AAOM: Herbal Medicine Committee Update

[Guest guest]

AAOM Herbal Medicine Committee Update

 

The long-term agenda of the AAOM Herbal Medicine Committee (HMC)

continues to be the facilitation of a separate regulatory category for

the Oriental Medicine (OM) herbal pharmacy. Your Herbal Medicine

Committee feels that having a separate category will be the strongest

option for our profession. Recent events with regard to importation and

labeling issues indicate that we must continue on this active path to a

resolution of the long-term problems our profession has been facing. We

feel that DESHEA is no longer adequate to address the problems and

challenges regarding the Chinese herbal products that we have been

using safely for many years.

 

The AAOM is a participant in the recently convened and ongoing Congress

on the Future of Traditional Herbal Medicines. This Congress was

attended by other major organizations including the American

Association of Naturopathic Physicians (AANP), the American Herbal

Products Association (AHPA), the American Herbalist Guild (AHG), the

Council of Colleges of Acupuncture and Oriental Medicine (CCAOM), the

Medicinal Herb Consortium (MHC), and the National Certification

Commission for Acupuncture and Oriental Medicine (NCCAOM). This

Congress will attempt to define a strategy for addressing future needs

of professionals utilizing an herbal pharmacopoeia.

 

As the AAOM continues to meet with the FDA, we are bringing to their

attention the ongoing problems suppliers experience with their herbs at

the American border. In addition to ephedra, other herbs under scrutiny

have recently included betel nut, trichosanthes, shen qu, and some

animal products. The Department of Health and Human Services and the

FDA issued a final regulation declaring dietary supplements containing

ephedrine alkaloids adulterated under the Food, Drug and Cosmetic Act.

What this means to the OM practitioner and to suppliers of Chinese

herbs: If the product contains the word “supplement” on the bottle and

contains ephedra, the product will not likely pass U.S. customs;

despite an exemption in the FDA ruling that allows for ephedra use by

practitioners of Asian Medicine, importation issues continue. The HMC

has determined that this importation difficulty is likely the result of

communication that is bureaucracy laden between the FDA administrative

offices and the border patrol; this speculation is based on our

positive interactions with the FDA. The AAOM continues to work

diplomatically to attempt to resolve this apparent miscommunication.

 

[Moderator's note: I still believe this last paragraph is inaccurate.

Prepared medicines containing ephedrines are banned whether they are

labeled as supplements or not. There is no other category in which to

place such products, so they are still regulated under DSHEA. In fact,

failing to label your chinese prepared medicines as supplements would

make them all illegal under current law. They MUST be labeled as

dietary supplements, so there is no loophole. Do not be duped. I

believe the litmus test for this ban is how readily available the

products are to the public. Well, pretty much every product you sell

in your offices is already being unscrupulously marketed directly to

the public over the internet. so allowing these products to be

imported is a loophole that could easily be exploited by a new wave of

weight loss experts. All they have to do is be clever about how they

word things (call ma huang a yang stimulant and you are home free,

right). that was not what the FDA intended. I commend the AAOM for

working towards the only real solution, one which should have been a

major political focus years ago when the writing on the walls was

clear. which is to create a separate regulatory category for certain

medicinals. However I would raise a possible concern I had not

considered in the past. Which is that the FDA may just reclassify all

chinese patents as a class reserved for certain lciesned practitioners.

This would mean lay herbalists would only have recourse to raw herbs

in their practices as raw herbs are exempt from DSHEA]

 

Practitioners should be aware that in recent weeks, the FDA has been

reviewing web sites for Western medical indications. Suppliers of

Chinese herbs have reported to the HMC that they have been contacted

with regard to what the FDA deems inappropriate listings of Western

indications on web sites which are intended for OM practitioners. This

may also apply to labeling, and could be an issue with customs as well.

The AAOM will endeavor to clarify these actions with the FDA in our

next meeting with them.

 

The AAOM is aware that many of our members would like to see immediate

action taken with regard to continued access to our herbal

pharmacopoeia. We would like our membership to know that we are taking

action as quickly as we can. However, administrative changes and

legislation take time. In the interim, our members can take action by

supporting your Herbal Medicine Committee. You can do this by making

donations via our administrator at 866-455-7999. You can assist by

renewing your membership when it is due and by stimulating, and

expecting, your colleagues to join you at this important juncture in

our profession's history: funds at this time will be going to the HMC

for legislative endeavors. You can also help by making personal contact

with your Senator or Representative and/or their staff.

 

One of the best ways to make contact with your Senator or

Representative is by letter, but an e-mail version is also acceptable.

For details about what to include in your letter, please go to the AAOM

web site at www.aaom.org, click on Press Room/Protecting Access to

Herbs. Additionally, all AAOM members are encouraged to contact the

AAOM legislative committee if they have any connections to legislators

or governmental personnel who might contribute to the strength of our

mission.

 

 

 

AAOM Herbal Medicine Committee

 

 

Committee Chair:

Atara Noiade, AAOM BOD

 

Committee Members:

Will Morris, AAOM BOD

Dave Molony, AAOM BOD

John Scott, CEO, Golden Flower Chinese Herbs

Claudette Baker, ISAA

John Chen, CEO, Evergreen Herbs

Christine Chang, AAOM Alternate BOD

Mark Thoman, AAOM Attorney

 

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AAOM

PO Box 162340

Sacramento, CA 95816

916-451-6950

916-451-6952 Fax

866-455-7999

info | www.aaom.org

 

 

 

 

 

 

Chinese Herbs