[MPWG] Transparency clarifications

Patricia_DeAngelis at fws.gov Patricia_DeAngelis at fws.gov
Wed Dec 8 09:14:52 CST 2004


Two things here -

1. I wonder if Mark Blumenthal is nearby and might comment on the new
labeling system that ABC worked on - does this address the transparency
issue, and if so, how?

2. Also, isn't there a role for the Certificates of Analysis (COA) in all
of this?

A COA is generated (all the time?) at some point between being dug out of
the ground (or picked, cut, etc.) and reaching the manufacturer.  The
information on these COAs already help to identify the quality and source
of the material.  I understand that there is some discussion as to when and
who should be responsible for generating the COA.  Perhaps my industry
colleagues will comment on this.

But, I'd also like to hear from you with respect to a broader use for the
COA - in commerce, for instance.   From a CITES perspective, a big
difficulty comes in trying to identify materials in trade.  When a dry,
brown powder comes to a port/border, the COA could serve as the
identification tool.  I mean, the COA is already being generated, couldn't
it be tweaked a bit to fit this need?

-Patricia

Patricia S. De Angelis, Ph.D.
Botanist - Division of Scientific Authority
Chair - Plant Conservation Alliance - Medicinal Plant Working Group
US Fish & Wildlife Service
4401 N. Fairfax Dr., Suite 750
Arlington, VA  22203
703-358-1708 x1753
FAX: 703-358-2276
Working for the conservation and sustainable use of our green natural
resources.
<www.nps.gov/plants/medicinal>



                                                                                                                                                   
                      DianeDonCarlos at aol.com                                                                                                       
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                      rvation.org                           Subject: [MPWG] Transparency clarifications                                            
                                                                                                                                                   
                                                                                                                                                   
                      12/08/2004 08:43 AM                                                                                                          
                                                                                                                                                   
                                                                                                                                                   




clarifications-
I was not suggesting the organic certification process as the transparency
solution for herbal products i.e.  all herbal product should be "organic".
I was suggesting that organic certification-the document, the process- be
used as a model for developing an herbal certification and/or the
beginnings of full disclosure labeling of herbal products.

Agreed that transparency isn't the only issue, but I feel it is paramount.
I believe in the power of the consumer. I believe in the intellect and
decision making if the consumer. If we have full disclosure on the label
for the contents of the product, then the consumer is faced with a decision
i.e. Certified Organic Ginseng vs. Wild Crafted Ginseng vs. Standardized
Ginseng---the consumer now has three choices and must become educated in
order to make the purchase. Somewhere in that process the consumer might
discover CITIES and a host of other information. Of course there are those
who simply make a purchase based upon price. But others, many others, want
to know the difference and will investigate. Education begins with the
label. Labels are on every bottle. The label is a powerful tool for raising
consciousness.


Diane Don Carlos
Herbalist, Organic Inspector
Sweet Farm
33735 Beech Grove Road
Rutland, OH 45775
740-742-1714_______________________________________________
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