Guest guest Posted October 26, 2008 Report Share Posted October 26, 2008 , I thougth it was agreed some time ago that this list is not for discussing SR as it is an issue for UK herbalist only...But who are " those in the know " ? Subject: EGM & SR To: ukherbal-list Date: Sunday, 26 October, 2008, 12:56 PM I write to you as a member of NIMH who is very concerned about this EGM, the manner it has been arranged, and the motion to vote to pursue Statutory Regulation (SR). There is no urgency to go ahead and vote for this now considering the three month long public consultation has not even started and I wonder why Council is trying to push through with this so quickly. I believe our herbal traditions and our livelihood are under threat. I am aware that not everyone has been politically active nor kept up with what is happening but even if this is the case I urge you to read this. I know that the complexity of the situation makes it hard to understand. Council has issued members with a 13 page document of inaccurate and misleading statements presumably to ensure as far as possible that members vote to give Council a mandate to pursue SR. We were informed of the EGM and motions at the last possible moment it could be legally done; i.e. three weeks before the EGM leaving insufficient time to counter their statements and with no easy access to all the membership. I would say the majority of members do not understand the possible implications of SR; in truth no one does at this time because we are not in possession of all the facts. Many members are completely lost as to the whole process. No proper members' consultation has been held, the full facts have not been given, many questions have been asked but have not been answered, information has been withheld, the pros and cons of regulation have not been presented or discussed in a balanced manner. How can members make an informed choice at this time? SOME QUESTIONS THAT NEED TO BE ANSWERED BEFORE WE AGREE TO STATUTORY REGULATION (SR) What form will Statutory Regulation take when and if it happens? Despite Councils' detailed explanations and reassurances as to what will happen and the benefits of SR, it needs to be pointed out that in actuality what Council has presented as facts are most definitely not. The Steering Group (SG) report on which they base their `facts' is nothing more than a proposal to present to the Dept of Health (DH). They have no idea what will happen in the future in respect to SR; whether it will take place, or the form it will take if it does. It is now commonly rumoured amongst `those in the know' that SR will now not happen. This comes from DoH and Woodfield of the MHRA - the government has changed its policy and is not likely to regulate herbalist (or other CAM practitioners) . Yet Council has not made an official statement on this, and has not told the membership but holds an EGM asking for a mandate from members to pursue SR without informing members of the situation. Given that it would seem that the government is now unlikely to regulate us, or at the very least is not happy with the idea, I think we can suppose that the government is not happy with the SG proposal in its current form and therefore if regulation does occur it will not be in the form the SG has proposed and in the form that Council has presented! Given the uncertainty of regulation why is Council pursuing this now and without first verifying the situation and telling members? Therefore, how can we possibly vote to go ahead with SR now when we do not know what we are agreeing to and effectively giving EHPTA, Council & the DoH etc a carte blanche to do as they want? Will we be taken into an increasingly tighter corner that we have difficulty getting out of and some sort of `regulatory' set-up we never dreamed of? We need to know what form regulation will take, if it will take place, (and until the public consultation has taken place we won't know) before we vote for it. I would therefore strongly recommend that members vote against this motion for SR until they know what they are voting for. Will the 1968 Medicines Act be changed should regulation of herbalists not happen? It might a strange question to insist on an answer to in a motion concerning voting for regulation. However, if we vote for SR in this motion we are in affect also voting and demonstrating our agreement for changes to take place in the 1968 Medicines Act under which we practice. Should these changes to the 1968 Medicines Act take place and regulation does not happen we will in affect be banned from practicing! As it would appear that regulation is unlikely to happen why are we being asked to vote now for SR before this is clarified?! Even if regulation does take place we still need to know what changes to the Medicines Act will take place. Following a letter put out by Philip on these very concerns McIntyre countered this saying no changes would happen `to the scope' of the Medicines Act but close questioning as to what he actually meant has not got an answer; the same questions posed to Woodfield of the Medicines and Healthcare products Regulatory Agency (MHRA) have also not been answered. Presumably, if they are not prepared to say that no changes will take place to the Medicines Act if SR does not happen, must mean that some sort of change is being considered if so what? It is our livelihoods that could be at stake here, we need to know exactly what is going to happen in respect to the Medicines Act should regulation not happen (or happen) before we agree to anything and this is a perfectly reasonable request. I therefore strongly recommend that members vote against the motion for SR until we are assured that the Medicines Act will remain unchanged if SR does not happen and the form it will take if it does. Will herbalists be able to continue making their own medicines? We have been assured time and again that herbalists will be allowed to continue to make their own medicines. However, we have also been told that we will need to adhere to Good Manufacturing Practice (GMP) which is currently under discussion. Council has been asked what this might entail but we have not been told. Will the required GMP procedures be something that a herbalist will realistically be able to do and will it be affordable? Pharmacognosy has been mentioned. What will be required of us in order to verify our plants and medicines; a microscope and a gas chromatography machine costing thousands? Or will we be required to send a sample to a laboratory? Will we need to do training, if so what, how long, and what cost? In theory we might be able to make or own medicines but in practice will we be able to do so? We need this information before we give any mandate to Council to pursue SR. What is going to happen to Schedule III list of herbs in the event of regulation going ahead or even regulation not happening? There has been talk of having an expanded Schedule III list alongside regulation, which comes under the Medicines Act. Schedule III herbs will be restricted to regulated practitioners only. Council has been asked for information on this but no information has been given. Schedule III herbs will not be available to those herbalists who do not join the register. Nor will Schedule III herbs be available to the general public. If there is the intention to have an expanded Schedule III list we need to know the details of what is being considered and the herbs that would go on it before we vote for this motion as we might not agree and it might later be imposed on us. An expanded Schedule III list might severely restrict the general public's ability to access herbs; and would also severely restrict ourselves as herbalists should changes be made to the Medicines Act and we are then not regulated; leaving only doctors & pharmacists access to the list. As such we need to know what is going to happen in this respect before we make a choice and vote to give Council a mandate on SR. European Directive (THMPD) Whilst on the subject of medicines I would like to clarify something to the members. In Council's document it states that " Medicines legislation in the European Union is dealt with under the First pillar of the European Union… (which) …uses directives which are signed up to by all MS's (Member States) and must under a time frame be transposed into national law of each MS and in accordance with each MS's legislative system. There are therefore no opt-out or different speed possibilities from this directive in the UK. " Daunting stuff! Fortunately it is not true. An EU Directive cannot be imposed on a MS even though the objective may be binding. It only aims to harmonise legislation. But if a tradition is going to be wiped out by a directive the MS cannot be expected to implement the directive. We therefore are able to opt out of this directive and instead of pursuing it, we should have been opposed a long time ago! I, personally, am opposed to regulation for many reasons; maybe you are not. However, whatever your views, I strongly recommend that members vote against this motion to pursue SR until they are in possession of all the facts and know what they are voting for. Nor do I consider it a good time to extend the period between AGM's. Yours, Verge If you cannot go to the EGM then please vote via proxy through another member; I would be happy to take your vote in so feel free to email me if you would like this. Email: herbal.traditions@ yahoo.co. uk Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 , Please excuse my simplicity, where else would SR be discussed if not on the most available forum? The majority of herbalists using this list were trained in the UK and I believe they will have interest in what's going on regarding their profession as what happens in the UK can reflect in other countries. Benn >, >I thougth it was agreed some time ago that this list is not for >discussing SR as it is an issue for UK herbalist only...But who are > " those in the know " ? > > -- Benn Abdy- MCPP Medical Herbalist 0 or 07957 65 88 90 Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 Benn, my impression was that the Nimh members forum was the discussion platform for that. This list was meant to be " apolitical " - i.e. focused on the treatment issues. Subject: Re: EGM & SR To: ukherbal-list Date: Monday, 27 October, 2008, 7:20 AM , Please excuse my simplicity, where else would SR be discussed if not on the most available forum? The majority of herbalists using this list were trained in the UK and I believe they will have interest in what's going on regarding their profession as what happens in the UK can reflect in other countries. Benn >, >I thougth it was agreed some time ago that this list is not for >discussing SR as it is an issue for UK herbalist only...But who are > " those in the know " ? > > -- Benn Abdy- MCPP Medical Herbalist 0 or 07957 65 88 90 Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 Thanks , I cannot tell you what criteria Graham set as regards politics but there are two matters that arise from your impression - 1. Not all herbalists are NIMH - for instance, I'm not 2. It is not only treatment issues that herbalists need to discuss - SR affects all UK herbalists and needs to be aired where all UK herbalists can access info regarding it. Benn >Benn, my impression was that the Nimh members forum was the discussion >platform for that. This list was meant to be " apolitical " - i.e. >focused on the treatment issues. -- Benn Abdy- MCPP Medical Herbalist 0 or 07957 65 88 90 Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 I think s point is valid in as much as s mailing is particularly focusing on the NIMH EGM and the failures she feels council are guilty of.In a word any complaints about NIMH council and washing of its perceived dirty linen should involve NIMH members only. regards ,annette Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 In brief Annette, if we are seriously concerned about what is happening and the possible consequences and feel the necessity to inform members and highlight potential serious problems in proceeding lightly down this path without due consideration(not about airing dirty linen); where and how else would we contact all NIMH membership at such short notice without spendings hundreds of pounds that are possibly not available. What is most important here? > > I think s point is valid in as much as s mailing is particularly focusing on the NIMH EGM and the failures she feels council are guilty of.In a word any complaints about NIMH council and washing of its perceived dirty linen should involve NIMH members only. > regards ,annette > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 by using the members forum and by direct mailing of members?I cant be the only member who has received exactly the same info through the post. annette Re: EGM & SR In brief Annette, if we are seriously concerned about what is happening and the possible consequences and feel the necessity to inform members and highlight potential serious problems in proceeding lightly down this path without due consideration(not about airing dirty linen); where and how else would we contact all NIMH membership at such short notice without spendings hundreds of pounds that are possibly not available. What is most important here? > > I think s point is valid in as much as s mailing is particularly focusing on the NIMH EGM and the failures she feels council are guilty of.In a word any complaints about NIMH council and washing of its perceived dirty linen should involve NIMH members only. > regards ,annette > > > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 27, 2008 Report Share Posted October 27, 2008 Hi All As far as I'm concerned discussion of SSR is fair game, discussion of NIMH internal politics is not. I appreciate that sometimes it's difficult to tell one from the other! Cheers Graham White, B. Sc. (Herb. Med.) Medical Herbalist ============================= Re: EGM & SR Thanks , I cannot tell you what criteria Graham set as regards politics but there are two matters that arise from your impression - 1. Not all herbalists are NIMH - for instance, I'm not 2. It is not only treatment issues that herbalists need to discuss - SR affects all UK herbalists and needs to be aired where all UK herbalists can access info regarding it. Benn >Benn, my impression was that the Nimh members forum was the discussion >platform for that. This list was meant to be " apolitical " - i.e. >focused on the treatment issues. -- Benn Abdy- MCPP Medical Herbalist 0 or 07957 65 88 90 Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 30, 2008 Report Share Posted October 30, 2008 I agree with Benn here. I am not a member of NIMH anymore, and I do wonder what other professional associations whose members belong to these forums think about the SR. What information have CPP or AMH or URHP to name but a few been given?? There should be a meeting of all UK Herbalists regardless whether they belong to an association or not. Because I don't, I am thankful for these forums and I trust that I would like to make up my own mind when all the positive and negative aspects of SR are examined by all. Are NIMH for example to make a decision for all herbalists?? I fnot what happens to other herbalists then?? Do CPP etc decide for them?? Whats happening here???? regards Jacqui Fordham. > > > Thanks , I cannot tell you what criteria Graham set as regards > politics but there are two matters that arise from your impression - > > 1. Not all herbalists are NIMH - for instance, I'm not > 2. It is not only treatment issues that herbalists need to discuss - SR > affects all UK herbalists and needs to be aired where all UK herbalists > can access info regarding it. > > Benn > > > >Benn, my impression was that the Nimh members forum was the discussion > >platform for that. This list was meant to be " apolitical " - i.e. > >focused on the treatment issues. > > -- > Benn Abdy- MCPP > Medical Herbalist > 0 or 07957 65 88 90 > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted October 30, 2008 Report Share Posted October 30, 2008 Indeed I would like to know what is happening in the other PAs. > > > > > > Thanks , I cannot tell you what criteria Graham set as regards > > politics but there are two matters that arise from your impression - > > > > 1. Not all herbalists are NIMH - for instance, I'm not > > 2. It is not only treatment issues that herbalists need to discuss - > SR > > affects all UK herbalists and needs to be aired where all UK > herbalists > > can access info regarding it. > > > > Benn > > > > > > >Benn, my impression was that the Nimh members forum was the > discussion > > >platform for that. This list was meant to be " apolitical " - i.e. > > >focused on the treatment issues. > > > > -- > > Benn Abdy- MCPP > > Medical Herbalist > > 0 or 07957 65 88 90 > > > Quote Link to comment Share on other sites More sharing options...
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