Sorry, not sorry

IT'S BEEN SEVERAL WEEKS SINCE I RECEIVED A NUTRACHAMPION AWARD and the elation has yet to wear off. This recognition means a lot to me because I know the editors of NutraIngredients-USA don’t bestow this award lightly. I appreciate their recognition that advocating for best practices, even in the face of occasional criticism, is valuable for our industry. Ultimately my vocal advocacy isn’t about receiving honors, it’s about making us all better. So, you could say that I’m sorry, not sorry for incessantly pushing the industry to keep getting better. Care to join me? Here’s how you do it:

You must be willing to alienate yourself from those who disagree about championing a vulnerable level of transparency. You must be willing to lose some clients due to your insistence on producing and providing accurate results, and you must make your editor work late into the night in an effort to take your sharp truths and elegantly and appropriately temper them so you effectively get your point across.

They say those who don’t learn from history are doomed to repeat it. In this light, here’s some history: I cut my teeth in this industry testing the ~1997 Australian herbal market out of a major TGA recall. A random knock at the door of our first lab facility (a former colonic room in my father's chiropractic practice) brought us over 300% growth as we confirmed identity by HPTLC of hundreds of little bottles of Cat’s Claw Bark or Nettle Root or Peumus Boldus Leaf. That single event put us on the map as we were the only lab competent to perform the analysis the TGA required to put products back on the shelves in Australia and New Zealand. Once that event had subsided, we remained active and were quickly known as “the plant ID lab;” a label we proudly wear today.

Later, in ~2005 we inadvertently exposed a major adulteration of Hoodia Gordonii, which was not with any intent other than to report the data we found but was the first example of ideal transparency. In an effort to try and resuscitate a category choked with fraud (that was the year more Hoodia was sold than was harvested - see the problem?), we pioneered what we now call Next Generation Transparency by offering good players the competitive advantage of sharing their independent lab results with the public. Consumers could whip out their Palm Treo 650 smart phone while at GNC, type in the lot number on the participating brand’s page on the world-wide-web and pull up our C of A showing the Analytical Triad consisting of Microscopy and HPTLC to confirm identity of Hoodia Gordonii stem and HPLC for the quantity of ‘P57’ (an analyte of Hoodia then used to verify identity). Consumers had, in their hands, third party analysis, creating trust in their buying decision.

Confronted with failed Hoodia tests results, clever suppliers concocted a brilliant yet insane explanation: “if you buy South African Hoodia seeds and grow them in China, the plant quickly changes its morphology and resembles a completely different genus and species of plant” that just happened to match the common adulterant of Hoodia which was Opuntia. This remains one of the biggest “what the?” experiences of my long career testing plants. Even with my average grades in botany, I knew that’s not how it works and did my best to dispel the misinformation with constant explanations and presentations on the matter.

Speaking of “what the?” moments; in 2015 New York Attorney General Eric Schneiderman, working with a New York Times reporter, launched an attack on the industry and specifically several major retailers, including GNC. Schneiderman's attack was deeply flawed because he mis-used science, deployed the wrong test method on the wrong products and deduced wrong data to support his assertion that herbal extract fraud was rampant. Let's just say that ‘Fit for Purpose’ testing was not his major concern, and those of us skeptical about his integrity based upon this experience weren’t heartbroken when he resigned from office three years later mere hours after assault claims by four women became public. That defective attack had a silver lining because it gave new life to the conversation about Next Generation Transparency and upped the industry’s testing game. In this case, its feisty sister ‘Fit for Purpose’ testing joined the movement when the industry had to quickly figure out this new dilemma: use of a technology that was not vetted enough to be fit for purpose (DNA), yet was mandated, disrupting use of actual ‘Fit for Purpose’ testing (HPTLC, etc.). Consumers were confused by the misinformation and reported the lowest trust rating for this industry ever recorded. Due to valiant education efforts by industry trade associations—top suppliers and brands that consumers trust, there was some shifting of market share—but overall, sales did not tank. Part of the reason was companies stepped up their testing programs and talked about it, but those that really did well as consumers re-examined their brand loyalty, were already following best practices and sharing that information openly. Since it is nearly impossible to earn back trust when it's lost, it is imperative to strive for the highest quality ingredients and highest quality testing lab to substantiate ingredient and product claims. Consumers today are looking more closely than ever for information on the origin, sustainability, collection policies and quality of ingredients. They want to know what a company does to ensure the product is sound. They are not only quick to jump ship with the slightest indication of foul play; they are even quicker to share their experience on social media. This data travels faster than the speed of light and can ruin a brand’s reputation overnight.

Historically, the industry takes a big step forward in producing and demonstrating quality when there is a very public attack on the integrity of our products. The brands that prevail best are the ones that already have programs in place to answer questions consumers didn’t even know they had.

To that end, I bring you some additional thoughts on the role of testing labs at both ends of the quality and transparency spectrum so each reader can decide where they want to reside.

Although I don’t hear this often, I long for the day I will never hear again from an about-to-be former client, “I don’t care about quality, I just want passing results. I can't use ingredients with a failing report.” Then, off they go to a substandard lab (likely tagged with an FDA 483) where they can get the passing result that they needed to sell that batch of substandard ingredient; actual identity be damned. We fail material in identity testing when it is either not the plant it is purported to be based upon ‘Fit for Purpose’ testing conducted utilizing our extensive experience or is not the stated plant part. In other words, it is not the material on the label and will not give the results the consumer expects when they buy and use the finished product. When a batch of substandard ingredients enters the marketplace, it compromises the quality of the products it’s destined for, and in the worst-case scenario, earns an FDA warning letter linking that substandard ingredient to a multi-state pathogen outbreak with numerous confirmed cases and multiple deaths. That’s just one example outlined in a recent FDA warning letter to a testing lab.

The cGMPs were forged leaving too much room for interpretation but just requiring use of a “scientifically valid method." This allowed for strategically unethical substandard labs to exploit the gaping hole of interpretation and service to those who are comfortable with willful ignorance. They rely on their substandard lab, and only care about that passing mark so the ingredients can sell. The coupling of a substandard lab and a willfully ignorant manufacturer can produce a terrible product.

The good news is that the hard work is already done if you are not selling a substandard product manufactured by a substandard manufacturer using substandard ingredients tested by a substandard lab. The remaining step to celebrate your competitive advantage is to differentiate your brand from others with Next Generation Transparency. ingredientsonline.com™ offers C of A’s on lots of specific ingredients we and other handpicked (for good, not evil) labs have tested.

As today’s consumers ask more questions about product quality, forward thinking brands are stepping up with increased transparency into sourcing, research behind ingredients in their formulations and efforts to produce quality products.

One area that is a marketing goldmine is telling the world about your testing program. Some suppliers and manufacturers spend a lot of marketing dollars telling their story. When they also spend a lot of money on product testing to assure identity and strength, but the only people who know about that are the internal team of QA/ QC professionals and auditors, that’s a missed marketing opportunity. We are convinced that consumers would love to hear about that too. We’re so convinced that we’ve developed a template for a consumer-friendly Certificate of Analysis suitable for disclosing because it explains what it says. We’re hoping this will become the next standard “best practice” in the industry.