Best Practices in the Herbal Ingredient Supply Chain

Similar documents
WORKING PARTY ON HERBAL MEDICINAL PRODUCTS (HMPWP)

MOFGA Certification Services Record Keeping Crop Example Forms

COMPLIANCE DATES. Preventive Controls. CGMP Compliance Date. Business Size. Business other than Small and Very Small employees

FDA s Final Rule for Preventive Controls for Human Food

NATIONAL ORGANIC PROGRAM APPLICATION & ORGANIC SYSTEM PLAN - FARMS

Organic Foods in Japan

Criteria for Organic agricultural products

GMP On Site Series. GMP Essentials

TITLE SPONSOR AHPA 2017 SPONSORS

Final Rule for Preventive Controls for Animal Food

TOMATO BEST PRACTICES MANUAL

GOOD AGRICULTURAL AND COLLECTION PRACTICES FOR MEDICINAL PLANTS

FSMA S PRODUCE SAFETY RULE

background info: organic agriculture

Low Risk Medium Risk High Risk My Risk Land is fenced virgin. Land has been used for prairie that has not been

Food Safety Plan. Name of Farm/Orchard. Farm mailing address City State Zip Code. GPS coordinates (optional) Longitude Latitude

FSMA: Understanding FDA s New Food Safety Rules

Food Safety Pest Management & Fumigation Services. Regional Companies Nationwide Service Global Network

USP Pesticide Roundtable: Collaboration Model

DRAFT: FSSC FSMA Comparison

Produce Safety Challenges & Opportunities. Jim Gorny, Ph.D. Vice President of Food Safety & Technology

Overview of Good Agricultural Practices (GAPs) for Fruit and Vegetable Growers Cary L. Rivard, Ph.D. Dept of Horticulture Kansas State University

GROWERS HANDBOOK GOOD AGRICULTURAL PRACTICES

The Food Safety Modernization Act: What Exporters to the U.S. Need to Know. Erik R. Lieberman Prepared for AgroBalt 2014 April 4, 2014

FSMA Regulations for Ethanol Co-Products

Cabbage Industry Challenges & Opportunities

NOA PGS ORGANIC ASSESSMENT

FDA FSMA Timeline. July 29, 2009 House version passed. Nov. 30, 2010 Senate version passed. Dec. 19, 2010 Senate revised version passed

What is organic farming?

20 THINGS YOU NEED TO KNOW ABOUT FSMA

The Quality of Composts: Implications for Use. Jean Bonhotal Cornell Waste Management Institute

GMPs: Distribution Centers

1/29/2016. IFVGA 2016 FSMA Produce Rule Summary FDA FOOD SAFETY MODERNIZATION ACT FSMA FDA: FSMA PRODUCE SAFETY REGULATIONS

EUREPGAP Protocol for Fresh Fruit and Vegetables

Agricultural Audits Organic Jump Start Program CROP

Environmental Health Response to E. coli 0157:H7

FSMA and Grain Handlers

The Food Safety Modernization Act and Its Implications for USDA and Dual Jurisdiction Establishments

GAP & GHP Good Agricultural Practices & Good Handling Practices Audit Verification Program

USDA Good Agricultural Practices Good Handling Practices Audit Verification Checklist

Community Alliance with Family Farmers

Preventive Controls & cgmp s for Animal Food Industry Perspective Michele M. Evans, Ph.D. Diamond Pet Foods

FIELD AUDITING PROGRAM STANDARD OPERATING PROCEDURES SOP

Control Points and Compliance Criteria

Quality Agreements with CMO s. Presented at ASQ Orange Empire Meeting May 13, 2014 By Luke Foo Sr. Director QA/QC Spectrum Pharmaceuticals

Food Safety Modernization Act (FSMA) Key Points for Warehouses. June David Hakes-Regulatory Manager

Updates on Quality Metrics - Industry Perspectives Dan Snider Vice President, Research and Development Mylan Inc.

Preparing for the Food Safety Modernization Act (FSMA) A summary of the FDA s rules, regulations, deadlines, and compliance requirements

Supplement FSSC & FSMA for Human Food FOOD SAFETY SYSTEM CERTIFICATION Supplement FSSC & FSMA for Human Food

EU and FDA GMP Regulations: Overview and Comparison

The Red Seal Your Road to FSMA and Quality Compliance

FairWild Standard Version 2.0. Approved by the FairWild Board on 26th August 2010

While comprehensive, this document does not replace a thorough review of the Rule to assure proper compliance.

FDA Produce Rule 101. WSDA Produce Safety Program. Jill Wisehart, MEd

Good Agricultural Practices. Food Safety Plan. for. Name of Farm/Orchard

Nature of the Agriculture/Horticulture Industry

A Guide to Current Good Manufacturing Practices (cgmp)

AUSTRALIAN CERTIFIED NON-GMO STANDARD. Version 1.0, 2016, Australian Organic Limited

Adding Value with Horticulture Farming

Food Safety Modernization Act: Question & Answer Series on Proposed Produce Safety Rule

ACVM Notice. Agricultural Compounds Exempt from Registration. Requirements for conditions of exemption. 1 August 2017

Version: July 24, 2014

Introduction. SQF Module 7 Final FSMA Produce Safety Rule Comparison. March 2016

Costco Produce Addendum for Harvest Crew Audits

H 5849 S T A T E O F R H O D E I S L A N D

GLOBALG.A.P Version Updates Presentation by: Matt Lomeli Food Safety Auditor

HACCP audit checklist

OECS GAP CERTIFICATION PROTOCOL FOR THE PRODUCTION OF FRESH FRUITS AND VEGETABLES

Watercourses and Wetlands and Agricultural Activities

An FDA Perspective on Atypical Active Ingredients

U.S. FSMA Seminar: Practices

What is Practical Produce Safety?

Food Safety Modernization Act (FSMA): FDA Proposed Animal Feed Rule Florida Overview. Susan Caime Mardenborough September 18, 2014

Feeding the World Farra Siregar Managing Director, DuPont Vietnam

Product Category Rules (PCR) (Approved PCR ID: PA-AA-01)

Food Safety Audit Ranch V07.04 Rev. 1

ORGANIC FARMING DEVELOPMENT IN PROSPECTS AND CHALLENGES

Draft Questionnaire on Cotton Value Chain in India from Environmental Sustainability Perspectives

Food Safety Modernization Act Info Session Revised Handout August 1, 2013 at SOREC

Palm Oil Innovations Group Charter

Appendix B. Sanitation Performance Standards

Our Proposal For Rice Farming in Malaysia. Syntropy Malaysia Sdn Bhd

Floods and Organic Producers: Steps to Recovery after a Natural Disaster

US FDA: CMC Issues for INDs

33. Fate of pesticides in soil and plant.

DOC: QCI-GAPMP-01(W) GOOD AGRICULTURAL PRACTCES FOR MEDICINAL PLANTS-REQUIREMENTS - 1 -

ORGANIC FARMING. Today s Lecture 10/12/2015

PLEASE TYPE IN THE INFORMATION AFIA SAFE FEED/SAFE FOOD GUIDELINES AUDIT

Organic Dairy Certification Requirements Overview

Watershed BMPs. Notes from NRCS online site on BMPs. Focus on key BMPs

What a Preventive Controls Facility Looks Like. FSMA-HARPC vs. HACCP

Modern Forestry: Growing Sustainable Bio-Materials

Good Agricultural Practices (GAPs)

Title: PSU Take-Home Training for Professional Standards: Good Agricultural Practices

USING TITHONIA AS A FERTILISER

PREVENT ERROR PROCESSING: TIGHT CONTROLS PROCESSING >

Certified Non-GMO by AGW

FDA 21 CFR Part 820 vs. ISO 13485:2016 Comparison Table created by greenlight.guru

Hein Voss. Agenda. Sustainable Fashion Entrepreneur. Hein Voss / AQM Quality Control 7 January The Current Situation. Alternatives offered

Transcription:

ACI s 4 th Annual Legal, Regulatory and Compliance Forum on Dietary Supplements June 27-28, 2016 Best Practices in the Herbal Ingredient Supply Chain Michael McGuffin President American Herbal Products Association mmcguffin@ahpa.org Tweeting about this conference?

GACP: Best Practice Seed to Harvest Good Agricultural and Collection Practice GAP: Relevant to farm operations Propagation material (identity; health and cleanliness; purity; organic status; GMO crops) Site selection (fertility; contaminants; location; crop history; Fertilization (choice and identification; application; guidance on both chemical and organic materials (e.g., composted manure) Irrigation (water source and monitoring; irrigation systems; legal conformity) Crop protection and maintenance (cultivation; companion plants; pesticide use)

GACP: Best Practice Seed to Harvest Good Agricultural and Collection Practice GCP: Relevant to wild harvest / wildcrafting operations Permits and permission (public vs. private property) Site selection (species habitat; site history; proximity to features of concern) Collection equipment (materials; maintenance and cleanliness; training and safety) Identification (training & experience; local floras as resources; voucher specimens; plant s life phase; substitutes and adulterants; positive ID) Sustainability (ESA compliance; abundance; population stability; propagation and regeneration; habitat stewardship) Timing of harvest

GACP: Best Practice Seed to Harvest Good Agricultural and Collection Practice Post-harvest handling: Relevant to all operations Handling (containers; avoidance of compaction; protection from contamination; temperature and moisture control) Facilities (light; pest control; order and cleanliness; equipment) Washing and cleaning (water supply; drainage; drying; foreign matter) Dehydration (timing; sunlight and shade; temperature control; air circulation; finished moisture content) Cutting and milling (timing; protection of operators; equipment maintenance; temperature control) Packaging (materials; labeling; storage)

GACP: Best Practice Seed to Harvest Good Agricultural and Collection Practice Personnel: Relevant to all operations Training (relevance to tasks; plant identification; hygiene) Safety (clothing; protective gear; environmental factors; tool and equipment) Hygiene (prevention of contamination; toilet facilities; hand washing; personnel health)

GACP: Best Practice Seed to Harvest Good Agricultural and Collection Practice Record keeping and retentions: Relevant to all operations Agricultural crop harvest records (propagation materials; crop site; agricultural inputs; water source and irrigation; harvest details) Wild crop collection records (permits and permissions; collection sites; identification procedures; collection details) Post-harvest handling records (facility; equipment; operations: washing, drying, dehydrating, cutting and milling, packaging) Personnel records (training; safety and hygiene practices) Retention samples (representative; labeling; storage; sample correlation at each stage of processing)

Good Manufacturing Practice Relevant FDA regulations??? GMP: Best Practice Harvest to Manufacturing 21 CFR 111: cgmp for Dietary Supplement Operations 21 CFR 112: Produce Safety Rules (FDA now has jurisdiction on farms) 21 CFR 117: cgmp for Food Manufacturing Operations / Hazard Analysis and Risk-Based Prevention Control Which apply to herbal ingredient operations?

Good Manufacturing Practice Various herbal ingredient operations: GMP: Best Practice Harvest to Manufacturing Bulk herb supplier for reprocessing / finished product manufacturing ONLY Bulk herb supplier for consumer sale with no further processing Extract manufacturer Extract supplier for reprocessing / finished product manufacturing ONLY Extract supplier for consumer sale with no further processing Etc.

GMP: Best Practice Harvest to Manufacturing Good Manufacturing Practice - Key questions: Should ingredient suppliers conduct at least one test or examination to verify identity for each ingredient? If so, how will the supplier s testing be evaluated? Will ingredient buyers support self-regulatory initiatives? Imposition of GMP guidance for suppliers will only be as good as ingredient buyers make it quality must take precedence over price.

Transparency initiatives Product registry Botanical ingredient cgmp 3 rd party certification Is it time to amend the FDCA (to open up DSHEA )? Other industry needs / consumer benefits? Traditional claims (redefine drug )? Readdress 3rd-party literature in the 21 st century (Internet)? NDI date reset/synthetics/clarifications? Parity on 321 (ff)(3)(b)? State preemption?

Thank you! Michael McGuffin President American Herbal Products Association mmcguffin@ahpa.org