Sep 20 2013

Health Canada Misses the Point

This is an unintended follow up to my post yesterday about holding the line against pseudoscience – this time with regard to regulations. It is one thing to lend an organization’s reputation to pseudoscience, and another when outright unscientific practices are given official sanction by a government or regulatory body. It continues to amaze me how naive (or perhaps it’s just politically expedient) such regulators can be.

On September 6th Nathan Kunzler and Arthur Caplan published an excellent editorial in The Star in which they called out Canada’s public health agency for hypocrisy. They pointed out that, according to Health Canada’s own website:

“To be licensed in Canada, natural health products must be safe, effective, of high quality and carry detailed label information to let people make safe and informed choices.”

Therefore, if they license a product they are proclaiming it safe and effective. Health Canada licenses homeopathic products, which are not effective. They are nothing but placebos, magic potions based on prescientific notions and with “active ingredients” that are often diluted beyond the point where any original substance is likely to remain. Homeopathic products are therefore literally nothing. Further, clinical trials have consistently shown that they do not, in fact, work.

Kunzler and Caplan were pointing out the disconnect here, with specific respect to homeopathic treatments offered as alternatives to vaccines, so-called “nosodes.” Nosodes are essentially diseased tissue or pus diluted out of existence and then the resulting water given to prevent the disease from which the tissue originates. It’s witchcraft. On the one hand Health Canada is warning the public about an upswing in measles cases, on the other hand they license worthless vaccine alternatives which are contributing to measles outbreaks. They write:

“Safety and quality aside, it is clear nosodes are not effective. Health Canada by the declaration on its page is tacitly saying that these products are in fact effective, a fact not borne out by any body of scientific evidence.

It should be noted that it have [sic] not approved these as acceptable alternatives to traditional vaccination. This seems to shout administrative cognitive dissonance; the agency knows nosodes are no substitute for effective vaccines yet by licensing them its says that these are effective remedies.”

Such is the typical nonsense of political correctness – trying to have it both ways.

Health Canada has now responded to being caught with their pants down with a stunning display of political misdirection. Adam Gibson, Director General, Natural Health Products Directorate, Health Canada, wrote a letter to the editor responding to Kunzler and Caplan. Gibson writes:

“In the article this past Friday, authors Kunzler and Caplan perpetuated an unfortunate misconception about homeopathic preparations or “nosodes”. Health Canada has not authorized any nosode as a vaccine alternative.  Authorizing homeopathic remedies, including nosodes, for use of traditional homeopathic care is a very different thing from authorizing them as alternatives to vaccines.”

Wrong and wrong. First, Kunzler and Caplan did not say that Health Canada authorized nosodes as vaccine alternatives. They wrote: “It should be noted that it have [sic] not approved these as acceptable alternatives to traditional vaccination.” In addition to calling into question his reading comprehension, Gibson is simply demonstrating that he did not understand the editorial – at all.

The point that Kunzler and Caplan were making is that Health Canada is sending mixed signals, in a misguided attempt to make everyone happy. On the one hand they are warning about a measles outbreak, and they do not specifically offer nosodes as a replacement for proven vaccines. On the other hand they license homeopathic nosodes, which are intended to be used as a replacement for vaccines, and the licensure of which directly includes an assurance of efficacy.

Type in “homeopathic nosodes” into Google and the first hit you get declares: “Nosodes: The Homeopathic Alternative to Vaccines – by Celeste Yarnall, Ph.D.” That is what homeopathic nosodes are – alternatives to vaccines. Some people might use them in addition to vaccines, but that is irrelevant. Nosodes are worthless as medicine, and their licensure by Health Canada can only increase the risk that some Canadians will use them instead of vaccines (worsening the measles outbreak about which they are so concerned).

Gibson further writes:

“And, to ensure there is no remaining confusion, Health Canada has also revised the requirements for authorization of nosode products to explicitly state on the product package: “This product is not intended to be an alternative to vaccination.”

This only furthers confusion – why is Health Canada licensing products they say should not be used as intended, or rather by pretending they are not intended for what they are clearly intended for.

Gibson gives away his motivation when he writes:

“Health Canada respects diversity and recognizes that a growing number of Canadians choose natural health products to maintain and improve their health.  On their behalf, we will continue to ensure that a wide range of safe high-quality products are available.”

It is not the job of a health organization to respect diversity of opinion, but rather to respect the scientific evidence in order to do their job – protecting the public health. Also note that Gibson talks now about “safe high-quality products.” However, the Health Canada website writes that “products must be safe, effective, of high quality.” So what happened to “effective?” Gibson just leaves that off, as if no one will notice. But efficacy is exactly what this is all about. More confusion.

If Health Canada is no longer going to guarantee the effectiveness of natural health products, then they should remove that claim from their website and any official documentation. They should explicitly say that – “Health Canada does not assess or guarantee the effectiveness of licensed natural health products.” That is apparently the current reality, at least as evidenced by this episode.

The “unfortunate misconception” is that Health Canada cannot keep its story straight. They are deceiving the public about what they actually do with regard to natural health products. They are allowing those who sell such products to have it both ways – they don’t need to prove their products work, but they get to claim that they do because they are licensed. They get to sell products clearly intended to be a substitute for vaccines, but now have the political cover of a disclaimer saying they are not intended as a substitute for vaccines.

All of this regulatory mischief is what you get when you substitute feel-good ideology for rigorous science, and when you give the keys to the kingdom to con artists and charlatans.

12 responses so far

12 thoughts on “Health Canada Misses the Point”

  1. xeis says:

    I think you are being generous concentrating on the effectiveness of nosodes, if you take what is at best a placebo as a vaccine then it is not safe. As for Health Canada

    “Health Canada respects diversity and recognizes that a growing number of Canadians choose natural health products to maintain and improve their health. On their behalf, we will continue to ensure that a wide range of safe high-quality products are available.”

    I would suggest (ignoring the naturalistic fallacy & argument from popularity) that Health Canada have doubled down claiming they are both “high-quality” and more importantly (from a litigation perspective) “safe”.

    Just silly, imo.

  2. dohashi says:

    Bad Science Watch ( has been running a Stop Nosodes campaign for a while now ( The campaign page has a nice rundown of the situation.

    One thing I have not seen mentioned yet is that Health Canada does have a efficacy requirement for their “natural/traditional/alternative” products, but it is complete nonsense.

    Basically if you can show “historical usage”, then it can be approved.

    Reading the actual documents it is clear that they want to have a sliding scale of evidence and health claims, stronger evidence allows for stronger claims. However I suspect they were ignorant to the fact that believers would completely ignore the approved claims and simply state their beliefs, using Health Canada’s approval as a stamp of legitimacy.

  3. pdeboer says:

    Gibson refers to the notice that Canadian companies must place on nosode products to say they are not a replacement for vaccines. Example, the product INFLUENZINUM:

    Under important information.

    “This product is not designed as a replacement for a flu vaccination. If you have been diagnosed or believe you are at high risk for complications due to influenza, consult your health professional for appropriate treatment.”

    Doing a general Google search will hit on many claims that INFLUENZINUM can prevent the flu and is an alternative to flu shots.

    The mistake would be easy to make by the uninformed.

    Not only is our government endorsing the efficacy of the flu treatment claims of this particular product, but it is approving the sale of a product that obviously thrives on purchases made with the purpose of immunization.

  4. Dmitri says:

    I agree with xeis. Saying nosode is safe is like saying motorcycle helmet made of grass and leaves is safe. Perhaps Canadian government will start endorsing such “natural” and “alternative” safety devices.

  5. ConspicuousCarl says:

    When the government arrests bank robbers, where is their respect for the diversity of people who choose to improve their wealth via alternatives to legally-approved income sources? Bigots!

  6. jesse.huebsch says:

    The current Canadian government is extremely anti science, to the point of deliberately destroying the means of collecting data (the long form census) just to spite their political foes. Why is this a surprise to anyone? They had a creationist as the science minister for several years.
    Of course the only reason they are in power is that their political opponents are more concerned with fighting each other than to actually do something good for the country, but that is a rant for another day.

  7. ccbowers says:

    “Authorizing homeopathic remedies, including nosodes, for use of traditional homeopathic care is a very different thing from authorizing them as alternatives to vaccines.”

    OK, Adam Gibson, let’s follow the logic. Licensing a natural product means that a product has “been assessed by Health Canada and found to be safe, effective and of high quality.” So in licensing these products (which you term ‘authorizing’) you imply an endorsement of efficacy as indicated by Health Canada’s own website.

    Now you later clarified that they are not intended as an alternative to vaccines through labeling (which has been their intended use by people who use them, and is the very reason for their existence as a product), so what uses have they been licensed for? For which intended uses have they shown efficacy in order to get a product license?

    Of course, I don’t expect answers to those rethorical questions, because there are no reasonable answers. “For use in tranditional homeopathic care” is a meaningless phrase, and is not an acceptable answer for the intended use of a product, especially when the endorsement of efficacy is implied. The source of the “unfortunate misconception” is pretty clear, and it’s not because of people like Kunzler and Caplan.

  8. westcoastnerd says:

    I emailed Health Canada recently to question them on how they determine efficacy. Their response was basically that they use the provings sent to them from the companies that produce the “remedies”. I was understandably astounded by this so have just sent off an Access To Information Request in order to get copies of all the documents they used in their determination of the efficacy of the homeopathic vaccines for polio, whooping cough and measles. Can’t wait to see what comes up!!

  9. Suraky says:

    After arguing with natural health providers who truly believed the license meant their crap was safe and effective, and complaining to the government about various products… Only to be ignored by my government, I dug through health Canada ‘ s website.

    I think the links are already posted in another comment, but basically if you stop at the first page after reading what you want to believe is true (if you are a natural health nut) you will think the government supports your view.

    If you dig much deeper you will find exceptions all over the place, you’ll see that some products can be sold with a partial licence as if it was safe and effective when really the government has only acknowledged that papers have been filed. You’ll see that the government does no testing, accepts anecdotes and simple lists of ingredients and indications for use as if these are evidence.

    You will see that for Homeopathy in particular ‘proof’ consists of nothing more than a remedy being made from ingredients listed in the homeopath pharmacopoeias, including Hahnemann ‘s original work! No testing. No safety measured. No efficacy proven.

    And if you search the natural health product database, you’ll find it to be almost unuseable as if it was put on a 386 computer to intentionally make it slow and difficult.

    I wanted to scream all this after listening to the recent SGU episode, but figured someone else would have beat me to it.

    The government is just people. This part of our government is people who are believers or natural health business owners protecting their profits with intentionally misleading regulations. And it has coerced people into thinking a license legitimises a product, or at least gives businesses a legal excuse to operate.

    I’d like to know, and have been unable to find out using the googles… There were a couple class action lawsuits going on here in Canada against homeopathic remedy makers, for not listing the actual amount of active ingredients in the required way, by weight or volume. What happened to these lawsuits?

  10. Davdoodles says:

    Nosodes ARE an alternative to vaccinating.

    In the same way that not vaccinating is an alternative to vaccinating.

    So there!

  11. embeetee says:

    FWIW (more, I hope, thank I fear Health Canada will think it is worth), I wrote my MP, the Minister of Health and the shadow ministers in the Liberal and NDP parties on this issue. Deeply embarrassing to me as a Canadian…though embarrassment is the least of the damage this ludicrous approach by Health Canada could create.

    I also wrote to the Dean of Medicine at U of T to protest the creation of a Centre of Complementary and Alternative Medicine; they are posting a Director position. This is in the same vein as the Minstry of Health, bending so far over backwards to be “inclusive” that you can hear the commitment to scientific standards and evidence-based medicine snap like a dry twig.

    The only way we’ll hold the line (or pull it back to where it should be) is by voicing our protests: Canadians must write to the institutions and people making these decisions.

  12. OlegSh says:


    As Canadians we can start a petition against Nosodes:

    I think it’s the only way to push our government back on science-based tracks.

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