Guest guest Posted March 3, 2011 Report Share Posted March 3, 2011 Is everybody here either outright against SR or sufficiently on the fence to not have anything to say on the matter? Are there no herbalists on this list who are for SR? Speak up, speak up. I wish for a lively debate. I wish for things to get aired NOW, so that the end result, whatever it turns out to be in the end, will be as good as it can possibly be. Thanks, Henriette -- Henriette Kress, AHG Helsinki, Finland Henriette's herbal homepage: http://www.henriettesherbal.com Uusi kirja: http://www.henriettesherbal.com/fi/kayt-laak.html Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 3, 2011 Report Share Posted March 3, 2011 Blimey that's really bad. It doesn't seem as if was selling it either. Forget the revolution! I'm sure the tractors will be out soon spreading said compost far and wide. Lorraine Lorraine Hodgkinson MNIMH MRCHM HERBS AND HELPERS 6, Butts Fold, Cockermouth, Cumbria, CA13 9HY. UK. Tel: +44 (0) 1900 826392 Mobile: 07761 489838 (O2) www.herbalmedicineuk.com > See article > <http://www.timesonline.co.uk/tol/news/world/europe/article640511.ece>about > Les Amis de l'Ortie (Friends of the Nettle) and EU shenanigans about > regulation > > Regards > > Gascoigne > > > > > > Yes we must never let the right to make be lost. Although I do agree > > that there will have to be minimal standards to which this is done. I > > have concerns that there could be a move to only let manufacture be > > done under GMP which I'm sure would suit a lot of people but we must > > never let thus happen. The function of a Herbalist includes this > > right, it is our culture and we have a safe time honoured tradition to > > back us up. > > > > The Portillo report seems to suggest to me that such things will be > > preserved. As for using herbs for personal use how can this not > > continue? Each person can choose to take stuff from their own garden > > for their own use. Unless Afghanistan style fire bombing is coming to > > eliminate 'illegal' supplies!??!! > > > > Lorraine > > > > Lorraine Hodgkinson MNIMH MRCHM > > HERBS AND HELPERS > > 6, Butts Fold, Cockermouth, > > Cumbria, CA13 9HY. UK. > > Tel: +44 (0) 1900 826392 > > Mobile: 07761 489838 (O2) > > www.herbalmedicineuk.com > > > > On 3 Mar 2011, at 22:08, Sally Owen <sally@... > > <mailto:sally%40thrc.org.uk>> wrote: > > > > > Hi Jaqui > > > > > > about 6(?) years ago, Woodfield of the MHRA attended > > > conference, and I pressed him on this point, which I considerer > > > absolutely central to our practice (Due to the risk of small suppliers > > > being discouraged by BMP regulation) He explicitly assured me that > > > they supported our rights in this area. And, as I said to Lorraine, > > > the following year there were workshops for those who had not > > > previously attempted medicine making. > > > > > > Sally Owen > > > > > > > > I refer to harvesting the herb, macerating in the alcohol and > > > > pressing out, making our own syrups, creams etc and not just mixing > > > > tinctures bought from a supplier > > > > Jacqui > > > > > > > > > > > >>> > > > >>>> Seems like it's business as usual around here, does no one else > > > >>>> find the > > > >>>> silence around SR deafening? > > > >>> > > > >>> I'm not (yet) affected here in Finland, and I don't know that I will > > > >>> ever be. > > > >>> That being said: > > > >>> > > > >>>> > > > >>> > > www.homeopathyheals.me.uk/site/latest-news/573-state-regulation-for-practitioner\ s-of-herbal-medicine > > > >>> > > > >>> comes across as a paranoiac. She also calls herself " Dr " > > > >>> with no > > > >>> credentials whatsoever. > > > >>> Also, as far as I know, McI was pushing for UK regulation of > > > >>> herbalists LONG before anybody was talking about EU regulation of > > > >>> herbs. The > > > >>> two are not related, and continuing to say they are is muddled > > > >>> thinking. > > > >>> > > > >>> That article is crap. > > > >>> > > > >>> My own take on the imminent regulation of UK herbalists: > > > >>> > > > >>> * doctors still believe that herbs are balderdash > > > >>> * doctors still think that herbs must be dangerous if they work > > > >>> (digitalis is > > > >>> pulled out of the cupboard regularly as a demonstration of this) > > > >>> * doctors are _heavily_ influenced by pharmaceutical companies. Not > > > >>> perhaps by > > > >>> direct bribery (although that, too, happens), but mostly by trusting > > > >>> mainstream medical journals. The " unbiased " " scientific " research > > > >>> there is > > > >>> bought and sold by the pint by pharmacogiants. > > > >>> * herbs are cheap, can't be patented, and are as good or better for > > > >>> quite a > > > >>> lot of chronic diseases than mainstream medicines. Oops, there > > > >>> goes the > > > >>> profit. > > > >>> * who is influencing your HMC, which, if I understood things > > > >>> right, is > > > >>> about > > > >>> to regulate you? Doctors and pharmaceutical companies. > > > >>> > > > >>> And you are going to let that lot tell you what you can and cannot > > > >>> practice? > > > >>> Uh. Oh. > > > >>> > > > >>> Next, where are your _guarantees_ that you will have access to > > > >>> otherwise > > > >>> restricted herbs, once you're regulated? That should be clearly > > > >>> spelled out > > > >>> in laws that can't be changed at the drop of a hat. > > > >>> You should also do your very best to protect your 1968 herbalist > > > >>> laws. > > > >>> > > > >>> I do hope SR won't come back to bite you lot in the arse, very hard. > > > >>> > > > >>> H. > > > >>> > > > >>> -- > > > >>> Henriette Kress, AHG Helsinki, Finland > > > >>> Henriette's herbal homepage: http://www.henriettesherbal.com > > > >>> Uusi kirja: http://www.henriettesherbal.com/fi/kayt-laak.html > > > >>> > > > >>> > > > >> > > > >> > > > >> > > > >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 4, 2011 Report Share Posted March 4, 2011 Hi Sally, The MHRA also initially judged the manufacture of tinctures as a non-commercial activity. Subsequent to this, Woodfield of the MHRA ‘....switched its interpretation position to regard typical manufactured herbal medicines as being industrially produced. Whether a product is supplied for retail or for supply via practitioners does not affect whether it is viewed as industrially produced.’ So I feel it is a profound mistake to believe any such reassurances. Organisations of the State can, and frequently do, radically alter their interpretations and stances to suit their own purposes, regardless of any so called cast iron reassurances previously given. I think the future does not look particularly rosy for those who make their own medicines. SR is not precipitating this threat, but I think that it will certainly speed the process. Best regards, Tim. From: Sally Owen Sent: Thursday, March 03, 2011 10:08 PM To: ukherbal-list Subject: Re: Re: Regulation Hi Jaqui about 6(?) years ago, Woodfield of the MHRA attended conference, and I pressed him on this point, which I considerer absolutely central to our practice (Due to the risk of small suppliers being discouraged by BMP regulation) He explicitly assured me that they supported our rights in this area. And, as I said to Lorraine, the following year there were workshops for those who had not previously attempted medicine making. Sally Owen > > I refer to harvesting the herb, macerating in the alcohol and > pressing out, making our own syrups, creams etc and not just mixing > tinctures bought from a supplier > Jacqui > > >>> >>>> Seems like it's business as usual around here, does no one else >>>> find the >>>> silence around SR deafening? >>> >>> I'm not (yet) affected here in Finland, and I don't know that I will >>> ever be. >>> That being said: >>> >>>> >>> www.homeopathyheals.me.uk/site/latest-news/573-state-regulation-for-practitioner\ s-of-herbal-medicine >>> >>> comes across as a paranoiac. She also calls herself " Dr " >>> with no >>> credentials whatsoever. >>> Also, as far as I know, McI was pushing for UK regulation of >>> herbalists LONG before anybody was talking about EU regulation of >>> herbs. The >>> two are not related, and continuing to say they are is muddled >>> thinking. >>> >>> That article is crap. >>> >>> My own take on the imminent regulation of UK herbalists: >>> >>> * doctors still believe that herbs are balderdash >>> * doctors still think that herbs must be dangerous if they work >>> (digitalis is >>> pulled out of the cupboard regularly as a demonstration of this) >>> * doctors are _heavily_ influenced by pharmaceutical companies. Not >>> perhaps by >>> direct bribery (although that, too, happens), but mostly by trusting >>> mainstream medical journals. The " unbiased " " scientific " research >>> there is >>> bought and sold by the pint by pharmacogiants. >>> * herbs are cheap, can't be patented, and are as good or better for >>> quite a >>> lot of chronic diseases than mainstream medicines. Oops, there >>> goes the >>> profit. >>> * who is influencing your HMC, which, if I understood things >>> right, is >>> about >>> to regulate you? Doctors and pharmaceutical companies. >>> >>> And you are going to let that lot tell you what you can and cannot >>> practice? >>> Uh. Oh. >>> >>> Next, where are your _guarantees_ that you will have access to >>> otherwise >>> restricted herbs, once you're regulated? That should be clearly >>> spelled out >>> in laws that can't be changed at the drop of a hat. >>> You should also do your very best to protect your 1968 herbalist >>> laws. >>> >>> I do hope SR won't come back to bite you lot in the arse, very hard. >>> >>> H. >>> >>> -- >>> Henriette Kress, AHG Helsinki, Finland >>> Henriette's herbal homepage: http://www.henriettesherbal.com >>> Uusi kirja: http://www.henriettesherbal.com/fi/kayt-laak.html >>> >>> >> >> >> >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 6, 2011 Report Share Posted March 6, 2011 Hi Maggie, > If we could FIND the grandmothers who still use herbal and traditional > remedies, I would like to spend a few days with them and suck up their > knowledge. But where are they? Teach in places where the great unwashed masses can find you. The state-sponsored community colleges are great for this, over here. People pay a pittance, and I get my usual hourly fee + travel costs. Have fun, H. -- Henriette Kress, AHG Helsinki, Finland Henriette's herbal homepage: http://www.henriettesherbal.com Uusi kirja: http://www.henriettesherbal.com/fi/kayt-laak.html Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 10, 2011 Report Share Posted March 10, 2011 Hello Marilena, I will always champion the right of Herbalists to make their own medicines for patients after one to one consultation. We must fight to the death and never lose this right. It would be wrong to ask such Herbalists to comply with full EU GMP and impossible for many. Also we have a long tradition of safe time honoured dispensing. SR must include minimal feasible standards for practitioners. This is not about products I sell. I will only be supplying herbal medicines to practitioners from 1st May as per section 12.1. Please note the word GMP means different things in different countries. In meetings with the MHRA they have said they only recognise EU GMP. The RCHM is not the UK regulator for medicines the MHRA is. If there is an incident you need to please the MHRA and courts not the RCHM. If a product has not been tested to a European standard then you have way of knowing if it meets a European standard. Please don't be fooled! Lorraine Lorraine Hodgkinson MNIMH MRCHM HERBS AND HELPERS 6, Butts Fold, Cockermouth, Cumbria, CA13 9HY. UK. Tel: +44 (0) 1900 826392 Mobile: 07761 489838 (O2) www.herbalmedicineuk.com > > Dear Lorraine, I think we need to make a difference between retail sale and practitioner sale. > Retail is to the general public, and has very stringent GMP requirements, because a Recall Procedure (in case of a mistake in preparation) needs to be put into place, which is difficult if selling to the general public. So stringent hygiene, identification, testing and traceability measures are required, to ensure that the product poses the minimum of risk and the maximum of traceability. > Practitioner sale is documented through case notes, with name, contact details and date of sale recorded. I f a mistake came through, for example through our suppliers, this would be traceable and the consumer can be adviced immediately to stop taking the medicine and take appropriate measures if needed. > At a two day workshop in 2004 given by MHRA on wholesale and manufacturing licensing, the MHRA officials confirmed that the sale through a practitioner on a one to one basis after personal consultation is not seen as retail. > Therefore, the manufacture by herbalists of medicines for their patients also needs less stringent GMP measures. > The RCHM is a practitioner organisation, not a retail organisation. > I am aware that you are selling your products quite widely, as you often promote them on this list, and therefore assume that you need really stringent EU GMP for your products, as you do not always have direct records of the consumer, if you are selling them on to other practitioners who then dispense them to their patients, which would probably be considered a retail activity. But a practitioner who gives them directly to their patients after having them made personally, from raw materials, can also ensure that Identification, Hygiene, Traceability and Contamination are according to standards. Anyone wishing to know what the MHRA guidelines are for herbal products for retail , should read the Orange Guide, available from WH (see MHRA website for real title), and adapt the requirements to their own situation. This would be advisable for anyone making their own remedies from raw materials (eg collecting herbs and making them into tinctures etc) for dispensing to their own patients. > So I think that there is no need to take down the RCHM scheme, just because it does not suit your needs, does not mean it is not good for others. > Kind regards, > Marilena. > > > > To: ukherbal-list > From: herbsandhelpers@... > Date: Thu, 10 Mar 2011 05:55:18 +0000 > Subject: Re: Re: Regulation > > > > > > > Hello , > I've remained outside this scheme for various reasons. Please don't be fooled though. The RCHM has no regulatory capacity over suppliers the MHRA is the regulator. All that's need to get into the ECHM scheme is for you to pay them to visit you. Please note the fact that any 'GMP' is accepted rather than what the MHRA sets down should ring alarm bells ... > > Please always ask questions of your suppliers I think you'll find that most rely in testing outside the EU. This is not acceptable to the MHRA who only recognise certified facilities. > > A lot of 'powders' may be borderline the standards that control what gets through should always meet EU levels. > > Best wishes, > > Lorraine > > Lorraine Hodgkinson MNIMH MRCHM > HERBS AND HELPERS > 6, Butts Fold, Cockermouth, > Cumbria, CA13 9HY. UK. > Tel: +44 (0) 1900 826392 > Mobile: 07761 489838 (O2) > www.herbalmedicineuk.com > > > >> Hi, >> >> Before everyone gets carried away and sounding like a branch meeting of >> UKIP debating 'foreigners' - the main point here is about herbal >> practice and herbal safety. >> >> The Register of Chinese Herbal Medicine developed a method of approving >> suppliers of Chinese herbs in 2004 so that practitioners and patients >> could be reassured about herbal quality. I personally have used Chinese >> herbal powders for getting on for 20 years with no problem and I am >> happy that they are what they claim to be and they are not contaminated. >> >> If you want to discuss other herbs, usually prepared and from mainland >> China, then please do not associate them, implicitly or explicitly, with >> the professional practice of Chinese herbal medicine. >> >> Regards >> >> Gascoigne >> >> >>> >>> On a different note, but also illegal- I was once with friends >>> hurrying through a chinese supermarket, buying tinned shitake, dried >>> whole roots to cook with at home, chillie sauce etc, and I bought a >>> tin of " herb jelly " without looking at it carefully. >>> When i got it home, I researched the ingredients on t'internet, and >>> found its main ingredient was endangered sea turtle, export of which >>> is prohibited under CITES. >>> >>> Even if we make our own tinctures, sometimes those pesky foreign herbs >>> are the ones that seem indicated. And I want to be able to rely on >>> them to be them - and not mixed with endangered turtle. >>> >>> just saying >>> >>> Sally Owen >>> >>> >>> >>>> Yes I'd agree, >>>> Once you start looking below the surface, asking >>>> a few questions then it can be quite scary. We with a Western mind >>>> set 'assume' things are okay for various reasons. However with TCM >>>> currently the only way to be sure is to have it tested in a European >>>> lab. You can then verify to European standards the facts about >>>> product, no argument. >>>> >>>> May sound scary but sometimes after European testing stuff has to be >>>> sent back! >>>> >>>> A European COA is the only way to be sure the stuff is what it's >>>> purported to be! >>>> >>>> Total traceability especially speed of response is also vital. It >>>> allows you to reassue clients, provide them with hard data if needed >>>> that you're doing it right and safeguarding their health. >>>> >>>> Lorraine >>>> >>>> Lorraine Hodgkinson MNIMH MRCHM >>>> HERBS AND HELPERS >>>> 6, Butts Fold, Cockermouth, >>>> Cumbria, CA13 9HY. UK. >>>> Tel: +44 (0) 1900 826392 >>>> Mobile: 07761 489838 (O2) >>>> www.herbalmedicineuk.com >>>> >>>> >>>> On 9 Mar 2011, at 10:45, " natlychid2000 " <natly@... >>> <mailto:natly%40chidley.org>> wrote: >>>> >>>>> Dear >>>>> I'm not basing my comments on hearsay, i've had personal direct >>>>> eyeball experience of TCM practitioner products in the last 4 weeks >>>>> that were exactly as i have described, and it wasn't a small >>>>> operation. >>>>> Apologies to those who are doing the right thing but you have to >>>>> admit that this has been, and continues to be, a real problem. >>>>> I'm not in favour of herbs being treated as standardised extracts, >>>>> tested as if they were pharmaceuticals, a small amount of traceable >>>>> paperwork is, however, necessary. Particularly in products where >>>>> you cannot use smell, touch taste to verify the contents. >>>>> >>>>> Looks like being another glorious day, wish i was in the garden! >>>>> Nathalie >>>>> >>>>> >>>>>>>>> >>>>>>>>>> >>>>>>>>> >>>>>>>>>> From: Therri Lahood <harkster@ >>>>>>>>> >>>>>>>>>> <mailto:harkster%40dsl.pipex.com>> >>>>>>>>> >>>>>>>>>> Subject: Re: Re: Regulation >>>>>>>>> >>>>>>>>>> To: ukherbal-list >>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>>> >>>>>>>>>> Date: Monday, 7 March, 2011, 19:07 >>>>>>>>> >>>>>>>>> > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 10, 2011 Report Share Posted March 10, 2011 Thank you for your apology, Lorraine. I am a fully qualified herbalist! And as such I have nothing to 'fear' from SR, i would be able to be registered/regulated should i wish. I do not wish to exchange my current right to practice for a privilege granted to me by a government which would then have the power to dictate what i may & may not do in my practice. It is as simple as that. I am not happy that those who wish to be regulated are in effect imposing this on me & that reforms to section 12 will in theory prevent me accessing my herbs, as i will not submit to regulation. There is no evidence that regulation protects the general public. None. It seems to me that herbalism in its vibrant diversity is being sacrificed for the illusion of more jobs, some publicity and greater status. I do not of course mean that everyone who wants to be regulated is a power & money hungry status seeker! Nathalie > > > I thought this was a peaceful and informative discussion > > > for all. No intention to irritate anyone. Can I ask how > > > I've offended you? > > > > You assumed that everybody wants to be regulated. That's not so. > > > > (I also think that grandmas are bona fide herbalists (the ultimate ones, so to > > speak); however, they'll never be eligible for registration ...) > > > > H. > > > > -- > > Henriette Kress, AHG Helsinki, Finland > > Henriette's herbal homepage: http://www.henriettesherbal.com > > Uusi kirja: http://www.henriettesherbal.com/fi/kayt-laak.html > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 10, 2011 Report Share Posted March 10, 2011 Hi Marilenna how would one gaijin not buying a small tin of herb jelly help these turtles? However I am reassured by Lorraine's information regarding this matter. Sally > > Hi Sally, with the power of consumer choice, use a strategy which > has been known to be effective: read the label, talk to the > shopkeeper, who may not be aware of the situation, and do not buy > the product. > Marilena. > > > To: ukherbal-list > From: herbsandhelpers@... > Date: Thu, 10 Mar 2011 09:49:25 +0000 > Subject: Re: Re: Regulation > > > > > > > Hello Tim, > I was just looking at the MHRA legislation regarding THMPD and they > have now tightened up the rules to say that any THMPD product coming > into the UK must be made in an EU GMP certified facility. Also you > will require an import license on such products. So it looks like > the idea is to try and stop 'rogue' products from entering the > country in the first place. There will of course always be the > suitcase importers claiming personal use. > > Lorraine > > Lorraine Hodgkinson MNIMH MRCHM > HERBS AND HELPERS > 6, Butts Fold, Cockermouth, > Cumbria, CA13 9HY. UK. > Tel: +44 (0) 1900 826392 > Mobile: 07761 489838 (O2) > www.herbalmedicineuk.com > > > >> Hello Sally, >> >> You must have been pretty gutted when you realised what you had >> purchased. But the incident you experienced illustrates that >> regardless of legislation, there will ALWAYS be those who can, and >> will, circumvent the most stringent legislation that is enacted. >> For instance, the likes of the noni juice salesman to whom >> referred, is likely to find more inventive ways to get round SR. >> >> The problem with adulteration of herbs with pharmaceuticals, >> contamination with bacteria, heavy metals etc. is that existing >> legislation covering such things has not been adequately enforced. >> So until that happens, the introduction of further layers of >> legislation seems to me not only to be futile, threatens the >> smaller scale producer (which gives the best possible community >> based situation for a herbalist to get to know and trust that >> producer) who I feel produces the best quality herbal medicines, >> and could engender the sense of false security. And There is an >> argument that the more complex the legislation, the more >> opportunity there is for less that honest producer to hide behind >> the complexity of that legislation. >> >> Best regards, >> Tim. >> >> From: Sally Owen >> Sent: Wednesday, March 09, 2011 5:03 PM >> To: ukherbal-list >> Subject: Re: Re: Regulation >> >> On a different note, but also illegal- I was once with friends >> hurrying through a chinese supermarket, buying tinned shitake, dried >> whole roots to cook with at home, chillie sauce etc, and I bought a >> tin of " herb jelly " without looking at it carefully. >> When i got it home, I researched the ingredients on t'internet, and >> found its main ingredient was endangered sea turtle, export of which >> is prohibited under CITES. >> >> Even if we make our own tinctures, sometimes those pesky foreign >> herbs >> are the ones that seem indicated. And I want to be able to rely on >> them to be them - and not mixed with endangered turtle. >> >> just saying >> >> Sally Owen >> >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 10, 2011 Report Share Posted March 10, 2011 Hello Nathalie, It was always my assumption that your Herbalness was a Herbalists Herbalist! That was the reason for my query. Yes it's your right to choose, of course and please follow your heart! Yes laws are laws and I understand that if you strongly oppose something then the only way is to vote with your feet. No definately not power hungry, no desire to work in the NHS etc but do want to keep using the stuff I usually do. Best wishes, hope harmony restored! Lorraine Lorraine Hodgkinson MNIMH MRCHM HERBS AND HELPERS 6, Butts Fold, Cockermouth, Cumbria, CA13 9HY. UK. Tel: +44 (0) 1900 826392 Mobile: 07761 489838 (O2) www.herbalmedicineuk.com > Thank you for your apology, Lorraine. I am a fully qualified herbalist! And as such I have nothing to 'fear' from SR, i would be able to be registered/regulated should i wish. > I do not wish to exchange my current right to practice for a privilege granted to me by a government which would then have the power to dictate what i may & may not do in my practice. It is as simple as that. > I am not happy that those who wish to be regulated are in effect imposing this on me & that reforms to section 12 will in theory prevent me accessing my herbs, as i will not submit to regulation. > There is no evidence that regulation protects the general public. None. > It seems to me that herbalism in its vibrant diversity is being sacrificed for the illusion of more jobs, some publicity and greater status. > I do not of course mean that everyone who wants to be regulated is a power & money hungry status seeker! > > Nathalie > > > > > > I thought this was a peaceful and informative discussion > > > > for all. No intention to irritate anyone. Can I ask how > > > > I've offended you? > > > > > > You assumed that everybody wants to be regulated. That's not so. > > > > > > (I also think that grandmas are bona fide herbalists (the ultimate ones, so to > > > speak); however, they'll never be eligible for registration ...) > > > > > > H. > > > > > > -- > > > Henriette Kress, AHG Helsinki, Finland > > > Henriette's herbal homepage: http://www.henriettesherbal.com > > > Uusi kirja: http://www.henriettesherbal.com/fi/kayt-laak.html > > > > > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 11, 2011 Report Share Posted March 11, 2011 Hi Lucy Thanks for sharing your thoughts on the issues about regulation and the debate that's going on. They do echo mine in many ways. What really motivates me is to be able to talk to people about using herbs, so they wish, as medicines. I also find it rather difficult having to ask for money after discussing their health issues and giving them advice. It just doesn't feel good, and it doesn't feel right either, that someone has to pay for a private herbal consultation and medicines when they're also paying taxes to access a public health service. I'd like to see that changing and hope that SR will open up the possibility for people to have the freedom to chose being treated with herbs in primary health care. With herbs in their natural form, as much as possible, and with herbal remedies prepared by herbalists who care about the wellbeing of others. Perhaps what we need to do is keeping a line of communication open with our MPs to voice our concerns. monica ---------------------------------------- Sent: 08 March 2011 15:15 To: ukherbal-list Subject: Re: Regulation I love this list and I am very glad to be a herablist and to be part of it. However, every now and then, it starts to feel as though it is getting personal. The pro SR point of view was asked for and only one person has put themself on the line to express themselves and then a few others seem to be brow-beating her into a corner. Whilst I see the points that are made, if they were directed at me, I think I would feel that it was getting a bit like a group attack! This is not the way to vent frustrations about what is happening. My big fear is that we become more divided by this and any other ruling than we already are. And I think that this is the very worst thing that can happen to a group of professionals. Divisions within a profession are more damaging than anything else. Ultimately, we all want to provide the best form of healthcare that we can to our patients. That's why we are getting heated about the changes. And, whilst we don't know what they will actually bring, there is inevitably fear about the future. It is unsettling. I am a new practitioner and work in lots of ways in order to earn a living. I don't have a long-standing style of practice to defend nor a hugh practice I am afraid of losing the right to maintain. I am a slow burner. I came into herbalism because I thought it was a wonderful thing. That I could take ingredients from my kitchen cupboard to make my cold symptoms better and as I found out more and more, gradually decided to study it. I wanted to spread the word. I wanted people to be able to access this wonderful mode of healing. I naievely thought when I joined the course, that I would soon be able to work, as a regulated pratitioner within the NHS, alongside doctors, making a herbalist's consultation free at the point of service. I didn't think that I was studying to become a private health practitioner. I was taught in an environment that was pro-regulation like the majority of new graduates from recent years. A few years older and wiser (I was part-time so it took a LONG time to qualify), I can see both sides of the argument. I am SO on the fence, my bum is sore. We were all sold SR very heavily by our professional bodies. I still am not really sure what it all means, let alone what I personally want. I would like to have this profession which I love to be acknowledged in the wider world so that I can say I am a medical herbalist to new people without them asking about my cauldron, whether that's the one that's just water really, or about acupuncture needles and so on. I have a secret and naieve awe for authority which makes me think that regulation would assist in this. Granting status with a protected title which eventually advances the profession within society as a whole. However, it is up to herbalists to make a bigger noise in society. To be there when the media espouse all the crap about herbs, to fight back against the negative press. This is also the job of the professional bodies. However, our professional bodies are not doing this enough. Where are they when we really need them? Why isn't there a HUGE lobby to fight the negative press? An appearance on You & Yours does not a positive attitude make! Perhaps, however, we could direct some of the passion towards those who have some influence in the wider sphere to 'big up' herbalists and remain nice to each other in our desires to express our opinions? Email can sound so harsh and it is easy to fire things off in a heated moment... I think I am sounding all peace and love but we all practice in our own ways and will never totally agree on the finer points. This is one of the reasons that herbs are so great. There is no one answer. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 13, 2011 Report Share Posted March 13, 2011 Hi monica I dont want to sound like an old cynic but I really wouldnt hold youre breath in hoping that herbal medicine will be any more acceptable or available in mainstream medicine under SR- I just cant see that happening in a month of sundays . If primary care wants to use herbs then I would imagine they ll just hijack it themselves - a bit like some doctors do already " oh youre depressed why not try st johns wort " best curmudgeonly regards ,annette I'd like to see that changing and hope that SR will open up the possibility for people to have the freedom to chose being treated with herbs in primary health care. With herbs in their natural form, as much as possible, and with herbal remedies prepared by herbalists who care about the wellbeing of others. Perhaps what we need to do is keeping a line of communication open with our MPs to voice our concerns. monica ---------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 13, 2011 Report Share Posted March 13, 2011 Thanks Annette but sometimes prefer to look at things with the pink glasses on, you see ? Yes I am with you there and know of the resistance and opposition from the general pharmaceutical and medical profession all too well. Yet there's still a few GPs who realise what's best for their patients. Would they share some of the 80 billions one wonders? Wasn't it like that when there was a GP Fundholding? After all they haven't been trained to prescribe herbs and if they had any ethics... Not holding my breath though and only believe on what I can achieve locally, so far a few talks & walks at townswomen's guilds and friends of parks groups, a couple of regular patients and treating people I know for peanuts - not enough to make a living but it's a start. Just planting the seed, and if you plant it on good soil, and look after it, it'll surely grow. Let's do our bit and hope for a bit of sunshine. Warmly, monica ---------------------------------------- Sent: 13 March 2011 18:07 To: ukherbal-list Subject: Re: Re: Regulation Hi monica I dont want to sound like an old cynic but I really wouldnt hold youre breath in hoping that herbal medicine will be any more acceptable or available in mainstream medicine under SR- I just cant see that happening in a month of sundays . If primary care wants to use herbs then I would imagine they ll just hijack it themselves - a bit like some doctors do already " oh youre depressed why not try st johns wort " best curmudgeonly regards ,annette I'd like to see that changing and hope that SR will open up the possibility for people to have the freedom to chose being treated with herbs in primary health care. With herbs in their natural form, as much as possible, and with herbal remedies prepared by herbalists who care about the wellbeing of others. Perhaps what we need to do is keeping a line of communication open with our MPs to voice our concerns. monica ---------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 14, 2011 Report Share Posted March 14, 2011 Hi Annette, there's a lot of stuff around at the moment about the international threats to health freedom [Codex etc] and this article often pops up. I thought it illustrates your point about doctors prescribing herbs and also ties in the interests of the big pharma. I can find very little about how herbalists train or work in the EU. www.becomehealthynow.com/ebookprint.php?id=505 Regards, Therri From: Annette Wass Sent: Sunday, March 13, 2011 6:07 PM To: ukherbal-list Subject: Re: Re: Regulation Hi monica I dont want to sound like an old cynic but I really wouldnt hold youre breath in hoping that herbal medicine will be any more acceptable or available in mainstream medicine under SR- I just cant see that happening in a month of sundays . If primary care wants to use herbs then I would imagine they ll just hijack it themselves - a bit like some doctors do already " oh youre depressed why not try st johns wort " best curmudgeonly regards ,annette I'd like to see that changing and hope that SR will open up the possibility for people to have the freedom to chose being treated with herbs in primary health care. With herbs in their natural form, as much as possible, and with herbal remedies prepared by herbalists who care about the wellbeing of others. Perhaps what we need to do is keeping a line of communication open with our MPs to voice our concerns. monica ---------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 14, 2011 Report Share Posted March 14, 2011 Hi, Ethics and conventional medicine - now that is an interesting discussion! I agree with Annette about being sceptical. I don't think that SR will lead to any great increase in work/referrals as osteopaths have had SR for some time now with little or no result on those lines. I am state regulated as a medical practitioner and I rarely get referrals from my former colleagues for acupuncture or herbal medicine. It is to do with belief and generally conventional practitioners have no great belief in what we do - that is if it even crosses their radar - a combination of prejudice, ignorance and simple lack of time are powerful forces for inertia. However, I also agree that things are changing. I believe that even until 1975 (the year before I qualified in medicine) you could still get struck off the medical register for referring a patient to an alternative medicine practitioner. Some GP's are more open and certainly fund holding does concentrate minds particularly if money can be saved by other forms of treatment. I must sound a cautionary note though. At the moment people self-refer. We need to careful not to enter into a relationship with medical practitioners where we see people only through referral from them. This will leave us with a restricted level of practice as others determine what we can and cannot treat. In an NHS setup, it is extremely unlikely that people will be able to self-refer to a herbalist. In the hierarchy of professionals, herbalists and other practitioners will come below GP's, in terms of status, pay and ability to treat what they like. Regards Gascoigne > > > Thanks Annette but sometimes prefer to look at things with the pink > glasses on, you see ? > > Yes I am with you there and know of the resistance and opposition from > the general pharmaceutical and medical profession all too well. Yet > there's still a few GPs who realise what's best for their patients. > Would they share some of the 80 billions one wonders? Wasn't it like > that when there was a GP Fundholding? After all they haven't been > trained to prescribe herbs and if they had any ethics... > > Not holding my breath though and only believe on what I can achieve > locally, so far a few talks & walks at townswomen's guilds and friends > of parks groups, a couple of regular patients and treating people I > know for peanuts - not enough to make a living but it's a start. Just > planting the seed, and if you plant it on good soil, and look after > it, it'll surely grow. Let's do our bit and hope for a bit of sunshine. > > Warmly, monica > > ---------------------------------------- > From: " Annette Wass " <annette@... > <mailto:annette%40laszlo.globalnet.co.uk>> > Sent: 13 March 2011 18:07 > To: ukherbal-list <mailto:ukherbal-list%40yahoogroups.com> > Subject: Re: Re: Regulation > > Hi monica > > I dont want to sound like an old cynic but I really wouldnt hold youre > breath in hoping that herbal medicine will be any more acceptable or > available in mainstream medicine under SR- I just cant see that > happening in a month of sundays . If primary care wants to use herbs > then I would imagine they ll just hijack it themselves - a bit like > some doctors do already " oh youre depressed why not try st johns wort " > > best curmudgeonly regards ,annette > > I'd like to see that changing and hope that SR will open up the > possibility for people to have the freedom to chose being treated with > herbs in primary health care. With herbs in their natural form, as > much as possible, and with herbal remedies prepared by herbalists who > care about the wellbeing of others. > > Perhaps what we need to do is keeping a line of communication open > with our MPs to voice our concerns. > > monica > > ---------------------------------------- > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 14, 2011 Report Share Posted March 14, 2011 Hi Tend to agree with Annette, I was all starry eyed myself years ago but the years wear you down and reality sets in. We are still in a massive recession and costs are spiralling in the UK. The NHS for example is not sustainable. Many already pay for their dentistry and moves are afoot to propose charging for consults within surgeries I heard from a doctor friend. Drugs prescribed for patients are chosen on price rather than often what is suitable for the patient. Mainstream herbalism will never happen from an economic persepective and i feel it will always remain in the private sector. And as Annette suggests, herbalism will be hijacked and I believe standardised via drug companies and would have very little to do with herbalists themselves, which is why we must fight hard and not surrender our rights to practice as we would wish. I have friends and patients who are doctors. They believe in what I do and would love to see an integrated system, but they concur that it would never come to pass on a political and monetary level until money, profit and control are out of the picture. Maybe one day in a modern utopia !! From what I hear from them we are better placed than them at the moment to practice medicine properly, their hands are tied too much by red tape and what advice they can give. There are many self help herbal bits and bobs that you can teach your patients, education is so important to empower them, but for serious health problems, they come to see us within the private sector and pay for our time and expertise, we should value this and make a decent living as do our colleagues within homeopathy, nutrition, acupuncture and any other therapies out there. Herbal Medicine is a calling for us all i believe, but we are entitled to make a decent living as professional herbalists and not just give it away. The NHS will never pay us, they are broke !!! best wishes Jacqui > > Hi monica > I dont want to sound like an old cynic but I really wouldnt hold youre breath in hoping that herbal medicine will be any more acceptable or available in mainstream medicine under SR- I just cant see that happening in a month of sundays . If primary care wants to use herbs then I would imagine they ll just hijack it themselves - a bit like some doctors do already " oh youre depressed why not try st johns wort " > best curmudgeonly regards ,annette > > I'd like to see that changing and hope that SR will open up the possibility for people to have the freedom to chose being treated with herbs in primary health care. With herbs in their natural form, as much as possible, and with herbal remedies prepared by herbalists who care about the wellbeing of others. > > Perhaps what we need to do is keeping a line of communication open with our MPs to voice our concerns. > > monica > > ---------------------------------------- > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 14, 2011 Report Share Posted March 14, 2011 > > . The NHS will never pay us, they are broke !!! They'd be a lot less broke if they did pay us - part of their application of EBM is working out the best economic treatment. Compare herbalism - cost of herbalist plus tinctures with most all pharmaceutical interventions? - massive saving. Those drugs are pricey. And that's not considering side efects, sequelae, chronic conditions ememrging from suppressed symptoms and unaddressed predisposing causes. False economy....... Sally Owen > > best wishes > > Jacqui > > >> >> Hi monica >> I dont want to sound like an old cynic but I really wouldnt hold >> youre breath in hoping that herbal medicine will be any more >> acceptable or available in mainstream medicine under SR- I just >> cant see that happening in a month of sundays . If primary care >> wants to use herbs then I would imagine they ll just hijack it >> themselves - a bit like some doctors do already " oh youre >> depressed why not try st johns wort " >> best curmudgeonly regards ,annette >> >> I'd like to see that changing and hope that SR will open up the >> possibility for people to have the freedom to chose being treated >> with herbs in primary health care. With herbs in their natural >> form, as much as possible, and with herbal remedies prepared by >> herbalists who care about the wellbeing of others. >> >> Perhaps what we need to do is keeping a line of communication open >> with our MPs to voice our concerns. >> >> monica >> >> ---------------------------------------- >> >> >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 14, 2011 Report Share Posted March 14, 2011 I quite agree Sally, but cannot see it happening. Big Pharma has too tight a grip and control i fear ! Regards Jacqui > >> > >> Hi monica > >> I dont want to sound like an old cynic but I really wouldnt hold > >> youre breath in hoping that herbal medicine will be any more > >> acceptable or available in mainstream medicine under SR- I just > >> cant see that happening in a month of sundays . If primary care > >> wants to use herbs then I would imagine they ll just hijack it > >> themselves - a bit like some doctors do already " oh youre > >> depressed why not try st johns wort " > >> best curmudgeonly regards ,annette > >> > >> I'd like to see that changing and hope that SR will open up the > >> possibility for people to have the freedom to chose being treated > >> with herbs in primary health care. With herbs in their natural > >> form, as much as possible, and with herbal remedies prepared by > >> herbalists who care about the wellbeing of others. > >> > >> Perhaps what we need to do is keeping a line of communication open > >> with our MPs to voice our concerns. > >> > >> monica > >> > >> ---------------------------------------- > >> > >> > >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 14, 2011 Report Share Posted March 14, 2011 Hi stephen, could not agree more !! regards jacqui > > > > > > Thanks Annette but sometimes prefer to look at things with the pink > > glasses on, you see ? > > > > Yes I am with you there and know of the resistance and opposition from > > the general pharmaceutical and medical profession all too well. Yet > > there's still a few GPs who realise what's best for their patients. > > Would they share some of the 80 billions one wonders? Wasn't it like > > that when there was a GP Fundholding? After all they haven't been > > trained to prescribe herbs and if they had any ethics... > > > > Not holding my breath though and only believe on what I can achieve > > locally, so far a few talks & walks at townswomen's guilds and friends > > of parks groups, a couple of regular patients and treating people I > > know for peanuts - not enough to make a living but it's a start. Just > > planting the seed, and if you plant it on good soil, and look after > > it, it'll surely grow. Let's do our bit and hope for a bit of sunshine. > > > > Warmly, monica > > > > ---------------------------------------- > > From: " Annette Wass " <annette@... > > <mailto:annette%40laszlo.globalnet.co.uk>> > > Sent: 13 March 2011 18:07 > > To: ukherbal-list <mailto:ukherbal-list%40yahoogroups.com> > > Subject: Re: Re: Regulation > > > > Hi monica > > > > I dont want to sound like an old cynic but I really wouldnt hold youre > > breath in hoping that herbal medicine will be any more acceptable or > > available in mainstream medicine under SR- I just cant see that > > happening in a month of sundays . If primary care wants to use herbs > > then I would imagine they ll just hijack it themselves - a bit like > > some doctors do already " oh youre depressed why not try st johns wort " > > > > best curmudgeonly regards ,annette > > > > I'd like to see that changing and hope that SR will open up the > > possibility for people to have the freedom to chose being treated with > > herbs in primary health care. With herbs in their natural form, as > > much as possible, and with herbal remedies prepared by herbalists who > > care about the wellbeing of others. > > > > Perhaps what we need to do is keeping a line of communication open > > with our MPs to voice our concerns. > > > > monica > > > > ---------------------------------------- > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 15, 2011 Report Share Posted March 15, 2011 Hi Lorraine, I do not know about RCHM suppliers, because I am not a TCM practitioner, I thought that RCHM is a practitioner organisation? Do they supply a list of reliable suppliers? Are you saying that these suppliers have Chinese GMP instead of EU GMP? Please be clear. In the Orange Guide published by MHRA regarding GMP, the ONLY GMP mentioned is EU GMP. So it means that they think that their GMP is equal to EU GMP. Best wishes, MARilena. To: ukherbal-list From: herbsandhelpers@... Date: Thu, 10 Mar 2011 16:56:44 +0000 Subject: Re: Re: Regulation Hello Marilena, Practitioners buy in bulk from suppliers. These suppliers import from countries outside the EU. Many of the RCHM suppliers claim they have 'GMP'. However the MHRA only recognises EU GMP no matter what the product. Lorraine Lorraine Hodgkinson MNIMH MRCHM HERBS AND HELPERS 6, Butts Fold, Cockermouth, Cumbria, CA13 9HY. UK. Tel: +44 (0) 1900 826392 Mobile: 07761 489838 (O2) www.herbalmedicineuk.com > > Dear Lorraine, my point is that MHRA is talking about retail sale, when they say that they only recognise EU GMP. > But RCHM does not do any retail, it is an organisation of practitioners. > According to section 12.1, you can only give herbs to someone after a one to one consultation, so that does theoretically exclude selling herbs to other practitioners who supply them to their patients, as opposed to your patients: that would be considered retail. which is why you would have to deal with MHRA guidelines in that case. > But Practitioner guidelines are regulated by their Associations (at the moment) and it is a practitioners' responsibility to ensure that their suppliers are acting and producing according to MHRA approved standards, which gives them the right to sell their products to us, so that we can sell them to our patients after a one to one consultation, which is not considered a retail situation by MHRA and is therefore not under their remit...... > At least, this is how I understand the situation as it is at the moment. > Marilena. > > > > To: ukherbal-list > From: herbsandhelpers@... > Date: Thu, 10 Mar 2011 11:00:15 +0000 > Subject: Re: Re: Regulation > > > > > > > Hello Marilena, > I will always champion the right of Herbalists to make their own medicines for patients after one to one consultation. We must fight to the death and never lose this right. It would be wrong to ask such Herbalists to comply with full EU GMP and impossible for many. Also we have a long tradition of safe time honoured dispensing. SR must include minimal feasible standards for practitioners. > > This is not about products I sell. I will only be supplying herbal medicines to practitioners from 1st May as per section 12.1. > > Please note the word GMP means different things in different countries. In meetings with the MHRA they have said they only recognise EU GMP. > > The RCHM is not the UK regulator for medicines the MHRA is. > > If there is an incident you need to please the MHRA and courts not the RCHM. > > If a product has not been tested to a European standard then you have way of knowing if it meets a European standard. > > Please don't be fooled! > > Lorraine > > Lorraine Hodgkinson MNIMH MRCHM > HERBS AND HELPERS > 6, Butts Fold, Cockermouth, > Cumbria, CA13 9HY. UK. > Tel: +44 (0) 1900 826392 > Mobile: 07761 489838 (O2) > www.herbalmedicineuk.com > > On 10 Mar 2011, at 10:45, marilena hettema wrote: > >> >> Dear Lorraine, I think we need to make a difference between retail sale and practitioner sale. >> Retail is to the general public, and has very stringent GMP requirements, because a Recall Procedure (in case of a mistake in preparation) needs to be put into place, which is difficult if selling to the general public. So stringent hygiene, identification, testing and traceability measures are required, to ensure that the product poses the minimum of risk and the maximum of traceability. >> Practitioner sale is documented through case notes, with name, contact details and date of sale recorded. I f a mistake came through, for example through our suppliers, this would be traceable and the consumer can be adviced immediately to stop taking the medicine and take appropriate measures if needed. >> At a two day workshop in 2004 given by MHRA on wholesale and manufacturing licensing, the MHRA officials confirmed that the sale through a practitioner on a one to one basis after personal consultation is not seen as retail. >> Therefore, the manufacture by herbalists of medicines for their patients also needs less stringent GMP measures. >> The RCHM is a practitioner organisation, not a retail organisation. >> I am aware that you are selling your products quite widely, as you often promote them on this list, and therefore assume that you need really stringent EU GMP for your products, as you do not always have direct records of the consumer, if you are selling them on to other practitioners who then dispense them to their patients, which would probably be considered a retail activity. But a practitioner who gives them directly to their patients after having them made personally, from raw materials, can also ensure that Identification, Hygiene, Traceability and Contamination are according to standards. Anyone wishing to know what the MHRA guidelines are for herbal products for retail , should read the Orange Guide, available from WH (see MHRA website for real title), and adapt the requirements to their own situation. This would be advisable for anyone making their own remedies from raw materials (eg collecting herbs and making them into tinctures etc) for dispensing to their own patients. >> So I think that there is no need to take down the RCHM scheme, just because it does not suit your needs, does not mean it is not good for others. >> Kind regards, >> Marilena. >> >> >> >> To: ukherbal-list >> From: herbsandhelpers@... >> Date: Thu, 10 Mar 2011 05:55:18 +0000 >> Subject: Re: Re: Regulation >> >> >> >> >> >> >> Hello , >> I've remained outside this scheme for various reasons. Please don't be fooled though. The RCHM has no regulatory capacity over suppliers the MHRA is the regulator. All that's need to get into the ECHM scheme is for you to pay them to visit you. Please note the fact that any 'GMP' is accepted rather than what the MHRA sets down should ring alarm bells ... >> >> Please always ask questions of your suppliers I think you'll find that most rely in testing outside the EU. This is not acceptable to the MHRA who only recognise certified facilities. >> >> A lot of 'powders' may be borderline the standards that control what gets through should always meet EU levels. >> >> Best wishes, >> >> Lorraine >> >> Lorraine Hodgkinson MNIMH MRCHM >> HERBS AND HELPERS >> 6, Butts Fold, Cockermouth, >> Cumbria, CA13 9HY. UK. >> Tel: +44 (0) 1900 826392 >> Mobile: 07761 489838 (O2) >> www.herbalmedicineuk.com >> >> >> >>> Hi, >>> >>> Before everyone gets carried away and sounding like a branch meeting of >>> UKIP debating 'foreigners' - the main point here is about herbal >>> practice and herbal safety. >>> >>> The Register of Chinese Herbal Medicine developed a method of approving >>> suppliers of Chinese herbs in 2004 so that practitioners and patients >>> could be reassured about herbal quality. I personally have used Chinese >>> herbal powders for getting on for 20 years with no problem and I am >>> happy that they are what they claim to be and they are not contaminated. >>> >>> If you want to discuss other herbs, usually prepared and from mainland >>> China, then please do not associate them, implicitly or explicitly, with >>> the professional practice of Chinese herbal medicine. >>> >>> Regards >>> >>> Gascoigne >>> >>> >>>> >>>> On a different note, but also illegal- I was once with friends >>>> hurrying through a chinese supermarket, buying tinned shitake, dried >>>> whole roots to cook with at home, chillie sauce etc, and I bought a >>>> tin of " herb jelly " without looking at it carefully. >>>> When i got it home, I researched the ingredients on t'internet, and >>>> found its main ingredient was endangered sea turtle, export of which >>>> is prohibited under CITES. >>>> >>>> Even if we make our own tinctures, sometimes those pesky foreign herbs >>>> are the ones that seem indicated. And I want to be able to rely on >>>> them to be them - and not mixed with endangered turtle. >>>> >>>> just saying >>>> >>>> Sally Owen >>>> >>>> >>>> >>>>> Yes I'd agree, >>>>> Once you start looking below the surface, asking >>>>> a few questions then it can be quite scary. We with a Western mind >>>>> set 'assume' things are okay for various reasons. However with TCM >>>>> currently the only way to be sure is to have it tested in a European >>>>> lab. You can then verify to European standards the facts about >>>>> product, no argument. >>>>> >>>>> May sound scary but sometimes after European testing stuff has to be >>>>> sent back! >>>>> >>>>> A European COA is the only way to be sure the stuff is what it's >>>>> purported to be! >>>>> >>>>> Total traceability especially speed of response is also vital. It >>>>> allows you to reassue clients, provide them with hard data if needed >>>>> that you're doing it right and safeguarding their health. >>>>> >>>>> Lorraine >>>>> >>>>> Lorraine Hodgkinson MNIMH MRCHM >>>>> HERBS AND HELPERS >>>>> 6, Butts Fold, Cockermouth, >>>>> Cumbria, CA13 9HY. UK. >>>>> Tel: +44 (0) 1900 826392 >>>>> Mobile: 07761 489838 (O2) >>>>> www.herbalmedicineuk.com >>>>> >>>>> >>>>> On 9 Mar 2011, at 10:45, " natlychid2000 " <natly@... >>>> <mailto:natly%40chidley.org>> wrote: >>>>> >>>>>> Dear >>>>>> I'm not basing my comments on hearsay, i've had personal direct >>>>>> eyeball experience of TCM practitioner products in the last 4 weeks >>>>>> that were exactly as i have described, and it wasn't a small >>>>>> operation. >>>>>> Apologies to those who are doing the right thing but you have to >>>>>> admit that this has been, and continues to be, a real problem. >>>>>> I'm not in favour of herbs being treated as standardised extracts, >>>>>> tested as if they were pharmaceuticals, a small amount of traceable >>>>>> paperwork is, however, necessary. Particularly in products where >>>>>> you cannot use smell, touch taste to verify the contents. >>>>>> >>>>>> Looks like being another glorious day, wish i was in the garden! >>>>>> Nathalie >>>>>> >>>>>> >>>>>>>>>> >>>>>>>>>>> >>>>>>>>>> >>>>>>>>>>> From: Therri Lahood <harkster@ >>>>>>>>>> >>>>>>>>>>> <mailto:harkster%40dsl.pipex.com>> >>>>>>>>>> >>>>>>>>>>> Subject: Re: Re: Regulation >>>>>>>>>> >>>>>>>>>>> To: ukherbal-list >>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>>>> >>>>>>>>>>> Date: Monday, 7 March, 2011, 19:07 >>>>>>>>>> >>>>>>>>>> >> >> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 15, 2011 Report Share Posted March 15, 2011 Hello Marilena, Yes because of problems in the TCM industry the RCHM wanted a scheme of suppliers. Anybody can join as long as you pay the RCHM to come and visit you. Most of the TCM suppliers have non EU GMP. The MHRA only recognises EU GMP. Please ask the MHRA themselves; they do not recognise non EU GMP. The only way to know if imported TCM products are to European standards is to test them in a European lab and have a European COA (all the KPC stuff I have has this, tested in Switzerland) and/or produce it in an EU GMP certified facility. There's no other way to guarantee that the product meets current European standards as we understand them and to be able to prove it. I strongly suggest you ask any TCM suppliers you buy from to supply you with a European COA to guarantee that they meet EU standards first. Be interested to know how you get on! Please dont be fooled! Lorraine Lorraine Hodgkinson MNIMH MRCHM HERBS AND HELPERS 6, Butts Fold, Cockermouth, Cumbria, CA13 9HY. UK. Tel: +44 (0) 1900 826392 Mobile: 07761 489838 (O2) www.herbalmedicineuk.com > > Hi Lorraine, I do not know about RCHM suppliers, because I am not a TCM practitioner, I thought that RCHM is a practitioner organisation? Do they supply a list of reliable suppliers? Are you saying that these suppliers have Chinese GMP instead of EU GMP? > Please be clear. > In the Orange Guide published by MHRA regarding GMP, the ONLY GMP mentioned is EU GMP. So it means that they think that their GMP is equal to EU GMP. > Best wishes, MARilena. > > > > To: ukherbal-list > From: herbsandhelpers@... > Date: Thu, 10 Mar 2011 16:56:44 +0000 > Subject: Re: Re: Regulation > > > > > > > Hello Marilena, > Practitioners buy in bulk from suppliers. These suppliers import from countries outside the EU. Many of the RCHM suppliers claim they have 'GMP'. However the MHRA only recognises EU GMP no matter what the product. > > Lorraine > > Lorraine Hodgkinson MNIMH MRCHM > HERBS AND HELPERS > 6, Butts Fold, Cockermouth, > Cumbria, CA13 9HY. UK. > Tel: +44 (0) 1900 826392 > Mobile: 07761 489838 (O2) > www.herbalmedicineuk.com > > On 10 Mar 2011, at 12:41, marilena hettema wrote: > >> >> Dear Lorraine, my point is that MHRA is talking about retail sale, when they say that they only recognise EU GMP. >> But RCHM does not do any retail, it is an organisation of practitioners. >> According to section 12.1, you can only give herbs to someone after a one to one consultation, so that does theoretically exclude selling herbs to other practitioners who supply them to their patients, as opposed to your patients: that would be considered retail. which is why you would have to deal with MHRA guidelines in that case. >> But Practitioner guidelines are regulated by their Associations (at the moment) and it is a practitioners' responsibility to ensure that their suppliers are acting and producing according to MHRA approved standards, which gives them the right to sell their products to us, so that we can sell them to our patients after a one to one consultation, which is not considered a retail situation by MHRA and is therefore not under their remit...... >> At least, this is how I understand the situation as it is at the moment. >> Marilena. >> >> >> >> To: ukherbal-list >> From: herbsandhelpers@... >> Date: Thu, 10 Mar 2011 11:00:15 +0000 >> Subject: Re: Re: Regulation >> >> >> >> >> >> >> Hello Marilena, >> I will always champion the right of Herbalists to make their own medicines for patients after one to one consultation. We must fight to the death and never lose this right. It would be wrong to ask such Herbalists to comply with full EU GMP and impossible for many. Also we have a long tradition of safe time honoured dispensing. SR must include minimal feasible standards for practitioners. >> >> This is not about products I sell. I will only be supplying herbal medicines to practitioners from 1st May as per section 12.1. >> >> Please note the word GMP means different things in different countries. In meetings with the MHRA they have said they only recognise EU GMP. >> >> The RCHM is not the UK regulator for medicines the MHRA is. >> >> If there is an incident you need to please the MHRA and courts not the RCHM. >> >> If a product has not been tested to a European standard then you have way of knowing if it meets a European standard. >> >> Please don't be fooled! >> >> Lorraine >> >> Lorraine Hodgkinson MNIMH MRCHM >> HERBS AND HELPERS >> 6, Butts Fold, Cockermouth, >> Cumbria, CA13 9HY. UK. >> Tel: +44 (0) 1900 826392 >> Mobile: 07761 489838 (O2) >> www.herbalmedicineuk.com >> >> On 10 Mar 2011, at 10:45, marilena hettema wrote: >> >>> >>> Dear Lorraine, I think we need to make a difference between retail sale and practitioner sale. >>> Retail is to the general public, and has very stringent GMP requirements, because a Recall Procedure (in case of a mistake in preparation) needs to be put into place, which is difficult if selling to the general public. So stringent hygiene, identification, testing and traceability measures are required, to ensure that the product poses the minimum of risk and the maximum of traceability. >>> Practitioner sale is documented through case notes, with name, contact details and date of sale recorded. I f a mistake came through, for example through our suppliers, this would be traceable and the consumer can be adviced immediately to stop taking the medicine and take appropriate measures if needed. >>> At a two day workshop in 2004 given by MHRA on wholesale and manufacturing licensing, the MHRA officials confirmed that the sale through a practitioner on a one to one basis after personal consultation is not seen as retail. >>> Therefore, the manufacture by herbalists of medicines for their patients also needs less stringent GMP measures. >>> The RCHM is a practitioner organisation, not a retail organisation. >>> I am aware that you are selling your products quite widely, as you often promote them on this list, and therefore assume that you need really stringent EU GMP for your products, as you do not always have direct records of the consumer, if you are selling them on to other practitioners who then dispense them to their patients, which would probably be considered a retail activity. But a practitioner who gives them directly to their patients after having them made personally, from raw materials, can also ensure that Identification, Hygiene, Traceability and Contamination are according to standards. Anyone wishing to know what the MHRA guidelines are for herbal products for retail , should read the Orange Guide, available from WH (see MHRA website for real title), and adapt the requirements to their own situation. This would be advisable for anyone making their own remedies from raw materials (eg collecting herbs and making them into tinctures etc) for dispensing to their own patients. >>> So I think that there is no need to take down the RCHM scheme, just because it does not suit your needs, does not mean it is not good for others. >>> Kind regards, >>> Marilena. >>> >>> >>> >>> To: ukherbal-list >>> From: herbsandhelpers@... >>> Date: Thu, 10 Mar 2011 05:55:18 +0000 >>> Subject: Re: Re: Regulation >>> >>> >>> >>> >>> >>> >>> Hello , >>> I've remained outside this scheme for various reasons. Please don't be fooled though. The RCHM has no regulatory capacity over suppliers the MHRA is the regulator. All that's need to get into the ECHM scheme is for you to pay them to visit you. Please note the fact that any 'GMP' is accepted rather than what the MHRA sets down should ring alarm bells ... >>> >>> Please always ask questions of your suppliers I think you'll find that most rely in testing outside the EU. This is not acceptable to the MHRA who only recognise certified facilities. >>> >>> A lot of 'powders' may be borderline the standards that control what gets through should always meet EU levels. >>> >>> Best wishes, >>> >>> Lorraine >>> >>> Lorraine Hodgkinson MNIMH MRCHM >>> HERBS AND HELPERS >>> 6, Butts Fold, Cockermouth, >>> Cumbria, CA13 9HY. UK. >>> Tel: +44 (0) 1900 826392 >>> Mobile: 07761 489838 (O2) >>> www.herbalmedicineuk.com >>> >>> >>> >>>> Hi, >>>> >>>> Before everyone gets carried away and sounding like a branch meeting of >>>> UKIP debating 'foreigners' - the main point here is about herbal >>>> practice and herbal safety. >>>> >>>> The Register of Chinese Herbal Medicine developed a method of approving >>>> suppliers of Chinese herbs in 2004 so that practitioners and patients >>>> could be reassured about herbal quality. I personally have used Chinese >>>> herbal powders for getting on for 20 years with no problem and I am >>>> happy that they are what they claim to be and they are not contaminated. >>>> >>>> If you want to discuss other herbs, usually prepared and from mainland >>>> China, then please do not associate them, implicitly or explicitly, with >>>> the professional practice of Chinese herbal medicine. >>>> >>>> Regards >>>> >>>> Gascoigne >>>> >>>> >>>>> >>>>> On a different note, but also illegal- I was once with friends >>>>> hurrying through a chinese supermarket, buying tinned shitake, dried >>>>> whole roots to cook with at home, chillie sauce etc, and I bought a >>>>> tin of " herb jelly " without looking at it carefully. >>>>> When i got it home, I researched the ingredients on t'internet, and >>>>> found its main ingredient was endangered sea turtle, export of which >>>>> is prohibited under CITES. >>>>> >>>>> Even if we make our own tinctures, sometimes those pesky foreign herbs >>>>> are the ones that seem indicated. And I want to be able to rely on >>>>> them to be them - and not mixed with endangered turtle. >>>>> >>>>> just saying >>>>> >>>>> Sally Owen >>>>> >>>>> >>>>> >>>>>> Yes I'd agree, >>>>>> Once you start looking below the surface, asking >>>>>> a few questions then it can be quite scary. We with a Western mind >>>>>> set 'assume' things are okay for various reasons. However with TCM >>>>>> currently the only way to be sure is to have it tested in a European >>>>>> lab. You can then verify to European standards the facts about >>>>>> product, no argument. >>>>>> >>>>>> May sound scary but sometimes after European testing stuff has to be >>>>>> sent back! >>>>>> >>>>>> A European COA is the only way to be sure the stuff is what it's >>>>>> purported to be! >>>>>> >>>>>> Total traceability especially speed of response is also vital. It >>>>>> allows you to reassue clients, provide them with hard data if needed >>>>>> that you're doing it right and safeguarding their health. >>>>>> >>>>>> Lorraine >>>>>> >>>>>> Lorraine Hodgkinson MNIMH MRCHM >>>>>> HERBS AND HELPERS >>>>>> 6, Butts Fold, Cockermouth, >>>>>> Cumbria, CA13 9HY. UK. >>>>>> Tel: +44 (0) 1900 826392 >>>>>> Mobile: 07761 489838 (O2) >>>>>> www.herbalmedicineuk.com >>>>>> >>>>>> >>>>>> On 9 Mar 2011, at 10:45, " natlychid2000 " <natly@... >>>>> <mailto:natly%40chidley.org>> wrote: >>>>>> >>>>>>> Dear >>>>>>> I'm not basing my comments on hearsay, i've had personal direct >>>>>>> eyeball experience of TCM practitioner products in the last 4 weeks >>>>>>> that were exactly as i have described, and it wasn't a small >>>>>>> operation. >>>>>>> Apologies to those who are doing the right thing but you have to >>>>>>> admit that this has been, and continues to be, a real problem. >>>>>>> I'm not in favour of herbs being treated as standardised extracts, >>>>>>> tested as if they were pharmaceuticals, a small amount of traceable >>>>>>> paperwork is, however, necessary. Particularly in products where >>>>>>> you cannot use smell, touch taste to verify the contents. >>>>>>> >>>>>>> Looks like being another glorious day, wish i was in the garden! >>>>>>> Nathalie >>>>>>> >>>>>>> >>>>>>>>>>> >>>>>>>>>>>> >>>>>>>>>>> >>>>>>>>>>>> From: Therri Lahood <harkster@ >>>>>>>>>>> >>>>>>>>>>>> <mailto:harkster%40dsl.pipex.com>> >>>>>>>>>>> >>>>>>>>>>>> Subject: Re: Re: Regulation >>>>>>>>>>> >>>>>>>>>>>> To: ukherbal-list >>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>>> <mailto:ukherbal-list%40yahoogroups.com> >>>>>>>>>>> >>>>>>>>>>>> Date: Monday, 7 March, 2011, 19:07 >>>>>>>>>>> >>>>>>>>>>> >>> >>> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 15, 2011 Report Share Posted March 15, 2011 I also feel there is a risk that SR under the HPC will lead to a narrowing of our scope of practice as other influences are brought to bear. There are also concerns as to how it will impact on running costs, training, post graduate training, and our mode of practice. What if SR proves to be a disaster individually, or collectively? Where is a fall back position then? By leaving 12(1) unchanged, and allowing both SR’ed and non-SR’ed herbalists to co-exist, this would give a plan B should one be needed. It would also provide a means whereby SR will not impose itself as the only possible option on those herbalists who, for perfectly rational reasons, would not want to become SR’ed. This is why it is so important the 12(1) does not become the exclusive domain of those who wish to be SR’ed. The inclusivity of this dual approach offers fairness, diversity, and a plan B should one be needed. Best regards, Tim. From: Dr S Gascoigne Sent: Monday, March 14, 2011 1:05 PM To: ukherbal-list Subject: Re: Re: Regulation Hi, Ethics and conventional medicine - now that is an interesting discussion! I agree with Annette about being sceptical. I don't think that SR will lead to any great increase in work/referrals as osteopaths have had SR for some time now with little or no result on those lines. I am state regulated as a medical practitioner and I rarely get referrals from my former colleagues for acupuncture or herbal medicine. It is to do with belief and generally conventional practitioners have no great belief in what we do - that is if it even crosses their radar - a combination of prejudice, ignorance and simple lack of time are powerful forces for inertia. However, I also agree that things are changing. I believe that even until 1975 (the year before I qualified in medicine) you could still get struck off the medical register for referring a patient to an alternative medicine practitioner. Some GP's are more open and certainly fund holding does concentrate minds particularly if money can be saved by other forms of treatment. I must sound a cautionary note though. At the moment people self-refer. We need to careful not to enter into a relationship with medical practitioners where we see people only through referral from them. This will leave us with a restricted level of practice as others determine what we can and cannot treat. In an NHS setup, it is extremely unlikely that people will be able to self-refer to a herbalist. In the hierarchy of professionals, herbalists and other practitioners will come below GP's, in terms of status, pay and ability to treat what they like. Regards Gascoigne On 13/03/2011 23:46, mailto:monica%40plantamedica.co.uk wrote: > > > Thanks Annette but sometimes prefer to look at things with the pink > glasses on, you see ? > > Yes I am with you there and know of the resistance and opposition from > the general pharmaceutical and medical profession all too well. Yet > there's still a few GPs who realise what's best for their patients. > Would they share some of the 80 billions one wonders? Wasn't it like > that when there was a GP Fundholding? After all they haven't been > trained to prescribe herbs and if they had any ethics... > > Not holding my breath though and only believe on what I can achieve > locally, so far a few talks & walks at townswomen's guilds and friends > of parks groups, a couple of regular patients and treating people I > know for peanuts - not enough to make a living but it's a start. Just > planting the seed, and if you plant it on good soil, and look after > it, it'll surely grow. Let's do our bit and hope for a bit of sunshine. > > Warmly, monica > > ---------------------------------------- > From: " Annette Wass " <mailto:annette%40laszlo.globalnet.co.uk > <mailto:annette%40laszlo.globalnet.co.uk>> > Sent: 13 March 2011 18:07 > To: mailto:ukherbal-list%40yahoogroups.com <mailto:ukherbal-list%40yahoogroups.com> > Subject: Re: Re: Regulation > > Hi monica > > I dont want to sound like an old cynic but I really wouldnt hold youre > breath in hoping that herbal medicine will be any more acceptable or > available in mainstream medicine under SR- I just cant see that > happening in a month of sundays . If primary care wants to use herbs > then I would imagine they ll just hijack it themselves - a bit like > some doctors do already " oh youre depressed why not try st johns wort " > > best curmudgeonly regards ,annette > > I'd like to see that changing and hope that SR will open up the > possibility for people to have the freedom to chose being treated with > herbs in primary health care. With herbs in their natural form, as > much as possible, and with herbal remedies prepared by herbalists who > care about the wellbeing of others. > > Perhaps what we need to do is keeping a line of communication open > with our MPs to voice our concerns. > > monica > > ---------------------------------------- > > Quote Link to comment Share on other sites More sharing options...
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