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 non–English 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 co–author 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