Sunday, April 29, 2012

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. 

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,, (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, 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.

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. 

When Arline and I went to the Senator Bernie Sanders’s alt. med. promotional conference,, 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.” 

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,, (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,, 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.

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.”

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. 

Dr. Chen never denied that VT NDs use of silver, not even that they use it intravenously., # 12.

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.

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.

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

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