Guest guest Posted February 18, 2004 Report Share Posted February 18, 2004 Hi All, & Hi Chris, Phil wrote: > I have argued that the labels of all CHM formulas [indeed, all > medicines and health supplements] should display the % of all raw > ingredients used. I did not include " fillers (starch, etc) in my > original note, but I include it here. Chris [TCM List] replied: > ... why [settle for] the percentage of ingredients? Why not [use] > mgs [instead]???? Virtually all supplements already list ingredients > in mgs. I believe it will be a better idea to conform our standards > to what is already out there. Less confusion. IF you insist we > label our stuff. Go for mgs. Please. Chris Chris, you are correct. I accept your point fully. Next summer, there will be a large (circa 1000 delegate) conference in TCM in Manchester, England. A proposed Brain- storming workshop [probable, but not yet confirmed] will be on the topic: " The future of TCM in western nations increasingly obsessed with regulation and " Evidence-Based-Medicine " . I am proposing the following Subtopics, and am trying to cobble together some points as discussion-openers to guide the brainstorming as below. I WOULD APPRECIATE CONSTRUCTIVE CRITICAL COMMENT UNDER ANY OR ALL HEADINGS: (a) How should the TCM professions tackle the hypocrisy (double standards) of the FDA & EU attitudes to Safety, Efficacy & Quality- Control of medicines and supplements when applied to herbal mediicines and homeopathic remedies? [To be filled in later, but using concepts of " level-playing-field " and highlighting the extent of iatrogenic disease caused by PERMITTED (non-banned) allopathic drugs, tobacco, alcohol, cars and " high-risk-sports. Why does FDA/EU not ban THOSE? They kill and maim more people each year than all of integrative medicine combined!] (b) How can TCM professionals foster precise and accurate labelling of Chinese Herbal Medicines & Supplements ( " Product Batches - PBs " )? Ideally, the label and/or data sheet with each PB would list (in Hanzi, Pinyin & the Language of the importing Country): Manufacturer's name and contact details, Product Name PB code, date of manufacture, & " use by " date, Min, Max and Mean daily dose and instructions for use Min & Max recommended duration of use, Known and potential adverse-effects, Known and potential interactions with allopathic medications, Contraindications or cautions, Procedure recommended if an adverse reaction should arise, etc Each PB should certify the amounts in the recommended daily dose of: each raw ingredient, filler and binder (in mg on a DM basis), and the nature and amount of each liquid vehicle or solvent (water, alcohol, etc) in ml. [Chris! I have taken your point!] To ensure a high degree of quality control, each PB should certify the amount of the most important active agents (for example, artemisin, ephedrine, ginkgolide, saikosaponin, ginsenoside, salidroside & rosavin, etc) in ug or mg in the daily dose. © How can TCM Professionals tackle the problem of unlisted ingredients in Chinese Herbal Medicines? All manufacturing plants should be licensed by their Government to produce each Product sold under standards of international GMP. The Government of the Country of Manufacture should police the Quality Control strictly and penalise heavily any factory that adds unlisted ingredients. (d) Can TCM professionals persuade Asian manufacturers and Governments to flag Hbs & Formulas known to contain toxic or potentially toxic contaminants or agents, like AA, Hg, As, Pb, etc? Can we propose a comprehensive and " agreed " list of suitable alternatives that match ALL the actions of discarded ingredients of existing Asian formulas? Each PB should certify bacterial- (coli, salmonella, staphs & strepts, etc) and heavy metal- (Cd, As, Hg, Pb, F, etc) levels and display the acceptable international levels for comparison. The Host Government should confiscate and destroy PBs that breach pre-agreed safety standards. Specific PBs that breach the safety standards of the Receiving Government ahould not be exported to that Country. (e) Can TCM professionals persuade Asian manufacturers and Governments to flag raw materials & Formulas known to contain human tissues or products (hair, placenta, umbilical cord, urine sediment, calculi, etc)? The Host Government should ban the inclusion of human or primate tissues or products in PBs for export and should enforce special labelling on such products if they are to be used at home. Where human or primate tissues are thought to be important to the action of the PB, the trade should include suitable alternatives to match ALL the actions of discarded ingredients. (f) Can TCM professionals persuade Asian manufacturers and Governments flag raw materials & Formulas containing animal tissues or products, especially those from endangered species (tiger, rhino, seahorse, etc), or tissues/products from animals treated in inhumane ways (bear-bile, dog/otter/seal genitals, etc), or harvested and processed in ways that fail to match standards of Food Safety imposed by FDA and EU Authorities? [To be discussed] Where animal tissues are thought to be important to the action of the PB, the professionals should agree a comprehensive list of suitable alternatives for inclusion to match ALL the actions of discarded ingredients. (g) Because high quality software to handle machine translation of Hanzi or Pinyin script to English and other non-Asian languages will be unavailable for several years, how can we make TCM Terminology readily available in DIGITAL form, so that users can search WWW or databases under Chinese (Hanzi), Japanese and Chinese characters, Pinyin (toned and untoned), Wade-Gilles, common names in English and/or Latin terms, etc? [To be discussed] (h) How can we foster high-quality research, especially well controlled clinical research, in Acupuncture & Chinese Herbal Medicine in human and animal subjects? [To be discussed] etc. If you have bright ideas, I would love to hear them. If you see major raasons why my initial suggestions may not be feasable, please spell them out! Best regards, Phil PS: My plea for help with the files on TCM Terminology went down like a lead balloon; Al, you are the only one left that is willing to help! Best regards, Email: < WORK : Teagasc Research Management, Sandymount Ave., Dublin 4, Ireland Mobile: 353-; [in the Republic: 0] HOME : 1 Esker Lawns, Lucan, Dublin, Ireland Tel : 353-; [in the Republic: 0] WWW : http://homepage.eircom.net/~progers/searchap.htm Quote Link to comment Share on other sites More sharing options...
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