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.

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