INTRODUCTION

Herbal Medicine, like everything else, needs to have a policy towards climate change and, more pressingly, the effects of passing peak oil production and the consequent influences of energy descent. We are also starting to see evidence of an equal anxiety, that of unsustainable bureaucracy. Herbal medicine in its own small way can observe at first hand the effects of incomprehensible, ambiguous and conflicting regulations. Heedlessly unjust, antisocial, counter-environmental and petty, they are surely accelerating towards collapse. In the interim, this obsession with regulation of both herbal practitioners and suppliers edges us closer to the orthodox models of globalisation of supply and demand and a high-technology, high-energy approach to the way we go about our business – entirely in the opposite direction to what, in our deeply considered opinion, will be needed (whether we like it or not). We can either start rehearsing our own necessary adaptations in an imaginative and well co-ordinated fashion or we can complacently wait for the worst to befall us from dramatic & sudden changes in socio-economic forces. Suppliers, like practitioners, all have different starting points – but we think it’s clear that there is a line we all have to travel down together.

We believe that herbalists and their suppliers should be at the cutting edge of environmental initiatives. This, regrettably, is not the case. Even now the majority of the medicines available to practitioners from commercial suppliers are not grown organically. Too little attention is paid to sustainability issues, fair working conditions for third world growers and producers, carbon footprinting of herbal supplies, and so on. The situation is even worse where the over-the-counter trade (that supplies the public) is concerned.


HERBAL PRACTITIONERS

We hope we are reflecting a growing awareness amongst herbalists that we need to adapt to survive as practitioners, let alone remain relevant. We need to come out of our professional bubbles by engaging more deeply with our local communities, promoting herbal medicine as the readily accessible common good it has always proved, especially when times are hard. We will be taking more responsibility for the in-house and local sourcing and preparation of herbal remedies. We will be reassessing our materia medica to concentrate on what can be found or cultivated in our own back yards. We will be reducing wastage, we will be recycling, we will be doing what we can to influence others. Herbalists are, after all, acting in their work as the representatives of nature to their patients. It smacks of hypocrisy if we are not also at the forefront of the greatest human undertaking yet – to save our planet from ourselves.


SUPPLIERS

In a review of feedback to the original consultation document in October 2007, we commented on the growing concerns that ultimately the herb trade’s market leaders would become linked to pharmaceutical companies, that they would absorb smaller companies or manufacture their medicines for them, that small dedicated grower/producers would decline, and that choice and quality would decrease whilst prices would rise. It is absolutely staggering that all these predictions had already been evidenced a mere six months later, and continue to deepen.

Curiously, although one might expect the trade to be in a stronger negotiating position than the profession, there appears to have been little or no challenge to regulation, no matter how daft or restrictive much of it seems, even where it might mean closure. In a world suddenly bristling with standards, no evidence has been offered of ethical/ environmental standards embodied either in the new legislation or promoted by trade associations.

There is another consequence of the co-ordinated regulation of the trade and the profession that seems to have gone unnoticed. Hitherto it has been clearly understood that herbal practitioners themselves have absolute responsibility for the identification and quality of the medicines they dispense to their patients. This system has been in place throughout the 150 years of absolute safety in practice that we are rightfully so proud of and is without question an integral feature of it. The responsibility is now being shifted to the manufacturer. It isn’t possible for it to prove safer and early indications are that the new regulated systems are no less vulnerable to error and abuse than before. At the same time, as a rule, university education in herbal medicine neither signals the need nor provides much training in herb identification and “organoleptic” (sensory) appraisal of medicines.

If we are startled by the breathtaking speed of change in the herb trade, there has been an equally startling (if gratifying) response from all manner of herbalists to reorganise and get busy growing, gathering and making their own medicines. However, we cannot realistically serve all our patients’ needs in this way now or in the foreseeable future, and however much we begrudge the effects of regulation on the herb trade, we still need them and they surely still need us. We must still work to make the very best of the situation that we can, which means supporting and encouraging suppliers who are interested in environmental initiatives and sending a clear message to those that ignore them by buying judiciously. That there remains a market majority that is neither organically produced nor ethically sourced is no longer defensible. Suppliers are urged to work vigorously to address this situation. Lofty plans for an unspecified future fail to impress!

It is noted that over 70% of the world herb trade is still sourced from the wild. There are many examples where apparently “ethical” and “sustainable” wild harvesting have made a significant contribution to the near-extinction of a growing list of species. Our association with this phenomenon cannot continue. The only acceptable solution is to bring the majority of our plant sourcing into cultivation. Equally we should be concentrating on those species which, indigenous or not, can be grown viably in the UK.

The preference for tinctures and other herbal medicines made from organic fresh herbs continues to grow, especially amongst those of us who incorporate the concepts of energetics into our everyday work with plants and people. This is almost exclusively a “home-grown” enterprise. Practitioners and grower/producers adapted to this find that it maximises yield from cultivation, generates considerable added value and enhances job satisfaction. It is noted that one of the significant vectors on “energetic” medicinal quality is the intentions of all those involved in the processes that take it from plant germination to patient treatment.


SOURCING OF PLANT MATERIAL

The concept of “herb miles” (in the same sense as “food miles”) needs to be adopted and acted upon. Practitioners will be encouraged to adapt their materia medica to become more concentrated on plant material that can be grown & prepared in the UK. Some favour will nonetheless be given (as long as economically viable) to supplies ethically sourced from third world countries.

  • Suppliers are asked to play a proactive role in promoting fair pay and conditions for all workers involved in the growing, gathering, preparation & commerce of herbal supplies.
  • The use of non-organically cultivated plant material should be phased out as rapidly as possible. Problems are cited regarding high levels of infection or contamination of organic material. These simply need to be sorted out!
  • Irradiation of imported dried herbs is completely unacceptable, gassing barely less so. High pressure steam sterilisation seems reasonable but is said to be expensive.
  • Wild harvesting should only be entertained under very limited circumstances and where rigourous evidence of ethical, sustainable practice is provided.
  • “Herb Miles”: a hierarchy of preference for local, thence national, European & intercontinental sourcing should be apparent. There is a counter-argument that drying of home-grown plant material may use more energy than the transport of naturally dried herbs from hotter countries. This is acknowledged but should not simply be used as an excuse to preserve the status quo.


MANUFACTURE & SUPPLY

  • Suppliers are expected to secure supplies of prime quality, to prepare and manage them to preserve this quality and to ensure what they supply is what they say it is.
  • All reasonable steps should be taken in-house to operate in an environmentally conscientious fashion.
  • Suppliers should both utilise and respond to feedback from organoleptic assessment of herbal medicines, equally to feedback regarding therapeutic efficacy. Laboratory analysis should not be considered a substitute.
  • There is no objection to the common practice of buying in herbs and their products from other suppliers but this should become sufficiently transparent for practitioners to make properly informed choices.


LABELLING

As well as the normal descriptive labelling of herbal remedies, we would welcome the inclusion of:-

  • The source of the raw plant material.
  • Its category (organic, biodynamic, non-organic, wild harvested, fresh or dry).
  • The date it was harvested. (This is not done despite its critical importance).
  • The date of manufacture (if applicable).
  • Observation of the above obviates the need for the largely arbitrary “best before” dates currently employed.


PACKAGING & PACKING

There will always be arguments about biodegradability – everything is ultimately biodegradable! A helpful yardstick is whether packaging and packing are compostable – they should decompose rapidly and leave no toxic residues. The best form of “recycling” is reuse, of course. And what can be used that is itself recycled? Again this is a very complex subject – but solutions will always be found if suppliers and customers take on board that we share a responsibility to reduce consumption of the energy and resources we have come to take for granted.

Bottles (e.g. for tinctures)

  • There are pros and cons regarding the use of polythene or PET bottles that do not lead to a clear preference. Hopefully both can be replaced by a more environmentally sound material in due course.
  • The use of glass is applauded but may not remain economically viable as distribution costs rise.
  • Labels should employ either peelable or water-soluble adhesives to aid reuse or recycling of the container.

Dried herbs, etc.

  • Brown kraft or natural cellophane bags are preferred to polythene or plastic laminates unless unsuitable (e.g. for sticky or oily contents.)
  • Sealing with gummed paper or natural cellulose (“Sellotape”) adhesive tapes.
  • Double wrapping should be phased out.
  • Packaging of a miscellany of sundry supplies is too complex to detail here, but it is hoped that suppliers will treat these in the same spirit of good environmental practice.

Transit packing

  • Cardboard cartons should be sealed with natural cellulose tape or gummed paper tape.
  • Infill should be confined to shredded/crumpled paper, or, if essential, cornstarch chips. The use of styrofoam chips is no longer acceptable.
  • The use of bubblewrap must be restricted to absolute need until functional alternatives (e.g. expanded pulp, corrugated kraft ) can be substituted.
  • Suppliers are encouraged to employ recycled materials in all viable aspects of transit packing.


DISTRIBUTION

It is clear that increases in fuel costs will soon cause carriers to introduce steep distance-related tariffs. Suppliers are encouraged to work with the concepts of relocalisation, perhaps providing incentives for customers in the same region and by encouraging/co-operating with central buying from local herbalist groups. Some thought should also to be given to the economics of returning glassware and specialised cartons for reuse.


CARBON FOOTPRINT

Suppliers, the same as practitioners, are encouraged to familiarise themselves with the concept and the detail of the “Carbon Footprint”. This is not just reflected in what has been discussed so far, but in the hundreds of details with which we manage our businesses and equally in our private lives. It would be neither reasonable nor practicable to attempt to monitor this! Nonetheless, suppliers that evidence policy and progress to this end will be an inspiration to others.

Acknowledgements

We would like to thank the Canal 12 group of independent herbalists for their collective work in originating this discussion, members of the Independent Herbalists chatroom who provided feedback, and in particular the many helpful respondents from growers, producers, manufacturers and suppliers of herbal medicine.

Like many of the Herbarium articles, this will be maintained as a live document, revised from time to time as new information arrives. It was last updated in December 2008.

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