Adulteration in the Time of COVID

Adulteration has been around since the beginning of trade, and with trade soon celebrating its sweet 5,020th birthday (Happy Birthday trade!), that’s a lot of years of adulteration.

Back in the Mesopotamian times, it wasn’t uncommon that when you ran out of cumin for your segment of that upcoming progressive dinner party where you planned to serve Stew of Gazelle with boiled wild tulip bulbs and coarse bread (said with a grimacing face) you couldn’t just log into your Instacart account to get some. The internet was so slow back then.... The rule was: If you did not grow it, you had to travel long distances for it. So, you’d borrow great uncle Sudberg's cutlass camel supreme and hit the open trail with the intention to barter and fulfill your ingredient list, and in case they didn’t want what you had to trade, you’d carefully carry that leather bag of shekels and hope they could make change.

Even back then, everyone had a guy, and at some point your 'yeah I know, your family has been buying from his for generations cumin guy’ started selling cumin cut with stone dust or semolina or grass paste. We should give your cumin guy the benefit of the doubt. Perhaps his family decided it was more profitable to resell someone else's cumin and so they stopped growing cumin themselves and planted their land with a new up-and-coming crop called Hemp. So, he lost control of the quality of his cumin. Perhaps he fell prey to that new magic box device that promised to use artificial intelligence and algorithms to determine quality, but forgot it's neither fit for purpose nor validated and can't easily detect fillers, and he didn’t have the batch independently tested by microscopy to detect fillers or HPTLC to detect adulterants. Or he just accepted the material without a third-party Certificate of Analysis (CofA).

{CUE Law & Order-esque sound bite}. If only the Reagan dealing with the Russians had coined the phrase ‘Trust but verify’ sooner...

At this point, you trustingly purchased adulterated cumin from your family’s ‘cumin guy’ and headed back home to continue your culinary masterpiece. Upon arrival, your great uncle Sudberg, whose primary concern is the wellbeing of his cutlass camel supreme, waddles over to collect his camel. Now, at a careful and modest 8:2 ratio of cumin and stone dust, no one's nose would know, and your nose certainly did not know, and at worst, your culinary masterpieces will be a little gritty. But perhaps that was not so unusual.

Enter great uncle Sudberg again... What you didn’t know is that he has an increased grey matter volume (GMV) in the anterior insula and in the hippocampus (dentate gyrus), which are the regions crucial for the integration of olfactory information as well as odor learning and odor memory. Basically, he is what is called a “super sniffer,” and with one extreme waft of his great uncle hands, his nose knows your proud sack of cumin has been adulterated.

{CUE the Law & Order BOM BOM}.

There is no time to make a Pictogram of this event, so you call for a scribe and send Ivan Wasserman’s great great great, etc., etc. grandfather a letter recounting the fraud. It is hard to tell what is worse, Uncle Sudberg’s disappointed glare or the legal fees you could have avoided if you dropped a few shekels on independent lab analysis.

Believe it or not, times have not changed much. Well, they have, a lot, but adulteration is still being perpetuated today by both willful ignorance and greed. See, once the supply of adulterated material is given the OK by inferior testing methods, it is like a virus and more than hard to get rid of unless proper testing is quickly deployed. Like a virus, adulterated material will kill the host and, in turn, itself unless it's given the chance to replicate. It replicates by ignorant resale after ignorant resale, and if left untested and undetected, can infect the ingredients of many in the supply chain.

On the topic of viruses (see what I did there?), as the COVID-19 pandemic gained momentum, companies around the globe restricted travel in the name of safety. We did the same at Alkemist Labs. Understandably, the FDA does not want to put its investigators in harm's way, so they reduced onsite inspections of low-risk manufacturers. To me, kind of a botanical private investigator, that’s like posting where the DUI check points are before the weekend. I have never understood why local authorities do that because it tells the drunks where not to drive. Once the authorities let the unscrupulous know where they won't look, that’s where the unscrupulous go.

Adulteration has now been given a free pass, and while it’s always been around, it now feels safer than ever knowing that the FDA is too busy busting COVID miracle cures to set foot in a shady manufacturing facility or lab failing to comply with basic cGMPs. Couple this with an unprecedented strain on supply and heightened demand and I could not agree more with CRN President & CEO Steve Mister’s words; “Now is the time for companies to double down on their quality controls.”

Alkemist Labs enjoys one of the best slices of our industry, partly because most of our clients have robust quality-management systems in place. When they are challenged by short supplies, many have back-up vendors they have qualified in advance. What this means for us is that because our clients are the industry’s best, we generally do not have tons of bad news to share on testing failure rates of botanicals. That said, as supply chains are strained and compromised, the frequency of testing is up, which speaks to the integrity and wisdom of our clients. Perhaps unsurprisingly, though, given the unprecedented circumstances, we have noticed some emerging trends and the failure rate is on the rise. Below are a few of the botanicals that are failing more consistently than normal:

The reasons for failure are the usual suspects, including, but not limited to; closely related species, dilute powders cut with fillers and plant part substitutions. Though not always intentional, many of these happen through willful ignorance, and unfortunately, malicious intent.

One of the most peculiar is the counterfeit Alkemist Labs CofAs we’ve discovered floating around select Chinese vendors. In the ultimate irony, our CofAs are now being adulterated, but instead of with cheaper plant parts, it’s by altering a lot number or changing a supplier’s name. While my increasingly achieved goal is for my best-in-class clients share our CofAs as collateral for their ingredients or products, now we also have unscrupulous vendors attempting to sell their untested Elderberry via email campaigns using counterfeit Alkemist CofAs as collateral.

Dateline NBC did an undercover investigation in 2012 that revealed a practice by some in the dietary supplement industry that involved issuing a Certificate of Analysis with whatever test results the client wanted, but not testing a product at all, a practice called “Dry Labbing.” We’re calling this new problem “Dry Reporting” and it has the potential to create as many terrible headlines for the industry as the dry labbing scandal did.

With the supply chain strained by COVID-19, some companies are buying from people they have not vetted and should proceed with extreme caution. It’s essential that whenever material changes hands, it’s tested. Don’t skip this step, especially now.

To combat this new category of adulteration, we are consulting industry experts on Block Chain, and implementing verification steps to secure our CofAs, and allowing the industry to validate claims of Alkemist Analysis.

Additionally, we are reaching out to the industry trades to spread the word on how buyers can protect themselves against these crooks. For more infomation, click here to read our press release. In the meantime, if you are being sold material and see our CofA being used as collateral, shoot me an email at [email protected] or call my office line: 714-754-4371 ext. 210. I’d love to verify it for you! We hope other testing labs in our industry will follow suit.

by Élan Sudberg [email protected] 714-754-4371 ext. 210

About the Author: Élan M. Sudberg is CEO of Alkemist Labs, a passionately committed contract testing laboratory specializing in plant authentication, botanical ingredient identification and quantitative analytical services to the Food & Beverage, Nutraceutical and Cosmeceutical Industries. He holds a degree in chemistry from California State University Long Beach and has authored numerous journal articles on phytochemistry and analytical techniques for the natural products and nutraceutical industry. He is a board member of AHPA, as well as AHPA’s Education and Research on Botanicals Foundation, and past chair of the Hemp and Medical Marijuana committee. He received the 2019 NutraIngredients-USA NutraChampion award for advocacy of best testing practices.