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ACMA Publication Issue March 1, 2002

Recommendation on Chinese Medicine in the

United States of America

(Supplement)

Bob Xu, CMD, MS

 

Cover Letter

1. Classification of Herbs

2.  TCM vs Acupuncture

Acknowledgements

 

 

Recommendation on Chinese Medicine in the 
United States of America
(Supplement)
TO:          White House Commission on Complementary and 
                    Alternative Medicine Policy
FROM:     Bob Xu
RE:           Recommendation (Supplement)
DATE:      February 20, 2002
 
Dear Sir or Madam:
 
I submitted a recommendation to WHCCAMP on December 4, 2001.  Since then, some issues not covered in that recommendation have drawn our attention.  We deem it appropriate to provide a supplement to the recommendation to elucidate the new issues. 
 
Hope the March final report could take into consideration of these issues.    
 
Thank you.
 
Sincerely,
 
Bob Xu, CMD, MS
Director
Center for Holistic and Herbal Therapy  

 
   
 
Herbal Medicine in general, and Chinese Herbal Medicine in particular, have met many challenges in the United States.  Many issues mentioned in previous recommendation relate to another fundamental issue ---- the classification of herbs.  Without a clear, appropriate, and scientific classification of herbs, it may be very difficult to solve other issues. 
 
Currently, herbs are classified as food dietary supplements.  Congress defined the term “dietary supplement” in the Dietary Supplement Health and Education Act (DSHEA) of 1994.  A dietary supplement is a product taken by mouth that contains a “dietary ingredient” intended to supplement the diet [1].
 
“To supplement the diet” may be appropriate for vitamins, minerals, amino acids, enzymes, etc.  However, it is inappropriate for herbs.  Herbs are much more complicated and have far more functions than simply “To supplement the diet”.
 
Then, what category should herbs be classified?  Following, we try to discuss this issue from several viewpoints:
 
(1)  Dietary Supplement Viewpoint
 
For thousands of years, millions or billions of clinic practices and studies prove that herbs can effectively prevent, treat, and cure diseases rather than to simply supplement the diet.  Therefore, it is inappropriate to classify herbs as dietary supplements. 
 
(2)  Efficacy Viewpoint
 
From the efficacy point of view, Herbal Medicine (as a generative or constructive medicine) is very effective in preventing, treating, and curing diseases.  This therapeutic function is similar to the Western Medicine. 
 
Generally speaking, Herbal Medicine takes effect slower but the results last longer than Western Medicine in treating diseases (There are, however, some cases in which Herbal Medicine works faster than Western Medicine).  For acute diseases, Western Medicine usually works faster and more effectively in controlling the signs and symptoms.  For chronic diseases, however, Herbal Medicine usually works more effectively than Western Medicine in treating the root cause of a disease. 
 
Therefore, herbs should be classified as a category of products for medicinal use rather than as dietary supplements. 
 
(3)  Safety Viewpoint
 
From the safety point of view, herbs are usually safer than chemical drugs.  Herbs are very different from chemical drugs in causing adverse side effects (Please refer to the previous recommendation).  Therefore, herbs should not be classified into the category of chemical drugs. 
 
Comparing with dietary supplements, however, herbs usually can be more dangerous if the herbs are prescribed inappropriately.  Many situations may lead to herbal side effects (Please refer to the previous recommendation).  Therefore, herbs should not be classified as dietary supplements.
 
Based on above discussion, herbs should be classified as a category:
 
(a)    different from dietary supplements;
(b)    for medicinal use;
(c)    different from chemical drugs.
 
Due to above reasons, it is appropriate and necessary to establish a new category for herbs.  This herbal category should be independent of, and between dietary supplements and chemical drugs.  The definition of herbs in this category should contain the following characteristics:
 
(1)   Efficacy:  Herbs can prevent, treat, and cure diseases;
(2)   Safety:  Herbs are generally safer than chemical drugs, but may be more dangerous than dietary supplements;
(3)   Mechanism, Rules, and Principles:  The mechanism of Herbal Medicine does exist, but it is more complicated than Western Medicine.  Herbal Medicine works under a set of rules and principles different from Western Medicine.  Some holistic and module approach may be needed in elucidating the mechanism of Herbal Medicine.
 
This new classification of herbs will have the following functions:
 
(a)    Send a clear message to the public that herbs are not dietary supplements.  Herbs can be very dangerous if taken inappropriately.  The public is not advised to take herbs at their own discretion.  This will reduce the herbal side effects caused through inappropriate self-administration of herbs by the public.
(b)   As a medicinal field, the profession of Herbal Medicine should be regulated.  This will reduce the herbal side effects caused through administration of herbal remedies by unqualified practitioners of Herbal Medicine.
(c)    With the decrease of herbal side effects and the increase of herbal therapeutic effects, insurance companies may be willing to pay for herbal treatments.  As a result, more Americans will benefit from the natural, safe, and effective Herbal Medicine. 
(d)   The regulated and judicious use of herbal remedies will very likely provide solutions for some problems facing the American health care system today.
   

 

 
 
Currently, many people in America have an impression that “Traditional Chinese Medicine (TCM) is acupuncture, and acupuncture is TCM”.
 
This is, in fact, a misunderstanding about Chinese Medicine.  As mentioned in the previous recommendation, TCM is composed of two parts:  Herbal Medicine and Acupuncture (the Herbal Medicine is about ten to twenty times larger than the Acupuncture).  To equal TCM to Acupuncture is to equal the whole (TCM) to a part (a smaller part: Acupuncture).   
 
Above misunderstanding could actually obstruct the development of TCM in particular, and Complementary and Alternative Medicine (CAM) in general in the United States.  If this situation continues, the American public will be unable to receive the vast amount of benefits that Chinese Herbal Medicine could offer.  The profession of Chinese Medicine deeply believes that without Herbal Medicine (which is the main component of TCM), TCM could never be complete. 
   
 
Reference
 
[1] FDA Overview of Dietary Supplements, U.S. Food and Drug Administration, Center for Food Safety and Applied Nutrition, January 3, 2001.
 
 
 
I would like to thank Dr. Stephen Groft, Executive Director of the White House Commission on Complementary and Alternative Medicine Policy (WHCCAMP), for calling me discussing the previous recommendation.  Most thoughts in this supplement were triggered and developed from that conversation.  Thanks also to Coordinator Bonnie J. McLaren of the Small Business Development Center at the College of DuPage for reviewing, editing, and commenting this and other projects.

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