Are the guidelines for safe Chinese herbal medicine practice released by the Chinese Medicine Registration board and taking effect in November 2017 ignored or accepted by our profession?
Why would the Chinese Medicine Registration Board release guidelines for the save practice of herbal dispensing? According to an article in the Perth Now (January 2016; http://www.perthnow.com.au/news/western-australia/new-guidelines-for-chinese-herbal-medicine/news-story/d69000520e525fef3b7bb2b6322e1ad3?from=public_rss), a well-known Chinese medical practitioner in Perth told The Sunday Times there was “definitely room for improvement”. And in the same article, Australian Medical Association WA president Michael Gannon said the guidelines for safe practice of herbal medicines should only be considered as an absolute minimum.
“CMBA did a good job in the broadly consultation process for this guideline, and minor issues may still exist and need to be reviewed and updated at an appropriate time” says Max Ma (CMIC Chinese Medicine Industry Council). He also adds that if practitioners are not familiar with Pin Yin, they will urgently need to address this with training to meet the minimal requirements. He noted, that the area of prescribing should be addressed as well.
We have got 12 months to get ready and adopt the standards that are now recommended or better, suggested.
In 2012, I asked 40 of my herbalist colleagues practicing in America and Australia to find out if they had any issues with herbal dispensing. 67% responded yes, they did have issues mainly relating to the availability of scheduled herbs (mainly Fu Zi and Ma Huang), the quality of herbs (especially raw herbs), the legality about herbal dispensing (GMP or not) and the storage and time associated with it.
In the comparison of pros and cons, the following areas were mentioned:
- direct supply of herbs to their patients on the spot
- customising herbs for the exact needs of their patients
- time, effort, space and finances involved in running their own dispensary
- availability of quality herbs
The Chinese medicine registration board reminds us to consider the case of an emergency, where a patient is administered to hospital and it needs to be established promptly what type of medication, herbs and supplements this person would have ingested. This is where the labelling issue of herbs is vital.
Coming from a country (Switzerland) where no Chinese medicine practitioner or medical practitioner is allowed to self-dispense, its common practice to send scripts to a dispensary or a pharmacy (sometimes it’s both). In Australia, every third party dispensary (where a patient has not direct contact with the prescribing practitioner) has to comply with GMP (Good Manufacturing Practice Standards). The TGA (Therapeutic Goods Administration) issues these licenses. All ‘raw materials’ (single herbs and ingredients) need to come from a manufacturer who complies with those standards as well.
So running your own dispensary is still a great option especially if you are working with certified products (products that have a Certificate of Analysis). We found that more and more individuals want to know there the raw materials are coming from and if they are safe to take.
To answer the initial question, are the herbal dispensing guidelines a joy or a pain, it’s probably a bit of both. Any change imposed is opposed. Perhaps some of us will find it difficult to adopt some of the practices and others are already on top of it. For our industry in general, it means great progress