Friday, January 25, 2008

01/25/08 - Web site cross promotion

 
… VLUeM – 01.25.08 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO

PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...

This issue: saving your company from costly new FDA regulations…
_______________________________________________

1. Health Freedom Blog update
2. Cross-promotion of web sites
3. VL Memo Archives Blog - improved format for this Update eMemo!
______________________________________________

1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/

Factoid: FDA just decided not to define the word “Natural” although petitioned to do so. Functional Nutrition Magazine also tells us that “Natural” was the favorite word last year for launching new food products, appearing on almost 2,500 of them. See: http://www.functionalingredientsmag.com/fimag/articleDisplay.asp?strArticleId=1553&strSite=FFNSite

The OneLook.com meta-dictionary defines “Natural” as: “adjective: existing in or produced by nature; not artificial or imitation… (used especially of commodities) in the natural unprocessed condition…”

eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join

If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .

This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
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2. Entire Web on Cross-promotion of Web Sites
Entireweb Newsletter * January 22, 2008 * ISSUE #407
Easy Cross-Promotion Tactics

Cross-promotion is an easy, inexpensive method for generating more traffic and more revenue for your business and for the business of your promotional partners.

What could be better than a real win-win situation? With cross-promotion not only can you generate more customers and profit, usually for free, but you can help another entrepreneur do the same!

One simple example of good cross-promotion is swapping business cards with another business in your area. The idea is to find a related, yet non-competing operation, give them a stack of your cards to hand out and take a stack of their cards in exchange.


For example when I ran a local Web design company I swapped stacks of business cards with a nearby computer repair service. It made sense because both of us targeted small businesses, and nearly all small businesses today have computers in their office and a Website to promote their products and services. So often my customers would have an interest in a good computer repair service, and the repair shop's clients might be interested in somebody to build or re-design their Website.

It's easy to see how both parties stand to benefit in this arrangement. And the customers of both businesses also benefit!

Putting together a win-win cross-promotion on the Web is even easier, and here are a few examples of how you might do this:

Exchange Thank You Page Ads
Thank you or confirmation pages that prospects see after they make a purchase or register for a free mailing list are great places to post promotions. The people who see these pages are action takers, making them the ultimate target for a good advertisement.

You could place an ad for your cross-promotion partner on one or more of your thank you pages and have them do the same for you.

Unannounced Member Bonus
If you and your promotional partner run membership programs, you could place unannounced bonuses within one another's secure member areas. For instance, when members login to your site they could find a "free gift" from your partner, and be required to register at your partner's Website to receive access to their free gift; of course you would place a similar promotion in your promotion partner's member area.

Swap Autoresponder Messages
You could include an email in your automated message series promoting your partner's product or service, and they could reciprocate with an email for you. You could even promote as affiliates for one another so you both earn commissions in the process.

Cover Page Promotions
If you and your partner both produce digital information products such as e-books and special reports, you could swap promotions on the first page of your PDF products. This would provide both of you with quality exposure as your ads would be seen by the people who purchase and actually open digital products; so prospects generated by this measure are both buyers and action takers.

These four examples are just the tip of the iceberg. Once you sit down and really brainstorm about innovative ways to cross promote you might be amazed with what you come up with.

Both you and your promotional partner(s) stand to benefit, and neither of you will need to pay any advertising expense to generate new traffic and sales.

About the Author: Tim Whiston is a professional Internet marketer who enjoys his work. He has owned numerous Websites and ezines and has created hundreds of thousands of dollars in profits for his clients. Be sure to check out his free Information Marketing Course and Internet Marketing Tools.

http://www.entireweb.com/newsletter/archive/2008/PRINT407.html



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3. Upgrading the VL Update eMemo!

I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com

In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________

You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com 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… 

And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com

For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...


Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .

Friday, January 18, 2008

01/18/08 - SOPs and FDA Regulations

 
… VLUeM – 01.18.08 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO

PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...

This issue: saving your company from costly new FDA regulations…
_______________________________________________

1. Health Freedom Blog update
2. News Target targets FDA attacks on supplements… are your SOPs ready?
3. Food niche with potential
4. VL Memo Archives Blog - improved format for this Update eMemo!
______________________________________________

1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/

Factoid: FDA just decided not to define the word “Natural” although petitioned to do so. Functional Nutrition Magazine also tells us that “Natural” was the favorite word last year for launching new food products, appearing on almost 2,500 of them. See: http://www.functionalingredientsmag.com/fimag/articleDisplay.asp?strArticleId=1553&strSite=FFNSite

The OneLook.com meta-dictionary defines “Natural” as: “adjective: existing in or produced by nature; not artificial or imitation… (used especially of commodities) in the natural unprocessed condition…”

eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join

If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .

This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. News Target targets FDA attacks on supplements – see SOP Alert! below.
“FDA Announces Plan to Eliminate Vitamin Companies by Byron Richards
“(January 15 - NewsTarget) The FDA, emboldened by its transformation into a drug company, has embarked upon an anti-American plan of interfering with business and intentionally eliminating various dietary supplement companies from the market. The FDA announcement came on Friday, June 22, 2007 under the guise of a final rule for dietary supplement good manufacturing practices (CGMPs). Within this 800 page rule the FDA states, "We find that this final rule will have a significant economic impact on a substantial number of small entities... Establishments with above average costs, and even establishments with average costs, could be hard pressed to continue to operate. Some of these may decide it is too costly and either change product lines or go out of business... very small …and …small dietary supplement manufacturers … will be at risk of going out of business... costs per establishment are proportionally higher for very small than for large establishments... The regulatory costs of this final rule will also discourage new small businesses from entering the industry." (http://www.cfsan.fda.gov/%7Elrd/fr07625a.html)

”This FDA rule will directly raise the price of dietary supplements for all consumers. The FDA acknowledges this and says "We expect that the majority of these costs will be borne by consumers of dietary supplements, who will likely respond to the increase in prices by reducing consumption." Thus, the FDA is intentionally seeking to shrink the size of the dietary supplement industry and reduce the influence of safe and effective options to improve the dreadful trend in the health of Americans. The goal is to leave toxic drugs as the primary health option.

”Independent analysis of this FDA rule has placed cost of compliance at 10 fold what the FDA estimates with as many as 50% of small companies unable to comply.”
To read more: http://www.newstarget.com/022499.html
SOP ALERT FOR COMPANIES: Now more than ever, “your papers must be in order…” – The Vitamin Lawyer Consultancy has prepared formats for Standard Operating Procedures to allow small companies to comply with the new rules, including the new AER law, by maintaining the necessary records. Our SOP format is relatively short (about 20 pages) but does cover all the areas needed:
A. Refund, Delivery & Returns Policies
B. Standard Disclaimers; Site Use Statement
C. Standard Testimonial Waiver
D. Email Privacy Policy
E. Document Retention Policy
F. Quality Control Procedures - Standards, Complaints and Policy Coordination
G. Order Processing Procedure
H. Bookkeeping and Account Management
I. Order Record Keeping and Retrieval; AER Reporting
J. Emergency Planning and Crisis Management
You can find out more at: http://tinyurl.com/2eu6yj
If you need the format, please email me at ralph.fucetola@usa.net and put “SOP” in the subject line. Typically, it takes an hour or two of my time to fine tune the format for you.
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3. Food niche with potential

Report pinpoints functional food niche with most potential - By Lorraine Heller

January 16, 2008 - Foods and drinks developed to address the specific health needs of consumers are expected to exceed category growth in the US functional food segment, according to a new report. Published by TSG, the study estimates that 'targeted foods', which currently make up 12 percent of the $60bn functional food segment, could grow to take a massive 25-35 percent share in 2012. This could bring up the total value of the sub-segment to between $55bn and $77bn over the next 13 years. Functional foods as a whole are projected to have a market value of $219bn by 2012.

TSG defines targeted foods are those functional foods that are designed to address specific health or disease conditions; specific physical or mental states; or specific age or gender needs. These, says the study, will grow "exponentially" as the functional foods markets continues its ascent into the mainstream.

"They will be the evolution of functional foods," TSG CEO Panna Sharma told NutraIngredients-USA.com.

Foods and beverages in this category include products that address: Digestive health, Celiac disease, Arthritis, Cancer prevention, Heart health

[Note from Vitamin Lawyer: some of these claims would not be allowed as Dietary Supplement claims.]

…[Other of these] products address: * Sports performance, * Beauty, * Skin care, * Libido, * Brain function

…TSG states: "Beverages will continue to drive innovation and early consumer adoption which will drive tighter alignment between functional ingredients and nutraceutical companies and the beverage community."

…"Global food and beverage giants will aggressively enter the market through acquisitions, alliances and select investments," said TSG.

For more –

http://www.nutraingredients-usa.com/news/ng.asp?n=82599&m=1NIU116&c=jegwylrviswtnqa
______________________________________________

4. Upgrading the VL Update eMemo!

I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com

In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________

You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com 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… 

And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com

For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...


Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .

Friday, January 4, 2008

01/04/08 - FDA on AER Labeling

 
… VLUeM – 01.04.08 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO

PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...

This issue: saving your company money…
_______________________________________________

1. Health Freedom Blog update
2. Web site titles and descriptions
3. The Electric Tree – savings and more
4. Guidance from FDA on AER labeling
5. Cost of foods… calorie
6. Coming next year: improved format for the VL Update eMemo!
______________________________________________

1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/

Factoid: Nutrition Business Journal (nutritionbusiness.com) announced recently that the global nutrition industry has reached $226-billion annually. Other sources suggest the US share is about 50% -- so what portion of that $113 billion a year does your company earn?

eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join

If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .

This eMemo is being sent through my “back-up” Earthlink email address since AOL seems to be blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________

2. Web site advice from Entireweb Newsletter * January 1, 2008 * ISSUE #401 – entireweb.com

“How to Create Compelling Site Titles and Descriptions - There are many places in your HTML you can include keywords, but the Titles and descriptions are arguably the most important elements of your Web site… These places are …most important in terms of their ability to compel someone to visit your Web site. That is, after all, the ultimate goal of search engine positioning, isn't it? Not a lot of point in attaining a top ranking in a search engine if you are just going to call you site "Shop Here." …the Title tag has special relevance, because so many search engines use the title exactly as it appears on your page. …the title of the site is more important than the site description.

“Longer Titles are More Effective - Longer titles build a more compelling reason to visit a Web site. Because it takes a certain number of words to persuade someone to take action, logic dictates that longer sentences have more opportunity to create that compelling argument… People often scan headlines in brochures and magazines, even when they don't read all the information…

“People Don't Read Text, They Recognize Words - …Educators know that people glance at words and recognize the words by the shapes defined by the tops of the letters. …Since people recognize words because the tops of words vary in height and appearance, then sentences that start with just one capital letter and then lowercase letters are easier to recognize and get read faster… Words in all caps are hard to read…

Every little advantage helps you.” - Pamela Upshur - upshurcreative.com
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3. The Electric Tree = savings and corporate responsibility

Natural Solutions Foundation has been chosen as one of The Electric Tree’s 2008 Corporate Responsibility Designees. What does this mean to your business? If you are located in one of the currently covered states (NY, CT, MA. IL, MD, DE ) and choose to participate, with NO cost to you, The Electric Tree can save between 8 and 14% of your electric power bill… if you spend at least $2,000 per month or more on electricity and are willing to donate half your savings to the Foundation. This can be a “win – win” situation. It is very simple to do. If you have interest, please email me with Electric Tree in the subject line.

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4. FDA Guidance & AER Labeling
You can find a listing of FDA guidance documents for the vitamin industry at: http://www.cfsan.fda.gov/guidance.html

Among the new guidances published is a draft labeling guidance for the AER (adverse event reporting) system, with frequently asked questions. This document was finalized on January 2, 2008, as “Guidance for Industry: Questions and Answers Regarding, the Labeling of Dietary Supplements as Required by the Dietary Supplement and
Nonprescription Drug Consumer Protection Act” - Docket No. 2007D-0491. It can be found at: http://www.cfsan.fda.gov/~dms/dsaergu2.html

Here is the summary of the label requirement: “the act requires the label of a dietary supplement being marketed in the United States to include a domestic address or domestic telephone number through which the responsible person may receive a report of a serious adverse event with such dietary supplement. If the label does not include the required domestic address or telephone number, the dietary supplement is misbranded.” FDA also “recommends that the label bear a clear, prominent statement informing consumers that the domestic address or telephone number is for reporting serious adverse events associated with use of the product.”

http://a257.g.akamaitech.net/7/257/2422/01jan20081800/edocket.access.gpo.gov/2008/07-6266.htm

Please note the distinction between “the act requires…” and FDA “recommends.” If a company voluntarily chooses to add language that the phone number or address on the label is there to report AERs, FDA does say “dual purpose” language such as “"To report a serious adverse event or obtain product information, contact..." would be acceptable.

And the FDA’s overall FAQs for AERs cam be found at: http://www.cfsan.fda.gov/~dms/dsaergui.html

That document also states: “Your submission will not be construed by FDA as an admission that the dietary supplement involved caused or contributed to the adverse event being reported. Any serious adverse event report submitted to FDA, including any new medical information submitted as a follow-up to the initial report, is considered a safety report under section 756 of the FD&C Act (21 U.S.C. 379v) and may be accompanied by a statement, which shall be a part of any report that is released for public disclosure, that denies that the report or the records constitute an admission that the product involved caused or contributed to the serious adverse event.”

If you have any occasion to report an adverse event, you ought to have the report reviewed by The Vitamin Lawyer before submitting it.
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5. Cost of food, per calorie
Reuters reported on 01/02/08, “the average price of the lowest-calorie foods -- including green vegetables, tomatoes and berries -- increased by almost 20 percent over 2 years. In contrast, in the same time period there was a 2-percent dip in the cost of the most calorie-laden fare, such as butter, potato chips, cookies and candy bars… findings, published in the Journal of the American Dietetic Association, highlight a key obstacle to healthy eating. … They found that snack foods, sweets and fatty foods offered the most bang for a shopper's buck. Whereas the price of the lowest-calorie fruits and vegetables was more than $18.16 per 1,000 calories, the most calorie-rich foods cost $1.76 per 1,000 calories.”
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6. Upgrading the VL Update eMemo!

Coming early this year: this email update system will be replaced by a second, private blog, the Vitamin Lawyer Update Blog, to allow me to keep you up-to-date better than ever! You’ll receive a shorter weekly update email with links to blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________

You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com 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… 

And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com

For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider making an end-of-the-year donation to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...

Wishing you and yours a joyous, prosperous, peaceful and free new year!

Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .