Thursday, January 29, 2015

Finally! Caffeine Regulations I can SUPPORT!

According to an article by Nutritional Outlook, six senators are urging the FDA to immediately ban the marketing and retail sale of pure caffeine. This is the FIRST caffeine regulation I can really get behind, and here's why:

This proposal addresses a legitimate safety issue; unlike some of the proposed energy drink bans, regulations to ban the sale of pure caffeine are a necessary step toward ensuring safe caffeine consumption.

Now, before you jump up and down with all the reasons you think energy drink bans are good, let me just say this: V8 V-Fusion has 80 mg of caffeine from green tea. This is an energy drink, but would you have a problem letting a 12 year old drink it? V8's energy drink has the same amount of caffeine as an 8 ounce Red Bull, but they both that LESS CAFFEINE (and potentially less sugar) than a tall mocha from Starbucks. 

The rest of my arguments against energy drink regulations can be found here ("Why You Could Get Carded for Buying a V8"), here ("NY Bans Marketing of Red Bull but Misses the Bull's Eye"),  and here ("Save Lives by Focusing on the Source of the Problem"). 

Senator Blumenthal (D-CT) is one of the six senators proposing this pure caffeine ban, and I have NOT been a fan of his other caffeine regulation proposals (see "Which comes first: supplement safety laws or the power to enforce them? The Durbin-Blumenthal Dietary Supplement Labeling Act").

But for this one time, I will stand with the Senator and support this pure caffeine ban.

Perhaps the best argument FOR this proposed ban on pure caffeine sales is the following stat:

A single teaspoon of pure caffeine is roughly the same amount of caffeine as 25 cups of coffee, according to FDA.

Source: http://www.nutritionaloutlook.com/150129/caffeine
No consumer needs pure caffeine. If you're buying pure caffeine to make your own energy drinks in your basement so you can sell them online, I am not okay with that. As a food scientist quality assurance professional, and caffeine consumer, everything about that situation scares me.
Dear FDA, I know you're under-staffed, under-appreciated and over-worked, and I know you've got your hands full with the necessary FSMA regulations. But can you do us all a favor and please, please, do something (swift) about this request. It'll make Mr. Richard Blumenthal (and Mr. Sherrod Brown) very happy.
-GreenEyedGuide

Related Posts:
Putting Caffeine in Gum is a BAD IDEA, here's why...
Friends with the Monster? Three Crucial Counterpoints to the Energy Drink Debate

Friday, January 23, 2015

Energy Drink of the Month -- Jan 2015

Do you believe in destiny? I'm not talking about "That wizard came from the moon" Destiny; I'm talking about strange coincidences that catch you by surprise and make you smile. This month's pick happens to be the source of such a surprising coincidence. It's a product I've wanted to talk about for a while, but was waiting for the right opportunity. Little did I know the stars would align when that opportunity came along.

The Energy Drink of the Month for January 2015 is Steaz Blueberry Pomegranate Organic Iced Green Tea. 

Keep reading-->

 

Saturday, January 17, 2015

Ingredient Testing -- Day in the Life of a Food Scientist Quality Professional



I spend 20 hours per week on ingredient testing. That may come as a surprise because I work for a supplement company. 

I am a Quality Assurance Specialist, but I feel "Raw Material Specialist (Extraordinaire)" is a more appropriate title. I manage projects involving development of raw material specifications. Ingredient testing is a large part of that, and thus, a large part of my job. 




Three Steps of Ingredient Testing
Sometimes we need to find a new ingredient for a new product; sometimes we need to qualify multiple suppliers of the same ingredient to make sure there's enough supply to meet demand. Before we can put use an ingredient in our product formulas, the ingredient needs to pass three steps of testing. 

 

ONE-Review Supplier Testing
From: http://www.lifedaily.com/15-cynically-humorous-mark-twain-quotes/

It's hard to get the Product Development (PD) team to taste something unless they're confident it's safe. Before they do any organoleptic testing (read: taste-testing), they review the documents the supplier has provided with the sample. These documents are usually in the form of a Certificate of Analysis and/or Product Data Sheet. If there's no micro testing data provided whatsoever, that sample drops to the Not Urgent, Not Important Steven Covey quadrant. Luckily, there's rarely a sample that arrives without some sort of testing information. 

 

TWO-Send Samples Out for Testing


Once the PD team has completed their document review and organoleptic testing, they bring me "presents". That's what we call them, because I love getting new samples to send out for testing. Before I can send the samples out, I need to complete my own document review, including a preliminary Risk Assessment – and I LOVE doing Risk Assessments. Risk Assessments are like an extensive background check for the ingredient.

Let's see, ah, Mr. Spirulina is it? Any criminal records I should know about? Have you ever been involved in a FDA recall? How about a case of fraud?

Before I can send a sample out for testing, I need to know what to look for. If I find any recalls for high or unapproved pesticides, I need to make sure I request pesticide testing. If I find reports of economically motivated adulteration (like putting vegetable oil in something labeled 100% EVOO), I might test for identity or potential adulterants. Even if the ingredient has a clean slate, I'm testing it for Heavy Metal content and pathogens like E coli, Salmonella and Listeria. 
[For more on the Risk Assessment process, including the top 5 most surprising discoveries I've experienced, see the next post]




THREE-Review Test Results

I swear some suppliers must have a secret stash of "the good stuff" they use exclusively for sending to potential buyers, not for manufacturing. When the results come back for an ingredient I sent out for testing, I compare those results to the supplier's ingredient specification.

It says here on your Product Data Sheet, your limit for lead is 3 parts per million (ppm), but our test results came back at 0.02 ppm. Are you just overly cautious or is there some crazy fluctuation I should know about?

Sometimes an ingredient supplier will have a "rainy day spec", one with limits and tolerances so wide or so high that even on the worst of days, their ingredient output is still "acceptable". Don't panic – even ingredients that approach those limits of the "rainy day spec" are safe, they're just not the best quality. There's nothing wrong with a load of spirulina powder that has a lead content of 2.9 ppm, but HOLY SMOKES BATMAN! There's no way I'm going to put an ingredient like that into a product with 70 other ingredients – imagine if they all were allowed to have up to 3 ppm of lead! 

Reviewing the test results is the end of the road for some ingredients. If their heavy metal contents are too high, if the microbial load is too risky, or the results of the other tests are not acceptable, it's a sign this ingredient is not suitable for use in our particular product. This ingredient could be fine for another product, but I always review the results with our finished product in mind. Our products are not baked, frozen, hot-filled or pasteurized, so our expectations and criteria are going to be different than that of products who are manufactured this way. 

If all the results are acceptable to our criteria, the ingredient passes to the next phase of product development. We may have to negotiate with the supplier on new heavy metal limits ("Can you only send us shipments that have less than 1ppm of lead?) or additional testing ("Can you start testing every shipment for salmonella? I know you don't do that now, but our finished product isn't cooked so we need this test done."). Negotiation and specification alignment can be tricky, but having testing data is crucial to identifying the ingredients that will be approved for use in our finished product.



BOTTOM LINE
The people I work with come from big food companies like Kraft, Mars, Nestle, Fresh & Easy (TESCO), and supplement companies like HerbaLife. For them, this ingredient testing process is normal. Granted, not all supplement companies have the same protocol, but companies that manufacture both supplements and food/beverage products are more likely to have these systems in place. Yes – there are undeniably some mischievous supplement companies out there, but certainly not all supplement companies are like that. In my opinion you can usually detect the sketchy supplement companies by their ads, commercials or label claims.
 
Related Posts:

Next Post in the Series: Fun with Risk Assessments! The 5 Most Shocking Risk Assessment Discoveries (click here!)