On
February 2, four major US retailers were sent cease-and-desist letters
demanding that they remove certain herbal dietary supplement products from their
New York stores.1 The sender, however, was not a representative of one
the federal agencies that oversees dietary supplements such as the US Food and
Drug Administration (FDA) or the Federal Trade Commission (FTC); rather, the
letters were issued by an unexpected party: New York State Attorney General
Eric T. Schneiderman.
Store-brand
herbal supplements from GNC, Target, Walgreens, and Walmart were deemed
adulterated based solely on the results of a DNA barcoding analysis, which
revealed the presence of unlisted ingredients — or a complete lack of the
labeled herbs’ DNA — in 79% of the tested products.1 Instead of
finding only ginkgo (Ginkgo biloba),
St. John’s wort (Hypericum perforatum),
ginseng (Panax spp.), garlic (Allium sativa), echinacea (Echinacea spp.), valerian (Valeriana officinalis), or saw palmetto
(Serenoa repens) in the supplements,
the attorney general-commissioned analyses found traces of potential allergens
such as rice (Oryza sativa) and wheat
(Triticum aestivum), and DNA from alleged
adulterants, e.g., the onion (Allium
spp.) or dracaena (Dracaena spp.)
genera.
In a large number of the tested products, according to Schneiderman’s office,
there was no detectable DNA from any plant species whatsoever.1
Media Response to
Ongoing Developments
Predictably,
on February 3, many major American news outlets ran articles about Schneiderman’s
findings and actions, and the media frenzy commenced. Over the following week,
the New York Times featured four
articles with familiar supplement-industry criticisms from staff writer Anahad
O’Connor*,2-5 in addition to unfavorable editorials (“Herbal
Supplements Without Herbs”6) and opinion pieces (“The Politics of
Fraudulent Dietary Supplements”7). Herbal supplements were labeled “stupid
pills” that likely contained more dust than active ingredients, sold in an allegedly
unregulated market ripe with fraud and adulteration.
“The
fact is virtually every product we tested includes ingredients not listed on
the packaging, and close to 80 percent failed to show any evidence that they
included even trace amounts of what was advertised,” noted a spokesperson for
the New York Attorney General.8 “This is ultimately a matter of
public health, and when public health is at stake the burden is on this largely
unregulated industry to prove what’s in its products.”
Less
than 24 hours after the New York Times
broke the news online, the nonprofit American Botanical Council issued a press
release stating that the New York Attorney General had misused the DNA barcode
technology and that its results were “premature.”9 At the same time,
natural products industry trade organizations10-12 issued press
releases and email advisories alerting their members to the situation. A
telling headline from a February 3 NutraIngredients-USA article,13
which included industry and natural health community leaders’ first reactions
to the news, referred to Schneiderman’s actions as “uninformed,”
“inappropriate,” and “premature.” As discussed later in this article, the
industry’s and wider community’s initial response focused on the attorney
general’s sole reliance on DNA barcoding, the method’s applicability to herbal
extracts (See “Experts Question” section), and the existing regulatory
framework for dietary supplements (See “Emphasizing Regulation” section).
Journalist
Mary Esch described some of these primary concerns in a February 8 Associated
Press article on DNA barcoding.14 “[I]ndustry groups and some
independent experts say DNA testing alone is inadequate for analyzing botanical
products that have gone through a lot of processing from leaf to tablet,” she
wrote, later quoting American Botanical Council (ABC) Founder and Executive
Director Mark Blumenthal, United Natural Product Alliance’s (UNPA) Loren Israelsen,
Harvard’s Pieter Cohen, MD, and United States Pharmacopeia (USP) Director of Dietary Supplements Nandukumara Sarma,
PhD — all of whom had raised significant scientific and technical concerns with
the AG’s reliance on only one analytical method, which has been shown to be
highly problematic and unreliable with the testing of botanical extracts.
On
February 11, as the novelty of the issue was beginning to fade and articles on
the topic had lost page-one status, the New York Attorney General sent a new
round of letters to the same four retailers.15 This time, Schneiderman
— a Harvard Law School-educated Democrat and the state’s highest-ranking law
enforcement officer16 — issued subpoenas for any and all data supporting
the “structure-function” claims of the retailers’ herbal products. Although the
retailers had already complied with the AG’s first request and removed the
affected supplements from New York stores — with Target and Walgreens going
further and removing the supplements from stores nationwide15 —
Schneiderman’s mission, it seems, was not yet finished.
Thus,
it was perhaps less surprising when, on February 24, he sent letters to four
additional supplement manufacturers (i.e., Nature’s Way of Lehi, Utah; NBTY of
Ronkonkoma, New York; Nutraceutical Corp. of Park City, Utah; and Pharmavite of
Mission Hills, California) requiring nine points of detailed information
regarding their herbal supplement products. The companies were given a deadline
of March 13 to comply,17 and members of the industry were left
wondering what might come next. These four companies were not openly implicated
in the AG’s initial actions against the four major retailers, but the actions
against them created a sense of wrongdoing even though there was none cited in
the AG’s letters.
Most
recently, on March 9, the New York Times
reported that attorneys general from Connecticut, Indiana, and Puerto Rico had
pledged their support for New York Attorney General Eric Schneiderman’s ongoing
investigation into herbal supplements.18 Although details are scarce,
Schneiderman explained the general goals of the new coalition in a statement:
“The initiative seeks to enhance transparency and ensure that the herbal
supplements industry is taking the steps necessary to validate their marketing
claims, including [those related] to authenticity and purity,” he said.19 “By joining together, and building on the long
track record of state attorneys general upholding the rights of consumers, we
can go further in investigating this industry and, as needed, in achieving
reform.”
The
day after the AG coalition was reported, a group of four expert scientists
announced the publication a white
paper20 commissioned by four
trade associations representing the dietary supplements industry (i.e., the
American Herbal Products Association [AHPA], the Consumer Healthcare Products
Association [CHPA], the Council for Responsible Nutrition [CRN], and UNPA). The objective of the paper,
according to the authors, is “to provide an expert assessment of the
capabilities and limitations of DNA barcoding for botanical dietary supplement
authentication to inform assessments of the applicability and accuracy of DNA
test results.”20 The 13-page document also includes a specific
“critique of the DNA testing methods used in a recent investigation of
botanical dietary supplements by the New York Attorney General’s Office.”
Investigation
Prompted by 2013 Canadian DNA Barcoding Study
According
to the New York attorney general’s February 3 press release,1
Schneiderman first became interested in the contents, quality, and regulation
of herbal dietary supplements after a study on DNA barcoding-based
identification of dietary supplement ingredients appeared in the October 2013
issue of BMC Medicine.21
The paper by lead author Steven Newmaster, PhD, an associate professor of
biodiversity genomics at the University of Guelph22 — titled “DNA
barcoding detects contamination and substitution in North American herbal
products”21 — was one of the first cases of highly publicized
negative results based on DNA barcoding of herbal products.
Numerous
errors and methodological oversights in the paper by Newmaster et al. brought
its results into question and led some organizations, such as the American
Botanical Council, to call for its retraction from BMC Medicine.23 ABC, working in conjunction with experts
in DNA barcoding and analysis from the University of Mississippi’s National
Center for Natural Products Research (NCNPR) and AuthenTechnologies, published a
comprehensive critique of the Newmaster paper in the November 2013 issue of
HerbalEGram.23
“Ironically, readers of the [Newmaster] article
can draw two opposing conclusions from this paper, neither of which is correct,”
noted the authors of the HerbalEGram article in their conclusion.23 “First, herbal critics will look at the paper and see
confirmation of their preconceived notions about the lack of competence of the
herbal industry. On the other hand, herbal advocates will use the authors’
indifference to established practice, the extant peer-reviewed literature, and
the current state-of-the-art herbal quality assurance processes to dismiss this
paper and to pretend that quality issues do not exist.”23
Despite describing an
entirely different set of analyses, the authors of the 2013 HerbalEGram article
could very well have been writing about the natural product community’s current
dilemma with the New York attorney general’s DNA barcoding of major store-brand
herbal supplements.
Schneiderman’s
office, citing protocol for ongoing investigations, has refused to release
additional details of the recent DNA barcoding results,24 which
makes direct comparisons to the Newmaster et al. paper difficult. However, in
both cases, DNA barcode technology was the only
analytical method utilized to attempt to determine the identity of the
herbal ingredients in the commercial herbal products tested. There were no additional
tests performed in either study; i.e., other analytical methods were not
employed to corroborate the results from the DNA testing. Prof. Newmaster
subsequently acknowledged to Blumenthal that the use of additional analytical
methods — particularly those described in officially recognized pharmacopeial
monographs (e.g., those published by the United States Pharmacopeia) — would
have been preferred as a means to corroborate the DNA results, but his research
budget did not allow for such tests. Consequently, he published his negative
findings based on his DNA barcode analysis without the ability to internally confirm
his results.
Despite
these issues, many major news outlets at the time used the results of
Newmaster’s uncontrolled study to vilify herbal dietary supplements, but the
natural product community’s experience navigating the media furor in some ways
primed the community for a more deliberate response to negative DNA
barcoding-based findings in the future.
Although
the natural products community’s reaction to the negative media coverage in February
may seem familiar to some, the New York Attorney General’s actions are unprecedented,
marking “the first time a state law enforcement agency has taken direct action
against major supplement retailers for alleged fraud.”25
“The
involvement of major retailers has the power to finally prompt the dietary
supplement industry to take the needed steps to earn the lasting trust of
consumers,” noted Frank L. Jaksch Jr., CEO of ChromaDex — a California-based
natural products company specializing in phytochemical analysis — in an article
for the San Jose Mercury News.26
“As the investigation invades headlines across the nation, rather than firing
back, the industry should use this opportunity to improve.”26
Still,
industry members have expressed concerns over long-term damage to the
reputation of herbal supplements in the minds of legislators, health
professionals, and the public. “However this shakes out,” wrote Elan Sudberg,
CEO of Alkemist Labs, in a February 5 article for NewHope360,27 “and
even if the results of this well-publicized testing are ultimately discredited,
the damage is done in the minds of consumers, and quite possibly in the minds
of Congress.”
Trade Organizations
Launch Grassroots, Social Media, and Education Campaigns
In
the days and weeks following the attorney general’s original cease-and-desist
letters to the four major retailers, industry members distributed press
releases and letters to the editors of major newspapers, scheduled
industry-wide conference calls to discuss new developments, and created new
educational resources and social networking campaigns to help address questions
from the public and media outlets.
Israelsen,
of UNPA, based in Salt Lake City, Utah, jump-started one such effort, emailing
a plan of action to his UNPA colleagues less than 12 hours after the New York Times published the first
articles on Schneiderman’s supplement investigation.
“Our first reaction was that the test results were so
uncharacteristic of what we would expect and because they only used the DNA
barcode testing, we felt it was important and urgent to secure samples of the
same lot numbers of products in order to be able to test those lots with highly
regarded, highly competent laboratories with deep expertise in these class of
products,” Israelsen was quoted as saying in an article from Natural Products Insider.28
The
response to Israelsen’s request was robust, and UNPA currently is in the
process of testing the various herbal supplement lots, with results expected
sometime in March.25 “We received over 20 boxes of samples, and we
have established a highly secure chain of custody,” Israelsen told Holistic Primary Care.25 “We
have two staffers inputting each sample received in preparation to send to
independent labs to test for ID and conformance with the supplement facts
panel. So far, we seem to be on track to have nearly 100% of all the affected
lots.”
Israelsen
later clarified that UNPA received 486 separate products purchased in retail
stores of three of the companies that were sent the cease-and-desist letters.
(After the news broke, Walgreens’ checkout system prevented clerks from selling
the products in question, making their acquisition difficult, if not
impossible.25)
Approximately
one week later, CRN and the Natural Products Association (NPA) had launched a
so-called “microsite”29 — created specifically to serve as consumer-friendly
information hub — and a social media campaign,30 respectively. Shortly
thereafter, AHPA created an online resource with six specific talking points to
help industry members accurately communicate the main concerns with
Schneiderman’s actions to media.31 CRN’s site consists of a simple
home page with four options, allowing visitors to find selected expert
opinions, an infographic on DNA barcoding, a list of CRN press releases on the
topic, and a “Consumer Q&A.” NPA’s website is more action-oriented and features
an overview of the situation and urges readers to email, call, or tweet their
concerns directly to Schneiderman.
Less
than two weeks after the social portal was launched, NPA noted in a press
release32 that thousands of individual communications had been sent
to the New York Attorney General through its social media campaign, with the number
increasing daily. “This industry has a long and successful history of affecting
change at the grassroots level when threats arise,” noted NPA CEO Daniel
Fabricant, PhD in the release,32 “which is why it was so important
for NPA to organize this campaign and give consumers, retailers, manufacturers
and all interested parties the opportunity to stand up and speak out in
response to Attorney General Schneiderman’s actions against dietary
supplements.”
Experts Question
Use of DNA Barcoding on Finished Herbal Products, Including Extracts
Despite
the unexpected and escalating nature of the attorney general’s actions against
herbal supplement retailers and manufacturers in February, the natural products
community’s response could be considered prompt, critical, and largely uniform
in message, primarily focusing on concerns with DNA barcoding of botanical
extracts.
“DNA
testing is a comparatively new technology,” noted Alkemist Labs’ Elan Sudberg.27
“It has the potential to become an important tool in identity testing, particularly
when used knowledgably. However, like any test method, in the hands of a
technician who does not have a working knowledge of the materials he is dealing
with, the results have the potential to be inaccurate.”27
Schneiderman’s
office commissioned Clarkson University professor James A. Schulte II, PhD — an
expert in reptilian biology — to test the selected herbal dietary supplements.
The DNA barcode analyses were conducted at Beckman Coulter Genomics, a DNA
sequencing lab based in Massachusetts.33 Schulte’s assignment as
investigator, however, was met immediately with criticism due to his lack of
experience in botanical identity testing.9,25,33 To date, no
scientific papers can be found that are authored or co-authored by Prof.
Schulte on the subject of genetic testing of plant material and/or finished
botanical dietary supplements.
According
to the Consortium for the Barcode of Life, an international initiative to
catalog DNA sequences of the world’s plant and animal species,34 “DNA barcoding is a technique for
characterizing species of organisms using a short DNA sequence from a standard
and agreed-upon position in the genome. DNA
barcode sequences are very short relative to the entire genome and they
can be obtained reasonably quickly and cheaply.”34
To
find a match, researchers compare DNA collected from the species being analyzed
to one of the main barcode data repositories, e.g., the Barcode of Life
Database (BOLD), the National Center for Biotechnology
Information (NCBI) GenBank, or the Medicinal Materials DNA Barcode Database (MMDBD).34
The
method is an extremely sensitive tool that can detect unimaginably small
quantities of “contaminants,” which must be taken into account when
interpreting results. CRN, the American Herbal Pharmacopoeia (AHP), UNPA, AHPA,
and the Consumer Healthcare Products Association highlighted some of these
concerns in a February 23 joint statement35 on the attorney
general’s actions:
“Some
manufacturers permissibly use such ingredients as rice bran as ‘flowing agents’
or other excipients in their products and label them appropriately. However, in
the case of trace amounts of other botanical material, there are
well-established legal thresholds that allow for trace amounts of some
ingredients that are not considered harmful or required on labels,” the
statement noted.35 “Separate allergen labeling regulations from the
FDA identify the top eight allergens and require labeling statements to
indicate the presence of such allergens unless a permissible threshold has been
set. Dietary supplements are subject to these same allergen rules mandated for
all foods and are tested for the presence of possible allergens.”29
According
to the USP, herbal raw materials used in dietary supplements may contain no
more than 2% of “foreign organic matter;36 such an allowance is
based on the recognition that botanicals are agricultural products and are thus
subject to minor contamination with other plants growing in agricultural settings.
Given
its intricacies and relative infancy, DNA barcoding is not considered a
universally appropriate method for identity testing of finished herbal products,
especially extracts. In particular, the technology is not suitable for
detecting plant DNA in dry, liquid, or powdered herbal extracts.29 Known
more commonly as a vocal critic of the supplements industry, Dr. Pieter Cohen of
Harvard Medical School has sided with the industry and other community experts on
this particular issue.
“DNA
barcoding looks for a specific fragment of DNA, but the ingredients in herbal
supplements are often highly processed — crushed, dissolved, filtered and dried
— so that they may no longer contain the particular fragment of DNA that
researchers are searching for, making the supplement appear to be mislabeled,”
Dr. Cohen was quoted as saying in The
Observer.37 “The biological compounds extracted from the
plant—the parts that supposedly have healing powers—would be in the supplement
without the DNA sought in the tests.”
Understanding
the shortcomings of DNA barcoding for botanical extracts makes the fact that up
to an estimated 74% of the tested products were extracts even more troubling.13
GNC also has stated that all six of its herbal supplement products were
extracts and are thus susceptible to inaccurate identification by DNA barcoding.13
From the beginning, GNC denied the accuracy and validity of the attorney
general’s results and has complied with all of Schneiderman’s requests for
information. Furthermore, the company commissioned an independent third-party
laboratory to conduct four rounds of additional testing on its Herbal Plus
supplements at various stages of processing, each time, according a GNC
release, confirming their purity and compliance with federal standards.38
In addition to its limited utility for identifying
materials in highly processed herbal dietary supplements, DNA barcoding has
another significant shortcoming. “While DNA barcoding is a valid and useful
technology, it is qualitative in nature (i.e., it can confirm whether DNA is
present or not, but it does not indicate in what quantity the plant material is
present),” explained USP Director of Dietary Supplements Dr. Nandukumara Sarma in a USP blog post
about the topic.39 “Thus, chemical analysis tests should be used to determine the strength
of a supplement in a quantitative manner.”39
More often than not, botanical raw materials
destined for finished dietary supplements will be exposed to multiple different
types of analytical tests depending on where it is in the supply chain and its
level of processing.12 As
AHP’s Roy Upton explained in an
extensive letter with attachments that he sent to Schneiderman: “Once
the source plant is extracted and DNA is no longer present, other technologies
are needed to determine the IDENTITY of the ingredient. Additional tests may be
needed to determine the POTENCY of the finished product. Still different tests
are needed to determine the PURITY of products in order to determine if ‘contaminations’
are in fact present.”12
As
such, DNA barcoding is not currently referenced in any official USP monograph,
nor is it used by the FDA for ingredient verification.39,40 However,
according to a widely distributed statement from FDA’s Center for Food Safety
and Applied Nutrition (CFSAN), the Administration is using the technology for
other purposes. “The FDA does
not currently use DNA sequencing for dietary supplement ingredient
verification, but is actively working toward developing validated methods for
plant identification, for use by both industry and the agency,” CFSAN stated in
the email.40 In addition, they noted that the
FDA is “working on building a library of DNA sequences for plants, but this
project is not complete. The agency currently uses chemical markers or
fingerprints when it performs ingredient verification.”40
In
his correspondence to the attorney general, AHP’s Upton recommended using
botanical analytical methods featured in “national and international guidelines
for determining the identity, quality, and purity of these products and
experienced labs that can conduct the tests.”12 His four-page letter
with 54 pages of attachments includes a list of such respected guidelines and
examples of “appropriate monographs for each of the botanicals tested.”12
Emphasizing
Regulation through Existing Framework
Although
detailed botanical monographs exist for each of the seven herbs involved in the
New York Attorney General’s investigation, the adoption of such testing
standards by dietary supplement manufacturers is voluntary per the 2007 dietary
supplements final rule for current good manufacturing practices (cGMPs).41
The cGMPs require manufacturers to “perform identity testing on every dietary
ingredient, every time it is used.” The manufacturer has the option to choose
which particular type of identity test(s) to use for authentication of each
dietary ingredient.40
“Even
with the advent of GMPs, people outside the industry are often surprised to
find that they don’t include specific standards for how you test specific
products,” Tod Cooperman, CEO of ConsumerLabs.org, told NutraIngredients-USA.42
“Companies are supposed to choose reasonable, scientifically valid tests. But
not defining these things … leave[s] it open for an herbal company, or even the
New York AG, to decide for itself in each case what is a reasonable test.”
The
2007 final rule and cGMPs are just one facet of the regulations currently in
place to help prevent adulterated products from entering the marketplace. Natural Products Insider noted other
important examples of federal protections in a February 27 article:43
“The FDA enforces DSHEA, which regulates the manufacturing and distribution of
dietary supplements, [and] cGMPs, which require manufacturers to perform
identity testing on incoming materials and finished product testing to ensure
identity, purity, strength, and composition,” the article noted.43 “The
FDA has an arsenal of options available to ensure compliance: a 483, a Warning
Letter, and even injunctive relief.”
When
Schneiderman subpoenaed supporting evidence from GNC, Target, Walgreens, and
Walmart for their products’ structure-function claims on February 13 — “a move that some say is a clear
overstep of authority”25 — the members of the industry and others in the
natural products community were left perplexed once again.
“There
are already federal laws and statutes in place to require dietary supplement
firms to only make claims that are truthful and not misleading; obtain
competent and reliable scientific evidence for claim substantiation; and file a
30-day structure/function notification for each claim that they make for
dietary supplement products,” explained NPA’s Fabricant in an NPA press release.44
“The New York attorney general should be inquiring about this information with
the Food and Drug Administration, as the agency should already have this
information at hand.”44
The
author of a recent Natural Products
Insider article expressed similar concerns, but with stronger hints of
frustration and skepticism. “Why is Schneiderman using resources and taxpayer
dollars to investigate something squarely within the expertise and jurisdiction
of the Food and Drug Administration (FDA)?” the author asked.43 “Political gain
and publicity? Likely.”
Self-Reflection
& Future Responses
New
York Attorney General Eric Schneiderman’s selection of major US retailers’
store-brand herbal supplements (of seven relatively well-known herbs) seems to
suggest that he was going after the widest possible audience. Still, consumers
and industry experts alike sometimes wonder how such lower-cost house brands
and generic brands can match the purity and quality of other well-known nationally
branded supplements.
There
are still many unknowns in the attorney general’s unexpected and aggressive
investigation into herbal supplements that began in early February. Faced with
a lack of essential details regarding Schneiderman’s testing procedures,
motivation, or goals, many in the dietary supplement industry have started
asking questions regarding the commitment of some companies to high quality
ingredients and products.
As
Frank Jaksch explained to the San Jose
Mercury News,26 “The bottom line is that this investigation ultimately
raised serious questions about the quality of dietary supplements. In order to
regain consumer trust and provide top quality products as promised, the
industry must use an attack such as the attorney general’s as a catalyst for
change,” he wrote.26 “The debate should lie in how. What should that
change be?”
At
least one proposal seems to have consistent support from natural
products-related organizations, including nonprofits, industry trade groups,
analytical labs, and others:27,45 the need for increased
transparency in all areas of the supply chain. Ideally, increased transparency
would help the industry take a more proactive approach to inevitable negative
press.
“If
anything, this latest and in some ways most damaging round of negative media
coverage based upon what my colleagues and I believe will ultimately be shown
to be flawed science underscores the need for testing transparency,” Sudberg wrote.27
“Companies can no longer afford to just say their products are tested; they are
going to have to start revealing where they are tested, by what methods and
why.”21
While
advocating for these higher standards, representatives in the industry and
other relevant herb-focused organizations should remember to keep their message
simple. In the case of the recent New York attorney general investigation, it may
be safe to presume that the minutia of barcoding analyses — despite the
validity of the point — will be lost on the average consumer.
“I
just don’t think that’s the kind of storyline that will resonate with our
consumers,” noted Steve Mister, CRN president and CEO, in a recent Nutritional Outlook article.46
“For the most part, consumers don’t want to have to determine between DNA
analysis and chemical analysis. They want to trust the brands that they buy.”46
*New York Times staff writer Anahad
O’Connor has covered major herbal supplement-related news developments in the
past, including the highly problematic 2013 Newmaster et al. study16
alleging widespread adulteration.
—Tyler Smith
References
1.
A.G. Schneiderman Asks Major Retailers
To Halt Sales Of Certain Herbal Supplements As DNA Tests Fail To Detect Plant
Materials Listed On Majority Of Products Tested [press release]. Albany, NY:
New York State Attorney General’s Office; February 2, 2015. Available at: www.ag.ny.gov/press-release/ag-schneiderman-asks-major-retailers-halt-sales-certain-herbal-supplements-dna-tests. Accessed February 24, 2015.
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O’Connor A. New York Attorney General
Targets Supplements at Major Retailers. New
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in Those Supplements? New York Times.
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4. O’Connor A. Chains
Pull Dietary Aids Off Shelves After Inquiry. New York Times. February 12, 2015. Available at: http://well.blogs.nytimes.com/2015/02/12/chains-pull-dietary-aids-off-shelves-after-inquiry/. Accessed February 24, 2015.
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O’Keefe M. Supplement experts: AG Eric
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9.
ABC Says New York Attorney General
Misused DNA Testing for Herbal Supplements, Should Also Have Used Other Test
Methods as Controls [press release]. Austin, TX: American Botanical Council;
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CRN Criticizes New York State Attorney
General ‘Sting’ on Herbal Dietary Supplements As Uninformed, Reckless and
Inexcusable [press release]. Washington, DC: Council for Responsible Nutrition;
February 3, 2015. Available at: www.crnusa.org/CRNPR15-CRNCriticizesNYAGHerbal020315.html. Accessed March 3, 2015.
12.
Upton R. American Herbal Pharmacopoeia Responds to New York Attorney General with
Extensive Analytical Data on testing for Botanical Adulteration [press
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Available at: www.herbal-ahp.org/documents/newsroom/NY%20AG%20Response%202.pdf.
Accessed March 6, 2015.
13.
Daniells S. ‘Uninformed’,
‘inappropriate’ and ‘premature’: Industry experts round on NY AG’s action
against major retailers over failed DNA tests for herbal supplements.
NutraIngredients-USA website. Available at: www.nutraingredients-usa.com/Research/NY-AG-takes-on-GNC-Walgreens-Walmart-Target-on-herbal-supplements.
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