Protect Your Access to Natural Healthcare
The FDA is using legal maneuvering to try to end your access to natural health products (like vitamins, minerals and herbs) and natural health therapies of all sorts.
Again.
This time, their ploy is to declare that therapies are "Medicine" so any non-physician who uses them will be practicing medicine without a license. Since these practices are "Medicine", any products used would be untested drugs and therefore forbidden.
Here's how it is designed to work:
1. By using the term "Medicine" rather than "Modality" for CAM (Complimentary and Alternative Medicine) practices, the FDA sets the stage so that anyone who is not a licensed physician is breaking the law by using these modalities since they are therefore 'practicing medicine without a license'.
2. By using the term "treatment" rather than "therapy", the FDA limits those who can perform these practices to licensed physicians and, again, anyone who is not a licensed physician is breaking the law by using these modalities since only licensed practitioners can legally address and treat health concerns. So people using these modalities are therefore 'practicing medicine without a license'.
3. By using the terms "Medicine" and "treatment" instead of "Modalities" and "therapy", all substances, including vitamins, minerals, herbs, co-factors, etc., automatically become untested drugs since they are being used to prevent, treat, mitigate or cure disease states. Such use can only legally take place with FDA approved drugs.
Your Comments are Vitally Important
Public, professional and industry comments are being accepted on the FDA proposal to "capture" alternative procedures and products as "medicine" and then make them illegal. The history of these repressive attacks by the FDA makes it clear that public outcry, IN HUGE NUMBERS, is the only effective tool that natural health supporters have to change this disastrous outcome.
PROTECT YOUR ACCESS TO NATURAL HEALTH - ADD YOUR VOICE TO THIS CAMPAIGN
Comments will be accepted until April 30.
By contacting everyone you can and asking for their participation in this comment campaign, we can kill this assault on personal health freedom. Please send the link to the comment campaign to everyone you can reach with a brief explanation of the issues. Urge everyone in your personal and professional circles of influence to protect their health freedom -- their personal right to make their own health care choices.
In addition, it is important to take a moment to email the manufacturers of the health care products you take and ask them to alert their suppliers and customer base to protect their businesses. Your natural health care providers need to alert their patients and colleagues, too.
Posted by Angela-Eloise at 9:12 AM
Comments
Hi:
At the request of some friends, I read the draft guidance. In essence, what the draft guidance says is that the FDA already regulates food, drugs, dietary supplements, and equipment, and, that it is issuing the guidance for CAM practitioners so that they will know if something is regulated and under what Act. The guidance states that, if something is regulated, the Act under which it is regulated depends on the intended use, i.e. is its intende use as a food, supplement or cure. In fact, in two paragraphs in the guidance, the FDA says that it does not regulate the practice of mind-body work or massage. It actually underlined the word not in the paragraph relevant to mind-body work. It says, e.g., that it does not regulate the practice of accupuncture, but it does regulate the needles.
I know that there are people in the CAM community that want the word medicine changed to modality, but I doubt that it will happen as the FDA is using the terms and definitions used by the National Center for Complementary and Alternative Medicine. This division of the government has been in existence, according to the draft guidance, since 1998. It's predecessor agency was created in 1992. Because of this, I doubt that the FDA will change the term medicine to modality. Possibly, the FDA might be persuaded to put in stronger language that it is not looking to regulate the practice of anything or force people to use only licensed physicians.
So, this stuff bout the regulation of food, etc has been out there for a long time, possibly even before 1992, and no one has been forced out of practice yet. That said, it probably doesn't hurt to email the FDA.
Posted by: Kathryn | April 18, 2007 8:37 AM