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17 Stan. L. & Pol'y Rev. 165 (2006)
A Drug by Any Other Name...: Paradoxes in Dietary Supplement Risk Regulation

handle is hein.journals/stanlp17 and id is 171 raw text is: A DRUG BY ANY OTHER NAME... . PARADOXES IN DIETARY SUPPLEMENT RISK REGULATION Lars Noah* Barbara A. Noah** How wonderful that we have met with a paradox. Now we have some hope of making progress. -Niels Bohr (1885-1962)' I. INTRODUCTION Dietary supplements-vitamins, minerals, herbs, amino acids, and sundry other substances-have soared in popularity over the past decade, resulting in a $20 billion industry with more than a thousand manufacturers marketing 29,000 products.2 A recent survey conducted by the National Center for Complementary and Alternative Medicine (NCCAM) found that approximately one-fifth of Americans use supplements.3 These products present vexing Professor of Law, University of Florida; served on Institute of Medicine (National Academy of Sciences) committee charged with developing a framework for evaluating the safety of dietary supplements (July 2001-Jan. 2002). I would like to thank Michael Nardella for his research assistance. Associate Professor of Law, Western New England College; invited reviewer of a report on dietary supplements prepared by the New York State Task Force on Life and the Law (2004). 1. Quoted in L.I. PONOMAREv, THE QUANTUM DICE 75 (A.P. Repieve trans., Inst. of Physics Publ'g 1993). 2. See Justin Gillis, Herbal Remedies Turn Deadly for Patients, WASH. POST, Sept. 5, 2004, at Al ; see also Benedict Carey, When Trust in Doctors Erodes, Other Treatments Fill the Void, N.Y. TIMES, Feb. 3, 2006, at A5; Sally Squires, Pills for Losers: Americans' Hunger for Diet-Aid Supplements Outweighs Unknowns, WASH. POST, Dec. 13, 2005, at F1. 3. See Rob Stein, Alternative Remedies Gaining Popularity, WASH. POST, May 28,

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