What well-documented evidence of harm does AMTA have that state regulation is needed to protect the public from harm?

Our search for harm, that led us to AMTA. did not provide information about harm.

Serious harm mistakenly attributed to massage.

Allegations of serious harm for which there is no evidence at all.

An invitation.

Unlike pre-Socratic Greeks, we do not believe the oracles, in the temples of so-called coalitions, who tell us that the gods want us to have state regulation. Instead. like Socrates, we use reason and logic to decide for ourselves whether state regulation is right or wrong, and why.

Like Socrates, we believe, "The unexamined life is not worth living. But the examined life alone does not bring fulfillment. Those satisfactions come from commitment and connection." Socrates

ABSTRACT

This report provides well-documented   evidence that message is safe, and that state regulation is  NOT needed to protect the public from harm by allegedly inadequately trained, unregulated massage therapists..

If there is enough well-documented serious harm (caused by allegedly inadequately trained massage therapists) to justify  state regulation, that harm is the best kept secret in the history of massage.

Knowledge  is of two kinds.  We know a subject ourselves, or we know where to find information on it. -  Samuel Johnson

TITLE  PROTECTION ACTS

Title protection acts are evidence of safety par excellence. They are well-documented evidence because they exist in precise detail. They are incontrovertible evidence because what they do is so clearly spelled out. They are legal evidence because they are state laws.

Why title protection acts tell

Title protection acts permit anybody, regardless of training, to do massage. However, those who have not complied with the act's regulatory requirements may not use restricted words such as massage, and restricted titles such as Massage Therapist. How can anybody seriously claim that state regulation is needed to protect the public from harm when title protection acts permit anybody, regardless of training, to do massage as long as they do not use restricted words.

If massage were harmful, there would be no title protection acts because these acts permit anybody to do massage, regardless of training. Title acts are therefore conclusive evidence that massage therapists, regardless of training, pose no significant risk of harm to the public.

We believe that other purpose that state regulation serves is to establish monopoly control.

From title protection to

"Licensing arrangements ...can be characterized less as methods for protecting the public and for providing external social control in the interest of the consumer than as a means for protecting the occupation's market dominance. Indeed, licensing has the unique quality of making a violation of the professional monopoly a punishable crime." Haug

"It seems that proponents of licensing are hopeful that a state license would mean more money, status, and power." Jerry A. Green, Attorney for the California Coalition on Somatic Practices.

 "I think the move toward licensure is regrettable. I believe licensing creates state-sanctioned monopolies ... with the explicit goal of "protecting the public, but with the real effect of protecting those who hold the monopolies respective entitlements, reducing information to the public, and restricting competition." Don Schwartz. Director, Trager Institute

"Professional regulation is not about serving society. It is about power, control, and money for a self-selected group of providers trying to be part of a health-care system rife with corruption, greed, and life-damaging and life-ending errors  - all well-documented by the nightly network news." Don Schwartz. Director, Trager Institute.

NORTH CAROLINA

North Carolina has a title protection act which now applies only to massage therapists.1  We are unaware of any well-documented evidence of harm that justifies the regulation of massage therapists in North Carolina.

Unanswered questions

Rhonda L. Wiitener, Secretary of the North Carolina AMTA Chapter, wrote, "It frightens me that there are people out there calling themselves massage therapists who have not had one hour of training."2 However, Whitener has not replied to my questions: How many massage therapists "have not had one hour of training," and how do you know they "have not had one hour of training"? Why do those "people out there,"  who "have not had one hour of training," frighten you? And, what harm have they caused?

Whitener also stated, "Most people don't know the difference between a good or bad massage." She also has not answered my questions: What is a "good massage"? How do you define a "good massage" and a "bad massage"? What well-documented evidence do you have which validates your allegation that "most people don't know the difference between a good or bad massage"?

"Mutiny in North Carolina"

From monopoly control to open rebellion

To escape the dragnet of state regulation,  bodyworkers who view themselves outside the 'massage net' are forming their own coalitions to protect their right to practice.3

The latest battle on the regulation front is the "North Carolina Mutiny."1  The mutiny began when polarity therapists (who did not want to be subject to regulation by the North Carolina State Board of Massage and Bodywork) threatened to take legal action against the Board.  "In October, "the  ... Board ... exempted almost a dozen energy and movement therapies from the 1998 law. "

In addition to polarity therapy, the board exempted Tragerwork, the Alexander Technique, Feldenkrais, Body-Mind Centering, Healing Touch, Reiki, Therapeutic Touch, Touch for Health, Jin Jyutsu, and medical Qigong. Reflexology was exempted last November.

If you shut up truth and bury it under the ground, it will but grow and gather to itself such explosive power that the day it bursts through, it will blow up everything in its way. - Emile Zola

Massage is safe in Georgia

When the Georgia AMTA Chapter promoted licensure, it pointed out the potential harm associated with massage, but did not present any well-documented evidence of harm that had actually occurred, The senators disregarded all that undocumented evidence, did their own research to find out how much harm had actually occurred, and concluded:

"There is no documented danger of actual harm to the public...

"The potential for harm to the public appears to be remote and would not be alleviated by licensing."

The Georgia legislators are to be commended for doing their own research. Their Review of Senate Bill 300, which  consists of a 12 page report and 32 pages of appendices, is a model for legislators, in other states, who have to consider the issue of whether massage should be regulated.4

Questions

If there's insufficient harm to justify state regulation in Georgia, why would there be sufficient harm to justify regulation in any other  state? There is no evidence that the incidence of contraindications for massage varies significantly in different states. Also, why would there have been sufficient harm to justify regulation in states which now have regulation, before they enacted regulation? If there originally was insufficient harm, the likely explanation for regulation in those states is that it was enacted to achieve monopoly control, just as states presently enact legislation to achieve monopoly control.

Massage is safe in states

There was only one complaint of possible harm in an estimated  19,240,000 massages.5

Massage is safe in Pennsylvania

Officers of the Pennsylvania Chapter of AMTA (PA-AMTA) and the Pennsylvania Licensure  Coalition (PALC) have not replied to Schatz's repeated request for well-documented harm that has occurred in Pennsylvania. His questions, addressed to those officers and other in PA-AMTA and PALC are reported in several issues of the Massage Law Newsletter <www.healingand law.com>. We therefore conclude those officers have no evidence that harm has actually occurred in Pennsylvania.  

The Minnesota Chapter of AMTA was unable to provide well-documented evidence of any harm that had actually occurred in an estimated 655,2000 massages, and therefore based its position on the potential for harm. The Minnesota legislators were not impressed by the potential for harm.6

Massage is safe in Arizona

The Arizona Coalition of Massage Therapists and Bodyworkers has recognized that massage is safe because it acknowledged. "We generally don't harm people."  This "makes it difficult" to persuade legislators that regulation is needed.7

Massage is safe in California

The California  Coalition on Somatic Practices,  reported, "The good news is that we injure very few clients. As a result ...we will have difficulty meeting the Sunrise criteria without manipulation of the data." In other words, the Coalition refused to falsify data to meet the state legislative requirement for evidence that unlicensed massage practitioners endanger the public.8

The Coalition's members are to be commended for their refusal to falsify data in order to comply with the requirements of the California Sunrise Process. The California state legislature is to be commended for its Sunrise Process. It makes perfect sense and is a model of what all states should have.

Massage is safe in the

The Canadian Province of Quebec conducted a two year research project which uncovered no harm associated with massage, regardless of the training of the practitioners.9

Massage is safe in the Canadian

The Health Professions Council in Vancouver, British Columbia, concluded, "The College" [of Massage Therapists of British Columbia] "has provided no literature or scientific studies to show objective evidence of significant harm" caused by unregistered massage therapists.10

Massage is safe in other

This information, about Canadian provinces, is in the Massage Law Newsletter.9 Alexander, in Ontario,  Canada told Massage Magazine, "Massage and bodywork are safe. There have never been any cases of physical injury to people."9  Alexander is editor of The Journal of Soft Tissue Manipulation which is published in Ontario.  He is also a Contributing Writer for the Massage Therapy Journal published by AMTA.

The Pew Report considers

This report considers massage therapy a  service which is "not especially harmful." The Pew Health Professions Commission" charged its TaskForce  ... to identify and explore how regulation protects the health, and to propose new approaches to health care workforce regulation to better serve the public's interests."11

The National Certification

NCE devotes only about 1.2% of its total content to contraindications.12 The most likely reason why NCE pays so little attention to contraindications is that there is so little if any well-documented evidence that massage therapists (and other bodyworkers) have caused a significant amount of serious harm. 

There is NO correlation between

The massage literature has no well-documented information about the incidence of well-documented harm caused by regulated and unregulated massage therapists. Nor is there any well-documented information about the incidence of well-documented harm associated with each contraindication.

Despite the lack of such information, proponents of state regulation continue to use the existence of contraindications as evidence that state regulation is needed to protect the public from harm.

The COST of professional liability

Will Green, President of the IMA Group that provides personal liability insurance for massage therapists and other bodyworkers, has provided the following information.13

"The cost of our malpractice coverage has been reduced by 50% over the past five years due to the lack of claims. We cover over 5,000 members with 100 hours of training in California, the largest state in the union." (California does not regulate massage therapists.) 

"Over the past five years, with 30,040 members to date, we average about one claim per month. Most claims are covered by general liability as they are claims caused by poor housekeeping, like tripping or falling."

"The purpose of most trade regulation legislation is to exclude others from practice and control a market unless there is a real need to protect the public. In this case we know of no real need to protect the public at this time unless you can send us validation of such claims.

"There is always potential for harm even as one sits in a meeting hall. How do we know the ceiling will not fall? We do not. Therefore we all protect our interests with insurance. To protect the public we suggest that every responsible business person carry liability insurance as our members do."

The cost of malpractice

The cost of malpractice insurance for doctors has increased to such an extent that in some areas doctors are scaling back their practices, retiring from medicine, and relocating to other areas where the cost is lower. Compare this with the cost of liability for massage therapists. As Will Green told us (above), "The cost of our liability insurance for massage therapists and other bodyworkers ... has been reduced by 50% over the past five years due to the lack of claims."

More evidence that

"Massage therapy is unusual as compared to most therapies in that its effectiveness is greatly out of proportion to its potential risk for causing harm."14

"Reports in the medical literature of injury from massage have been rare in the past. This can be readily understood in terms of the practice and training norms that prevail throughout most of North America... Relaxation massage and general rather than specific therapeutic effects are emphasized.

" Also, although there has been a great increase in public interest in massage therapy and other forms of complementary health care in recent years, information presented at a recent meeting of the National Certification Board for Therapeutic Massage and Bodywork (May 19-20, 1999) indicated that a majority of US practitioners do not provide treatment in a medical context and receive few if any medical referrals. It was estimated that fewer than 25% of all practitioners in the US currently do any medically oriented massage that involves treating clinically diagnosed conditions.

"The three most often cited reasons for  receiving massage therapy by US consumers are relaxation (27%), relief of muscle soreness, stiffness or spasm (13%), and stress reduction (10%). Outside of BC [British Columbia], both physicians and the public have tended to approach massage therapy treatment with caution, and primarily for relaxation and other general therapeutic benefits.

"Patients with musculoskeletal injuries and disorders typically receive treatment from MDs or other health care professionals rather that massage therapists. This is not a pattern of massage therapy associated with a significant risk of harm."14

Our previous research

Many of our reports in the Massage Law Newsletter (too numerous to cite here) point out that there is insufficient serious harm, associated with massage, to justify the alleged need for state regulation to protect the public from that harm. These reports also refer to our publications on the same subject that have appeared in other periodicals.

Schatz's Letter to the Editor of Massage

I was pleased to see George Gluzinski's Letter to the Editor [Summer], 1999. I believe an objective evaluation of state regulation is long overdue, and should be done by a committee whose members have no vested interest in state regulation.

There is no well-documented evidence that allegedly inadequately trained massage therapists have caused enough serious harm, in people with contraindications, to justify the alleged need for state regulation to protect the public from that harm. There is no well-documented evidence that state regulation has protected the public from harm in states which regulate massage therapists.

There is no well-documented evidence that state regulation assures competence. There is no generally accepted definition of competence for massage therapists, and there is no way to objectively measure that competence. There is no well-documented evidence that anybody needs more than the 250 hour training which Texas requires.

The fact is that so many massage therapists with so many varied trainings have massaged so many people (with so many contraindications) so many times, for so many years, in so many states (which do not regulate massage), with so many well-documented reports of so many benefits, but with so little if any well-documented evidence of serious harm. - Albert Schatz, Philadelphia

No refutation of any allegation in Schatz's Letter, has appeared in Massage Therapy Journal.

.WHAT WELL-DOCUMENTED EVIDENCE

The Law and Legislative Program (L&LP  of the American Massage Therapy Association (AMTA) has allocated "MORE THAN $500,000 TO PROMOTE STATE REGULATION."15 The following information indicates that AMTA's L&LAP has insufficient well-documented evidence of harm, caused by allegedly unregulated massage therapists, to justify the alleged need to regulate massage therapists to protect the public from harm.

What  evidence of harm

According to "Ron Precht, a spokesman for the American Massage Therapy Association in Chicago, adverse reactions to massage 'are really rare. Precht, whose association offers liability insurance to all of its over 37,000 members, calls the number of claims against massage therapists in the United Stated each year 'minuscule,' but couldn't give an exact figure."16  Precht is Communications Manager at AMTA.

"Claude Gagnon, who runs the Lakeside School of Massage Therapy in  Milwaukee, Wisconsin, [said] injuries during massage are extremely rare."17 Gagnon was president of the AMTA Council of Schools.

We assume that Precht and Gagnon would have commented on what harm has been caused by regulated versus unregulated massage therapists, if they had that information. Also, if there is reliable information that unregulated massage therapists have caused more well-documented serious harm than regulated massage therapists, that information would certainly have been publicized by proponents of state regulation, which none of them have ever done.

Since Precht and Gagnon have and had, respectively, close affiliations with AMTA, we assume that AMTA's L&LAP does not have sufficient well-documented evidence of enough serious harm (caused by unregulated massage therapists) to justify the alleged need for state regulation to protect the public from that harm.

Information about harm by AMTA

This information about harm consists of personal injury claims against AMTA members.18  The authors of the JAMA report tell us, "We obtained data on claims against massage therapists from Albert H. Wohler and Co. of Park Ridge, Illinois.

"Wohler has provided professional indemnity insurance services to members of the American Massage Therapy Association (AMTA) since 1993, and currently insures approximately 27,000 massage therapists  throughout the country ... almost half of all licensed practitioners in this area."

The JAMA report  covers the four year period of 1993 through 1996, It tells us the number of "Claims per 100 policy holders" (i.e., AMTA members), the "Claims paid, %," and the "Average indemnity payment per paid claim" in dollars.

The report does not tell us whether the injuries were associated with contraindications; and, if so, with which ones. Nor does the report tell us whether the massage therapists, who caused the injuries were or were not state-regulated. 

In the absence of evidence to the contrary, we believe there is more well-documented evidence about harm caused by AMTA members than by allegedly inadequately trained massage therapists in states which do not regulate massage therapists.

AMTA state chapters have insufficient

If AMTA has insufficient well-documented evidence of harm to justify the need for state regulation to protect the public from harm, it follows that AMTA state chapters also have insufficient well-documented evidence of harm to justify promoting state regulation to protect the public from harm.

OUR SEARCH FOR HARM

We did one search for harm with the search engine GOOGLE, and  asked for information about "massage harm" and "harm massage". None of the many reports that we read,  among the considerable total, referred to harm that had actually occurred as a result of massage. Instead the reports commented on the danger of and potential for harm associated with massage. We therefore tried government agencies.

The National Center for Health

On December 8, 2000, we asked the National Center for Health Statistics (NCHS) to search for reports on (a) "massage harms people," (b) "people injured by massage therapists," (c) "massage therapists harm people," and (d) massage therapists injure people." Four identical replies, which came from the Center for Disease Control (CDC) each said, "Your query message" matched 0 [zero] documents. Try checking your syntax or using different words."

We also shortly thereafter received this e-mail from NCHS: "NCHS does not obtain the requested data. Contact the National Health Information Center" (NHIC). This is part of the U.S. Department of Health and Human Services.

The National Health Information

We then located NHIC, and asked NHIC's "healthfinder" to obtain information about "people injured by massage." NHIC's "healthfinder" gave us several possible sources for the information we requested, of which AMTA was the most likely source.

What evidence of harm

We clicked on  "AMTA", but the information provided by AMTA said nothing about harm caused by massage. It did not even include the word "harm."

Schatz, who is a member of AMTA, then clicked on AMTA's "Contact us" and sent this  e-mail to AMTA: "The National Heath Information Center web site referred me to AMTA when I requested information about how many people are injured annually by massage in the U.S. I would appreciate it if you would please give me that information. Thank you." Schatz immediately received the following confirmation from AMTA, "Your comments have been received."

Happy New Year

The following well-documented reports of serious harm DO NOT justify the alleged need for state regulation to protect the public from harm by allegedly inadequately trained massage therapists.

James F. Trotter, M.D., reported a hepatic hepatoma after "deep tissue massage."19 But his report does  not tell us what kind practitioner did the "deep body massage."  However, Trotter does  say, "The incidence of adverse effects of body massage is not known, but it is probably quite low." Trotter gives references to four reports of harm associated with massage.

In the first report, the author mistakenly equates Rolfing with "therapeutic massage."20

In the second report, the massage involves a woman who walked on her husband's back while he was lying in a prone position, after he had injured his back.21

The third report," a 45-year-old ... male massage therapist" was taken to the emergency room after "acute onset of right hand extensor paralysis"  which" occurred immediately after deep tissue massage with pressure point concentration laterally and distal to the lateral epicondyle. The massage lasted approximately one and a half hours with 15 to 20 minutes of direct pressure applied laterally with the masseuse's elbow.

"The patient was seeking massage for sore extensor and flexor muscles, presumably secondary to overuse from performing deep tissue massage on clients himself. He admits to some pain from the massage but not more than anticipated."22 In this case, a massage therapist who had injured himself doing massage permitted another massage therapists to treat him in a way that resulted in serious harm.

Do we need state regulation to protect massage therapists from being injured by other massage therapists?

The fourth report is about a case of harm, in Singapore, caused by traditional medicine massage.23 This is not the massage therapy practiced in the United States.

Harm associated with Shiastu, which

Shiatsu has unfortunately been equated with massage therapy, as Rolfing has in the above-mentioned first report.20 I have already discussed9 one Shiatsu report.24 Another report may also not differentiate Shiatsu from massage therapy.25

ALLEGATIONS OF SERIOUS

Peter Behr, who was president of the College of Massage Therapists in the Canadian Province of British Columbia (CMTBC), reported that "We've had a man who died of a heart attack from being in hydrotherapy" (presumably administered by a massage therapist), and "We had a man recently who had a stroke on the table" presumably when he was being massaged." Behr also said, "In Alberta [Canada], right now there's a suit that a therapist" (presumably a massage therapist) caused someone to become a "paraplegic."

 Can you imagine a massage therapist harming a client more seriously than causing a stRoke, converting a client into a paraplegic, or killing a client? But do not be alarmed. Behr presented no evidence that these cases of harm had ever actually occurred.

Behr made these astonishing allegations of such extraordinary harm at a public hearing convened by the Health Professions Council, a government agency. Since then, Behr has not provided any evidence at all that that serious harm had actually occurred, despite repeated requests for such evidence by Lincoln Lau, President of the British Columbia Coalition of Allied Bodywork Practitioners, and by Albert Schatz. Lau also researched Behr's alleged harm, but found no evidence that that harm had ever occurred.

Douglas M. McRae, Registrar of CMTBC), has also not provided any evidence that validates Behr's allegations of serious harm, again despite repeated requests for such well-documented evidence. Nor has McRae denied that harm has actually occurred.

Did Behr fabricate that harm?

 Behr also said at the hearing, "I am not making this up."26 with respect to other undocumented harm which he also alleged had occurred.

Since neither Behr nor the Registrar of CMTBC has provided well-documented evidence that the serious harm (which Behr reported) has actually occurred, how can one avoid the conclusion that Behr did in fact "make it up"?

AN INVITATION

If we have inadvertently published inaccurate information, we will publish corrections. We invite those who disagree with anything we have published, to submit articles with well-documented relevant evidence, and give us permission to publish their articles in the Massage Law Newsletter <www.healingandlaw.com>..

REFERENCES

1. Walsh, K. North Carolina Mutiny. Massage Magazine. page 185. January/February. 2001.

2. Schatz, A., and Brewster, M. What is a "good" massage? What is a "bad" massage? And who is most qualified to decide whether a massage is "good" or "bad"? Massage Law Newsletter. 14(4):1-3. 2000.

3. Walsh, K. The regulatory net. Part 2. Untangling the net of massage regulation. Massage Magazine. pages 131-139. May/June. 2000.

4. Review of Senate Bill 300 Which Proposes to Regulate Massage Therapists. Georgia Occupational Regulation Review Council. October, 1997.

5. Schatz, A. The Georgia AMTA's data reveal that massage is safe, not harmful. Licensure is not needed to protect the public from harm which does not occur. Spiritual Massage Ministry Newsletter. 3(2):1-4. 1998.

6. Schatz, A. 655,200 reasons why Minnesota does not need to regulate massage therapists to protect the public from harm. There's no harm in Georgia and in the Canadian Province of Quebec, So why would there be any harm in Minnesota? Massage Law Newsletter. 13(2):1-5. 2000.

7. Schatz, A. Arizona does not need to regulate massage therapists to protect the public from harm. Massage Law Newsletter. 15(4):1-9. 2000.

8. Schatz, A., and Brewster, M. Massage does not cause enough harm in California to justify state regulation. Journal of Spiritual Bodywork. 2(4):6-7. 1996.

9. Schatz, A. Massage should be deregulated because it does not cause harm. Massage Law Newsletter. 5(2):1-18. 1998.

10. Epstein, I., et al. Massage Therapists Scope of Practice (Preliminary Report. Health Professions Council. Vancouver. British Columbia. Canada. February, 1999.

11. Reforming Health Care Work-force. Regulation Policy Considerations for the 21st Century. Report of the Taskforce on Health Care Work-force Regulation.  The Pew Health Professions Commission. Center for Health Professions. University of California. San Francisco. December 1995

12. Schatz, A., and Brewster, M. The National Certification Examination devotes little content to contraindications.. Massage Law Newsletter.  9(1):1-5, 1999.

13. Schatz, A.  Pennsylvania does not need Senate Bill 1220 to protect the public from harm. Will Green, President of the IMA Group, tells us that massage therapists do not harm people. This is why massage therapists now pay 50% less for malpractice insurance  than they did five years ago. Massage Law Newsletter. 13(4): 1. 2000.

14. College of Massage Therapists of British Columbia. July 6, 2000, Submission (to the Health Professions Council) entitled Further Commentary on the Risk of Harm Associated with the Practice of Massage Therapy. A Supplemental Response to the Health Professions Council's February 1999 Preliminary Report on the Massage Therapists Scope of Practice,

15. Information that AMTA distributed to members.

16. Precht's comment originally appeared in Adam Marcus' article "Rubbed the Wrong Way" in the December 22, 1999, issue of the newsletter HealthSCOUT. We found Marcus' article reprinted  in the September 1, 2000, issue of the  newsletter A Healthyme (<www.ahealthme.com>. The contents of this newsletter are copyrighted by Blue Cross Blue Shield of Massachusetts which "makes this website available for the sole purpose of providing educational information on health-related issues and providing access to health-related resources."

17 Gagnon, Claude. Quoted from the same article which has Precht's comment. (Reference 1).

18. Studder, D. M., et al. Medical malpractice implications of alternative medicine. Journal of the American Medical Association.  280(18):18. 1610-1615, November 11, 1998

19. Trotter, J. F. Hepatic hematoma after deep tissue massage. New England Medical Journal. (Letter to the Editor). Vol. 341. No. 26. December 23, 1999.

20.. Kerr, H. D. Ureteral stent displacement associated with deep massage. Wisconsin Medical Journal. 96(57-58, 1997

21. Mikhail, A, et al. Renal artery embolism after back massage in a patient with aortic occlusion. Nephrol. Dial. Transplant 12297-298. 1997.:

22. Giese, S. and Hentz, V. R.. Posterior interosseous syndrome resulting from deep tissue massage. Plastic and Reconstructive Surgery. 102:1778-1779. 1998.

23. Kalinga, M. J. et al. Popliteal artery pseudoaneurism caused by an osteochondroma - a traditional medicine massage sequelae. Singapore Medical Journal 37:443-445. 1996.

24. Mumm, A. H. et al.  Zoster after shiatsu massage. The Lancet. 341:447. February 13, 1997.

25. Hershowitz. S. et al. Shiatsu induced injury in the medium recurrent motor branch. Muscle Nerve. 15:1215. 1992.

26. Information about Peter Behr's allegations of harm are in reports in the Massage Law Newsletter. References to these reports are in the Massage Law Newsletter, Volume 17, No. 1. page 3. November. 2000.