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use of herbal medicines is a growing phenomenon in both developed
and developing countries. To improve patient safety, various WHO-led
initiatives encourage Member States to establish comprehensive national
pharmacovigilance systems which incorporate herbal medicines.
The unique characteristics of herbal medicines pose enormous challenges
to monitoring of the safety of herbal medicines effectively. After
years of implementation of various measures by national regulatory
authorities and national pharmacovigilance
centres, it is appropriate to assess the
effectiveness of those approaches.
The objectives of this working
group were: 1) to share recent observations related to herbal medicines'
safety concerns, 2) to identify better ways to apply the WHO guidelines
and other technical documents to enhance safety of herbal medicines,
3) to identify means of creating trust among health professionals,
providers of herbal medicines and patients for the prevention of
potentially serious risks from misuse of herbal medicines, 4) to
propose tools for assessment of the effectiveness of national pharmacovigilance systems for monitoring of herbal medicines,
and 5) to make recommendations to WHO about specific technical assistance
to national centres.
Discussions for the objectives
from 1 to 5 include the following:
The group agreed to distinguish
the differences between "herbal medicines" (referring
to herbal products regulated as medicines under national regulatory
framework) and "herbal remedies" (referring to herbal
products not regulated as medicines under the national regulatory
framework and herbal preparation directly given by the practitioners,
e.g. traditional medicine practitioners, and herbalists).
1) Proliferation on the market
of developing countries of herbal remedies and the so-called food
supplements adulterated with undeclared pharmaceutical substances
(orthodox medicines) pose a serious threat to patient safety. Patient
safety continues to
be compromised by the misconception
that every natural product is safe. In the absence of a regulatory
framework for herbal medicines in most of these countries, it is
almost impossible to implement any effective regulatory intervention
including adverse drug reaction monitoring of herbal medicines.
It was also pointed out that the traditional medicine practitioners
or herbalists in these countries provide their own herbal formularies
directly to their patients as part of their practice and that these
herbal formularies are usually not the subject under the national
regulation. It is difficult to regulate such products particularly
in these developing countries. It was suggested
that the establishment of a national regulatory framework for registration
of traditional medicine practitioners or herbalists may be one
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approach
to improve the situation.
2) The group acknowledged the
availability of WHO guidelines and other documents which could be
applied not only to guide regulation of herbal medicines and the
monitoring of their safety, but also to provide training. However,
there-appear to be cases where these resource materials are kept
in offices without being utilized in those countries where herbal
remedies are on the market.
3) The
low numbers of spontaneous adverse drug reaction reports associated
with herbal medicines were attributed to the general lack of "pharmacovigilance culture" among stakeholders. For trust,
transparency is necessary and there must be the willingness by both
producers of herbal medicines and providers of herbal medicines,
especially traditional practitioners to learn proven ways of doing
things better and to observe regulatory requirements and best practices.
A herbal remedy that has been subjected
to the necessary scientific assessment and is duly registered induces
confidence for its use and for its safety profile to be better monitored.
4) In principle, it was recognized
that there is the need for the assessment of the effectiveness of
a pharmacovigilance system for monitoring
the safety of patients who use herbal medicines. It was, however,
observed that until the necessary legislative and regulatory framework
and the accompanying infrastructure are put in place, it is practically
impossible to define the required assessment tools.
5) Since countries are at various
levels of regulatory "maturity" in respect of the regulation
of herbal medicines, it was the opinion of the group that national
centres and national regulatory authorities
should identify their specific needs to be presented to their respective
governments and WHO.
It was recommended that governments
should exercise the political will to put in place the necessary
legislative framework for the effective regulation of herbal medicines.
National regulatory authorities and pharmacovigilance centres should
make use of available resources including the WHO guidelines and
other published texts to enhance their regulatory processes and
safety monitoring efforts. WHO, in collaboration with national centres,
should take the lead in the creation of training opportunities for
providers of herbal medicines to improve their knowledge base in
quality issues in general and to introduce them to the culture of
pharmacovigilance in particular to enhance
spontaneous reporting by providers of herbal medicines. Countries should strengthen the capacity of their
quality control infrastructures to analyse
herbal medicines and the so-called food supplements, and to share
such information.
Discussion:
For effective
therapeutic and ADR monitoring of herbal medicines, the labels of
products should indicate the place of origin in order to identify
the drug properly.
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