We are disappointed that the trade group AHPA has yet to retract it's patently false and misleading statement of November 23 that some of the products that failed our tests of valerian supplements actually passed. Those products failed to meet criteria put forward by AHPA as well as that used by CL. The calculations are straightforward, as explained in our response on 11/24/2010 (
ConsumerLab.com Faults Herbal Products Trade Group (AHPA) for Misrepresenting Quality of Valerian Supplements) and, again, below.
Unless it intends to willfully deceive the public, AHPA should correct itself. AHPA should also report on the actions, if any, it and its members have taken to improve products that failed to contain their listed standardized extracts and one that potentially contained no Valeriana officianalis. In addition, AHPA should correct its statements suggesting that another product that failed testing is identical to a product that was clinically tested. As noted previously, labeling of the product tested by ConsumerLab.com is different from the product noted in the clinical study and the study failed to chemically characterize the product, making comparison to any current product impossible. ConsumerLab.com encourages more clinical trials of dietary supplements and has actively assisted in many studies by independent investigators. However, unlike AHPA, ConsumerLab.com puts more faith in clinical trials conducted independently of a product's manufacturer than in those conducted and paid for by a manufacturer.
When determining the appropriate standards for the valerian review ConsumerLab.com’s research team, headed by pharmacognocist William Obermeyer, Ph.D., found that there were inconsistent standards for valerian between the European Pharmacopoeia (EP) and the United States Pharmacopoeia (USP), although the two are supposed to be harmonized. The 0.17% standard for total valerenic acids was chosen by ConsumerLab.com because it is the most quoted standard for valerian root (ESCOP, EP, Expanded Commission E Monographs, and ABC Clinical Guide to Herbs). ConsumerLab.com’s selection of 3 valerenic acids (hydroxyvalerenic acid (HVA), valerenic acid, and acetoxy valerenic acid) to represent “total valerenic acids” was based on discussions with the American Herbal Pharmacopoeia in order to give a better picture of the total valerenic acids. While AHPA claims that different standards should apply to cut versus dried whole herb, previous work conducted by Bos 1997 showed no difference in content in valerenic acids when comparing these two vastly different drying methods. ConsumerLab.com also found that there is very little written on fresh valerian root. The Expanded Com. E (pp 396-7) notes that fresh undried valerian root must contain not less than 5% (v/m) volatile oil and the botanical identity must be confirmed by TLC, macroscopic, microscopic examinations and organoleptic evaluation. The ESCOP valerian root monograph requires that the material comply with the European Pharmacopeia.
Unlike other third party testing organizations that fail to publicly disclose their passing criteria, ConsumerLab.com freely published its criteria for testing valerian products on its website when it reported its test results, per its protocol. The same valerian criteria has been published on our website since our initial review of valerian in 2004. However, in its apparent haste to defend the quality of certain brands of valerian that failed our testing, AHPA personnel chose to ignore the freely available criteria used by CL to test valerian supplements, which was based on the total amount of 3 valerenic acids. Consequently, AHPA declared on November 23 that some of the products that failed CL’s testing actually passed the EP standard based on 0.10% total valerenic acids, despite the fact that this standard is based on the total of only two valerenic acids. ConsumerLab.com noted on November 24 that the products in question do not meet AHPA’s suggested standard, falling short of 0.10% valerenic acids based on the 2 valerenic acids.
Anyone truly concerned about the quality of dietary supplements should understand the fundamental differences between the goals of ConsumerLab.com and AHPA. AHPA's mission is to represent and promote the herbal products industry. ConsumerLab.com mission is to help consumers identify the best quality health and nutrition products through testing. The question in our minds at ConsumerLab.com when we choose criteria for evaluating supplements is not "what are the minimum standards required by a manufacturer?” but "what criteria best meet the needs of consumers, including our own families, who rely on our information?" It should not be surprising that the criteria selected by ConsumerLab.com often exceed the minimums chosen by the industry. This explains why, for example, we hold herbal products to the strict California State limit of 0.5 mcg of lead per daily serving, as opposed to AHPA's preferred limit of 10 mcg of lead per daily serving. Eleven years of product testing show that our standards are not only achievable, but that many of the products on the market can meet our criteria.