What about coltsfoot?

[linden]

Does coltsfoot have the same regulatory status as comfrey, since it has the same alkaloids?

[crabapple]

Funny, but I don't think so. The official FDA alert on comfrey did not mention coltsfoot. As far as I know there are no legal restrictions on coltsfoot in the US. Does anyone else have any other information?
_________________
Rebecca Hartman
Crabapple Herbs: http://crabappleherbs.com/
The Herbwife's Kitchen: http://crabappleherbs.com/blog/

[linden]

That's so weird that they would attack comfrey but not coltsfoot. Why do you think that is?

[kavawaka]

Hi - FDA comments from 2001 did include an overly broad statement...

'FDA believes that the available scientific information is sufficient to firmly establish that dietary supplements that contain comfrey or any other source of pyrrolizidine alkaloids are adulterated under the Act. The agency strongly recommends that firms marketing a product containing comfrey or another source of pyrrolizidine alkaloids remove the product from the market and alert its customers to immediately stop using the product. The agency advises that it is prepared to use its authority and resources to remove products from the market that appear to violate the Act.'
ref: http://www.cfsan.fda.gov/~dms/dspltr06.html

They do not even differentiate between potentially harmful unsatured PAs and saturated PAs(!), but it would be reasonable to consider this as unsaturated PAs only. This FDA opinion does spill into the final GMPs. Jim's GMP post includes this FDA quote concerning the their stance on regulating practioners...

'Further, we are not considering exercising our enforcement discretion with respect to practitioners who...prepare batches of a dietary supplement for which there is a known or suspected safety concern.'

The products listed below would probably all meet FDA's safety concern. Here is the American Herbal Products Association (AHPA) recommendation on PA-containing plants...

V. Pyrrolizidine Alkaloids (adopted July 1996)
AHPA recommends that all products with botanical ingredients which contain toxic pyrrolizidine alkaloids1 bear the following cautionary statement on the label:
For external use only. Do not apply to broken or abraded skin. Do not use when nursing.
1. Including but not limited to: Alkanna tinctoria (alkanet); Anchusa officinalis (bugloss); Borago officinalis* (borage); Crotalaria spp., Cynoglossum spp., Erechtites hieraciifolia, Eupatorium cannabinum (hemp agrimony); Eupatorium purpureum (Joe Pye), Heliotropium spp., Lithospermum officinale (European gromwell); Packera candidissima, Petasites spp. (e.g., butterbur); Pulmonaria spp. (e.g., lungwort); Senecio jacobaea (European ragwort); Senecio vulgaris (groundsel herb); Symphytum spp. (comfrey); and Tussilago farfara (coltsfoot).
* Borage seed oil is specifically exempt from the above label recommendation.
ref: http://www.ahpa.org/Portals/0/pdfs/AHPA_CodeOfEthics.pdf

[teasel]

joe pye weed?

you can't sell it for internal use?

what???

[kavawaka]

Technically, no, but some people do. Most companies have quit selling it. The test results i've seen appeared to be pretty loaded with PAs. i believe (recollecting here) that the only member of the genus without PAs is boneset.