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Validation was performed by characterizing a Kratom product purchased via the internet. This

positive control was extracted seven times over three days and analyzed by all three analytical

techniques: GC/MS, LC-MS/MS and UPLC/PDA. The UPLC/PDA data demonstrated a mean value of

1.041% (n=21, 4.2%) and the LC-MS/MS 1.140% (n=14, 6.81%) for mitragynine in the positive

control. This positive control was extracted and analyzed in duplicate with every analytical batch.

II.

REVIEW OF THE METHOD ONLY:

1.

Does the applicability of the method support the applicability of the SMPR? If no, please explain

what is missing.

Yes.

2.

Does the analytical technique(s) used in the method meet the SMPR? If no, please specify what

how it differs from what is stated in the SMPR.

No, it only covers 1.0% mitragynine, and not the entire range in Table 1. Also the RSDr is > 3.

3.

Are the definitions specified in the SMPR used and applied appropriately in the method? If no,

please indicate how the terms are used.

Yes.

4.

Does the method, as written, contain all appropriate precautionary and warning related to the

method’s reagents, components, instrumentation, or method steps that may be hazardous? If

no, please suggest wording or option(s).

No, it needs a safety statement.

III.

REVIEW OF INFORMATION IN SUPPORT OF THE METHOD:

1.

Are the definitions specified in the SMPR used and applied appropriately in the supporting

documentation (manuscripts, method studies, etc…)? If no, please explain differences and if the

method is impacted by the difference.

Yes, but they need to be clearer.

2.

Is there information demonstrating that the method meets the SMPR Method Performance

Requirements table? If no, for any of the parameters in the SMPR Method Performance

Requirements table, then please explain what is missing and the impact on performance of the

method.

no, not all of the parameters have been validated. The method only meets the > 0.5 - 15%

range, nothing less.