FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products #00403

Submission Number:
Peter Gold
Initiative Name:
FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products
Thank you for the opportunity to comment on your review of advertising standards for homeopathic products. I am a well trained biologist and have been using homeopathic products for my family since 1999. Our family GP is an MD practicing integrative medicine and has been using homeopathy successfully with her patients for 20 years. In addition, my wife and I have taught ourselves the basics of homeopathy for very simple acute diseases and injuries and have found it easy to find what we need at retail and online. We love how well we respond to homeopathic remedies and having ready access to those remedies at retail and online is extremely important to us. Does advertising effect our purchase decisions? Packaging yes. Advertising - no. As a biologist by training - I was at first highly skeptical of homeopathy. I first began investigating it as a member of the Board of Directors of Hartford Hospital. I sat on a special integrative medicine panel. Over time, skepticism yielded to curiosity and I began to probe the subject in great depth. I subsequently met our present GP and now use homeopathy for most of our medication needs. In truth - much research has been done on this topic over the past 200 years. That research has included basic science studies as well as pre-clinical and clinical research (http://homeopathyusa.org/uploads/Homeopathy_references.pdf). And there is a vast amount of epidemiological evidence from reliable public health records as well as the case reports of tens of thousands of physicians. Additionally, homeopathy has proven to have a safety record unparalleled in the history of medicine. How could that be? And are there legitimate questions about how homeopathy works? Yes and it seems the answer to how it works is tied to why it is so safe. Twelve (12) independent labs from around the world have now verified that homeopathic remedies contain small quantities of nanoparticles generated from the original medicinal substances during the manufacturing process - and that those nanoparticles persist from potency to potency. And it has been demonstrated in multiple studies that nanoparticles produce beneficial and therapeutic hormetic effects in living organisms (see papers like Nascarella, M. et. al., A METHOD TO EVALUATE HORMESIS IN NANOPARTICLE DOSE-RESPONSES, Dose-Response, 10:344--354, 2012 and other papers on this topic). Should the FTC alter the way homeopathic products are advertised or sold. 500 million people worldwide rely on homeopathic remedies for their health. It would be a crime to allow special interests with opposing business objectives to persuade regulators there is a problem where none exists. To that statement I add this caveat - there are companies that sell products using the word homeopathic that are not in fact formulated to HPUS standards. That practice needs to stop. But for the vast majority of homeopathic products - please protect our rights to choose and purchase these products at retail and over the internet. Thank you for considering this opinion.