The Revision of Herbs of Commerce

Transcription

1 The Revision of Herbs of Commerce Michael McGuffin Michael McGuffin is the President of the American Herbal Products Association. He has been active in the herbal industry since 1975, having owned and managed both retail and manufacturing businesses in this field. He is the Managing Editor of Botanical Safety Handbook (1997) and of Herbs of Commerce, 2nd edition (2000). He also serves as Treasurer of the American Herbal Pharmacopoeia, and as a Board member of United Plant Savers. by Michael McGuffin Backgound In an effort to reduce the confusion associated with labeling of botanical ingredients in herbal products, the American Herbal Products Association (AHPA) published Herbs of Commerce in 1992 ( HOC1 ). This work established a single standardized common name for each of the nearly 600 broadly distributed herbs listed in the book, recognizing that many of the herbs in trade had come to be known by various common names. Shortly after publishing this reference AHPA recommended that its members adopt its standardized common names in labeling their products. This recommendation took on greater significance in 1997 when the Food and Drug Administration (FDA), in implementing the Dietary Supplement Health and Education Act (DSHEA), determined that The common or usual name of ingredients of dietary supplements that are botanicals (including fungi and algae) shall be consistent with the names standardized in Herbs of Commerce, 1992 edition. Even prior to this acceptance of HOC1 by FDA, AHPA had initiated a revision of the first edition. The primary consideration in taking on this task anew was to expand the number of plants for which common names would be standardized. The resultant Herbs of Commerce 2nd edition ( HOC2 ) was published in October 2000 and listed just over 2000 species. Regulatory Implications The language of the US regulatory code quoted above has a very specific regulatory intent and implication: FDA now requires that the common name of the herbal ingredients in dietary supplement products be the same as the standardized common name given in HOC1. The current Federal regulation has no direct bearing on the common names of herbs that are used in other products such as conventional foods and cosmetics. Also, FDA has not adopted the Latin names given in HOC1, and in fact the same rule cited above states that Any name in Latin form shall be in accordance with internationally accepted rules on nomenclature, such as those found in the International Code of Botanical Nomenclature. AHPA has requested that FDA give consideration to revising their labeling rule for supplements to incorporate the more thorough HOC2. AHPA has not requested that its new work be used by food or cosmetic marketers nor that the Latin names in HOC2 take on a greater significance than the internationally accepted rules. Determination of Common Names in HOC2 In approaching the assignment of a single standardized common name (SCN) to each of the plants listed in the revised HOC2 the greatest emphasis was placed on consistency. The following criteria were established and prioritized: the SCN should be the name of the plant, not the name of any particular part or product of the plant the SCN should be in English except where a non English name has been well established the first preference for an SCN is any broadly established English name unless the use of that name is likely to result in confusion absent a broadly established English name or when such name is likely to result in confusion the next preferred SCN is either: the name of the genus if such name is generally established and the use of that name is not likely to result in confusion, or the Latin binomial for all plants listed in HOC1 the first preference for the SCN in HOC2 was to accept the name given in the first edition except when such given name was inconsistent with the above criteria There are exceptions to most of the above criteria. For example, while the name bloodroot includes the name of a plant part, that name is widely accepted as the common name for Sanguinaria canadensis. Yerba santa, though not English, is the broadly used name for Eriodictyon californicum. The use of the genus name as the SCN deserves some additional examination. This use is quite widespread in the naming of plants directly borrowed from the Chinese herbal tradition (e.g., astragalus). Examples of such use also include, however, common plants such as lobelia (Lobelia inflata), sassafras (Sassafras albidum), luffa (Luffa spp.), and hibiscus (Hibiscus spp.). As a general rule, the genus name is accepted as the SCN for a particular species only if it is the only species within the genus for which the unmodified genus name is generally used (sassafras), or if there are several species for which interchangeable use is accepted (luffa and hibiscus). Quite a few of the listed 40

2 Green Notes species of Chinese plants fall into this last category, as it is not uncommon for related species to bear the same common name. In some instances where several species of the same genus are in trade, the unmodified genus name, if used as an SCN, is assigned to the one species with the most established history of use (Lobelia inflata = lobelia). In these cases, the other species receive a different SCN that consists of either a modified generic name (Lobelia siphilitica = blue lobelia; L. laxiflora = Sierra Madre lobelia) or an entirely different common name (Lobelia cardinalis = cardinal flower). Determination of Latin Binomials in HOC2 The primary focus of HOC2, like the first edition, is on the standardized common name for each of the entries in the revised reference. Nevertheless, the review process included qualified taxonomic experts, specifically Drs. John Kartesz and Art Tucker, and expended considerable resources in assuring accuracy in the given Latin names. An issue that has often come between taxonomists and others whose work is linked to the use of plants is the tendency of the taxonomists to change their minds on too regular a basis. Witness the following complaint, written over a century ago by a physician in the introduction of his work on the homeopathic use of saw palmetto: The genus Sabal embraces six or eight species, five of which are found in Florida and other Gulf States. Some officious botanist removed the Saw Palmetto from this genus and made it a monotypic member of a new genus Serenoa There was no occasion for such a change. It only renders the study of botany more difficult and serves no practical use (Hale, EM; 1898; Saw Palmetto; Philadelphia: Boericke & Tafel). One hundred and three years later the confusion between Sabal and Serenoa has been largely forgotten, and it would likely be considered newly officious for a taxonomist to suggest that Sabal serrulata be reestablished for the plant that is now widely known as Serenoa repens. There are other genera, however, that are broadly used today by herbalists and by marketers and that have been subjected to more recent revisions. These include Senna and Cassia, Actaea and Cimicifuga, and Acanthopanax and Eleutherococcus, to name a few. The approach taken in the production of HOC2 was that of simply accepting the taxonomist community as the expert in the area of taxonomy. The key references for determination of the current accepted status of conflicting nomenclature were authoritative databases that have developed review processes for the specific purpose of making such determinations. The most important and most often accessed of these were those which provide systematic reviews of taxonomic accuracy, and so included the USDA s Agricultural Research Service s Germplasm Resources Information Network (GRIN); the Integrated Taxonomic Information System (ITIS) maintained by the Smithsonian Institute for a U.S. Federal interagency group; and Flora Europa. In the absence of opinions from these authorities or when these references were in disagreement, preference was given to the view of the experts on the editorial committee (again, Drs. Kartesz and Tucker). Also, as stated in that Introduction to HOC2, it is important to note that determination of such status [as the accepted name] depends on taxonomic study and opinions that are prone to revision from time to time. Editors and Reviewers This author (Michael McGuffin) served as the Managing Editor for HOC2. The Taxonomic and Technical Editors of the revision were John T. Kartesz Ph.D., Director, Biota of North America Program, University of North Carolina at Chapel Hill; Arthur O. Tucker Ph.D., Research Professor of Agriculture and Natural Resources, Delaware State University; and Albert Y. Leung Ph.D., a pharmacognosist and co author of Encyclopedia of Common Ingredients Used in Foods, Drugs and Cosmetics. The work was subjected to significant review at several stages. All AHPA members were specifically invited to participate in reviews and several of these provided meaningful input. The most active of these, as identified in the Acknowledgements that precede the text, were: Roy Upton; Daniel Gagnon; Kay Wright; Bill Popin: Ahmed Warfa; Josef Brinckmann; and Steven Foster. Botanical Nomenclature for Herbal Practitioners The following lists, excerpted from the Exam Topics Study Guide for the National Botanical Medicine The common or usual name of ingredients of dietary supplements that are botanicals (including fungi and algae) shall be consistent with the names standardized in Herbs of Commerce, 1992 edition. Journal of the American Herbalists Guild 41

3 Certification Examination of the American Herbalists Guild and Botanical Medicine Academy (publication available through the AHG) are not exhaustive and include only those herbs most commonly used or considered important to know by clinical practitioners in the United States, as determined by surveys conducted by the American Herbalists Guild and Botanical Medicine Academy in They reflect the most recent changes found in Herbs of Commerce 2. More on AHPA and Botanical Name Changes: Notes from Personal Correspondence Scientific Binomial Changes Old Scientific Binomial Agropyron repens Alchemilla vulgaris Anemone pulsatilla Anemone pulsatilla Barosma betulina Berberis aquifolium Cassia senna Ceanothus gregii Cimicifuga racemosa Erigeron canadensis Euphrasia officinalis Euphrasia officinalis Lavandula officinalis Piscidia erythrina Populus candicans Rhamnus purshiana Stachys betonica Ulmus fulva New Scientific Binomial Elymus repens Alchemilla xanthochlora Pulsatilla patens Pulsatilla pratensis Agathosma betulina Mahonia aquifolium Senna alexandrina Ceanothus americanus Actaea racemosa Conyza Canadensis Euphrasia rostkoviana Euphrasia stricta Lavandula angustifolia Piscidia piscipula Populus balsamifera var. balsamifera Frangula purshiana Stachys officinalis Ulmus rubra Ed. Note: Michael McGuffin has been kind enough to further explain the origin and meaning of some of the binomial changes. Below are excerts from written communication that Michael has granted permission to publish in the JAHG. Our first goal in managing the revision, though it is not always apparent, was to be consistent. In that regard, we established a system of prioritization to take into account many factors. We always tried to give prece- dence to an actual established common name (established in references, in traditions, or in the marketplace) if such exists and is not confusing (the Federal definition of common or usual name actually states that the name may not be confusingly similar to the name of any other food that is not reasonably encompassed in the same name ). We also gave precedence to English names except when a non English name is well established (e.g., yerba mansa). In the absence of an established (usually English) common name, either the genus name or the Latin binomial was given. Again, there was an attempt to be consistent with the choice of either genus or Latin binomial, with the same emphasis on established use. It was easy, therefore to record the common name lobelia for Lobelia inflata, even as other species of the genus are named, e.g., blue lobelia or cardinal flower. Similarly, the use of the name astragalus is well established for several species of that genus that are broadly used in TCM and sold in the marketplace. As a rule, when only the genus was used as the common name, it was either quite well established in trade (e.g., sassafras) or it was assigned to that species most established (usually traditionally and/or officially established) as the primary therapeutic article of commerce. Other details for which consistency was the target: we tried to remove, as much as possible, any use of the part of the plant in a name (exceptions include, e.g., cardinal flower!); we also gave the name of the plant rather than the commercial product of the plant (so quinine becomes cinchona and Canada balsam becomes balsam fir). In addition, we also tried to find some consensus (if not unanimity) from authoritative references and knowledgeable reviewers that the standardized common name given in the revision have some well referenced basis. Regarding the echinaceas: the choice to give the Latin binomials as the common names for these species was made by the editors of the first edition. In the revision process, our decision to accept this original decision was the result of a two step process. First, it was agreed that there is a need to split rather than group these species since it is generally perceived that the plants are not completely interchangeable as therapeutic agents, Secondly, having decided to maintain separate names, it was believed that the name Echinacea angustifolia is better established, at least in today's marketplace, than narrow leaf echinacea or narrow leaf purple coneflower; the same is true for E. purpurea and E. pallida versus purple coneflower and pale purple coneflower, respectively. In addition, 42

4 Green Notes Common Name Changes Old Common Name New Common Name Scientific Binomial monkshood aconite Aconitum napellus sweet flag calamus Acorus calamus garden angelica angelica Angelica archangelica uva ursi uva ursi Arctostaphylos uva ursi oats oat Avena sativa green tea tea Camellia sinensis false unicorn root false unicorn Chamaelirium luteum greater celandine celandine Chelidonium majus gold thread coptis Coptis chinensis foxglove digitalis Digitalis purpurea purple coneflower Echinacea angustifolia Echinacea angustifolia Siberian ginseng eleuthero Eleutherococcus senticosus ma huang ephedra Ephedra distachya crane's bill cranesbill Geranium maculatum cotton root cotton Gossypium hirsutum gumweed grindelia Grindelia camporum gurmar gymnema Gymnema sylvestre pennyroyal American pennyroyal Hedeoma pulegioides pennyroyal European pennyroyal Mentha pulegium lavender English lavender Lavandula angustifolia bugle weed bugleweed Lycopus virginicus German chamomile chamomile Matricaria recutita partridge vine partridge berry Mitchella repens white pond lily sacred lotus Nelumbo nucifera peony tree peony Paeonia suffruticosa Jamaican dogwood Jamaica dogwood Piscidia piscipula plantain English plantain Plantago lanceolata he shou wu, fo ti fo ti Polygonum multiflorum balm of Gilead balsam poplar Populus balsamifera spp. balsamifera wild cherry black cherry Prunus serotina kudzu, kuzu kudzu Pueraria montana var. lobata rhubarb chinese rhubarb Rheum officinale willow white willow Salix alba willow black willow Salix nigra elder European elder Sambucus nigra elder American elder Sambucus nigra spp. canadensis huang quin Chinese skullcap Scuttelaria baicalensis goldenrod European goldenrod Solidago virgaurea nettle leaf stinging nettle leaf Urtica dioica spp. dioica nettle root stinging nettle root Urtica dioica spp. dioica old man's beard usnea Usnea barbata vervain blue vervain Verbena hastata vervain European vervain Verbena officinalis spp. officinalis blackhaw black haw Viburnum prunifolium periwinkle lesser periwinkle Vinca minor violet sweet violet Viola odorata ashwaganda ashwagandha Withania somnifera prickly ash southern prickly ash Zanthoxylum clava herculis Journal of the American Herbalists Guild 43

5 it is difficult to believe that consumers can readily differentiate the various purple coneflowers based only on the absence or presence of modifiers. It might also be argued that the consumer cannot well differentiate products based on the the differentiation of the several species, but we (and the original authors) made the choices that we believed would most minimize confusion. Different references were accessed for different classes of plants (e.g., mushrooms; Chinese medicinal plants; garden plants; vegetables; etc.). In addition, different reviewers were also somewhat specialized. (See the HOC 2 bibliography for the complete list of accessed references.) In establishing who are the authorities on this subject, we approached this issue by including taxonomic experts in our selection of editors (Drs. John Kartesz and Art Tucker) and by accepting the taxonomist community as the expert in the area of taxonomy. The key references for determination of the current accepted status of conflicting nomenclature were authoritative databases that have developed review processes for the specific purpose of making such determinations. The most important and most often accessed of these were those which provide systematic reviews of taxonomic accuracy, and so included the USDA s Agricultural Research Service s Germplasm Resources Information Network (GRIN); the Integrated Taxonomic Information System (ITIS) maintained by the Smithsonian Institute for a U.S. Federal interagency group; and Flora Europa. In the absence of opinions from these authorities or when these references were in disagreement, preference was given to the view of the experts on the editorial committee (again, Drs. Kartesz and Tucker). from the heart of the Earth The book you have been waiting for! Detailed information on 170 herbs. 102 compound formulas. Learn how to care for your own and your family s health with herbs. Valuable charts & more! To order call: (Discounts available for multiple copies.) $ pages ISBN What the experts have to say: "Dr. Tilgner has written an impressive, well-researched guide on the use of herbs that professionals and lay people alike will find very practical and informative." - Christiane Northrup, M.D. "A wonderful guide for those new to herbs as well as an excellent formulary for those already skilled in herbalism." - Rosemary Gladstar, author, herbalist, founder of United Plant Savers "This book is broad enough in scope that it contains within it material enough for three books." - Paul Bergner, Medical Herbalism "Sharol's new book is an interesting and useful contribution, with surprising new information, conveniently packaged." - Jim Duke Ph.D., author of The Green Pharmacy "This is an important text for the budding herbalist, and a handy reference for the experienced clinician. A most valuable and useful addition to anyone's herbal library." - Jill Stansbury, N.D. 44