Sunday, July 14, 2013

TGA Advertising Proposals - Urgent Submissions Needed

A TGA proposal is currently underway to amend regulations on advertising therapeutic goods to the general public. This will also restrict Naturopaths and Herbalists so I encourage everyone who has benefited from seeing myself or another Naturopath to enter their own submission as it is open to all members of the general public. The consultation document can be found at http://www.tga.gov.au/newsroom/consult-advertising-ris-130531.htm Concerns regarding this proposal relate to Point 7 (pg 28) Advertising directed to health professionals and Proposal 6 (pg 42) which relates to this. Submissions on this consultation are due by this Friday July 19. 

What Are The Issues?
The proposed changes affect what advertising material product suppliers will be able to supply to the general public. The general intention of these changes is to better protect the public, and some of the suggested changes are positive. However, the proposed changes will mean that it is ok to provide information to a nationally registered health professional, regardless of whether or not they are trained in prescribing those medicines, and excludes health practitioners (including Naturopaths and Herbalists) who are not registered under the Australian Health Practitioners Regulatory Authority (AHPRA). Under Option 2 of Proposal 6, Naturopaths and Herbalists are considered general public and not health professionals. Therefore, we will not be able to access advertising material or technical research information on the products that we are prescribing to patients.


Public safety
Currently practitioners receive important technical information on efficacy and safety of listed therapeutic goods from companies both in written material and via face-to-face seminar activities that comprise a portion of continuing education for the profession. Such activities encourage not only the updating of knowledge vital for safe professional practice but also employ critical analysis of research, sharing of professional knowledge, and promote professional behaviour such as adverse reaction reporting. All these elements contribute to public safety. 

What can I do?

Download a proforma letter you can use to respond to the TGA advertising consultation. This letter is based on the NHAA (National Herbalists Association of Australia) submission. It is suggested that you personalise it if you have anything further to add. However, bear in mind that the TGA will not consider emotive responses so please stick to the facts and keep it simple.

IMPORTANT: For your submission to be accepted, you need to follow the "How to Respond" instructions on the TGA website at http://www.tga.gov.au/newsroom/consult-advertising-ris-130531.htm#respond