herbs and LHC

[Guest guest]

I have identified the following herb related issues

in the LHC report.

 

1. licensing of non-L.Ac. herb sellers - the state

may require laypersons who sell herbs to have licenses

that will require training in ID, drug/herb

interaction, etc.

 

2. required disclosures, consumer cautions and

public notices - in addition or as an alternative, the

state may require various notices be posted in places

where herbs are sold. These notices will warn the

consumer of risks and the generally unregulated nature

of the industry.

 

3. meeting 450 hour classroom requirement - this is

a lot more hours in herbs than prior and the no

double-dipping clause will be enforced strictly. that

means all the herb classes must be herbs only, not OM

classes that mention herbs in passing. This is

probably long overdue. Some schools already meet the

standard.

 

4. associated federal regs - GMP, AA, DSHEA and

trad.

asian remedies - the report raises the issues of the

definition of chinese herbs under federal law. They

acknowledge there is no conflicting evidence on how

chinese herbs are classified under federal law. This

may result in chinese herbs being restricted for sale

in the state. They could conceivably be classified by

the state (asian remedies perhaps)and restricted for

sale only by licensed herb sellers only upon

prescription by an Lac. this would effectively end

the practice of chinese herbology in CA outside our

field. This would have unintended consequences and

affect the local ethnic asian communities. Such a

model could be extended to herbology in general.

While this would have a economically protective effect

on the field, the intent is supposedly protection of

the public. However it would violate the spirit of

the recently passed health freedom act and seems

unlikely to be the route that would be supported by

the current administration in the absence of any

public need.

 

5. Purity, potency, safety issues - COA's:

the state is concerned about herb safety and makes

specific recommendations about required testing and

disclosures. This touches upon topics like toxicity

and standardization. This will make herbs more

expensive if mandatory. Advise we support voluntary

standards and required disclosures.

 

6. Reporting of adverse events - a centralized

mechanism is recommended. Very strict criteria should

be developed in order to prevent over or under

reporting. This will necessitate the development of

procedures to insure compliance and accuracy

 

7. Labeling of dispensed rx and packaged products -

use of latin botanical will be required on all

products and formulas. This will necessitate the

development of procedures and supplies to insure

compliance and accuracy

 

8. clarification of herb scope - vis a vis possible

restrictions on substances and conditions:

current law does not state clearly enough what is in

our scope. Our training only covers the therapeutic

use of chinese medicinals, but our law appears to give

us the right to use a much wider array of substances.

LHC implies that the intent could not have been to

allow us to prescribe substances for which we have no

formal training. further, any current or future

prescription of substances based upon modern or non OM

concepts without a second degree (such as ND) is

considered ill-advised. This could have major effects

on the practices of those who rely on homeopathy,

western herbs and other supplements. Since LHC does

not want us to use these susbtances based upon modern

concepts, we should lobby to expand the materia medica

with these substances based upon consensus about their

actions from an OM perspective.

 

 

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[Guest guest]

Todd

what is the UCSF study?

alon