Tuesday, December 20, 2016

The Naturocrit Podcast – s02e02d3.1 [Episode 012d3.1] - Script & Annotations

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:

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,

 and my letter of complaint to FTC about 'naturopathy's miseducation product labeling'.

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. 

 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?



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.”


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.

Now, I have many years of teaching 'basic law and ethics for allied healthcare'.

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!

“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.”

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:

“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.”


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.

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:


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.

"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.

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."


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."

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."

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.

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.”

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.

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.

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.

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.

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.

“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".


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.

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.


 [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.

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.
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