Health Freedom Waikato Newsletter Action Alert

Hi all

…………………………………..PLEASE LET THIS GO VIRAL…………………………………

Submission responses due 17th May 2010

A Consultation Document for The Development of a Natural Health Products Bill is currently before New Zealanders and the Government has asked for your response. Health Freedom NZ supports the efforts of the National and Green Parties who are responsible for bringing in sensible regulation. However we have concerns about some of the details that their officials have drafted, that would see your access to consumer choice being denied.

We were expecting the discussion document to be based upon the proposed Natural and Traditional Health Products Bill that was prepared in full consultation with Maoridom, Consumers, the NZ Health Trust and the Natural Health Products Industry over a two-year period.

Unfortunately the MoH Consultation Document is diametrically opposed to most of the principals outlined in the proposed Bill.

If we want continued access to affordable vitamins, minerals and other natural products we are going to need more than 5,000 submissions made against this document in order for it to be effective, so everyone who wants continued access to natural products needs to act now.

We believe this might well be the last opportunity we have to send a very loud and clear message that consumers do not need the kind of protection that the bureaucrats are offering – protection of pharmaceutical profits over our health.

PLEASE READ ON

After a tremendous amount of effort from several dedicated individuals we now have several submission templates available to assist you to write your responses to the Consultation Paper. (PLEASE NOTE that it is a Consultation Paper not a Bill.)

If you are in the Natural Health industry we have two company submission templates for you. One is extensive, detailing the questions and answers (16 pages), the second document is a simple template, where the questions and answers have been omitted, but with an outline of response reasoning. Please request copies of these documents if you need them, by emailing pld@actrix.co.nz as we know not everyone wants to receive large attachments unnecessarily.

If you are a consumer of Natural Health products we have a detailed 18 page submission template for you on our website www.HealthFreedom.co.nz (again too large to send as an attachment in this email). It is easy to abbreviate it, enlarge it, personalise it and either print it out and post it or email it.

If you wish to make an email response, go to our website www.HealthFreedom.co.nz and click the Login button (top right). Register your details to enter the discussion forum and then download the submission template file (NOTE download the Word version rather than the PDF file). If you have any problems downloading it I can email you the complete document directly pld@actrix.co.nz

Remember, our comments are just a guide. Duplicated responses may receive initial attention, but rarely much consideration, and may end up being lumped together. Therefore it is important to have your submission reflect your own personal views.

We encourage everyone to be courteous and respectful. Concise, well-considered personal letters are one of the most effective ways New Zealanders have of influencing law-makers.


RULES FOR RESPONSES

1 Your Name Must Be On The Document to be counted

2 Your Address Must Be On The Form to be counted

3 Keep Your Responses Concise

4 It must not be duplicated material

5 Any duplicated responses will count as only one response
6 Only one response per organisation is counted

7 Any people submitting as part of an organisation will all count at one response

8 It must arrive on time to count.

POST TO:
Natural Health Products Consultation
Policy Unit
Health and Disability Systems Strategy Directorate
Ministry of Health
PO Box 5013
Wellington

by Wednesday 12 May to arrive in time for the deadline 17 May 2010.  (Mail posted on Fridays doesn’t always get delivered until Tuesday).
OR EMAIL TO: nhpproposal@moh.govt.nz

Thank you for your attention at this important time in shaping the future of New Zealand’s Natural Health Industry.

Pat McNair

Robyn Hembry

Health Freedom Waikato

This entry was posted in Activism, Natural health news, New Zealand. Bookmark the permalink.

2 Responses to Health Freedom Waikato Newsletter Action Alert

  1. mike says:

    I fout the greeeeens luft me.
    They luff us all I will vote four them, tha greens truly represent me.

  2. Clare Swinney says:

    Get your consultations in folks.

    E-mail Pat McNair for a 2 page template, which he emailed out on Sunday, if you need to get some ideas on what to include and you are short on time.

    Two of us sent in this one. It is primarily based on the 2 page template.

    To Whom It May Concern
    Re: The Development Of A Natural Health Products Bill
    In the matter of the consultation document titled: The Development of a Natural Health Products Bill, we are writing as people who have an interest in both natural health and Big Pharma issues, and as regular users of natural health products.

    We accept your offer to regulate the Natural Health Product Industry of New Zealand, though only if the following conditions are adhered to:

    1) That any regulatory authority is made up of people who have the public’s best interests at heart. That it be comprised of consumers, natural health practitioners and suppliers of natural health products and

    2) That control and regulation stays within this country and that it is
    neither influenced by Big Pharma nor by overseas interests, in any way whatsoever.

    Outline of response reasoning
    We are not answering the questions raised within the discussion document, as the questions do not allow the appropriate response to what level of regulation (self regulation or imposed regulation) is required and it assumes that proposed costs are acceptable, even at the lowest levels proposed. This response is based on applying the proposed industry code in a self-regulatory model and not the interpreted regulatory overview/enforcement model outline in the discussion document.
    Regulatory Model
    Regulation of natural health products as proposed (Pharmaceutical level regulation and costs) is, we believe, completely unnecessary and this is an example of government becoming predatory, rather than working in the best interests of the public. Regulation of natural health products should be dealt with within the industry code of practice under a self-regulatory/co-regulatory model to ensure that costs are minimised, particularly now, as the economy goes downhill, while maintaining the paramount safety and efficacy of products to the consumer.

    Informational Database
    A database maintained and funded directly by the industry with the regulator obtaining access to the registered products contained with on an as required basis, should be sufficient to meet the informational needs identified in the discussion document.

    Ingredient Listing
    To ensure that an appropriate level of risk ingredients are excluded from this category, a black list is sufficient to be maintained by the regulator preventing any product containing that ingredient being sold within New Zealand.
    An informational white list may be maintained, but is unnecessary to ensure the safety of products within the New Zealand market.

    Ingredient Declaration
    A requirement by the industry maintained database for a declaration (statutory or regulated requirement) on lodgement, that the product does not contain risky ingredients or an excess of permitted levels of risky ingredients and will give regulatory assurance that safety is being achieved.

    Quality, Good Manufacturing Practice and Declarations
    This would also apply for the quality systems involved in the manufacture of the products whether in New Zealand or internationally for Good Manufacturing Practice. A declaration is sufficient requirement that an appropriate level of Good Manufacturing Practice is being maintained. Acceptance of the ISO standards (ISO 22000 or the EU FSSC 22000) for this should be more than adequate to achieve this requirement and while Australian TGA audits would be quite acceptable as an option this should not form the benchmark requirement for GMP when the ISO under international agreement has clearly established what is appropriate GMP and Auditing to that level.

    Claims
    Claims that are provable should be able to be made. The claim that sunlight is good for one’s immune system does not make the sun a medicine. Similar claims regarding natural products do not make them a medicine either. A working group made up of both industry and regulators (at least at a 50/50 ratio make up of the group) must be formed to establish what are acceptable claims that can be made, and any regulation needs to empower that group to both be formed and to routinely meet to look at new claims and levels of evidence that would be required to make those claims.
    Yours sincerely,

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