Everyone is claiming to have valid data to evaluate these products, including Consumer Labs. Consumer Labs has some useful information but as you can see from this letter, it is not the whole enchilada.


Subject: Glucosamine Hcl
Date: Thu,
22 Jun 2000 17:56:02 -0500
To: info@consumerlab.com

Good afternoon,

We are Pfanstiehl Laboratories located in
Waukegan , Ill. Our company's primary focus is manufacturing intermediates and API's for the global pharmaceutical industry. Our customers include most of the Fortune 500 pharma companies (Abbott, Lilly, Pharmacia, Bristol Myers Squib, Pfizer, etc.) as well as many biotech/venture capital (virtual) pharmaceutical companies. We also produce 2 dietary supplements - Creatine Monohydrate (sports nutrition) and Glucosamine Hcl. To the best of our knowledge, Pfanstiehl is the only cGMP producer of Creatine and Glucosamine Hcl in the world and certainly in the US . We began producing both of these products over 40 years ago as pharmaceutical ingredients, not as dietary supplements.

We have reviewed your web site with interest, particularly the section dealing with glucosamine and chondroitan sulfate. It appears as though your testing of commercial, dosage form products is limited to potency issues only, i.e. assay or purity. It does not appear that you are testing for impurities (which might come from impure raw materials or result from the synthesis of the product), heavy metals, or gross contamination. We find this very interesting. Although these contaminants are typically present in very low levels (.1% or less) and thus have little or no effect on the potency as you are measuring it, they can nonetheless be very harmful. Neither does it appear that you are taking in consideration the conditions under which the bulk ingredients contained in these products are manufactured. Considering that the vast majority of US dietary supplement marketers primary criteria in sourcing bulk ingredients is price, price, and price and that Chinese producers have virtually taken over this market for this reason, we are also curious as to why you have made no attempt to assess these conditions or make them a part of your rating system. If the typical consumer of dietary supplements in this country were aware of the conditions under which most bulk dietary supplements are produced in
China , I doubt that they would knowingly consume them. At the very least, they would demand to have access to this information. The information provided in your web site would be of significantly greater value to the consuming public if you included the above analysis and assessment in your evaluation of various products and vendors. This is particularly true in light of the fact that there is little or no regulatory oversight of the Dietary Supplement industry.

Those companies who do care enough to include these tests and considerations in their assessment of potential vendors (Nutramax,
Baltimore , Md. , and Nutrasense, Lenexa , Ks. ) are playing on a very tilted playing field. As it is, your service provides little, if any, value. I would be pleased to receive your comments on the above observations.

Very Truly Yours,

Edward S. Holstein, Executive Vice President http://www.Pfanstiehl.com