Clinical study parameters can turn a dietary supplement study into a drug study in FDA’s view, triggering Investigational New Drug (IND) requirements. In one FDA Bioresearch Monitoring investigation, a study on a product containing multiple dietary supplement ingredients was treated as a drug because it ...
Welcome to Warning Letter Wednesday
A weekly exploration of FDA warning letters and enforcement trends
Every Wednesday Asa reviews interesting warning letters and other enforcement trends. He’s been writing this each week for 4+ years, and it is a labor of regulatory love.
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Recent Warning Letter Wednesday Posts
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Mar 04
Before & After Pictures Require Substantiation
This is a cautionary tale about a skincare company that relied on a third-party app score and before-and-after images, leading ...
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Feb 25
Homeopathic Manufacturing GMP Issues
This is a story about a homeopathic manufacturer that was cited for several GMP issues, and about a discarded “sticky ...
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Feb 18
Nicotine Caffeine Drink Product Receives Warning Letter
A nicotine and caffeine drink company was cited for making disease claims and for selling a “new tobacco product.” I’ve ...
Who is Asa Waldstein?
Asa Waldstein is a 24-year veteran of the dietary supplement industry, with experience spanning manufacturing, marketing, and regulatory compliance. He is the principal of Apex Compliance, a software company dedicated to streamlining regulatory marketing compliance for the dietary supplement and natural products sectors. Asa also leads Supplement Advisory Group, a boutique consultancy focused on marketing risk analysis, labeling, and practical compliance strategies for websites and social media. Asa has helped oversee three FDA GMP inspections with no 483s and was honored with the 2023 AHPA Herbal Hero Award and the 2024 What's Up Supps Policy and Change Agent Award. He currently serves as Chair of the American Herbal Products Association’s (AHPA) Technology & AI Innovation Committee.
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