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I was told by a chinese herbalist friend of mine in N.C., USA, that,

new herbal laws slated to be in effect soon, would restrict one from

compiling herbal prescriptions, unless (s)he were registered as a

manufacturer. Which means, any formula given or sold to someone, must

be purchased pre-mixed by a manufacturer.

I'm not sure I understand this correctly. Can someone please

unlighten me? Thanks.

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Your friend in NC is probably referring to the new Current Good

Manufacturing Practice (cGMP) governing dietary supplements

(including herbs) adopted in June 2007 by FDA.

 

The new regulation does not require registration but does require any

dietary supplement manufacturer to ensure quality throughout the

manufacturing, packaging, labeling, and storing of dietary supplements.

 

While it is true that individual compounding herbalists were not

exempted from this regulation, FDA has indicated that they would use

" enforcement discretion " in deciding whether to apply the cGMP to

individual herbalists as long as the herbalist meets certain

criteria. Namely...

 

1. Are appropriately trained to prescribe herbs;

2. Provide individualized, appropriate herbal formulations based

upon a one-on-one personal consultation; and

3. Avoid the use of dietary supplements or dietary ingredients—

including herbs—that pose a known or suspected safety concern.

 

Rather than going into all the details here, you can read more on the

CSOMA website...

 

http://www.csomaonline.org/i4a/pages/index.cfm?pageid=3401

 

Regards,

Bill Mosca

 

--

Bill Mosca, LAc

Executive Director

California State Oriental Medical Association (CSOMA)

703 Market Street, Suite 250

San Francisco • CA • 94103-2100

[Toll Free Voice]: (800) 477-4564 • [Fax]: (415) 357-1940

: bill • [Website]: csomaonline.org

On Nov 14, 2007, at 12:50 PM, ykcul_ritsym wrote:

> I was told by a chinese herbalist friend of mine in N.C., USA, that,

> new herbal laws slated to be in effect soon, would restrict one from

> compiling herbal prescriptions, unless (s)he were registered as a

> manufacturer. Which means, any formula given or sold to someone, must

> be purchased pre-mixed by a manufacturer.

> I'm not sure I understand this correctly. Can someone please

> unlighten me? Thanks.

>

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Yes, that was exactly it. Thanks Bill.

 

Bill Mosca <mosca wrote: Your friend in NC is probably referring

to the new Current Good

Manufacturing Practice (cGMP) governing dietary supplements

(including herbs) adopted in June 2007 by FDA

 

 

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