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Attilio,

 

To clear up several misconceptions:

 

The UK has placed its entire common law system of governance at risk

by joining the EU, which is dominated by countries with Napoleanic

code legal systems, which is in turn derived from the tradition of

feudalism - the idea that one must obtain explicit permission from

the manor lord to do almost anything. The common law tradition (a

natural person is free do almost anything unless it violates the

rights or property of another) is alive and well in many countries

around the world, and Britain's recent decision to join the EU has

little effect on these other countries. The USA seceded from Britain

in 1775, and at that point its legal system began to diverge from

Britain's. Britain's joining the EU may have dire consequences for

British herbalists, who must now tremble at the thought of EU

bureaucrats' desires to micromanage their professions. But it will

have no direct effect on the USA and other former members of the

British Commonwealth.

 

After reading

http://www.chinesemedicinetimes.com/section.php?xSec=132

I have several questions and comments.

 

The aristolochia debacle in Belgium seems to have triggered quite a

storm. But there are several things about this that strike me as

being illogical. Licensed medical doctors were responsible for

perpetrating this atrocity, when they chose to use a Chinese herb

that they did not investigate thoroughly. Moreover, they combined it

with a veritable witches' brew of other toxic herbs and drugs. It

seems the only things they forgot to include were arsenic and

strychnine. Since ***licensed medical doctors*** were responsible for

this, why does the EU wish to punish everyone else??? Why not go

after the culprits directly and insist that if licensed medical

professionals wish to branch out into topics beyond their training,

that they obtain training, or at the very least, document that they

have read books on the subject? Is that really too much to ask?

 

I would find it very interesting to know what was going on in the

minds of these doctors. Were they so cocky and arrogant that they

assumed that with their advanced degrees in medicine that they could

tackle a new subject without reading the basics, like basic

toxicology and contraindications data in any TCM materia medica? Or

rather than arrogance, was it a naive trust that because it was

available for sale in the EU, that it must be safe - after all, the

government, in its omniscient wisdom, would never allow anything

unsafe to be sold, would it?

 

Regarding the topic of regulation, even benign and beneficial

regulation, it is human nature to become complacent and expect that

the government will protect them from all of life's dangers. (What I

find even more preposterous is only 60 years after the decline of the

Third Reich, Europeans seem to have forgotten how government

bureaucrats can suddenly turn evil.) A few years ago I was hiking in

Glacier National Park, which is famous for its grizzly bears. They

are dangerous and have been known to eat people. I was astounded to

hear a tourist explain to her children not to be afraid of the bears,

because if they were really dangerous, the government would not allow

them to roam wild! I interrupted, explaining that they were indeed

dangerous, and that there were certain things one does not do around

grizzly bears, and that this really was a wilderness and not an

amusement park. I held my tongue, however, when it came to the

subject of government regulation.

 

In the U.S., western herbalists are much better versed in the herbal

history than their TCM counterparts. In 1909-10 the Flexner

Commission was responsible for destroying the herbal tradition in the

U.S. for at least the next half century. It was accomplished through

a combination of withholding accreditation from medical schools that

continued to teach plant pharmacy (herbal medicine), by increased

state licensing of health professions, by prosecution of herbalists

who strayed into the legal territory of practicing medicine (by

making explicit medical claims, doing medical diagnosis, and by

allowing others to call themselves " doctor " ), and by increasing the

power of the FDA. Most western herbalists are by now familiar with

this history and know these tricks of the legal system. TCM

herbalists are behind the curve on this and need to bone up.

 

A few years ago I wrote an extensive paper on the subject of common

problems in herbal regulation, delivered at a conference at UC

Berkeley. Also attending were academics from Asia and South America.

I rewrote the article several times to incorporate suggestions and

criticisms from these other attendees.

Why not read it before you assume that mandatory regulation is the

best answer to various abuses? In it I specifically discuss the

aristolochia incident, as well as other regulatory examples (like

Proposition 65 re heavy metal contamination of herbs in California)

that illustrate the law of unintended consequences - how regulation

can backfire and result in consequences that may sometimes worsen the

very problems it was written to address.

 

http://www.rmhiherbal.org/review/2003-2.html

Orwellian schemes for maximizing health-care industry profits - How

these endanger the practice of herbal medicine

 

I'll end with quote from an ancient Roman statesman:

" A bureaucrat is the most despicable of men, though he is needed as

vultures are needed, but one hardly admires vultures whom bureaucrats

so strangely resemble. I have yet to meet a bureaucrat who was not

petty, dull, almost witless, crafty or stupid, an oppressor or a

thief, a holder of little authority in which he delights, as a boy

delights in possessing a vicious dog. Who can trust such creatures? "

-- Marcus Tullius Cicero

 

 

---Roger Wicke PhD

Rocky Mountain Herbal Institute

website: http://www.rmhiherbal.org/

email: http://www.rmhiherbal.org/contact/

 

 

 

On 2006.Dec.27, at 09:29, wrote:

 

> 1d. Re: earnings/potential of TCM herbology

> Posted by: " " attiliodalberto

> attiliodalberto

> Tue Dec 26, 2006 8:51 am ((PST))

>

> Roger, Bill and All,

>

> I see, so the US law is largely based on Anglo-Saxon common law. I

> read somewhere that herbalists in the UK where protected by a law

> introduced by Henry VIII, although i can't say that's for sure.

>

> What i do know, is that this English common law is no longer. A new

> European directive has been introduced which rides over it. This new

> European directive will be fully implemented by 2011 and will require

> all herbalists to be licensed and regulated. For a full briefing on

> this, see http://www.chinesemedicinetimes.com/section.php?xSec=132

>

> I believe this is a good thing for a number of reasons. It stops

> anyone from saying they are a herbalist and danger patients, which

> gives us all a bad name. It will improve standards as all herbalists

> will have to undergo formal training. At the moment if any herb is

> remotely dangerous, govt. agencies like the FDA or MHRA try to ban

> it. This is not surprising as anyone can give it out. Once regulated,

> we'll be in a stronger position to use those herbs under license.

> We'll also get better access to primary care facilities and insurance

> as well as research money. As part of regulation in the UK, language

> requirement are being introduced, which will help protect patients

> from those herbalists that cannot communicate to their patients. As

> mentioned in previous threads, herbal pills are being sold over the

> internet. Under new regulation, that will not be possible in Europe

> and the UK.

>

> I believe that in a few years, similar regulation proposals may be

> introduced in the US. So this is a good `heads up'.

>

> Attilio

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Roger

We do however have aristolochia cases with LAcs in US as well

 

 

 

 

Oakland, CA 94609

 

 

-

Roger Wicke

Wednesday, December 27, 2006 9:01 PM

TCM herbology/regulation

 

 

Attilio,

 

To clear up several misconceptions:

 

The UK has placed its entire common law system of governance at risk

by joining the EU, which is dominated by countries with Napoleanic

code legal systems, which is in turn derived from the tradition of

feudalism - the idea that one must obtain explicit permission from

the manor lord to do almost anything. The common law tradition (a

natural person is free do almost anything unless it violates the

rights or property of another) is alive and well in many countries

around the world, and Britain's recent decision to join the EU has

little effect on these other countries. The USA seceded from Britain

in 1775, and at that point its legal system began to diverge from

Britain's. Britain's joining the EU may have dire consequences for

British herbalists, who must now tremble at the thought of EU

bureaucrats' desires to micromanage their professions. But it will

have no direct effect on the USA and other former members of the

British Commonwealth.

 

After reading

http://www.chinesemedicinetimes.com/section.php?xSec=132

I have several questions and comments.

 

The aristolochia debacle in Belgium seems to have triggered quite a

storm. But there are several things about this that strike me as

being illogical. Licensed medical doctors were responsible for

perpetrating this atrocity, when they chose to use a Chinese herb

that they did not investigate thoroughly. Moreover, they combined it

with a veritable witches' brew of other toxic herbs and drugs. It

seems the only things they forgot to include were arsenic and

strychnine. Since ***licensed medical doctors*** were responsible for

this, why does the EU wish to punish everyone else??? Why not go

after the culprits directly and insist that if licensed medical

professionals wish to branch out into topics beyond their training,

that they obtain training, or at the very least, document that they

have read books on the subject? Is that really too much to ask?

 

I would find it very interesting to know what was going on in the

minds of these doctors. Were they so cocky and arrogant that they

assumed that with their advanced degrees in medicine that they could

tackle a new subject without reading the basics, like basic

toxicology and contraindications data in any TCM materia medica? Or

rather than arrogance, was it a naive trust that because it was

available for sale in the EU, that it must be safe - after all, the

government, in its omniscient wisdom, would never allow anything

unsafe to be sold, would it?

 

Regarding the topic of regulation, even benign and beneficial

regulation, it is human nature to become complacent and expect that

the government will protect them from all of life's dangers. (What I

find even more preposterous is only 60 years after the decline of the

Third Reich, Europeans seem to have forgotten how government

bureaucrats can suddenly turn evil.) A few years ago I was hiking in

Glacier National Park, which is famous for its grizzly bears. They

are dangerous and have been known to eat people. I was astounded to

hear a tourist explain to her children not to be afraid of the bears,

because if they were really dangerous, the government would not allow

them to roam wild! I interrupted, explaining that they were indeed

dangerous, and that there were certain things one does not do around

grizzly bears, and that this really was a wilderness and not an

amusement park. I held my tongue, however, when it came to the

subject of government regulation.

 

In the U.S., western herbalists are much better versed in the herbal

history than their TCM counterparts. In 1909-10 the Flexner

Commission was responsible for destroying the herbal tradition in the

U.S. for at least the next half century. It was accomplished through

a combination of withholding accreditation from medical schools that

continued to teach plant pharmacy (herbal medicine), by increased

state licensing of health professions, by prosecution of herbalists

who strayed into the legal territory of practicing medicine (by

making explicit medical claims, doing medical diagnosis, and by

allowing others to call themselves " doctor " ), and by increasing the

power of the FDA. Most western herbalists are by now familiar with

this history and know these tricks of the legal system. TCM

herbalists are behind the curve on this and need to bone up.

 

A few years ago I wrote an extensive paper on the subject of common

problems in herbal regulation, delivered at a conference at UC

Berkeley. Also attending were academics from Asia and South America.

I rewrote the article several times to incorporate suggestions and

criticisms from these other attendees.

Why not read it before you assume that mandatory regulation is the

best answer to various abuses? In it I specifically discuss the

aristolochia incident, as well as other regulatory examples (like

Proposition 65 re heavy metal contamination of herbs in California)

that illustrate the law of unintended consequences - how regulation

can backfire and result in consequences that may sometimes worsen the

very problems it was written to address.

 

http://www.rmhiherbal.org/review/2003-2.html

Orwellian schemes for maximizing health-care industry profits - How

these endanger the practice of herbal medicine

 

I'll end with quote from an ancient Roman statesman:

" A bureaucrat is the most despicable of men, though he is needed as

vultures are needed, but one hardly admires vultures whom bureaucrats

so strangely resemble. I have yet to meet a bureaucrat who was not

petty, dull, almost witless, crafty or stupid, an oppressor or a

thief, a holder of little authority in which he delights, as a boy

delights in possessing a vicious dog. Who can trust such creatures? "

-- Marcus Tullius Cicero

 

---Roger Wicke PhD

Rocky Mountain Herbal Institute

website: http://www.rmhiherbal.org/

email: http://www.rmhiherbal.org/contact/

 

On 2006.Dec.27, at 09:29, wrote:

 

> 1d. Re: earnings/potential of TCM herbology

> Posted by: " " attiliodalberto

> attiliodalberto

> Tue Dec 26, 2006 8:51 am ((PST))

>

> Roger, Bill and All,

>

> I see, so the US law is largely based on Anglo-Saxon common law. I

> read somewhere that herbalists in the UK where protected by a law

> introduced by Henry VIII, although i can't say that's for sure.

>

> What i do know, is that this English common law is no longer. A new

> European directive has been introduced which rides over it. This new

> European directive will be fully implemented by 2011 and will require

> all herbalists to be licensed and regulated. For a full briefing on

> this, see http://www.chinesemedicinetimes.com/section.php?xSec=132

>

> I believe this is a good thing for a number of reasons. It stops

> anyone from saying they are a herbalist and danger patients, which

> gives us all a bad name. It will improve standards as all herbalists

> will have to undergo formal training. At the moment if any herb is

> remotely dangerous, govt. agencies like the FDA or MHRA try to ban

> it. This is not surprising as anyone can give it out. Once regulated,

> we'll be in a stronger position to use those herbs under license.

> We'll also get better access to primary care facilities and insurance

> as well as research money. As part of regulation in the UK, language

> requirement are being introduced, which will help protect patients

> from those herbalists that cannot communicate to their patients. As

> mentioned in previous threads, herbal pills are being sold over the

> internet. Under new regulation, that will not be possible in Europe

> and the UK.

>

> I believe that in a few years, similar regulation proposals may be

> introduced in the US. So this is a good `heads up'.

>

> Attilio

 

 

 

 

 

 

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Attilio,

 

To clear up several misconceptions:

 

Attilio: I'll make it a little clearer.

 

The UK has placed its entire common law system of governance at risk

by joining the EU, which is dominated by countries with Napoleanic

code legal systems, which is in turn derived from the tradition of

feudalism - the idea that one must obtain explicit permission from

the manor lord to do almost anything. The common law tradition (a

natural person is free do almost anything unless it violates the

rights or property of another) is alive and well in many countries

around the world, and Britain's recent decision to join the EU has

little effect on these other countries. The USA seceded from Britain

in 1775, and at that point its legal system began to diverge from

Britain's. Britain's joining the EU may have dire consequences for

British herbalists, who must now tremble at the thought of EU

bureaucrats' desires to micromanage their professions. But it will

have no direct effect on the USA and other former members of the

British Commonwealth.

 

Attilio: The EU is made up of 27 different countries. Only a minority

of countries such as France and Spain use Napoleonic law. The UK did

not join recently but decades ago. As the UK defeated Napoleon and

later had him poisoned, there is little chance they will suddenly

decide to follow his doctrine. In many respects, this would amount to

Napoleon winning his war.

 

As discussed in the article on regulation (see link below), the UK

already has legislation that protects herbalists. This legislation is

being woven into European law. Ireland also has the same legislation

protecting herbalists. Countries that use Napoleonic law have

outlawed the use of herbs by non MDs. We'll have to wait and see what

other countries in the EU will do.

 

US style of govt is largely built on the UK version and hasn't

changed much. It is not a question of commonwealth countries

following the UK, this thinking is out of date. It more to do with

developed countries watching each other and seeing how improvements

can be made. I believe the FDA will see the benefits of patient

safety to be more important than " person is free do almost anything " .

 

After reading

http://www.chinesemedicinetimes.com/section.php?xSec=132

I have several questions and comments.

 

The aristolochia debacle in Belgium seems to have triggered quite a

storm. But there are several things about this that strike me as

being illogical. Licensed medical doctors were responsible for

perpetrating this atrocity, when they chose to use a Chinese herb

that they did not investigate thoroughly. Moreover, they combined it

with a veritable witches' brew of other toxic herbs and drugs. It

seems the only things they forgot to include were arsenic and

strychnine. Since ***licensed medical doctors*** were responsible for

this, why does the EU wish to punish everyone else??? Why not go

after the culprits directly and insist that if licensed medical

professionals wish to branch out into topics beyond their training,

that they obtain training, or at the very least, document that they

have read books on the subject? Is that really too much to ask?

 

Attilio: It is true that MDs caused all the problems here, yet it

also highlights the need for regulation in the herbal sector. In a

personal communication with the MHRA, they stated that Aristolochia

was banned because " persistent evidence of confusion of species in

the TCM sector " . Chinese herbal suppliers need to step up their game

by improving their labeling of species as well as ensuring a good

supply of herbs without contaminants. As there was no regulation in

place to define the word `herbalist' anyone could call themselves a

herbalist and use the herb Aristolochia. It was therefore necessary

to ban the herb to protect the public. If regulation was already in

place, then it is unlikely the herb would have been misused by MDs as

they wouldn't be licensed to use it and it wouldn't be banned.

 

I would find it very interesting to know what was going on in the

minds of these doctors. Were they so cocky and arrogant that they

assumed that with their advanced degrees in medicine that they could

tackle a new subject without reading the basics, like basic

toxicology and contraindications data in any TCM materia medica? Or

rather than arrogance, was it a naive trust that because it was

available for sale in the EU, that it must be safe - after all, the

government, in its omniscient wisdom, would never allow anything

unsafe to be sold, would it?

 

Attilio: After it was found to be unsafe and there was no regulation

to control its use, it was banned. What do you expect the authorities

to do, just stop MDs from using it but the rest of the public can?

 

Regarding the topic of regulation, even benign and beneficial

regulation, it is human nature to become complacent and expect that

the government will protect them from all of life's dangers. (What I

find even more preposterous is only 60 years after the decline of the

Third Reich, Europeans seem to have forgotten how government

bureaucrats can suddenly turn evil.) A few years ago I was hiking in

Glacier National Park, which is famous for its grizzly bears. They

are dangerous and have been known to eat people. I was astounded to

hear a tourist explain to her children not to be afraid of the bears,

because if they were really dangerous, the government would not allow

them to roam wild! I interrupted, explaining that they were indeed

dangerous, and that there were certain things one does not do around

grizzly bears, and that this really was a wilderness and not an

amusement park. I held my tongue, however, when it came to the

subject of government regulation.

 

Attilio: This has really little point to do with the discussion here.

If you want to look at how government bureaucrats can suddenly turn

evil, look closer to home.

 

In the U.S., western herbalists are much better versed in the herbal

history than their TCM counterparts. In 1909-10 the Flexner

Commission was responsible for destroying the herbal tradition in the

U.S. for at least the next half century. It was accomplished through

a combination of withholding accreditation from medical schools that

continued to teach plant pharmacy (herbal medicine), by increased

state licensing of health professions, by prosecution of herbalists

who strayed into the legal territory of practicing medicine (by

making explicit medical claims, doing medical diagnosis, and by

allowing others to call themselves " doctor " ), and by increasing the

power of the FDA. Most western herbalists are by now familiar with

this history and know these tricks of the legal system. TCM

herbalists are behind the curve on this and need to bone up.

 

A few years ago I wrote an extensive paper on the subject of common

problems in herbal regulation, delivered at a conference at UC

Berkeley. Also attending were academics from Asia and South America.

I rewrote the article several times to incorporate suggestions and

criticisms from these other attendees.

Why not read it before you assume that mandatory regulation is the

best answer to various abuses? In it I specifically discuss the

aristolochia incident, as well as other regulatory examples (like

Proposition 65 re heavy metal contamination of herbs in California)

that illustrate the law of unintended consequences - how regulation

can backfire and result in consequences that may sometimes worsen the

very problems it was written to address.

 

http://www.rmhiherbal.org/review/2003-2.html

Orwellian schemes for maximizing health-care industry profits - How

these endanger the practice of herbal medicine

 

Attilio: I'll read it when I have time.

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A major point of the article I mentioned below is that the FDA is a

corrupt and hypocritical regulatory agency. Anyone in the US

alternative health community is probably familiar with their abuses.

The FDA's major purpose is to protect the profits of the drug

companies. If it were really concerned about public safety, it would

immediately ban Aspartame and a long list of other useless and

dangerous food additives and drugs.

 

I'm not going to reproduce the arguments in that paper here. They are

outlined in the article in detail. A lot of the points you address,

Attilio, are discussed in that paper, and are focused on the

situation in the U.S. I am describing problems that alternative

health practitioners experience here. I am aware that the regulatory

situation is not quite as abusive in Europe and that Europeans

perceive regulation as being more humane and positive.

 

The U.S. spends more per capita on health care than any other nation

in the world, and yet has less to show for it in terms of overall

health, infant mortality, etc. We obviously have a sick situation

here; however, solutions that may work in Europe may not necessarily

work here because of specific pathologies in our political and

regulatory systems.

 

---Roger Wicke PhD

Rocky Mountain Herbal Institute

website: http://www.rmhiherbal.org/

email: http://www.rmhiherbal.org/contact/

 

 

 

On 2006.Dec.31, at 10:43, wrote:

 

> 4. Re: TCM herbology/regulation

> Posted by: " " attiliodalberto

> attiliodalberto

> Sat Dec 30, 2006 3:39 pm ((PST))

>

> I believe the FDA will see the benefits of patient

> safety to be more important than " person is free do almost anything " .

 

> http://www.rmhiherbal.org/review/2003-2.html

> Orwellian schemes for maximizing health-care industry profits - How

> these endanger the practice of herbal medicine

>

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