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To: The TGA (Therapeutic Goods Administration)
Stop the TGA and BigPharma Controlling Infomation on Botanical Medicine and Vitamins
Write a submission to the TGA before 5pm, Friday 12 July 2013. Electronic submissions in MS-Word format are preferred and should be emailed to email@example.com. Please include 'Advertising consultation 2013' in the subject line of the email. Include a cover sheet http://www.tga.gov.au/word/consult/consult-advertising-ris-130531-coversheet.docx
TO WHOM IT MAY CONCERN
Dear Sir(s), Madam(s)
I am writing in relation to the Natural Medicine Review by the Department of Health and Aging, the TGA, and the NHMRC.
It has come to my attention that this government is planning to reduce the Health care options available to me (as a consumer and practitioner) in regard to Natural Medicines and Vitamins. This review is being disseminated by means of what appears to be a rushed paper that lacks proper community and industry consultation.
Natural Medicines are used by up to 60% of the Australian population on a daily basis, and of these, half of those people use Natural Medicines for chronic health conditions. This in itself saves the Australian Government billions of dollars annually, as the general public overwhelmingly fund these Natural treatments out of their own pocket.
Natural Medicine consumers exercise the right to take care of their bodies with medicines that have shown to have beneficial effects, ultimately saving an already over-stretched Government Health System.
I particularly disagree with the TGA’s advertising consultation which includes a proposal to update the exemption for health professionals, outlined in 42AA of the Act, to recognise only health practitioners regulated under the Health Practitioner Regulation National Law. The TGA states that it has no formal assurance that those groups of practitioners, not included in the NRAS, are able to exercise specialist judgement when either, treating consumers with advertised therapeutic goods, or advising consumers about the use of advertised therapeutic goods. I believe that it is disingenuous to state that only those practitioners included in the NRAS are competent to advise consumers about herbal medicine and nutrition, considering that none of these groups ( chiropractors, dentists, medical practitioners, nurses and midwives, optometrists, osteopaths, pharmacists, physiotherapists, podiatrists, and psychologists )have any training in either Herbal Medicine or Nutrition!
As the TGA has stated that it has no formal mechanism to determine whether all practitioners in the groups listed under section 42AA of the Act are more competent than ordinary consumers to assess advertising about therapeutic goods, I would suggest that the TGA board, in the interests of consumer health safety, resign immediately and elect a more competent panel to make such decisions! Does the TGA have any formal mechanism to determine whether those listed in NRAS are any more competent than ordinary consumers?
Already, I strongly disagree with Section 42DL of the Act which prohibits, in general, the publishing or broadcasting of advertisements about therapeutic goods that: a) make anti-microbial claims and b) contain statements referring to biologicals. I find this very discriminating toward Natural Medicine Practitioners.
I demand that you allow me the choice as a Natural Medicine Practitioner to give consumers access to detailed and accurate information about Natural Medicines. Health Care practitioners undergo four years of university training (Naturopathy, Western Herbal Medicine, Nutrition, etc) and have a clear understanding of the pitfalls of prescribing Natural Medicines, free of the bewildering flood of information on the “internet”, which would be impossible to control. These changes threaten the livelihoods of many health care providers and put at risk consumers’ access to safe, effective and sensible advice on alternative and biological medicines.
Furthermore, Practitioners access to In-Vitro Diagnostic devices should, I believe, be encouraged not discouraged, together with further funding for good science.
I note that there is concern about the criticism that many of the businesses whose advertisements are being regulated under the Act are also members of either or both CHC and ASMI. There is also concern that the current membership arrangements of the TGA Panel could lead to a potential source of conflict of interest. I feel that any “conflict of Interest” should be declared and as we need people with a background in the area they are supervising; any perceived financial gain or “conflict of Interest” should be discontinued or the person replaced.
To conclude, I believe that freedom of choice should include access to trained Natural Health Professionals who provide preventative measures that create healthy life choices.
I would like a response from you that these rushed consultations will take into account a wider consultation of the public to include all stakeholders of the Natural Medicine Industry.
Why is this important?
The Therapeutic Goods Administration (TGA) is slowly trying to control everyones use of Natural Medicines including Herbal Medicines and Nutritional supplements. They are trying to make it illegeal for Herbalists and Naturopaths to give advice and infomation to the general public on Botanical Medicine and vitamins.