TGA - sample letter for anybody not seeing a naturopath. Please print and sign Your name sample letter Your street address Your suburb & postcode Today’s date Advertising Consultation Recalls and Advertising Section Office of Product Review Therapeutic Goods Administration PO Box 100 WODEN ACT 2606 Re: Advertising Consultation As an informed member of the public, I want to express my concern about the proposed regulation of advertising of therapeutic goods to consumers and the effects of the proposed changes on the professions Western Herbalists, Naturopaths and Nutritionists. As a regular user of complementary and alternative medicine, the effect of the proposed TGA changes has potential impact on my future health. Western Herbalists, Nutritionists and Naturopaths currently hold TGA exemption from Part 5-1 of the Therapeutic Goods Act; this allows them to receive technical information from companies regarding herbs and supplements regarded as tools of trade for these professions. It has been noted that proposal 6.2 will have a detrimental impact on the practise of Western Herbal Medicine, Nutritional Medicine and Naturopathy, and proposal 5 will also have a deleterious impact should proposal 6.2 be implemented. My concerns relate to the following proposals: Proposal 5: Advertising of higher risk medical devices Option 1: Status quo - maintain the current system. Option 2: Prohibit the advertising of higher risk medical devices. While proposal 5.2 is supported in principle I am concerned that proposal 6.2 will deny Western Herbalists, Naturopaths and Nutritionists access to tools of the trade such as In-Vitro Diagnostic devices—for example, bio-impedance analysis, live blood analysis, urine analysis and other in-clinic testing and monitoring devices or tools. Proposal 6: Advertising directed to health professionals Option 1: Status quo - maintain the current system. Option 2: Update the exemption for health professionals in section 42AA of the Act to only recognise health practitioners regulated under the Health Practitioner Regulation National Law. Either the current list of health professionals should remain (option 1) or Western Herbalists, Naturopaths and Nutritionists should be added to the new list. As previously mentioned, option 2 deprives Western Herbalists, Naturopaths and Nutritionists tools of trade to practise effectively and safely. The potential consequences of not considering these suggestions will have an impact on the following: Potential redundancy of tertiary qualifications: Currently, students of Western Herbal Medicine, Naturopathy and Nutritional Medicine study either an Advanced Diploma or Bachelor degree in these modalities. These are advanced, highly technical and increasingly evidence based qualifications. The knowledge and professionalism gained in these courses certainly places Western Herbalists, Naturopaths and Nutritionists at a much higher level of expertise than a member of the general public. The proposed TGA changes also have the potential to bring redundancy to courses which have been studied at considerable financial expense. These courses are continually accredited to ensure the highest level of educational compliance through ASQA. These courses place students at a level of education equal to other allied health care professionals. Public safety: Currently, practitioners and students receive important technical information on efficacy and safety of listed therapeutic goods from practitioner-only companies both in written material and via face-to-face seminar activities that comprise a portion of continuing education for the professions. Such activities encourage the updating of our knowledge (which is vital for safe professional practice). Additionally, this allows both practitioners and students to employ critical analysis of research, sharing of professional knowledge, and promote other professional behaviours such as adverse reaction reporting and referral to other medical professionals. This enforces the important point of Scope of Practice. All these elements contribute to public safety. Maintaining expertise: Herbalists, Naturopaths and Nutritionists currently hold expertise in herbal and nutritional medicine, in particular holding the highest qualification resulting in the prescription of herbal medicines. A recent study confirmed herbalists and naturopaths had similar knowledge to pharmacists in clinically proven benefits of herbal medicines, and significantly better knowledge than pharmacists of clinically significant interactions . These findings provide evidence that contradicts the TGA’s argument for excluding naturopaths and herbalists as recognised health professionals. Scope of Practice: The current minimum standard to practice Western herbal medicine and naturopathy is an Advanced Diploma. However, the professions are moving toward Bachelor degree as minimum standard, and many hold post-graduate qualifications. The professions are also moving from a mainly tradition based body of knowledge to evidence based practice (EBP)1. This is supported by current education standards in all tertiary education sectors and professional association course accreditation requirements for research, clinical sciences, herbal therapeutics and toxicology. In conclusion, I recommend that the TGA either maintain the status quo (6.1) or add Western Herbalists, Naturopaths and Nutritionists to the new exemption list as they are legitimate qualified health practitioners. To do otherwise is to add risk to public safety and adversely affect the practice of naturopathy, herbal and nutritional medicine, potentially resulting in professional and financial hardship. Yours sincerely (your signature) 1 Braun, LA, Spitzer, O, Tiralongo, E, Wilkinson, JM, Bailey, M, Poole, SG, & Dooley, M. (2012). Naturopaths and Western herbalists’ attitudes to evidence, regulation, information sources and knowledge about popular complementary medicines. Complementary therapies in medicine. 2012;21:58-64.
Posted on: Thu, 11 Jul 2013 02:44:32 +0000
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