In preliminary comments filed with Health Canada’s Natural Health Products Director (NHPD) AHPA asked that a more thorough process be established beyond the current consultation to completely review the monograph.
"AHPA both appreciates and supports the need to develop a monograph based on the theory of traditional Chinese medicine, however, we also believe that a much more thorough review process is needed," said AHPA President Michael McGuffin. "AHPA is offering its expertise and that of its membership to ensure that the finished product is as accurate as possible."
The trade group’s comments were developed in conjunction with AHPA’s Chinese Herbal Products Committee, which is a group of 20 companies specializing in the manufacturing and marketing of herbal products that are based on or derived from TCM. The group came together to craft the comments on the draft Canadian monograph, which was issued on Sept. 12, 2012.
The draft monograph lists fewer than 300 TCM ingredients--mostly botanicals and some animal and mineral ingredients. The monograph sets for the conditions under which these could be used in Natural Health Products within Canada’s regulatory structure for this class of goods.
A substantial portion of AHPA’s suggestions concern nomenclature. The draft monograph includes a table listing the scientific name of the TCM ingredient and its corresponding pinyin name (Roman transliteration of Chinese characters). AHPA suggests that this table be made more robust by including in each case the part of the plant from which the TCM ingredient is derived (fruit, leaves, root, etc.) and also include the name of the ingredient in Mandarin characters.
Monograph could help research cause
The recognition of TCM ingredients by a Western governmental body is good news, according the Heather Zwickey, PhD, dean of research at the National College of Natural Medicine in Portland, Ore. Zwickey said even with its history spanning several thousand years, TCM still labors under misconceptions and prejudices, with a notable exception.
“I think that the general public is recognizing acupuncture more and more. There are well over 50 acupuncture schools in the U.S. at this point,” Zwickey told NutraIngredients-USA.
“With regards to the herbal medicine and the whole system of Traditional Chinese Medicine, I think it’s less accepted. Will it ever be accepted at the rate that our conventional biomedical system is accepted? Probably not.”
“But there are plenty of people who have not been served by the conventional model and those people are always looking for alternatives and they are quick to turn to Traditional Chinese Medicine,” she said.
Formulas don't fit reductionist model
“From the herb standpoint, I think there is less evidence (of efficacy) than for acupuncture,” Zwickey said.
Having better characterization of materials for future studies, such as the more thorough list AHPA is suggesting for the NHPD monograph, will help in future research. But, Zwickey said, there are still many difficulties, because TCM preparations spring from a different philosophy of medicine and so are not a good fit for the Western mode of research.
“The Chinese herbs are much more difficult to study. One of the reasons they are complex to study is that you almost never give a individual herb; you always give a combination,” she said.
“But in research we try to do it in a reductionistic fashion where we may study only one herb or only one constituent of an herb. And that’s not how those herbs are administered in the medical system and they often don’t work once you start breaking them down into these individual ingredients.”