Monday, October 23, 2006

10/23/06 - More on SoPs and SEO


Here’s what I cover in this memo:

1. SoPs – More on Operating Procedures

2. Top Ten SEO Factors – from Entire Web


1. SoPs - More on Standard Operating Procedures

I know I’ve been telling you quite a bit over the past couple months on Standard Operating Procedures. There is an important business reason for that: bit by bit the FDA is coming out with more requirements that apply to dietary supplement companies, enforcing a provision in the 1994 DSHEA law giving FDA authority to codify current Good Manufacturing/Marketing Practices in the industry.

In comments to one member of Congress, discussing a meeting on SoPs, FDA stated: “The agenda included topics regarding the small business entities' manufacturing practices and standard operating procedures for: (1) personnel; (2) buildings and facilities; (3) equipment; (4) laboratory operations; (5) production and process controls; and (6)

warehousing, distribution and post-distribution of' raw, intermediate and final products . The meeting included a discussion about the verification of the identity, purity and composition of dietary supplements and dietary supplement ingredients.”

There has been continuing controversy regarding SoPs for the industry. GNC made its position clear in 2003, “FDA asserts that “dietary supplements have their own set of unique requirements as a result of the characteristics and hazards due to their ‘hybrid’ nature, e.g., dietary supplements can be considered as falling somewhere along the continuum between conventional foods on the one hand and drugs on the other.” Dietary supplements in fact fall within the food category and were treated as a food item for their entire history. DSHEA in 1994 confirmed the food status of dietary supplements and provided an expanded definition of the category.”

As a result, the original intention of FDA to have formal cGMP in place several years ago has been delayed. Now the agency seems to be imposing the regulations in a more piecemeal strategy. I’ve recently been reading FDA warning letters that cite a lack of an SoP as a concern of the agency.

To anticipate these developments, I’ve created a standard Operations Manual for my Vitamin Lawyer Consultancy clients. As the SoP is developed, it will cover all the areas cited by the FDA above. The most recent addition to the SoP is a page of instructions about reviewing Advertising Claims, whether on labels, literature or web sites. Those clients who are on a regular monthly retainer agreement with me have received that additional page already.

As an “added value” to my extended client base, I would be happy to provide a copy of this SoP page upon request. Of course the best way to be kept up to date is to be a regular monthly retainer client. And, you receive two added bonuses: a lower hourly rate and the use of my Vitamin Lawyer Oversight Seal. Drop me an email if you’d like more details.

See also [includes outline of SoP]: 07/05/06
See also [Crisis SoP]: 11/16/06


2. Some more good SEO advice from Entire Web -

"Entireweb Newsletter - October 24, 2006 - ISSUE #277

Top Ten SEO Factors

These are what I believe to be the top 10 most important things (not necessarily in order) that you need, in order to get your website found in the search engines.

There are many other factors as well, but if you follow these guidelines, you'll stand a much better chance, and you'll be off to a good start.

1. Title Meta Tags

The title tag is what displays as the headline in the SERPs (Search Engine Results Pages). It's also what displays in the top blue band of Internet Explorer when your site is displayed

Your title tag of your website should be easy to read and designed to bring in traffic. By that, I mean that your main keyword phrase should be used toward the beginning of the tag. True there are websites being found now that do not use the phrase in the title, but the vast majority still do as of this writing.

Don't make the mistake of putting your company name first, unless you are already a household name, like Nascar or HBO. People are likely searching for what you have to offer, not your name.

Your title tag should be written with a capital letter starting the tag, and followed by all lowercase letters, unless you're using proper nouns. Some people prefer to capitalize every word, too.

2. Description Meta Tag

The description tag is the paragraph that people will see when your page comes up in the search results.

Your description tag should be captivating and designed to attract business. It should be easy to read, and compel the reader to act right now and follow your link. Without a description tag, search engines will frequently display the first text on your page. Is yours appropriate as a description of the page?

A proper description tag is what people will see below your title. You should make proper use of punctuation, and with readability, use your subject and geographical references.

3. Keywords Meta Tag

The importance of Meta keyword tags fluctuates from month to month among different search engines. There is a debate in the SEO community as to whether or not they help at all on certain search engines. In fact, in the summer of 2004 it appeared as if they were losing importance altogether.

However, you'll NEVER be penalized on any search engines for using relevant targeted keywords in moderation, and they can only help you with most, especially Yahoo.

Avoid stuffing your keyword metatags with too many keywords. Just use relevant tags that apply directly to the content of that particular page, and don't overdo it.

4. Alt Tags

The small yellow box that comes up when your mouse cursor is placed over an image is called the ALT tag. Every relevant image should have an alt tag with your key words or phrases mentioned in the tag.

A proper ALT tag goes after the file name, and before the Align indicator. * - The ALT tag is no longer being considered for ranking purposes by some search engines. That said, it still cannot HURT you, and will still help you with some engines. My recommendation is to continue to use them, but be sure to avoid keyword stuffing. Besides, who knows when the pendulum will swing back the other way?

5. Header Tags

The text of each page is given more weight by the search engines if you make use of header tags and then use descriptive body text below those headers. Bullet points work well too. It is not enough to merely BOLD or enlarge your text headlines.

6. Link Text

Search engine spiders cannot follow image links. In addition to having image links or buttons on your web pages, you should have text links at the bottom or elsewhere. The text that the user sees when looking at the link is called the link text. A link that displays products does not carry as much weight to the search engines as a link called oregon widgets. Link text is very important, and is actually one of the most frequently overlooked aspects of web design that I've seen.

7. Site Map

Using a site map not only makes it easy for your users to see the entire structure of your website, but it also makes it easier for the search engines to spider your site. When the search engine spiders come to visit, they will follow all of the text links from your main index page. If one of those links is to a site map, then the spiders will go right to the sitemap, and consequently visit every page you have text linked to from that site map. On the site map page, try to have a sentence or two describing each page, and not just a page of links.

8. Relevant Inbound Links

By relevant, I mean similar industry or subject related sites. Right now, no single strategy can get your site ranked higher faster than being linked to by dozens of other relevant websites. It used to be that the quantity of incoming links mattered most, but today, it's much better to have three highly relevant links to you from other popular related websites than 30 links from unrelated low ranked sites. If there are other businesses in your industry that you can trade links with, it will help your site enormously. Link to others, and have them link to you. It's proven, and it works. To see who's linking to you, in Google type the following... links:

9. Your Content

Not to be forgotten of course, is the actual content of your webpage. It must be relevant helpful information that people want to read. These days, each webpage should be laser focused on one specific product or subject, in order to rank highly for that search phrase. The days of writing one webpage to appeal to dozens of search terms are long gone. Ideally, each page should have between 400 to 650 words on it. Too few, and the search engines won't consider it to be relevant enough. Too many words and the search engine spiders may have a hard time determining the actual subject or focus of the page.

Use your keywords or phrases often, and use them at the beginning of your paragraphs wherever possible. Don't overuse them and make the page sound phony, but don't write a page about a certain subject, and not mention that subject repeatedly either. Reading it out loud to yourself is a great way to judge how natural your text sounds.

Concentrate on writing quality pages that actually appeal to the human reader. Write pages that provide the reader with exactly what they are looking for; that is, information about the exact search phrase they've entered.

10. Avoid Cheating

With all of these tidbits of information, it's tempting to think that you can stuff 100 keywords into your title, or create a page with the phrase oregon widget company being used 100 times in headers, text links, ALT tags, bullet points etc. but that cannot help you. In fact, it can penalize you, and get your website banned from certain search engines.


About the Author: Scott Hendison is an internet consultant that specializes in search engine optimization and internet marketing. He has written over 100 articles that are available on his website. He has also developed a tutorial area for beginning search engine optimization, at 'SEO101'."


That’s all for now – I hope you find this information useful!

Thursday, October 12, 2006

10/12/06 - VL Free Online Seminar; Codex DVD


Here’s what I cover in this memo:

1. Vitamin Lawyer Free Online Seminar
2. Codex DVD and Committee Meeting


1. Vitamin Lawyer Free Online Seminar: Over the years I’ve written many briefs and white papers about dietary supplement regulation and about alternative health care practices. I’ve posted these on an index page that you can find at: / Updated:

Here are some of the titles:

Alternative Practices and the AMA Code of Ethics
The Practice of Alternatives is not the Practice of Medicine
Mum Marketing -- Niches on the Internet
The Right of the Public to the Truth - Current Vitamin Marketing Rules
The Herbalists' Charter -- Ancient Rights for Modern Practitioners

-------------------------------------------------------- Index

2. Here’s some insider information on the Codex Alimentarius (World Food Code) issue and the future of international regulation of the Dietary Supplement marketplace.

“Codex is a winnable battle. It takes awareness, motivation, hope and tools to win. And it takes people. You know that we don't have the major media fighting to be first in line to tell the story of Codex and the industrialization/pollution of our food supply. They are not itching to let everyone in America know that despite the fact that nutrients are safe and effective, to say nothing of inexpensive, they make most drugs unnecessary…” Dr. Rima Laibow.

See exciting excerpts from Dr. Laibow’s hard-hitting DVD, Nutricide, now posted at:

The Codex Nutritional Foods Committee (CCNFSDU) is meeting in Thailand at the end of this month, and for the first time ever, the organization’s autocratic chair will be held by someone who is more favorable to nutrients than the current leadership. This same meeting is required to consider the WHO/FAO Global Strategy on Diet, Physical Activity and Health, having before it the 11 pro-health principles offered by South Africa. You can see a media release regarding these at:

It is important to SUPPORT the Natural Solutions Foundation, who helped develop the 11 Point Program, and thereby ensure that Foundation representatives can get to Thailand for what will be a very important meeting that will effect the way Vitamin Companies in the U.S. do business, not just globally, but domestically as well. It is expensive for NGO (Non-Governmental Organization) groups like NSF to fund such efforts, since they must rely entirely on private donations, unlike the bureaucrats and pharma cartel lobbyists who have plenty of money!

Check the video to learn why. Then donate, as though your Health Freedom depended on it, which, in my humble opinion, it does:

Thank you!

Ralph Fucetola JD

Friday, October 6, 2006

10/06/06 - Register Food Processing Facilities; Nanotech Coming...


For those of you who are new to the VLUeM, the purpose of this e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. You got on this e-list by opting in or becoming a client of the Vitamin Lawyer Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own elist… J

Here are the items I am covering in this e-memo:

1. Registration of Food Processing Facilities
2. Nanotech Coming to the Vitamin World – are you as ready as the FDA?
3. VLUeM Archives now online!!


1. Registration of Food Processing Facilities

Says FDA – “Domestic and foreign facilities that manufacture/process, pack, or hold food for human or animal consumption in the United States are required to register their facility with the FDA.” Among the foods included are that class of foods known as Dietary Supplements. See:

“Who must register? Owners, operators, or agents in charge of domestic or foreign facilities that manufacture/process, pack, or hold food for human or animal consumption in the United States are required to register the facility with the FDA.” The web page states that this requirement applies to Dietary Supplements.

There are three simple steps on the web site to register:

“1. Verify that your computer system meets the minimum system requirements.
2. Create an Account for the online FDA Industry Systems.
3. Register or Update a Food Facility.”

If you do not do your own manufacturing, processing, packaging or holding, the company you contract with for those services needs to be registered. You should ask for that company’s registration information.

Registration form:


2. Nano Technology

Here are excerpts from a recent online report; note how innuendo and distortion are used to equate dangerous drugs that kill hundreds of thousands each year with generally safe food products [my comments in brackets]:

FDA not ‘nano-ready’, says report

By Clarisse Douaud

10/5/2006 - A former FDA deputy commissioner for policy has denounced the agency's capacity to properly regulate nanotechnology products including supplements, a criticism that could inflame debate leading up to the agency’s first major public meeting on the atomic technology.

In a report commissioned by the Woodrow Wilson Center's project on emerging nanotechnologies, University of Maryland School of Medicine professor Michael Taylor concluded the US Food & Drug Administration's resource base is severely eroded. This is despite what appears to be a recent nanotechnology policy kick-start at the FDA.

The report reveals regulatory weaknesses affecting new products, such as certain dietary supplements and cosmetics, using the technology. Critics say questions over nanotechnology safety have not been answered and the FDA is not in a position to effectively police it. . . .

Nanotechnology is the ability to control things at an atomic and molecular scale of between one and 100 nanometers and has been met with enthusiasm across a variety of industries. Critics highlight the murky area of how nanoparticles affect toxicity and say nanoparticles should be treated as new, potentially harmful materials and tested for safety accordingly.

[A word to the wise: Foods (which is what Dietary Supplements are, after all) are NOT TOXIC chemicals, like pharmaceutical drugs are, and there is no evidence that nano-sized particles of those same Foods are any different. After all, the body breaks the nutrients down to molecular particles in order to use them. The above statement by the “expert” follows the political line laid down by new world order entities such as Codex, the World Food Code control organization.] …

Unlike pharmaceuticals, which must go through a series of pre-market approvals, finished dietary supplements need no pre-market approval. Under the Dietary Supplement Health and Education Act (DSHEA), which is part of the Food and Cosmetics Act, only ingredients not marketed in the US before October 1994 must be approved by FDA before use in consumer products.

Thus, as it stands, pre-market regulation of nanotechnology in dietary supplements does not fall under FDA's regulatory umbrella, nor – according to Taylor – can fit into the agency's budget. . . .

"Business and health leaders alike should join in ensuring that FDA has the scientific tools and knowledge it needs to say 'yes' to safe and effective new products," said Taylor.

[Note: the “safe and effective” standard is the Drug standard. By law and court decision, Dietary Supplement Foods need only be safe when used as directed. The government does not evaluate the efficacy of Foods, only consumers on the open market can do so.]

The market stands to benefit from nanotechnology and therefore, stands to lose a lot according to Taylor, if it is not thoroughly regulated.

[The above statement is only possible from a former government employee who has never heard about the self-regulating abilities of the marketplace and has purposely remained ignorant of the disasters of government regulation, which have led to millions of unnecessary deaths.] …

FDA's nanotechnology public meeting will take place October 10, 2006 in Bethesda, Maryland. …

“FDA is interested in learning about the kinds of new nanotechnology material products under development in the areas of foods (including dietary supplements), food and color additives, animal feeds, cosmetics, drugs and biologics, and medical devices…” states an online FDA notice for the upcoming meeting. ...


3. VLUeM Archives now online!

I’ve provided update memoranda to my regular clients for several years. I’ve now begun to create an Online Archives of the memos, working backward. So you can find everything you ever wanted to know about regulating the vitamin industry… sort of. See the Index at: I would appreciate any feedback.