VETERINARY RESIDUES COMMITTEE ANNOUNCEMENT OF THE RESULTS OF THE BRAND NAMING SURVEY OF CHLORAMPHENICOL IN CERTAIN ROYAL JELLY NUTRITIONAL SUPPLEMENTS A survey carried out by the Veterinary Medicines Directorate (VMD) on behalf of the Veterinary Residues Committee (VRC) found residues of chloramphenicol in 18 samples of royal jelly nutritional supplements sold in the form of capsules, tablets or fresh royal jelly out of 71 samples analysed. The VRC is concerned about the findings of the survey, which show a high rate of non-compliance in the samples tested. This survey focused on products containing high concentrations of royal jelly and the Committee is aware that other products are available which contain lower concentrations of royal jelly which have not been the subject of this survey. The Committee recommended that royal jelly in nutritional supplements form should be tested for this antibiotic following a series of Rapid Alert Reports from the European Commission on residues of chloramphenicol detected in royal jelly. Whilst the Committee recognised that it is not a widely consumed product, it was concerned that those who do take it are likely to consume it every day and are therefore high level consumers. Previous brand naming surveys were based on sample collection at Border Inspection Posts (BIPs) and retail outlets. However the number of consignments of royal jelly entering the UK at BIPs is limited. The Committee therefore recommended that this survey focused on retailers and internet suppliers. A total of 71 samples were analysed in the survey which was carried out between September and November 2007. Eighteen samples contained confirmed residues of chloramphenicol. Concentrations ranged between 0.33μg/kg and 21μg/kg. Following the confirmation of these residues the Food Standards Agency (FSA) was informed of the results and trade withdrawals were carried out by the FSA in collaboration with local authorities. The FSA contacted the eleven UK retailers/suppliers of products that tested positive. These companies have informed customers who bought the implicated products of the reasons for the withdrawal and asked them not to consume the product and return it to the company. Chloramphenicol is not authorised for use in the treatment of animals for food production in the EU and may not be used in the production of food of animal origin which is exported to the EU. Chloramphenicol is considered to be a potential genotoxic carcinogen, though the risks from the levels of intake arising from the consumption of royal jelly would be extremely small, especially if exposure were relatively short-term. Medical use of chloramphenicol has also been associated with a rare idiosyncratic aplastic anaemia which can be fatal. However, intakes of chloramphenicol from royal jelly would be seven orders of magnitude lower than medical exposures and any incidence of aplastic anaemia would be expected to be extremely low and unlikely to be distinguishable from a low background incidence in the population. 1 Results of the brand naming survey for chloramphenicol in royal jelly nutritional supplements Summary A survey of chloramphenicol in royal jelly nutritional supplements was carried out by the Veterinary Medicines Directorate (VMD) between September and November 2007. The purpose of the survey was to assess the incidence of residues of this antibiotic in high concentration royal jelly food supplements available from retail outlets and internet sites. The use of chloramphenicol in the treatment of food producing animals is prohibited in the EU and residues should not be present in food products or supplements intended for human consumption. A total of 71 samples of royal jelly were analysed for residues of chloramphenicol. Samples for the survey were purchased from a range of internet sites and retailers by shoppers employed by the market research organisation Mintel International Group Ltd. All the samples were analysed by the Central Science Laboratory (CSL) using a validated method of analysis. Chloramphenicol residues were confirmed in 18 samples. Three samples of ‘pure royal jelly’ purchased from different internet sites were found to be from the same supplier and the same batch of royal jelly. Two samples of capsules purchased from one internet site were identical samples. The Decision Limit (CCα) for the analysis of chloramphenicol in royal jelly is 0.11µg/kg. This limit is in line with the EU Minimum Required Performance Limit (MRPL) of 0.3µg/kg for this substance. Any results at or above the MRPL for chloramphenicol are non-compliant under European legislation. In each case where non-compliant results for chloramphenicol were confirmed, the Food Standards Agency (FSA) was informed. The FSA took consistent risk management action in all cases. Trade withdrawals were carried out in collaboration with local authorities. The FSA contacted all the UK retailers/suppliers of the non-compliant products. These companies have informed customers who bought the implicated products of the reasons for the withdrawal and asked them not to consume the product and return it to the company. In one case a point of sale notice was put up by a retail outlet as they had been supplying the product in store. Where royal jelly products were purchased directly from a non-EU country and EU legislation does not apply, the VMD has contacted the relevant authorities in the non-EU countries concerned, requesting them to take further action. Annex 1 gives details of all the samples collected as part of the survey. Annex 2 gives details of sample preparation and the method of analysis. The results show a high incidence of residues of chloramphenicol in high 2 concentration royal jelly nutritional supplements sold as capsules or fresh product. Background Royal jelly is a product made by bees for the nourishment of larvae developing into queen honey bees. It is sold as a nutritional supplement normally in the form of capsules. Since 2004, the European Commission has reported evidence of residues of chloramphenicol in royal jelly imported into the EU. Eighteen notifications were sent out to Member States under the Commission’s Rapid Alert System for Feed and Food between 2004 and 2006. The concentrations of chloramphenicol detected ranged from 0.6μg/kg to more than 5000μg/kg. Prior to this survey no notifications had been issued in 2007. Legislation EC legislation requires that all active substances used in veterinary medicines for food producing animals must be assessed so that a Maximum Residue Limit can be set. Due to the lack of adequate studies, evidence of genotoxicity in a number of in-vivo and in-vitro tests and the inability to identify a “threshold” level for the induction of aplastic anaemia in humans, no Acceptable Daily Intake or Maximum Residue Limit could be set for chloramphenicol. Chloramphenicol is therefore in Annex IV of Council Regulation 2377/90 and its use in the treatment of food producing animals, including bees, is prohibited in the EU. Countries that wish to export food of animal origin to the EU must respect the requirements of this legislation thus should not contain residues of Annex IV substances. Commission Decision 2002/657 introduced the concept of Minimum Required Performance Limits (MRPLs). This recognises the need for EU harmonisation of analytical detection limits, particularly for banned substances, and is the concentration at which regulatory laboratories should be able to detect and confirm the presence of particular substances. In March 2003 Commission Decision 2003/181/EC set an MRPL of 0.3µg/kg for chloramphenicol in meat, milk, eggs, aquaculture products and honey. Article 2 of Commission Decision 2005/34/EC, states that the MRPLs laid down in Annex II to Decision 2002/657/EC shall be used as reference points for action irrespective of the matrix tested. In practise this means that the MRPL of 0.3µg/kg for chloramphenicol applies to royal jelly and any results at or above the MRPL are non-compliant. Selection of products for testing Royal jelly is a constituent in a number of products including topical creams and nutritional supplements. In deciding the type of product to be analysed as part of this survey there were a number of considerations, in particular, the concentration of royal jelly in the product. Shoppers were instructed to purchase either capsules containing 500mg of royal jelly or fresh royal jelly. The overall sample size was 50g of royal jelly. This sample size ensured 3 sufficient material to complete screening analysis, and confirmatory analysis, should it be required, and to provide sufficient sensitivity to meet the required MRPL for each portion tested. Whilst royal jelly was the main constituent in the products purchased, other minor constituents are likely to have been present including honey and beeswax. Sampling The original intention was to purchase and analyse 100 samples. Sourcing these products at the retail level proved particularly difficult. Shoppers from the market research organisation were unable to find sufficient retailers selling these products to fulfil all the sampling requests because most products on sale had less than the target level of royal jelly per capsule. Out of 50 requested retail samples, shoppers were only able to obtain 27. The majority of these were from health food shops and two chemists, one of which specialises in complementary medicine. Three samples were obtained from two department stores in London. Of these, there were three sets of samples (seven samples in total) where the batch number was duplicated. This was a result of shoppers buying the same product from the same outlet in different parts of the country. At retail level the majority of samples were two brands, Holland and Barrett and Power Health Bumbles. Where capsules/fresh royal jelly were on sale, shoppers also experienced difficulties in obtaining sufficient quantity with the same batch number to meet the 50g requirement. Six of the samples purchased were made up of capsules with more than one batch code. The shoppers who purchased samples from internet sites were more successful in obtaining suitable samples. They were provided with a list of pre-selected sites and the quantity of product required. Out of 50 samples requested 45 samples were purchased. One sample was not analysed because the capsule contained a very highly concentrated form of royal jelly which made it unassayable by the Central Science Laboratory (CSL) method. Of the samples purchased, there were three sets of samples (8 samples in total) where the batch number was duplicated. Details of all samples collected for the survey are given in Annex 1. Results Full results of the survey are detailed in Annex 1. Details of the analytical methods are set out in Annex 2. Eighteen samples were confirmed as non-compliant. The countries of origin were Australia (2 duplicate samples), China (8 samples (3 duplicates)) and the USA (5 samples). In the case of three samples, the country of origin of the raw product is unknown. The VMD wrote to all retailers and suppliers of the products sampled as part of the survey, requesting information on the country of origin of the raw material. 4 In accordance with the FSA survey guidelines, the importers or wholesalers of the contaminated product were asked if they wished to comment on the confirmed results. Comments received are detailed in Annex 3. Risk assessment Chloramphenicol is listed in Annex IV of Council Regulation 2377/90 and therefore is not authorised for use in the EU. Chloramphenicol is genotoxic and therefore assumed to be potentially carcinogenic, but the risk from the levels of intake arising from consumption of the royal jelly cannot be quantified, especially if the exposure were relatively short-term. Medical, oral and intravenous use of chloramphenicol is associated with a rare idiosyncratic aplastic anaemia which can be fatal. The mechanism for this is not fully understood and there is no identified dose-response relationship or threshold for this effect. Therefore, although intakes from royal jelly would be approximately seven orders of magnitude lower than oral medicinal exposures, the risk is uncertain. Chloramphenicol is also used in some eye drops and topical creams and results in levels in the body which are lower than other therapeutic uses but approximately two orders of magnitude higher than potential intakes from the royal jelly. Epidemiological data indicates that the use of chloramphenicol eye drops is unlikely to be associated with aplastic anaemia. Therefore, any incidence of aplastic anaemia from such intakes of chloramphenicol would be expected to be extremely low and is unlikely to be distinguishable from a low background incidence of aplastic anaemia in the population. An MRPL of 0.3µg/kg has been set for chloramphenicol by Commission Decision 2003/181/EC amending 2002/657/EC. (MRPLs are agreed EU laboratory standards to detect a substance or its residues and are not safety limits. Food should not contain any traces of chloramphenicol). Action taken on residue findings i) Samples purchased from UK internet sites/retailers Of the 11 samples purchased from within the UK and found to contain residues of chloramphenicol ten were from internet sites and one was purchased from a retail outlet. The concentrations detected were between 0.93µg/kg and 21µg/kg. For the retail sample, the country of origin is not known. There was no product left and the retailer agreed to display a point of sale notice. The remaining ten samples originated from the USA (three samples), China (five samples (three were duplicates)), Turkey (one sample), with the country of origin of one sample being unknown. 5 Following action from the FSA in association with local authorities, the remaining stock for eight of the samples was withdrawn and for six of these the customers were notified. For the remaining two samples, one was dealt with by the States of Guernsey and for the other the company was no longer trading from the advertised address and all efforts to contact them have failed. Rapid Alerts have been issued for five samples. Three of these originated from the USA, one from China and one sample where the country of origin is unknown. Rapid Alerts were not issued for the other non-compliant samples where information on the supplier of the product is lacking. The Commission will be sent a copy of the report including all the results. The Acting Chief Veterinary Officer has written to the authorities in the USA regarding their three samples and to the authorities in China regarding three of their five samples asking to be kept informed of the outcome of any action that is taken. ii) Samples purchased from foreign internet sites These samples were purchased directly from internet sites without a UK base. As no risk management action could be taken in this country, the VMD has contacted the relevant authorities in the countries concerned for them to take further action. Seven samples purchased from foreign internet sites were found to contain residues of chloramphenicol. The concentrations detected were between 0.33µg/kg and 5.5µg/kg Three samples were purchased from sites based in the USA with one of the samples originating from China and the other two originating from the USA. The American authorities have been notified by the VMD and are investigating these results. Two samples were purchased from sites in New Zealand (NZ) and following investigations by the NZ authorities there we understand that the two internet suppliers obtain their supplies from two different NZ manufacturers. Each manufacturer obtains royal jelly from China and one manufacturer’s supplies go via their Australian parent company before arriving in NZ. Investigations by the NZ authorities are ongoing. Two samples were purchased from a site based in Australia. They were duplicate samples with the same best before dates, production dates and batch numbers. The authorities in Australia have confirmed that the royal jelly was of Chinese origin. 6 Conclusions The VRC is concerned about the findings of the survey which show a high rate of non-compliance in the samples tested. This survey focused on products containing high concentrations of royal jelly and the Committee is aware that other products are available which contain lower concentrations of royal jelly which have not been the subject of this survey. The presence of chloramphenicol, which is not authorised for use as a veterinary medicine in the EU, in products that are available for purchase by UK consumers is a serious concern. The Committee welcomes the risk management action taken by the FSA and hopes that equivalent action will be taken by those nonEU countries that were selling royal jelly food supplements that were contaminated with chloramphenicol. 7 ANNEX 1 Royal Jelly Brand Survey 2007 Results NSR No Web Address Power Health Bumbles 07N0881 Holland & Barrett 07N0883 07N0896 07N0897 Brand www.yourhealthfoodstore.co.uk www.swsupplements.co.uk Labelling Details Country of (as appears on Origin product) Royal gellee 30 x 500mg capsules Royal Jelly 60 x 500mg capsules China England Date of Purchase 26/11/2007 26/11/2007 Best Before Date Jun-09 Jul-10 Fresh Royal Chorley Health Jelly 500mg x 60 Unknown 18/09/2007 19/09/2009 Food Store capsules Seventh Wave 100% Pure Royal Jelly 1500mg capsules Unknown 21/09/2007 07/04/2008 8 Batch 81352 A07264 Q3680 Retail Address Supplier / Manufacturer Address Result/ confirmed value μg/kg Dennis Gore Chemist 26 Whittaker Lane Prestwich Manchester M25 1FX Power Health Products Ltd Pocklington York YO2 1NR Holland & Barrett 25 The Haymarket Bury BL9 0BX Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW Chorley Health Food Store c/o Abrams Ashton 41 St Thomas Road Chorley Lancashire PR7 1JE Gemini Health Care PO Box 92 Keighley BD20 6EW Seventh Wave Supplements Suite 78 151060407 792 Wilmslow Road Manchester M20 6UG Compliant Compliant Compliant NSR No 07N0898 07N0900 07N0901 07N0902 07N0903 Web Address www.power-health.co.uk www.althealth.co.uk www.good4you.co.uk www.bodykind.com www.purelyforyou.com Brand Labelling Details Country of (as appears on Origin product) Power Health Royal gellee Bumbles 500mg capsules Venus Health Royal Jelly Now Royal Jelly Apitherapy Apitherapy Made with fresh Royal Jelly 500mg x 30capsules High Potency Royal Jelly 1500mg x 60 capsules Pure Royal Jelly 50g Pure Royal Jelly 50g China China USA China China Date of Purchase 19/09/2007 19/09/2007 18/09/2007 18/09/2007 18/09/2007 9 Best Before Date Aug-10 May-09 Feb-10 Feb-08 Feb-08 Batch 88642 60500 Retail Address Power Health Products Airfield Estate Pocklington York YO42 1NR 302/07 Power Health Products Ltd Pocklington York YO2 1NR Althealth 11 Market Way Wakefield WF1 1QJ Good 4 You Nutrition Gateway Ltd 8538070825 PO Box 34 Wrexham LL14 5YG 302/07 Supplier / Manufacturer Address Result/ confirmed value μg/kg Compliant Compliant Now Foods Bloomingdale IL 60108 USA Bodykind Boxblack Trading Ltd Unit 4 Whitegate Business Centre Oldham OL9 9JT Apitherapy Health Ltd 28 The Street Sustead Norwich NR11 8RU Purely for You PO Box 589 Timperley Altrincham WA15 7ZA Apitherapy Health Ltd 28 The Street Sustead Norwich NR11 8RU Noncompliant 1.4 Noncompliant 7.5 Noncompliant 1.4 NSR No 07N0905 07N0906 07N0907 07N0908 07N0909 07N0910 Web Address Brand Labelling Details Country of (as appears on Origin product) www.healthmonthly.co.uk Made with fresh Royal Jelly Health Monthly 500mg x 60capsules www.bioceuticals.co.uk Made with fresh Royal Jelly. Each jar Biobees Royal contains 25g of Jelly Fresh Royal Jelly www.healthydirect.com www.auravita.com www.pinkgoods.co.uk www.justvitamins.co.uk Healthy Direct Summer Bee Royal Jelly 600mg x 90 capsules Royal Jelly 500mg x 50 capsules Now Royal Jelly Royal Jelly 1000mg x 60 softgel capsules Just Vitamins Royal Jelly 500mg x 90 capsules Date of Purchase Best Before Date Batch Retail Address Supplier / Manufacturer Address Health Monthly 91-93 Great Union 5026143987 Road Unknown 18/09/2007 01/03/2009 St Helier 706 Jersey JE2 3WA Italy Australia USA USA 19/09/2007 19/09/2007 20/09/2007 18/09/2007 Unknown 19/09/2007 10 Aug-09 Apr-09 Jan-09 May-09 Apr-10 609041 00014 Bioceuticals Ltd Brandon House 1 Balham Road London SW12 9PH Healthy Direct PO Box 325 Guernsey GY1 3TT Manufactured in the EU Pinkgoods Unit 2 Cooper Drive 7711710422 Braintree Essex CM7 2RF GO1 Compliant Bioceuticals Ltd Nutri House 26 Zennor Road Balham London SW1L 0PS Auravita Ltd 140 Cricklewood Lane BH021606 London NW2 2DT Just Vitamins PO Box 4112 Coventry CU4 0BA Result/ confirmed value μg/kg Compliant Compliant Summerbee Products PO Box 213 Torquay TQ1 Now Foods Bloomingdale IL 60108 USA Noncompliant 3.1 Noncompliant 3.4 Compliant NSR No 07N0911 07N0912 07N0913 07N0914 07N0915 Web Address www.healthy.co.uk www.hollandandbarrett.com www.naturesremedy.co.uk www.bodysmart.co.uk www.summerbee.co.uk Brand Cornucopia Fresh Live Royal Jelly Holland & Barrett Natures Remedy Labelling Details Country of (as appears on Origin product) 100% Royal Jelly 20gm Date of Purchase Best Before Date Unknown 19/09/2007 Not known Royal Jelly Unknown 26/09/2007 500mg capsules Jul-10 Fresh Royal Jelly 500mg x 60 Unknown 18/09/2007 06/09/2009 capsules Life Source Royal Jelly 60 capsules Summer Bee Pure Fresh Royal Jelly. Tested and completely free from chloramphenicol 50gms take 1/4 tsp on bread or neat China China 19/09/2007 18/09/2007 11 Feb-09 Feb 08 Batch Unknown AO7264 Q3680 25147 100906 Retail Address Supplier / Manufacturer Address The Really Healthy Company 4 Tanner Street Unit 1 London SE1 3LD Result/ confirmed value μg/kg Compliant Holland & Barrett PO Box 5736 Burton upon Trent DE14 1BR Holland & Barrett Retail Ltd Warwickshire Compliant CV11 6XW Natures Remedy Barley Castle Bank Street Hayfield SK22 2EQ Gemini Health Care PO Box 92 Keighley BD20 6EW Life Source Supplements Ltd Camp Hill Industrial Estate Ripon North Yorkshire HG4 1QY Summerbee Products PO Box 213 Torquay TQ1 Compliant Compliant Wuhan Musen Ltd Wuhan Hubei China 430017 Compliant NSR No 07N0916 07N0917 07N0918 07N0919 07N0920 07N0921 Web Address www.healthspan.co.uk www.apitherapy.eu.com www.wellbeing-nutrition.com www.healthypulses.co.uk www.simplyhealthy.co.uk www.cgcmall.com Brand Healthspan Apitherapy Wellbeing Labelling Details Country of (as appears on Origin product) 200mg capsules Pure Royal Jelly 50g Fresh Royal Jelly 500mg x 30 capsules Made from fresh Royal Jelly Power Health Bumbles 500mg x 60 capsules USA China China China Date of Purchase 18/09/2007 18/09/2007 Best Before Date Sep-08 Feb-08 26/09/2007 19/09/2007 19/09/2007 Aug-08 Fresh Royal Simply Healthy Jelly 500mg x 60 Unknown 18/09/2007 26/09/2009 softgel capsules Golden Lily High Strength Royal Jelly 486mg x100 capsules China 28/10/2007 12 Jan-09 Batch 5546 302/07 W3680 75154 810560 01/2005 Retail Address Supplier / Manufacturer Address Healthspan PO Box 64 Guernsey GY1 3BT Apitherapy Health Ltd 28 The Street Sustead Norwich NR11 8RU Result/ confirmed value μg/kg Compliant Apitherapy Health Ltd 28 The Street Sustead Norwich NR11 8RU Elizabeth Harfleet Wellbeing 12 Gwendor Avenue Manchester M8 4LE Noncompliant 1.5 Compliant Healthy Pulses 95 Cornwall Street Plymouth Devon PL1 1NX Power Health Products Ltd Pocklington York YO2 1NR Simply Healthy The Health Store 8 Skirvving Street Shawlanos Glasgow G41 3AA Logical Health Care PO Box 5717 Derbyshire DE56 2YW CGC Mall FL 1 13736 Laburnum Ave Flushing, NY USA 11355-4138 Imported into USA by: NonKingsway compliant Trading Inc 0.33 Corona New York 11368 Compliant Compliant NSR No 07N0922 07N0923 07N0924 07N0925 07N0926 Web Address www.foodsforhealth.co.uk www.nzpurehealth.com www.aroma-blast.co.uk www.westons.com www.dixiehealth.com Brand Power Health Bumbles Labelling Details Country of (as appears on Origin product) Made from fresh Royal Jelly 500mg x 30 capsules Deep Blue Health Royal Jelly 1000mg x 100 capsules Summer Bee Products Pure Fresh Royal Jelly. Tested and completely free from chloramphenicol 50gms take 1/4 tsp on bread or neat Valupak Royal Jelly capsules Royal Jelly 30 capsules Royal Jelly 500mg x 60 capsules China China China Date of Purchase 28/10/2007 28/10/2007 28/10/2007 Unknown 28/10/2007 USA 28/10/2007 13 Best Before Date July 2010 (x 2) Aug 2010 (x 1) June-10 Feb 08 Jun-10 Oct-08 Batch 88256 (x 2) F 7025 100906 L 07137 362122 Retail Address 14 Bank Street Teignmouth Devon TQ14 8AW Supplier / Manufacturer Address Power Health Products Ltd Pocklington York YO2 1NR New Zealand Pure Health PO Box 40718 Glenfield Auckland New Zealand Result/ confirmed value μg/kg Compliant Noncompliant 1.5 Aroma Blast 21 Elizabeth Avenue Newbury Berks RG14 6HA Wuhan Musen Ltd Wuhan Hubei China 430017 Westons Internet PO Box 1646 Hassocks West Sussex BN6 9GS BR Pharmaceuticals Ltd Compliant Leeds LS16 6QE Dixie Health Inc 2161 Newmarket Parkway Suite 222 Marietta GA 30067 USA Compliant Noncompliant 3.2 NSR No 07N0927 07N0928 07N0929 07N0930 07N0931 Web Address www.giftsofnz.com www.goodnessdirect.co.uk www.dancingbeeacres.com www.lifetimehealth.com.au www.nutrisun.co.uk Brand HNZ New Zealand Power Health Bumbles Dancing Bee Acres Natural Life Natures Aid Labelling Details Country of (as appears on Origin product) Royal Jelly 1000mg x 180 capsules Royal Gellee 500mg x 60 capsules Royal Jelly 500mg x 60 capsules Royal Jelly 1000mg x 60 capsules Royal Jelly 150mg x 90 capsules China China USA China Australia Date of Purchase 28/10/2007 28/10/2007 28/10/2007 28/10/2007 28/10/2007 14 Best Before Date Sep-10 Aug-10 Jun-10 Feb-10 Apr-10 Batch AL 0093 Retail Address Gifts of New Zealand 16 Learn Mouth Avenue Auckland New Zealand 1310 Goodness Direct South March Daventry B/N 90064 NN11 4PH 51807 EO 195 31A1074 Supplier / Manufacturer Address Honey New Zealand 8 Short Street Te Awamutu New Zealand Power Health Products Ltd Pocklington York YO42 1NR Dancing Bee Acres 198 W. Wyoming Avenue Irrigon Oregon OR 97844 USA Noncompliant 1.2 Compliant Noncompliant 3 Lifetime Health Products Pty Ltd 1/111 Old Pittwater Road Brookvale NSW 2100 Australia Nutrisun Ltd (The Good Life) 207 High Street Sutton SN11 1JU Result/ confirmed value μg/kg Noncompliant 5.4 Natures Aid Kirkham Preston PR4 2DQ Compliant NSR No 07N0932 07N0933 07N0934 07N0935 07N0936 Web Address www.simplysupplements.co.uk www.flynnsbeefarm.co.uk www.ldb.co.uk www.reginahealthcare.com www.panaxginseng.co.uk Brand Labelling Details Country of (as appears on Origin product) Date of Purchase Royal Jelly Simply Tablets 100mg x Unknown 28/10/2007 Supplements 180 tabs The Food of Queens Fresh Royal Jelly 100g Zip Vit Royal Jelly 500mg x 30 capsules Regina Premium Fresh Royal Jelly 150mg x 90 capsules Pine Brand High Strength Royal Jelly 200mg x 100 capsules China 28/10/2007 Unknown 28/10/2007 Turkey China 28/10/2007 28/10/2007 15 Best Before Date May-2009 Feb-08 Jun-09 Aug-09 N/A Batch Retail Address 333102 Simply Supplements PO Box 206 Guernsey GY1 3NB 892510 8071 1H06 Flynns Bee Farm Ltd Elmley Road Bramble Down Minster-On-Sea Isle Of Sheppey Kent ME12 3SS Zip Vit Ltd The Towers Business Park Rugeley Walsall Staffs WS15 1BR Regina Health Care PO Box 789 Thornton Heath Croydon CR7 7WY Panax Ginseng UK 504 Wallisdown Road CP 03105D Bournemouth Dorset BH11 8PT Supplier / Manufacturer Address Result/ confirmed value μg/kg Noncompliant 21 Importer: Bee Well Products Ltd Laurel Cottage Apiaries Hockley Lane Wingerworth Derbyshire S42 6QQ Noncompliant 13 Compliant Bentley Laboratories Ltd NonStandard House compliant 1-2 Church Way 1 Edgware Middlesex The Central Pharmaceutical Co Ltd NonTianjin compliant China 0.93 NSR No 07N0937 Web Address www.healthreaction.com 07N0938 www.lifetimehealth.com.au 07N0939 www.burstingwithhealth.co.uk 07N0940 07N0941 www.armstrongshealth.com www.theultimatecatalogue.co.uk Brand Natures Aid Natural Life Labelling Details Country of (as appears on Origin product) Royal Jelly 150mg x 90 capsules Royal Jelly 1000mg x 60 capsules Australia 28/10/2007 Best Before Date Apr-10 Batch 31A 1074 28/10/2007 01-Feb E 0195 Fresh Royal Bursting With Jelly 500mg x 60 Unknown 28/10/2007 Health capsules 03/2009 08/2009 50710 Armstrongs Royal Jelly Royal Jelly 150mg x 90 capsules China Date of Purchase Australia 28/10/2007 Made from fresh Royal Jelly. Royal Jelly Unknown 28/10/2007 500mg x 60 capsules 16 Sep-08 Mar-09 314407 F01 Retail Address Health Reaction PO Box 241 Stockport SK4 3FZ Supplier / Manufacturer Address Natures Aid Kirkham Preston PR4 2DQ Lifetime Health Products Pty Ltd 1/111 Old Pittwater Road Brookvale NSW 2100 Australia Bursting With Health 27 Vance Road Blackpool Lancashire L11 4QD Armstrongs Herbal Store 22 Town Road Hanley Stoke-On-Trent ST1 2JQ Result/ confirmed value μg/kg Compliant Noncompliant 5.5 Compliant Natures Aid Ltd PR4 2DQ The Ultimate Premier Health Catalogue Products 76 Philadelphia Lane CV4 9UP Norwich Norfolk NR3 3JU Compliant Compliant NSR No 07N0946 07N0947 07N0948 07N0949 07N0951 07N0952 Web Address Brand Power Health Bumbles Holland & Barrett ISO Power Health Bumbles GNC Holland & Barrett Labelling Details Country of (as appears on Origin product) Royal gellee 500mg x 60 capsules Royal Jelly 500mg x 60 capsules Royal Jelly 500mg x 60 capsules Royal gellee 500mg x 30 capsules Royal Jelly 500mg x 30 capsules Royal Jelly 500 mg x 60 capsules China China Date of Purchase 24/09/2007 24/09/2007 Unknown 24/09/2007 China USA China 24/09/2007 24/09/2007 24/09/2007 17 Best Before Date Aug-10 Apr-10 Aug-08 1/3/2010 3/7/2010 Jun-10 Feb-10 Batch 88642 6324 20207 88233 AO7192 5736 Retail Address Supplier / Manufacturer Address Hanover Health Foods 40 Hanover Street Edinburgh EH2 2DR Result/ confirmed value μg/kg Compliant Holland & Barrett Hanover Buildings Rose Street Edinburgh EH2 2NN Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW ISO Edinburgh 57-59 South Clerk Street Edinburgh EH8 9PP Ecovit Grey Cottage Hardings Green Cookham Dean Berkshire SL6 9NX Holland & Barrett 124 Nicolson Street Edinburgh EH8 9EH Power Health Products Ltd Pocklington York YO2 1NR GNC 16 Laurie Walk Romford Essex RM1 3RT Health and Diet Ltd Hucknall Notts NG13 7HQ Holland & Barrett 27 Laurie Walk Romford Essex RM1 3RT Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW Noncompliant 3 Compliant Compliant NSR No 07N0953 07N0956 07N0957 07N0958 07N0961 07N0962 Web Address Brand Power Health Bumbles Holland & Barrett Power Health Bumbles Power Health Bumbles Power Health Bumbles Premier Health Food Products Labelling Details Country of (as appears on Origin product) Royal gellee 500mg x 30 capsules Royal Jelly 500mg x 60 capsules Royal gellee 500mg x 30 capsules Royal gellee 500mg x 30 capsules Royal gellee 500mg x 30 capsules China China China China China Date of Purchase 24/09/2007 25/09/2007 25/09/2007 24/09/2007 24/09/2007 Made from Fresh Royal Jelly Unknown 24/09/2007 500mg x 60 capsules 18 Best Before Date 22/07/2010 22/03/2010 Batch 87590 88230 88233 Apr-10 6324 March 2010 July 2010 85893 86502 88264 87078 May 2010 Feb 2010 Aug 2010 July 2010, March 2010 Mar-09 86865 88264 85437 88230 88256 86502 Unknown Retail Address Supplier / Manufacturer Address Result/ confirmed value μg/kg Holland & Barrett 27 Laurie Walk Romford Essex RM1 3RT Power Health Products Ltd Pocklington York YO2 1NR Holland & Barrett Cornwall Street Plymouth PL1 1LR Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW Holland & Barrett Cornwall Street Plymouth PL1 1LR Power Health Products Ltd Pocklington York YO2 1NR Kilworthy Kapers 11 King Street Tavistock PL19 0DS Power Health Products Ltd Pocklington York YO2 1NR Holland & Barrett Brunswick Pavillion West Borough Scarborough YO11 2PA Power Health Products Ltd Pocklington York YO2 1NR Victoria Health Food Centre 91 Victoria Road Scarborough YO11 1SL Compliant Compliant Compliant Compliant Compliant NSR No 07N0966 07N0967 07N1552 07N1604 07N1605 07N1607 Web Address Brand Holland & Barrett Power Health Bumbles Holland & Barrett Power Health Bumbles Power Health Bumbles Power Health Bumbles Labelling Details Country of (as appears on Origin product) Royal Jelly 500mg x 60 capsules Royal gellee 500mg x 30 capsules Royal Jelly 500mg x 60 capsules Royal gellee 500mg x 30 capsules Royal gellee 500mg x 60 capsules Royal gellee 500mg x 60 capsules China China England China China China Date of Purchase 22/09/2007 24/09/2007 22/11/2007 21/11/2007 21/11/2007 28/11/2007 19 Best Before Date Jun-10 Mar-10 Sep-10 Apr-07 Jul-10 Mar-10 Batch 6864 87078 86042 86274 BO7264 Retail Address Supplier / Manufacturer Address Result/ confirmed value μg/kg Holland & Barrett 53/54 Mander Square Mander Centre Wolverhampton WV1 3NL Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW Holland & Barrett 98 Church Street Bilstow West Midlands WV14 0AX Power Health Products Ltd Pocklington York YO2 1NR Holland & Barrett 2 Globe Lane The Lanes Carlisle CA3 8NX Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW Gordon's Chemist 66 Main Street Bushmills B/N 71751 Co Antrim BT57 8QD Power Health Products Ltd Pocklington York YO2 1NR The Health Food Store NI B/N 88234 62 The Promenade Portstewart Northern Ireland Power Health Products Ltd Pocklington York YO2 1NR Iona Shop 27 Church Road Holywood B/N 85917 Co Down BT18 9BU Power Health Products Ltd Pocklington York YO2 1NR Compliant Compliant Compliant Compliant NSR No 07N1609 07N1610 07N1614 07N1615 07N1616 07N1617 Web Address Brand Holland & Barrett Power Health Bumbles Biobees Royal Jelly Queen Bee Labelling Details Country of (as appears on Origin product) Royal Jelly 500mg x 60 capsules Royal gellee 500mg x 60 capsules Royal Jelly 750mg x 30 capsules Fresh Royal Jelly 60g Royal Jelly Biobees Royal Made from fresh Jelly Royal Jelly 25g Holland & Barrett Royal Jelly 500mg x 60 capsules England China Italy Australia Date of Purchase 25/11/2007 26/11/2007 20/11/2007 Best Before Date Sep-10 Jul-10 Jan-09 20/11/2007 06/03/2009 Batch B07264 Holland & Barrett Unit 6 St David's Way St David's Centre Cardiff CF10 2DP Health With Herbs Cowbridge Road B/N 88234 East Canton Cardiff CF11 9DX 501044 Unknown Italy 20/11/2007 Aug-09 609041 England 20/11/2007 Sep-10 B07264 20 Retail Address Supplier / Manufacturer Address Result/ confirmed value μg/kg Holland & Barrett Retail Ltd Nuneaton Warwickshire Compliant CV11 6XW Power Health Products Ltd Pocklington York YO2 1NR Compliant Selfridges Oxford Street London W1A 1AB Bioceuticals Ltd Brandon House 1 Balham New Road London SW12 9PH Harrods 87-135 Brompton Road Knightsbridge London SW1X 7XL Health World (King & Gardiner Ltd) 7 Falcon Court Compliant St Martins Way London SW17 0JH Harrods 87-135 Brompton Road Knightsbridge London SW1X 7XL Holland & Barrett Oxford Street London W1R 1FE Bioceuticals Ltd Brandon House 1 Balham New Compliant Road London SW12 9PH Holland & Barrett Retail Ltd Nuneaton Compliant Warwickshire CV11 6XW Compliant NSR No 07N1618 Web Address Brand Power Health Bumbles Labelling Details Country of (as appears on Origin product) Royal gellee 500mg x 60 capsules China Date of Purchase 21/11/2007 21 Best Before Date Aug-10 Batch 90064 Retail Address Planta Health Shop 32 Weston Hill Upper Norwood London SE19 1RX Supplier / Manufacturer Address Power Health Products Ltd Pocklington York YO2 1NR Result/ confirmed value μg/kg Compliant ANNEX 2 ANALYTICAL METHODOLOGY Approach All royal jelly samples were transported to the Central Science Laboratory (CSL) at ambient temperature and maintained at ambient temperature during the survey. For samples in capsule form, a sub-sample for screening analysis was prepared by mechanically extracting and combining the capsule contents. A portion of each sample was retained as intact capsules, and stored separately for confirmatory analysis should this be necessary. Where samples in capsule form were subject to confirmatory analysis, confirmation aliquots were prepared by mechanical extraction (as above). For samples consisting of royal jelly in pots, a portion of each sample was removed for the screening analysis. The remainder was retained in the original container, and stored separately for confirmatory analysis should this be necessary. For samples in tablet form a portion of each sample was removed and crushed to a powder. A portion of each sample was retained as intact tablets, stored separately for confirmatory analysis should this be necessary. Where samples in tablet form were subject to confirmatory analysis, confirmation aliquots were prepared by crushing (as above). Samples were analysed in accordance with the quality criteria defined in EU Legislationa and ISO17025 accredited methodology. An overview of the analytical method is as follows: Chloramphenicol (CAP) was extracted from the royal jelly using acetonitrile/water at 45-50ºC. The cooled extract was applied to a disposable cartridge packed with a specially cleaned diatomaceous earth and eluted with dichloromethane. The eluent was reduced to dryness under a stream of nitrogen, resuspended in hexane/ethyl acetate and loaded onto a preconditioned amino (NH2) Solid Phase Extraction cartridge. After washing, the sample extract was eluted from the cartridge with ethyl acetate/methanol. The cleaned-up sample extract was reduced to dryness under nitrogen and reconstituted with water. Samples were analysed using LiquidChromatography-Mass Spectrometry/Mass Spectrometry (LC-MS/MS). Identification of CAP residues in a sample was made via two LC-MS/MS transitions. A deuterated internal standard was used in the quantification of CAP residues. All samples were screened and confirmed at CSL using LC-MS/MS. a Commission Decision 2002/657/EC of 12 August 2002 implementing Council Directive 96/23/EC concerning the performance of analytical methods and the interpretation of results 22 Quality assurance All screening batches included known blank samples, a matrix matched standard (i.e. a known amount of analyte added to a known blank sample after extraction), an extracted matrix matched standard (i.e. a known amount of analyte added to a known blank sample prior to extraction) and multi-level solvent standards. Suspect “positive” (non-compliant) samples from these initial screening analyses were subject to confirmatory tests. All confirmatory analyses were conducted in duplicate using test portions taken from the retained sample, along with the Quality Assurance samples and multilevel solvent standards included for screening (see above). Any detectable CAP residues were implicitly corrected for recovery via the use of d5-Chloramphenicol as an internal standard. Quality assurance was also demonstrated by regular participation in both UK and EU–wide proficiency schemes and collaborative studies. Decision limit(CC) and Detection capability(CC) The LC-MS/MS method for determining CAP was validated at CSL according to the requirements of Commission Decision 2002/657/EC. This required the determination of a number of key parameters including “CC” (Decision limit) and “CC” (Detection capability): CC CC CAP in Royal Jelly (µg/kg) 0.11 0.19 23 ANNEX 3 Comments from suppliers/retailers of confirmed samples Note from Summerbee Products: “These capsules were imported from USA using a recognised registered supplier of long standing. Summerbee has a record of clean and analytically sound royal jelly products dating back to 1991”. 24
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