Issue:
96
Page: -
Letters to the Editor
by William Egloff, Holly J. Bayne, R. William Soller, PhD, Daniel E. Moerman, PhD
HerbalGram.
2012; American Botanical Council
To the editor,
Re: Soller RW, Bayne HJ, Shaheen C. The Regulated Dietary
Supplement Industry: Myths of an Unregulated Industry Dispelled. HerbalGram 2012;93:42-57.
This article is really great!
I am curious, however, as to why 2004’s Federal
Register notice (FR69 6787) “Final Rule on Ephedrine Alkaloids, etc” (21
CFR Part 119) was not included in Table 1 on “Key Developments of the Legal
Framework.”
Losing the ability to prescribe ma huang [aka ephedra; Ephedra
sinica, Ephedraceae] (even at 24mg/day Total Ephedrine Alkaloid) had a
HUGE NEGATIVE regulatory impact on the traditional Chinese medicine (TCM)
state-licensed practitioner community.
Does this regulatory precedent pose a problem for future
regulatory restrictions on certain TCM herbs? Obviously.
The process of banning ma
huang was a relatively easy regulatory reaction to a perceived urgent
situation.
- Practitioner-prescribed risk data on ma huang could have been obtained from Taiwan or Japan.
- Banning herbs is not an acceptable
regulatory solution for trained and licensed practitioners.
- Maximum Daily Dosage of some herbs
needs to be studied and allowed.
William Egloff
Owner, Crane West Herb Company
Sebastopol, CA
To the editor,
Thank you for your letter and for bringing to our attention that FDA’s
final rule on ephedrine alkaloids in dietary supplements (Dietary Supplements
that Present a Significant or Unreasonable Risk) was not included in Table 1 of
our article. Table 1 is primarily focused on legislation, covering the major
Acts of Congress relating to dietary supplements. Since certain FDA regulations
were included in Table 1, however, we appreciate your view that FDA’s ephedra
rulemaking should also have been included, as it represents a major regulatory
development. We will consider inserting the ephedra rulemaking into Table 1 in
a revised online version of the article.
We addressed the ephedra rulemaking and ban in the body of the article,
under the section “The Effect of the Ephedra Controversy.” We understand your
frustration relating to the absolute ban of ma
huang, even by licensed complementary and alternative medicine (CAM) practitioners. A review of the practice (utilization) of ma huang by licensed CAM practitioners and the impact on patient
care and outcomes of the ephedra ban was beyond the scope of the article. This
is an area of continued interest, particularly among CAM practitioners.
Holly J. Bayne Attorney and Founder, The Law Office
of Bayne & Associates Washington, DC
R.
William Soller, PhD
Executive
Director, Center for Consumer Self Care Health Sciences
Clinical
Professor of Pharmacy, University of California – San Francisco
To the editor,
Re: Engels G, Brinckman J. Cinnamon. HerbalGram 2012;95:1-5.
Just a note to say that I really enjoyed the
article about cinnamon [Cinnamomum verum,
Lauraceae] in the current HerbalGram. One additional “folk use” of it comes to me
from Jason, my beekeeper, who suggested sprinkling it around the beehives to
repel ants. After learning that, we
tried it on the back porch this spring (where we had quite the invasion of
them). Worked nicely. Sorry, no RCT
[randomized controlled trial] randomly comparing cinnamon to inert brown powder
is available.
Best,
Dan
Daniel E. Moerman
William
E. Stirton Professor Emeritus of Anthropology
University
of Michigan-Dearborn
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