Ingredient adulteration—what you need to know now!

By definition, adulteration means, “to make impure by adding extraneous, improper or inferior ingredients.” The FDA/USDA considers “adulteration a legal term if a food product fails to meet federal or state standards. This usually refers to noncompliance with health and safety standards as determined in the US, by the FDA and the USDA.”
In a recent FDA warning letter to TerraVare, Inc., dated 7/12/16, the FDA stated: “These violations cause your High Frequency Super Food Formula dietary supplement products to be adulterated under Section 402(g)(1) of the Federal Food, Drug, and Cosmetic Act (the Act) [21 U.S.C. §342(g)(1)] because they have been prepared, packed or held under conditions that do not meet the CGMP regulation for dietary supplements.”
Adulteration can happen in many forms. One example is adulteration with illegal or tainted substances. Other issues may include heavy metal contamination; high level microbiological counts; and residues like pesticides or solvents. Testing is the key to knowing exactly what is in your products, although not every adulterant can easily be found. However, if you are testing for known contamination and adulteration potentials, this is a great place to start finding any problems.
Case in point—in 2013, an enzyme recall occurred after chloramphenicol, an antibiotic drug residue, was found in digestive enzyme products. No one would have ever expected an adulterant or illegal substance in this type of product. As a result, many enzyme manufacturers now screen incoming raw materials for chloramphenicol, as it’s now considered an adulterant to watch for in these types of products. Subsequentially, testing for chloramphenicol residue in enzymes is now a normal quality check, performed routinely in our lab.
When choosing what testing is needed for your materials, you must evaluate the product for known contamination risks. Since botanical or herbal ingredients are grown outside, potentially coming in contact with pesticides for insect control, a pesticide residue screen would be able to verify that the botanical is clean and free from any pesticide residue. For botanicals labeled organic, this is even more critical, as unintended contamination from pesticide runoff in other fields could have occurred. The pesticide residue must be monitored to ensure that the material would not be considered adulterated
Plant material and anything grown in the soil, is also susceptible to higher heavy metal and microbiological counts in countries with crude waste disposal or poor water quality. Botanical ingredients must be tested to ensure that they are safe for human consumption. Also, since microbiologic counts could be high in botanical materials, processors may use irradiation treatments to help lower the bacterial counts. In many countries, including the US, materials that have been irradiated must be labeled as such. USP <2250> Pulsed Photo Simulated Luminescence (PPSL) was added to the USP in 2015 as a testing method to detect irradiation of ingredients. Testing to determine if your material has been irradiated will allow you to label your finished product correctly.
Adulteration of products is serious business, as many high-profile supplements have been abruptly yanked off the shelves by the FDA because they included illegal ingredients. It is imperative to make sure your product matches your label claims and is free of any unintended ingredients. Your quality team will be tasked with deciding what testing is needed for each material that will be used in manufacturing, and knowing who to call for your testing needs is paramount. Just know, SORA Labs is always here to help with testing any of your testing needs—let us be an extension of your quality team!
 
 
 
 
 

Taking the Mystery out of Enzyme Blends

Enzyme blends are complicated to understand, but appropriate testing can help solve the mystery that is often associated with these. There are several recommended tests for enzyme products that are identified by Good Manufacturing Practices (GMPs). These include: identity, potency, contamination and/or adulteration
It is possible to identify enzymes in a blend with mini-assays for many of the common enzymes on the market. These ID tests are not FTIR fingerprint tests, but instead show that the enzyme is still working and has not been deactivated by heat or humidity. If the enzyme in the blend does not have this wet chemistry identity test available, then the full potency assay could be completed with the ID listed as “positive per assay.”
For enzyme potency claims, most manufacturers measure enzyme activity units, “by input.” This is applicable because enzymes have interactions that are unique to each blend. When trying to follow GMP’s and FDA regulations, it’s important to test your finished products to meet all label claims. Testing of the blend is possible, but your results may differ from the “input” activities on the label because by definition, enzymes are proteins that act as catalyst for biochemical reactions. Testing the blends is the only way to fully understand these interactions. Some of the common interactions can be read here.
Since contamination can come from several sources, it is recommended to test enzyme products for common culprits such as heavy metal or microbial contamination. Heavy metal contamination could be introduced with tainted water that is used in the fermentation process or with carriers used in the drying process. Microbial contamination may come from improper handling, dirty equipment or other surfaces that have not been cleaned properly that the material touches.
Product adulteration, often the result of supplier mistakes or dishonest practices, may be difficult to identify. Research should be done to determine if there are any known adulterants for that specific material. While it’s impossible to test for every adulterant known for each ingredient, we can certainly test for specific ones that have been found to be an issue in the past. One known adulterant affecting the enzyme market is chloramphenicol. Chloramphenicol is an antibiotic that was used overseas to clean equipment or control microbial growth and consequently became a residue in finished material. With chloramphenicol being a known issue, material screening can effectively identify the presence of chloramphenicol residue. SORA Labs developed an in-house validated chloramphenicol testing method based on the FDA LIB4306. This in-house method specifically detects chloramphenicol in the enzyme matrix using the HPLC MS/MS. A proud accomplishment, SORA was recognized at the NA Residue Conference for outstanding development. More information on chloramphenicol testing can be found here.
Enzyme blends are complex, but choosing the right testing lab will go a long way in demystifying what testing is needed to ensure your products are safe and of the highest quality. SORA Labs has the enzyme expertise with this matrix and many other enzyme activity methods on their ISO 17025:2005 scope of accreditation. Let SORA Labs solve your enzyme testing mystery today!

Arsenic, Cadmium, Lead, and Mercury…Why Should You Care?

Heavy metals—What are they and why should you be concerned about them? The elements known as heavy metals include arsenic, cadmium, lead and mercury. These elements can be present in the soil that your materials are grown in or found in facilities where your products are produced. These contaminates can pose a health risk to your consumers and could even cause poisoning if they are consumed in high enough quantities. Due to their high health risk, the FDA requires testing for these analytes to be compliant with their GMP regulations. You may be asking yourself some questions regarding this testing and SORA Labs is here to answer them! Some of the most commonly asked questions and their responses are below:
Q: What stage of manufacturing can you test for heavy metals?

  • Raw Material
    • When you test your raw materials, you are more likely to catch a “bad” ingredient before you add it to your blend and ruin your entire batch.
  • Finished Products:
    • Finished product testing confirms that the product meets required standards once all ingredients are blended and no heavy metal contamination occurred during the manufacturing process.

Q: Why Choose the ICP-MS method?

  • There are other methods that can be utilized for heavy metals analysis, however, ICP-MS allows the laboratory to achieve lower detection limits when compared to ICP-OES. This lowered detection limit allows for more accurate and precise data on your product.
  • Prop 65 requires certain limits of heavy metals to be met. Some prop 65 results can be obtained by ICP-OES; however, the serving size becomes a large factor. By using ICP-MS the factor of serving sizes becomes less of a deterrent. We are now able to achieve prop 65 levels on a larger variety of serving sizes.

If you have any remaining questions, please do not hesitate to contact us. SORA Labs would love to assist you with making sure your consumers are getting a top quality product! We offer ICP-MS heavy metal and mineral testing along with many other assays, ID and contaminate testing needed in the dietary supplement industry. Contact us today!