TRADITIONAL CHINIESE HEALERS ASSOCIATION (TCHA)
09 November 2007
Submission by the Traditional Chinese Healers Association to the Health
Portfolio Committee on the Traditional Health Practitioners Bill [B 20 2007].
The Traditional Chinese Healers Association (TCHA) has reviewed the
Traditional Health Practitioners Bill [B 20 2007] and would like to
congratulate all involved in drafting the Bill. We welcome the extended consultation
and the latest call for comments on the Bill and would like to propose the
following:
General comments:
1. The Bill must be commended for reference to all forms of traditional health
in a number of clauses, but the Traditional Chinese Healers Association is
concerned that despite Classical Chinese Medicine [1] (see note at end of
email) following traditional health practices, philosophies and principles as
defined by the Bill, practitioners are excluded from being covered under this
Act (p 4 - definition for 'traditional health practice').
2. Although we are 'registered' with the Allied Health Professionals Council,
they do not recognise traditional philosophies and training methods
(master-to-student). The Allied is structured around the regulation of
alternative and complimentary healers (e.g. Western medical doctors who have
done a short course and practice acupuncture periodically in addition to
Western medical practice). The people regulating us have no understanding of
the principles underpinning traditional systems of medicine. This is being
evidenced in definitions within the Act, which give no recognition to the
traditional aspects of Chinese medicine, effectively altering a complex,
ancient traditional practice to a narrowly defined Western practice, without
consultation with people affected by these amendments. Section 22 of the
Constitution stipulates: "Every citizen has the right to choose their
trade, occupation or professional freely. The practice of the trade, occupation
of profession may be regulated by law. "
3. We also commend the Bill for recognizing 'traditional tutors' and
traditional internship type training (Master-to-student) - the members of TCHA
are all trained and train under this system. In China, these healers were originally
called "barefoot doctors" and had such a positive impact on health
that were recognized and influenced the Alma Ata declaration. Unfortunately the
system in China is now predominantly standardized and taught in colleges and
universities and in general no longer adheres to the traditional philosophies
and practice.
4. There is a global tendency to try and apply Western standards to traditional
practice - we fear that if we are regulated under a structure that does not
give due recognition to the traditional philosophies and methods of training,
this ancient traditional healing practice could be lost to South Africa. South
Africa can play an important role in ensuring the continuation of this ancient
traditional practice, ultimately for use in improving health in under resourced
communities.
Specific input:
The Traditional Health Practitioners Bill [B 20 2007] could without
adaptation include the Classical Chinese Medicine practitioners, except for the
fact that they are currently supposed to be registered under the Allied Health
Professionals Act and therefore excluded.
The Bill states:
Bill (P2)
To establish the Interim Traditional Health Practitioners Council of South
Africa; to provide for a regulatory framework to ensure the efficacy, safety and
quality of traditional health care services; to provide for the management and
control over the registration, training and conduct of practitioners, students
and specified categories in the traditional health practitioners profession;
and to provide for matters connected therewith.
Traditional Chinese Healers training and practicing with traditional
philosophies should, according to the above definition be regulated under this
council. There are further examples throughout the Bill e.g. within the definitions,
the Objects of the Bill (p26), etc. There is however no such recognition of the
traditional philosophies or training within the Allied Health Professions Act.
If the Traditional Health Practitioners Council to be established will carry
the responsibility of regulating traditional health care services in South
Africa, the Traditional Health Practitioners Bill needs to allow for inclusion
and membership of all traditional healers following traditional philosophies
and training.
We would be happy to further elaborate on this or provide clarity if required.
Peter Siyata: Secretary: TCHA
Dr Jeff Lan: Chairperson: TCHA
It should be noted that there are two different 'streams' of Chinese medicine
both internationally and in South
Africa. What is commonly referred to as Traditional Chinese Medicine (TCM)
usually refers to a standardized and academic/institutionalized healing - this
is the most common form, including within in China where Chinese medicine was
standardized to satisfy Western standards. It is this form that is recognized
by the Allied Health Professional Council South Africa (AHPCSA).
There are however a small group of traditionalists who have followed a lineage
"master-to-student" training, and hold ancient information passed
down through generations. It is this group that needs to be looked at
separately, as the traditional philosophies and training are not recognized by
the AHPCSA and in danger of being lost. We have (as have a few groups
internationally) called it Classical Chinese Medicine to distinguish it from
the standardized TCM.