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Monday, September 06, 2010

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Detailed Bookstore Descriptions

Please browse the variety of publications that are offered on botanical science, botanical manufacturing, general botanical information and the regulation of herbal supplements.

AHPA EDUCATIONAL COURSE MATERIALS, GUIDANCE and REFERENCE BOOKS



 

   

AMERICAN BOTANICAL COUNCIL REFERENCE BOOKS

 

AHPA Educational Course Materials, Guidance and Reference Books

Herbal Cleanliness

Manufacturers are caught between pending federal Good Manufacturing Practices, California’s Proposition 65, the need to produce clean and safe products, and keeping costs in check. Even organic raw materials face issues of microbial loads and heavy metal uptake from the soil. Each company must weigh its unique quality standards and liability risk against the cost of implementing a program to ensure herbal cleanliness. Instituting an appropriate process can be a practical approach to protect your company. Not only should your system demonstrate a record of quality and safety, but a smooth and effective system also helps provide good customer service. This AHPA educational course will help you establish a process to fit your company’s needs, focusing on these topics:

  • pending Good Manufacturing Practices purity specifications
  • California’s Prop 65 and heavy metals
  • the impact of quality and safety on industry credibility
  • cleanliness standards
  • pragmatic program implementation

Take advantage of the expertise of these speakers:

  • Angie Brackhahn and Kevin Ernst, both of Trout Lake Farm
  • Josef Brinckmann and Katie Huggins, both of Traditional Medicinals
  • Steven Dentali and Michael McGuffin, both of AHPA
  • Loren Israelsen, of the United Natural Products Association
  • Nancy Linde, of The Toxicology Group of NSF International
  • Trenton Norris, Esq, of Bingham McCutchen, and Anthony Young, Esq, of Kleinfeld, Kaplan and Becker

Materials in this packet include:

  • A critical-point process flowchart to help identify risk issues and intervention points
  • Tables of Recommended Maximum Microbial Limits, both those presented at the event (2004) and an updated version (2006)
  • A detailed document, Background on California Proposition 65: Issues Related to Heavy Metals and Herbal Products, produced by AHPA and updated for this educational event
  • Course Outline, Speaker Bios
  • Transcripts from the two duplicate sessions, and answers to questions posed by attendees
  • Audio CD

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How to Conduct an FDA Inspection

It’s inescapable: the FDA inspector on your doorstep with the clipboard, the forms, the questions. This AHPA tele-seminar provides expert guidance to help you understand your rights and obligations when the FDA inspects a facility where dietary supplements or ingredients are manufactured, processed, packed, or held. Course materials include AHPA's Guidance for Addressing FDA Inspections of Dietary Supplement Facilities, an invaluable resource to have before the FDA inspector arrives.

This course is based on FDA’s rules for inspecting conventional foods, and is therefore relevant to most companies in the dietary supplement industry, and provides:

  • An overview of FDA’s inspection authority, which derives from both the Federal Food, Drug and Cosmetic Act and the Bioterrorism Act
  • Suggestions on the steps that a firm should take in advance to be prepared for an FDA inspection
  • Guidance on what should be expected during an inspection by FDA personnel
  • Observational findings that follow an inspection and the need to maintain a thorough internal record of each inspection

Federal laws and regulations are amended from time to time, so it is vital to be aware of any such amendments, and to understand the current status of all relevant rules. This tele-seminar is a supplementary guide to the law and regulations.

Take advantage of the expertise of these speakers:

  • Staci Eisner, regulatory affairs, quality assurance, research and development, and facility design for ExtractsPlus/PlusPharma, Quality and Regulatory Affairs Manager, Botanica Bioscience
  • Jim Prochnow, Esq, Greenberg Traurig, Adjunct Professor of Law at the University of Denver Law School
  • Steven Shapiro, Esq, Ullman, Shapiro & Ullman, LLP
  • Robert Ullman, Esq, Ullman, Shapiro & Ullman, LLP
  • Anthony L. Young, Esq, Kleinfeld, Kaplan and Becker, LLP
  • Mary Beth Watkins, BS, MS, Director of Quality and Compliance for Botanical Laboratories, Inc.

Materials in this packet include:

  • AHPA's Guidance for Addressing FDA Inspections of Dietary Supplement Facilities, a 42-page document containing four sections, presented in question and answer formats, and two appendices:
    • Part 1 is an overview of FDA’s inspection authority, which derives from both the Federal Food, Drug and Cosmetic Act and the Bioterrorism Act.
    • Part 2 is the shortest but perhaps most essential section of this Guidance, as it provides suggestions on the steps that a firm should take in advance to be prepared for an FDA inspection.
    • Part 3 provides guidance on what should be expected during an inspection by FDA personnel.
    • Part 4 discusses the observational findings that follow an inspection and the need to maintain a thorough internal record of each inspection.
    • Appendix 1 is a template for establishing a written standard operating procedure for FDA inspections. This template incorporates much of the information contained in the main section of this Guidance.
    • Appendix 2 provides the actual relevant text of the Federal Food, Drug and Cosmetic Act and the Bioterrorism Act upon which FDA’s inspection authority is based.
  • A template for establishing a written standard operating procedure for FDA inspections. This template incorporates much of the information contained in the main section of the Guidance
  • Course Outline, Speaker Bios
  • Transcripts to the two duplicate sessions, and answers to questions posed by attendees
  • Audio CD

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Federal Food Allergen Labeling & Consumer Protection Act

This AHPA educational session addresses how to ensure that you comply with the requirements of the Food Allergen Labeling and Consumer Protection Act of 2004. Any food (including dietary supplements) that contains a major food allergen must meet the disclosure requirements of the new law when labeled on or after January 1, 2006. A panel with legal, regulatory, and scientific expertise focus on these issues:

  • The origin and rationale of the new law
  • Compliance deadlines
  • The major food allergens required to be labeled
  • The petition and notification process for exemption from food allergen labeling requirements
  • Proper labeling of major food allergens present in dietary supplements

What you’ll learn from these experts:

  • Anthony Young, Esq, of Kleinfeld, Kaplan and Becker, LLP, & AHPA’s Legal Council — discusses the law, its history and the significance of compliance from a legal and regulatory perspective
  • Robert S. Donofrio, MS, Director of the microbiology and molecular biology laboratory, NSF International — outlines various testing methods for the allergens listed in the law, and advises how to set up testing and compliance program within your company
  • Mary Hardy, MD, Member of the Human Nutrition Division at the UCLA-based David Geffen School of Medicine, and Medical Director of Cedars-Sinai Integrative Medicine Program — with her extensive training in botanical and western medicines, she gives a clinical perspective on the risks of food allergens and the risk of non-compliance
  • Rhonda Kane, MS, RD, Consumer Safety Officer with the FDA — reviews "FDA’s Q & A on the Food Allergen Labeling and Consumer Protection Act", which she co-authored
  • Robert J. Moore, PhD, Team Leader for Compliance and Enforcement in the Division of Dietary Supplement Programs, Office of Nutritional Products, Labeling and Dietary Supplements, FDA — answers questions about compliance and FDA enforcement of the new law

Materials in this packet include:

  • Text of the Food Allergen Labeling and Consumer Protection Act of 2004, and related FDA guidance 
  • 10-page NSF International template: Dietary Supplements In-Plant Audit Checklist
  • List of Allergen Test Kits, arranged by major allergen groups, that includes details on detection limits, equipment requirements, cost and time requirements
  • Bibliography of key articles on food allergen research and findings
  • Course Outline, Speakers’ Presentations & Bios
  • Transcript, and answers to questions posed by attendees
  • Audio CD

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Claims Substantiation:
How to Ensure Your Dietary Product Claims are Truthful and Legal

Avoid government fines and sanctions by ensuring your product claims are truthful, legal and fully documented. AHPA gives you the tools you need by providing the experience and insights from this outstanding panel of experts and a wealth of resource documents that include an SOP document, letter template, guidance documents, and bibliography of selected sources of traditional use evidence according to these systems of traditional herbal medicine:

  • Ayurveda
  • Traditional Chinese Medicine
  • Unani
  • Tibetan Buddhist
  • Western Europe (German)
  • Western Europe (Australia, Canada, UK, and the US)

What you’ll learn from these experts:

  • Anthony Young, Esq, of Kleinfeld, Kaplan & Becker LLP, and AHPA’s General Counsel — explains today’s regulatory environment and the risks and liabilities marketers face if claims are not supported adequately
  • Richard Cleland, Esq, Assistant Director, US Federal Trade Commission Division of Advertising Practices — provides FTC’s perspective, recent enforcement actions, and the level of substantiation that the respondents in those actions possessed or did not possess
  • David Mark, PhD, President, DMark Consulting LLC — discusses general claim substantiation, including what kind and how much support is needed, who should review the evidence, advertising implications, and more
  • Josef A. Brinckmann, Vice-president of Research and Development, Traditional Medicinals — focuses on substantiation of traditional use claims, including guidance on what a substantiation file should contain and how it should be structured, guidance from domestic and foreign government agencies, reliable resources

Materials in this packet include:

  • AHPA resource document: Outline for Issues to Address in Creating a ‘Standard Operating Procedure’ for Making Dietary Supplement Structure Function Claims with Appropriate Substantiation Files, and an example of a Structure/Function Filing Letter
  • Bibliography of internationally recognized and respected substantiation resource documents for traditional herbal medicine as practiced in a variety of cultures
  • FTC’s Dietary Supplements: An Advertising Guide for Industry
  • FDA’s Draft Guidance for Industry: Substantiation for Dietary Supplement Claims
  • FDA’s Fact Sheet on FDA’s Draft Guidance for Industry: Substantiation for Dietary Supplement Claims
  • AHPA’s Comments on FDA’s Draft Guidance for Industry: Substantiation for Dietary Supplements
  • Course Outline, Speakers’ Presentations & Bios
  • Transcript, and answers to questions posed by attendees
  • Audio CD

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Navigating FDA’s New Dietary Ingredient (NDI) Notification Requirements

If your products include ingredients that came on the market after DSHEA was passed in 1994, you may have a serious problem. All herbal and dietary supplement companies must understand FDA’s NDI notification requirement so you may ensure that the ingredients in your products are lawful and not NDIs that have never been filed with FDA. Further, the success rate for those who do file these "75-day notices" is very low, often due to fundamental mistakes made when preparing notifications.

AHPA has committed to becoming the supplement industry’s expert on NDIs, and you benefit from that expertise. Analyzing NDI submissions and FDA responses has led to the AHPA NDI Database, which cuts through the confusion of the FDA dockets. And AHPA has now published 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

What you’ll learn from these experts:

  • Anthony Young, Esq, of Kleinfeld, Kaplan & Becker LLP, and AHPA’s General Counsel — defines an NDI and outlines what’s at stake for your company in today’s regulatory climate, what "filing without comment" means, the meaning of a negative response from FDA, and more
  • Marc S. Ullman, Esq, of Ullman, Shapiro and Ullman — provides insight into the FDA NDI review process and describes common mistakes by submitters, how FDA seems to try not to approve NDIs, and FDA limitations on NDIs, even those that are filed "without comment"
  • James T. Heimbach, PhD, FACN, President of JHeimbach Food and Nutrition Consulting — discusses the types of safety substantiation that FDA has found to be adequate to allow an NDI notification to be accepted without FDA comment
  • Michael McGuffin, AHPA President — describes the AHPA NDI Database, which provides detailed analysis of NDI notifications as well as links to all of the FDA files containing those notifications

In this packet, materials include:

  • AHPA’s Interim Guidance for New Dietary Ingredient Notifications for Manufacturers of Distributors of New Dietary Ingredients
  • Food and Drug Law Journal article reprint by McGuffin and Young, Premarket Notifications of New Dietary Ingredients: A Ten-Year Review
  • Course Outline & Speakers Bios
  • Transcript, including a link to an online Macromedia Flash tour and demonstration of AHPA’s NDI Database, and answers to questions posed by attendees
  • Audio CD

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Introduction to cGMPs: Strategies for Compliance

This course is designed for companies that want to evaluate current GMP systems already in place or initiate a new system as you prepare for new demands expected to be in FDA’s final rule on dietary supplement Good Manufacturing Practices. Specific topics include:

  • Organizing and defining your company’s departments
  • Staff job descriptions and training
  • Necessary documentation, recordkeeping and SOPs
  • Establishing and documenting staff safety training

What you’ll learn from these experts:

  • Michael McGuffin, AHPA President — reviews FDA’s proposed dietary supplement cGMP regulations, compares them against current food GMP rules and industry’s proposed dietary supplement GMP rules
  • Carl Reynolds, Senior Consultant with ASC/Kendle Regulatory Affairs and former Director of CFSAN’s Field Programs Office — outlines company segments and their responsibilities, documentation and records, variances and deviations, stability issues, inspection management
  • Mary Beth Watkins, BS, MS, Director of Quality and Compliance for Botanical Laboratories, Inc. — explains documentation requirements (policies, SOPs, control systems and review) records (batch, packaging), log books

Materials in this packet include:

  • Sample documents and forms — SOPs, document draft logs, distribution logs, revision logs, master batch records
  • Documents that provide detailed analyses of FDA’s proposed cGMP rules
  • Course Outline, Speakers’ Presentations & Bios
  • Transcript, including answers to questions posed by attendees
  • Audio CD

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cGMP Compliance: Botanical Identity & Herb Quality

As ever, AHPA provides useful information that can be put to immediate use, as well as practical advice from experienced professionals who describe both basic and advanced tools that are effective to meet your needs when it comes to:

  • Cleanliness — including adulteration, pesticides and herbicides, and heavy metal testing
  • Identification — providing reference resources and offering guidance on establishing specifications, macro- and microscopic examination and more
  • Testing — from inspection and sampling to various analytical methods and approving or rejecting materials;
  • Practical examples and solutions.

What you’ll learn from these experts:

  • Lynda Hammons, Vice-present of Quality and Regulatory Affairs at Nature’s Sunshine Products — gives practical advice on setting and using standards, how to set ingredient specifications and select vendors, and shares a practical Raw Materials Testing Criteria Flow Chart
  • Sidney Sudberg, DC, LAc, RH (AHG), Director of Alkemists Pharmaceuticals, Inc. — explains Good Laboratory Practice, quality control, various analytical techniques for ingredient characterization and standardization, and case studies.
  • Roy Upton, RH (AHG), Executive Director of the American Herbal Pharmacopoeia, Vice-president of the American Herbalists Guild — reviews the legal requirements and expectations, and details physical tests (macroscopic characterization, microscopy), chemical tests (HPTLC, HPLC, FTIR, NIR), methods validation, documentation, sampling

Materials in this packet include:

  • A practical Raw Materials Testing Criteria Flow Chart
  • Course Outline, Speakers’ Presentations & Bios
  • Transcript, including answers to questions posed by attendees
  • Audio CD

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cGMP Compliance: The Quality Unit

Providing the expertise that only comes through experience, AHPA presents an outstanding panel of speakers in this GMP Compliance Tele-Seminar on the Quality Unit. This course addresses the critical requirement to have an independent quality group within your company, its responsibilities and authority, and how to manage quality for product excellence, consumer safety, compliance, company liability and practical cost considerations. The Quality Unit touches on nearly all the manufacturing processes, from setting ingredient standards to ensuring they are met, qualifying third-party testing labs, packaging components and labeling, and finished product quality.

What you’ll learn from these experts to set up your company’s Quality unit efficiently and economically:

  • Warren Majerus, MS, Quality Systems Implementation, Inc., President — With nearly 30 years of experience in product development and Quality Control in food and supplement processing and analytical methods, Mr. Majerus is experienced in DSHEA- and CFR 110-based compliance auditing worldwide. He focuses on Auditor/Manufacturer/QC considerations, which include your Quality Unit’s scope of responsibility and authority, how to establish written specifications for materials and processes, and those specifications’ purpose and basis.
  • Daniel Stephens, MBA, Herb Pharm, Quality Control & Laboratory Services Manager — Involved in quality control and food safety compliance for nearly 30 years, Mr. Stephens has instituted and managed HACCP and ISO systems and audited quality assurance methods for production facilities, retail stores, storage sites and distribution centers. He shares his insights on industry/practical Considerations that the Quality Unit must address, including packaging components, raw materials, labeling, third party testing lab qualification, and finished products.
  • Anthony Young, Esq, General Counsel, American Herbal Products Association, partner with the law firm Kleinfeld, Kaplan and Becker, LLP — Practicing food, drug and environmental law since 1974, Mr. Young advises and represents domestic and foreign manufacturers with respect to compliance and defense of matters under the statutes enforced by the FDA, FTC, DEA, EPA, and more. He discusses the importance of the Quality Unit and legal liabilities.

If you haven’t started down this road, these speakers will provide solutions. And if your company already has a Quality Unit in place, these AHPA materials will help you identify new efficiencies or areas that need more resources.

Materials include:

  • The proposed cGMP regulation that clearly outlines the Quality Unit requirements
  • Presentations by Warren Majerus and Dan Stephens, with several supporting documents for each
  • Transcript, including answers to questions posed by attendees
  • Course Outline & Speakers Bios
  • Audio CD

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Adverse Event Reporting: How to Comply with the New Law

Preparing for new federal requirements to report serious adverse events to FDA is not a difficult task — not when you have access to the right experts to show you how to handle such calls. AHPA provides that expertise and the tools you need to comply with the new AER law. Develop a formal and pragmatic adverse event reporting system based on practical, “step-by-step” advice and useful documents from a panel of legal, business and medical experts who know every detail of taking AERs and the new AER law. In addition to learning how to complete FDA’s mandatory MedWatch form by asking callers the right questions in the right way, you’ll be able to distinguish between a quality issue complaint and an AER, and between a serious and non-serious adverse event.

 

What you’ll learn from these experts to set up your company’s AER system efficiently and economically:

  • Tony Young, Esq. — general counsel to the American Herbal Products Association and the Pharmaceutical Distributors Association, partner with the law firm Kleinfeld, Kaplan and Becker, LLP. He has practiced food, drug and environmental law since 1974, representing ingredient and product manufacturers, developers and distributors. In 2004, Mr. Young testified about mandatory AER reporting before a U.S. Senate subcommittee, focusing on the scenario that the new law, the Dietary Supplement and Nonprescription Drug Consumer Protection Act, will put into place when it goes into effect in December 2007. In this course, he explains companies’ legal obligations, including the practicalities of submitting AERs, recordkeeping requirements, and more.
  • Michael McGuffin — president of AHPA, Mr. McGuffin led the supplement industry toward recognizing the need for mandatory AERs, and was deeply involved in ensuring that the new law provide the same protections that the pharmaceutical and medical device industries have had in their respective AER systems. Active in the supplement industry since 1975, having owned both retail and manufacturing businesses, he has been AHPA’s president since 1999. He reviews the MedWatch forms, explains how to handle customer AER calls, and offers a step-by-step guide to creating a complete record.
  • Paula Gardiner, MD, MPH — research fellow at the Division for Research and Education in complementary and Integrative medical therapies at Harvard Medical School’s Osher Institute, Dr. Gardiner’s work focuses on dietary supplement safety issues, including interactions with prescription medicines. She is also a member of the U.S. Pharmacopeia’s Dietary Supplements Expert Committee, where she has worked to improve adverse event reporting. In this course, she focuses on how to gather important medical details, including medical history, concurrent use of other medical products, and other relevant information.

 

Materials include:

  • “AER vs. Customer Complaint” — a decision-making flow chart 
  • AHPA’s AER MedWatch Worksheet — AHPA’s instructive form for recording information concerning an adverse event associated with dietary supplement product use
  • Presentations from all speakers
  • Written transcript, including answers to questions posed by attendees
  • Course Outline & Speakers Bios
  • Audio CD


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Good Manufacturing Practice: The Final Rule

The new Good Manufacturing Practice (cGMP) regulations for dietary supplements run to more than 200 pages of fine print in the Federal Register, 800-plus pages in the pre-pub version. Understanding the cGMPs will be easier with insight and advice from this AHPA cGMP tele-seminar. Industry and legal experts and the head of the Food and Drug Administration (FDA) dietary supplement program that wrote the new regulations. Among the educational course materials is AHPA’s Annotated Final Rule on Dietary Supplement cGMP, which presents key points and comments made by FDA in the rule’s preamble next to the relevant sections. The preamble, or introduction to the rule by FDA, runs to 192 pages, while the final rule itself is only 17 pages, and provides details that are critical to understanding how to comply.

 

“I really believe that anyone in the dietary supplement industry should read the whole preamble as it provides context and explains the logic behind the rule,” said Vasilios H. Frankos, MS, PhD, director of Division of Dietary Supplement Programs in the FDA's Center for Food Safety and Applied Nutrition “AHPA’s annotated version provides a good synopsis of the preamble and makes understanding the rule much easier.”


Speakers:

  • Vasilios H. Frankos, MS, PhD, director of Division of Dietary Supplement Programs in the FDA's Center for Food Safety and Applied Nutrition — responsible for the full implementation of the DSHEA Act of 1994, Dr. Frankos directs and coordinates policy and administrative activities within the Division. Dr. Frankos advises on policy and management issues on dietary supplement programs, new dietary ingredient safety assessments, good manufacturing practice, adverse reaction monitoring, and related activities pertaining to dietary supplements.
  • Marc Ullman, Esq, partner with the law firm of Ullman, Shapiro & Ullman — specializing in food, drug, and cosmetic law, he also provides legal services to his clients in many other areas, including litigation support and trademark/copyright matters. Mr. Ullman’s practice includes representation relating to FDA compliance — including labels, labeling, claims, good manufacturing practices, and adversarial proceedings relating to the scope of the agency’s powers under DSHEA.
  • Michael McGuffin, president of the American Herbal Products Association — Active in the supplement industry since 1975, having owned both retail and manufacturing businesses, Mr. McGuffin has been AHPA’s president since 1999. He has represented the herbal industry at state and federal hearings on herbal regulatory issues and as a member of various FDA’s Food Advisory Committee Working Group on Good Manufacturing Practices for Dietary Supplements, and the Dietary Supplements Subcommittee of the FDA’s Food Advisory Committee.
  • Event Facilitator: Tony Young, Esq, partner with the law firm of Kleinfeld, Kaplan & Becker

 

Materials include:

  • AHPA’s Annotated Final Rule on Dietary Supplement cGMP
  • Copies of the cGMP rules as published in 2003 and 2007
  • Comparison of current good manufacturing practice regulations
  • Presentations from all speakers
  • Written transcript, including answers to questions posed by attendees that were not addressed during the event for lack of time
  • Course Outline & Speakers Bios
  • Audio CD


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Structure/Function Claims: Crafting Smart and Lawful Marketing Info and Labels

If you’ve ever wondered, what more can you say about your products? If you’ve ever asked, “How can the competition make that claim?” If you want to know how to increase sales by improving the quality and scope of your structure/function claims, and need to know the media standards for allowable marketing literature at trade shows and in publications. Learn the answers to these questions and more from this educational course that brings you business and legal information, expert presenters, and insight from the FDA official who heads the review team for such claims and who is involved with enforcement actions on unlawful claims.

Speakers:

  • Robert Moore, PhD, of FDA’s Regulations Implementation Team — describes FDA’s process for reviewing structure/function claims — including language that pushes the agency’s hot buttons and the level of substantiation expected to support those claims — the agency’s enforcement actions on claims that are not lawful for dietary supplements, how companies should respond properly to FDA Warning letters or Courtesy letters. He also discusses resubmitting claim notifications and disputing the FDA regarding lack of substantiation.
  • Anthony Young, Esq, of Kleinfeld, Kaplan & Becker LLP, and AHPA’s General Counsel — reviews the three federal laws that affect dietary supplement claims and the types of allowable product claims, outline the process of substantiating structure/function claims and how the 30 day notification to FDA provision for such claims works. He also details the regulatory reach of the FDA and FTC — the federal agencies that enforce the laws on product claims — with respect to your product labeling, third-party literature and your company website. Mr. Young has more than three decades of experience in this arena. 
  • Jon Benninger, of Virgo Publishing; Don McLemore and Michelle Kelly, both of New Hope Natural Media — representing two of the industry's major convention organizers and media outlets, these three speakers describe their respective companies’ standards for claims appearing in print advertisements and trade show collateral materials, including their review and enforcement processes and examples of non-conforming advertising.
  • Leslie A. Beyer, MS, DABT, Senior Environmental Health Scientist with Gradient Corporation — focuses on developing claims in a competitive world and the level of evidence that is sufficient for substantiation, and how to use information from traditional use, scientific research, and whether specific research information can be used broadly to support a category of products. A senior project manager and toxicologist with 20+ years of experience, Ms. Beyer’s projects have covered a variety of topics including structure/function claims for dietary supplements.


Materials include:

  • Descriptions of Databases and Information Sources: Structure-Function Claim Substantiation
  • Guidance for Industry: Structure/Function Claims, Small Entity Compliance Guide
  • Guidance for Industry: Substantiation for Dietary Supplement Claims Made under Section 403(r)(6) of the Federal Food, Drug, and Cosmetic Act
  • Substantiation for Dietary Supplement Claims Made Under the Federal Food, Drug, and Cosmetic Act
  • Presentations from all speakers
  • Course Outline & Speakers Bios
  • Written transcript, including answers to questions submitted by industry
  • Audio CD


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Adverse Event Reporting: Strategies for Compliance

The Dietary Supplement and Nonprescription Drug Consumer Protection Act requires that serious adverse event reports be sent to the FDA so that any public safety concerns can be identified and dealt with quickly. Learn how to navigate this new process with insights from these experts:

  • Anthony Young, Esq, of Kleinfeld, Kaplan & Becker LLP, and AHPA’s General Counsel — reviews your legal obligations under the new law, the Dietary Supplement and Nonprescription Drug Consumer Protection Act. In addition to reviewing FDA’s guidance document, he will also describe how the law differentiates a serious AER from an AER and a customer complaint and explain required reports and recordkeeping requirements.
  • Michael McGuffin, AHPA’s President — focuses on how companies should communicate with their customers and how to use the current MedWatch form.  He will also discuss the information needed to create a complete record of each report and add his insights into the FDA guidance.
  • Tieraona Low Dog, MD, Director of Education for the Program in Integrative Medicine at the University of Arizona, Clinical Assistant Professor in the Department of Medicine and a Clinical Lecturer for the University of Arizona College of Pharmacy —explains important considerations when recording adverse event history, including how to focus on the clinical course of the reported event, medical history, recording concomitant use of other medical products and other relevant medical information.

Questions they answer include:

  • How do we communicate AER information to our contracted manufacturer? Who should take those calls? Who should follow up afterwards?
  • Can we handle this task in-house, or do we need to contract someone?
  • Which MedWatch form should we use? None of them are really for dietary supplement or OTC products.
  • We don’t have doctors on staff, so how (and who) decides if an AER is serious?
  • How much should we follow-up after an adverse event is reported? 
  • Do we have to show our AER files to FDA during inspections? 
  • How can we get accurate information, and how much of their medical history is important?
  • What should we tell our health food store and practitioner clients? 

Support documents to help your company comply with the law include:

  • “AER vs. Customer Complaint” — a decision-making flow chart
  • Mandatory MedWatch form and facsimile MedWatch form
  • “Quick Glance Advice about Mandatory Reporting”
  • AHPA’s instructive form for recording information concerning an adverse event associated with dietary supplement product use

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Debriefing the FDA’s cGMP Implementation Seminar

Perhaps the only thing worse than waiting so long for good manufacturing practice (GMP) regs for dietary supplements is the conflicting interpretations and confusion of the recently published regs themselves. The FDA held a multi-media discussion of the new GMPs, and in this course AHPA translates their statements and dispels any confusion from the FDA overview.

AHPA understands that the cGMPs will affect your business in many ways, and that some of these regulations are complicated. To ensure you have the knowledge and tools to comply, AHPA offers its expertise to answer specific questions. In order to comply and stay in business, learn from AHPA President Michael McGuffin and AHPA’s general counsel, Tony Young, Esq.

  • Both have closely scrutinized the GMPs throughout their development, understanding their practical applications and legal details and providing comments on behalf of industry to shape their final form.
  • Both have also participated in AHPA’s ongoing series of educational tele-seminars on GMPs.
  • McGuffin authored AHPA’s Annotated Final Rule on Dietary Supplement cGMP, which links key points and comments found in FDA’s lengthy preamble to the final GMP rule to each specific section of 21 CFR 111 to which it applies.

Course materials include:

  • Audio CD of the AHPA event
  • An unedited transcript of the AHPA event
  • Links to FDA’s archived webcast. 

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Good Agricultural and Collection Practices

Growers and collectors of herbal raw materials used in herbal dietary supplement and personal care products must make every reasonable effort to ensure that all such ingredients are fit for their intended use. Additionally, manufacturers must set specifications that communicate their needs while meeting new good manufacturing practice regulations.

To help herbal ingredient growers, collectors, brokers and manufacturers understand each others’ needs and comply with federal and state regulations, AHPA General Counsel Anthony Young (Kleinfeld, Kaplan & Becker); Edward J. Fletcher, COO, Strategic Sourcing; Mark Wheeler, founder, owner & operator, Pacific Botanicals; and Rupa Das, VP of Global Quality and Compliance, BI Nutraceuticals, presented this highly informative two-hour educational tele-seminar, which covers such issues as:

  • Identification
  • Quality Assurance
  • Cleanliness
  • Environmental stewardship
  • Legal conformity
  • Optimal harvest conditions

Course materials include:

  • Audio CD of the AHPA event
  • An unedited transcript of the AHPA event
  • Agenda
  • Presenters Bios

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Shelf Life Statements on Dietary Supplement Labels

 

The new Good Manufacturing Practice regulations for dietary supplements require that manufacturers with shelf life statements on their labels have appropriate scientific substantiation. However, expiration dates are not required by the rule, and the cGMPs released in June provide little to no guidance as to what qualifies as scientific substantiation. Manufacturers are left wondering whether it is in their best interest to provide a shelf life statement and, if so, what the appropriate testing programs are for substantiating shelf life – a daunting and difficult task for manufacturers and marketers of herbal products.  

 

To help manufacturers and marketers comply with GMPs, the American Herbal Products Association offers an information-packed tele-seminar, "Shelf Life Statements on Dietary Supplement Labels."

 

You’ll have a chance to pose your specific questions and gain regulatory, legal and scientific insight from these knowledgeable speakers:

 

¨      Anthony Young, Esq., general counsel to AHPA and a partner with the law firm Kleinfeld, Kaplan and Becker, LLP, Washington D.C., will explore the dietary supplement cGMP implications of providing shelf life statements on dietary supplement products. Tony has practiced food, drug and environmental law since 1974. He advises and represents domestic and foreign suppliers, manufacturers and marketers and serves as AHPA General Counsel

 

¨      Michael McGuffin, president of AHPA, is the spokesman for the herbal products industry before state and federal agencies and has twice served on a working group and a subcommittee of FDA’s Food Advisory Committee. Michael’s presentation will address shelf life statements on dietary supplements from a regulatory and practical perspective.  Michael recently authored the association’s highly praised Annotated Final Rule on Dietary Supplement cGMP.

 

¨      Jeff Stassi, program manager for dietary supplement testing at Covance Laboratories, acts as a primary liaison for dietary supplement clients as well as providing expertise on designing comprehensive testing programs to meet scientific and regulatory requirements. He has over 22 years of experience in laboratory operations and client management and has set up testing programs for hundreds of clients within the dietary supplement supply chain. Jeff will address concerns and answer questions related to the execution and substantiation of stability studies.

Course materials include:

  • Audio CD of the AHPA event
  • An unedited transcript of the AHPA event

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Sustainability & Crafting Responsible "Green" Marketing

 

The Federal Trade Commission (FTC) attention to “green” marketing is increasing as the pressure from consumers and customers to implement and market authentically earth-friendly practices and products grows. With the marketplace continuing to fill with “green” claims, how can you communicate effectively to consumers and assure them your claims are authentic? What substantiation is FTC looking for as it evaluates claims in the marketplace? What actions has the National Advertising Division (NAD) of the Council for Better Business Bureau taken? What are your company’s internal standards, and what opportunities might you be overlooking in terms of social justice and cost-cutting sustainable initiatives?


The American Herbal Product Association’s (AHPA), “Sustainability & Crafting Responsible “Green” Marketing,” brings together an expert panel to address these questions both practically and legally by examining the FTC’s definition of “green marketing” and its recent enforcement activities, as well as issues regarding green sourcing in the herbal products industry and best practices for an eco-friendly company.


Don’t miss this opportunity to access the legal knowledge of former FTC Assistant Director Advertising Practices Division and current Kleinfeld, Kaplan & Becker Partner Anne Maher and the practical advice and wisdom of top executives Chuck Bennett, Vice President, Earth & Community Care, Aveda, Lynda LeMole, Executive Director, United Plant Savers and Kathy Larson, Vice President of Sustainability, Frontier Natural Products Co-op.

Course materials include:

  • Audio CD of the AHPA event
  • An unedited transcript of the AHPA event  

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AHPA's Herbs of Commerce, 2nd edition

by Michael McGuffin, John Kartesz, Albert Leung and Arthur Tucker

This book identifies over 1,500 herbs listed by their common names and Latin names. AHPA published the first edition of Herbs of Commerce as self-governing guidance in 1992 in order to reduce confusion associated with labeling of botanical ingredients. The first edition established a single "standardized" common name for each of the listed herbs. This revised 2nd edition published in 2000, was expanded and reorganized so that over 2,000 plants are now included. 

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AHPA's Botanical Safety Handbook

by Michael McGuffin, Christopher Hobbs, Roy Upon and Alicia Goldberg

AHPA’s Botanical Safety Handbook is a comprehensive 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. The BSH lists specific information on the safe use of herbs, including labeling recommendations, dose limits, and possible adulteration.


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AHPA's Guidance Documents for the Manufacture and Sale of Botanical Extracts, the Standardization of Botanical Products and Manual for Alcohol Tax Drawbacks

A collection of five documents that set forth guidelines for procedures and issues encountered in the manufacture, sale and labeling of herbal extracts.

The first three documents consist of Guidance for the Manufacture and Sale of Bulk Botanicals Extracts, Guidance for the Retail Labeling of Dietary Supplements Containing Soft or Powdered Botanical Extracts, and Use of Marker Compounds in Manufacturing and Labeling Botanically Derived Dietary Supplements. by the Botanical Extracts Committee of the American Herbal Products Association

The White Paper on Standardization of Botanical Products describes the many factors that contribute to the proper standardization of a botanical product. The scope of the document covers a variety of preparations, from crude botanicals to extracts to solid oral dosages. This document is intended to foster a heightened awareness of the complexities associated with standardization and to facilitate informed discussions between raw material suppliers, product manufacturers, practitioners, clinicians, regulators and consumers.

The Manual for Alcohol Tax Drawbacks serves as guidance to assist manufacturers to understand and conform to the Federal Regulations that govern the drawback of prepaid excise tax on alcohol used in the products of nonbeverage products. This document is particularly relevant to manufacturers that purchase alcohol manufactured in the U.S. and that produce herbal extracts and tinctures that are sold in liquid form as dietary supplements.
Used to train ATF Staff.
by the Liquid Extracts Committee of the American Herbal Products Association



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A Diggers Guide to Medicinal Plants

by Allen Lockard and Alice Q. Swanson

Guidelines for conservation practices and for harvesting, cleaning, drying and preparing plants for market.


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American Botanical Council Reference Books


The Complete German Commission E Monographs: Therapeutic Guide to Herbal Medicines

by Mark Blumenthal, senior editor
1998, Hardcover, 712 pages

In 1978, the German government established an expert committee, the Commission E, to evaluate the safety and efficacy of over 300 herbs and herb combinations sold in Germany. The results were published as official monographs that give the approved uses, contraindications, side effects, dosage, drug interactions and other therapeutic information essential for the responsible use of herbs and phytomedicines. For the first time, the complete set of Commission E monographs has been compiled, translated into English and edited for use by physicians, pharmacists, health professionals, researchers, regulatory agencies, consumers and the herb industry.

  • 380 Herb Monographs with Therapeutic Information: Uses, Dosage,
  • Contraindications, Side Effects, Drug Interactions and Pharmacological Actions
  • Easy-to-Use Therapeutic and Chemical Indexes
  • Glossary of Medical, Pharmaceutical, and Technical Terms
  • Excerpts from European Regulatory Literature
  • Analysis of Market Trends and Regulatory Issues


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Herbal Medicine: The Expanded Commission E Monographs

by Mark Blumenthal, senior editor
2000, Hardcover, 544 pages

This reference updates 107 monographs from the original Commission E translation by the American Botanical Council, expanding each to include the following:

  • In-depth overviews
  • Information on clinical research
  • Expanded sections on chemistry and pharmacology
  • Additional information on dosage and administration
  • Extensive references
  • Full color photos

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The ABC Clinical Guide to Herbs: Continuing Education Module & Reference Book

by Mark Blumenthal, senior editor
2003, Hardcover, 512 pages

How does the healthcare professional effectively respond to patient inquiries on the use of herbal supplements? What clinical research has been conducted? How is safety evaluated? This science-based educational course answers these and other questions for healthcare professionals, pharmaceutical companies, health management companies, policy makers, the dietary supplement industry and consumers. It is also the first such reference to offer national continuing education credit in five healthcare professions.

The entire work has been peer reviewed by experts, including healthcare professionals in allied health fields as well as those selected by the accrediting agencies. This book contains:

  • 29 single herb profiles
  • 13 proprietary product monographs

Each herb profile includes:

  • a comprehensive clinical monograph which is fully referenced and contains a table of clinical studies
  • a Clinical Overview for quick reference
  • a Patient Information sheet for duplication

Herbs: Bilberry, Black cohosh, Cat’s claw, Cayenne, Chamomile, Chaste tree, Cranberry, Echinacea, Eleuthero, Ephedra, Evening primrose oil, Feverfew, Flax, Garlic, Ginger, Ginkgo, American ginseng, Asian ginseng, Goldenseal, Hawthorn, Horse chestnut, Kava, Licorice, Milk thistle, Peppermint, Saw palmetto, St. John’s wort, Black and green tea, Valerian

Understand the Research and Safety of Herb Combinations: Many products on the market are based on combinations of herbs. A chapter presents monographs on numerous herbal combination products that have undergone human clinical studies.

Proprietary Products: Pycnogenol®, Alluna, Esberitox®, Euvegal® forte, Hochu-ekki-to®, Hova®, Liv. 52®, Mastodynon®, Nutrilite® Saw palmetto with Nettle Root, Padma® Basic/Padma® 28, Phytodolor®, Prostagutt® forte, Sinupret®

Identify Products Backed by Clinical Research: One of the most useful and innovative features of the comprehensive clinical monograph is a table which reviews many of the clinical studies conducted on the herb, study design, and brands used in the studies. Practitioners have been requesting this information. Separate tables in the book summarize all of the brands mentioned in the book and include brand name in the United States, foreign product brand names, company names and company contact information.


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