It is time to CARE about Supply Chain Accountability

October 9, 2018

Now, more than ever, supply chain accountability is imperative. It is not acceptable for a dietary supplement brand to turn over all responsibility for sourcing to the contract manufacturer without any brand owner involvement in the process. Quite simply the brand owner must pay attention to the ingredients going into their product. The liability and risk should something go awry ultimately lands with the brand, so it is an absolute abdication of responsibility for the brand to not know or CARE what’s in their products. The four aspects to CARE are:

  • Compliance
  • Awareness
  • Responsibility
  • Efficacy


Many aspects of cGMP require the brand owner to know the full extent of the process going into the manufacture of a product, regardless if a contract manufacturer is involved. The FDA has provided repeated Warning Letters detailing this fact (FDA Warning Letters)  and I wrote about this a couple of months ago (A Must Read Warning Letter). The Food Safety Modernization Act is also a consideration for brand owners as this legislative action requires the brand to have traceability of their ingredients in case of contamination or recall (FDA FSMA Guidance).


It is as essential to know the source and supply of an ingredient as it is to understand the intended benefit of the ingredient. Concerns such as the impact of weather, importation issues, reputation and stability of supply, and other issues should go into the decision to launch a product with chosen ingredients.


The responsibility of supply chain awareness is not only prudent from a compliance standpoint but also from a position of economics. It is important to have direct dialogues with ingredient manufacturers to know price and use trends that may influence future supply. In addition, some marketing positions and claims can only be ensured by the use of specific ingredients.


Trust Transparency Center recently tested 150 Amazon brands using 3rd party analytical laboratories. The products were ordered directly from Amazon and sent to the independent analytical lab. The results found over 60% of the products tested failed to meet Supplement Facts label claims as provided on the bottle. We contacted the brands with failing label claims to make them aware of the issue and ask them to engage with us to talk about ways to remedy it. The majority of the responses received to date from the brand owners, unbelievably, have indicated a need for the brand owner to contact the contract manufacturer for any additional information. Few brands have had assay information testing readily available for reference. The standard of assay assurance should be a paramount concern for any brand committed to providing a meaningful and customer-centric product offering. Many of these referring companies were woefully unprepared to meaningfully discuss their product quality. This lack of accountability presents not only a liability for the company involved, but the broader industry and the retailer ‘gatekeeper’ as well.

More information discussing these findings will be presented in future articles.

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Lori Diez

Lori Diez combines compassion and excellence to lead organizations to their next level. A small-town Texas childhood taught her the value of hard work and relationships, which she uses to foster teamwork that brings results that have transformed cultures and programs to their highest potential. Her successful career in pharmaceutical and nutraceutical sales leadership and event hosting has prepared her to deliver results as the COO of TrustTransparency, where she uses her industry knowledge to ensure that the company’s operations run smoothly as they support nutraceutical companies in their mission to help others. Lori’s passion for charity reflects her belief that individuals working together can change the world, no matter how small their contribution to the effort. This year, she looks forward to continuing over a decade of service at the Houston Livestock Show And Rodeo, where she will be the Chairman of the Livestock Committee.

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Glynnda Steinford

Glynnda Steinford, Trust Transparency Consulting’s Director of Customer Relations, brings over four decades of healthcare experience to her vital role in client engagement and relationship building. Her diverse background spans from administering medical groups to impactful stints in pharmaceutical and nutraceutical sales, all underlined by her degree in Healthcare Administration.

At the heart of Glynnda’s work is her talent for nurturing long-term connections, a skill she leverages to enhance client experiences and partnerships within the consultancy. Beyond her professional commitments, she enjoys life’s simple pleasures, whether it’s her love for cats and cooking or her ventures into golf, always prioritizing cherished moments with family and friends. Her personal interests echo the dedication and warmth she extends in her professional network, making her an invaluable asset to the team.

Caiti Dowden

Caiti Dowden stands as a crucial pillar at Trust Transparency Consulting, bringing invaluable insight and expertise to her role as Senior Executive Assistant’ since her start in 2018. With an academic background from Sam Houston University and a career shift from education to the nutraceutical sphere in 2010, Caiti has cultivated a sharp acumen for dissecting industry trends and bolstering strategic decision-making.

Her transition from Data Analyst reflects her growth and deep understanding of the business landscape. Caiti’s commitment goes beyond professional excellence; she thrives on balance, drawing from her rich life outside of work to enhance her organizational contributions. Whether it’s family time, volunteering, or rooting for Houston’s sports teams, she believes in embracing experiences to fuel her professional creativity and insight.

In her current role, Caiti’s dedication to dynamic business analysis and operational support proves her to be an irreplaceable asset to our team, embodying the synergy of personal enrichment and professional success.

Pam Hilpert

Pam Hilpert, Chief of Staff at Trust Transparency Consulting, has been instrumental in the firm since its inception, leveraging her 17 years of accounting experience, including a significant tenure in the nutrition sector. Her collaboration with Scott Steinford spans various successful ventures, emphasizing her integral role in the company’s financial and strategic initiatives.

An alumnus of Sam Houston State University, Pam holds degrees in both Business Administration and Accounting, as well as an MBA, adding academic heft to her practical industry insights. Beyond her professional prowess, Pam is passionate about family, enjoys live music, delves into quilting, and volunteers at her church, reflecting her well-rounded life.

Her multifaceted expertise and longstanding dedication make Pam a cornerstone of Trust Transparency Consulting’s operational strength and team unity.

Scott Steinford

Scott Steinford, a trailblazer in strategic leadership, boasts a certified M&A background, having navigated companies from their genesis to industry prominence. His brainchild, Trust Transparency Consulting, born in 2007, stands as a testament to his dedication to ethical business practices and strategic foresight, offering industry stakeholders invaluable guidance.

Beyond founding and steering companies, Scott has enriched the business landscape with his insightful keynotes and prolific written contributions, emphasizing his commitment to elevating industry standards. His executive tenure shines in roles as CEO or President of for-profits like ZMC-USA and Doctor’s Best, extending to significant contributions in non-profit sectors.

Notably, Scott’s influence is a driving force in the CoQ10 market, where his leadership has significantly bolstered the ingredient’s global presence. His roles in various capacities, including as a New Hope Ambassador, keep the community informed, providing in-depth industry reports and insights.

An active advocate within professional associations and an Editorial Advisor for leading industry publications, Scott’s expertise is both recognized and sought after. With academic roots in Pre-Law and a Master’s in Law, his journey transcends textbooks, embodying real-world business acumen and transformative leadership.

Scott Steinford merges visionary entrepreneurship with principled leadership, creating a legacy of innovation, growth, and unwavering commitment to industry excellence.