The email below summarizes the situation. NNFA New Zealand requested that Simon Pettman of IADSA issue a press release to defend Kava when Kava was under attack in the media. Pettman refused, repeatedly, despite Ron Law providing him with complete risk assessment information.

Due to this refusal, Law raised the issue of conflict of interest re Pettman due to pharmaceutical interests he's representing as a lobbyist for not only Dennin via IADSA, but also EHPM, and ERNA- two European vitamin trade associations that are riddled with pharmaceutical interests including German interests who very well may want Kava banned because it competes with their drugs. Dennin and Pettman never responded to Law's questions about Conflict of Interest. Members of NNFA USA should ask the question "Why didn't they respond???"

You can see Dennin's response to what Law is saying here: he gets very angry. Is his anger justified? Perhaps as an employee of Pfizer, the world's largest drug company it is if he's trying to deflect unwanted attention to what Law is saying.

Here Ron Law examines the issue of IADSA showing favoritism to Australia, however he notes that the matter was recently ironed out and that IADSA had agreed to let New Zealand respresent the S.Pacific region on IADSA's Executive in 2002. Note that IADSA, via Simon Pettman later reneged on that agreement, meaning that NNFA NZ was totally disenfranchised.

Here you can see that Dennin was angry about NNFA NZ not paying full dues as a form of protest, and you can see NNFA NZ's response to that, and its a very solid response. NNFA USA members should be asking this question: "Was NNFA New Zealand given a chance to defend themselves when IADSA made the decision to expel them?" (The answer is no, they were not. There wasn't even so much as a conference call with the IADSA Board for the sake of a discussion.) The question MUST be asked: WHY was NNFA NZ thrown out of IADSA??? Look at this exchange of email:

Date: Fri, 01 Mar 2002 22:02:54 +1300
Subject: Re: CHC & IADSA
To: iadsa <IADSA@EAS.BE>,
Bruce Dennison <BRUCE@VHF.CO.ZA>,
Cc: Alfredo Gadano <NATULIFE@RCC.COM.AR>,
Loren Israelse<LDI@LDIGROUP.COM>,
Maurice Hanssen <MAURICE@HANSSEN.CO.UK>,
Michael McGuffin <MMCGUFFIN@AHPA.ORG>,
Bill Bracks <BRACKS@XTRA.CO.NZ>,
Garth Wylie <WYLIE@DSANZ.CO.NZ>,

Dear Bruce & Randy

Nice to hear from you both. Randy, it's been a long time.

A couple of brief comments...

1. I have never made "wild and unsubstantiated claims about IADSA and EAS" -- Wild, may be, unsubstantiated claims - never. I've asked hard questions (Simon will tell you that questions are not claims) such as a request for a declaration of competing interests, transparency, etc. Often people don't like answering those soughts of questions. Mostly these questions have gone unanswered. Simon said that IADSA had been asked to keep members informed about the kava PR disaster. He responded. I asked for a press statement -- Simon never resonded - I asked for a risk analysis --Simon never responded. Karl Reidel asked for a Risk Analysis - and I reinforced that call -- .... Nothing's happened. Again I ask -- why not? Simon said the executive hadn't instructed a press statement be put out; did the executive instruct the secretariate that we all be kept informed of what was happening? Why wasn't the information I sent pointing out the total hypocracy of the regulators double-speak distributed "to keep members informed"? I asked if my requests for the press statement and risk analysis had been put to the executive -- no response. Given the fact that the German manufacturers had requested that kava be made a prescription only medicine (which is as good as a ban) I asked about competing interests regarding EAS's representation. I think the word is accountability. Nothing wild or unsubstantiated here... This day and age it's simply best practice. It's the norm.

2. In Brisbane in October 2000, Randy agreed, verbally and in writing, the following "I agreed with Ron to acknowledge his e-mails although there may be times I will not reply directly to the e-mail itself." Such acknowledgement has rarely occurred nor have emails been answered -- despite the promises, which were in direct response to hard questions being asked and outrage (an absolutely legitimate and expected outcome of poor communication) at being ignored. [Letter dated October 23, 2000, attached. Also, see below.]

3. You say, "For the past two years, NNFA New Zealand has paid 50% of the minimum fee (ie $US500) as a form of protest." It is true that the jury has been out regarding the bang industry gets for IADSA's buck for some time. Jeez, what could be done with $US200,000 per year... The 50% reduction in the minimum is paid by other small associations too -- are their 50% responses due to protest or economics?

The NZ NNFA total budget is $US20,000 -- that includes my fee and all expenses - including attending IADSA meetings etc. Is there another association who has put such a proportional effort into IADSA as the NNFA NZ? I suspect not. We note that the CHC, which has a budget of perhaps $US 400,000, only pays 50% of their nominated $US5,000 fee. So please don't try and play the guilt card.

NNFA NZ has, for the last four years has committed nearly 30% of our none salaried income (about 15% of total) to IADSA affairs -- so don't talk about not contributing. The feedback I and our President got regarding my presentation in Capetown was that it was not only of the highest quality, but that it was one of the few contributions that actually offered hope for global harmonisation. I doubt there's another in the world who has put as much effort into researching and working through the myriad of issues and has looked for an innovative evidence based regulatory model that protects public health, that is appropriate to the extremely low risks associated with our products, does not kill small to medium companies through burdensome direct and indirect regulatory costs, and enables consumers to retain access to safe products, and make free and informed choice.

I think many people don't like confronting evidence when it's put in front of them. There are several industry related empires I'm only too aware of that would collapse if a simple, effective and cheap regulatory system is put in place around the world. I'm also aware that many larger companies don't mind paying high regulatory fees as they simply absorb it, and then pay for it out of increased market share as smaller competitors bite the dust. Ive had that exact scenario put to me, over lunch, by the CEO of a large Australian company.

I suspect IADSA is getting more than enough benefit from NNFA's membership -- If you are saying that our contribution and committment to making a difference is lacking, please confirm those views to this elete group... I await your response with tremendous interest on that one.

4. Your first paragraph says, "In discussion with Executive Committee members about the current divisions between Australia and New Zealand, one issue has arisen which we believe has not be dealt with adequately."

Val represents the South West Pacific at the decree of Randy. I did agree to it in October 2000 in Brisbane on the understdning that that representation was for 2001 and it would be rotated. Randy's letter states, "Val will represent the South Pacific region for the year 2001." The reason for shared membership on the executive prior to that was simply because Val thought she should be on it because Australia's more important than New Zealand (Australian's think like that) and I wouldn't trust Val with a barge pole to represent New Zealand's position objectively and fairly. Anyway, it's now 2002 and the NNFA Board has confrmed at yesterday's Board meeting that the NNFA will be representing the SWP this coming year as agreed.

I doubt that any executive could ever get a balanced view of the position in Australia and New Zealand from Val. To help you understand where the font of truth stands, let me reflect on another of your paragraphs.

You say, "In respect of your emails regarding the Herbal Regulatory Task Force being headed by Val Johanson of CHC Australia, we would like to inform you that a proposal was put forward by Val for the creation of such a group, the Executive Committee agreed to the proposal and then requested Val to head it. She did not appoint herself. The work that the Task Force is carrying out has had and continues to have the full support of the Executive Committee."

Randy, Val and I discussed Val's initiative in establishing a herbal task force when we met at the CHC conference in Brisbane in October 2000. I did not object and Randy suggested she put it to the IADSA executive. I would never in a month of Sundays have agreed to her heading a dietary supplement task force for the simple reason that Val's mindset is birthed in TGA and has never left it -- she continuously defends Australia's position with tockenism from time to time. Sometimes, when the audience changes she flexes her muscles and speaks poorly of the TGA and the 'failed' reforms. The trouble is, you can't keep crossing a busy street forever without getting hit by oncoming traffic. Her own Australian Secretary of Health noted that very astutely and very publicly commented on the CHC's ability to say one thing in one forum and another in a different forum. NNFA's experience of the CHC is exactly that. [see attached]

What totally blew me away, however, was to see a press release a few days after our meeting in Brisbane, and just two weeks before the publication of Australian minister's scathing rebuke of CHC's modus operandi, (it was known to be in-press) stating, "Executive Director of the Complementary Healthcare Council of Australia Val Johanson has received worldwide acclaim for her work in the complementary healthcare industry." when nothing of the sort has ever happened, and "At the invitation of the International Alliance of Dietary Supplements Associations (IADSA), Val has agreed to head an international task force on the global regulation of complementary healthcare products." which is nothing short of a nonsense. This statement was made on October 26th 2000; the executive considered HER request on November 9th 2000, and recorded in the minutes (attached) "The Executive Committee appreciated the idea and need of a regulatory task force but questioned the feasibility of such a task force." This is hardly the stunning announcement of International adulation announced two weeks earlier in the Australian press.

The executive also "questioned whether this Task Force should start operating now or that efforts should first be focussed on the regulatory workshop in Cape Town. The conclusion was that the Executive Committee in principle supports a Regulatory Task Force but requested a more detailed work programme and operation plan from Val Johanson." Hardly "worldwide acclaim" hardly, "at the invitation of" hardly, "has agreed to head an international task force on the global regulation of complementary healthcare products."

I was surprised to see the minutes of the executive conference call refer to a request to head up a task force for "dietary/food" supplements given Val's vehement opposition to such a categoty and to the terminology. That's partly why I asked Simon for a copy of Val's request which I presume was in writing because Val did not take part in the conference call (according to the minutes.) Simon has not responded. Nor has he responded to my request for the minutes of the 2001 conference calls prior to the AGM in Capetown.

As we all know, the HERBAL task force was agreed to in Capetown 2001, some five months AFTER the infamous "Honoured" press statement.

Why have I mentioned this? -- because the email, to which I'm replying, seems to be trying to infer that all is sweet with the journey to Val's appointment, at that I'm telling fibs, and therefore unreliable and therefore shouldn't be on the executive.... Please tell me I'm wrong.

To help you see the picture more clearly -- your email says, "we would like to inform you that a proposal was put forward by Val for the creation of such a group, the Executive Committee agreed to the proposal and then requested Val to head it. She did not appoint herself."

I totally agree with this statement, expect for the second-last bit -- IADSA did not request that Val head it -- it affirmed her request to head it. I have never said that she appointed herself. I would have thought Simon would have picked that up (legal training, accuracy and all that.) The approval and endorsement of Val's chairing of the task force came at the end of March 2001 at the AGM, some five months AFTER the public self-acclaimation.

The public proclamation that Val had "received worldwide acclaim for her work in the complementary healthcare industry" is a myth.

The statement, "At the invitation of the International Alliance of Dietary Supplements Associations (IADSA), Val has agreed to head an international task force on the global regulation of complementary healthcare products" is a myth.

The statement, "The IADSA invitation follows a special award for services to the industry presented to Val at the complementary healthcare industry's annual Expo in Brisbane (October 21-22)." ie between the 23rd and 26th of October 2000, is a myth.

Why are these myths?

Simply, because,

a) they never happened, and
b) allowing for sloppy journalism, any request wasn't even considered until two weeks later and approval wasn't given for another 5 months.
c) The appointment was limited to herbals and not the whole industry product range.

So, why's this impoprtant? Again, that's simple -- it is prima facie evidence of the antics New Zealand has had to put up with in trying to negotiate an appropriate regulatory system. Despite extensive communication with IADSA (initially without cc-ing) this issue has been ignored, and what's more IADSA has sided with Australia and ignored New zealand's requests for help and assistance.

You say, "If you continue to view IADSA as an organisation which is not serving the interests of your members, then you should be considering carefully whether you wish to remain in IADSA membership."

If IADSA excludes New Zealand from debate and discussion on issues surrounding harmonisation simply because another party has disqualified its spokesperson from participating, then surely we have every right to state categorigcally that IADSA has not acted in our interest.

Val will utter howls of protest, but I can produce any number of witnesses to testify to the fact; the simple fact is that Val has meddled in New Zealand industry affairs and conspired to prevent the NNFA from participating fully and effectively in the discussions taking place.

The NNFA Board met yesterday and unanimously stated that I go to Vancouver to put New Zealand's excellent researched and considered position on the international table. It unanimously reaffirmed the NNFA's position on harmonsation, and rejected the Australianisation of New Zealand's industry... Even Val in Sth Africa last year, said that Australia's regulatory system was international worst practice -- why on earth would New Zealand consider such a system for a minute, why on earth would Val defend it? Why on earth would IADSA give support to it?

IADSA's integrity is at stake here. I'll be in Vancouver, and will have, by then, presented my research and NNFA's regulatory model in three continents. To deny me the opportunity to present the objective, evidence-based regulatory model developed over four years of very fractious harmonisation talks at the IADSA workshop would be unjust and unfair. What's more, this is real -- this is what the whole global industry is facing -- surely, this is exactly what IADSA is about -- surely there is no more reason for IADSA to take a particular interest in trans-Tasman affairs because if TGA wins here then it will become the European model and then the global model. TGA is not chair of PIC/s and the ICH devices task force for nothing -- its mission is to be adopted as THE global model.

If IADSA backs Val on this then it must, by definition, change its name to something like IACMA - International Alliance of Complementary Medicines Associations as it will have finally given up its stated position of regulating dietary supplements at the food end of the spectrum -- Val rejects that totally -- be warned.

Finally, I leave you with Senator Tambling's own words, "One could be forgiven for believing that the CHC message changes depending on the audience." He was bang-on!

So there you have it. I'll be in Vancouver, and one way or another, my research and New Zealand's regulatory position will be presented. I recently was given a 90 minute audience with the New Zealand Attorney General. We discussed a 50 page summary of the tortuous harmonisation process that's been underway for four years -- I've been invited to develop the paper further and present it to all members of the New Zealand Parliament. I have no doubt whatsoever that New Zealand will end up with a regulatory system that will provide a useful global model -- I suspect Australian industry will continue to labour under its current burdensome and expensive system with assistance from CHC - although the current internal audit may affect that.

Given that IADSA has provided not one ounce of assistance to New Zealand's efforts, even when asked, and yet has sided with Australia's efforts to silence New Zealand's pro dietary/food voice, the executive of IADSA itself needs to ask, "Are we serving the interests of our members?"

I'll make you a deal. You've got until the Vancouver meeting to prove me wrong on this. Provide me with the evidence that I'm wrong, and I'll get up at the meeting, apologise, and take no further part in IADSA affairs. If you can't do that then I look forward to participating fully in IADSA workshop, including presenting the NNFA's position, and as a member of the IADSA executive in 2002.

Good luck - it's your opportunity to stand on the side of truth and put the DS back into IADSA.

For the record, I'm still appalled at the lack of an IADSA public response to Kava -- am I missing something here?

I've attached some NNFA documents, and some OHP's on our proposed regulatory models that the CHC is so vehemently opposed to. Your collective thoughts would be welcome.

So there you have it -- I guess the ball's in your court...


Ron Law

PS, You'll note that I've added a few more names to the e-list.

Bill Bracks is NNFA Chair of the Regulatory Task Force

Warren Sanderson is immediate past President of the NNFA and member (and former chair) of the NNFA Regulatory Task Force. Warren was at the inaugural meeting in London in 1998 and moved the modification of the proposed name to that adopted - the International Alliance of DIETARY/FOOD Supplement Associations. This was the meeting where it was agreed that IADSA (Acronym suggested by the NNFA) be an alliance of Associations -- not big companies.

Gary Mabey is Chair of the International Nutritional Products Association (NZ) - an importer group that formed before my time. It would be fair to say that historically INPA and the NNFA have not been friends (reasons - before my time.) We are now, however, very united in our position regarding both the continual meddling in New Zealand affairs by the CHC, and in our vision for a future regulatory environment in New Zealand.

Garth Wiley is Secretary of the Direct Sellers Association and chair of the New Zealand Dietary Supplement Consultative Group - a loose umbrella discussion forum of wider industry interest groups.

Janice Priest is a natural healthcare practitioner, is editor/owner of a large Australasian lifestyle magazine, and active leader in Citizens for Health Choices

Paddy Fahy is Chief Executive Officer of the New Zealand Health Practitioners Charter, the peak body for associations representing about 6,000 practitioners.

All of the above have endorsed the NNFA's position, and my research, and have endorsed the regulatory model that industry has developed.

You are welcome to communicate with any or all of them to discuss the above.

I've included Karl because I've mentioned him in the email. I've included Euan Murdoch because he's the President of CHC and is fully aware of the infamous press statement -- he needs to be reminded that the truth and perception are not necessarily the same.



The following at http://www.soc.iastate.edu/sapp/soc415.risk.html and http://www.fao.org/WAICENT/FAOINFO/ECONOMIC/ESN/riskcomm/riskcom5.htm are worthy of reflection. It's part of a discussion on the need to understand outrage in risk management terms.

""Whether seeking to reduce or create outrage, risk communicators first must consider the position of the public. We might characterize the public, or "consumer," as being ignorant, not fully trusting of science, industry, or government, and sensitive to unfavorable information about new technology. All too often, those who create technology and attempt to gain adoption of it consider these characteristics of the public to be "unfavorable" ones. In contrast, we need to think of these attributes as natural and even "favorable" characteristics of consumers. Let's think about these characteristics.

Ignorance: We all are ignorant. Although I have approximately 22 years of formal education and a Ph.D. degree, I could not possibly tell you how this computer I am working with operates.

Trust: Do you have 100% trust in your government, in every thing it tells you, all the time? I hope not! After all, in a democracy we citizens are supposed to challenge, ask questions, double-check what we are told. Otherwise, a democracy will not work. Neither do we have 100% lack of trust in our government because democracies require that we work with each other.

Fear: Suppose you are walking a path through the woods and nearby, on the ground, you hear a rustle in the leaves. Do you stop suddenly to look? Of course you do; our species would not have survived on this planet this long if we did not check out potentially harmful uncertainties.

So, you see, ignorance, lack of trust, and listening to naysayers about technology are perfectly natural, even expected behavior. No need to become frustrated and angry that a skeptical public at first hearing about a complex new technology hesitates to adopt. Instead, it is essential to learn how to communicate about technology to an ignorant, not fully trusting, wary public. After all, that's us! ""

""The risk analysis process
Risk communication is essential throughout the risk analysis process. It was clear to the Consultation that if risk communication is to be effective, then several key issues dealing with the process itself, must be addressed.
These include:

. Involvement and interaction of all interested parties.

. Use of persons trained in risk communication.

. Assurance that the risk communication is received and understood.

. Fostering transparency during the entire process. ""

Please don't try and dis-involve, or dis-interact with genuinely and legitimately interested parties -- some of us are fully trained in spin-doctor detection methods and techniques -- such SD practices usually are exposed, and simply create further outrage.


----- Original Message -----
From: "iadsa"
To: "Ron Law" ;
Cc: "Alfredo Gadano" ; "Anthony Bush"
; "Bill Lee" ; "David
Seckman - NNFA" ; "Loren Israelsen" ;
"Luc Claessens" ; "Maurice Hanssen"
; "Michael McGuffin" ; "Shuhei
Yoshida" ; "Val Johanson"

Sent: Friday, March 01, 2002 1:59 PM
Subject: NNFA NZ & IADSA

To: Ron Law

cc: John Blanchard (NNFA New Zealand)
IADSA Executive Committee

From: Randy Dennin
Bruce Dennison

Dear Ron

In discussion with Executive Committee members about the current divisions between Australia and New Zealand, one issue has arisen which we believe has not be dealt with adequately.

Over the past 2-3 years, you have sent numerous emails across the IADSA network which have made often wild and unsubstantiated claims about IADSA and EAS. The tone and approach you use make no positive contribution to IADSA and, on the contrary, damages the cohesion of IADSA and the motivation of those that work with it. Your most recent response to the Secretariat and others implying that pharmaceutical interests had prevented IADSA issuing a press release on kava kava is a case in point.

For the past two years, NNFA New Zealand has paid 50% of the minimum fee as a form of protest. If you continue to view IADSA as an organisation which is not serving the interests of your members, then you should be considering carefully whether you wish to remain in IADSA membership.

In respect of your emails regarding the Herbal Regulatory Task Force being headed by Val Johanson of CHC Australia, we would like to inform you that a proposal was put forward by Val for the creation of such a group, the Executive Committee agreed to the proposal and then requested Val to head it. She did not appoint herself. The work that the Task Force is carrying out has had and continues to have the full support of the Executive Committee.

With Kind Regards

Randy Dennin Bruce Dennison
Chairman Vice Chairman