here, I provide an
annotated script for the first half of the last third of the fourth part of Season 02
Episode 02 of The Naturocrit Podcast:
001. the Episode 012d3.1 script and annotations:
Standard Introduction:
Episode Synopsis:
Main Text:
001. the Episode 012d3.1 script and annotations:
Standard Introduction:
Welcome to, as that robot voice
says, The Naturocrit Podcast, and thank you for boldly listening.
What
ARE we even talking about?
Well, this podcast series is my take on
naturopathic medicine, an area I've been studying for about twenty
years, including my time in so-called 'scientific nonsectarian
naturopathic medical school'.
My approach is a pairing of scientific skepticism and a deep knowledge of naturopathy's intimate details.
In
previous episodes of this series, I established that naturopathy is,
essentially, a kind of knowledge blending, misrepresentation, and
irrationality.
I have termed naturopathy both 'an epistemic conflation
falsely posing itself as an epistemic delineation' and 'the
naturopathillogical':
the science-exterior is mixed with what is
scientific, and then that whole muddle is absurdly claimed to be science
as an entire category, while particular sectarian science-ejected
oath-obligations and -requirements are coded or camouflaged, therein
effectively disguising naturopathy's system of beliefs in public
view.
Naturopathy's ultimate achievement is a profound erosion of
scientific integrity and freedom of belief packaged in the marketing
veneers "natural, holistic, integrative and alternative"
and improperly embedded in the academic category "science".
Episode Synopsis:
In this admittedly
sprawling Naturocrit Podcast Episode 012, aka s02e02, titled
"Preponderant and Universal Medical Ethical Codes and North
American Naturopathy's Transgressions",
I've been looking at
general professional ethical commitments and specifically modern
medicine's ethical commitments, and comparing those stringencies to
naturopathy's 'anything goes ethical laxity and required
fraudulence'.
In this first half of the last third of Part Four of this Episode
012, I'll conclude this episode by looking at:
the MNANP briefly
again,
various sources within naturopathy that claim 'branch of
medical science upon naturopathy' as NDs Smith and Logan did in that 2002 MCNA
paper,
the FTC's recent action regarding homeopathy,
In the second half, I'll cover the two 2003 and 2004 Medscape papers by MD Atwood that
are critical of naturopathy.
Plus, as regards NEASC, I'll, as I'd
said:
“answer those two OLD questions formulated by NEASC, from
2004, with the benefit of 12 retrospective years of UB naturopathy
and North American naturopathy behavior […] 1. Are students and
prospective students given timely, sufficient and accurate
information to serve as a basis for their decisions regarding
pursuing a degree in naturopathic medicine? 2. Are students in
naturopathic medicine provided with adequate academic
advising?”
Additionally, as I said in the introduction to this
Episode:
“part of my conclusion will be what I'll call
'naturopathy's unethical code of misconduct', which will be a
summation of naturopathy's past and current behaviors generalized
into 'rules of misbehavior'”
and I'll touch on the phenomenon of
'gaming the system' aka licensed falsehood.
Main Text:
A Brief MNANP Revisit:
I had promised in this Episode to return to the Minnesota
Association of Naturopathic Physicians, which is a state chapter of
the AANP, as an example.
I'd discussed their nonsense language of, as I summarized:
“profession, protection of naturopaths, expansion of
naturopathy, strong professional standards, public awareness, natural
and integrative, expertise, advanced health care degree,
comprehensive understanding, coded vitalism, blending of science and
nonscience, traditional, holistic, diagnosis and treatment, coded
vitalism again, listening, and scientifically-up-to-date […] 'a
holistic, yet science-based approach to medicine' […]
'science-based, clinically verified wholistic medical treatments.'”
So, with ethics now fleshed out in terms of the AANP, and mainstream allied health organizations, what can I say about this AANP
affiliate, MNANP?
Well, let's add the label 'ethics subset unethicality' to my
summary language because, though the AANP Code of Ethics is
compulsory for MNANP, we're getting a heck of a lot of problems aka
'the bad' regarding what AANP says should be GOOD not BAD concerning:
honesty, performance, obligation, competence and communication.
For starters, it's that same-old-problem of COMMUNICATING to the
public a false categorical science label upon the essentially
naturopathic, for promotional purposes in the marketplace, in terms of the AANP's Code
of Ethics.
Yet, we're told in mnanp.org's page “About Us” [2016 archived]:
“all naturopathic members of the AANP
and the MNANP follow the Naturopathic Code of Ethics listed below.”
Now, below, on the page, is a link to the page
titled “AANP Model for Affiliate Organization Bylaws” [2016 archived] where we're told:
“article VII code of ethics: the
corporation may refuse to grant or may suspend or revoke membership
in the corporation for any of the following reasons [...including]
the use of fraud or deception […] the impersonation […]
committing an immoral, fraudulent or dishonest act as a naturopathic
physician, resulting in substantial injury to another […]
misleading advertising.”
But, merely looking at what's falsely
sold as science when it isn't online by naturopaths, aren't we
customarily getting gross violations by MNANP and its members
regarding:
fraud, deception, impersonation,
immorality, dishonesty, harm, and misleading advertising?
And yet licensed falsehood marches on
in Minnesota, without any sanctions.
So again we see FAKE RULES, as fake as naturopathy's science self-categorizing...
Naturopathy's 'With All Other Branches
of Medical Science' False Categorical Self-Labeling:
I'm adding here
onto that 'branches' label that NDs Smith and Logan presented in
their 2002 MCNA paper.
Now, this 'branches' language is truly an
INVENTION by naturopathy FOR naturopathy that is categorically false
in terms of the essentially naturopathic, and employed for marketing
purposes.
Of course, you'll find some 'borrowed science' within
naturopathy, but contemporary science basically has discarded the
'essentially naturopathic' both as ideas and activities, such
as:
vitalism, supernaturalism, homeopathy, detox, colonics, food as
medicine, reiki, craniosacral therapy, meridian theory, applied
kinesiology, subluxation theory and the like.
Yet, though rife with
'nonsense stuff aka the naturopathillogical', naturopathy continues to
categorically label itself 'a branch of medical science'.
Here
are some CURRENT examples, 14 years – and counting – after that
2002 NDs Smith and Logan MCNA paper.
Now, my databases online are generally
arranged this way, from the bottom-up:
reference tools; academics and
authors; practitioners; journals; states, state and provincial
organizations; international and national organizations; and finally
schools at the top.
Let me sample some 'branches language' from each
kind of source.
As a reference tool category example, and also for
the schools category as an example, I'll employ
explorehealthcareers.org.
It fits both categories because it offers itself to the public as:
“a free,
interactive health careers website designed to explain the array of
health professions and provide easy access to students seeking
information about health careers […] to help educate students about
the importance of a health care career”.
So it seeks to serve as a
general reference site, and their naturopathy entry states:
“the Association of Accredited Naturopathic Medical Colleges reviewed this career profile”,
which is the North American ND schools' consortia.
“the Association of Accredited Naturopathic Medical Colleges reviewed this career profile”,
which is the North American ND schools' consortia.
Overall, in terms of accuracy regarding naturopathy, I give
explorehealthcareers.org a big F.
I've listed the site for many
years at my Blogger page “Appendix I.07.01.”
Now, WHO are they, this
explorehealthcareers.org?
Live, currently, on a page titled
“History” [2016 archived], the
publishers tell us about themselves.
And this is really fucking
strange:
would you believe that behind this published naturopathy
falsehood is a mainstream dental education organization [2016 archived]?
Actually apparently THE dental education organization.
We're told:
“on November 1, 2006, the American Dental Education Association
(ADEA) assumed leadership of explorehealthcareers.org […] ADEA is
the leading national organization for dental education. Its members
include all U.S. and Canadian dental schools, advanced dental
education programs, allied dental education programs, corporations,
faculty and students. ADEA's mission is to lead individuals and
institutions of the dental education community to address
contemporary issues influencing education, research and the delivery
of oral health care for the health of the public. ADEA's activities
encompass a wide range of research, advocacy, faculty development,
meetings and communications, as well as the dental school admissions
services [...] and the Journal of Dental Education.”
So, that was a claim of all encompassing CONTROL over so much of the dental enterprise, and though they claimed "a wide range of research", ADEA are so WRONG about naturopathy's science branch claim, which as a label is WIDELY or preponderantly FALSE.
And it is easy therefore to determine such.
Here's how FALSE ADEA is:
explorehealthcareers.org has bought into that false sectarian label
for modern medicine invented by homeopathy's founder Hahnemann, 'allopathy', because their page discussing medical doctors is titled
“Allopathic Physician (M.D.)” [2016 archived].
As I've said many times:
just because the lineage of modern medicine contains prescientific medicine, it makes no sense to call current medicine by any prescientific name.
That would be a false representation, like:
how we don't currently call chemistry alchemy and we don't currently call astronomy astrology.
Yet somehow it's ok to call current medicine the medicine of the late 1700s?
No.
No.
Fail.
Specifically, to the point, regarding pro-naturopathy propaganda, here's what's said on ADEA's explorehealthcareers.org page “Naturopathic Physician” [2016 archived] in terms of science, and need I remind you I'd rather it be titled 'naturopathic metaphysician':
“naturopathic physicians collaborate with all other branches of medical science […] these are some commonalities that naturopathic medical students share [...including being] academically successful and grounded in the sciences [...and they] understand the art and the science of medicine.”
So, science science science.
Grounding the essentially naturopathic IN science is quite an impossibility:
how do you ground as science what science has ejected?
We're also
told:
“they provide individualized, evidence-informed therapies that
balance the least harmful and most effective approaches to help
facilitate the body’s inherent ability to restore and maintain
optimal health […] addressing disease and dysfunction at the level
of body, mind and spirit […they] treat the whole person [...and]
view the body as an integrated whole in all its physical and
spiritual dimensions […] naturopathic medicine is based upon six
fundamental principles [...including] the healing power of nature:
trust in the body’s inherent wisdom to heal itself […]
naturopathic medicine is a distinct primary health care profession
that combines the wisdom of nature with the rigors of modern science
[...and we're shown] the therapeutic order [as a diagram...which states] stimulate
the self-healing mechanisms, vis medicatrix naturae.”
So:
an efficacy
claim, supernaturalism, coded vitalism, and that 'distinctly blended'
inanity.
So, NO heads-up regarding
naturopathy's contradictory and false labels and contents, NO heads-up
regarding naturopathy's epistemic fraud.
Thanks, explorehealthcareers.org, for being a co-conspirator.
I actually have dental assisting students in that course, and therefore I'm quite aware of the American Dental Association's
Code of Ethics.
And Codes of Ethics are what this Episode 012 is centrally about!
So, ADA states on a page titled “Celebrating 150 Years of Putting Patients First: The ADA Principles of Ethics and Code of Conduct” [2016 archived]:
“the Principles of Ethics are the aspirational goals of the
profession. They provide guidance and offer justification for the
Code of Professional Conduct and the Advisory Opinions. There are
five fundamental principles that form the foundation of the ADA Code:
patient autonomy, nonmaleficence, beneficence, justice and veracity.”
patient autonomy, nonmaleficence, beneficence, justice and veracity.”
I think we've heard such before in this Episode 012,
because such are general or preponderant professional ethical
principles particular to healthcare.
Specifically, the 2016 ADA Code of Ethics PDF [2016 archived] states:
Specifically, the 2016 ADA Code of Ethics PDF [2016 archived] states:
“unsubstantiated representations: a
dentist who represents that dental treatment or diagnostic techniques
recommended or performed by the dentist has the capacity to diagnose,
cure or alleviate diseases, infections or other
conditions, when such representations are not based upon accepted
scientific knowledge or research, is acting unethically.”
So,
basically for dentistry NATUROPATHY'S 'defining default mode' is
unethical, as:
“not based upon accepted scientific knowledge.”
Like:
science subset vital force and homeopathy, and kind.
And yet here's the dental education organization promoting naturopathy uncritically, without warning, without context.
“not based upon accepted scientific knowledge.”
Like:
science subset vital force and homeopathy, and kind.
And yet here's the dental education organization promoting naturopathy uncritically, without warning, without context.
They go
on, stating:
”marketing or sale of products or
procedures: dentists [...] in the regular conduct of their practices [...] must take care not to exploit the
trust inherent in the dentist-patient relationship for their own
financial gain. Dentists should not induce their patients to purchase
products or undergo procedures by misrepresenting the product’s
value, the necessity of the procedure or the dentist’s professional
expertise in recommending the product or procedure. In the case of a
health-related product, it is not enough for the dentist to rely on
the manufacturer’s or distributor’s representations about the
product’s safety and efficacy. The dentist has an independent
obligation to inquire into the truth and accuracy of such claims and
verify that they are founded on accepted scientific knowledge or
research. Dentists should disclose to their patients all relevant
information the patient needs to make an informed purchase decision,
including whether the product is available elsewhere and whether
there are any financial incentives for the dentist to recommend the
product that would not be evident to the patient.”
We see here:
no unfair commerce by way of exploitation, misrepresentation, or false necessity.
And there is emphasis regarding "an independent
obligation to inquire into the truth and accuracy of such claims and
verify that they are founded on accepted scientific knowledge or
research."
And there is mention of informed consent as "informed purchase decision."
After all, the title of the first ADA page I'd mentioned was "Celebrating 150 Years of Putting Patients First: The ADA Principles of Ethics and Code of Conduct" which is dentistry lauding its fiduciary duty to the public it serves.
So, ADEA cannot simply say in our false representation of 'naturopathy's as a branch of medical science claim and medicine as allopathy', it's not our fault'.
According to dental's own Code of Ethics, ADEA has a duty to independently verify the veracity of naturopathy's labels and such.
And by way of 'naturopathy and allopathy', ADEA has failed in terms of behaviors required in the dental code.
I don't see how naturopathy can be endorsed by a
dental organization of any kind, in any way.
But here's such.
As I've said before,
OH MY.
What a contradiction, what a violation, what a collision as in
what I termed earlier:
naturopathy's 'required fraudulence' versus what is generally professionally good.
Now, the dental code is pretty detailed
regarding veracity and nonmaleficence.
We're told:
“veracity
('truthfulness'): the dentist has a duty to communicate truthfully.
This principle expresses the concept that professionals have a duty
to be honest and trustworthy in their dealings with people. Under
this principle, the dentist’s primary obligations include
respecting the position of trust inherent in the dentist-patient
relationship, communicating truthfully and without deception, and
maintaining intellectual integrity […] dentists shall not represent
the care being rendered to their patients in a false or misleading
manner […] nonmaleficence ('do no harm'): the dentist has a duty to
refrain from harming the patient. This principle expresses the
concept that professionals have a duty to protect the patient from
harm. Under this principle, the dentist’s primary obligations
include keeping knowledge and skills current.”
Yet, naturopathy
hugely doesn't communicate truthfully, honestly, in a trustworthy
way.
Naturopaths actually are deceptive, and the area as a whole is
without intellectual integrity.
Naturopathy is false and
misleading, and also has not kept up in knowledge development in terms of what actually is science.
In that sense, in terms of the naturopathy product,
naturopaths minimally monetarily harm their patients with their outdated
science-ejected knowledge falsely claimed as continuously science,
and then profited upon.
It's just amazing how thoughtless DENTAL
support for naturopathy is, how contrary it is to 'what's good' in
terms of dental ethics.
So, there's ADEA aka organized North American dentistry as a reference tool source, and the ND schools' consortia AANMC as a school source, falsely claiming 'branch of medical science' upon the categorically science-exterior essentially naturopathic.
So, there's ADEA aka organized North American dentistry as a reference tool source, and the ND schools' consortia AANMC as a school source, falsely claiming 'branch of medical science' upon the categorically science-exterior essentially naturopathic.
As a concurrent counterpoint to that science
claim, let me introduce you to a ANOTHER web page from Yale
University, this time within the Yale University hospital system from
my own city Bridgeport, CT.
Here I go again, with a different part
of the Yale medical octopus because I've already, in this episode,
used Yale as a source for exposing naturopathy's nonscience core.
Yale New Haven Health at Bridgeport
Hospital tells us in "Naturopathy"
[vsc 2016-12-10; 2016 archived]:
"naturopathy's main goal is to use
the natural healing power of the body to fight disease, also known as
the vis or life force [...] naturopathic therapies may include [...]
homeopathy [...which is of] natural and lifestyle therapeutics
[...of] naturally-oriented therapies [...] online medical reviewer:
Garilli, Bianca, ND."
So, that's vitalism, in full splendor,
with an ND having approved that contents:
science-ejected vitalism.
Garilli is a Bastyr ND graduate, and incidentally, I don't regard naturopathy credentials as "medical".
Meanwhile, in the same city as Yale New
Haven Health at Bridgeport Hospital, is the University of Bridgeport,
which places their ND program within a “division of health sciences" [2016 archived].
So that is patently categorically false as a commerce and academic label.
Obviously, I live in a CRAZY place:
corrupticut.
I sometimes wonder if, like the narrator in Camus's
The Fall, I've descended into Hades, as some kind of 'slimy epistemic madhouse'.
For an 'academics and authors' source for this branches claim, I'll employ the book "Ticked Off" by patient Janet L. Decesare.
Its year of publication was 2011 with ISBNs 1617390240 and 9781617390241.
We're told in the book:
"Dr. S. is a licensed naturopathic physician (ND) and is educated in all of the same basic sciences as a medical doctor [...] Dr. S. is expertly trained [...in such things as] acupuncture, homeopathic medicine [...and] chiropractic [...] Dr. S. cooperates with all other branches of medical science."
So, right out of naturopathy's talking points.
For a 'practitioners' source, I'll employ the ND collective "Integrated Health Clinic", which is at Fort Langley, in British Columbia, Canada.
They tell us on the page "About What We Do ... Naturopathic Medicine" [2016 archived]:
"naturopathic doctors [...] cooperate with [all] other branches of medical science" [oops, I say all without them having written all; same essential branches categorization].
They are NDs:
Adrian, Boudreau, Dawson, Duffee, Fruson, Kefferputz, McGee, Gurdev and Karen Parmar, Rurak, Sjovold and Willis.
They are NDs:
Adrian, Boudreau, Dawson, Duffee, Fruson, Kefferputz, McGee, Gurdev and Karen Parmar, Rurak, Sjovold and Willis.
For a 'journals source', I'll employ an article from Complementary Health Practice Review which is now the "Journal of Evidence-Based Complementary & Alternative Medicine."
The JEBCAM actually says on its homepage:
"this journal is a member of the Committee on Publication Ethics (COPE)."
COPE has a document titled "Principles of Transparency and Best Practice in Scholarly Publishing" [2016 archived] with one of the principles they list being:
"journals shall have editorial boards or other governing bodies whose members are recognized experts in the subject areas included within the journal’s scope."
COPE has a document titled "Principles of Transparency and Best Practice in Scholarly Publishing" [2016 archived] with one of the principles they list being:
"journals shall have editorial boards or other governing bodies whose members are recognized experts in the subject areas included within the journal’s scope."
EXPERTS!
Well, since medicine is an applied science, scientific filtering of that which is scientifically labeled should be happening.
Yet, somehow, what I'm about to quote from within JEBCAM slipped by them editors and has, like that MCNA NDs Smith and Logan claim, stayed slipped by.
The JEBCAM article is "Diffusion of Naturopathic State Licensing in the United States and Canada" [2011 archived] and its citation is "Complementary Health Practice Review October 2004 9: 193-207."
The authors are "Donald Patrick Albert and Ferry Butar Butar", with the former being a "Professor of Geography" and the latter being a "Professor of Mathematical Statistics".
And in the article we're told by the authors, who cite Bastyr University language circa 2002:
"naturopathic physicians cooperate with all other branches of medical science."
And so COPE appears again, and I have a plan, I have a plan for 2017!
For a 'states, state and provincial organizations' source, I'll employ the State of Vermont Department of Health.
"naturopathic physicians cooperate with all other branches of medical science."
So, there's that categorical label of science upon what isn't categorically science.
Now, JEBCAM's 'naturopathy branches'
claim is merely 12 years persistently wrong, unlike MCNA's which is
14 years persistently wrong.
But I think you can see the pattern, the uncorrected pattern of naturopathy false science categorical claims polluting the medical science literature.
But, good luck getting a correction out of JEBCAM!
JEBCAM currently has at least 8 NDs on their editorial board [2016 archived].
Try COPING with that!
Oh, and by the way, Elsevier, which publishes MCNA, has a YouTube video titled "Medical Clinics of North America" [2014] which assures us:
"why read source after source when our expert contributors have already done the work for you?"
EXPERTS again, who've let so much slip through and persist slipped.
And Elsevier states regarding its "Authorship Guidelines and Ethics" [robots blocked]:
"the
Clinics authorship guidelines are based on the International Committee
of Medical Journal Editors’ (ICMJE) authorship criteria [...see] icmje.org."
ICMJE has the document "Recommendations for the Conduct, Reporting, Editing, and Publication of Scholarly Work in Medical Journals Updated December 2016" [2016 archived], which has the word "retract"
in it at least 30 times.
Generally, we're informed:
"errors [...] require publication
of a correction when they are detected […] corrections are needed
for errors of fact."
And I maintain that naturopathy is not science categorically, in fact.
And I maintain that naturopathy is not science categorically, in fact.
There's also a section titled
“scientific misconduct, expressions of concern, and retraction.”
Specifically there, we're told:
“scientific misconduct includes but
is not necessarily limited to data fabrication; data falsification
including deceptive manipulation [...] and plagiarism. Some
people consider failure to publish the results of clinical trials and
other human studies a form of scientific misconduct. While each of
these practices is problematic, they are not equivalent. Each
situation requires individual assessment by relevant stakeholders. When
scientific misconduct is alleged, or concerns are otherwise raised
about the conduct or integrity of work described in submitted or
published papers, the editor should initiate appropriate procedures
detailed by such committees such as the Committee on Publication
Ethics (COPE) [...] and may
choose to publish an expression of concern pending the outcomes of
those procedures [...] retracted articles should remain in the
public domain and be clearly labeled as retracted.”
For a 'states, state and provincial organizations' source, I'll employ the State of Vermont Department of Health.
In "Vermont Arthritis Resource Guide 2005" [2016 archived], hosted at that State's .gov [11 years of falsehood and counting], we're told:
"naturopathic physicians cooperate with all other branches of medical science."
Now, naturopaths are licensed in Vermont with a pretty wide scope of practice.
So, what we obviously have here is collusion between North American organized naturopathy and a licensing state's Department of Health, with the result being harmful falsehood minimally harming scientific integrity, the basis of public health.
For 'international and national organizations', I'll employ an AANP paper-based publication they sent to me by way of the USPS after I purchased it from them.
In the undated "Naturopathic Medicine: Primary Care for the 21 Century" [here's a live not-OCR'd copy hosted by an ND; 2016 archived], we're told:
"naturopathic physicians cooperate with all other branches of medical science."
So that's me done with my sample of naturopathy's false 'branches' claim from various sources.
So, obviously, NDs Smith and Logan are not an anomaly in their false claim:
this fraud is naturopathy-wide.
this fraud is naturopathy-wide.
The Federal Trade Commission's Ruling on Homeopathy and My Recent Letter of Complaint to Them About Naturopathy Miseducational Institutions:
The AANP, the American national naturopathic
organization, has a position paper on homeopathy that has existed
since 1993 and was “amended” in 2011.
The ND signatories to that position paper
are specifically:
Aesoph, Broadwell, Dickson, Edwards, King, Mathieu,
Reichenberg-Ullman, Rollo, Traub, and Winston.
It is titled "House of Delegates Position Paper Homeopathy" [2016 archived].
The PDF states:
"homeopathy has been an integral part of naturopathic
medicine since its inception and is a recognized specialty for which
the naturopathic profession has created a distinct specialty
organization, the Homeopathic Academy of Naturopathic Physicians.
Homeopathy has been recognized, through rigorous testing and
experimentation, as having significant scientific evidence supporting
its efficacy and safety."
And here we go down the rabbit hole of
naturopathic epistemic misrepresentation and incompetence.
This is a current claim, this is a current document, here, now at the end of 2016,
after so many high-quality broad analyses of homeopathy that actually show
that homeopathy is NOT scientifically supportable.
Let's call that:
the same old lies by the naturopathy organizations.
the same old lies by the naturopathy organizations.
We're also
told:
"homeopathy is taught in the naturopathic colleges and its
practice should be included in the naturopathic licensing laws.
Naturopathic physicians recognize other licensed practitioners of the
healing arts who are properly trained in homeopathy."
So, organized American naturopathy INSISTS that bogus pharmacy be licensed aka 'licensed falsehood.'
And
just HOW is one properly trained in such bogosity?
So, we know what side
of this matter American naturopathy is on:
the historically WRONG side, scientifically false side,
the falsehood-licensing side.
Now, the Wikipedia page for the Federal Trade Commission states:
“the Federal Trade Commission (FTC) is an independent agency
of the United States government, established in 1914 by the Federal
Trade Commission Act. Its principal mission is the promotion of
consumer protection and the elimination and prevention of anti-competitive business practices [...within is] the Bureau of Consumer
Protection [...with its] mandate is to protect consumers against unfair or
deceptive acts or practices in commerce. With the written consent of
the Commission, Bureau attorneys enforce federal laws related to
consumer affairs and rules promulgated by the FTC. Its functions
include investigations, enforcement actions, and consumer and
business education. Areas of principal concern for this bureau are:
advertising and marketing, financial products and practices,
telemarketing fraud, privacy and identity protection, etc.”
At the
'.gov' web page of the Federal Trade Commission titled “OTC Homeopathic Drugs: Established FTC Proof Standards Apply” [2016 archived], published 2016-11-16, we're told:
“the FTC applies a consistent
approach to evaluating ad claims. Companies must have a reasonable
basis for objective representations, including claims that a product
can treat specific health conditions. Whether it’s an
over-the-counter drug, dietary supplement, or food, the same
established standards apply. And as an FTC Enforcement Policy
Statement explains, that also holds true for OTC homeopathic drugs.
Consumers can find a host of homeopathic remedies on store shelves.
Homeopathy is a view dating back to the 1700s that disease symptoms
can be treated by tiny doses of substances that produce similar
symptoms if given in larger doses to healthy people. Many homeopathic
products are diluted so much that they no longer have detectable
levels of the initial substance. Generally speaking, health claims
for homeopathic products aren’t based on modern scientific methods
and there’s controversy about their effectiveness […] read the
Enforcement Policy Statement for more information and check out the
FTC Staff Report on the Homeopathic Medicine and Advertising
workshop.”
So, advertising standards, as in representation in
commerce, and particularly misrepresentation in commerce by way of
homeopathy's absurd efficacy claims, is the issue and it is obvious
that homeopathy will no longer receive any unfair EPISTEMIC
CHARITY in the marketplace, and that epistemic filter will be one of "modern scientific methods".
Excellent.
But, I think too that there's a false balance going
on, in a small way, in the FTC language on that page.
I'd argue that
FTC there is manufacturing a “controversy”, because really, if we
are talking about what's objectively true, the science regarding
homeopathy isn't controversial:
homeopathy simply doesn't work and
can't work.
The controversy may be that many people don't care to use
science as a filter for pharmacological claims, but that's an absurd
and extremely fringe position akin to saying:
that there's still controversy about
human-induced climate change
because I've compared all that preponderant rigorously-filtered scientific data with the fact that I just went outside in a snowstorm and made a snowball.
because I've compared all that preponderant rigorously-filtered scientific data with the fact that I just went outside in a snowstorm and made a snowball.
These two positions are NOT equivalent.
I'd therein be creating a fake
controversy, creating a fake equivalency, because weather on any given day isn't a microcosm of
overall climate trending.
Beside this language of false balance, I think in general, a good job was done
here by FTC.
That new FTC enforcement policy on homeopathy is a PDF
titled “Enforcement Policy Statement on Marketing Claims for OTC Homeopathic Drugs”
[2016 archived] and also was published in November of 2016.
It states, and I
admittedly REVEL in this language because, as I've said before in this
podcast, I detest homeopathy and that's why I left naturopathy's false enterprise:
“the Federal Trade Commission (FTC) is
issuing this Policy Statement to provide guidance regarding its
enforcement policy with respect to marketing claims for
over-the-counter (OTC) homeopathic drugs. It applies only to OTC
products intended solely for self-limiting disease conditions. The
Commission believes this Policy Statement is appropriate in light of
the burgeoning mainstream marketing of OTC homeopathic products
alongside other OTC drugs […] the FTC’s authority over disease
and other health-related claims comes from Sections 5 and 12 of the
FTC Act. Section 5, which applies to both advertising and labeling,
prohibits unfair or deceptive acts or practices in or affecting
commerce, such as the deceptive advertising or labeling of OTC drugs.
Section 12 prohibits the dissemination of false advertisements in or
affecting commerce of food, drugs, devices, services, or cosmetics.
Under these provisions, companies must have a reasonable basis for
making objective product claims, including claims that a product can
treat specific conditions, before those claims are made. Homeopathy,
which dates back to the late-eighteenth century, is based on the view
that disease symptoms can be treated by minute doses of substances
that produce similar symptoms when provided in larger doses to
healthy people. Many homeopathic products are diluted to such an
extent that they no longer contain detectable levels of the initial
substance. In general, homeopathic product claims are not based on
modern scientific methods and are not accepted by modern medical
experts, but homeopathy nevertheless has many adherents […] the FTC
Act does not exempt homeopathic products from the general requirement
that objective product claims be truthful and substantiated.
Nevertheless, in the decades since the Commission announced in 1972
that objective product claims must be substantiated, the FTC has
rarely challenged misleading claims for products that were
homeopathic or purportedly homeopathic. Efficacy and safety claims
for homeopathic drugs are held to the same standards as similar
claims for non-homeopathic drugs […] the Commission, in evaluating
the types of evidence necessary to substantiate a claim [and by the way, that is like a microcosm of the activity known as scientific skepticism...] considers
'the type of claim, the product, the consequences of a false claim,
the benefits of a truthful claim, the cost of developing
substantiation for the claim, and the amount of substantiation
experts believe is reasonable.' For health, safety, or efficacy
claims, the FTC has generally required that advertisers possess
'competent and reliable scientific evidence,' defined as 'tests,
analyses, research, or studies that have been conducted and evaluated
in an objective manner by qualified persons and [that]are generally
accepted in the profession to yield accurate and reliable results.'
In general, for health benefit claims, particularly claims that a
product can treat or prevent a disease or its symptoms, the
substantiation required has been well-designed human clinical
testing. For the vast majority of OTC homeopathic drugs, the case
for efficacy is based solely on traditional homeopathic theories and
there are no valid studies using current scientific methods showing
the product’s efficacy. Accordingly, marketing claims that such
homeopathic products have a therapeutic effect lack a reasonable
basis and are likely misleading in violation of Sections 5 and 12 of
the FTC Act […] in summary, there is no basis under the FTC Act to
treat OTC homeopathic drugs differently than other health products.
Accordingly, unqualified disease claims made for homeopathic drugs
must be substantiated by competent and reliable scientific evidence.
Nevertheless, truthful, non-misleading, effective disclosure of the
basis for an efficacy claim may be possible. The approach outlined in
this Policy Statement is therefore consistent with the First
Amendment, and neither limits consumer access to OTC homeopathic
products nor conflicts with the FDA’s regulatory scheme. It would
allow a marketer to include an indication for use that is not
supported by scientific evidence so long as the marketer effectively
communicates the limited basis for the claim in the manner discussed
above.”
Wonderful, wonderful, wonderful.
Now, I'm highly interested
in FTC's language there,
"section 5 [...] applies to both advertising and labeling [...and] prohibits unfair or deceptive acts or practices in or affecting commerce such as [...] deceptive advertising or labeling [...there's a] general requirement that objective
product claims be truthful and substantiated”
in relation to
naturopathy's 'false science categorical self-labeling' particularly in their academic and clinical commerce, and in their political-legislative activity.
Because a naturopathy degree is first and foremost a product in the marketplace, and categorical labeling of a product falsely seems to me to be right within FTC's area of responsibility.
We've seen how accreditation doesn't work, perhaps FTC can help.
So, I left a
comment on the first FTC document I just covered, “OTC Homeopathic Drugs: Established FTC Proof Standards Apply”, and that comment has
been published there publicly by FTC I'm happy to
say.
The
comment is dated 11/26/2016 [here's its permalink].
I wrote:
“The
Naturocrit Podcast and Blog:
This is great news, particularly in terms
of consumer informed consent:
since the FDA was hamstring (or
unwilling), you stepped up to the plate in terms of marketplace
governance.
I am interested in an FTC opinion regarding:
a)
fully-accredited (actually multiply-accredited) in-residence
naturopathy degrees in the U.S. that claim, contrary to this
enforcement policy for homeopathy for instance, that homeopathy and
kind is squarely SCIENCE
b) and also, actually, specifically, that the
supernatural is squarely SCIENCE, and what clearly is implausible and
without evidence is squarely SCIENCE.
I've been writing letters for
years:
like the FDA, it seems that Federal and States' Departments of
Education and Consumer Protection either are
a) hamstrung,
committed-colluding, or simply do not care
b) about this egregious,
unmerchantable product on the market called 'a naturopathy doctorate'
that has Title IV access though academically CATEGORICALLY
fraudulent.
There are lots of 'shoulds' to ask, such as
should:
AANMC-AANP naturopathy be allowed to falsely MARKET the
contents and activities of naturopathy as categorically / broadly
SCIENCE?
The Naturocrit Podcast is on iTunes.
-r.c.”
[Here's a recent AANMC Facebook post that does just that:
].
For what it's
worth.
Ironically the FTC's banner on the page is “Federal Trade
Commission: Protecting America's Consumers” [checked].
Except for people
exploited by academic naturopathy, I know, personally:
because North American naturopathy
basically claims science subset naturopathy subset homeopathy with
impunity.
And you must ally yourself with that in order to operate as a naturopath, which to me is an organized crime.
And I've said this before too, the RICO ACT, I think, relates to this, very very closely.
And yet, I'm highly doubtful of ANYTHING happening to these
fraudsters.
But I still have a duty to at least try, and get them schwacked.
Yet, the ftc.gov article "DeVry University Agrees to $100 Million Settlement with FTC" of 12-15-2016 gives me a little hope.
This has been the first half of the last third of Part Four of this Episode 012.
Yet, the ftc.gov article "DeVry University Agrees to $100 Million Settlement with FTC" of 12-15-2016 gives me a little hope.
This has been the first half of the last third of Part Four of this Episode 012.
Next will be the second half, and last Episode 012 audio recording, which will FINALLY get to MD Atwood's naturopathy critical articles and a few other things.
Thank you for boldly listening.
.
.
.
.
.
.
No comments:
Post a Comment