We are so delighted to introduce our trailblazer of the month – Pamela Jones Harbour, Independent Director at Tupperware Brands Corporation & Advisory Board Member at Radicle Science, Inc. With a notable career in antitrust and consumer protection law, she’s made significant contributions as the first African-American female Commissioner of the United States Federal Trade Commission. Her expertise spans key industries like healthcare and technology, shaping pro-consumer enforcement agendas and policies. Pamela excels in evolving areas of competition and consumer protection law, including privacy and data security.
1. If you could change one thing about our industry, what would it be, and why?
To better protect the industry, I would like to see enhanced self-regulation in the advertising of natural health-related products – more specifically in the area of claims substantiation. Self-regulation can be defined as the process whereby an industry monitors its own adherence to legal, ethical, or safety standards.
As a former regulator, I can attest that the Federal Trade Commission’s (FTC’s) substantiation standard is a rigorous one, particularly when claims relate to health.
In the case of the natural health products industry, effective self-regulation would not replace the need for companies to follow the many regulations and laws that govern the industry. Instead, effective self-regulation would further complement and enhance government regulation.
Further improving the current self-regulatory program regarding natural health product claim substantiation would go far to restoring regulators’ confidence in the industry. Refinements in the efficiency, independence, and transparency of the existing self-regulatory machinery and its administration would benefit the industry and consumers. The FTC has indicated that successful self-regulatory initiatives share several features:
- Clear requirements that conform to the law;
- Widespread industry participation;
- Active monitoring programs;
- Effective enforcement mechanisms;
- Procedures to resolve conflicts;
- A transparent process;
- Responsiveness to a changing market and consumers; and
- Sufficient independence from direct control by industry.
Radicle Science’s AI-driven, virtual, direct-to-consumer, clinical research model approach could be explored as an improved self-regulatory standard for substantiating industry structure/function claims for natural health products.
The cost of developing substantiation for natural health products was prohibitive before Radicle’s clinical research model approach was introduced. This approach now enables strong structure/function claims through gold standard blinded, randomized, placebo-controlled clinical trials that are easy and, more importantly, affordable. By utilizing Radicle’s pioneering approach to crowd-sourced trials, I believe the industry could become state-of-the-art in self-regulation, enabling effective substantiation for all natural health products.
2. Can you share a memorable “aha” moment from your career that changed the way you approach work?
My “aha” moment was learning to overcome adversity, which has made a few cameo appearances in my own professional life. However, it is not the absence of adversity, but rather how one overcomes it that determines success. Over the years, I’ve shared a few life-lessons about overcoming adversity:
And finally, adversity taught me that I should never be too proud to ask for help. As you go through life, you will unexpectedly encounter people who are willing and able to help you. Let them. Their benevolence will surprise you.
- Adversity taught me to recognize my strengths and weaknesses. Going forward, I knew I had to accept the weaknesses and always play to my strengths.
- Adversity taught me to be courageous because success is not final and failure is not fatal; rather, it is the courage to continue that counts. I realized that courage means doing what you are afraid to do.
3. In your opinion, what emerging technology or trend will have the most significant impact on our industry in the next three to five years?
Artificial Intelligence (AI) systems will rapidly transform the natural products health industry, adding tremendous value, by learning from data and making decisions or predictions based on that data.
However, the use of AI poses some risk because the results can be unexplainable and unpredictable. In addition, AI has the potential to cloak unethical biases, making it difficult for the public or regulators to determine whether there has been integrity in the application. Education concerning how these risks are addressed is key to building trust in consumers and regulators. Therefore, thoughtful industry leadership (with an emphasis on transparency and responsible disclosure) is important to educate society and build the necessary trust to protect the industry.