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, " Bob Flaws <

pemachophel2001> " <pemachophel2001> wrote:

> Dear All,

>

> So far as I've read, no one has said they are interested in following

> up on James and my suggestions to do a comparative study of various

> extracts' concentration ratios (or other particulars).

 

Bob

 

This definitely interests me and perhaps Chinese Herbal Medicine is

reasonably neutral on this matter. I have my personal a priori biases, but I am

much more interested in providing some hard data for the profession. I would

gladly change my mind about certain products if the data contradicted my

assumptions. I think I could insure a pretty unbiased approach perhaps by

having a group of blinded experts evaluate the data and report back to me.

 

I have already contacted a few companies requesting a particular piece of

data. while things like concentration rations and levels of contaminants are of

great importance, my main interest is in being able to compare products using

the only standard considered reliable by pharmacologists. Which is to

determine the levels of particular marker ingredients delivered in the standard

dosage recommended by the manufacturer of the product. Bill Egloff at Crane

showed me information from a japanese company that does exactly this.

Measuring levels of marker constituents is more accurate than concentration

ratios, because a poor quality herb that is concentrated 10 times might be less

effective than really good quality at lower concentration.

 

Before anyone cries foul and thinks I am advocating required standardization

of production techniques, I am not. I just want to know how to compare

products of differing form in order to provide accurate dosage to my patients

when using prepared products. As it stands right now, I cannot possibly see

how many of the products on the market can deliver anywhere near the

equivalent dosages of herbs I typically use in decoction, which is about 75-

100 grams per day.

 

For me, phase one would be to establish the extraction levels of an active

constituent in decoction form using raw herbs from a few suppliers. I would

use a korean extractor for the decoction in order to insure controlled time and

temperature in a closed environment. It might also be useful to do a few

reference stovetop decoctions with various degrees of sloppiness or rigor. for

fun, we could do a useful formula that is made by many companies, which is

xiao chai hu tang. We could use the japanese established standards and

measure the level of saikosaponins, baicalin and glycyrrhizin and compare

the amounts delivered in mg/day to the same formula in prepared form from

various companies. Or perhaps similar formulas in the case of companies

that do not make classical formulas -- I think this can be done fairly and

accurately -- a variation of xiao chai hu tang will still have a certain % of

the

same ingredients and adjustments can be made in the final analysis to

compensate for slight differences. Also, the goal is not to reveal subtle

differences, but gross ones. thus, it doesn't matter if there variations in

levels

of actives from 25% below or above the reference range. We would expect

that type of variation in nature anyway. That is why the japanese model uses

reference ranges, not absolute values, to standardize around.

 

However it does matter greatly to myself and many others, including

researchers and insurers, if there are differences in the strength of various

products that I literally believe are on the level of 100 fold in some cases.

for

example a standard tincture (not an extract like kan or far east) delivers the

extract of 5 grams of herb per ounce of fluid. If a tincture bottle lasts five

days,

the patient has consumed the extract of 1 gram of herbs per day, which is 100

times less than some of my decoctions. alcohol extraction is much more

efficient than decoction, but I would like to know exactly how much. It is

notable that British medical herbalists prescribe tinctures of SINGLE herbs at

dosages of 1/2 oz. per day. I also need to point out that it does not really

matter if many members in our field are satisfied with the status quo. It

should

matter to suppliers that many of us are not. And we will not prescribe products

based merely upon subjective claims and persuasive advertising.

As I said in an earlier post, you may not be able to be prescribe down to the

exact millligram with raw herbs (and I am not advocating that for products,

either,if you read closely), but an experienced herbal phamacist can certainly

identify the difference between decent and crappy herbs. In which case,

moderate dose decoctions will be pretty reliable in delivering a decent

amount of actives within an acceptable fluctuation of ranges that can easily be

corrected by adjusting dosage on an ongiong basis (something I often do by

phone). We just need to get a ballpark idea of where various pills, tinctures,

extracts, etc. fit into this range. Various companies clearly make products

that

taste and smell potent, but it has never been established how many of these

products truly relate in dosage to an extraction. So even if it is the best

extraction method around, that means nothing if doseage is inadequate on

the level of 25-100 fold (BTW, for those who glaze over with math, this is

potentially a 2,500% - 10,000% variation I am talking about here, not merely a

25%-100% variation!)

 

Unfortunately, Chinese Herbal Medicine has not developed a way to raise

capital for this and other projects of interest as of yet. One of the purposes

of

the upcoming June conference is to increase our visibility in hopes of creating

some revenue for such things. If it looks like this will pan out, then perhaps

preliminary steps could begin within a few months.

 

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Bob,

I think you raise a number of great questions. However, isn't assuming

a company's environmental track record (like you say) also a subjective

measure of a product's 'shoddiness'? I'm not trying to imply those

aren't important factors in choosing a manufacturer, but objectivly, do

they really have much to do with potency, purity, efficacy, of a

product? One of my teachers in school visited a herbal product

manufacturer in California and who uses recycled products etc.. But she

said that it wouldn't be allowed to even operate in China due to the

degree of sanitary conditions that would be required due to Chinese

regulations. Again, I don't think that has any objective relevence in

the potency, purity, or efficacy of the end product, but it's just

another take on this subject. I'm sure that you can measure potency and

purity of herbs through independent laboratories, but how could you even

begin to measure the efficacy? For me, I appreciate hearing everyone's

opinions, even though people disagree... This empirical evidence will

have to do for now.

 

Geoff

 

> " Bob Flaws <pemachophel2001 "

> <pemachophel2001

>

> Seems to me that there has been a conspicuous lack of real evidence

> presented to substantiate people's choice of herb powders.

> Mostly what

> I've read here are choices based on very subjective

> parameters such as

> smell, taste, fineness of powder, etc. One person has said they

> don't like Sun Ten (Brion) and another person has said they think

> they are the best. One person has said they like the finer

> ground powders and another has said they do not. As someone in the

> industry, I am constantly amazed that, by and large, customers do not

> ask more substantial questions regarding potency, purity, efficacy,

> etc. Some people have voted in this forum for some brands which are

> generally known within the industry to have a dubious reputation.

>

> As both a practitioner who prescribes Chinese meds and someone who

> manufacturers and markets a line of extracts, here's the kinds of

> questions I would be asking of my suppliers:

>

> 1. How are your products made? There are different processes out

> there. I want to know exactly the steps and procedures used to

> manufacture a product I am going to prescribe (and become legally

> responsible for prescribing). I want to know exactly what

> happens from

> the time the raw materials enter the factory till the

> finished product

> is packaged for shipment.

>

> 2. Where are your products made and who provides the quality

> assurance? For instance, is there state or national certification or

> licensing?

>

> 3. Do you have certificates of analysis (COA) showing that what you

> say is in the product is actually there? Are copies of these

> available

> to consumers upon request?

>

> 4. How are your products chosen or created? Who is the formulator and

> what are his or her credentials?

>

> 5. What is the extract ratio?

>

> 6. Do you use any fillers or binders and, if so, what are they?

>

> 7. Do you use any sugars, artificial colors, or artificial flavors in

> your products? If so, what are they and why do you use them?

>

> 8. Do you have your products tested for:

>

> A) microbial contamination?

> B) heavy metals?

> C) pesticides?

>

> If so, where are they tested? Who tests them? How often are they

> tested? Are tbey tested in-house or by an independent company. What

> specifically are they tested for, and what are the outcomes of these

> tests? Are copies of these outcomes available to consumers upon

> request?

>

> 9. Do you have any research or other evidence that supports your

> product's safety and efficacy? If so, what kind of research or

> evidence, done by whom and where?

>

> 10. What is your company's position on CITES (Commission on

> international Trade in Endangered Species) and the use of endangered

> species in medicine? What is your comapny's track record on these

> issues?

>

> 11. What is your company's general environmental policy and track

> record? Do you have an in-house recylcing program? Do you try to use

> recycled papers and soy-based inks. Do you try to use chlorine free

> papers? Do you use recyclable plastics in your packaging? Do you try

> to keep you packaging to a minimum? While one may say that these

> issues do not directly affect a medicinal's effectiveness, in my

> experience, companies which are conscious and conscientious about

> these kinds of things are less likely to produce a shoddy or unsafe

> product.

>

> 12. Do you make a conscious and consistent effort to inform yourself

> and comply with FDA regulations regarding the manufacture, packaging,

> and labelling of herbal supplements?

>

> 13. Are you a member in good standing of AHPA (American Herb

> Producers

> Assoc.)? If not, why not?

>

> These are the kinds of questions I like to have answered before I buy

> a product that I am going to become responsible for

> prescribing. I can

> also tell you, these are the kinds of questions that get asked in a

> court of law when there are problems with Chinese herbal products.

>

> Bob

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....while things like concentration ratios and levels of contaminants are of

great importance, my main interest is in being able to compare products

using

the only standard considered reliable by pharmacologists. Which is to

determine the levels of particular marker ingredients delivered in the

standard

dosage recommended by the manufacturer of the product.

 

 

As I believe I have previously mentioned in this forum, we have been doing

this type of research on both raw materials and extraction methods since

1993. The more hard analytical data I see on quality issues the more I have

come to value the use of lab analysis as a way to assess quality. As Todd

correctly points out, extraction ratios tell an incomplete story without

knowing the quality of what is being extracted. Also, the transfer rate

varies considerably from one extraction method to another. (Transfer rate

reflects what percentage of the phytochemical components are transferred

during extraction from the raw material to the finished extract). The

transfer rate of many bioactive components of herbs is much greater using

ethanol (in varying percentages depending on the plant particulars) with

water as part of the menstruum (solvent).

 

My colleagues and I have set up a very capable analytical lab in Beijing to

facilitate our ongoing research. Since we do not currently market products

to the professional Chinese herb community we would consider providing some

analytical services as an independent lab at much more favorable rates

(roughly half the cost) than you would get in the US.

 

In the end, in order to have TCM herbalists know enough to ask the kinds of

questions Bob has suggested, I believe at least some of the required

classroom education time for students of Chinese herbs should be devoted to

quality control issues and the use of analytical labs.

 

 

Stephen Morrissey

 

 

P.S. Zev's point on the storage of suan zao ren is very important. We have

seen the aflotoxin levels go to deadly levels on that ingredient when the

raw material had been stored after harvest for 6 months. Even after

extraction with hot H20 and ethanol the aflotoxin levels remained very high.

If you think it tastes/smells a little moldy, toss it!

 

 

 

 

 

 

 

 

Chinese Herbal Medicine, a voluntary organization of licensed healthcare

practitioners, matriculated students and postgraduate academics specializing

in Chinese Herbal Medicine, provides a variety of professional services,

including board approved online continuing education.

 

 

 

 

 

 

 

 

 

 

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wrote:

 

>>>The checking for aroma, test, and consistency are intuitive

qualities, like that of a wine-taster.<<<

 

Can anybody articulate what these intuitive qualites are, or is it

simply your body's reaction to them?

 

> Some products

> containing suan zao ren suffered from rancidity after a short time,

> meaning that even some spray-dried powders sometimes need

> refrigeration, despite claims sometimes to the contrary.

 

That reminds me. Does anybody else find that their herb extract of Lai

Fu Zi smells a little like sour milk?

 

I threw away one bottle, but when I reordered it, it smelled the same.

This was actually from two different companies.

 

Just made me wonder, is all.

 

--

Al Stone L.Ac.

<AlStone

http://www.BeyondWellBeing.com

 

Pain is inevitable, suffering is optional.

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Measuring levels of marker constituents is more accurate than concentration ratios, because a poor quality herb that is concentrated 10 times might be less effective than really good quality at lower concentration

>>Todd the problem with markers is that they do not necessarily mirror the rest of the herb.

 

alcohol extraction is much more efficient than decoction, but I would like to know exactly how much.

>>>but extracts different ingredients

alon

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Stephen is it true that many herbs cannot be reliably concentrated much above 8X1 and still be powdered?

Alon

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Geoff,

 

I agree with you that a company's environmental consciousness and

track record may be one of the least important of the questions I

suggested. However, it is my experience that those companies which are

environmentally conscious tend to also be very concerned over their

products' safety and efficacy. I have yet to come across any companies

were this connection was not operative. However, I do agree this may

be one of the less important things to know about a supplier in terms

of purity, potency, and efficacy.

 

Bob

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Stephen,

 

Definitely, lab analysis in China is cheaper than in the U.S., and

for practitioners' and scholars'personal knowledge purposes, lab

analysis from China is fine (as long as everything being compared is

analyzed in the same lab by the same techniques and equipment).

However, for governmental purposes, it is, in our experience,

unacceptable. Our distributors in the EU and Switzerland refuses to

accept any Chinese lab work because, they say their governments refuse

to accept any Chinese lab work. Do you have any experience with this?

 

Bob

 

, " Stephen Morrissey "

<stephen@b...> wrote:

>

>

> ...while things like concentration ratios and levels of contaminants

are of

> great importance, my main interest is in being able to compare

products

> using

> the only standard considered reliable by pharmacologists. Which is

to

> determine the levels of particular marker ingredients delivered in

the

> standard

> dosage recommended by the manufacturer of the product.

>

>

> As I believe I have previously mentioned in this forum, we have been

doing

> this type of research on both raw materials and extraction methods

since

> 1993. The more hard analytical data I see on quality issues the

more I have

> come to value the use of lab analysis as a way to assess quality.

As Todd

> correctly points out, extraction ratios tell an incomplete story

without

> knowing the quality of what is being extracted. Also, the transfer

rate

> varies considerably from one extraction method to another.

(Transfer rate

> reflects what percentage of the phytochemical components are

transferred

> during extraction from the raw material to the finished extract).

The

> transfer rate of many bioactive components of herbs is much greater

using

> ethanol (in varying percentages depending on the plant particulars)

with

> water as part of the menstruum (solvent).

>

> My colleagues and I have set up a very capable analytical lab in

Beijing to

> facilitate our ongoing research. Since we do not currently market

products

> to the professional Chinese herb community we would consider

providing some

> analytical services as an independent lab at much more favorable

rates

> (roughly half the cost) than you would get in the US.

>

> In the end, in order to have TCM herbalists know enough to ask the

kinds of

> questions Bob has suggested, I believe at least some of the required

> classroom education time for students of Chinese herbs should be

devoted to

> quality control issues and the use of analytical labs.

>

>

> Stephen Morrissey

>

>

> P.S. Zev's point on the storage of suan zao ren is very important.

We have

> seen the aflotoxin levels go to deadly levels on that ingredient

when the

> raw material had been stored after harvest for 6 months. Even after

> extraction with hot H20 and ethanol the aflotoxin levels remained

very high.

> If you think it tastes/smells a little moldy, toss it!

>

>

Chinese Herbal Medicine, a voluntary organization of licensed

healthcare

> practitioners, matriculated students and postgraduate academics

specializing

> in Chinese Herbal Medicine, provides a variety of professional

services,

> including board approved online continuing education.

>

 

>

>

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At 3:52 PM +0000 1/16/03, Bob Flaws <pemachophel2001 wrote:

>But I strongly encourage someone to take the first step. If

>no one is willing to take this step, then it suggests that we, as a

>group, are really not interested in some of the issues we say we are.

--

 

Bob, I started this thread, and I think your criteria are excellent.

I do intend to follow up as you suggest, but I've been very busy.

I'll try to delegate some of the work to people at the college, and

mainly oversee it.

 

Anyway, thanks for your suggestions. And thanks to all who offered

opinions and information.

 

Rory

--

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-----Original

Message-----

Alon Marcus

[alonmarcus]

 

Stephen is it true that many herbs cannot be reliably concentrated

much above 8X1 and still be powdered?

Alon

 

 

 

Alon, this

has not been our experience. In

fact the main way to exactly control extraction ratio is to take the final

extracted liquid material and mix it into or with a carrier during spray or

vacuum drying or while it is still in concentrated liquid form in order to achieve

the targeted ratio. Otherwise, whatever

you can manage to extract with the solvent and the techniques you use is what

you get if your target is to obtain as broad a phytochemical spectrum as

possible. Very often that ratio

naturally gravitates to a 10 to one on average when using water/ethanol

combinations and typically a bit lower concentration ratio with water. Each different plant material has its

own physical characteristics that dictate whether it is easily powdered or

not. We powder many extracts in

the ten to one range. Hou pu, for

example, is particularly sticky and requires more creative approaches to making

its 10 to 1 powder user friendly.

 

Stephen

 

 

 

 

 

 

Chinese Herbal Medicine, a voluntary organization of licensed

healthcare practitioners, matriculated students and postgraduate academics

specializing in Chinese Herbal Medicine, provides a variety of professional

services, including board approved online continuing education.

 

 

 

Your use of

is subject to the

Terms of Service.

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, " Stephen Morrissey " <

stephen@b...> wrote:

 

> My colleagues and I have set up a very capable analytical lab in Beijing to

> facilitate our ongoing research. Since we do not currently market products

> to the professional Chinese herb community we would consider providing

some

> analytical services as an independent lab at much more favorable rates

> (roughly half the cost) than you would get in the US.

 

I think this would be more than adequate for our purposes in conducting such

a study designed mainly to inform practitioners. I wonder if you already have

any data on what level of constituents a controlled water decoction extracts

from 100 grams of herbs. Because that will be my standard for comparison. It

seems the most reasonable standard because it is about the average size

formula one finds in typical formularies and texts on internal medicine

available in english as well as being similar in size (if not smaller) than

hundreds of research formulas that have been abstracted in various english

publications.

 

 

> In the end, in order to have TCM herbalists know enough to ask the kinds of

> questions Bob has suggested, I believe at least some of the required

> classroom education time for students of Chinese herbs should be devoted

to quality control issues and the use of analytical labs.

 

I feel the same way and have an upcoming article in the OM News from

PCOM stressing the importance of insuring that our doctoral candidates have

this type of knowledge. Particularly because I want us to be educated enough

to responsibly self regulate before public hysteria causes the government to

do something very prohibitive.

 

> P.S. Zev's point on the storage of suan zao ren is very important. We have

> seen the aflotoxin levels go to deadly levels on that ingredient when the

> raw material had been stored after harvest for 6 months.

 

It is ironically far safer to spray suan zao ren with a fungicide than it is to

risk

exposure to afflatoxins. Just like with peanuts. Correct me if I am worng, but

afflatoxins, a naturally occurring by-product of certain fungi, I believe, are

amongst the most carcinogenic substances. I was not aware of this concern

for suan zao ren. Does roasting the suan zao ren right after harvest prevent

this problem?

 

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Stephen,

 

Your post contained some really good information. However, it's the EU

and Swiss governmental agencies which will not accept the Chinese lab

reports.

 

Bob

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Simon,

 

What with Stephen and your posts, I think that now we are getting some

really useful information on all of this. This is all very

complex. Thanks.

 

Bob

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, " Simon " <s.becker@l...>

wrote:

Determining the amount of substance (quantitative

> analysis) is more difficult and especially much more expensive.

 

thank-you, simon. this is unfortunate. if we cannot test for quantity of

actives,

this is a waste of time. many companies already tests for the presence of

actives, but this is of much less value. at least we know we got the right

thing,

but how much is more important to me. I am sure you are right as to the

reasons why companies avoid this issue. Persoanlly, I have switched back to

the use of raw herbs in almost all patients.

 

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Each different plant material has its own physical characteristics that dictate whether it is easily powdered or not. We powder many extracts in the ten to one range. Hou pu, for example, is particularly sticky and requires more creative approaches to making its 10 to 1 powder user friendly.

>>>>is going higher than 10X1 difficult?

Alon

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The problem in the US is that there are no laws requiring testing (at leastnot that I am aware of). Sometimes we order products from the US and testthem prior to selling them. Unfortunately, I have found all kinds of toxins,most strikingly aflatoxins, cadmium (our limit is 0.5 here, I believe it ishigher in the US. However, Cd levels of 0.9 seem a bit high to me), andAristolochic acid

>>>Simon thanks for elaborating on my previous statement. Here in CA some of the companies get analysis from the CA FDA which checks some of the above mentioned impurities. The problem is that it is done only patchily. For years I have tried to push the companies I buy from to be more consistent, it has been difficult. What are the levels of aflatoxins you have been finding. Aflatoxins are extremely toxic we need much more information on this. It is the first time I hear of this.

Alon

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It still seems to me that alcohol extracted herbs are different than water

extracted herbs.

 

The proper ratios of herbs are determined by formulas based upon texts like

the Shan Han Lun which used water extraction or herbs that were crushed into

powders.

 

There seems to me a faulty line of logic that assumes alcohol extraction are

identical - or taunted as superior to the formulas reverenced.

 

One does create a different product. May be superior but it is different -

isn't it?

 

Why are some herbs twice cooked, pan fried, some added early some last?

 

Why not cook herbs according to the Text (Shan Han Lun for example)

Dehydrate to powders, rehydrate to use and then compared the reconstituted

herbs to the original cooked herbs.

The same comparisons could be made with single herbs and then combining to

compare with the original cooked formula.

 

The question of heavy metals, chemicals, pesticides are an important but

secondary issue.

My argument is that the standard should be how does it compare to the

original text - without the hype.

 

Ed Kasper LAc

Santa Cruz, CA.

 

 

 

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, " ALON MARCUS " <

alonmarcus@w...> wrote:

Aflatoxins are extremely toxic we need much more information on this. It is

the first time I hear of this.

> Alon

 

I would like to know what other herbs have common aflatoxin problems. also,

are they contaminated during growth or storage. If during storage, what can

be done to prevent this. Ironically, sulfur is a powerful fungicide. I used it

in

my garden all the time in moldy Oregon. I bet sulfur prevents the fungal

growth that produces these toxins. It is thus a matter of when treatment is

necessary. I hate to say this, but this is another issue we have to address

before the feds require all our herbs to be sprayed at customs. It may require

that we allow selective spraying of culprit herbs like suan zao ren. I did

doublecheck and aflatoxins include the most potent hepatocarcinogens ever

studied. I wonder if aflatoxins were actually responsible for the aristolochic

acid hysteria.

 

s for sulfur, this is another hysterical issue. An extremely small % of people

have true sulfite allergies. And no one is actually allergic to ionic sulfur,

as it

is a major tissue constituent and has too low a molecuclar weight to initiate

allergy anyway. It is far more likely that people are reacting to pollen of

certain highly allergenic plants like ragweeds, quite a few of which are

chinese herbs (sorry, don't know which ones offhand). We may need to revisit

the sulfur issue since less than1% of the population has sulfite allergies, but

a

healthy adult could die within 72 hours of aflatoxin exposure. BTW, I have

heard all the sulfur anecdotes out there; these anecdotes do not square with

modern science. People who think they are reacting to sulfur are most

definitely reacting to something else (they may be homeopathic provers, for

example). In some cases, herbs may be chemically sulfited and this may

pose a big risk for a very few, but I do not think this is prevalent.

 

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Does roasting the suan zao ren right after harvest prevent

this problem (aflotoxin)?

 

I would say that any influence that dries out the moisture content would be

helpful since high moisture content is a key instigator of the mold growth.

But that's just speculation since I haven't actually tested this idea.

Certainly storage conditions are important as well.

 

Stephen

 

 

Chinese Herbal Medicine, a voluntary organization of licensed healthcare

practitioners, matriculated students and postgraduate academics specializing

in Chinese Herbal Medicine, provides a variety of professional services,

including board approved online continuing education.

 

 

 

 

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At 7:20 AM +0000 1/17/03, < wrote:

> > In the end, in order to have TCM herbalists know enough to ask the kinds of

>> questions Bob has suggested, I believe at least some of the required

>> classroom education time for students of Chinese herbs should be devoted

>to quality control issues and the use of analytical labs.

>

>I feel the same way and have an upcoming article in the OM News from

>PCOM stressing the importance of insuring that our doctoral candidates have

>this type of knowledge. Particularly because I want us to be educated enough

>to responsibly self regulate before public hysteria causes the government to

>do something very prohibitive.

---

 

 

 

Will there be any presentations along the lines of the issues raised

in this thread at the upcoming CHA conference. It seems that there

are several possible lecture subjects that would be very useful to

practitioners.

 

Rory

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Aflatoxin analysis is comparativley inexpensive. I suggest you take a bottle of Bai Zi Ren and possibly Yan hu Suo from several different companies and send them to a lab. If the levels are too high, let the company know. Then they will most likely begin testing.

>>>I think we should all pressure the companies to provide certificate of analysis for alfatoxins. I am going to with my supplier.

Alon

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Taiwan, where most the granules come from, is also not a PIC country

>>>I thought many of the taiwan labs are GMP certified by Germany

Alon

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According to our distributors, they will accpet U.S. lab analyses.

However, they have their own laundry lists of what they want tested.

 

Bob

 

> That's certainly different that what I was envisioning. I would be

> surprised if the EU and Suisse Gov't would accept US lab results

either. Do

> you know?

>

> Stephen

>

> Chinese Herbal Medicine, a voluntary organization of licensed

healthcare

> practitioners, matriculated students and postgraduate academics

specializing

> in Chinese Herbal Medicine, provides a variety of professional

services,

> including board approved online continuing education.

>

>

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Guest guest

This is not my impression. All GMP certificates I have seen were issued by the Taiwanese Ministry of Health.

Simon

>>>Thanks I remember seeing literature from shengcheng that they meet German GMP

Alon

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I think that is a great idea. While you are at it, ask for a certificate for the Mercury (Hg) content of Gelatinum Asinii (E Jiao).

>>I will. I did ask for sea products CA and it looked good. Mu Li, Hai Zao and Hai Dai (Min Tong)

Alon

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