At the end of this article we copy a Ministerial Statement from Andrew Lansley, Secretary of State for Health, published on Wednesday 16th February, and also a statement from the MHRA published on their website on the same day.
The main substance of these announcements are: –
· In order to comply with European Directive 2004/24/EC, (aka THMPD), herbal practitioners (of all traditions) will be statutorily regulated by the Health Professions Council (HPC).
· Section 12(1) of the 1968 Medicines Act would be reformed so that unlicensed medicines can only be used in the practices of HPC registered herbalists.
· The arrangements should be put in place by 2012.
· Acupuncturists, (hitherto considered to be a necessary part of the regulatory package) will not be regulated as they are not affected by the directive.
Like everybody else, we are in shock. Every indication was that the whole SR enterprise had foundered – it was an ill-conceived and unworkable plan, and assumed to be unattractive to a government beset by much greater problems and determined to cut costs. You can review the Herbarium’s commentaries on this in the ‘Law and Herbal Medicine’ files, which we will retain for the time being to help give insight into why we feel that this is all such a self-destructive nightmare.
Some insight into how this extraordinary eleventh-hour success for the EHTPA could have been possible comes from the PR company, Cogitamus, engaged during the final months of the campaign, who quote EHTPA Chair Michael Mcintyre thus: “On behalf of our thousands of members, I cannot thank or praise you enough for the vital support and advice you gave to us when it really mattered. Your intimate knowledge and experience of the health sector, combined with your understanding of both the formal decision-making processes and informal political dynamics in Whitehall, Westminster and the devolved administrations was exactly what we needed. It is no exaggeration to say that I truly believe you made a significant difference between ultimate success and failure in the final decision. I would have no hesitation whatsoever in recommending your services to any organisation in the health world needing calm, professional and deeply experienced advice or advocacy.”
So, this was less about our patients’ needs, the balance of arguments and good sense, and more about money (probably quite a lot of it) spent on lobbying. You may draw your own conclusions.
Whatever bringing SR to fruition might mean to other larger herbal modalities in the UK, it’s not good news for traditional western herbal medicine. Without the weight of numbers from the acupuncturists, with a government keen to spend as little as possible of taxpayer’s money, with the HPC under pressure to regulate way outside their comfort zone – this will cost regulated herbalists very dear – so much so that, given the humble incomes of most of us, it is unlikely to be affordable by all but a very, very, few – maybe too few to be sustainable. For the rest of us, having lost the right to make our own medicines, or indeed to buy them, and no doubt with other disincentives in place, we would be forced underground to work outside of the law. This is not an obvious recipe for growth either.
How do we respond to this? No fear! The joy of a good pun is to be able to convey two things at once – we won’t be cowed into submitting to regulation, nor will we allow it to lure us back into the trap of fear that we’ve be doing so much good work to escape.
The statements of government ministers seldom prove to be infallible – as is so often the case, the devil’s in the detail. The schedule of a 2012 completion seems particularly unrealistic. There are at least two further public consultations to compile, publish, call in and analyse, parliamentary time has to be found to debate and vote on two streams of legislation, the HPC has to develop its new bureaucracy, the PAs and their members have to go through a multitude of adaptations. It may nonetheless be rushed through and be so full of holes as to prove unworkable. If it’s delayed for long, it may be delayed forever. It may anyway simply prove to be beyond the purse of any of the interested parties.
The Herbarium, as we often remind ourselves, was launched to try and give herbal medicine a future. This is not the future the whole SR rigmarole would assume – that the western world is recovering from a little recession and we can soon all get back to escalating our material consumption. It’s the future of climate chaos, energy descent, and the decline of global bureaucracies and power structures. (This is at the core of the Transition Herbal Medicine ethos). If it turns out that we’re a little premature, at least we’ve left a message in a bottle for our grandchildren. But if we’re right, and there are all the signs that we are, then our work – every sensible herbalist’s work – has to be in preparation for a very different working environment, and one in which we are again relevant and valued. So the message to everybody in the midst of our hurt is chin up, hold steady, and keep the faith. Herbalists are hard to kill – if history will out, impossible to kill. Remember that the worst-case scenario has happened before in living memory – herbal medicine was illegal from 1941 to 1968. It proved paradoxically to be a golden era for our forebears, and nobody was prosecuted. It was a consequence of sheer bloody-mindedness, weak legislation, and the reticence of successive governments to prosecute citizens for doing no harm. Those who battled to bring the thoroughly civilized and effective Section 12(1) into the new Medicines Act, however much they also dreamt of official recognition, must surely be turning in their graves at the horrors that foolish herbalists and jaded politicians have managed to cook up 50 years later. We will have no part in it.
************
Written Ministerial Statement
DEPARTMENT OF HEALTH
Practitioners of acupuncture, herbal medicine and traditional Chinese medicine
Wednesday 16 February 2011
The Secretary of State for Health (Mr Andrew Lansley): The issue of whether or not practitioners of acupuncture, herbal medicine and traditional Chinese medicine should be statutorily regulated has been debated since the House of Lords’ Select Committee on Science and Technology’s report in 2000 recommended statutory regulation for the first two of these groups.
We have today published an analysis of the 2009 consultation by the four United Kingdom Health Departments which sought views on the possible regulation of practitioners of acupuncture, herbal medicine and traditional Chinese medicine. This factual report has been placed in the Library and can be found on the Department of Health’s website at:
www.dh.gov.uk/en/Consultations/Responsestoconsultations/DH_124337
Copies are available to hon Members from the Vote Office and to noble Lords from the Printed Paper Office.
I can now set out how we intend to take forward the regulation of herbal medicine practitioners and traditional Chinese medicines practitioners, specifically with regard to the use of unlicensed herbal medicines within their practice. As this matter is a devolved matter in Scotland and Northern Ireland we have had discussions with Health Departments in the three Devolved Administrations which have been constructive and we are committed to a unified UK-wide approach to the regulation of these practitioners.
When the European Directive 2004/24/EC takes full effect in April 2011 it will no longer be legal for herbal practitioners in the UK to source unlicensed manufactured herbal medicines for their patients. This Government wishes to ensure that the public can continue to have access to these products.
In order to achieve this, while at the same time complying with EU law, some form of statutory regulation will be necessary and I have therefore decided to ask the Health Professions Council to establish a statutory register for practitioners supplying unlicensed herbal medicines. This will ensure that practitioners meet specified registration standards. Practitioner regulation will be underpinned by a strengthened system for regulating medicinal products. This approach will give practitioners and consumers continuing access to herbal medicines. It will do this by allowing us to use a derogation in the European legislation to set up a UK scheme to permit and regulate the supply, via practitioners, of unlicensed manufactured herbal medicines to meet individual patient needs.
The Health Professions Council is an established and experienced statutory regulatory body which has the necessary experience to be able to successfully establish and maintain a statutory register for practitioners wishing to supply unlicensed herbal medicines. Subject to Parliamentary approval, such practitioners who wish to supply unlicensed herbal products will be required by law to register with the HPC.
The four UK Health Departments will consult jointly on the draft legislation once it is prepared. This will give practitioners and the public the opportunity to comment. Subject to Parliamentary procedures we will aim to have the legislation in place in 2012.
Until the new arrangements are in place the Medicines and Healthcare products Regulatory Agency (MHRA) will continue to take appropriate compliance and enforcement action where products are in breach of the regulatory requirements. In line with the MHRA’s normal approach, the action taken will be proportionate and will target products which pose a public health risk. Guidance issued by the MHRA makes clear their view that, where practitioners hold stocks of unlicensed products on 30 April 2011 that legally benefited from transitional arrangements under the European Directive, the practitioner can continue to sell those existing supplies to their patients.
The 2009 consultation also looked at practitioners of acupuncture. The practice of acupuncture is not affected by the EU Directive and, therefore, compliance is not required. I am confident that acupuncturists have their own voluntary regulatory measures in place, which are sufficiently robust. Additionally, local authorities in England have powers to regulate the hygiene of the practice of acupuncture, to protect against the risk of transmission of certain infectious diseases. Similar measures are also in place in Scotland, Wales and Northern Ireland.
I am pleased to say that this decision resolves a long-standing issue, to the benefit of
both practitioners and the public who use herbal medicines.
…and from the MRHA: –
The Secretary of State for Health has made an announcement today about regulation of herbal medicine practitioners. The issue of whether or not practitioners of acupuncture, herbal medicine and traditional Chinese medicine should be statutorily regulated has been debated since the House of Lords Select Committee report on Complementary and Alternative Medicine in 2000.
The Health Professions Council (HPC) has now been asked to establish a statutory register for practitioners supplying unlicensed herbal medicines. The proposal is, following creation of this register, to make use of a derogation in European medicines legislation (Article 5 (1) of Directive 2001/83/EC) that allows national arrangements to permit those designated as “authorised healthcare professionals” to commission unlicensed medicines to meet the special needs of their patients.
Accordingly, a scheme would be created enabling registered practitioners to commission unlicensed herbal medicines to meet the special needs of their individual patients. Safeguards for the public would be provided by a combination of professional regulation and linked medicines regulation, for example, to safeguard manufacturing standards.
If practitioner regulation is in place for the purposes of creating an Article 5(1) scheme this also opens the way to reform Section 12 (1) of the Medicines Act 1968. Under Section 12 (1), practitioners may prepare unlicensed herbal medicines on their own premises for use following consultation with individual patients. It is intended to move to the position that only registered practitioners would be able to operate under Section 12 (1) after regulation of practitioners is in place.
A formal consultation exercise will take place on specific legislative proposals for establishing the register and proposed reforms of medicines legislation later in 2011.
The Herbarium 
33 comments
Comments feed for this article
February 18, 2011 at 1:19 pm
Worried herbalist in training
Regulation is something that has been sold to herbal medicine students as the only way we will be able to practice in the future.
I now worry that the years (and years) of training that I have gone through will mean that I cannot practice except underground.
But while there are still herbs growing on this land, and herbalists who believe in herbal medicine and their patients, it is not the end!
February 18, 2011 at 1:46 pm
David
I am a practicing herbalist and I must say I am shocked to read this article and do agree with your points.
Why would anyone want to get rid of section 12(1)??!
February 18, 2011 at 3:08 pm
Phil
The pro-SR people have taken the announcements by the Secretary of State and the MHRA to mean they have definitely got Statutory Regulation, but it is jumping the gun to say this, because this is not what the statements themselves actually say.
To quote from the announcements:
“Subject to Parliamentary approval, such practitioners who wish to supply unlicensed herbal products will be required by law to register with the HPC” – is a clear statement that SR can only go ahead if Parliament agrees to the proposal; this means that if Parliament does not agree, it cannot go ahead.
“A formal consultation exercise will take place on specific legislative proposals for establishing the register and proposed reforms of medicines legislation later in 2011” – indicates that the whole thing is a proposal, and that there is to be a consultation on this proposal later this year.
The recent reversal of the proposals for Forestry during the consultation process shows us that Government proposals are certainly liable to be changed.
Phil
February 18, 2011 at 6:20 pm
Robert Scott
The problem is that if you do not fit the HPC criteria you are out in the cold. Ayuvedic tibetan etc were not included in the public consultation and will therefore go out of business as their medicines fall outside THMPD licensing. No Licence, no SR no practice = ethnic discrimination. The EHTPA has been trying to shut the IRCH down for years as we practice traditional western herbal medicine which does not comply with the model of the National Institute. The HPC requires the area of regulated activity to be defined, so there can be only one regulated model. This is the death of tradition herbal medicine in this country. The claim of defying Europe is a scam as the proposal was written in all the time. Those traditions outside SR will only have watered down products and the MHRA is even going to take away ordinary herbs as well. They could not do that without SR. This is even stated in their own documentation. SR is the bait in a rat trap to destroy all herbal medicine. Even the Chairman of the EHTPA said to my face that this would collapse Herbal Medicine within 10 years and that he did not care, as he would be retired by then.
This is a disaster that must be fought tooth and nail.
THMPD is bad enough and a challenge is being prepared against it, as you know, but THMPD + SR is a death sentence.
The whole proposal is based on false assumptions that do not stand up to evaluation. It is nothing more than a PR job.
February 18, 2011 at 7:10 pm
Susan
I was quite speechless and disheartened when I read the news. So so pleased to read the Herbarium response. Thank you for the hope and words of sanity.
February 18, 2011 at 7:58 pm
Kym
SR is still not a forgone conclusion, as the consultation processes have to be gone through. All of you in the UK have to ask yourselves if you end up supporting the SR process out of fear ( ie fear of not being able to practice) but know the system that will govern you is (very) ill-judged from the perspective of herbal medicine being a safe medicine in tune with the Earth – then you will have to answer to your heart and souls as to how long this can be sustained in the name of true well-being on a micro and macro level. And while at the moment this is a UK issue, I am in no doubt the (old) schools of over control would like to see similar implemented elsewhere. Just look at what the USA is doing to control gardening, and people growing their own food in any shape or form….all stories from the same sorry mindset that does not serve life.
February 19, 2011 at 1:48 pm
Jennie Wharam
Devastating news for all Traditional Herbalists. The battle isn’t over and the “pro regulatory” advocators have very shaky foundations. We must keep the Faith.
February 20, 2011 at 7:29 am
Phil
On the legislative side, the following can be read in the EU document ‘Communication from the Commission to the Council and the European Parliament’, dated Sept 2008: “….it should be emphasised that Community legislation on medicinal products, in particular directive 2001/83/EC laying down the procedures for placing products on the market, follows a product-specific approach and does not attempt to provide a framework for the regulation of traditions of medical practice”. This statement by the European Commission goes out of its way to state that the Traditional Herbal Medicinal Products Directive only concerns the marketing of products (as indeed its title would suggest), and is not concerned with the regulation of practitioners. Conversely, the Health Minister’s announcement on SR would appear to indicate that the government is seeking to use a section of the Directive – stated by the MHRA as the derogation allowed by Article 5(1) of Directive 2001/83/EC – as the basis for regulating herbal practice. Such an act would, however, constitute a direct infringement of the scope of the Directive as stated by the European Commission. The government wants to use this derogation and permit ‘authorised healthcare professionals’ to supply unlicensed medicines to their patients, this constituting the basis of their rationale for regulating herbal practitioners. The Health Secretary would appear to confirm this by saying “The practice of acupuncture is not affected by the EU Directive and, therefore, compliance is not required”. This means to say that the government is seeking to make herbalists comply with a Directive which the European Commission specifically states does not provide a framework for the regulation of traditions of medical practice. The government is not proposing to regulate acupuncturists, stating that they fall outside the scope of the Directive. By the same token, they should not be proposing to regulate herbalists on this basis either, because they too fall outside the scope of the Directive, as is made clear by the European Commission.
The announcement on SR simply does not stand up to an analysis. For that single reason, let alone any of the many others – which would include ethnic and religious discrimination, breaching the human rights laws by disqualifying many thousands from earning their living, and the fact that the HPC would be in breach of its own regulations if it regulated a profession that had no evidence-base for its practice – I cannot see the proposals coming to fruition.
February 24, 2011 at 2:06 pm
Caroline
Not sure this is the best place to post this comment (aware that internet polarises opinion) but until someone else organises a face to face forum of herbalists, i thought i’d give it a go!
I lean towards the type of herbalism advocated on this website and agree that in my ideal world i would prefer to practice without state interference, or without issues of money raising their ugly head. Indeed i would like it if there were no need for state or money. But in my experience our best chance (as activists) of getting to this utopia, and in the mean time increasing the access of low income groups to herbal medicine, is to build alliances with other progressive groups, including the traditional left, who are of course strongly committed to defending and extending state funded healthcare – in my view rightly.
It seems to me that there is a great opportunity here – as well as risk. if the state is going to regulate herbalists and demand certain standards of training and safety, then in return would we not have a stronger argument for the state to fund herbal treatment, if patients want it (incidentally saving lots of NHS cash!)? Other HPC regulated professions get state funding to practice and for training, as well as a much higher profile. All these things mean these other HPC regulated professions are currently more accessible to low income groups (both as patients and as practioners) than herbalism is.
I’m not blaming either side (though i don’t think some of the herbal manufacturers have helped) but can we try not to polairse things so much? I’m a first year student on a NIMH accredited course so my lecturers are mostly ‘pro’ SR but I know they are also concerned about the risks and it seems to me we REALLY need to work together on this. I understand the concerns around the expense of accreditation, the potential for inteference with how we practice from people who don’t understand herablism, and the issue of recognising the skills of people who may have been practicing effectively and safety for years, outside the nimh structure.
These are real issues and I would actually like to understand these concerns a lot better. I would like it if these issues could be debated somewhere (not online!).
But I would also like it if people could reflect on the potential benefits rather than assuming the ‘pros’ have been brainwashed by lobbyists, or that we don’t share an awareness of the need to address the bigger picture ie the ills of environmentally destructive capitalism!
Can we find enough common ground to unite against our real enemies, or shall we stay divided, and give them succour? It really dismays me to see herbalists I respect enormously line up with David Colquoun, Bad Science, the Royal College of Physicians, and the allies of big pharma, and oppose SR (which as previously posts correctly point out, is NOT yet a done deal).
Can we not work collectivcely to ensure our real concerns are properly addressed? Herbalists have been demonised for centuries, but rather than be pessimistic about the ‘devil in the detail’ perhaps we ought ensure there is ‘spirit in the detail’, ensuring that there is a way that existing skills can be recognised and accredited if they want, that people’s ability to practice evidence based medicine (not just a reductionist RCT-dependent concept, but recognising the experiences of both practioner and patient) is recognised and improved, and most importantly that our regulators are people from within our own tradition as far as possible and who understand us properly. Maybe even, some of you?!
Any chance of a face to face about this stuff???
February 25, 2011 at 8:20 pm
Therri Lahood
Dear Caroline, herbs and their healing properties belong to every person on this planet and it is fundamentally wrong for any one group to control access to them to the exclusion of everyone else. Sometimes, when such an important principle is at stake, it is not possible to compromise on the detail. As Edmund Burke said, “for evil to succeed, all that is necessary is for good men to do nothing”. To this you could add “or make the best of it”.
February 26, 2011 at 3:29 pm
natlyc
Dear Caroline, Most of the herbarium were part of nimh at one time. many of us tried to have debates about SR when the process was being ‘explored’ more than 10 years ago. No debate was allowed.
Part of the problem is not only that SR is a crap thing for us as herbalists & for the general public but that the process has been conducted in such a dishonest, manipulated and overbearing way.
I realise that this is distressing for you as a student but it is true.
February 26, 2011 at 9:40 pm
natlyc
Dear Caroline, can i suggest that if you haven’t already, you read the articles that we have posted here about SR?
February 27, 2011 at 11:33 pm
Caroline
hi natlyc, thanks for your response, i’ve read the stuff on here about SR and i still have questions about exactly what the fears are, though i understand the concerns about the way the debate has or hasn’t been conducted. i realise i’m new to all this and it’s sad to hear that a debate wasn’t allowed 10 years ago and i can understand why people who tried then are reluctant to try now, but i would still hope there might be some willingness on both sides… seems to me there is a lot at stake.
i also agree with the other poster that herbs are our birthright, but will people (ie non registered herbalists) not still have access to herbs so long as these aren’t sold processed, mixed, or advertised with medicinal benefits? and also no-one can stop ordinary people treating each other with herbs that we grow or pick ourselves, can they? sorry i realise these are basic points but i am quite confused about this, i agree the debate has been conducted in less than clear terms.
February 28, 2011 at 11:24 am
herbalistic
Hi Caroline, the plan is not to stop legislating once SR is enacted. The next step is reform of s12(1) of the medicines act, which will entail restricting the legal practice of herbal medicine to SR’d practitioners. In reality, the DH or MHRA may not be able to monitor or even stop all ‘illegal’ herbal practices, but herbalists outside the legal structures would have to be self-sufficient (they would not be allowed to buy medicines from suppliers, for example) & would run the risk of being caught for carrying out an illegal activity. This is not a jaundiced, dystopian vision of our herbal future, the DH & particularly the MHRA have written of their plans quite openly. I’m not sure what common ground I would have with herbalists that think this legal tip-toe to destroying our freedom to practice is a necessary & good thing…
February 28, 2011 at 4:41 pm
philip
dear Caroline
I was interested in your question “but will people (ie non registered herbalists) not still have access to herbs so long as these aren’t sold processed, mixed, or advertised with medicinal benefits?” You are referring here to the current right of herbalists to operate under Section 12(1) of the 1968 Medicines Act.
Here is an extract from the MHRA announcement on the proposals for SR:
“If practitioner regulation is in place for the purposes of creating an Article 5(1) scheme this also opens the way to reform Section 12 (1) of the Medicines Act 1968. Under Section 12 (1), practitioners may prepare unlicensed herbal medicines on their own premises for use following consultation with individual patients. It is intended to move to the position that only registered practitioners would be able to operate under Section 12 (1) after regulation of practitioners is in place”.
Does that give you the answer you were looking for?
March 1, 2011 at 12:53 pm
Kate
I think what Caroline is asking is; will the general public (non herbalists) be able to still buy herbs fir their personal use? And I believe the answer to that question be yes, as long as they buy from herbalists who are registered under the SR (if it goes through to completion).
I agree completely with the views and opinions of the herbarium, I have had my niggles about the SR since I first heard about it, and the information I have read here has confirmed my concerns, I for one (due to qualify as a herbalist at the end of this year) sincerely hope that the SR does not get to completion and that Section 12(1) stays exactly as it is. Otherwise I feel that everything that has been gained by traditional herbalists over the past 300 or so years will be lost due to people who believe ‘they have the powers that be’ not understanding the basic principles of traditional herbal medicine that has been practised as a craft since the beginning of humankind for healing and well-being for all mankind (and animals etc). I feel personally that if this were to go ahead then they would be treating traditional herbalists no better now than when we were burned at the stake during the witch trials. Let us do our job the way we know best that has been passed down through hundreds of generations and they should get on with far more pressing issues not being dealt with properly by the government like affordable housing and education etc. We dont tell them how to do their job, so they should stop trying to tell us how to do ours.
March 1, 2011 at 8:26 pm
herbalistic
Hi Kate, I think you’re making a dangerous assumption about the general public being able to buy herbs for their personal use from herbalists under SR & s12(1) reform. Firstly, such an activity would be classed as OTC & therefore fall under the THMPD. Secondly, we’ve no idea what s12(1) reform would look like (other than restricting the practice of herbal medicine to SR’d herbalists).
March 2, 2011 at 7:22 am
Kate
Hi Herbalistic,
I was referring to the companies like Neals Yard and Baldwins that I’m assuming have herbalists on hand who would presumably be registered under the SR if it goes through so that the general public can still buy herbs for their personal use from those companies as they do now. I don’t see the general public all wanting to pay a consultation fee to a SR herbalist just to purchase their herbs.
March 2, 2011 at 1:36 pm
philip
hello Kate
The problem is that for an SR’d herbalist to sell herbs OTC would take them out of the practitioner field (in which they would be authorised) and into the OTC field, which is then restricted by the THMPD, as herbalistic says. Have you contacted the two companies you mentioned, to ask how they see it?
March 2, 2011 at 7:32 pm
Kate
Hi Philip,
No I haven’t contacted them yet but I will do, thanks.
March 11, 2011 at 9:36 am
Caroline
hi philip & co, thanks for the response re section 12(1). sorry for delay in responding, i guess i was feeling a bit out of my depth! but i understand better now. my next comment was going to be ‘if that is the most pressing concern then please can we focus on that issue and try and unite around it’ but i see you have done exactly this on the subsequent post on this site. so many thanks again for the people who run this site and their thoughtful posts.
March 11, 2011 at 2:57 pm
Helen
I am a midwife and a very new student of herbal medicine. Being a member of a profession which has very heavy SR I know that whilst at best it can be supportive of practitioners and increase standards of care, at worst it is punitive, ill-informed of specific practice issues and often does not improve practice, standards or public health. Our litigious society has brought us to the point where childbirth and midwives are heavily regulated, governed by policy procedure and protocol and a step outside of the accepted norm even where that practice is ‘safe’ leads to investigation.
Whilst I am not arguing against SR for midwives or other members of the registered healthcare profession per say (although I can dream in a utopian society!), improvements are desperately needed and our own regulatory body the NMC are are the subject of investigation and consultation for the massive problems in process and function of this dinosaur of an institution.
The safety of traditional western herbalism is well established given the low cost of insurance and the relatively small numbers of cases brought. It is a world away from the levels of litigation in obstetrics or general practice. SR increases litigation and malpractice by tightening our views of what constitutes ‘correct practice’. My fear is that this will happen within herbalism too and it is so disproportionate.
When I decided to train as a herbalist, something I have been aspiring to for many years, I researched courses and was told time and time again that I should train with an institution accredited by NIMH or EHTPA yet without moving this was almost impossible. The nearest institutions fees would have amounted to over £30,000 for the three years training, more than it cost me to train as a midwife and the huge amount of money asked didn’t seem to improve the course content when judged against the more reasonably priced more traditional mentorship program which I eventually decided on. It will still take me three years to complete my training and at the end of that time I just hope and pray that there will be a way to practice the kind of herbalism I want to practice rather than a herbalism which has become a poor relative of conventional medicine, treating symptoms rather than the whole person.
SR will ensure the demise of the institution eventually because courses are too expensive, institutions too spread out to train enough herbalists and no doubt the tide will reverse because people will always need herbalists. The Scottish School of Herbal Medicine has already closed. I too believe (or want to believe) that as long as there are herbs in our gardens and plants in our hedgerows, there will be those with the expert knowledge to help people use them.
Thank you herbarium for the information and for keeping us all up to date and for being a beacon of home in this insanity.
March 11, 2011 at 10:05 pm
Therri Lahood
Hi Helen, I loved your post, thankyou. I’m really interested to know more about your training choice. However, if you are not comfortable sharing on an open forum I fully understand, these are strange times indeed.
Take care, Therri
March 13, 2011 at 8:54 pm
Helen
Hi Therri,
Being very new to the field and really with only my own research and conversations with local herbalists to go on, I based my choice on course content, school location and very much liking the folk I spoke to at the school. I am discovering more and more that just as in midwifery, there are are many politics in the world of herbalism with some recommending the same courses that others will look down their noses at!
I am just about to start my foundation year with the School of Natural Medicine based in Cambridge. I like that the course has a very holistic, naturopathic focus and is very mentorship lead.
Best wishes, Helen
March 14, 2011 at 1:03 pm
therri
Dear Helen,
The very best of luck with your training and thank you for sharing. I have a great regard for Dr Christopher and the American naturopathic approach. I hope you enjoy every minute.
Kind regards, Therri
March 15, 2011 at 10:23 am
Helen
Dear Therri,
Thanks for the encouragement, I am sure I will! :)
Helen
March 16, 2011 at 8:42 am
Lesley
Folks how are we going to fight the amendment? I think this site is fantastic but I fell upon it by accident, after seeing allied health posts on facebook – yet couldnt find anything this detailed and with correct facts elsewhere. Whats the plan – does anyone have details of the present point section 12(1) is at – who to take the issue up with and how are we going to get people on board to back this! I think the important point that might not have been significan that long ago, is if big manufacturers go out of business due to world events, peak oil, is the knowledge going to be left, and will the new regulated herbalists really know how to grow, identify and make all the preparations. I’d like to begin today to try and stop this amendment but need information of where it is all at and what people are doing right now – and I think it needs to go out to a wider audience. Transition towns are having a big meeting this year, the information could also be circulated there. My email is is anyone wants to send me information of what is happening, because its not too late yet – mslesleyroberts@hotmail.co.uk
March 16, 2011 at 5:18 pm
herboscy
Hello Lesley,
There’s no planned ‘campaign’ that I know of as yet – apart from anything else, we’re in a rapidly changing situation – for instance, there was a Government announcement just today that all other complementary therapists are ‘off the hook’ where SR is concerned. If the plans for herbal medicine remain firm, there will be at least two consultations (DH & MHRA) to respond to, and then at least two bits of law to go through parliament that we can lobby MPs over… if it ever gets that far.
Stephen
March 16, 2011 at 6:58 pm
Lesley
Oh I dont like the idea of leaving it till then, like the forest campaign we need to be prepared, because they love telling you things at the last minute. And maybe it will go through the house of Lords and there are alot of Lords to lobby. I think the word should be spread wide, because it means people in general will not have the choice. If an individual herbalist has the knack of making a particular tincture, and i have had some incredible ones, that cannot be compared to those from bigger producer for their health.
March 16, 2011 at 7:00 pm
Lesley
…..the why should the consumer be denied having the choice of having that tincture. Just an example.
March 30, 2011 at 9:34 am
Herbelfast
Much of the confusion over this issue is the speculative nature upon which many people are basing their opinions.
SR may go through, SR may not go through, SR does this, could do this, might do this etc
We are all now subject to European legislation, that is to say Napoleonic Law which will displace and replace Common Law. Under common law everything is legal until deemed otherwise. Under Napoleonic law the opposite is the case – everything is illegal until deemed otherwise. THMPD is a classic case of the Napoleonic system.
To be honest I tend to side with the general thrust of this site, being diametrically opposed to having my tradition regulated or legislated upon by those who know nothing about it, BUT I am also concerned that trying to operate outside of the law with the very best of intentions will be an uphill struggle.
I think the main focus might still be on what can be done with THMPD.
To my knowldege only 32 herbs have licenses under THMPD with a few others in the pipeline, while others can be classified as foods. How the interpretation of THMPD will be implemented remains to be seen (with safety issues thought to be the priority). No herbs from the Ayurvedic or TCM distinctions have been granted a license. In effect while consumers will obviously be affected, so too will suppliers of any herb which is unlicensed, meaning that in terms of supply we may be left with a very narrow range to operate from, like the 32 ‘medicinal’ herbs mentioned above or those that fall under the category of food.
There is apparently a judicial review of THMPD being launched by ANH but as it stands this legislation is a far greater threat to our tradition than speculation over SR and the Medicines Act.
I agree these are vital issues but in practical terms we need to collectively look at our position and how we can best serve the tradition, and all that implies, in the now.
In practical terms that means preserving any plants which fall foul of the legislation – the establishment of physic gardens with this remit (along with protection of endangered species) should be a paramount to this process. Preparation of definite monographs which are easily accessed on anything that is threatened so as to preserve knowledge base might also be considered. And in the meantime we fight tooth and claw.
Once enforced we are open to litigation and despite our best intentions we need to be very wary of that, whether it is THMPD, SR or whatever else they have planned or are planning in the coporate boardrooms of Big Pharma.
March 31, 2011 at 12:25 pm
philip
I agree with your sentiments. If the THMPD can be stopped, then SR for herbalists must be off as well, as it was to circumvent the THMPD that the proposal for SR was announced.
May 5, 2011 at 4:21 pm
philip
As the (single) reason stated by the Minister for the proposed SR of herbalists was to sidestep the THMPD, I cannot see that SR could go ahead while there was a legal process underway to get the THMPD overturned/amended (ie. the ANH’s challenge in the courts). If this were to happen (or even be attempted), the Dept of Health would lose its credibility entirely. The outcome of the legal challenge will have to be awaited before any decision on the proposed SR needs to be made.
In the meantime, presumably there will be no prosecution of herbalists who continue to commission unlicensed medicines from third party suppliers, even though the THMPD is effective as of May 1st, and such ought to now be against the law.
This whole affair could go on for years, as legal matters often do.