Therapeutic Products Bill – Assessment, Report and Objections by the NZ Outdoors & Freedom Party

The NZ Outdoors & Freedom Party makes this report on the TPB for the party and on behalf of the 15,000 people who signed our open letter to the Prime Minister, Andrew Little and other members of parliament and for our 25,000+ members and supporters.
We confirm our support for the Reports on the TPB by PSGR – Physicians and Scientists for Global Responsibility, HealthPost, Hilary Butler, Guy Hatchard and Charlotte Milton’s report on the effects of the TPB on Rongoa Maori.
NZ O&F Party Health and Wellbeing Policy is a central part of our Policy statements and includes natural medicine as an inalienable right for all New Zealanders.
The Outdoors & Freedom Party (O&FP) believes that the most important thing a person can possess is the gift of good health and the most important thing a government can do is to ensure the health of the nation. We envision a world class system that is based on a regenerative and holistic approach to health that combines conventional and complementary approaches. This system would take an integrated approach to biological, functional and environmental medicine and lifestyle that will inform, educate and empower the patient, their family/whanau and their community to create and maintain their own health and well-being.


“health, housing and education are the basic requirements of individual welfare as well as being essential for the prosperity and effective functioning of a modern society” (Australian economist, Peter Self)


Our Nation is suffering an epidemic of asthma, chronic fatigue syndrome (CFS), autoimmune disorders (diabetes, rheumatoid arthritis, multiple sclerosis, thyroid disorders etc.), mental illness (anxiety and depression), neurological degeneration (dementia), stroke, undetected infections and their complications (rheumatic heart disease, Guillain-Barré Syndrome). Our leading causes of death are ischaemic heart disease, cancer (colorectal, breast, prostate, lung), suicide and trauma, diabetes, stroke and other diseases of circulation. (https://www.health.govt.nz/our-work/populations/maori-health/tatau-kahukura-maori-health-statistics/nga-mana-hauora-tutohu-health-status-indicators/major-causes-death)


The O&FP recognizes that modern medical treatment may help alleviate a patient’s symptoms, but if the underlying cause is not resolved, the patient often experiences further deterioration of their health. It is clear that our medical system is not designed to prevent or heal chronic diseases. This Bill has nothing in it that gives us confidence that having a ‘regulator’ and new rules will improve our state of health, if anything it will make it harder to take responsibility for ones health. We here at O&FP believe the creation of good health should be Government’s primary goal, instead of an increasingly expensive disease management system. The O&F Party recognises that good health is not “a coincidence” and is dependent on multiple factors but decades of poor risk assessment means that kiwis are exposed to multiple toxic substances on a daily basis. Ignoring this as a cause of disease puts the burden of health on to individuals instead of society. This Bill does nothing to change these risk factors. In fact, without clinical toxicologists investigating acute and chronic harm from chemicals, (pharmaceutical, agrichemical, petrochems, household etc) and clinical pharmacologists managing drug interactions and poly-pharmacy, O&F Party sees this Bill increasing risk of harm from pharmaceuticals because there are enough ‘free passes’ in this bill that will allow the pharmaceutical industry to ‘get away with murder’ as they already are, with a slap in the wrist with a wet bus ticket.


This bill will likely interfere with the Outdoors and Freedom Party’s ability to fulfill our policies and for the public and private sector to fulfill their stated objectives to ensure the health and safety of New Zealanders.
If the stated purpose of the TPB is “to protect, promote, and improve the health of all New Zealanders” then it’s clear that NHP’s have no place being regulated in this bill alongside pharmaceuticals, medical devices, biologics, gene and cell therapies. Our reasons are as follows.

  1. O&F Party is completely in agreement that herbal remedies and other supplements imported or manufactured in New Zealand should be of excellent quality and include only the ingredients that they say, and it makes sense that health products should be free from contamination such as pesticides, herbicides, pharmaceuticals and metals, other herbs, etc. But that is no reason to regulate them with pharmaceutical medications, gene modifying processes and medical devices that are high risk. Herbal remedies are already regulated by the Dietary Supplement Regulator and Fair Trading Act.
  2. Outdoors & Freedom Party certainly agree that pharmaceuticals, biologics, medical devices and gene therapies need extreme regulation and strong penalties for deceitful and harmful practises. But this bill mentions NHP 280 times and biologics 30 times and gene therapy just the two times. We feel that this bias is already obvious and is focusing on something that isn’t the problem, and ignoring the thing that is the problem. A fine of $1,000,000 is nothing to the pharmaceutical industry and is just a ‘cost of doing business’ but would destroy a small natural remedies company, so there is no comparison of “proportionate risk”.
  3. NHP may be up to 100,000 times (using data from Australian Iatrogenesis reports) safer than pharmaceuticals. A 2012 report of EU causes of death rate risk of death from natural remedies and herbs to be less than being struck up lightening, a similar finding in Australia. (graphs in section below) They do not cause significant harm and do not need regulating. All that is required is that they follow good manufacturing process and consumer guarantee that the product is what it says it is. They should have to be proven to be free from contaminants and if stated as organic, should it fact be “organic”. This is what the health industry has been requesting, not the Bill that you have produced – might I add with NO consultation with the ‘stakeholders’ – the 60% of New Zealanders who take supplements on a regular basis.
  4. Many of our members and supporters spend a lot of time, effort and funds to maintain their health – with supplements, organic foods, natural treatments for them and their families. Many of us successfully managed our covid symptoms at home with specific high dose supplements – keeping us out of the medical system altogether, easing strain on the hospital system. We are collectively saving the govt millions of dollars whilst we take care of our own health. These people are not counted in your Government run medical system, hence this Bill does not take account the tens of thousands (hundreds of thousands?) of us who have to pay for our own health care because natural health care is not Govt funded in this country. Many of us have poured thousands of hours and thousands of dollars in to discovering what works for us and our families, and through trial and error, and support from our chosen health professional – we’ve figured out what works for us. If supplements are too expensive it will reduce our ability to ‘trial and error’ or even do combination of supplements, or take them long enough, because it’s often a combination of remedies and time used that are effective in curing a particular illness. The complete lack of funding for natural therapies and the subsidization of pharmaceuticals and Govt sanctioned medicine, means that natural health care is accessible only to the middle and upper income earners. This legislation will potentially embed that further in our society. Granted, herbal remedies CAN cause reactions and allergies, but the risk is minute compared to pharmaceuticals, and generally mild and self-limiting.
  5. This Bill is highly likely to increase the costs for a small producer to the point that they can’t afford to stay in business, and we will all suffer due to this reduction in chose. O&F Party believes in “localism”, sourcing and supporting and being sustainable in our own rohe (food basket) but this bill may force our (natural) health providers out of business and their patients and customers reliance on overseas products.
  6. We are not infants, and can manage our own health, and we resent Govt potentially interfering in our ability to access herbs, high potency supplements, rongoa and IV vitamin C and so on.
  7. Therefore NHP’s have no place in this Therapeutic Products Bill.
    THE REGULATOR
  8. The Regulator can not be trusted to perform its duty appropriately, for neither NHPs OR pharmaceuticals, as it has already been captured by the pharmaceutical and bio-tech industry. We know this because MedSafe, the current medical ‘regulator’, did not pull the Comirnaty BioNTech injection when it is more than clear that great harm is being done, despite its stated mission being to: “To enhance the health of New Zealanders by regulating medicines and medical devices to maximise safety and benefit.”
  9. It has clearly been negligent in its duty shown simply in the CARM reporting on the Comirnaty BioNTech injection https://www.medsafe.govt.nz/COVID-19/safety-report-46.asp if you go to the very bottom of this page, in very small writing, is the Download AEFI-line-listing.xlsx (Excel, 4087 KB) which documents nearly quarter of a million different vaccine reactions reported by nearly 70,000 people. Medsafe has dismissed nearly all of these reactions as they did ‘not necessarily mean that the vaccine did cause the event” and “the observed number of deaths reported after
    vaccination is actually less than the expected number of natural deaths” and by Medsafe dismissing and discrediting AEFI reports, they are negligent in fulfilling their stated objectives of keeping New Zealanders “safe”. The public expects Medsafe to actually investigate these reactions and act quickly to withdraw the offending compound, not just dismiss reactions and deaths as ‘less than background rate’.
  10. Example: The Regulator in Australia, TGA, the Australian equivalent to Medsafe, and hence the new New Zealand regulator, has been exposed to have purposely hidden data from the public that showed that the Comirnaty injection has killed children in Australia, because it might “cause the public to lose trust in the vaccine”.
    https://dailysceptic.org/2023/02/15/australias-drug-regulator-hid-child-vaccine-deaths-to-maintain-public-confidence/
  11. This is the utter opposite to the objectives of this organisation which clearly states “We are Australia’s government authority responsible for evaluating, assessing and monitoring products that are defined as therapeutic goods. We regulate medicines, medical devices and biologicals to help Australians stay healthy and safe.” And then proves it is clearly not interested in “helping Australians stay healthy and safe” by disregarding and downplaying reactions to the Comirnaty Injection. As seen on their website: https://daen.tga.gov.au/medicines-search/
  12. The ‘public servants’ running Medsafe in NZ, have also downplayed deaths and side effects to the covid injection, Example: https://www.stuff.co.nz/national/health/coronavirus/300564406/covid19-third-death-considered-linked-to-vaccine-was-a-teenager which proves it to be a ‘captured’ and corrupt organisation. Medsafe staff has been doing this for decades, this favourable treatment of the pharmaceutical industry is nothing new. They have ignored and dismissed data that shows vaccines given to infants is also causing harm including deaths, seen in past years Iatrogenesis reports. Medsafe can not be trusted to give enough data on a
    medication for medical practitioners and potential drug recipients to have ‘full informed consent’.
  13. So what guarantee does this new bill give us that the NZ “regulator” will not be equally corrupt, lobbied and captured by the pharmaceutical industry? At this point, absolutely none. This bill does not give us confidence that the new regulator will function any differently to Medsafe or TGA, in fact, the wording between the two is so oddly similar that you would think that the same people were writing it.
  14. Insert Clause: any corruption, collusion and conspiring with corporation by government employees and members of Parliament may prosecuted in their private and personal capacity. An individual/committee who withholds and/or ignores data that shows harm from a drug, GE therapy, medical device may prosecuted in their private and personal capacity.
    Pharmaceutical Industry ‘capture’
  15. The enormous sums of money that the pharmaceutical industry has at its disposal gives it unacceptable control over information and information flows, and over people in and around the industry. The Pharmaceutical industry sees the huge fines for its wrongdoing just the price it pays for doing business. Fines do not bother them, therefore liability has to be proportioned fair and square on to the individuals and companies involved. This article shows how in the USA, their ‘regulating body’ the Food & Drug Administration and the pharmaceutical industry have a revolving door which makes these individuals highly susceptible to corruption: https://www.science.org/content/article/fda-s-revolving-door-companies-often-hire-agency-staffers-who-managed-their-successful . There is other corruption as well, the “Big Pharma” paying for doctors to put their names to published reports to give them credibility. And Big Pharma hiding ‘negative’ data and only publishing results that show their products in a positive light. E.g. 1) https://slate.com/technology/2017/09/big-pharmas-ghostwriting-problem.html e.g.2) https://www.drugwatch.com/featured/clinical-trials-and-hidden-data/
  16. Insert Clause: Public servants switching between industry and government regulator should have to confirm no residual interest. Regulator staff must disclose any and all conflicts of interest and must not take payment of any sort, including gifts, from industry, or may be prosecuted for corruption in their private and personal capacity.
  17. The Australian regulator, the TGA showed itself to be corrupt in the harassment and ultimate destruction of Pan Pharmaceuticals, the largest supplement manufacturer in Australia and the fourth largest in the world. The TGA eventually paid Jim Selim $50 million for the loss of his company due to their discrimination and malicious attacks and eventually another $120 million was paid out to affected parties. It is believed that the constant stress from the TGA and abuse by the press caused his early death. (https://rense.com/general37/deathblow.htm).
  18. Where are the guarantees that the NZ regulator will not abuse its power and waste millions of dollars in a similar way? Hence clauses required to prevent abuse of power and corruption.
  19. Insert clause: There must be no facility for industry/corporations to influence the regulator and no ability to lobby the government to favour the pharmaceutical industry. Any one in government or regulation being influenced by corporations may be prosecuted for corruption.
  20. Insert clause: Cases of harassment (such as Pan Pharmaceuticals) should be enforced in the private and personal capacity of the individuals, not the company, so the blame is put squarely where it belongs.
  21. Insert Clause: Lying in data, or not disclosing all data for pharmaceutical, biological, gene and cell therapy, medical devices is grounds for open-ended financial penalties and imprisonment – in the private and personal capacity of the offending individual/s.
  22. Insert Clause: The amount Pharmaceutical companies are liable for when they withhold (negative) data or misrepresent sponsor data, should not be limited to $1,000,000 but should be set at an amount that is commensurate with the harm done and the criminal intent. Fines and punishment may be imposed on those men/women in their private and personal capacity. Punishment may include being excluded from participating in the New Zealand pharmacy/Pharmac system.
  23. Insert Clause: no company can make secret agreements, non-liability agreements, all agreements with Pharmaceutical companies must be open and transparent. The regulator may not enter into secret agreements.
  24. Insert Clause: All research data including negative findings must be included in assessments for market authorisation by the regulator.
    Biologics/GMOs/Gene Editing Technology
  25. Fast-tracking of biologic drugs designed to alter genetic functioning, has been shown to be flawed and has already resulted in novel technologies being approved without proof of safety or efficacy. This bill over-emphasizes control of known to be safe NHP and underplays the dangers of ‘emerging’ health technologies that are inherently risky. It mentions gene and cell therapy and gene modification as if in passing, and yet most scientists know the astonishing risks associated with these technologies. Example:
    https://abcnews.go.com/Technology/wireStory/death-crispr-gene-therapy-study-sparks-search-answers-92665447
    Gene Editing/GMOs/Novel Organisms
  26. The O&F Party is opposed to gene editing technology and GMO’s as the “risks outway the benefits” and changes at a genetic level often have unforeseen consequences downstream, by the time anyone realises you can’t undo the changes. This bill will remove our ability to have input into the GMO’s coming into New Zealand. It needs to be clear in the bill that there is a complete ban on research and imports of GMO, gene editing and CRISPR technology.
    Ref: https://www.stuff.co.nz/science/115517513/geneediting-risks-are-still-too-great-to-warrant-a-change-in-the-law
  27. Insert Clause: No GMO’s, no Crispr, no gene editing medical technology shall be ‘fast-tracked’, imported or produced in New Zealand.
    Market Authorisation:
  28. Does this mean that individuals will not be able to order supplements from overseas? This is 1) discriminatory especially for those who rely on certain remedies to maintain health or manage disease or access traditional remedies from their home country 2) those who access cheaper products, because they can’t afford to buy them at NZ prices. The TGA allows Australians to order for their personal use and we assume that this will be the case in New Zealand.
    Price increases:
  29. A further concern is that prices for NZ NHP will increase considerably to fulfil the regulator requirements, and then people will have to buy offshore which does not increase safety for locals and reduces income of local suppliers. I’m sure you’re getting many objections from local manufacturers who can see the writing on the wall for their small and medium sized business.
    Homeopathics as low dose NHP:
  30. Many homeopathic remedies contain human or animal tissue that patients require to recover their health, this bill looks like it will take some of those remedies away. Are we reading that correctly? If so, this is another reason to take natural health products out of this
    bill, because clearly the authors have no idea of the safety profile of these remedies.
    Natural Health Advice now “illegal”?
  31. The TPB will push patients and many health practitioners “underground”, patients taking ‘banned’ substances will not tell their GP’s and that will not make health care safer at all. Supplements from overseas will be smuggled in, relabelled as something else – I think we can all agree, this will not make “natural medicine” safer! Older natural health practitioners, who have decades of experience, will just retire rather than take the risk of prosecution for giving newly ‘illegal’ advice.
  32. “Health Shops” are a cheap source of advice on natural medicines for a large percentage of people who can’t afford to go to a health professional, and many of these shop owners have a wealth of knowledge and/or are trained practitioners, offering free advice for managing minor illnesses. This bill will scare these people into not helping their customers due to threats of fines and jail. And the low waged will lose that community resource meaning that including NHP’s in this bill discriminatory against the poor.
  33. The book “The Orthomolecular Treatment of Chronic Disease” details thousands of case studies and years of research into the effects of surprisingly high doses of vitamins and minerals. These practitioners have had outstanding success with many serious illnesses that have been either completely misdiagnosed and/or mismanaged by pharmaceutical medicine, little or no negative effects. These dosages would be considered extreme by most medical practitioners and yet they cured patients of life threatening and life diminishing illness. The clauses that enforce “the regulator decides the doses” and therefore ‘anything else is illegal and open to prosecution’ means that this type of treatment may be prohibited, and even telling patients to try high potency vitamins would leave practitioners open to prosecution. One particular chapter of interest in this book is treating drug addictions with extraordinary high doses of Vitamin C, with complete turnaround noted in those cases with no negative effects. Another study below shows high dose vit D successful in saving lives of those suffering Covid-19 infection.
    Medsafe as ‘regulator’ disproportionately discriminatory against NHP
  34. In the case of Arthrem, the company that carried out research to show that Artemisia Annua was effective in helping arthritis patients. The small number of side-effects, 14 complaints out of 250,000 bottles of Arthrem, a side effect rate of 0.0007 with full recovery in all cases, has now been banned in New Zealand. https://www.nbr.co.nz/promisia-shares-tumble-on-medsafe-warning-but-company-stands-by-product/
  35. Another case of Medsafe unfairly attacking natural substances is melatonin being made “a prescription only medicine, for patients over 55 years of age” when the negative effects are miniscule compared to pharmaceutical sleeping pills. Considering the higher death rate of those taking pharmaceutical sleeping pills, https://www.medicalnewstoday.com/articles/242211#1 you’d think that Medsafe would be supporting the use of a safer substance that is naturally produced by the body. Ssafety data sheet of one such medication with known side effects: https://medsafe.govt.nz/profs/Datasheet/i/Imovanetab.pdf
  36. The UK “regulator’ MHRA has persecuted the owner of an organisation, David Noakes, working on a natural therapy for treating cancer; (excerpt below) to show the lengths that corrupted “regulator” will go to to shut down effective natural health products, and there is nothing in this TPB that gives us confidence that it will be any different here. https://www.ukcolumn.org/article/gcmaf-and-persecution-david-noakes-lyn-thyer-immuno-biotech
  37. The USA “regulator” the FDA is even more horrific in its practise – with behaviour more fitting of an organised crime racket, than regulating foods and drugs. Ref: https://www.naturalnews.com/021791_the_FDA_medical_racket.html I have first hand knowledge as a naturopathic doctor friend of mine was persecuted by the FDA for teaching people how to use a “bioresonance machine” (a medical device?) and had to leave his home land to protect himself against their attacks.
  38. It is clear that Medsafe and MOH and this new regulator can not be trusted to make sensible decisions regarding natural substances vs pharmaceutical substances.
  39. It is outrageously unfair that Natural remedies that are already being sold in NZ that have been shown to be safe, will not be getting automatic market authorisation and pharmaceuticals that have not been shown to be safe at all, get automatic consent. The NZ iatrogenic reports are a testament to the risks associated with these medicines. This is already showing the Bill’s bias against the natural health industry. Another reason to take NHP out of this Bill, they will not be served well by this legislation.
  40. The latest information out of the USA shows complete lack of harm from supplementation by vitamins and minerals:
    http://www.orthomolecular.org/resources/omns/v19n06.shtml
  41. and this Australian data from 2011, and European 2012, shows that the risk of death from natural and complementary medicines is lower than being hit by lightening, and iatrogenic and drug reactions to be the main risk of death.
  42. You could argue that sicker people go to hospital and take more medication but they were probably hoping that modern medicine would help them, not kill them. In reality, most natural health professionals have to deal with the ‘fall out’ from the medical profession, where the patient survives the treatment but is still sick and in pain. Hospitals are used to patients “looping in and out” of their care, moving from acute to chronic back to acute again, with no long term improvement. In the USA, Iatrogenesis is between the third and first leading cause of death. In New Zealand the figures appear to be lower than that, but studies show only .3 of 1% of iatrogenic deaths are reported as such, so the figure bandied about is around 3000, but may be far higher.
    Proportionate risk and criminal prosecution:
  43. The Bill fails to recognise the considerable difference in risk between artificial and novel pharmaceutical drugs and natural products and that pharmaceutical drugs are a significant cause of harm and death, whereas food and herbs are not. The TPB talks about “proportionate risk’ and then does nothing to clarify what that risk is, and even goes so far as to state in Clause 313/2 “In a prosecution of a person for the offence, it is not necessary to prove that the conduct—(a) created or increased a significant risk to any specific individual; or (b) exposed any specific individual to a risk of death or serious injury or serious illness.”
  44. Which sounds as if it doesn’t matter whether or not anyone is harmed by ‘disobeying the regulations’ so, one could disobey this legislation, no body gets hurt and then still be prosecuted? Is that the case? That makes a criminal out of someone who has hurt no one, a criminal by legislation alone. You can see why we are afraid that our natural health practitioners may be harmed by this bill. And a number of health practitioners have said that they are not prepared to find out if they are disobeying the legislation or not, they would rather just quit practise. As in David Noakes case, no harm was done, and yet the MHRA prosecuted him nonetheless. He spent 15 months in an English jail and then faced another 2 years in a French jail! Obviously a very dangerous man….
  45. The state of health of our people right now is terrible, and anything that reduces our capacity to take care of our selves or access high quality information for natural remedies will make it worse and increase the need on the state. If the government wishes to encourage improvements in health and longevity, it would do well to launch a public education programme about natural health products and approaches but instead The TPB will more likely limit the use and increase the costs to maintain health.
    Transitional Provisions:
  46. Transitional provisions in the Bill provide that products that are currently consented under the Medicines Act 1981 will automatically receive a market authorisation under the Bill. However, products that do not require a consent under the Medicines Act 1981 (such as medical devices and natural health products) and that were lawfully being supplied in New Zealand before the Bill commences will have a transitional period of 2 to 5 years to seek a market authorisation.
  47. In other words, pharmaceuticals, known to cause harm will be ‘grandfathered in’ – natural therapeutics that have shown NO HARM
    will not. Another reason to take NHP’s out of the same legislation regulating pharmaceuticals. O&F Party policy is to scrutinize ALL medication, including previously authorised medication, to ensure safety and efficacy and compare them to natural remedies to find the most effective and the least harmful.
    NHPs Injection/Parenteral infusion
  48. Clause 71 “prohibits a person from administering an NHP by injection or parenteral infusion.”
    This removes the life-saving treatment protocol of IV vitamin C that many people rely on. The case of Alan Smith, Waikato hospital would rather have let him die (take off life support) than trial an IV Vit C drip. Alan and his family are convinced that forcing the hospital to give Alan the IV Vit C saved his life. Removing this safe and effective medicine will effectively be signing patients death warrants and this govt will be culpable. IV Vitamin therapy needs to be taken out of the TPB. Vitamin C is not the only injectable NHP – B12, ozone, glutathione etc have all been shown to be helpful especially in cases of vaccine injury.
    Current regulation of NHP:
  49. p:1 : “This regulatory arrangement does not provide an appropriate level of assurance that products imported and supplied in New Zealand are safe or made to the appropriate quality standards. It also does not adequately regulate health benefit claims made about natural health products.”
    However, it is very clear in the Dietary Supplement Regulations 1985 that there are clear statements regarding ‘therapeutic claims’ on NHP. (below)
    It is vital to ensure imported and local products are safe and uncontaminated, but that is covered under previous legislation and not required to be covered again in the TBP.
    Prohibited Product, serious concern in wording of Clause 33/2/b:
  50. “ Clause 33 Prohibited product
    (1) A therapeutic product is a prohibited product if the regulations say it is.
    (2) The Minister must not recommend that regulations be made about a product for
    subsection (1) unless satisfied on reasonable grounds that—
    (a) the product directly or indirectly exposes any individual to a risk of death, serious injury, or serious illness; and (b) the risk cannot be adequately managed by the exercise of the Regulator’s powers under this Act.”
    How does the regulator manage this risk of death, serious injury and serious illness? It appear this clause 33 reads, that if the risk is ‘managed’ then it’s OK for risk of death, serious injury etc? Who decides what the risk is? Medsafe and CARM obviously aren’t managing that risk now, so how does creating another layer of legislation change that? They are penalising low risk products and letting high risk products have a light handed regulation. How does that help the health of our people?
  51. Insert clause: As soon as any evidence of a product directly or indirectly exposing any individual to a risk of death, serious injury, or serious illness, the Minister must ensure that product is removed from the market or face penalty of negligence in their private and personal capacity.
    Concerns around Clause 211:
  52. “If unable to find a person in charge of the place, before leaving the place, the inspector must leave a written notice setting out all of the following:……….. However, an inspector is not required to comply with this section if— (a) it is not practicable to do so; or (b) the inspector is satisfied on reasonable grounds that doing so would defeat the
    purpose for which the function or power is being performed or exercised.
  53. We believe this gives the Regulator powers of warrantless entry which is inappropriate in most cases of this type of manufacturing activity and leaves us open to the FDA type behaviour of raiding clinicians practises and manufacturing plants. It treats practitioners and business people like criminals and is heavy handed and could be both dangerous, harmful to small and medium business and clinicians as well as publically humiliating. The regulator could easily over-step the mark and abuse its power, and leave itself open to prosecution as did the TGA with Pan Pharmaceuticals, which would cost ‘the Regulator’ i.e. Crown organisation huge sums of money. Individuals who make these decisions must act with honour and integrity to not damage the reputation of the regulatory body and know that they are liable in their private and personal capacity for wrongful harassment.
    Who is pushing this agenda?
  54. The natural health sector was not the organisation pushing for NHP to be regulated and legislated as proven by this submission to Select Committee from The New Zealand Medical Association. The NZMA makes it clear that they have an agenda to get rid of ‘pesky’ supplements, and they believe New Zealanders are utterly incompetent at deciding what type of health care they need. Their quote from a previous submission
    “is very disappointed that complementary and alternative medicine products are not being brought under the TPB and associated regulatory scheme. We have long been concerned about the array of natural health products on the market, with consumers making uninformed choices based on unproven health claims, with no assurance of product safety, quality or efficacy. Health literacy in New Zealanders is often insufficient for many people to know the important differences between approved medicines and complementary and alternative medicines. Furthermore, the currently permitted practice of co-locating complementary and alternative medicine products and evidence-based medicines in pharmacies, with both categories being sold by pharmacists, gives inappropriate legitimacy to natural health products.”
  55. It bothers us that one organisation feels that it can rouse up government to go against an entire sector of the community with out any proof of its claims. The NZMA does not speak for all medical practitioners. Australian trauma and general surgeon Dr Valerie Malka, former director of trauma services at Westmead Hospital, says, “while modern medicine is revolutionary when it comes to surgery, particularly in emergencies, for pretty much everything else, traditional, natural or alternative medicine is much more effective. Dr Malka says in particular, modern medicine is completely unable to treat or cure chronic illness. Rather than focusing on symptom control, natural medicines work on the body’s ability to heal the cause of the illness while modern medicine suppresses the body’s healing mechanism with drugs that attack the body’s natural defence mechanisms, disturbing the immune system.” “Natural therapies …… deserve a place in society and even in modern medicine.” The NZMA, MOH, NZ Parliament would do well to heed her words if they want kiwis to enjoy good health.
  56. This legislation is clearly designed to “harmonise” with off shore rules and regulations. The wording is so similar to many other countries that have incorporated WTO rules and standards. NZ has already ‘harmonised’ food standards according to MPI who is doing all it can to ensure NZ is ‘compliant’. From reading the TPB, it appears much of this wording is coming from overseas sources, which means it is not tailored to the New Zealand requirements. Some wording is around “harmonising with international standards’ to fulfil our international treaty obligations. We were continuously promised (aka ‘lied to’) when we battled against the TPPA (Trans-Pacific Partnership Agreement renamed “Comprehensive and Progressive Agreement for Trans-Pacific Partnership”) that “it would not prevent NZ from legislating for the common good” and yet here we are, complying with WTO requirements to the detriment of our people.
  57. The O&F Party policy believes that we should be governing our country for ourselves, not for organisations with an agenda to support industry and global control by multi-national corporations, giving them power in this land over the beneficial interests of the men, women and children of this land. Therefore
  58. This bill must be revised and amended: 1) removing NHP entirely, 2) fulfilling New Zealand’s GMO-free policy, 3) to guarantee the health and safety of our people, and 4) to ensure no foreign interference in our health system, 5) to guarantee complete transparency, and 6) to ensure no corruption in the regulating body.
    If there is no solution to the issues we’ve raised, the bill must be discarded.
  59. There are obviously far more concerns but we had to stop somewhere. Outdoors & Freedom Party feels that the whole bill is poor legislation, complicated, has not enough input from stakeholders, does not resolve the real problems we face with pharmaceuticals and natural remedies and is not fit for purpose. Thank you for your time for reading this report.
    Refs:
    https://www.anhinternational.org/2012/08/15/anh-exclusive-lightning-more-dangerous-than-herbs-or-vitamins/
    https://www.allnaturaladvantage.com.au/wp-content/uploads/2021/03/Societal-vs-Individual-Risk-of-Death-in-Australia-2011.pdf
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Tracy Livingston

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