Certificate of analysis CPR and the resurgence of open source testing methods
When we first started the lab nearly 20 years ago I recall our founder, and my father, Sidney Sudberg, speaking at a trade show about our testing, and an audience member asked a question (in the form of a statement). He said, "Why bother when the average C of A [certificate of analysis] isn't worth any more than the paper it's printed on?"
I took personal offense to this comment—maybe because I was younger and more pugnacious—and later confronted the man who made that statement. He sarcastically explained to me that the average C of A has basic data but does not share the method, severely limiting any value to recipients and, more importantly, FDA auditors. In that moment I understood why the average C of A was just not trusted by a lot of industry people. I also knew how to make sure an Alkemist Labs C of A was.
From that moment on I worked hard to develop a template for our C of As that shared 100 percent of the method, data and not only everything you need to reproduce the analysis, but everything you need to defend the results in front of auditors. I fought many fights against those trying to limit the information we give out for free. Disappointingly I was strongly urged by most other labs in the industry not to share the entire method but only results and conclusion. I did not listen to my competition, as is my way, and that man who challenged the validity of the conventional C of A is still a customer of Alkemist Labs today.
Like an endangered species, the fully transparent, open source C of A is nearly extinct. It's as if the executives of labs colluded over fine single malts and agreed upon a limited amount of data they were comfortable giving away. These days, most labs simply don't offer the entire method used to arrive at the information on the C of A that the client receives. Or if they do, there's an extra charge. Some make you spend a certain level of money before allowing an audit. I have to ask, though, how is making it harder for manufacturers to document their product quality good customer service? How does that support an ethical industry?
The good news is that the recent industry push for supply chain transparency will soon trickle down to the labs where the words 'proprietary method' may soon be a dirty phrase, and labs who charge for the full method will be looked at with disapproval. This will be a significant step forward for industry transparency and accountability.
As a testing lab, we act as a gatekeeper for quality in this industry. When testing is utilized and done properly, it allows Alan on the farm to ship that container of ginseng root, or Samantha the broker to fulfill an order to the extract manufacturer, or Mark the contract manufacturer to combine the ingredient with all the others, or Robert in the warehouse to push the green button on the conveyer belt, all of which ultimately allows the consumer to take a safe and effective product that contains what they expect it to. Yet in this day of increased scrutiny where quality is an obligation, some labs still get away with keeping just how they got that data to themselves. Why is this tolerated? It's high time to take quality out of the closet and share the data. CPR on the standard C of A is needed. As the industry moves to meaningful transparency, the open source C of A is inevitable.
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