To read part one of this post, click here. Please take the time to do so; this post lacks critical background information that’s provided there.
The information about “Registered Holistic Allergists” (R.h.A’s) and the purported allergy treatment they offered, “BioEnergetic Intolerance Elimination” (BIE), that was presented in part one was gathered by me all within about three weeks of coming across its existence for the first time. Taking my cue from the practitioner that claimed that Health Canada had “acknowledged” BIE (strongly suggesting the regulator approved of the practice), I decided to call her bluff. The Ad Standards Council, had already informed me that the complaint was out of their jurisdiction and suggested I check with Health Canada about the status of the medical device the R.h.A’s were using. I did just that, and forwarded my concerns and everything I had found to an inspector at the Compliance and Enforcement Inspectorate Program, Medical Devices CVI Unit. I was determined to get something done. Thankfully, they were willing to listen to my concerns, even though I hadn’t been directly affected by the treatment itself.
I exchanged correspondence with a medical device compliance officer, who explained to me the limits of Health Canada’s regulatory mandate in this case. Health Canada does indeed regulate advertising claims regarding medical devices but this is limited to the manufacturer, distributor, and importer (typically, this advertising is not directed at consumers or potential patients). This means that the treatment claims being made by any “Registered Holistic Allergist” cannot be challenged by Health Canada. Not even the claims they make about the device they use, the GSR-120. Claims in advertising by practitioners are regulated by the Competition Bureau (though, to be clear, when what a practitioner does crosses over into medical practice territory, provincial regulation can also come into play). Initially, while the inspector was patiently explaining to me what she could, and could not do with regard to my complaint, I felt I had hit a dead end. It seemed much like I was being sucked into the black hole of regulation.
That feeling lasted only as long as it took for me to process the implications of what the Inspector was telling me. Health Canada couldn’t deal with the claims the practitioners were making, but they could and would investigate claims made by the manufacturer and distributor of the device. Since the BIE treatment and the GSR-120 used to administer it was under the control of the Institute of Natural Health Technologies (identified by Health Canada as the manufacturer), it put the focus squarely on them and the claims they were making about the device they gave the practitioners to use. Health Canada was now very interested in verifying that the GSR-120 was in compliance with existing legislation. Just like that, my frustration turned into cautious optimism. Instead of playing a game of whack a mole with practitioners, there was a real opportunity to get at heart of the problem.
A Critical Moment
It’s been about a year since Health Canada accepted my complaint for investigation and in that time I’ve learned that the key to getting regulators to take action is a combination of reasonableness and persistence. Being right might be sufficient, but being diligent and calm during the process is absolutely necessary. You won’t get anywhere if you insist that something be done that simply cannot. When I was told that Health Canada couldn’t address the claims of the holistic allergists I was upset, but I couldn’t let that anger and frustration cause me to miss the opportunity at hand. After all, we’re talking about practitioners that claim that they can effectively test for and treat all kinds of allergies and intolerances, even anaphylaxis, after doing nothing more than taking a six day course. I left the Inspectorate to do its job and retreated to watch and wait, contacting the Inspector periodically (this is the persistence part) to check on the status of the investigation.
The Results are In…
It was back in May and on a whim I checked up on the Institute of Natural Health Technologies and a variety of Registered Holistic Allergists. To my surprise I couldn’t find any. Instead, I found that practitioners had changed their title to “Registered BioEnergetics Practitioners” and changed their claims somewhat. I noticed similar intriguing changes on the INHT website itself. To my estimation, these changes had occurred en masse recently and so I contacted the Health Canada Inspector immediately to figure out what was going on.
The Inspector informed me that the compliance verification was still ongoing, but she was nearly ready to close the file. As a result of the investigation the Institute of Natural Health Technologies had issued a recall of the GSR-120. Specifically, the device’s claims were recalled and replaced with new ones that made the GSR-120 no longer a medical device in the eyes of Health Canada. So what is it? A consumer product now subject to the Canadian Consumer Product Safety Act.
To explain how this happened a little background on medical device regulation is helpful. All medical devices in Canada fall into one of four classes according to risk. The three higher risk categories of devices require licenses before they can be legally sold or distributed (the GSR-120 did not have a license). The lowest risk category (which includes things like thermometers) doesn’t require market authorization. However, the manufacturer, distributor or importer still must have an Establishment License. Any way you slice it, the INHT needed to be in compliance with the law in order to continue distributing the device as they were. They likely could not comply and so the INHT was forced to retract the medical claims they were making about the GSR-120. This has put them in a tight spot.
How tight? Tight enough that the INHT has taken some serious steps to maintain the market share they have on alternative allergy practitioners. Significantly they’ve made every “Registered Holistic Allergist” change the credential they use to “Registered BioEnergetics Practitioner” (R.B.I.E). (Click here for the before link and here for the after)
Every former Holistic Allergist I can find has now made this change. At least, this is true of the Holistic Allergists in Canada. There are a very small number of practitioners that are active in the U.S. that are still using the R.h.A credential. You can click here for an example of a practitioner who has not changed their website. Interestingly a naturopath that otherwise seems to offer everything under the sun has completely removed all references to BIE as a treatment he offers.
That’s just weird, isn’t it? I mean, the treatment is so advanced it can clear 80% of allergies in one session, the remainder in three more and is scientific to boot! How did the naturopath get it so wrong?
Here’s part of the company description of BIE before:
BIE is a powerful new scientific approach that uses a simple and effective method to radically eliminate all symptoms of allergy or intolerance without the use of needles or drugs.
And the same part after:
BIE is a simple new natural modality that uses a state-of-the-art instrument called the GSR-120 unit that is used to direct energy onto various acupuncture points on the body to help create a homeostatic state, therefore alleviating suffering.
With the above example it begins to become plain what the intention is here. BIE was “powerful”, now it’s “simple”. Before it was a “scientific” treatment, now it’s a “natural modality”. Once it could “radically” eliminate symptoms, now it “help[s] create” homeostasis. They’re trying to back away from any implication that BIE can directly treat and cure allergies and using fancy pants language to do it. It’s very much like a game of linguistic twister.
Even the practitioners are getting into the game. One of the first practitioners I sparred with has recently written an article titled “Could You Have Allergies and Not Even Know It?”
Being a Registered Holistic Nutritionist in Vancouver, I often have clients come to see me with very specific health concerns…allergies not being one of them. Regardless of the symptoms my clients may be presenting, I always encourage them to consider exploring the possibility of an allergy or sensitivity.
As a Bioenergetics Practitioner, I do not diagnose, treat or cure allergies. What I am most focused on is what particular stressor may be contributing to my client’s current imbalances. This could mean an allergy, or sensitivity, or intolerance, or whatever other label you would like to give it. The label should not be the main concern. The fact remains that the body is experiencing symptoms resulting from an underlying imbalance due to the inability to process specific stressors.
With that in mind, I believe that nearly all symptoms people experience could be related to a sensitivity or allergy. So to answer the title question, Yes, you absolutely can have allergies and be completely unaware that this is what is causing your discomfort.
Whether your imbalance is caused from an allergy, intolerance or sensitivity, the underlying mechanism which is triggering the response is constant. We rely on our body’s ability to identify, interpret and react to the energetic signatures that all stressors emit. If this ability becomes compromised or skewed, then we may experience adverse reactions, such as allergies.
Allow me to put the lie to some of the above. Before he was a “BioEnergetics Practitioner”, he was a “Registered Holistic Allergist” and he did, without question, have clients see him about allergies. He also, without question, continues to see clients about allergies. This is an attempt to convince us otherwise by redefining allergies as the symptom of the real underlying problem and putting as much space between that and what he really wants us to think he treats – which is easy to do, when the thing you say is being treated is completely made up.
So has anything other than the marketing really changed? Not according to this practitioner:
Terminology for what we do has changed has you will see from other pages on this web site. Please take note that currently RHA’s are called Registered Bioenergetics Practitioners (R.BIE). The method is the same. The training is the same. The results are the same. The high tech GSR 120 device used in the modality has been updated and some terminologies have been changed.
The nonsense is the same, that’s for sure.
There’s evidence that the INHT themselves may have some concerns about what can be found on the web about BIE. Much of the previous marketing material, though still available on the web, like the video and an entire page of testimonials, cannot now be easily found by clicking through the site. The most telling change, I think, is the fact that practitioner contact information now doesn’t include web addresses when once it did. Again, why wouldn’t you make it as easy as possible for people to avail themselves of your amazing treatment?
Practitioners claim that the credential change was initiated by Health Canada, but this could not be true. Health Canada does not regulate the practice of medicine; this is a provincial responsibility. Yet, it’s almost certain that this retreat from the previous allergy claims and marketing tactics was taken after the INHT felt the heat of regulatory scrutiny. They’ve now realized that people will pay attention and some, maybe even a short woman of no consequence in Southwestern Ontario, might not choose to let it go.
Outrageously, some practitioners have even tried to turn the regulatory action taken by Health Canada into a mark of approval. For example, this is the way one practitioner website appeared on September 7, 2012.
I had seen this exact language on several practitioner sites back in May and alerted Health Canada to the shenanigans. Over the course of the summer this too started to disappear from websites. This practitioner apparently didn’t get the memo, but it only took a quick email to the inspector to solve that problem.
This is currently the state of affairs, and it’s clear that none of these practitioners are going away, nor are they really going to change what they’re doing. So my work isn’t done. There are a few loose ends to tie up and a few more regulatory avenues to wander down (as I’m sure you can understand I need to keep these under my hat for now). It’s frustrating to watch these folks kick around medical terms like “homeostasis” like a beach ball, contort themselves as they make new claims, and generally continue to do the same thing. However, it’s damned satisfying watching them sweat a little and squirm under the pressure. My hope is that fewer people get taken in, and more practitioners find it at least somewhat difficult to maintain the practice. On the other hand, I know that people will always be vulnerable. There will always be another bit of nonsense to take its place if it disappears, or other opportunities these ideas can take advantage of if they appropriately adapt.
So why did I fight this? Because nonsense, unchallenged, will persist. The good news is that we can persist in challenging nonsense. Sometimes we even win.