As Sept. 1 deadline for comments nears, practitioners debate
Digital art by Tamara Rees. Sources: Adobe Stock/kubko; Adobe Stock/aradaphotography; Depositphotos/macrovector
Botanical medicine, the use of plants or plant-based extracts rather than synthetic drugs to treat medical conditions, is at the center of a debate spurred by a proposal to recognize the field as a formal veterinary specialty.
Last October, the American College of Veterinary Botanical Medicine (ACVBM) petitioned the American Board of Veterinary Specialties (ABVS) for official recognition as a veterinary specialty organization.
The response to a short article by the VIN News Service on the proposal highlights a divide at the heart of the practice of medicine.
The topic drew nearly 300 comments over five weeks on a message board of the Veterinary Information Network, an online community for the profession. The comments evolved into a heated debate on the science supporting botanical (or herbal) medicine, the definition of scientific validity, and how other medical treatments and diagnoses are validated.
The conversation also ranged into the broader field known as complementary and alternative medicine (CAM), which encompasses modalities such as acupuncture, chiropractic and homeopathy. As practitioners and methods in CAM often overlap — for instance, herbalists using diagnostic methods taught in traditional Chinese medicine — discussions about one discipline often spread to the others.
Formal recognition of the botanical medicine group as a veterinary specialty organization would give plant-based medical practice equal status with disciplines such as surgery, ophthalmology and cardiology.
Proponents and opponents of recognition agree that specialty status would help general practitioners and animal owners identify trustworthy experts in the subject. Beyond that, those on both sides of the issue part ways. Here are highlights of the debate.
The scientific basis
Dr. Brennan McKenzie, a veterinarian in Los Altos, California, who has served as president of the Evidence-Based Veterinary Medicine Association, is skeptical that the scientific evidence provided in the ACVBM petition is of sufficient caliber to establish herbal medicine as a medical specialty. As such, he believes the petition for formal recognition to be premature.
Dr. Narda Robinson, who formerly taught courses in botanical medicine at the Colorado State University School of Veterinary Medicine, and is president of Curacore Integrative Medicine and Education Center, concurs. “It’s too early for herbal medicine across the board because we don’t have enough science on the safety and effectiveness of these products," Robinson said. "We don’t even have evidence-informed guidelines on proper dosing.”
Dr. Barbara Fougere, president-elect of the ACVBM, maintains that formal recognition of herbal medicine as a veterinary specialty would, paradoxically, address such concerns by speeding scientific progress in the discipline.
“When every other veterinary specialty has been recognized, amazing advances in veterinary medicine and animal care have ensued," said Fougere, who practices in Australia and has been active with the U.S.-based botanical organization since its origins in 2003. "We only have to look at the recent [rehabilitation] specialty to see what a difference these veterinarians are having on the quality of life and speed to recovery of patients. It is that collective recognition, improved training, publication and clinical knowledge base that speeds development of the field. Cross referral and cross fertilization [have] been the key to these advances.”
Dr. Susan Wynn, a member of the ACVBM organizing committee and a Georgia-based specialist in veterinary nutrition, maintains that other recently approved veterinary specialties, such as behavior and shelter medicine, “did not enjoy nearly the scientific basis from high quality trials in their populations of interest that herbal medicine does.”
When clients go it alone
One of the arguments for a dedicated specialty in herbal medicine is a perceived increase in public interest and need.
Pet owners and organic farmers, the latter of whom are barred from using many mainstream pharmaceuticals, have an increasing tendency to go it alone on alternative treatments for their pets. Wynn and Fougere assert that official recognition of a specialty college would place control and expertise of herbal remedies in the hands of veterinarians.
“The assurance that scientifically trained veterinarians can make knowledgable recommendations for herbal treatments will be good for the animals," Wynn said, "keeping their care in the hands of veterinarians, as opposed to the many lay herbalists with no veterinary training at all.”
She asks, “Is herbal medicine more or less deserving of veterinary study because pet owners and livestock producers are using herbs commonly at their own discretion and direction? That situation has certainly not led to more scientific study of herbs. Would establishment of a cadre of scientifically trained veterinarians be better at promoting research?”
Fougere argues that development of veterinary expertise in herbal medicine would mitigate the challenges of “human health and environmental concerns about chemical and drug residues in livestock; the consumer demand for organic produce; diseases refractory to antibiotics or anthelmintics because of resistance.”
She said the tendency of the public to seek botanical remedies without veterinary assistance “is problematic on many fronts: more appropriate treatment may be delayed, inappropriate treatment may be given in the absence of a practitioner-patient relationship and animal welfare may suffer. Clients are not impressed when their veterinarian doesn’t know about an herb they wish to discuss, and they become motivated to treat their own animal.”
In the organic-farming realm, the use of botanicals is particularly complex, owing in part to multiple and not necessarily consistent rules by the U.S. Food and Drug Administration and U.S. Department of Agriculture. Treatment of food-producing animals in the United States is heavily regulated to avoid adulterating the human food supply. Pharmaceuticals used in food animals must have documented “withdrawal times” — the period between the last use of the drug and when the animal's meat, milk, or eggs enters the food supply.
Regarding botanical medications and withdrawal times, Fougere acknowledges the situation “is a little bit gray. FDA guidelines do not allow for the use of unapproved drugs, regardless of whether or not the substance is a botanical or food supplement, for treatment of food-producing animals even under the supervision of a veterinarian. So no, there are no specific withholding periods [established].”
Then there is the USDA. Fougere recounted: "The USDA National Organic Program (NOP) prohibits most synthetic substances from use in organic livestock production. The advice given is to check with the certifier when evaluating a product for use in animals. The basic rule of thumb is that the NOP prohibits all synthetics unless specifically allowed, and allows all natural substances unless specifically prohibited.”
And then, there are studies (one published in the Journal of Dairy Science in 2004, another presented at the American Agricultural Economics Association annual meeting in 2007) indicating that “organic farmers in the United States report less dependence on veterinarians, more dependence on the opinion of other organic farmers, and fewer regularly scheduled veterinary services as compared with conventional farmers," she said.
In summary, Fougere said, “It appears there is a mismatch between FDA, USDA and what producers are doing. This is clearly an area where veterinarians should be and can be involved in animal health and welfare.”
Herbal product origins, safety
Another question is the safety and origins of herbal products.
Robinson pointed to an FDA import alert dated Aug. 1 on unapproved new animal drugs that calls out a line of popular herbal products, among other drugs.
The herbal products are produced by Dr. Xie’s Jing Tang Herbal, which is affiliated with a member of the ACVBM organizing committee, Dr. Huisheng Xie.
The FDA alert serves as guidance to agency field staff that they may detain without physical examination imported shipments of finished new animal drugs from the identified manufacturers. The alert does not prohibit use of the listed products.
Robinson is concerned about how continued use of the products in question might impact veterinary schools, pharmacies, patients and practitioners. She wondered, “What if this was a pet food ... cited in an FDA import alert? Would it be prudent practice for veterinarians to continue to sell and recommend it?”
McKenzie, who chronicles his investigations into evidence-based medicine on a blog called SkeptVet, worries that according specialty status to botanical medicine could lead practitioners and clients alike to believe that herbal remedies are subject to the same scrutiny as conventional drugs, when that may not be the case.
“Veterinarians and animal owners who trust the system of specialty designation will incorrectly believe that the practices of board-certified herbalists have been scientifically tested and proven safe and effective when, in reality, the vast majority of them have not," he said.
Fougere does not view proprietary herbal formulations as a mainstay or a responsibility of the ACVBM, saying they are “not expected to be part of the training for botanical diplomates.” She compared the role of the group to that of internal medicine specialists, whose training “does not usually involve trade names, but the drug itself.” She said standardization of herbal formulations is not on the ACVBM agenda “in the same way [that] drug quality is not on the agenda of internal medicine diplomates.” (The American College of Veterinary Internal Medicine has written a letter opposing elevating botanical medicine to a formal specialty.)
Wynn, by contrast, indicated interest in the college potentially having a role in setting standards for herbal preparations. In her view, problems with purity, potency, safety and efficacy “are not going to be solved by veterinarians with only a passing knowledge of herbal medicine, or clinical pharmacologists who haven't accomplished in-depth study of herb chemistry. Only specialty recognition would help to propel those initiatives,” she said.
McKenzie would like to see herbal medicines vetted using a different approach. He suggests this: “Veterinary patients and clients, and the profession, would be better served by establishing a systematic effort to evaluate claims and uses of herbal remedies that employs the expertise of pharmacologists, toxicologists, nutritionists, and epidemiologists to test the claims of herbalists. If these claims prove true, then the practices can be appropriately integrated into veterinary medicine and herbalists may have a legitimate claim to the expert status they are now seeking.”
A gateway for other, less proven modalities?
Robinson's chief objection to making botanical medicine a veterinary specialty is what she perceives as undue influence by practitioners of traditional Chinese veterinary medicine (TCVM), a modality she worries could erode the scientific foundation of veterinary medicine.
“In my mind, it is a serious undermining influence that has been allowed to spread in an unchecked fashion," she argued. "[TCVM] is an imported and outdated ideology, non-scientific, and based in metaphors. It’s how ancient Chinese doctors described physiology. Their explanations might have sufficed as a primitive, folkloric methodology, but centuries later, we can and need to do better.”
Fougere rejects the idea that a botanical medicine specialty would serve to enable other, related, modalities to become mainstream. “The ACVBM is no more a gateway to other CAM modalities than the rehabilitation speciality is to Reiki, Bowen therapy, kinesiology or other body-work modalities,” she said.
Wynn calls the claim that herbal medicine lacks scientific backing “a blatant display of bias against any modality that has been aligned with alternative medicine at any time in the past.”
She added: “Each modality that has been considered 'alternative' must stand on its own merits.”
Regarding what she called the “mysticism” surrounding TCVM, Wynn takes an historian’s approach to extracting the science from the legend. “I believe that the study of TCVM, Ayurveda, historical Greek medicine, Native American medicine, etc., should be studied from the ethnobotanical/ethnomedical/ethnoveterinary perspective," she said. "Ethnomedicine is an established science-based path for studying phytopharmacognosy. While ethnomedicinal studies must observe and document the cultural beliefs that underlie the traditional medical practices, the ultimate purpose is not to promote those beliefs, but to liberate some of the medical practices if they can be validated scientifically.”
McKenzie countered that delving into the historical uses of plants dilutes scientific progress with folklore. “If a purely science-based approach is to be taken towards the great potential of plants to provide medicinal compounds, it should begin with established scientific specialties that are not tainted by entrenched folk beliefs and methods,” he said.
“Clinical pharmacology, toxicology, and nutrition are already recognized scientific specialties that can lead such efforts,” he continued. “The arguments made by the ACVBM for why it should be the focus of herbal medicine research and practice rather than these existing specialties ... rely almost entirely of the assumption that their specialized knowledge and expertise, derived from folk medicine traditions and beliefs, is superior to the scientific approach that these other specialty colleges espouse.”
He called ethnomedical knowledge “code for a familiarity with the folk beliefs regarding plant remedies, and it obscures the fact that most of these beliefs remain untested and that many are incompatible with established scientific understandings of physiology and pharmacology.”
Robinson said that extrapolating from traditional human herbal remedies to animals further muddies the waters.
Why not align with an existing specialty?
Some wonder why botanical medicine can't be recognized as a subset of an existing specialty such as pharmacology rather than its own specialty.
Explaining why the college seeks specialty recognition in its own right, Wynn said: “The main reason was the sheer breadth of information one must learn to be an expert herbalist. You need to be familiar with the principles of ethnomedical research and with hundreds, if not thousands, of plants and parts used.”
She also spoke of “a serious philosophical divide” between herbal medicine practitioners and clinical pharmacologists.
In clinical pharmacology, she said, the standard approach is to isolate a particular active ingredient, purify it and create a drug from the known ingredient, with a known concentration.
In herbal medicine, by comparison, Wynn said, “The complexity of the herbs is a strength, with the dozens of active components having multiple activities on a patient a potential advantage.”
McKenzie counters that the science should come before the specialty, “with consistent, identifiable ingredients for specific indications."
He said, “There is no reason to treat herbal remedies differently from other medicines in how they are tested and employed."
VIN News Service commentaries are opinion pieces presenting insights, personal experiences and/or perspectives on topical issues by members of the veterinary community. To submit a commentary for consideration, email firstname.lastname@example.org.