Archive for March, 2018

Congress Receives Vaccine Safety Project Details Since the CDC & FDA Ignore Their Own Data and Proclaim Vaccines Do Not Cause Autism

https://worldmercuryproject.org/news/congress-gets-vaccine-safety-project-details-including-actions-needed-for-sound-science-and-transparency/

Congress Receives Vaccine Safety Project Details Including Actions Needed for Sound Science and Transparency

 

 Approx. 9 Min.

Vaccine Safety Project Trailer

Since the FDA considers vaccines to be “biologics” not drugs, they have the capacity to fast track them without mandating rigorous studies as drugs must go through.

This short informative video shows exactly how vaccines are not rigorously studied with any sort of sincere science.

According to HHS’s own calculations, if they were able to capture ALL adverse events, they state that nearly 6 MILLION Americans would be adversely affected every year by vaccines if all of them were reported to the current Vaccine Adverse Events Reporting System (VAERS).

The committee overseeing vaccine safety should be absolutely free of any conflicts of interest, particularly the pharmaceutical industry, yet the opposite is true.

A new investigation in 2009 found that:

  • CDC has a systemic lack of oversight of the ethics program.
  • 97% of committee members’ conflict disclosures had omissions.
  • 58% had at least one unidentified potential conflict of interest.
  • CDC & FDA scientists receive royalties of $150K per year on vaccines they develop.

Looking at the IOM 700 page report on DTap, the conclusion reads,

“The evidence is inadequate to accept or reject a causal relationship between diphtheria toxoid-, tetanus toxoid-, or acellular pertussis-containing vaccine and autism.”

What this means is they claim they couldn’t find any study on the relationship between Dtap and autism.  But, in fact they acknowledge in the first paragraph that there is one study that does show a causal relationship between Dtap and autism, but they reject it because it provides data from passive surveillance (VAERS) that lacked a comparison of an unvaccinated population.

So while the CDC website cites the 2011 Institute of Medicine study that “vaccines do not cause autism,” they seem to be counting on people not reading the 700+ page report. Anyone who does can find that the researchers behind this study ignored existing research showing a correlation between vaccines and autism.

Rather than doing their due diligence (scientific studies) they just proclaim vaccines do not cause autism.

For more:  https://madisonarealymesupportgroup.com/2018/03/01/vaccines-could-contribute-to-disease-epidemics-due-to-retrovirus-contamination/

https://madisonarealymesupportgroup.com/2017/12/04/ingredients-in-kinrix-a-dtap-ipv-vaccine/

https://madisonarealymesupportgroup.com/2017/10/04/pharma-using-scare-tactics-over-pertussis-vaccine-failure/

https://madisonarealymesupportgroup.com/2017/09/21/aluminum-flawed-assumptions-fueling-autoimmune-disease-and-lyme/

Vaccines have been found to activate latent Lyme/MSIDS infections: https://madisonarealymesupportgroup.com/2017/12/02/scottish-doctor-gives-insight-on-lyme-msids/ (Please read comment section after article for more links)

https://madisonarealymesupportgroup.com/2016/04/24/gardasil-and-bartonella/ Asymptomatic girls after receiving Gardasil activated dormant Bartonella which was confirmed by testing.

https://madisonarealymesupportgroup.com/2018/01/28/the-secret-x-files-the-untold-history-of-the-lymerix-vaccine/

 

Podcast: Improving Tick-Borne Disease Testing

http://livingwithlyme.us/2018/03/episode-21-improving-testing-for-lyme-and-other-tick-borne-diseases/

Episode 21: Improving Testing For Lyme and Other Tick-Borne Diseases

March 15, 2018

Cindy Kennedy, FNP, discusses Lyme disease testing with Dr. Jyotsna Shah, who heads one of the leading laboratories for the diagnosis of tick-borne diseases.

Joytsna

Dr. Jyotsna Shah

Dr. Jyotsna Shah is the President and Laboratory Director of IGeneX Clinical Laboratory, Palo Alto, California. Dr. Shah has over 40 years of research experience in immunology, molecular biology and microbiology. She earned her B.Sc. and M.Sc in Biological Sciences from UK and her Ph.D. in diagnostic immunology from Nairobi University, Kenya. She then joined International Laboratory for Research on Animal Diseases (ILRAD) as a post-doctoral scientist where she started the first DNA sequencing laboratory in E. Africa. On completion of her fellowship, she joined Harvard University, Department of Tropical Medicine, Boston as a research fellow and continued work on development of molecular tools for diagnosis of parasitic diseases.
Since then she has worked at several Biotechnology companies, mostly involved in development of novel molecular technologies for diagnosis of infectious diseases. She is a world expert on use of Fluorescent in Situ Hybridization (FISH) technique for direct detection of pathogens in clinical samples. She has many publications and over 20 patents.

She joined IGeneX as the Director of Research and Development in 1997. She introduced the first Fluorescent In Situ Hybridization (FISH) test for Babesia and also set up the PCR department for tick-borne diseases. Since April 2003 she has been the Laboratory Director (clinical and research). She represents IGeneX at local and international meetings. Under her guidance, the laboratory has developed an excellent QA program. Because of her scientific guidance IGeneX has become one of the leading reference laboratory for diagnosis of tick-borne diseases in the world.

https://madisonarealymesupportgroup.com/wp-content/uploads/2018/03/lwlepp21.mp3

Transcript of Episode 21: Improving Testing for Lyme and Other Tick-Borne Diseases

Cindy: Hello, everybody out there. This is your host, Cindy Kennedy. You are listening to an episode of Living with Lyme. I am honored today to have Dr. Jyotsna Shah. She is the President and Laboratory Director of IGeneX, and that is out in Palo Alto, California. Dr. Shah has over 40 years of research experience in immunology, molecular biology, and microbiology. She received her PhD in Diagnostic Immunology from Nairobi University in Kenya. She is certainly well-versed and has certainly extensive experience, and we’re very, very excited to have her with us today. So, I’d like to say hi, Dr. Shah. Welcome.

Jyotsna: Thank you, Cindy, for inviting me to your show.

Cindy: I’m so happy to have you. You know, we all know the word IGeneX, but we’re not necessarily well-versed on how you work and how people get tested. So, give me some background, give me some information. If I were to call you and say, “Hey, what do I do? I’ve been sick. I continue to test negative for a tick-borne illness.” Tell me what would happen.

Jyotsna: Okay. So, if you call me with such a question, one of the first things the person whoever is answering the phone is going to kind of say, “Well, one of the things you can do is get tested for Lyme and tick-borne diseases.” And, the question might be what kind of testing to do. And, they would recommend sort of going through the protocol and explaining that you can do a panel approach, where you look at the full spectrum of the disease, where you do not know when you were infected, for example. Sometimes we get a call with, “I don’t know. I just have the symptoms.” So, we don’t know on the spectrum where that person is. Is it early disease? Is it not Lyme? Or is it late disease?
So, then they would kind of walk through the test request form and say you might want to order … take a panel approach where you look for the full spectrum of the disease. And, there are two ways of testing. One is you always look for how the patient response is to an infection. Number two is what is the cause of the disease? So, you look for the path of pathogen. And, that is looking for the proteins or DNA. And, when you’re looking at the response, you’re looking for cellular immunity or humoral immunity, which is looking for B cells, antibodies. Generally, that is the most common testing that is done for Lyme, is looking for antibodies.

Cindy: So, those are antibodies you’re talking about that if you actually get an infection your body tries to fight it and makes those B cell antibodies, which are part of your white blood cell, correct?

Jyotsna: That is correct. So, but before that, what happens is this, say, you got infected. The first response is cellular immunity. Your T cells get activated and respond. So, if it was very early in the disease, you would see either the presence of the pathogen or the T cell response. And, then as the B cells start making antibodies, the T cells go down and your antibody response is increased, and we can see that. The first response is IgM, and then it converts to IgG, which is a long term response.

Cindy: Sure. A lot of people don’t know. I mean you produce this IgM how long after infection? I know that it takes a few weeks to see that in a blood test, correct?

Jyotsna: Yes, it takes minimum of a week before you could see anything, I would say. And, then from our experience in the lab, it’ll be present for at least two months before you start seeing IgG response. I know CDC says you shouldn’t be using IgM after a month, but looking at the data, in the most cases IgM doesn’t convert to IgG within a month. It takes longer for the conversion. So, then you will see both the antibodies in some patients’ [CNM 00:04:18] as the disease progresses. Then, in a traditional disease it converts to IgG, that’s the long term antibody. But, in Lyme, this is the big difference, what we find that in some patients IgM can persist for a very long time. And, there is a reason for it.
The reason is Borrelia like to hide in tissues. So, they’re hiding somewhere and the patient may have no symptoms. And, an analog of that, a very similar thing happens with TB. When a person gets infected with tuberculosis, some patients have no symptoms, the bacteria goes into hiding. And, then later on, when your immune system is weak due to some reason or the other, it could be some kind of medication, it could be just another infection, it could be anything, your immunity is low and for some reason the bacteria come out. Something triggers these bacteria to come out. And, that is what we believe is the reason why IgM response may be present for a long time. And, there’s no proof, these are just thoughts, because we do see IgM for a very long time in some patients, not in all patients.
Now, because of this picture, we always recommend doing testing for IgG and IgM, irrespective of where the disease is, because we don’t know what we are going to find in the patient. Secondly, about 20% of the people do not make antibodies, okay?

Cindy: Ever? Ever?

Jyotsna: Ever. Really, that’s documented fact. So, these patients that cannot make antibodies, if you’re going to look for by western blots, it’s going to be negative. Then, we have to look for DNA in these patients, for Borrelia DNA. Or you can do a T cell test. Because of all these factors, what we recommend is to do immunoblots and PCR testing at the same time so you get the full picture of what’s going on in the patient. That’s our recommendation.

Cindy: Tell everybody what the PCR stands for.

Jyotsna: Okay. PCR it’s a technique where we isolate the pathogen DNA from the clinical sample and we amplify the signal to see whether the pathogen is present in the clinical sample or not. Pathogen’s DNA specifically. Every cell has our human DNA. However, with the pathogen DNA, this is where it becomes very tricky, is that there are going to be only few cells, right, in the blood sample, 99.99% is going to be all DNA and probably 0.001% is going to be Borrelia there. So, you try to expand that signal of Borrelia by purifying your DNA and using specific method known as PCR.

Cindy: Wow, sounds complicated.

Jyotsna: I know. So, basically, PCR is a method of detecting Borrelia DNA in your clinical sample, is all you need to know.

Cindy: That’s all you need to know.

Jyotsna: Yeah.

Cindy: Wonderful.

Jyotsna: Okay.

Cindy: You know, I noticed on your website that you have testing for relapsing fever.

Jyotsna: Yes.

Cindy: What is relapsing fever?

Jyotsna: Okay. It’s a different group of Borrelia that causes relapsing fever. And, the reason it’s known as relapsing fever was that when a patient gets infected with a relapsing fever Borrelia, they get fevers at set stages. Some might get it every few days. That is why it’s known as relapsing fever, the fever is at set intervals.

Cindy: Yeah, it’s actually they do have fevers, then you’re talking fevers over 100.4, 100.5?

Jyotsna: Yeah, they do have fevers.

Cindy: I see.

Jyotsna: So, that used to be the classical symptom of relapsing fever. And, nobody ever paid much attention to it for a very long time, because if you saw that, you would test the patient for relapsing fever. But, what we know now is that relapsing fever symptoms overlap Lyme symptoms, okay?

Cindy: Yeah.

Jyotsna: So, now there’s another complication that has come in the picture and we are finding more and more of it. So, patients may have Lyme-like symptoms. They do Lyme testing and it comes negative, which is quite common. We hear about it all the time. And, the doctors would call us and say, “The patient definitely has Lyme. How come the test are negative?” Our answer is, “We can’t do anything. We are giving you the results that we got on that patient’s sample.” And, that used to bother us quite a bit, what is going on? What are we missing? And, the story started when I was in Africa. I was visiting a clinic for malaria in Tanzania, and when I was talking to the lab people there, they told me that they find a spirochete quite often in their blood samples.
I had seen it once or twice when we were looking at malaria slides, but I’d never paid much attention, simply because we are a Lyme lab, and I was concerned that there might be a contamination or something. But, when they told me about it, they said a lot of people are misdiagnosed in the third world countries as malaria patients when they really are not, they’re relapsing fever. And, that kind of triggered my imagination and kind of like my research my creative mind. So, I said, “I need to look at this.” And, we found out that this was a very common disease, not only in Africa but in Europe, Australia, and U.S., far more common than we know, we thought of it.
And, now we find that a lot of these patients, when we did our research for several years, we started finding out that a lot of patients who had Lyme-like symptoms and were negative by all the Lyme tests were turning out to have antibodies to relapsing fever Borrelia. Okay?

Cindy: So, is that a different strain or a different species? And, can you tell me the difference of those two terms?

Jyotsna: These are it’s a different species. One is Borrelia burgdorferi Group that causes Lyme disease. The other one is a Relapsing Fever Borrelia Group, it has a lot of different strains in there all over the world. And, it’s transmitted by pigs, mostly, but also by lice. And, it is transmitted by hard ticks, like Lyme disease, and by soft ticks. So, what is happening is for a long time we always related Lyme disease with the Ixodes ticks, the hard ticks.

Cindy: Right, the deer ticks.

Jyotsna: Now, we know that the same ticks can transmit another group of Borrelia which causes similar symptoms to Lyme disease.

Cindy: Are they here in the United States? Do we-

Jyotsna: Yes. Everywhere where there is Lyme disease. Everywhere.

Cindy: So, are these ticks, they come with travelers, is that how it became populated?

Jyotsna: No.

Cindy: No?

Jyotsna: They’re here. They’re here. We have had them.

Cindy: Well, I don’t want them. I want them to go away.

Jyotsna: I know, but unfortunately, they’re here everywhere. They knew about it on the western part of the U.S. But, the number of cases have been reported is so low, which is underestimated. So, the big question now is we should not be looking for Lyme disease Borrelia burgdorferi only, but we should be looking at borreliosis. That’s really what we need to do now, change our thinking.

Cindy: So, is that what is included on your whole panel when you said early on? Yes?

Jyotsna: Yes. So, what we have done now is, and I’m going to explain a little bit more, so what we have done is we offer, of course, we offer all kinds of testing for Lyme disease, relapsing fever. But, our recommendation is to do the borreliosis panel, where you’re looking at both groups of Borrelia, you look for antibodies to both of them, and you look for DNA for both of them. That is our recommendation as a screening test now.

Cindy: I see. Okay.

Jyotsna: Okay? Because, we are finding, I mean so many of the patients, some have mixed infections, some have one or the other. Now, the other thing I want to mention is that everybody knows about western blots.

Cindy: Yes.

Jyotsna: Western blots are a way of looking at patient antibodies, and based on the patterns you can decide is it early, late infection in some cases, or that’s what we find useful there. But, one of the problems with a western blot is that the way it is made, you could have more than one particular antigen or protein present at a position. So, that means that sometimes when you see a signal it may not be as specific as you think.

Cindy: You say the word signal, and I think to the general people who are listening they don’t know what a signal is other than maybe a traffic light.

Jyotsna: Okay, so basically when we’re looking at it, they would get a positive result.

Cindy: Okay, so like a positive band?

Jyotsna: Yeah, a band. Yes, a positive band on a western blot.

Cindy: Got it.

Jyotsna: So, when they get a positive band, it’s reported as positive, but as time went on, we all learn that in some positions there were other bands, more than one band present. So, when you got the positive band, you didn’t know which one it was, whether it’s a specific signal for Borrelia or something else. You know, it is a housekeeping gene which is present not only in Borrelia but a lot of other bacteria, for example. So, this is very, very important, what I’m going to say here, that is why I want to explain this a little bit more. So, what we have done now is we have prepared two reasons, okay. One reason with the western blot is that you only look at one particular strain of Borrelia when you make a western blot, because that’s how it is made. You don’t mix, you know.
So, if you had different strains, in U.S. there are several different strains that cause the disease now. We know that. So, if you really wanted to test for all of them, you would need lot more western blots, and it’s really not a practical way of testing a patient sample, and it’s going to be extremely expensive. So, what we have done is we have developed an immunoblot, where we take pure antigens that we know are important in different species and strains and put it on one membrane, so that the patient now when they order immunoblots from IGeneX get tested for all the species that we know of that cause Borrelia infection, whether they have picked it up in Europe, in U.S., or somewhere else. Okay?

Cindy: Okay.

Jyotsna: So, that is what we have done. So, we have developed this test to encompass Borrelia burgdorferi infection from anywhere in the world. And, that’s very important because we all travel all over the world now. People travel so much, East Coast, West Coast, you’re everywhere. Now, if we were just to test, for example, with B31 that is recommended by CDC as the strain to be used, we would miss a lot of patients just because they got infected, say, in California, for example, or somewhere else, like mayonii, the new species that has been identified in Wisconsin. So, that is why I wanted to point out that it’s very important to do testing with Lyme immunoblots and not western blots, that we have developed, because it’s fully inclusive of what we know today that causes Lyme disease, Borrelia burgdorferi group that causes Lyme disease.
So, it replaces a western blot, and there are two big advantages. One, it’s very inclusive. Secondly, the way it is made, it’s very, very specific. So, that is why I would recommend that. And, we have done the same thing for Relapsing Fever Borrelia group. We know that the test we have developed that TBRF ImmunoBlot will detect species that cause relapsing fever in U.S., in Europe, and Australia. We have tested at least 500 samples now to make that statement. So, that is why we recommend doing the immunoblots rather than western blots for Lyme and relapsing fever. Now, going to the T cell story. T cells, as I said, is your first response when a patient gets infected. So, only in the disease we have come up with a test that we look for T cells. We call it the IgX spot test. So, what it does-

Cindy: I spot Lyme.

Jyotsna: Yes.

Cindy: Yeah.

Jyotsna: Yeah, for Lyme.

Cindy: Yeah.

Jyotsna: Currently, we only have it for Lyme, and that test will work only in the disease for a short time before the antibodies are present. So, when we were doing our research, we would take patients who were western blot positive, had all the antibodies, those patients would come out to be negative. And, then what we found that late in the disease, when patients have very low levels of antibodies, the test was coming out to be positive. This is what we are finding. So, this is what we recommend, say everything came back negative. Or, you knew the stage of the disease, that is the test to order then.

Cindy: Okay. Now, tell me about the CD57. I have to admit that your lab test was finally the test … and this was a bit of years ago, so I was one of those indeterminate kind of people. I made one band, but I was sick, so treatment was necessary. But, at a separate lab, I don’t think it was part of the IGeneX grouping, but I had a CD57. And, that one was extremely low. So, that one being a soft marker it kind of put the doc over the edge to start treatment. But, can you explain a little bit about CD57, because you actually do have that as a test that’s optional?

Jyotsna: Yes. CD57 looks for CD57 killer cells, okay? And, what we find is a mark of a chronic disease, if your immune system is weak. It is not a marker for Lyme disease, okay?

Cindy: For chronic.

Jyotsna: But, if you had Lyme disease positive by western blot or whatever and you had CD57 count low, then you can say that your chronic disease may be due to Lyme disease.

Cindy: Okay.

Jyotsna: Okay?

Cindy: Could it be secondary to something like an Epstein-Barr?

Jyotsna: Yes, it can be. So, that is why I said it’s a chronic disease marker, not a specific marker for Lyme. You could have chronic fatigue-like symptoms, your immunity might be low, CD57 count is going to be low. So, CD57 just tells you about your immune status.

Cindy: I see. Okay.

Jyotsna: Okay?

Cindy: So, that being said, what’s the turnaround time? So, say someone knows nothing about it, and we’ve got some open-minded people, doctors, nurse practitioners, and they’re going to call you and they’re going to say, okay, you have a clinician on board that’s going to help them determine what type of testing. Maybe there’s been testing prior and the person has moved on to another practitioner. And, they’re going to get the kit, and that’ll take a few days, I assume, via post office. Once you get the specimen, what’s the turnaround time for the majority of these labs?

Jyotsna: Some labs are reporting that they give results overnight. We don’t do that. We can’t. The way we run our tests, and we do all our reading manually for our western blots. That’s very important, western blots and immunoblots, because readers miss out quite a bit. Readers are not that accurate. Every time you go to an automated system, there’s always some loss. It’s a trade-off. And, being a reference lab and really tick-borne disease, we really pay special attention. So, we have readers who are reading these blots, well-paid readers who have gone through lot of training and ton of experience.
So, our minimum time, I would say, a week is what I would give some of the results out. Our PCRs sometimes take longer, so that would be 10 working days minimum. For the other one, five working days.

Cindy: Now, if somebody’s been treated with antibiotics already, and they have changed providers, and they’re still not well, and will that interfere with the testing?

Jyotsna: With some test it may interfere. But, in case of western blots, there’s a protocol that some physicians are using where they treat the patient with antibiotics to boost their immune system. So, their thinking there is that when they give antibiotics what’s happening is Borrelia that are hiding some of the antibiotics will get to them. The cyst forms of the bacteria or hiding forms come out and induce the antibody response, so that would be better. That’s what some of the physicians think. So, it doesn’t really interfere with your results in that respect. And, if the patient has recovered, you are not going to get anything, that test should be negative then.

Cindy: You know, some patients that I’ve treated, I do gynecology, so it’s a rare occasion that I do have somebody, but I have made some diagnoses. They say to me after, “You know what, I got sick again. I was fine after you treated me with antibiotics, but then I think I got another tick on me. How come I get sick again?” And, is it because different species or strains and you don’t hold your immunity like you do possibly with chickenpox?

Jyotsna: Maybe that’s true. I am not the expert on that. But, we do see a response when somebody gets infected with a second tick with Borrelia, you do see an IgM response. And, you can see that’s a new response because two things happen when a patient gets bitten by a tick again. The memory cells remember, so that some of the late stage antibodies to that start developing if you get a second infection and you see the new infection as well, but sometimes can be worse than the first one.

Cindy: People always say, “Okay. So, I tested positive. I’m treated. Shouldn’t I have another test to make sure it’s all gone?” What do you say to that?

Jyotsna: Okay. Number one, that there are no good tests to see how you’re responding, unfortunately. There has been suggestions that the IgX spot test should be the one that would answer the question, that you do clear it out if the treatment is successful. I don’t have even enough evidence to make a call one way or the other. I am hearing that from Europe a lot, that six months after you have stopped the treatment and if you’re still well, that is the test you should do and it should be negative.

Cindy: I see. Okay.

Jyotsna: That is what I know. But, I think there are certain tests that are being developed, biochemical tests that might be useful. I don’t have much information or feel for those at this point in time. So, really, the answer to me is for Lyme you have to see how you’re feeling and what is working.

Cindy: Okay. So, I do want to point out that you can order a test kit. However, you do have to have a physician signature so that they will accept the results and be able to interpret it. Your company, though, would help a physician who’s not familiar with this to-

Jyotsna: Absolutely, absolutely, we will definitely guide the physician. Once the results come, we walk through the results, we hold their hands, and if they need help or guidance as to who they should point them for treatment, we will provide that information as well, we put them in the right direction. We also have a consulting clinician, a Lyme-literate physician who will help the physicians, family doctors in terms of treatment as well.

Cindy: What is-

Jyotsna: So, we do have that service we provide.

Cindy: What is your sensitivity rate in terms of picking up an infection? People are always saying, “Well, you know, the standard tests are less than 50% accurate.” How accurate is your testing?

Jyotsna: Okay. So, when you talk about accuracy, we look at the sensitivity and specificity. Our specificity with the immunoblots is as good as a two-tier CDC test. Like, just a second, I’m going to give you, I have a chart ready for you. So, let me just walk through that. Okay, so this is looking at our immunoblots. We looked at it, and our specificity if we combine both is 95.4% with really well-defined samples that we looked at. And, our sensitivity, I think, so where we had well-defined samples, very early stage disseminated and late stage disease, our sensitivity was 92.3% in this well-defined set of samples. We do miss samples early in the disease because patients have not made antibodies. This is looking at well-defined samples.
I just want to give you one more very important factor. Let me see where that is, on the Lyme disease specifically. Okay, so we, not us but somebody else, looked at well-defined samples. This was presented recently with the immunoblots. They looked at 49 samples. And, this represented at least one-third, 30 of them was early Lyme disease, okay, out of these 49. And, overall, the sensitivity combining all of them is 85%. Okay, and the standard testing, because that information was provided in this particular case, was overall 69% in this particular set of samples. So, early in the disease they were missing a lot more.

Cindy: Okay. All right.

Jyotsna: Okay, this is just with the well-defined samples that they were testing. I think this was provided by CDC or somebody, I’m not sure exactly. But, I’m pretty sure these are CDC samples. But, this is well-defined samples where you knew that the patients had Lyme disease, and the specificity, as I said, with this particular set of data is very, very high for the immunoblots. It is 95% overall for M, okay? The biggest problem so far has been IgM western blots, where the specificity is always lower. With the immunoblots, the specificity is 98%. So, the immunoblots that we have are very inclusive of all the different species.
The sensitivity not just with well-defined samples but with any clinical sample is going to be very high, and the specificity is extremely high. I think that is very, very important factor. We really believe that they should become the gold standard, the immunoblots, based on the limited information we have. We don’t have thousands of samples done by it, but what we have it’s very, very clear-cut answers.

Cindy: Well, it sounds-

Jyotsna: The specificity [inaudible 00:29:51] is very high as well, which has always been a question with western blots. That’s what I can tell you.

Cindy: You’re telling us an awful lot. And, I think that this has been an awesome interview, because this is something that people often think about, they don’t know if they should actually spend the money to do this because you don’t work with insurance companies.

Jyotsna: This is something we are working on. Hopefully, it’s going to work out. I am very, very concerned about that fact that we are not accepting insurance. But, we are trying to work if we can help patients put claims for them and get some money out of the network. So, we are trying to work that out to help the patients so at least they can get some of their money back.

Cindy: So, but they have to send their invoice into their insurance company.

Jyotsna: No, no, no, no. That’s what I’m trying to say.

Cindy: Okay.

Jyotsna: So, they would pay upfront to us because we’re still working the system out, and then we are going to provide a free service to all the patients that we will file it to the insurance. We file it for them.

Cindy: That’s so wonderful, yes.

Jyotsna: And, they just get the check directly. So, we’ve been working on this for a while, because that is one of the things that’s dear to my heart, that I really feel that patients, yes, our testing is expensive, I understand that. But, then what we are providing is just beyond what everybody else is, so it does take a lot of effort, and that’s why it’s little more expensive. But, how do we help the patient on the other side, is what we are trying to work out as well.

Cindy: Right. That is the bottom line.

Jyotsna: Right.

Cindy: I want to thank you again for coming on, and doing this recording, and telling us all about IGeneX Lab. And, I encourage people to talk with their doctors, to actually look up the information about IGeneX to know that is a better test than the general labs that are just from your area labs, per se. We’ve heard that data, we understand that it’s backed by research. So, again, thank you for visiting with us today.

Jyotsna: One more thing, can I just add one more thing?

Cindy: One more thing, go right ahead.

Jyotsna: Sorry. Okay, because one of the things people have been accusing us is that we are not publishing. But, we just published, our paper is coming out, which talks about the panel approach for … in that case we were doing western blots because up to now we have been doing western blots, and PCR, why it’s important. It should be out later this month.

Cindy: Okay, okay.

Jyotsna: So, that should help people and give an explanation to the physicians why they should do a panel approach for diagnosis of Lyme disease.

Cindy: Okay. All right. I think that’s an important fact. And, again, thank you for being with us and I hope you have a great day. All right?

Jyotsna: Okay. Thank you very much, Cindy.

Cindy: You’re welcome. You’ve been listening to Living with Lyme, and we have just had an excellent recording with Dr. Jyotsna Shah. And, if you’re listening to this and you’re enjoying it, please, visit our website at http://www.livingwithlyme.us. Subscribe to the podcast so that you can stay up to date whenever anything new is released. We have some great upcoming guests, and I encourage you to keep in touch. All right. Email me with any questions. I’d be happy to help you and answer those, too. Everybody, you have a good day and a good night. Take care, now.

____________

For more:  https://madisonarealymesupportgroup.com/2018/01/16/2-tier-lyme-testing-missed-85-7-of-patients-milford-hospital/

https://madisonarealymesupportgroup.com/2017/08/15/reliability-of-lyme-testing/

https://madisonarealymesupportgroup.com/2018/01/15/new-lyme-tests-could-offer-quicker-more-accurate-detection/

https://madisonarealymesupportgroup.com/2018/01/20/review-of-lyme-tests-how-to-diagnose-lyme-dr-marty-ross-llmd/

https://www.lymedisease.org/lyme-basics/lyme-disease/diagnosis/

https://madisonarealymesupportgroup.com/2016/12/07/igenex-presentation/

https://madisonarealymesupportgroup.com/2017/10/17/igenex-introduces-3-new-lyme-tests/

https://madisonarealymesupportgroup.com/2017/04/12/comparing-lyme-testing-with-hiv-testing/

 

Junk Science: Pertussis Vaccination in Pregnancy Study by Journal of Pediatrics

https://jameslyonsweiler.com/2018/03/13/its-that-bad-in-an-embarrassment-to-harvard-and-yale-journal-of-pediatrics-and-the-american-academy-of-pediatrics-publishes-another-great-example-of-junk-science-pertussis-vaccination-in-pre/

“It’s That Bad”: In an Embarrassment to Harvard and Yale, JOURNAL OF PEDIATRICS and the American Academy of Pediatrics Publishes Another Great Example of Junk Science – Pertussis Vaccination in Pregnancy

by James Lyons Weiler

I AM CALLING ON ALL OF MY COLLEAGUES AND FRIENDS AT UNIVERSITIES AND MEDICAL CENTERS IN THE US TO MOVE TO HAVE THEIR UNIVERSITIES DROP THEIR SUBSCRIPTIONS TO THE JOURNAL OF PEDIATRICS UNTIL THIS INCREDIBLY FAKE STUDY IS RETRACTED. I AM CALLING ON ALL STATE UNIVERSITIES TO DO THE SAME.

You would think now that they know that the public knows that they cook vaccine safety studies, and how they do it, the people from

Immunization Safety Office, Centers for Disease Control and Prevention, Atlanta, Georgia; HealthPartners Institute, Minneapolis, Minnesota; Department of Obstetrics, Gynecology, and Reproductive Sciences, Yale School of Medicine, Yale University, New Haven, Connecticut; Kaiser Permanente Washington Health Research Institute, Seattle, Washington; Division of Research, Kaiser Permanente of Northern California, Oakland, California; Center for Health Research, Kaiser Permanente Northwest, Portland, Oregon; Marshfield Clinic Research Institute, Marshfield, Wisconsin; Department of Research and Evaluation, Kaiser Permanente Southern California, Pasadena, California; Department of Population Medicine, Harvard Medical School and Harvard Pilgrim Health Care Institute, Boston, Massachusetts; and Institute for Health Research, Kaiser Permanente Colorado, Denver, Colorado

who conducted the latest study to attempt to convince the public that TdaP vaccination during pregnancy is safe would try to either do better science, or better hide their bad science.

Nope.

Instead, they stuck w/the tried and true formula: use covariates as confounders, exclude bad outcomes, do not measure fetal deaths…

Here’s the garbage study: Infant Hospitalizations and Mortality After Maternal Vaccination:  http://pediatrics.aappublications.org/content/pediatrics/early/2018/02/16/peds.2017-3310.full.pdf

You won’t believe this.

I’ll start with excluding bad outcomes:

“We also excluded infants of multiple gestation pregnancies…”

NO REASON GIVEN – AND WOMEN W/MULTIPLES WILL SURELY STILL BE VACCINATED (TRANSLATIONAL FAILURE)

“infants born before 34 weeks’ gestation…”

OK. STOP. REALLY. PRE-TERM BIRTHS ARE A VERY SERIOUS CONCERN. WHAT IF TDAP USE IN PREGNANCY CAUSES PRE-TERM BIRTHS??? I’m sure pregnant women would like to know. IT GETS WORSE:

“…and infants with major birth defects because these infants are at a higher risk of hospitalization and death.”

WHA? WHAT?? INFANTS WITH MAJOR BIRTH DEFECTS??? THAT’S THE F*CKING POINT OF THE STUDY!!!! OH, AND THEY WERE JUST GETTING STARTED:

“Furthermore, we excluded all infants who died during their delivery hospitalization because cause of death in these infants is often…” [YOU HAVE THE RECORDS, HOW OFTEN??] – BUT WAIT –

‘…a perinatal complication (such as placental abruption) that would likely be unrelated to maternal vaccination”….

I’M GOING FOR MY PITCHFORK ABOUT NOW. WE KNOW THAT ISSUES WITH THE PLACENTA EXIST DUE TO PROBLEMS WITH THE UNFOLDED PROTEIN RESPONSE AND ER-STRESS, but that’s only part of the issue…

THIS IS NOT SCIENCE. CIRCULAR REASONING RULES. VACCINES ARE SAFE, SO LET’S NOT DO A VACCINATED VS. UNVACCINATED. VACCINES ARE SAFE, SO LET’S IGNORE THE DATA THAT WE HAVE ALREADY COLLECTED TO DETERMINE IF VACCINES ARE SAFE – BECAUSE VACCINES ARE SAFE.

“Additionally, infants who die during the birth hospitalization may be less likely to be enrolled in the VSD and captured in our data.”

WELL, THEN WE HAVE A PROBLEM WITH VACCINE ADVERSE EVENTS REPORTING THEN, DON’T WE???

AND THEN THIS GEM:

We also excluded infants with external causes of death (International Classification of Diseases, 10th Revision [ICD-10] codes S00-T98 and V00-Y98) and infants with external causes of hospitalizations (International Classification of Diseases, Ninth Revision [ICD-9] codes 800-999, E800-E999) due to injury and poisonings because these are unlikely to result from a maternal vaccination. ICD-10 coding was not available for hospitalization diagnoses in the United States during the time of this study.

WAIT, YOU HAD ICD-10 FOR EXTERNAL CAUSES OF DEATH, BUT YOU LOST THE BOOK FOR ‘HOSPITALIZATION DIAGNOSES’???

LOOK AT THE FIGURE, THEY ALSO EXCLUDED CASES THAT HAD MULTIPLE VACCINES. YOU CAN BET THEY WON’T NOT GIVE MULTIPLE VACCINES TO PREGNANT WOMEN (TRANSLATIONAL FAILURE).

They also excluded >16,000 who had no prenatal care. Why exclude them? Oh, they didn’t take folic acid, and were not exposed to pertussis by health care workers who are silent carriers because they vaccinate against pertussis every 10 years.

THEY EXCLUDED THE UNVACCINATED.

junk

THIS IS HARVARD? THIS IS YALE?? They should ask their faculty with their names on this garbage to request that the ‘study’ be withdrawn.

But, not to worry. The exclusion criteria were approved by…

THE US CDC.

And I never even got to the over-correction (model over-fit) and use of covariates as confounders. What’s the point?

If I were a pregnant woman, and I was offered Tdap or influenza, I’d get up and leave and find another ob/gyn. Or I’d home birth. Yikes.

And I’d leave a copy of this blog article for them.

JUNK SCIENCE KILLS.

No apologies for yelling or profanity. CDC, just stop. You’re hurting people.

JLW, allison park, pa Tuesday, March 13, 2018

 

 

Lyme Interrupted: Our Stories

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Created by Lyme Interrupted

“In the fullness of time, the mainstream handling of chronic Lyme disease will be viewed as one of the most shameful episodes in the history of medicine because elements of academic medicine, elements of government and virtually the entire insurance industry have colluded to deny a disease.
This has resulted in needless suffering of many individuals who deteriorate and sometimes die for lack of timely application of treatment or denial of treatment beyond some arbitrary duration.”  Kenneth B. Liegner, M.D.”

 

Today is the Deadline to Comment on Regulation for Homeopathy

https://articles.mercola.com/sites/articles/archive/2018/03/06/regulation-on-homeopathic-medicines

Critique of Proposed Regulations of Homeopathic Medicines and Alternative Proposals

homeopathic remedies

Story at-a-glance

  • At a time in history when governments are reducing regulations, the Food and Drug Administration (FDA) is planning to increase its regulation on homeopathic medicines, despite their longtime history of being the safest medicines presently available
  • The FDA is planning to nullify its previously established guidelines on the regulation of homeopathic medicines and replace them with a risk/benefit analysis that will increase the enforcement of homeopathic medicines that it deems to have a “higher risk” of danger
  • The FDA claims that certain homeopathic medicines have been “associated with” an increased number of side effects and a small number of deaths, though, to date, no homeopathic medicines have been proven to contain toxic amounts of a drug ingredient
  • The FDA is proposing an increase in regulation of homeopathic medicines sold to “vulnerable” populations, such as pregnant women, infants, children and the elderly, even though the 200-plus years’ remarkable history of safety makes the use of homeopathic medicines to be a preferred method of treatment for these groups of people

By Dana Ullman, MPH, CCH

In December 2017, the U.S. Food and Drug Administration (FDA) announced their interest in protecting consumers from “potentially harmful, unproven homeopathic drugs.”1 The FDA is proposing to nullify its previous guidelines by which homeopathic medicines can be marketed. Instead, the FDA would deem all homeopathic medicines to be “unapproved new drugs,” which would make them subject to enforcement based on the perceived “risk/benefit” of a specific drug.

Some legal analysts and health writers initially wondered if the FDA’s proposed guidelines would mean that homeopathic medicines may become “illegal,”2 but the FDA has assured the American public that the agency doesn’t plan to begin requiring that homeopathic products get “drug” approval. Janet Woodcock, director of the FDA’s Center for Drug Evaluation and Research, told reporters during a teleconference that many homeopathic medicines will not be considered “high risk” and will still be available to consumers.3

However, Woodcock asserted that the FDA would “go after” homeopathic medicines that “cause or might cause” overt harm. The homeopathic community supports the FDA in its efforts to increase the safest possible use of all types of drugs, including homeopathic medicines, but homeopaths and others question the logic of going after homeopathic medicines that “might cause” harm.

The FDA does not have a history of going after any Big Pharma company on the grounds that a drug “might” cause problems (some potential problems of the FDA prohibiting access to certain homeopathic medicines based on theoretical grounds are discussed later in this article). The previous FDA guidelines have been in use since 1988, and these guidelines provide specificity as to how homeopathic medicines can be marketed and sold.

In contrast, the new guidelines seem to allow the FDA to provide enforcement based on a vague and undefined “risk/benefit” that could change from one year or decade to another. Further, homeopathic medicines have an impressive record of safety, with relatively rare exceptions.

In this light, every rational and reasonably educated person should and must wonder what the motivations are behind the FDA’s interest in increased regulation of homeopathic medicine especially since these natural medicines are recognized worldwide as some of the safest medicines presently available.

Regulating Homeopathic Medicines Should Be at the Bottom of FDA’s Priorities

Risk-based regulations make sense as a means to use limited governmental resources to help regulate access to medicines. However, homeopathy’s long-established reputation of safety far surpasses that of conventional drugs, and there is strong historical and worldwide evidence of this fact, let alone solid scientific evidence from modern toxicology.

Therefore, in light of “risk-based” assessment, the regulation of and the enforcement of regulations for homeopathic medicines should be at the very bottom of the FDA’s priorities, except in the rare instances where:

  • Homeopathic medicines are being marketed for serious diseases
  • They are not diluted to safe levels of an ingredient as determined by the most up-to-date evidence from toxicology
  • Evidence exists of real fraud in their manufacture or marketing

Because of the FDA’s commitment to “risk-based” approach to regulation, the FDA should immediately stop this change in regulations on homeopathic medicines until and unless it is determined that specific products are a real danger to public health. There are instances where homeopathic medicines do pose some type of minor risk, but such instances are rare and usually so mild that it’s confusing that the FDA has made an issue of it.

A small number of Americans have reported instances of health problems that “may” have been caused by a homeopathic medicine, but despite some media claims about homeopathic teething tablets, there has not been to date a single instance in which toxic or dangerous amounts of a medicinal agent were found in these tablets. Although the FDA did report that they found “variable amounts” of belladonna alkaloids in the teething tablets,4 the amounts found were well within safe limits, even if an infant swallowed an entire bottle.

Further, as discussed in more detail later in this document, the common potato has more belladonna alkaloids in it than any homeopathic medicine on the market today. At a time when many regulations are being questioned and reduced, it is a bit odd that the FDA is choosing to significantly increase the regulation of homeopathic medicines, despite their 200-plus years’ history of safety.

When we consider the serious problems related to drug use, it would seem that there are many other much more serious problems facing the American public:

  • The opioid crisis
  • The overuse of antibiotics
  • The epidemic of polypharmacy (the use of many drugs concurrently)
  • The ineffectiveness and real dangers of many prescription drugs
  • The high costs of select drugs

These items can and should be the primary focus of public health agencies and regulatory forces. By tricking people through misdirection by drawing the public’s attention somewhere else, the magician is able to fool the audience. Likewise, the FDA is presenting itself to the American public like a clever magician, trying to draw the attention of the consumer to the “dangers” of homeopathic medicines while it ignores the much more dangerous conventional medications.

The FDA will create a major public relations problem if it chooses to drastically change the regulatory status of homeopathic medicines and will lead to a serious credibility problem for the FDA. Although the FDA doesn’t care about popularity contests, if it is more interested in improving access to safe medicinal agents, regulatory actions on the world’s safest (homeopathic) medicines will instead suggest to the world that there are other concerns that play a larger role than safety issues.

The FDA asserts that new regulation is necessary because homeopathic medicine is now such a “large” industry in the U.S., with sales amounting to $2.9 billion yearly. A more precise calculation suggests that the true figure is less than half this amount. In any case, both the real and inflated estimates still represent less than 1 percent of overall drug sales in the U.S., which are estimated to be $446 billion.5

The Strong Safety Evidence for Homeopathic Medicines

Even homeopathy’s strongest critics acknowledge that these medicines provide too low a dose to have a significant physiological effect, let alone a toxic one. Therefore, it simply cannot be true that homeopathic medicines have no physiological effect and yet are somehow toxic. Clearly, whoever is making these determinations is doing so based on factors other than good science or good public policy. The World Health Organization (WHO) published a special report, “Safety Issues in the Preparation of Homeopathic Medicines,” in 2009.

On page 1, it asserts: “Adverse events occurring during homeopathic treatment are rarely attributed to the homeopathic medicine itself.”6 Further, a detailed review of homeopathic medicines conducted by a group of physicians and public health officials in Tuscany, Italy, found a remarkably high level of safety.7 They asserted that “because minimum doses are used (in homeopathic medicines), they could also be suitable for pregnant women, newborns and children.”

Therefore, when the FDA recently expressed concern about the safety of homeopathic medicines, especially for certain “vulnerable populations including pregnant women, infants and the elderly,” it is precisely these groups of people for which homeopathic medicines provide decreased risk of safety problems, as compared with conventional medications.

Based on 200 years of a high level of safety in the usage of homeopathic medicines, it would seem that the FDA should be promoting and encouraging the use of these medicinal agents for these vulnerable populations.

This comprehensive report from Italy made reference to a review of adverse effects from homeopathic medicines, saying, “A survey containing data from 1970 to 1995 reported a higher incidence of adverse effects with homeopathic medicines as compared to placebo. However, these effects were mild and transient, leading the authors to conclude that highly diluted homeopathic drugs prescribed by medical doctors specialized in homeopathy are safe.”8

The fact that some homeopathic medicines contain belladonna, nux vomica, arsenic or other known poisons is meaningless because every toxicologist and scientist today understands that the dose of a substance determines whether it is dangerous or not.

Modern sophisticated technologies can measure infinitesimal amounts of various substances in medicines and our environment. Serious scientists know that these substances are worthy of public health concern only at levels where they are known to cause specific problems.

Homeopathic practitioners, patients and manufacturers support the FDA in its efforts to improve the already stellar reputation that homeopathic medicines have for safety concerns. At the same time, we do not support the FDA’s efforts to reduce access to these basically safe natural medicines, since there is inadequate compelling evidence to date that they pose real risks.

This report to the FDA will question the veracity of some of the underlying assumptions behind the FDA’s desire to make significant changes in its regulation of homeopathic medicines. However, before getting into this issue, it is important to acknowledge the good working relationship that the FDA has traditionally had with homeopathic medicine.

The History of the FDA’s Good and Healthy Relationship With Homeopathic Medicines

Homeopathic medicines have been an integral part of the FDA’s purview since 1938, when Sen. Royal Copeland of New York sponsored the famous consumer rights legislation, called the Federal Food, Drug and Cosmetic Act (FDCA), which empowered the FDA to regulate drugs. Royal Copeland was not simply a senator, he was also a medical doctor and a homeopathic physician. His efforts to empower the FDA have led to safer drugs and improved public health.

Just as medical historians acknowledge that homeopathic medicine provided appropriate critique of 19th century medicine, medical historians will thank homeopaths again for providing appropriate critique of 21st century medical care.

As Mark Twain noted in Harper’s Bazaar back in 1890,

“The introduction of homeopathy forced the old-school doctor to stir around and learn something of a rational nature about his business. You may honestly feel grateful that homeopathy survived the attempts of the allopaths (conventional physicians) to destroy it.”

The FDCA gave separate recognition to the Homeopathic Pharmacopoeia of the United States, as distinct from the United States Pharmacopeia National Formulary or the conventional U.S. Pharmacopeia, for a reason: Homeopathic drugs are not just “additional” drugs available to the public, but represent a different system of making and using medicinal agents.

If the intent had been to regulate all drugs in the same way, the FDCA would have recognized one united compendium of drugs — but this was not the intent of this important work of legislation.

The Need for Homeopathic Medicines Today and Scientific Evidence That Verifies the Benefits

Opiate Drugs

The U.S. Centers for Disease Control and Prevention (CDC) recently announced that for the first time, U.S. life expectancy has declined for the second year in a row. The primary reason for this, according to the CDC, was increased deaths from drug overdoses from various pain medications.9

Ironically, a large study conducted in France and published in a conventional pharmacology journal specializing in drug safety showed that patients with chronic musculoskeletal disorders used 50 percent less conventional pain medication when under the care of a homeopathic physician.10

Good evidence published in leading medical journals has shown benefit from homeopathic treatment of fibromyalgia, a musculoskeletal syndrome for which opiate drugs provide little benefit. The BMJ published a double-blind, crossover study showing efficacy from a homeopathic medicine called Rhus toxicodendron,11 and these results were so substantially significant that the difference in benefit between subjects given a homeopathic medicine and a placebo were P=0.005.

Further, the journal Rheumatology published an additional study that found that 50 percent of patients given a homeopathic medicine experienced a 25 percent or greater improvement in tender point pain on examination. For comparison, only 15 percent of those who were given a placebo experienced a similar degree of improvement (P=0.008).12 

Further scientific evidence for the usage of homeopathic medicine in various pain syndromes was published in the American Association for Pain Management’s textbook, “Weiner’s Pain Management.”13

If the FDA, other regulatory agencies, and health and medical organizations are sincere in their concern about the overuse of opiate drugs in today’s health care, then these regulatory agencies and medical organizations should encourage the increase in health care and medical professionals who are trained to use homeopathic medicines.

This assertion is not to imply that homeopathic medicines should be the primary or only method of treatment for pain management but, instead, to simply include it as a part of a comprehensive strategy for this common health concern.

Antibiotics

Today’s excessive use of antibiotics has created new public health problems, and virtually every regulatory agency, medical organization and public health advocacy group is seeking ways to rely less upon antibiotics. The journal Pediatrics published an important randomized, double-blind, placebo-controlled study on children suffering from diarrhea.14

Although diarrhea is not a serious problem in the U.S., the World Health Organization considers it one of the most serious public health problems, because several million children die each year from the dehydration it causes.15 The study showed that children prescribed a homeopathic medicine were significantly more likely to have their diarrhea resolved than those given a placebo.

Further, two studies in which different homeopathic practitioners treated children with diarrhea in two separate countries each also found that children prescribed homeopathic medicines had their health restored significantly faster than those given a placebo.16 Today, the most common reason that children in the U.S. go to a physician is for the treatment of an ear infection. A randomized double-blind, placebo-controlled study prescribed individualized homeopathic medicines or placebo to 75 children.17

There were 19.9 percent more treatment failures in children given a placebo. Diary scores showed a significant decrease in symptoms at 24 and 64 hours after treatment in favor of those given a homeopathic medicine. What was particularly impressive about these results was that improvement from homeopathic medicines occurred rapidly and within the first day. Hippocrates enjoined physicians to “First, do no harm.” Homeopathic and other safe, natural remedies are reasonable choices for methods that fulfill this dictum.

Respected Research Shows the Efficacy of Homeopathic Medicines

Research showing the efficacy of homeopathic medicines has been published in the most respected medical journals in the world, including The Lancet,18 BMJ19,20 (British Medical Journal), Chest (the publication of the American College of Chest Physicians),21 Pediatrics (publication of the American Academy of Pediatrics),22 Cancer (journal of the American Cancer Society),23 Journal of Clinical Oncology,24 Pediatrics Infectious Disease Journal (publication of the European Society of Pediatric Infectious Diseases),25 European Journal of Pediatrics (publication of the Swiss Society of Pediatrics and the Belgium Society of Pediatrics)26 and numerous others.

The newest review of homeopathic research published in Systematic Reviews27 confirmed a difference between the effects of homeopathic treatment and of placebo. In reviewing the “highest quality studies,” the researchers found that homeopathic patients were almost twice as likely to experience a therapeutic benefit as those given a placebo.

Further, in reviewing a total of 22 clinical trials, the homeopathic patients experienced greater than 50 percent likelihood to have benefited from the homeopathic treatment than those given a placebo. Perhaps one of the strongest statements in this article was the confirmation that four of the five leading previous systematic reviews of homeopathic research also found a benefit from homeopathic treatment over that of placebo:

“Five systematic reviews have examined the RCT research literature on homeopathy as a whole, including the broad spectrum of medical conditions that have been researched and by all forms of homeopathy: four of these ‘global’ systematic reviews reached the conclusion that, with important caveats, the homeopathic intervention probably differs from placebo.”

In addition to the above individual studies and the meta-analyses, the largest and most comprehensive review of basic sciences research (fundamental physico-chemical research, botanical studies, animal studies and in vitro studies with human cells) and clinical research ever sponsored by a governmental agency was in Switzerland.28 The Swiss report affirmed that homeopathic high-potencies seem to induce regulatory effects (e.g., balancing or normalizing effects) and specific changes in cells or living organisms.

The report also reported that 20 of the 22 systematic reviews of clinical research testing homeopathic medicines detected at least a trend in favor of homeopathy.

Because certain skeptics of homeopathy frequently assert misinformation about homeopathy by asserting that there is no good evidence that homeopathic medicines are effective, it is important, even vital, that regulatory agencies avoid relying upon partisan and biased evidence of homeopathy (additional analysis on misinformation on homeopathic research is provided below in the section on “Intellectual Dishonesty and Questionable Ethics from Skeptics of Homeopathy”).

Is There Really Evidence That Homeopathic Medicines Are Not Safe?

Admittedly, every system of healing has certain risks, though even homeopathy’s most severe skeptics assert that these medicines contain such small doses that they cannot be adequately therapeutic. Therefore, it is surprising to hear the claim that these extremely low-dose medicines can be toxic.

The FDA recently asserted that homeopathic teething tablets are dangerous due to the “variable” doses of the herb belladonna in this medicine, even though the 12X dose in the tablets would require a newborn infant to imbibe dozens of bottles in rapid succession to achieve a dose that “might” create minor symptoms.

Even at the highest level FDA found, this was still 1,000 times lower than the safe amount.29 Health Canada (the Canadian version of the FDA) has found these same homeopathic teething tablets to have no safety concerns.30

It may seem that the FDA chose to err on the side of caution when they recommended the withdrawal from the marketplace of Hyland’s Teething Tablets due to the possibility that they may lead to seizures, but as it will be shown below, the FDA seems to have overreacted. According to the FDA, one bottle of Hyland’s Teething Tablets that was found to have the highest amount of scopolamine (an alkaloid in belladonna) had approximately 299 nanograms of it, or .00029 milligrams.31

No other bottle was found to have this amount of this chemical, but even this dose is well within safe doses. Today, a commonly prescribed drug for motion sickness includes 0.075 mg of scopolamine for infants of 3 years of age,32 or the equivalent of over 250 bottles of this same Hyland’s Teething Tablets bottle! Further, seizures are not even listed as one of the common side effects of scopolamine. Instead, it is listed as one of the extremely rare side effects.

In fact, seizures are so rare from this chemical that it is much more likely that an infant will simply experience a random seizure from unknown reasons than it is for the infant to experience a seizure from this chemical. If exposure to alkaloids from belladonna were really an issue, the FDA would have to outlaw potatoes.

The nightshade family of plants (Solanaceae) includes both belladonna and potatoes. These plants possess a diverse range of alkaloid glucosides (alkaloids), such as tropanes (atropine) and hyoscine (scopolamine), as well as nicotine and solanine. Belladonna, for the most part, is a combination of atropine, hyoscyamine and hyoscine.

Targeted Homeopathic Medicine Safer Than Potatoes

An average russet potato of 300 grams (0.7 pounds) contains 7 parts per million of belladonna. The amount of belladonna and its alkaloids found in homeopathic teething tablets were in the parts per billion or trillion, making this homeopathic medicine considerably safer than potatoes!

The FDA’s press release also expressed safety concerns about a homeopathic medicine called nux vomica. Although nux vomica is a poisonous plant that contains strychnine, every scientist and toxicologist knows that the dose of a poison is critical in determining whether it is dangerous.

Sir William Osler (1849–1919), widely known as the “father of modern medicine,” considered “hope and nux vomica” to be the two most important treatments in his clinics33 — and the doses he used were considerably higher than any homeopathic doses available to the public today. It is disturbing that the FDA would consider reducing the availability of this medicine on “theoretical grounds,” because, as yet, there has not been a single report of a poisoning from homeopathic doses of nux vomica.

The FDA says it felt compelled to increase regulation of homeopathic medicines due to an increase in reports of problems to the National Poison Control Centers related to “homeopathic agents.” However, these reports combine “miscellaneous dietary supplements, herbs, homeopathic and homeopathic agents,” with no differentiation.

To make matters worse, many consumers are confused by the term “homeopathic” and often assume that herbal remedies and other types of supplements are “homeopathic” when this is not always true.

The reports from the National Poison Control Centers provide no assurance that any legally defined homeopathic drug was included in the term “homeopathic agents.” The term is not used by consumers or clinicians and may have become a generic category for whatever the consumer or the survey giver could not assign elsewhere. Although it seems that the term “homeopathic agents” was meant to include just “homeopathic drugs,” only one death and three “major” outcome problems occurred.

And due to the fact that these reports do not provide any further details about which homeopathic medicine was involved in these incidences, it cannot be assured that the medicines involved were truly “homeopathic” or not. In the National Poison Control Centers reports from 2010 to 2013 for “homeopathic agents,” two years (2011 and 2013) report no deaths.

A longer period would be more representative. What about 10 years? In the other two years, a “self-claimed homeopath” gave his wife hydrogen peroxide (2010), which is not a homeopathic remedy, and one death was reported without any details (2012).34 The number of “major” outcome problems during the same period averaged 2.5 annually, indicating that any problems “homeopathic agents” caused were rare.

The Significant Limitations on FDA Adverse Events Data

In 2017, the FDA forced Hyland’s to take their teething tablets off the market. Despite the fact that these tablets have been in the marketplace for almost a century, with a stellar record of safety, in the past decade the FDA has recorded an increase in “adverse events” associated with this medicine. From 2006 to 2009, the FDA received just four records of complaints associated with Hyland’s Teething Tablets.

However, from 2010 to 2017, 633 such complaints (or 79 per year, on average) were lodged. Further, some media reported that there were 10 deaths associated with this homeopathic medicine,35 but this assertion has been proven to be false. The FDA’s website noted nanodose levels of a belladonna chemical called scopolamine,36 and yet the U.S. government’s own database for toxic substances reports that “there are no reported fatal doses for scopolamine.”37

The reports include a disclaimer: “Submission of a safety report does not constitute an admission that medical personnel, user facility, importer, distributor, manufacturer or product caused or contributed to the event. The information in these reports has not been scientifically or otherwise verified as to a cause and effect relationship and cannot be used to estimate the incidence of these events.”

Even more problematic is how the media misrepresents this information from the reporting by citizens on their experiences with various drugs. For instance, one report on the death of an infant included a note saying, “Death did not occur, box needed to be checked to proceed.”

One mother complained about her baby having “dry skin,” though she admitted it “may be due to solid food (oatmeal).” Another baby ingested one-quarter of a bottle of teething tablets and then, two days later, the baby experienced “difficulty breathing,” to which a doctor diagnosed as “croup” (a condition for which belladonna isn’t known to cause).

In some cases, the infant was taking conventional pharmaceuticals in addition to the teething product or had been recently vaccinated. It appears that if the report includes a teething product, the FDA considers that part of the evidence against it, even if something else is more likely to have caused the problem.

Some of the reports against Hyland’s Teething Tablets included reference to a parent giving the infant Orajel Baby Teething Gel, which is not homeopathic and includes propylene glycol, a chemical used in brake and radiator fluids. Opinions differ as to its toxicity.

Priorities for FDA Enforcement

The FDA says it has no intention of outlawing homeopathic medicines but claims that it wants to reduce potential problems arising from them. The agency claims that it plans to develop “a new, risk-based enforcement approach to homeopathic drug products that have the greatest potential to cause risk to patients.” The FDA asserts that they wish to align “risk-based” assessments of all types of drugs, to protect the public.

If the FDA’s concerns about “risk assessment” are real, then the vast majority of homeopathic medicines will not undergo any new regulation that will make them unavailable to the general public, as the vast majority of homeopathic medicines are substantially safer than conventional drugs.

For example, it is illegal to jaywalk, and it is illegal to drive a car while drunk. If law enforcement chose to enforce jaywalking vigorously, it wouldn’t have the time or resources to enforce drunken driving. Obviously, there is much greater risk to have drunk drivers than jaywalkers.

That said, there can and must always be exceptions. At rare times, there may be jaywalkers who choose to take exceptional risks in traffic and who create potentially dangerous situations for others. It is obvious where the FDA needs to place its enforcement priorities. The FDA asserts that it intends to focus its new enforcement priorities on the following kinds of homeopathic products38 It will be helpful, therefore, to review each of the above categories individually.

Products with reported safety concerns Products that contain or claim to contain ingredients associated with potentially significant safety concerns
Products for routes of administration other than oral and topical Products intended to be used for the prevention or treatment of serious and/or life-threatening diseases and conditions
Products for vulnerable populations Products that do not meet standards of quality, strength or purity as required under the law

Products with reported safety concerns.

If a homeopathic medicine is reported to have safety concerns, it is reasonable for the FDA to investigate them. However, because some safety concerns are false, imaginary or the result of antagonists to homeopathy, the FDA should explore: 1) what the modern literature from toxicology suggests are and aren’t safe doses; and 2) whether similar safety concerns occur in other countries.

For example, Hyland’s Homeopathic Teething Tablets were reported in the U.S. to potentially cause seizures in children. These same teething tablets were sold in Canada with no such reports.39

Products that contain or claim to contain ingredients associated with potentially significant safety concerns.

  • An infectious agent with the potential to be pathogenic;
  • A controlled substance, as defined in the Controlled Substances Act, 21 U.S.C. 812;
  • Multiple ingredients that, when used in combination, raise safety concerns due to possible interactions, synergistic effects or additive effects of the various ingredients; and,
  • Ingredients that pose potential toxic effects, particularly when those ingredients are concentrated or in low dilution presentations (e.g., 1X, 2X or 1C) or are not adequately controlled in the manufacturing process.

Below are comments about safety concerns of homeopathic medicines in the above categories:

The FDA is claiming homeopathic medicines that contain ingredients of an infectious agent pose a safety risk. The FDA here is referring to what are called “homeopathic nosodes,” that is, homeopathic medicines made from bodily tissue or fluids that contain bacteria or viruses. Nosodes are generally available in high dilutions, where the dose is so small that it is not known to have toxicological or infectious effects.

Most nosodes in the U.S. are available only to homeopathic health and medical professionals, because most of the nosodes are intended for more complex health and medical conditions, for which an OTC (over-the-counter) drug is not indicated.

A small number of nosodes, however, are known to treat OTC conditions and to help reduce the severity and duration of common and relatively minor ailments. Therefore, it makes sense to maintain the present status of homeopathic nosodes as those remedies that are available only to certain licensed health and medical professionals as well as those who are certified or licensed to practice homeopathy.

In 2016, Hahnemann Laboratories provided testimony at an FTC hearing on homeopathic medicines. This testimony affirmed the safety of homeopathic medicines, asserting that “the FDA has never received an Adverse Event Report for a classical single remedy oral use homeopathic product with a ‘safe’ dilution level of 6C (one part per trillion) or more.”40

The FDA already does not allow homeopathic medicines to be made from substances defined in the Controlled Substances Act. This includes those that have a high potential for abuse, have no currently accepted medical use for treatment in the U.S. or for which accepted safety protocols for use under medical supervision do not exist.

Some of the substances to which this act refers include heroin, morphine, psilocybin, cannabis and peyote.41There is no real logic to making homeopathic doses of these substances illegal to professional homeopaths whose patients would sometimes benefit therapeutically when a patient had overdosed or simply became ill after abusing crude doses of these drugs. In this instance, the FDA should consider changing its position that disallows homeopathic doses of Schedule I drugs.

There is no evidence that multiple ingredients of the nanodoses used in homeopathic medicines have safety concerns. And because there is greater use and sale of multiple-ingredient homeopathic medicines than single-ingredient, one would expect more evidence of problems from such medicines, and this evidence simply doesn’t exist.

Unless the FDA can provide adequate evidence that a combination of ingredients in homeopathic doses pose actual danger, it should not prohibit the marketing or sale of homeopathic formula products, except in the marketing for conditions of serious ailments (which OTC drugs are not allowed to do anyway).

The homeopathic community has collaborated with the FDA and with scientists who specialize in toxicology to determine at what dose a plant, mineral, animal or biological medicine is no longer safe. The homeopathic community has no problem reducing access to doses that pose safety risks, but such restrictions must not be just theoretical. Toxicological science must verify such risks, not politics or economics. Present FDA regulations already incorporate this determination.

Products for routes of administration other than oral and topical.

The vast majority of homeopathic medicines are oral and topical, though homeopathic eye drops (for acute eye conditions of an OTC nature) and nasal sprays (for acute nasal ailments, including the common cold or respiratory allergies) are occasionally employed. Historical usage supports both means of dispensing homeopathic medicines. In fact, Dr. Samuel Hahnemann, the founder of homeopathic medicine, sometimes encouraged patients to simply sniff an alcoholic solution of a homeopathic medicine.

In recent times, Zicam (a homeopathic medicine for symptoms of a common cold) uses a cotton swab-like device inserted into the nose. This application of a homeopathic medicine is new and does not have a record of historic usage. Because this means of application is not a time-tested method of administrating homeopathic medicines, it may be reasonable for the FDA to deem this type of dispensing a “new drug.”

Products intended to be used for the prevention or treatment of serious and/or life-threatening diseases and conditions.

Homeopathic medicines sold to consumers are, by definition, over-the-counter drugs and, as such, should be marketed only for “over-the-counter ailments,” — that is, ailments that do not require a medical diagnosis, are not life-threatening and are basically self-limiting.

To date, none of the leading established homeopathic manufacturers make or market OTC homeopathic medicines for “serious diseases” and, in fact, homeopathic manufacturers support the FDA in its efforts to crack down on individuals or companies that make or market homeopathic medicines for heart disease, cancer, diabetes or any other life-threatening disease.

Products for vulnerable populations.

There is certain logic in reducing the availability of potentially dangerous drugs to vulnerable populations. However, due to homeopathy’s longtime impressive safety record, these medicines can be used by vulnerable populations. Pregnant and lactating women, infants and children are ideal populations for such usage. In fact, historically and internationally, these vulnerable populations have benefited from having access to homeopathic medicines due to the products’ high level of safety.

It is common for parents to use homeopathic medicines for their infants and children for minor health problems, and it is essential that parents maintain access to homeopathic medicines for such nonserious and non-life-threatening ailments. Parents experience much higher risks with virtually any conventional medication than with homeopathic ones.

Products that do not meet standards of quality, strength or purity as required under the law.

Present FDA regulations allow for enforcement of standards of quality, strength and purity. However, modern technologies can measure exceedingly small variations in these factors. In a recent action on homeopathic teething tablets, the FDA found “variable amounts” of a listed ingredient, belladonna.

However, what the FDA did not report was that the variable amount was still in the safe range, with a vast margin of error. Therefore, it is prudent for the FDA to only consider enforcement of these standards when the public’s safety is seriously threatened.

Suggestions for Regulating Homeopathic Medicines

In 1988, the FDA adopted CPG 400.400 to eliminate the confusion over what could and could not be sold as a homeopathic drug. The recent FDA guidelines seek to eliminate this guidance and replace it with vague guidelines that will create confusion for the homeopathic industry and for consumers. It makes more sense to maintain the CPG 400. 400 guidelines and to simply add more specificity to them rather than abolish them.
In some European countries, a medicinal agent can only be considered homeopathic if it is in at least a 3X dilution. A change in this definition would help differentiate herbal doses from homeopathic ones. Further, this change in regulation would make it more difficult for new medicinal agents to be marketed under the “homeopathic” banner that tend to work by conventional pharmacological means.
The FDA could make it clear to manufacturers and consumers that a homeopathic ingredient cannot be mixed with a nutritional supplement (which the FDA deems to be a “food”). Such “formulas” would constitute mixing a “drug” and a “food.” As I understand it, present FDA regulation already doesn’t allow mixing drugs and foods.
The new FDA guidelines are exploring whether to prohibit the marketing of mixed-ingredient homeopathic medicines. These “homeopathic formula products” have a long history of usage and safety throughout the world, and studies have found them effective for many conditions, especially respiratory allergies.

For example, a randomized, double-blind and placebo-controlled trial has been published in the Lancet42 in the treatment of people with hay fever and a high-quality study published in the British Medical Journal43 confirmed homeopathic doses of various allergens were found effective for respiratory allergies to that allergen.

The small group of homeopathic medicines made from diseased tissue, bacteria or viruses are called “nosodes” and, at present, the vast majority of them are available only by prescription by certain health and medical professionals. No new regulation of homeopathic nosodes is necessary unless the FDA has some new toxicological or epidemiological evidence.

Most single-ingredient homeopathic medicines are regulated as over-the-counter drugs and, as such, the FDA requires that manufacturers list a specific ailment for which each drug is indicated.

Because single-ingredient recommendations are based on a pattern of symptoms, not a specific disease diagnosis, it behooves the FDA to consider withdrawing the requirement for an “indication for treatment” for single-ingredient homeopathic drugs, except when adequate research confirms the efficacy of that homeopathic medicine.

FDA guidelines do not allow the sale and marketing of homeopathic medicines made from controlled substances, such as opium, heroin or (still) cannabis sativa (or indica). These guidelines have been enforced for several decades, even though it is a somewhat ludicrous regulation due to the obvious fact that no one can or does use homeopathic doses of these drugs in recreational ways. Therefore, the FDA should rescind this regulation.
Even if an extremely small number of people may be hypersensitive to exceedingly small doses of a medicinal agent in a homeopathic medicine, our society doesn’t outlaw common foods that are known allergens (milk, peanuts, wheat, strawberries), nor does it make them available only upon prescription by a physician, even though some can cause significant distress, anaphylactic shock or death.

Therefore, the remote possibility that this might occur does not justify restricting the availability of homeopathic medicines that benefit many others.

Intellectual Dishonesty and Questionable Ethics From Skeptics of Homeopathy

Pulitzer Prize–winning author Paul Starr, in his book “The Social Transformation of American Medicine: The Rise of a Sovereign Profession and the Making of a Vast Industry,” acknowledged that homeopathic medicine in the 19th century was a medical, scientific and economic threat to conventional medicine. Starr even asserted, “Because homeopathy was simultaneously philosophical and experimental, it seemed to many people to be more rather than less scientific than orthodox medicine.”44

The American Medical Association (AMA) was founded in 1848, two years after the formation of the American Institute of Homeopathy. Starr notes that the AMA was founded, in part, to slow the growth of homeopathy. From 1860 to 1900, the AMA’s code of ethics prohibited AMA members from consulting or even socializing with medical doctors who practiced homeopathy.

This ethical code was one of the few that were ever enforced. An extreme example of this prejudice occurred on the night of Lincoln’s assassination. William Seward was one of Lincoln’s closest political advisers and an advocate for homeopathic medicine. On the night Lincoln was assassinated, Seward was stabbed in the multi-person assassination plot against the Union.

Thanks to the medical care provided by Dr. Joseph K. Barnes, U.S. Surgeon General, Seward survived. However, Seward’s personal physician was a homeopathic doctor, and due to the fact that the AMA had a policy that it was an ethical violation for conventional physicians to consult with a homeopathic doctor or even provide care for a homeopathic patient, Barnes was denounced by the AMA for providing medical care.45

Medical history shows that homeopathy gained its greatest popularity in Europe and America due to its impressive results during infectious disease epidemics, including typhoid, cholera, yellow fever, scarlet fever, pneumonia and influenza.46 A book titled “The Logic of Figures” compared the death rate from various infectious diseases in the 19th century in conventional versus homeopathic hospitals. The death rate in the conventional hospitals was between two and eight times greater.47

In 1855, a governmental report on the London cholera epidemic of 1854 “just happened” to omit the mortality figures of the London Homeopathic Hospital. This epidemic was made famous because Dr. John Snow took the matter into his own hands by removing the handle of the pump from which Londoners were getting their tainted water. Because the homeopathic hospital was the closest hospital to this pump, many people who developed cholera went there for treatment.

The mortality rate at this hospital was only 19 percent as compared with 33 percent to 53 percent at all other London hospitals. When the authors of this report were challenged in the House of Lords, a representative of the Board of Health disingenuously proclaimed that inclusion of these statistics would give “an unjustifiable sanction to the empirical practice alike opposed to the maintenance of truth and to the progress of science.”48

Intellectual Dishonesty Has Continued Into the 21st Century

In 2010, the U.K. House of Commons’ science and technology committee report on homeopathy was highly critical of this subject. However, any rational person should be suspicious of this “report.” The Science and Technology Committee normally consists of 14 members of Parliament, yet this report was approved and signed by only three members, with one vote against the report (most members of the committee did not take this investigation seriously).

Of the three votes in favor, two members were so newly appointed that they did not attend any of the hearings. The remaining “yes” vote was from Evan Harris, a medical doctor and devout antagonist to homeopathy. Ironically, shortly after this vote, Harris was voted out of office from a general election by a twenty-something-year-old candidate who had no previous political experience.

More recently, the Australian National Health and Medical Research Council (NHMRC) published a report on homeopathy that concluded there is “no reliable evidence that homeopathy is effective for any condition.”

However, the definition of “reliable evidence” was so high that only between 2 to 5 percent of conventional medical practices would be deemed to have reliable evidence, despite the billions of dollars on medical research conducted yearly (after reviewing over 3,000 treatments, the British Medical Journal only found 11 percent of medical treatments are “beneficial” IF the minimum reliable study size was just 20 patients; this number would be considerably less IF the minimum reliable study was 150 patients).49

Even more problematic about the Australian report was the fact that this governmental agency hid evidence of the existence of this first report. This previous review found homeopathic medicines effective. In other words, not only has there been “intellectual dishonesty” in the attacks on homeopathy but also serious breaches of ethics in evaluating it.50

Stifling Homeopathic Medicines Could Have Detrimental Effects

Brian Josephson, Ph.D., is a British physicist who won a Nobel Prize in Physics in 1973 for work he completed when he was only 22 years old. He is currently a professor at the University of Cambridge. Responding to an article in New Scientist, Josephson wrote:

“Regarding your comments on claims made for homeopathy: criticisms centered around the vanishingly small number of solute molecules present in a solution after it has been repeatedly diluted are beside the point, since advocates of homeopathic remedies attribute their effects not to molecules present in the water, but to modifications of the water’s structure.

Simple-minded analysis may suggest that water, being a fluid, cannot have a structure of the kind that such a picture would demand. But cases such as that of liquid crystals, which while flowing like an ordinary fluid can maintain an ordered structure over macroscopic distances, show the limitations of such ways of thinking. There have not, to the best of my knowledge, been any refutations of homeopathy that remain valid after this particular point is taken into account.

A related topic is the phenomenon, claimed by Jacques Benveniste’s colleague Yolène Thomas and by others to be well established experimentally, known as ‘memory of water.’ If valid, this would be of greater significance than homeopathy itself, and it attests to the limited vision of the modern scientific community that, far from hastening to test such claims, the only response has been to dismiss them out of hand.”51

Josephson’s remarks on the structure of water have been confirmed by more recent research.52 The American Chemistry Society’s journal, Langmuir, published a series of studies that confirmed using three different types of spectroscopy that nanodoses of six different homeopathic medicines persist in water solutions even after dilutions of 1-to-100, six times, 30 times and 200 times.

Of special importance, the dosages remaining in water were similar in size as doses to which our bodies’ hormones and cell-signaling agents are known to operate.53 Josephson went on to describe how many scientists today suffer from “pathological disbelief;” that is, they maintain an unscientific attitude that is embodied by the statement “even if it were true I wouldn’t believe it.”

Ultimately, homeopathic medicine is the “original nanopharmacology,”54 and any new regulations that stifle this important system of medicine just as new and strong evidence is emerging to verify its mechanism of action and its efficacy could have detrimental effects on the future of health and medical care. Because some of the testimony given to the FDA repeats a historic bias against homeopathy, it is important to understand the origins of this misinformation and not let it be accepted without verifiable evidence.

Closing Thoughts

Is America a pluralist society or a homogenous one — and should regulation reflect our society? This is not just an academic question but a practical one, and the way it is answered will play an important role in how the FDA should regulate homeopathic medicine (as well as other systems of healing).

The founding of the U.S. placed a special value on personal freedoms and cultural diversity. America was temporarily thought to be a “melting pot” country, but today, it is much more clear that we are a cultural mosaic or, if you will, a “salad bowl” with diverse ingredients, each with its own value.

Likewise, there has never been just one school of thought and practice in medicine and in healing, both historically and internationally. The appreciation for diversity in medicine and healing was canonized in the federal Food Drug and Cosmetic Act of 1938. This important legislation gave recognition to the Homeopathic Pharmacopeia of the United States as an equal, but different, body of medicinal agents to the U.S. Pharmacopeia.

The fact that U.S. law recognizes both of these compendiums of drugs means that there are two different standards for drugs in America. We are not a homogenized culture where there is just one school of thought and practice in medicine. We are a pluralist society and therefore need pluralist laws that respect this diversity.

In 1988, the FDA issued the Compliance Policy Act 400-400 titled Conditions Under Which Homeopathic Drugs May Be Marketed, and this document has established clear, measurable and enforceable standards for the manufacture and sale of homeopathic drugs in the U.S.

These guidelines contribute significantly to improving cost, quality and access to safe homeopathic drug products. There may be certain challenges to respecting different schools of thought and practice in medicine, but Thomas Jefferson, our third president, reminded us of the importance of American liberty and of the necessity to work to educate the population how to make the best of our freedoms. He said:

“I know no safe depository of the ultimate powers of the society but the people themselves; and if we think them not enlightened enough to exercise their control with a wholesome discretion, the remedy is not to take it from them, but to inform their discretion by education.”

Consumer Actions

1.The American Association of Homeopathic Pharmacists is encouraging those who live in certain states (Colorado, New Mexico, Pennsylvania, Tennessee, Washington, Utah) to urge their legislators to tell FDA not to scrap the current guidelines regarding the regulation of homeopathic products. These representatives work on committees that have oversight on the FDA. You are simply asked to sign your name to the letter.

You may wish to do one additional, simple thing and that is to add some type of personal statement about your experiences with the safety and efficacy of homeopathic medicines. Click HERE or HERE to access more information and to access your political representatives (please note that there are certain senators and other congresspersons to contact).

If you happen to have a personal relationship with any of the congresspersons who work on FDA issues, please consider contacting the American Association of Homeopathic Pharmacists (office@aahp.info).

2.The homeopathic community is NOT encouraging everyone to write to the FDA. Now is not the time to express fear about the FDA’s potential actions or to condemn them. Consider submitting short positive comments to the FDA in support of homeopathy.

You might tell the FDA that its current regulatory guidelines (Compliance Policy Guide 400.400) for homeopathic products provide much consumer protection and that any further changes place your right to choose in jeopardy. The period for public comment before FDA makes its final decisions about this important policy closes March 20, 2018. Click HERE to make your comment to the FDA.

3.Consider supporting homeopathic organizations, pharmacies and resource centers that work to provide useful, practical information about homeopathy so that you can optimize your usage of these natural medicines.

Becoming a member of the National Center for Homeopathy is particularly important because they will keep you informed about developments with the FDA and about future suggested actions to consider. For details, go to www.HomeopathyCenter.org. Put your wallet where your heart is and where your health is!

 

Dana Ullman, MPH, CCH, is one of America’s leading advocates for homeopathy. He has written 10 books, including, “The Homeopathic Revolution: Why Famous People and Cultural Heroes Choose Homeopathy” and the best-selling, “Everybody’s Guide to Homeopathic Medicines,” with Dr. Steven Cummings.

He is the founder of Homeopathic Educational Services (https://homeopathic.com/), a leading resource center for homeopathic books, tapes, medicines, software and correspondence courses. Ullman recently created an e-course on Learning to Use a Homeopathic Medicine Kit.