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I have copied the following message from the Herbal Medicine tribe. Please read asap. The comment period ends 3/31 unless we can get an extension. I have read this document and, as an herbalist who practices traditional medicine using mostly herbs grown in gardens or harvested from the wild, I'm scared. This "regulatory model" is being written by organizations who are trying to protect their livelihood and are not providing any service to those of us who do not manufacture herb capsules, tinctures, etc. in a lab. Please send comments to the email address and include the reasons for extending the deadline outlined below. If traditional medicine starts being regulated in this manner, it is no longer traditional.
Blessed Be!
Raven
Dear Fellow Herbalists,
I want to thank my good friends, Cascade and Susun for bringing this ‘Proposed Regulatory Model for Traditional Medicine’ to my attention and getting me off my seat to do something about it. If you’ve not heard about it yet, then you’ll also want to thank Cascade and Susun and Marguerite, the NEHA Journal, and all the people who are out there trying to circulate this information before its ‘forever too late’. . Because if you are impassioned by your work with plants and love the freedom and spirit of herbalism, its imperative that you respond immediately (see email addresses below). Public comment ends March 31, yet few people outside of the organizations that drafted the proposal, know what’s happening. So, what in a nutshell is happening? “Nine national organizations working together as the Traditional Medicines Congress have released the first public draft of A Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components. This comprehensive document presents ideas for a new model for the regulation of traditional medicines in the United States, and will now be subject to an open review process by interested individuals and organizations. Etc” It’s a long tedious document, but well worth reading as it will effect the way we all practice herbal medicine…and if put in action will effect the future of herbalism in this country.
I must admit, I’m biased. I don’t think licensing is beneficial for the practice of herbalism. As Susun Weed states in her letter addressing this same issue, “from Culpepper until today, herbal medicine has been the medicine of the people, not the medicine of the licensed elite….People don’t need licenses to care for themselves and their families (or community). Licenses don’t protect people; they protect, and create, institutions’ (blog at www.susunweed.com)
Whether we agree or not on this matter, is not really the issue. What is the issue is decisions are being made about the profession we each love and cherish, a ‘calling’ that we’ve devoted our lives and hearts and souls to, in which we have not had adequate notice or public forums for discussion. The public comment date is over March 31, 2006. We need to request an extension on the Public Comment Date and we need to comment. There are several points that Cascade has listed (see below) that set a precedent for an extension on the date for public comments: limited visibility and distribution of the document, in adequate accessibly to the document, and lack of public forums over the document.
Please take a few minutes to read the document and then contact the following three organizations with Your Comments and ask for a 6 Month Extension on the Public Comment Date.
American Herbal Products Association AHPA - Karen Robin (301) 588-1171, ext. 107 - krobin@ahpa.org
TMCongressFeedback@pobox.com.
American Herbalist Guild: ahgoffice@earthlink.com; 203.272.6731
Cascade summed this up for us to make it easier to access and to get a good understanding of some of the key issues (Thank you, Cascade)
The March 31, 2006 deadline for public comments regarding the document entitled, A Proposed Regulatory Model for Traditional Medicines, should be extended for a minimum of 6 months due to issues regarding accountability, transparency and visibility. The following represent a few of the most apparent problems.
1) This document is not easily available and accessible.
- No link to the document is mentioned on AHPA's homepage (and unable to find it by clicking around. It is on the AHG's homepage and the link takes you to AHPA's link.)
2) This document has limited visibility and distribution.
-- No link to the document is mentioned on AHPA's homepage (and unable to find it by clicking around. It is on the AHG's homepage but the link to the actual pdf draft document takes you to AHPA's.)
-- A comprehensive distribution list of interested parties related to all aspects of the broad range of subjects addressed in this document needs to be established and utilized.
3) The vehicle, an email address, for making public comments does not adequately provide a public forum. In addition it does not provide assurance to a submitter that their comments have been received and will remain unaltered.
-- A public comment vehicle should follow the general protocol of the U.S. government's Federal Registry: "The general policy for comments and other submissions from members of the public is to make these submissions available for public viewing on the Internet as they are received and without change, including any personal identifiers or contact information. For any agency specific information, see the Federal Register Notice on which you are commenting." (as taken from: www.regulations.gov/fdmspubl...ent/main)
4) There is extremely limited background information available about the Traditional Medicine Congress who apparently created the document.
-- A roster of the individuals sitting on the Traditional Medicine Congress needs to be clearly posted with background information on the members.
-- There are no agendas and/or minutes of the meetings of the Traditional Medicine Congress available to provide background and context to the public.
-- One of the apparent primary sponsoring organizations, the American Herbalists Guild (AHG), is also lacking a roster of board and/or staff members
Press releases cut and pasted from AHPA and the AHG sites:
www.ahpa.org
CONTACT:
AHPA - Karen Robin (301) 588-1171, ext. 107 - krobin@ahpa.org
Traditional Medicines Congress Calls for Comments on “Ideal Regulatory Model”
(November 29, 2005) — Nine national organizations working together as the Traditional Medicines (TM) Congress* have released the first public draft of “A Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components.” This comprehensive document presents ideas for a new model for the regulation of traditional medicines in the United States, and will now be subject to an open review process by interested individuals and organizations.
The American Herbal Products Association joined with eight other organizations in the spring of 2004 to exchange ideas about the future of traditional medicines in the U.S. The result of these discussions was the formation of the TM Congress. In seeking to emphasize both the value of traditional medicines and the responsibilities that are associated with their use, it was agreed that:
The goal of the Traditional Medicines Congress is to benefit public health by ensuring access to traditional medicines in a manner that provides a reasonable expectation of public safety.
“The current legal framework for dietary supplements provides significant options for consumer health care choices,” noted AHPA President Michael McGuffin. “And while some goods that have long been used as traditional medicines fit neatly into this framework, the therapeutic uses of these are restricted and many are entirely excluded. The model proposed here would completely protect the current law while developing a new option that will benefit marketers who want to sell traditional medicines and practitioners and consumers who want to use them,” he added.
Anyone with an interest in traditional medicines is now invited to review the draft document that the TM Congress has developed. A Proposed Regulatory Model for Traditional Medicines is posted online at www.ahpa.org/05_1129_TMC...edModel.pdf.
Comments can be emailed to TMCongressFeedback@pobox.com. The deadline for comments is March 31, 2006.
* The Traditional Medicines Congress is comprised of these organizations:
* Acupuncture and Oriental Medicine Alliance (AOMA);
* American Association of Naturopathic Physicians (AANP);
* American Association of Oriental Medicine (AAOM);
* American Herbalist Guild (AHG);
* American Herbal Products Association (AHPA);
* Council of Colleges of Acupuncture and Oriental Medicine (CCAOM);
* Medicinal Herb Consortium (MHC);
* National Ayurvedic Medical Association (NAMA); and
* National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM).
www.americanherbalistsguild.com/
Traditional Medicines Congress Press Release
November 29, 2005
Traditional Medicines Congress Calls for Comments on Ideal Regulatory Model
Nine national organizations working together as the Traditional Medicines (TM) Congress [1] have released the first public draft ofA Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components. This comprehensive document presents ideas for a new model for the regulation of traditional medicines in the United States, and will now be subject to an open review process by interested individuals and organizations.
The American Herbalists Guild joined with 8 other organizations in the spring of 2004 to exchange ideas about the future of traditional medicines in the U.S. The result of these discussions was the formation of the TM Congress. In seeking to emphasize both the value of traditional medicines and the responsibilities that are associated with their use, it was agreed that:
The goal of the Traditional Medicines Congress is to benefit public health by ensuring access to traditional medicines in a manner that provides a reasonable expectation of public safety.
"We are extremely pleased to be part of this group of national organizations working cooperatively for the first time to address one of the most critical issues facing our profession" said Aviva Romm, President of the American Herbalists Guild. "This is an important first step in protecting access to traditional medicines and improving people's health and well being."
According to Roy Upton, Vice President of the American Herbalists Guild and Executive Director of the American Herbal Pharmacopoeia, "The current regulation of herbs as 'dietary supplements' is fine for accessing them for general health purposes, in healthy individuals. This must be protected at all costs. However, it completely neglects the legitimate use of botanicals for therapeutic purposes, which is one of the greatest values of herbs in health care. Also, many botanicals have been prohibited from use due to politics, improper use as a result of inappropriate marketing, or inaccurate reports of potential toxicity. This new proposal is designed to protect continued access to herbal medicines and promote their safe and responsible use."
Anyone with an interest in traditional medicines is now invited to review the draft document that the TM Congress has developed. A Proposed Regulatory Model for Traditional Medicines is posted online at:
www.ahpa.org/05_1129_TMC...edModel.pdf. Comments can be emailed to TMCongressFeedback@pobox.com. The deadline for comments is March 31, 2006.
------------------------------------------------------------------------
[1] Acupuncture and Oriental Medicine Alliance (AOMA); American Association of Naturopathic Physicians (AANP); American Association of Oriental Medicine (AAOM); American Herbalists Guild (AHG); American Herbal Products Association (AHPA); Council of Colleges of Acupuncture and Oriental Medicine (CCAOM); Medicinal Herb Consortium (MHC); National Ayurvedic Medical Association (NAMA); and National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM).
The pdf of the document A Proposed Regulatory Model for Traditional Medicines
as downloaded from: www.ahpa.org/05_1129_TMC...sedModel.pdf
posted by:
Alura
California
20 friends
Blessed Be!
Raven
Dear Fellow Herbalists,
I want to thank my good friends, Cascade and Susun for bringing this ‘Proposed Regulatory Model for Traditional Medicine’ to my attention and getting me off my seat to do something about it. If you’ve not heard about it yet, then you’ll also want to thank Cascade and Susun and Marguerite, the NEHA Journal, and all the people who are out there trying to circulate this information before its ‘forever too late’. . Because if you are impassioned by your work with plants and love the freedom and spirit of herbalism, its imperative that you respond immediately (see email addresses below). Public comment ends March 31, yet few people outside of the organizations that drafted the proposal, know what’s happening. So, what in a nutshell is happening? “Nine national organizations working together as the Traditional Medicines Congress have released the first public draft of A Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components. This comprehensive document presents ideas for a new model for the regulation of traditional medicines in the United States, and will now be subject to an open review process by interested individuals and organizations. Etc” It’s a long tedious document, but well worth reading as it will effect the way we all practice herbal medicine…and if put in action will effect the future of herbalism in this country.
I must admit, I’m biased. I don’t think licensing is beneficial for the practice of herbalism. As Susun Weed states in her letter addressing this same issue, “from Culpepper until today, herbal medicine has been the medicine of the people, not the medicine of the licensed elite….People don’t need licenses to care for themselves and their families (or community). Licenses don’t protect people; they protect, and create, institutions’ (blog at www.susunweed.com)
Whether we agree or not on this matter, is not really the issue. What is the issue is decisions are being made about the profession we each love and cherish, a ‘calling’ that we’ve devoted our lives and hearts and souls to, in which we have not had adequate notice or public forums for discussion. The public comment date is over March 31, 2006. We need to request an extension on the Public Comment Date and we need to comment. There are several points that Cascade has listed (see below) that set a precedent for an extension on the date for public comments: limited visibility and distribution of the document, in adequate accessibly to the document, and lack of public forums over the document.
Please take a few minutes to read the document and then contact the following three organizations with Your Comments and ask for a 6 Month Extension on the Public Comment Date.
American Herbal Products Association AHPA - Karen Robin (301) 588-1171, ext. 107 - krobin@ahpa.org
TMCongressFeedback@pobox.com.
American Herbalist Guild: ahgoffice@earthlink.com; 203.272.6731
Cascade summed this up for us to make it easier to access and to get a good understanding of some of the key issues (Thank you, Cascade)
The March 31, 2006 deadline for public comments regarding the document entitled, A Proposed Regulatory Model for Traditional Medicines, should be extended for a minimum of 6 months due to issues regarding accountability, transparency and visibility. The following represent a few of the most apparent problems.
1) This document is not easily available and accessible.
- No link to the document is mentioned on AHPA's homepage (and unable to find it by clicking around. It is on the AHG's homepage and the link takes you to AHPA's link.)
2) This document has limited visibility and distribution.
-- No link to the document is mentioned on AHPA's homepage (and unable to find it by clicking around. It is on the AHG's homepage but the link to the actual pdf draft document takes you to AHPA's.)
-- A comprehensive distribution list of interested parties related to all aspects of the broad range of subjects addressed in this document needs to be established and utilized.
3) The vehicle, an email address, for making public comments does not adequately provide a public forum. In addition it does not provide assurance to a submitter that their comments have been received and will remain unaltered.
-- A public comment vehicle should follow the general protocol of the U.S. government's Federal Registry: "The general policy for comments and other submissions from members of the public is to make these submissions available for public viewing on the Internet as they are received and without change, including any personal identifiers or contact information. For any agency specific information, see the Federal Register Notice on which you are commenting." (as taken from: www.regulations.gov/fdmspubl...ent/main)
4) There is extremely limited background information available about the Traditional Medicine Congress who apparently created the document.
-- A roster of the individuals sitting on the Traditional Medicine Congress needs to be clearly posted with background information on the members.
-- There are no agendas and/or minutes of the meetings of the Traditional Medicine Congress available to provide background and context to the public.
-- One of the apparent primary sponsoring organizations, the American Herbalists Guild (AHG), is also lacking a roster of board and/or staff members
Press releases cut and pasted from AHPA and the AHG sites:
www.ahpa.org
CONTACT:
AHPA - Karen Robin (301) 588-1171, ext. 107 - krobin@ahpa.org
Traditional Medicines Congress Calls for Comments on “Ideal Regulatory Model”
(November 29, 2005) — Nine national organizations working together as the Traditional Medicines (TM) Congress* have released the first public draft of “A Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components.” This comprehensive document presents ideas for a new model for the regulation of traditional medicines in the United States, and will now be subject to an open review process by interested individuals and organizations.
The American Herbal Products Association joined with eight other organizations in the spring of 2004 to exchange ideas about the future of traditional medicines in the U.S. The result of these discussions was the formation of the TM Congress. In seeking to emphasize both the value of traditional medicines and the responsibilities that are associated with their use, it was agreed that:
The goal of the Traditional Medicines Congress is to benefit public health by ensuring access to traditional medicines in a manner that provides a reasonable expectation of public safety.
“The current legal framework for dietary supplements provides significant options for consumer health care choices,” noted AHPA President Michael McGuffin. “And while some goods that have long been used as traditional medicines fit neatly into this framework, the therapeutic uses of these are restricted and many are entirely excluded. The model proposed here would completely protect the current law while developing a new option that will benefit marketers who want to sell traditional medicines and practitioners and consumers who want to use them,” he added.
Anyone with an interest in traditional medicines is now invited to review the draft document that the TM Congress has developed. A Proposed Regulatory Model for Traditional Medicines is posted online at www.ahpa.org/05_1129_TMC...edModel.pdf.
Comments can be emailed to TMCongressFeedback@pobox.com. The deadline for comments is March 31, 2006.
* The Traditional Medicines Congress is comprised of these organizations:
* Acupuncture and Oriental Medicine Alliance (AOMA);
* American Association of Naturopathic Physicians (AANP);
* American Association of Oriental Medicine (AAOM);
* American Herbalist Guild (AHG);
* American Herbal Products Association (AHPA);
* Council of Colleges of Acupuncture and Oriental Medicine (CCAOM);
* Medicinal Herb Consortium (MHC);
* National Ayurvedic Medical Association (NAMA); and
* National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM).
www.americanherbalistsguild.com/
Traditional Medicines Congress Press Release
November 29, 2005
Traditional Medicines Congress Calls for Comments on Ideal Regulatory Model
Nine national organizations working together as the Traditional Medicines (TM) Congress [1] have released the first public draft ofA Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components. This comprehensive document presents ideas for a new model for the regulation of traditional medicines in the United States, and will now be subject to an open review process by interested individuals and organizations.
The American Herbalists Guild joined with 8 other organizations in the spring of 2004 to exchange ideas about the future of traditional medicines in the U.S. The result of these discussions was the formation of the TM Congress. In seeking to emphasize both the value of traditional medicines and the responsibilities that are associated with their use, it was agreed that:
The goal of the Traditional Medicines Congress is to benefit public health by ensuring access to traditional medicines in a manner that provides a reasonable expectation of public safety.
"We are extremely pleased to be part of this group of national organizations working cooperatively for the first time to address one of the most critical issues facing our profession" said Aviva Romm, President of the American Herbalists Guild. "This is an important first step in protecting access to traditional medicines and improving people's health and well being."
According to Roy Upton, Vice President of the American Herbalists Guild and Executive Director of the American Herbal Pharmacopoeia, "The current regulation of herbs as 'dietary supplements' is fine for accessing them for general health purposes, in healthy individuals. This must be protected at all costs. However, it completely neglects the legitimate use of botanicals for therapeutic purposes, which is one of the greatest values of herbs in health care. Also, many botanicals have been prohibited from use due to politics, improper use as a result of inappropriate marketing, or inaccurate reports of potential toxicity. This new proposal is designed to protect continued access to herbal medicines and promote their safe and responsible use."
Anyone with an interest in traditional medicines is now invited to review the draft document that the TM Congress has developed. A Proposed Regulatory Model for Traditional Medicines is posted online at:
www.ahpa.org/05_1129_TMC...edModel.pdf. Comments can be emailed to TMCongressFeedback@pobox.com. The deadline for comments is March 31, 2006.
------------------------------------------------------------------------
[1] Acupuncture and Oriental Medicine Alliance (AOMA); American Association of Naturopathic Physicians (AANP); American Association of Oriental Medicine (AAOM); American Herbalists Guild (AHG); American Herbal Products Association (AHPA); Council of Colleges of Acupuncture and Oriental Medicine (CCAOM); Medicinal Herb Consortium (MHC); National Ayurvedic Medical Association (NAMA); and National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM).
The pdf of the document A Proposed Regulatory Model for Traditional Medicines
as downloaded from: www.ahpa.org/05_1129_TMC...sedModel.pdf
posted by:
Alura
California
20 friends
posted by:
|
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