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Alternative Medicine Reforms in Australia, the Codex, and Pan

Follow the government's agenda step by step as they tighten the noose around the neck of the alternative medicine industry

To go directly to the following subsections of this article click on the subtitles.

How to Deceive the Public - Pan to the Rescue

Strict New Rules Curb Herbal Drug Sales

Cutting Through the Codex Smokescreen: is the Australian Government moving to restrict availability of alternative medicines and reduce health freedoms?

Conclusion

Links and References

How to Deceive the Public - Pan to the rescue

If drug companies, realising that the past century of pharmaceutical drugs have been a total failure when it comes to curing chronic diseases such as cardiovascular disease, cancer, Alzheimer's disease, diabetes and a host of other diseases (see Health Trends), wished to takeover the alternative medicine industry how would they go about it? First, they would clearly need to justify such a takeover in the minds of the public. The safe and effective reputation of alternative medicines must be undermined and the alternative medicine industry as we currently know it, particularly at a retail or consumer level, must be rendered unviable. The alternative medicine industry must be discredited and the public convinced they must be saved from dangerous alternative medicines. This is in spite of the fact that the TGA describes alternative medicines as (1) "low risk". The public must be convinced they need to be protected, not from dangerous drugs, but rather from "low risk" "usually harmless" (5) alternative medicines  which are (2) "on average many hundreds of times safer than foods and many tens of thousands of times safer than the average medicine."

What would be needed would be some high profile media event which could be exploited for these ends. Such a media event could be high on sensationalism while also be rather lacking in scientific facts. This of course was the Pan crisis ( 3). 

The Pan crisis however, revealed that when drugs and alternative medicines were produced under shoddy conditions with poor quality control THE ONLY PRODUCT TO PRODUCE ILL EFFECTS WAS A DRUG (3). Huge numbers of alternative medicines produced under these same sub-standard conditions FAILED TO MAKE ANYONE ILL (3). In other words, the Pan crisis confirmed again the expert view that alternative medicines are, in the words of the TGA, "low risk" (4, 5 ), or in the words of Professor Dwyer (3, 5), "usually harmless". In spite of this however, the implications of the Pan crisis were twisted so successfully that most in the media, and also the wider community, were led to believe, in a campaign to discredit the alternative medicine industry, they should be protected from those "low risk" products that made no one ill, NOT the DRUGS which caused so much suffering. Their apparent eagerness to discredit the alternative medicine industry resulted in public statements that ranged from wild unscientific exaggerations to complete inaccuracies and falsehoods ( 3). Even the Commonwealth Minister for Health was shown to be making untrue statements ( 3). As far as I am aware no official apology for, and retraction of, these comments, was ever issued.  

Even in spite of all the publicity and allegations about the alleged dangers of "low risk" alternative medicines experts were unable to produce precise statistics revealing the high and increasing death rates from alternative medicines. This is in stark contrast to the situation in the pharmaceutical industry where the dangers of drugs are extensively documented. Authorities however, expressed no desire to introduce reforms to protect us from these dangers.

The obvious question is: why would anyone go to such amazing lengths to conceal the truth about alternative medicines and falsely convince the public that such products are so dangerous immediate action is required?

In spite of their failure to supply any scientific evidence of the dangers of alternative medicines as a result of the Pan crisis the government and the TGA were nevertheless successful in obtaining the inquiry they required in order to begin to establish the machinery and commence the legislative changes which would be necessary before any market takeover could occur. According to government authorities and those with a vested interested in the medico-pharmaceutical industry however these changes were necessary, not to enable a takeover, but rather to (4) "restore confidence" in the $800 million industry and ensure the safety of alternative products (4,6,7,8,25). There is however, another more covert agenda, a fact which is further confirmed by the TGA's reluctance to promote reforms for the most dangerous products, namely, pharmaceutical drugs. This agenda is related more to commercial considerations such as "market exclusivity" and "data protection."

Amazingly, two of the measures recommended by the inquiry to achieve the publicly stated aims of government authorities as far as restoring confidence and ensuring safety was concerned were guaranteed "market exclusivity" and "data protection" (6,8,9,10). Data protection of course simply means that the true benefits of alternative medicines must be kept a closely guarded secret (2). There must be a crackdown on internet sites and other sources of totally accurate information on alternative medicines. According to Verkerk (2)  current proposals under Codex in Europe "could represent a very severe infringement of freedom of speech because it will prevent people talking about the true benefits of a range of products." The same thing has been happening in America where the FDA has been attempting to prevent truthful scientific health claims about dietary supplements (33,35), while these moves to outlaw the truth are also a central part of Codex (47).

In Australia current restrictions which prevent truthful health claims about alternative medicines will also be strengthened. According to the TGA (20):

This of course is in spite of the fact that scientific and medical journals increasingly contain abundant references to the advantages of using  various dietary supplements for treating or preventing serious chronic diseases such as heart disease, cancer, birth defects, and asthma (4; see also; B Vitamins, Nutrition and Megavitamins, Asthma and B Vitamins, Nutrition is for the Birds, Health News and Links). Medical experts have even estimated that billions of dollars in health care costs (not to mentioned reduced suffering) could be saved if everyone took nutritional supplements (4; see also Experts say dietary supplements may save $billions in health care costs!!). While medical experts claim in scientific publications that anyone who does not take nutritional supplements is increasing their risk of suffering from serious or fatal diseases (4; see also Nutrition and Megavitamins), according to the TGA it is more important that we are prevented from making or publicising such claims.

While the TGA expresses abhorrence about the public being told the truth about the advantages of dietary supplements, they have failed to express the same degree of concern about the misinformation which was deliberately propagated during the Pan crisis (4). While they seek to strengthen regulations to penalise those who tell the truth about dietary supplements (4), they do not seek stronger regulations to penalise those who falsely denigrated dietary supplements during the Pan crisis (3). According to the TGA it seems, doctors, scientists and drug companies should be the only ones who know the true benefits of dietary supplements.

Market exclusivity of course is intended to guarantee the profits of drug companies which go to the expense of developing a herbal drug by isolating the active ingredient/s from herbs that have been used successfully for thousands of years (11, 12). Of course if multinational drug companies are to reap the benefits of products they develop then their investment must be protected. No use marketing and renaming expensive alternative medicines if the consumer can simply purchase the raw ingredient over the counter at health food stores or herb shops (12). In order to monopolise the market, market exclusivity must be guaranteed (6,9,10) To do this the natural products must first be banned or made so expensive that their continued marketing becomes impossible (11,12). When market exclusivity has been guaranteed and vested interests control product information then profits can be ensured. 

Precisely how market exclusivity and data protection, both of which are profit increasing marketing tools, are intended to ensure the safety of alternative medicines and restore consumer confidence has never been explained. Although there is obviously a commercial agenda here, this is not highlighted by government propaganda. Apparently it is expected that the wider community can be led to believe that data protection and market exclusivity are necessary to "restore confidence" and ensure the safety of "low risk" alternative medicines.

Let us examine now some of the initial consequences of the government's campaign to restore confidence in the alternative medicine industry, bearing in mind that if the government's commercial agenda is to be successful, then the current alternative medicine industry must first be made unviable. This of course applies particularly to the retail or consumer alternative medicine industry.

"Strict New Rules Curb Herbal Drug Sales" (13)

The above headline from an article in the Sydney Morning Herald in March 2005 underlines the initial impact of government attempts to "restore confidence" in the alternative medicine industry. This was followed by a report in The Age entitled (14) "Red Tape Forcing Up Medicine Prices". In this latter article Marcus Blackmore describes current reforms as "irresponsible and draconian" and he claims that the alternative medicine industry is over regulated. Mr Blackmore further stressed that many people now (14) "sit in fear of the regulator." This was further confirmed by Professor Ian Brighthope who stressed that he could not deal with "a regulator that to all intents and purposes is regarded as hostile to the industry." Both Blackmore and Brighthope acknowledged that their businesses may no longer be viable in Australia and they may be forced to move offshore. According to Lyn Allison of the Australian Democrats the current reforms are (14) "hounding manufacturers out of the country."

That the TGA is hostile to the alternative medicine industry is not news. The relentless determination with which they pursued the entire alternative medicine industry over the Pan crisis, even pretending that alternative medicines were so dangerous they must be immediately withdrawn from sale, is well documented (3). On the other hand, when the arthritis drug Vioxx was found to be causing deaths from heart disease (26,27,28,29,30) the TGA refused to act to ban or withdraw the drug preferring instead to leave it to the company involved to initiate a voluntary withdrawal (31,32).

In spite of these facts however, parliamentary secretary Christopher Pyne was unrepentant claiming that (14) "the sole basis of the government's regulation of complementary medicines is to ensure the safety of the public." He added: "we don't intend to lessen our regulations on the basis of pressure from the regulated industry." It would seem from these comments that, according to Mr Pyne the government is no longer interested in restoring confidence to the industry since the " sole" basis of the government's campaign is now "safety". However, approximately six weeks later Mr Pyne was quoted as making the following statement (6): "the Australian government has backed the recommendations contained in a high level review of herbal and other complimentary medicines aimed at enhancing the public's confidence in the Australian alternative medicines sector" (emphasis added). It is notable that the government never seems to express any concern whatsoever about public confidence and safety when it comes to drugs such as Vioxx.

If Mr Pyne, the government, and the TGA are at all concerned about public health and safety then their first and foremost concerns should be cardiovascular disease, cancer, and pharmaceutical drugs - for these are the greatest threat to mankind and by far the biggest killers (see Health Trends, Holistic Medicine Sets the Standard for Safety). Interestingly, scientific evidence reveals dietary supplements have the potential to reduce the death rate from all these 'diseases' (4; see also; B Vitamins, Nutrition and Megavitamins, Asthma and B Vitamins, Nutrition is for the Birds, Health News and Links, Holistic Medicine Sets the Standard for Safety) - and yet, according to the government, they are dangerous! Perhaps what is meant is that it is dangerous to continue to market them without total market control by multinational pharmaceutical companies!

Even in spite of all the facts cited above and elsewhere on this web site we are still expected to believe that we must be protected from the safest therapeutic products on the market, those products which the TGA acknowledges cause only 1%-2% of the total number of adverse reactions (4,8). Products which have been used safely for thousands of years are now suddenly becoming too dangerous to sell without radical legislative reforms (although we still need product exclusivity and data protection to guarantee markets for these products!). If the the government seriously expects the public to believe this it is clear that they still have an extremely low opinion of the intelligence of the general community.

All this recent concern about safety of products with such a long history of safe use is particularly strange given the dramatic reforms introduced by the Australian government six years ago (15,16,17,18). According to Senator Grant Tambling in 1999 these new regulations "mark the dawn of a new era for complementary medicines in Australia." One of the features of these new regulations was a (15,16) "shift of focus from market entry controls to post market vigilance for low-risk listable goods". It was further stated that consumers could have "confidence there are adequate safeguards from unsafe products." This new era of confidence however, lasted less than six years. How long will the next era last?

Cutting Through the Codex Smokescreen: is the Australian government moving to restrict availability of alternative medicines and reduce health freedoms?

As the current crackdown on alternative medicines continues the Australian government warns that soon they intend to "reformulate" or "withdraw" various alternative medicines from the market (9,13,19), allegedly to protect us from the dangers of  "low risk"  products (1). Even in spite of these trends some have claimed that the Codex requirements simply do not apply to Australia (20,21,37) Such claims however, usually completely ignore or downplay changes that are already occurring in Europe and the UK where 5000 natural products could disappear from retail outlets by August this year if opposition is unsuccessful (2,44). According to evidence cited by Eve Hillary however, the Codex does indeed apply to Australia and the retail availability of dietary supplements in Australia may be severely restricted from 1st July when new legislation, The TGA Amendment Bill 2005, will be enacted (38,39). 

According to Hillary (38):

Although the suggestion that the availability of dietary supplements without a prescription may become illegal (11,12) has been criticised (21), there is a global trend to reclassify dietary supplements as drugs (12,38,43). While Germany currently leads the world in this respect, having reclassified all dietary supplements as drugs (12), other countries such as Iceland, Denmark, Sweden and Norway are also making similar changes (2,12,34,36). The result of these changes is to dramatically increase the price of supplements and make it illegal to obtain higher potency supplements without a prescription (12). In the words of Hillary (40):

Similar changes are occurring in the UK and across Europe (44):

When considering the current controversy about international reforms to the alternative medicine industry it should be realised that although international guidelines established by Codex should require legislative backing in separate countries, such as the Food Supplements Directive in the EU (45,46,47,48), in practice this may not be necessary (45,46,47,48).  Australian laws are already being tightened in accord with the principles of Codex.

We should not forget that the stated purpose of the Pan witch hunt and subsequent reforms, according to the TGA, and the Australian government, was to protect consumers (from the safest therapeutic products on the market) and "restore confidence" in the alternative medicine industry (4,25). That these stated aims were a complete sham has been exposed beyond question (3,4). The subsequent inquiry has even resulted in headlines such as (13) "Strict New Rules Curb Herbal Drug Sales", all in the interest of "increasing confidence" in alternative medicines of course. The Pan scare campaign has effectively been utilised to justify moves which would favour those who seek to take control of the alternative medicine industry for financial gain. 

In view of the despicable activities of the TGA  and other authorities it is absolutely astonishing that the alternative medicine industry has not been much more vocal in their opposition to the Pan fiasco and the subsequent inquiry. Some sections of the industry seem more concerned about suggestions of a link between Pan and current international trends in alternative medicine than they are about the monstrous travesty of justice which resulted from Pan. Perhaps this is because of the influence of "front organisations" which covertly represent the interests of pharmaceutical companies (41). Associations and organisations which claim to represent the alternative medicine industry have all too frequently failed to represent the interests of consumers of alternative medicines.

As a consumer I am not so concerned about the name given to describe current undisputable trends to dramatically increase regulatory control over the alternative medicine industry (2,3,4,5,11,12,22,38,39,42) - I am interested in the motives behind such moves and the eventual result. Regardless of whether "Codex" applies to Australia or not, the fact is that governments all around the world are seeking to introduce dramatic reforms which have the potential to significantly reduce the availability of dietary supplements to consumers and erode health freedoms. It matters not whether these changes are described as "Codex", "Food Supplement Directive", or the "Therapeutic Goods Amendment Bill." Such arguments are intended to further conceal the fundamental underlying issues, namely, protection of dietary supplement availability and preservation of health freedoms. 

One should be wary indeed of those who do not mention these fundamental issues, those who merely offer irrelevant distractions, and those who pretend that it is nothing more than an amazing coincidence that countries all around the world suddenly simultaneously decided to "harmonise" and extend their control over alternative medicines and ensure that telling the truth becomes a criminal offence.

The current controversy regarding the Codex and the future of alternative medicine is so unnecessary and so avoidable. Politicians and health experts could so easily offer an "iron clad guarantee" that our current freedoms will be protected and rendered immune to the selfish desires of those whose vested interests are more related to money than health. Further, our politicians could enact legislation to ensure the preservation of our freedoms when it comes to the use and availability of alternative medicines. And those organisations which claim to represent alternative medicine should be at the forefront of the queue of lobby groups aimed at ensuring this is so. But alas, why is this not so? Why the extreme reluctance to move towards protection for the alternative medicine industry and the preservation of the freedoms of consumers? Why are the powers that be moving in exactly the opposite direction by seeking never ending powers over the dietary supplement industry? It is abundantly clear that many people are extremely worried about the direction of recent developments but yet no public authority is sufficiently concerned to take action to positively protect and preserve current freedoms, or tell the truth about the potential benefits of dietary supplements. And organisations purporting to represent alternative medicine all too frequently seem to forget to even make any such suggestion.

In the present crisis it seems consumers have been virtually forgotten as the different vested interests pursue their own particular interests.

Although disappointing, this is not too surprising. Those with a vested interest who perceive that industry changes could result in them reaping a considerable financial reward could, at least from an entirely selfish perspective, hardly be blamed for sacrificing current freedoms and the interests of consumers. Yet, although perhaps foolishly, as a consumer one nevertheless hopes that industry representatives will eventually acknowledge the greater good. 

It should not be forgotten however, that the golden rule when it comes to the introduction of flagrantly undemocratic and unpopular reforms is that the the true intentions of politicians and vested interests be must be concealed and the public must be kept ignorant and confused.....until it is too late. Industry puppets are likely to be expected to assist in this process of deceit and confusion.

As has been noted by Kathryn Alexander (12):

It is indeed interesting to note that the TGA is also now attempting to dispel fears regarding the Codex in Australia (20). Yet the TGA has been responsible for the Pan witch hunt and the unjustified condemnation of alternative medicines when a DRUG was found to be toxic (3,4). It is history now that this witch hunt was the first step in the TGA's current campaign to dramatically reform the alternative medicine industry in this country, including proposed restrictions on factual information, guarantees of market exclusivity, withdrawal or relabelling of products, and increased power to cancel licences of manufacturers (4,6,8,9,13,19,23). Amazing how these changes are so in line with changes being promoted by Codex. 

The Australian government, the TGA, and other bureaucrats who were involved, have an extremely serious credibility problem. Why should anyone believe them now when they went to such incredible lengths to conceal the truth, and their long term agenda, during the Pan crisis and its sequela. 

For those who are obsessed with names, we could call the Pan witch hunt, the resultant inquiry and industry reforms, and the harmonisation with New Zealand (24), the "Australian Takeover of Alternative Medicine" or the "Australian Codex". The eventual result may be identical whether Codex applies to Australia or not.

The upcoming harmonisation of Australian laws with New Zealand, which comes into effect on 1st July, has been described thus by Eve Hillary (41):

Since many medical experts have now openly acknowledged the scientific evidence indicating that people who do not take vitamin supplements daily are risking the onset of serious diseases (4), the fact that the TGA has adopted such an irresponsible and unscientific position by failing to make such recommendations is cause for grave concern indeed. When is the TGA going to adopt a position which is in accord with the scientific facts and public health considerations? And why does the TGA consistently display a bias in favour of drugs and drug companies? Why does the TGA adopt a  public health policy which seeks to crackdown on the safest therapeutic products on the market while virtually ignoring those products which cause 98-99% of all adverse reactions? When is the TGA going to admit the truth about the benefits of dietary supplements and acknowledge the fact that the Pan crisis proved yet again the dangers of drugs as compared to dietary supplements?

When our national drug regulator seeks to abandon the available scientific evidence relating to public health and adopt a stance instead which is consistent with the commercial interests of multi-national drug companies then  an urgent inquiry is obviously needed.

If the TGA really wished to dispel fears about Codex in Australia they would obviously have called for the government to enshrine health freedoms pertaining to alternative medicines in legislation. Why was it decided to omit such vitally important matters from the terms of reference of the recent inquiry? When does the government intend to act to protect and preserve the current health freedoms of consumers? It is all very well to adopt an entirely negative position and state that Codex does NOT apply to Australia, how about a detailed picture of what DOES apply to Australia? What is the eventual aim of their current anti-alternative medicine campaign? What is the underlying agenda? Why have they gone to so much trouble to mislead the public about the consequences of Pan?  What possible reasons could the government have for being so determined NOT to make any such assurances or adopt legislative reforms to protect the freedom of choice of alternative medicine consumers?

Conclusion

Currently attempts are being made around the world to radically reform the alternative medicine industry. While these changes are being promoted by Codex in many countries, in Australia they are being justified by Pan. These reforms aim to destroy the ready availability of dietary supplements at a retail level and create protected markets and guaranteed profits for drug companies which invest in such products. While these reforms will be justified on the grounds of safety this is the reverse of the truth. Not only has there been no sudden documented upsurge in adverse reactions to alternative medicines in all the countries proposing these changes, but experts have advised the public that anyone who does not take vitamin supplements is risking serious chronic diseases. These changes are being imposed from above with utter disregard of the interests of consumers and public health. They are commercially based changes aimed at guaranteeing the profits of drug companies. They are being driven by the current international boom in alternative medicines, the failure of drug therapies to control modern chronic diseases combined with the toxicity of drugs, and increasing scientific evidence of the benefits of alternative medicines.

As these reforms are instituted the following changes are likely to occur.

1. The retail availability of dietary supplements will be significantly reduced if guaranteed markets are to be established. This will be achieved either by pretending dietary supplements are dangerous and lacking in efficacy and reclassifying such products as drugs to be made available by prescription only (except perhaps for very low potency supplements which may continue to be available); or by forcing up costs to such an extent that the retail dietary supplement industry is largely destroyed.

2. There will be restrictions on freedom of speech when it comes to claims about the benefits of dietary supplements. There will be moves to interfere with the flow of truthful scientific information about such products, particularly on the internet. Authorities such as the TGA will decide what the public is permitted to know. 

3. Attempts to discredit the alternative medicine industry will continue as authorities seek to create public panic about the safety of dietary supplements. On the other hand these same authorities will ignore or downplay the safety risks posed by the most dangerous therapeutic products, namely pharmaceutical drugs.

4. There will be a remarkable similarity between the industry changes instituted in different countries. The changes will be global. Authorities will stress the need to "harmonise" these new laws.

While there is still some uncertainty about precisely when current reforms will be fully implemented, there is absolutely no doubt about the direction in which we are progressing and the nature of the long term agenda of the government and the TGA, a fact which is confirmed by the determination with which this agenda has been concealed. URGENT ACTION IS REQUIRED NOW!

Go to http://www.evehillary.org/secret.antihealth.legislation.htm and register your protest. 

Links and References

1.  http://www.tga.gov.au/docs/pdf/cmfact3.pdf  See: Complementary Medicines Explained, Therapeutic Goods Administration, Canberra.
2.  http://www.nhca.com.au/documents/INTERVIEWwithDRVERKERK.pdf See: Louise Mclean, Interview with Dr Robert Verkerk, Alliance for Natural Health, April 2005.
3.  http://www.holistichealthtopics.com/HMG/pan.html
4.  http://www.holistichealthtopics.com/HMG/response.html
5.  http://www.holistichealthtopics.com/HMG/drug.html
6.  http://www.health.gov.au/internet/wcms/publishing.nsf/Content/health-mediarel See: Christopher Pyne, Australian Government Supports Reform for Complementary Medicine, Media Release, Department of Health, Canberra, 9th March 2005.
7.  http://businessnetwork.smh.com.au/articles/2005/03/03/1797.html See: Dominic Cadden, Natural Withdrawal Symptoms, Sydney Morning Herald, 4th March 2005.
8.  http://www.tga.gov.au/docs/html/cmreport1.htm See: Expert committee report: Complementary Medicines in the Australian Health System, Report to the Parliamentary Secretary to the Minister for Health and Ageing (2003), Department of Health, Canberra.
9.  http://www.tga.gov.au/cm/cmresponse.htm See: Australian Government response to the recommendations of the Expert Committee on Complementary Medicines in the Health System, Department of Health, Canberra, March 2005.
10.http://www.asmi.com.au/PosPaperDataProtectMar05.doc See: Data Protection and Market Exclusivity for Non-prescription Complementary and Over-the-Counter Medicines, Australian Self Medication Industry.
11.http://www.holistichealthtopics.com/HMG/codex.html
12.http://www.holistichealthtopics.com/HMG/codex2.html
13.http://www.smh.com.au/news/National/Strict-new-rules-curb-herbal-drug-sal See: Mark Metherell, Strict new rules curb herbal drug sales, Sydney Morning Herald, 10th March 2005.
14.http://www.theage.com.au/news/National/Red-tape-forcing-up-medicine- See: Phillip Hudson, Red tape 'forcing up medicine prices' , The Age, 24th April 2005.
15.http://www.health.gov.au/internet/wcms/publishing.nsf/Content/health-mediarel See: Grant Tambling, Launch of the Complementary Healthcare Council of Australia, Speech by Grant Tambling at the launch of the Complementary Healthcare Council of Australia, Media Release, Department of Health, Canberra, 14 May 1999.
16.http://www.seniors.gov.au./internet/wcms/publishing.nsf/Content/health-mediar See: Grant Tambling, Proprietary medicines - "Better health through responsible self medication", Speaking at a Proprietary Medicines Association of Australia (PMAA) dinner in Melbourne, Department of Health, Canberra, 23rd February 1998.
17.http://www.seniors.gov.au./internet/wcms/publishing.nsf/Content/health-mediar See: Grant Tambling, New complementary medicine legislation passed by parliament, Media Release, Department of Health, Canberra, 26th March 1999.
18.http://www.seniors.gov.au./internet/wcms/publishing.nsf/Content/health-mediar See: Grant Tambling, Government's complementary medicines reforms up and running, Media Release, Department of Health, Canberra, 28th April 1999.
19.http://www.abc.net.au/news/newsitems/200503/s1319924.htm See: Alternative medicine rules tightened, ABC News Online, 10th March 2005.
20.http://www.tga.gov.au/cm/fs_codex.htm See: Fact sheet - Codex, Therapeutic Goods Administration, Canberra.
21.http://www.atms.com.au/news/Codex.pdf See: Raymond Khoury, The Codex Threat To Australia - Fact or Fiction?, J. Aust. Trad. Med. Soc., March 2005.
22.http://www.holistichealthtopics.com/HMG/Hillary.html
23.http://www.tga.gov.au/docs/html/argcm.htm See: Australian regulatory guidelines for complementary medicines, Therapeutic Goods Administration, Canberra.
24.http://www.jtaproject.com/hot.htm#CMConsult See: Trans-Tasman Therapeutic Products Agency Project.
25.http://www.tga.gov.au/docs/html/cmreport.htm See: Expert committee on complementary medicines in the health system, Therapeutic Goods Administration, Canberra.
26.http://afr.com/cgi-bin/newtextversions.pl?pagetype=printer&path=/articles/200 See: Merck recalls $3.5bn arthritis drug , Australian Financial Review, 1st October 2004.
27.http://www.heraldsun.news.com.au/common/story_page/0,5478,12814548% See: Matt Cunningham, 300 deaths blamed on arthritis pill, Herald Sun, 11th April 2005.
28.http://www.abc.net.au/4corners/content/2005/COX-2-chronology.htm See: COX-2 Chronology, FOUR CORNERS, Australian Broadcasting Corporation.
29.http://query.nytimes.com/gst/health/article-page.html?res=9B03E3DE1338F See: Barry Meier, Merck and Vioxx: The Clinical Tests; For Merck, Defense of a Drug Crumbles at a Difficult Time, New York Times, 1st October 2004.
30.http://www.taipeitimes.com/News/biz/archives/2004/10/03/2003205410 See: Merck's Vioxx a triumph of marketing over science, Taipei Times, 3rd October 2004.
31.http://www.tga.gov.au/media/2004/040930_vioxx.htm See: Consumer level recall of arthritis drug, Therapeutic Goods Administration, Canberra, 30th Sept 2004.
32.http://www.tga.gov.au/recalls/2004/vioxx.htm See: Vioxx (Rofecoxib) Medicine recall, Therapeutic Goods Administration, Canberra, 1st Oct 2004.
33.http://www.supplementquality.com/news/FDA-court-short.html See: Court Finds FDA Rejection of Truthful Health Claims Unconstitutional.
34.http://www.newmediaexplorer.org/sepp/2004/09/07/denmark_t See: Sepp Hasslberger,  Denmark To Eliminate Concept Of Supplements: 'They're All Medicines', 7th Sept 2004.
35.http://www.lewrockwell.com/paul/paul34.html See: Ron Paul and Peter DeFazio, Don't Regulate Supplements, Joint Statement from Congressmen Ron Paul (R-TX) and Peter DeFazio (D-OR) submitted to the House Committee on Government Reform: "Six Years After the Enactment of DSHEA: The Status of National and International Dietary Supplement Regulation and Research", US Congress.
36.http://www.mayday-info.dk/279.0.html See: Health Freedom Under Serious Threat in Denmark, MayDay.
37.http://www.chc.org.au/scripts/cgiip.exe/WService=ASP0012/ccms.r?Roxy= See: Industry Response to Codex, Complementary Healthcare Council of Australia.
38.http://www.evehillary.org/sickness.industry.last.stand.1.htm See: Eve Hillary, Codex - The Sickness Industry's Last Stand, Part 1, 23rd April 2005.
39.http://www.evehillary.org/secret.antihealth.legislation.htm See: Eve Hillary, Secret Anti-Health Supplement Legislation Being Passed in Aussie Parliament.
40.http://www.evehillary.org/sickness.industry.last.stand.ref.htm See: Eve Hillary, Reference 33, Codex - The Sickness Industry's Last Stand, 23rd April 2005.
41.http://www.evehillary.org/sickness.industry.last.stand.2.3.htm See: Eve Hillary, Codex - The Sickness Industry's Last Stand, Part 2, 23rd April 2005.
42.http://www.newmediaexplorer.org/sepp/2005/05/09/australia_new_zealand_c See: Sepp Hasslberger, Australia, New Zealand - Codex Alimentarius and Trans-Tasman Harmonization, 9th May 2005.
43.http://www.asmi.com.au/Complementary%20Medicine.htm See: ASMI and Complementary Medicine, Australian Self-Medication Industry.
44. http://www.newmediaexplorer.org/chris/2005/02/10/whats_happening_in_the See: Chris Gupta, What's happening in the UK effects YOU - FSD/CODEX, 10th Feb 2005.
45.http://www.thenhf.com/codex_24.htm See: Paul Anthony Taylor, Overview: The Differences between Codex and the EU Food Supplements Directive, National Health Federation, October 2004.
46.http://www.healthchoice.org.uk/codex/default.aspx See: Paul Anthony Taylor, CODEX Alimentarius – A threat to your vitamin supplements?.
47.http://www.westonaprice.org/federalupdate/aa2005/infoalert_042205.html See: Jim Turner, CODEX Guidelines on Dietary Supplements, Weston A. Price Foundation, 22nd April 2005.
48.http://www.mercola.com/2005/may/4/codex_conundrum.htm 

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