Take Action Against Career-threatening FDA Proposed Regulation

Jun 6th, 2008

Cathy Christensen

The Day Spa Association issued a release to its members urging them to take action against a new career-threatening regulation. The U.S. Food and Drug Administration (FDA) has recently rewritten their regulations in an attempt to outlaw and eliminate alternative health care modalities. From massage to vitamins, minerals, and herbs, all alternative and complementary modalities will be labeled as practicing medicine without a license unless prescribed by a physician.

The subtle change of vocabulary from "alternative health care" to "alternative medicine" makes all of these industries subject to control by the FDA as medicine. Only medical doctors would be allowed to provide, prescribe and supervise the delivery of these services. Anybody else who provided any of these services would be practicing medicine without a license, and subject to incarceration and fines.

Click here to read the actual draft guidance.

What this means

1. By using the term "medicine" rather than "modality," for CAM practices, the FDA sets the stage so that anyone who is not a licensed physician is breaking the law by using these modalities since they are therefore "practicing medicine without a license."

2. By using the word "treatment," rather than "therapy," the FDA limits those who can perform these practices to licensed physicians.

3. By using the terms "medicine" and "treatment," instead of "modalities" and "therapy," all substances including vitamins, mineral herbs, co-factors, etc., automatically become untested drugs since they are being used to prevent, treat, mitigate, or cure disease states. Such use can only legally take place with FDA with FDA approved drugs.

What you can do

Write to the FDA directly.

Write individual letters, call your congressman's office, or send an e-mail.
Raise awareness among your colleagues and encourage them to take action, as well.