AOAC SPDS Meeting Book March 19 2015
Background (Diastereoisomers of Mitragynine)
Speciociliatine
Speciogynine
(S)
(S)
(S)
(R)
(S)
(S)
Regulatory Guidance
Kratom – should be slotted appropriately comfrey ephedra
rauwolfia red yeast rice butterbur Kratom could fit under 201(ff) as an herb or other botanical (alkaloids with opioid activity are the issue) Kratom (mitragynine or 7‐hydroxymitragynine) = adulterated based on 402(f)(1)(B) Kratom (mitragynine and 7‐hydroxymitragynine removed) = allowable? (all other alkaloids left ‐ cause relaxation) At what level would they be acceptable? Zero tolerance? Agency has to make that case
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