FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products #00549

Submission Number:
William Rogers II
Initiative Name:
FTC to Host September Workshop in Washington, DC, to Examine Advertising for Over-the-Counter Homeopathic Products
As a relatively late convert to the practice of homeopathy, I wish that I had enjoyed as much confidence in the safety and efficacy of conventional OTC medications during my years of pediatric practice as I now have for OTC homeopathic remedies. I never hesitate to recommend OTC homeopathic remedies, when indicated, to friends and colleagues as well as to patients; and, of course, I use them myself. Not once have I received a complaint about an adverse effect arising from the use of these products. In addition, the implicit encouragement of self-care that is a byproduct of understanding and using OTC homeopathic remedies properly is, in my opinion, a substantial public health benefit that we would all do well to support. Lingering misgivings about the mechanisms of homeopathy seem misguided to me -- especially in the face of over 200 years of repeatedly validated clinical experience throughout the developed world. This is not a transient fad, and the supporting evidence is not solely anecdotal. There is a substantial body of work that demonstrates the efficacy of homeopathic treatment, including placebo-controlled, double-blind (and even triple-blind) interventional studies. The work of Iris Bell, MD, PhD, has been exemplary in these endeavors. It is also not true that scientific methods have failed to elucidate possible mechanisms by which homeopathic remedies exert biological effects. Recent studies of ultra-dilute solutions that are subjected to succussive potentization have demonstrated that they acquire the capacity to store 'information' through the mechanisms of intra-molecular bonding. These are new frontiers in science, but they are very promising -- and, to me, the mechanisms that are being proposed seem less far-fetched than the conjectural 'science' that is routinely cited in support of the use of many psychiatric medications. Indeed, one cannot help but wonder how many conventional OTC medications have been subjected to the same levels of statistical scrutiny that are now being demanded of OTC homeopathic remedies. And safety? I suspect that there have been more deaths from OTC pseudoephedrine formulations than from all OTC homeopathic remedies (http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5601a1.htm). Finally, even if there were legitimate concerns about the safety and efficacy of OTC homeopathic remedies, then I hope that the FDA would fulfill its oversight responsibilities not by tossing out the baby with the bathwater but by encouraging the development of research initiatives, biostatistical techniques, and epidemiological methods that are appropriate for assessing these products in the context of the practice of homeopathy. I strongly urge you to support the continued responsible use of OTC homeopathic remedies. Thank you for the opportunity to provide this input, William Rogers II, MD, MPH, FAAP