The NHAA gratefully request consideration to the proposed labelling requirements for amygdalin and hydrocyanic acid as there remains insufficient evidence supporting toxicity or adverse events at a maximum daily dose < 5mg amygdalin or equivalent dose of hydrocyanic acid (HCN) < 0.3mg 4. Potential risks for vulnerable groups, for example children or pregnant women, and long-term use/intentional misuse can also be mitigated by additional labelling requirements. The NHAA appeals for the Delegate to re-consider previous submissions and the benefits and use of Cherry Bark as an extemporaneously compounded therapy by Naturopaths and Herbalists nationwide. Once again, the NHAA appreciates the opportunity to respond to the interim decision to amend (or not amend) the current Poisons Standard - 5 October 2023. We acknowledge that concerns have been raised with the current scheduling of amygdalin, and thus an inability to utilize herbs including Wild Cherry Bark. We remain undeterred and assured that the current amygdalin scheduling presents a misguided and unconvincing action supported by insufficient evidence which does not duly defend that the health risks far outweigh the documented risks.
