FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products #00538

Submission Number:
Anna Vakil
Initiative Name:
FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products
I am a practicing homeopath and while I completed my training about six months ago, for more than 20 years prior to this I regularly purchased OTC homeopathic products like many other members of the general public. It was my experience of effectively treating my children and myself during this period that resulted in my decision to pursue homeopathy professionally as a second career following my first career in planning and public policy teaching and research. Before, this, however, I usually purchased single remedies in a 30C potency since these were readily available, but occasionally bought combination remedies if I was uncertain about which individual remedy might be required. Conditions in my own family that I treated included hives, food sensitivities, nasal allergies, sore throats, coughs, stomach upsets, diarrhea and flu as well as cuts and scrapes. I used introductory written material on homeopathy to help guide my decisions about which remedies to purchase. In many cases, I took my children to the doctor in order to verify they did not have a serious condition and the doctor would typically prescribe a conventional medication such as an antibiotic. I would then try the chosen homeopathic remedy and if it did not work within a few hours, I would administer the Rx prescription. With recurring conditions, I became skilled enough to the point that it was no longer necessary to take my children to the doctor since I was able to easily recognize the condition and they recovered quickly with the homeopathic remedy alone. What I have found helpful in understanding how homeopathic remedies might work is the well referenced summary by Iris Bell PhD MD of some of the recent research on homeopathic remedies and nanoparticles (link #1 below). Perhaps the most important takeaway from this article is the following statement: "… although skeptics have long attacked homeopathy because of the molecular limits of Avogadro's number and the presumption that homeopathic medicines are too "dilute" to contain any active material, the scientific evidence is that homeopathic remedies are nanoparticles, not ordinary conventional bulk forms of source material. That fact changes the scientific issues completely from a debate over "placebo effects" to a serious scientific consideration of how nanoparticles can act in the body to stimulate healing processes". If true, this statement has far-reaching implications. Unfortunately, the process of independently verifying its accuracy (and other claims such as the clinical efficacy of homeopathic remedies) requires a working knowledge of a number of fields of scientific inquiry. As a result, motivated members of the general public tend to rely on self-appointed interpreters of the science on homeopathy who repeatedly circulate outdated assumptions that are readily accessible but are not supported by the accumulated evidence. I would respectfully urge the members of the FTC to read the attached article link (#1 below) and, if at all possible, the fuller review article published by Iris Bell and Mary Koithan in 2012 in the Journal of Complementary and Alternative Medicine, (link #2) and to reflect on the latter article's conclusion and its significant implications for the advancement of human health: "The proposed model suggests that homeopathy is not only scientifically "plausible," but also grounded in an extensive empirical research literature. Homeopathic remedies come into existence and exert their biological effects mainly as nanostructures. Physiology, not pharmacology, is the most relevant discipline for studying remedy nanoparticle actions… The resultant findings on what homeopathic remedies are (highly reactive nanoparticles) and how they interact with complex living systems (as pulsed, low level doses of a salient and novel environmental stressor) could significantly advance the field as a valuable form of nanomedicine". Thank you for providing me the opportunity to contribute to this debate.