Commission E

The German Commission E Monographs are a therapeutic guide to herbal medicine. There is an English translation^[1] by the American Botanical Council, with 380 monographs evaluating the safety and efficacy of herbs for licensed medical prescribing in Germany. The commission itself was formed in 1978, and no longer exists.

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The Commission E Monographs were imported into the United States with considerable fanfare in 1998 by The American Botanical Council. They were unequivocally endorsed in a forward by the late Varro Tyler, a well-known professor of pharmacognosy at Purdue University. Tyler states in his forward that "...safety data were reviewed by the Commissioners according to a "doctrine of absolute proof" and efficacy according to a "doctrine of reasonable certainty."

As a result of this heavy promotion, Commission E is frequently confused with books on alternative medicine in the USA; but in fact, it is an administrative law book for German national regulation of herbs. As such, the book has attracted criticism for having a covert government agenda to assist commerce that is incompatible with science, medicine, and traditional, as well as experiential herbalist, systems of healing.

Criticism

The best known critic of Commission E is Jonathan Treasure, MNIMH, a UK licensed medical herbalist^[2] and author of numerous herbalism monographs[2]

Treasure's lengthy review^[3] (31K) offers evidence in detail after detail that the book is not a work of science, medicine, or vitalist herbalism. Rather it is a book of German legal-medical regulations, since "In Germany, only those herbs with Commission E Approved status are (or will eventually become) legally available."

Quotations from Making Sense of Commission E

Abstract: "A review of the ABC's English translation of The German Commission E Monographs. The essay critically examines the monographs and the publisher's extensive additions to the volume. The author disputes the publishers claims of scientific accuracy and contemporary therapeutic relevance of the Commission E Monographs. The reviewer concludes that healthcare professionals in North America needing accurate information regarding safety, efficacy and administration of herbal medicines will not find this book to be an appropriate or useful resource, and that it may in fact be misleading, contrary to the claims of the publisher."

Lack of references: "The brevity of the monographs is compounded by the complete absence of any citations or references to the sources that formed the basis of the Commissioners deliberations on the herbs. These sources are apparently only accessible when legal cases are brought under the German Medicines Act. The failure to include verifiable scientific primary sources necessarily places the entire Commission E Monograph corpus irredeemably outside the most elementary accepted standards of academic requirements for rigorous scientific publications. The uninformed reader is thus obliged to accept as an article of faith the veracity of the information in the text." [Emphasis is in current source.]

Lack of scientific authority: "...former Commission members themselves might consider the publisher's claims about this edition to be inappropriate. Most revealing in this connection are the candid personal communications from Professor Heinz Schilcher quoted in the introduction. Prof. Schilcher was the Vice-president of the Commission and in response to a query from the editors regarding the apparent lack of scientific substantiation for the Commissions' claimed risks of Sarsaparilla use, Schilcher replied that the cautions made by the Commission were actually based on "a theoretical standpoint and we have in Germany little experience with Sarsaparilla". This extraordinary admission leaves one wondering how many other conclusions the Commission made based on theoretical speculation as a surrogate for the "doctrine of absolute certainty". " [Emphasis is found in web archive version of this document. [3]]

Lack of cross-referenced dosages: "Dosage is a crucial matter in administering herbal medicines safely and effectively. The Approved monographs contain dosage information, which in line with German practice, is mostly given in terms of dried herb for aqueous infusions or decoctions - generally in the range of 2-10 gms daily. For certain herbs with more potent drug-like constituents (such as Ephedra) maximum daily doses are given appropriately in terms of mg calculated "as mg active constituent", such as "total ephedrine alkaloid". The problem for potential users of the Commission E in the US is that hydroethanolic extracts, (usually tinctures, or solid preparations derived from such extracts) often derived from fresh rather than dried herb material, are the form of herbal remedies commonly used in clinical practice - not teas. Unfortunately conversion between dried herb infusion and fresh plant tincture data is not straightforward. Equally, the trend in North America toward use of standardized herbal material is not easily related to the infusion based dose data in the monographs. Finally where figures are occasionally given for tinctures and fluid extracts, they do not always correlate. For example the single dose for valerian tincture (herb/menstruum ratio not stated, but usually 1:5 in Europe) is given as 1-3ml, but the single dose for a fluid extract (Fluid extracts are 1:1 and hence more around 5 times more concentrated) is given 2-3ml whereas it should obviously be less rather than more. "

– Jonathan Treasure © 1999-2000, Making Sense of Commission E^[4]

References

1. ^ The Complete German Commission E Monographs, Therapeutic Guide to Herbal Medicines, 1st ed. 1998, Integrative Medicine Communications, pub; Bk&CD-Rom edition, 1999.
2. ^ Jonathan Treasure - Author's biography by Herbal Educational Services.
3. ^ Making Sense of Commission E, review by Jonathan Treasure, 1999-2000.
4. ^ Fair use rationale: Mr. Treasure's strongly critical and detailed reviews of Commission E are difficult to paraphrase with legal accuracy, and the technical details of Lack of cross-referenced dosages are risky to paraphrase as dose safety and efficacy information. These long quotations are expected to be a fair use of Jonathan Treasure's copyright, especially considering that the author's website offers a free download of this review in printable PDF format.[1]