Comfrey Targeted for Removal

Earlier this year, the Association of Animal Feed Control Officers (AAFCO, a non-profit organization of state and federal feed regulators that has no regulatory power, but helps guide national interpretation of feed laws) planned to select one or more animal feed supplement ingredients and stage a nationwide "regulatory event" in order to bring attention to the problem of illegal animal supplements. The first target ingredient for upcoming enforcement actions, identified at the AAFCO annual meeting in August, is comfrey contained in feed, feed ingredients, or supplements to be added to feed. State regulators intend to seek out feed products with comfrey and stop the sales of these products. (For additional information on the planned enforcement action, see

The Enforcement Strategy for Marketed Ingredients (ESMI) Working Group of AAFCO cited an increasing number of unapproved or undefined ingredients appearing in animal feed and pet food as well as "growing concerns about consumer protection, protection of animal health, and food safety" as the reason behind taking a more active role in enforcement. The group intends to initially target just comfrey for regulation at the state and federal level, and that ingredient will be the focus of its enforcement activities.

According to the Physicians Desk Reference for Herbal Medicines, which is written for human medicine, comfrey (Symphytum officinale) is used externally for bruises and sprains, and internally for gastritis and gastrointestinal ulcers. "In folk medicine, it is used for rheumatism, bronchitis, pleuritis, and as an antidiarrheal agent," noted the reference. It went on to say that "one should entirely forgo internal administration of the drug, due to the presence, however small, of pyrrolizidine alkaloids, which have hepatotoxic (toxic to liver cells) and carcinogenic (cancer-causing) effects. It has been determined that traces of the alkaloids present a danger."

The next step in the current regulatory action would be for the FDA Center for Veterinary Medicine to release supporting information on the reasons comfrey shouldn't be contained in feeds or supplements. However, since manufacturers know that comfrey has been targeted, they have begun to remove it from products, according to National Animal Supplement Council (NASC) president Bill Bookout.

Future Nutraceutical Research

In order to meet AAFCO ingredient definitions, NASC participating members propose to contribute 2% of sales from products containing targeted ingredients for research. NASC selected three non-herbal and two herbal/botanical ingredients for their first funding/regulatory quest. The non-herbal ingredients are glucosamine, chondroitin, and methylsulfonylmethane (MSM). The two herbal/botanical ingredients tentatively are garlic and rehmannia. Currently, NASC has more than $50,000 pledged for the research on glucosamine.

About the Author

Kimberly S. Brown

Kimberly S. Brown was the Publisher/Editor of The Horse: Your Guide To Equine Health Care from June 2008 to March 2010, and she served in various positions at Blood-Horse Publications since 1980.

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