To Welcome
OVARIAN HORMONE THERAPY
General - risks, definition of NHRT Which OHT?  Deciding on it  Getting off it  "Natural" hormones Long term considerations
  natural progesterone 
  natural estrogens
  definition of NHRT
OTC natural progesterone creams
marketing practices
Standard caveat
Legality of product claims
Cosmetics That Are Also Drugs (FDA)
About multilevel marketing
This the standard caveat which is posted to a.s.m whenever it appears that a post is a commercial message disguised as "help" for fellow menobabes. It was written about a specific real company, with genuine metatags for that company but has been adapted to be applicable to any such company.  Note that the vast majority of such posts to a.s.m are a lead in to the selling of "natural progesterone" over the counter products. Prescription strength natural progesterone products are an entirely different matter.Note also that OTC progesterone products may not be sold in Canada, Australia, New Zealand or the UK.. 


I don't consider [a representative company] a benign organization. I too have heard that their site is down for reconstruction, but let me give you a behind-the-scenes tour of their site as it was -- the ugly truth behind what you used to see on your computer screen when you called up www.[repcomp].com: 
---begin standard caveat--- 
Reproduced below are the META tags from the [representative company's] homepage,  the hidden tags that will cause a search engine to display this page when one of the search terms is used. This hidden tag includes repetitions of various diseases to increase the chance of a "hit" -- and MLM, or multi-level-marketing (read: pyramid scheme) is mentioned six times. This company is the company whose products the poster is representing. 

These are not the techniques of a company I would choose to do business with. At best, they are designed to influence a search engine and I take them as a marker for other questionable business practices. I will post this caveat, or a variation thereof, any time anybody attempts to establish bonafides for her company or its products.

vlhb002 

---begin excerpt from [Repcomp] homepage--- 

  <meta name="keywords" content="Hormone Balance Nutrition hot flashes  PMS menopause osteoporosis progesterone breast pain Aging, Alzheimers,  Arthritis, Atherosclerosis, Bleeding Gums, Bruises, Cancer, MLM  Cataracts, Cold Feet &amp;; Hands, Diabetes Type ID, Edema,  Fatigue, Heart Attacks, , Inflammation, Jet Lag, Kidney Damage, Liver  Damage, Phlebitis, Poor Circulation, , Rheumatism, Senility, Stroke,  Stress Damage, Swollen Joints, Wrinkles Aging, Alzheimers, Arthritis,  MLM Atherosclerosis, Bleeding Gums, Bruises, Cancer, Cataracts, MLM Cold  Feet &amp;; Hands, Diabetes Type ID, Edema, Fatigue, Heart Attacks, ,  Inflammation, Jet Lag, Kidney Damage, MLM Liver Damage, Phlebitis, Poor Circulation, , Rheumatism, Senility, Stroke, Stress Damage,  Swollen Joints, Wrinkles Aging, Alzheimers, Arthritis, Atherosclerosis,  Bleeding Gums, Bruises, Cancer, Cataracts, Cold Feet &amp;; Hands,  Diabetes Type ID, MLM Edema, Fatigue, Heart Attacks, , Inflammation,  MLM Jet Lag, Kidney Damage, Liver Damage, Phlebitis, Poor Circulation,  , Rheumatism, Senility, Stroke, Stress Damage, MLM Swollen Joints,  Wrinkles"> 

---end excerpt from [Repcomp] homepage--- 

Regards, 
vlhb002

Multilevel Marketing - the ugly truth

http://www.fraud.org/internet/inttip/pyramtip.htm
Similar Tips from the National Fraud Information Center 
http://www.vandruff.com/mlm.html
A pretty good independently written article (sounds like a reformed  Amway distributor) -- with a number of interesting links, including  our old nemesis Dr. Steven Barrett of Quackwatch: 
http://www.quackwatch.com/01QuackeryRelatedTopics/mlm.html
And finally, the Old Quackwatcher Himself:

vlhb002

Check out the laws about direct selling - you too could benefit, not just the "direct sellers" - at 
http://www.mlmlaw.com
"MLMLAW emphasizes preventative law. While it may be a cliche, it is nonetheless true that an ounce of prevention is worth a pound of cure. By using this resource, you can learn more about the potential challenges you face and address them on the front-end rather than after the fact. Direct sellers can learn how to cope with them before their costs, in terms of dollars, time and general corporate resources, spin out of control." 
More sites with cautions about MLM
http://www.mlmwatch.org/
http://www.falseprofits.com/
http://www.mlmsurvivor.com/

http://www.ftc.gov/bcp/conline/pubs/alerts/lotionalrt.htm

FTC Consumer Alert
Lotions and Potions:  The Bottom Line About Multilevel Marketing Plans
also from the (US) Federal Trade Commission but this time intended for possible investors
http://www.ftc.gov/bcp/conline/pubs/invest/mlm.htm
Extract from http://vm.cfsan.fda.gov/~dms/cos-labl.html
Cosmetics That Are Also Drugs

Cosmetics making therapeutic claims that they may affect the structure or function of the body are regulated as drugs and cosmetics and must meet the labeling requirements for both. One way you can tell if you're dealing with such a product is if the first entry in the ingredient list says "Active Ingredient." (The active ingredient is the chemical that makes the product effective, and it must be safe for its intended use.) However, active ingredients are not legally required to be identified by this term. The law does require the active ingredient(s) to be listed first, followed by a list of all inactive cosmetic ingredients. 

Examples of products that are both cosmetics and drugs are shampoos that treat dandruff, fluoride toothpastes to prevent dental decay, and sunscreens and sunblocking cosmetics, including foundations that contain sunscreens. (See "Dodging the Rays" in the July-August 1993 FDA Consumer.) [ A reference elsewhere on the page also includes "hormone creams"]

A product with a drug and cosmetic classification must be scientifically proven safe and effective for its therapeutic claims before it is marketed. If the product is not, FDA considers it to be a misbranded drug and can take regulatory action. 

It is my impression that the above is not being complied with. Tishy



The website of the UK Medicines Control Agency includes the following information which may well be the basis of the UK classification of all progesterone creams as prescription products. The information itself is very similar to the FDA's, yet its application results in different outcomes.

http://www.mca.gov.uk/ourwork/licensingmeds/whatis/whatis.htm
What is a medicine?
A medicine is defined in European legislation (Article 1 or  Directive 65/65 EEC) as:

  • "Any substance or combination of substances presented for treating or preventing disease in human beings or animals".
  • "Any substance or combination of substances which may be administered to human beings or animals with a view to making a diagnosis or to restoring, correcting or modifying physiological functions in human beings or animals is likewise considered a medicinal product".
  • What is a borderline product?
    Most human medicines are clearly identifiable as such and are subject to EC marketing    authorisation procedures. However, there are some products where it is not so easy to distinguish   a medicine from, for example, cosmetics or food supplements. These are known as "borderline   products".... <snip>

    ....should any of the above contain a pharmacologically active substance or make medicinal claims (claims to treat or prevent disease, or to interfere with the normal operation of a physiological function of the human body) are [to be] regarded as medicinal).

    How legal are the claims being made for a "cosmetic"?

    This an extract from an actual asm post in response to a specific salesperson's quoting from Dr Preston's online booklet.

    Dr. Preston might be free and clear. Why? Because in his booklet at the very beginning, he has a *disclaimer* distancing himself from the opinions of the very people that he is quoting. Very clever. But if he does not stand behind the statements in his own booklet, why on earth should anyone else believe it? 

    I will repeat again though that it was indiscriminate comments by salespeople in Canada that resulted in AIM progesterone cream voluntarily being withdrawn from the market in Canada.

    I received a Sears' Mature Outlook newsletter in the mail today (Volume 5, Issue 4) that mentioned the progesterone creme withdrawal and the reason, "It's use without a doctor's approval could lead to complications" stated Health Canada's Bruce Wozny. I've also read about this in my community newspaper. Health Canada obviously feels the issue is important enough to keep at it to get the message out.

    On the weekend on looking in the back of Leslie Keaton's book, I found out that the Pro Gest creme in Britain that was being distributed by Higher Nature Ltd. was taken from the market after two months and is now available only through a physician by a patient exemption from the drug control regulations. (or some such procedure, I am of course not familiar with British regulations )

    Why would that be, [salesperson]? Perhaps you should find out before quoting any more information from Preston's booklet.

    Meanwhile in the US the media is starting to light into the sleazy MLM supplement claims. Elizabeth Hiser, the Nutrition Editor for Eating Well magazine has a piece in the January/February issue on this (p. 48) Too bad that your creme is a cosmetic and so will not be covered under the up and coming supplement labeling laws in the US.

    Kathryn

    To Welcome
    OVARIAN HORMONE THERAPY
    General - risks, definition of NHRT Which OHT?  Deciding on it  Getting off it  "Natural" hormones Long term considerations
      natural progesterone 
      natural estrogens
      definition of NHRT
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