The American Herbal Products Association (AHPA) has published an open letter to the editor of Consumer Reports magazine, in response to an article titled "Dangerous Supplements: Still at Large" in the May issue of that publication. The full text of the letter is printed below for review and comment.
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April 28, 2004
Consumer Reports Letters to the Editor 101 Truman Avenue Yonkers, NY 10703-1057
An article in the current (May 2004) issue of Consumer Reports titled "Dangerous Supplements: Still at Large" identifies ten herbal ingredients or constituents as "too dangerous to be on the market." While some of the information provided in this article is accurate, much of it is exaggerated and some is false.
The American Herbal Products Association (AHPA) has no disagreement with Consumer Reports' advice to avoid internal consumption of four of the identified herbal substances. The safety concerns associated with aristolochic acid, for example, are sufficiently well established to support removal from the market of any product containing herbs in which this compound occurs.
The article fails to report, however, that products that contain aristolochic acid are illegal. Contrary to the statement tha "until very recently the U.S. Food and Drug Administration (FDA) had not managed to remove a single dietary supplement from the market for safety reasons," FDA has used its current regulatory authority to identify products containing aristolochic acid as "adulterated" - and adulterated products are illegal products. This was not news to AHPA when FDA took this action in 2000, and AHPA had provided information to its members regarding the potential substitution of species of aristolochia as early as 1997.
Similarly, AHPA agrees that comfrey should not be an ingredient in any dietary supplement unless the potentially toxic compound that naturally occurs in this plant is first removed. This has been our formal position since 1996, which was five years before FDA acted, again by identifying comfrey as adulterated. Both FDA and the Federal Trade Commission have since acted, under their existing authority, to remove from the market products containing comfrey.
Also, the herb germander has no legitimate place in the market, but it is disingenuous of Consumer Reports to fail to disclose that the company that was identified as offering this plant for sale also warns consumers not to use the herb without the advice of a healthcare practitioner - and any knowledgeable practitioner (even if they have not subscribed to the magazine) will warn against its use.
In addition, AHPA and its members are aware of the concerns associated with oral consumption of pennyroyal oil, and have recommended that pennyroyal herb not be used by pregnant women. The dangers identified in the article for pennyroyal oil are not, however, necessarily relevant to the herbal products that were identified in the article.
At the other extreme, AHPA strongly contests the listing of skullcap as presenting a danger of "abnormal liver function or damage." The only suggestion of such a danger was associated with an incident of misidentification of skullcap in a product that, in fact, contained germander and did not contain skullcap.
With regard to the other five herbs listed in this article, the evidence on each of these suggests that consumers who choose to use these products should be provided with information to assist them in making such choices. AHPA recommends, for example, that kava products bear a serious warning statement about the potential risk of liver toxicity that has been identified by FDA as "rare." Though chaparral is not broadly sold, AHPA recommends that all such products also inform consumers of potential liver risks, even though such risks are based on similarly rare reports of side effects. In addition, many products that contain bitter orange caution consumers to consult with a healthcare practitioner prior to use. Each of these five herbs can be used with respect and with knowledge - but that is true with every herb that is available as a dietary supplement. Respectful and informed use, however, is far from Consumer Reports' advice to avoid all use of these herbs.
Michael McGuffin, President American Herbal Products Association