
Archived Cautions for CAM Wellness Practices
http://www.naturalhealthoptions.net/LifeSpiritWebinars.php
 
"Do you have a CAM “Alternative” health practice? Do you provide nutrients, remedies or health related items to clients?
 
Do you have questions about your legal rights and limits … or need information about how best to run your health care business? Are you aware there are words you cannot use and statements, although true, you cannot safely say to clients?
 
Hiring an attorney, one on one, to review these issues could cost you hundreds of dollars… making a mistake could cost you thousands. I invite you, instead, to learn from my Webinar, Cautions for CAM Wellness Practices.
 
I am known as The Vitamin Lawyer, because much of my 36 year legal practice centered around helping people in CAM practices, nutrient purveyors and advanced healthcare teachers. Today I am a Trustee of Natural Solutions Foundation. I can keep you out of trouble and operating smoothly so you can fulfill your mission to help others…"
This $99 PEL Webinar runs about an hour through 32 slides. It includes an 18 page eBook of information and forms all of which would cost over $500 if one on one. This is a Natural Solutions Foundation Benefit Webinar."

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Vitamin Lawyer Connections…
Notice of Fee Increase: 2011 Rates: $340 standard and $285 discounted.
Do you Skype? If so, free Skype.com is one of the easiest ways to contact me, no matter where I may be.
My Skype handle is: vitaminlawyer
Our new affiliation site: www.naturalhealthoptions.net
Do you have an affiliation program? We’d like to list it.
If you don’t have an affiliate program… I have Affiliate Program SOPs & Rules …
And good advice… for you.
“One on One with the Vitamin Lawyer” from Power Pictures Inc.
Trailer: www.youtube.com/watch?v=wWPvzpn0YgA www.powerpicturesinc.net/store.html
Follow me on Twitter - www.twitter.com/healthfreedomus  

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Ralph Fucetola JD
www.NaturalHealthOptions.net www.vitaminlawyer.com http://vitaminlawyerarchives.blogspot.com http://vitaminlawyerhealthfreedom.blogspot.com www.HealthFreedomPortal.org
If you want to unsubscribe to this newsletter, please email me at ralph.fucetola (at) usa.net with “Unsubscribe” in the subject line.