Responding to the TGA "Impact Statement"
Friday, July 5, 2013 at 7:39AM
Mark Donohoe

We want you all to know about this TGA regulation impact statement, and we are devoting our FoCM App exclusively to this process until the deadline for submissions on 19th July. We have a very limited period of time to approach the TGA with input on the potential negative consequences of the proposed changes, principally The Option 2 of Proposals 5 and 6 on page 42-45 of this document.

Read our take on the details of this proposed change in regulations here. If you're as concerned as we are, take our survey on your response to the TGA Options, and we will use these results to inform our own submission.

Option 2 of the Proposals seek to limit the types of "advertising" on medical devices and therapeutic products to homoeopaths, western herbalists and naturopath to advertising available to the general public. The TGA separates these practitioners, who have not become part of the national registration process in Australia, from those others such as doctors, chiropractors, osteopaths and traditional Chinese medicine practitioners who are on the national registration program. 



One of us (MD) was president of the Natural Healthcare Alliance  (NHCA) In Mid-2000 period for about five years. He and a group of other dedicated practitioners worked hard to moving natural health care into the medical mainstream, and identified the necessity for joining in a national registration process is essential for the ongoing relevance and survival of natural health care practitioners in Australia.

Certain large groups representing natural healthcare practitioners, principally ATMS and ANTA,  resisted the process which ultimately led to the disbanding of the NHCA four years ago.

Since that time, critics of complementary medicine such as the Friends of Science in Medicine have been chipping away the gains made during those five years, attacking education and research in complementary medicine, and pressuring universities to drop courses that they regarded as "unscientific". 

Our concern is that these TGA proposals are the "thin edge of the wedge", and that once advertising is limited to these professional groups, they will be unable to participate in quality ongoing educational programs, and will be unable to maintain their professional development, and relevance to the community in health care in Australia.

Groups such as ARONAH (The Australian Register of Naturopath and Herbalists) have arisen to represent the interests of the many naturopath and herbalists who do see national registration as a valuable attainment, and one which protects not only the public, but the profession itself.

The Centre for Evidence-Based Complementary Medicine supports ARONAH in this endeavour,  and we are looking at ways of contributing materially to their process.

This is not a single battle, and whether or not the TGA makes changes to the advertising regulations will not in the long-term impact the uptake of complementary medicine and natural Healthcare by consumers.

We professionals need to get on board with issues of accountability, educational quality, evidence-informed practice, and effective healthcare delivery to a public that increasingly sees natural healthcare is the first option in prevention and health care.


We urge naturopaths, herbalists, homoeopaths and other natural health modalities not nationally registered to express their concerns and provide input to the TGA before 5PM Friday 19 July 2013 (it was extended a week after pressure). Electronic submissions in MS-Word format are preferred and should be emailed to Details of how to do this can be found at this TGA page.


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