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Campus News

On-Campus Crew Tincture Production Deferred Until Production Regulations are Followed

by Micah Wilkins, Editor-in-Chief

Several crews have had to stop producing herbal remedies. Photo by Jackson Bicknell

Warren Wilson is a unique college in many ways—our work program, our small community, our beautiful and vast campus, our farm and garden—all of these elements attract a certain kind of person, students like you and I. We care about the earth, we care about our community, and we care about our own well-being.

The college’s emphasis on wellness was the main reason why Senior Devon Kelley-Mott chose to come to Warren Wilson. She heard that several work crews on campus produced tinctures, which are concentrated solutions extracted from herbs, usually using grain alcohol.

Prior to coming to Warren Wilson, Kelley-Mott produced tinctures independently. She has been happy to produce tinctures for the past couple years, under the guidance of local herbalist Sandy Ford.

“It was a dream come true,” Kelley-Mott said. “And all of a sudden it was shut down.”

Last year, the college asked Wellness Crew and Herb Crew to forgo the production and distribution of tinctures to students on campus. These herbal mixtures posed many legality and liability issues for the college that have recently come to light.

Because tinctures are something that you ingest, they are subject to various food laws enforced by the Food and Drug Administration. Firstly, safe products need to be manufactured in a certified kitchen if they are to be sold and distributed. The only two we have on campus are the Cowpie and Gladfelter kitchens.

Furthermore, as an herbal medicine, tinctures are surrounded by many other rules, or GMPs (good manufacturing practices) that regulate their production and distribution. In order to make tinctures that can be sold legally, paperwork needs to be filled out, so that the FDA may trace the production process to ensure that they are being created in a sound way.

Though crews like Herb Crew and Wellness have been producing tinctures for years, the college, as an institution, must ensure that the recommended procedures are being followed, according to Dean of Work Ian Robertson.

“Anything that’s produced on this campus is a Warren Wilson product, not necessarily a crew or an individual product,” Robertson said. “The college has a responsibility that what they’re doing or selling follows the law, rules and regulations. We’re protecting ourselves right now, until we understand more.”

In recent years, the college has had to adopt various regulations to adhere to state and federal laws. According to Robertson, for example, students now need to be trained to drive the large vans that seat over 10 people. Students also must go through chainsaw certification. When Robertson came to Warren Wilson in 1981, there was no certification process for operating this machinery. Virtually every area of campus has gone through an increase in regulations, whether through training requirements or food safety laws, and the herb cabin is no exception to this.

There are two ways to make tinctures, according to Hannah Schiller, a member of the Herb Crew. There’s the scientific way, practiced by clinical herbalists, which is regulated, and then there’s a traditional, non-regulated way.

“We’ve done it the folksy way,” Schiller said.

Most of what students on the Herb Crew have learned about this field has been from wisdom passed down by past crew members. This type of knowledge-exchange is typical of herbalism, according to crew member Luna Dietrich.

“Everything I’ve learned from herbalism is from Hannah, Ariel, five book and two conferences,” crew member Chloe Smith adds. “We are not doctors.”

Though Schiller has been on Herb Crew for two years and is a certified herbalist, she and others on her crew and Wellness are not allowed to prescribe tinctures to students, which is another restriction surrounding their distribution. According to Robertson, the only people on campus who can prescribe things are the school’s nurses and psychiatrist.

“It’s been a huge learning experience for people to come in [with a symptom] and I can say ‘I know how to help you,’” Schiller said. “And to be able to provide them with medicine for free, when they would have to [spend more elsewhere].”

But this type of sliding-scale medicine and health care is not something that the herb cabin can offer anymore.

“The way it has been, it will never again be that way in the future,” Schiller said. “That’s why we have to put emphasis in a different way, on helping people help themselves.”

But despite these changes in practice, the Herb Crew acknowledges that these new supervisions are for the best.

“Yes, herb crew made tinctures for a while, but Warren Wilson as an institution is always re-evaluating itself, to ensure its sustainability and to ensure this place maintains its core values,” Smith said. “It’s not like the WPO is halting tinctures. They’re just re-evaluating, to better that aspect.”

When the Herb Crew met with Robertson, he emphasized that tincture production, nor any other crew activity, is not a money-making venture, but rather a learning initiative. Robertson wants tinctures to continue to be available to students, but in a legal and safe manner.

“How can we make available to students herbal remedies?” Robertson asked. “What should those changes be and how can we be responsible for the manufacture and distribution of them? Until we know that, they’re not available.”

In order to once again start making these herbal remedies, the Herb Crew must develop a plan of action, establishing and adhering to guidelines for how they make and distribute tinctures.

Last week, Forestry Crew produced their first batch of tinctures in a legal, regulated process at Blue Ridge Food Ventures, a shared-use food processing facility with a certified kitchen. The crew has been looking into forest medicinals, and they hope that this “test run,” according to crew member Hannah Billian, who has helped guide this project, will eventually lead to the crew selling tinctures in co-ops and at the farmer’s market on campus.

The Herb Crew is also thinking about using Blue Ridge Food Ventures as a venue for producing regulated tinctures. The paperwork seems tedious, Billian said, but it is good practice, and an important skill for people to have, especially those who want to pursue herbalism.

“It’s where the industry is going,” she said.

Though the Herb Crew and Wellness Crew are no longer able to distribute tinctures, they still provide other forms of remedies for students to take advantage of.

For now, Herb Crew hopes to focus more on outreach and education, by hosting workshops and inviting herbalists from the area to speak on campus. On March 30, herbalist Lorna Mauney-Brodek will visit campus to provide an informative discussion on herbal first aid.

Though it may take some time, the Herb Crew hopes to carry on with their tincture production as soon as possible.

“It’s a bit intimidating when you look at the GMPs and the paperwork,” Smith said. “But that’s not going to stop us. We just have to take a deep breath.”

Discussion

One Response to “On-Campus Crew Tincture Production Deferred Until Production Regulations are Followed”

  1. Hi guys! I hope I get a response on this! The Travelers Rest Farmers market is wanting to accept a tincture-making couple to become a vendor here, but I don’t know any of the regulations that DHEC imposes. Can you enlighten me as to the rules, or point me to a webpage about tincture manufacture and DHEC rules? How are y’all doing? Has the Herb crew been able to resume tincture making?

    Posted by Adrienne | November 23, 2013, 1:07 am

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