Archive for the ‘Treatment’ Category

The Agony of MCAS

https://www.lymedisease.org/lyme-sci-mcas-agony/

LYME SCI: The Agony of Mast Cell Activation Syndrome (MCAS)

Lonnie Marcum, March 2018

In the winter of 2016, my 17-year-old daughter was dying. She had severe allergic reactions every day, was in constant pain, and was losing weight at a rate that was not sustainable to life. She had reached the end of her rope, and I was completely out of ideas on where to turn for help.

Eighteen months earlier, after a long illness and finally completing treatment for Ehrlichia chaffeensis, Bartonella and Lyme disease, she had been doing great. Unfortunately, she soon caught the flu and then everything went south.

Over the next year, one setback after another landed her in the hospital every other month with atrial-fibrillation (irregular heartbeat) and/or near-anaphylaxis (acute allergic reactions). Each trip to the doctor took one more piece of hope away from us, since no one could pinpoint the cause of her rapid decline.

Over time, my daughter developed allergies to soaps, perfumes, juices, fruits, vegetables, and lunch meats. Eventually, she was down to only two foods that didn’t make her lips swell, mouth break out in blisters and throat tighten–sauteed chicken and brown rice noodles.

Not knowing what to do, I reached out in desperation to the “LymeParents” Yahoo group. Another mother recognized the symptoms I was describing as mast cell activation syndrome (MCAS) and connected me with Dr. Lawrence Afrin at University of Minnesota. Dr. Afrin consulted on my daughter’s case, then referred us to Dr. Mark Renneker, a mast cell specialist at the University of California, San Francisco.

Soon, she received a diagnosis of MCAS, and with it a path to healing.

Coincidentally, one month after my daughter’s diagnosis, I attended Dr. T.C. Theoharides’ lecture on mast cell activation at ILADS in Philadelphia. In his words:

Mast cells are the “universal alarm cell” that starts the inflammatory cascade. They can be triggered by infection, allergens, environmental factors like pollution, or even emotional stress. Once that happens, mast cells set into motion a series of inflammatory reactions, including the activation of immune cells and the release of tumor necrosis factor-alpha (TNF-a), a pro inflammatory protein or cytokine.

If you or a loved one are in a similar situation, here’s what you need to know.

The Diagnosis

MCAS is a clinical diagnosis based upon signs, symptoms and response to treatment. There are a number of tests available to confirm the diagnosis, but negative tests do not rule out MCAS.

(For a complete guide to the diagnosis of MCAS, click here:  https://jhoonline.biomedcentral.com/articles/10.1186/1756-8722-4-10)

Mast Cell Activation Diseases

Mast cells are a normal part of our immune system. They are located in every organ and connective tissue of the body. When mast cells detect stress, injury, toxins or infection, they release specific chemicals which trigger an immune response. Think of them as sentries or guards.

When mast cells perform properly, they are our friends. When mast cells are agitated or over-reactive, the immune system goes haywire and starts to attack the body, triggering auto-inflammatory processes or some types of autoimmune illnesses.

There are two major forms of mast cell activation diseases (MCAD)

  • Mastocytosis—the abnormal accumulation of mast cells in one or more organ systems (cardiovascular, central nervous, digestive, endocrine, genitourinary, lymphatic, muscular, peripheral nervous, respiratory) which is diagnosed by a bone marrow biopsy or a C-Kit genetic mutation.
  • Mast Cell Activation Syndromes—the inappropriate release of mast cell mediators including: histamine, interleukins, prostaglandins, cytokines, chemokines, and heparin.

As far back as 1999, researchers were able to demonstrate how Borrelia burgdorferi induces mast cell activation, contributing to greater illness in Lyme disease.  https://www.ncbi.nlm.nih.gov/pmc/articles/PMC96436/

Somehow, I feel this fact has remained under-appreciated until just recently.

(To view my previous blog on symptoms of MCAS, click here: https://www.lymedisease.org/mast-cell-activation-immune-system-goes-haywire/)

PTSD of the Immune System

When I describe my daughter’s condition to non-medical folks, I say it’s like her immune system has post-traumatic stress disorder (PTSD). After going a year with multiple untreated infections, her immune system was very depleted, and the combination of antibiotics she needed to fight her infections added additional stress. As she completed antibiotic treatment for her infections, we added supplements to boost her immune system and promote healing. Or so we thought.

Unbeknownst to her doctors and me, one of her prescription medications (ketotifen) contained lactose, which she is intolerant to. In addition, she had developed an allergy to microcrystalline cellulose (MCC), one of the most common fillers in prescription medications, vitamins and supplements. Eliminating these allergens was a major turning point in her healing.

Our Five Steps to Healing

Step 1 Reduce or eliminate mast cell triggers (common triggers)
  • Infection (bacteria, fungi, parasite, virus)
  • Insect bites (spiders, ticks, fleas, mosquitos, bed bugs)
  • Stress (heat, cold, fatigue, emotional stimuli)
  • Foods (dairy, fermented or aged foods, wheat, shell fish, sugar, preservatives)
  • Drugs (alcohol, hormones, antibiotics, anesthetics, opioids, aspirin, NSAIDS, excipients)
  • Dyes (food coloring, radiographic dyes, pigments in makeup)
  • Environmental toxins (pollen, dust, mold, animal dander, heavy metals, pesticides)
  • Noxious odors (perfumes, smoke, exhaust fumes, smog)

Step 2 Assemble the “A TEAM” (sample)

  • Physician knowledgeable about Lyme and other tick-borne diseases (treat infections)
  • Physician knowledgeable about mast cell activation syndrome (lower histamine, stabilize mast cells)
  • Psychotherapist (emotional support)
  • Physical therapist (modalities for pain, lymph drainage, home care instructions)
  • Doctor of Osteopathy (functional medicine, supportive hands-on therapy)

Step 3 Find the right combination of medications/supplements

Many people with mast cell issues will improve by taking antihistamines. Antihistamines are medications that block or inhibit the histamine receptors on mast cells and other cells found throughout the body.

Histamine is a unique chemical produced primarily by mast cells that causes inflammatory reactions and the itching feeling most of us are familiar with. Histamine also signals the immune system, regulates the digestive system, and acts as a neurotransmitter in the brain, spinal cord and uterus.

There are at least five different types of cells that respond to histamine (H1-H5 receptors) found throughout the body, although H1 and H2 appear to be the most common.

Antihistamines are classified by the type of receptor that they inhibit as listed below:

  • H1 blockers—act throughout the body (Allegra, Benadryl, Clarinex, Claritin, Silenor, Vistaril, Xyzal, Zyrtec, etc.) Note: Those that cause drowsiness cross into the brain.
  • H2 blockers—act mostly in the stomach (Pepcid, Prilosec, Tagamet, Zantac, etc.)
  • H3 blockers—act in the brain (Mostly experimental: Ciproxifan, Pitolisant)

Leukotrine inhibitors —act primarily in the airways (Accolate, Singular, Zyflo)

Mast-cell stabilizers—strengthen or stabilize the mast cell to reduce the release of histamine and other inflammatory chemicals (Cromolyn, Ketotifen, Hydroxyurea)

Tricyclic antidepressants—antidepressant that also sedate H1 receptors in the brain (Amitriptyline, Doxepin, Nortriptyline etc.)

Tyrosine kinase inhibitor—inhibits certain types of proteins that control a wide range of functions including cell growth (Imatinib)

Natural antihistamines and mast-cell stabilizers—natural supplements that act to block or clear histamine and stabilize mast cells (alpha lipoic acid, ascorbic acid, B6, diamine oxidase enzymes (DAO), luteolin, N-acetylcysteine (NAC), Omega-3’s, riboflavin, SAMe, quercetin, etc.)

Step 4 Customize Nutrition

Patients with certain genetic defects are more prone to MCAD. Looking into your genetics can help determine your predisposition to MCAD and/or histamine intolerance and help you design a customized nutrition plan.

Genetic defects related to MCAS:
  • KIT-D816V—KIT is a master regulator protein found on and in mast cells. A KIT mutation typically results in the mast cell being constantly activated. About 90% of patients with mastocytosis have a KIT-D816V mutation (there is a PCR test for this mutation).
  • MTHFR—The body makes several enzymes called MTHFR that are critical for the production of folate and many cellular functions. Patients with MTHFR defects may have an inability to clear histamine leading to MCAS and histamine intolerance.
  • HNMT—In the central nervous system, histamine is broken down by histamine methyltransferase (HNMT). Patients with a lot of HNMT defects will have trouble clearing histamine from the brain and nerves. Moodiness, sleep disturbance and frequent rashes or hives can be a sign of this.
  • ABPI—In the digestive tract, histamine is broken down by diamine oxidase enzymes (DAO). Defects in ABPI lead to lower levels of DAO and higher levels of histamine.
  • HLA—Variations in the HLA gene can increase the chances of gluten intolerance.
    VDR—VDR defects may lead to lower levels of Vitamin D, which is critical to immune health.
  • MAT—MAT gene is involved in the conversion of the amino acid methionine into SAMe. SAMe has 100s of critical functions throughout the body. If vitamin B12 makes you feel sick, you may have a lot of MAT defects. Your doctor can order blood work to check methionine and SAMe levels.

Nutrition

Genova Diagnostics, Tree of Life, Nutrahacker and Genetic Genie are the tools we used for my daughter. We also ran a complete vitamin and mineral panel to pinpoint nutrient deficiencies. Then, we designed a custom nutrition plan that was specific to her needs—I’ll describe it in detail in my next post.

Basic diet: Clean, fresh (nothing cured, processed or fermented), organic, gluten-free, dairy-free, dye-free, sugar-free, low-histamine, low-citrus, low-oxalate, low-nightshade.

Step 5 Stick to a Routine

Maintain the same sleep schedule
Maintain the same eating schedule
Maintain the same basic level of activity from day to day

Putting it all together

These steps may seem daunting. But when you are in a crisis like my daughter was, you are willing to go to extremes to get your life back. In my next post, I will share more details about what precisely we did.

Note: I am not a doctor. The information here represents my personal opinions and experiences. It is for informational purposes only—it is not intended to treat, diagnose, cure or prevent any disease.

LymeSci is written by Lonnie Marcum, a Licensed Physical Therapist and mother of a daughter with Lyme. Follow her on Twitter: @LonnieRhea Email her at: lmarcum@lymedisease.org .

References:

Mast cell activation disease: a concise practical guide for diagnostic workup and therapeutic options.

Full List of Publications and Presentations by Lawrence B. Afrin, M.D.

Borrelia burgdorferi Spirochetes Induce Mast Cell Activation and Cytokine Release

Recent Publications and Presentations by Theoharis C. Theoharides, Ph.D., M.D.

__________

Great, great information here.  Many Lyme/MSIDS patients will improve dramatically when they consider MCAS and take active steps like the ones mentioned here.

Another option not mentioned is LDA/LDI.  My daughter’s Mast Cell issues are nearly resolved after this treatment that helps the immune system recognize “friend from foe.”  Go here for more on LDA/LDI:  https://madisonarealymesupportgroup.com/2016/05/30/new-kids-on-the-block-ldaldi/

For more:  https://madisonarealymesupportgroup.com/2017/04/17/mast-cell-activation-syndrome-lymemsids/

https://madisonarealymesupportgroup.com/2017/03/23/rebecca-keith-on-mcas-parasites-lymemsids/

 

 

 

 

 

West Virginia Governor Signs Lyme Insurance Bill

http://www.journal-news.net/opinion/editorials/2018/03/lyme-disease-treatment-best-decided-by-doctor-patient/

Lyme disease treatment best decided by doctor, patient

EDITORIALS
MAR 25, 2018

Gov. Jim Justice signed legislation this week preventing insurance companies from denying coverage for Lyme disease treatments.

This is good news for residents here in the Eastern Panhandle, which has the highest number of tick bite reports in West Virginia.

The legislation was promoted by a Berkeley Springs couple, Eric and Linda Pritchard. Since at least the summer, the couple has been conducting a public information campaign. If it weren’t for the couple’s diligence, this law may not have been passed.

We’re grateful for their hard work, and for the efforts of Eastern Panhandle lawmakers, who recognized insurance companies denial of such coverage was unacceptable.

The West Virginia legislation was endorsed by state Sen. Charles Trump, R-Morgan, chairman of the state Senate Judiciary Committee. Senate Bill 242 was also co-sponsored by Sens. Craig Blair, R-Berkeley, and Patricia Rucker, R-Jefferson. A comparable House Bill 4328 was co-sponsored by Del. Jill Upson, R-Jefferson.

Lyme disease is caused by a bacteria infection that is primarily transmitted to humans through bites from deer ticks.

The new law requires insurance companies to pay costs for Lyme disease treatments, including detection tests and antibiotics prescribed by a doctor.

The disease is painful for those suffering from it.

Symptoms of Lyme disease can vary depending on the stage of the disease, according to the Centers for Disease Control and Prevention.

Early symptoms may include fever, chills, headache, fatigue, muscle and joint aches, swollen lymph nodes and rash.

Without proper treatment, these symptoms grow worse. Days to months after a tick bite, the symptoms may progress to severe headaches and neck stiffness, arthritis with severe joint pain and swelling, facial palsy, pain in tendons, muscles, joints and bones, heart palpitations, inflammation of the brain and spinal cord, nerve pain and problems with short-term memory, the CDC reports.

Clearly, Lyme disease can turn into something serious if not treated.

According to Eric Pritchard, insurance companies, however, have adopted policies that rely on medical authorities, such as the Infectious Diseases Society of America, which have questioned whether long-term antibiotic treatment is effective for conditions associated with chronic Lyme disease.

Those suffering from chronic Lyme disease, however, often have low quality of life. Treatment – which is best decided by a patient and his/her doctor and not insurance companies — increases the possibility something can be done to help these patients.

But treatments are often expensive.

Requiring insurance companies to cover such treatments is the humane thing to do. We’re happy to see lawmakers in the state recognize this.

______________

This needs to happen in every state.  Notice that this article acknowledges the dedicated & tireless work of a couple.  This is what is needed.  Dedicated workers who will not take “no” for an answer.  The challenge, of course, is finding enough people who’s brains function & who have the stamina to endure such a process!

 

What is Air Hunger, Anyway?

https://globallymealliance.org/air-hunger-anyway/

WHAT IS AIR HUNGER, ANYWAY?

By Jennifer Crystal MARCH 22, 2018

CHRONIC LYME DISEASE & ITS CO-INFECTIONS, LIKE BABESIA, CAN PRODUCE UNIQUE SYMPTOMS. ONE OF THEM IS REFERRED TO AS AIR HUNGER.

When I tell people I have chronic Lyme and some of its co-infections, they often look at me quizzically and ask: “What’s a co-infection?” I explain that in addition to Lyme ticks can transmit other diseases as well. I get an understanding nod until I say the names of the diseases. Rarely have people heard of them: Babesia, Ehrlichia, and Bartonella. One of my graduate school professors got so tired of trying to say “Babesia” that he jokingly renamed it “babelicious.”

I get a similar reaction when I tell people that a chief symptom of Babesia is air hunger. Some hear the term and think of marathon runners or asthma patients. Most really have no idea what it actually means. Literally, it means to be hungry for air. But how is that related to Babesia, and what does the symptom actually entail?

Babesia is a parasite that eats the oxygen in red blood cells. This result is low blood oxygen levels in the body. When you are hungry for food, your stomach might grumble, and you might feel a gnawing or emptiness, a craving for sustenance. You might become lightheaded or even faint. The same is true when your blood is hungry for oxygen, except you feel the hunger in your cells rather than in your stomach.

You know when exercising how you can feel your blood pumping, whereupon endorphin release makes you vivacious and energized? That feeling when your muscles are a little tired from running or biking, but you’re also exhilarated, hitting that “runner’s high” when you feel like you can do a million jumping jacks?

I used to feel that, too. I used to ski for eight hours in the back bowls of the Rocky Mountains, bouncing through mogul fields with reckless abandon. And at the end of the day, my body would be loose and limber. I was tired, sure, but it was nothing that a good meal and a good night’s sleep couldn’t fix. The next morning, I’d be ready to ski again.

Then I got Lyme, Babesia, and Ehrlichia. At first, before the illnesses were properly diagnosed, I simply noticed that I couldn’t keep up with my fellow skiers as I used to. I tired more easily, needed more breaks, and often experienced blood sugar crashes and lightheadedness after a particularly intense run. Skiing at a high altitude means there’s less oxygen available, to begin with, but what I didn’t know was that a blood parasite was also compromising my oxygen levels.

As the tick-borne illnesses slowly took over my body, my post-exertional fatigue and hypoglycemia increased. Sometimes I’d experience these symptoms when I was simply walking down the street. I started to get terrible migraines, always after exercise but sometimes just after a long day of teaching, and sometimes for no apparent reason at all. What I didn’t know was that the oxygen level of my red blood cells was getting lower and lower, causing these debilitating symptoms.

One day towards the end of my second year of teaching in Colorado, I tried to go for a short hike near my apartment. I barely made it a few feet up the dirt path before I found myself gasping for air. I wanted to take a deep breath, but couldn’t get one. As I clutched my chest, another hiker asked if I was okay. “Asthma,” I wheezed, even though I’d never experienced that condition before.

A doctor did diagnose asthma but didn’t explain the sudden onset. He didn’t realize that my gasping for breath was a literal manifestation of air hunger caused by Babesia. Instead, he gave me an inhaler, which I sometimes needed to use in class; in the middle of a lecture, I would get so lightheaded and short of breath.

Later, when I was finally diagnosed with and treated for tick-borne illnesses, I experienced Herxheimer reactions so bad that skiing, hiking and even walking became activities of the past; I could barely get up a flight of stairs. Often my arms and legs would feel jumpy like I was having a panic attack. This is because they weren’t getting enough oxygen; the jumpiness was their way of “grumbling” like a stomach does when it needs food. My limbs felt, how can I put this? They felt empty, the opposite of the way they used to feel when they were pumped full of healthy oxygenated blood during exercise. I wanted to take a deep breath and send the air right to my limbs, right to my cells, to re-invigorate them, but I couldn’t.

Overeager during treatment, I started physical therapy too soon, and paid for it. A mere thirty seconds on a stationary bike left my limbs gasping for air. It seemed like a thick molasses was seeping through my whole body, weighing me down. A heavy sensation crept into my head, filling it with pressure until I was overtaken by a full-blown migraine. After, I was in bed for a week.

The good news about that experience is that it told my doctor I needed to increase my Babesia treatment. Anti-malarial medication got me back on my feet, eventually back on the stationary bike, and, finally, back on my skis. I don’t think I’ll ever be able to bounce through moguls for eight hours at a time again, but I can ski a full morning without getting air hunger. I can paddle-board or canoe for hours. Sometimes, when I push myself too hard, I feel a tightening in my chest for a day or two after exercise. And sometimes I begin to feel air hunger in my cells as I’m walking around the city, getting that jumpy feeling in my limbs when I climb a flight of stairs or get a headache shortly after exercise. This tells me that it’s time to increase the homeopathic drops I now take to keep Babesia at bay.

Now I can say to my doctor, “I’m starting to feel some air hunger,” and he knows exactly what we need to do. Hopefully, this explanation will be a revelation for those readers who, like me, were so long perplexed by this frightening undiagnosed symptom.

Opinions expressed by contributors are their own.

Jennifer Crystal is a writer and educator in Boston. She is working on a memoir about her journey with chronic tick-borne illness. Contact her at jennifercrystalwriter@gmail.com

______________

**Comment**

Great example of a nasty Babesia symptom.  My husband struggled particularly with the blood sugar crashes that could come on at any time, necessitating his keeping protein bars with him at all times.  He would literally begin shaking.  It was a frightening symptom that thankfully passed with treatment.

Besides air hunger, Babesia is known to cause horrific headaches and dizziness as well as chest pressure.  The good news is proper treatment will alleviate and often eliminate these symptoms, but doxycycline won’t do it.  You need proper anti-malarial drugs to kill this monster.

 

 

 

Homeopathy & Lyme/MSIDS Presentation

Recently I posted the fact the FDA is planning to increase regulation on homeopathic medicines:  https://madisonarealymesupportgroup.com/2018/03/15/march-20-deadline-to-protect-homeopathy/ and https://madisonarealymesupportgroup.com/2018/03/19/today-is-the-deadline-to-comment-on-regulation-for-homeopathy/.

The following link is an excellent presentation by Katina Makris on homeopathy and how it can be used to treat Lyme/MSIDS symptoms.

https://www.eomega.org/videos/homeopathy-and-lyme-disease  Click here for presentation.  Approx. 45 Min.

 

 

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.