Monday, December 30, 2019 1:58:09 PM
The FDA's problem is that they don't have clear legal precedent to proceed (because of the DSHEA definition of dietary supplement) and they don't have the gonadal fortitude to do something that would be perceived as "radical." The pressure on FDA is immense and they cannot sit all year. They either need a tweak to DSHEA law, or publish some interim guidance.
I just got a direct mailer from Lord Jones CBD and they only sell 2 lotions. I gotta ask: why would anyone use a lotion? I wouldn't. I will use balm (which is different from lotion). But CBD lotion? Shampoo? Moisturizer? Just speaks to the ignorance and confusion of the customer base. FDA could help change that by requiring the all companies enter a registry where they provide information (e.g., do they have SOPs? Operate under GMP? Have an adverse event/quality complaint system? How many mg of CBD in each product?). Most of th 2700 poseurs would fall away after this. And there is no new capital for loan. So let them go away and the cream rises to the top.
MT
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