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SALMONELLA: FACT & FICTION
#1
FROM THE DESK OF DAVE HERMAN
CHAIRMAN
AMERICAN KRATOM ASSOCIATION

TO ALL KRATOM VENDORS

SALMONELLA: FACT AND FICTION

The Salmonella outbreak in some kratom products has dominated the news cycle across the country over the past three weeks, largely because of the war on kratom that the FDA is waging in their broader effort to criminalize kratom manufacturers and consumers. That War on Kratom is the fiction of the day, and the FDA should end its campaign of misinformation.

Salmonella contamination is a serious issue, and it must be dealt with appropriately to eliminate both the current source and to prevent re-contamination by implementing appropriate sanitizing procedures on all equipment that may have been used in the production of kratom products. This is a critical step because Salmonella bacteria can cross-contaminate products if production equipment is not properly cleaned.

Heat and chemical processing are the enemies of Salmonella bacteria, and they should be effectively used to make your processing facilities Salmonella-free – as opposed to just getting a test result of “Salmonella negative.” These procedures must be implemented to contain and ultimately end the Salmonella outbreak that has been traced to the supply chain of some kratom raw materials.

The AKA’s first concern is the safety of kratom consumers. I am encouraged that responsible kratom suppliers that we have spoken with share this concern. Product safety for consumers and the protection of their businesses are the overwhelming messages of concern that we have received.

ACTING RESPONSIBLY; BEING TRANSPARENT; AND TELLING THE KRATOM STORY.
The good news about any Salmonella outbreak is that there is an endpoint once the source of the bacteria is identified, and that is true for any kratom contamination that may currently exist. The Centers for Disease Control (CDC) is currently managing Salmonella outbreaks in dried coconut, chicken salad, raw sprouts, and frozen shredded coconut (Vietnamese). 

It is clear that the FDA is exploiting the current Salmonella outbreak in kratom to advance their broader battle to ban kratom in the United States. No one is hearing that all consumers should stop consuming dried coconut, chicken salad, raw sprouts, or frozen shredded coconut. Yet, that is the central message the FDA is promoting through its public relations machine on kratom.

However unfair that messaging is on kratom, it is critical that every kratom product that is identified with a potential Salmonella contamination carefully follow the requirements of the FDA and CDC to document that appropriate steps have been taken to eliminate the public health threat.

The AKA strongly recommends that all of your interactions with these government agencies be respectful, responsive, and conducted in a way to develop a relationship of trust as quickly as possible.

The bad news is that the FDA is aggressively using new authority granted under the Food Safety Modernization Act that grants the FDA the authority to order a recall of food products when it determines "that there is a reasonable probability that the food product is adulterated under section 402 or misbranded under section 403(w) and use of or exposure to such article will cause serious adverse health consequences or death to humans or animals."

The triggering event for the utilization of this authority requires that the FDA has made an affirmative determination that a product that you are manufacturing and/or distributing has been contaminated with Salmonella. You are within your rights to request testing documents utilized by the FDA or CDC in making this determination.

Because there are also potential product liability issues, you would be well advised to consult an attorney on these issues.

You should provide the attorney with critical information regarding kratom and demonstrate your willingness to do what is necessary to secure the supply chain to consumers to assure your product is Salmonella-free. 

You can also visit the AKA website to obtain the latest information and science on kratom. On the AKA website ( https://www.americankratom.org/ ), there is a button on the front page labeled “Media.” The first item on the pull-down menu is “Kratom A-Z.” Key information items are listed in this section with a short explanation for each item. This information will be useful as you responsibly deal with either the FDA or CDC in addressing a potential Salmonella contamination of your product line.

• Your product must be tested for safety. The proof of this lab testing has to be current and specific regarding the purity of any product being sold to the public. This testing should be done by more than one lab as a safety cross-check on the accuracy of the tests.

• Document each communication with the government officials you deal with on this issue and ask for written copies of any information that reference as the basis for their inquiries or actions.


• Respond to all demands made as quickly as you can, following the advice of your attorney, to avoid allowing the government to take more aggressive actions against you and your kratom products.

You also have rights just like any other citizen, and if you believe you have been treated unfairly, you can inform your congressional delegation about any missteps by either the FDA or CDC.

• Make appointments and meet with your local legislators and your Federal representatives for both the House of Representatives and the US Senate.

• If there are other Kratom merchants in your area, meet with them to form a local council that becomes a group that can be considered Key Opinion Leaders (KOL).


• These meetings are your path to explain your fears regarding the safety of the consumer and your businesses. Bring handouts. Show that your key efforts are all based on cooperation and you want to be able to come back to these people if a problem arises.


• As new information becomes available, share that with those legislators and staffers that you have met with on Kratom.


• Contact your local media and arrange to meet with them and share the information you have gathered. Local TV, newspapers and radio stations are your target audience.


• Join a business group in your area like the local Chamber of Commerce and introduce your business to this community. The more people know about your business, the more local support you will receive.


In the broader picture, be sure you are a registered voter. Be sure everyone that represents you or is a member of the above group is a registered voter. We have a right to stand up for ourselves, and the right to hold the government accountable for their actions.

Sadly, I have heard that there are some vendors who think that "laying low and staying under the radar" is the best way to protect their business operations. While that may work for a while, it will not serve either your business interest or kratom consumers over the long term.

We believe the FDA and CDC have a duty to protect American consumers from unsafe food products, and we support responsible regulatory actions to assure consumers are protected. We also believe that these agencies must not use the Salmonella outbreak as a pretext to pursue their own biased agenda to ban kratom from the marketplace. We must keep them accountable for their actions.

The AKA can help in such cases if you provide us with information and data on any unfair or unreasonable treatment you receive from the FDA or CDC in your efforts to comply with requests from them to address any documented Salmonella contamination in your product line.
Worry comes from the belief you are powerless
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#2
What gets me is WI is a hot zone. Haven't been aware of a Kratom consumer from there in some time.
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