– Fostering Autonomy, Accountability and Self-Reliance among Western Herbalists


Most Western Herbalists in the UK belong to Professional Associations (PAs). These organisations are currently very proactive in pursuing the regulation of herbalists and their medicines by the state.

The purpose of this document is to set out an alternative framework by which herbalists can organise themselves, one that avoids unnecessary state interference or the pitfalls manifested by the hierarchical organisation of existing PAs.

Brief Analysis of the Current Situation

At present we have a fractured (and sick) community of herbalists. Most herbalists work in isolation and have infrequent contact with their peers and elders. Most PAs, nominally the prime custodians of herbal medicine, are currently dominated by a status-driven minority that is out of touch with the needs and aspirations of most rank-and-file members. Herbalists have for a long time been told that statutory regulation (SR) is inevitable. This has tended to a sense of apathy among the majority and a helpless assent to a flawed legislative programme. In consequence, if these plans come to fruition, PA members will soon be compelled to enrol with the Health Professions Council (HPC) – an organisation offering the same centralised, top-down hierarchical structure as allopathic medicine, the NHS in general, and just about everything else that has failed to escape the attention of modern government.

We decline to accept the so-called ‘professionalisation’ of herbal medicine under the above arrangements, which is damaging to the interests of patients and practitioners alike. As practitioners we attempt to empower our patients by promoting autonomy, self-accountability and self-reliance. Thus it would be incongruous for us to voluntarily enter into arrangements designed to disempower us as people. We believe that it would not be possible to maintain our integrity as practitioners while being members of the HPC, an organisation whose norms and procedures would undermine our core values.

1) Autonomy: A Network of Independent/Transition Herbalists

We already have considerable experience to draw on as a small, autonomous group of independent herbalists. There have been both triumphs and disasters, but overall enormous benefits – many of these are outlined in the “Greening Herbal Medicine” sections. We now encourage others to make this leap of imagination.

We will have to wait until other groups form in order to determine the exact manner in which we organise ourselves and how our interrelationships might develop. We do not wish to dictate how this unfolds, but we all have to start somewhere, so here are our suggestions and thoughts on the subject:-

We aspire to become part of a new, healthy community of herbalists that strives to preserve and promote Western herbal traditions. We envision a horizontal, non-hierarchical, low-bureaucracy and multi-centred network built on co-operative links between small autonomous groups of herbalists practising transition/sustainable herbal medicine within their communities.

We feel that a nation-wide system of linked member groups working together, offering each other mutual support (and challenge) is the most in keeping with the core values of participation, individual empowerment and parity. We suggest that these member groups might comprise between 6 and 12 practitioners.

The network would have no central, standardised set of rules or code of practice/ethics. However, in order to foster a culture of openness and accountability, each group would opt to formulate and publish their own code of practice/ethics or equivalent.

We value diversity and pluralism and would therefore suggest that decision-making within each group is achieved by consensus (not by voting). In consensus-based decision making, issues are debated openly and rationally, and – most importantly – all available options are considered and all views heard. No decisions are adopted unless everyone in a group is in agreement – this relies in part on a degree of ‘give and take’. At times it may be possible to accommodate more than one point of view, as there is often more than one way of doing things. If a group remains divided over an issue and no consensus has been reached, then no decision is taken and it is held open for further discussion. Group members must of course uphold executive decisions.

2) Accountability: ‘Standing By’ and ‘Good/Safe Practice’

Western herbal medicine has a matchless safety record and we reject any restrictions on our common law freedom to practise. The state is attempting to impose SR on herbalists under the pretext of ‘protecting the public’ without providing a scrap of evidence that we have ever posed a risk. There is also no evidence to suggest that SR and the HPC would in any way improve professional competence or enhance public protection. We therefore have to assume that this is part public relations exercise and part complicity with the powerful lobbies of the pharmaceutical industry and the medical profession.

The state cannot regulate practitioner integrity. Genuine accountability arises from a herbalist’s working relationship with patients and fellow herbalists. Thus we believe that the accountability and competence of practitioners is best fostered through an ongoing process of self and peer assessment. Practitioners in member groups must be committed to knowing and ‘standing by’ each others’ work. They should take responsibility for supporting ‘good/safe practice’ within their own group and within other groups on the network. A group’s membership of the network would assume this commitment to avoiding, resolving and rectifying problems. Therefore, all groups on the network should be willing to have their processes examined and challenged by other groups. In return, a member group would be able to draw on the experience and assistance of neighbouring groups and, ultimately, that of the whole network.

There are at least as many regulated as unregulated exploiters of the public, but the regulated ones are more dangerous because of their ‘certified’ credibility and trustworthiness. Therefore, we believe that devolving responsibility for ‘good/safe practice’ and ethical conduct to a process of continuing face-to-face peer validation at a local (member group) level is a more effective way to look after the interests of both patients and practitioners. We see the network as providing an autonomous framework, outside hierarchical accountability structures (e.g., the HPC model), not only for developing practitioner accountability and competence, but also for promoting continuing practitioner development.

3) Self-Reliance and Making Herbal Medicines

At present, relatively few herbalists make or know how to make their own medicines – most are dependent on suppliers for their medicines. Graduates from the BSc degree courses are taught little of the art of medicine making or knowledge of plant husbandry. A generation of herbalists is losing contact with nature and the very plants that are the source of their medicine. We believe that most students are allowing themselves to be deskilled and disempowered by the present educational arrangements.

The UK state and the European Union (EU) are stepping into this skills vacuum. SR and the Traditional Herbal Medicinal Products Directive or THMPD (an EU-sponsored Directive scheduled to come into force in 2011), are being used as a pretext to limit the right to prescribe and use herbal medicines. Production of and access to herbal medicines are being brought under the control of medicine regulators, such as the UK’s Medicines and Healthcare Products Regulatory Agency (MHRA). Furthermore, pharmaceutical industry protocols are being imposed on our suppliers (threatening their very existence) in a move to transform traditional, hands-on, low-tech herbal medicine into high-tech, industrial, laboratory-derived ‘product’. Herbal medicines produced in environments and by processes that mimic pharmaceutical laboratories are of unacceptably poor therapeutic quality.

We would like to encourage herbalists to become self-reliant and self-sufficient by growing, harvesting and producing their own medicines. With this in mind, we have made available information for herbalists elsewhere in The Herbarium on how to garden with herbs, how to make tinctures and other medicines, and how to make external preparations.

We see the co-operative links forged within and between practitioner groups providing routine opportunities to share not only knowledge of herbal medicine but also the medicines themselves – a bit like a “swap shop”. We believe that the best way to develop and maintain the quality and effectiveness of practitioner-produced herbal medicines is through the ongoing process of peer review. Allowing fellow herbalists to provide organoleptic assessment, and feedback from the use of such herbal medicines in their practices, are the best form of quality control. We believe that by growing, making and sharing our medicines we are reconnecting with, reclaiming ownership of, and safeguarding the future of our plant medicines.


We wish to take our place in a radically reorganised community of herbalists. The Network of Independent/Transition Herbalists is a grand vision. It is, after all, a perfectly normal way for human beings to organise themselves that in our current society is nonetheless all but forgotten – so it calls for a shift in attitude – away from centralised control, bureaucratic box-ticking and standardisation, towards self-empowerment, community-building and the celebration of diversity. At the core of the idea of Transition Herbal Medicine is that practitioners should treat their work increasingly as a community enterprise. First we have to start functioning as a proper community ourselves. We view the network as less an organisation with a set of rules and more a culture interested in means, not ends, and in opportunity, not limitation.

Some of the content of this document draws on the work done by members of the IPN – a network of psychotherapists/counsellors vigorously opposed to the regulation of their profession by the HPC (http://i-p-n.org).