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Letters to the Editor Issue 206

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listed in letters to the editor, originally published in issue 206 - May 2013

Promise on Statutory Regulation of Herbalists

Open letter sent today to the Prime Minister requesting that the government keeps its promise on the statutory regulation of UK herbalists.

Letter also sent by fax and hard copy by mail.

On behalf of Robert Verkerk PhD
Founder, executive and scientific director
Alliance for Natural Health InternationalRt. Hon. David Cameron, MP
10 Downing Street, London SW1A 2AA

8th May 2013


Dear Prime Minister

Please Keep Your Promise on Statutory Regulation of UK Herbalists

On behalf of many of the 8 million British citizens who use herbal medicines prescribed by a practitioner, I am writing to you to express deep concern over the lack of apparent progress on development of a legislative framework for the statutory regulation of herbalists.

As you will recall, the former Health Secretary, the Rt Hon Andrew Lansley, made this commitment on 16th February 2011.  The Medicines and Healthcare products Regulatory Agency (MHRA) website continues to indicate the Department of Health’s intention to statutorily regulate herbal medicine practitioners.

More to the point, we have heard from more than one MP that your Government may be close to announcing a decision to renege on Mr Lansley’s commitment, which we recall was also supported by yourself in principle.

While many governments have broken promises, doing a U-turn on a policy that seminally affects not only how individuals manage their health, but also how they are protected from unscrupulous or bogus operators, is likely to engender a powerful public backlash.  Such a backlash could be expected given the positive conclusions on herbal medicine and statutory regulation expressed in two recent Department of Health committee reports and a further two public consultations.

Under what continues to be referred to as the “herbalist’s exemption”, Regulation 3(6) of The Human Medicines Regulations 2012 grants “a person” (rather than a qualified herbalist) the right to manufacture or assemble herbal medicines at the request of individual patients.

The MHRA and others have identified considerable weaknesses in this Regulation, some of which we regard as valid.  Not least of which, the Regulation does not specify any requirement for qualifications or experience in herbal medicine by the prescribing practitioner.  In addition, the Department of Health appears to perceive a need to amend the herbalist’s exemption to comply with EU medicinal law (Directive 2001/83/EC), specifically in relation to its exemption which allows “authorised health-care professionals” to supply unregistered medicines (Article 5(1)).

While the MHRA has fully implemented the EU’s Traditional Herbal Medicinal Products Directive (2004/24/EC) as of May 2011, with nearly 200 herbal medicinal products being registered currently under the scheme in the UK, these “are intended and designed for use without [my emphasis] the supervision of a medical practitioner”.  It is of great relevance that almost none of these relate to the longstanding and highly popular Asian traditions of medicine, such as traditional Chinese medicine (TCM) or Ayurveda.  Since products licensed under the scheme are intended for direct use by consumers without supervision by a practitioner, they are not generally relevant to the type of products prescribed or recommended by herbal medicine practitioners.

The repeal of Regulation 3(6) of The Human Medicines Regulations, along with the absence of statutory regulation of herbalists, would result in a disastrous situation for herbal medicine practitioners, their suppliers and - most importantly - the millions of British citizens who rely on these products for their health.  Not only will these citizens potentially be exposed to greater risks from completely unregulated products purchased from bogus suppliers, especially on the Internet, but, in addition, their choice of herbal formulations will be reduced dramatically.

At a time when personal responsibility and patient choice in healthcare are of key importance to help relieve the burden on the over-taxed National Health Service (NHS), we call on you to intervene and:

  1. Progress the legislative proposal for statutory regulation of herbalists.  This could readily be achieved, even if only as an interim measure, by self-regulation of herbalists through designated practitioner associations, most - if not all - of which are already known to the MHRA;
  2. Provide your assurance that there is no risk of repeal of the existing UK herbalist’s exemption until such time that the statutory regulation of herbalists is fully effected.

On behalf of UK patients and citizens reliant on herbal medicines, and the practitioners who supply them, both of which groups have waited for over 2 years for positive news about the statutory regulation of herbalists, I look forward to your prompt response to these two suggestions.

I respectfully request that you provide your answer in advance of any public announcement being made about your Government’s position on this issue.

Yours sincerely

Robert Verkerk PhD

Founder, Executive and Scientific Director,

Alliance for Natural Health International

cc. by email, fax and hard copy:

Rt Hon Nick Clegg MP, Deputy Prime Minister
Rt Hon Jeremy Hunt MP, Secretary of State for Health
Dr Daniel Poulter MP, Parliamentary Under Secretary of State for Health
Anna Soubry MP, Under Secretary of State for Public Health
Richard Woodfield, Head of Herbal Policy, MHRA

Email copied to all UK Conservative MPs, and selected Labour, Liberal Democrat and UKIP MPs.



Midwives Angry with Government Write Open Letter to the Press

Government refuses urgent meeting with independent midwives Women and midwives request for help ignored by health ministers Women’s choices in childbirth to be denied. Women and midwives fight back EU law may drive more women to birth alone EU law will cost NHS maternity system approx. £12 million a year Government ignore own commissioned report

The Health Minister Dan Poulter has repeatedly ignored and refused requests for help from hundreds of women and midwives to stop the illegalisation of Independent Midwifery in October. He has refused an urgent request for a meeting from Independent Midwives UK to discuss the barriers their members have in accessing insurance and have left them no option to write an open letter in the press (see bottom of this press release). Independent Midwives UK is the organisation which represents Independent Midwives. The organisation and their supporters want the Government’s help to secure the insurance which is needed for them to remain legal.

A Department of Health consultation on the legislation concludes on 17th May 2013 with the likely outcome of making it a condition of registration for all healthcare professionals to have insurance despite it being not available for Independent Midwives, not because of clinical risk, but for commercial reasons.

Government Policy ‘Maternity Matters’ promises to improve women’s choice and standard of  maternity services, yet the new law will illegalise a midwifery service which currently meets the Governments own targets.

Independent Midwives care for approximately 3000 women a year, an estimated saving of £12 million for the NHS. This figure could increase as thousands more of midwives would work self-employed if insurance was available. At a time of a rising birth rate of 22% and deficit of 5000 midwives the Government are ignoring part of the solution to the plight of childbearing women and the national midwifery shortage.

Women will have no safe alternative choice to the NHS. Many women refuse to use the NHS, because of the failing system and state they would now choose to birth alone with no medical help. Public funds to the value of £260.000 have already been spent on the Governments recommended solution despite being informed by Independent Midwives that it is flawed.

Thousands of supporters have contacted Dan Poulter to inform him of their dissatisfaction with the Governments response to an appeal for help. He constantly sends out standard replies which ignore the issues.

The campaign for a workable system of insurance for midwives has support from the Association for the Improvements in the Maternity Services, (AIMS) The National Childbirth Trust, (NCT) The Association of Radical Midwives (ARM) Doulas UK, as well as all birth choice campaign groups across the U.K.  All groups are urging Dan Poulter to meet with IM UK.

Many MPs have pledged support. Ian Duncan Smith assured his constituent Samantha Lealman, Independent Midwife, of his support. Samantha said “Before I left his office he looked me straight in the eye and said, 'I am 100% behind you, I really mean this, don't think it's just talk and nothing will happen. I will put the contents of this meeting in writing to you and then we will arrange to meet again after I have met with the cabinet to talk about what we can do next.' “

In April 2007 Prime Minister David Cameron said, “At a time when maternity units in the NHS are threatened with closure, there is a shortage of midwives in the health service generally, and Ministers are struggling to make good their promise of one-to-one care and genuine choice in childbirth, it would be utterly foolish to force independent midwives to cease practising”.  David Cameron has also assured his constituent that he has requested Dan Poulter meets with IMUK immediately, but to date Dan Poulter continues to refuse.

Supporters will be publically requesting a meeting between IMUK and Dan Poulter. IM UK publically requests a meeting with Dan Poulter by 10th May 2013.

The Finley Scott review commissioned by the Government to advise on this subject states:

"In respect of independent midwifery, the review recommended that for groups for whom the market does not provide affordable insurance or indemnity, the four health departments should consider whether it is necessary to enable the continued availability of the services provided by those groups; and, if so, the health departments should seek to facilitate a solution (recommendation 20)."

Evidence Dan Poulter is avoiding acknowledging this issue.

IM UK and the public participated in a Christmas card and Valentines card campaign. They wrote to Dan Poulter explaining the need for Independent Midwives & the barriers they face.  Dan Poulters office did not acknowledge the content of the hundreds of letters and sent out standard replies. 

Approx. 600 supporters demonstrated outside parliament on 25th March and met with MPs.  Dan Poulter did not meet any of his constituents.

Dan Poulter tried to dissuade Nicky Garret, Independent Midwife and constituent of his from keeping an appointment at his surgery.

IM UK received a standard reply letter with additional information, refusing a meeting with IM UK.

To Dan Poulter, Health Minister

Cc Jeremy Hunt, David Cameron, Stephen Dorrell, Margaret Hodges, Members of the Cabinet, National Press

Open letter to The Health Minister Dan Poulter from Independent Midwives UK

Further to your standard issue letter dated 16th April 2013, in response to Independent Midwives UK correspondence, public campaigning, petitioning and public rallying regarding the issue of finding workable, affordable insurance for Independent Midwives to comply with EU Directive (2011/24/EU). We publically state how extremely frustrated and concerned IM UK are by both your complete refusal to meet with board members of the organisation, and the obscene inertia in firing off standard responses to letters, Christmas cards and Valentine cards sent by members of the public over the last few months.

IM UK represents the only health professionals who will be outlawed in October as a result of the linking insurance to registration; it is not only short sighted to refuse to meet with us, but is insulting and unprofessional to do so in such a manner.  You have agreed meetings with The Royal College of Midwives and Neighbourhood Midwives – organisations who support IM UK, but whom are not directly affected by the legislation and have their own campaigns to fight. We believe that you are unwilling to meet with IM UK, because acknowledging support for Independent Midwives from the public and maternity stake holder organisations in the UK would entail you having to recognise and respond to Recommendation 20 in the Finley Scott review:

"In respect of independent midwifery, the review recommended that for groups for whom the market does not provide affordable insurance or indemnity, the four health departments should consider whether it is necessary to enable the continued availability of the services provided by those groups; and, if so, the health departments should seek to facilitate a solution.”

The independent review by Findlay Scott states that it is through no fault of our own that indemnity insurance is not available - lack of availability is due to commercial reasons and not for clinical risk.  We see no evidence of you honouring the recommendation Mr Poulter; indeed there is mounting evidence that you are actively trying to avoid it!  Independent Midwives will no longer be able to register, simply because insurance is not available, and women will lose the choice of a safe alternative to the NHS.  The DoH continually claims that a solution has been found in social enterprise companies; £260,000 of public money was invested in the Neighbourhood Midwives project, which whilst a potential alternative to the NHS, it is not independent midwifery and to date it has not been able to secure a contract from NHS commissioners.

Independent Midwives are fully qualified and regulated; they are the midwives who provide the maternity care you promised your voters in Maternity Matters and other documents. This includes:

  • Choice in maternity care
  • continuity of carer
  • increased home birth rates
  • increased normal birth rates
  • increased breastfeeding rates
  • increased satisfaction

The Government are making illegal the only midwifery service which fully meets these criteria.  Independent Midwives save the NHS an estimated £12 million a year by providing a high standard of care for women outside the system. There is a rising birth rate in the UK of 22% and a deficit of 5000 midwives; losing Independent Midwives will only compound the problem. Does the government that supposedly supports choice want to be responsible for women losing this choice and for increasing further burden on the NHS?

In summary, IM UK and its supporters have informed you of the barriers facing Independent Midwives in accessing insurance many times.  Our requests for meetings have been refused; you are avoiding the voice of the thousands of voters who have pledged support and engaged in this campaign; it is disrespectful that you ignore these concerns and respond with ill thought -out standard replies - replies which ignore specific questions and only waste more taxpayers’ money. 

IM UK again requests an urgent meeting with you, Jeremy Hunt and David Cameron to discuss this issue before 10th May.

Jacqui Tomkins (Chair IMUK)

Further Information

Source: Virginia Howes

Spokesperson: Virginia Howes Tel: 07747723560





EU Bans Neonicotinoid Insecticides for Two Years

Europe on the right track to protect bees!

EU-wide citizens’ actions and petitions in support of the European Commission’s proposal to prohibit three neonicotinoid insecticides secure enough support amongst Members States for the ban to be enforced.[1,2,3] This decision shows that Europe is concerned about the dramatic decline of pollinators and their essential role to our environment and our food.

EU Bans Neonicotinoid Insecticides for Two Years

From December 1st 2013 onwards the application of three neonicotinoids - imidacloprid, thiamethoxam and clothianidin – will be prohibited throughout Europe for a two-year period. Their use by non-professionals, e.g. private gardening, is completely banned. However, neonicotinoid treatments will still allowed for treating crops that are not attractive to bees such as winter cereals, in greenhouses, and for seed production.

For the two year period when the ban is applicable, producers such as Syngenta, Bayer Crop Science and Sumitomo Chemical will need to provide risk assessments on the exposure of bees to pesticides through pollen, nectar, honeydew and guttation water. The agro-chemical industry reacted angrily to the EU Commission’s decision to enforce the ban, claiming that is disproportionate and that it will pose risks to Europe’s agricultural production.

The measures proposed by the European Commission will significantly reduce the exposure of insects, including bees, to neonicotinoids. However, it will take time to observe a real recovery due to the high amount of neonicotinoids that have been used to date; their persistence in the water and soil and given that some applications of these products will still be allowed for use.

Francesco Panella, spokesman for the European Beekeeping Coordination said, "The prohibition of systemic insecticides is a first step in the right direction to save bees and life in our fields. The decision is a great encouragement for good agricultural practices and for the preservation of Europe’s soil fertility. We must now ensure that the EU-Commission will act upon it to produce a coherent policy linking agriculture to nature and to life."

Stephanie Roth campaign coordinator at ARC2020 said, “The Commission’s ability to enforce the ban is due to unprecedented citizens’ action throughout Europe. It is the millions of people from EU-members states ranging from the UK to Bulgaria and from Germany to Greece who wrote to their Commissioner and who took their messages to the streets that made this change for better happen. Let's remain vigilant to ensure that harmful pesticides including neonicotinoids remain banned once and for all.”




3.         Break-down of how EU member states voted on 29th of April 2013:

Further Information

Please contact Francesco Panella, spokesman for the European Beekeeping Coordination on Tel: +32 10 47 16 34;  

Paola Nano, Slow Food International Press Office on Tel: +39 329 8321285;


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