Fi: We've talked a lot of about ingredient quality, particularly for ingredients from China. How big is this problem, and what solutions do you see?
SS: Ingredient quality and transparency of supplier is the issue around which I have established my career. Ingredient quality is a concern that has gained a great deal of geographic consideration but in no way should that be the central criteria. The central criteria should be the thorough knowledge of the quality of the company and, most importantly, the processes that go into the manufacturing of the ingredient. While it is conceivably impossible for many companies to audit every ingredient manufacturer, it is important every effort to assess the ingredient manufacturing process be conducted. It is my contention the more transparent the ingredient manufacturer becomes, the more likely they are to supply a consistent quality ingredient. Having said that I also believe it is important to look for reputable third party references that support the manufacturing process.
Fi: Can GMPs alone address spiking and economic adulteration?
SS: GMPs alone are not the complete answer to ingredient verification. Routine and complete ingredient analysis is imperative. Current cGMP makes the brand holder ultimately responsible for each component of the product. Recent FDA warning letters indicate the responsibility of ingredient verification rests with the brand holder regardless of the involvement of a contract manufacturer. This onus of responsibility makes the evaluation of ingredient manufacturers even more important to the brand holders. Transparency of supply needs to be applied as far back in the supply chain as possible.
Fi: How can suppliers compete with companies selling ingredients that are either not what they are purported to be or are just garbage?
SS: The risk of "getting caught" selling garbage has increased over the past few years thanks largely to cGMPs but also to the realization that faulty or false ingredients will likely be identified somewhere in the supply process. A company which has been identified as having promoted bad product is more easily exposed through FDA, internet and the media with rapid and substantial economic impact. FDA warning letter NYK 2011-24 was to a contract manufacturer whereby the brand holder was identified and subsequently became transparent to anyone on the internet. FDA warning letter NYK 2011-28 was to a brand holder whereby the FDA stated the brand holder was deficient in establishing specifications for the components. The risk/reward analysis has changed dramatically to the point that it has become less worthwhile to accept ingredients based solely on price.
Fi: Do you wear kilts only for meetings of the Single Malt Quality Assurance Association (SMQAA ) or is that a regular part of your wardrobe?
SS: Having been born and raised in Texas, kilts were not a garment with which I was privileged to have association; F-150s and kilts are not an easy match. SMQAA and my more Scottish brethren introduced me to the nuances and, dare I say, enjoyment of the kilt experience. My Texas friends and family don't really understand, but having Scott as a first name makes answering the question "are you Scottish?" much easier! Wearing a kilt was never on my bucket list but having worn one a time or two I highly recommend the experience at least once. Luckily, I don't look better than my wife in a dress so she accepts my Scottish attire as well.