Over the years this question has constantly come up. Just yesterday it was raised on the Blog by a reader/customer. This is what was asked:
"Hi, I noticed your products are not covered or reviewed by ConsumerLab.com (the most famous/trusted provider of independent test results and information to help consumers and healthcare professionals evaluate health, wellness, and nutrition products) May I know, is there any specific reason? I emailed ConsumerLab.com and they requested I suggest to you that your company participate in ConsumerLab.com's testing. Thanks."
Because it is a question in many customer’s minds I thought that I would put the time into giving a detailed explanation to clarify the situation.
So, the following is our response to this question:
Yes, we would like to do something with Consumer Lab but it is not practical to do so as I will explain further. I would make the comment though that the assertion that Consumer Lab is ‘the most famous/trusted provider…’, is somewhat off the mark and they have been very controversial over the years. Some of the work they do is very good…but, quite a bit is questionable.
Consumer Lab is a very effective marketing business, and they are there for a single reason…profit!! They are not a consumer organization as it seems at first glance. In fact, they are not actually a laboratory at all.
We understand that their lab work is contracted out to various laboratories but a list is not supplied identifying whom these labs are and as such it is not known if those labs are GMP compliant. Consumer Lab provides services to manufacturers for a fee and they also sell information to consumers on the basis that it is independent. It is unclear if many consumers are aware of this. In other words they have a business model which creates revenue from consumers and industry alike and as such there sometimes appears to be some bias in what they do.
There have been many complaints by industry that if they do not pay to have their products reviewed that they may find they get a negative one if selected for testing, but if they do pay and Consumer Lab gets a negative finding that they are not published. I have no first hand info about these issues and I make them as an observer from reading many news articles about Consumer Lab over the years.
I actually met Ted Cooperman the President and Founder of Consumer Lab about 8 years ago in Washington and discussed the possibility of having Consumer Lab do testing of our products. I was told that this could have been done for a fee which at that time was around $35,000 for just one product. However we did not pursue this with Consumer Lab for several reasons which I will allude to shortly.
The random tests that Consumer Lab conduct on a regular basis and publish to consumers on a subscription basis, are usually only for a very small number of actives in each product and this is generally done without each manufacturer being involved in the validation of the test methods. Because of this, the results can sometimes be suspect and this does from time to time trigger off legal action because of the damage it can do to the affected company. There is much more to testing a supplement product than just purchasing a product off the shelf and sending it to a lab and asking for an analysis of certain ingredients. Let me give you some background…
You are probably aware that we are compliant with the FDA cGMP code for Dietary Supplements, and we are members of the Natural Products Association of the US. We also have a HACCP program which is audited by the NZ Food Safety Authority, part of the NZ Ministry of Health. We work with a range of GMP labs in New Zealand, Australia and the USA. In reality it generally costs between about $5000 - $15000 to do the method development and validation for each marker (ingredient) in the case of the complex products which Xtend-Life produces.
The reason for this is that the marker has to be identified and quantified based on an active compound within anywhere between 30 – 90 other ingredients, all of which have the potential to either mask or magnify the test results. This means that a test method that works for an ingredient in one product may not work for the same ingredient in a different product. In the case of some ingredients it is impossible to test for them in a complex finished product. This is one of the reasons that Consumer Lab can have problems with manufacturers as it is sometimes impossible to get an accurate result unless the expensive method development and validation steps are first carried out.
So, to put our Xtend-Life’s situation into perspective if it was possible to do this with every ingredient and Consumer Lab was to develop a protocol for all 85 ingredients in our Total Balance mix the costs to them would be in the order of around $750,000. An accurate analysis simply could not be done for $35,000. We have had to invest heavily in developing the protocols for ingredients but it would not be commercially sensible to share this info with others.
One of the many reasons that we test the activity of every raw material we purchase along with using detailed SOP’s (standard operating procedures) is to control every process and every step of production, and there are dozens of pages of paperwork that follow every batch through production, with every step being signed and then checked and signed off by QC & QA staff.
Finished product testing is important, and we do it not only for our own satisfaction but also to comply with our GMP program, but, it is only through following the rigorous procedures that I mentioned that we can be completely certain that every product is true to label. End product testing can never give a 100% reliable and accurate result.
Our processes how we achieve this will become more apparent to you as the posts explaining how we make our supplements are made over the next week or two.