AHPA to Create ODI Database

The American Herbal Products Association (AHPA), Silver Spring, MD, has requested that its members and others that have sold dietary supplements and dietary ingredients since at least 1994 submit information to AHPA that records which “old dietary ingredients” (ODIs) they marketed prior to October 15, 1994. AHPA is specifically soliciting pre-1994 printed records, such as labels, product catalogues, invoices, packing lists, certificates of analysis, product specification sheets, and production or packaging records, which document the marketing or sale of individual dietary ingredients or their presence in a company’s product line. AHPA intends to use this information to create a centralized “ODI Substantiation Database.”
When the Dietary Supplement Health & Education Act (DSHEA) became law, it defined the term “new dietary ingredient” (NDI) as “a dietary ingredient that was not marketed in the U.S. before October 15, 1994.” DSHEA also stated that the term “does not include any dietary ingredient which was marketed in the U.S. before October 15, 1994,” and the industry has come to refer to these prior-marketed ingredients as ODIs.
“As we approach DSHEA’s 12th anniversary, we need to preserve the records that substantiate which ingredients were already in the market,” stated Michael McGuffin, president, AHPA. “This will become even more important as more years pass, so now is the time to consolidate the records of the industry’s historical uses.”
AHPA has already initiated the first stages of this program, as it is in possession of numerous dated herb catalogues from 1994 and earlier. Companies that provide additional information now will receive a discount for accessing the information that will be contained in the AHPA “ODI Substantiation Database.”
To participate in this “call for records,” please send copies of any dated materials with a date earlier than October 15, 1994. The most useful records will be those that clearly identify the ingredients included in products that were marketed in the U.S. prior to that date, in a form that would today be recognized as a dietary supplement. As noted above, these may include product catalogues; production or packaging records; label printing records; invoices; packing lists; certificates of analysis; product specification sheets; or any other information that clearly establishes the marketing of the ingredients. Records should describe the ingredient(s) in as much detail as possible. Where appropriate, you may redact the information to remove confidential or proprietary information (pricing, customer names, etc.), or request AHPA to redact it for you. Send all records to: AHPA ODI Substantiation Database, 8484 Georgia Ave., #370, Silver Spring, MD 20910.