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The Official Publication of the American Herbal Products Association
March 2010
www.ahpa.org
Volume 25, Number 3
In this issue of the AHPA Report
You Need to Know
2
• New Members
• AHPA’s Dentali Provides Valuable Counterpoint in High-Impact Journal
• AHPA 2010 Board of Trustees Election – Has Your Company Voted?
• AHPA’s 2010 Expo West Meeting and Event Schedule
Chairman’s Corner
5
• What Makes AHPA Tick?
by Edward J. Fletcher, Chair, AHPA Board of Trustees
Special Topic
6
• Products Spiked with ED Drugs an International Problem
by Katia Fowler, Director of Communications, AHPA
Legal & Regulatory 9
• AHPA Supports Banning Controlled Substances from Supplements; Opposes S. 3002
• FDA Overreaches in Liquid Product Draft Guidance – AHPA, IASC Joint Comments
• New CBP Filing Rule for Imports via Ocean Vessels Effective January 26, 2010
• Warning Letter Review
Remember These Three Rules
by Anthony L. Young, Esq., AHPA General Counsel
• Quick Round Up
Communications Update 14
• AHPA Media Scan: Notable “herbal headlines,” AHPA in the News”
Calendar of Botanical Events 15
Botanical Science Update 21
• Meeting Attended
USP’s Last Dietary Supplement Information Expert Committee
• Upcoming Meeting
Developments in Botanical Dietary Supplements Research from 1994 to Today
9th Annual Oxford International Conference on the Science of Botanicals
You Need to Know
New Members


AD Medicine International LTD is a market leader in the
research, development and production of a new generation
of liquid colloidal multi-complex phytoformulas. AD
Medicine came to the US market from Britain in 2008,
working with two manufacturing facilities in California and
Florida that produce a diverse line of high-bioavailability nutritional products designed to meet all of the human body’s
needs. AD Medicine LTD specializes in custom formulations and contract manufacturing.
Seagate Since 1981, Seagate has been producing raw materials from their own fishing and farming operations which
they process into a variety of products, health foods, vegetable concentrates, natural remedies, and fertilizer which are
marketed under their own brand. 
AHPA’s Dentali Provides Valuable
Counterpoint in High-Impact Journal
Dentali also discusses herbal safety, efficacy in companion podcast
American Herbal Products Association (AHPA) Chief Science
Officer Steven Dentali, Ph.D., provides a point/counterpoint to a
call for changes to the Dietary Supplement Health & Education Act
(DSHEA) in the February 2010 issue of the Nature-published journal Clinical Pharmacology & Therapeutics.
Dr. Dentali’s article, “Successful Botanical Research Requires
Botanical Expertise,” provides an opposing perspective to an article
by Drs. Tsourounis and Bent. While they argue additional regulatory oversight by the Food and Drug Administration (FDA) is needed
to improve the quality of botanical research, Dr. Dentali compelling
argues that what is needed in current research is experience working
with crude botanical materials. Scientific interest of well-known botanicals declined in the U.S. during the middle decades of the 20th
century as the use of medical herbs fall out of fashion within the
The AHPA Report, the official voice of the American
Herbal Products Association (AHPA), is published
monthly as a service to AHPA members and friends
of the herbal products industry. The material
contained in this publication is for the information
of AHPA members. Although the information
is believed to be correct, AHPA disclaims all
responsibility for any damage or liability that
may result from any reliance on the information
contained in this publication.
Articles may not be reproduced or reprinted
without written permission from AHPA.
medical community, Dr. Dentali explains, and it will take some
time to reestablish our forgotten familiarity with them.
“Every field of scientific inquiry and exploration is defined by expertise put into practice,” said Dr. Dentali. “The current challenge in
botanical research is to involve experts who understand botanical
preparations in the context of modern medical investigative approaches. I am honored to have had this opportunity to educate an
important group of scientists and doctors on the past and future of
botanical research.”
In addition to the article, Dr. Dentali and William Gurley, Ph.D.
discuss the safety and efficacy of herbal supplements in an accompanying podcast available online.
Members interested in learning more about the article should contact Dr. Dentali ([email protected]; 301-588-1171 x103) or visit
http://www.nature.com/clpt/journal/v87/n2/index.html.
The podcast is available here: http://www.nature.com/clpt/podcast/
index.html. 
AHPA 2010 Board of Trustees Election –
Has Your Company Voted?
Absentee/mail-in ballots for the 2010 Board of Trustees Election
must be received by Mon., March 8. Members of the American
Herbal Products Association’s (AHPA) Board of Trustees serve as
representatives of AHPA’s membership, and AHPA encourages all
member companies to participate in the selection of their representatives by casting a ballot in the 2010 elections.
The election to fill vacancies on the AHPA Board of Trustees will
take place during the association’s annual Member Breakfast Thurs.,
March 11 at the Anaheim Convention Center room 203-B (more
information available p. TK). If you are not planning on attending,
we urge you to cast your absentee ballot promptly (ballots can be
faxed or scanned/emailed (to: [email protected]), as well as mailed
via postal service).
AHPA Staff
Michael McGuffin, President
[email protected]
Steven Dentali, PhD, Chief Science Officer
[email protected]
Devon Powell, Chief Operations Officer
[email protected]
Katia Fowler, Director of Communications
[email protected]
Send inquiries, comments or requests to:
American Herbal
Products Association
8630 Fenton Street, Suite 918
Silver Spring, MD 20910
Phone: 301-588-1171
Fax: 301-588-1174
Email: [email protected]
Website: www.ahpa.org
© copyright 2010, AHPA
March 2010 • Page Five vacancies on the Board will be filled at this year’s election, and
10 candidates have announced their intention to stand for
election:

Matt Redd (A. M. Todd Botanicals)

Volker Wypyszyk (Azile LLC)

Garry Pay (Ideasphere)

Betsy Fallon (Martin Bauer Group)

Steven Yeager (Mountain Rose Herbs)

Moses McCord (New Sun)

Travis Borchardt (Schwabe North America)

Edward Fletcher (Strategic Sourcing)

Stefan Gafner (Tom’s of Maine)

Tina Mori (Vitarich Laboratories)
Chief Operating Officer Devon Powell at (301) 588-1171 x102 or
[email protected].
If you have not yet registered for the annual AHPA Member Meeting
and Breakfast, please do so here: http://www.ahpa.org/Member_
Breakfast_Registration.pdf.
Election materials are available for download at http://www.ahpa.
org/AHPA_BOT_Election_Materials.zip. 
AHPA’s 2010 Expo West Meeting and
Event Schedule
The American Herbal Product Association (AHPA) looks forward
to seeing its members during the Natural Products Expo West trade
show and convention held March 11-14 in Anaheim, Calif.
Each candidate will be provided with an opportunity to address the
Membership at the March 11 meeting. In conformity with the
AHPA Bylaws and Election Policies, nominations for additional
candidates will not be accepted from the floor and write-in votes
will not be accepted.
AHPA member companies are leaders in the herbal industry, and
association-hosted events provide members with excellent networking and educational opportunities during Expo West. Meet established and up-and-coming industry leaders at our member breakfast
and reception. Guide AHPA’s work, learn from colleagues and stay
in-the-know about news and developments in the industry at committee meetings.
If you are your company’s primary contact and have not received an
email containing the ballot and candidate statements or you have
questions regarding the election process, please contact AHPA’s
Download the complete schedule here:
http://www.ahpa.org/Portals/0/pdfs/10_0126_ExpoWest2010_
AHPAMeetingSchedule_Final.pdf
March 2010 • Page AHPA Member Breakfast (Thurs., March 11) will include the
election of AHPA’s Board of Trustees and presentation of the 2010
AHPA Awards. The Board nomination deadline is Feb. 9. If you
wish to seek election to the Board, simply request the “Intent to
Stand for Election” form from AHPA’s Devon Powell at dpowell@
ahpa.org. To register for the breakfast, please see http://www.ahpa.
org/Member_Breakfast_Registration.pdf.
AHPA Member Reception (Fri., March 12) will begin after the
show floor closes, offering an opportunity to network with your fellow AHPA members and AHPA staffers. The reception will be held
in the Hilton’s Pacific Ballroom.
AHPA Committee Meetings (March 11–13) are where the work
of AHPA is identified and developed. In addition to guiding the activities and direction of your trade association, becoming a member
of an AHPA committee is a guaranteed way to stay abreast of industry developments and learn from your peers through discussion and
information-sharing.
Education / Small Business Committee
4:30 – 6:00 p.m. / March 11 / Anaheim Convention Center /
Room 203-B
Staff Liaison: Devon Powell ([email protected])
Learn about the committee online:
http://www.ahpa.org/Default.aspx?tabid=88
Joint Meeting: Analytical Labs / Botanical Raw Materials /
Standards
9:00 – 11:45 a.m. / March 12 / Anaheim Convention Center /
Room 203-B
Staff Liaison: Steven Dentali, PhD ([email protected])
Learn about the committees online:
Botanical Personal Care Products Committee
Room 203-B
Staff Liaison: Katia Fowler ([email protected])
Government Relations Committee
9:00 – 11:00 a.m. / March 13 / Anaheim Convention Center /
Room 203-B
Staff Liaison: Michael McGuffin ([email protected])
Animal Products Committee
11:15 – 12:45 p.m. / March 13 / Anaheim Convention Center
/ Room 203-B
Staff Liaison: Katia Fowler ([email protected])
Chinese Herbal Products Committee
Room 203-B
Ayurvedic Herbal Products Committee
Room 203-B
AHPA’s Board of Trustees will be meeting Wed., March 10 from
12:00 to 6:00 p.m. and Thurs., March 11 from 12:30 to 2:00 p.m.
in the Hilton’s Palos Verdes room. The AHPA Foundation for
Education and Research on Botanicals Board will be meeting
Wed., March 10 from 2:15 to 4:15 p.m. in the Anaheim Convention
Center Room 203B. Contact Michael McGuffin for more information about either of these board meetings. 
Tai Sophia Institute’s
New Graduate Certificate Program
in Medical Herbalism,
starting April 2010
The Tai Sophia Institute, a nonprofit, accredited graduate school is now offering a 9-weekend (one weekend
per month for 9 months) Graduate Certificate in
Medical Herbalism. This program is exclusively designed to put health-care professionals, researchers and
supplement manufacturers at the forefront of the wellness revolution that is shaping the future of health care.
Gain a foundational knowledge of herbal medicine that
emphasizes issues of quality, safety, and efficacy as well
as an in-depth understanding of the 30 most commonly
used herbal supplements in the US market. The program is approved for continuing education units and
contact hours toward licensure requirements for select
professions and is approved for federal financial aid.
Class begins this April. To learn more, visit http://www.
tai.edu, call the Office of Graduate Admissions 401888-9048 ext. 6647, attend an Open House on March
20 or a faculty-led herb walk on April 7.
March 2010 • Page Chairman’s Corner
What Makes AHPA Tick?
By Edward J. Fletcher, Chair, AHPA Board of Trustees
It has been an exciting time to serve as the Chair of the AHPA Board
of Trustees. Since beginning my tenure in 2007, the industry has
seen the implementation of mandatory adverse event reporting and
all but the smallest companies are now subject to the long-awaited
Good Manufacturing Practice (GMP) for dietary supplements. And
the news in this issue of the AHPA Report regarding Senator McCain’s
introduction (and now possible re-consideration) of S. 3002 shows,
it will remain an exciting time for this industry for years ahead.
As I consider my time as Chair, I am particularly struck by AHPA’s
ability to bring creative solutions to complex problems. Earlier this
month, AHPA adopted a position to support legislation that would
ban controlled substances from dietary supplements (see p. 9 of this issue for more information). The impetus behind this decision was a desire
among the Board members not to simply oppose what is currently on
the table (S. 3002), but to offer a solution. The result was an idea for a
legislative action that would truly address the concerns voiced by
Senator McCain and those who encouraged the introduction of his bill.
The AHPA NDI Database
Within AHPA, the ability to become truly
engaged in orchestrating change in this
industry is not restricted to membership
on the Board of Trustees. In fact, as a bottom-up organization, most solutions are
recommended to the Board by AHPA
Edward J. Fletcher
committees. These committees – ranging
from Government Relations to Analytical Laboratories to Chinese
Herbal Products – provide the expertise and hard work that brings
strong ideas to the Board of Trustees for consideration. AHPA’s
committees are the engines that make the system run. So, this week
I encourage members to drop by at least one meeting of interest held
during Natural Products Expo West – and bring your concerns and
ideas when you attend! I also hope to see many of you at our AHPA
Annual Member Breakfast and Meeting and at the Member
Reception on Friday. Travel safe and best wishes for a great 2010
Expo West!
Genuinely,
Edward J. Fletcher
Out-going Board Chair
Your key to future botanicals
The AHPA NDI Database helps companies that have invested in new dietary ingredients
increase their knowledge how to submit NDI notifications and speed their time to market.
Cut through the confusion
The AHPA NDI Database is the most complete listing and analysis resource for NDI filings, often posting information well in advance of the FDA website. No need to review lengthy or numerous documents to try to determine
the outcome of an NDI submission. “Outcome statements” for each notification summarize FDA’s response.
Easily locate notifications by searching for such key terms as the generic names, brand names, Latin names, the
submitting firm or their counsel or other consultant, or the report number assigned by FDA.
Subscribe to and access the database at http://ndi.npicenter.com/
But wait! There’s more …
AHPA also offers a practical guidance document to help companies increase their success in filing NDI notifications.
AHPA’s Interim Guidance for New Dietary Ingredient Notifications for Manufacturers of Distributors of New
Dietary Ingredients explains the NDI regulations, details what information to include (and exclude) in a notification, and provides three practical hands-on worksheets:
♦ Determination of Requirement to Submit
♦ Submission of NDI Notification
♦ Cover Letter Template for Notification Submission
Available for purchase via the AHPA online bookstore www.ahpa.org
March 2010 • Page Special Topic
to contain xanthoanthrafil (also known as benzamidenafil), which is not
indicated on the label. http://www.hc-sc.gc.ca/ahc-asc/media/advisoriesavis/_2008/2008_169-eng.php
Products Spiked with ED Drugs
an International Problem
By Katia Fowler, Director of Communications, AHPA
A study in the current issue of the International Journal of Clinical
Practice calls physicians’ attention to direct and indirect health risks
associated with the use of counterfeit Viagra® sold on the internet.
Included among the different types of counterfeit drug products
identified by the study authors are “spiked” dietary supplements
marketed for sexual dysfunction.
The inclusion of these products in the study is a good reminder that
the counterfeit drug trade is indeed a driving force behind the continued sale and consumption of spiked supplements – a point often
lost in discussions of DSHEA. As the list below shows, it is also consistently lost in the debate that the problem of products spiked with
erectile dysfunction (ED) drugs is a worldwide problem that extends far beyond the reach of DSHEA.
Health Canada catalogs product alerts from around the world.
Here is a list of product alerts from the past two years, with alerts
from the United States Food and Drug Administration omitted. Canada
March 10, 2008 – Health Canada warns of ADAM an unauthorized
product containing a drug like sildenafil. http://www.hc-sc.gc.ca/ahcasc/media/advisories-avis/_2008/2008_39-eng.php
April 25, 2008 – Health Canada warns of Vigoureux an unauthorized product containing a drug like sildenafil. http://www.hc-sc.gc.
ca/ahc-asc/media/advisories-avis/_2008/2008_63-eng.php
May 22, 2008 (updated June 5, 2008) – Health Canada is warning
consumers not to use Desire, an unauthorized product promoted to
enhance male sexual performance as this product may pose serious
health risks in certain patients. Lot 0070263 of the product was
found to contain the prescription drug phentolamine, which is not
indicated on the label. http://www.hc-sc.gc.ca/ahc-asc/media/advisoriesavis/_2008/2008_80-eng.php and http://www.hc-sc.gc.ca/ahc-asc/
media/advisories-avis/_2008/2008_88-eng.php
October 28, 2008 – Health Canada is warning consumers not to use
Eros Fire, a product promoted to enhance sexual performance, as
this product may pose serious health risks. The product was found
G. Jackson , S. Arver , I. Banks, V. J. Stecher. Counterfeit phosphodiesterase type 5 inhibitors pose significant safety risks. Int J Clin Pract.2010;
64(4):497-504. http://www3.interscience.wiley.com/journal/123243854/
abstract [Accessed on March 4, 2010]
For all advisories, recalls and alerts issued by Health Canada see http://
www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/index-eng.php [Accessed on
March 4, 2010]
November 26, 2008 – Health Canada warns of Firm Dose and Granite
Rooster unauthorized product scontaining a drug like sildenafil. http://
www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_2008/2008_176-eng.php
Denmark
May 5, 2008 – The Danish Medicines Agency advised consumers
not to use the product vpxl No1 Dietary Supplement for Men because it was found to contain tadalafil. http://www.hc-sc.gc.ca/ahcasc/media/advisories-avis/_fpa-ape_2008/2008_71-eng.php
July 24, 2008 – The Danish Medicines Agency has warned against
the use of Wodibo because it was found to contain sildenafil and
tadalafil. http://www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpaape_2008/2008_118-eng.php
Finland
January 6, 2010 – The Finnish Food Safety Authority, Evira, recalled
Full Contact Max Potency after it was found to contain undeclared
thio-sildenafil and thio-homosildenafil, which are unauthorized
substances similar to sildenafil. http://www.hc-sc.gc.ca/ahc-asc/media/
advisories-avis/_fpa-ape_2010/2010-01-eng.php
Hong Kong
June 24, 2008 – The Hong Kong Department of Health issued several press releases from February through April 2008 advising consumers against the use of Nangen Zengzhangsu (may also be known
as Nangen or Nangeng), Sanbianwan, Jiu Bian Wang, Tian Huang
Gu Shen Dan, Zui Xian Dan Gong Shi Zi, and Power Up because
they were found to contain sildenafil and/or glibenclamide. http://
www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_2008/2008_
96-eng.php
August 11, 2008 – The Hong Kong Department of Health has
recalled Oyster Extract Caps because they were found to contain
hydroxyacetildenafil, a compound similar in structure to sildenafil.
http://www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_
2008/2008_129-eng.php
August 22, 2008 – The Hong Kong Department of Health warned
consumers not to buy or use Lover Liquid Nutriment Herbal
Supplement and Onyo because they were found to contain undeclared pharmaceutical ingredients. Lover Liquid Nutriment Herbal
Supplement was found to contain sildenafil while Onyo was found
to contain sildenafil, as well as unapproved substances with structures
similar to sildenafil (acetildenafil) and vardenafil (pseudovardenafil).
http://www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_
2008/2008_157-eng.php
March 2010 • Page September 19, 2008 – The Hong Kong Department of Health
warned consumers not to buy or use Dr. Life or Chong Cao Ju
Wang because they were found to contain undeclared pharmaceutical ingredients. Dr. Life was found to contain an unauthorised substance with a structure similar to tadalafil (aminotadalafil) while
Chong Cao Ju Wang was found to contain sildenafil. http://www.
hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_2008/2008_159eng.php
October 14, 2009 – The Hong Kong Department of Health warned
consumers not to buy or use Kam Yuen Brand Wan Ying Yang Gan Wan
after it was found to contain undeclared sildenafil. http://www.hc-sc.gc.
ca/ahc-asc/media/advisories-avis/_fpa-ape_2009/2009-168-eng.php
October 17, 2008 – The Hong Kong Department of Health warned
consumers not to buy or use the product Sweet Energizer Vitality
Candy because it was found to contain an unauthorised substance
with a structure similar to tadalafil (aminotadalafil). http://www.hcsc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_2008/2008_166eng.php
March 1, 2010 – The Hong Kong Department of Health (HKDH)
warned consumers not to buy or use 2H & 2D after it was found to
contain undeclared tadalafil. http://www.hc-sc.gc.ca/ahc-asc/media/
January 30, 2009 – The Hong Kong Department of Health warned
consumers not to buy or use the product Zhuang Tjar Gere after it
was found to contain undeclared sildenafil and tadalafil. http://www.
hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_2009/2009-10eng.php
March 1, 2010 – The Irish Medicines Board warned consumers not
to buy or use STRO Emperor Capsules after it was found to contain
undeclared tadalafil. http://www.hc-sc.gc.ca/ahc-asc/media/advisoriesavis/_fpa-ape_2010/2010-30-eng.php
June 3, 2009 – The Hong Kong Department of Health warned consumers not to buy or use Zhong Guo Shen Fang after it was found
to contain hydroxyacetildenafil, an unauthorized substance similar
to sildenafil. http://www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_
fpa-ape_2009/2009-87-eng.php
The Netherlands
December 22, 2009 – The Hong Kong Department of Health
warned consumers not to buy or use Zeng Da Yan Shi Wan after it
was found to contain undeclared sildenafil. http://www.hc-sc.gc.ca/
ahc-asc/media/advisories-avis/_fpa-ape_2009/2009-209-eng.php
Ireland
August 11, 2008 – The Netherlands Health Care Inspectorate, the
U.K. Medicines and Healthcare Products Regulatory Agency, and
the Danish Medicines Agency have warned consumers not to use
Herb Vigour, Natural Vigour or China Vigour because they were
March 2010 • Page AHPA Member Discount
25% off all
heavy metals testing
found to contain tadalafil (Herb Vigour), vardenafil (Natural
Vigour) and an unapproved substance with a structure similar to
sildenafil (China Vigour). http://www.hc-sc.gc.ca/ahc-asc/media/
advisories-avis/_fpa-ape_2008/2008_128-eng.php
Singapore
June 24, 2008 – Singapore’s Health Sciences Authority has warned
against the use of Zhong Hua Niu Bian because it has been found to
contain sildenafil, tadalafil, glibenclamide and sibutramine. http://
www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_2008/2008_
97-eng.php
February 25, 2009 – The Singapore Health Sciences Authority
warned consumers not to buy or use Menergy M-Essence capsules
after it was found to contain two unauthorized substances similar to
sildenafil (acetildenafil and acetilacid). http://www.hc-sc.gc.ca/ahcasc/media/advisories-avis/_fpa-ape_2009/2009-26-eng.php
Frontier Global Sciences, a leader in
heavy metals testing has partnered with
AHPA to give members 25% off on every
test we offer.




Lead
Mercury
Arsenic
Cadmium
October 14, 2009 – The Singapore Health Sciences Authority
(HSA) warned consumers to not buy or use Dynasty Worldwide
Jinglida So Young Formula after it was found to contain undeclared
aminotadalafil, an unauthorized substance similar to tadalafil. http://
www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_fpa-ape_2009/2009166-eng.php
December 22, 2009 – The Singapore Health Sciences Authority issued a recall notice for Power-Plus P (expiry date 03/03/2011) after
it was found to contain undeclared tadalafil. http://www.hc-sc.gc.ca/
ahc-asc/media/advisories-avis/_fpa-ape_2009/2009-207-eng.php
January 6, 2010 – The Singapore Health Sciences Authority issued
a recall notice for one batch (batch number CA009A08F, expiry
date 15/01/2011) of M-Action after it was found to contain undeclared desmethylacetildenafil and acetilacid, which are unauthorized
substances similar to sildenafil. http://www.hc-sc.gc.ca/ahc-asc/media/
If you have questions about how we can
support metals testing and California’s
Prop 65 Compliance, give us a call!
Switzerland
October 17, 2008 – Swissmedic warned consumers not to buy or use
the product Powertabs because it was found to contain an unauthorised
substance with a structure similar to sildenafil. http://www.hc-sc.gc.
ca/ahc-asc/media/advisories-avis/_fpa-ape_2008/2008_165-eng.php
United Kingdom
(206) 622-6960
www.frontiergs.com
April 29, 2008 – The United Kingdom Medicines and Healthcare
products Regulatory Agency (MHRA) advised the public not to
use the product Tian Li, because it was found to contain tadalafil
and hydroxyhomosildenafil. http://www.hc-sc.gc.ca/ahc-asc/media/
advisories-avis/_fpa-ape_2008/2008_65-eng.php
June 2, 2009 – The United Kingdom’s MHRA warned consumers
not to buy or use the product Jia Yi Jian after it was found to contain
undeclared sibutramine and tadalafil. http://www.hc-sc.gc.ca/ahc-asc/
media/advisories-avis/_fpa-ape_2009/2009-83-eng.php 
March 2010 • Page Legal & Regulatory Update
already defines dietary supplements to explicitly exclude approved
new drugs. But neither DSHEA nor the McCain-Dorgan bill directly address anabolic or “designer” steroids.
AHPA Supports Banning Controlled
Substances from Supplements;
Opposes S. 3002
The American Herbal Products Association (AHPA) has adopted a
policy to support federal legislation to clarify that controlled substances, as defined by the Controlled Substances Act, may not be included as ingredients in dietary supplements. While no such
legislation has been introduced in the U.S. Congress at this time,
AHPA plans to support this kind of direct approach to address occasional reports of products labeled as “dietary supplements” that
contain anabolic steroids, a class of controlled substances that adulterate the supplements and make them unlawful.
“Legislation to exclude controlled substances from the definition of
dietary supplements would remove these ingredients from the product category entirely,” noted AHPA president Michael McGuffin.
“It is AHPA’s view that the Congress did not intend to allow steroids
and other controlled substances in supplements but it now appears
that some clarification of this point is needed.”
AHPA has also adopted a position to oppose S. 3002, a bill introduced in February by Senators John McCain (R-AZ) and Byron
Dorgan (D-ND), in part to address undeclared steroids and drug
ingredients in supplement products. S. 3002 would make significant amendments to the Dietary Supplement Health and Education
Act (DSHEA), which
“There is no place for anabolic steroids or other controlled substances in dietary supplements or in sports nutrition,” noted
McGuffin. “The actions taken by the AHPA Board are intended to
refocus the attention of the Congress and sports organizations onto
a legislative route that will address the stated purposes of Senators
McCain and Dorgan without disrupting access to lawful supplements by consumers who choose to use them to support their
health.”
In voting to oppose S. 3002, the AHPA Board expressed concern
that this legislation as introduced would have significant detrimental effects on the dietary supplement industry, including retailers,
and on American consumers’ access to a broad range of dietary supplements. The Board also noted that the bill is redundant in some
places to current laws, and would create new burdens for the Food
and Drug Administration without any reciprocal benefit.
Shortly after AHPA announced its opposition to the bill, a March 4
letter to Senator John McCain was released in which Senator Orrin
Hatch (R-UT) notes that Senator McCain intends to withdraw his
support for certain elements of S. 3002.
“We don’t know yet if any of the concepts included in this legislation will survive,” said McGuffin, “but this is certainly good news
and a testament to the continuing leadership role that Senator Hatch
Support Safety by Supporting the Botanical Safety Handbook Revision
AHPA’s Botanical Safety Handbook is a reference book that provides safety information on more
than 600 species in trade as ingredients in dietary supplements. An essential reference for healthcare providers, consumers, retailers and manufacturers of herbal products, its safety classifications
are frequently cited in other publications.
Time for an update
v
Significant herbal research has been published since the BSH was published in 1997
v
A number of new ingredients are now on the market.
The revision will be based upon comprehensive literature reviews for each herb, historical uses and traditional knowledge,
and case reports of adverse reactions and herb-drug interactions, herb-drug interaction studies, metabolism studies, toxicology studies and clinical trials.
The BSH revision is to be completed over a three-year period, and seed money for the project has been pledged by the Office
of Dietary Supplements at the National Institutes of Health, the University of Massachusetts, and individual and corporate
contributions to the AHPA-ERB Foundation.
Pledge your tax-deductible contribution today!
Contact Michael McGuffin at [email protected].
March 2010 • Page plays in protecting consumer access to a broad range of health-promoting dietary supplements.”
tially the same as a conventional food, so long as it is not represented
for use as a conventional food” (62 FR 49859, Sept. 23, 2997).
In his letter, Senator Hatch expresses his appreciation for the latter’s
“agreeing to withdraw your support for the provisions of S. 3002
that I believe would do great harm to the dietary supplement industry and work with me on solutions that will truly help dietary supplement consumers without injuring this important industry.” The
letter also states Hatch’s intention to work with McCain “on calling
for the full enforcement of existing laws … so Americans will have
uninterrupted access to safe dietary supplements and bad actor
companies are removed from the market immediately.” 
“The draft guidance represents new and original thinking by the
agency that is in direct opposition to prior policy provided to industry in a rulemaking process,” said McGuffin. “If FDA does not accept the suggestions of AHPA and IASC, the issuance of an
unamended guidance as final would constitute de facto rulemaking
and be in opposition to the rulemaking requirements of the
Administrative Procedure Act.”
FDA Overreaches in Liquid Product Draft
Guidance – AHPA, IASC Joint Comments
In joint comments filed Feb. 2, the American Herbal Products
Association (AHPA) and International Aloe Science Council (IASC)
assert the Food and Drug Administration (FDA) overreaches when
it suggests that packaging or serving size may be factors – and potentially the only factor – that are indicative of whether a liquid supplement product is represented as a conventional food.
AHPA and IASC submitted comments in response to FDA’s draft
guidance for industry, “Factors that Distinguish Liquid Dietary
Supplements from Beverages, Considerations Regarding Novel
Ingredients, and Labeling for Beverages and other Conventional
Foods.” According to the draft guidance released Dec. 4, 2009,
“Liquid products that suggest through their serving size, packaging,
or recommended daily intake that they are intended to be consumed
in amounts that provide all or a significant part of the entire daily
drinking fluid intake of an average person are represented as
beverages.”
However, AHPA and IASC point out that it is nowhere written in
FDA’s food labeling regulations that serving sizes for conventional
foods are reserved for conventional foods only. Likewise, there is no
regulation that implies that any form of packaging is reserved to
conventional foods and not available to dietary supplements.
The joint comments filed by AHPA and IASC are available here:
http://www.ahpa.org/Portals/0/pdfs/10_0202_Comments_FDA_
LiqProd_Draft_Guidance.pdf.
FDA’s draft guidance is on the agency’s Web site: http://www.fda.
g o v / Fo o d / G u i d a n c e C o m p l i a n c e R e g u l a t o r y In f o r m a t i o n /
GuidanceDocuments/ucm192702.htm/ 
Warning Letters
For the benefit of our members, AHPA notifies members of new
Warning Letters posted on FDA’s Web site. Below AHPA General
Counsel Anthony L. Young, Esq. (Kleinfeld Kaplan & Becker) reports on the significance of several recently-issued Warning Letters.
Warning Letters are first distributed to AHPA members who subscribe to the AHPA Legal Alert service. For more information, email
Katia Fowler, [email protected].
Creativity
Innovation
Science
“Simply stated, neither packaging nor serving size ‘represents’ the
‘form’ of a food,” said AHPA President Michael McGuffin. “The
first is required to carry and preserve the food for the consumer, and
the second is required by law to be stated as part of the nutrition information for both dietary supplements and conventional foods.”
The trade associations also note the draft guidance fails to acknowledge and take into account prior statements by FDA regarding dietary supplements in conventional food form, and request that any
final guidance be revised as needed to make all of the points previously communicated by the agency. For example, in the preamble to
a final rule addressing nutrient content claims, health claims and
statements of nutritional support for dietary supplements, FDA
writes: “….a dietary supplement may be a product with physical attributes (e.g., product size, shape, taste, packaging) that are essen-
March 2010 • Page 10
11767 Road 27 1/2, Madera, Ca 93637
ph 559.661.0031 • fax 559.661.0 032
www.stiebs.com • [email protected]
Remember These Three Rules
By Anthony L. Young, Esq., Partner, Kleinfeld Kaplan & Becker
and AHPA General Counsel
The FDA’s Warning Letter to Innovative Beverage Group, Inc
teaches that conventional beverage marketers need to do their homework before they put ingredients from the dietary supplement industry into their products. This company’s product is Drank, a 16
oz beverage, with melatonin, and promoted for relaxation. This is
the first letter that has come out following the FDA’s December
publication of its draft Guidance for Industry: Factors that Distinguish
Liquid Dietary Supplements from Beverages, Considerations Regarding
Novel Ingredients, and Labeling for Beverages and Other Conventional
Foods. The rationale for this letter is that melatonin is not an approved food additive and not Generally Recognized as Safe (GRAS)
for use in food. If a company wants to self-affirm an ingredient as
GRAS for use in food, it should do so using qualified experts who
rely on good science. Indeed, there is at least one stevia product on
the market now that self-affirmed and had its self-affirmation examined by FDA, and pass. FDA is not blind to good science reviewed
by good scientists. FDA made its first assault on novel ingredients in conventional beverages back in June 2001 with Warning Letters to Hansen’s, Fresh
Samantha and Knudsen’s. Those companies were using ingredients
like ginkgo, Echinacea and ginseng, all of which FDA questioned. The
upshot of those letters, however, was that the companies just kept on
marketing their products, and FDA apparently never followed
up. That past may not be the prologue now. On March 3, FDA released a barrage of Warning Letters to food companies about label
claims and labeling, along with a letter from FDA Commissioner
Hamburg that gave a simple message – follow the food labeling regulations or find your company name and product name on the
morning and evening news, and in the papers. It is clear that there is a new Sheriff in town, and it is clear that companies must be more attentive to the lane markers on the regulatory
highway. This brings to mind the three important rules for survival
in a regulated industry. ONE. Is what we propose to do
lawful? TWO. Will what we propose to do make a profit? THREE. Remember the order of the three rules. The warning letter to Innovative Beverage Group, Inc is available
here http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
ucm201435.htm 
Recent H1N1 Warning Letters
Mountain Health Line 1/5/2010
Product(s): Living Streams Flora PM
Cited Claim(s):
Examples
• "It is only recently that scientific research has been performed on humic minerals [ingredients in your product]. .
. . Scientific studies have shown that it impairs the attachment of the HIV-1 virus . . . Another study examined
influenza viruses, including the swine flu, with the same results. . . . There is every reason to expect that its
antiviral properties are broad spectrum, meaning it may have usefulness against the Asian or bird flu pandemic."
Letter: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm196454.htm
Ascential Experience Online 1/5/10
Product(s): Swine Flu Kit #7980
Cited Claim(s):
Examples
• Swine Flu Kit #7980"
• "Diseases caused by viral infection include: ... flu ... The herbal approach to viral infection is two pronged: ...
The specific use of antiviral herbs to disrupt the replication cycle so it cannot survive."
• "Kit includes: 2 oz Bird Flu Formula #1495, ... 2 oz Cold/Flu/Virus Preventative #1025"
• "Instructions Take 10-20 drops 3 times a day of all three tinctures at the onset of any flu like symptons [sic] or
before as a preventative.
• "#1025 COLD/FLU/VIRUS PREVENTATIVE [a component of your product]: Use ... as a preventative when
there is ... flu or virus present in your home or office Luckily, however, whilst there are few effective antiviral
drugs available, there are many plant extracts with proven antiviral activity."
Letter: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm196790.htm
Quick Round-up
For the benefit of our members, AHPA keeps an eye on the many
agencies that regulate the herbal products industry. Below are several
recent regulatory developments that may interest you. They were
first sent to those AHPA members who subscribed to the AHPA
Legal Alert. For more information, email AHPA’s Katia Fowler,
[email protected].
FDA Update on the Investigation into the
Salmonella Montevideo Outbreak
The Food and Drug Administration, along with the Centers for
Disease Control and Prevention and the U.S. Department of
Agriculture’s Food Safety and Inspection Service, on Feb. 25 provided an update on the investigation of an outbreak of Salmonella
Montevideo infections associated with certain Italian-style sausage
products including salami/salame.
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/
ucm202128.htm
Wholesome Spice Recalls 25 Lb. Boxes Of Crushed
Red Pepper Because Of Possible Health Risk
Wholesome Spice of Brooklyn, NY is recalling all lots of 25 lb boxes
of Crushed Red Pepper sold between 4/6/09 and 1/20/10, because
they have the potential to be contaminated with Salmonella, an
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Obama Administration Details Healthy Food
Financing Initiative
The Obama Administration on Feb. 19 released details of an over
$400 million Healthy Food Financing Initiative, which will bring
grocery stores and other healthy food retailers to underserved urban
and rural communities across America. The initiative was announced
in Philadelphia by Treasury Secretary Tim Geithner and Agriculture
Secretary Tom Vilsack. The two cabinet members appeared with
First Lady Michelle Obama, who recently launched the Let’s Move!
campaign to solve the epidemic of childhood obesity within a generation. The initiative is a partnership between the Departments of
Treasury, Agriculture, and Health and Human Services.
http://www.hhs.gov/news/press/2010pres/02/20100219a.html
U.S. patent office rejects part of Viagra patent
The U.S. Patent and Trademark Office has partially rejected a patent
on Pfizer Inc’s impotence drug Viagra because it works in a way similar to the Chinese herb Yin Yang Huo, which is sold on websites
under the colorful name Horny Goat Weed, Reuters reports Feb. 16.
http://news.yahoo.com/s/nm/20100216/hl_nm/us_pfizer_viagra
[Editor’s Note: The final decision of the USPTO’s Board of Patent
Appeals and Interferences is here: http://des.uspto.gov/Foia/ReterivePdf
?system=BPAI&flNm=fd2009004106-02-12-2010-1]
“Complete 7-Day Cleanse” Recalled Due to
Possible Serious Health Risks
Health Canada advised consumers Feb. 9 that the unauthorized
product “Complete 7-Day Cleanse” is being recalled because it contains a number of active ingredients with a combined effect that
may pose serious health risks. “Complete 7-Day Cleanse” is a multiingredient natural health product promoted for “cleansing” or removing toxins from the body.
http://www.hc-sc.gc.ca/ahc-asc/media/advisories-avis/_2010/2010_19eng.php
Springfield Business Owner Pleads Guilty to
Fraudulently Marketing Dietary Supplements
Internet Businesses Generated Nearly $12 Million with
False Claims to Prevent, Cure Diseases
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organism which can cause serious and sometimes fatal infections in
young children, frail or elderly people, and others with weakened
immune systems, the company announced Feb. 25.
http://www.fda.gov/Safety/Recalls/ucm202113.htm
ISO 9001:2000 Certified
Beth Phillips, United States Attorney for the Western District of
Missouri, announced Feb. 8 that a Springfield, Mo., business owner
has pleaded guilty in federal court to her role in a conspiracy to
fraudulently market dietary supplements over the Internet with illegal claims that these supplements could prevent, treat or cure a
number of diseases. Several Web sites were used to sell nearly $12
million worth of the products in 2005 and 2006.
ucm199516.htm
Notice of Funds Availability (NOFA) Inviting
Applications for the Specialty Crop Block Grant
Program–Farm Bill (SCBGP-FB)
The Agricultural Marketing Service (AMS) announced Feb. 3 the
availability, of $55,000,000 in grant funds, less USDA administrative costs, to solely enhance the competitiveness of specialty crops.
SCBGP-FB funds are authorized by the Food, Conservation, and
Energy Act of 2008 (the Farm Bill). State departments of agriculture
are encouraged to develop their grant applications promptly. State
departments of agriculture interested in obtaining grant program
funds are invited to submit applications to USDA.
http://edocket.access.gpo.gov/2010/pdf/2010-2218.pdf
$119.5 Million in State Awards Announced
as Part of Recovery Act Community Prevention
and Wellness Initiative
The U.S. Department of Health and Human Services (HHS) on
Feb. 3 awarded $119.5 million to states and U.S. territories to sup-
port public health efforts to reduce obesity, increase physical activity,
improve nutrition, and decrease smoking-the four most important
actions for combating chronic diseases and promoting health. This
money supports the first of several initiatives that make up the comprehensive prevention and wellness initiative, Communities Putting
Prevention to Work which is funded under the American Recovery
and Reinvestment Act.
http://www.hhs.gov/news/press/2010pres/02/20100203a.html
FDA Requests $4.03 Billion to Transform Food
Safety System, Invest in Medical Product Safety,
Regulatory Science
FY 2011 request represents a 23 percent increase
over FY 2010 budget
The U.S. Food and Drug Administration announced Feb. 1 it is requesting $4.03 billion to promote and protect public health as part
of the President’s fiscal year 2011 budget – a 23 percent increase
over the agency’s current $3.28 billion budget. The FY 2011 request, which covers the period of Oct.1, 2010, through Sept. 30,
2011, includes increases of $146 million in budget authority and
$601 million in industry user fees.
ucm199516.htm 
National and International
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You can access the AHPA Program through your agent/broker by having them
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www.dickgriffin.com • [email protected]
Communications Update
AHPA Media Scan:
Notable “Herbal Headlines”
These “herbal headlines” – and headlines of interest to the herbal
industry – have been selected from the past few weeks of media activity. If you would like a copy of any of these articles, please email
Katia Fowler [email protected].
AHPA in the News
Feb. 19, 2010 – AHPA Representative Provides Counterpoint to
DSHEA Changes Nutraceuticals World
Feb. 8, 2010 – FDA Should Not Judge A Liquid Supplement By
Its Packaging – Stakeholders “The Tan Sheet”
Feb. 8, 2010 – GMP Supplier Qualification Appears More Viable
Route Than Testing “The Tan Sheet”
Feb. 4, 2010 – Industry attacks McCain Bill for “regulatory overkill” Nutraingredients-USA.com
Feb. 1, 2010 – GAO New Dietary Ingredient Probe Has Puzzled
Firms Seeking Legal Advice “The Tan Sheet”
Feb. 23, 2010 – Acupuncture Benefit Seen in Pregnancy Reuters
Feb. 16, 2010 – “Natural” Cleaners: “Green”? Effective? CBS News
Feb. 12, 2010 – ‘Biggest Loser’ trainer Jillian Michaels sued over
‘bogus’ diet pill claims The Money Times
Feb. 11, 2010 – Fake doctor sentenced to 9 months in OC jail Mercury
News
Feb. 11, 2010 – Poisonings point to holes in supplement oversight
Reuters
Feb. 11, 2010 – Vegetable tests show pesticides: Guangdong residents
say they are concerned about quality China Daily
Feb. 6, 2010 – Chemnutra Owners Sentenced for Melamine-Tainted
Pet Food Consumer Affairs
Feb. 3, 2010 – Fewer Than 1% of U.S. Farms Are Organic, USDA
Says Wall Street Journal
Feb. 1, 2010 – Santa Cruz prosecutor finds no Hoodia in diet pill;
company says ‘so sue us’, prosecutor complies Santa Cruz Sentinel
Feb, 1, 2010 – Herbal remedies, heart drugs a dangerous combo
CNN
Jan. 28, 2010 – Obama’s pick for food safety chief surprises consumer
advocates Washington Post
Jan. 26, 2010 – Herbal use common among pregnant women in U.S.
Reuters
Jan. 21, 2010 – Foods fortified with extra vitamins could prove costly
L.A. Times
Jan. 21, 2010 – Guilty Plea in Sale of Products With Steroids New
York Times
Jan. 20, 2010 – Democrats scramble on health care after GOP win
CNN.com
Jan. 14, 2010 – New FDA deputy to lead food-safety mandate
Washington Post
Jan. 13, 2010 – When the Gym Isn’t Enough New York Times
Jan. 12, 2010 – Most people get insufficient Vitamin D, but extra
supplements may not be needed Washington Post
Jan. 11, 2010 – N.J. lawmakers approve expanding chiropractor treatment scope NJ.com
Dec. 30, 2009 – If You Can Tell By the Label…AHPA’s Call for
Efficient Enforcement Against Illegal Steroid Products Whole Foods
Magazine
Dec. 28, 2009 – Labeling standards for caffeine L.A. Times
Dec. 17, 2009 – China succeeds in developing herbal medication to
treat A/H1N1 flu Xinhua
Dec. 17, 2009 – Universities push for better CAM training Pharmacy
News
Dec. 10, 2009 – Three Substances to Lose Place on Store Shelves New
York Times
Dec. 9. 2009 – Flu-Fighting Foods CBS News
Dec. 7, 2009 – ‘Green’ cuisine not always as ordered Washington Post
Dec. 6, 2009 – A broader definition of healthcare L.A. Times
Nov. 24, 2009 – Herbal remedies need real scrutiny CNN
Nov. 12, 2009 – Fighting illness isn’t just a one-shot deal Washington
Post
Nov. 10, 2009 – Experts: Placebo power behind many natural cures
Associated Press
Nov. 9, 2009 – In Central Oregon, a sip of South America The
Bulletin
Nov. 4, 2009 – Kellogg’s Pulls Immunity Claims From Cereal Boxes
WCCO
Nov. 3, 2009 – Home Flu Cures: Bad Medicine? The Wall Street
Journal
Nov. 3, 2009 – More insurers are paying for alternative remedies
Associated Press
Nov. 3, 2009 – Complementary and Alternative Medicine Therapies
for Cold and Flu Season: What Is the Science? Medscape
Nov. 2, 2009 – Med, nursing schools teaching alternative remedies
Associated Press
Oct. 27, 2009 – A dubious alternative Washington Post
Oct. 27, 2009 – FDA sets sights on products that purport to fight
swine flu Washington Post
Oct. 26, 2009 – Alternative Health Care Offsets Cost Woes CBS
Oct. 18, 2009 – Student’s Research: Energy Drinks are Bunk CBS
Oct. 16, 2009 – Beware of Flu Scams The Today Show
Oct. 14, 2009 – FDA chief: Regaining your trust Fortune
Oct. 14, 2009 – Chinese herbs show promise for diabetes prevention
Reuters
Oct. 14, 2009 – FDA warns P&G over vitamin C in DayQuil and
NyQuil Reuters
Oct. 13, 2009 – Green tea may curb risk of some cancers Reuters
Oct. 13, 2009 – A Vigorous Push From Federal Regulators
Washington Post
Sept. 30, 2009 – Hallucinogenic Herb Under Legislative Eye
Washington Post
Sept. 29, 2009 – Congress, Concerned About Steroids, Reviews Law
on Dietary Supplements The New York Times
Sept. 9, 2009 – Harkin accepts chairmanship of HELP Committee
The Hill 
Calendar of Botanical Events
 March 21-25: 239th ACS National Meeting & Exposition,
AHPA on the Road
Natural Products Expo West in Anaheim, Calif. is March
11-14. Join AHPA at its Annual Member Breakfast and
Meeting on Thursday, March 11 and at the AHPA
Member Reception on Friday, March 12. Members are
also encouraged to attend one or more of AHPA’s committee
meetings, which will be held March 11-13. For a complete
schedule of AHPA’s events, see p. TK and here:
http://www.ahpa.org/Portals/0/pdfs/10_0126_ExpoWest2010_
AHPAMeetingSchedule_Final.pdf.
Many more listings are online at www.ahpa.org.
 March 11: Food and Dietary Supplement Immunity Claims
and Enforcement, Webinar hosted by the Food and Drug Law
Institute (FDLI). Hear the relevant regulators discuss product
claims along the spectrum from immune system support, to
enhancing immunity, to strengthening the immune system,
to preventing colds and flu, and to preventing H1N1 influenza. Such claims currently appear in a wide variety products
and in diverse contexts. Dr. Robert Moore will talk about the
FDA’s joint initiative with FTC against companies marketing fraudulent anti-H1N1 influenza products and about the
agency’s approach to more general immune system and immunity claims. Richard Cleland will discuss FTC’s expanded
enforcement activities involving unsubstantiated immunity and
immune system boosting claims, including the FTC’s recent
cases against chain retailers for claims on their store brands.
Website: http://www.fdli.org/conf/webinar/immunity/?utm_
source=MagnetMail&utm_medium=email&utm_term=kfowler@
ahpa.org&utm_content=FDLI%20Prospectus,%20January%201
3,%202010&utm_campaign=fdli-2010-01-13
 March 13-25: CITES: 15th Meeting of the Conference
of Parties, Saheraton Doha Resort and Convention Center,
Doha, Qatar. CITES (the Convention on International
Trade in Endangered Species of Wild Fauna and Flora) is an
international agreement between governments. Its aim is to
ensure that international trade in specimens of wild animals
and plants does not threaten their survival. Website:
http://www.cites.org/eng/news/meetings/cop15/index.shtml
 March 16-18: GMA Science Forum: Navigating Current
Food Safety, Public Health and Lifestyle Goals, Washington, DC. Website: http://guest.cvent.com/i.aspx?1Q,P1,E54
775F9-28DA-4F8C-A99F-27D3EDCAEE65
San Francisco, CA. For further information, please contact the
symposium organizers or the AGFD program chair (Michael
Appell 309 681-6249 [email protected]).
 March 23: Symposium on Developments in Botanical
Dietary Supplements Research from 1994 to Today,
University of Illinois, College of Pharmacy, Chicago, IL. Cofunded by the National Institutes of Health Office of Dietary
Supplements, the symposium will review and discuss scientific
developments in botanical dietary supplements research and
regulation since 1994, when the Dietary Supplement Health
and Education Act was passed. Join us that evening for a
celebration honoring Botanical Center Director Norman
Farnsworth for his 50+ years of contributions to the study of
natural products and to commemorate his 80th birthday.
Website: http://www.uic.edu/pharmacy/about_the_college/news_
and_events/events/botanicalsymposium2010.php
 March 25-26: Sustainable Cosmetics Summit, New York.
Sustainable Cosmetics Summit is a new generation of international summits that focus on sustainability in the beauty
industry. F st time, a series of international summits examine
the leading issues the beauty industry faces concerning
sustainability, natural, organic, fair trade and ecological
products. Hosted at the Steigenberger Frankfurter Hof hotel
in Frankfurt, the inaugural summit focused on industry
developments, CSR & sustainability best-practices and green
formulations. Call for Papers: The conference programme for
the North America edition of the Sustainable Cosmetics
Summit is currently under development. Prospective speakers
should send an abstract of their papers, with full contact
details by completing a registration form.
Website: http://www.sustainablecosmeticssummit.com/
 March 26-28: 2010 Energy trust Better Living Show,
Portland Expo Center, Portland, OR. Live well and have fun
doing it. Earth friendly products for you, your home and
garden. From cutting edge technologies and eco chic fashion
to better energy efficiency and sustainable outdoor living,
if it’s green and it’s beautiful - it’s here at the Energy Trust
Better Living Show! And best yet, admission is free. We’ll
introduce you to businesses and groups in our region that will
help you make choices you feel good about. All presented in
an entertaining way like you’ve never seen before. If you are
looking for green products, this festival is simply too good to
miss. Sponsored by Energy Trust of Oregon.
Website: http://www.betterlivingshow.org/
 April 1: NBJ Webcast: Functional Foods & Beverages
Website: http://nutritionbusinessjournal.com/calendar/2010nutrition-business-webseminar/index.html
compounds from medicinal plants, food crops, or other natural
sources. Website: http://www.phytochemicalsociety.org/events.htm
 April 12-15: 9th Annual Oxford International Conference
 April 8-10: International Symposium: Drugs from Nature
Targeting Inflammation, University of Innsbruck, Tyrol,
Austria. A national research network for “Drugs from Nature
Targeting Inflammation (DNTI)“ was established in April
2008. The overall aim of the project is to identify and
characterize bioactive natural products which are capable
to combat or prevent inflammatory processes specifically
in the cardiovascular system. Website: http://www.uibk.
ac.at/pharmazie/pharmakognosie/dnti/
 April 8-11: AAAOM Expo 2010 - From Ancient Medicine
to New Horizons, Hyatt Regency Tamaya Resort and Spa,
Albuquerque, N.M. Expo 2010 will serve as AAAOM’s bridge
to our 2011 “Walk on Washington” to be held in conjunction
with our World Conference on Integrative Medicine, where
our profession will take the lead to define AAAOM’s role in
U.S. healthcare as an integrative medical provider in the U.S.
healthcare delivery system. As a profession, each milestone
and juncture we reach forms the platform for all activity that
follows. Join us in Albuquerque when we come together as
practitioners, students, businesses, and educators to deepen
our clinical practice skills. We will forge the unity and
involvement necessary to assure that our combined expertise
and knowledge will eloquently and strategically define our
political path forward. Website: http://www.aaaomonline.org/
 April 10-11: Southwest Conference on Botanical Medicine
in Tempe, Arizona. Join us for a sunny weekend in the
blooming desert! Keynote speaker: Rosita Arvigo of Belize.
Topics: Pelvic Decongestant Herbs; Herbal Pairing in the
Vitalist Tradition; Cardiovascular Blood Markers; Uses and
Cautions for Prescription-Only Botanicals; Ten Most Important Essential Oils with David Crow and much more. Preconference intensive on April 9: Women’s Health: Alternatives to
Statins, HPV Vaccine, Anti-depressants and Anxiolytics with
Amanda McQuade Crawford. Friday Field Studies, herb walks
at the Desert Botanical Garden, and outdoor classes in
medicinal herb preparation. CE credits for health professionals.
Information www.botanicalmedicine.org or (800) 252-0688.
 April 11-14: PSE Young Scientists Meeting: Trends in
Natural Products Research, Leicester, United Kingdom.
The aim of the conference is to discuss trends, present recent
results, and exchange ideas related to key aspects of Natural
Products Research. During the conference, ample opportunity
will be provided for PhD-students and young post-doctoral
researchers to meet internationally acknowledged researchers
in their field, and to exchange thoughts on the chemistry of
on the Science of Botanicals, Oxford Conference Center,
Oxford, Miss. The purpose of this conference is to review,
discuss, and explore the confluence of current research topics
in natural product chemistry, Pharmacognosy and botanicals. Topic areas will include such issues as authentication,
cultivation, collection, post-harvest practices for producing
quality plant material, chemical and toxicological methods
for quality/safety assessment of botanicals. Contributed
presentations, both oral and poster, are invited. Each session
will open with a plenary speaker outlining the current approaches, limitations, and research needs of the topic area.
Speakers will be leading researchers from industry, academia,
nonprofit institutions, and government. Each speaker will
address current approaches, limitations, and research needs.
Website: http://guest.cvent.com/EVENTS/Info/Summary.
aspx?i=541ae65b-b5d8-407d-891d-006296d2d8d1
 April 14-15: Policy Conference & Hill Visit Days, Hall of
the States, Washington, D.C. 2010 marks 20 years since the
passage of the Organic Foods Production Act and 10 years
since the publication of the National Organic Program’s Final
Rule. Join OTA as we celebrate these milestones and our own
25th anniversary at a very special reception in the House
Agriculture Committee Hearing Room on Capitol Hill.
Website: http://www.ota.com/advocacy/events.html
 April 18-22: 6th Conference on Aromatic and Medicinal
Plants of Southeast European Countries (6th CMAPSEEC),
Antalya, Turkey. The conference will cover the plenary lectures
by distinguished invited speakers, oral and presentations on the
topics of all aspects of medicinal and aromatic plants including
natural product chemistry, pharmacology of natural products,
plant biotechnology, cultivation, processing, and marketing
of medicinal plants, ethnobotany and ethnomedicine, and
culinary herbs. The conference venue is the Convention
Center of Hotel Kervansaray Lara.The 6th CMAPSEEC will
also be a special atmosphere to celebrate 10th anniversary of
foundation of AMAPSEEC. On this occasion, we expect
many participants from all over the world of pharmacist,
agriculturalist, biologist, chemists, etc., origins.
Website: http://www.6thcmapseec.org
 April 22-23: FDLI & FDA 53rd Annual Conference,
Hilton Washington, Washington, D.C.
Website: http://www.fdli.org/conf/#upcoming
 April 24-28: ASN Scientific Sessions and Annual Meeting,
Anaheim, California. ASN holds its Scientific Sessions and
The cutting-edge
ingredient show
Annual Meeting in conjunction with Experimental
Biology (EB) (http://experimentalbiology.org/content/default.aspx)
which is a multi-society, interdisciplinary meeting featuring
plenary and award lectures, symposia, oral and poster
sessions, career services, and exhibits of scientific equipment,
supplies, and publications. Show Website:http://www.nutrition.
org/meetings/asn-annual-meetings-at-experimental-biology/
 April 26-28: SupplySide East, Secaucus, New Jersey.
Where
InnovatIonBegins
Meet hundreds of exhibitors offering
thousands of healthy and innovative
ingredients
Learn about the latest cutting-edge
ingredient technology
Meet hundreds of exhibitors offering thousands of ingredients
at SupplySide East, April 26 to 28 at the Meadowlands
Exposition Center in Secaucus, N.J. For manufacturers,
marketers and formulators, SupplySide East offers the
opportunity to learn about the latest ingredient technology
and supporting science; find new solutions to reduce costs;
and develop your next best seller. AHPA Members save $50
on registration now through April 22. (Offer does not replace
a previously paid registration and is limited to finished-product
manufacturers.) Click this link to register as an AHPA
Member: http://www.supplysideshow.com/2010/east/register.
html?sc=AHPAw Show Website: http://www.supplysideshow.com/
 May 1: HerbDay 2010, Nationwide. HerbDay is a coordi-
Develop your next best seller
> From consumer attitudes and trends to ingredients
and formulation know-how, all the resources
for innovative product development await you.
www.supplysideshow.com
(800) 454-5760
nated series of independently produced public educational
events celebrating the importance of herbs and herbalism.
HerbDay was conceived of by five nonprofit organizations
with interests in herbs and herbalism (the HerbDay Coalition)
to raise public awareness about the significance of herbs in our
lives and the many ways herbs can be used safely and creatively
for health, beauty care, and culinary enjoyment. Greater
familiarity with herbs will increase informed use of herbal
products and build public support for maintaining personal
choice in the use of botanicals.
Website: http://www.herbday.org/index.php
 May 11-12: Food Technology, Innovation & Safety Forum
2010, Hyatt Regency O’Hare, Chicago, IL. The 4th Food
Technology, Innovation & Safety Forum 2010 brings together
leading R&D, Innovation, New Product Development (NPD),
Marketing and Food Safety and Quality Assurance professionals to discuss, innovate, knowledge-share and shape the future
of the food industry into the new decade.
http://www.thefoodsummit.com/
April 26-28, 2010 t Exhibit Hall April 27 & 28
Meadowlands Exposition Center t Secaucus, NJ
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PA 50 31! 3
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* Offer does not replace a previously paid registration,
is limited to AHPA members who are
finished-product manufacturers, and is
valid thru March 31, 2010
En
o
 May 11-13: DCAT Nutrition & Health Forum, Desert
Springs JW Marriott Resort & Spa, Palm Springs, Calif.
What are the effects of the economic, political and regulatory
environments on nutritional supplement manufacturers and
suppliers? Find out as industry experts explore these subjects
at DCAT’s Nutrition & Health Forum—the must-attend
networking and educational event for the dietary supplement
industry.
http://dcat.org/Pages/progr_ShowProgram.aspx?IDProgram=37
VF 2010 visprom ad 92x239 AHPA1:Layout 1 21/01/2010 09:16 Page 1
 May 18-20: Vitafoods, Vitafoods is the only event in the
world to concentrate exclusively on the expanding market for
nutraceuticals, cosmeceuticals, functional foods and drinks
ingredients & raw materials. An annual exhibition and
conference the show attracts over 8000 attendees, 500 exhibitors and 250 delegates and is regarded as the leading event in
the nutraceuticals industry calendar. The 2010 edition takes
place on 18-20 May 2010 at GENEVA PALEXPO, Switzerland. For more information please visit http://www.vitafoods.
eu.com/ahpa
 May 18-20: Finished Products Expo, Finished Products Expo
is Europe’s only dedicated exhibition for manufacturers and
suppliers from the dietary supplement, functional foods and
functional drinks industries. The show attracts over 150
exhibiting companies and 2500 attendees from the industry
and is co-located with Vitafoods, the global nutraceutical event.
The only meeting place for all those within this industry,
Finished Products Expo 2010 takes place on 18 - 20 May 2010
at GENEVA PALEXPO, Switzerland. For more information
please visit http://www.finishedproductsexpo.com/ahpa
 June 5- 7: Medicines from the Earth Herb Symposium,
The Global
Nutraceutical Event
18 - 20 May 2010
GENEVA PALEXPO
Switzerland
Register online for FREE at
www.vitafoods.eu.com/ahpa1
& benefit from
Fast track entry
Free event guide
Save €80
Black Mountain, NC. Annual symposium on herbal medicine
at beautiful Blue Ridge Assembly near Asheville, North
Carolina. Keynote speaker: Tieraona Low Dog, MD. Topics:
Latest Research in Women’s Health with Tori Hudson, ND;
Maintaining Healthy Levels of Testosterone and Human
Growth Hormone During the Elder Years; The Impact of
Phytoestrogens on Breast Cancer and Reproductive Disorders
and much more. Conservation of our medicinal plant
heritage discussion with Rosemary Gladstar. Herb walks in the
surrounding forest, medicine making and food preparation
demonstrations. Preconference intensive June 4 with Tieraona
Low Dog, MD. CE credits for health professionals. Information www.botanicalmedicine.org or (800) 252-0688.
 June 5-8: NACDS Marketplace, San Diego, Calif. The
NACDS Marketplace Conference is not your typical trade
show. It is a venue for retail buyers and sellers to meet one
another and work together to bring new and innovative
products to market. Where else can you have a guaranteed
meeting with buyers from top retail companies? Pair this with
the most expansive and timely selection of education programming in the industry and you have NACDS Marketplace.
Website: http://meetings.nacds.org/marketplace/2010/
 June 10-13: Food as Medicine 2010, Capital Hilton,
Join us on
Organised by IIR
Co-located with
Finished Products Expo
Washington, D.C., Food as Medicine is the most comprehensive 4 day long professional nutrition training program in the
U.S. It offers the equivalent of a semester’s worth of nutrition
curriculum. This program provides the latest in science-based
nutrition education and is designed to give graduates the
knowledge, confidence and compassion required to successfully
guide patients toward life-giving, healthy nutrition. Website:
http://www.cmbm.org/holistic_medicine_PROFESSIONAL_
TRAINING_EDUCATION/food_as_medicine_description.php
 July 10-14: 51st Annual Meeting of the American Society
of Pharmacognosy and Phytochemical Society of North
America, Chicago, Illinois. The annual meeting and exhibition
continues to be an excellent opportunity for scientists and
engineers from academia, government and industry to exchange information, share ideas, network, and advance the
science of pharmacognosy. A program committee consisting
of leaders from the industrial and academic communities has
been assembled and a first-rate scientific program consisting
of over 50 symposia has been put together covering the
following topics: Biocatalysis, Environmental Microbiology,
Fermentation & Cell Culture, Metabolic Engineering, and
Natural Products. Website: http://www.asp2010.com/
 July 17–21: Institute of Food Technologists Annual
Food Expo, Chicago, Illinois.
Website: www.ift.org; E-Mail: [email protected]
 July 20-23: NBJ Summit, St. Regis Resort, Dana Point, Calif.
The NBJ Summit is an intimate, invitation-only networking
event where top-level executives from leading companies in the
health and nutrition industry discuss strategic business issues,
market conditions, competitive challenges, and branding/
product strategies. Over the past 12 years, The NBJ Summit
has attracted key leaders and CEOs in the $100 billion dollar
health and nutrition industry. This year we will present the
latest Nutrition Business Journal market statistics with key
insights for the future of the industry and how it might impact
strategic planning in 2010, moving into 2011 and beyond.
AHPA members, contact Katia Fowler ([email protected])
for a special registration code.
Website: http://www.nbjsummit.com/nbj10/public/enter.aspx
 August 19: NBJ Webcast: U.S. Nutrition Industry Overview
Website: http://nutritionbusinessjournal.com/calendar/2010nutrition-business-webseminar/index.html
 Aug. 22-27: 28th International Horticulture Congress
(IHC), Lisbon, Portugal. Participants will find events to
suit specific interests among the 8 colloquia, 18 symposia,
14 seminars, workshops and thematic sessions.
Website: http://www.ihc2010.org.
 Aug. 30-Sept. 3: II International Symposium on the Genus
Lilium, Pescia, (Tuscany) Itlay. E-Mail: info@symplitaly2010.
com. Website: www.symplitaly2010.com.
 Sept. 12-15: ABIC 2010: Bridging Biology & Business,
Saskatoon, Canada, ABIC 2010 features a stellar line-up of
presenters in three streams: Energy, Health and Sustainability, with 66 expert speakers and four keynote presentations.
ABIC 2010 also includes a tradeshow, an international poster
competition and a public forum. A Gala and other networking
events round out the social aspects of this premier conference.
http://www.abic.ca/abic2010/
 Sept. 20-25: 11th Congress of the International Society of
Ethnopharmacology (ISE 2010), Albacete, Spain. This joint
conference will certainly be one of the most exciting and
prestigious international events in the field of medicinal plant
sciences. Spain is a fascinating country that is full of vitality,
cultural diversity and culinary delights. We trust that the
dynamic and magical spirit of the small city of Albacete
(Castilla-La Mancha) will provide a very stimulating milieu
for scientific exchange amongst ethnopharmacologists,
ethnobiologists and ethnobotanists from all over the world.
We are certain that this event will offer exciting opportunities
for exchanging the latest scientific news and for networking
with colleagues. Website: http://www.ise2010.org/
 Oct. 2-6: Mind-Body Medicine, Hyatt Regency, Crystal City,
Va., Learn the scientific basis for mind-body medicine and
experience the depth and power of our unique small group
approach. Explore and learn to use a range of the most
effective tools for self-care and stress management, including:
meditation, guided imagery, biofeedback & autogenic training,
breathing & movement, and self expression through words
and drawings.This is the Center’s core program. We have been
teaching it around the world since 1994. It has provided
thousands of professionals with the tools and experiences
needed to transform their lives and practices. Website:
http://www.cmbm.org/holistic_medicine_PROFESSIONAL_
TRAINING_EDUCATION/mind_body_medicine_description.php
 Oct. 20-22: SupplySide West, Venetian & Sands Expo,
Las Vegas. SupplySide is the world’s largest trade show and
conference for healthy and innovative ingredients. Thousands
of decision makers from the global food, beverage, dietary
supplement and cosmeceutical industries converge to learn,
network, source and create. Your next big idea is just a show
away. Website: www.supplysideshow.com
 October 21: NBJ Webcast: Consumer Research
Website: http://nutritionbusinessjournal.com/calendar/2010nutrition-business-webseminar/index.html 
If Latin
 Sept. 26-29: PSE Symposium: TERPENES Application,
Activity & Analysis, Istanbul, Turkey. The aim of this
symposium is to bring together worldwide eminent scientists
and industry involved in chemistry, biochemistry, biology,
pharmacology, biosynthesis and analysis as well as applications
of terpenes. The meeting will consist of plenary lectures, short
lectures, poster sessions and social activities to catalyse vigorous
scientific discussions at various levels and platforms.
Website: http://www.terpenist2010.org/index.html
 Sept. 29: CRN’s The Workshop, Hyatt Regency Lost Pines
Resort, Austin, Texas. The Council for Responsible Nutrition
each year brings together top scientific experts on nutrition and
dietary supplements for a full day of focused discussion in an
intimate setting. Website: http://www.crnusa.org/TheWorkshop/
 Sept. 29-Oct. 2: CRN’s The Conference, Hyatt Regency Lost
Pines Resort, Austin, Texas. Join the Council for Responsible
Nutrition for the premier event that brings together top
industry professionals for three days of the most relevant
sessions on business, legislative, regulatory and scientific
issues—and plenty of networking opportunities.
Website: http://www.crnusa.org/TheConference/
is not your
native language…
Add AHPA’s new custom dictionary
to your computer and finally trust
that you have the correct spelling
of the Latin names listed in AHPA’s
Herbs of Commerce, 2nd edition.
If you are responsible for the accuracy
of product labels, technical or
scientific writing or regulatory affairs,
then loading this file on your computer
will ensure the correct spelling
of your taxonomic terms.
For sale now,
$100, in AHPA’s online bookstore!
www.ahpa.org
Botanical Science Update
by Steven Dentali, Ph.D.
MEETING ATTENDED
USP’s Last Dietary Supplement Information
Expert Committee
Compendia or not. The current approach has been modified from
UPS’s earlier policy that attempted to mitigate safety concerns
through labeling (see http://www.usp.org/USPNF/notices/USPRevised
AdmissionCriteria.html for the current system and the previous classification that was notably similar to that employed in AHPA’s
Botanical Safety Handbook).
I attended USP’s 15th meeting of their 2005-2010 Dietary
Supplements Information Expert Committee meeting on March 1,
2010 as an invited guest. This was the last meeting of that committee for the 2005-2010 cycle and included safety reviews of gotu
kola, forskohlii, bacopa, maca, and melatonin. I have reported on
USP’s herb safety review work in the past including their recommended labeling for black cohosh root and green tea extract, which
AHPA commented on (see AHPA’s January 11, 2008 update).
Through the process of conducting safety reviews of botanical materials during the meeting it became clear that the form of the material and the dosage must be considered. This requires a departure
from USP’s usual monograph approach because USP monographs
specify quality parameters, not dosage information. Not all forms of
all the materials considered at the meeting were approved and further information was requested on some extracts in order to know
exactly what the material is and how it compares to crude herb and
associated safety data.
Because information regarding what needs to be on a drug product
label is determined by FDA, USP doesn’t have to decide either if a
USP drug monograph should be written or not or what should be
on a product label. The situation is different for supplements as
USP relies on the Dietary Supplement Information Committee to
make the determination if an article should be included in the
During this meeting USP also revisited their labeling requirements
for herbs which currently reads as follows, “(t)he label of an herb or
other botanical intended for use as a dietary supplement bears the
statement, “If you are pregnant or nursing a baby, seek the advice of
a health care professional before using this product.”” Earlier committee discussions led the committee to realize that this approach
What’s In a Name?
Herbs of Commerce, 2nd Edition
by Michael McGuffin, John Kartesz,
Albert Leung and Arthur Tucker
This revised edition, published in 2000, lists 2,048 separate species, including 25 fungi and 23 seaweeds, by their Standardized Common Names
and Latin binomials, and includes Indian Ayurvedic names for more than
300 plants and Chinese (pinyin) names for 500 herbs. Also, 639 botanical synonyms are included; older botanical names no longer accepted
can be cross-referenced. AHPA published the first edition in 1992 to
reduce confusion by establishing “standardized” common names. It
was recognized and codified when FDA adopted the original edition
in 1997: the common names may be used instead of Latin binomials
to identify herbal ingredients in dietary supplements.
Special Member Price: $79.99
U
Non-Member Price: $99.00
To order, call: 301-588-1171 or buy online at: http://www.ahpa.org/bookstore.htm
was not appropriate for all materials but to conclude that in the absence of data indicating safety during pregnancy or nursing a cautionary approach to materials was preferred over no statement at all.
The consensus arrived at was to follow essentially the Canadian
model where sufficient evidence of safety during pregnancy and
nursing for a particular material could result in the removal of the
general labeling requirement. Consequently the committee agreed
to revise the existing statement by prefacing it with “(u)nless specified in the individual monograph…” and to extend the labeling requirement to all supplement ingredients, not just herbs. The
committee also began the process of examining safety data for materials that could reasonably be excluded from this blanket statement
such as possibly cranberry, ginger, and flax seed oil.
Next the committee was read part of the legacy document from the
Dietary Supplements General Chapters Committee that expressed
the belief that the change for the next 5-year cycle to a single dietary
supplement expert committee would not be sufficient to adequately
address specific botanical needs and that a botanical committee
structure on the level of an expert committee would be needed.
Finally it was recognized that the Dietary Supplement Information
Expert Committee functions very well as a group. I hope that USP
is able to maintain the integrity of that group though it may be relegated to an advisory panel position. 
Monday evening’s keynote speaker presenting on the topic of defining efficacy for Natural Health Products in Canada.
Tuesday morning is scheduled to open with presentations from
Norman Farnsworth PhD of the University of Illinois at Chicago,
and the Deputy Director of the National Center for Complementary
and Alternative Medicine (NCCAM), Jack Killen MD, who will be
speaking on the current and future directions of CAM research at
NCCAM. Rainer Bussman PhD of the Missouri Botanical Garden
will be speaking on medicinal plant use in Northern Peru including
markets, vendors, healers, collectors and modern applications, and
Alan Crozier PhD from the University of Glasgow will be discussing
the role of plant bioactive compounds in the human diet.
Concurrent sessions of the conference include pharmacology, quality assessment, regulatory aspects, and pharmacognosy, with global
perspectives to conclude on Thursday afternoon. This conference
affords attendees the opportunity to rub elbows with national and
international regulators, researchers, and industry representatives.
In my view it should be a touchstone conference for the US dietary
supplement industry because it offers so much. Do attend if you can.
Further information is available at http://www.oxfordicsb.org/. 
This space could be yours
UPCOMMING MEETINGS
Developments in Botanical Dietary Supplements
Research from 1994 to Today
ADVERTISE
IN THE AHPA REPORT
This unique conference and dinner is part overview of the accomplishments of botanical dietary supplement research since the
passage of DSHEA and part honoring the University of Illinois at
Chicago Botanical Center Director Norman Farnsworth for his over
50 years of contributions in the natural products field and to commemorate his 80th birthday. Conference sessions will include regulation and funding, product integrity and defining quality, mechanistic
studies, and generating clinical evidence with a stellar complement
of presenters.
The conference and dinner will take place Tuesday, March 23 at the
Holiday Inn Chicago Mart Plaza. Further information is available at
http://www.uic.edu/pharmacy/about_the_college/news_and_events/
events/botanicalsymposium2010.php.
9th Annual Oxford International Conference
on the Science of Botanicals
This excellent conference and phenomenal networking opportunity
will again be taking place April 12-15 in Oxford, Mississippi. The
program will begin Monday with a symposium on Indian Ayurvedic
systems of medicine. Health Canada’s Director General of the
Natural Health Products Directorate, Michelle Boudreau, will be
easy
cost effective
targeted audience
NonMembers Members
Half Page
$200
$300
Quarter Page
$100
$150
contact: [email protected]

here

Transcription

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