The Rant: Tested, But Not Trusted
Mega-corporation CVS has announced their plans to require third party testing on all the supplements they carry. The program, called “Tested To Be Trusted,” has been touted as an industry-leading initiative that completely revolutionizes a customer’s experience around purchasing supplements.
I think that’s a wee bit of a stretch.
Credit where due: Yes, testing to verify your products is good and a step in the right direction.
Rant where that is due: Big whoop. It’s not special. Technically it’s just satisfying minimum requirements. The problem, as I see it, is the marketing that will follow will muddy the waters around real supplement quality issues.
Today we’ll rant about “third party testing,” referring back to other pieces around supplement quality, but looking ahead at what the future will bring with this new initiative from CVS.
I’ve stressed so many times why I think transparency in the supplement industry is so important. In some of my lectures I’ve talked about a time, very recently, when the AG in NY went after some supplements sold in big box stores and identified that up to 85% of products on the shelf had absolutely no active ingredients in them. More on this in a moment...
That’s pretty wacky. How in the world can an entire industry continue to exist, making money hand over fist at all touch points, while it sells snake oil? It’s not 1890!
Unfortunately for us, that’s the BEST case when it comes to BAD supplements: you buy a product with nothing in it. In fact, count yourself lucky if your bad supplement is barren.
Bad supplements at their worst will give you much more than you bargained for. Most of us don’t realize that there are 3 types of dietary supplements, and 1 of the 3 are dangerous, “moldy cheeseburgers” (it’s a great analogy - read the article if you haven’t). They’re fraught with contaminants like heavy metals and solvents or adulterants like bootleg, synthetic chemicals. Transparency laws like Proposition 65 are rare and aren’t executed correctly, so manufacturers run amok.
What were the brands with worthless, empty supplements told to do to get their act together? Test their products.
Forgive me if I am a bit skeptical of the reasoning and the execution of this new program, but it seems this isn’t some independent thought CVS adopted because some money was burning a hole in their pocket and wanted the best for the world. More likely, this is a proactive PR move.
Again, credit where it is due: the idea of this all is great. More people need to take leadership here around quality. I just think there are a few reasons why this initiative may actually cause more problems than it solves.
1. They messed up. Twice now.
Back in 2015, the bada$$es at the NY Attorney General’s office did an investigation of herbal supplements at 4 major retailers: GNC, Walmart, Walgreens, and Target. Their findings? Four out of 5 products had 0 active ingredients. The ingredients listed on the supplement facts panel were nowhere to be found. Eighty freakin’ percent!
Egg on the industry’s face, for sure, but nothing surprising to us.
Now, CVS has bragged about how in implementing this “Tested To Be Trusted,” they’ve found 7% of their supplements didn’t meet minimum standards. That’s what they’ve reported, at least.
Do you think I'm going to celebrate a corporation putting a positive spin on the fact that 7% of their products don't meet minimum manufacturing standards? Especially after what happened before?
You have a 1 in 14 chance that a product you get from them isn’t what it says it is. In a potentially dangerous way, no less. A 1 in 14 chance that you’re just lighting your money on fire.
To me, this highlights the continued negligence of the industry. The retailers are just selling stuff without vetting anyone. The manufacturers are just producing garbage. The raw material suppliers are cutting every corner they can. No one is doing the right thing.
CVS is now watching, though, and they’ve found these problems. What about the thousands of other retailers without the resources of a mega-corporation-retail-store-and-pharmacy-that-is-now-a-pharmacy-benefits-manager-and-an-insurer-while-also-gobbling-up-every-other-vertical-in-the-pharmacy-space?
2. It's what you're supposed to do.
In the eyes of the FDA, if your logo and brand are on the label, you are a manufacturer. Technically, you’re called an Own-Label Distributor (OLD) and have numerous responsibilities that are, in most cases, the same as the contract manufacturer that’s physically making and labelling the supplements.
So many are ignorant to that fact. Any store you walk into (including ours) that has their own branded products should technically have procedures and controls in place to guarantee the product is what it says it is.
I’m not a retail giant and I have this. The option that most of us in the industry take, though, is to put our heads in the sand and run the risk that the FDA won’t come after you. They’ve increased their pursuit of OLDs, though, so I hope they don’t get accustomed to dirt sammiches.
Having processes in place to ensure your own label supplements are what they say they are isn’t “above-and-beyond.” It’s minimum competency.
Don’t break your elbow patting yourself on the back here, guys.
3. It shouldn't have to be done
Can we just take a step back to say how awful it is that a retailer is the one that HAS to do the testing of all vitamins they carry? The retailer is the last stop of the product journey, just one step before the customer. This should be sorted out already!
It would be like a car dealer saying “Hey, we’re taking a stand for consumer safety so we’re sending airbags to be tested and prove they’re in each car we sell.”
Retailers shouldn't be the ones driving change here. The fact that manufacturers can just throw stuff out into the market without first guaranteeing quality is crazy. Quite crazy and quite unique to the natural products industry.
We have this weird regulatory environment where the Food and Drug Administration has stated compliance with basic regulations is voluntary. Where the resources of the regulatory group are limited, so they can only go after the big threats: brands making horrific, unsafe claims and products that could literally kill you.
I’m all for having oversight. I am rooting for the industry, but we need to up our game. This program is a good start, but it’s maddening that this is where this pressure must come from.
How about a rant within a rant? A little rant-ception. Part of it is our fault. Resistance is two forces. One of those forces comes from us consumers. To us, supplements are commodities. We want these things to be cheap and delivered instantly. We can’t have cheap and right. When we have cheap, we get OK. We get the McDonald’s cheeseburgers .
The economic force of us demanding cheap supplements is what drives manufacturers to cut corners and use cheap, ineffective forms of ingredients. Testing things has a cost. Using better forms of nutrients has a cost.
Our cornerstone argument is people should be using fewer, higher quality supplements. Most of us can take about 70% of their current supplement regimen and throw it away. This frees up a bunch of capital that can be applied to getting better forms of important nutrients. I’d much rather someone spend some money on the right dose and strength of fish oil, then spend the same money on 4 different “antioxidants” or “anti-inflammatory” supplements.
Let’s dig into the final stage of this rant, where it all matters. This initiative is problematic because it really isn’t an indicator of quality.
4. It doesn't really tell you anything.
“What does “Third Party Testing” mean?” I ask semi-rhetorically.
Let’s break it down:
Third Party - this means someone that isn’t the actual brand. They’re paid by the brand, but they normally have to be independent. Technically a true “third party” test is done by a group with no financial or operational connection to the original organization. Technically. The term third party has stretched to mean “not the manufacturer corporation itself,” but another corporation owned by the mega-corp.
Testing - they check stuff. What stuff? That’s a great question. You can third party test for lots of things. Potency, by looking for active ingredients. Purity, by looking for contaminants and adulterants. Consistency, by testing frequently.
My concern is that the third party testing that we are bragging about isn’t thorough enough to address bigger issues. I believe the third party testing we will be settling for just covers basics: does the product have the right amount of the active ingredient with no gross irregularities.
A third party test, in most cases, is a spot check. It’s checking a small portion of a lot, one that is hopefully representative of the whole shebang. It’s a CYA thing.
Like anything, it is a game-able system. There are ways to stop this. In our compounding pharmacy, we made a random selection of a portion of each lot and blinded the compounder (they didn’t know which preparations we were going to test) as a way to make sure we were getting an accurate view of “everyday” life.
The tests that are done and goal levels are normally set by the manufacturer themselves. I can third party test for things I know won’t show up in there, and not test for things that may be present. I’m paying for the test!
Testing for and preventing adulterants from entering your supply chain is like a game of whack-a-mole with both arms tied behind your back. You’ll keep slamming your head against the thing and the mole will keep mocking your feeble attempts.
It’s my guess that the testing scrutiny will not be as thorough as required. They’ll go for low hanging fruit. Potency verification (i.e. is there really 500mg of Vitamin C). Known adulterants. I have a hard time believing they will be pushing the envelope and extensively testing for the latest and greatest threats that make their way into the supply chain.
The bottom line is that "Third Party Testing” is a phrase used that signals to people something that it really isn't. It’s another claim made by a supplement company that may lack evidence to support it.
We need open-source supplements. We need full transparency into the raw material suppliers, ingredient lists (especially inert ingredient and their amounts), and shared third party testing data before we can truly be confident that a “Third Party Tested” supplement is what it says it is.
Hopefully, someday, I can provide that with our brand!
5. It will be mistaken for quality.
In a previous rant, we Quantified Quality. I think this was a good discussion of common markers for quality different brands use to try to differentiate themselves. “USP Verified” is the big example; people think that means the product is good, it just means that basic quality controls have been in place. The unifying trait of all of these is that none of them are comprehensive enough to truly indicate quality.
Quality is more than a lab test. It’s a consideration of everything from ingredients to final product and beyond.
- Where are the raw materials coming from?
- What are the internal processes and procedures?
- Is there compliance with GMP?
- Yes, are third party tests done in a comprehensive, transparent manner?
Even this list only does one thing: it verifies that a potentially crappy product is exactly the crappy product they set out to make.
Quality must take into consideration the therapeutics. What dose and form of the ingredient is needed to actually do something?
Even the sustainability of the brand, product, and process should be considered to help slow our crumbling environment. We even go so far as to look at the ethics of the company to determine the quality of a product.
I keep re-stating all of this because I will wager $10,000 that someone somewhere will say, “My supplements are high quality because they are Tested to be Trusted.”
All a basic third party test done for compliance shows is that your product isn’t horrible.
Just because your supplements are tested, doesn’t mean they are quality.
The clinical implications are still confusing to the end user. Will a third party tested product be any more useful than the same, improperly dosed, poor quality ingredient that wasn’t tested?
They may be clean, but they’re not the steaks you think they are. They are probably no longer moldy cheeseburgers, but McDonald’s cheeseburgers at best.
A third party test is just one of a multitude of steps that are done to create a quality product. Yet, the marketing and media spin will sing a song of a higher quality product at CVS because of this new initiative.
Trusted To Be Tested
Wouldn’t it be nice if we didn’t have to worry about this? I would love to live in a world where companies innovate to make products the market wants, but makes good ethical choices along the way to get there. I believe over-regulating is a bad thing and a search-and-destroy mentality is harmful. I also believe oversight provided by the government with everyone’s safety in mind should be well funded to provide consumer protection.
Instead of a private organization spinning compliance and doing what they are supposed to into “Tested to Be Trusted,” I would love to just trust that these things are tested.
One last mini-rant about CVS and their humble-brag about their wellness programs: Just because you stop selling cigarettes, offer yoga classes while people wait (yes, they do this now), and take responsibility for your products, doesn’t mean you are a beacon of wellness. Sugary drinks, M&Ms, junk food galore show there is still a bit of hypocrisy left in you. It’s well known the cigarette thing was in response to your bigger profit goals as you gobble up insurances like Aetna and steal more patients for your pharmacy through your Pharmacy Benefits Manager.
You can position your company any way you want. Business reality at the ground level is that their stores are becoming less about personal interactions and more about volume, messaging, and profits.
Throw a rock and you’ll hit a few of their pharmacy employees who are overworked and under-appreciated, all saying they don’t have enough time to perform the most important, yet basic, quality function of a pharmacist - patient counseling.
And who the heck would want to do yoga in CVS anyway? Where gross people could stare at you? I imagine it’s hard to focus on your downward dog when your face is two inches away from dog kibble.
“Tested To Be Trusted” is a bit of the industry pressure we do need. It doesn’t solve all our problems. It still doesn’t mean people are asking the important, tough questions.
I definitely applaud the effort. If all retailers forced this and required all products to be tested, then we'd at least have a more consistent experience and we can finally move past minimum competency and start having real quality discussions.
Until then, we stick to our comprehensive Vitality Approved Standards, herding the cats, and ranting away.
Just trying to keep it real,
Neal Smoller, PharmD
Owner, Pharmacist, Big Mouth