The Revision of Herbs of Commerce

by Michael McGuffin rate the more thorough HOC2. AHPA has not request- ed that its new work be used by food or cosmetic mar- Backgound keters nor that the Latin names in HOC2 take on a In an effort to reduce the confusion associated with greater significance than the internationally accepted labeling of botanical ingredients in herbal products, rules. the American Herbal Products Association (AHPA) published Herbs of Commerce in 1992 (“HOC1”). Determination of Common Names in HOC2 In approaching the assignment of a single “standard- Michael McGuffin This work established a single “standardized” com- mon name for each of the nearly 600 broadly distrib- ized common name” (SCN) to each of the plants listed in the revised HOC2 the greatest emphasis was placed Michael McGuffin is the uted herbs listed in the book, recognizing that many of the herbs in trade had come to be known by various on consistency. The following criteria were established President of the American common names. and prioritized: Herbal Products ¥ the SCN should be the name of the plant, Shortly after publishing this reference AHPA recom- not the name of any particular part or product of Association. He has mended that its members adopt its standardized com- the plant been active in the herbal mon names in labeling their products. This recommen- ¥ the SCN should be in English except where a industry since 1975, dation took on greater significance in 1997 when the nonÐEnglish name has been well established having owned and Food and Drug Administration (FDA), in implement- ¥ the first preference for an SCN is any broadly ing the Dietary Supplement Health and Education Act established English name unless the use of that managed both retail and (DSHEA), determined that “The common or usual name is likely to result in confusion manufacturing businesses name of ingredients of dietary supplements that are ¥ absent a broadly established English name or in this field. He is the botanicals (including fungi and algae) shall be consis- when such name is likely to result in confusion Managing Editor of tent with the names standardized in Herbs of the next preferred SCN is either: the name of the Commerce, 1992 edition.” genus if such name is generally established and Botanical Safety Handbook the use of that name is not likely to result in con- Even prior to this acceptance of HOC1 by FDA, AHPA (1997) and of Herbs of fusion, or the Latin binomial had initiated a revision of the first edition. The primary Commerce, 2nd edition ¥for all plants listed in HOC1 the first consideration in taking on this task anew was to preference for the SCN in HOC2 was to accept (2000). He also serves as expand the number of plants for which common names the name given in the first edition except when Treasurer of the American would be standardized. The resultant Herbs of such given name was inconsistent with the above Commerce 2nd edition (“HOC2”) was published in Herbal Pharmacopoeia, criteria October 2000 and listed just over 2000 species. and as a Board member There are exceptions to most of the above criteria. For of United Plant Savers. Regulatory Implications example, while the name “bloodroot” includes the The language of the US regulatory code quoted above name of a plant part, that name is widely accepted as has a very specific regulatory intent and implication: the common name for Sanguinaria canadensis. “Yerba FDA now requires that the common name of the herbal santa,” though not English, is the broadly used name ingredients in dietary supplement products be the same for Eriodictyon californicum. as the standardized common name given in HOC1. The use of the genus name as the SCN deserves some The current Federal regulation has no direct bearing on additional examination. This use is quite widespread in the common names of herbs that are used in other the naming of plants directly borrowed from the products such as conventional foods and cosmetics. Chinese herbal tradition (e.g., astragalus). Examples of Also, FDA has not adopted the Latin names given in such use also include, however, common plants such HOC1, and in fact the same rule cited above states that as lobelia (Lobelia inflata), sassafras (Sassafras “Any name in Latin form shall be in accordance with albidum), luffa (Luffa spp.), and hibiscus (Hibiscus internationally accepted rules on nomenclature, such spp.). As a general rule, the genus name is accepted as as those found in the International Code of Botanical the SCN for a particular species only if it is the only Nomenclature.” species within the genus for which the unmodified AHPA has requested that FDA give consideration to genus name is generally used (sassafras), or if there are revising their labeling rule for supplements to incorpo- several species for which interchangeable use is accepted (luffa and hibiscus). Quite a few of the listed

40 Fall/ Winter 2001 Green Notes

species of Chinese plants fall into this last category, as The approach taken in the production of HOC2 was it is not uncommon for related species to bear the same that of simply accepting the taxonomist community as common name. the expert in the area of taxonomy. The key references for determination of the current “accepted” status of In some instances where several species of the same conflicting nomenclature were authoritative databases genus are in trade, the unmodified genus name, if used that have developed review processes for the specific as an SCN, is assigned to the one species with the most purpose of making such determinations. The most established history of use (Lobelia inflata = lobelia). important and most often accessed of these were those In these cases, the other species receive a different which provide systematic reviews of taxonomic accu- SCN that consists of either a modified generic name racy, and so included the USDA’s Agricultural (Lobelia siphilitica = blue lobelia; Research Service’s Germplasm Resources Information L. laxiflora = Sierra Madre lobelia) or an entirely dif- Network (GRIN); the Integrated Taxonomic ferent common name (Lobelia cardinalis = cardinal Information System (ITIS) maintained by the flower). Smithsonian Institute for a U.S. Federal interagency Determination of Latin Binomials in HOC2 group; and Flora Europa. In the absence of opinions The primary focus of HOC2, like the first edition, is on from these authorities or when these references were the standardized common name for each of the entries in disagreement, preference was given to the view of in the revised reference. Nevertheless, the review the experts on the editorial committee (again, Drs. process included qualified taxonomic experts, specifi- Kartesz and Tucker). cally Drs. John Kartesz and Art Tucker, and expended Also, as stated in that Introduction to HOC2, “it is “The common or considerable resources in assuring accuracy in the important to note that determination of such status [as usual name of given Latin names. the accepted name] depends on taxonomic study and ingredients of An issue that has often come between taxonomists and opinions that are prone to revision from time to time.” others whose work is linked to the use of plants is the dietary supple- Editors and Reviewers tendency of the taxonomists to change their minds on This author (Michael McGuffin) served as the ments that are too regular a basis. Witness the following complaint, Managing Editor for HOC2. The Taxonomic and written over a century ago by a physician in the intro- botanicals Technical Editors of the revision were John T. duction of his work on the homeopathic use of saw Kartesz Ph.D., Director, Biota of North America (including fungi palmetto: Program, University of North Carolina at Chapel and algae) shall The genus Sabal embraces six or eight species, five of Hill; Arthur O. Tucker Ph.D., Research Professor of be consistent which are found in Florida and other Gulf States. Agriculture and Natural Resources, Delaware State Some officious botanist removed the Saw Palmetto University; and Albert Y. Leung Ph.D., a pharmacog- with the names from this genus and made it a monotypic member of a nosist and coÐauthor of Encyclopedia of Common standardized new genus Serenoa…There was no occasion for such a Ingredients Used in Foods, Drugs and Cosmetics. change. It only renders the study of botany more diffi- in Herbs of The work was subjected to significant review at sever- cult and serves no practical use (Hale, EM; 1898; Saw Commerce, al stages. All AHPA members were specifically invited Palmetto; Philadelphia: Boericke & Tafel). to participate in reviews and several of these provided 1992 edition.” One hundred and three years later the confusion meaningful input. The most active of these, as identi- between Sabal and Serenoa has been largely forgotten, fied in the Acknowledgements that precede the text, and it would likely be considered newly “officious” for were: Roy Upton; Daniel Gagnon; Kay Wright; Bill a taxonomist to suggest that Sabal serrulata be Popin: Ahmed Warfa; Josef Brinckmann; and Steven reestablished for the plant that is now widely known as Foster. Serenoa repens. There are other genera, however, that are broadly used today by herbalists and by marketers Botanical Nomenclature and that have been subjected to more recent revisions. for Herbal Practitioners These include Senna and Cassia, Actaea and Cimicifuga, The following lists, excerpted from the Exam Topics and Acanthopanax and Eleutherococcus, to name a few. Study Guide for the National Botanical Medicine

Journal of the American Herbalists Guild 41 Certification Examination of the American Herbalists dence to an actual established common name (estab- Guild and Botanical Medicine Academy (publication lished in references, in traditions, or in the market- available through the AHG) are not exhaustive and place) if such exists and is not confusing (the Federal include only those herbs most commonly used or con- definition of “common or usual name” actually states sidered important to know by clinical practitioners in that the name “may not be confusingly similar to the the United States, as determined by surveys conducted name of any other food that is not reasonably encom- by the American Herbalists Guild and Botanical passed in the same name”). We also gave precedence Medicine Academy in 1999Ð2000. They reflect the to English names except when a nonÐEnglish name is most recent changes found in Herbs of Commerce 2. well established (e.g., yerba mansa). In the absence of an established (usually English) common name, either the genus name or the Latin binomial was given. More on AHPA and Botanical Again, there was an attempt to be consistent with the Name Changes: Notes from choice of either genus or Latin binomial, with the same Personal Correspondence emphasis on established use. It was easy, therefore to record the common name “lobelia” for Lobelia inflata, even as other species of the genus are named, e.g., “blue lobelia” or “cardinal flower.” Similarly, the use Scientific Binomial Changes of the name “astragalus” is well established for sever- al species of that genus that are broadly used in TCM Old Scientific Binomial New Scientific Binomial and sold in the marketplace. Agropyron repens Elymus repens As a rule, when only the genus was used as the com- Alchemilla vulgaris Alchemilla xanthochlora mon name, it was either quite well established in trade Anemone pulsatilla Pulsatilla patens (e.g., sassafras) or it was assigned to that species most Anemone pulsatilla Pulsatilla pratensis established (usually traditionally and/or officially Barosma betulina Agathosma betulina established) as the primary therapeutic article of com- merce. Berberis aquifolium Mahonia aquifolium Cassia senna Senna alexandrina Other details for which consistency was the target: we tried to remove, as much as possible, any use of the Ceanothus gregii Ceanothus americanus part of the plant in a name (exceptions include, e.g., Cimicifuga racemosa Actaea racemosa cardinal flower!); we also gave the name of the plant Erigeron canadensis Conyza Canadensis rather than the commercial product of the plant (so quinine becomes cinchona and Canada balsam Euphrasia officinalis Euphrasia rostkoviana becomes balsam fir). In addition, we also tried to find Euphrasia officinalis Euphrasia stricta some consensus (if not unanimity) from authoritative Lavandula officinalis Lavandula angustifolia references and knowledgeable reviewers that the stan- dardized common name given in the revision have Piscidia erythrina Piscidia piscipula some wellÐreferenced basis. Populus candicans Populus balsamifera var. balsamifera Rhamnus purshiana Frangula purshiana Regarding the echinaceas: the choice to give the Latin binomials as the common names for these species was Stachys betonica Stachys officinalis made by the editors of the first edition. In the revision Ulmus fulva Ulmus rubra process, our decision to accept this original decision was the result of a two step process. First, it was Ed. Note: Michael McGuffin has been kind enough agreed that there is a need to “split” rather than to further explain the origin and meaning of some of “group” these species since it is generally perceived the binomial changes. Below are excerts from written that the plants are not completely interchangeable as communication that Michael has granted permission therapeutic agents, Secondly, having decided to main- to publish in the JAHG. tain separate names, it was believed that the name Echinacea angustifolia is better established, at least in Our first goal in managing the revision, though it is not today's marketplace, than “narrow–leaf echinacea” or always apparent, was to be consistent. In that regard, “narrowÐleaf purple coneflower;” the same is true for we established a system of prioritization to take into E. purpurea and E. pallida versus “purple coneflower” account many factors. We always tried to give prece- and “pale purple coneflower,” respectively. In addition,

42 Fall/ Winter 2001 Green Notes

Common Name Changes Old Common Name New Common Name Scientific Binomial monkshood aconite Aconitum napellus sweet flag calamus Acorus calamus garden angelica angelica Angelica archangelica uva ursi uva–ursi Arctostaphylos uva–ursi oats oat Avena sativa green tea tea Camellia sinensis false unicorn root false unicorn Chamaelirium luteum greater celandine celandine Chelidonium majus gold thread coptis Coptis chinensis foxglove digitalis Digitalis purpurea purple coneflower Echinacea angustifolia Echinacea angustifolia Siberian ginseng eleuthero Eleutherococcus senticosus ma huang ephedra Ephedra distachya crane's bill cranesbill Geranium maculatum cotton root cotton Gossypium hirsutum gumweed grindelia Grindelia camporum gurmar gymnema Gymnema sylvestre pennyroyal American pennyroyal Hedeoma pulegioides pennyroyal European pennyroyal Mentha pulegium lavender English lavender Lavandula angustifolia bugle weed bugleweed Lycopus virginicus German chamomile chamomile Matricaria recutita partridge vine partridge berry Mitchella repens white pond lily sacred lotus Nelumbo nucifera peony tree peony Paeonia suffruticosa Jamaican dogwood Jamaica dogwood Piscidia piscipula plantain English plantain Plantago lanceolata he shou wu, fo ti fo–ti Polygonum multiflorum balm of Gilead balsam poplar Populus balsamifera spp. balsamifera wild cherry black cherry Prunus serotina kudzu, kuzu kudzu Pueraria montana var. lobata rhubarb chinese rhubarb Rheum officinale willow white willow Salix alba willow black willow Salix nigra elder European elder Sambucus nigra elder American elder Sambucus nigra spp. canadensis huang quin Chinese skullcap Scuttelaria baicalensis goldenrod European goldenrod Solidago virgaurea nettle leaf stinging nettle leaf Urtica dioica spp. dioica nettle root stinging nettle root Urtica dioica spp. dioica old man's beard usnea Usnea barbata vervain blue vervain Verbena hastata vervain European vervain Verbena officinalis spp. officinalis blackhaw black haw Viburnum prunifolium periwinkle lesser periwinkle Vinca minor violet sweet violet Viola odorata ashwaganda ashwagandha Withania somnifera prickly ash southern prickly ash Zanthoxylum clava–herculis

Journal of the American Herbalists Guild 43 it is difficult to believe that consumers can readily dif- developed review processes for the specific purpose of ferentiate the various “purple coneflowers” based only making such determinations. The most important and on the absence or presence of modifiers. It might also most often accessed of these were those which provide be argued that the consumer cannot well differentiate systematic reviews of taxonomic accuracy, and so products based on the the differentiation of the several included the USDA’s Agricultural Research Service’s species, but we (and the original authors) made the Germplasm Resources Information Network (GRIN); choices that we believed would most minimize confu- the Integrated Taxonomic Information System (ITIS) sion. maintained by the Smithsonian Institute for a U.S. Federal interagency group; and Flora Europa. In the Different references were accessed for different class- absence of opinions from these authorities or when es of plants (e.g., mushrooms; Chinese medicinal these references were in disagreement, preference was plants; garden plants; vegetables; etc.). In addition, given to the view of the experts on the editorial com- different reviewers were also somewhat specialized. mittee (again, Drs. Kartesz and Tucker). (See the HOC 2 bibliography for the complete list of accessed references.) In establishing “who are the authorities” on this subject, we approached this issue by including taxonomic experts in our selection of editors (Drs. John Kartesz and Art Tucker) and by accepting the taxonomist community as the expert in the area of taxonomy. The key references for determi- nation of the current “accepted status of conflicting nomenclature were authoritative databases that have

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44 Fall/ Winter 2001