Some time ago, our resident pharmacist asked the question “Is there anything the Natural Health Products Directorate won’t approve?” In that post there was a short list of some of the products Health Canada has allowed on the market, including homeopathic insulin and chloroform. Unfortunately, these products are not peculiarities. I’ve made it a habit to regularly browse the Natural Health Products Database and over the past few months I’ve gathered quite a long list of the more absurd homeopathic products that have been allowed onto the market. I’m alarmed and angered by what I’ve found.
Briefly, to be legally sold in Canada, a natural health product must have a NPN (Natural Product Number), DIN-HM (Drug Identification Number – Homeopathic Medicine), or an exemption number (EN). Exemptions are temporary and are given to products that have passed an initial review (based on safety), but have not been given final market authorization. A product for sale with an NPN or a DIN-HM can be assumed to have complied with the licensure process. It follows that if the Natural Health Products Directorate (NHPD) issues a licence, they’ve judged the evidence submitted sufficient to warrant describing the product as “effective”.
There is an important exception to this. A product that does not have a DIN-HM, NPN or EN can be sold if it is compounded by a health care provider and is specifically requested by a patient in the context of a patient-practitioner relationship. This means that a homeopath can sell a remedy they prepared from starting material of any kind, to a person under their care. There appears to be no regulatory oversight of the claims made about these remedies.
Here is my long list of absurd homeopathic remedies Health Canada has licensed as “effective”. To look up the following product monographs on Health Canada’s Natural Health Products Database, click here and search each individual DIN-HM/NPN number using the simple search tool. I’m sorry that I have to make you do all the work, but direct links time out.
The Current Long List
- Dtp Toxinum – Homeopathic diphtheria, tetanus and pertussis in a combination remedy, strongly suggesting that it’s meant to be used as a vaccine. NPN 80032577.
- Luesinum (Syphilinum) – Homeopathic syphilis. NPN 80007664.
- Tuberculinum Bovinum – Homeopathic tuberculosis sourced from cows. NPN 80018011. Enjoy this thread where a parent asks for a second opinion on the appropriateness of this remedy for a child. A homeopath suggests that the remedy would be appropriate if the child has a line of hair along the spine, has temper tantrums and is artistic.
- Carcinosinum – Homeopathic cancer. No particular type specified. NPN 80022612.
- Penicillinum – Homeopathic penicillin. NPN 80009432.
- Nicotinum – Homeopathic nicotine. NPN 80018789.
- DNA – Homeopathic DNA from an unknown source. I’m assuming it’s human. NPN 80016274.
- Cholesterinum – Homeopathic cholesterol. NPN 80010019.
- Orchitinum – Homeopathic wild boar testicles. NPN 80013901.
- Muqueuse Anale – Homeopathic rabbit anus. NPN 80012721.
- Formica Rufa – Homeopathic whole wood ant. NPN 80008075.
- Lac Caninum – Homeopathic dog’s milk. NPN 80010074.
- Lac Defloratum – Homeopathic skim milk. NPN 80008156.
- Ova Tosta – Roasted egg shells. My guess is that these are chicken eggs. NPN 80019832.
- Rock Water – Homeopathic mineral water. DIN-HM 80005224.
- X-Ray – Sugar pills exposed to x-rays, then serially diluted. DIN-HM 80029649.
- Hekla Lava – Homeopathic lava from an Icelandic volcano. Because Iceland is magic. NPN 80008228.
- Viburcol N – Health Canada approved the following indication: “Homeopathic preparation for the relief of restlessness, teething or colic, with or without fever and pain.” They’re homeopathic rectal suppositories for infants. DIN-HM 80022258.
- Petroleum 5ch – Homeopathic crude oil. NPN 00858900.
- Olibanum – Homeopathic incense, possibly frankincense. What would Jesus re-gift? NPN 80018836.
- Gunpowder Pellets – Homeopathic gunpowder. Not for use in guns. NPN 80017147.
- Oxygenium – Homeopathic oxygen. So many questions. Don’t blank sugar pills already have this included? How do you keep the original oxygen from being inhaled or floating away? NPN 80009300.
- Zea Mais – Homeopathic corn. I don’t quite know why this amuses me, but it does so it made the list. Make of that what you will. NPN 80016526.
- Silica marina – Homeopathic sand from a salt water beach. NPN 80018955.
- Mygale – Homeopathic black cuban spider. Here’s an explanation of what it’s used for. NPN 80019868.
- Homarus – Homeopathic digestive fluid of live lobster. NPN 80019872.
Did you notice that of the 26 products in that list, 3 have DIN-HM numbers while the rest have NPN’s? It turns out that under certain circumstances homeopathic products cannot receive a DIN-HM and so are permitted to apply for a NPN instead. It’s unclear what evidence standard is applied to homeopathic products in this circumstance. While products applying for a NPN with a traditional use claim need only supply evidence of use for at least 50 years, those making non-traditional use claims are required to provide scientific evidence of some kind. All the homeopathic remedies listed above have their indicated use listed as a variation of ‘homeopathic remedy’, just like those with DIN-HM’s. Though a careful reading would seem to indicate that these products are subject to the stricter standard, one wonders what scientific evidence was accepted as sufficient to support the efficacy of homeopathic oxygen and beach sand.
DIN-HM or NPN, it makes no difference. Every one of the products in that list is completely useless. What kind of responsibility does Health Canada bear for the role they’ve played in legitimizing rank quackery? Apparently, they don’t recognize that this is what they’re doing:
“We’re not in a position to debate this,” said Stéphane Shank, senior media relations adviser at Health Canada, referring to the issue of efficacy. “Health Canada approves the homeopathic products, but not the practice.”
Excuse me, but without the products there is no practice.
Nevertheless, they contend that they only regulate the products, not the practitioners, nor what they may say to their patients about the products they recommend. However, the practitioners are practically restricted by the regulations because they can only sell approved products, and then only according to their approved indications, all of which have been carefully reviewed by Health Canada, right?
Wrong. Remember that homeopathic remedies can be individually compounded. Also, consider the fact that single ingredient homeopathic remedies cannot make specific claims (combination remedies can, however). With the exception of DTP Toxinum and Viburcol N, all of the products above (supposedly) contain only one ingredient and can only claim that they are a homeopathic medicine, drug, remedy or preparation. In other words, they can’t claim they are indicated for anything, either explicitly or implicitly. Even the name of the product must not imply a claim, use, or purpose. These products are just sort of – there.
I argue that this restriction on claims provides no real protection at all. A practitioner can pretty much tell a patient whatever they want when they prescribe a single ingredient homeopathic remedy because the practice of homeopathy is out of Health Canada’s jurisdiction. As far as the NHPD and Health Canada are concerned, how these single ingredient remedies are used is someone else’s problem.
There is also the issue of Health Canada’s approval of certain homeopathic nosodes, which are used as vaccine substitutes. Bad Science Watch has recently launched a campaign to put pressure on Health Canada to de-register these products (I suggest taking the time to visit the campaign page as there is a list of approved homeopathic nosodes that I compiled). Health Canada responded to media enquiries:
“While some Canadians may choose the use of nosodes to maintain and improve their health, immunization is more effective in preventing vaccine preventable diseases,” Health Canada wrote in an email to the Star.
Health Canada added that it “has not licensed any pertussinum products with a specific claim for pertussis, nor any homeopathic medicines as ‘homeopathic vaccines.’”
Health Canada is simply trying to distance themselves from a problem they’ve created.
It’s worth noting that I could have just as easily written this post using a list of ridiculous traditional Chinese, ayurvedic, or other herbal products. There is no shortage. In fact, as of March 1, 2012 there have been 34,043 product licenses issued by the NHPD. It’s anybody’s guess what percentage of these have been approved on the basis of questionable evidence.
Hundreds of natural health products are reviewed and approved every month by the NHPD at Health Canada. At Skeptic North, we have been consistently critical of this process. We’ll continue, so long as Health Canada insists on legitimizing quackery instead of guarding us from it. Ironically, instead of being protected from ineffective or potentially unsafe natural health products, we’ve been absolutely bombarded with them.