The American Kava Association- Advocating for the responsible distribution of Kava in North America.
- Thread starter kl.TylerKTB
- Start date
I don't live in the US but I like the idea. I think it would be great for kava's reputation all around the world if kava became a more mainstream product in the US, and of course it would be critical that it is marketed and distributed in a responsible way. I wish you luck guys.
Ed!
Kava Enthusiast
I love this stuff. Thanks for being a leader here, Tyler.
I can't think of any other points that would be good to have, and I don't take issue with anything on there. I think if anything is missing from those 9 points it's just what you mentioned earlier, having educated staff that can speak to the cultural relevance of kava. From our previous discussions on this topic I think that's a really big deal, and what takes kava out of the "you're just finding a plant that you get get messed up on!" into the space of a unique cultural experience that's in many ways better than our culturally accepted crud. We aren't licking toads or sniffing glue here, this is a time-honored tradition.
Regarding the age thing I think Judd's approach is great, and I agree with others that when you go with the "U CANNOT HAV" approach you unintentionally encourage over-indulgence, which in-turn encourages negative attention. Education and recommending caution are what I think needs to happen here, not a hard and fast rule either way. Treating younger folks like adults and encouraging responsibility works better than treating them like stupid puppies. Stupid puppies like to see what they can get away with.
Otherwise I'm really excited. I've considered trying to start a kava bar/juice bar/tea shop in the past that caters to green-minded folks (hipsters?). I just don't know for sure if my widwestern city is ready to take to something like that. This could be a good step (at least politically) towards getting the area to accept kava.
I can't think of any other points that would be good to have, and I don't take issue with anything on there. I think if anything is missing from those 9 points it's just what you mentioned earlier, having educated staff that can speak to the cultural relevance of kava. From our previous discussions on this topic I think that's a really big deal, and what takes kava out of the "you're just finding a plant that you get get messed up on!" into the space of a unique cultural experience that's in many ways better than our culturally accepted crud. We aren't licking toads or sniffing glue here, this is a time-honored tradition.
Regarding the age thing I think Judd's approach is great, and I agree with others that when you go with the "U CANNOT HAV" approach you unintentionally encourage over-indulgence, which in-turn encourages negative attention. Education and recommending caution are what I think needs to happen here, not a hard and fast rule either way. Treating younger folks like adults and encouraging responsibility works better than treating them like stupid puppies. Stupid puppies like to see what they can get away with.
Otherwise I'm really excited. I've considered trying to start a kava bar/juice bar/tea shop in the past that caters to green-minded folks (hipsters?). I just don't know for sure if my widwestern city is ready to take to something like that. This could be a good step (at least politically) towards getting the area to accept kava.
kl.TylerKTB
Kava Curious
Good point Vekta. I intentionally avoided putting the word Kava in the name of my establishment. The local health departments can be extremely difficult once they catch onto the idea that you will be serving Kava. I spent literally days arguing with city, local, and state Health Boards on the liver toxicity (non) issue with traditionally prepared Kava. I'll have to upload some of the letters I got from the State health board, they have a bunch of entertaining reasons why Kava should not be served in retail spots. Perhaps we SHOULD stray from the association with "Bars".
"They're called Nakamals in the islands"
Only in Vanuatu. That word has no meaning in Fiji, Polynesian nations, Solomons and so on.
" I think the term "kava bar" might need some changing."
This is a good point though. It might be hard to disassociate kava drinking with other "bar like activities" without dropping the word "bar" entirely.
Only in Vanuatu. That word has no meaning in Fiji, Polynesian nations, Solomons and so on.
" I think the term "kava bar" might need some changing."
This is a good point though. It might be hard to disassociate kava drinking with other "bar like activities" without dropping the word "bar" entirely.
Yes, those islands.
The question that popped into my head right after I posted that and had to leave was " Well what in the heck are we suppose to call them?"
ha! As far as I know I've only seen them referred to a couple different ways.
*after thought*
I was working on my bicycle the past hour or so and it occurred to me that Judd already gave us a good alternative for "kava bar".
"Kava House"
Saying "hey, lets bring the kids to the Kava House" sounds better than "hey, lets bring the kids to the Kava Bar". Doesn't it?
The question that popped into my head right after I posted that and had to leave was " Well what in the heck are we suppose to call them?"
ha! As far as I know I've only seen them referred to a couple different ways.
*after thought*
I was working on my bicycle the past hour or so and it occurred to me that Judd already gave us a good alternative for "kava bar".
"Kava House"
Saying "hey, lets bring the kids to the Kava House" sounds better than "hey, lets bring the kids to the Kava Bar". Doesn't it?
Bravo Tyler!
Although, we are not kava bar owners, we have supplied several kava bars in Hawaii and several on the mainland. Being the people behind the people is a big responsibility and one we take seriously, as most of you know.
The framework seems comprehensive and the KAVA BAR parts are for you guys to iron out. However, some of e following points are important to us right now, and more will be added later.
No minors, 18+ got my 'yes', we've written that on our website and every jar of extract since we got into business. We need this clause. A 16 year old with cool parents is the exception.
I like the accountability of mixing a certain kava amount weight to water ratio, which differs for fresh and powder. I know an old fresh kava supplier f years past, who is now out of business because of a serious lack of Hawaiian kava growers in Hawaii, who insisted on a specific ratio of kava pulp to water for every client kava bar; if they disagree, he stops supplying them. Tough but effective. Kava cannot get a bad name if good quality beverage is being ingested and a fair quantity of kava is in each shell.
I will not go into detail but you and I spoke briefly in person about a certain Hawaiian kava bar you visited here which sold light muddy water with very little kava. I nodded and shook my head and uttered my standard line about them " if you have nothing good to say, don't say anything at all"
However, an association changes my standard response and it removes the personal aspect, since I know these people well, as well as most kava bar owners in Hawaii. I understand their issues with high rent and tight supply. I also understand how they buy product. Non standardized and erratically cleaned. Some batches are clean, some are dirty. Sometimes they run a special for $2 a shell instead of their regular $5 and all you will do is urinate all night without feeling the effects a noticeably weak kava.
I can go on...kava bars are like any other niche business. There is not one for many miles around, so they have certain advantages to do as they please, and also have certain obligations to the industry to represent kava at its finest. Choice is theirs.
a positive marketing plan for us has always been -
The TRADITIONAL aspect of kava as a drink encircled with a lineage of ceremony and one with multiple uses. From teething and high strung children to honoring chiefs and guests. This is our staff of life Tyler. It protects our industry and the original kava beverage. Critical and of singular importance IMO. All other value added products come second.
Besides this one, its all grey areas where claims cannot be made.
Not a single claim on a jar of kava we ever sold, as an example. From 1st generation to the upcoming 5th, we stay far far away from clams of any sort.
A business killer and necessary burden to bear in this unregulated kava world we inhabit.
One of my mentors and dear friend, Uncle Robert of Kalapana solved this BAR issue by calling his place UNCLE'S AWA CLUB. I think it's genius to dissociate with alcohol.
Adil Ghiasi
Although, we are not kava bar owners, we have supplied several kava bars in Hawaii and several on the mainland. Being the people behind the people is a big responsibility and one we take seriously, as most of you know.
The framework seems comprehensive and the KAVA BAR parts are for you guys to iron out. However, some of e following points are important to us right now, and more will be added later.
No minors, 18+ got my 'yes', we've written that on our website and every jar of extract since we got into business. We need this clause. A 16 year old with cool parents is the exception.
I like the accountability of mixing a certain kava amount weight to water ratio, which differs for fresh and powder. I know an old fresh kava supplier f years past, who is now out of business because of a serious lack of Hawaiian kava growers in Hawaii, who insisted on a specific ratio of kava pulp to water for every client kava bar; if they disagree, he stops supplying them. Tough but effective. Kava cannot get a bad name if good quality beverage is being ingested and a fair quantity of kava is in each shell.
I will not go into detail but you and I spoke briefly in person about a certain Hawaiian kava bar you visited here which sold light muddy water with very little kava. I nodded and shook my head and uttered my standard line about them " if you have nothing good to say, don't say anything at all"
However, an association changes my standard response and it removes the personal aspect, since I know these people well, as well as most kava bar owners in Hawaii. I understand their issues with high rent and tight supply. I also understand how they buy product. Non standardized and erratically cleaned. Some batches are clean, some are dirty. Sometimes they run a special for $2 a shell instead of their regular $5 and all you will do is urinate all night without feeling the effects a noticeably weak kava.
I can go on...kava bars are like any other niche business. There is not one for many miles around, so they have certain advantages to do as they please, and also have certain obligations to the industry to represent kava at its finest. Choice is theirs.
a positive marketing plan for us has always been -
The TRADITIONAL aspect of kava as a drink encircled with a lineage of ceremony and one with multiple uses. From teething and high strung children to honoring chiefs and guests. This is our staff of life Tyler. It protects our industry and the original kava beverage. Critical and of singular importance IMO. All other value added products come second.
Besides this one, its all grey areas where claims cannot be made.
Not a single claim on a jar of kava we ever sold, as an example. From 1st generation to the upcoming 5th, we stay far far away from clams of any sort.
A business killer and necessary burden to bear in this unregulated kava world we inhabit.
One of my mentors and dear friend, Uncle Robert of Kalapana solved this BAR issue by calling his place UNCLE'S AWA CLUB. I think it's genius to dissociate with alcohol.
Adil Ghiasi
kl.TylerKTB
Kava Curious
Hey Adil!
Thanks for coming in, as always, your words are pearls brother.
Everyone that I have talked to has had very little disagreement with these minimum set of rules. I am good to post them on the site for the moment, as I have to get this thing up and going - obviously if we have some minor details that need some changing, we will do so. I'll make a voting section on the site as well so that when we do propose rules, or changes to rules, members can login and democratically vote the rules in. Deal?
Since we have accomplished a loose set of rules for the bars, lets move into association approved suppliers and their rules. This would be farmers and wholesale distributors. I realize that it was only a few weeks ago that I came under scrutiny for having 7500 other plants next to Kava in the same catalog. We all have our different views on it but for the purpose of the association I feel like an approved supplier ought to be subject to the same rules that the Kava serving establishments are subject to which states that it should not be served next to K@. Therefore, while it excludes my personal parent company from becoming an approved vendor, I'll go ahead and throw it out there so its not weird for anyone else to have to bring up: An association approved Supplier ought to specialize PRIMARILY in Kava.
1. An association approved supplier ought to specialize PRIMARILY in Kava.
2. Noble varieties
3. FDA / USDA inspected facilities with FDA reg numbers (as much as I hate them, its the law that if you distribute food / herbs, you need to be registered)
4. Certificates of Analysis on batches - KT's Lab can assist anyone wanting to do a cheap cert, I do them for people often for less than half what the other guys do them for.
5. Same Marketing standards as the serving establishments
6. Listing name / origin / age of the root
7. Chem ferts?
Help - I am on the road and my brains scattered, if someone can re-organize these into a coherent manner and add any other ideas to the list, that would be awesome. We don't want to make it overly invasive, but we need some standards here as well.
Thanks for coming in, as always, your words are pearls brother.
Everyone that I have talked to has had very little disagreement with these minimum set of rules. I am good to post them on the site for the moment, as I have to get this thing up and going - obviously if we have some minor details that need some changing, we will do so. I'll make a voting section on the site as well so that when we do propose rules, or changes to rules, members can login and democratically vote the rules in. Deal?
Since we have accomplished a loose set of rules for the bars, lets move into association approved suppliers and their rules. This would be farmers and wholesale distributors. I realize that it was only a few weeks ago that I came under scrutiny for having 7500 other plants next to Kava in the same catalog. We all have our different views on it but for the purpose of the association I feel like an approved supplier ought to be subject to the same rules that the Kava serving establishments are subject to which states that it should not be served next to K@. Therefore, while it excludes my personal parent company from becoming an approved vendor, I'll go ahead and throw it out there so its not weird for anyone else to have to bring up: An association approved Supplier ought to specialize PRIMARILY in Kava.
1. An association approved supplier ought to specialize PRIMARILY in Kava.
2. Noble varieties
3. FDA / USDA inspected facilities with FDA reg numbers (as much as I hate them, its the law that if you distribute food / herbs, you need to be registered)
4. Certificates of Analysis on batches - KT's Lab can assist anyone wanting to do a cheap cert, I do them for people often for less than half what the other guys do them for.
5. Same Marketing standards as the serving establishments
6. Listing name / origin / age of the root
7. Chem ferts?
Help - I am on the road and my brains scattered, if someone can re-organize these into a coherent manner and add any other ideas to the list, that would be awesome. We don't want to make it overly invasive, but we need some standards here as well.
August West
Kava Enthusiast
Tyler, I appreciate your time, effort, and knowledge for safeguarding the root. And you do it with class, man. Even though things got a little heated, i'm glad my thread brought you to this forum. Thanks again. Once I have the funds, i'm excited to sample yours' and Adil's piper. He's been good to me as well.
Good posts and nice to read everyone's ideas and comments. It seems like a lot of the onerous should (and still be) on the source of the kava and following the supply chain from the originating country. Unfortunately, there is supply out there cut with less quality kava because farmers need to make some extra cash. By the time we get it in the United States, we don't know entirely what we are dealing with (unless the buyer has close connections with the process) -thus, no matter how good the laws or enforcement is; we are essentially regulating "tainted" product that could potentially do harm to the kava industry in the long run.
My one big question about the last proposed regs. is how enforceable are they really going to be? Like Steve mentioned there is going to be kava out there cut with sub-par root and there really isn't a whole lot any law or regulation that's going to do much about that. I'm not saying regulation is bad or pointless. The regs suggested might not even be unreasonable but how realistic are some of those really?
#1 That's a given#2 Like it#3 It must be done#4 Well...ok...that's nice. But if a vendor meets everything else but this then what? Cheap or not it's more overhead to be apart of "the club" so to speak and that extra cost may get passed down the line. What exactly is analysed here? Is this test to ensure the quality, safety and authenticity of the kava or is it mainly just to say something like "This is Kava and this certificate says it is what I said it was" kind of thing? #4 is still a good thing but not a shoe-in at least in my mind#5 Yeah, that's great. Simple and uniform#6 It would be nice, if possible#7 Please, do tell
#1 That's a given#2 Like it#3 It must be done#4 Well...ok...that's nice. But if a vendor meets everything else but this then what? Cheap or not it's more overhead to be apart of "the club" so to speak and that extra cost may get passed down the line. What exactly is analysed here? Is this test to ensure the quality, safety and authenticity of the kava or is it mainly just to say something like "This is Kava and this certificate says it is what I said it was" kind of thing? #4 is still a good thing but not a shoe-in at least in my mind#5 Yeah, that's great. Simple and uniform#6 It would be nice, if possible#7 Please, do tell
kl.TylerKTB
Kava Curious
Hi Steve, thanks for chiming in!
This is exactly what we're trying to prevent. As many kava-cutting, shady businessmen as there are out there, there are also plenty of good farms and honest distributors who don't cut their product. Lets support those farmers and distributors and only allow the highest quality material through our approved wholesalers, retailers, and kava serving establishments. This is where analytical testing comes in. I test everything, be it kava, or any other botanical I work with, to make sure it conforms to some standardized specification. I encourage other vendors to do the same because well, its the law, and its in your best interest, as well as the best interests of your customers, and the plant itself.
If Vanuatu Boroguru is supposed to be 14% Kavalactones and the 426XXX Chemotype, its a pretty simple test to confirm that through HPLC, GC/MS, and or Near Infared spectrum technologies. FDA regs clearly state several requirements which are often ignored by smaller vendors who don't follow GMP (good manufacturing process) regulations. Briefly, when you get a batch of a "raw agricultural commodity" like Kava from a farmer, it is entirely the vendor's responsibility to perform all testing on this material to ensure that it meets MINIMUM standards. Farmers who harvest Kava, have absolutely no GMP regulations in place to ensure a quality product. FDA makes that clear: Exclusions § 110.19
(a) The following operations are not subject to the GMP: Establishments engaged solely in the harvesting, storage, or distribution of one or more “raw agricultural commodities” as defined in section 201(r) of the act, which are ordinarily cleaned, prepared, treated, or otherwise processed before being marketed to the consuming public.
Until you have conducted the proper testing on your material that you intend to sell, it must be quarantined away from your other materials. You must perform a certificate of analysis on this material and test it for identity markers, microbiological testing, heavy metals, and pesticides. These are MINIMUM requirements as required by FDA and GMP proceedures, I usually go a few steps above these requirements to be on the safe side. Failure to do so will get your facility shut down and inventory confiscated, not to mention you will be smeared by the FDA for the rest of your existence. After you perform the COA on the material and it "conforms to spec" i.e. Kavalactones are at 15%, chemotype is what was expected based upon what the farmer said they were supplying, no pesticides, bugs, e. coli, or mold etc., it can be moved from quarantine and into your GMP clean room for packaging. Again - these are really basic FDA requirements that any vendor of any herb must follow if they wish to market their products within the United States.
You cannot simply grab kava from a farmer, put it in your own bag and start selling kava to people. As ridiculous as that might sound to some, it sounds equally ridiculous to me that anyone would think that you would be allowed to do this. So really, all I am suggesting is that the association would simply approve Kava suppliers who are actually following the laws and regulations, testing their materials for quality and contaminants.
As Vekta pointed out - theres overhead involved - I absolutely hear that haha. I am already regulated to the hilt and these sorts of formalities cost me an arm and a leg. Here's another way of looking at it. A COA might run you $150 - $350 depending on the depth of analysis, on a batch of Kava from your favorite farmer. One FDA visit will ruin your entire operation if they show up and you are not registered with them or following GMP regulations such as a GMP clean room, packaging station, batch numbers, quarantine, spec sheets, and master manufacturing records. Being able to show your customers that you are a responsible vendor that abides by FDA law, tests your material for E. Coli, lead, Arsenic, etc. and follows good manufacturing processes, is worth more than the dollar per pound increase in cost that a proper COA would run you. From a liability standpoint, how would a vendor possibly defend themselves if say a batch of their kava gave someone E. Coli? What exactly would they say? The farmer who gave it to me said it was good and clean? I ate it myself and I am fine? FDA would have a field day and by the end of it, armed FDA swat teams would be hauling every bit of inventory out of the vendors home office. My suggestion is to approve vendors who follow GMP requirements which includes analytically testing their product before giving it to consumers.
By educating people to these facts we would be steering consumers to responsible vendors and kava houses who buy from responsible distributors and farmers and the costs will pay for themselves many times over.
My suggestion is to have the association use its collective volume purchasing power to get the cost of COA's down to a very reasonable cost per test, or have the association be the issuing body for these COA's. I'll also be glad to assist anyone in getting up to compliance if they want to make their own COA's using their own independent labs (outside of mine or the other ones that I use).
This is exactly what we're trying to prevent. As many kava-cutting, shady businessmen as there are out there, there are also plenty of good farms and honest distributors who don't cut their product. Lets support those farmers and distributors and only allow the highest quality material through our approved wholesalers, retailers, and kava serving establishments. This is where analytical testing comes in. I test everything, be it kava, or any other botanical I work with, to make sure it conforms to some standardized specification. I encourage other vendors to do the same because well, its the law, and its in your best interest, as well as the best interests of your customers, and the plant itself.
If Vanuatu Boroguru is supposed to be 14% Kavalactones and the 426XXX Chemotype, its a pretty simple test to confirm that through HPLC, GC/MS, and or Near Infared spectrum technologies. FDA regs clearly state several requirements which are often ignored by smaller vendors who don't follow GMP (good manufacturing process) regulations. Briefly, when you get a batch of a "raw agricultural commodity" like Kava from a farmer, it is entirely the vendor's responsibility to perform all testing on this material to ensure that it meets MINIMUM standards. Farmers who harvest Kava, have absolutely no GMP regulations in place to ensure a quality product. FDA makes that clear: Exclusions § 110.19
(a) The following operations are not subject to the GMP: Establishments engaged solely in the harvesting, storage, or distribution of one or more “raw agricultural commodities” as defined in section 201(r) of the act, which are ordinarily cleaned, prepared, treated, or otherwise processed before being marketed to the consuming public.
Until you have conducted the proper testing on your material that you intend to sell, it must be quarantined away from your other materials. You must perform a certificate of analysis on this material and test it for identity markers, microbiological testing, heavy metals, and pesticides. These are MINIMUM requirements as required by FDA and GMP proceedures, I usually go a few steps above these requirements to be on the safe side. Failure to do so will get your facility shut down and inventory confiscated, not to mention you will be smeared by the FDA for the rest of your existence. After you perform the COA on the material and it "conforms to spec" i.e. Kavalactones are at 15%, chemotype is what was expected based upon what the farmer said they were supplying, no pesticides, bugs, e. coli, or mold etc., it can be moved from quarantine and into your GMP clean room for packaging. Again - these are really basic FDA requirements that any vendor of any herb must follow if they wish to market their products within the United States.
You cannot simply grab kava from a farmer, put it in your own bag and start selling kava to people. As ridiculous as that might sound to some, it sounds equally ridiculous to me that anyone would think that you would be allowed to do this. So really, all I am suggesting is that the association would simply approve Kava suppliers who are actually following the laws and regulations, testing their materials for quality and contaminants.
As Vekta pointed out - theres overhead involved - I absolutely hear that haha. I am already regulated to the hilt and these sorts of formalities cost me an arm and a leg. Here's another way of looking at it. A COA might run you $150 - $350 depending on the depth of analysis, on a batch of Kava from your favorite farmer. One FDA visit will ruin your entire operation if they show up and you are not registered with them or following GMP regulations such as a GMP clean room, packaging station, batch numbers, quarantine, spec sheets, and master manufacturing records. Being able to show your customers that you are a responsible vendor that abides by FDA law, tests your material for E. Coli, lead, Arsenic, etc. and follows good manufacturing processes, is worth more than the dollar per pound increase in cost that a proper COA would run you. From a liability standpoint, how would a vendor possibly defend themselves if say a batch of their kava gave someone E. Coli? What exactly would they say? The farmer who gave it to me said it was good and clean? I ate it myself and I am fine? FDA would have a field day and by the end of it, armed FDA swat teams would be hauling every bit of inventory out of the vendors home office. My suggestion is to approve vendors who follow GMP requirements which includes analytically testing their product before giving it to consumers.
By educating people to these facts we would be steering consumers to responsible vendors and kava houses who buy from responsible distributors and farmers and the costs will pay for themselves many times over.
My suggestion is to have the association use its collective volume purchasing power to get the cost of COA's down to a very reasonable cost per test, or have the association be the issuing body for these COA's. I'll also be glad to assist anyone in getting up to compliance if they want to make their own COA's using their own independent labs (outside of mine or the other ones that I use).
kl.TylerKTB
Kava Curious
Absolutely Vekta, I sincerely appreciate all of your comments brother, you have brought many excellent points to the table.
krunkedout
Kava Lover
All sounds pretty good to me. As long as its not so harsh that people would be discouraged from starting kava clubs or nakamals. And I would much rather pay a few extra bucks and buy root that I know where it came from and know its high quality.
kl.TylerKTB
Kava Curious
I'm wishing a few more farmers could chime in on this one... I'm going to have to make a few calls hehe.
I'm sure Adil can attest to FDA regs as he is one of the farmers who is well versed in the FDA rules on the supply end of things.
An association approved Farmer / Supplier should:
1. Specialize PRIMARILY in Kava.
2. Sell noble varieties with a minimum 3 year harvest.
3. Be registered with FDA or USDA and be in full accordance with cGMP or cGAP - whichever is applicable to their operation. This is to include but not limited to:
a. Proper cleaning and drying of root material.
b. The disposal of the above ground portions.
c. Keeping meticulous records which include grow logs, harvest date, variety, date dried, date powdered, date packaged, batch numbers and shipping records
d. Farmers and Vendors who package Kava for sale must also keep meticulous records in accordance with GMP requirements which include quarantine requirements, inventory records, batch numbers, analytical testing, and shipping records.
4. Be able to provide current Certificates of Analysis on their Kavas before selling to wholesalers, retailers, Kava serving establishments, or end users.
5. Not market kava as an alternative to any other substance or make health or drug claims as defined by FDA.
6. Labeling shall include the name / origin / age of the root as well as the FDA / USDA reg number and contact info for the vendor.
Now if you've never heard about any of the FDA GMP stuff before, it can be overwhelming. The association is here to help with that. For example COA's can be made using relatively simple analyses and fairly cheaply. GMP requirements went into effect in 2010 for small businesses. We all had to get on board. If you are still not on board with GMP, I highly suggest you bring your company up to standard before FDA nails you, and they will. Make a clean room with a filtered air supply, wear booties, a lab coat, and a hair / beard net. Quarantine and test your materials. The clean room needs washable surfaces, i.e. a stainless steel top. No carpet. Keep meticulous records, post your procedures, don't have dogs running around the clean room, don't store your Kava on the floor, keep it in double sealed bags, etc.. Register with the FDA and buy from FDA registered farms (yes Vanuatu has FDA registered facilities too). A good portion of this is common sense (i.e. don't lick the kava spoon and put it back in the bag). You can bring your business into compliance in a month and be smooth sailing after that. Your customers will thank you for showing them where their material is being processed and bagged so they don't have to wonder.
So why is any of this important? Isn't it a bit much? Yeah, it might seem that way. Afterall, the ancients were just digging up a muddy root and smashing it and drinking it. However, they didn't use pesticides, chemical fertilizers, have a bunch of environmental contaminants, or know anything about yeast, mold, e. coli etc.. Here in the modern regulatory climate, its extremely important for Kava to have farmers / suppliers to follow the minimum set of standards outlined by the FDA and USDA for food and supplement safety. The last time that we had irresponsible farmers / sellers / manufacturers in the Kava supply chain who weren't following the rules was when China bought the above ground scraps trying to save a buck and sold it as Kava root extract and we nearly lost the plant forever. A simple analytical test could have alerted these companies, "Hey, our Kava root Extract has chlorophyll in it and the roots don't have any chlorophyll... somethings not right here Bill, didn't we buy root extract?" We should not support a Kava market that is more concerned with obtaining cheaper kava by forgoing minimal standards, than they are with following the rules and protecting the customers whom they serve. Again, the FDA and GMP requirements that i am proposing are minimal standards that any legitimate and legal herbal distribution business would already be abiding by and wouldn't cost them a dime or encumber their businesses whatsoever.
Point 7 - I was curious how we felt about chemical fertilizers. It'd be nice to grab some nice organic Kava =) I'll strike the idea, and if we get good organic stuff popping up, awesome, I will sure buy it, but I don't think it should be a requirement.
I'm sure Adil can attest to FDA regs as he is one of the farmers who is well versed in the FDA rules on the supply end of things.
An association approved Farmer / Supplier should:
1. Specialize PRIMARILY in Kava.
2. Sell noble varieties with a minimum 3 year harvest.
3. Be registered with FDA or USDA and be in full accordance with cGMP or cGAP - whichever is applicable to their operation. This is to include but not limited to:
a. Proper cleaning and drying of root material.
b. The disposal of the above ground portions.
c. Keeping meticulous records which include grow logs, harvest date, variety, date dried, date powdered, date packaged, batch numbers and shipping records
d. Farmers and Vendors who package Kava for sale must also keep meticulous records in accordance with GMP requirements which include quarantine requirements, inventory records, batch numbers, analytical testing, and shipping records.
4. Be able to provide current Certificates of Analysis on their Kavas before selling to wholesalers, retailers, Kava serving establishments, or end users.
5. Not market kava as an alternative to any other substance or make health or drug claims as defined by FDA.
6. Labeling shall include the name / origin / age of the root as well as the FDA / USDA reg number and contact info for the vendor.
Now if you've never heard about any of the FDA GMP stuff before, it can be overwhelming. The association is here to help with that. For example COA's can be made using relatively simple analyses and fairly cheaply. GMP requirements went into effect in 2010 for small businesses. We all had to get on board. If you are still not on board with GMP, I highly suggest you bring your company up to standard before FDA nails you, and they will. Make a clean room with a filtered air supply, wear booties, a lab coat, and a hair / beard net. Quarantine and test your materials. The clean room needs washable surfaces, i.e. a stainless steel top. No carpet. Keep meticulous records, post your procedures, don't have dogs running around the clean room, don't store your Kava on the floor, keep it in double sealed bags, etc.. Register with the FDA and buy from FDA registered farms (yes Vanuatu has FDA registered facilities too). A good portion of this is common sense (i.e. don't lick the kava spoon and put it back in the bag). You can bring your business into compliance in a month and be smooth sailing after that. Your customers will thank you for showing them where their material is being processed and bagged so they don't have to wonder.
So why is any of this important? Isn't it a bit much? Yeah, it might seem that way. Afterall, the ancients were just digging up a muddy root and smashing it and drinking it. However, they didn't use pesticides, chemical fertilizers, have a bunch of environmental contaminants, or know anything about yeast, mold, e. coli etc.. Here in the modern regulatory climate, its extremely important for Kava to have farmers / suppliers to follow the minimum set of standards outlined by the FDA and USDA for food and supplement safety. The last time that we had irresponsible farmers / sellers / manufacturers in the Kava supply chain who weren't following the rules was when China bought the above ground scraps trying to save a buck and sold it as Kava root extract and we nearly lost the plant forever. A simple analytical test could have alerted these companies, "Hey, our Kava root Extract has chlorophyll in it and the roots don't have any chlorophyll... somethings not right here Bill, didn't we buy root extract?" We should not support a Kava market that is more concerned with obtaining cheaper kava by forgoing minimal standards, than they are with following the rules and protecting the customers whom they serve. Again, the FDA and GMP requirements that i am proposing are minimal standards that any legitimate and legal herbal distribution business would already be abiding by and wouldn't cost them a dime or encumber their businesses whatsoever.
Point 7 - I was curious how we felt about chemical fertilizers. It'd be nice to grab some nice organic Kava =) I'll strike the idea, and if we get good organic stuff popping up, awesome, I will sure buy it, but I don't think it should be a requirement.
kl.TylerKTB
Kava Curious
I would too... any day of the week. The markup at a nakamal certainly affords a dollar or two extra per pound. And where you and I are coming from on this one, there are many people who, when given the choice, would want to know that their material is clean, pesticide free, and lacking heavy metals. Even if the chances of Kava from our usual suppliers containing these things is relatively low, the market will respond positively to those who put that sort of care and concern into their craft, over those who do not. This is where I say the price to implement these standards should be looked at as a minor investment with an enormous ROI for farmers / suppliers, vendors, and kava serving establishments alike. In the end, if the consumer is made aware that these sorts of standards exist and that THESE businesses follow them, 9 times out of 10 the consumer will choose these businesses over the ones who do not follow these standards.Krunkedout said:
KavaKrunked
Kava Enthusiast
Adil-
I found it interesting that you mentioned that a certain kava to water ratio should be required. I thought for sure the aim of this would be to limit the strength of grog, when in fact the opposite is true. Outstanding.
But I think free market capitalism would win in the event that a location produces sub-par grog strength. If a regular bar only served a half-beer, half-strength mixed drink, or 0.75 oz of liquor in a shot but charged the same price as the bar down the street, they would lose customers very quickly. This assumes local competition, however, which certainly isn't the case in all cities with a nakamal (yet, I hope!).
Great points.
I found it interesting that you mentioned that a certain kava to water ratio should be required. I thought for sure the aim of this would be to limit the strength of grog, when in fact the opposite is true. Outstanding.
But I think free market capitalism would win in the event that a location produces sub-par grog strength. If a regular bar only served a half-beer, half-strength mixed drink, or 0.75 oz of liquor in a shot but charged the same price as the bar down the street, they would lose customers very quickly. This assumes local competition, however, which certainly isn't the case in all cities with a nakamal (yet, I hope!).
Great points.
Tyler, everything you wrote is in accord with my views, but we already knew that when we met 
Kava krunked, standardization is the key to determining actual value per cup ( talking about all elements involved, cost, benefit, etc)
Kava krunked, standardization is the key to determining actual value per cup ( talking about all elements involved, cost, benefit, etc)