Dec 02 2011

You Too Can Be a Snake Oil Salesman

Almost every day I get e-mails asking me about some new supplement, health product, or new treatment. They seem to be endless, and there is no way I can get to them all. That’s why it is so important to understand how to assess such claims – the whole “give me a fish and feed me for a day, teach me to fish and feed me for life” thing.

This morning I was asked about a product called Neurosafe, which is claimed to be a “seatbelt for the brain.” Specifically they claim that their supplement “may” help protect athletes from brain injury and help recover faster. Are the claims credible? Before I get to this one product, let me give you a how-to guide for selling snake oil.

The first thing you need to realize is that it doesn’t matter at all what you put in your product. The easiest thing to do is use everyday vitamins in low to moderate doses. Just look at Airborne – you can sell a multivitamin and pretty much make up whatever claim you want for it.

If you want to get fancy you can put other nutrients in there as well. Amino acids, fatty acids, and minerals are all good. If you want to include herbs that is yet another option. Again – it doesn’t really matter which ones you choose.

Next come up with a marketing angle, some target demographic or condition you want to claim to help. Name your product something that suggests it will help with the identified condition. Then simply claim that your product “may” help, or that it will boost the immune system or support the bodies ability to heal from or deal with the condition.

These types of claims are called “structure function” claims – a massive loophole invented as a gift to the supplement industry. In the US at least you can make such claims with carte blanche, without any need to provide evidence to back up the claims.

That is all you really need to do – you now have a supplement you can sell with pseudo-health claims. The FDA requires that you slap on what we call the “quack Miranda warning” – “these claims have not been reviewed by the FDA,” etc. But most of your prospective customers will likely not even notice the boilerplate.

If you want to take the even easier route, don’t even bother with supplements. You can market anything – a silly piece of rubber and plastic – and make whatever structure function claims you wish. You can sell magic beans – whatever. It does not appear to matter.

Marketing your product is the key. Testimonials work the best, especially if they are from a celebrity. If you are marketing a product for any performance or sports related condition, then a sports star is a must. Don’t worry, they are easy endorsements to get, and it’s a worthwhile investment. Cherry picking and the placebo effect with guarantee that you can find testimonials to support whatever claims you want to market. Don’t worry about the fact that your product does not actually do anything.

If you want to go that extra step, then you can pretend that there is scientific evidence to back up your claims. There are two routes to take for this. The first is to simply search for basic science research that is already published – just search on the name of your ingredients and plenty of studies will come up. These will be studies in test tubes or animals, mostly. Then extrapolate wildly from whatever effects are seen in these studies. Anything that affects any component of the immune system and you can claim your product “boosts the immune system.”

For supplements all you have to do is find out in what part of the body they can be found, then claim that supplementing that nutrient will enhance that body function. Muscles are made of proteins, right. So eating protein will build muscle. Brains are made of lots of things, including glycoproteins and lipids, so eating these things may boost brain function. It’s that simple.

For “magic bracelet” type products it’s even easier. Your product essentially works by magic, so just throw out a bunch of technobabble that doesn’t mean anything. Keep up with the latest buzzwords for maximal effectiveness, but here are some suggestions: “Balances your energy frequencies,” “Quantum whatever,” “Works on the nano cellular level, “Resonates with your connecticazoit.” Make sure to include at least one reference to “quantum” or “energy” and you’re good.

For more ambitious marketing you can do an actual clinical trial. Don’t bother with FDA applications – those kinds of trials are difficult and expensive. Just do a simple “in house” study that is small and poorly controlled and the placebo effect and experimenter bias will be sure to get you the results your marketing team requires. Even better you can outsource to an independent company that will do all that for you. Just let them know what results you want.

Another option is to give an MD or PhD a share of the company for their endorsement. Be careful that they don’t make any actual claims. They will be good for citing irrelevant research. If an MD they can say that they recommend this kind of treatment for their patients with…whatever your marketing the product for.

Now here’s the best news – the internet makes is cheap and easy to get up and running. A slick website can bring together all of these pieces – flashy claims, celebrity endorsements, lists of irrelevant studies or ginned-up clinical tests – and you can sell right from the website. Remember to hide the FDA required warning in small print at the bottom.

Let’s see how Neurosafe stacks up. The website claims:

NeuroSafe NeuroProtective Drink – “Seatbelt for Your Brain”. World’s Only NeuroProtective Drink for Athletes that may Reduce Brain Injury and help you Recover Quicker from Concussions.

It has a good name and catchphrase. They know their target demographic and have a compelling structure function claim, complete with the weasel word “may.” However, I do not see their mandated FDA disclaimer.

They have an endorsement from NFL wide receiver Wes Welker (ach!  – from my own Patriots). It looks to me like their marketers wrote his endorsement for him – good move.

How about the science? Well, they don’t list any studies or even specific ingredients. They just say “scientifically proven neuroprotective compounds.” That’s nicely vague. “Neuroprotective” is also a fabulous buzzword, and seems to be the center piece of their marketing strategy.

What’s the evidence? Since they don’t cite specific studies or ingredients, it’s hard to be very specific. But in terms of neuroprotective supplements in general, nothing has been proven in appropriate clinical trials. There are a few agents that are interesting, like Coensyme Q10, for example. They have promise in some animal models, but have not panned out for the most part in neurological diseases. For concussion and traumatic brain injury there is some preliminary evidence that omega-3 fatty acids may be helpful.

I’m surprised the website doesn’t specifically exploit this preliminary evidence. Maybe they will get to it, or maybe their product doesn’t contain either of these ingredients.

It isn’t a crazy idea that certain nutrients might help the brain recover from injury. In times of metabolic stress certain nutrients may be in higher demand than usual, and supplementing may be useful. This is why specific nutritional supplements are given post surgery, or to pregnant women.

The problem here is that “neuroprotection” is being used in a vague way as a marketing term, without specific scientific evidence to substantiate specific claims for specific ingredients. Also – we do not yet have well-controlled clinical trials to substantiate any specific claims for neuroprotection, or improved outcome in head injury.

Most effects that seem promising at the basic science or preliminary level do not pan out when tested in rigorous clinical trials. So it is highly deceptive to base clinical claims on such preliminary evidence. Unfortunately, the laws allow for just that.

The makers of Neurosafe do not have to do any research, or defend their pseudo-claims with evidence. All they need is a slick website and a celebrity endorsement. That they have.

 

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33 responses so far

33 Responses to “You Too Can Be a Snake Oil Salesman”

  1. kakaydinon 02 Dec 2011 at 11:50 am

    I love these “how to”-style posts. Pulling back the curtain on pseudoscientific operations demystifies the whole industry. Superb anti-credulitant.

  2. Jim Shaveron 02 Dec 2011 at 12:34 pm

    Steve, Wes Welker plays for the Patriots; I don’t know about Was Welcher. :) The Neurosafe site does have his name spelled correctly.

    Also, isn’t it “carte blanche” (“blank check”), not “card blanche”?

    Sorry for the pedantry. Loved the article and the advice for starting my own alternative medicine company. Thanks! Maybe I’ll cut you in on the profits.

  3. DevoutCatalyston 02 Dec 2011 at 1:15 pm

    Can’t we do multi-level marketing? Let other people screw their friends, while we rake in the dough.

  4. Steven Novellaon 02 Dec 2011 at 1:15 pm

    Thanks – I did not have time to spell check this morning, but those corrections are now made.

  5. nybgruson 02 Dec 2011 at 3:20 pm

    I’m pretty sure it was Phil Plait sometime a year(ish) ago that had a post about how incredibly easy it would be for skeptics like us to make money hand over fist. We know enough science to make things seem legit and we know all the cognitive tricks, traps, and fallacies to exploit. He noted that the one catch with this thing we call “ethics” and “morals.” Though the religious folks keep telling me I can’t possibly have any since I don’t believe in their sky fairy. So what is it that is stopping me from bilking them all out of their money? Oh right, I actually do have them.

    Though how Machiavellian would it be to create a vast enterprise, make a few hundred million dollars, and then turn that into a massive endowment that would be the antithesis to the Bravewell Collaboration and use that money to show people how not to get scammed out of their money (again)?

    Of course, Kurt Vonnegut’s Mother Night comes to mind….

  6. daedalus2uon 02 Dec 2011 at 3:39 pm

    They do have an ingredient list.

    http://6degreenutrition.com/neurosafe.html

    The ingredient that probably matters is the alpha lipoic acid, but they don’t say how much is in it. Judging from where it is listed, not very much.

    I have kind of a conceptual problem with accepting an endorsement that something prevents brain injury from someone who has exposed himself to a lot of activity that sometimes causes brain injury. If it didn’t work, how would he be able to tell?

    It also contains sucralose, the non-calorie sweetener made from chlorinated sugar.

    http://en.wikipedia.org/wiki/Sucralose

  7. nybgruson 02 Dec 2011 at 3:55 pm

    total sidetrack here, but I love the story of no-calorie sweeteners. Every single one was discovered by accident, and every single one was discovered by someone being stupid and not following lab protocol or thinking critically. It is a very entertaining history. I knew most of this beforehand, since I always did find it entertaining, but >a href=”http://www.youtube.com/watch?v=VUo2XW0z218″>c0nc0rdance has a video on it as well.

    Sorry for the sidetrack. Hopefully someone finds it as entertaining as I do.

  8. Karl Withakayon 02 Dec 2011 at 4:56 pm

    I need financial backing for the one supplement to rule them all: Vitatap.

    Naturally derived.
    Absolutely essential for a healthy life
    Promotes longevity.
    Boosts the immune system.
    Promotes healthy digestion and nutrient absorption.
    Vital for proper organ function.
    Supports healthy joints.
    Key to proper liver function.
    Improves cognitive mental function, concentration, creativity, and memory.
    Male and female enhancement.
    Increases energy, athletic performance, balance, and vitality w/ no crash.
    Contains no caffeine or sugar.
    Helps support quality, restful sleep.
    Promotes regularity.
    It’s ingredients have been used by ancient cultures for thousands of years.
    As safe as water!

    Vitatap comes at a minimal cost out of a tap in my kitchen (far superior to bathroom derived Vitatap), I need only $ for packaging, marketing, and distribution. I promise a many fold return on your investment.

  9. Karl Withakayon 02 Dec 2011 at 5:00 pm

    In the US, it also prevents dehydration. I’m not sure if we can claim that in the EU. :)

  10. Karl Withakayon 02 Dec 2011 at 5:42 pm

    Maybe it supports and promotes proper hydration. That might pass muster.

  11. SARAon 02 Dec 2011 at 7:01 pm

    Karl, just add a color, probably green, and you I think you have a plan.
    You don’t want anyone suspecting that they are drinking “plain” water.

    Imagine how successful the snake oil salesmen were when they could legally include cocaine, etc. in their concoctions. That stuff had to make you feel better, whether you actually were better or not.

    As an aside, I started to feel rather guilty while reading this. My daily multi is actually geared toward hair and nails. I got it on clearance. It had all the stuff I’m supposed to take, so I bought out the stock and now I feel like I’m supporting Snake Oil. eeek.

  12. ConspicuousCarlon 02 Dec 2011 at 9:20 pm

    OK, I’ve got it… bake-at-home, self-rising vitamins! Make your own vitamins at home, just like our founder, Colonel C. James Johnson, did when he invented the first oven-raised vitamins to support his own mother’s wellness in 1847. The secret formula was once thought to have been lost forever in Colonel Johnson’s personal writings, which he recorded in code to protect it from the greedy medical establishment. But now, after more than a century of work by our researchers, JJ’s Home Baked Wellness its available in an easy-to-use evaporated powder mix. Just mix a cup of JJ’s powder, a cup of pure water, and a little love. Roll the dough into small dots, and bake for 20 minutes.

  13. ccbowerson 02 Dec 2011 at 11:30 pm

    nybgrus-

    I didn’t get to the video yet, but I was already ‘entertained’ by titles of the ‘similar’ videos youtube places next to the video you referenced. Titles such as “A poisoned world Pt 20,” “The Truth About Aspartame” and “Aspartame: Sweet Misery, A Poisoned World.”

    Actually I should be disturbed by such misinformation, but I guess we are all a bit numb about such nonsense to be as disturbed as we should be. Artificial sweeteners are classic targets of a certain segment of the quack industry… especially those who find the naturalistic fallacy appealing and promote it as a way of life.

  14. nybgruson 03 Dec 2011 at 1:21 am

    ccbowers:

    Yes, it is sad how much misinformation there is and how incredibly pervasive and powerful the naturalistic fallacy is (btw, c0nc0rdance has a great video on that as well – can you guess that he is one of my favorite YouTubers?).

  15. DevoutCatalyston 03 Dec 2011 at 9:36 am

    http://www.youtube.com/watch?v=VUo2XW0z218

    “Sorry for the sidetrack. Hopefully someone finds it as entertaining as I do.”

    That video makes me want to send away to New Zealand for a supply of Sucaryl just to flaunt the decision that makes it unavailable in the US. That sweetener got a raw deal in the USA, seems to me, and I’d love to be a fly on the wall and understand why it still cannot be approved for sale here.

  16. tmac57on 03 Dec 2011 at 12:00 pm

    ConspicuousCarl
    “Roll the dough into small dots, and bake for 20 minutes.”

    That’s so wrong! Everyone knows that to achieve full potentiation you need to bake them for EXACTLY 21 minutes (3×7=21 powers of three times the power of seven.)
    Better still,bake them 3 times for 7 minutes each.

  17. ccbowerson 03 Dec 2011 at 2:08 pm

    “…how incredibly pervasive and powerful the naturalistic fallacy is.”

    I think it is one of the most overlooked informal logical fallacies. It is even fairly common even among those with a scientific background, which is frustrating.

  18. nybgruson 03 Dec 2011 at 2:15 pm

    ccbowers:

    I agree. I can’t tell you how many conversations I’ve had with people ranging from high schoolers to scientists and physicians that go something along the lines of:

    “I believe that natural, organic, fresh food is healthier for you”
    “What is it about natural or organic or particularly fresh that makes it different and thus healthier?”
    “Well, if it isn’t fresh you can get sick from it.”
    “Right, so obviously spoiled food is bad for you. But the question is how is fresh food intrinsically better for you than less “fresh” food that isn’t spoiled?”
    “Well, um, it just is. That’s obvious.”
    “OK, I agree. It seems obvious that being all natural, fresh, and organic would be better and healthier. But what is it that actually makes it better?”
    “Well, it’s what nature intended for us to eat.”
    “You are aware that every food crop that we eat is nothing even remotely resembling the original ‘natural’ version, right?”
    “Well, sure, but you know its still better for you….”

    And that’s about all I can get. And some people realize their error, but most don’t seem to understand that if you can’t actually tell me why it is better/healthier then you have absolutely no justification for claiming that it is.

  19. DevoutCatalyston 03 Dec 2011 at 2:35 pm

    They sell organic seeds. Do seeds have memory of manure / no manure? Does the resultant tomato really know? Does the acronym IFOAM suggest something sinister about organic foodies? Rabies?

  20. ccbowerson 03 Dec 2011 at 2:36 pm

    nybgrus-

    I have had that same conversation with a friend of mine who graduated from business school (finance). She later went on to medical school, and is currently a resident. I wonder if she would still say the same things today… I’m not sure.

    Your made up conversation reminds me of how people react when I ask them why they are taking a particular oral supplement. I usually just want them to give a simple answer, and they rarely can (despite spending $100s/year). If they can give an answer I usually end up carefully providing an explanation that the product is not worth spending money on, since there is little/no evidence of efficacy for whatever they were taking it for. I imagine that it may make them think the next time they are in the supermarket and making a purchasing decision.

    Part of the problem is that the naturalistic fallacy sometimes correlates with reality. It is true that getting nutrients from fresh foods is usually better than supplementation in tablet form. Its just that the explanation has nothing to which option is more natural… it is just what the evidence indicates

  21. Vinay Punwanion 03 Dec 2011 at 3:06 pm

    Nice post Steve, as usual.

    I’m tempted to start my own multivitamin website. I’m thinking OsteoProtein Pure (TM), it’s protein for your bones and it may help to support your body’s bone mineralization process. Only $39.99 per bottle, which lasts 2 weeks.

  22. tmac57on 03 Dec 2011 at 4:43 pm

    Ny and cc-I do recall that Consumer Reports did some testing of organic foods ,and found that the nutrition content,and taste were the same as for conventional,but that it had less pesticide residue in general,so that might be a valid conderation,but I think careful washing or peeling of the produce,should result in similar levels.
    I think we need a name for stuff that is supposed to be better because of the naturalistic fallacy…
    How about ‘Naturish’? Sort of like ‘ truthiness’.
    I’m sure someone can do better.

  23. DevoutCatalyston 03 Dec 2011 at 5:03 pm

    NaturoFallic

  24. ccbowerson 03 Dec 2011 at 6:59 pm

    “but that it had less pesticide residue in general,so that might be a valid conderation,but I think careful washing or peeling of the produce,should result in similar levels.”

    I am amazed that we don’t have more definitive answers about this especially considering how much money is spent on food. The comparison in studies should be between washed organic and nonorganic produce. Since the vast majority of people wash their produce what is the point in knowing the prewashed pesticide content? Then again if we find a difference we will have to decide if this difference is meaningful. (In general, I do have a problem with the term “organic” and its definition, because the naturalistic fallacy is built into the criteria, but I am realistic in that the term is here to stay)

  25. nybgruson 04 Dec 2011 at 1:42 pm

    Well, first off, in the States at least the term “organic” means next to nothing. As far a I have been able to ascertain it means only that a few specific fertilizers and pesticides aren’t used. Interestingly enough, in many cases that means older and more toxic pesticides are used for certain “organic” crops and in other cases significantly more of less toxic stuff is used. There really is no specific oversight or regulation, so Hippie McCrunchy may or may not be getting what he thinks “organic” means. Which, of course, when you ask them they can’t usually define beyond “all natural, man. You know, grown the way Mother Gaia wanted it to be.” Or something along those lines ;-)

    When it comes to supplements as you pointed out CCBowers, that is hit or miss for me. I don’t try and engage people in it too much, unless I think that there is distinct and direct possibility of harm (like the HCG diet or using nasal spray Zicam). However, one personal anecdote is that not terribly long into dating my current girlfriend, I was helping her move out of her place and found she had a gigantic bottle of echinacea. I didn’t want to start anything so I just said “I don’t really think this is worth spending money on, but if you want to go right ahead.” She got a little upset and told me that her doctor had said it was useful and she’d been using it for years and it made her colds feel better. My response was to the effect that I didn’t think it would hurt anything, it’s her money to waste if she wants, and that her doctor may not be hip to the newest data showing it really doesn’t do anything. That was about it.

    Two days later she comes up to me and says she needs to apologize and thank me. Huh? Turns out she sat down and did some research and discovered I was right. Here’s the kicker – she actually did a PubMed search and found the same 2005 article that I thought was a pretty good clincher on it. She then did something very few people ever do – she changed her mind based on the evidence. And gave the bottle of echinacea to her very fun and cute yet hippie-ish dancer/pilates instructor roommate. LOL.

    Needless to say, she is still my girlfriend. So yeah, the whole Dr. Oz’s wife thing – I picked better ;-) (BTW – she is an aerospace engineer, not a medical scientist, so I was doubly impressed she did a pubmed search, read, and undertsood the articles).

    Anyways, I am also curious about the apparently better absorption of vitamins and nutrients from foods vs pills. I really don’t know much about it, from an evidence based perspective. But it has been “common knowledge” that this is the case. Me being who I am feels that there must be some sort of actual explanation and MOA for it. Perhaps it has to do with digestion in general? What if you take in foods and pills at the same time vs pills alone on an empty stomach? Is that where the discrepancy lies? I don’t know – just spitballing, but I’d be curious if anyone here has any actual data or other ideas.

  26. SteveAon 05 Dec 2011 at 7:26 am

    Karl Withakay: “I need financial backing for the one supplement to rule them all: Vitatap…”

    You forgot the big one – Fat free!

  27. 2_wordson 05 Dec 2011 at 9:08 am

    The natural fallacy is a problem of the dualist. Their thought follows from “humans are unantural intrusions in the world” therefor anything we make is unatural and suspect.

    A refinery pumping carcinogens into the atmosphere is as natural as an ant hill. The natural world has produced both of them.

  28. 2_wordson 05 Dec 2011 at 9:11 am

    Please pardon my natural misspelling of “unnatural.”

  29. ccbowerson 05 Dec 2011 at 10:22 am

    “Anyways, I am also curious about the apparently better absorption of vitamins and nutrients from foods vs pills. I really don’t know much about it, from an evidence based perspective.”

    Well, my understanding is from a different angle, and the way you are asking the question is the reverse from the way I think the problem lies. The issue seems to be a problem of attributing the “benefits” of a healthy diet to specific vitamins in foods. For example, lets take a body of research that people who have a diet high in fruits and vegetables have lower rates of diseases x, y, and z. Lets assume for the sake of argument that this is a causal relationship. It does not follow that we can simply use a supplement that contains those vitamins found in those foods to replicate results of that diet, but that is where the thinking goes beyond the evidence. This is not a new issue, but I’ve noticed this problem with “antioxidants” more recently… assuming that the theoretical explanation is the whole story when it is an oversimplifcation that makes it incorrect

  30. sonicon 05 Dec 2011 at 12:52 pm

    nybgrus–
    Vitamins from plants and animals come in a one-handed form with the flavonoid attached.
    Vitamins made in factories (not living things) come in two-handed versions without the flavonoid attached.

    The handedness of the molecules might be of importance– there are a few studies I’ve read that indicate they are.
    But it is the flavonoids that are really important IMO. That is because our digestive systems will not use vitamins with the flavonoids attached unless the vitamin is released by a bacterium in the digestive system.

    It appears the bacteria in our digestive systems regulate which vitamins we actually get by releasing only those needed at the time.
    It seems taking vitamins without flavonoids can lead to various imbalances due to the bypassing of this system.

    BTW–The term ‘organic’ is meaningful in the US– it doesn’t mean what many of the farmers lobbied for- but it is meaningful none the less. (My friend recently tried to get his farm certified– not so easy after all…)

  31. nybgruson 05 Dec 2011 at 2:09 pm

    @ccbowers:

    The issue with that sort of approach is that it basically begs for the Hawthorne effect. Is it really the diet that is making these people healthier or is it that fact that people who actually care about their diet enough to think about eating healthier tend to lead a healthier overall lifestyle (exercise, etc)?

    @sonic:

    I am very aware of the chirality of molecules. It is a basic principle that is hammered into you during organic chemistry in undergrad. And in fact, it is not just that the chirality is important – it is downright necessary. D-glucose is readily utilized by the body, but L-glucose is not. Enzymes (for the most part) have a very significant amount of specificity such that they cannot act on different enantiomers.

    However, there are ways to purify a supplement to contain only the proper enantiomer and even if it is racemic (contains both), then all you need to do is double the dose.

    So chirality, or handedness, can’t really be the issue here.

    As for the flavinoids – I’ll admit I am reasonably ignorant on the topic, but from what I do know that also doesn’t really have a bearing on it. Unless you can cite some data which demonstrates one needs flavinoids to absorb vitamins and minerals – which I think is highly unlikely based on how we treat such deficiencies in CF patients. Once the vitamin makes it into circulation and assuming it is the correct enantiomer, the body can’t possibly differentiate whether it came with or without a flavinoid or from an orange or a tablet. The question, as far as I know it, must be a bit deeper and lie in the gut somewhere – if it exists at all.

    As for the bacteria – they don’t exactly regulate our vitamin intake. They can most definitely affect it, but they do not act in a concerted symbiotic fashion to make sure we don’t get too much or get enough. They synthesize vitamin K for us and we take it and utilize it as needed. Beyond that, they can indeed prevent vitamin absorption in certain cases (usually pathologica states that globally decrease intestinal absorption capacity) and do play a role in overloading us with ammonia, but that is about it. In other words, they do not release only those vitamins that we need at the time.

    As for your friend’s farm – I never said it was easy to get certified organic, but that it doesn’t really mean all that much vis-a-vis what most people think it means. But I am also under the impression that there isn’t a single uniform “organic accreditation” committee or standard and that foods can say “organic” and actually have that mean different things depending on exactly where it comes from. I could be wrong on this – I haven’t researched it in depth. But if you have some links that summarize exactly what it does mean and delineate if there is a uniform standard or not, I’d be keen to peruse them.

  32. ccbowerson 05 Dec 2011 at 3:33 pm

    “Is it really the diet that is making these people healthier or is it that fact that people who actually care about their diet enough to think about eating healthier tend to lead a healthier overall lifestyle (exercise, etc)?”

    The confounding variables cut in every direction, so that is always an issue. But extrapolating recommendations for supplementation adds yet another layer removed from the evidence, which is even more problematic than the diet recommendation itself. In addition to any vitamins we may identify in foods (some of which may not be typically found in supplement form), there are other factors: fiber content, displacement of less healthy foods, etc.

  33. tmac57on 05 Dec 2011 at 4:14 pm

    Nybgrus
    This looks like a good resource
    http://www.ams.usda.gov/AMSv1.0/nop

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