Re: Cosequin is not a drug

Truman Prevatt (truman.prevatt@netsrq.com)
Mon, 9 Dec 1996 10:26:05 -0400

>Tom -
>
>I am not sure what you are taking issue with. I don't know what the legal
>defintion is of neutraceuticals. I did not define it as something the
>body produces. I was taking issue with that definition. Or, are you
>saying any product the body produces should be unregulated (insulin, growth
>hormone, testosterone, etc.) I suspect the legal loophole has to do with
>marketing. As long as the manufacturer makes no claims for its product, it
>is essentially unregulated. But of course it can encourage someone to
>write a book about it. Anybody out there with experience in drug
>regulatory affairs?
>
>Incidently, I do not consider Cosequin to be the worst abuser of this
>loophole. My understanding (third hand rumor) is that they are actually
>doing some controlled testing.
>
>Duncan Fletcher
>dfletche@gte.net

If you are going to state benefits of a product then you have to prove it
to the FDA through extensive (and expensive) testing. Just because it can
be bought over the counter doesn't mean it is not a drug - many of the
items you see in the durg store shelves were once controlled through
perscription.

Adaquan IM is not available over the counter but it is basically the same
components as Cosequin. Adaquan has, however, undergone extensive testing
and can prove it claims. Consequin has not undergone extensive
statistically valid testing and hence cannot make definite claims to its
effectiness. There was some initial research that suggested that the
active compound in Consequin is not bioavailable to the horse when taken
orally. Auburn Univ. recently performed research that indicted that
Cosequin was in fact effective.

At a recent clinic the speaker, a vet, stated the benefits of using Adaquan
in performance horese. She stated that in her opinion Adaquan was a
nutrient and not a drug. When I mentioned this to my vet his comment was
"really?" According to him, Adaquan has a definite pharmacological effect
and is accordly a drug. BTW he also considers Cosequin a drug for the same
reason. He even considers high levels of Vit C a drug for the same reason.

There are many companies in the supplement business that are trying to
"skirt" the FDA testing criteria by calling their products "nutrients"
while claiming pharmacological effects. If you don't believe this just go
into a local GNC and ask what they have for condition X, and put your
favorite condition in X. This situtation got to the point that last year
congress was considering legistation to control the supplement indurstry.

This situtation is not necessarly bad unless the intent is to defraud, and
most supplement companies are good companies.

I think most of us agree that the AERC drug policy is a good policy. It's
definition of drug is extremely board. For example while MSM is considered
my many to be a nutrient, if I am not wrong, if you tested for MSM you
would be in violation of the AERC drug policy. The problem is not if
something is or is not a drug - drugs are not inherently bad. The question
is really what compounds can be used safely and when they can be used on
the endurance horse. Our goal should be to get the best performance from
our horses while protecting the horse and protecting the image of endurance
riding. If your horse cannot complete a ride without taking MSM the day of
the ride then he should be retired.

Truman

Truman Prevatt
Sarasota, FL