tag:blogger.com,1999:blog-86496583941573309022024-03-13T10:03:59.456+00:00Lobby for the regulation of Herbal MedicineNapiers the Herbalistshttp://www.blogger.com/profile/00720682833256172455noreply@blogger.comBlogger9125tag:blogger.com,1999:blog-8649658394157330902.post-13497899876041233342009-10-06T22:30:00.019+01:002009-11-09T22:39:43.226+00:00Act for a Choice of Herbal Medicine in the Future<b style="color: red;">Is it important to you that herbal medicine exists?</b> The Department of Health is running a Consultation to ask people whether medical herbalists should be regulated, or not. This will have important consequences in determining <i>whether (or not)</i> you and your family can access herbal medicine in the future! <a href="http://actnow.napiers.net/2009/10/what-can-you-do-to-help.html"><b style="color: red;">Act Now</b></a> as the deadline is <b style="color: red;">16 November</b>. For the <a href="http://actnow.napiers.net/2009/10/status-of-herbal-medicine-practitioners.html">full story click here</a>, but, in a nutshell, most herbalists want to be regulated and:<br />
<br />
<b>If all herbalists have to be regulated</b> they will:<br />
<ul><li>be professional practitioners with an agreed level of training</li>
<li>have a Degree in Herbal Medicine (like all those at Napiers)</li>
<li>regulated by a professional body</li>
<li>undergo Continuous Professional Development</li>
<li>adher to a code of ethics and be insured to practice</li>
<li>be more accessible to G.P.s and other healthcare practitioners</li>
<li>have access to a wide range of herbal medicines (of controlled quality)</li>
</ul><b>If herbalists are NOT regulated</b> as is the case now:<br />
<ul><li>anyone could practice, calling themselves a medical herbalist - even if not qualified!</li>
<li>there will be widely varying standards of professionalism and qualifications</li>
<li>they'll have little ability to hold dialogue with G.P.s or other healthcare practitioners</li>
<li>not be able to supply a full range of herbal medicines to patients</li>
</ul><div style="color: red;"><span style="font-size: large;"><b>PLEASE ACT NOW</b></span><br />
</div>The consultation closes on <b>16 November</b> this year. Please do one of or all of the following:<br />
<ul><li>Write to your M.P. in your own words or download a template of <a href="http://actnow.napiers.net/2009/10/write-to-your-mp-about-herbal-medicine.html">Sample MP Letter 1</a> on the right.</li>
<li>Copy this to your M.E.P. or M.S.P.</li>
<li>You can find your M.P.'s address <a href="http://findyourmp.parliament.uk/" target="new">here</a></li>
<li>Fill in the Department of Health's Consultation Paper (<a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">download here</a>) or</li>
<li>Write to the DH Consultation Team, in your own words or using <a href="http://actnow.napiers.net/2009/10/simple-response-to-to-herbal-medicine.html">Sample DoH Letter 2</a> or <a href="http://actnow.napiers.net/2009/10/response-to-consultation-on-herbal.html">Sample DoH Letter 3</a> on the right, to request they register your opinion</li>
</ul><div style="color: #274e13;"><span style="font-weight: bold;">THANK YOU</span><br />
</div><b style="color: #274e13;">This is so important. People have used herbal medicines for at least 25,000 years and we want to retain our right of choice to do so in the future. Post-2011, in order for you to have the most choice in herbal medicine, it is vitally important that herbalists are regulated. </b>This way you will have access to both a small range over-the-counter <i>licensed</i> herbal remedies and to a wide range of prescription herbal formulas. And, you will also know your practitioner is properly trained, up-to-date and operating from a strict code of ethics. It is important to remember that herbalists themselves want to be regulated. Only by acting now can we influence the Government's decision.Napiers the Herbalistshttp://www.blogger.com/profile/00720682833256172455noreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-42223726130661156702009-10-06T22:25:00.003+01:002009-10-07T15:50:17.200+01:00A Letter from Dee to all our Patients and Customers<a href="http://lh3.ggpht.com/_SPLZQd9Tl7U/SrzX-fiNwbI/AAAAAAAAAbg/-u_TmBh6l9E/DeeWinterWeb.jpg" onblur="try {parent.deselectBloggerImageGracefully();} catch(e) {}" style="clear: right; float: right; margin-bottom: 1em; margin-left: 1em;"><img alt="" border="0" src="http://lh3.ggpht.com/_SPLZQd9Tl7U/SrzX-fiNwbI/AAAAAAAAAbg/-u_TmBh6l9E/DeeWinterWeb.jpg" style="float: right; height: 197px; margin: 0pt 0pt 10px 10px; width: 197px;" /></a>Dee Atkinson,<br />
MNIMH, MCCP, Medical Herbalist<br />
Managing Director<br />
Napiers the Herbalists Ltd<br />
35 Hamilton Place<br />
Edinburgh EH3 5BA<br />
<br />
October 2009<br />
<br />
<br />
<br />
Dear Patient, Customer, Colleague or Friend<br />
<br />
I am writing to you on a matter of the utmost importance. A matter that may affect your ability to buy herbal medicines in the future. It may come as a surprise to you to know that not all herbalists are qualified and nor are they regulated! Of course, all Napiers practitioners are, and I have worked hard with various national forum and working groups to ensure that medical herbalists practice at the same high levels you would expect from any healthcare practitioner.<br />
<br />
The Department of Health has now published a <a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567">Consultation Document</a> on the regulation of herbalists. In order to protect your access to professional herbal treatment, and to allow people to have the choice to use herbal medicine, it is essential that as many of us as possible respond positively stating that we want herbalists to be regulated. I have explained the reasons for this in <a href="http://actnow.napiers.net/2009/10/why-vote-yes.html">more depth here</a> but in essence, <a href="http://actnow.napiers.net/2009/10/act-for-choice-of-herbal-medicine-in.html">if herbalists are regulated</a> they will still be able to provide a wide range of herbal medicines.<br />
<br />
The <a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">Consultation Document</a> is complex and not easy to understand, so we have published <a href="http://actnow.napiers.net/2009/10/consultation-questions-and-sample.html" target="new">our response</a> to it on our website. On the website we have also posted a couple of sample letters which you could use if you wish to do so - <a href="http://actnow.napiers.net/2009/10/write-to-your-mp-about-herbal-medicine.html" target="new">a sample letter to your MP</a>, a <a href="http://actnow.napiers.net/2009/10/simple-response-to-to-herbal-medicine.html" target="new">personal reply to DoH</a> and a <a href="http://actnow.napiers.net/2009/10/response-to-consultation-on-herbal.html" target="new">professional reply to DoH</a> – though in order for your response to really count you should ‘personalise’ it in some way so that it is not an exact copy. Your response may not be counted if it is seen to be a standard reproduced letter.<br />
<br />
As a frequent user of herbal medicine, I am urging you to write to the Department of Health immediately. Responses must be in by the end of October to be valid, so time is of the essence. Your letter should be sent to:-<br />
<br />
AHMTCM Consultation Team<br />
Department of Health <br />
Room 2 N09 <br />
Quarry House <br />
Quarry Hill <br />
Leeds LS2 7UE<br />
<br />
When you write your letter I suggest that you put the phrase ‘cc Constituency MP’, and then send a copy to your own MP, at the same time as you send your response to the Department of Health. Your can find your MP by <a href="http://findyourmp.parliament.uk/" target="new">clicking here</a> or, if you wish to do so you can contact the National Institute of Medical Herbalists on 01392 426022 and they will help you to find this information. <br />
<br />
I know you have many calls on your time but if we want to protect the right for ourselves and our families to access herbal medicine treatment then we must act – I know that us herbalists can’t do this on our own – <a href="http://actnow.napiers.net/2009/10/what-can-you-do-to-help.html">we need you to speak for us</a>.<br />
<br />
Thank you so much.<br />
<br />
<img alt="" border="0" src="http://lh5.ggpht.com/_SPLZQd9Tl7U/SrzX-n-CnkI/AAAAAAAAAbk/nqmAgD7H_eM/DeeSigWeb.jpg" style="float: left; height: 63px; margin: 0pt 10px 10px 0pt; width: 114px;" /><br />
<br />
<br />
<br />
<br />
Dee Atkinson, MNIMH, MCCP<br />
Medical Herbalist<br />
Managing DirectorUnknownnoreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-11412332110328690682009-10-06T22:20:00.006+01:002009-10-07T12:23:16.085+01:00The Current Situation on Herbal MedicineYou may or may not have been aware that there are some big changes to the way that herbal medicine is regulated during the past few years. This affects your ability to buy herbal remedies. Please take a moment to read this and please do take action if you would like to have access to herbal medicine in the future.<br />
<br />
<span style="font-weight: bold;">A NEW E.U. DIRECTIVE (THMPD) LIMITS HERBAL REMEDIES</span><br />
In 2005 a new E.U. law was passed called The Herbal Medicinal Products Directive. The United Kingdom agreed to comply with it and we are currently in a transitional phase. The result of the law is that after April 2011, no unlicensed herbal medicines can be sold over the counter. This means that the majority of herbal products will disappear from the market as it is too costly and complex for most companies to comply. So far, only about 39 products across the entire U.K. have got a new THR licence. You can get up to date information on this from the <a href="http://www.mhra.gov.uk/Publications/PublicAssessmentReports/PublicAssessmentReportsforherbalmedicines/index.htm" target="new">MHRA website</a>.<br />
<br />
<span style="font-weight: bold;">HERBAL PRESCRIPTIONS</span><br />
Alongside this new THMPD law mentioned above, the intention was that herbalists would be regulated, so that they could still purchase the herbal tinctures and blends (known as "specials") that they use to create your unique prescription. Without regulation herbalists will not be able to buy any unlicensed herbal tinctures or blends, while today a herbalist may stock their dispensary with around 300 different herbal tinctures.<br />
<br />
<span style="font-weight: bold;">REGULATION OF HERBALISTS</span><br />
You might be surprised to know that currently anyone can call themselves a herbalist and trade as such. Reputable companies such as Napiers the Herbalists only employ fully qualified herbal medicines practitioners, who are also members of governing bodies such as NIMH (the National Institute of Medical Herbalists) and CCP (the College of Phytotherapy Practitioners). However, some people without qualifications, and often without fluent English, can and do practice as herbalists. This can lead to the misuse of herbs - such as contraindications with prescription drugs - that qualified herbalists are trained to avoid.<br />
<br />
<span style="font-weight: bold;">GOVERNMENT CONSULTATION</span><br />
The Department of Health is running a Consultation to find out whether people think that medical herbalists should be regulated, or not. This will have important consequences and will determine the level of your and your family's access to herbal medicine in the future!<br />
<br />
<b>WHAT DOES THIS MEAN TO YOU?</b><br />
After April 2011 you will only be able to buy licensed herbal remedies (currently only 39 have THRs but hopefully there will more more over the next year). So any other herbal preparations you need can only be got from a herbalist. However, the herbalist will only be able to supply you if they are regulated, unless they make their own homemade tinctures - currently most are made in accredited factories with proper Quality and Batch Control procedures. So post-2011, in order for you to have the most choice in herbal medicine, it is important that herbalists are regulated. <a href="http://actnow.napiers.net/2009/10/why-vote-yes.html">Click here for more reasons.</a><br />
<br />
<span style="font-weight: bold;">If all herbalists have to be regulated</span> they will:<br />
<ul><li>p<span lang="EN-US" style="font-family: "Times New Roman"; font-size: 12pt;">rofessional practitioners with an agreed level of training - a Degree in Herbal Medicine </span>(like all those at Napiers)</li>
<li>r<span lang="EN-US" style="font-family: "Times New Roman"; font-size: 12pt;">egulated by a professional body and undergo</span> Continuous Professional Development<br />
</li>
<li>adher to a code of ethics and be insured to practice<br />
</li>
<li>be more accessible to G.P.s and other healthcare practitioners</li>
<li>have access to a wide range of herbal medicines (of controlled quality)</li>
</ul><span style="font-weight: bold;">If herbalists are NOT regulated as is the case now</span>:<br />
<ul><li>anyone will be allowed to practice and call themselves a medical herbalist - even if they are not qualified!</li>
<li>have widely varying standards of professionalism and qualifications<br />
</li>
<li>have little ability to hold dialogue with G.P.s or other healthcare practitioners</li>
<li>not be able to supply a full range of herbal medicines to patients <br />
</li>
</ul><div style="color: red;"><b>PLEASE ACT NOW</b><br />
</div>The consultation closes on 30 October this year. Please do one of or all of the following:<br />
<ul><li>Write to your M.P. in your own words or download a template of <a href="http://actnow.napiers.net/2009/10/write-to-your-mp-about-herbal-medicine.html">Draft 1</a> on the left.</li>
<li>Copy this to your M.E.P. or M.S.P.</li>
<li>You can find your M.P.'s address by <a href="http://findyourmp.parliament.uk/" target="new">clicking here</a></li>
<li>Fill in the Consultation Paper (<a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">download here</a>) or</li>
<li>Write to the Consultation Team in your own words or using <a href="http://actnow.napiers.net/2009/10/simple-response-to-to-herbal-medicine.html">Draft 2</a> or <a href="http://actnow.napiers.net/2009/10/response-to-consultation-on-herbal.html">Draft 3</a> on the left to request they register your opinion</li>
</ul><span style="font-weight: bold;">THANK YOU</span><br />
This is so important. People have used herbal medicines for at least 25,000 years and we want to retain our right of choice to do so in the future. Only by acting now can we influence the Government's decision.Unknownnoreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-61333888676698409312009-10-06T22:15:00.005+01:002009-10-07T12:30:55.247+01:00Why vote yes?After April 2011 under the new E.U. Directive <a href="http://actnow.napiers.net/2009/10/status-of-herbal-medicine-practitioners.html">THMPD</a> you will only be able to buy <i>licensed</i> herbal remedies. Currently only 39 products have THRs but hopefully there will more more over the next year. So for any other herbal preparations you need, you can only get them from a herbalist following a consultation.<br />
<br />
Currently, herbalists have access to a wide range of herbal medicines and are able to custom blend prescriptions for you. In some situations herbalist such as Napiers have some very traditional blends such as our Skullcap Oat and Passionflower Compound, that has been made since 1860. <br />
<br />
If herbalists are regulated they will be able to continue to supply their patients with a range of herbal remedies and will be able to supply traditional blends such as Napiers Skullcap Oat and Passionflower Compound. A regulated situation will support public safety and preserve access to herbal remedies.<br />
<br />
Unregulated herbalists may be untrained or unqualified. This might lead to a huge discrepancy in the experience the patient has and it might even lead to the wrong diagnosis or the wrong treatment plan. Unregulated herbalists will be unable to use traditional blends and the public will lose access to a huge number of herbal remedies. There is a big issue here of public safety. <br />
<br />
So post-2011, in order for you to have the most choice in herbal medicine, it is important that herbalists are regulated. This way you will have access to both over-the-counter <i>licensed</i> herbal remedies and to a wide range of prescription herbs. And, you will also know your practitioner is properly trained, up-to-date and operating to a strict code of ethics. It is important to remember that herbalists themselves want to be regulated.<br />
<br />
Please take the trouble to <b><span style="color: #cc0000;">ACT NOW</span></b> and help preserve the widest choice for us all.Napiers the Herbalistshttp://www.blogger.com/profile/00720682833256172455noreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-20698583823698427232009-10-06T22:10:00.003+01:002009-10-07T15:55:23.893+01:00Sample response to the questions in the DoH's Consultation Document<b>Question 1: </b><b>What evidence is there of harm to the public currently as a result of the activities of acupuncturists, herbalists and traditional Chinese medical practitioners? What is its likelihood and severity? </b><br />
<br />
While I only visit fully trained and qualified practitioners, I know there are unscrupulous practitioners in other practices who do not know enough, or care about what they prescribe, or where the herbs they use are sourced and made. These individuals are a potential danger to the public and cases have been documented showing the potential health risks that these people could cause.<br />
<br />
However, herbal medicine is actively sought as a preferred medical treatment by millions of people each year. The potential for harm comes from people not being able to access a register of statutorily regulated herbalists. Regulated herbalists would be known to be safely and competently trained, undertake continuous professional development, and have a properly operating complaints and disciplinary process, along with a Code of Ethics.<br />
<br />
<b>Question 2: Would this harm be lessened by statutory regulation? If so, how? </b><br />
<br />
I wish to be able to be sure about the herbal practitioner I choose to use and a statutory register would enable me to make safe choices about my health treatments. It would reduce the risk of danger from an incompetent practitioner. It would allow all members of my health care team, including my GP/Consultant and Medical Herbalist, to communicate freely to the overall benefit of patient safety and well being.<br />
<br />
<b>Question 3: What do you envisage would be the benefits to the public, to practitioners, and to businesses, associated with introducing statutory regulation? </b><br />
<br />
The public could be sure that mechanisms exist to train and monitor the practitioner they choose. Patients could be sure the practitioner they visit is appropriately qualified.<br />
<br />
Practitioners would be working more closely with their peers in the healthcare professions which would make for better practice and understanding of healthcare needs thus promoting patient welfare. Working in a collaborative way would also improve other professions' understanding of the practice of herbal medicine.<br />
<br />
Business would have a safe secure and guaranteed market for their products safeguarding jobs (many of which are in rural communities which often have high unemployment rates). Business would therefore be encouraged to invest in research and better equipment.<br />
<br />
<b>Question 4: What do you envisage would be the regulatory burden and financial costs, to the public, to practitioners, and to businesses, associated with introducing statutory regulation? Are these costs justified by the benefits and are they proportionate to the risks? If so, in what way? </b><br />
<br />
The Government has already significantly increased the costs associated with regulation by holding this Consultation. Over ten years of costs and expenses associated with various reports and other consultations has been a huge investment of money and time on the part of the civil service and the professions themselves.<br />
<br />
The recommended Regulating Body, the Health Professions Council (HPC) has already been set up and has expressed their agreement to take on this responsibility for medical herbalists. Therefore the small further cost of introducing the relevant legislation seems to be perfectly justified.<br />
<br />
The huge potential benefits in terms of business profitability and safeguarding of jobs is also another justification for regulation.<br />
<br />
Another issue to be considered is the huge potential SAVINGS on the nation's drug bill that could be made, if doctors were able to refer patients with long term chronic ailments which currently have restricted treatment options (such as arthritis or irritable bowel syndrome), to a medical herbalist. These patients use up huge amounts of NHS time and money and many of these patients can usefully be supported by herbal medicine which is many cases is a much cheaper option.<br />
<br />
<b>Question 5: If herbal and TCM practitioners are subject to statutory regulation, should the right to prepare and commission unlicensed herbal medicines be restricted to statutorily regulated practitioners? </b><br />
<br />
Yes. Absolutely. The preparation of herbal medicines requires training and proper procedures that are part of the professional training of a medical herbalist or a GMP registered manufacturing facility.<br />
<br />
<b>Question 6: If herbal and TCM practitioners are not statutorily regulated, how (if at all) should unlicensed herbal medicines prepared or commissioned by these practitioners be regulated? </b><br />
<br />
How can the Government adequately cope with this risk without regulating herbal practitioners? It is likely that without statutory regulation, protecting the supply of such medicines to properly trained professionals, that more members of the public will access them from questionable sources over the internet or in shopping malls and market stalls, thus increasing the risk of supply of harmful herbal preparations to the public.<br />
<br />
<b>Question 7: What would be the effect on the public, practitioners and businesses if, in order to comply with the requirements of European medicines legislation, practitioners were unable to supply manufactured unlicensed herbal medicines commissioned from a third party, after 2011? </b><br />
<br />
This would restrict public choice and potentially put practitioners and businesses out of business. Rather than buying preparations from GMP licensed or accredited manufacturers, herbalists would be making their own remedies and have a far greater burden in analysis of raw material, manufacture, quality control, testing and record keeping. This takes time away from seeing patients in the clinics. <br />
<br />
<b>Question 8: How might the risk of harm to the public be reduced other than by statutory professional self-regulation? For example, by voluntary self-regulation underpinned by consumer protection legislation and by greater public awareness, by accreditation of voluntary registration bodies, or by a statutory or voluntary licensing regime? </b><br />
<br />
Statutory regulation is the only satisfactory way to deal with all the issues. Voluntary regulation would still not prevent unscrupulous, incompetent practitioners from posing a danger to the public. Herbal preparations should also only be made by registered herbalists and accredited manufacturers.<br />
<br />
<b>Question 9: What would you estimate would be the regulatory burden and financial costs, to the public, to practitioners, and to businesses, for the alternatives to statutory regulation suggested at Question 8? </b><br />
<br />
Statutory regulation is the most cost effective alternative. The cost for the other alternatives would be born by the general public in terms of; not being able to get guaranteed access to safe competent practitioners, nor to herbal medicines which have been produced to high quality standards.<br />
<br />
<b>Question 10: What would you envisage would be the benefits to the public, to practitioners, and to businesses, for the alternatives to statutory regulation outlined at Question 8? </b><br />
<br />
None<br />
<br />
<b>Question 11: If you feel that not all three practitioner groups justify statutory regulation, which group(s) does/do not and please give your reasons why/why not? </b><br />
<br />
All three groups should be regulated. This is the Government's stated policy and the public deserves that their healthcare is treated with the proper respect and professionalism.<br />
<b><br />
</b><br />
<b>Question 12: Would it be helpful to the public for these practitioners to be regulated in a way which differentiates them from the regulatory regime for mainstream professions publicly perceived as having an evidence base of clinical effectiveness? If so, why? If not, why not? </b><br />
<br />
No. Medical herbalists do have an evidence base of clinical effectiveness. Many pharmaceutical drugs are based on plants both historically and also in new research into cures for a wide range of illnesses from malaria to breast cancer. Many herbs have been studied in clinical trials and are the subject of research papers documenting their clinical effectiveness. Although the body of work is smaller than many better-funded pharmeceuticals, nevertheless it is significant.<br />
<br />
Herbal medicine has a well-documented history. Many of the companies who started in the 1800's, have well documented letters from patients and reports from practitioners recording clinical results, for over 100-150 years.<br />
<br />
The public also demonstrably understands as evidence, the millions of people who use such therapies on an annual basis. It is unethical to apply different standards of proof to one or other medical profession. Much of mainstream medicine does not have clear ‘proof’ of effectiveness but there is no presumption that such should not be used. A clinician must be free to use judgment in these matters and assess effectiveness by what the patient reports.<br />
<br />
Additionally, statutory regulation would enable herbalists to access research facilities, patient groups and funding which would greatly aid the health care community in understanding how much the practice of herbal medicine does work.<br />
<br />
<b>Question 13: Given the Government’s commitment to reducing the overall burden of unnecessary statutory regulation, can you suggest which areas of healthcare practice present sufficiently low risk so that they could be regulated in a different, less burdensome way or de-regulated, if a decision is made to statutorily regulate acupuncturists, herbalists and traditional Chinese medicine practitioners? </b><br />
<br />
I understand the Government must be prudent in expenditure at this time. However, the health of the nation has been identified as an area which should be protected. The minimal cost to complete this statutory regulation should not pose a massive burden especially as all the work has now been completed and the regulatory body has already been established. Failure to see this project through to completion would be a dereliction of duty and the Government could be called to task for wasting tax payer’s money and failing to deliver the promised service.<br />
<br />
<b>Question 14: If there were to be statutory regulation, should the Health Professions Council (HPC) regulate all three professions? If not, which one(s) should the HPC not regulate?</b><br />
<br />
The Health Professions Council should regulate all three professions.<br />
<br />
<b>Question 15: If there were to be statutory regulation, should the Health Professions Council or the General Pharmaceutical Council/ Pharmaceutical Society of Northern Ireland regulate herbal medicine and traditional Chinese medicine practitioners? </b><br />
<br />
The Health Professions Council should be the statutory regulator.<br />
<br />
<b>Question 16: If neither, who should and why? </b><br />
<br />
The Health Professions Council should be the statutory regulator.<br />
<br />
<b>Question 17:</b><br />
<b>a) Should acupuncture be subject to a different form of regulation from that for herbalism and traditional Chinese medicine? If so, what? </b><br />
<br />
No, the Health Professions Council should be the statutory regulator for acupuncture too.<br />
<br />
<b>b) Can acupuncture be adequately regulated through local means, for example through Health and Safety legislation, Trading Standards legislation and Local Authority licensing? </b><br />
<br />
No. These bodies do not have the necessary expertise.<br />
<br />
<b>Question 18: Should the titles "acupuncturist", "herbalist" and "[traditional] chinese medicine practitioner" be protected?</b><br />
<br />
Yes, the titles should be protected and only used by qualified, registered practitioners.<br />
<br />
<b>Question 19: Should a new model of regulation be tested where it is the functions of acupuncture, herbal medicine and TCM that are protected, rather than the titles of acupuncturist, herbalist or Chinese medicine practitioner? </b><br />
<br />
No. Both the functions and titles should be regulated as discussed and planned.<br />
<br />
<b>Question 20: If statutory professional self-regulation is progressed, with a model of protection of title, do you agree with the proposals for "grandparenting" set out in the Pittilo report? </b><br />
<br />
Yes<br />
<br />
<b>Question 21: In the event of a decision that statutory or voluntary regulation is needed, do you agree that all practitioners should be able to achieve an English language IELTS score of 6.5 or above in order to register in the UK? </b><br />
<br />
Yes. It is vital for the proper care of patients that their practitioners can speak good English and can communicate properly with them to achieve a correct diagnosis and treatment plan.<br />
<br />
<b>Question 22: Could practitioners demonstrate compliance with regulatory requirements and communicate effectively with regulators, the public and other healthcare professionals if they do not achieve the standard of English language competence normally required for UK registration? What additional costs would occur for both practitioners and regulatory authorities in this case? </b><br />
<br />
No, practitioners cannot demonstrate compliance without a competency in the English language. The costs of learning English to the level required should be born by the individual (and/or professional body) to bring practitioners up to the required standards and not by the Government nor tax payer.<br />
<br />
<b>Question 23: What would the impact be on the public, practitioners and businesses (financial and regulatory burden) if practitioners unable to achieve an English language IELTS score of 6.5 or above are unable to register in the UK? </b><br />
<br />
Transition arrangements could be made for such individuals already practising in this country, where they can demonstrate that they are not endangering patients through their inability to fully communicate. No new practitioners should enter the country to practice or be regulated without this English proficiency.<br />
<br />
<b>Question 24: Are there any other matters you wish to draw to our attention?</b><br />
<br />
The Government has promised timetables for statutory regulation and failed to deliver on more than one occasion in the past. If it fails to deliver statutory regulation to this sector, combined with the impact of the Traditional Herbal Medicines Product Directive where hundreds of herbal remedies will be lost, the public, which makes great use of herbal medicine, will notice the loss of businesses, remedies, jobs and health care options. The loss of a traditional therapy with roots going back hundreds of years in the UK, and thousands of years worldwide is not to be countenanced.<br />
<br />
The general public who use herbal medicine are generally well-informed and are making concious and deliberate health choices. It is no coincidence that the number of people buying OTC herbal remedies has grown consistently every year since 2002 by an average of 9% per year (Mintel 2007). To restrict their access to trained herbalists and properly manufactured preparations will drive many to self-diagnose and purchase on the internet from unverified and possibly unreliable sources, with potentially fatal consequences.Napiers the Herbalistshttp://www.blogger.com/profile/00720682833256172455noreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-32347836630821324372009-10-06T22:00:00.000+01:002009-10-06T23:59:05.828+01:00Sample Letter 1: A letter to your MP, MSP or MEP about the Consultation<div style="text-align: right;">[Your Address: Insert as appropriate ]<br />
</div><br />
[<a href="http://findyourmp.parliament.uk/" target="new">MP’s Name : Insert as appropriate</a>]<br />
House of Commons,<br />
London<br />
SW1A 0AA<br />
<br />
[Date : Insert as appropriate]<br />
<br />
<br />
Dear [MP’s Name : Insert as appropriate]<br />
<br />
I am writing to you to express my concern about the current Department of Health joint consultation on the Report to Ministers from the DH Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and other Traditional Medicine Systems practised in the UK <a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">www.dh.gov.uk/en/consultations/liveconsultations/DH_103567</a><br />
<br />
I wish to preserve the right to access a full range of herbal medicines from a professional herbalist who is statutorily registered.<br />
<br />
It is now a matter of the utmost urgency that the Government bring forward legislation leading to the statutory regulation of herbalists.<br />
<br />
I trust that you will raise this matter on my behalf with the Department of Health.<br />
<br />
[Include following or delete as applicable:] I am also enclosing a copy of my response to the Consultation for your information.<br />
<br />
Yours faithfully,<br />
<br />
<br />
[Signature]Unknownnoreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-45556402170634063042009-10-06T21:55:00.001+01:002009-10-07T00:52:22.750+01:00Sample Letter 2: A simple, personal response to the Consultation Team on the Consultation Paper<div style="text-align: right;">[Your Address : Insert as appropriate ]<br />
</div>AHMTCM Consultation Team<br />
Department of Health<br />
Room 2 N0.9<br />
Quarry House<br />
Quarry Hill<br />
Leeds LS2 7UE <br />
<br />
[Date: Insert as appropriate ]<br />
<br />
<br />
Dear Sir<br />
<br />
Response to : Joint UK-wide consultation on the Report to Ministers from the DH steering Group on the Statutory Regulation of Practitioners of Herbal Medicine, Traditional Chinese Medicine and other Traditional Medicine Systems practised in the UK <a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567</a><br />
<br />
I find the Consultation Document itself to be too lengthy and complex to follow easily. I would therefore like to make my response to this Consultation as follows:<br />
<br />
As a frequent user of herbal medicine, I wish to see improved quality and safety of herbal medicines which I believe can best be done through the protection of the practice of professional medical herbalists.<br />
<br />
I wish to safeguard the right of myself and my family to have the choice of using professional herbal medicine if we wish to do so and would be strongly against any moves which threatened this right. Indeed I wish to see herbal medicine properly integrated into the health care arena making it possible for my GP/Consultant/Medical Herbalist to be able communicate and share professional responsibility for my health care.<br />
<br />
I understand that the Government's own House of Lords report started the process of regulation of herbal medicine in 2000. The Steering Group reported in June 2008 with clear direction as to how and why herbalists should be regulated. I am in agreement with these documents.<br />
<br />
It seems to me that all due care and process has been taken - it is now time for the Government to enact the legislation which would allow herbalists to be statutorily regulated.<br />
<br />
Yours faithfully,<br />
<br />
<br />
[Signature]Unknownnoreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-64042188889173493202009-10-06T21:52:00.003+01:002009-10-07T00:52:47.983+01:00Sample Letter 3: Professional response letter to the Consultation Team on the Consulation Report<div style="text-align: right;">[Your Address : Insert as appropriate ]<br />
</div>AHMTCM Consultation Team<br />
Department of Health<br />
Room 2 N0.9<br />
Quarry House<br />
Quarry Hill<br />
Leeds LS2 7UE <br />
<br />
[Date: Insert as appropriate ]<br />
<br />
<br />
Dear Sir<br />
<br />
Response to : Joint UK-wide consultation on the Report to Ministers from the DH steering Group on the Statutory Regulation of Practitioners of Herbal Medicine, Traditional Chinese Medicine and other Traditional Medicine Systems practised in the UK <a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567</a><br />
<br />
As a busy person I would find it impossible to read and absorb all the information in the referenced documents for this Consultation in full. I am apparently expected to be able to understand the following:<br />
<ol><li>DH. Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century </li>
<li>Extending professional and occupational regulation: the report of the Working Group on Extending Professional Regulation : Department of Health</li>
<li>Report to Ministers from The Department of Health Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK May 2008</li>
<li>Section 12(1) of the Medicines Act and other Medicines Legislation including European medicines legislation Art 5.1 of 2001/83/EC</li>
<li>“A consultation on the framework for registration of health and adult social care providers”, published 25 March 2008. </li>
<li>Legislation on Health and Safety/Trading Standards/Advertising Legislation</li>
<li>Local Authority Registration and Licensing</li>
<li>Statutory Licensing Schemes</li>
</ol>I have read, and am in agreement with, the responses provided by both the National Institute of Medical Herbalists and The European Herbal and Traditional Practitioners Association, and would like my response to be registered as in favour of statutory regulation for medical herbalists.<br />
<br />
Yours faithfully,<br />
<br />
<br />
[Signature]Unknownnoreply@blogger.comtag:blogger.com,1999:blog-8649658394157330902.post-872034953081754152009-10-06T20:00:00.001+01:002009-11-09T22:41:30.319+00:00What can you do to help?<div style="color: red;"><span style="font-size: large;"><b>PLEASE ACT NOW</b></span><br />
</div>The consultation closes on <b>16 November</b> this year. Please do one of or all of the following:<br />
<br />
<b>Write to your Member of Parliament</b><br />
<ul><li>Write to your M.P. in your own words or use our template <a href="http://actnow.napiers.net/2009/10/write-to-your-mp-about-herbal-medicine.html">Sample MP Letter 1</a>. You can also <a href="http://www.napiers.net/download/SampleLetter1.doc">download this template</a> as a Word document. <br />
</li>
<li>Copy this to your M.E.P. or M.S.P.</li>
<li>You can find your M.P.'s address <a href="http://findyourmp.parliament.uk/" target="new">here</a></li>
</ul><b>Write to the Department of Health </b><br />
<ul><li>Write to the DoH Consultation Team, in your own words or using <a href="http://actnow.napiers.net/2009/10/simple-response-to-to-herbal-medicine.html">Sample DH Letter 2</a> which sets out a simple, personal response. You can also <a href="http://www.napiers.net/download/SampleLetter2.doc">download this template</a> as a Word document. </li>
<li>Or write a more professional response using <a href="http://actnow.napiers.net/2009/10/response-to-consultation-on-herbal.html">Sample DH Letter 3</a>, to request they register your opinion. You can also <a href="http://www.napiers.net/download/SampleLetter3.doc">download this template</a> as a Word document. </li>
<li>Fill in the Department of Health's Consultation Paper (<a href="http://www.dh.gov.uk/en/Consultations/Liveconsultations/DH_103567" target="new">download here</a>)if you have time. You can also look at <a href="http://actnow.napiers.net/2009/10/consultation-questions-and-sample.html">Napiers response</a> if you wish.</li>
</ul><b>Ask all your friends, family and colleagues</b><br />
<ul><li>To visit our site at ActNow.Napiers.net</li>
<li>To write to their M.P. and the DoH too</li>
<li>To pass on the word to others</li>
<li>To actively lobby to preserve the choice of herbal medicines for the future.<br />
</li>
</ul>Napiers the Herbalistshttp://www.blogger.com/profile/00720682833256172455noreply@blogger.com