Medicines Act Campaign Update Two 1st June 2012

[Rochelle Marsden]

From: The Society of Homeopaths [mailto:society@homeopathy-soh.ccsend.com] On Behalf Of The Society of Homeopaths
Sent: 01 June 2012 13:55

Subject: Medicines Act Campaign Update Two 1st June 2012
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Medicines Act Campaign Update Two - 1st June 2012
Dear Rochelle,
Thank you for your participation in the recent Medicines Act campaign and your ongoing support as we continue to tackle this important issue. In particular, the letter-writing campaign has started to gain traction and we now need to move onto the next step in this lobbying process.

The response from members has been impressive with many writing to their MPs and providing feedback to us. As expected, many members have received standard replies stating that no changes are being made to the law, including Section 10.

These responses are correct in so much as the MHRA's consolidation process is a routine exercise designed to simplify the law without changing it. However, these standard MP responses are misleading because they infer that because the law is not being changed, access to unlicensed homeopathic medicines will continue.

This is not the case

The Medicines Act 1968 aims to ensure that medicinal products are produced and supplied in a way which ensures both product quality and patient safety. The MHRA's recent consultation and 'consolidation' aimed to make this vast, confusing, outdated law simpler, clearer and up to date.

However, this process has highlighted ways in which the Act is inappropriate when applied to modern use of homeopathic medicines because:

a) the Act was written with conventional drugs in mind i.e. the regulations it created were designed to protect the public from potentially dangerous substances, and

b) it was written long before the phone, internet and mail order became major supply routes.

Once this review of the Medicines Act has been concluded, if Section 10 remains unchanged, it will clearly state that it is unlawful to supply unlicensed homeopathic medicines (i.e. most remedies) by phone, mail order or via the internet.

As homeopathic medicines are at high dilution they do not pose the same dangers as conventional drugs, carrying no risk of toxicity. For this reason, the homeopathy profession is asking for an amendment to be made to Section 10, exempting homeopathic medicines from this part of the Act.

This is the only way to ensure that we maintain access to homeopathic medicines

So, where are we now with this campaign?

For over 18 months, the homeopathy profession has engaged with the MHRA concerning key issues of access to medicines and the potential negative impact on homeopaths as well. As a profession and as individual practitioners we have responded to the Medicines Act public consultation and the MHRA Red Tape Challenge suggesting practical and workable solutions.

For clarity

In addition to the guidance notes and bullet points provided for the original MP letter it is important to understand that:

c) Keeping Section 10 unchanged is not acceptable to patients, practitioners or manufacturers

d) Whilst correspondence from MPs is generally positive, they are often misunderstanding the main points as described above

e) If current proposals by the MHRA are endorsed by Government it could lead to you no longer being able to access homeopathic medicines by phone, mail order or online. Homeopaths would not be able to dispense or prescribe medicines and homeopathic medicines could only be obtained at the handful of homeopathic pharmacies in the UK
What you can do - Write to your MP again!

The next step is to write to your MP again to clarify the situation and highlight the above misunderstandings. It is even better if you can write to and meet with your MP. If you can do that with a patient, other practitioner or as a group, that would be even more effective.

If you can secure a meeting, please do let the Society know.

Helpful points for a follow up letter to your MP

In addition to the bullets above, the following could be used to create a follow up letter to your MP. As with the first letter it is not necessary to include all the text and it is important that you personalise your letter. Even more critical is that you include your name, address and postcode on all correspondence to your MP. If you are emailing, put a subject such as Medicines Act consolidation in the subject field.

f) I continue to be deeply concerned that the draft proposal set out by the MHRA as part of its consolidation and review of the Medicines Act 1968 could have a significant impact on the access to homeopathic medicines in the UK

g) If Section 10 is not changed or amended, and is enforced in the future, access to unlicensed homeopathic medicines will be restricted to receiving them in person from a specialist pharmacy with expertise in homeopathy. This would be unworkable as far as patient choice and access is concerned for the 10% of the population that use homeopathy in the UK

h) Whilst this consolidation could be classed as a routine review/consultation of the law and would leave policy unaltered, this is precisely the problem. By not amending Section 10 it may create difficulties with future access to homeopathic medicines

i) The wording of the Medicines Act of 1968 does not adequately cover the evolving practice of homeopathy in the UK. For the majority of homeopathic users, access to homeopathic medicines is only possible through the Internet or mail order. The profession needs clarity in the language of the Medicines Act that will confirm in law access to the current supply routes for unlicensed homeopathic medicines

j) This current issue is complex and has become burdened with misunderstanding. I am therefore asking you to raise the issue with an appropriate minister as soon as possible

k) There could be significant economic ramifications if Section 10 of the Medicines Act is not changed as it will increase pressures on regulatory bodies and NHS services, as well as decreasing the commerce in the homeopathic sector at a time when the UK and Europe is in dire need of economic growth

It would be extremely helpful if you could respond to your MPs again urgently, clarifying the situation and highlighting that a policy of 'no change' could have serious consequences for millions of patients in the UK who use homeopathy, and for over 2,000 practising homeopaths. A policy of 'no change' will also compromise patient choice.

There is still time to act. There is an urgent need to lobby MPs and Health Ministers to make an amendment to Section 10 (4a) so that it does not apply to homeopathic medicines dispensed at dilutions of 6X or above

If you need to refer to the original guidance notes for the first campaign letter please click here

To ensure that you receive information like this quickly please register to receive the Society enews by emailing soh_info@homeopathy-soh.org . Alternatively join the Society intranet (FCM). For further information, please visit click here

Thank you very much for your participation and continued support. Please let us know what response you get from your MP as this will help us put increasing pressure on the decision-makers to ensure a positive result from this campaign.

Best regards

Phil Edmonds
Chair
11 Brookfield, Duncan Close Moulton Park Northampton NN3 6WL

T: 01604 817890 F: 01604 648848 www.homeopathy-soh.org

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