March 2010
Regulation
Since November 16th when the Department of Health closed its consultation, it has made no response, and it seems increasingly unlikely that one will be forthcoming before the imminent UK General Election. One nonetheless has to assume that herbal medicine’s pro-regulation lobby spearheaded by the EHTPA gained some inkling that things were not going well – since November they’ve been busy with the media and have continued lobbying MPs. As the EHTPA and the large PAs such as NIMH evidently have nothing else left in their armoury, they have concentrated on the message that herbal medicine is inherently dangerous and therefore must be regulated as a matter of urgency. This is an absolutely extraordinary stance for the representatives of herbal practitioners to take, the more so as it patently isn’t true.
Education
We’re deeply saddened to learn that, short of a miracle, the BSc course at the Scottish School of Herbal Medicine is closing in September. This was far and away the best course in the UK and, we should take this opportunity to thank Maureen & Keith Robertson & their staff for turning out so many fine practitioners during the last two decades. We hope that placements can be found for their students to complete their degrees elsewhere.
Two other BSc courses, Edinburgh & Lancashire, are ‘teaching out’, leaving nothing further north than Lincoln still functioning, although curiously, the Leeds Metropolitan University is just announcing provisional details of new course. At the same time, there are anxieties being expressed regarding the ability of the three London university courses to maintain the most expensive part of the operation, namely their training clinics. We are faced with the possibility that there might be no higher education in western herbal medicine before long, or failing this that what remains may represent a further reduction in quality.
It would be too easy to blame all this on the recession, but in truth this is only partly to do with cutbacks in university funding. The primary problem is dramatically diminishing enrolment in these courses, compounded by higher drop-out rates. Why should this be? Part of the problem, as we have often complained, is that whilst the PAs have spent 15 years in an all out effort to achieve statutory regulation, they have been extraordinarily neglectful in addressing problems of competition, the dramatic growth in the over-the-counter trade, the need to counter adverse publicity from the ‘quackbuster’ brigade, and so on. Likewise they have failed to maintain anything like an acceptable level of postgraduate and professional aid & support, resourcing, professional development, information sharing, PR & promotion, and so on. The other major problem, we are convinced, is that Statutory Regulation, far from making a career in herbal medicine a more attractive proposition, has appeared very big-brotherish, part of the overbearing feel of the whole thing arising from within herbal medicine itself. One listens to countless BSc graduates who complain that their training was neither a pleasurable experience, nor did it prepare them to enter practice with any confidence, nor do the PAs do much to ameliorate either of these things.
Returning to the plight of the Scottish School, this is a unique set of circumstances as its BSc course is externally validated and is dependent on student fees and charitable funding. One can’t help wondering how different the situation might be if it were to be relieved of all the expense, bureaucracy and impedimenta of a BSc course – a humble diploma has proved adequate in the past (and in reality provided a high standard of occupational training that has never been improved on). This is not a viable solution at the present, because a BSc is nominated as the minimum qualification for members of a regulated herbal profession… but if, as we anticipate, SR fails, there are surely lessons to learn here for the future.
A source of hope
We are clearly apprehending the end of an era. The most telling reflection is that SR is no longer relevant – whether it happens or whether it’s shelved will make no significant difference. So what phoenix will rise from the ashes? Whilst all this has been going on, whilst the mainstream of herbal practice has been losing its confidence, whilst patient rolls have been dropping, whilst we wonder where the next generation of herbalists will come from, there are nonetheless herbalists out there that have been doing well despite it all. They are the ones that have embraced the Transition Herbal Medicine ethos, have been making their own medicines, engaging with their local communities, organising the herb patch in community gardens, running workshops, conducting herb walks, working in close harmony with neighbouring herbalists (and students!), and so on. We once again draw attention to the quite startling popularity of the Herbarium – in part because we are trusted to speak the truth where the ‘politics’ of herbal medicine is concerned, but mostly because the practical information we provide to help herbalists work in a sustainable, self-reliant fashion is being used so much. We know from feedback and the number of overnight ‘hits’ that this is rapidly becoming an international phenomenon.
A problem with TCM
A court case concerning a Chinese retail outlet has recently received considerable press coverage. A mislabelled complex remedy (containing a banned substance, Aristolochia fangchi), was alleged to have caused kidney failure in a customer – it should be noted that the shop assistant accused was found not guilty. We will surely all be relieved next year when the THMPD can stop China exporting this sort of remedy into Europe. However, it was a problem of the over-the-counter trade and has nothing whatsoever to do with herbal practice, let alone western herbalists. Nonetheless the EHTPA & NIMH seem to have joined forces with the ‘quackbusters’ on this one, somehow managing to interpret it as evidence that herbal practitioners must be regulated. This is absurd.
CRB & ISA checks
An issue has arisen regarding herbal practitioners apparently being compelled by at least one PA, without consultation or notice, to undergo checks from the Criminal Records Bureau. Whilst responsible practitioners are unlikely to object to being able to evidence a clean record from the CRB, the fact remains for the time being that it is a service provided to employers, and there are no arrangements available as yet for self-employed complementary practitioners. Likewise the remit of the Independent Safeguard Authority does not appear to include herbal practitioners, provided we do not engage in consultation with unaccompanied vulnerable individuals.
The Herbarium 
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September 11, 2010 at 8:38 pm
Robert Scott
Against the backdrop of a domino effect of closing university courses, it is perhaps somewhat telling that the chairman of the EHTPA, along with other directors of that institution, did his utmost to arm-twist the Inernational register of Herbalists and Homoeopaths to close its acadamy in traditional herbal medicine as the price to be paid for inclusion in the list of organisations to be recommended for grandparenting into the HPC. He also baldly stated in my pesence that he and his fellow members of the EHTPA inner circle had no intention of recommending the IRCH for this “honour” that in any case lay out side his gift to bestow, on the basis of their antipathy to two former IRCH company secretaries (both named) who were not even current members of the organisation. As the application was claimed to be based on “A SNAP SHOT IN tIME” this was not only unconstitutional in itself, in regards to the steering group report, but also constituted a breach of the EHTPA constitrution as it was conspiring against the interessts of a then current member.as this meeting took place in the kitchen of his own home, it might also be viewed as a gross breach of hostpitality, particularly as he had instituted this meeting himself.
Needless to say this exposure of the true colours of the organisation led to the resignation of the IRCH from the EHTPA on the grounds that its policy was counter to the interests of traditional herbal medicine in general and those of the IRCH in particular.
I am however glad to assure everyone that the IRCH has contiued to train and graduate practitioners of traditional herbal medicine despite an ongoing campaign by the EHTPA to dissuade applicants from joining on the grounds that their qualification might not be recognized (eactly by whom is not stated). It is amatter of note that the Unified Register of Hebal Practitioners (URHP) is largely dependent apon IRCH graduates who are tempted to join on the promise of proffessional/political protection by the EHTPA for deserting the register and its acadamy. This has proved to be more than a little frustrating as the URHP was judged to fail to meet the HPC criterion of having “a discreet area of activity showing some degree of homogeneity”. This is because this register enjoys a unique characteristic of hosting practitioners from a wide range of Eastern and Western traditions, the majority of which had not been considered for Statutory Regulation in the public consultation document. Any such accommodation would thertefore have given rise to any number of anomalies! This is quite apart from the small problem of it having been openly admitted that no officially accepted protocol for establishing “evidence of efficacy” had ever been established (this would have lead to any attempt by the HPC to statutorily regulate by “Protected Title” to not only breach its own constituion, but also to commit a criminal offence as protected title is a legal instument).
The IRCH acadamy in traditional western herbal medicine continues onward and upward and is pleased to take up the slack of other institutions that have fallen under the burden of the current financial crisis. In part this is because the IRCH is a registered non-prfit making organisation dedicated to the training of herbal practitioners and has been doing so now for half a century.