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Dietary Supplement Label Review Checklist

by NaturPro in Uncategorized Comments: 0

The Food & Drug Administration (FDA) has specific rules for labeling and claims related to dietary supplements on packaging, marketing, websites, inserts and other promotional materials. If a label states a false or misleading claim, FDA, other regulatory agencies or class-action attorneys may file warning letters or lawsuits.

Dietary Supplement Label Review Checklist

⊗ PACKAGING REQUIREMENTS

Five general requirements for labels include: 1) the statement of identity (name of the dietary supplement), 2) the net quantity of contents statement (amount of the dietary supplement), 3) the nutrition labeling (Supplement Facts Panel), 4) the ingredient list, and 5) the name and place of business of the manufacturer, packer, or distributor.

⊗ LABEL STATEMENTS

You must place all required label statements either on the front label panel (the principal display panel) or on the information panel (usually the label panel immediately to the right of the principal display panel, as seen by theconsumer when facing the product), unless otherwise specified by regulation(i.e., exemptions).

⊗ SUPPLEMENT FACTS PANEL

Total calories, calories from fat, total fat, saturated fat, cholesterol, sodium, totalcarbohydrate, dietary fiber, sugars, protein, vitamin A, vitamin C, calcium, andiron must be listed when they are present in measurable amounts. Calories from saturated fat and the amount of polyunsaturated fat, monounsaturated fat, soluble fiber, insoluble fiber, sugar alcohol, and other carbohydrate may be declared, but they must be declared when a claim is made about them.

⊗ INGREDIENT LIST

When present, you must place the ingredient list on dietary supplementsimmediately below the nutrition label, or if there is insufficient space belowthe nutrition label, immediately contiguous and to the right of the
nutrition label.

⊗ WARNING STATEMENT

FDA requires warning statements related to safety and special precautions that, if not followed, could make the product unsafe.

⊗ UNITS OF MEASUREMENT

Proper units of measurement must be used, for example milligrams (mg), micrograms (mcg) or other appropriate units

⊗ PERCENTAGE DAILY VALUE (DV)

The % DV must be declared for all dietary ingredients for which FDA has established Daily Values, except that 1) the percent for protein may be omitted, and 2) on the labels of dietary supplements to be used by infants, children less than 4 years of age, or pregnant or lactating women, you must not list any percent for total fat, saturated fat, cholesterol, total carbohydrate,dietary fiber, vitamin K, selenium, manganese, chromium, molybdenum,chloride, sodium, or potassium.

⊗ DOMESTIC ADDRESS OR PHONE NUMBER

The label of a dietary supplement being marketed in the United States must include a domestic address or domestic phone number through which the responsible person may receive a report of a serious adverse event with such dietary supplement. If the label does not include the required domestic address or phone number, the dietary supplement is misbranded.

⊗ UPC BAR CODE

The UPC bar code may be obtained from the Uniform Code Council (www.uc-council.org)

⊗ NATURAL AND ARTIFICIAL FLAVORS

You must declare these ingredients in ingredient lists by using either specific common or usual names or by using the declarations  “natural flavor” or “artificial flavor,” or any combination thereof.

⊗ CHEMICAL PRESERVATIVES

You must list the common or usual name of the preservative, which may be followed by a description that explains its function e.g., “preservative,” “to retard spoilage,”“a mold inhibitor,” “to help protect flavor,” or “to promote color retention.”

⊗ OTHER DIETARY INGREDIENTS

You must list “other dietary ingredients” by common or usual name in acolumn or linear display. FDA has not specified an order that you must follow. You must list the quantitative amount by weight per serving immediately following the name of the dietary ingredient or in a separate column. You must place a symbol in the column for “% Daily Value” that refers to the footnote “Daily Value Not Established,” except that the symbol must follow the weight when you do not use the column format.

⊗ LIQUID EXTRACTS

You must list liquid extracts using the volume or weight of the total extract and the condition of the starting material prior to extraction when it was fresh. You may include information on the concentration of the dietary ingredient and the solvent used. The solvent must be identified in either the nutrition label or ingredient list.

⊗ DRIED EXTRACTS

For dietary ingredients that are extracts from which the solvent has been removed, you must list the weights of the dried extracts.

⊗ CONSTITUENTS

You may list constituents of a dietary ingredient indented under the dietary ingredient and followed by their quantitative amounts by weight per serving. You may declare the constituents in a column or in a linear display.

⊗ PROPRIETARY BLENDS

You must identify proprietary blends by use of the term “Proprietary Blend” or an appropriately descriptive term or fanciful name. On the same line, you must list the total weight of all “other dietary ingredients” contained in the blend. Indented underneath the name of the blend, you must list the “other dietary ingredients” in the blend, either in a column or linear fashion, in descending order of predominance by weight. These ingredients should be followed by a symbol referring to the footnote “Daily Value Not Established.”Dietary ingredients having RDIs or DRVs must be listed separately and the individual weights declared.

⊗ PRODUCT CLAIMS

Claims come in four basic varieties:

  • structure/function claims
  • disease claims
  • health claims and qualified health claims
  • content claims

Basically, dietary supplements cannot make “disease” claims (for example: “treats cancer”). Dietary supplements that make disease claims are considered by FDA as drugs.

Dietary supplements can make “structure/function” claims (for example, “calcium builds strong bones”). A structure/function claim describes the product’s role in maintaining the “structure or function of the body,” or “general well-being.”

The Federal Trade Commission (“FTC”) has overlapping jurisdiction with the federal Food and Drug Administration (“FDA”), and focuses more on whether advertising is truthful, or false and misleading. Thus, it is important to respect nuanced labeling rules, including those regarding the statement of the identity.

⊗HIGH POTENCY CLAIMS

The regulation states that the term “high potency” may be used in a claim on the label or in labeling to describe individual vitamins or minerals thatare present at 100 percent or more of the Reference Daily Intakes (RDI) per reference amount customarily consumed (21 CFR 101.54(f)(1)(i)). This means a supplement may be labeled as “high potency” for each nutrient(s) that is present at 100% of the RDI per serving.

⊗ ANTIOXIDANT NUTRIENT CONTENT CLAIMS

A claim that describes the level of antioxidant nutrients present in a food is a nutrient content claim and may be used on the label or in the labeling of a food when the conditions of use in the regulation are met (21 CFR 101.54(g)).

The antioxidant nutrient must meet the requirements for nutrient content claims in 21 CFR 101.54.

⊗SUGAR-FREE CLAIMS

A dietary supplement may include claims in labeling such as “sugar free,” “no sugar,” or other claims provided it meets all of the eligibility criteria set forth in the regulation.

Among other requirements, a food must be labeled as “low calorie” or “reduced calorie” or bear a relative claim of special dietary usefulness. However, a dietary supplement that is prohibited from bearing a “low calorie”or “reduced calorie” claim can still use a sugar-free claim provided it meets the “low calorie” requirement in 21 CFR 101.60.

⊗HIGH OR GOOD SOURCE CLAIMS

You may make a “high” claim when your dietary supplement contains atleast 20% of the Daily Value (DV) (i.e. the Reference Daily Intake (RDI) or Daily Reference Value (DRV)) of the nutrient that is the subject of the claim perreference amount customarily consumed. You may make a “good source”claim when your dietary supplement contains 10 to 19% of DV.

⊗ LOW OR FREE-FROM CLAIMS

If a similar dietary supplement is normally expected to contain a nutrient and your dietary supplement is specially processed, altered, formulated, or reformulated as to lower the amount of the nutrient in the food, remove the nutrient in the food, or not include the nutrient, then you are permitted to make a “low” or “free” claim as applicable.

⊗ LOW CALORIE CLAIMS

A “low calorie” claim may not be made on dietary supplements, except when an equivalent amount of a dietary supplement that the labeled dietary supplement resembles and for which it substitutes (e.g., another protein supplement), normally exceeds the definition for “low calorie.”

⊗ QUALIFIED HEALTH CLAIMS

FDA will permit the use of a qualified health claim provided that 1) FDA hasissued a letter stating the conditions under which we will consider exercisingenforcement discretion for the specific health claim, 2) the qualified claim is accompanied by an agency-approved disclaimer, and 3) the claim meets all the general requirements for health claims in 21 CFR 101.14, except forthe requirement that the evidence for the claim meet the validity standard for authorizing a claim, and the requirement that the claim be made in accordance with an authorizing regulation.

This guidance was prepared by the Office of Nutritional Products, Labeling and Dietary Supplements (ONPLDS) in the Center for Food Safety and Applied Nutrition (CFSAN) at the U.S. Food and Drug Administration.

Further reading:

Article: Food and Supplement Claims with Confidence

Food and Supplement Testing for Natural Products

Dietary Supplement Facts and Label Review FAQ

Dietary Supplement and Food Label Review

 

 

Food & Supplement Testing for Natural Products


Testing Foods, Supplements and Ingredients

NaturPro offers independent laboratory support for food & supplement testing for natural products.

Have natural product analysis questions? Contact Us..

Why Testing is Important: Supplement and natural product testing with a compliant laboratory is required by FDA for foods, dietary supplements and ingredients to ensure they meet standards for safety, quality and effectiveness. For example, identity, potency and purity are quality control parameters needed to legally sell a natural product as an ingredient, food or dietary supplement.

NaturPro Scientific is driven to achieve the right answers for our clients.  Some have even called us the UnLab. Why?

Being independent means that we do not own or have interest in any laboratory, which means we are free to pick from the top scientific experts for each type of test or analysis. As a result, we are truly able to work on behalf of our clients, to ensure that correct methods are used and results are obtained.


Natural Product and Supplement Testing Consultants

Natural Product and Supplement Testing Consultants

We know which labs are experienced with ginseng, but not with ginkgo — and this can mean a world of difference in test results.


11 reasons to use a supplement testing consultant for natural products:

  1. To ensure analytical methods used are valid and fit for purpose
  2. To make sure laboratories don’t take shortcuts with your sample
  3. To determine if results are precise and accurate
  4. To replicate the results of another lab
  5. To resolve out-of-specification test results
  6. To resolve disputes in data reports
  7. To determine if “dry-labbing” may be occurring
  8. To have an independent expert to review methods and results
  9. To perform due diligence on a supplier or partner
  10. To eliminate the potential for perceived conflict of interest when testing own products
  11. To qualify a lab as a good partnership choice.

3 main benefits of food and natural products testing consultants:

  1. Better analysis and testing validity  for reliable, replicable and defensible results.
  2. Fast turnaround and lower testing costs.
  3. Reduced retesting, rejections, production delays and product recalls.

Bottom Line – NaturPro knows the right methods and labs to use, and the right questions to ask. We know the shortcuts that testing labs can take, and how to prevent that from happening to you, to ensure testing gives the most scientific, accurate and defensible results possible.

 


Contact Us with your Testing Questions

AOAC ERP of the Year to Kombucha Alcohol Group

by NaturPro in Uncategorized Comments: 0

NaturPro Contributes to Expert Panel Receiving AOAC Award: “ERP of the Year” to Kombucha Alcohol Group

The AOAC Expert Review Panel (ERP) charged with reviewing methods of analysis for ethanol in kombucha initially met in September 2016 to review methods against AOAC SMPR 2016.001 (Determination of Ethanol in Kombucha). At this meeting, the ERP adopted an Official Method of Analysis for First Action status, AOAC 2016.12 (Determination of Ethanol in Kombucha) using gas chromatography with flame ionization detection (GC-FID). The selection and validation of this method was coordinated by NaturPro Scientific and performed by Covance Laboratories, Wisconsin.

kombucha tea testing alcohol ethanol

Method adopted for kombucha tea testing for alcohol in validated labs

AOAC states: “The ERP’s work directly impacts the resolution of urgent and key issues identified by industry, and serves as a forum where both the kombucha industry and government work together.

“The ERP was selected because its open and thorough scientific scrutiny of methods and its output clearly demonstrate the culmination of an industry-wide effort that facilitates regulatory and industry engagement for addressing urgent analytical disputes and facilitating trade. All ERP members receive the award, and publicly receiving the award on behalf of the group is the ERP chair, Sneh Bhandari.

“The Expert Review Panel (ERP) of the Year Award recognizes an ERP for achieving and completing signicant milestone(s) (e.g., Final report, First Action Method, Final Action Method), highlighted by some unique or particularly noteworthy aspect of a review panel report, such as innovative technology or application, breadth of applicability, critical need, difficult analysis, or timeliness.

“The report demonstrates significant merit as to the scope of the project, diversity of the panel, or an innovative approach to difficult analytical challenges. The report must have been submitted within the last 3 years.”

 

 

Cannabis Consultants

by NaturPro in Uncategorized Comments: 0

NaturPro Scientific stands out as consultants who work for our clients.

Our history: We have more than 30 years experience in developing the scientific aspects of botanical products to support human health. So when we started to work on cannabis, hemp and CBD products in 2013, it was second nature.

There are a lot of things to consider when developing cannabis products or hiring a consultant.

  1. Whether your partners understand regulations, compliance and quality assurance, and how to balance these with business. We help you meet the legal requirements and regulations, without breaking the bank.
  2. Scientific expertise and experience across all the function platforms of health product businesses. Whether it’s the science, regulations, communications, validation or due diligence needed, you need someone who’s going to share expert opinions with honesty and transparency.
  3. Inside knowledge of industry standards through active participation on committees of industry standards-setting organizations like American Herbal Products Association, ASTM International and the U.S. Hemp Roundtable. We have a solid reputation in the food, supplement, CBD and cannabis  industry as someone you can trust.
  4. Experience consulting and working efficiently with companies of all sizes and types. Our clients ultimately value our knowledge of both the ideal and the practical, and helping to bridge the gap between efficiently and cost effectively.

Contact us today to learn more about how our expert consultants can help drive your cannabis firm and products to groundbreaking innovation, compliance and success.

——————-

Cannabis Consultants and Experts in Innovation, Product Development and Regulatory Compliance

——————-

Quick Links:

——————–

 

NaturPro Scientific is a recognized leader in regulatory compliance, GMP and quality assurance on CBD, cannabis, botanical drugs, dietary supplements and foods.

What are Good Manufacturing Practices?  Good Manufacturing Practices (GMP) ensures products are consistently produced and controlled to the quality standards and conform to all applicable regulatory requirements.  Good Manufacturing Practices are fundamental to any manufacturing industry and are often required to be implemented in plants and factories by national governments.  Our team of experts can assist you with the development and evaluation of GMP programs  for cannabis, marijuana, hemp and CBD products.

We help you to train qualified staff, get in-depth and correct understanding of standards, and establish comprehensive management systems.

Audits for GMP and Quality Assurance

Here are some of the services we offer for cannabis compliance:

  • Audits
    • Preliminary Gap Analysis
    • Facility GMP pre-audits
    • Internal Audits
    • Third-Party Audits
    • CAPA Audits
  • Quality Management
  • Materials Testing
  • Process Approvals
  • Documentation and SOP
    1. Quality Manual
    2. Recordkeeping
    3. Document Control
    4. Traceability & Recall
      1. Formula Records
      2. Batch Records
      3. Certificates of Analysis
    5. Risk Analysis
      1. Hazard Analysis
      2. Purchasing Criteria & Specifications
    6. Supplier Qualification
    7. Preventive Controls
    8. Product Approval & Rejection, Material Inspection
    9. Complaints & CAPA (Corrective Actions)
    10. Quality Issue Investigation and Resolution
  • Training and Hiring
  • Investor Due Diligence
cannabis-consultants-extraction-GMP

NaturPro Scientific are cannabis consultants for extraction and GMP

NaturPro works closely with our clients to provide the most cost effective way to achieve GMP certification and an edge in the market.

The 4 main benefits of our audits (among many) include:

  1. Understanding where you are may not meet regulatory requirements
  2. Provide reviews and recommendations from a fresh perspective
  3. Train your staff on dealing with regulatory audits
  4. Reduce the risk of a food safety issue or costly product recall.

Audits are an integral part of the licensing and ongoing regulatory compliance process for cannabis, marijuana and CBD products. Cannabis audits can be rigorous, and are seen as a true ‘stress test’ on your quality system.

Pre-License Audits
Prior to issuing a license (e.g.,  Cultivation, Processor, Retail), regulators may require demonstration  compliance with the relevant cannabis regulation, and to ensure implementation of critical regulatory requirements such as physical security requirements, recordkeeping and good production practices. Licensed cannabis firms are required to demonstrate regulatory compliance at these audits in order to achieve (and maintain) their license.

Introductory Audits

An introductory audit may be scheduled after the pre-licensing audit, when the licensee is ready to start production. NaturPro Scientific is often hired to participate in and support our clients before, during and after regulatory audits. This audit is conducted to verify compliance against regulations in addition to inventory control/activities.

GMP Audit 
This type of audit assesses compliance against established Good Manufacturing Process (GMP) guidelines. Our experts have extensive experience with GMP audits to assist cultivators and processors  identify gaps against the regulations/standards, and putting appropriate corrective and preventative actions in place.

Quality Assurance
NaturPro has FDA-trained food safety experts (PCQI) and chemists on staff, and we are often called to perform duties of a Quality Manager for our clients. We handle and interpret lab testing, support supply chain and supplier qualification based on best practices for cannabis and botanical drugs.

 

Standard operating procedures (SOP) for cultivation, processing and testing operations can be challenging. NaturPro Scientific’s experience with SOP helps you get to your desired outcome quickly and efficiently.

Our experience in cannabis includes:

  • Currently serve on ASTM International and American Herbal Products Association (AHPA) Cannabis Committees
  • Supported the development of operating standards and wrote standard operating procedures (SOP) for Good Manufacturing Practices (GMP) for cannabis standards‐setting organization, currently under review by ASTM International
  • Currently serve as regulatory and quality assurance consultant for hemp industry and trade organizations
  • Founding member of new self regulatory organization for hemp and CBD products
  • Coordinated initial R&D, production, quality assurance and regulatory affairs for a cannabis startup with operations in Washington, Colorado and Nevada
  • Assisted in development of cannabis license applications in New York, Florida, California, Colorado and Louisiana
  • Established analytical testing standards and guidelines for potency and purity of cannabis products
  • Audited cannabis analytical laboratory data according to ISO 17025 standards
  • Developed in‐house formulas, materials lists, manufacturing processes, manufacturing records and operational guidelines for cannabis extract and finished product production
  • Developed R&D for and commercial processes for large‐scale extraction and purification of cannabinoids and terpenes from cannabis

CBD Procedures and SOP (Standard Operating Procedures) are the central part of operations of any cultivation, extraction, processing, packaging or testing business. Startups who invest in solid standard operating procedures (SOP) find themselves several steps ahead, running efficiently, with well-trained staff, and don’t suffer any costly mistakes.

CBD SOP are required by each state where cannabis, marijuana or hemp are regulated.

Any cannabis, hemp, medical or adult-use (recreational) marijuana product is subject to a number of controls, from seed to shelf. NaturPro Scientific has supported a number of clients in the aim of providing safe, effective cannabis and hemp products to support human health.


  1. Cultivation or Processing
    1. Management
    2. Applicable Regulations
    3. Operations
    4. Training & Safety
    5. Hygiene
    6. Sanitation & Cleaning
    7. Farm or Facility
    8. Equipment
    9. Seeds and Propagation Materials
    10. Agricultural Inputs
    11. Pre-harvest practices
    12. Harvesting
    13. Post-harvest practices
    14. Drying & Milling
    15. Sampling
    16. Testing (Potency, purity, cannabinoids, microbiology, heavy metals, pesticides)
    17. Waste Management
  2. Quality Management Systems
    1. Product Quality Policy/Manual
    2. Recordkeeping
      1. Document Control
      2. Formula Records
      3. Batch Records
      4. Certificates of Analysis
    3. Traceability & Recall
    4. Risk Analysis
      1. Hazard Analysis
      2. Purchasing Criteria & Specifications
      3. Supplier Qualification
      4. Intentional Adulteration
      5. Preventive Controls
    5. Product Approval & Rejection, Material Inspection
    6. Complaints & CAPA (Corrective Actions)

CBD Quality Consultants and Experts 

by NaturPro in Uncategorized Comments: 0

In a world where everyone claims to be an expert, NaturPro Scientific stands out as consultants who work for our clients.

Our history: We have more than 30 years experience in developing the scientific aspects of botanical products to support human health. So when we started to work on cannabis, hemp and CBD products in 2013, it was second nature.

Our experience: There are a lot of things to consider when developing cannabis products or hiring a consultant.

First, is whether your partners understand regulations, compliance and quality assurance, and how to balance these with business. We help you meet the legal requirements and regulations, without breaking the bank.

Second, is scientific expertise and experience across all the function platforms of health product businesses. Whether it’s the science, regulations, communications, validation or due diligence needed, you need someone who’s going to share expert opinions with honesty and transparency.

Third, is inside knowledge of industry standards through active participation on committees of industry standards-setting organizations like American Herbal Products Association, ASTM International and the U.S. Hemp Roundtable. We have a solid reputation in the food, supplement, CBD and cannabis  industry as someone you can trust.

Fourth — is experience consulting and working efficiently with companies of all sizes and types. Our clients ultimately value our knowledge of both the ideal and the practical, and helping to bridge the gap between efficiently and cost effectively.

Contact us today to learn more about how our expert consultants can help drive your cannabis firm and products to groundbreaking innovation, compliance and success.

——————-

CBD Quality Consultants and Experts Specializing in Innovation and Product Development and Regulatory Compliance

——————-

Quick Links:

——————–

 

NaturPro Scientific is a recognized leader in audits, GMP and quality assurance on CBD, cannabis, botanical drugs, dietary supplements and foods.

What are Good Manufacturing Practices?  Good Manufacturing Practices (GMP) ensures products are consistently produced and controlled to the quality standards and conform to all applicable regulatory requirements.  Good Manufacturing Practices are fundamental to any manufacturing industry and are often required to be implemented in plants and factories by national governments.  Our team of experts can assist you with the development and evaluation of GMP programs  for cannabis, marijuana, hemp and CBD products.

We help you to train qualified staff, get in-depth and correct understanding of standards, and establish comprehensive management systems.

CBD Auditors, GMP and Quality Assurance

Here are some of the services we offer for cannabis compliance:

  • Audits
    • Preliminary Gap Analysis
    • Facility GMP pre-audits
    • Internal Audits
    • Third-Party Audits
    • CAPA Audits
  • Quality Management
  • Materials Testing
  • Process Approvals
  • Documentation and SOP
    1. Quality Manual
    2. Recordkeeping
    3. Document Control
    4. Traceability & Recall
      1. Formula Records
      2. Batch Records
      3. Certificates of Analysis
    5. Risk Analysis
      1. Hazard Analysis
      2. Purchasing Criteria & Specifications
    6. Supplier Qualification
    7. Preventive Controls
    8. Product Approval & Rejection, Material Inspection
    9. Complaints & CAPA (Corrective Actions)
    10. Quality Issue Investigation and Resolution
  • Training and Hiring
  • Investor Due Diligence
cannabis-consultants-extraction-GMP

NaturPro Scientific are cannabis consultants for extraction and GMP

NaturPro works closely with our clients to provide the most cost effective way to achieve GMP certification and an edge in the market.

The 4 main benefits of our audits (among many) include:

  1. Understanding where you are may not meet regulatory requirements
  2. Provide reviews and recommendations from a fresh perspective
  3. Train your staff on dealing with regulatory audits
  4. Reduce the risk of a food safety issue or costly product recall.

Audits are an integral part of the licensing and ongoing regulatory compliance process for cannabis, marijuana and CBD products. Cannabis audits can be rigorous, and are seen as a true ‘stress test’ on your quality system.

Pre-License Audits
Prior to issuing a license (e.g.,  Cultivation, Processor, Retail), regulators may require demonstration  compliance with the relevant cannabis regulation, and to ensure implementation of critical regulatory requirements such as physical security requirements, recordkeeping and good production practices. Licensed cannabis firms are required to demonstrate regulatory compliance at these audits in order to achieve (and maintain) their license.

Introductory Audits

An introductory audit may be scheduled after the pre-licensing audit, when the licensee is ready to start production. NaturPro Scientific is often hired to participate in and support our clients before, during and after regulatory audits. This audit is conducted to verify compliance against regulations in addition to inventory control/activities.

GMP Audit 
This type of audit assesses compliance against established Good Manufacturing Process (GMP) guidelines. Our experts have extensive experience with GMP audits to assist cultivators and processors  identify gaps against the regulations/standards, and putting appropriate corrective and preventative actions in place.

Quality Assurance
NaturPro has FDA-trained food safety experts (PCQI) and chemists on staff, and we are often called to perform duties of a Quality Manager for our clients. We handle and interpret lab testing, support supply chain and supplier qualification based on best practices for cannabis and botanical drugs.

 

Standard operating procedures (SOP) for CBD processing operations can be challenging. NaturPro Scientific’s experience with SOP helps you get to your desired outcome quickly and efficiently.

Our experience in cannabis includes:

  • Currently serve on ASTM International and American Herbal Products Association (AHPA) Cannabis Committees
  • Supported the development of operating standards and wrote standard operating procedures (SOP) for Good Manufacturing Practices (GMP) for cannabis standards‐setting organization, currently under review by ASTM International
  • Currently serve as regulatory and quality assurance consultant for hemp industry and trade organizations
  • Founding member of new self regulatory organization for hemp and CBD products
  • Coordinated initial R&D, production, quality assurance and regulatory affairs for a cannabis startup with operations in Washington, Colorado and Nevada
  • Assisted in development of cannabis license applications in New York, Florida, California, Colorado and Louisiana
  • Established analytical testing standards and guidelines for potency and purity of cannabis products
  • Audited cannabis analytical laboratory data according to ISO 17025 standards
  • Developed in‐house formulas, materials lists, manufacturing processes, manufacturing records and operational guidelines for cannabis extract and finished product production
  • Developed R&D for and commercial processes for large‐scale extraction and purification of cannabinoids and terpenes from cannabis

CBD Procedures and SOP (Standard Operating Procedures) are the central part of operations of any cultivation, extraction, processing, packaging or testing business. Startups who invest in solid standard operating procedures (SOP) find themselves several steps ahead, running efficiently, with well-trained staff, and don’t suffer any costly mistakes.

CBD SOP are required by each state where cannabis, marijuana or hemp are regulated.

Any cannabis, hemp, medical or adult-use (recreational) marijuana product is subject to a number of controls, from seed to shelf. NaturPro Scientific has supported a number of clients in the aim of providing safe, effective cannabis and hemp products to support human health.


  1. Cultivation or Processing
    1. Management
    2. Applicable Regulations
    3. Operations
    4. Training & Safety
    5. Hygiene
    6. Sanitation & Cleaning
    7. Farm or Facility
    8. Equipment
    9. Seeds and Propagation Materials
    10. Agricultural Inputs
    11. Pre-harvest practices
    12. Harvesting
    13. Post-harvest practices
    14. Drying & Milling
    15. Sampling
    16. Testing (Potency, purity, cannabinoids, microbiology, heavy metals, pesticides)
    17. Waste Management
  2. Quality Management Systems
    1. Product Quality Policy/Manual
    2. Recordkeeping
      1. Document Control
      2. Formula Records
      3. Batch Records
      4. Certificates of Analysis
    3. Traceability & Recall
    4. Risk Analysis
      1. Hazard Analysis
      2. Purchasing Criteria & Specifications
      3. Supplier Qualification
      4. Intentional Adulteration
      5. Preventive Controls
    5. Product Approval & Rejection, Material Inspection
    6. Complaints & CAPA (Corrective Actions)

CBD and Cannabis Audits, GMP and Quality

by NaturPro in Quality Comments: 0

NaturPro Scientific is a recognized leader in audits, GMP and quality assurance on cannabis, botanical drugs, dietary supplements and foods.

What are Good Manufacturing Practices?  Good Manufacturing Practices (GMP) ensures products are consistently produced and controlled to the quality standards and conform to all applicable regulatory requirements.  Good Manufacturing Practices are fundamental to any manufacturing industry and are often required to be implemented in plants and factories by national governments.  Our team of experts can assist you with the development and evaluation of GMP programs  for cannabis, marijuana, hemp and CBD products.

We help you to train qualified staff, get in-depth and correct understanding of standards, and establish comprehensive management systems.

CBD and Cannabis Auditors, GMP and Quality Assurance

Here are some of the services we offer for cannabis compliance:

  • Audits
    • Preliminary Gap Analysis
    • Facility GMP pre-audits
    • Internal Audits
    • Third-Party Audits
    • CAPA Audits
  • Quality Management
  • Materials Testing
  • Process Approvals
  • Documentation and SOP
    1. Quality Manual
    2. Recordkeeping
    3. Document Control
    4. Traceability & Recall
      1. Formula Records
      2. Batch Records
      3. Certificates of Analysis
    5. Risk Analysis
      1. Hazard Analysis
      2. Purchasing Criteria & Specifications
    6. Supplier Qualification
    7. Preventive Controls
    8. Product Approval & Rejection, Material Inspection
    9. Complaints & CAPA (Corrective Actions)
    10. Quality Issue Investigation and Resolution
  • Training and Hiring
  • Investor Due Diligence
cannabis-consultants-extraction-GMP

NaturPro Scientific are cannabis consultants for extraction and GMP

NaturPro works closely with our clients to provide the most cost effective way to achieve GMP certification and an edge in the market.

The 4 main benefits of our audits (among many) include:

  1. Understanding where you are may not meet regulatory requirements
  2. Provide reviews and recommendations from a fresh perspective
  3. Train your staff on dealing with regulatory audits
  4. Reduce the risk of a food safety issue or costly product recall.

Audits are an integral part of the licensing and ongoing regulatory compliance process for cannabis, marijuana and CBD products. Cannabis audits can be rigorous, and are seen as a true ‘stress test’ on your quality system.

Pre-License Audits
Prior to issuing a license (e.g.,  Cultivation, Processor, Retail), regulators may require demonstration  compliance with the relevant cannabis regulation, and to ensure implementation of critical regulatory requirements such as physical security requirements, recordkeeping and good production practices. Licensed cannabis firms are required to demonstrate regulatory compliance at these audits in order to achieve (and maintain) their license.

Introductory Audits

An introductory audit may be scheduled after the pre-licensing audit, when the licensee is ready to start production. NaturPro Scientific is often hired to participate in and support our clients before, during and after regulatory audits. This audit is conducted to verify compliance against regulations in addition to inventory control/activities.

GMP Audit 
This type of audit assesses compliance against established Good Manufacturing Process (GMP) guidelines. Our experts have extensive experience with GMP audits to assist cultivators and processors  identify gaps against the regulations/standards, and putting appropriate corrective and preventative actions in place.

Quality Assurance
NaturPro has FDA-trained food safety experts (PCQI) and chemists on staff, and we are often called to perform duties of a Quality Manager for our clients. We handle and interpret lab testing, support supply chain and supplier qualification based on best practices for cannabis and botanical drugs.

Food and Supplement Product Manufacturing Feasibility


Knowing whether a material will be able to be made into a product is a key step to product development. A lot of natural products are unstable, insoluble, non-flowable, terrible tasting, or otherwise challenging to mix into the desired product form.

In today’s ‘clean label’ demanding market, many of the additives used to make a high quality tablet or beverage are no longer salable.

Food and Supplement Product Manufacturing Feasibility

Related to the exercise of understanding manufacturing feasibility, we also offer a number of production-related services:

  • Source and qualify bulk raw materials
  • Raw material quality verification program
  • Supplier verification program
  • Facility design and GMP
  • Formula/recipe development
  • Project management
  • Manufacturing process design
  • Equipment qualification, sourcing, IQ/OQ/PQ
  • Contract manufacturer qualification
  • Materials selection & sourcing
  • Packaging & label development
  • Documentation & systems

NaturPro’s core experiences are in understanding how to make better products and better ingredients. Contact us to learn more.

Food and Supplement Product Manufacturing Feasibility

Food and supplement product manufacturing feasibility is the first step in understanding whether the product of your dreams can become a reality.

The Regulatory Patchwork of Dietary Supplements

by NaturPro in Quality Comments: 0

In the United States, dietary supplements and their ingredients are subject to a patchwork of regulations, industry guidance, voluntary certifications and audit programs. With some exceptions, few standards for dietary supplements have been developed with expert consensus and  broadly implemented by the dietary supplement industry.

FDA’s dietary supplement GMPs (good manufacturing practices) are part of the exception and have made today’s supplement products generally a higher level of quality than at any time before.

Dietary Supplement Deming Opinion

In Dietary Supplements, Data is Needed to Support Compliance

Making A Quilt from the Regulatory Patchwork: What Successful, Resourceful Firms Do

Yet few industry standards are clearly understood, consistently applied and sufficiently comprehensive to cover all the ground.

One primary example is the gap between compliance requirements for dietary ingredients (under food GMPs) and dietary supplements, whose GMP framework is derived from that for pharmaceuticals. The underlying litmus test for the level of safety demanded for supplements and foods are different—that of “non-adulteration” versus “safe for human consumption,” Respectively. Maybe due to the differences, supplement GMP audit programs can overlook the food GMPs that govern ingredients. It is not uncommon for a manufacturer and a supplier to speak completely different quality languages. Audits for supplement GMPs are frequently unable to determine to a reasonable degree of certainty whether a particular ingredient, based on its certificate of analysis (CoA), should be expected to meet supplement requirements once it is placed inside a capsule or tablet.

As could be expected, an unintended consequence of this major gap is the common practice of a raw material CoA being duplicated as the manufacturer’s raw material specification.

In this scenario, an ingredient specification has been developed according to food requirements and, often without further analysis or verification, it is assumed to meet the requirements of the finished supplement. The result is a supplement that is essentially of no better quality than the “food-grade” ingredients put into it.

Especially for botanicals and animal-derived raw materials: cultivation, harvesting and processing before the final ‘transformation’ adds another dimension..

Confirming identity and purity is a complicated problem, particularly for a global supply chain of agricultural materials susceptible to contaminants during farming, harvesting, processing, storage or transportation to the ingredient processing facility.

In many poorer countries, the supply chain, and contaminants are not as well regulated as in advanced nations, and are freely shipped with no knowledge of their destination. Likewise, the final manufacturer or end user may have no information on the source of the material beyond the previous dock. In an uncomfortable way, the U.S., with its more lax regulations, often receives the materials rejected by Europe. Thus, potential contaminants may not be necessarily listed on the specification or controlled by the food GMPs, yet they can cause the products to which they are added to be adulterated.

Dozens of standards have been written for agricultural products, many of which don’t (or can’t) apply to the small family farmers who are a predominant source of botanical raw materials. In addition to recent requirements for fresh produce established by the Food Safety Modernization Act (FSMA), which don’t really apply to dried agricultural materials, we also have: USDA good agricultural practices (GAPs), which are intended for large farms and seldom fully practiced in the United States; certified organic, which requires no testing for contaminants like pesticides that may cause a product to be adulterated; independent farm standards like Global GAP, which arealso intended for large, modernized industrial farms; and, dozens of good agricultural and collection practices (GACPs) for medicinal plants that have been independently written by various nations and trade groups.


Some experts say the mess of standards, the dynamics of the industry and the law of entropy do not support the possibility of a clear and unified regulatory structure.


Others recognize the limitations, yet remain busy sewing the patches together into a quilt that is greater than the sum of its parts.


Fortunately,

initiatives are in process or recently completed that contribute to the integrity of our industry quilt and have provided free information. Just in the past couple years:

•             The U.S. Pharmacopoeia (USP) and American Herbal Pharmacopoeia (AHP) developed monographs and methods for testing dietary supplement ingredients.

•             USP also developed a Food Fraud Mitigation Database that lists adulterants common for food ingredients.

•             AOAC International developed analytical methods for dietary supplement ingredient potency and contaminants.

•             The National Institutes of Health’s (NIH) Office of Dietary Supplements (ODS) website became a valuable source of information and resources.

•             Trade groups such as the American Herbal Products Association (AHPA) and American Botanical Council (ABC) made enormous efforts to educate and guide the industry on issues around botanical dietary ingredients and adulteration, including a recently updated draft GACP from AHPA, and the ABC-AHP-National Center for Natural Products Research (NCNPR) Botanical Adulterants Program.

•             The Supplement Online Wellness Library (OWL) was established by the Council for Responsible Nutrition (CRN), to allow labels for supplement products on the U.S. market to be put into in one place.

•             The Supplement Safety and Compliance Initiative (SSCI) was formed as a broad industry initiative, with wide support from trade associations, to address some of the gaps for supplements that aren’t sufficiently covered under other standards. SSCI is led by experienced players in retail, manufacturing and supply, and includes a focus on identity, risk assessment and quality for raw materials.

•             In response to consumer demand, leading retailers, manufacturers and ingredient suppliers invested significant resources into traceability and quality, and are now able to make meaningful claims to these effects that are not only important to consumers, but also serve as a reliable way to differentiate from the competition.

Today’s movement toward a greater level of education and transparency includes a firming of the gaps, especially where raw material traceability and quality are concerned. Successful companies across the entire supply chain are actively improving and adopting new standards, building a level of quality and integrity that provides lasting value to their business. Those who are upping their game are piecing together a quilt of their own, leveraging their quality advantages into claims that deliver marketing value. On the other side, those who continue to rely on ignorance or a lack of regulatory clarity as reason to take no action are increasingly left behind.

In an industry where faceless online product marketers are more common than they should be, and where a list of the tens of thousands of products available on the market is just getting online, our combined efforts to fill in the gaps of the collective regulatory patchwork benefits everyone.

This article was previously published in Natural Products Insider, July 2017. 

Dietary Supplement Ingredients and Raw Materials


NaturPro Scientific are experts in dietary supplement bulk raw materials and ingredients, especially botanicals and herbs.  We know how botanical and medicinal plants are grown, harvested, aggregated, processed, extracted and tested.

We are specialists in qualifying, testing and sourcing herbal dietary ingredients and botanical raw materials used in supplements, foods, pharmaceuticals and cosmetics.


Quick Facts on Bulk Supplement Ingredient Formats, Quality, Testing 

  1. Most raw materials are available as whole, cut, powdered or powdered extract. We recommend and specialize in fully standardized botanical extracts with full supply chain traceability and transparency, meeting the strictest global requirements.
  2. For non-botanicals, we suggest working directly with the manufacturer, and not with a distributor. All certificates of analysis should list the manufacturer’s name and the address of the manufacturing facility where the product was produced, or be accompanied by traceability documentation.
  3. Many raw materials are available as Certified Organic. Most products are naturally non-GMO.
  4. All materials may be tested at dedicated laboratories for the presence and amount of nutrients, potency, microbiology and pathogens, heavy metals, pathogens, 500+ pesticides, 100+ volatile organic compounds and solvents, food allergens and gluten, and mycotoxins.
  5. The testing plan is based on the material specification, which is typically based on the regulatory requirements of the country where the materials will be sold.
  6. We also recognize and actively seek out materials meeting various benchmarked quality standards, such as U.S. 21 CFR 111, USP <561> Articles of Botanical Origin and official pharmacopeial monographs, WHO Good Agricultural and Collection Practices (GACP), USDA Good Agricultural Practices, Fairtrade,  U.N. Forum on Sustainability Standards.

Dietary Supplement Ingredients and Raw Materials 

Here is a partial list of ingredients that we are able to qualify and develop for our clients:

Abies webbiana  (Talispatra)

Abrus precatorius (Rati Gunj)

Acacia arabica (Nilotica)

Acerola Cherry

Achyranthes aspera Seed (Apamarg)

Adhatoda vasica Leaf (Vasa, Adulsa)

Aegle marmelos Fruit (Bilva, Bel)

Aesculus hippocastanum L.

Aglaia roxburghiana Fruit (Priyangu)

Ajmud (Carum roxburgianum)

Allium sativum L.

Aloe ferox Miller

Aloe Gel (Ghrit Kumari)

Aloe vera

Alpha Lipoic Acid

Amalaki, Amla Fruit (Emblica officinalis)

Ambrette Seed (Latakasturi, Muskdana)

Amla Fruit Extract (Phyllanthus emblica)

Amorphophalms konjac

Andrographis Herb (Bhunimba, Kalmegh) Papda)

Andrographis paniculata

Angelica sinensis (Oliv.)Diels

Annatto (Shinduri)

Apple

Arctostaphylos uva-ursi L.

Argemone mexicana Herb (Swarnakshiri)

Argyreia nervosa Seed (Vriddhadaru)

Aristolochia indica Root (Pushkarmul)

Arjun Bark (Terminalia arjuna)

Arrowroot

Artemisia annua L.

Ascorbic Acid

Ascorbyl Palmitate

Ashok Bark (Saraca indica)

Ashwagandha Root (Withania somnifera)

Asparagus racemosus Root (Shatavari)

Astaxanthin

Asteracantha longifolia Seed (Talimakhana)

Astragalus membranaceus(Fisch.)Bge

Atibala Root (Abutilon indicum)

Azadiracta indica Bark (Neem)

Azadiracta indica Leaf (Neem)

B-3 Niacinamide USP

Bacopa monnieri Herb (Brahmi)

Bala Root (Sida cordifolia)

Baliospermum montanum (Danti)

Bamboo Manna (Vansrochan)

Barberry Stem Bark

Barley Grass (Yava)

Basil Leaf

Basil Seed (Sabja, Tukmaria)

Basil, Camphor (Karpur Tulsi)

Bauhinia tomentosa Bark (Kanchanar)

Beet Root

Berberis aristata Stem (Daru Haridra/Haldi)

Bergenia ligulata (Pashan Bheda)

Bhringraja Herb (Eclipta alba)

Bhumyamalaki Herb (Phyllanthus amarus)

Bhunimba Herb (Andrographis paniculata)

Bibhitaki, Baheda Fruit (Terminalia bellerica)

Bilberry (Vaccinium myrtillus L.) Fruit

Bilva, Bel Fruit (Aegle marmelos)

Biotin

Bishops Weed Seed (Ammi majus)

Bitter melon (Karvellak, Karela)

Black Cohosh

Blackberry

Blueberry

Boerhavia diffusa (Punarnava)

Bombax malabaricum (Mochras)

Borago officinalis L. (Borage)

Boswellia serrata (Frankincense, Shallaki)

Brahmi (Bacopa monnieri)

Bridelia retusa (Asana)

Broccoli (Brassica oleracea) Flower Powder

Broccoli Seed Ext BSPE-13-25

Bromelain

Bupleurum Root

Butea monosperma Bark (Palash)

Butea monosperma Flower (Palash)

Buxus sinica(Rehd.et Wils.)Cheng

Caesalpinia bonducella Seed (Lata Karanj)

Caesalpinia sappan (Patang, Sappan wood)

Calamus Root (Vacha, Bach)

Calendula Petals

Calotropis gigantea Root (Mandar, Aak)

Camellia sinensis (L.) O.Kuntze (Green Tea)

Camphor

Camptotheca acuminata

Cane Sugar

Capsicum annuum L.

Cassia absus (Chakshu)

Cassia angustifolia Vahi

Cassia fistula Fruit Pulp (Arghvadh, Bahava)

Cassia nomame(sibe.)L.Kitagawa

Cassia tora (Chakramard)

Catechu Bark (Khadir, Khair)

Cayenne Pepper Powder

Cedrus deodar Wood (Devdaru)

Celastrus paniculatus Fruit (Jyotismati)

Celery Seed (Apium graveolens, Ajmud)

Centella asiatica (Gotu kola) aerials

Chamomile Herb

Chamomilla recutita(L.)Rausch

Chaste Tree Berry

Chen Pi Extract

Chickweed (Stellaria Media Herb) Extract

Chlorophytum borivilium Root (Safed Musli)

Choline Bitartrate

Chrysin

Cimicifuga foetida L.

Cinnamomum zeylanicum (True or Ceylon cinnamon) bark

Cinnamon (Cinnamomum cassia) bark

Cinnamon Powder Low Oil

Cissampelos pareira (Patha)

Cissus quadrangularis Herb (Ashthisandhar)

Citric Acid Anhydrous USP/FCC

Citrullus colocynthis Fruit (Indravaruni) Citrus anrantium L.

Citrus aurantium L.

Citrus Bioflavonoids

Citrus Bioflavonoids Extract

Citrus paradisi Macfadyen

Clerodendron serratum Root (Bharangi)

Clitoria ternatea Herb (Aparajita)

Cnidium monnieri L.

Coenzyme Q10

Cola nitida(Vent.) Schott et Endl

Coleus barbatus Benth

Coleus forskohlii Root (Pashanbheda)

Commiphora mukul Resin (Guggul)

Commiphora myrrah Resin (Raktabol)

Convolvulus pluricaulis Herb (Shankhpushpi)

Coptis Chinensis Extract

Cordyceps sinensis Extract

Costus speciosus (Kustha)

Country Mallow, Indian Root (Atibala)

Cranberry Fruit Powder

Crataegus pinnatifida

Crataeva nurvala Wood (Vaiverna)

Croscarmellose Sodium

Curculigo orchioides Root (Musli)

Curcuma amada Root (Amra Haridra, Amba Haldi)

Curcuma aromatica (Van Haridra)

Curcuma zedoaria (Karchura)

Curcumin 95% Powder

Curry (Murraya koenigii) Leaf

Cyanocobalamin (Vitamin B12 1%)

Cyanocobalamin 0.1%, Vit B12

Cynara scolymus L

Cynodon dactylon (Durva)

Cyperus rotundus Root (Musta, Nagarmotha)

Datura metel Seed (Dhoorta, Dhatura)

Desmodium gangeticum Root (Shaliparni)

Dioscorea bulbifera Tuber (Varahi Kand)

D-Limonene

Dong Quai Extract

Echinacea purpurea Herb Extract

Eclipta alba Herb (Bhringraja)

Eleutherococcus Senticosus Root Extract

Embelia ribes Seed (Vidang)

Emblica officinalis Fruit (Amalaki, Amla)

Epimedium brevicorn

Equisetum arvense L.

Eucalyptus citridora Leaf (Nilgiri)

Euphorbia nerifolia Herb (Sudha)

Evodia rutaecarpa(Juss.)Benth

Evolvulus alsinoides Herb (Shankhpushpi)

Feronia limonia (Wood apple, Kapittha, Kaith)

Ficus benghalensis Bark (Banyan, Vata, Vad)

Ficus benghalensis Shoot (Vatankur)

Ficus racemosa Bark (Udumbara, Gular)

Ficus religiosa Bark (Ashwatha, Peepal)

Flax Seed Extract

Flaxseed Lignans Powder

Foeniculum vulgare Mill (Fennel)

Folic Acid 10%

Folium Artemisiae Argyi

Fructose DC

Fucus vesiculosus L.

Fumaria parviflora Seed (Yavan Parpat, Pitta Papda)

Galangal (Kulinjan)

Ganoderma lucidum (Leyss.ex Fr.)Karst

Garcinia cambogia Fruit Rind (Vrikshamla)

Garcinia mangostana L. (Mangosteen)

Gardenia gummifera (Nadihingu)

Gardenia jasminoides Ellis

Ginger Extract 5%

Ginger Root Powder

Ginkgo Biloba 24% Extract

Gloriosa superba Seed (Langli, Kalihari)

Glucosamine HCl (non-shellfish)

Glycine max(L.)Merr

Glycyrrhiza glabra L.

Gmelina arborea Root (Gambhari, Shivan)

Gokshur Fruit (Tribulus terrestris)

Gokshur Herb (Tribulus terrestris)

Gotu Kola Herb (Mandukparni, Brahmi) Pumpkin Seed

Grape (Citis vinifera) Seed

Green Coffee (Coffea arabica) Bean

Green Tea (Camellia sinensis) Leaf Ext

Green Tea 40% Decaffeinated Water Extracted

Green Tea PE Decaffeinated 40% EGCG

Griffonia Simplicifolia

Guar Gum

Guduchi, Amrita Herb (Tinospora cordifolia)

Guggul Resin (Commiphora mukul)

Gum arabic (Acacia arabica, A. nilotica)

Gymnema Leaf (Madhunashini, Shardunika, Gudmar)

Gymnema sylvestre

Gynostemma pentaphyllum (Thunb.) Makino

Hamamelis mollis Oliver

Haritaki, Harde (Terminalia chebula)

Harpagophytum procumbens DC

Hawthorn Leaf and Flower Ext 5.5 to 1

Hedychium spicatum Root (Sati, Kapur Kachri)

Helicteres isora Fruit (Avartini)

Hemidismus inducus (Anantmul)

Hemsleya amabilis Diels

Hemp Protein

Hemp Seed Oil

Hemp Extract (Cannabidiol, CBD)

Henna Leaf (Madayantika, Mehandi)

Herpestis moniera Herb (Brahmi)

Hesperidin

Hibiscus Flower (Japa, Jaswand) Sage

Hippophae rhamnoides L.

Holarrhena antidysenterica Bark (Kutaj)

Holy Basil Leaf (Tulsi)

Honey

Hops Extract Powder

Hops Powder

Horse Chestnut Extract  20%

Horsetail Shavegrass

Humulus lupulus L.

Huperzia serrata (Huperzine-A)

Hydrocotyle asiatica Herb (Mandukparni)

Hypericum perforatum L.

Indian Goosebery Fruit (Amalaki, Amla)

Indigo Leaf (Neelini, Neel)

Indole-3-Carbinol

Inositol

Ipomoea digitata Tuber (Kshri Vidari)

Japanese Knotweed Extract

Jasmine Flower (Mallika)

Jatamansi Root (Nardostachys jatamansi)

Jatropha curcas

Jujube Seed

Kanchanar Bark (Bauhinia tomentosa)

Korean Ginseng (Panax ginseng)

Kutki Root (Picrorhiza kurroa)

Lagerstroemia speciosa (L.) Pers

Laminaria japonica Arsch

L-Arginine

Lavandula pedunculata L.

L-Carnitine Fumarate

L-Citrulline

L-Cysteine

Lemon Bioflavonoid Complex

Lemon Peel

Lemongrass

Lentinus edodes (Berk.)sing

Lepidium sativum Seed

Leptadenia reticulata (Jivanti)

L-Glutamine

Licorice Extract, Deglycyrrhizinated (Glycyrrhiza Glabra)

Linum usitatissimum L.

Lllicium verum Hook.f

Lotus (Padam, Neel Kamal)

L-Selenomethionine

Lycium barbarum L. (Goji berry)

Maca root

Madder, Indian Root (Manjistha)

Madhuca india (Madhuka)

Magnesium Carbonate

Magnesium Gluconate

Magnesium Lactate

Magnolia Bark

Magnolia officinalis Rehd. et Wils

 

Manganese Gluconate

Marigold Flower (Zendu)

Marjoram

Marshmallow Root Ext 4:1

Melissa officinalis L. (Lemon Balm)

Mentha haplocalyx Briq

Mesua ferra Stamen (Nagkeshara)

Mexican Poppy Herb (Argemon mexicana)

Milk Thistle Seed Extract 80% silymarin

Momordica charantia (Bitter Melon)

Moringa oleifera (Shigru, Sahijan)

Motherwort Powder Extract  6.5:1

Mucuna pruriens

N-Acetyl L-Cysteine

Narcissus pseudonarcissus L.

Neem

Nettle Root

Niacin

Noni (Morinda citrifolia) Fruit

Nyctanthes arbortristis Leaf (Parijat, Harsingar)

Oenothera erythrosepala Borb

Olive Leaf Extract

Opuntia dillenii

Orange Peel

Orange Powder

Oregano

Oregon Grape Root Extract 4:1

Oroxylum indicum Root (Shyonak, Tetu)

Oroxylum indicum(L.)Vent

Orris, Indian Root (Pushkarmula)

Panax Ginseng Extract

Papaya Leaf

Parsley

Passion Flower Ext

Patchouli Leaf

Pepper, Long Fruit (Pippali)

Pepper, Long Root (Pippali)

Perilla frutescens(L.)Britt

Perilla Seed Extract

Periwinkle Herb (Sadaphuli)

Phellodendron amurense (Berberine HCl)

Phellodendron amurense Rup

Phosphatyl Serine 30%

Phyllanthus amarus Herb (Bhumyamalaki)

Phyllanthus emblica Fruit (Amalaki, Amla)

Picrorhiza kurroa Root (Katuka, Kutki)

Picrorhiza kurroa Root Extract

Pinus massoniana Lamb

Pinus massoniana Lamb

Piper betle Leaf (Nagvalli, Paan)

Piper Methysticum

Piper nigrum L.

Pistacia integerrima (Karkatshringi)

Plantain Flour

Pluchea lanceolata Root (Rasna)

Plumbago zeylanica Root (Chitrak)

Polygonum cuspidatum Root Extract 50%

Pomegranate Fruit Extract

Pomegranate Flower

Pongamia pinnata (Karanj)

Poppy Seed (Post Dana)

Potassium Sulfate

Potassium bicarbonate

Pregelatinized Starch

Premna integrifolia Root (Agnimantha)

Prune Skin Extract

Psoralea corylifolia Seed (Bakuchi, Bavchi)

Psyllium Husk (Isaphgula, Isabgol)

Pterocarpus marsupium Wood (Vijaysar)

Pueraria lobata (Willd.)

Pueraria Root Extract 40% Isoflavones

Pueraria tuberose Tuber (Vidari)

Pumpkin Seed Powder – Steam Treated

Punarnava Root (Boerhavia diffusa)

Punica granatum L.

Pyridoxine Hydrochloride

Quercetin Anhydrous Granular

Quercetin Anhydrous Powder GRAS

Quercetin Dihydrate

Quercetin Dihydrate Powder

Quercus infectoria (Mayaphal, Majuphal)

Randia dumetorum (Madanphal)

Raspberry Fruit Powder

Rauwolfia serpentine Root (Sarpagandha)

Red Clover Extract

Red Yeast Rice

Rhamnus purshiana

Rhodiola rosea

Rhus succedanea (Karkatshringi)

Riboflavin (Vitamin B2)

Rice Protein Hydrolysate

Rodiola Rosea 5%

Rose Petal (Shatpatri, Gulab)

Rosemary Ext 95%

Rosmarinus officinalis L.

Rublaceae.Corynant.Yohimbine

Rubus chingli Hu

Rue Herb (Ruta graveolens)

Ruscus aculeatus L.

Rutin

Safed Musli Root (Chlorophytum borivilium)

Safflower Seed

Salacia chinesis (Saptarangi)

Salix alba L.

Salvia Extract, 1% Dan Shen

Salvia Sclare L.

Sambucus williamsii Hance

Sappan Wood (Patang)

Saraca indica Bark (Ashok)

Sarperia (Rauwolfia serpentina)

Sarsaparilla, Indian (Anantmul)

Saw Palmetto Ext 45%

Schisandra chinensis(Turcz.)Baill

Scindapsus officinalis (Gajpippli)

Seabuckthorn (Hippophae rhamnoides)

Selenium

Semecarpus anacardinum Nut (Bhallatak)

Senna Leaf (Markandika, Sanai)

Serenoa repens (Saw palmetto)

Sesame Seed (Til)

Sesamum indicum L.

Shankhpushpi Herb (Convolvulus pluricaulis)

Shatavari Root (Asparagus racemosus)

Sheabutter officinalis

Shorea robusta (Raal)

Sida cordifolia Root (Bala)

Sida rhombifolia Root (Mahabala)

Silybum marianum(L.)gaertn

Sisymbrium officinale L.

Skullcap Root Extract

Soap Nut (Arishtak, Reetha)

Sodium Ascorbate Granular 99%

Sodium Copper Chlorophyllin

Solanum indicum Root (Brihati)

Solanum lycopersicum L

Solanum nigrum Root (Kakmachi)

Solanum xanthocarpum Fruit (Kantakari)

Sophora alopecuroides L.

Sophora japonica L.

Sophora subprostrata

Sorbus aucuparia L.

Soy Isoflavones

Spent Hops (Polyphenol Rich Hops Pellets)

Sphaeranthus indicus Herb (Mundi)

Spikenard, Indian Root (Jatamansi)

Spilanthes acmella Root (Akarkarbha)

Spirulina

St John’s Wort

Stereospermum suaveolens Root (Patala)

Stevia Leaf Extract (Rebaudioside A)

Strychnos potatorum (Nirmali)

Sunflower

Symplocos racemosus Stem (Lodhra)

Syzygium cumini Seed (Jambu, Jamun)

Tagetes erecta L. (Marigold)

Tamarind Fruit

Tamarindus indica L.

Tarragon (Artemisia dracunculus)

Taxus baccata L

Tea, Black

Terminalia arjuna Bark (Arjuna)

Terminalia bellerica Fruit (Bibhitaki, Baheda)

Terminalia chebula Fruit (Haritaki, Harde)

Thiamine Hydrochloride

Thyme

Thymus mongolicus Ronn

Tinospora cordifolia Stem (Guduchi, Amrita, Galo)

Trachycarpus fortunei(Hook.)H.Wendl)

Tribulus terrestris Fruit (Gokshur, Gokhru)

Trichosanthes cucumerina Root (Patol)

Trifolium pratense L.

Tulsi Leaf (Ocimum sanctum)

Turmeric (Curcuma longa) Root Extract

Turmeric Root Powder

Vaccinium myrtillus L.

Valerian Root ext 0.8%

Valeriana wallichi Root (Sugandha bala, Tagar)

Vanadium Citrate 0.5%

Vanilla Bean

Vasa, Adulsa Leaf (Adhatoda vasica)

Viola odorata Leaf (Banafsa)

Vitex negundo Herb (Nirgundi)

Vitex trifolia L.

Vitis vinifera L.

Voacango africana Stapf

Watercress Herb Ext. 4:1 Steam Treated (non irradiated)

Wheat Grass

White Willow Bark 15%

Withania somnifera (Ashwagandha)

Wormwood Plant Ext 5%, 8:1

Xylitol (Foods)

Zanthoxylum bungeanum Maxim

Zinc Chelate (Tasteless) 10%

Zinc Citrate 32%

Zingiber officinale Roscoe (Ginger) root

Ziziphus jujube

Here are ingredient of concern listed on FDA’s website:

Dietary Supplement Testing and Analysis: Quality Control

by NaturPro in Uncategorized Comments: 0

Dietary Supplement Testing and Analysis: Quality Control

Dietary supplements are subject to FDA requirements for good manufacturing practices (cGMP) and quality control in the United States. cGMP require specifications for each ingredient and finished dietary supplement. The specifications list parameters for identity, purity, potency and other requirements for regulatory compliance. Each parameter on the specification must be tested with a scientifically valid method.

NaturPro Scientific, as an UnLab, partners with expert analytical laboratories to conduct specific testing on dietary supplements. Testing typically includes:

  • Physical characteristics (visual, color, odor, taste, density, mesh size)
  • Identity (matching an ingredient in a pass/fail fashion to a particular species of botanical or herb, or a chemical purity test)
  • Potency (concentration of active or marker compounds)
  • Purity (absence of impurities such as moisture, microbiology, pathogens, heavy metals, residual solvents, pesticides, mycotoxins)

The following are analytical principles or instruments that may be used for dietary supplement testing:

  • Karl Fischer
  • Ro-tap and particle size analysis
  • Titration
  • Gravimetry
  • Thin Layer Chromatography (TLC or HP-TLC)
  • High Performance Liquid Chromatography (HPLC)
  • Gas Chromatography with Flame Ionization Detection (GC-FID)
  • Gas Chromatography with Mass Spectrometry (GC-MS of GC-MS-MS)
  • Inductively Coupled Plasma Mass Spectrometry (ICP-MS)
  • Total Aerobic Plate Count
  • Pathogens (Salmonella, E. Coli, Staph)

The following is a list of documentation and regulations requiring testing under cGMPs:

  • Documentation of the specifications established (21 CFR 111.95(b)(1))
  • Documentation of your qualification of a supplier for the purpose of relying on the supplier’s certificate of analysis (21 CFR 111.95(b)(2))
  • Documentation for why meeting in-process specifications, in combination with meeting component specifications, helps ensure that the dietary supplement meets the specifications for identity, purity, strength, and composition; and for limits on those types of contamination that may adulterate or may lead to adulteration of the finished batch of the dietary supplement (21 CFR 111.95(b)(3))
  • Documentation for why the results of appropriate tests or examinations for the product specifications that you selected for testing ensure that the dietary supplement meets all product specifications (21 CFR 111.95(b)(4))
  • Documentation for why any component and in-process testing, examination, or monitoring, and any other information, will ensure that a product specification that is exempted under 21 CFR 111.75(d) is met without verification through periodic testing of the finished batch, including documentation that the selected specifications tested or examined under 21 CFR 111.75 (c)(1) are not able to verify that the production and process control system is producing a dietary supplement that meets the exempted product specification and there is no scientifically valid method for testing or examining such exempted product specification at the finished batch stage (21 CFR 111.95(b)(5))

There are a number of sources of information for developing specifications and test methods for analysis of dietary supplements. The below is a partial list of references and resources:

  1. Dietary Supplement Ingredient Database, https://dietarysupplementdatabase.usda.nih.gov/
  2. Dietary Supplement Label Database, https://ods.od.nih.gov/factsheets/DietarySupplements-HealthProfessional/
  3. Dietary supplement laboratory quality assurance program: the first five exercises. Phillips MM, Rimmer CA, Wood LJ, Lippa KA, Sharpless KE, Duewer DL, Sander LC, Betz JM.  J AOAC Int 2011;94:803-14. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3173719/
  4. Heavy metals: analysis and limits in herbal dietary supplements, http://www.naturalhealthresearch.org/wp-content/uploads/2013/02/09_1214_AHPA_Heavy-Metals-White-Paper-Revised.pdf
  5. Pesticide Analytical Manual, Vol I, FDA. Source: http://www.fda.gov/downloads/Food/FoodScienceResearch/ucm113702.pdf
  6. Pesticide Analytical Manual, Vol II, FDA. Source: http://www.fda.gov/downloads/Food/FoodScienceResearch/ucm113721.pdf
  7. Quality assurance of cultivated and gathered medicinal plants. Mathe and Mathe, Source: http://www.mtk.nyme.hu/fileadmin/user_upload/kornyezet/Mathe/Quality_assurance.pdf
  8. Quality control methods for medicinal plant materials (1998) World Health Organization
  9. Recommendations for microbial limits in herbal products, American Herbal Products Association, http://www.ahpa.org/Portals/0/PDFs/Policies/14_0206_AHPA_micro_limits_comparisons.pdf
  10. Standardization of herbal medicines – A review. Kunle O.F. et al, (2012) Int. J Biodiv and Conserv. 4(3) 101-112. Source: http://www.academicjournals.org/article/article1380017716_Kunle%20et%20al.pdf
  11. USP Food Fraud Mitigation Guidance, http://www.usp.org/food/food-fraud-mitigation-guidance