Guest guest Posted March 9, 2011 Report Share Posted March 9, 2011 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: Dr S Gascoigne <gasco@ <mailto:gasco%40eircom.net>> > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> Subject: Re: Re: Regulation > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> To: ukherbal-list > <mailto:ukherbal-list%40yahoogroups.com> > >>>> <mailto:ukherbal-list%40yahoogroups.com> > >>>> <mailto:ukherbal-list%40yahoogroups.com> > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> Date: Sunday, 6 March, 2011, 20:33 > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> And will regulation solve this? I am medically qualified - > >>>> regulated and > >>>>>> > >>>>> > > > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 9, 2011 Report Share Posted March 9, 2011 Hello Sally, CITES products vary in availability depending on whether a CITES certificate is available. Some things disappear never to return but others lead to beneficial cultivation programs. Tian Ma is one such example dangerously over collected and protected it disappeared. Only to reemerge once some old Chinese guy had worked out how to cultivate it with the fungus it needs to grow. Now they're all at it and supplies flow, leaving wild populations alone. It is controlled. 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 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 > > > > > > > > > >> 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> > >>>>>> > >>>>>>> Date: Monday, 7 March, 2011, 19:07 > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> Hi , > >>>>>> > >>>>>>> > >>>>>> > >>>>>>> So SR is necessary in order to protect the public by weeding out > >>>>>> > >>>>>>> unscrupulous CAM practitioners. Yet no clear evidence has been > >>>>>> > >>>>>>> produced by the state that western herbalists are engaging in > >>>> poor/bad > >>>>>> > >>>>>>> practice or that patients are being abused or even that existing > >>>>>> > >>>>>>> voluntary/self-regulating structures are failing to deal with > >>>>>>> any > >>>>>> > >>>>>>> malpractice. Furthermore, there is no research that demonstrates > >>>> that > >>>>>> > >>>>>>> state regulation would in any way improve professional > >>>> competence or > >>>>>> > >>>>>>> enhance public protection and as points out medical > >>>>>>> doctors > >>>>>> > >>>>>>> are regulated, yet cases of malpractice continue to occur. As I > >>>> have > >>>>>> > >>>>>>> said before, I am happy to support regulation for those > >>>> herbalists who > >>>>>> > >>>>>>> believe that their practice will be enhanced by working within a > >>>>>> > >>>>>>> statutory framework. I have read the arguments but I am > >>>>>>> finding it > >>>>>> > >>>>>>> hard to fathom why SR is diminished, in terms of best practice, > >>>> safety > >>>>>> > >>>>>>> etc, by independent herbalists working alongside it. Surely it Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 9, 2011 Report Share Posted March 9, 2011 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 9, 2011 Report Share Posted March 9, 2011 What would stop you dining Nathalie? Surely any bone fide Herbalist will be eligible to register. 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 > Agreed. Unfortunately SR & reform of section12(1) as it is envisaged will leave many who wish to dine without access to the cutlery, dining service or menu. > > Apologies for pushing out the metaphor boat! > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > From: Therri Lahood <harkster@ > > > > > > > > > > > > > > > > > > > <mailto:harkster%40dsl.pipex.com>> > > > > > > > > > > > > > > > > > > > Subject: Re: Re: Regulation > > > > > > > > > > > > > > > > > > > To: ukherbal-list <mailto:ukherbal-list%40yahoogroups.com> > > > > > > > > > > > > > > > > > > > Date: Monday, 7 March, 2011, 19:07 > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > Hi , > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > So SR is necessary in order to protect the public by weeding out > > > > > > > > > > > > > > > > > > > unscrupulous CAM practitioners. Yet no clear evidence has been > > > > > > > > > > > > > > > > > > > produced by the state that western herbalists are engaging in poor/bad > > > > > > > > > > > > > > > > > > > practice or that patients are being abused or even that existing > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 10, 2011 Report Share Posted March 10, 2011 Lorraine, is your language deliberately inflammatory? Therri From: Herbs and Helpers Sent: Thursday, March 10, 2011 5:57 AM To: ukherbal-list Subject: Re: Re: Regulation What would stop you dining Nathalie? Surely any bone fide Herbalist will be eligible to register. 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 > Agreed. Unfortunately SR & reform of section12(1) as it is envisaged will leave many who wish to dine without access to the cutlery, dining service or menu. > > Apologies for pushing out the metaphor boat! > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > From: Therri Lahood <harkster@ > > > > > > > > > > > > > > > > > > > <mailto:harkster%40dsl.pipex.com>> > > > > > > > > > > > > > > > > > > > Subject: Re: Re: Regulation > > > > > > > > > > > > > > > > > > > To: ukherbal-list <mailto:ukherbal-list%40yahoogroups.com> > > > > > > > > > > > > > > > > > > > Date: Monday, 7 March, 2011, 19:07 > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > Hi , > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > > So SR is necessary in order to protect the public by weeding out > > > > > > > > > > > > > > > > > > > unscrupulous CAM practitioners. Yet no clear evidence has been > > > > > > > > > > > > > > > > > > > produced by the state that western herbalists are engaging in poor/bad > > > > > > > > > > > > > > > > > > > practice or that patients are being abused or even that existing > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted March 10, 2011 Report Share Posted March 10, 2011 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 > > 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 Thanks Lorraine for this response. But tightening rules is meaningless without enforcement. This ‘turtle jelly’ product sounds not someone bringing it to the UK in a suitcase, but someone importing it for retail sale in a commercial outlet! And the contents (even if in Chinese) were stated on the label! So until there is enforcement of existing rules (in this case the CITES stuff), there is no point in introducing ever more complex legislation. Best regards, Tim. From: Herbs and Helpers Sent: Thursday, March 10, 2011 9:49 AM To: ukherbal-list 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 On 10 Mar 2011, at 09:16, " Tim Lane " <mailto:tim_lane%40live.co.uk> wrote: > 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: mailto:ukherbal-list%40yahoogroups.com > 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 Hi Marilenna I do realise that, I have been practicing thus for about 37 years, during which time I have learned to pick my battles. I am very active in many campaigns some successful, some not However, in this particular incidence, the situation was not practical to engage in. As I explained in my original email, I didn't have time to assess the product until I got home, didn't have the contact details of the supermarket, and on past experience have had trouble communicating with the shop staff. If our conversation inspires others to consider their consumer choices, I am glad, but had assumed that our colleagues were also already doing this. I do agree that one should aways take action when possible, but have recently ceased my efforts to change the world single handed, as it was becoming exhausting. Sally > > Hi sally, there is such a thing as critical mass..... > each one of us is an individual. Even the government is made of > individual people. Unless an individual takes some action, there > will be no action. > If you decide not to buy the product because it has an endangered > turtle species in it, and you tell the shopkeeper about that, that > person might not realise that, because they may not have time to > check all the indredients of all the products they are selling. Or > they may not think that the life of a turtle is important. o we can > start to engage in discussions tlaks etc about why the life of one > turtle is important, and that if we eat all the turtles, then one > day there will be no turtle on this planet, which may have all sorts > of consequences for other animals, because everything is interrelated. > So if I can explain that to the shopekeeper, that person might not > immediately agree with me or see the truth in that, but that person > might start to think it over, and then when they are going to buy a > new stock of products they might think twice about buying the one > with the turtle in it, and might start to look at other ingredients > of other products too. > My own thought on these things also have come about not by > themselves, but because someone started to talk to me about this, > and so on, so now we are talking about it on this list and many more > are reading this too, and that is how a critical mass is formed: > that is how change actually happens. > Marilena. > > > > To: ukherbal-list > From: sally@... > Date: Thu, 10 Mar 2011 11:01:13 +0000 > Subject: Re: Re: Regulation > > > > > > > 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 Hi Tim I think Lorraine already pointed out that the turtles are now being farmed, so my concern in that case was unfounded. (I'm glad to say) I think your general point on enforcement is sound though. Sally > > Thanks Lorraine for this response. But tightening rules is > meaningless without enforcement. This ‘turtle jelly’ product sounds > not someone bringing it to the UK in a suitcase, but someone > importing it for retail sale in a commercial outlet! And the > contents (even if in Chinese) were stated on the label! So until > there is enforcement of existing rules (in this case the CITES > stuff), there is no point in introducing ever more complex > legislation. > > Best regards, > Tim. > From: Herbs and Helpers > Sent: Thursday, March 10, 2011 9:49 AM > To: ukherbal-list > 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 > > On 10 Mar 2011, at 09:16, " Tim Lane " <mailto:tim_lane%40live.co.uk> > wrote: > >> 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: mailto:ukherbal-list%40yahoogroups.com >> 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 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 10, 2011 Report Share Posted March 10, 2011 Hi Tim, CITES is internationally enforced. The metropolitan police have a dedicated unit. Lots of products are internationally banned like ivory and tiger products etc. 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 > > Thanks Lorraine for this response. But tightening rules is meaningless without enforcement. This ‘turtle jelly’ product sounds not someone bringing it to the UK in a suitcase, but someone importing it for retail sale in a commercial outlet! And the contents (even if in Chinese) were stated on the label! So until there is enforcement of existing rules (in this case the CITES stuff), there is no point in introducing ever more complex legislation. > > Best regards, > Tim. > From: Herbs and Helpers > Sent: Thursday, March 10, 2011 9:49 AM > To: ukherbal-list > 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 > > On 10 Mar 2011, at 09:16, " Tim Lane " <mailto:tim_lane%40live.co.uk> wrote: > > > 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: mailto:ukherbal-list%40yahoogroups.com > > 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 Thanks Sally! Tim. 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...
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