Dispensing Code of Ethics for Chinese Medicinals

[Guest guest]

As a Fellow of the Register of Chinese Herbs in the UK, I recently

received their newly published Code of Ethics for Dispensing Chinese

Herbs. This is different from their Code of Ethics for practicing

Chinese herbal medicine. Both are good in my opinion. Who on this list

thinks it would be a good idea to have an AAOM or Alliance code of

ethics for dispensing (i.e., filling prescriptions for and selling)

Chinese herbal meds? This would include everything in terms of both QA

and ethics in training, purchasing, storage, dispensing, charging,

maintaining records, cleanliness, government compliance, disclosure

and transparency, etc.

 

We are coming under more and more scrutiny, and, I believe that, the

more we police ourselves, the better off we will be in the long run.

Seems to me, most in this profession are simply not thinking about

these kinds of issues. What d'ya think?

 

Bob

[Guest guest]

I am interested in this issue

--

Cara O. Frank, R.Ac, Dipl Ac & Ch.H.

President China Herb Company

Program Director of the Chinese Herb Program

Tai Sophia Institute for the Healing Arts

office: 215- 438-2977

fax: 215-849-3338

Www.chinaherbco.com

Www.carafrank.com

 

 

 

 

Bob Flaws <pemachophel2001

 

Wed, 19 Jul 2006 15:15:27 +0000

 

Dispensing Code of Ethics for Chinese Medicinals

 

 

 

 

 

As a Fellow of the Register of Chinese Herbs in the UK, I recently

received their newly published Code of Ethics for Dispensing Chinese

Herbs. This is different from their Code of Ethics for practicing

Chinese herbal medicine. Both are good in my opinion. Who on this list

thinks it would be a good idea to have an AAOM or Alliance code of

ethics for dispensing (i.e., filling prescriptions for and selling)

Chinese herbal meds? This would include everything in terms of both QA

and ethics in training, purchasing, storage, dispensing, charging,

maintaining records, cleanliness, government compliance, disclosure

and transparency, etc.

 

We are coming under more and more scrutiny, and, I believe that, the

more we police ourselves, the better off we will be in the long run.

Seems to me, most in this profession are simply not thinking about

these kinds of issues. What d'ya think?

 

Bob

 

 

 

 

 

 

 

[Guest guest]

Me as well.

 

 

On Jul 19, 2006, at 9:58 AM, Cara Frank wrote:

 

> I am interested in this issue

> --

> Cara O. Frank, R.Ac, Dipl Ac & Ch.H.

> President China Herb Company

> Program Director of the Chinese Herb Program

> Tai Sophia Institute for the Healing Arts

> office: 215- 438-2977

> fax: 215-849-3338

> Www.chinaherbco.com

> Www.carafrank.com

>

>> .

>

>

 

 

 

 

[Guest guest]

, " Bob Flaws "

<pemachophel2001 wrote:

Who on this list

> thinks it would be a good idea to have an AAOM or Alliance code of

> ethics for dispensing (i.e., filling prescriptions for and selling)

> Chinese herbal meds? This would include everything in terms of

both QA

> and ethics in training, purchasing, storage, dispensing, charging,

> maintaining records, cleanliness, government compliance, disclosure

> and transparency, etc.

 

At the very least, I think that practitioners should be informed

about the identity and dose of the medicinals that they are

prescribing. We've made a lot of progress as a group in terms of

spreading awareness about proper species differentiation for meds

like sheng ma, wang bu liu xing, fang ji, bai tou weng, etc.

 

Although we are not too far off track in terms of identity issues,

the profession as a whole remains woefully uninformed on the issue

of dosage. This is particularly obvious in granule dispensing.

Here, I'm not referring to the fact that some of us are talking

about using teaspoons while others are using tablespoons, I'm

talking about a basic awareness of how many grams of raw herbs were

cooked down into the powder that we just gave to our patient.

 

Many of our granules are made in Taiwan. The Taiwanese label to the

identical product has a very clear breakdown of the exact extraction

ratio, allowing practitioners to know exactly how much of each

medicinal they are prescribing. Inexplicably, the same companies

omit this data for their US distribution, presumably because it is

not required by law. As a result, no one knows whether extract A is

4.3:1 and extract B is 6.2:1, we just round it all off to 5:1 for

convenience and thank our lucky stars that we rarely have to explain

to lawyers or scientists the fact that we don't really know exactly

how much fu zi we prescribed yesterday.

 

I'm surprised that practitioners do not demand this data from the

granule distributors. It doesn't require any new testing or

expense, and there is really no excuse for the lack of

transparency. Instead of simply having clear labels so that we can

discuss our dose preferences accurately, we spend time debating dose

ranges as though there was something to debate, instead of just

having granular dose ranges that are a reflection of our raw

dispensing habits. We don't need to re-invent the wheel by having

every practitioner slowly accrue enough experience to " get a feel "

for the efficacy of granules at a given dose range, we should be

able to simply look at the box and say " I gave them four 1 gram

scoops, so they have ingested 6.4 grams of fu ling in their formula

today. "

 

In my mind, Blue Poppy is the only US herb company that is truly

giving their customers transparency at this time. All the big

Taiwanese companies could easily provide transparency, but for

whatever reason they choose not to in the US market. An informal

survey of the labels quickly shows that the new Blue Poppy products

can be clearly traced back to their raw dose equivalents, while most

of the other companies seem to require estimation based on data that

isn't clearly provided. I've also happily noticed clarity and

transparency on some of Andy Ellis' tablet formulas, which I have

seen distributed through Golden Flower (and maybe others?). But

some of the liquid extracts on the market give very little

information, and when you dig for the info, you sometimes discover

that the patient should be drinking one or two whole bottles a day

to approximate a raw dose.

 

I don't have any association with any of the companies nor do I have

any strong opinions about the quality, but I do advocate the notion

of transparency so that we can dose accurately. As far as dose

goes, if people insist on giving doses by the teaspoon or gelcap,

Blue Poppy is probably the best bet because their products tend to

have the highest concentration on the market at this time. A high

concentration is needed if one is using gelcaps and telling their

patients that they are receiving mainstream Chinese medicine. I've

also seen good results with Andy Ellis' tablets; I wouldn't

personally like to swallow 20 tablets a day (I prefer powder), but

if the patient does, the results are totally satisfactory.

 

Anyway, yes, transparency please. No one wants their MD giving

drugs by the scoop with no label to assess the dose. Granted, many

traditional medicinals have a wide margin of safety and efficacy,

but there is still no excuse to not be able to trace back the dose

when using extracts.

 

Eric

[Guest guest]

Seems there are a few (predictable) people interested in an American

dispensing code of ethics. Let me see if there is a digital version of

the RMCH code at their website. If so, I will post it here for review

and discussion.

 

However, if we were to decide to do something about this, what would

our steps be? How could we make this a reality?

 

Bob

 

P.S. Thanks for the endorsement Eric. Everyone else please know that

Eric is not a Blue Poppy ringer. I wish he were!

[Guest guest]

Bob,

I would be certainly interested in looking at the RMCH code of

ethics. As far as making this a reality, I think CHA could adapt a

group position/statement on this issue. Other than that, I think a

consortium of herb companies in America and Europe to develop common

standards and ethics is an idea long overdue.

 

 

On Jul 19, 2006, at 11:39 AM, Bob Flaws wrote:

 

> Seems there are a few (predictable) people interested in an American

> dispensing code of ethics. Let me see if there is a digital version of

> the RMCH code at their website. If so, I will post it here for review

> and discussion.

 

I

>

> However, if we were to decide to do something about this, what would

> our steps be? How could we make this a reality?

>

> Bob

>

> P.S. Thanks for the endorsement Eric. Everyone else please know that

> Eric is not a Blue Poppy ringer. I wish he were!

>

>

>

 

 

 

 

[Guest guest]

I would also like to see it. Tai Sophia has a fairly comprehensive training

manual, as they also have the botanical program there. And Simon Mills ( UK)

is the director of the program. I could ask if I can share it.

 

CAra

--

Cara O. Frank, R.Ac, Dipl Ac & Ch.H.

President China Herb Company

Program Director of the Chinese Herb Program

Tai Sophia Institute for the Healing Arts

office: 215- 438-2977

fax: 215-849-3338

Www.chinaherbco.com

Www.carafrank.com

 

 

 

 

<zrosenbe

 

Wed, 19 Jul 2006 11:48:06 -0700

 

Re: Re: Dispensing Code of Ethics for Chinese Medicinals

 

 

 

 

 

Bob,

I would be certainly interested in looking at the RMCH code of

ethics. As far as making this a reality, I think CHA could adapt a

group position/statement on this issue. Other than that, I think a

consortium of herb companies in America and Europe to develop common

standards and ethics is an idea long overdue.

 

 

On Jul 19, 2006, at 11:39 AM, Bob Flaws wrote:

 

> Seems there are a few (predictable) people interested in an American

> dispensing code of ethics. Let me see if there is a digital version of

> the RMCH code at their website. If so, I will post it here for review

> and discussion.

 

I

>

> However, if we were to decide to do something about this, what would

> our steps be? How could we make this a reality?

>

> Bob

>

> P.S. Thanks for the endorsement Eric. Everyone else please know that

> Eric is not a Blue Poppy ringer. I wish he were!

>

>

>

 

 

[Guest guest]

I think it would be a good idea.

 

 

On Behalf Of Bob Flaws

Wednesday, July 19, 2006 8:15 AM

 

Dispensing Code of Ethics for Chinese Medicinals

 

 

 

As a Fellow of the Register of Chinese Herbs in the UK, I recently

received their newly published Code of Ethics for Dispensing Chinese

Herbs. This is different from their Code of Ethics for practicing

Chinese herbal medicine. Both are good in my opinion. Who on this list

thinks it would be a good idea to have an AAOM or Alliance code of

ethics for dispensing (i.e., filling prescriptions for and selling)

Chinese herbal meds? This would include everything in terms of both QA

and ethics in training, purchasing, storage, dispensing, charging,

maintaining records, cleanliness, government compliance, disclosure

and transparency, etc.

 

We are coming under more and more scrutiny, and, I believe that, the

more we police ourselves, the better off we will be in the long run.

Seems to me, most in this profession are simply not thinking about

these kinds of issues. What d'ya think?

 

Bob

 

 

 

 

 

 

 

[Guest guest]

, " Bob Flaws "

<pemachophel2001 wrote:

> P.S. Thanks for the endorsement Eric. Everyone else please know that

> Eric is not a Blue Poppy ringer. I wish he were!

 

Actually, I use the Taiwanese stuff personally. I like the

transparency and the potency of the Blue Poppy products, I am just in

the habit of using classical formulas with additions or mixing

singles. The style that I am most comfortable with requires a full

array of singles and unaltered classical formulas, so as a consumer my

needs are better met by the large Taiwanese companies that stock

everything under the sun. But if we are talking about labelling,

clarity, potency, etc, then I wish that more companies would follow

the Blue Poppy model, including the Taiwanese companies that I use on

a regular basis.

 

I personally buy stuff based on the ratio of potency to cost, assuming

that the quality of the raw ingredients is comparable. I have

discovered that it is cheaper for me to buy a month supply of granules

in Taiwan, then express mail them to a patient in the US than it is to

order the same thing from a distributor located 50 miles from the

patient's home. Even if the express shipping from Asia costs 35

bucks, the margins of the US distributors are so much higher than the

Taiwanese bulk rate that the patient saves money overall. While the

Taiwanese products do provide the precise dosage on the labels, their

labels tend to use the atrocious pinyin-like Romanization that is

supported by the Taiwanese government, so the labels would be a

tremendous nuisance for someone who doesn't read Chinese and is used

to standard PRC pinyin.

 

Eric

[Guest guest]

Eric,

 

When you need to add a couple of singles to a classical formula, who in Taiwan

would mix them for you/patients? The distributor, or a local connection?

 

Mike L.

 

Eric Brand <smilinglotus wrote:

, " Bob Flaws "

<pemachophel2001 wrote:

> P.S. Thanks for the endorsement Eric. Everyone else please know that

> Eric is not a Blue Poppy ringer. I wish he were!

 

Actually, I use the Taiwanese stuff personally. I like the

transparency and the potency of the Blue Poppy products, I am just in

the habit of using classical formulas with additions or mixing

singles. The style that I am most comfortable with requires a full

array of singles and unaltered classical formulas, so as a consumer my

needs are better met by the large Taiwanese companies that stock

everything under the sun. But if we are talking about labelling,

clarity, potency, etc, then I wish that more companies would follow

the Blue Poppy model, including the Taiwanese companies that I use on

a regular basis.

 

I personally buy stuff based on the ratio of potency to cost, assuming

that the quality of the raw ingredients is comparable. I have

discovered that it is cheaper for me to buy a month supply of granules

in Taiwan, then express mail them to a patient in the US than it is to

order the same thing from a distributor located 50 miles from the

patient's home. Even if the express shipping from Asia costs 35

bucks, the margins of the US distributors are so much higher than the

Taiwanese bulk rate that the patient saves money overall. While the

Taiwanese products do provide the precise dosage on the labels, their

labels tend to use the atrocious pinyin-like Romanization that is

supported by the Taiwanese government, so the labels would be a

tremendous nuisance for someone who doesn't read Chinese and is used

to standard PRC pinyin.

 

Eric

 

 

 

 

 

 

 

 

Get on board. You're invited to try the new Mail Beta.

 

 

[Guest guest]

, Mike Liaw <mikeliaw

wrote:

>

> Eric,

>

> When you need to add a couple of singles to a classical formula,

who in Taiwan would mix them for you/patients? The distributor, or a

local connection?

 

I don't do it in any significant quantity or with any significant

frequency. There are a few people that I send stuff to, but fairly

simple combinations and on such a small scale that it is never an

issue. Usually I just send them whole bottles and have them mix it in

the proper ratio.

 

Eric

[Guest guest]

, " Eric Brand "

<smilinglotus wrote:

>

We've made a lot of progress as a group in terms of

> spreading awareness about proper species differentiation for meds

> like sheng ma, wang bu liu xing, fang ji, bai tou weng, etc.

>

 

Eric, exactly what progress has been made? Is there something in the

archives about this?

 

Tom.

[Guest guest]

, " Tom Verhaeghe "

<tom.verhaeghe wrote:

We've made a lot of progress as a group in terms of

> > spreading awareness about proper species differentiation for

meds

> > like sheng ma, wang bu liu xing, fang ji, bai tou weng, etc.

> >

>

> Eric, exactly what progress has been made? Is there something in

the

> archives about this?

 

I'm not speaking so much about CHA, I am speaking more about general

progress in the Western CM community. The aristolochic acid issues

have highlighted a number of items, and widespread publicized input

from pharmacy experts like Andy Ellis has brought other things to

light. Tom, I know that you are in Europe and I don't know how much

awareness there is in Europe about these species issues, so I

suppose that my comments have more to do with trends in the US

because they are easier for me to see. When I say that progress has

been made, I mean that more practitioners are aware of the correct

species of these herbs, and more herbal suppliers have taken steps

to reflect this awareness. The prominence of this issue is such

that the new Bensky text has made a special point of devoting a lot

of attention to the topic of species and substitutes. Erich Stoger,

a specialist in this area, made some invaluable contributions to the

Bensky text in this regard.

 

Eric

[Guest guest]

Here in the state of Victoria, Australia, the g'vment registration board

offers registration in three divisions (acupuncture, herbs and

dispensing) Seems logical, yes? Well, last time I checked, however, I

noted with interest that nobody had actually registered for dispensing.

For more info see:

http://www.cmrb.vic.gov.au

Regards,

Lea.

 

, " Bob Flaws "

<pemachophel2001 wrote:

>

> As a Fellow of the Register of Chinese Herbs in the UK, I recently

> received their newly published Code of Ethics for Dispensing Chinese

> Herbs. This is different from their Code of Ethics for practicing

> Chinese herbal medicine. Both are good in my opinion. Who on this

list

> thinks it would be a good idea to have an AAOM or Alliance code of

> ethics for dispensing (i.e., filling prescriptions for and selling)

> Chinese herbal meds? This would include everything in terms of both

QA

> and ethics in training, purchasing, storage, dispensing, charging,

> maintaining records, cleanliness, government compliance, disclosure

> and transparency, etc.

>

> We are coming under more and more scrutiny, and, I believe that, the

> more we police ourselves, the better off we will be in the long run.

> Seems to me, most in this profession are simply not thinking about

> these kinds of issues. What d'ya think?

>

> Bob

>

[Guest guest]

Here's the RCHM's dispensing code of practice:

 

Register of Chinese Herbal Medicine

 

Dispensary Codes of Practice

 

These Codes of Practice are intended as a guide to good dispensary

practice in anticipation of Statutory Self-Regulation. Drug

pharmacies are regulated by strict protocol and whilst we are not

trying to copy these, there are several matters in relation to herb

audit which should be followed. The Codes are not a detailed handbook

for dispensary procedures but they do form a blueprint for looking at

areas of training and upgrading of your dispensary practice.

 

Dispensary Layout

 

The external appearance of a herbal dispensary should inspire

confidence in the nature of the healthcare provided.

 

The premises should be kept clean and in good repair so as to enable

effective cleaning. Surfaces should be washable and joints sealed.

 

A defined area should be given for recalled products where there have

been adverse herb reactions or quality problems.

 

Storage of Herbs

 

Herbs should be stored in airtight containers unless specified that

ventilation is required in the Pharmacopoeia. This prevents

deterioration and insect infestation.

Storage should be away from sunlight, heat and moisture. Ideally the

temperature of the dispensary should remain constant and cool.

 

The quality of herbs should be regularly monitored and a system of

stock rotation established to ensure that herbs are not dispensed when

degraded through age or poor storage. Herbs subject to moulds such as

fruits and grains should be discarded after their assigned sell by date.

 

Responsible Person

 

There should be a single person responsible for dispensary standards.

If the practitioner is also dispenser this is simple, but there can be

confusion when using an external dispensary service.

 

Although the dispenser is seen as the responsible person in all

matters relating to dispensary practice, the practitioner has the

responsibility in choosing a dispenser with adequate training to carry

out the task.

 

Practitioners must be aware of all regulations and codes relating to

dispensary practice even if they do not carry out the dispensing

themselves.

 

Standards of Training and Development

 

The person dispensing should have adequate training for the task. In

effect the dispenser must either be a trained herbalist or have

received training of a suitable standard such as the RCHM Dispensary

Course or equivalent.

 

The dispenser must be familiar with all procedures relating to

dispensary practice including record keeping and labelling as

indicated in these codes.

 

There should be a system for rapidly updating the work of the

dispenser to allow for changes in legislation or Codes of Practice as

these occur. Changes will be communicated directly to the herbalist by

the RCHM. Practitioners should ensure that such information is

transferred to the dispenser.

 

The herbalist should ensure that adequate written reference material

is available for reference including up to date information on herb

safety/restrictions and drug interactions.

 

Legal Requirements

 

Herbs listed under paras II and III of Statutory Instrument SI

1977/2130 should be isolated physically in a secure storage area and

herb use recorded in a ledger.

 

No substance should be used which is included in the RCHM Restricted

Substances List.

 

Under the 1968 Medicines Act, it is not necessary to have a product

licence for a herbal remedy that is dispensed following a one to one

consultation, and is manufactured or assembled on premises from which

the public can be excluded. It is also unnecessary to have a product

license for herbal products (which includes tablets/tinctures/creams),

where these only specify the herbs and the process to which they have

been subjected, and make no written recommendation as to the use of

the remedy.

 

The provisions of the 1968 Medicines Act relating to herbal remedies

are currently under review and you will be expected to comply with any

changes in the legislation as they occur, following notification by

the RCHM.

 

Where the practitioner or dispenser is preparing products for direct

sale to the general public without individual consultation then

additional rules apply under the Sale of Goods Act to ensure that

products meet the appropriate quality standards.

 

Health and Safety

 

Dispensary staff should be protected by a contract, which offers

appropriate insurance cover. There should be a Health and Safety

Policy in place to protect the health of the dispenser. This should

include protection from dust (especially when working with

Concentrated Powders) and training in relation to any toxic or

potentially dangerous herbs/chemicals or equipment used in the dispensary.

 

Dust levels in the dispensary should be closely monitored and

appropriate measures taken to protect the health of the staff and

ensure that dust is not a source of contamination.

 

Hygiene

 

An adequate washing area is required for utensils and storage

containers. Cream making equipment should be washed separately. The

toilet facility should include hot water, soap, nailbrush and hand

drying facility. Toilets should not open directly onto the dispensary.

 

Personal hygiene by the dispensary staff should be ensured. A suitable

dressing must cover cuts and abrasions. The use of nail varnish or

cosmetics is not recommended. Long hair should be tied back.

 

Handling of herbs should be kept to a minimum preferably by wearing

gloves. This is essential when working with gelatine or where the herb

product is not going to be boiled.

 

The Prescription

 

The prescription is defined as the herbal formula prescribed by the

practitioner and passed to the dispenser. This can either be integral

with the case notes, or a separate sheet faxed to the external

dispensary service.

 

Verbal communication of a prescription is prone to many errors of

pronunciation.

 

Prescriptions for dried herbs should be in written form and clearly

legible. It is good practice to include the herb code as well as the

pinyin when dealing with an external dispensary service. An external

dispensing service is one where the herbs are given or sent to a

patient by a dispensary other than the herbalist own dispensary.

 

Practitioners should satisfy themselves that the quality of the

external dispensary is adequate and that systems are in place which

will enable herbalists to ensure that a verifiable audit trail exists.

 

The practitioner and the dispenser should both sign the prescription.

 

Each prescription should be identified individually with a reference

number or date to allow for tracking in the case of reaction. This

reference number should be put on all bags of herbs in the

prescription given to the patient.

 

Similarly, when giving herbs as tablets or tincture, the patients

should have the appropriate batch number and date on the dispensed item.

 

Record Keeping

 

It is recommended that the dispensary should operate adequate audit

trail procedures to allow tracking of herbs from the supplier to the

patient. This includes changes of batch numbers on herbs in relation

to individual prescriptions. The RCHM does have a simple card system

to allow this, available from the RCHM office. In the case of any

adverse reactions, which need to be reported, it is expected that the

practitioner can rapidly indicate which herbs were in the

prescription, including their batch numbers from the supplier.

 

All records should be retained.

 

Dispensing Procedure

 

Where staff other than the practitioner are engaged in dispensing,

written procedures should be in place detailing dispensary procedure.

 

An agreed procedure should be in place between the herbalist and the

dispenser in the case of confusion in the prescription or lack of

available herbs to complete the prescription.

 

Weighing and Measuring Procedures

 

For concentrated powders, scales should be accurate to 0.1gms. Scales

should be regularly calibrated.

 

When weighing a dried herb prescription it is good practice to use a

double-checking procedure. This could be weighing all the completed

bags at the end of dispensing.

 

The quality of herbs should be regularly monitored and a system of

stock rotation put into operation. The shelf life of herbs has not

been specified in these Codes. However, herbs should be examined for

signs of degradation, in particular fruits and moist herbs.

 

Products for External Use

 

The manufacture and storage of creams and ointments for external use

needs particular care to avoid bacterial growth and other contamination.

 

These should be prepared in a dedicated area using equipment which can

be thoroughly cleaned. A board and pallet knife should be used rather

than vessels with corners. It is inadvisable to recycle jars for

creams and ointments.

 

Base materials should be of pharmaceutical grade and the containers

should not react with the active ingredients or additives.

 

A heating process in the manufacture is beneficial but not a

guarantee of microbial quality. A preservative should be added and

care taken when diluting a cream which will reduce the shelf life or

impair the stability of the preparation even though no physical change

may be apparent. The shelf life is dependent on the ingredients used

and must be indicated on the product. Normally this is a maximum of

1-2 months. For this reason dispensed items should be made up for

individual patients and not made in large batches and stored.

Manufacture on a larger scale will require more stringent quality

control measures. On a large scale this would include microbial

testing of the product.

 

All equipment should be thoroughly cleaned after use in hot water and

detergent and rinsed. Equipment for creams and ointments should be

washed separately from other items in the dispensary.

 

Labelling

 

All individual herb products in storage should be clearly labelled.

These should preferably be in both pinyin and Latin (including part of

plant used). The batch reference should also be indicated.

 

When breaking bulk, the batch information needs to be transferred to

herb products.

If there is no batch on the product from the supplier, then use the

date of arrival in your dispensary.

 

All products given to patients should include the name and contact

phone number of the dispenser and information such as the prescription

reference number to allow tracking. The date of dispensing should also

be indicated.

 

When labelling jars, the information should be put on the jar and

never on the lid.

 

It is not necessary to list all the herbs in the prescription as long

as there is a reference number on the bags, which can be traced to the

prescription.

 

Suppliers of Herb Products

 

The RCHM is producing a list of Approved Suppliers who have been

inspected by independent auditors using guidelines laid down by the

RCHM. All suppliers on this list will have demonstrated a commitment

to ensuring the quality and authenticity of herbal supplies. You are

strongly recommended to use suppliers who are on this list.

[Guest guest]

Z'ev,

 

" I think a consortium of herb companies in America and Europe to

develop common standards and ethics is an idea long overdue. "

 

I think that's a separate issue. Here we're talking about

practitioners dispensing herbal medicines. So it needs to be a

practitioner-based initiative.

 

That being said, I agree that there should be a trade association of

Chinese herbal companies with its own code of ethics. There already is

APHA. However, they don't have a code of ethics. In addition, the

FDA's GMP regulations are supposed to be implemented soon. In terms of

the herb manufacturers, those GMPs will go a long way towards setting

better standards within the industry. Still, GMPs are not a code of

ethics.

 

Interestingly, having a code of ethics separate from governmental laws

is one of the defining characteristics of a profession as opposed to a

trade.

 

Bob

[Guest guest]

Hi Bob et al,

 

Here is AHPA¹s Code of Ethics :

 

AHPA's Code of Ethics

 

³AHPA members are required to comply with a Code of Ethics & Business

Practices and to adhere to all of its policies and principles. This Code of

Ethics was adopted by the membership and so reflects the ethics of the

responsible center of the herbal products trade.

The Code can be revised by the adoption of trade recommendations to which

conformity is required to maintain membership. Over the years AHPA has

actively pursued the adoption of specific trade recommendations that serve

to provide informed guidance for the herbal industry. These policies are

developed when it is determined that a significant body of evidence

warrants, for example, labeling or manufacturing standards beyond those

mandated by the federal laws that govern herbal supplements. By taking

responsibility for our own business practices, AHPA and its members can

ensure that those practices are informed by experience.²

 

 

Please link to AHPA¹s Code of Ethics at

http://www.ahpa.org/Default.aspx?tabid=129 & aId=263 & zId=13

 

 

Bill Egloff

Crane Herb Co.

Crane Herb Pharmacy

 

 

 

 

 

 

[Guest guest]

Bill,

 

Thanks. I didn't know APHA has a code of ethics. Thanks for posting it

for all to see. As an extension of this, practitioners who value

ethics and QA (quality assurance) should ask their herb suppliers A)

if they are an APHA member and, 2) if not, why not. Personally, I

would recommend buying ready-made Chinese medicine only from AHPA

members. In other words, vote with your pocketbook.

 

Bob

 

, William Egloff <bill

wrote:

>

> Hi Bob et al,

>

> Here is AHPA¹s Code of Ethics :

>

> AHPA's Code of Ethics

>

> ³AHPA members are required to comply with a Code of Ethics & Business

> Practices and to adhere to all of its policies and principles. This

Code of

> Ethics was adopted by the membership and so reflects the ethics of the

> responsible center of the herbal products trade.

> The Code can be revised by the adoption of trade recommendations to

which

> conformity is required to maintain membership. Over the years AHPA has

> actively pursued the adoption of specific trade recommendations that

serve

> to provide informed guidance for the herbal industry. These policies are

> developed when it is determined that a significant body of evidence

> warrants, for example, labeling or manufacturing standards beyond those

> mandated by the federal laws that govern herbal supplements. By taking

> responsibility for our own business practices, AHPA and its members can

> ensure that those practices are informed by experience.²

>

>

> Please link to AHPA¹s Code of Ethics at

> http://www.ahpa.org/Default.aspx?tabid=129 & aId=263 & zId=13

>

>

> Bill Egloff

> Crane Herb Co.

> Crane Herb Pharmacy

>

>

>

>

>

>

[Guest guest]

" Here in the state of Victoria, Australia, the g'vment registration

board offers registration in three divisions (acupuncture, herbs and

dispensing). "

 

Same three divisions as in most CM colleges and unviersities in China.

 

Bob