herb regulation

[Guest guest]

et al.

 

The issue of herb regulation is one with many valid yet conflicting

arguments. By attempting to address the issues involved, the shortcomings

of the professional TCM community's position on this issue would come into

the light and those shortcomings could then be thoughtfully addressed, if

capable people were willing to step forward with adequate persistence and

commitment.

 

The biggest concern of regulatory types is safety. Efficacy is very

secondary until you make claims to the public about a commercial product.

Safety testing of Chinese herbs used by TCM practitioners is not only

lacking but is generally not well understood. The 1990 Chinese

Pharmacopoeia lists herbs with safety considerations. It lists 19 herbs as

slightly toxic, 36 as toxic, and 9 very toxic. How many of the very

knowledgeable and generally impressive people on this CHA list can name HALF

of them without looking? Of the ones that you can list, what exactly is the

toxic nature of that herb and how and to what degree can it be mitigated by

preparation or proper formulation? How many TCM professionals in the US

were aware of the concerns about aristolocic acid prior to or even three

years after the 1992 events in Belgium? None? How many patent meds were

sold in the US by TCM professionals without their knowing the contents of

that product, i.e. heavy metals, coliforms, or adulterants? How many TCM

practitioners require a C of A with every batch of herbs they order? And

how many even know what target standards would be acceptable in each of the

categories listed on the C of A?

 

The answers to these and many other questions would illustrate how prepared

the TCM community is to capably shoulder the responsibility that

prescription status of TCM ingredients should require.

 

There are ways to overcome these shortcomings. Does anyone want to step

forward? Even if regulatory control of the TCM pharmacopoeia is not the

outcome it would still be a worthwhile cause.

 

Respectfully,

Stephen Morrissey OMD