Vermont Bill H.524 Senate Government Operations Committee Hearing

Vermont Bill H.524 which proposed giving VT licensed NDs, naturopaths, who had passed a “pharmacology exam” the privilege of administering, using and prescribing the same legend drugs that MDs do passed from the House Government Operations Committee http://rosemary-jacobs.blogspot.com/2012/02/vermont-bill-h524-vt-nds-prescription.html to the Senate Operations Committee which held a public hearing on it on April 10, 2012. I presented written and oral testimony to the committee. 

On March 20, 2012 before the hearing took place I sent the State Health Commissioner, Harry Chen, MD, and the Director of the State Office of Professional Regulation, Chris Winters, the following email.

An Open Letter To: Harry Chen, MD, VT Commissioner of Health; and, Chris Winters, Director of the VT Office of Professional Regulation.

If passed as written, Bill H.524 will grant naturopaths, NDs, licensed in VT who pass a pharmacology exam the right to prescribe all the drugs that MDs prescribe.  

Representative Mike Marcotte tells me that you are assuring legislators that the exam that NDs will be required to pass will be sufficiently rigorous to demonstrate that they are competent to prescribe drugs.

Can you tell me specifically: what qualifications the person who draws up the test will be required to have; what the test will cover; who will decide what it covers; how it will be administered; will it be an open book test taken anywhere the candidate chooses over a period of days or a supervised exam over a period of hours, etc.? 

Can you tell me how you can guarantee that any of the answers you give to the above will in fact be carried out? Even if you were to have the authority, time, knowledge and resources to ensure that specific conditions were met what guarantee would there be that another administration would also meet them when not legally required to do so by law?

Why are you pushing to have a bill passed that will give VT NDs more prescription privileges than they already have knowing that you were unaware that their IV use of silver was dangerous and illegal until I brought it to your attention and since the NDs ignored me when I alerted them to their error? http://rosemaryjacobs.com/naturopaths.html How can you trust their judgment or the state's ability to supervise them? 

Why are you pushing to give NDs all the same prescription privileges that primary care physicians have rather than letting them continue to practice under a limited license as they do now? To put it another way, since you were unable to protect the public before, how will you protect it after you give NDs more privileges?

Who drew up the test that the author of the Vermont Medicine Show blog passed? http://vermontmedicineshow.blogspot.com/2012/02/i-have-no-scientific-or-medical.html? What privileges were those who passed that test awarded or going to be awarded? 

On March 29, 2012 I forwarded Chen and Winters the same message adding that I expected them to address those issues at the Senate hearing.

I also sent them and the state’s naturopathic advisors, William Warnock & Sam Russo, the two NDs who had testified before the House Government Operations Committee hearing the following email:

When the Senate Government Operations Committee holds its hearing on Bill H.524, I am going to request that you, or if you are not present, Chris Winters, Harry Chen or whoever represents the naturopaths provide me and the committee with the names and contact information of the companies or individuals from whom you purchase the substances that may be administered IV that you have included on p. 5 of your formulary, 

http://www.vtprofessionals.org/opr1/naturopaths/info/Naturopathic Physician Formulary 20091211.pdf

I will also request the formulations of any of those substances which are not FDA approved drugs and specifically approved for IV use. 

I am especially interested in having this information regarding silver. 

I also will request the names and contact information for the companies or individuals who provide you with the "colloidal silver" included on p. 1 of your formulary as well as its formulation. Is it MSP, ionic silver, a silver compound, a silver salt or colloidal silver? 

Thank you.

This is the written testimony that I presented to the committee:

Vermont Senate Government Operations Committee Hearing on Bill H.524

April 10, 2012

I oppose the section of Bill H.524 that pertains to naturopaths.

Background:

In the 1950s I was given a drug that contained silver by an MD which discolored my skin. The condition which is well known and well documented is called argyria. My doctor was one of the last MDs to prescribe a silver drug for internal use. If he had read his medical journals in an era when drug companies had as much license as dietary supplement companies have today, he never would have prescribed the drug that disfigured me. He would have seen the articles warning doctors about the drug companies' fraudulent ads and would have learned that ingesting silver offers no benefits and causes argyria.

In 1995 when I learned that silver was being sold as a dietary supplement I asked salesmen for evidence showing that their products were safe and effective for something. They had none. When I predicted new cases of argyria, they laughed. Unfortunately, I was right. There are now many.

When I learned in 2010 that VT NDs have a state sanctioned formulary http://www.vtprofessionals.org/opr1/naturopaths/info/Naturopathic Physician Formulary 20091211.pdf that includes “colloidal silver” for use in the eyes (p.1) and “silver” to be administered IV (p.5), I contacted the OPR and attempted to contact the Health Commissioner. 

http://rosemary-jacobs.blogspot.com/2010/08/naturopaths-silver_6314.html

(Scroll down to see correspondence.)

It was only through the efforts of Rep. Michael Marcotte that I was able to get through to the HC and the Director of OPR. 

When NDs learned of my concerns, they ignored them.

http://rosemaryjacobs.com/naturopaths.html 

Questions Regarding the “pharmacology exam” Bill H.524 proposes

The bill proposes that any licensed ND who wishes to prescribe, administer or use legend drugs pass a “pharmacology exam”. 

I would like Dr. Chen and Mr. Winters, the apparent authors of the bill, to explain:

• what qualifications the person who draws up the test will be required to have
• what the test will cover
• who will decide what it covers
• how it will be administered - will it be an open book test taken anywhere the candidate chooses over a period of days or a supervised exam over a period of hours, etc. 
• how they can guarantee that any of their answers to the above will in fact be carried out 
• even if they were to have the authority, time, knowledge and resources to ensure that specific conditions were met what guarantee would there be that another administration would also meet them when not legally required to do so by law
• why are they pushing to have a bill passed that will give VT NDs more prescription privileges than they already have knowing that they were unaware that their IV use of silver was dangerous and illegal until I brought it to their attention and knowing that the NDs ignored me when I alerted them to their error
• how can they trust NDs’ judgment or the state's ability to supervise them 
• why are they pushing to give NDs all the same prescription privileges that MDs have rather than letting them continue to practice under a limited license as they do now 
• who drew up the test that the author of the Vermont Medicine Show blog passed http://vermontmedicineshow.blogspot.com/2012/02/i-have-no-scientific-or-medical.html 
• what privileges were those who passed that test awarded or going to be awarded 

Questions about the sources and formulations of substances that are not approved drugs included in the 2009 Vermont Naturopathic Formulary:

I would like the NDs or their representatives to tell the committee and the public:

• the names and contact information for the companies or individuals from whom VT NDs purchase the substances that may be administered IV that they have included in their formulary 
• the formulations of any of those substances which are not FDA approved drugs and specifically approved for IV use, especially silver
• the names and contact information of the companies or individuals who provide VT NDs with the "colloidal silver" included on p. 1 of their formulary as well as its formulation

General Questions:

• under federal law must all drugs be manufactured by a licensed manufacturer or licensed compounding pharmacist
• must all substances intended for IV administration be sterile
• do Vt NDs, the Health Commissioner and the Director of OPR believe that NDs practicing in VT are exempt from federal drug laws
• is the state aware that there is an ND in Quebec charged with manslaughter because her patient died after she illegally injected him with magnesium that was contaminated with bacteria http://montreal.ctv.ca/servlet/an/local/CTVNews/20120201/mtl_naturo_120201/20120201/?hub=MontrealHome
• if an ND injures or kills a person because the State Of Vermont permitted him to violate federal drug laws or gave him privileges based on misinformation he or his colleagues provided about their educations that was accepted but never verified by the state, will the state and all of its citizens be held liable

Conclusion:

Although I  believe that the questions I’ve presented are serious issues that the committee must consider, I do not believe that the section of Bill H.524 that pertains to NDs should be passed even if the state bureaucracy satisfactorily responds to them because I think that the manner in which the state and the NDs have dealt with silver shows at best very bad judgment on the part of both parties.

When the state learned in 2010 that the VT ND Formulary illegally included silver, dangerous snake oil, they blithely responded over a year later, “It has to be removed but the way the rules are written we can’t do that. We have to change the law to do it.” To me that makes no sense. Isn’t including an illegal, dangerous substance in the formulary much worse than breaking a law or a rule to remove it?

At the very least the state and the NDs should have jointly issued an official notice and consumer alert to all the NDs licensed in VT and to the media informing NDs and the public that “colloidal silver” and “silver” had mistakenly been included in the formulary, that using them as indicated was illegal, that there was no evidence showing that they offered benefits and a lot of evidence demonstrating that they could cause harm by seriously discoloring people’s skin and eyes. 

The way the state and the NDs have dealt with silver along with the way the state has and is still passing laws behind closed doors giving NDs the same privileges that MDs have without their ever having to demonstrate that they deserve them all smells to me of cover-up, back room deals, favors to special interest groups, all things that the majority of Vermonters vehemently oppose, all things that harm the public and betray the trust it has in government. 

That is the end of my written comment.

Neither Warnock, Russo nor Chen appeared at the hearing when I was there. Gabriel Archdeacon, ND who said he was covering for Sam Russo, who had been scheduled to attend but was unable to do so, read a written statement. 

Mr. Winters said that the test that Ben from the Vermont Medicine Show blog had taken and passed was meant to assess an ND's knowledge of the state formulary. Ms. Mongan a lawyer representing the Vermont Medical Society disagreed. She said that the intention had been to draw up an exam that would test, “an applicant’s knowledge of the pharmacology, clinical use, side effects, and drug interactions of agents in the naturopathic formulary”, adding that what had happened instead was that an exam had been drawn up by the 2 state naturopathic advisors, the same ones who still served in that capacity, and that both of them had also taken the test themselves. Do you think they passed? 

I’m sorry. I couldn’t keep from asking that. It is so typical of NDs and so totally different than any other profession I’ve ever dealt with. They start their own schools. Use their own teachers. Name their own courses and then shout from the rooftops that what they learn in those classes is what scientists and MDs learn in classes with the same names. In other words, We study pharmacology. They study pharmacology. We learn pharmacology. They learn pharmacology. We know as much as they do, so there!

While it is possible that all or some of what they learn is the same, I am totally astounded that legislators across N. America take their word for it without ever even trying to independently verify their claims. Is it any wonder people hold our government and politicians in such low esteem? Not only is no one watching the store, they are giving the merchandise away for free! They are giving NDs the same privileges MDs have without making sure that they have earned them. 

I wonder what would happen if a group got together and set up an alternative flying school. If they insisted that they had the same education and skills as regular pilots and that they had passed tests that they had drawn up themselves which they insisted were as rigorous as those that real pilots took would governments take their word and license them to fly over my house? 

Aside from Mr. Winters’s comment about the purpose of the exam that Ben passed, neither Gabriel nor he addressed any of my other questions although Archdeacon did state that NDs do not use silver intravenously. Addressing the senators, he glanced my way and said, “You have heard complaints about the item silver on our formulary. While it is listed within the minerals section, some of which are used intravenously (IV), to my knowledge no ND has used silver in this way. Furthermore, it is my understanding that there have been attempts by our organization to eliminate this item from our formulary. Unfortunately, the process of updating our formulary is so dysfunctional that this has not happened.”

Unfortunately, Mr. Archdeacon didn’t mention how silver had gotten into the formulary in the first place or how it had been included in the category of minerals that “may be administered” intravenously. Neither did he say how colloidal silver had gotten into the formulary or whether or not he knew of NDs who used CS topically or put it in patients’ eyes nor did he say whether or not he knew any NDs who administered silver orally or sold, promoted or recommended silver supplements to the patients they saw. Of course, even if he didn’t know of any who did any of that, it wouldn’t mean that there weren’t any.

(Ben, owner of the Vermont Medicine Show blog, video taped the hearing. He also gave testimony which I taped. When he posts the video I will link to it.)

I told the committee that the state bureaucrats were asking us to trust the state and the NDs and that I most certainly did not trust them. Based on my experience with both groups I thought that they had demonstrated that they didn’t deserve anyone’s trust and that Bill H.524 needed to include guarantees that the pharmacology test the state intended to give to NDs adequately showed that those who passed had the knowledge and competency required to safely and effectively use prescription drugs. 

I added that I believe that adults should be able to choose the health care practitioners, drugs and therapies that they want and that included taking silver internally if they so desired. However, I also believe that once something like a formulary is sanctioned by the state or a practitioner is licensed by it that the standards change. They have to be much higher if for no other reason than that the public assumes that when the state gives such endorsements that it has done their homework for them, that it has investigated and determined that the goods and services being sold are safe and beneficial and that it therefore is unnecessary for the customer or patient to determine that for himself.  

I further explained that people who had gotten argyria from silver “dietary supplements” had been having dermatologists treat them with laser therapy. The cost of a whole face was about $7,000. and no one was satisfied with just a face. The cost of a whole body was estimated to be $100,000. The treatment had to be repeated and no one knew if there would be side effects later on. 

Most of those who have had laser therapy done to treat argyria have had insurance companies pay for the procedure. I don’t believe that it is fair to use remedies or therapies that have never been tested or that are known to be dangerous or to use the services of practitioners who use such things and then expect others to help pay their bill if they are injured by them, and I don’t think it is fair to ask others to reimburse them for the costs of dangerous or untested drugs and therapies or practitioners who habitually use them.  

I also pointed out a memo from Donald R. Swartz, MD, to Sharon Moffatt, Acting Health Commissioner dated December 11, 2007 about the Naturopath Formulary that Madeleine Mongan from the Vermont Medical Society had presented to the commission in which it stated that Dr. McCormack, the pharmacologist who had been consulted about the naturopathic formulary, had been concerned about “the administration of agents intravenously. This concern was a strong element in the recommendations of the advisory group. As a result, in general the formulary prohibits IV use even when that route is allowed by the label. The exceptions to the rule are identified by specifically so noting in the formulary. These exceptions generally fall into one of two conditions. The first is the use of standard IV solutions such as saline, used to treat dehydration. The second is the use of IV preparations of vitamins, minerals, or other ‘natural’ substances which are allowed by the current formulary and which represent well established and standard practice of naturopathy. It is my view that reservations about the safety of the preparations or their use are offset by the long history of use and that the use is so integrally part of naturopathic practice that it falls within the intent of the legislature regarding the scope of practice of the ND. The proposed formulary authorizes IV administration of ‘Childbirth preparations.’ This does not conform to either of these exceptions, and therefore I agree that IV administration of these agents should be disapproved.”

I noted that Dr. Swartz had apparently taken the NDs word for their long history of IV use of the substances in the formulary, but I didn’t think that they could have been using them for a long time, at least not legally, since it is only within the last thirty or so years that NDs have been given the right to use substances intravenously and even today they can only do that in a few states. Also, long history of use does not demonstrate safety. 

Vermont naturopaths, naturopaths prescribing drugs, Gabriel Archdeacon, Sam Russo, Bill Warnock, Chris Winters, Harry Chen, Vermont primary care physicians, health care costs

Do Naturopaths In Vermont Use Silver?

Naturopaths speaking at legislative hearings are telling legislators and me that they don’t know of any ND in VT who uses silver. During a break, one told me directly that: she doesn’t know of any ND who uses silver; NDs don’t know how silver got into their formulary; and, they’ve been trying for years to get it removed.

At a hearing before the Senate Government Operations Committee, Gabriel Archdeacon, ND, testified that, “You have heard complaints about the item silver on our formulary. While it is listed within the minerals section, some of which are used intravenously (IV), to my knowledge no ND has used silver in this way. Furthermore, it is my understanding that there have been attempts by our organization to eliminate this item from our formulary. Unfortunately, the process of updating our formulary is so dysfunctional that this has not happened.”

Unfortunately, Gabriel didn’t mention how colloidal silver got into the formulary or whether or not he knew of NDs who used it topically or put it in patients’ eyes nor did he say whether or not he knew any NDs who administered silver orally or sold or promoted silver supplements to the patients they saw. Of course, even if he didn’t know of any, it wouldn’t mean that there weren’t any.

While the legislators may take the naturopaths at their word, it will take  independent verification to convince me that their claims are true. 

What follows is what I’ve come up with so far in my attempt to obtain such verification. 

1.

When I first learned that Vermont NDs had included silver in their state sanctioned formulary, I wrote to the State Office of Professional Regulation, their regulating agency, http://rosemary-jacobs.blogspot.com/2010/08/naturopaths-silver_6314.html, (scroll down to the correspondence) and asked, “How can NDs use ‘colloidal silver preparations’ as topical or ophthalmic antibacterials and how can they administer silver IV…?”  This was in reference to the Naturopathic Formulary, http://www.vtprofessionals.org/opr1/naturopaths/info/Naturopathic Physician Formulary 20091211.pdf [pdf download], where it specifically states:

Antibacterial Agents - Topical And Ophthalmic Antibacterials: Silver Sulfadiazine Cream, Mupirocin, Nemycin, Chlorhexidine, Clioquinol, Colloidal Silver Preparations. (p.1)

Minerals, their derivatives and compounds (May be administered IV) - Boron…Silver…Zinc. (p. 5 which includes 17 additional substances)

The agency forwarded my email to the naturopathic advisor who according to testimony given to the Senate Government Operations Committee by Madeleine Mongan, a lawyer with the Vermont Medical Society, had been the advisor at the time the 2009 formulary was drawn up and implemented. OPR forwarded me the advisor’s response on May 27, 2010. He wrote:

“Antibiotics are not allowed to be administered IV which includes colloidal silver. In the minerals section it says "may be administered IV". The list of minerals is an example of minerals that are prescribed, some but may used IV. Silver is not intended to be administered IV. Other minerals are meant to be administered IV. There are no NDs in the state that I know of administering silver IV. Silver is generally used in medicine as a topical antimicrobial in other forms than the colloidal form and we will consider updating the language of the formulary to reflect this. None the less, you should probably respond thanking her for her comments which we will take into consideration as we annually update the formulary which is done with the opportunity for review of professionals from other professions.

Sam”

That made no sense to me.  

When Sam wrote, “The list of minerals is an example of minerals that are prescribed, some but may used IV,” maybe he meant to write, “Some may be used IV”?  I’ll give him the benefit of the doubt, but come on, Sam. You said, “Silver is not intended to be administered IV.” Then why on earth is it included with the minerals that “may be administered IV”? How do NDs know they aren’t supposed to use it IV when the formulary says that it may be used that way? Do you have phone conferences explaining that while you wrote one thing you really meant something else? I can hear it now, “Hey, guys! How ya doing? Just wanted ta make sure ya all know that while we listed silver in the official state sanctioned formulary with the minerals that can be administered IV, we didn’t mean it should be administered IV. Ya all knew we didn’t mean it, didn’t ya?” 

And even if it were true that the NDs who wrote the formulary never meant that silver should be used intravenously and even if it were true that all NDs licensed in Vermont knew that, putting it in the IV category gave every ND licensed in the state the right to use it that way which is exactly what I would expect any ND to do who believed that it was safe and beneficial. Surely one or many could be using it intravenously without Sam’s knowledge.

But why hadn’t Sam addressed my specific question about how NDs could use “colloidal silver preparations” as “topical or ophthalmic antibacterials”? Interestingly, just like Gabriel he didn’t say that NDs didn’t use “colloidal silver” although he did call it an “antibiotic” in spite of the fact that the FDA has said that it is not. 

Sam also said that silver was included in the “minerals that are prescribed”. Did that mean that he knew NDs prescribed silver to be taken other ways than intravenously? Orally or in the eyes perhaps? I have no idea. As I said before, Sam’s response made absolutely no sense to me. In addition to being illogical it was incoherent. 

Also interesting is that Sam never indicated that the process for updating the formulary was dysfunctional, and he was one of the two NDs who served as official advisors to the state for their profession when he wrote that. He even added that they would take my comments into consideration when they updated the formulary, an annual occurrence, according to Sam, which he seemed to fully expect would take place on a timely basis. 

2.

When Arline and I went to the Senator Bernie Sanders’s alt. med. promotional conference, http://rosemaryjacobs.com/naturopaths.html, in October 2010 we spoke to the ND manning their information booth who promised she’d try to get silver removed from the formulary but said it could take awhile do to red tape. She also said that she’d call all the NDs in VT and tell them not to use silver. When I said, “There are probably some selling silver supplements to their patients,” she replied, “There probably are.” 

3.

When with the aid of local State Representative Michael Marcotte, I finally got through to the Director of the Office of Professional Regulation, Attorney Chris Winters, in June 2011, http://rosemary-jacobs.blogspot.com/2011/08/naturopaths-vermont-and-me.html, (scroll to # 4) he said that the ND advisors had agreed “that colloidal silver should be removed from the naturopathic physician formulary…” That sounded to me as if the NDs fully intended to leave silver, the mineral they were permitted to use IV, right there. I suspected that they still didn’t get it and that the only reason that they had agreed to remove “colloidal silver” was because on a visit to the OPR office I had given one of the administrators copies of documents showing the illegality and danger of using silver as a drug which included an article from the Wall St. Journal that was unavailable online without paying a fee. In it federal regulators were quoted as saying that “colloidal silver” was a “total scam”. I guessed that reading that had really upset the state regulators and that the language was plain enough for the NDs to understand whereas the language in the medical literature and the Federal Register, the scientific and legal language, was beyond their scope of education. 

For that reason, I insisted on meeting personally with Mr. Winters so that I could ask him if the NDs had agreed to remove silver as well as colloidal silver from their formulary and to impress upon him the necessity of doing so. In answer to my question as to whether or not they had agreed to remove silver, he said “probably not”. He then asked why it should be excluded. I explained then came home and sent him an email, http://rosemary-jacobs.blogspot.com/2011/08/naturopaths-vermont-and-me.html, scroll to # 6, that referenced and quoted from the FDA’s final rule about silver in the Federal Register that specifically states that silver cannot be used as a drug and that there is no evidence that it offers benefits and evidence that it causes argyria.

4. In response to my question as to where the NDs got the colloidal silver, silver and other substances they used IV from, Mr. Winters said they had told him from various sources. They couldn't or wouldn’t provide names. He didn’t say that they denied using silver or that they denied using it IV. 

5. When I explained my concerns with silver and the other IV preparations listed in the ND formulary, Mr. Winters said he wondered why no one had brought these things up before. He had been director of the ND regulating agency from before the 2009 formulary in question had been drafted and implemented and during the intervening years.

6.

Madeleine Mongan, a lawyer with the Vermont Medical Society, presented a memo from Donald R. Swartz, MD, to Sharon Moffatt, Acting Health Commissioner dated December 11, 2007 to the Senate Government Operations Committee. It stated that Dr. McCormack, the pharmacologist who had been consulted about the naturopathic formulary, had been concerned about “the administration of agents intravenously. This concern was a strong element in the recommendations of the advisory group. As a result, in general the formulary prohibits IV use even when that route is allowed by the label. The exceptions to the rule are identified by specifically so noting in the formulary. These exceptions generally fall into one of two conditions. The first is the use of standard IV solutions such as saline, used to treat dehydration. The second is the use of IV preparations of vitamins, minerals, or other ‘natural’ substances which are allowed by the current formulary and which represent well established and standard practice of naturopathy. It is my view that reservations about the safety of the preparations or their use are offset by the long history of use and that the use is so integrally part of naturopathic practice that it falls within the intent of the legislature regarding the scope of practice of the ND. The proposed formulary authorizes IV administration of ‘Childbirth preparations.’ This does not conform to either of these exceptions, and therefore I agree that IV administration of these agents should be disapproved.”

7.

The second edition of the Textbook of Natural Medicine first printed in 1999 and reprinted twice in 2000 which was edited by prominent naturopaths Joseph E. Pizzorno Jr. and Michael T. Murray and used, I believe, in ND four-year schools lists “colloidal silver” for the treatment and prevention of opportunistic infections in AIDS patients (p. 1292). Since the route of administration isn’t stated and the dose is measured by the spoonful, I assume it is given by mouth. I found no listing at all in the textbook index for either the term “IV” or “intravenous”. The citation given to support the use of colloidal silver was the journal article: Electrochemical Ag+ for Preservative Use; Applied & Environmental Microbiology, Dec. 1992, p. 3834-3836; Vol 58; # 12; Simonetti, et. al. (Ag is the chemical symbol for silver. The plus sign indicates ionic silver.)  

Using this reference is laughable. Ask any pharmacologist or MD. The study, which of course I have a copy of, was done as the title states to test the value of using silver as a preservative, specifically a preservative for cosmetics and drugs. The authors didn’t test it to see if it worked as an antibiotic. One of the most basic things a pharmacologist, but evidently not an naturopath, even one who claims to know and practice scientific medicine, knows is that something that works in a test tube may not work inside people and that something applied to the skin may not be safe to drink. Silver, like bleach and alcohol, is a disinfectant. Vodka doesn’t treat or prevent pneumonia. Another reason using this reference in support of their recommended therapy is laughable is that another basic tenet of science is that one or a few studies don’t mean much. To draw reliable conclusions, many good studies consistently giving the same results are needed. It shows once more that although NDs insist that they practice scientific medicine that they don’t have a clue as to what scientific medicine is.

Another interesting thing, at least to me, is that in 2002 Michael Murray published The Pill Book Guide To Natural Medicines. By then he had found and referenced the FDA rule in the Federal Register from 1999 stating that silver cannot be sold as a drug, that it is useless and dangerous and can cause argyria. Murray gave it F grades for both effectiveness and safety. 

8. 

Dr. Chen never denied that VT NDs use of silver, not even that they use it intravenously.  http://rosemary-jacobs.blogspot.com/2011/08/naturopaths-vermont-and-me.html, # 12.

9.

Over the years many people have written to tell me that a naturopath told them to use a silver supplement. I always had assumed that those were mail-order naturopaths, not those who had gone to 4 year ND schools. I just didn’t think that the people teaching at those schools could be so ignorant, or so deeply entrenched in their belief that nature heals and doesn’t harm, as to not know and warn students about the danger and uselessness of taking silver internally. But after learning that the VT NDs who had gotten degrees from ND schools included it in their state sanctioned formulary, I asked the next person who told me that an ND had recommended the stuff if the ND, who practiced in a state where NDs are not licensed, had a degree from a 4 year ND school. She said that she had and that she wouldn’t have gone to her if she hadn’t.

10.

There is an ND, not in Vermont, on Youtube doing a promotional video for her business who looks like she has argyria. A person interviewing her asked about colloidal silver. The ND was very vague indicating that it can be used but that nothing should be used all the time. Since there is no way to accurately determine from a photo or video if a person has argyria, I would love to contact this woman and ask her, but I don’t have an email address. The website for her business is “under construction” and has been ever since I first saw it about 6 months ago. I don’t want to phone because I want a record of our conversation.

11.

The word or rumor in the alt community in my little corner of the Vermont woods is that NDs use silver.

I realize that #s 10 and 11 have no value as evidence taken alone, but in view of everything else, I myself give them a little weight. 

Looking at the total picture painted by all of the above, everything I’ve found to date, leads me to believe that NDs in Vermont intentionally included colloidal silver and silver for internal use, even IV use, in their formulary and that aside from the pharmacologist mentioned above who objected to NDs using substances intravenously, no one besides myself has ever objected to their including colloidal silver or silver in their formulary, not even in their including silver in the category of minerals that that “may be administered IV”. The fact that several NDs say that they don't know any NDs in Vermont who use silver intravenously is meaningless even if it is true, and there is no way to know if it is or not.

I suspect that there are many VT NDs who, unaware of or contrary to, all the objective evidence, believe that silver taken internally offers benefits and is safe and that that is why it was included in their formulary. I think the only reason the NDs agreed to remove it is because, when presented with the evidence, the state bureaucrats realized the illegality and danger of leaving it there and said that it has to be removed. I also think that someone convinced many of the NDs that the inclusion of silver, especially for IV use, and the attention I was calling to it, reflected very poorly on them and that for business purposes they had to do their best to distance themselves from this major faux pas. I suspect that most of the NDs now consider the inclusion of silver a marketing goof, not a horrible medical decision or even a mistake. 

How about you? Do you think VT NDs use, promote and sell silver for internal use and use in the eyes? Do you think they use it IV? Do you think that they and their state regulators are being honest with the legislature and the public? Do you think that the legislators should take the word of the state officials and the NDs without verifying their claims independently? 

I think the NDs are running ahead of the bulls trying desperately, and very successfully, to avoid being trampled. When they get caught doing something that gets bad PR, they deny doing it if they think they can get away with it, just like all good business people in this unethical era. They call it “marketing”. I call it deceiving. 

And I don’t believe that NDs are only doing this with silver. I think they are engaged in a very successful marketing/lobbying campaign which I’d be amazed to learn isn't being run by paid professionals. I think they are using my blog to find the leaks in the dike that have to be plugged in order to make them look good and presentable to the government and the public.

In Vermont the state bureaucrats are advocating for the NDs. While all the hearings I’ve gone to have had NDs present, I’ve yet to see an MD, and I’ll bet that while the NDs are furiously lobbying the state bureaucrats and elected officials that MDs aren’t. I believe that is because NDs desperately need business to keep their doors opened while MDs are overwhelmed trying to provide rational care to large numbers of really sick people in a health care delivery system that is a mess. The majority of MDs aren’t accepting new patients while NDs are advertising for them and spending lots of time with patients. Their office hours seem short and, of course, they supplement their incomes with the sale of supplements even to the patients they treat, something I think is unethical and should be illegal.

If there is anyone reading this who has something to add that I’ve missed, please do so in the comment section. I’d be most interested. I’d be especially interested in hearing from NDs.

Vermont naturopaths, silver, colloidal silver, silver IV, silver intravenously, health care in Vermont, Gabriel Archdeacon

Naturopaths Terrify Me. NDs Do Not Practice Scientific Medicine

I was facially disfigured by an incompetent MD who practiced unscientific medicine back in the 1950s. My MD was a good caring human being who was so ignorant that he used snake oil. 

http://rosemaryjacobs.com/rose1.html

http://rosemaryjacobs.com/rose2.html

He was so naive that he believed the fraudulent ads from drug companies in an era when they were as unregulated as the “dietary supplement” companies, often owned by drug companies, are today.

http://rosemaryjacobs.com/index.html

http://www.bloomberg.com/news/2012-02-27/pfizer-buys-maker-of-emergen-c-vitamin-alacer-to-add-to-supplements-line.html 

Naturopaths, NDs, use snake oil now. They use silver, the “natural remedy” that disfigured me. MDs stopped using silver internally over 50 years ago, but what really terrifies me is that NDs, unlike those who practice evidence-based medicine, use, promote and sell “dietary supplements” aka “natural remedies” before they are ever studied scientifically to determine if they are safe and beneficial. One or more of these untested “remedies” could be totally useless and as lethal as cigarettes but by the time that is discovered it will be too late to save many from premature deaths. That is why naturopaths terrify me. 

Patients Beware! NDs are not MDs. No matter what they claim, naturopaths do not practice scientific or evidence-based medicine. No scientist would routinely use, promote or sell untested products or make claims about the safety and efficacy of untested products. Anyone who does that, as NDs routinely do, either doesn’t know diddle about science or is lying when he claims that he practices scientific medicine. 

The NDs of today, including those who have graduated from “naturopathic medical schools”, are as ignorant and dangerous as the MD who disfigured me over 50 years ago. But with today’s NDs it is not a problem of incompetent individual practitioners. It is a problem with the entire profession. Naturopathy is a belief-based system of medicine, not an evidence-based or scientific one and the State of Vermont is giving NDs the same privileges that MDs have. This is terrifying. This is dangerous. It is also highly deceptive.


dangerous doctors, naturopaths, incompetent doctors, vermont naturopaths, naturopathic schools, state of vermont, unscientific medicine