Keep traditional acupuncture alife in Ontario, Canada!

An open letter to the Ontario Minister of Health and Long Term Care Deb Matthews

22nd January, 2009

The Hon. Deb Matthews, MPP
Ontario Minister of Health and Long Term Care

Dear Honorable Deb Matthews, Ontario Minister of Health and Long Term Care,

It has been three years since The Traditional Chinese Medicine Act has passed legislature. If, during the stages of implementation, acupuncture is to be separated from Traditional Chinese Medicine (TCM), it will cause misdirection of the public from seeking professional practitioners who practice TCM. This would violate the principles of protecting public safety as outlined in the Traditional Chinese Medicine Act, and may critically harm the interest and well-being of the public.

As such, a few issues must be brought to attention:

1. To respect and consider the regularity and integrity of the Science of Acupuncture and Moxibustion in protecting the benefit and interest of the public:

In order to enact regulations in any field of health profession, it is in the best interest of all involved to do so in accordance with the regularity and integrity of the proposed subject. "The Science of Acupuncture and Moxibustion is a science guided by the theory of Traditional Chinese Medicine in the research of meridians and collaterals, acupoints, and the manipulation of needle, with discussion of the application of acupuncture and moxibustion serving as prevention of illnesses and diseases, it is an important component of Traditional Chinese Medicine" (Science of Acupuncture and Moxibustion, Chinese National Advanced Standard curriculum for Chinese Traditional Medicine Universities and Colleges, 2006).

It is clearly described in the statement above that acupuncture serves as an important component of TCM and it cannot be separated from the integrity the system. The clinical practice of acupuncture and moxibustion involves the application of Four Elements and Eight Principles of TCM diagnostic theory (tongue diagnosis, pulse diagnosis), selecting acupoints according to the meridians and collaterals based on TCM theory, and the use of particular manipulations of reinforcement or reduction techniques during an acupuncture treatment. Only under these standards is it referred to as the professional and scientific application of acupuncture, TCM acupuncture and moxibustion. Public interest will only be protected if the service is delivered under the professional standards mentioned above.

2. Without proper guidance in TCM theory in needling (anatomical acupuncture), it cannot be assumed that the responsibility to protect the maximum interest of the public is maintained:

The root of acupuncture and moxibustion arises from a sound knowledge of TCM. Only under the guidance of TCM philosophy and theory can diseases, such as those related to internal medicine, surgery, gynecology, pediatrics, bone-setting, and various others, be treated professionally through TCM.

Needling procedures performed with a lack of knowledge of TCM theories and without the guidance of anatomical acupuncture, may be used as an adjunctive therapy with other health professional practices, such as those in pain management. However such practices cannot assume that the quality of a professional treatment can be provided in accordance to TCM standards. Therefore, quality treatment of the above mentioned diseases in a clinical setting cannot be assured and therefore it cannot serve to protect the maximum interest and well-being of the public.

Clinical acupuncture under the guidance and discipline of TCM theory are classified into three major principles that must be followed when choosing acupoints: the proximate acupoint around the local region, the remote acupoint that is along the same meridian, and the special acupoint with extra functions. To illustrate, prolapsed organs, such as the stomach, uterus, or the rectum, would be diagnosed as flaccidity of "middle jiao qi" based on TCM theories. The acupuncture treatment principle for this diagnosis would be to raise yang (qi) in order to lift the flaccidity. Rather then choosing proximal points, practitioners with proper TCM guidance are able to choose remote acupoints along the same meridians such as Baihui (DU-20), Zusanli (ST-36) and other remote points. Without proper training in TCM theories, a practitioner may be limited to only choosing proximal points, which is considered to be an entry level skill for an acupuncture treatment. This level of skill in acupuncture cannot be considered as a professional acupuncture treatment and therefore cannot ensure maximum benefit to the well-being of the patient and the public.

Professional acupuncture, in TCM theory, also emphasizes the practitioner's needle manipulation techniques during a clinical treatment. For example, in treating irregular menstruation or abnormal uterine bleeding, the treatment requires needling on Guanyaun (RN-4) and to radiate needle sensation towards the genital region. Based on the patient's condition, professionals could either apply the "ENRICHING BY FIRE" or "BURNING MOUNTAIN FIRE" needle manipulation technique to treat cold and deficient syndrome. Or apply the "DRENCHING WITH WATER" or "THROUGH HEAVENLY COOL" technique to treat excess and heat syndrome patients. Without the proper fundamental training in anatomical acupuncture manipulation techniques, merely inserting needles under the derma or using electrical pulses through the needles to cause vibration would be insufficient. The techniques mentioned above would not be perform by a practitioner who is inferior in skills and techniques compared to trained TCM professionals who can perform such techniques. The patient would not be able to receive the maximum benefits of acupuncture when practitioners are equipped with only entry level knowledge of needle manipulation techniques.

3. Abiding by the TCM Act 2006 and implementing TCM regulation simultaneously in order to protect the interest of public:

Since the Ontario Parliament was introduced and passed Bill 50 in 2006, The Traditional Chinese Medicine Act 2006 (The TCM Act), it is the obligation of all parties to abide by the law and to respect the law. It is also the obligation of the other eight regulated health professions, in relation to the TCM Act, including the Ministry of Health and Long Term Care and HPRAC, to abide by this law. Based on that agreement, mutual communication and cooperation should be initiated. Instead it is not, and the opposite is being done. By separating acupuncture from the TCM philosophical and scientific system, this will cause confusion in the differentiation of Registered Acupuncturist and Non-Registered Acupuncture Practitioner (Anatomical Acupuncture). As a result, this will mislead the public when seeking professional acupuncture practitioners.

4. Make reference to the requirements of World Health Organization (WHO) to upgrade the acupuncture knowledge and technique level of other health professionals in order to become Registered Acupuncturist:

World Federation of Acupuncture & Moxibustion Societies, which is affiliated with the non-governmental organization WHO, have instructive documents indicating that western medicine professionals who possess 250 hours of study in the knowledge of acupuncture and moxibustion can provide needling services as an adjunctive therapy to their main scope of practice. However, continuing education requiring 1750 hours of advanced study is required in order to become a qualified professional acupuncturist. As a comparative example, everyone can learn how to cook in a matter of time. However, individuals must go through rigorous training in order to be given recognition as a chef. Likewise, professionals who want to be addressed as professional acupuncturists should be required to complete the necessary training and education that would warrant such a title.

Recommendations have been made in reference to the requirements of WHO in support of providing a specially designed educational curriculum for chiropractors and seven other professionals who are practicing acupuncture. This would serve to enhance the level of their needling practice in order to become registered acupuncturist. By working together to jointly promote the academic advancement of acupuncture and moxibustion, this will protect and benefit the interest of all Ontarians.

Bin Jiang Wu, Ph. D / Prof.
President - Ontario College of Traditional Chinese Medicine
Professor - Heilonjiang University of Chinese Medicine / Henan University of TCM
President and Founder - Wu's Head Massage International Association
Executive Member - The World Federation of Acupuncture & Moxibustion Societies (WFAS) (Non-Governmental Organization in Relation with WHO)
Vice President - The University Cooperation Working Committee of WFAS
Vice President - Educational Instruction Committee of World Federation of TCM Societies
Vice President - International Association of Acupuncture & Moxibustion Manipulation Technique
Board of Director - Chinese Medicine and Acupuncture Association of Canada
Judging Expert - NSFC (National Natural Science Foundation of China) Department of Life Sciences, Division of Traditional Chinese Medicine

Cc: Prof. Cedric Cheung, President of Transitional Council
Ms. Emily Cheung, Registrar of Transitional Council
College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario
163 Queen Street East, 4th Floor, Toronto ON M5A 1S1
Tel: 416-862-4790
Fax: 416-874-4078
Email: info@ctcmpao.on.ca



Posted on: January 26th 2010