Position Papers on Practitioner Laws Supported by NHFC

NHFA 2007, Formal Comments in response to the FDA Draft Guidance entitled: “Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration” Docket ID. 2006d-0480, Department of Health and Human Services, Food and Drug Administration, December 2006. 

Registration:  Impact of Regulation on Fundamental Right of Privacy to Make Health Care Choices Aug 2004  

Rationale for National Health Freedom Action (NHFA) position on registration NHFC.  Oct 2004

Position on Regulation of Specific Vocations and Professions Supported by NHFC

Miller, D 2016.  Homeopathy and NHFC, The American Homeopath.

Why NHFA Opposes Licensure of Herbalists in Hawaii, 2014

Why NHFA Opposes Licensure of Homeopaths in Arizona, 2011 

Miller, D, 2008.  Collaboration in the Health Freedom Movement: A Source of Power and Healing, Alternative and Complementary Therapies.

Miller, D, 2008.  Naturopathic Practitioners Work to Protect Rights to Practice, Alternative and Complementary Therapies.

Miller, D, 2007.  Expanding Access to Holistic Health Care, Alternative and Complementary Therapies.

Miller, D. 2006.  Homeopathy in the Context of Government and Laws, Power Point Presented at the Joint Homeopathic Conference, San Jose, April 2006.

Miller, D, 2006. The Ins and Outs, Pros and Cons of Non-licensed Practice: Report and Commentary on the Health Freedom Movement, Alternative and Complementary Therapies.

Barrette, J, 2003.  The Alternative Medical Practice Act: Does It Adequately Protect the Right of Physicians to Use Complementary and Alternative Medicine?  St. Johns – Law Review, Vol. 77, Winter 2003, Number 1.

Palmer, D, 2002.  It’s Time for Freedom of Access, Massage Magazine Editorial, Issue 95. 

Gilruth, C, and Miller, D, 2002:  Interview with Diane Miller on Homeopathy and Right to Practice of Complementary and Alternative Health Care.  NASH Newsletter, used with permission. 

Miller, D, 2002.  Reiki and Religious Freedom: Legal Practice Issues for Reiki. (Used with permission from William Lee Rand)

Homeopathy: 

• NHFA to FDA, March 2018, Formal Comments in response to the FDA proposed Draft Guidance entitled: Drug Products Labeled as Homeopathic: Guidance for FDA Staff and Industry, Docket ID. FDA-2017-D-6580, Food and Drug Administration – Center for Drug Evaluation and Research (CDER) in cooperation with the Center for Biologics Evaluation and Research (CBER), December 2017. 

Communicable Disease: 

• NHFA to CDC, September, 2016, Formal Request for the Withdrawal of the CDC’s Notice of Proposed Rulemaking entitled: Control of Communicable Disease, Docket No. CDC-2016-0068, Department of Health and Human Services, Center for Disease Control and Prevention, August 2016. 

Vaccines:

• NHFA to MDH Rulemaking Admin Court, June 27, 2013:  NHFA Formal Comments to the Minnesota Department of Health Rulemaking Proceedings on MDH’s proposed amendments to rules governing child care and school immunizations entitled: “Proposed Permanent Rules Relating to Immunization of School Age Children and Children in Child Care and School-Based Early Childhood Programs” 

Vaccines: 

• NHFA to MDH Rulemaking Admin Court, July 24, 2013:  NHFA Formal Rebuttal Comments on the MDH July 17, 2013 Response Letter to Testimony and Comments Received About the Department’s Proposed Amendments to Rules Governing Child Care and School Immunizations Entitled: “Proposed Permanent Rules Relating to Immunization of School Age Children and Children in Child Care and School-Based Early Childhood Programs” 

New Dietary Ingredients: 

• NHFA November 2011, Formal Comments in response to the FDA proposed Draft Guidance: “Draft Guidance for Industry; Dietary Supplements: New Dietary Ingredient Notifications and Related Issues; Availability”, Docket No. FDA–2011–D–0376 20, July 2011.

Creating New Laws: 

• Miller, D, 2009. Creating New Health Care Laws and Regulations, Alternative and Complementary Therapies.

Choice of Treatments: 

• Miller, D, 2008.  Protecting the Right to Choose CAM over Conventional Medicine: The Case of Daniel, Colleen, and Anthony Hauser, Alternative and Complementary Therapies.

International Products:

• Miller, D, 2008. Impact of International Product Regulations on Consumer Access to, and the Manufacturing of, Dietary Supplements: The Need for Health Freedom Advocacy, Alternative and Complementary Therapies.

Dietary Supplement Product Labeling:

• Miller, D, 2007.  Freedom of Speech and Truthful Information in Health Care, Alternative and Complementary Therapies.

CAM and the FDA:

• NHFA to FDA, 2007, Formal Comments in response to the FDA proposed Draft Guidance entitled: “Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration” Docket ID. 2006d-0480, Department of Health and Human Services, Food and Drug Administration, December 2006

Codex:

• Miller, D, 2004.  Decoding the Codex Threat: Are Limits on Access to Dietary Supplements Looming?, Alternative and Complementary Therapies.

Miller, D, 2008. Impact of International Product Regulations on Consumer Access to, and the Manufacturing of, Dietary Supplements: The Need for Health Freedom Advocacy, Alternative and Complementary Therapies.

NHFC’s Response after Codex 2005 Passage of the Vitamin and Mineral Guidelines. Power Point

“Codex: Do We Need to Worry?  

Joint Response of Friends of Freedom International and National Health Freedom Action: Codex: Myth and Facts – Health Freedom Facts, March 23, 2005. 

CODEX BASICS– A Health Freedom Infringement: Presentation by Diane Miller JD, Los Angeles Health Freedom Expo 2005

Miller, D, 2004.  Decoding the Codex Threat: Are Limits on Access to Dietary Supplements Looming?,  Alternative and Complementary Therapies.

Understanding Codex Alimentarius and Its Impact on Health Freedom: A Summary of a Full Text White Paper  

Understanding Codex Alimentarius and Its Impact on Health Freedom: Full Text Paper by Diane Miller JD, (With grateful thanks for comments from Suzanne Harris JD and David Hinde, Solicitor) 

Websites with additional Codex Health Freedom Information

National Health Federation

American Holistic Health Association

Codex Alimentarius official website