On 26th March 2015 the Department of Health published its ‘Report on the Regulation of Herbal Medicines’, authored by Professor David Walker. You can access the full report at https://www.gov.uk/government/publications/advice-on-regulating-herbal-medicines-and-practitioners – but it is summed up thus: –
‘Having taken into account the evidence available and the views of representatives of the sector, I consider that despite strong calls by many for statutory regulation, there is not yet a credible scientific evidence base to demonstrate risk from both products and practitioners which would support this step.’ (p.28).
This effectively puts the whole issue of the statutory regulation of herbal medicine ‘on ice’ for the foreseeable future. Hooray! A victory for clear thinking, common sense and the precautionary principle! Let’s hope this is the end of the top-down dictatorial bureaucracy that has plagued herbal medicine for so long, and heralds a new era for the grass-roots approach that The Herbarium has joined so many others in fostering.
However, you may have noticed that The Herbarium has been ‘on ice’ itself for more than a year. It’s true to say that those of us who have been working diligently to counter statutory regulation for years (in some cases, decades) have found it arduous and on occasions personally very distressing, so at the risk of mixing metaphors, we feel somewhat burnt out. Equally in the last year or two, we have all found ourselves moving on in one way or another – new homes, new children, new jobs.
The Herbarium will remain on the internet as a reference – the ‘political’ posts may have some historic interest, more importantly the practical medicine-making files, and our other informative articles still continue to grow in relevance and popularity. There might be more to add in time – perhaps new blood, new inspiration – but for now, we’re resting! A big ‘thank you’ to everybody who has looked this way, subscribed, commented, and most important, used the Herbarium as a practical workbook.
Neil Pellegrini (‘herbalistic’)
6 comments
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April 8, 2015 at 10:03 pm
The Hopeful Herbalist
Thanks for the update, and for all the info at Herbarium, I really enjoy dipping into its wealth of knowledge. Hope you will come back refreshed in the future.
April 9, 2015 at 12:07 am
madhupamaypop
That is wonderful to hear. Does this affect just England/UK or all of Europe? Just curious. I live in the US but have been wondering about how things are shaping up for you all. I remember meeting a friend’s mother from Germany who had a tea/herb shop for many years. She told me that she couldn’t even formulate a tea blend without putting before the pharmaceutical board. That really surprised me!
April 10, 2015 at 8:24 am
herbalistic
Just the UK. The report does not question the traditional basis of herbal practice in the UK nor our right to practice here.
April 11, 2015 at 9:22 pm
Jenny Allan
Many thanks for your treasure trove site and more importantly for your inspiring idealism and integrity, eloquently expressed in your mission statement. To all of you, thank you for your work. May you all flourish and prosper like a joyful midsummer garden of herbs!
April 12, 2015 at 9:06 am
Lynn
Thank you for this update and for your information-packed site. I recently moved to Scotland from the midwestern U.S. and have been surprised and sad not to see small-scale, lovingly harvested and handmade herbal products available at farmers’ markets, in etsy-style shops and on natural foods store shelves, as I used to do in America. Perhaps this will change now?
April 28, 2015 at 8:51 am
Phil Evans
The following piece has come my way, and I thought here might be a good place to put it up.
Herbalists: the way forward (2015)
The failed quest for Statutory Regulation of herbal practitioners must confront the herbalists who are proponents of SR with something of a crisis of identity. Up to now, their vision of the direction of their profession has in effect been based on its identity, and even its validity, being dependent on association with and acceptance by orthodox science and allopathic medicine. Seeking validation of this nature must demean their sense of self-worth, which in turn, from a psychological point of view, would most likely de-skill them as confident practitioners. The belief that they are in some way deficient without the approval of the HCPC is a misconception, of which they seriously and rapidly need to be disabused.
The current situation has placed such herbalists at the crossroads. SR has now been declared impossible by the Deputy Chief Medical Officer’s Report on the Regulation of Herbal Medicine and Practitioners, published in March 2015, for two primary reasons: 1) there is no evidence that herbal medicine overall is posing a threat to public health, and 2) there is no scientific evidence-base to support what herbal practitioners do.
The UK Department of Health has summed the SR situation up by saying the following: “The main conclusion of the Report was, ‘Having taking into account the evidence available and the views of representatives of the sector, [Professor Walker] considers that, despite strong calls by many for statutory regulation, there is not yet a credible scientific evidence base to demonstrate risk from both products and practitioners which would support this step.’ “
The Report does of course go into much more detail. It states that investigation into the alleged dangers of herbal medicine had failed to reveal that they existed in anything like the degree the government had been led to expect, and that the potentially dangerous medicines that had existed (in the form of rogue, adulterated unlicensed products) had been removed from the market by the final full implementation of the THMPD. In addition to this, the Report also states the opposition of sectors within the National Health Service to admit herbalists onto their “hallowed turf”. The Report also explains specifically that the proposal to introduce an inappropriate degree of regulation (SR), by using Article 5.1 of the THMPD as a means of allowing unlicensed products back onto the market, had been ruled out under EU law.
The SR proposal has now therefore been ruled both out of the question through lack of evidence bases, and not allowable by law. The full 40-page report is available on the DoH website. It is a thorough evaluation of all the points of view that had been put forward by the interested parties involved, and does not leave any discernible leeway for reinterpretation.
There is of course the saying that “if it ain’t broke, don’t fix it”. With Regulation 3(6) of the 2012 Human Medicines Regulations enshrining in law their right to practice, if herbalists decide that their role is to offer a dynamic and effective alternative to pharmaceutical drugs, then they are already exactly where they need to be, and all they actually need is the self-validation and the belief in what they are doing, along with the same passion that originally brought them to study herbal medicine in the first place.
We all stand in the here and now, not some mythical future. Being here and now, it is our job to deal with it as best we can under the guidance of our personal truth. By doing this we transform the here and now, rather than discard our truth in pursuit of some ill-conceived green grass on the other side of an imaginary fence.
Many herbalists believe that the nature of traditional herbal medicine does not academically belong under the heading of “science”, and that instead, it should be taught under the heading of “humanities.” This would allow the inclusion of its energetics, spiritual aspects and life force of the herb involved. It is for this very reason that the pursuit of HCPC regulation, with the limiting qualification of a science degree, automatically involved a major threat to the future teaching and subsequent practice of all genuine traditional medicine, be it Western, Chinese, Ayurvedic, Unani Tibb or indeed any other tradition.
Bearing all of this in mind, the message that needs to be brought to proponents of SR is that they need to rediscover the original nature of herbal medicine so that they become better equipped to practise it, and to wake up and recognise why they are doing it in the first place. After all, if they really are so besotted with the world of allopathic medicine, they would have been more true to themselves if they had trained as conventional doctors.
Herbalists are now all back on the same side again, where they started. The man-made malignant syndrome of “we’re qualified, but they’re not”, together with its secondary, even more dangerous phase of “we’re safe, but they aren’t”, now no longer exist, unless some herbalists continue to choose to see it this way, and to discredit herbal medicine by propagating such concepts. If there are future threats to the practice of herbal medicine, then herbalists must all stand together and combat them, not split apart into factions.
It is perfectly understandable that some individuals may find these thoughts and opinions unacceptably challenging, while others hopefully will feel that they speak to their hearts.
If any of this is of any use to you, please use it as you see fit. If you fundamentally disagree with anything put forward here, this in turn may help raise and focus your awareness on the detail of your own opinions.
Either way, it is hoped these comments will be useful to you.
About twenty years ago, someone was asked where they saw herbal medicine going in the future. Their reply was that herbal medicine is already exactly where it is supposed to be.