Supplement "general" references to bodily function should be disease claims -- Gilhooley.

Executive Summary

SUPPLEMENT "GENERAL FUNCTION" STATEMENTS INTERPRETATION AS DISEASE CLAIMS rather than structure/ function claims urged by Margaret Gilhooley, Seton Hall University, in a July 15 letter to FDA in response to the agency's recent proposed rule on structure/function claims. "In my view, a statement can be considered a disease claim even if it is not a specific reference to a disease or disease symptom," Gilhooley maintains. The Seton Hall law professor served as a member of the President's Commission on Dietary Supplement Labels.