(October 2, 2002)- Opinion of John Hammell, IAHF:


Members of NNFA USA Should scrutinize their bylaws, and vote out Capsugel on a basis of Dennin wrongly expelling NNFA NZ from IADSA, and on a basis that he played a key role as former co chair of NNFA's International committee in misleading members of NNFA into believing that DSHEA is "safe" from international harmonization. The Congressional Research Service has indicated otherwise to Congressmen Paul and De Fazio.

NNFA's CODE OF ETHICS: http://www.nnfa.org/aboutnnfa/codeofethics/index.htm Under this code members pledge to "increase nutritional information" and "enhance consumer rights"

Question: Is Randy Dennin (Capsugel/Pfizer) in fact doing this? On what legitimate basis was NNFA NZ expelled from IADSA? Is IADSA endorsing Australia's highly restrictive medicalized regulatory model over New Zealand's Food based regulatory model as Ron Law of NNFA NZ says IADSA is? In his capacity of former co-chair of NNFA USA's International committee, and in his current capacity as a member, is Dennin (Capsugel/Pfizer) truly defending the interests of ALL members of NNFA USA? Is it REALLY true (as Dennin/Capsugel/Pfizer) claim that DSHEA would "never" be threatened by international harmonization?

NNFA BYLAWS: http://www.nnfa.org/aboutnnfa/bylaws/BYLAWS.pdf

Especially see Article 14.3 Conflict of Interest Disclosure... Shouldn't NNFA Members inquire as to whether or not Dennin filled out a conflict of interest disclosure form as a member and former co chair of NNFA's International Committee, as required in this bylaw? In so doing, did he state that he was an employee of Warner Lambert, until 2000 when Warner merged with Pfizer? Is he currently stating in a conflict of interest disclosure form that he is an employee of Pfizer? How extensive is this conflict of interest disclosure form? Does it ask the member to list the names of pharmaceutical drugs that their company sells which compete in the marketplace with dietary supplements? If not, why not? How can NNFA be certain that a member is adhering to NNFA's Code of Ethics if they do not attempt to determine this via a conflict of interest disclosure form???

Has a member of NNFA ever been expelled for violations of either the Code of Ethics or the Bylaws? If not, why not? How can NNFA claim to be enforcing their Code of Ethics and their bylaws if they allow pharmaceutical companies to join, hold key committee chairmanships, and be on key committees??? Shouldn't every dues paying member of NNFA demand answers to these questions in light of this information? Granted, I am stating opinions here. I am not asserting that everything I am presenting here is a totally unasailable fact- but shouldn't these questions be asked?

Take a look at Article 3.9, Expulsion. A member can be expelled "for cause, after notice, and a reasonable opportunity to be heard, by the affirmative vote of 2/3rds of the Directors present and voting at a meeting at which a quorum (simple majority) is present and for which notice of the proposed expulsion has been provided. Cause shall be limited to failure to pay dues, failure to continue to meet the qualifications for membership, or actions which are detrimental to the best interests of the Association."

It is IAHF's opinion that Pfizer's gameplan is to have Dennin make contributions via Pfizer subsidiary Capsugel to numerous dietary supplement industry causes and functions, and to join numerous vitamin industry trade associations, and to take actions via such things as chairmanship of IADSA to create an APPEARANCE of loyalty to the industry in order to keep people from looking "too closely" at the position of hardliners (such as Ron Law or John Hammell) regarding matters such as what IADSA is ACTUALLY doing, and such as whether Dennin's advice to members of NNFA via his being on their International committee are REALLY in the best interests of ALL members of NNFA... Politics is the manipulation of perceptions. It is IAHF's opinion that Pfizer did not become the world's #1 pharmaceutical company by accident- they go there by being very shrewd businessmen, and that includes having a very solid grasp of politics- and how to manipulate perceptions.

2. If NNFA Won't Expel Capsugel (Pfizer), Members Fearing that IAHF May Be Correct should work with IAHF to form a new trade association and:

A) Push for a GENUINE oversight hearing on the Codex vitamin issue, since the first hearing was whitewashed

B) Get Behind Legislation such as Ron Law's American Sovereignty Restoration Act, intended to remove the US from the UN in order to protect US sovereign law, particularly DSHEA

C) At the international level, immediately assist the UK based Alliance for Natural Health http://www.alliance-natural-health.org/ and the UK based Health Freedom Movement http://www.healthfreedommovement.com to do the following:

1) Hold huge demonstrations throughout England, especially, also Holland and Sweden against the EU Directives

2) Get the EU to make extensive amendments to the Medicines, and Herbs Directives in order to protect consumer access to supplements

3) File suit against the European Commission over the Vitamin Directive which unfortunately passed.

4) Put massive pressure on the FDA to stop participating in the creation of a finalized Codex vitamin standard in accordance with the will of the American people as clearly expressed via the amendment to the FDA Modernization Act of 1997 wherein the harmonization language of the bill was amended to exempt dietary supplements. IAHF has evidence in the form of a letter from FDA Attorney L.Robert Lake that FDA intends to IGNORE our amendment, and to press on at Codex REGARDLESS of the will of the people and the will of Congress.

5) Via IAHF and allied groups world wide, form a NEW UN NGO group to REPLACE IADSA since IADSA can't be trusted.

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