Welcome to Health Canada Approves… where we ask you to determine which products have been licensed by Health Canada’s Natural Health Products Directorate.
Here are the results from last week’s poll.
- Buzzardskill 22: Anishinaabe remedy for cough and cold relief (67%, 36 Votes)
- Plumbum 4CH: Homeopathic remedy (33%, 18 Votes)
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Buzzardskill 22 was the clear favourite this week, but alas, it is no testament to ancient Anishinaabe wisdom. The actual approved product is Plumbum 4CH, proudly bearing Natural Health Product Number 00876119 as proof of its safety and efficacy.
Plumbum (abbreviated Pb on the periodic table) is simply lead, and 4CH tells us that it’s a homeopathic dilution of one part in a hundred million. Using the latin name is quite common for homeopathic remedies, and Plumbum makes it easy to see why. Lead is a poisonous heavy metal that should be stridently avoided, but Plumbum…well, that just sounds like healing in a bottle. This kind of re-branding strategy is common in advertising, and its ability to impact our risk perceptions is well established. [For more on this topic, scroll down to the block quote around the middle of this recent post.]
No, not that Plumbum
So next question: why would someone buy really really dilute lead, regardless of what it’s called? Health Canada tells us that Plumbum’s Recommended Use or Purpose is (wait for it): “Homeopathic remedy”. Well that certainly clears things up. And of course, by issuing a Natural Health Product Number, Health Canada is telling consumers that it’s effective at being a homeopathic remedy.
Also, tautologies are tautological.
But the absurdity doesn’t end there. The NHPD database for Plumbum advises consumers to “Consult a health practitioner if symptoms worsen or persist.” Symptoms of what exactly? It’s not recommended for any condition.
So Plumbum has vaguely deceptive branding, no recommended use, meaningless safety warnings, and — being a high-dilution homeopathic preparation — no plausibility or evidence supporting its magical principles. Nice work Health Canada…I feel healthier already.
For the life of me I cannot understand the point of issuing a unique ID number for such a product. It’s enough to make a blogger go a little bit Jack. But I signed up for this gig, so I’m duty bound to deliver your choices for this week, which you’ll find below. And remember, the real product (sigh) “has been assessed by Health Canada and has been found to be safe, effective and of high quality under its recommended conditions of use.”
- Photosyn 12: Vital antioxidant. Contains 12 parts blue algae per dose. (60%, 41 Votes)
- Sinupas: Homeopathic remedy for sinus congestion and inflammation. (40%, 27 Votes)
Answers next week…naturally!
Hi Erik,
Could you give us an idea of the prevalence of this type of product description from the NHPD?
I find it utterly bewildering that Health Canada could so blatantly allow and promote this nonsense. The monograph has no information or referencing on the product whatsoever. It is reasonable to suggest that an average person reading this, being probably ignorant of the true nature of homeopathy, but knowing that it is supposed to contain lead, would wonder why there is no warning or instructions etc.
Would it be useful to register some type of complaint in these cases? To whom? Any ideas?
Dianne, I did a quick search of the Product Purpose extract, and of the nearly 24,000 products licensed as of Sept 2nd (date of extract), about 7400 have no recommended use at all. The vast majority of these simply say Homeopathic Medicine / Remedy / Preparation, but there’s also similarly unhelpful Recommended Use wording for Gemmotherapy, Oligotherapy, and Organotherapy. And that’s using a very strict definition that only captures products with no indication at all of what they’re to be used for – products like Plumbum. There are thousands more that occupy the next level of vagueness, such as those that say they’re a factor in the maintenance of good health, or that they’re an antioxidant. Plus, I’m sure my Anglo eyes missed a bunch of the French ones. But safe to say that nearly a third of the products in the database have no recommended use.
In most cases, this is by design. The evidentiary requirements only allow specific claims for homeopathic preparations that contain two or more ingredients, have dilutions under under 30CH (one part in a trillion trillion trillion trillion trillion), and are backed by some actual evidence — however weak — connecting the claim to an ingredient. From the guidelines, it does not appear to be necessary to show that the ingredient is efficacious at homeopathic dilutions however.
In terms of complaints, good luck. Health Canada’s shown no capacity to self-regulate in this area, and the Competition Bureau has expressed reticence to enforce deceptive advertising legislation against Health Canada, which is essentially providing a testimonial in the form of a registration number that certifies effectiveness. I’d say the best course of action is political — write your MP, copy the Minister of Health and the minority health critics.
Thanks for the information. I spent the better part of yesterday going copiously through some product monographs for substances that are recommended by homeopaths for substance abuse(i.e lycopodium). Most product monographs were like the one for plumbum – vague recommended use and a list of ingredients only. Initially I was curious to see if there was any product that would have subtsance abuse as a recommended use(so far nothing found), but I became more curious about the variety of igredient mixes. Specifically, why do some homeopathic preparations list that they contain the same ingredient at different dilutions (10D, 30D, 200D, 1000D of lycopodium in the same bottle)? It’s curiously bizarre.
I’m going to focus my own research on homeopathy and substance abuse. There is a very serious risk to a person who decides to use a homeopathic preparation to treat their withdrawal symptoms, depending on the drug of abuse.
Once I have a good understanding of what is occurring I will follow up with contacting my MP, etc for answers and action.
I absolutely love these posts and the discussions regarding these specific products, and look forward to them every week.
Regards,
Dianne
In future polls, could you change the font for the products in the survey? On my computer, the bold italics is difficult to read.
I voted for Phytosyn 12 on the logic that the description for Sinupas actually means something (albeit something stupid).
I think that qualifies you to review natural health products for Health Canada!
If you want to register a complaint, you can join me in contacting the Food and Drug Acts Liaison Office (FDALO). I’ve already started a complaint with them over this, though they are taking their time arranging for me to speak to someone. I am being a bit heavy-handed, and explained that I’m willing to submit an ATI request (access to information) to get all the financial information related to the review of homeopathic drugs, as I figure that if I can’t have a productive dialogue on the science and policy, I can at the least do a media piece on the costs associated with rubber-stamping the products.
They probably don’t take individual complaints too seriously, but if FDALO starts getting a lot of complaints about the same thing they’ll possibly take notice.
That’s great, I didn’t even know this office existed. Here’s the link for anyone who wants to put in a call…I certainly will.
http://www.hc-sc.gc.ca/ahc-asc/activit/fdalo-bllad/index-eng.php
Hello Epinephrine and Erik,
Thanks for this, will absolutely join you in this as well.
Epinephrine, are you trying to get information on how much Health Canada is receiving or expending for the Natural Health Products program? Have you tried looking at the Treasury Board Secretariate Estimates publications? There is a lot available online here:
http://www.tbs-sct.gc.ca/est-pre/index-eng.asp
I am more familiar with looking at the Estimates part III, which you can look at for each federal department and agency. they are published every year, and will tend to have info in particular when something is new or is an initiative of some kind. This may be key to following the money trail.
I just had a shiver remembering the many hours spent in the basement @ the library of the University of Guelph reading these things. Bring caffeine or better.
Cheers,
Dianne
Thanks Dianne, I’m familiar with the Reports on Plans and Priorities, but if I want information specific to the costs related to review of homeopathic products (for example) the easiest and most effective way is likely a request through the Access to Information and Privacy Division (http://www.hc-sc.gc.ca/ahc-asc/branch-dirgen/csb-dgsg/aipd-daiprp/index-eng.php) under the Access to Information Act.
I am glad you’ll both be writing to FDALO, and I certainly will be reading this column regularly – it’s great fun. Thanks for doing all the research and making such an entertaining read.
I wonder what silicon, chromium, vanadium, iron and carbon cure in homeopathy. There’s more of that in the 4CH than the Pb !