In recent years, the FDA and other governing bodies have
been tightening regulations for dietary supplement companies. Seen in the
recent attacks by the NY attorney general and other agencies, they have
criticized companies for mislabeling ingredients. It was unfortunate for the
companies on the receiving end of these attacks because the agencies used non-traditional
testing methods, which have not been proven to be effective at identifying the
purity of raw ingredients. As a result, these companies faced loss of consumer trust
in their products and it undoubtedly affected their bottom line. So how can you
protect your company from events like this? Testing your raw ingredients is the
best way to address this concern!
According to 21 CFR 111.120, companies are required to
determine whether all components, packaging, and labels conform to
specifications that are established in 21 CFR 111.70 (b) and (d). These specifications are provided for each
component (raw ingredient) that is used and must be established as follows:
(b)
1.
You must establish an identity specification.
2.
You must establish component specifications that
are necessary to ensure that specifications for the purity, strength and
composition of the dietary supplements manufactured using the components are
met.
3.
You must
establish limits on those types of contamination that may adulterate or may
lead to adulteration of the finished batch of the dietary supplement to ensure
the quality of the dietary supplement.
(d)
You must establish specifications for
dietary supplement labels (label specifications) and for packaging that may
come in contact with dietary supplements (packaging specifications). Packaging
that may come into contact with dietary supplements must be safe and suitable
for its intended use and must not be reactive or absorptive or otherwise affect
the safety or quality of the dietary supplement.
If you pay
close attention to (b) you can see how the testing of your raw ingredients is
mandatory. The minimum requirement is for ID, purity and strength to ensure
your raw ingredients are what you are claiming. This documentation is also very
important when you test your finished product and notice matrix interference
occurring after testing has been completed. Matrix interference can cause
certain analytes to be much higher or much lower than your anticipated label
claim. When you have documentation of the quality of your raw ingredients, it
allows for a written documentation detailing the unexpected results for
reference if your product is ever under scrutiny.