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Written by: Dr. Danister L. Perera Page 1
Written by: Dr. Danister L. Perera Page 2
What is the reason for this write up?
One of the recommendations of a recent progress report of WHO mission (13th Feb. 2012) on CKDu is
stated as there are 66 ayurvedic prescriptions that contain aristolochia, increase awareness of
ayurvedic practitioners and public of renal toxicity of aristolochia species.
If the rationale of this recommendation with regard to the findings of the mission, this statement has
indirectly expressed their concern to reconsider the connection between CKD and Aritolochia spp. used
for indigenous / traditional medical preparations. From the very beginning of national dialogue to identify
the actual cause of CKDu, some biomedical academics were in a suspicion that Sri Lankan CKDu problem
may have a connection with a kind of herbal medicine which can produce nephrotoxicity. Then they
wanted to lead the whole conversation into a hypothetical conclusion to prove that irrational use of
herbal medicines or unsafe of traditional medical preparations can be correlated with CKDu. But this
argument was formulated on an evidence-based and a totally unscientific approach which could have led
the researchers to a wrong end.
What is the history and origin of this hypothesis?
The relationship between aristolochic acid (AA) and nephropathy is not a new hypothesis that is
sometimes proven with animal experiments and human case studies. There are many scientific evidences
to accept the nephrotoxicity of AA as one of many other active principles available in plants which are
having the similar effect on kidneys. Therefore worldwide case reports have demonstrated long term use
of the Aritolochia plant species as medicines or foods can produce nephropathy and ultimately lead to
CKD. At the same time we must not forget that there are many other environment factors also being
scientifically proven to cause CKD and sometimes it is multifactorial as in other countries still remained
etiology unknown.
According to some nephrologists the progressive renal interstitial fibrosis with urothelial malignancies
due to consuming Aritolochia species is called Aristolochic Acid Nephropahty (AAN). This was initially
given the name Chinese Herbs Nephropathy (CHN) because renal failure cases reported due to
consuming Chinese herbal medicine contained Aristolochia fangchi. However, this could be considered
misleading in relation to the hundreds of Chinese medicinal herbs that are safely used throughout the
world, including for renal diseases. Thus alternatives such as aristolochic acid-associated nephropathy
AA-induced nephrotoxicity and Aristolochia nephropathy are also used. After publishing Belgium
outbreak of CHN, mostly connected with weight reducing Chinese herbal medicines, there were more
incidents of AA caused nephropathy reported worldwide. Later the hypothesis that AA could be an
environmental cause of Balkan-Endemic Nephropathy (BEN) or Danubian endemic familial nephropathy
(DEFN) also aristolochia seeds were comingle with wheat used for bread and being baked into bread and
therefore consumed on a regular basis in diet. After all the hypothesis of AA and CRF is well-established
and supported by many scientific research findings over and over which eventually create an officially
accepted skeptic approach to herbal medicine contained Aritolochia spp.
I must clearly admit that, in this document I will not attempt to deny the hypothesis of AA causation of
CKD which sometimes is claimed to have sufficient scientific evidences but probabaly challenged. My
argument is all about the irrational attempt to build up a connection between Aristolochia usage in TRM
products and CKDu in NCP or elsewhere in this country. Also this is not a write up against any discipline or
professional opinion but to safeguard the uniqueness TRM practices and prevent any negative impact on
genuine TRM contribution in beneficiary outcomes in health care in this country.
Written by: Dr. Danister L. Perera Page 3
Source: International Society of Nephrology (2008)
What is the status of Aristolochia usage in Sri Lankan traditional medicine (TRM)?
In Sri Lanka, there are three Aritolochia spp. botanically recorded namely; A. indica, A. bracteolata, and A.
ringens and A. indica or Indian birthwort is locally known as sassanda or sapsanda and in Ayurvedic terms
it is called irwaramli or rudrajata. Mainly the dried roots of the plant are used and sometimes fresh
leaves are used to extract juice for medicinal oils. In indigenous medical lore the recipes contained
sassanda are prescribed for both internal and external medicine in accordance with the condition of the
patient. Comparatively number of recipes contained sassanda in available in published and unpublished
TRM sources is higher than Ayurvedic classical literature. Specially sassanda is an common ingredient
used in snakebite treatments for controlling acute conditions but not recommended for long term use. In
this context we must very carefully asses the current status of usage level and utility range of sassanda in
traditional medicine as well as the consumption level sassanda and exposure potentiality to AA in such
cases. Therefore following observations must be critically considered before any conclusion with regard
to comment on the possibility of sassanda as a cause of renal injury of consumers of TRM.
1. After introducing Ayurveda, TRM practices and practitioners in the country getting diminished
and TRM medicines are underutilized.
2. Sometimes most of the TRM preparations are not manufactured due to unavailability of plant
raw materials found in natural habitat, one of which can be sassanda.
3. Even though it is widely used in snakebite treatments it is limited only for external applications
and it is very rarely prescribed for internal administration. (Also it is statistically evident that most
of snakebites are brought to Western hospitals and therefore TRM has a low incidence of utility
in snakebite treatments)
Written by: Dr. Danister L. Perera Page 4
4. The TRM multi-ingredient recipes contain more than 50-100 ingredients in one mixture and
undergo a very complex process of blending to get the final product.
5. With the product diversity and holistic approach patients are always treated with many multi-
ingredient medicines with constant change of preparations.
6. It is very rarely Ayurvedic recipes contained sassanda are popular among Ayurvedic practitioners
but not commonly used.
7. Ayurveda pharmacopeia officially published by the GoSL is bearing almost zero recipes contained
sassanda.
8. None of the commonly and widely used classical Ayurvedic or proprietary products contains
sassanda.
9. There is no history of chronic nephrotoxicity due to ingestion of sassanda in TRM recorded so far
from NCP or any area of the island.
10. No sporadic and isolated cases of chronic toxicity of sassanda in TRM indexed from among CKDu
victims of NCP.
What is the phytochemical and pharmacological profile of sassanda?
Aristolochia indica L. is one of the plant species belong to Aristolochiaceae family and most of them are
used in traditional systems of medicine or folk medicine in any country. It has long been used in
Ayurveda, Sri Lankan TRM to treat dysentery, fever, bowel troubles, ulcers, leprosy, skin diseases,
menstrual problems, cancer, lung inflammation and snakebites. The plant is also used. In the indigenous
system of medicine, the plant was used as emmenagogue, abortifacient, antineoplastic, antiseptic, anti-
inflammatory, antimicrobial, antifungal, antihelmintic, antiulcer, antiplasmodial, antioxidant, antipyretic,
antifertility, anti-spermatogenic, purgative, antipyretic, anti-inflammatory agent. The plant contain
Aristolochic acid, has many medicinal properties in various diseasecondition. The Phytochemical
screening revealed the presence of alkaloids, triterpenoids, steroids and sterols, flavonoids, tannins and
phenolic compounds and cardio glycosides. Some studies have shown the variations of available levels of
chemical compounds in different Aristolochia spp. are different.
The essential oil of the aerial parts of A. indica is dominated by sesquiterpenes and monoterpenes such
as -caryophyllene, -humulene, ishwarone, caryophyllene oxide I, ishwarol, ishwarane, aristolochene,
linalool and -terpinolene. The roots of A. indica contain aristolindiquinone, aristololide, 2-hydroxy-1-
methoxy-4H-dibenzo[de,g]quinoline-4,5-(6H)-dione, cepharadione, aristolactam IIa, -sitosterol--D-
glucoside, aristolactam glucoside I, stigmastenones II and III, methyl aristolate, ishwarol, ishwarane and
aristolochene. Other components found in A. indica include 12-nonacosenoic acid methyl ester, aristolic
acid, (12S)-7,12-secoishwaran-12-ol, (+)-ledol, ishwarone, methyl aristolate, para-coumaric acid,
5H,7,10-selina-4(14),11-diene, isoishwarane, aristolochic acids I, IVa, aristolochic acid IVa methyl
ether lactam and aristolactam -D-glucoside.
Written by: Dr. Danister L. Perera Page 5
Aristolochic acid is absorbed from the gastrointestinal tract and distributed unchanged and/or in
metabolized form throughout the body. Several structurally defined metabolites were identified
following the oral administration of aristolochic acid I and aristolochic acid II to rats and mice. In humans,
the reduction products aristolactam I and II are the only metabolites detected in urine although full
metabolic profiles have not been reported. Phase II metabolites of aristolochicacids have been identified
in the urine of rats, and include N- and O-glucuronides, and acetate and sulfate esters.
Synonyms of AA I: Aristolochic acid I
Aristinic acid Aristolochia yellow Aristolochic acid A Aristolochin Aristolochine Descresept Isoaristolochic acid 8-Methoxy-3,4-methylenedioxy-10-nitrophenanthrene-1-carboxylic acid 8-Methoxy-6-nitrophenanthro[3,4-d]-1,3-dioxole-5-carboxylic acid 3,4-Methylenedioxy-8-methoxy-10-nitro-1-phenanthrenecarboxylic acid Tardolyt TR 1736
Synonyms of AA II: Aristolochic acid II
Aristolochic acid B 3,4-Methylenedioxy-10-nitrophenanthrene-1-carboxylic acid 6-Nitrophenanthro[3,4-d]-1,3-dioxole-5-carboxylic acid
Several structurally defined metabolites (mainly nitroreduction products) have been reported following
oral administration of aristolochic acid I (five metabolites) and aristolochic acid II (three metabolites) to
rats and mice. Fewer metabolites were observed in beagle dogs, rabbits, guinea-pigs and humans than in
rats and mice. The toxic effects of aristolochic acids I and II have been inferred from effects seen in
patients suffering from kidney nephropathy as a result of consuming herbal mixtures containing
Aristolochia species, which leads to rapidly progressive fibrosing interstitial nephritis. In experimental
animals, high doses of aristolochic acids administered either orally or intravenously caused severe
necrosis of the renal tubules, atrophy of the spleen and thymus, and ulceration of the forestomach,
followed by hyperplasia and hyperkeratosis of the squamous epithelium. Various constituents of
Aristolochia indica including aristolochic acids and aristolic acid (a metabolite) caused termination of
pregnancy in female mice, hamsters and rabbits, but not rats.
There is sufficient evidence in humans for the carcinogenicity of herbal remedies containing plant
species of the genus Aristolochia.
There are no data in experimental animals on the carcinogenicity of herbal remedies containing
plant species of the genus Aristolochia.
There is limited evidence in humans for the carcinogenicity of naturally occurring mixtures of
aristolochic acids.
There is sufficient evidence in experimental animals for the carcinogenicity of aristolochic acids.
Source: International Agency for Research on Cancer (IARC)
Written by: Dr. Danister L. Perera Page 6
Plant species known or suspected to contain aristolochic acid and their vernacular names
Botanical name Common or other names
Aristolochia spp. Aristolochia, Guan Mu tong, Guang Mu tong
Aristolochia acuminata (Syn. Aristolochia tagala) Oval leaf Dutchman's pipe
Aristolochia bracteata Ukulwe
Aristolochia clematitis Birthwort
Aristolochia contorta Ma Dou Ling (fruit), Bei Ma Dou Ling (root), Tian Xian Teng (herb)
Aristolochia cymbifera Mil homens
Aristolochia debilis (Syn. Aristolochia longa, A. recurvilabra, A. sinarum)
Ma Dou Ling (fruit); Tian Xian Teng (herb), Qing Mu Xiang (root), Sei-Mokkou (Japanese), Birthwort, Long birthwort, Slender Dutchman's pipe
Aristolochia fangchi Guang Fang ji (root), Fang ji, Fang chi, Mokuboi (Japanese), Kou-boui (Japanese), Kwangbanggi (Korean)
Aristolochia heterophylla Han Fang Ji
Aristolochia indica Indian birthwort (root), Yin Du Ma Dou Ling
Aristolochia kaempferi (Syn. Aristolochia chrysops, A. feddei., A. heterophylla, A. mollis, A. setchuenensis, A. shimadai, A. thibetica, Isotrema chrysops, I. heterophylla, I. lasiops)
Yellowmouth Dutchman's pipe, Zhu Sha Lian
Aristolochia macrophylla (Syn. Aristolochia sipho) Dutchman's-pipe
Aristolochia manschuriensis (Syn. Hocquartia manshuriensis, Syn. Isotrema manchuriensis)
Manchurian birthwort, Manchurian Dutchman's pipe (stem) Guan Mutong (stem), Kan-Mokutsu (Japanese), Mokuboi (Japanese), Kwangbanggi (Korean)
Aristolochia maxima (Syn. Howardia hoffmannii) Maxima Dutchman's pipe, Da Ma Dou Ling
Aristolochia mollissima Wooly Dutchman's pipe, Mian Mao Ma Dou Ling
Aristolochia moupinensis Moupin Dutchman's pipe, Huai Tong
Aristolochia serpentaria (Syn. Aristolochia serpentaria) Virginia snakeroot, Serpentaria, Virginia serpentary
Aristolochia triangularis Triangular Dutchman's pipe, San Jiao Ma Dou Ling
Aristolochia tuberosa Tuberous Dutchman's pipe, Kuai Jing Ma Dou Ling
Aristolochia tubiflora Tubeflower Dutchman's pipe, Guan Hua Ma Dou Ling
Aristolochia versicolar Versicolorous Dutchman's pipe, Bian Se Ma Dou Ling
Asarum canadense (Syn. Asarum acuminatum, A. ambiguum, A. canadense, A. furcatum, A. medium, A. parvifolium, A. reflexum, A. rubrocinctum)
Wild ginger, Indian ginger, Canada snakeroot, False coltsfoot, Colic root, Heart snakeroot, Vermont snakeroot, Southern snakeroot, Jia Na Da Xi Xin
Asarum himalai(y)cum Tanyou-saishin (Japanese)
Asarum splendens Do-saishin (Japanese)
Worldwide, there are an estimated 200 to 350 Aristolochia species, and virtually all of them contain
aristolochic acids. Asarum species (wild gingers) also are widely distributed in the United States. Plants of
the genus Hexastylis, a group of rare plants endemic to the southeastern United States, were reported to
have unexpectedly high levels of aristolochic acids. Concentrations ranged from 3 to 12,980 ppm for AA
I and from not detected to 6,325 ppm for AA II. In Asarum species, concentrations of AAs I and II ranged
from trace levels to 3,377 ppm. Other studies detected AA IVa at concentrations of 79 to 3,360 ppm of
crude drug, aristolactam I at 6 to 358 ppm, and aristolactam II at 14 to 91 ppm.
Written by: Dr. Danister L. Perera Page 7
What are the international regulations related to herbal medicine with Aristolochia?
The Therapeutic Goods Administration (TGA) of Australia has issued a Fact Sheet stating that all species
of Aristolochia are prohibited for supply, sale or use in therapeutic goods in Australia. The TGA also
issued a Practitioner Alert to communicate its concern about traditional Chinese medicine herbal
products that are known to contain, or suspected to contain, Aristolochia species, which may contain AA.
The TGA has published three lists of botanicals or products at risk of containing AA: botanicals known or
suspected to contain AA (Group A); botanicals which may be adulterated with AA (Group B); and
products which have Mu Tong and Fang Ji as declared ingredients (Group C).
The use of Aristolochia in unlicensed medicines was prohibited by the Medicines Control Agency (2001) in
the UK in July 1999, and a further temporary prohibition covering certain herbal ingredients at risk of
confusion with Aristolochia came into force in June 2000. The UK Committee on Safety of Medicines
(2001) made these prohibitions permanent by issuing a Statutory Instrument to prohibit the sale, supply
and importation of any medicinal product consisting of or containing certain plants belonging to a species
of the genus Aristolochia or consisting of or containing Guan Mu Tong; or belonging to any of eight
specifically listed plants (Akebia quinata, Akebia trifoliata, Clematis armandii, Clematis montana, Cocculus
laurifolius, Cocculus orbiculatus, Cocculus trilobus,Stephania tetrandra); or consisting of or containing an
extract from such a plant.
In addition, the European Agency for the Evaluation of Medicinal Products issued a position paper in
October 2000, warning European Union Member States to take steps to ensure that the public is
protected from exposure to aristolochic acids arising from the deliberate use of Aristolochia species or as
a result of confusion with other botanical ingredients. The European Commission (EC) (2000) has
prohibited aristolochic acid and its salts, as well as Aristolochia species, and their preparations in
cosmetic products. In 1999, Health Canada issued a warning not to use products containing
Aristolochiadue to potential risk of cancer, cell changes and kidney failure.
Health Canada issued four additional warnings and advisories in 2001 advising not to use products
labeled to contain Aristolochia. The Food and Drug Administration of the USA has issued a Consumer
Advisory to communicate its concern about the use and marketing of dietary supplements or other
botanical-containing products that may contain aristolochic acids. It has also posted a listing of botanical
ingredients of concern, including: botanicals known or suspected to contain aristolochic acids; botanicals
which may be adulterated with AA; products in which Mu Tong and Fang Ji are declared ingredients;
and botanical products determined by FDA to contain AA.
Why multi-ingredient products in TRM?
When many poisonous plant material and toxic metals used in TRM for treating patients, are processed
in a proper manner and rationally dispensed it shows efficacy without any side-effect or iatrogenic
complication. Almost all of them are multi-ingredient and deliberately mixed in which the chemical
profile of final product is not analyzed, screened or identified. These kinds of products demonstrate
unique collective activity which is totally different from individual ingredients in primary source. It is
evidently proven that according the solvent also the level of solubility and percentage of presence of
compounds can vary. In this complex phytochemical mixture many reactions can occur among natural
components in both synergetic and antagonistic manners which have not been validated in terms of
pharmacodynamics and pharmacokinetics. In this phytochemical complexity there may be antagonistic
compounds which can counteract nephrotoxic action of AA and synergetic factors to enhance nephro-
protective action of the product. Therefore following observations are very important.
Written by: Dr. Danister L. Perera Page 8
1. Final product can have a different phytochemical, pharmacological and therapeutic effect
generated out of blending
2. The intake of single agent is very minute quantity in recommended dosage of final product. It can
be always less than recommended safe level of a single ingredient.
3. Most of the studies have shown that AAN or progressive CRF had occurred after ingestion of high
dose of AA (active principle) for long time.
4. Sometime this multi-ingredient product is administered with another natural vehicle / adjuvant
prepared specially according to the patients condition.
5. Pharmacodynamics of AA and metabolic outcomes can vary due to diversity of phenotypes
according to the latest findings.
Why research findings of CHN / AAN cannot be applied to TRM products in Sri Lanka?
Findings of CHN / AAN researches Arostolochia containing TRM (A) products
Most of the CHN / AAN patients have taken Chinese herbal medicine with AA as a self-medication (OTC) without medical prescription or advice
No TRM (A) medicine in the market for self-medication (OTC) or on medical prescriptions
All most all of CHN / AAN patients have taken medicine for long time
TRM (A) products are not prescribed for long term and in normal TRM medications also follow a rational discontinuation manner.
Some of them have taken more than one medicine contained AA in different dosage forms (pills, decoctions etc.)
TRM medications are prescribed always in an interchanging consecutive sequence.
Most of them have taken medicine in high doses Mostly TRM (A) are prescribed in acute or emergency conditions like snakebites and given in small doses which contain very low amount of AA.
Most of proprietary Chinese medicines are not having high number of ingredients
All TRM (A) medicine administered internally has a very high number of ingredients that may inhibit direct ingestion of AA and promote pharmacodynamics synergism.
In some cases medicines were adulterated with Aritolochia spp.
In Sri Lanka Aristolochia spp. are not a source of adulteration in TRM
CHN / AAN reported in a specific consumer group or specific geographical area
Utility of TRM in Sri Lanka has an island-wide distribution and TRM (AA) products are not geographically-specific
Researchers conducted with AA in animal models have proven the causation of progressive nephropathy and renal malignancies.
These data will not be sufficient for validate TRM products in human
Written by: Dr. Danister L. Perera Page 9
Is there any evidence for utility TRM contained AA in NCP?
No proper study has been done so far for such conclusion in NCP or among the CKD victims. Also it is not
rational to assume that CKDu victims were potentially exposed to TRM with AA for any similar medical
reason or any geographically specific medicine within last three decades. No medication history of TRM
usage of victims was traced in any study pertaining to CKD and no data were collected about usage or
availability of sassanda containing recipes in TRM practice within the NCP.
Null and void connection between CKDu and Aristolochia spp. in TRM
Different levels of toxicity and clinical features, histo-pathology, renal injury caused by them cannot be
compared or synchronized into AAN
Method of preparation, dosage form, mode of administration, daily intake, period of usage, discontinuity,
interactions with other medicines, kidney function, and other pathophysiological factors should critically
be evaluated before conclusion. Also we must not forget the pharmacogenomics is an emerging subject
in the field of assessing effect of substances within an individual biophysical model.
Multi-ingredient TRM product or admixture containing Aristolochia indica or sassanda with other medicines or mixed with an adjuvant
Crude form of the whole plant of Aristolochia indica or sassanda
Water extract of the whole plant of Aristolochia indica or sassanda
Roots of Aristolochia indica or sassanda
The ethonolic extract of roots of Aristolochia indica or sassanda
Pure Aristolochic acid
Availability of
Aristolochia
species in
TRM recipes
CKDu
in NCP
Low availablility of plant Low utility of recipes
Phytochemical complexity Multi-ingredient products
No specific geographic usage No commonly use products
No long term usage No history of chronic AA toxicity
S
A
F
E
T
Y
T
O
X
I
C
I
T
Y
Written by: Dr. Danister L. Perera Page 10
Why this recommendation is WRONG, unjustifiable and prejudiced statement?
It is based on technically wrong information generated through a simple and random survey
conducted by a group without professional, expert and academic involvement.
It implies a wrong assumption that may lead to establish an irrational hypothesis on positive
relationship between TRM and CKDu NCP or elsewhere.
It reflects a wrong meaning and suspicious concern on TRM products and practices nationally as
well as internationally.
It has no rational connection with the findings on etiology of CKDu which are obviously related to
arsenic and cadmium due to chronic pesticide poisoning.
It will have a negative impact unreasonably on TRM with regard to public confidence which
prevailed for centuries in the country.
It may lead to potential unnecessary regulatory control on TRM in future and encourage
detrimental enforcements in export market.
What should be done?
1. The flagship stakeholder of the sector, Ministry of Indigenous Medicine and relevant
institutions should urgently respond to the WHO and request for justifiable principles based for
such recommendation.
2. TRM authorities of should make a request for evidences which should have been based for
WHO recommendation and actively analyze the scientific rationale of such data and validate
reliability, acceptability, applicability and sufficiency of the same.
3. BMARI should urgently initiate a national research programme to evaluate any probable
toxicity or potential chronic poisoning based on pharmaco-epidemiology.
4. Ministry of indigenous medicine must express their commitment for extending safety of TRM
products through a national pharmaco-vigilance initiatives and updating ADR database on
TRM.
5. Awareness must be raised among professionals, academics and researches pertaining to these
issues for encouraging them for further verifications through scientific studies and peer
reviews.
6. A national level dialogue must be created to build up a meaningful and productive
understanding between biomedical and TRM sectors in a mutually respected manner.
7. Ministry of health and TRM authorities with the support of international agencies WHO must
build up a reciprocally co-existing professional culture and introduce pluralistic health care
principles into medical education.
8. WHO must consult a wider TRM group to revisit, scrutinize and redraft the above mentioned
recommendation and revalidate the TRM practices in encountering such health problem.
Written by: Dr. Danister L. Perera Page 11
ANNEXURE I:
Proposed pathway for metabolic activation and detoxication of aristolochic acid I (AAI), leading to renal
injury and urothelial cancer. Aristolochic acid nephropathy (AAN); Balkan endemic nephropathy (BEN); 7-
(deoxyadenosin-N6-yl)aristolactam I (dA-AAI)
Source: Interdiscip. Toxicol. 2008 June; 1(1): 812 PMCID: PMC2993473
Although hepatic CYP enzymes were found to detoxicate AAI in mice, thus decreasing its renal toxicity
individual enzymes, which might metabolize (activate and/or detoxicate) AAI in vivo, and their impact on
AAI-mediated nephrotoxicity and carcinogenicity, have not been fully resolved as yet. Therefore, such a
subject remains to be investigated. Namely, the evaluation of inter-individual variations in the human
enzymes playing a major role in AAI activation and detoxication, including their genetic polymorphisms,
remain a major challenge to explain an individual's susceptibility to AAI, and to predict cancer risk among
the AAN and BEN patients. Therefore, the study we started in our laboratory addresses still unsettled
question whether the metabolism of AAI, and if so, which enzymes participating in this process,
determine pathophysiological effects of this compound in development of AAN and BEN diseases.
However, some differences between AAN and BEN patients, and rabbits with AAN should be pointed out.
Involvement of the columns of Bertin in BEN autopsied patients appears less prominent than in AAN
patients. On clinical grounds, four findings in AAN patients differ from BEN: firstly, the sex-ratio in BEN is
approximately 1/1, in contrast to the female preponderance in human AAN; this reflects the almost
exclusive female attendance of the X clinic. Secondly, AAN patients progress to end-stage renal failure
within a few months or years, in contrast with the slow evolution of BEN and of AAN in rabbits over time.
This could reflect a higher level of toxic exposure in AAN than in BEN patients and interspecies
differences in the susceptibility to the toxic agent as suggested by the differences in the metabolic
transformation of AAs between humans and animal species.
Written by: Dr. Danister L. Perera Page 12
ANNEXURE II
Aristolochic acid I Chem. Abstr. Serv. Reg. No.: 313-67-7 Deleted CAS Nos.: 12770-90-0; 61117-05-3 Chem. Abstr. Serv. Name: 8-Methoxy-6-nitrophenanthro[3,4-d]-1,3-dioxole-5- carboxylic acid Synonyms and trade names: Aristinic acid; aristolochia yellow; aristolochic acid A; aristolochin; aristolochine; Descresept; isoaristolochic acid; 8-methoxy-3,4- methylenedioxy-10-nitrophenanthrene-1-carboxylic acid; 3,4-methylenedioxy-8- methoxy-10-nitro-1-phenanthrenecarboxylic acid; Tardolyt; TR 1736
Aristolochic acid II Chem. Abstr. Serv. Reg. No.: 475-80-9 Deleted CAS No.: 79468-63-6 Chem. Abstr. Serv. Name: 6-Nitrophenanthro[3,4-d]-1,3-dioxole-5-carboxylic acid Synonyms: Aristolochic acid B; 3,4-methylenedioxy-10-nitrophenanthrene-1-carboxylic acid Aristolochic acids (a) Description: Crystalline solid [aristolochic acid I] (Buckingham, 2001) (b) Melting-point: 281286 C, decomposes [aristolochic acid I] (Buckingham, 2001) (c) Solubility: Slightly soluble in water; soluble in acetic acid, acetone, aniline, alkalis, chloroform, diethyl ether and ethanol; practically insoluble in benzene and carbon disulfide (ONeil, 2001) (d) Octanol/water partition coefficient (P): log P, 3.48
Source: IARC Monographs Vol. 82
Written by: Dr. Danister L. Perera Page 13
ANNEXURE II
Herbal medicines were first included in the WHO International Conference on Drug Regulatory
Authorities in 1986 [30]. In 1991, WHO prepared draft guidelines for assessment of herbal medicines,
which were adopted by the 6th International Conference on Drug Regulatory Authorities (ICDRA). This
includes basic criteria for quality, safety, and efficacy of herbal medicines. These guidelines provide
valuable assistance to national regulatory authorities, scientific organizations, and manufacturers to
undertake assessment of documentation of submissions.
Warning concerning interstitial renal fibrosis
Belgium. On 14 March 2000, the Ministry of Public Health in Belgium issued a public statement addressed to all persons having consumed Chinese plant preparations in the past 10 years, in order to allow these persons to obtain advice on the need for further investigations of their renal function. The reason for this announcement is the observation that urothelioma has been recently discovered in half of the patients having developed end-stage renal failure following the intake of Aristolochia in the early 1990s in herbal slimming agents that were found to contain Aristolochia fangchi instead of Stephania tetrandra or Magnolia officinalis. (1,2).
More than 100 patients have been identified in Belgium with interstitial fibrosis of the kidney, a form of nephropathy sometimes referred to as "Chinese herbs nephropathy". At least 70 of these patients have required renal transplant or dialysis. It is estimated that in Belgium about 10,000 persons have used Aristolochia from a contaminated lot in the early 1990s. A "Dear Doctor" letter has been sent to all physicians and pharmacists advising them to refer cases with abnormal serum creatinine levels to a specialised centre.
Malaysia. The Drug Control Authority (DCA) decided to cancel the registration of all products containing the herbal ingredient Aristolochia which contains aristolochic acid. This decision was made in the light of reports received from Europe where the use of products containing Aristolochia has been associated with interstitial nephropathy and end-stage renal failure. Aristolochic acid is found in traditional Chinese medicines used as a diuretic and in slimming preparations.(3)
United Kingdom. The Committee on Safety of Medicines has banned the import, sale and supply of medicinal products containing aristolochia with effect from 28 July 1999. This action was taken after two reports of end-stage renal failure associated with aristolochia in herbal medicines being taken to treat eczema. As in the cases reported from Belgium, there is evidence that aristolochia was mistakenly used instead of other plants, in these cases clematis, or that the products were contaminated with aristolochia. The Medicines Control Agency is considering making the banning order permanent.(4)
United States of America. The Center for Food Safety and Nutrition has issued a "Dear Health Care Professional" letter and a letter to industry warning about nephrotoxicity associated with botanical products found to contain aristolochic acid.(5) Although the FDA has not yet received any reports of such cases, the Center stresses that a thorough history of use of dietary supplements as well as traditional medicines, including Chinese and Ayurvedic (Indian) preparations, should be sought as part of the medical history, particularly in cases of unexplained interstitial renal fibrosis.
The Center also sent a letter to industry urging manufacturers to take steps to positively confirm that botanical ingredients are not inadvertently contaminated with plant material containing aristolochic acid, by testing their products to confirm the absence of aristolochic acid, by identifying and reporting adverse events, especially renal system disorders, associated with any product that contains an ingredient that may contain aristolochic acid. The FDA will also issue an import alert to ensure that all products imported into the USA will be examined to ensure that they do not contain aristolochic acid.
Written by: Dr. Danister L. Perera Page 14
Note: Preparations containing aristolochic acid were withdrawn in Austria, Germany, Egypt and Venezuela in the early 1980s after the publication of a study in rats that revealed the carcinogenic potential of aristolochic acid. UN Consolidated List of Products whose consumption and/or sale have been banned, withdrawn, severely restricted or not approved by governments.
Source: WHO Pharmaceuticals Newsletter No. 2, 2000
China's State FDA (SFDA) has banned two commonly used herbs containing aristolochic acid, a toxin
reported to be linked to kidney failure and cancer. Manufacturers have been directed to replace
Aristolochiafangchi and Aristolochia debilis with Stephania tetrandra and Inula helenium respectively, in
their traditional medicine formulations by 30 September.The Provincial Drug Bureaux has been instructed
to carry out inspections to ensure compliance with the ban by 31 October. Medicines found to contain
either Aristolochia fangchi or Aristolochia debilis after 30 September will be treated as fake under
Chinese law. By a previous order, special restrictions were imposed on four other potentially harmful
aristolochic acid-containing herbs (Fructus Aristolochiae, Aristolochia mollissima Hance, Herba
Aristolochiae and Aristolochia tuberose) in China; there was no outright ban on these products. Several
countries withdrew aristolochic acid containing preparations in 1981 following the demonstration of a
carcinogenic potential in a three month toxicity study in rats (see UN Consolidated List of Products whose
consumption and/or sale have been banned, withdrawn, severely restricted or not approved by
governments, Eighth Issue, Pharmaceuticals, available at
http://www.who.int/medicines/li brary/docseng_from_a_to_z.shtml#p.
Source: WHO Pharmaceuticals Newsletter No. 5, 2004
Scientific Committee on Cosmetics and Non-Food Products (SCCNFP)
Summary sheet on Commission Review (ref. XXIV/1991/97)
Ingredient : Aristolochic acid (I,II,V)
CAS n : 313-67-7; 475-80-9; 15918-62-4; 61117-05-3
Function and max in use concentration : botanical
Relevant toxicity data :
Assessment of acute toxicity (oral, i.v.) : Toxic for kidneys.
Assessment of chronic/sub-chronic toxicity : Repeated dose toxicity (oral 21 d., 90 d.): multiple
carcinogenic gastrointestinal tract cell metaplasia.
Assessment of genotoxicity/carcinogenicity: Mutagenic in vitro, clastogenic in vitro and in vivo.
Very potent carcinogen affecting forestomach, kidneys and several other organs.
Human data: Causal factor in "Chinese herb nephropathy" (kidney destructive process).
Classification: 2a (See Classification of Substances)
SCCNFP Opinion
Aristolochic acid (A.A.) is mutagenic in bacteria, in mammalian cells and in Drosophila.
A.A. binds covalently to DNA inducing similar DNA adducts in vitro and in vivo in rats.
A.A. is a very potent carcinogen affecting the forestomach and several other organs including the
kidneys in mice and rats after short induction periods with low doses. In rats, the effects were
shown to be time and dose dependent.
Very recently (1996) A.A. derived DNA adducts biomarkers of A.A. exposure, were found in renal
tissues of patients suffering from a rapid kidney destructive fibrotic process designated as Chinese
Herbal Nephropathy.
Written by: Dr. Danister L. Perera Page 15
These data support SCCNFP opinion that Aristolochic acid and salts must not be used in cosmetic
products. Moreover, A.A. being the active constituent of Aristolochia species, the SCC is of the
opinion to extend that the ban to Aristolochia species and preparations.
Statement on the toxicological evaluation
The SCCNFP is the scientific advisory body to the European Commission in matters of consumer
protection with respect to cosmetics and non-food products intended for consumers.
The Commission's general policy regarding research on animals supports the development of
alternative methods to replace or to reduce animal testing when possible. In this context, the
SCCNFP has a specific working group on alternatives to animal testing which, in co-operation with
other Commission services such as ECVAM (European Centre for Validation of Alternative
Methods), evaluates these methods.
SCCNFP opinions include evaluations of experiments using laboratory animals; such tests are
conducted in accordance with all legal provisions and preferably under chemical law regulations.
Only in cases where no alternative method is available will such tests be evaluated and the
resulting data accepted, in order to meet the fundamental requirements of the protection of
consumer health.
Source: Opinion of the intended for Consumers concerning Aristolochic acid and salts adopted by the
plenary session of the SCCNFP of 21 January 1998
Regulations: Food and Drug Administration (FDA)
Federal Food, Drug, and Cosmetic Act as amended by the Dietary Supplement Health and Education Act
Manufacturers and distributors as of 2007 must record adverse events and report to the FDA serious adverse events reported to them about their products.
Label requirements for dietary supplements have been established. Manufacturers must establish and meet specifications for identity, purity, strength, and
composition and for limits on contamination of dietary supplements under current Good Manufacturing Practices (cGMP) regulations published in 2007.
Warnings and Alerts
Food and Drug Administration (FDA)
Warnings issued in 2000 and 2001 (FDA 2000, 2001a,b) covered botanical products that contain aristolochic acids:
Practitioners who prescribe botanical remedies urged to discard those products containing aristolochic acids.
Manufacturers and distributors urged to ensure that botanical products are free of aristolochic acids.
Consumers urged to immediately discontinue use of botanical products that contain or likely contain aristolochic acids.
An import alert issued in 2000 and revised in 2007 provided for the detention of products labeled
as Aristolochia or any that could be confused with it unless analytical evidence shows no
aristolochic acids.
Source: National Toxicology Program, Department of Health and Human Services
Written by: Dr. Danister L. Perera Page 16
ANNEXURE IV
Source: Nephrology Rounds. 2008 Feb. 6(2)