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from Susun Weed re: Proposed Regulatory Model for Traditional Medicines

Posted Nov 03 2008 8:46pm

To: Michael McGuffin, American Herbal Products Association

From: Susun Weed
Re: no licenses for herbalists

March 23, 2006

Dear Michael,

Thank you for responding so thoroughly and promptly to the concerns of the herbal community, including myself and Rosemary Gladstar, in regards the "Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components."

Your challenge to us to find the "exact place" that this work builds in licensing is beside the point. The entire document builds in licensing. As soon as we open the door to regulation, as soon as we refer to herbs as medicines, as soon as we start defining how, when, why herbs should be prepared and used, we have lost herbal medicine and created a vortex that will, sooner or later, result in licensing/regulation for those using regulated substances.

No, you may not assume that I "do not want an herbalist who is not qualified to use an herb to use it anyway." This points to licensing, does it not? Who is qualified to use which herbs? Who is qualified to tell me which herbs I may and may not use? I do not want anyone to have that power.

My, very personal, opinion is that golden seal and cayenne are widely misused. But, fortunately, I don't have the power to force other herbalists to conform to my thoughts/rules. I want each one of us to have the right to use herbs as we see fit, even if others disagree with us.

It is pretty obvious that many people, including herbalists, misuse echinacea, too. Are you proposing that only "qualified" herbalists should have access to echinacea and they alone are safe to misuse it? I want people to have the right to misuse herbs if they want to. They already misuse alcohol, pain killers, and other, potentially more damaging, substances.

According to the new, scientific herbals that I consulted, yellow dock root preparations are unsafe to use during pregnancy. The first dozen midwives I asked laughed at this. Their experience, and mine, point to the opposite conclusion. Are you seriously suggesting that I support any rules that would replace my sisters' wisdom?

One of the apprentices I trained last year practices midwifery in Germany.

She found Hypericum ointment on the nipples of newly-nursing moms countered pain and helped establish a good nursing relationship quickly. But she was frightened of suggesting it to new moms, as, she told me, her supervisor threatened to take her to the licensing board if she did, for it is well known in Germany that Hypericum has adverse effects on infants. If that statement has your scratching your head in bafflement, then you know why I am against the model you propose. Any laws made about herbs will lead to more laws, about herbs, and about herbalists. (According to Aviva Romm and sources she consulted, no infant has ever been harmed by Hypericum infused


The point is that herbs are generally safe enough to stand a little misuse.

That's why herbal medicine is people's medicine. That's why I am against your proposed model. That's why I smell licensing written between the lines in your assumptions and components. Once you establish regulations for herbs, people will be regulated. If you don't see that, I ask you to observe what has and is happening in Europe and Canada, where laws have and are, slowly but surely, strangling the freedom of herbalists and herbalism.

I am insulted to be told by you that "all of the herbs are at risk of being taken away." This is so far from the truth that it would be silly -- except that you seem to believe it, and your paranoia seems to be affecting others. During the forty years that I have actively been involved with herbs, herbalism, and herbalists, I have heard that fear repeated many times, but it has not, and will not, happen. Are vitamin and mineral supplements still sold over the counter? Yes! Have there been laws trying to take them away from us? Not really, but people were led to believe so; and they responded with an outpouring of letters, e-mails, faxes, and phone calls to the House and Senate protesting. Should there ever be a bill proposing to outlaw herbs then I will personally do my utmost to see to it that a similar avalanche of comment reaches the legislature preventing your dire fantasy from coming true.

You decided to "tell it like it is" and "go ahead and call them [herbs] medicines." How dare you?! I have devoted my life to showing that many herbs are nourishing foods, tonics, alteratives, and non-medicine helpers. If I allow you to label nettle or oatstraw as "medicine," I have relinquished the right to use herbs traditionally, and my unique voice has been silenced.

I ask you all to reconsider your proposal from the ground up. The people in Germany whose livers failed after they took a regulated herb found that regulations don't prevent mistakes (the wrong part of the herb was used).

The type of regulations you propose do not protect the consumer; instead they create the idea that herbs -- and therefore herbalists -- need regulation.

I honestly believe that you are spinning the rope that will be used to hang you. Feel into your proposal from your heart, which I am certain is at least as wise as your excellent mind, and let the truth of people's medicine shine out. Let the "man's" ideas of protocols and standards and enforced rules reveal its ugly attachments. Then allow this proposal, this idea even, to gracefully disappear back into the void.

Herbal medicine in the USA is strong and healthy. And, may I assume you agree with the statement: "If it isn't broken, don't fix it."

Green blessings.

Susun S Weed
POBox 64
Woodstock NY 12498


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