April 8, 2020
To: BAPP Underwriters, Endorsers, Supporters, ABC Members, AHP Members, Valued Industry and Botanical Community Stakeholders
Re: Update from the Botanical Adulterants Prevention Program Regarding BAPP’s Role in the COVID-19 Pandemic
Dear Herb Industry and Medicinal Plant Community Friend and Colleague:
As we all work our way through this most unfortunate and disruptive COVID-19 pandemic, we fervently hope that you and your family and work associates are safe and robustly healthy.
We are taking this opportunity to share with you how we see the significant and essential role that the ABC-AHP-NCNPR Botanical Adulterants Prevention Program (BAPP) has in the botanical ingredients industry.
We at the American Botanical Council (ABC) and BAPP are deeply concerned about the integrity of the botanical supply chains and value networks that provide botanical ingredients for products intended to enhance consumer health. Our expectations for near-term supply chain strategies include the need for heightened quality control vigilance and diligence, particularly related to establishing the proper identity of botanical raw materials, extracts, and essential oils.
Accordingly, we want to remind you of the many BAPP consumer protection tools that your generous support has enabled us to provide over the past almost-10 years. We are all in this challenging situation together, and we want to work more closely with our friends and colleagues in any appropriate way that can help enhance supply chain integrity with respect to preventing adulterated materials from getting into the dietary supplement, conventional food, cosmetic, and natural products markets.
It is a scientific truism that nature abhors a vacuum. History teaches that a supply chain disruption, or a series of such disruptions — be they due to crop failure, weather issues, political developments in countries where some herbs are grown, sudden spikes in consumer demand, and/or the many combinations of abrupt, unplanned changes to the supply and demand sides of commerce in botanical materials — causes adulteration and fraud (i.e., criminal activity) to increase.
When fraudulent practices are associated with one ingredient, it is obviously unfavorable and unfortunate for consumers, health professionals, researchers, and the herb industry as a whole. When this happens due to simultaneous interruptions of numerous ingredients based on a global pandemic, it is predictable that unscrupulous suppliers and sellers of botanical (and other) ingredients will attempt to take even greater advantage of short- or long-term supply dislocations and shortages. The result can be — and predictably will be — an increase in availability of fraudulent ingredients. Based on our many years of experience in the botanical industry, we think it reasonable to expect an increase in ingredient adulteration. We also expect that new forms of adulteration may emerge.
With the US Food and Drug Administration’s having recently reduced inspections amid this global chaos, there will be less government oversight of storage and production facilities in the botanical supply chain in the United States and elsewhere. This may entice some companies to loosen up on their testing requirements, thus possibly facilitating the sale of adulterated material.
Accordingly, buyers must be more vigilant than ever before in the assurance of ingredient quality, particularly the first step in quality assessment — the determination of proper identity. Responsible buyers, even those with relatively robust quality control programs, may need to double- or even triple-down on QC measures that deal with ingredient identity and authenticity.
Understandably, analytical laboratories are busy with ingredient testing as buyers seek to source alternative suppliers and establish supply chain redundancy in order to preserve and protect an uninterrupted supply of authentic botanical ingredients. We believe that integrating the many quality control resource tools that are currently freely available from BAPP into industry quality programs — especially into ingredient specifications, qualification, and testing protocols — is mission-critical more than ever before.
We encourage buyers of botanical ingredients to take the time to engage their quality team to review and adopt these BAPP tools (and other appropriate resources, such as USP, Ph. Eur., AHP, and others) — today. It is a moral imperative amidst what we believe may become a highly challenging and unprecedented supply chain threat. Until we know how this will evolve over the next several months, we encourage an abundance of caution and heightened testing to protect every botanical stakeholder.
To clarify for the sake of some stakeholders who may not be very familiar with BAPP and its publications, to date, BAPP has published 57 peer-reviewed documents on its website. The many resources and tools that BAPP has provided over the years include 20 Botanical Adulterants Prevention Bulletins that confirm which herbs are subject to adulteration, and how this adulteration is done. In addition, BAPP has published 10 Laboratory Guidance Documents (LGD) in which we thoroughly review known published laboratory analytical methods and evaluate their fitness-for-purpose to deal with the types of adulteration that has been confirmed for a particular botanical ingredient. The importance of BAPP’s LGDs cannot be over-estimated: outdated and not fit-for-purpose methods can be ‘fooled’ by some of the more sophisticated methods of adulteration.
As part of this important communication, we would like to share with you the thoughts of Steve Mister, president of the Council for Responsible Nutrition (CRN), who wrote the following to his members in response to BAPP’s publishing last week the Turmeric Raw Materials and Products Laboratory Guidance Document. Turmeric is an herb which, according to CRN, is experiencing “exploding” demand “amidst supply chain disruptions.”
Mister wrote: “The supply chain disruptions brought about by COVID-19 will likely bring supply shortages of turmeric that will heighten the temptation to substitute other substances, i.e., lesser quality material that may be adulterated and even dyed to look like turmeric. ABC’s Botanical Adulterants Prevention Program offers ways to identify product, spot counterfeit or inferior materials, and protect your supply chains. Adopting appropriate methods is an excellent way to protect your consumers and avoid introducing fraudulent material into the market. That’s what it means to be ‘responsible.’”
In February, we sent a notice about a survey that we created to help us understand more about how many of our colleagues and stakeholders in the botanical industry have been reading and utilizing our BAPP publications, particularly the Bulletins and the LGDs. By February 28, we received 105 responses. Numerous respondents indicated that they not only read and utilize BAPP’s extensively peer-reviewed and authoritative publications, but they also use them as the basis for setting or resetting botanical ingredient specifications for the development of herb products they manufacture and/or market, with some respondents declaring that they have changed ingredient suppliers as a result of the new specifications.
If you have not yet reviewed and responded to this brief survey, we invite you do so now by filling out the survey here. Your comments and feedback are deeply important to us.
During these challenging times, we are reminded of how we are all together on one planet. We can, with your cooperation, participation, and support, take the current supply disruption to create transformative changes that will benefit us all.
We thank you for your continuing support, engagement, and collaboration. We hope that you, your loved ones, and your professional and business associates will remain safe and robustly healthy, as we move through this, together.
Mark Blumenthal, ABC Founder & Executive Director; BAPP Founder & Director
Stefan Gafner, PhD, ABC Chief Science Officer; BAPP Technical Director
Ikhlas Khan, PhD, Director, National Center for Natural Products Research, University of Mississippi
Roy Upton, AHG (DAyu), President, American Herbal Pharmacopoeia
Michael D. Levin, Founder, Health Business Strategies, LLC; Special Expert Consultant to BAPP