The American Botanical Council (ABC) recently announced the availability of new and revised documents through their Botanical Adulterants Prevention Program (BAPP). BAPP is an initiative of ABC, American Herbal Pharmacopeia (AHP), and National Center for Natural Products Research (NCNRP). Designed to fairly protect the interests of all suppliers, buyers, and third-party laboratories, these documents are intended to provide common language with clearly defined and referenced regulatory definitions to reduce the incidence of and possibly eliminate the resale of irreparably defective articles. ABC invites comments from members of the ingredient supply chain on the expanded documents by Monday, December 14th. If you submit comments to ABC, please also send CRN a copy of those comments (send to rdenton@crnusa.org).
In Fall 2018, CRN participated in the initial comment period of the first draft documents, which consisted of the Supplier-Buyer Contract template and the Standard Operating Procedure (SOP) template. These items were presented to CRN’s Board of Directors in December 2018 for review. The Board endorsed BAPP in concept and also placed a motion to demonstrate CRN’s public support of the self-regulatory program.
The updates to the documents are:
- 15 new/revised definitions, some with footnoted references to statute or relevant guidance documents
- Expansion of the mandatory disposal and destruction of irreparably defective articles section, dispute resolution, and financial responsibilities
- Addition of a Frequently Asked Questions (FAQs) document to explain the thinking on the contract language and SOP
- Addition of the Three-Way Confidentiality Agreement template, which protects interests of the buyer, supplier, and independent third-party analytical laboratory when sharing confidential information needed for potential dispute resolution
Please carefully review the new and revised documents then provide your comments using the Track Changes editing mode in MSWord. Please return the documents, in track changes, via email to bappsop@herbalgram.org by Monday, December 14th and forward a copy to Rashidah Denton upon submission.
To access the documents, please click here. You will be asked to complete a short survey first before accessing the documents.
