here we go

[Guest guest]

An FDA Letter to Industry issued on May 16, 2000,

states that it will not release any herbs or herb

products suspected to

contain aristolochic acid from impound until the

responsible party can

provide " direct analytical evidence that (the herb

or herb product) is free

of aristolochic acid. " (FDA Letter to Industry May

16 2000

http://vm.cfsan.fda.gov/~dms/ds-botl1.html)

 

I think the FDA has made up its mind on this matter. The only way we

are getting mu xiang, mu tong and xi xin into this country is with

chemical analysis of each batch to prove the absence of AA. I have

talked to the local FDA public affairs officer and this is not even open

for discussion. We can use the herbs, but we must prove their identity.

 

It is not wholly unfair that we need to be sure what we are using when

potential toxicity is involved. The potential seriousness of this issue

of herb identification was raised almost a decade ago by knowledgeable

parties. Unfortunately, this issue seems to have been dismissed as a

marketing ploy by many px. Only one major chinese herb distributor in

america has made its principal mission correct species identification.

Most others have ignored this complex issue and focused on simplistic,

often unfounded issues, such as confusing the traditional chinese

sulfuring of herbs with modern process of adding sulfites (BTW, the

latter causes allergies in a small number of people while the former is

a constituent of all living tissues - if you were allergic to sulfur,

you would drop dead instantly and for most people the risk is far

greater to consume rotten or rancid herbs)

 

While some people may consider mu tong and xi xin and mu xiang

substitutable, I do not. In fact, it is not possible to practice shang

han lun style herbalism without using mu tong and xi xin. The only

option, it would seem, is to purchase these herbs from someone who can

provide a certificate of analysis. Hopefully someone will see this as

an economic opportunity and our herb supply will not be interrupted.