I have some substantial concerns about the Traditional Medicines Congress

A) The list of primary texts from which use of an herb may be authorized is
severely limited and does not represent, in any form, current American herb
usage or bioregional herb usage. USP and NF listings, past and present,
represent crude botanicals used in the manufacturing of drugs, not their
use as herbs. I seldom use Kino Gum, Aleppo Nutgall or Physostigma in my
practice. The B.H.P. is skewed towards European plants and disagrees
substantially with much current American usage.

B) There is no allowance for NEW botanicals or uses. Herbalists are
constantly utilizing new resources. I live near Mexico and NONE of the
widely used Latin American herbs would be allowed, many arising from
current experimenting by medicas and curanderas as disorders change and
environmental factors bring out new diseases. I use Ocotillo, Matthew Woods
uses Teasel Root, David Winston uses Nettle Seeds...all examples of finding
new uses of herbs by hook and by crook. None may be allowed.

C) The frequent references to "Practitoners" and their ability to continue
to make products in a separate but equal fashion to the manufacturers is
grossly misleading. If the feds are going to take any of this on, they will
want definitions. "What practitioners?" "Under what authority?" "Who
authorizes the authority?" There will HAVE to be codifications and
regulations. That means standardization. The Canadian model allows for
Native American usage...if you are a Native American Healer. Can you
imagine the feds doing even this much? Will us American herbalists, in
order to practice and make medicines, have to join the AHG? Pass boards?

D) Schools are exempted. WHAT schools? At present we have two accredited
schools...Bastyr's little herb-oriented program and Tia Sophia's Master
Degree Program. EVERYTHING else is some form of Master Class. As an
ex-musician, I recognize the difference very well. You can attend a
university, take an academic path to music, and learn to be a music
teacher. If you want to study an instrument, your best training will be
with a known artist; if composition, your best training is with a composer.
Some music departments coordinate the two, with some academic classes and
the bulk studying being private or master classes. The best herb "schools"
are not faculty oriented but are various forms of master classes or
apprenticeships, and do not, in any way, qualify as a federally recognized

I will be frank. Virtually everything I have tried to teach for 28 year
will be undermined if the Traditional Medicines Congress comes to pass.
Yes, it would enable manufacturers of herb products to include uses, doses
and contraindications on their labels (and lessen their liability). I can
see hardly any value in it for herbalists.

Remember, this is the government that is requiring every food manufacture
to register with the Department of Homeland Security (including taco
wagons) and will be requiring the federal registering and tagging of every
farmyard animal under the NAIS proposal (including a pet duck) and is
recording an unknown number of phone calls and emails "just because we
can". And doing much of it poorly.