R00504 PDS
R00504 PDS
R00504 PDS
com
Kerala 682 311, India F +91484 2834351 W www.s ynthite.com
Dear Divya,
1. I noticed that the number 2160025692/10 is indicated on PDS and other documents. It is on the COA also.
Please help me with the below‐
Is 2160025692/10, the product code of this material ? ‐ Sample number, Product Number is 5010000676
If this is the product code of the material, then what is the batch/lot number of the sample that was sent to
us?
If this is a lab produced batch and it has no lot number, can the manufacturing date be taken as the lot
number ‐ It's not a lab prepared sample
2. E coli: Is < 3 mpn/g also the detection limit of the method? ‐ Detection limit is 3 mpn/g
3. S aureus: Is < 10 cfu/g also the detection limit of the method? ‐ Detection limit is 10 cfu/g
4. ID: Can you provide the chromatograph of the reference standard. Attached the chromatogram of the sample ‐
2160025692/10 (lot manufactured ‐ 25.03.2019)
Dear Aniket,
Thank you very much for your email and for working on this request.
1. PDS (Product Data Sheet): PDS is missing in the attached, kindly provide updated PDS with the lot#
2160025692/10, Sample Number & Qty and Mfg. Date, removed.
1
2. E coli: We understand that the spec for E coli is set at < 3 mpn/g (based on BAM method). Is < 3 mpn/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing E coli?
3. S aureus: We understand that the spec for S aureus is set at < 10 cfu/g (based on BAM method). Is < 10 cfu/g
also the detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for
testing S aureus?
4. ID: Method of analysis, reference standard used for testing sigma standard.
6. Nutritional Information.
7. Non‐BSE Statement(BSE)
2
Dear Divya,
a) On attached PDS, can the lot# 2160025692/10, Sample Number & Qty and Mfg. Date, be
removed from the PDS, as this gives the impression that the PDS is “lot” specific ‐ Corrected
Product Data Sheet is attached in the mail.
b) Total Plate Count (< 10000 cfu/g) and Total Yeast & Mold (< 500 cfu/g) actual values are
not reported on COA lot#2160025692/10. Are these values also the detection limit of the
method? If not, can actual values be provided for COA lot#2160025692/10, can actual results be
reported going forward, on the COA ‐ These are actual values only, we are sure that in future
batches the microbiology results will be under herbalife permissible limits.
2. ID chromatogram: Can you confirm attached ID chromatogram is for lot#2160025692/10, as the lot
number is not indicated. Additionally, please confirm which of these is the reference standard. We need the
chromatogram of both the sample (lot#2160025692/10) and reference standard ‐ Corrected ID
chromatograph is attached for your reference, we will share the Method of analysis, reference standard
used for testing sigma standard.
3.Allergen Statement(ALR): Since the attached Allergen statement indicates some allergens as “present in the
same manufacturing plant”, can you please provide your Allergen Control Program ‐ As explained we are
doing change over from product to product which comprises of steam washing of complete plant along
with cleaning in place with cleaning agent, flow chart for the same will be submitted by end of the day.
4.Nutritional Information(NUT): Please provide a nutritional statement for this material. ‐ Sample has been sent
to third party lab for nutritional data analysis, the results are expected within 8‐10 working days.
5. Storage Conditions(STO): Please provide the storage conditions for this material. Please note that we
cannot accept this information on the MSDS. Kindly add this to the PDS or provide a separate statement.
Email statement is also acceptable ‐ You need to keep the drum in sealed condition in cool and dry place
without any exposure to the sun & moisture.
3
6. Non‐BSE Statement(BSE): Please provide a Non‐BSE Statement for this material ‐ Non‐BSE statement will
be sent to you by the end of the day.
Additionally, please help address the below on the PDS and COA:
1.Yeast & Mold, Lead and Mercury: We understand, that you have set higher specs for the below (compared to
Herbalife Specs) based on natural batch variation, but can you confirm based on the results on the attached
COA(lot# 2160025692/10), that if tested, this material will meet Herbalife Specs as listed below? ‐ Our
product test results will be within herbalife specs for all the supplies.
Dear Aniket,
Any updates on our request for samples for lot#2160025692/10? Please note that a 150g sample would suffice. If
available, please kindly send to Kishan’s attention.
a) On attached PDS, can the lot# 2160025692/10, Sample Number & Qty and Mfg. Date,
be removed from the PDS, as this gives the impression that the PDS is “lot” specific.
b) Total Plate Count (< 10000 cfu/g) and Total Yeast & Mold (< 500 cfu/g) actual values are
not reported on COA lot#2160025692/10. Are these values also the detection limit of the
method? If not, can actual values be provided for COA lot#2160025692/10, can actual results be
reported going forward, on the COA.
2. ID chromatogram: Can you confirm attached ID chromatogram is for lot#2160025692/10, as the lot
number is not indicated. Additionally, please confirm which of these is the reference standard. We need the
chromatogram of both the sample (lot#2160025692/10) and reference standard.
4
3. Allergen Statement(ALR): Since the attached Allergen statement indicates some allergens as “present in the
same manufacturing plant”, can you please provide your Allergen Control Program.
4. Nutritional Information(NUT): Please provide a nutritional statement for this material.
5. Storage Conditions(STO): Please provide the storage conditions for this material. Please note that we
cannot accept this information on the MSDS. Kindly add this to the PDS or provide a separate statement.
Email statement is also acceptable.
Additionally, please help address the below on the PDS and COA:
1. Yeast & Mold, Lead and Mercury: We understand, that you have set higher specs for the below (compared
to Herbalife Specs) based on natural batch variation, but can you confirm based on the results on the
attached COA(lot# 2160025692/10), that if tested, this material will meet Herbalife Specs as listed below?
2. E coli: We understand that the spec for E coli is set at < 3 mpn/g (based on BAM). Is < 3 mpn/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing E
coli?
3. S aureus: We understand that the spec for S aureus is set at < 10 cfu/g (based on BAM). Is < 10 cfu/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing S
aureus?
I look forward to your response at the earliest possible. Thank you for understanding.
Herbalife |
From: Kishan H R
Sent: May 09 2019 16:38
To: Divya Narasimhan <[email protected]>
Cc: Sumit Nitnaware <[email protected]>; Shashi Shekhar <[email protected]>; Jesus Ortega‐Haquet
<[email protected]>
Subject: RE: [External] Re: Reg: Natural Caffeine Powder (Anhydrous) (2160025692/10), R00504
The link ed image cannot be display ed. The file may hav e been mov ed, renamed, or deleted. Verify that the link points to the correct file and location.
Regards,
Email : [email protected]
6
From: Kishan H R
Sent: 09 May 2019 04:36 PM
To: Divya Narasimhan <[email protected]>
Cc: Sumit Nitnaware <[email protected]>; Shashi Shekhar <[email protected]>; Jesus Ortega‐Haquet
<[email protected]>
Subject: RE: [External] Re: Reg: Natural Caffeine Powder (Anhydrous) (2160025692/10), R00504
Dear Divya,
The link ed image cannot be display ed. The file may hav e been mov ed, renamed, or deleted. Verify that the link points to the correct file and location.
Regards,
Email : [email protected]
7
Dear Aniket,
a) Attached COA indicates lot# 2160025692/10. This is also on the PDS. Can the lot#
2160025692/10, Sample Number & Qty and Mfg. Date, be removed from the PDS, as this gives
the impression that the PDS is “lot” specific.
c) Total Plate Count (< 10000 cfu/g) and Total Yeast & Mold (< 500 cfu/g) actual values are
not reported on COA lot#2160025692/10. Are these values also the detection limit of the
method? If not, can actual values be reported on the COA for these parameters going forward.
2. Allergen Statement(ALR): Please fill out the attached Herbalife Allergen template or confirm the absence of
below in this material, as the attached Allergen Statement that was provided does not cover these:
a. Tree Nuts, and products thereof (provide type of nuts e.g. Almonds, Beech Nuts, Brazil Nuts,
Butternut, Cashews, Chestnuts, Chinquapin, Coconut, Hazelnut/Filbert, Ginkgo Nuts, Hickory Nuts,
Lychee Nuts, Macadamia Nuts, Pecans, Pine Nuts, Pili Nuts, Pistachio, Shea Nut, Walnuts,
Queensland Nuts).
c. Natural Latex.
d. Gluten [Wheat (including Spelt and Kamut), Oats, Barley, Rye and Triticale].
8
Additionally, please help address the below on the PDS and COA:
1. Yeast & Mold, Lead and Mercury: We understand, that you have set higher specs for the below (compared
to Herbalife Specs) based on batch variation, but can you confirm based on the results on the attached
COA(lot# 2160025692/10), that if tested, this material will meet Herbalife Specs as listed below?
2. E coli: We understand that the spec for E coli is set at < 3 mpn/g (based on BAM). Is < 3 mpn/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing E
coli?
3. S aureus: We understand that the spec for S aureus is set at < 10 cfu/g (based on BAM). Is < 10 cfu/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing S
aureus?
I look forward to your response at the earliest possible. Thank you for understanding.
9
Thanks and Regards,
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize
the sender and know the content is safe.
Dear Divya,
Kindly find attached list of documents, we have already submitted a sample of 1 Kg, sample has been delivered on
4th April in Richmond road office.
COA for the same is attached in the documents zip file, we will share the composition statement soon as caffeine is a
pure extract from
reagrding TYMC, e coli & s aureus, lead & mercury, the source of the product is natural green coffee beans & they
are bound to fluctuate from batch to batch, depending upon change in climatic conditions.
10
that's the reason why we have considered higher range.
to kishanh, customerservice, me
Item Details
2160030471/10/NEWPRODUCT/CAFFEINE/1.000 /kg
Provide the tracking number in the below site to track the consignment.
11
The link ed image cannot be display ed. The file may hav e been mov ed, renamed, or deleted. Verify that the link points to the correct file and location.
Best Regards,
Aniket Ingale
E [email protected] | W www.synthite.com
Hi All,
I have updated the list of documents below with the additional request for a Non‐BSE Statement(BSE).
From: Kishan H R
Sent: May 02 2019 16:19
To: [email protected]
Cc: Divya Narasimhan <[email protected]>; Dr Viju Jacob (Synthite Kolenchery) ([email protected])
<[email protected]>; John Joshy Kondody (Synthite Kolenchery) ([email protected])
<[email protected]>; Binu Skaria(Synthite Kolenchery) ([email protected])
<[email protected]>
Subject: RE: Reg: Natural Caffeine Powder (Anhydrous) (2160025692/10), R00504
The link ed image cannot be display ed. The file may hav e been mov ed, renamed, or deleted. Verify that the link points to the correct file and location.
Regards,
Email : [email protected]
Dear Aniket,
13
Hope this finds you well.
I am reaching out to you with the below document request for Natural Caffeine Powder (Anhydrous)
(2160025692/10), R00504 as we are in the process of internally qualifying it for use. I have attached the COA and
some templates also for your convenience, to provide the information requested.
Please also kindly provide 3 X100g sample from the same lot (accompanied with a COA and ID Chromatogram) to
the following address. Kindly email me the tracking number once the samples are dispatched.
Additionally, please help address the below on the PDS and COA:
14
None detected when
BAM, USP or Can you confirm
2 E coli tested in a sample size < 3 mpn/g < 3 mpn/g
equivalent detection limit o
of 10 gm min
None detected when
BAM, USP or Can you confirm
3 S aureus tested in a sample size < 10 cfu/g < 10 cfu/g
equivalent the detection lim
of 10 gm min
Your spec for Le
4 Lead 1 ppm max ICP‐MS or equivalent 2 ppm max 2 ppm max your spec from 2
not, please let u
I look forward to your response at the earliest possible. Thank you for understanding.
‐‐
‐‐
Best Regards,
15
Aniket Ingale
E [email protected] | W www.synthite.com
‐‐
Best Regards,
Aniket Ingale
E [email protected] | W www.synthite.com
‐‐
Best Regards,
Aniket Ingale
E [email protected] | W www.synthite.com
17
Divya Narasimhan
Dear Divya,
Kindly find attached non BSE statement, STO declaration, MOA for caffeine & allergen control plan used for cleaning the
manufacturing facility thoroughly before change over to the new product extraction.
1. PDS (Product Data Sheet): PDS is missing in the attached, kindly provide updated PDS with the lot#
2160025692/10, Sample Number & Qty and Mfg. Date, removed.
2. E coli: We understand that the spec for E coli is set at < 3 mpn/g (based on BAM method). Is < 3 mpn/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing E coli?
‐ We confirm the minimum sample was 10 g
3. S aureus: We understand that the spec for S aureus is set at < 10 cfu/g (based on BAM method). Is < 10 cfu/g
also the detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for
testing S aureus? ‐ We confirm the minimum sample was 10 g
4. ID: Method of analysis, reference standard used for testing sigma standard. ‐ Reference standard used for ID
chromatograph was sigma standard.
6. Nutritional Information ‐ We have sent the sample to third party lab for analysis.
1
On Mon, May 13, 2019 at 3:00 PM Divya Narasimhan <[email protected]> wrote:
Dear Aniket,
Thank you very much for your email and for working on this request.
1. PDS (Product Data Sheet): PDS is missing in the attached, kindly provide updated PDS with the lot#
2160025692/10, Sample Number & Qty and Mfg. Date, removed.
2. E coli: We understand that the spec for E coli is set at < 3 mpn/g (based on BAM method). Is < 3 mpn/g also the
detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for testing E coli?
3. S aureus: We understand that the spec for S aureus is set at < 10 cfu/g (based on BAM method). Is < 10 cfu/g
also the detection limit of the method? Can you confirm that a minimum sample size of 10 g was used for
testing S aureus?
4. ID: Method of analysis, reference standard used for testing sigma standard.
6. Nutritional Information.
7. Non‐BSE Statement(BSE)
2
Divya Narasimhan| Sr. Specialist ‐ Documents Control| Quality Assurance|
Dear Divya,
a) On attached PDS, can the lot# 2160025692/10, Sample Number & Qty and Mfg. Date, be
removed from the PDS, as this gives the impression that the PDS is “lot” specific ‐ Corrected
Product Data Sheet is attached in the mail.
b) Total Plate Count (< 10000 cfu/g) and Total Yeast & Mold (< 500 cfu/g) actual values are
not reported on COA lot#2160025692/10. Are these values also the detection limit of the
method? If not, can actual values be provided for COA lot#2160025692/10, can actual results be
reported going forward, on the COA ‐ These are actual values only, we are sure that in future
batches the microbiology results will be under herbalife permissible limits.
2. ID chromatogram: Can you confirm attached ID chromatogram is for lot#2160025692/10, as the lot
number is not indicated. Additionally, please confirm which of these is the reference standard. We need the
chromatogram of both the sample (lot#2160025692/10) and reference standard ‐ Corrected ID
chromatograph is attached for your reference, we will share the Method of analysis, reference standard
used for testing sigma standard.
3
3.Allergen Statement(ALR): Since the attached Allergen statement indicates some allergens as “present in the
same manufacturing plant”, can you please provide your Allergen Control Program ‐ As explained we are
doing change over from product to product which comprises of steam washing of complete plant along
with cleaning in place with cleaning agent, flow chart for the same will be submitted by end of the day.
4.Nutritional Information(NUT): Please provide a nutritional statement for this material. ‐ Sample has been sent
to third party lab for nutritional data analysis, the results are expected within 8‐10 working days.
5. Storage Conditions(STO): Please provide the storage conditions for this material. Please note that we
cannot accept this information on the MSDS. Kindly add this to the PDS or provide a separate statement.
Email statement is also acceptable ‐ You need to keep the drum in sealed condition in cool and dry place
without any exposure to the sun & moisture.
6. Non‐BSE Statement(BSE): Please provide a Non‐BSE Statement for this material ‐ Non‐BSE statement will
be sent to you by the end of the day.
Additionally, please help address the below on the PDS and COA:
1.Yeast & Mold, Lead and Mercury: We understand, that you have set higher specs for the below (compared to
Herbalife Specs) based on natural batch variation, but can you confirm based on the results on the attached
COA(lot# 2160025692/10), that if tested, this material will meet Herbalife Specs as listed below? ‐ Our
product test results will be within herbalife specs for all the supplies.
Dear Aniket,
Any updates on our request for samples for lot#2160025692/10? Please note that a 150g sample would suffice. If
available, please kindly send to Kishan’s attention.
4
Chaithra .
Dear Samyukta,
1. We have received samples 2800014529/10 (400g) and 2800014529/20(100g). Only these sample
numbers are indicated on the label. Could you please provide the actual lot numbers and COA
for the samples? Two COAs Attached.
2. PDS is missing below parameters, can these be added? PIS Updated and Attached
Parameter Specification
Pesticide Residue 213 Per FSSAI
Melamine 2.5 ppm max
3. We understand that lot# 421H231726 not tested for below parameters. Could you please provide
future COA template for below parameters, and can you please acknowledge on below spec and
test frequency? We can provide Bacillus cereus and Sulfite reducing clostridia (SRC) in every
lot in future consignments. As per FSSAI we are testing the highlighted parameters every
6 months
4. Composition statement doesn’t indicate the % range of ingredient. Is this 100% NATURAL
CAFFEINE POWDER? Attached
5. Please provide Storage condition: PIS updated
Dear Samyukta,
2
Samyukta Hegde
Dear Samyukta,
Hi Shaiju,
1. Per Old mfg flow chart, material is extracted via hot water extraction, where in new mfg flow chart, extraction process via water and calcium
hydroxide. Please clarify.
Attached
1
2. In all previous documents material name provided as “Natural Caffeine Powder (Anhydrous)”, where in new documents “NATURAL CAFFEINE
EXTRACT 98.5%”. Please let us know why material name has been changed. Please provide product code equivalence statement, if both are
same.
Declaration attached
3. Please confirm the testing frequency for Total Aflatoxins (B1+B2+G1+G2), Aflatoxin B1 (Herbalife testing frequency is ‘First 3 delivery lots and
once a year’).