Dear Reader,
The consequences of the investigations into the authenticity of dietary
supplements by the New York State Attorney General (NY AG) Eric Schneiderman
continue to impact the dietary supplement industry and have increased the
emphasis on the need for appropriate test methods to detect botanical
ingredient adulteration. Following the NY AG’s investigation into devil’s
claw supplements, the
United Natural Products Alliance (UNPA) organized an analytical summit in Salt
Lake City, Utah, which was held in November 2015. The goals of the summit were
to update participants on the latest developments with regard to the NY AG’s
actions, to discuss analytical technologies to authenticate dietary supplement
ingredients, and to detect adulteration, with emphasis on DNA-based methods.
DNA-based identification of botanical ingredients was also one of the
topics of the Adulteration and Fraud in Food Ingredients and Dietary
Supplements workshop held in early December of 2015, co-sponsored by United
States Pharmacopeia (USP), the American Botanical Council, and the Food Protection and Defense Institute.
Based on the numerous talks on the topic of DNA-based identification methods during
the two events, it is clear that genetic technologies represent a valuable tool
for authentication of crude botanical ingredients, especially if combined with
appropriate chemical or other (e.g., taxonomy, microscopy) identification
methods. However, there is some disagreement among experts in DNA-based
authentication methods with regard to the capabilities and limitations of the
various methods, in particular the ability of genetic methods to identify
processed ingredients (e.g., herbal extracts) and provide quantitative results,
as well as the extent of validation requirements. In addition, DNA-based
analytical techniques cannot differentiate among plant parts (e.g., root, leaf,
flower, etc.) – an important requirement in Good Manufacturing Practices (GMPs)
for herbal dietary supplements, thereby requiring the use of other methods,
e.g., scientifically valid compendial analytical methods – nor is DNA
methodology capable of differentiating between acceptable levels or trace
amounts of foreign organic matter (for example, USP normally allows up to 2%). The
two seminars have shown that dietary supplement adulteration is an increasingly
important matter and that efforts to educate on the issues and provide
solutions to the problems are much needed. A review of the highlights of these
two conferences is provided in this Botanical Adulterants Monitor in the
section on recent conferences focusing on botanical ingredient adulteration.
Regarding news from the Botanical Adulterants Program (BAP), the
Laboratory Guidance Document (LGD) on black cohosh (Actaea
racemosa, Ranunculaceae) was released in December. This document, which
is available free of charge through the Program homepage on the ABC website,
sums up the conclusions of a review of 36 methods for the analysis of black
cohosh, which were evaluated with respect to their suitability to authenticate black
cohosh and to detect adulteration. I am grateful to the 20 expert reviewers who
spent the time to read the document and provided their expert feedback to help ensure
the accuracy and authority of the document.
Looking ahead to upcoming BAP publications, the next in the LGD series will
be on the adulteration of so-called grapefruit (Citrus × paradisi, Rutaceae) seed extract with synthetic
antimicrobial compounds. Also, we will soon be introducing a new series
consisting of short summaries on specific topics of adulteration, the Botanical
Adulterants Bulletins, which are at various stages of production. Initial Bulletins
drafts have been written covering the adulteration of bilberry (Vaccinium myrtillus, Ericaceae) fruit extract, goldenseal (Hydrastis canadensis, Ranunculaceae) root, grape (Vitis vinifera, Vitaceae) seed extract, and skullcap (Scutellaria lateriflora, Lamiaceae) herb, among others.
The
Regulatory Alerts section of this issue of the Botanical Adulterants Monitor has
a short report about the change in language used by the US Food and Drug
Administration (USFDA) to talk about illegal active pharmaceutical ingredients
(APIs) marketed as dietary supplements.
The review on newly published science pertaining to topics of adulteration focuses on chemical methods for the authentication of commercial products labeled to contain Rhodiola rosea (Crassulaceae) root and rhizome; the ability of hyperspectral imaging to differentiate Stephania tetrandra (Menispermaceae) from the carcinogenic, mutagenic, and nephrotoxic substitute Aristolochia fangchi (Aristolochiaceae); and a review of a DNA-based method to identify mushrooms and mycelia of the genus Ganoderma (Ganodermataceae).
Stefan Gafner, PhD
Chief Science Officer
American Botanical Council
Technical Director,
ABC-AHP-NCNPR Botanical Adulterants Program