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Natural Health Product microbiology testing should begin with the product, specification and quality decision, not simply with the name of a United States Pharmacopeia chapter.

Depending on the product and microbiological requirement, applicable testing may involve:

  • USP <61>;
  • USP <62>.
  • USP <2021>.
  • USP <2022>.

These chapters do not all answer the same question.

Some methods evaluate how much microbial growth is present, while others evaluate whether specified microorganisms are detected under the applicable method.

PBR Laboratories supports Natural Health Product manufacturers, ingredient suppliers, contract manufacturers, brand owners and quality teams from Edmonton across Alberta, Western Canada and Canada.

The starting question should be:

What microbiological requirement applies to this product, what sample is being tested, and what decision must the result support?

Which USP Microbiology Test Does My Natural Health Product Need?

The appropriate USP microbiology test depends on the Natural Health Product category, matrix, specification and microbiological question.

Microbial enumeration testing measures microbial populations.

Specified-microorganism testing evaluates selected microorganisms according to the applicable method.

USP <61>/<62> and USP <2021>/<2022> should therefore not be treated as interchangeable test names.

The specification should first establish whether the product requires:

  • Microbial enumeration.
  • Specified-microorganism testing.
  • Or both.

What Is Microbial Enumeration?

Microbial enumeration measures the microbial population recovered from the submitted sample under the applicable analytical method.

Depending on the product and specification, this may include measures such as:

  • Total aerobic microbial count.
  • Yeast and mould.

Enumeration testing can support:

  • Raw-material assessment.
  • Finished-product specifications.
  • Lot evaluation.
  • Supplier monitoring.
  • Quality trending.
  • Investigation of elevated microbial counts.

The reported value should always be interpreted against the applicable method, units and product specification.

USP <61> — Microbial Enumeration

USP <61> addresses microbial enumeration for applicable non-sterile products.

The test helps answer:

How much microbial growth was measured in the submitted sample?

An enumeration result does not identify the source of an elevated count and does not automatically determine whether a batch should be released.

Those decisions require the product specification, sampling context and quality-system requirements.

USP <62> — Specified Microorganisms

USP <62> addresses testing for specified microorganisms in applicable non-sterile products.

This answers a different question:

Does the submitted sample meet the applicable requirement for the specified microorganism?

The microorganisms included in the testing program should reflect the product and specification rather than a generic panel applied to every Natural Health Product.

USP <2021> — Microbial Enumeration for Nutritional and Supplement Products

USP <2021> addresses microbial enumeration for applicable nutritional and dietary supplement products.

Testing may support assessment of aerobic microbial populations and yeast and mould where these parameters are relevant to the product specification.

The result should be considered alongside:

  • Product matrix.
  • Sample identity.
  • Units.
  • Method.
  • Specification.
  • Sampling plan.

USP <2022> — Specified Microorganisms for Nutritional and Supplement Products

USP <2022> addresses specified-microorganism testing for applicable nutritional and dietary supplement products.

Depending on the product and specification, relevant microorganisms may include:

  • Bile-tolerant Gram-negative bacteria.
  • Escherichia coli.
  • Salmonella species.
  • Staphylococcus aureus.
  • Pseudomonas aeruginosa.

The applicable testing should be confirmed for the specific Natural Health Product.

USP <61>/<62> vs USP <2021>/<2022>

Testing Question Applicable Framework
Microbial enumeration for applicable non-sterile products USP <61>
Specified microorganisms for applicable non-sterile products USP <62>
Microbial enumeration for applicable nutritional and supplement products USP <2021>
Specified microorganisms for applicable nutritional and supplement products USP <2022>

The method should be selected because it matches the product category, specification and analytical question, not simply because the chapter is familiar.

Does a Natural Health Product Need Both Enumeration and Specified-Microorganism Testing?

Potentially.

A finished-product specification may contain:

  • Microbial-count limits.
  • Specified-organism requirements.
  • Or both.

The appropriate program depends on:

  • Product type.
  • Ingredients.
  • Dosage form.
  • Applicable specification.
  • Quality program.

There is no single microbiology panel that should automatically be used for every Natural Health Product.

Raw Material vs Finished Product USP Testing

Raw-material microbiology and finished-product microbiology answer different questions.

Raw-material testing may support:

  • Supplier qualification.
  • Incoming-lot decisions.
  • Investigation of ingredient variability.

Finished-product testing evaluates the actual manufactured product after:

  • Ingredients are combined.
  • Blending occurs.
  • Processing occurs.
  • Handling and packaging are completed.

Passing raw materials does not automatically establish that the finished product will meet its microbiological specification.

What Does a High Microbial Count Mean?

A high microbial count means that the submitted sample produced a result above the applicable comparison criterion or specification.

It does not automatically identify the cause.

An investigation may need to consider:

  • Raw materials.
  • Supplier lots.
  • Manufacturing.
  • Sanitation.
  • Handling.
  • Storage.
  • Moisture.
  • Water activity.
  • Sample representativeness.

What Does a Negative Specified-Microorganism Result Mean?

A negative or not-detected result applies to the submitted sample under the applicable method.

It does not automatically prove that the entire production lot is free of the microorganism.

How confidently the result represents a larger lot depends on:

  • Sampling plan.
  • Number of units.
  • Lot size.
  • Product heterogeneity.
  • Sample handling.

Why Sampling Matters

Laboratory results are only as representative as the submitted sample allows.

Potential issues include:

  • Too few units.
  • Samples collected from only one location.
  • Heterogeneous powder lots.
  • Inappropriate compositing.
  • Insufficient sample quantity.
  • Poor handling.
  • Failure to retain units for investigation.

Before submitting a large or heterogeneous lot, discuss sample requirements with PBR.

Moisture, Water Activity & Microbiology

Moisture and water activity can provide useful supporting information during some microbiological investigations.

They do not replace microbiology testing.

Moisture describes the amount of water associated with the product.

Water activity provides information about how available that water is within the formulation.

Common Mistakes in USP Testing

Choosing the USP Chapter Before Defining the Product

The product and specification should determine the method.

Treating Enumeration and Specified-Microorganism Testing as the Same Thing

They answer different microbiological questions.

Using the Same Panel for Every Natural Health Product

Ingredient and matrix risks can vary substantially.

Assuming Passing Ingredients Guarantee the Finished Product

Manufacturing introduces additional factors.

Treating a Negative Result as Proof About the Entire Lot

The result applies to the submitted sample.

Automatically Retesting an Unexpected Result

First determine what the follow-up testing needs to establish.

USP Testing in Edmonton & Alberta

PBR Laboratories provides Natural Health Product microbiology support from Edmonton, Alberta.

Manufacturers and quality teams can discuss:

  • Product matrix.
  • Microbiological specification.
  • Raw material or finished product.
  • Applicable USP chapter.
  • Enumeration requirements.
  • Specified microorganisms.
  • Sample requirements.
  • Unexpected results.

USP Testing Across Western Canada

PBR supports Natural Health Product manufacturers and quality teams throughout Western Canada.

The testing pathway should be:

product → specification → microbiological question → applicable method → representative sample → result → quality decision

USP Testing Across Canada

PBR supports Canadian Natural Health Product manufacturers, brand owners, ingredient suppliers and quality teams requiring applicable microbiology testing.

PBR helps clients understand not only the result, but also what the result represents and what testing decision may be appropriate next.

Frequently Asked Questions

What USP microbiology testing may apply to Natural Health Products?

Depending on the product and specification, applicable methods may include USP <61>, <62>, <2021> and <2022>.

What is the difference between microbial enumeration and specified microorganisms?

Enumeration measures microbial populations. Specified-microorganism testing evaluates selected microbial targets.

Does every Natural Health Product need the same microbiology testing?

No. The appropriate testing depends on the product, ingredients, specification and quality program.

Can PBR test for Salmonella?

PBR supports Salmonella testing for applicable matrices.

Can PBR test for Escherichia coli?

PBR supports Escherichia coli testing for applicable matrices.

Does a negative result prove the entire lot is free of the microorganism?

No. The result applies to the submitted sample, and the sampling plan affects how confidently it represents the production lot.

Should raw materials be tested for microbiology?

Potentially. Raw-material testing can support supplier qualification, incoming-lot decisions and investigations.

Does passing raw materials mean the finished product will pass?

No. Finished-product microbiology is also influenced by manufacturing, handling, packaging and storage.

Need Help Selecting USP Microbiology Testing?

Tell PBR:

  • What product you are testing.
  • Whether it is a raw material or finished product.
  • What specification applies.
  • Whether microbial counts, specified microorganisms or both are required.
  • What quality or batch decision the result needs to support.

Choose PBR — Because Precision Matters, Defining Excellence in Laboratory Services Since 1984.