Overall, brand marketers/manufacturers are best served if they have a lab qualification procedure in place just as they have a supplier qualification procedure, according to Blake Ebersole, president, NaturPro Scientific.
NaturPro Verified Supply™
As consultants for a diversity of supplement and food firms, NaturPro Scientific has qualified numerous ingredients, suppliers and products.
So, we decided to share some of the products and ingredients that we have verified, within a curated supply catalog: NaturPro Verified Supply™
What’s different about NaturPro Verified Supply compared to other suppliers and manufacturers?
- Suppliers cannot pay to be listed. Unlike most suppliers, NaturPro does not accept fees or commissions to represent or promote any specific ingredients or products. Our core business is in vetting the best ingredients and products — not selling them.
- We are not tied or committed to any one ingredient or supplier, so we can keep our standards high.
- Our vetting process goes beyond FDA regulatory requirements. NaturPro standards include our intimate understanding of supplier practices, supply chain quality, sustainability, GMP’s, best practices, traceability to source, a track record of integrity, and a demonstrated commitment to quality and research.
Connect to NaturPro Verified Supply™ Portal
Contact us with questions or comments!
Ethical Sourcing Assessments for Ingredients, Supplements and Foods
NaturPro has served an essential role in helping our clients source and evaluate ethically sourced ingredients.
Our Ethical Sourcing Assessments include elements from many recognized programs such as Fairtrade(R), and uses one of the most comprehensive set of standards guiding the evaluation of the social and environmental impact of natural products and foods.
Ethical Sourcing Assessments are Key to Understanding Social, Environmental and Product Sustainability
The following outline covers subject matter covered in our evaluation protocol, which is derived from multiple sources, including the International Labour Organization Labour Principles of the United Nations Global Compact, the UN Forum on Sustainability Standards, Fairtrade,, WHO GAP, Global G.A.P., and NOP Organic.
General Guidelines for Ethical Sourcing: The Human Element
Product:
- Contact information
- Product name
- Specifications, nomenclature
- Sourcing origin
- Land use and inputs
- Harvest practices
- Plant population care
- Raw material processing and labeling
Relationships
- Type and controls
- Prices and wages
- Non-discrimination
- Reciprocity
- Communications
Employment
- Labor practices
- Fair wages and prices
- Child labor
- Harrassment
- Working conditions
- Worker safety
Environment
- Legal requirements
- Policies and communications
- Management responsibilities
- Waste management
- Emissions
- Energy usage
Management and Supply Chain
- Written policies
- Training
- Supplier management
- Dealing with non-compliances
- Audit program
- Geographic risk
- Community improvements
NaturPro fits our review protocol and minimum standards according to your practices currently in place, and we also evaluate according to the ‘stretch goal’ standards our clients are working to achieve, and set a clear path towards improved social and environmental impact.
Here are a couple examples of case studies we have performed for clients:
1. “Seed-to-Shelf Independent Audit” — A comprehensive, umbrella independent review of all quality and ethical procedures, relating to both farm-level and manufacturing practices.
We review all documentation, audit reports and other information, provide a list of opportunities to improve quality, identify gaps that minimize business, regulatory and product quality risk, help our clients meet the minimum level of regulatory compliance, and identify ‘best practices’ that are either already in place, or can be implemented.
2. “Human Impact Audit” – A third-party independent review of the “human element” of an agricultural or wild-collected product, focusing in particular on staff training, farming practices and GAP, worker health and safety, and cultural preservation. This includes a review of personnel SOP, safety, fair trade, farm practices, environmental impact estimates, ethical sourcing & organic practices.
The above 2 programs could be done separately or combined, and are typically performed in 2 phases:
Phase 1: Document Audit
Phase 2: In-person/field Audits
3. Program marketing and communications – A comprehensive review paper that describes in detail all the elements of the program, references to the standards applied, and images or video footage. This comprehensive review can then be broken down into separate stories, that can become webpages, Youtube videos and social media posts that educate your audience.
Contact us for more information on NaturPro Scientific’s ingredient traceability and ethical sourcing programs.
Dietary Supplement Formulation
As Dietary Supplement Formulators we often are asked what we think of a product concept. The thought process to develop an answer is generally similar, regardless of the type of product, and whether its finished product, or an ingredient or raw material.
A number of considerations go into formulating successful, effective, safe and compliant dietary supplements, foods, and food and dietary ingredients. These include:
- What does the supplement or food do?
- What can be claimed about the product?
- Is the evidence supporting the claims sufficient?
- How safe is the product?
- Who will benefit from the product?
- How is the ingredient dosage determined?
- Are the ingredients available at an acceptable quality, cost and volume?
The 4 Initial Steps to Dietary Supplement Formulation
There are seven basic elements to formulating a groundbreaking product:
- Begin with the finished product in mind. Determine in full detail how the product will be marketed, what the desired product claims will be, and how the product will address an unmet market need.
- Intimately understand the product value and market positioning compared to the competition. How will the product address an unmet need, or be different than what is already found on the market? How will the product be priced compared to the competition? A full competitive analysis is important to determine positioning.
- What language will be used to describe the product? (This language, found on product labels and on webpages, is considered to be part of product claims.)
- In what country(s) will the product be marketed? Regulations in different countries vary, and it is important to understand the unique requirements of each location.
Sufficient time spent in the planning phase is the difference between success and failure.
Product formulating plans often coordinate the knowledge of supplement consultants and experts, review regulatory status of the product and evaluate the available scientific evidence. A good formulating plan will identify not only opportunities, but also gaps and risks that may prevent success.
Contact us for more information on our Dietary Supplement Formulation and Development
Additional Reading:
Food and Supplement Claims with Confidence
Dietary Supplement Formula Development
Dietary Supplement Ingredient Regulatory Status
Supplement Manufacturing Consulting
Creating Natural Product Intellectual Property
Protecting botanicals from adulteration
Blake Ebersole, president of NaturPro Scientific, noted adulteration of natural products, especially foods and botanical ingredients, has been occurring for thousands of years. He added, “Two main classes of adulteration include economically motivated adulteration—generally the substitution or dilution of expensive ingredients with cheaper ones—and also, unintended cases of accidental adulteration or mistaken botanical identity.”
Cannabis, Hemp & CBD | SOP and Procedures
Standard Operating Procedures (SOP) for Cannabis, CBD and Hemp operations are required for every type of business — even if you are only a distributor or marketer.
Our experts have decades of experience with all types of document requirements, for all types of firms — especially SOP supporting the following:
- Good Manufacturing Practices (GMP’s)
- Good Agricultural and Collection Practices (GACP)
- Good Distribution and Storage Practices
Need help with your SOP’s and GMP’s? Contact us!
Our goal is to help you meet Cannabis, CBD and Hemp regulatory requirements as efficiently as possible.
Cannabis & Hemp Procedures and SOP (Standard Operating Procedures) are the central part of operations of any cultivation, extraction, processing, packaging, marketing, distribution, or testing business.
Cannabis SOP are required by each state where cannabis, marijuana or hemp are regulated.
All cannabis, hemp, medical or adult-use (recreational) marijuana product is subject to a number of regulations and standards 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.
Startups who invest in solid standard operating procedures (SOP) accelerate their growth from the start.
The worst thing a start-up can do is go in blind to what their processes and procedures — their Good Manufacturing Practices — should be.
But within a patchwork of regulations, processes and procedures depend on the type of product you are making.
So what GMP guidelines should you follow?
Here’s some free advice, that’s common sense: Follow the most applicable regulatory guidelines, that are closest to your type of product.
The following types of products are generally considered dietary supplements, which are products intended to supplement the diet, but not replace food. Supplements in the U.S. are governed by 21 CFR 111, Good Manufacturing Practices (GMP) for Dietary Supplements:
- Tinctures
- Oils
- Capsules and Softgels
- Tablets
- Powders
- Food products with structure-function claims nutrients without recommended daily values
The following types of products are generally considered foods, governed under 21 CFR 117, that are FDA GMP’s for Food:
- Protein powders
- Ready to drink beverages
- Snacks
- Infused coffee and tea
Need help with your SOP’s and GMP’s? Contact us!
When it comes to other types of products, standards or test methods, we generally recommend to pick the most relevant standards for your type of product.
Here is a basic set of quality management SOP’s for a Food facility:
- Quality Management Systems
- Product Quality Policy/Manual
- Recordkeeping
- Document Control
- Formula Records
- Batch Records
- Certificates of Analysis
- Traceability & Recall
- Risk Analysis
- Hazard Analysis
- Purchasing Criteria & Specifications
- Supplier Qualification
- Intentional Adulteration
- Preventive Controls
- Product Approval & Rejection, Material Inspection
- Complaints & CAPA (Corrective Actions)
We recommend to follow the standards and requirements set by FDA and other standards-setting organizations:
- 21 CFR 111, Good Manufacturing Practices (cGMP) for Dietary Supplements
- 21 CFR 117, Good Manufacturing Practices (cGMP) for Foods
- American Herbal Pharmacopoeia Monograph on Cannabis
- American Herbal Products Association Cannabis Guidelines for Regulators
- AOAC International Official Methods for Cannabinoids
- ASTM International D.37 Group Standards
- USDA Hemp Program
- FDA BAM
- FDA PAM
- U.S. Hemp Authority
- U.S. Pharmaceopoeia Expert Panel on Medical Cannabis
Need help with your SOP’s and GMP’s? Contact us anytime!
Farmers are at the root of high quality product, so here’s some free SOP’s for farmers, followed by a sample guidance proposed for cannabis, hemp and CBD agricultural materials (i.e. “Farm SOP’s”)
CANNABIS, HEMP AND CBD FARM SOP LIST
- Cultivation or Processing
- Management
- Applicable Regulations
- Operations
- Training & Safety
- Hygiene
- Sanitation & Cleaning
- Farm or Facility
- Equipment
- Seeds and Propagation Materials
- Agricultural Inputs
- Pre-harvest practices
- Harvesting
- Post-harvest practices
- Drying & Milling
- Sampling
- Testing (Potency, purity, cannabinoids, microbiology, heavy metals, pesticides)
- Waste Management
———————
A BASIC EXAMPLE for FARM OPERATIONS
The following information is a partial excerpt from draft from U.S. Hemp Roundtable guidance for CBD products, which NaturPro was fortunate to contribute to.
CBD SOP’s and Cannabis Procedures
U.S. Hemp Guidance Program PHASE 2
1 GROWER
1.1 GENERAL TERMS & DEFINITIONS
The following Definitions and Interpretations apply to such terms when used in this U.S. Hemp Guidance Program.
Adulteration refers to a food that may be considered adulterated if it contains “any poisonous or deleterious substance which may render it injurious to health…..or if any valuable constituent has been in whole or in part omitted or abstracted therefrom; or (2) if any substance has been substituted wholly or in part therefor; or (3) if damage or inferiority has been concealed in any manner; or (4) if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is”.
Batch means a specific quantity of industrial hemp that is uniform, that is intended to meet specifications for identity, purity, strength, and composition, and that is produced during a specified period of time according to a single manufacturing record.
Batch number, or lot number means any distinctive group of letters, or numbers, or any combination of them, from which the complete history of the processing, packaging, labeling, and/or storage of a batch or lot of industrial hemp product can be determined.
Biomass means the amount of living matter in a given habitat, expressed either as the weight of organisms per unit area or as the volume of organisms per unit volume of habitat.
Component means any substance intended for use in the manufacture of industrial hemp, including those that may not appear in the finished batch of the industrial hemp.
Growth Medium means the solid, liquid or semi-solid substance used to support the growth of the plant.
Hemp refers to cannabis varieties and any part of the plant, whether growing or not, containing a delta-9 tetrahydrocannabinol (THC) concentration of no more than three-tenths of one percent (0.3%) on a dry weight basis.
Industrial Hemp is Hemp
Ingredient means any substance that is used in the manufacture of hemp and that is intended to
be present in the finished batch of the hemp product.
In-process material means any material that is compounded, blended, ground, extracted, sifted, sterilized, derived by chemical reaction, or processed in any way for use in the manufacture of the hemp product.
Lot means a batch, or a specific identified portion of a batch, or, in the case of a hemp product produced by continuous process, a specific identified amount produced in a specified unit of time or
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U.S. Hemp Guidance Program PHASE 2
quantity in a manner that is uniform and that is intended to meet specifications for identity, purity, strength, and composition.
Microorganisms means yeasts, molds, bacteria, viruses, toxins, and other similar microscopic organisms which may or may not have a health or sanitary concern.
Pest means any objectionable insect or other animal including but not limited to birds, rodents, flies, mites, and larvae.
Physical plant or facility means all or any part of a building or facility used for or in connection with manufacturing, processing packaging, labeling, or storage of industrial hemp products or ingredients.
Processor means making a transformative change to the hemp plant or product following harvest.
Product complaint means any communication that contains any allegation, written, electronic, or oral, expressing concern, which may or may not have be related to the quality of an industrial hemp product.
Quality means that the hemp product meets the established specifications for identity, purity, strength, and composition, and limits on contaminants, and has been manufactured, packaged, labeled, and held under conditions to prevent adulteration.
Quality Management Systems means a planned and systematic operation or procedure for ensuring the quality of a hemp product.
Quality Management Systems personnel means any person, persons, or group, within or outside the organization, designated to be responsible for quality control operations.
Representative sample means a sample with an adequate number of units that are intended to ensure that the sample accurately portrays the material being sampled.
Reserve sample means a representative sample of product that is held for a designated period of time.
Sanitize means to adequately treat cleaned equipment, containers, utensils, etc.by a process that is effective in destroying of microorganisms of public health concerns.
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U.S. Hemp Guidance Program PHASE 2
1.2 REGISTRATION/APPLICATION/NOTIFICATION
Prior to the Industrial Hemp Grower planting any seed, a license or agreement with the State must be obtained. The following information is required to make the application before a license will be issued: (Each State may have different regulations – refer to application – See Kentucky Hemp Policy Guide as an example)
1.2.1 Registration/Application Guidance
- Name of the person or corporation to whom the license or authorization is to be issued
- Address of the farm or place including county and township or legal description
- The number of acres
- Global Positioning System coordinates
- Intended purpos of industrial hemp
- In the case of a plant breeder, the variety of industrial hemp that may be cultivated; and
o Any conditions that are necessary to minimize security, public health or safety hazards related to the licensed or authorized activities.
o Specify if the hemp is for food or non-food purposes
1.2.2 Notification of Changes to the licensor by the licensee
Every licensee shall notify the State of any changes to the information provided on the application, within 15 days after the change, including:
- Corporate name or ownership, or officers, and the replacement of an officer, or director
- Any change to the address of the licensee
- The replacement of an individual referred to a licensee
- Any change in the mailing address of the licensee
- Any change in the ownership of the land used to cultivate industrial hemp
- Any change to the approved cultivar being sown or, in the case of a plant breeder, to thevariety of industrial hemp being sown;
- Any genetic modification.
Signature: _____________________________ Date: ________________________ Printed Name: __________________________ Company/Location: ________________________
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U.S. Hemp Guidance Program PHASE 2
1.3 PERSONNEL
Qualified employees who grow, manufacture, package, or label industrial hemp shall be qualified to do so, and those responsible for quality control or performing any quality control operations, must have the education, training, or experience to perform the assigned functions.
Supervisors shall be qualified by education, training, or experience to supervise.
Contamination Prevention and Hygienic measures shall be taken to exclude from any operations
any person who might be a source of microbial contamination.
Such measures shall include the following:
- Exclude personnel from working in any operations that may have an illness, infection, open lesion, or any other abnormal source of contamination.
- Instructing employees to notify their supervisor if there is a possibility that they have a health condition described above.
- Wearing outer garments in a manner that protects against the contamination.
- Maintaining adequate personal cleanliness.
- Washing hands thoroughly, and sanitizing if necessary, in a hand-washing facility.
- Removing or covering all unsecured jewelry and other objects that might fall into components, industrial hemp, equipment, or packaging.
- Using gloves when appropriate.
- Wearing, where appropriate, hair nets, caps, beard covers, shoes, PPE etc.Personnel and employee safety measures shall include the following:
- Appropriate and Adequate First Aid Equipment
- Adequate bathrooms and changing rooms
- Appropriate OSHA warnings, labels, and training
- Appropriate training and personal protective equipment for pesticide application
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U.S. Hemp Guidance Program PHASE 2
1.3.1 U.S. HEMP GUIDANCE – GROWER – PERSONNEL CHECKLIST |
||||
√ ifApplicable |
YES |
NO |
NOTES |
|
Are the supervisors qualified for their responsibilities by training, education or experience? |
||||
Do the employees performing the growing, processing, packaging and labeling tasks, have the proper training necessary to perform the tasks? |
||||
Are contamination and hygienic measures in place to exclude personnel who might be a source of contamination? |
||||
Are personnel excluded from operations if they have, an illness, infection, open lesion, or any other abnormal source of contamination? |
||||
Do employees notify their supervisor if there is a possible health condition as described above? |
||||
Do personnel wear outer garments in a manner that protects against the contamination? |
||||
Do operating personnel maintain adequate personal cleanliness? |
||||
Are hand washing facilities available and used? |
||||
Do operating personnel remove or cover unsecured jewelry etc. to prevent them from falling into hemp products or causing harm? |
||||
Are gloves used when appropriate? |
||||
Are caps, shoes and head covering used when appropriate? |
||||
Is the appropriate Personal Protective Equipment (PPE) used as needed? |
||||
Are there adequate and appropriate first aid equipment available? |
||||
Is there adequate bathrooms and changing rooms? |
||||
Are the OSHA warnings and signs visible? |
||||
Has there been adequate training? |
||||
If applicable is the PPE and trains available for the pesticide applicators? |
Signature: _____________________________ Date: ________________________ Printed Name: __________________________ Company/Location: ________________________
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U.S. Hemp Guidance Program PHASE 2
1.3.2 U.S. HEMP GUIDANCE – GROWER – BEST MANAGEMENT PRACTICES CHECKLIST
NOTES
YES |
NO |
|
Are you using the best soil available? |
||
Have you Soil tested for macro and micro nutrients? |
||
Have you used the appropriate Growth Medium for intended purposes? |
||
Has the licensee determined the concentration of THC in the hemp? |
||
Is seed planted listed on the license? |
||
Is the entire hemp plant used as licensed? |
||
Do you properly use pre- plant weed control? |
||
Do you have a Germination Certificate from the seed supplier |
||
Did you use the proper Certified Seed suitable for location? |
||
Did you use the proper seed treatment? |
||
Do you have a site history? |
||
Do you have a water quality report or history? |
||
Did you use fertilizer to target desired yield per acre according to soil test? |
||
Did you use animal manure for fertilizer or biomass purposes? |
||
Did you plant by optimum seeding date? |
||
Did you plant at the optimum rate of seeds per acre? |
||
Have samples of the industrial hemp been collected in accordance with the Guidance Procedures? |
||
Has the equipment used to sow, harvest and transport the hemp been thoroughly cleaned to prevent contamination? |
||
Are you prepared to harvest when the plant is ready? |
||
Have you complied with the drying procedures |
||
Do you have sufficient and proper storage facilities or adequate transportation equipment available? |
||
Is the biomass sold to a licensed person or entity according the Guidance Procedures? |
||
Is the biomass packaged, labeled, and transported according to the Transportation Guidance Procedures? |
||
Has any loss or theft been reported according to the license requirements? |
||
Are the records being kept according to the Guidance Procedures for Record Retention? |
Grower Signature___________________________ Date _________________ Printed Name___________________ Farm location or identifier__________________
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U.S. Hemp Guidance Program PHASE 2
1.3.3 U.S. HEMP GUIDANCE – GROWER – FACILITY & BIOSECURITY AWARENESS CHECKLISTA.
√ ifApplicable
Facility Security (physical security of buildings and grounds) |
|||
Is the facility using: |
YES |
NO |
NOTES |
Security lighting |
|||
Perimeter fencing |
|||
Controlled gate access |
|||
Off-hours security guard |
|||
Electronic motion detectors |
|||
Door alarms |
|||
Video cameras |
|||
Adequate indoor lighting |
|||
Alarms linked to an off-site security system |
|||
Door hardware is of industrial design |
|||
Guards are installed on exterior ladders |
|||
Exit doors and gate are electronically/mechanically secured |
|||
Entry and discharge points of exterior tanks are padlocked when not in use |
|||
All vehicles parked outside are locked |
|||
Empty/loaded containers are parked inside |
|||
Law enforcement patrol over company premises on regular but unpredictable basis |
|||
Employees reporting any suspicious behaviors |
|||
Restricted access to computer process control and data systems |
|||
Safeguard of data systems using data security program |
|||
Backup of all data and processes at an off-site place |
B.
√ ifApplicable
Visitor Policy
Is the facility using:
YES
NO
NOTES
Company representative for visitor to check in with
Signs informing visitors where to report
Specific area for visitor parking
Records of visitors (include name, company, arrival and departure, and purpose of visit)
Visitor badges/identification cards
Company representative to escort visitor all the time
Restricted access to key manufacturing areas
C.
√ ifApplicable
Distribution
Is the facility implementing the following:
YES
NO
NOTES
Bulk containers are inspected prior to loading for foreign and/or suspicious material
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U.S. Hemp Guidance Program PHASE 2
Verify that all customer pick-up drivers are representatives of the customer |
|||
The product stream is inspected visually |
|||
Container access points are secured after loading |
|||
Seal numbers are documented on the shipping papers |
|||
Shipping documents are used to identify the contents of each compartment |
|||
Shipping log is maintained |
|||
Bio-sanitation program is implemented |
|||
Procedures exist to disinfect vehicles and drivers |
D.
√ if Applicable
E.
√ ifApplicable
Housekeeping
Is the facility implementing the following:
YES
NO
NOTES
Written housekeeping program for all areas of the facility
Written pesticide and rodenticide program
Emergency Response
Is the facility implementing the following:
YES
NO
NOTES
Employees are adequately trained to respond to a crisis as calmly and safely as possible
Current inventory of all hazardous and flammable products
A plan to provided MSDS to emergency response teams etc.
A list of emergency contacts is posted
An action plan to deal with suspicious devices or substances
Evacuation plan in case of fire and explosions is published
Establish and maintain an up-to-date employee roster and visitor log to facilitate personnel head count at any time
Disaster Preparedness Plan
A weapons security program
Conduct evacuation and respond drill periodically
Post a site plan depicting escape routes, fire-fighting and rescue equipment
Signature: _____________________________
Printed Name: __________________________ Company: ________________________________
Date: ________________________________ Facility Location: ________________________________8
U.S. Hemp Guidance Program PHASE 2
1.4 SAMPLING AND HANDLING HEMP FOR THC & CBD1.4.1 Definitions
delta-9-THC means delta-9-tetrahydrocannabinol concentration.
Authority having jurisdiction usually means the state, but it could be FDA, USDA,
county or city.
Certified seed means seed for which a certificate or any other instrument has been issued, by an agency authorized under the laws of a state, territory, or possession to certify seed and which has standards and procedures approved by the United States Secretary of Agriculture to ensure the genetic purity and identity of the seed certified.
Plot means a contiguous area in a field, greenhouse, or indoor growing structure containing the same variety or strain of hemp throughout the area.
ppm means parts per million.ppb means parts per billion.
Post-Harvest Sample means a sample taken from the harvested hemp materialfrom a particular plot’s harvest. The entire plot’s harvest must be in the same form(e.g., intact-plant, flowers, ground materials, etc.), homogenous, and not mixed with non-hemp materials or hemp materials from another plot.
Pre-Harvest Sample means a composite, representative portion from plants in a hemp plot collected in accordance with the procedures as defined by the state providing authority.
Processing means converting an agricultural commodity into a marketable form.Prohibited Variety means a variety or strain of cannabis excluded from the state
providing authority.
Sample means a sufficient amount of material that is representative of the population from which it is taken. A sample may be a particular plant part, including inflorescence (flower), leaf, stalk or seed, or it may be a processed product (oil, extract, powder. Samples must be dried to a sufficiently low moisture content so as not to harbor growth of microorganisms.
Seed source means the origin of the seed or propagules as determined by the state providing authority.
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U.S. Hemp Guidance Program PHASE 2
- 1.4.2 Sampling Timeline and Grower Responsibilities
- The grower shall refer to the jurisdiction having authority to determine a timeline.
- During the sampling, the grower or an authorized representative shall be present at the growing site.
- Floral materials harvested for phytocannabinoid extraction shall not be moved beyond the processor, nor commingled, nor extracted, until test results are complete
- 1.4.3 Pre-Harvest Sampling Procedure
- Adequate personal protective equipment shall be used.
- Proper equipment shall be used to prevent cross contamination.
- The material selected for Pre-Harvest Sampling will be determined by the grower. Cuttings will be collected to make one representative sample.
- Refer to the authority having jurisdiction to determine adequate number of samples and proper locations. In the absence of jurisdictional requirements, the following guidance is given.
- Clip the top 12 inches of hemp plant’s primary stem, including female floralmaterial.
- Take cuttings from at least five (5) hemp plants within the plot.
- Place the complete sample in a paper bag.
- Seal the bag by folding over the top once and staple the bag shut.
- A separate sample must be taken from each non-contiguous plot of a given variety.
- A separate sample must be taken for each variety.
- Samples shall be secured in a paper bag (to allow for air-drying during transport).
- Label the sample container with a sample ID.
- 1.4.4 Handling Procedures of Pre-Harvest Samples
- Samples will be taken for drying and storage.
- Samples should be arranged in a single layer for drying.
- Drying oven will be used when possible.
- Samples in the oven will be left in the labeled sample bag.
- If selected for testing, the entire sample will be sent to a testing lab for analysis.
- 1.4.5 Post-Harvest Sampling Procedures for Floral Material
- Refer to the authority having jurisdiction to determine adequate number of samples and proper locations. In the absence of jurisdictional requirements, the following guidance is given.
- Adequate personal protective equipment shall be used.
- Proper equipment shall be used to prevent cross contamination
- The plot selected for sampling shall be designated by the Pre-Harvest Sampleresults. The material selected for Post-Harvest Sampling from this plot will be
10
U.S. Hemp Guidance Program PHASE 2
determined by the grower. All Post-Harvest Samples of floral material shall be taken from the designated harvested plot materials in the form (intact-plant, flowers, ground materials, etc.) in which the material will be sent to the processor
e. Grower must inventory the entire harvest to determine the form in which it exists and follow the protocol as appropriate in part a), b), or c) below.
- If, upon inventory, the grower determines that the entire harvest is not in a homogenous form (intact-plant, flowers, ground materials, etc.), it must be determined to take additional samples or other course of action or take the pre-harvest results.
- For intact-plant post-harvest samples:
- Ensure that the entire harvest is accounted for and in the sameform (i.e., intact-plants).
- Clip the top 12 inches) of hemp plant, primary stem, includingfemale floral material.
- Take cuttings from at least five (5) non-adjacent hemp plantswithin the harvest’s storage/drying area.
- Place the complete sample in a paper bag.
- Seal the paper bag by folding over top once and stapling to keep closed.
- Complete sampling procedures in part (d) –(f).
- For ground plant or ground floral material Post-Harvest Samples:
- Ensure that the entire harvest is accounted for and in the sameform (i.e., all harvested material whether whole plant or floral material only must be ground with no intact plants or whole flowers remaining from that harvest).
- Sample material from bag or container.
- Sample from a minimum of four locations within the containers from a given harvest.
- Place the complete sample in a plastic sample container.
- Seal the plastic sample container.
- Complete sampling procedures in part (d) –(f).
- For Post-Harvest Samples in other forms (e.g., trimmed floral material, or floral material and stems, etc.):
- Ensure that the entire harvest is accounted for and in the same form (i.e., all harvested material must be uniform).
- Randomly collect at least one cup of material by volume.
- Place the complete sample in a paper bag or plastic containerand seal the container, as appropriate.
- Complete sampling procedures in part (d) –(f).
- A separate sample must be taken for each plot designated for Post-Harvest Sampling.
- Samples shall be labeled and prepared for transport to the lab.
- Label the sample container with a sample ID.
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U.S. Hemp Guidance Program PHASE 2
1.4.6 Handling Procedures of Post-Harvest Samples
- The entire sample will be sent to the testing lab for analysis.
- Industrial hemp crops generated from Certified seed will incur pre-harvest testing of at least five percent (5%) of growing plots per variety, per seed source.
- Industrial hemp crops from planting materials other than Certified seed will incur pre- harvest testing of at least fifty percent (50%) of growing plots per variety, per seed source.
- 100% of post-harvest samples will be tested.
Botanical Authentication for the Long Haul
Blake Ebersole, president of NaturPro Scientific, noted adulteration of natural products,
especially foods and botanical ingredients, has been occurring for thousands of years. He added, “Two main classes of adulteration include economically motivated adulteration— generally the substitution or dilution of expensive ingredients with cheaper ones—and also, unintended cases of accidental adulteration or mistaken botanical identity.”
Private Label Drink and Beverage Powder Supplement Formulation
Creating a successful customized drink and beverage powder is a lot more than creating a list of ingredients that mix well together.
NaturPro has a broad base of knowledge in production of drinks and beverage powder development, spanning from pilots to private labels.
We guide our clients in the right direction, by helping to manage all or parts of the process for private label drink and beverage powder formulation and development all for dietary supplement and health products.
Drink and Beverage Supplement Formula Development
Our client list includes folks of all shapes and sizes, from startup to large corporation.
No two clients or projects are the same, but there are some common approaches found in our Product Development Toolbox:
Product Development Toolbox: Top 10 Development Tools:
Powder development requires a ‘toolbox’ of analysis including the following
- Market Analysis, Competitive Analysis and Positioning
- Supplier and Copacker Relationships
- Understanding of Regulatory Status / Safety Assessment
- Claims Development and Substantiation
- Costing and Financials
- Ingredient Readiness, Supplier Qualification
- GMP’s, Specifications, and Analytical Testing
- Intellectual Property Development
- Manufacturing Feasibility
- Contract Manufacturer Qualification and Negotiation
Contact Us
- Email: [email protected]
- Website: www.npscientific.com
- Twitter: @NaturalBlake
- Instagram: @NaturPro
Brain Health: Today is Almost Tomorrow
The brain is not simple, and neither are any answers. Early risk detection and a combination of supplements and interventions are the focus of today’s research by thousands of scientists and physicians who are likely to bear fruit in the near future.
Our Black Mentors | Why Black Lives Matter
A message from the Founder and President:
Many of you know me as a “science guy”, a consultant for food and supplements who always tries to go the extra mile and do the right thing for our clients. Many of our clients aren’t aware that the values of NaturPro are essentially the same as the values of the people who have influenced me, in particular, the Black men who have influenced my life.
When I was 14, I went to work for Glenn Ebersole, my dad, at the Country Club of Harrisburg in Pennsylvania. I spent almost every holiday, summer and busy weekend there until I was 22. Although my parents and family, and my education and work experiences are the foundation of NaturPro Scientific, some of the most important lessons of my life came from the Black men who trained and mentored me at the club.
Ron, who is Black, is a banquet legend in Central PA. (I changed his name to protect his privacy). I’ll always remember Ron in a tux uniform, a shining gold-toothed smile, gliding in between the crowd with a giant stacked tray of dirty china hoisted high in the air, so smooth that no one even sees him there. Ron was known to carry 32 entrees at a time, 16 plates tray-stacked, on each hand. Ron could set a formal service for 100 guests in an hour, by himself.
I was the kind of teenager who didn’t like to listen to my dad, if for no other good reason than he was the boss, and I was a teenager. Ron understood that, and he took me under his wing, and called me a brother. My dad set the high standards, but Ron taught them and got me to meet them, all by example. My time with Ron came with valuable lessons on life, that I believe Black men in America are uniquely qualified to share.
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Private country clubs in America are places where the disparity between the staff and the members is especially striking. In the 1990’s, there were no Black club members at CCH. But Black people, and people of color made up most of our full-time staff. My dad paid and treated all his staff fairly. He gave second and third chances to his employees, and posted bail and gave out more loans than he can probably remember. As a staff, we were all in it together in the aim to keep guests happy, while bearing daily witness to the engine of inequality in America.
Ron’s driver’s license was suspended for 18 years after being caught joyriding as a teenager. But I don’t remember Ron ever complaining or making excuses about it. He showed up for work every day, often a few minutes late, usually in a taxi or on his bicycle after riding the few miles to work.
When Ron got his driving privilege back, he never went back to get his license. When I asked why, he said he wanted to stay out of trouble. They’re not gonna get me again, I remember him saying with his Carolina country drawl that was often difficult for us PA folk to understand.
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Ron taught me my first lessons about quality assurance, in the form of the most effective and efficient technique used to wipe water stains from every piece of silver and glass. Not many restaurants wipe their silverware, which is why there’s always water marks on them.
Wiping silver and glass for formal service requires a certain technique to do correctly and efficiently, using a clean cloth of just the right type (clean, white, 100% cotton hand towel), and with just the right amount of water. If the cloth is too dry, it doesn’t wipe off the water marks. Too wet and it just creates new water marks. The water used for wiping silverware should also be just the right temperature (hot, from the coffee machine, but allowed to cool in the cloth for a few minutes so that it doesn’t burn your hand). That way, the water left from wiping evaporates and doesn’t create new water marks.
This was all Ron’s technique he developed to make sure the silverware looked like new for every guest, without it being an all-day project. Using this technique, one of us could clean and inspect about 1,000 pieces of spotless silverware per hour. Wiping silverware was the only time we got to sit down all day, so we looked forward to wiping silverware, as we listened to old R&B on an old clock radio, and I listened to Ron talk about life.
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Ron didn’t bark orders. Most of the time, he simply and quietly did the job better than anyone else. Ron expected everyone else to watch and learn, to try their best, to be helpful and not lazy. But slow-walking and empty hands were the red flags for which Ron would watch everyone closely, and he wasn’t afraid to call you out on it when he needed to.
Ron protected and helped me, covered for my mistakes on the floor without question or judgment, and helped me clean up the china and glasses I broke. Ron put me in the position to look good, when I was 15 and anything but. He did that for everyone else too – it was a team effort, always. Because if one person screws up, then we all screwed up. As I got older, the two of us flawlessly ran 5-course white-cloth meals for 100+ guests, with no other communication needed aside from nods and hand signals.
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Ron taught me some of the most important lessons about work, and about life, that a teenager can learn. These were the important lessons we all need to learn when we’re young. Lessons about going the extra mile to make the guests happy. Lessons about taking responsibility and working hard. About picking your battles, holding your tongue and saying the right things at the right time, when the truth matters.
There were numerous lessons about how food should look on a plate. There were many lessons about what real street smarts are, and about the importance of trust and loyalty, that I will always have with me. There were lessons about doing the right thing, even when everyone else thinks is right doesn’t make any sense. There were lessons about staying positive and having a sense of humor during life’s challenges. And lessons about taking the time to enjoy a cold Coors Light at the end of the day.
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Ron didn’t talk about white privilege, but he didn’t need to. We saw it in action, every day at work. We had to have thick skin for some of the rude looks and the nasty comments from guests, and meet them with a smile. I learned that what other people think, no matter how rich they are, or the color of skin – it doesn’t matter, as long as you stick to your own values and intuition. Ron rarely talked about how he had been treated unfairly by the system that took away half a lifetime of driving privileges for his harmless joyride. And at the time, I knew I benefited just by the color of my skin, without needing it explained.
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Ron is not the only Black mentor I had at the club who did hard time just for being Black. There was Ron’s friend, Curtis. Curtis is quiet, humble, hardworking. The maintenance guy and cleaner who knew how to remove every type of stain. I learned from Curtis that sometimes the cleaning sprays don’t work, and you just have to scrub the shit out of a stain until its gone. Curtis knew how to fix everything with duct tape and still make it look like new.
Curtis’s skin was dark as night. He did time in county jail for threatening a white co-worker who had stolen money from him. He was a big, strong guy, could bench 400 pounds and run five miles without breathing heavy. After scrubbing the locker rooms and shining golf shoes all day, Curtis would don the tux and haul trays at night until exhaustion. Curtis showed up for work every day with a level of loyalty and dedication that is rare for anyone of any skin color.
There are a lot more Ron’s and Curtis’s I’ve known, but they are two of the high-character Black people who have influenced me greatly. I know and trust Ron and Curtis, my dad knows and trusts them, and numerous influential white people in the Harrisburg area know and trust them.
Yet Ron and Curtis had their lives turned upside down for behavior that white people typically get a slap on the wrist for.
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Today, I’m aware of white people who would call Ron and Curtis “thugs”, but that couldn’t be further from the truth. Ron and Curtis are Black people, who I would choose to be in my corner, any day. And they deserve better from America.
There’s millions of Ron’s and Curtis’s out there who’s stories are lost in labels of ignorance. That’s why Black Lives Matter to me, and that’s why we are long overdue for real and permanent change in this country.
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On behalf of NaturPro Scientific, I am pledging our support to the following:
–Sharing the stories of our experiences with great Black people like Ron and Curtis, and encouraging others to do the same.
–Encouraging all white people in America to understand and reflect on the issues facing Black people, and people of all colors, nationalities, races, genders and sexualities.
–Communicating on issues of diversity within our network in the food and supplement space
–Donating to organizations supporting Black people, such as Black Lives Matter and ACLU
I hope that you will join me.
Sincerely,
Blake Ebersole
President and Founder
NaturPro Scientific LLC