Background for TGA survey
Saturday, July 6, 2013 at 11:03PM
Mark Donohoe

We're interested in your vote in this survey. Yes, we're demanding! We want you to read and know what Proposals 5 and 6 of the TGA Impact Statement (pages 42 to 45) are, so I have summarised this below. We are mainly interested in the Proposal 6, related to information on healthcare products to naturopaths, herbalists and other healthcare practitioners who have not yet achived national registration.

To answer the survey, you may need to know that:

  1. Many healthcare practitioners are registered nationally with AHPRA - the Australian Health Practitioner Regulation Agency. Naturopaths, western herbalists and homoeopaths are not.
  2. Proposals 5 and 6 separate health practitioners nationally registered from those who are not, and proposes different rules for each on advertising and education
  3. Proposal 5 Option 2 would limit the use of "higher risk medical devices", including some "in vitro diagnostic devices", because there is "need for involvement of a healthcare practitioner to ensure safe use of the product". This would presumably be a AHPRA registered healthcare practitioner, plausibly removing naturopaths, herbalists and homoeopaths from using some diagnostic devices.
  4. Proposal 6 Option 2 on advertising directed to health professionals again seeks to treat naturopaths, herbalists and homoeopaths as if they are the equivalent of the untrained general public, and would have the effect of them being unable to maintain their education and knowledge on healthcare products, and this would severely reduce their ability to advise their clients on quality healthcare.
  5. Option 1 on both proposals leaves the status quo, with naturopaths, herbalists and homoeopaths continuing as valuable and up-to-date health care practitioners in Australia.
  6. There is an option for submission of another Option - an "Option 3" - which we are recommending.


YES, we at CEBCoM DO believe that all healthcare practitioner bodies need to move into the national independent regulatory model, and to break the shackles of the peak bodies who serve their own interests rather than the long-tem interests of their members. 

But the deadline of one year is almost impossible, even for peak bodies committed to national registration.

That's why we propose an "Option 3" for both of these proposals - a moritorium for 5 years while the peak bodies of natural therapists move to AHPRA regulation and registration within within that 5 year period.

Enough from us - give us your opinion in this survey. We have put our option 3 in, but you can add your own, and we will take that view forward in our submission to the TGA.



Article originally appeared on CEBCoM Apps (
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