AHPA is managing the revision process via an understanding with GNC. Unlike some other industry efforts in recent years to coordinate practices which have undergone a rather desultory revision step as busy executives devote time where and when they’re able, the GNC/AHPA document is in an active phase, propelled by the fire that was kindled under the industry by the actions of New York Attorney General Eric Schneiderman.
“It is a very active process for us. We already have drafts in circulation, but I’d be loathe to predict a date when it will be finished. We were at first aiming for the first of the year,” AHPA president Michael McGuffin told NutraIngredients-USA.
The GNC proposal included much work that had already been done by AHPA as part of its seed-to-shelf best practices effort. McGuffin gave an overview of that strategy recently as part of a panel at the American Conference Institute's (ACI's) fourth annual Legal, Regulatory, and Compliance Forum on Dietary Supplements in New York City.
“The event had as a broad scope efforts by supplement industry to promote transparency and integrity in the face of public and private scrutiny. CRN presented the work they have done on their products database, and at AHPA we took on the raw botanical GMP portion of it,” he said.
McGuffin’s presentation included a portion on GACP, or Good Agricultural and Collection Practice. This recognizes that many botanicals that end up as dietary ingredients come from cultivated fields, while a significant proportion of herbs are still wildcrafted.
“Most of our botanicals are cultivated and we recognized the need to treat those with an agricultural set of guidelines,” McGuffin said. These include the choice of propagation material, site selection (especially important for some finicky botanicals that in the wild occupy very specific habitats), fertilization and irrigation. On the collection side of the coin, McGuffin focused on facets of proper identification, collection equipment, sustainability and timing of harvest. Once the botanical material is in the house, so to speak, the process becomes clearer, McGuffin said.
“From that point on you go back to general good manufacturing practices,” he said.
Even so, McGuffin said it’s important to keep in mind the highly variegated nature of the supply of raw botanical ingredients. Some companies are consolidators, getting material from brokers who are dealing with many suppliers operating on a micro scale. As such, these companies might function as mere holding operations. Other perform more manufacturing steps that could include steam sterilization, cutting and powdering, while still others go the full nine yards toward providing finished extracts. Sitting above these are branded ingredient suppliers, that have standardized extracts backed by research data. These products often featuring unique delivery technologies backed by patents. It’s a challenge, McGuffin said, to bring together a botanical supply GMP structure that can address all of these disparate parts.
“I think it’s important to recognize the leadership GNC took on this,” he said. “They had already started on [the revision process]. They have a lot of reach and they already knew a lot of these vendors.”
Room for demand to grow
McGuffin said that leadership could be helpful in building up the demand for ingredients produced in accordance with these standards. The program is only as good as the amount of buy-in it generates within the industry.
“We certainly aren’t doing this just for the exercise,” McGuffin said. “We can do all this work and then it will only be valuable if the manufacturers demand it. If someone says that first and foremost they need a cheap material, then it won’t work.
“The longer term outcome we would hope for is that over time the companies selling poor quality material will start to see their businesses fail,” he said.