The Treatment Action Campaign (TAC) notes that the Portfolio Committee on Health is currently considering proposed amendments to the Medicines and Related Substances Control Act No. 101 of 1965. We also note that a number of presentations have been made to the committee by representatives from the complementary and alternative medicines (CAMs) industry.
Given these current discussions, we wish to restate our position on the regulation of CAMs.
1. CAMs that are found by the regulator to be safe and of good quality should be allowed on the market. People who want to buy such products should be allowed to do so.
2. However, it is, and should be, unlawful to make unsubstantiated claims about the efficacy, safety or quality of such CAMs.
3. Claims of safety and efficacy must be judged by the regulator in terms of all the available scientific evidence relating to the use of the product in question. Products should not be registered without convincing evidence from double-blinded, randomised placebo controlled trials. Such trials are blind to paradigmatic differences and provide the fairest test of efficacy at our disposal. We reject the notion that lower standards of evidence should be applied when it comes to CAMs.
4. It is against the public interest to allow scientifically unsubstantiated claims of efficacy to be made in the marketing or on the packaging of any CAM products. The regulator has a duty to protect the public from being misled by such unsubstantiated claims.
5. Unsubstantiated claims can lead to (1.) people (often poor people) wasting money on ineffective products and (2.) people using ineffective treatments for serious diseases and delaying the initiation of proven treatments.
6. Traditional medicines should be regulated in the same way as CAMs and for the same reasons.
We call on the Portfolio Committee on Health and the Department of Health to put the interests of the people ahead of the narrow financial interests of the CAM industry. Not only should CAMs be properly regulated, the regulator should be resourced and capacitated in order to act more swiftly and decisively against companies, quacks, or fake healers who mislead the public.
For more information contact
Marcus Low // email@example.com // 082 962 8309
– TAC submitted comments on draft guidelines for the regulation of complementary medicines in October 2011. That submission can be read here. https://www.tac.org.za/community/node/3180