The Dos and Donts of Chinese Herbal Dispensing

September 30, 2020

Safflower Chinese Herbs. Expertly Dispensed has been compounding herbs for over 12 years. When it comes to herbal dispensing, we have gathered a fair bit of expertise. We love herbal dispensing and are lucky enough to be able to support at least three projects per year. Recently, we have decided to back:

  1. Chinese herbal cultivation in Australia
  2. Bringing acupuncture to our most vulnerable communities
  3. Support Chinese herbal research

Our dispensary service only operates because practitioners take up our offer. Thank you to those loyal individuals in Australia who have supported our model for many years. We sincerely appreciate it. For our colleagues who have decided to do their own herbal dispensing, this short article, might help you to streamline or optimize your current herbal dispensing practice.

The importance of being familiar with the Guidelines for the Safe Practice of Chinese Herbal Medicine

The Chinese medicine registration board (CMBA) developed the guidelines for Chinese medicine (CM) practitioners under section 39 of the Health Practitioner Regulation National Law. This means, even though they are not actively enforced, they will be used as evidence in proceedings. The fact that they were developed in the first place also means that a risk associated with Chinese herbal medicine was identified. We are held accountable by the Board and are required to meet the standards set by the CMBA. The guidelines are reviewed every three years which means, we will have to keep an eye out for potential changes to them sometime this year.

In a nutshell, the requirements for a safe herbal dispensing practice are:

  • Clear and consistent herbal nomenclature
  • Comprehensive Patient records
  • Adequate prescriptions
  • Accurate labelling
  • Precise and professional compounding & dispensing
  • Guidelines apply to all practicing and registered CM practitioners (not to retailers when sale not part of a consultation with a registered practitioner)

If you are registered in Acupuncture only and are intending to prescribe/dispense herbs for patients, you are required to disclose to your patients, that you currently not have registration in Chinese herbal medicine. If you prescribe or sell patents (finished products) to your patients, it is not necessary because patents are usually universally available and sold over the counter.

Supply Chain and Stock Management

At Safflower, we believe, it is important to know where the products are coming from. So, we use a system called supplier profiling which allows us to work out if a company can provide us with the service that we expect. We always want to establish the full supply chain and know exactly where products have originated. We investigate if criteria that we have set (for a partnership) are met and above all, has the supplier ethical and sustainable practices in place. How are the communication pathways, are we taken seriously in our requirements and do they behave like a real partner? We believe that helping each other out is important especially in a small industry like ours.

After all, we want to be able to offer a top quality product and service. One of the criteria are Certificates of Analysis (COA’s). In our case, our GMP (Good Manufacturing Practice) requires them. If we would not get quality certificates, we would have to have every single batch analyzed to rule out wrong botanical identity (of herbs) and harmful contamination. This is costly, and in our case, an important factor to consider when sourcing herbs and contacting suppliers. Once we found a potential partner, we will negotiate terms and conditions, not necessarily prices, but perhaps payment conditions or minimal stock amounts or anything else that will assist us in streamlining our herbal dispensing practice. We are always optimizing our current structure, so we can deliver as much value to our practitioners as possible.

Stock management is the key to your success. And it is a fine line. After years of trialing, the key ingredient to success lies in being organized with great attention to detail. Choose a stock management system that you can easily follow, and it could be as simple as keeping an excel sheet. What we found with practitioners is that they want to have ‘everything’ in their herbal dispensaries, because, we get it, having herbs is great. But rather than choosing too many product, focus on a particular area (like Women’s health) and then endeavor to stock the most important herbs for that area. Complement this with either using patents or using a dispensary service. For example, you are seeing children as well or you are working with auto-immune conditions the source herbs for those target groups in buying in patents or tapping into a 3rd party dispensary. We feel, this is one of the common mistakes that practitioners make.

Dispensing, Record Taking and Patient Safety

Be diligent with hygiene and remain diligent with hygiene. Not just in times of pandemics but constantly. If you can assign batch numbers to each script and patient, that would be awesome. As you know the batch number allows you to back track the product to its origins. Its also important for Patient Safety, in the unlikely event of you having to make a recall because your supplier was forced to do that, you will be able to find the patients promptly who had a certain substance. Of course, they might have already ingested it but at least there is full disclosure. We are also supposed to report adverse effects to the TGA. With individually composed formulas it’s a little more difficult because single substances are not listed on the ARTG (Australian Register of Therapeutic Goods) but patents are. Single substances are sometimes considered as food or in our case as starting materials.

At Safflower, we are not fans of recycled containers. So, we use packaging materials that is medicine grade. They do create more waste, which is unfortunate. Perhaps glass containers are an option if your patient can bring them back for a refill, especially because they can be washed in high temperatures. If you look at how consistently you dispense product, it is easier to make out why a particular patient has reacted in a certain way. But if you are not sure if you put the same ingredients into each of their repeat scripts, its difficult. In our operation, consistency is achieved with following SOP’s (Standard Operating Procedures). We have it for every single activity in the dispensary including washing dispensary utensils, cleaning, adding stock, disposing of expired stock, compounding products, releasing finished products, packing, and dispatching.

It is a lot of work, but for a professional dispensing service, its necessary for continuous consistency and patient safety.

Labelling Requirements

As per the guidelines, it’s very clear what needs to be on the label of a medicine that you give your patient:

  • English language and herbs in pin yin
  • Patient name and dispensing date
  • Individual ingredients and dosages
  • Dispenser/practitioner name and contact phone number
  • Specific directions and cautions
  • Warnings where relevant
  • Easy to read for everyone: Labels are for patients (and everyone else, emergencies)

It’s hard to believe that some practitioners still refuse to put the exact ingredients onto the label. Labels are most important for the patient and anyone else that might require to take action with an ill patient that has also taken Chinese herbal medicines.

Restricted Herbs

The law is clear about it. If we are not registered medical practitioner, dentist, veterinary surgeon or pharmacist, Fu Zi and Ma Huang is out of our reach. This is very frustrating, and remember, you can’t even touch them as Chinese medicine practitioner if their measurements are below the threshold levels. To use those herbs is highly illegal. Thankfully, scheduling might be happening down the track. A couple of years ago, the profession has asked the CMBA to assist with this. We don’t have an update but we knew it was going to take some time for the entire process (we are talking years).

Patents or Manufactured Herbal Medicines

Safflower does not have a lot of expertise with patents. So, our experience is limited. They should all have the AUSL or AUSR (which means that they are listed on the ARTG) and comply with certain (medical) standards. They should not be repackaged or re-labelled and the AUSL or AUSR should be clearly visible. If you need to change the dosage of the patient, it is best to stick it onto the product, so the patient can check it and will remember how to take their herbs.

Potential Issues with Herbal Dispensing

Herbal dispensing is a specialist skill and there is a risk to not take it seriously enough. It does require know how and resources. The financial outlay can be significant. The financial gain for a practitioner through the sales of herbs is a sub-optimal situation. It was the very reason why it was stopped in some countries. So, what we have been discussing for years is could we charge a dispensing fee.

The pharmacist is paid by the products that he sells, but they are usually not (or at least not all of them) prescribed by him. That is a big difference. You must be familiar with the CMBA guidelines. Imagine if someone is reporting you and you are investigated. It is very stressful to be audited. You can avoid problems or not being able to answer some questions by reading and adhering to the guidelines. They are here for a reason. And lastly, keep up the great hygiene guidelines that we have all developed in the past six months or so and never deviate from them ever again. Do not be temped to use stock that is expired or about to expire. We know how difficult it is to waste products, especially if someone sometime said that they wanted it. You just must bite the bullet and chuck it out.

If you know exactly what you are doing with your herbal dispensing and are confident that you are meeting all the marks, well done. Congratulations! We know how hard it can be.

If you are interested in reading the White Paper: Should a Chinese Medicine Practitioner Dispense their own herbs, you can download it from here.

Some economical Considerations that you might want to check

Be smart about it, that’s the key to your success. BE aware that there is a financial outlay that might be too much when first starting out. Perhaps consider a limited range of herbs for a particular area of interest. The costs of a full dipsnesary are very high and to keep stock on your shelves is around 1.8% of your stock value. There is going to be restricted cashflow and as as single operator, it simply might not be worth the time and effort for you to have your own dispensary. You will only know if you calculate your profit and loss and include all your resources in the calculation not just the purchasing costs of herbs. Our recent survey revealed that most prractitioners use around 0.5 – 1.5 hours for re-ordering herbs per week. So if you want to see more patients, running your own herbal dispensary might not be the best option to achieve that.

Invest into a inventory management system, it can be as simple as an excel sheet. But keep track of your data and finances, that’s what the most important economical consideration is.

In essence the dos:

  • Analyze your requirements for herbs, have a clear plan about it
  • Be aware of your responsibility and the consequences of your actions
  • Be organized and systematic 
  • Strict hygiene guidelines
  • Keep track and look at data (both inventory and financial)
  • Stay consistent

and donts of herbal dispensing:

  • Don’t just go random about your herbal dispensing, plan it out
  • Don’t give your patients expired products/stock (this includes raw herbs with life in them)
  • Don’t try and have as many herbs available as possible (it will be difficult to keep up)
  • Don’t be tempted into buying, obtaining, dispensing or dealing restricted herbs – it’s very clear, we don’t have legally access to them

Please ask us any questions that you might have and thank you for your time and attention.

Brigitte Linder

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