August 31, 2004 Page 1 Canada August 31, 2004 Todd Norton Sabinsa Corporation 121 Ethel Road West, Unit #6 Piscataway, NJ 08854 Dear Mr. Norton: At the request of Sabinsa Corporation, CANTOX Health Sciences International (CANTOX) has reviewed the safety of Forslean®, a root extract of Coleus forskohlii containing 10% forskolin, under the conditions of intended use as a dietary supplement for marketing in the United States. We have evaluated scientific information and data, provided by Sabinsa Corporation and obtained from literature searches, pertaining to the safety of Forslean®. The purpose of this review is to provide an independent expert opinion on whether Forslean® is safe for its intended level of intake of oral intake of 500 mg/day. Introduction Forslean® is composed of a powdered extract from the root of the Coleus forskohlii plant. The extract is standardized to contain 10% forskolin, the active ingredient. The intended dose of Forslean® is one 250 mg capsule to be taken twice daily, providing a total daily dose of 500 mg/day, as an aid for weight loss. This dose provides 50 mg forskolin/day. C. forskohlii is cultivated commercially in India where the roots are used as a spice in pickles (de Souza et al., 1983). Its root also has been used traditionally in Hindu and Ayurvedic traditional medicine for the treatment of heart diseases, abdominal colic, respiratory disorders, painful micturition, insomnia, and convulsions (Ammon and MOiier, 1985; Shah, 1985; Murray, 1995). In addition, the raw roots of the plant have been consumed for the treatment of cough (Shah, 1985). August 31, 2004 Page 2 Review of the Safety Studies of Forslean® Acute Toxicity Studies In an acute toxicity study, male and female Wistar rats were given a single oral dose of 2,000 mg ForsLean®/kg body weight (Graver, 2000). No deaths occurred; however, diarrhea, soiling of the anogenital area, and wetness of the mouth and anogenital area were reported. No histopathological lesions were observed following necropsy. The LD50 was reported to be >2,000 mg/kg body weight. Earlier studies by de Sousa et al (1983) showed the acute LD50 of forskolin to be 3,100 and 2,550 mg/kg by oral administration and 105 and 92 mg/kg body weight when administered intraperitoneally, in mice and rats, respectively. Subchronic Toxicity Study in Rats Groups of 5 Sprague-Dawley rats/sex were administered doses of C. forskohlii 10% extract of 0, 100, 300, or 1,000 mg/kg body weight/day by gavage for a period of 28 days (Bhide, 2004). Two additional groups of rats (5/sex/group) were administered the extract at doses of 0 or 1,000 mg/kg body weight/day for 28 days, and were observed for a 14- day recovery period thereafter to assess the reversibility of any possible effects. Daily observations of clinical signs and mortality, and weekly measurements of body weight and food consumption were conducted. Ophthalmoscopic examinations were conducted at the beginning and end of the dosing period and at the end of the recovery period. Hematological, biochemical, and urinary parameters were assessed at the end of the dosing and recovery periods. All animals were subjected to necropsy, and histopathological examinations of the organs were conducted. No toxicological effects were observed in any of the measured parameters at any dose. The no-observed-effect level (NOEL) of C. forskohlii 10% extract was considered to be 1,000 mg/kg body weight/day, the highest dose tested. This NOEL represents an appropriate high multiple of the intended human dose. Mutagenicity Study ForsLean® was reported not to be mutagenic in the bacterial reverse mutation assay with an independent repeat assay using Salmonella August 31, 2004 Page 3 typhimurium strains TA98, TA100, TA1535, and TA1537, and Escherichia coli strain WP2 uvrA, both in the presence and absence of metabolic activation, at doses of up to 5,000 µg/plate (Wagner and Klug, 2001). Clinical Studies A number of clinical studies investigating the efficacy of ForsLean® for weight loss have been conducted and are summarized in Table 1. It is important to note, although efficacy was the primary purpose of these trials, that parameters related to safety were also monitored. Open field studies 8 to 12 weeks in length have reported significant decreases in mean body weight and body fat with no significant adverse effects in overweight men and women who consumed 125 to 250 mg Forslean® twice daily (providing 250 to 500 mg Forslean®/day or 25 to 50 mg forskolin/day) (Tsuguyoshi, 2001; Badmaev et al., 2002). Similarly, double blind, randomized, placebo-controlled trials ranging in length from 8 to 12 weeks have demonstrated no significant adverse effects in subjects who consumed 250 mg Forslean® twice daily (500 mg Forslean®/day or 50 mg forskolin/day) (Agena, unpublished; Kreider et al., 2002; Bhagwat et al., 2004). Measurements of systolic and diastolic blood pressure and pulse rate in each of the studies also revealed no significant effects as a result of Forslean® consumption. In addition, Kreider et al. (2002) reported no clinically significant effects in metabolic markers, blood lipids, muscle and liver enzymes, electrolytes, red blood cells, white blood cells, hormones (insulin and thyroid hormones), heart rate, blood pressure, or other side effects. Bhagwat et al. (2004) also reported no significant changes in liver and kidney function, thyroid function, as measured by triiodothyrodine {T3), thyroxine (T4), and thyroidstimulating hormone (TSH) levels, nor any significant changes in blood lipid profile, with the exception of a significant increase in high-density lipoprotein (HDL) cholesterol and a significant decrease in total cholesterol/HDL ratio. Other clinical studies have evaluated the effects of C. forskohlii extract on blood pressure in hypertensive patients. Dubey et al. (1997) conducted 2 trials in which hypertensive patients were given capsules containing 165 mg of C. forskohlii extract (5 mg forskolin). In the first trial, 23 hypertensive patients were instructed to take 1 capsule 3 times daily for a period of 3 weeks (total daily dose = 495 mg C. forskohlii and 15 mg forskolin). In the second trial, 28 subjects were given the same doses of C. forskohlii extract for a period of 8 weeks, while 9 subjects were given 2 capsules 3 times daily (total daily dose = 990 mg C. forskohlii and 30 mg forskolin) over the same period. August 31, 2004 Page 4 Blood biochemical and hematological parameters were assessed and stool and urine analyses were performed at the beginning and end of the study period in both trials. All parameters assessed were reported to remain within normal ranges; however, serum cholesterol, creatinine, and blood urea were reported to decrease significantly in both phases of the study. Systolic and diastolic blood pressure also were reported to significantly decrease over the course of the study period. Side effects that were reported to diminish over the course of the study included gastrointestinal disturbances, palpitation, dyspnea on exertion, insomnia, headache, and anxiety. These studies represent a significant clinical database since, even though numbers of subjects are limited as in most such trials with volunteers, results are consistent and reproducible. Although these trials have been presented at scientific meetings, complete study data have not been published. August 31, 2004 Page 4 Table 1 Summary of Clinical Studies of Coleus forskohlii Extracts Number of Subjects Dose of C. forskohlii Extract (mg/day) [dose of (mg/day)] Study Design Study Length Measured Outcome(s) Reference 12 wk No significant effects on systolic and diastolic blood Tsuguyoshi et al., pressure or pulse rate. No significant adverse effects. 2001 No significant effects on systolic and diastolic blood Badmaev et al., pressure or pulse rate. 2002 No significant effects on body weight, heart rate, mean arterial pressure, or systolic and diastolic blood Agena, unpublished forskolin Clinical Studies of Forslean® 14 overweight 250 [25] Open-field study subjects (1 male, 13 female) 6 overweight women 16 overweight men (8/group) 500 [50] 500 [50] Open-field study Randomized, doubleblind, placebo- 8 wk 8 wk controlled study 19 women [n=12 (controls); n=7 (test)] 500 [50] Randomized, doubleblind, placebo- pressure. 12 wk controlled study 60 obese men and women (30/group) 500 [50] Randomized, doubleblind, placebo- No significant differences between groups in metabolic markers, blood lipids, muscle and liver Kreider et al., 2004 enzymes, electrolytes, red blood cells, white blood cells, hormones (insulin, TSHa, T3b, T/}, heart rate, blood pressure, or reported side effects. 12 wk No significant effects on blood pressure, liver, kidney, and thyroid function or blood lipid profile, with the Bhagwat et al., 2004 exception of increased HDLd cholesterol and decreased ratio of total:HDL cholesterol. controlled study Clinical Studies of Other C. forskohlii Extracts 23 hypertensive patients 495 [15] Open-field studies 3 wk No significant effects on blood biochemical and hematological parameters, urinalysis. 8 wk blood urea, and systolic and diastolic blood pressure. Significant decreases in serum cholesterol, creatinine, 37 hypertensive 495 [15] (n=28) patients 990 [30] (n=9} Side effects included: gastrointestinal disturbances, palpitation, dyspnea, insomnia, headache, anxiety; side effects diminished over the course of the study. - Thyroid-stimulating hormone b Triiodothyronine c Thyroxine d High-density lipoprotein Dubey et al., 1997 August 31, 2004 Page 5 Pharmacological Effects and Mechanism of Action of Forskolin Forskolin has been reported to possess antihypertensive activity, positive inotropic effects, and to inhibit platelet aggregation (de Souza et al., 1983; Ammon and MOiier, 1985). The mechanism of action of forskolin is thought to be related to its stimulatory action on adenylate cyclase, increasing the intracellular level of cyclic adenosine monophosphate (cAMP), which mediates a number of biological responses (de Souza et al., 1983; Ammon and MOiier, 1985; Dohadwalla, 1985; Seamon, 1985). Numerous pharmacological studies on the various effects of forskolin have been conducted in laboratory animals and humans following topical, intravenous (i.v.), intraarterial, intraperitoneal (i.p.), intratracheal (i.t.), and inhalation treatment. Physiological effects of cAMP, which also have been demonstrated by forskolin, include inhibition of platelet aggregation, increased adipocyte lipolysis in vitro, positive inotropic effects on heart muscle, potentiation of insulin secretion by the pancreas, increased secretion of thyroid hormones, increased steroidogenesis by the adrenal glands, increased adrenocorticotropic hormone (ACTH) release by the pituitary gland, and decreased intraocular pressure in topical application (Dubey et al., 1981; Caprioli and Sears, 1983; Malaisse and Malaisse-Lagae, 1984; Ammon and MOiier, 1985; Dohadwalla, 1985; Potter et al., 1985). Forskolin also has been reported to induce bronchodilation in guinea pigs (i.v. doses of 1 ml/kg body weight for 10 minutes and i.t. administration of 30 µg) and in asthmatic patients (inhalation of 1 to 10 mg forskolin, as dry powder), with no significant side effects (Lichey et al., 1984; Kreutner et al., 1985; Bauer et al., 1993). Conclusions To put the safety of forskolin, or any substance for that matter, into perspective, it is important to consider the toxicological principle of dose response. Any substance at a sufficient dose will be toxic, and there is a dose for all substances below which no effect will occur. The evidence we have reviewed for forskolin has not revealed any reason to believe that it is not safe at the dose levels tested in animal studies and in clinical trials. The activation of adenylate cyclase and subsequent increase in cAMP levels in the body are associated with a number of physiological functions. Although the available toxicological studies in animals and clinical studies at the intended level of use indicated that C. forskohlii 10% extract is welltolerated and without adverse effects, these studies do not address the possibility of interactions with other active substances. The 28-day study in August 31, 2004 Page 6 rats provided a NOEL of 1,000 mg/kg body weight/day, the highest dose tested, which provides a 120-fold margin of safety over the intended dose of 500 mg/person/day (8.3 mg/kg body weight/day for a 60 kg individual). This margin of safety would likely be more for the intended, overweight user. Clinical studies in which ForsLean® was administered at doses of up to 500 mg/day for periods of up to 12 weeks have demonstrated no significant effects on clinical chemistry or hematological parameters, nor any significant detrimental effects on blood pressure and thyroid function. Based on review of in vitro studies on the pharmacological actions of forskolin, but without the benefit of recent toxicological and clinical studies, in 1997 the American Botanical Council (ABC) indicated that forskolin "has the ability to potentiate many drugs", and has suggested that caution be exercised in all patients taking prescription medications. In addition, the ABC contraindicated the use of forskolin by gastric ulcer patients and hypotensive patients (ABC, 1997). It should be noted that forskolin's mode of action is not the same (Lindner et al, 1987; Kramer et al, 1987) as sympathomimetic agents which have been a concern due to their stimulant activity. Nevertheless, as an activator of adenylate cyclase, possible interaction with other physiologically active supplements or drugs should be subject to warnings on product labels. Normally, in the absence of clinical data, a minimum battery of genotoxicity, reproduction, and subchronic (i.e., 90 days) studies is desirable. The toxicological database for forskolin is limited, with the longest duration of exposure of 28 days in a rat study, but a number of longer term clinical studies are available. A bacterial mutation test showed no genotoxic potential in a microbial system. In the absence of developmental or reproduction studies, the product should be labeled with a warning against use by pregnant women. Lack of chronic data can be addressed by clear labeling that warns against long term use. The clinical database is supportive of the safety of the intended dosage level (50 mg forskolin/day). The available studies, of which three are randomized, placebo-controlled and double-blind, provide evidence that helps to compensate for a limited toxicological database. Safe use of forskolin also is supported by a long history of its use as a spice and in traditional medicine. Although it has been estimated that consumption from spice in India may amount to 5 mg intake of forskolin per day, there is no specific information available about dosage levels from Hindu and Ayurvedic traditional medicine. If serious side effects or adverse events had been suspected to be linked to forskolin, however, it is logical that there would not be continuing use of such preparations, and one might expect reports of adverse effects in the literature. In the United States, 10's of millions of dosages per year have been consumed in recent years without Adverse Effect Reports (AERs). Although AERs are not a reliable source of information concerning August 31, 2004 Page 7 safety, the absence of AERs for forskolin is helpful, given the publicity and political pressure attendant to the AERs reported for other herbals such as ephedra and kava kava. In summary, with appropriate labeling to address potentiation, contraindications, cessation with serious or continuing side effects, period of time of consumption, etc., especially considering the intended use for obesity, the available information supports the safety of Forslean® at the intake level of 500 mg per day resulting in a dose of 50 mg of forskolin per day. References ABC. 1997. Coleus forskohlii Monograph. American Botanical Council HerbClip, May 1, 1997. Agena, S.M. Unpublished. The effect of forskolin supplementation on weight loss in moderately active overweight males. Ammon, H.P.T.; MOiier, A.B. 1985. Forskolin: From an ayurvedic remedy to a modern agent. Planta Med No. 6:473-477. Badmaev, V.; Majeed, M.; Conte, A.A.; Parker, J.E. 2002. Diterpene forksolin ( Coleus forskohlii, Benth.): A possible new compound for reduction of body weight by increasing lean body mass. NutraCos 1(2):6-7. Bauer, K.; Dietersdorfer, F.; Sertl, K.; Kaik, B.; Kaik, G. 1993. Pharmacodynamic effects of inhaled dry powder formulations of fenoterol and colforsin in asthma. Clin Pharmacol Ther 53:76-83. Bhagwhat, A.M.; Joshi, B. (Principal Investigators); Joshi, A.S.; Jain, A.; Sawant, N. (Co- Investigators). 2004. A randomized double-blinded multicenter phase Ill clinical trial to investigate the efficacy and safety of ForsLean® in increasing lean body mass. Shri C.B. Patel Research Centre for Chemistry and Biological Sciences; Mumbai, India. Sponsored by Sarni Labs Limited; Bangalore, India. [Study Protocol Number: FL-003/2003]. Bhide, R.M. 2004. Subacute oral toxicity study (28 day) of C31971 in the Sprague- Dawley rat. Indian Institute of Toxicology, Pune, India. Project No. 9620 unpublished study report. Caprioli, J.: Sears. M. 1983. Forskolin lowers intraocular pressure in rabbits, monkeys, and man. Lancet 1:958-960. de Souza, N.J.; Dohadwalla, A.N.; Reden, J. 1983. Forskolin: A labdane diterpenoid with antihypertensive, positive inotropic, platelet aggregation inhibitory, and adenylate cyclase activating properties. Med Res Rev 3(2):201-219. Dohadwalla, A.N. 1985. Biological Activities of Forskolin.!.O.: Rupp, R.H.; de Souza, N.J.; Dohadwalla, A.N. (Eds). 1985. Proceedings of the International Symposium on Forskolin: its chemical, biological and medical potential. Hoechst India Limited, Bombay 400 080. p 19-30. Dubey, M.P.; Srimal, R.C.; Nityanand, S.; Dhawan, B.N. 1981. Pharmacological studies on coleonol, a hypotensive diterpene from Coleus forskohlii. J Ethnopharmacol 3(1):1-13.