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Position Statements

CLOSED CONSULTATIONS

Link to CMA's Submission (12 pages) and Position Statement (25 pages) to Sports Supplements Consultation

On 22 October, the TGA released a consultation with a draft of a proposed Declared Therapeutic Goods Order under Section 7 of the Act, which will transform or clarify a high number of products, commonly known as sports supplements, into goods regulated as therapeutic goods. Members and businesses are welcome to view and refer to Complementary Medicine's Australia Position Statement in regards to the consultation on sports supplements.

NOTE:

1. This may affect health products other than sports supplements.

2. Some products on the ARTG may be de-regulated under the proposal

Industry stakeholders have a strong level of concern in respect of the released for sports supplements consultation, as it is expected to have very high anticipated regulatory impacts on Australian businesses, and could worsen, rather than improve safety for consumers. For example, it is estimated to:

  • Immediately affect approximately 40% of existing sports supplements products with a cascading or wider effect of up to 60-80% of products, many of which will be unable to transition to the framework or will not be able to transition in a cost competitive way;
  • Create a domino effect on local manufacturers and retailers due to loss of turnover and bulk purchasing power;
  • Cause local manufacturers and distributors to close down, minimise, or move offshore;
  • Close several hundred or more retail specialty sports supplement stores and have a negative impact on other retailers;
  • Be opposed by the consumer base who purchase these products and demand international equivalency to available products;
  • Reduce Australia’s ability to be a competitive influence in the growing global market for these goods;
  • Replace demand with personal importation of the products from international e-commerce websites.

A solution is sought that protects both businesses and Australian consumers and provides a coherent framework whereby businesses may succeed and consumers can obtain products from Australian businesses. Therefore broad policy options are sought under principles of best practice regulation.

The consultation closed on 3 December 2019 on the TGA website.


Medical Board of Australia - proposed guidelines for complementary, unconventional and emerging medicine

The Medical Board of Australia (MBA) has commenced a public consultation on new guidelines for medical practitioners related to ‘complementary and unconventional medicine and emerging treatments‘. 
In the rationale to these guidelines complementary medicine (CM) and integrative medicine (IM) are specifically mentioned. 
The concern is that, if progressed, a new set of guidelines would create a two-tiered system that would be divisive to the practice of CM and IM and could lead to medical and allied healthcare practitioners (under AHPRA) being unfairly and unreasonably targeted (read the guidelines here).

Of additional concern is the rational the MBA have used in their discussion paper, which states the consultation is in response to ‘concerns raised by stakeholders about this area of practice’.
However, no evidence has been provided in the discussion paper that quantifies risk or relative risk in practicing complementary or integrative medicine compared with ‘conventional’ medicine.

CMA and the peak body for integrative medicine in Australia (AIMA), as well as other IM organisations and the research community were not consulted in the lead up to this consultation.

As such we are working together and calling for the Medical Board to retract the consultation.

In the meantime, CMA encourages individuals and organisations to make a response specific to their concerns and field of practice.
You may wish to let the MBA know these guidelines could effect your practice and impact consumers’ freedom of choice and quality use of medicines.

A whole-health system view is necessary as consumers obtain their medicines from a range of sources such as those initiated by themselves, general practitioners, other medical specialists, pharmacists and complementary therapists.

Make a submission to the MBA

Submissions can be made by email marked ‘Consultation on complementary and unconventional medicine and emerging treatments’ should be sent to medboardconsultation@ahpra.gov.au by close of business 30 June 2019
You can view CMA’s position on the consultation here:
CMA Position Statement on the MBA Consultation

Additional Resources:

FX Medicine - Complementary Medicine Under Siege – Prof. Stephen Myers

https://www.fxmedicine.com.au/content/complementary-medicine-under-siege-prof-stephen-myers

FX Medicine – Concerns over Complementary Medicine Suppression – Dr Penny Caldicott

https://www.fxmedicine.com.au/blog-post/breaking-news-concerns-over-complementary-medicine-suppression-dr-penny-caldicott



ADVOCACY 

CMA's goal is to achieve a sustainable vibrant, compliant industry that holds its place in consumer health. We support the ethical and responsible promotion of complementary healthcare products and their value to the health of our community.

Call us on 02 6260 4022 or fax 02 6260 4122

Address: PO Box 450 Mawson, ACT 2607 Australia

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