Tag: Canada

The Failure of Self-Regulation of the Chiropractic Profession is an Urgent Public Health Crisis

May 17, 2019

Below is a letter I recently sent to Ontario’s Minister of Health and Long-Term Care, Christine Elliott. The letter was written following a number of very disappointing decisions I received from the College of Chiropractors (CCO) of Ontario concerning a number of complaints I have submitted over the past couple of years (details to follow soon). 

The CCO has made it clear that they are either unable or unwilling to hold chiropractors to a reasonable ethical or scientific standard for the protection of the public. I have submit complaints detailing how Ontario chiropractors have used deceptive advertising, how they have disseminated provably false claims, how they have misled the public on scientific and medical issues, how they have cautioned that vaccinations are “toxins”, how they have lectured that medical doctors “kill” their patients, how they have endangered lives by claiming such nonsense as one cannot overdose on vitamin D, how they have made false claims supporting invalid tools and techniques, how they have exposed patients to x-rays unnecessarily, how they have targeted patients with predatory sales tactics, and how they have shown a blatant disregard to their responsibilities as regulated health professionals. No single chiropractor has been disciplined for any of the above issues.

I am at wit’s end. The regulatory college is not effective and not appropriately acting on its mandate to protect the public. I have been reasonable and gone through the proper channels by submitting complaints, but now I realize that chiropractors are not capable of self-regulation. There are many great chiropractors who initially gave me hope that the profession could reform itself, but I no longer see this as a realistic possibility. The profession must either be dismantled or there must be intervention by independent authorities.

We are increasingly aware of the danger that health and science misinformation both pose to public health, democratic decision making, and the public’s understanding of science. The chiropractic profession was given a chance to regulate themselves and improve. They have collectively failed. 

The Letter

Dear Minister Elliott,

Several years ago, while completing my PhD, a colleague of mine handed me a pamphlet advertising an event put on by a local chiropractor. Curiously, the topic of the seminar was cancer, but chiropractors are not medical doctors and certainly not specialists in oncology.

As I learned more about this practice, I found that the chiropractic profession harbored strange beliefs surrounding medicine generally. While some practice akin to physical therapists, there exists a large subset of practitioners who believe that spinal “adjustments” are the core requirement to maintain good health and prevent disease – a provably absurd notion. The philosophy behind this belief is even
more absurd, but I will spare you the details.

At the time, I was most passionate about science education, but I felt that my efforts were undone by regulated practitioners who disseminated misinformation to large audiences, utilizing their authority as health professionals to deceive the public for financial gain. This was the beginning of my adventure in science advocacy in activism.

Learning of the existing regulatory mechanisms in place that are intended to protect the public, I began systematically submitting complaints against practitioners to The College of Chiropractors of Ontario. Most recently (today), I submitted a complaint concerning two chiropractors who claim that vaccinations are the “absolute number 1 chemical stressor” requiring chiropractic treatment. This is merely a sampling of the many absurd and dangerous claims I encounter daily.

Unfortunately, the regulatory college has failed to appropriately act on complaints. Recent stories in various national outlets (some of which have featured my activism) highlight the extent of the issue and shed light on a greater regulatory failure: The College of Chiropractors of Ontario itself is comprised of council members who harbor pseudoscientific beliefs, including a strong opposition to immunization. In the midst of low vaccination rates and increasing outbreaks, this is completely unacceptable.

I have – thus far – played by the regulatory rules and mechanisms available, but they are simply inadequate. For the safety and general good of the public, I ask that you intervene with the College, review complaints, and enact stronger regulation. As with other health professionals, chiropractors
operate within a privileged marketplace. It is time that the profession took on the responsibility that comes with that privilege.

Sincerely,

Ryan Armstrong

The Science Aesthetic

February 19, 2019

Appearances matter. I do not expect anyone to object to that conclusion in reference to art or in the day-to-day appreciation of beauty in its various forms. But aesthetics in science? Is science not the one domain where we can isolate and mitigate the forces that colour our perception? Can we not harness the powers of logic and rationality to steer us towards conclusions that are true rather than conclusions that please us?

Simply exploring the role of the aesthetic in science can be troubling; it reveals a bias of human cognition where all the pretty hypotheses are developed into full-fledged theories while the less desirable wait at home, hoping a dreamy scientist will one day reach outside the institutional norms and bring them to the prom of ideas. One must look no further than the search for a single theory of everything as a scientific pursuit predicated on the beauty of simplicity and totality.

While the exploration of aesthetic influence within science is certainly fascinating, there exists also an aesthetic of science and the institutions that support and surround it. These are the cues – interpreted both consciously and subconsciously – that confer scientific authority to ideas without granting them any particular merit with regard to their descriptive power of reality.

One needs not look far for popular imagery and stereotypes in science. If you Google “scientist“, the search yields a large number of photos (including many stock photos) depicting lab coated chemists hard at work with their various laboratory apparati, yet most scientists are not chemists and lab coats are not particularly pervasive across other specialties. For better or worse, these aesthetic stereotypes invade the public consciousness, impacting not only how professionals in science and medicine are portrayed, but becoming symbolic of the authority and legitimacy of those professionals. As a result, the aesthetic itself has become a tool for exploiting public trust.

Whether purposefully manipulative or entirely subconscious, various movements have adopted aspects of the established aesthetic within the scientific and mainstream medical domain. Take – for example – a Google search for “naturopathic doctor“. What do you see? White coats, stethoscopes, lab spaces, and – notably absent from our search for scientists – an obvious appeal to the natural aesthetic that has so infected our consumer culture. One could very well argue that the naturopathic profession was built largely to appeal to our aesthetic values. Indeed, many have argued that the profession merely takes advantage of such deficiencies in the medical system. This is perhaps most evident in the narrow conditions most commonly treated and utilized as naturopathic “success stories”; such lists often contain self-limiting conditions which tend to resolve without any intervention at all. Patients do not need treatment, but do they need the comfort of being heard and cared for?

Of course, any profession that is built on such thin facades as borrowed apparel is doomed to fail. I can dress a monkey up as a physician, but at some point you’re going to question if eating the lice he grooms out of your daughter’s hair is really proper clinical etiquette. But what if he didn’t eat the lice? What if he could write and speak? What if that monkey didn’t look like a monkey? Evidently, the aesthetic of scientific legitimacy is not a simple binary, but a continuum of qualities that are context and observer dependent.

For some people, a clean office, lab coat, and stethoscope may be sufficient for putting their faith into a practitioner. For others, they may be sufficiently persuaded by formal credentials. Of course, persuasion of patients alone is not sufficient to create a professional health paradigm; in Canada, provincial jurisdictions have the final say over what types of practices are permitted and whether they receive public funding. This is, after all, why we have elected representatives and regulators. In theory, their job is to evaluate objective criteria against our shared values to create a system that best balances access to healthcare, patient safety, consumer choice, value, and more. Luckily, it seems to take more than a white coat to fool these folks. Unfortunately, this means that deception just gets that much more complicated.

The naturopathic establishment knows it cannot exist without some level of scientific validation, or – at very least – the appearance of scientific validation. This notion launched a movement that is perhaps best typified by the US-based National Center for Complementary and Integrative Health (NCCIH), which despite billions of dollars of funding has not produced particularly impactful research and has failed to report clinical trials. What do they have? An aesthetic that relies on buzzwords to convey a unique patient-centered value and studies that are scientific only in appearance.

A shocking proportion of the scientific literature consists of works that do not simply fail to expand upon human knowledge, but impede such developments by promoting false notions, often the result of vested interests. While these studies typically rely on methodology of such poor rigor that they fail to impact the broad scientific consensus, they can be wielded as devastating weapons against the public consciousness for political and social gains. Indeed, they generally possess all of the aesthetic markers that the lay public rely on to distinguish scientific work from news, opinion, commentary, etc. And when the peer-review process fails, such works can even make their way into prestigious journals that confer an additional veneer of legitimacy.

One need not look beyond the border to find such egregious abuses of science. Recently, I’ve become familiar with a naturopath-driven cancer institute close to home: the Ottawa Integrative Cancer Centre. The clinic claims to provide treatments for “any stage of cancer” as well as “prevention of cancer”. Throughout the website, there are many claims that the clinical practices employed are “evidence-informed” or “evidence-based“, but are they really?

Let’s explore the “Evidence-Based Monographs” page. The page includes various monographs targeting both patients and health professions with rousing titles such as “Flax for Breast Cancer“. Virtually all of the documents make extraordinarily strong suggestions of benefits for compounds that simply are not supported by quality research. Take for example Mistletoe. The author(s?) rely on carefully suggestive language; instead of claiming that mistletoe has definitive benefits, they say that it “is most commonly used in cancer care” for a number of purposes, which include reducing tumour size and slowing disease progression. Elsewhere on the site, you can find claims that “Mistletoe Improves Overall Survival” referencing a single dated study. More recently, the preponderance of evidence indicates that “the literature does not provide any indication to prescribe mistletoe to patients with cancer” yet this review is nowhere to be found on the website of a clinic that just happens to offer intravenous mistletoe therapy for cancer patients.

At what point does this become the abuse of science for its aesthetic? At what point does this become a serious ethical breach of informed consent? Obviously, I don’t have a window into day-to-day clinical practices, but the website really does not instill any confidence that vulnerable cancer patients are receiving accurate information. Is this really the type of clinic we are comfortable permitting patients to be lured into spending their money and last hours in?

This is all – quite frankly – infuriating, but we have barely scratched the surface here. My first run-in with the OICC was through a Twitter exchange with Jean Seely, who just happens to be the sister of the clinic’s Executive Director: Dugald Seely. Jean pointed out that patients were provided “helpful support” without “false expectations.” Well, if the website reflects what goes on in the clinic, I am highly skeptical of both claims. She went on to cite a “good” study performed by her brother, which didn’t touch on cancer at all, but on “Naturopathic medicine for the prevention of cardiovascular disease“. The study is a perfect example of science in appearance only; while the authors conclude that the findings “support the hypothesis that the addition of naturopathic care to enhanced usual care may reduce the risk of cardiovascular disease among those at high risk” the study entirely fails to adequately test that hypothesis. Let’s dig in.

The study was designed as a trial to compare enhanced usual care to enhanced usual care with the addition of naturopathic care among middle aged postal workers with an increased risk of cardiovascular disease in a number of major Canadian cities (classic A vs. A+B). Billed as a “pragmatic” approach, the study – if properly designed – should give insight into the practical benefits that naturopaths can offer patients via regular visits. Unfortunately, the study was only pragmatic in the sense that its design effectively guaranteed positive results, but not through the magic of naturopathy.

Let’s take a step back. What do we know about the clinical practice of naturopaths? We know that most of what Canadian naturopaths advertise is an assortment of completely bogus therapies, including homeopathy, chelation, colon cleanses, and various forms of IV therapy. We know that a large proportion of Canadian naturopaths advertise phony treatments and diagnostic techniques related to allergies and asthma. We know that a vast number of naturopathic websites (and presumably practitioners) promote vaccination misinformation, which is undoubtedly related to the high prevalence of vaccination hesitancy among patients who see naturopaths (indeed, I have personally submitted complaints on this issue to various regulatory bodies that have yet to take any action). We know that a large number of naturopaths offer completely pseudoscientific “stem cell” therapies. We also know that patients who receive “complementary medicine” for their cancer are more likely to refuse medical care, and ultimately, are at a greater risk of death.

By these measures, the naturopathic profession in Canada is largely anti-science and a measurable threat to public health. So how did Seely et al. work this reality into their pragmatic study design? Well instead of opening the floodgates to the multitude of dangerous and pseudoscientific practices popular among Canadian naturopaths, the authors cherry-picked the acceptable interventions that could be utilized by the participating naturopaths:

  • Dietary interventions (tailored diet, caloric restriction, etc.)
  • Supplement-based interventions (fish oil, fibre, lutein, etc.)
  • Lifestyle interventions (exercise)

And how did they track what interventions were chosen? They didn’t:

“Because a range of interventions were recommended to participants in the naturopathic group, the frequency and composition of each recommendation as well as participant adherence are not reported. We did not have direct control over the care given to the control group; thus, we did not track or report recommendations made by the participants’ family physicians. “

So what were the results of added diet and lifestyle counselling? The group receiving “naturopathic” counselling improved marginally over the control group on the primary endpoints relating to cardiovascular risk (there are some statistical issues, but those are really trivial compared to the fundamental conceptual flaws of the paper). What is worth noting, is that the “naturopathic group reported significantly more weekly minutes of moderate exercise.”

So… wait a minute. The study took a group of naturopaths, restricted them to traditional interventions to promote physical activity and dietary lifestyle changes for cardiovascular risk factor reduction, including exercise, which is known to reduce CVD risk, and – as a result – the naturopathic group exercised more, reducing their risk, and they have the audacity to attribute these benefits to the magic of “naturopathic medicine“? If I was a betting man, I would bet that a Richard Simmons VHS would outperform these amateurs.

So what did the study really tell us? Well, ignoring the other major methodological deficiencies, the most generous interpretation tells us that naturopaths could have a positive effect when they act as glorified diet and fitness motivators, but could this not be accomplished more efficiently with a science-based specialty that practices exclusively in this domain? Did the authors forget about the following more science-based practitioners who can give advice in this domain:

  • Physicians
  • Occupational therapists
  • Physical therapists
  • Dietitians
  • Personal trainers
  • Nurses
  • Nurse practitioners
  • Chiropractors (vitalists excluded, sorry)
  • Kinesiologists
  • Karen from Farm Boy

Or did they simply ignore them in the quest to legitimize their field with the scientific aesthetic? Because once you peel back the assumptions and the misleading language, that’s all this study is: an aesthetic of science.

Studies like these are among the many ways that alternative practitioners misuse the aesthetic legitimacy of existing establishments to bolster their own professional identity. I continue to be shocked that journals do not require authors to report conflicts of interest when their work is primarily intended to promote their own profession rather than to ask legitimate scientific questions relating to novel medical interventions. The evidence shows that these types of practitioners will use any means available to elevate their reputation, from producing and relying on bad science, to claiming that 3 years of arbitrary undergraduate schooling constitutes “university-level pre-medical training.”

Worse still, the Canadian associations that represent naturopaths are nothing short of ignorant and dangerous. The Ontario Association of Naturopathic Doctors – for example – has promoted turmeric as a cancer treatment, homeopathic alternatives to vaccines, and high dose IV vitamin C therapy as a possible cancer cure. In this context, the monkey in the white coat doesn’t look so bad…

David Gorski, in his article looking at funding for dubious research performed out of the OICC, said it best: “In the end, naturopaths like Dugald Seely are cosplaying real doctors and clinical trials are their props.” Whether conscious of not, these practitioners co-opt the scientific aesthetic for personal and professional promotion without adopting firm scientific principles. Look for substance here, and you will be shocked at what you find.

How To: Complaints Against Canadian Health Professionals

September 4, 2018

Unlike other articles on my blog, this is a living document and will be updated as needed to be relevant and accessible. The intent is to provide a comprehensive and accurate guide to pursuing regulatory action against unethical health practitioners. This is not legal advice. This article is constructed from my own research and experience and – while every attempt has been made to ensure accuracy – errors may be present. Please contact me for any corrections. Comments are permitted, but – unlike my other posts – I will not permit trolling or unsubstantiated criticism. Last updated September 15, 2018.

A Brief Introduction to Health Profession Regulation in Canada

Canadian health professionals operate in a privileged marketplace; under various regulatory laws and frameworks, they are granted the ability to offer and advertise services within a prescribed scope of practice. This prevents anyone without the appropriate training or education from offering services as a medical doctor, dentist, nurse, massage therapist, and more. It is a reasonable expectation – for example – that a surgeon has actually attended medical school and has been trained in surgery.

These privileges come with a set of responsibilities that members of health professions must adhere to. The responsibilities are set out by provincial legislation and refined by regulatory authorities that draft and enforce standards of practice using the legal framework as a scaffold to build additional ethical and professional obligations. This includes addressing aspects such as informed patient consent, advertising, medical record keeping, dispensing of drugs, and more. Naturally, the extent and focus of standards vary from profession to profession.

The colleges that maintain these standards are not government agencies. Rather, Canadian provinces have granted the various health professions the right to regulate themselves. There are a number of advantages to this regulatory structure. First, it unburdens the government from the job. Second, it gives the job to those who possess the precise domain knowledge required to ensure that professionals are practicing in a way that is in the best interest of the public. After all, how is a bureaucrat to know what constitutes valid and invalid medical practices? This is the expertise of physicians, not government officials. That’s part of the reasoning, anyway.

While the intent of the self-regulating colleges is to facilitate professional regulation in the interest of the public, this regulatory structure presents a number of challenges. First, professionals who contravene their obligations are not judged by an independent group of arbitrators, but by their own peers. While legislation has attempted to mitigate this concern by permitting the requirement for members of the public to hold positions within regulatory authorities, this certainly does not eliminate the risk of bias.

An additional challenge is posed when it comes to scientific issues. While professionals may possess extensive domain knowledge relevant to their specialization, what happens when this knowledge is antithetical to the scientific and medical literature at large? For example, consider Ontario’s College of Homeopaths. The practice of homeopathy is not only scientifically implausible but remains entirely unsubstantiated by clinical trials. How then, can the College appropriately regulate complaints concerning misleading advertising and ineffective treatments? To address these issues appropriately, the college would have to admit that the entire profession is not distinguishable from health fraud. Of course, the obvious solution is to dissolve the profession via provincial legislature, but the solution is not as clear cut when it comes to professions that offer both legitimate and borderline fraudulent practices.

A further limitation of the regulatory system concerns the balance between proactive and reactive efforts to regulate the industry. The colleges employ a number of proactive measures towards protecting the public; members of the profession must be appropriately educated, registered, and cleared from basic criminal record checks. In many cases, they must submit to ongoing evaluations and engage in continuing education. Unfortunately, for many professions, there is little direct oversight of professional practices once the barriers to entry are overcome. A specific consequence of this includes the spread of misinformation and promotion of phony procedures by fringe practitioners and professions, ultimately endangering the health of Canadians.

This is where you come in.

Though you may not have realized it, public participation is a crucial component of our regulatory system. Whether you have stumbled upon unethical practices through marketing material or have been personally wronged by a health professional, you have the power to initiate a cascade of regulatory events that could help to protect the public at large. Unfortunately, this is no easy task. How is a layperson to know what is a valid and invalid practice? How is a patient to know when they have been a victim of malpractice? Further, how does one make the case to the regulatory authority and go head-to-head against a practitioner and their legal team?

The best approach is undoubtedly to seek legal counsel. If you can afford it, this is the route for you. Unfortunately, legal advice and representation is prohibitively expensive for many of us. If this your limitation, you’re in the right place. While I cannot provide legal or medical advice, the intent of this post is to empower you – the patient, the consumer, the public – to best access and navigate the regulatory mechanisms available to you. This guide covers accessing professional standards, drafting and submitting complaints, performing investigative work and documentation, and proceeding through the complaint process. In addition, if you want to chat or need direct assistance, you can always contact me.

Terminology

The terminology used in the complaints process is not extensive, but worth including for clarity. Ontario-centric terminology is used for simplicity and due to my own familiarity.

College – A self-regulating, provincial regulatory authority for a given health profession.

Complainant – The member of the public or patient who is submitting a complaint to a regulatory college.

HPARB (Ontario) – Health Professions Appeal and Review Board. This is an independent tribunal that addresses appeals from complaints to the colleges. Other provinces have similar appeal boards.

ICRC (Ontario) – Inquiries, Complaints, and Reports Committee. This is the college-designated committee mandated to investigate complaints submitted to the college and determine their merit. Other provinces have similar committees.

Member – A health practitioner who is registered with a college.

SoP – Standards of Practice. These standards are drafted by a self-regulating health college based on provincial legislation.

Assessing Professional Standards

If you are unclear on what constitutes appropriate practices, you should begin with the SoP of the health professional’s college. All colleges are required to maintain and make available their SoP. A web search of the following form will likely bring you to the right page: <province> college of <profession> standards of practice.

As an example, take a look at the College of Massage Therapists of Ontario’s SoP. Here, they reference the legislation that governs the profession and make available the standards that members (massage therapists, in this case) must adhere to. If you cannot find a standard concerning your particular issue, you may need to consult the legislative framework, which could include profession-specific legislation, or province-wide legislation such as the RHPA in Ontario. Of course, you can always contact the college itself, though I have found some to be less than helpful.

Regardless of a profession’s standards, it is worth noting that there are many issues that are universally enforced. For example, if you are assaulted in any way, this is a serious offence and you should immediately contact the police. Non-criminal issues are less clear-cut, but there are still many prohibited practices that apply to all professions, such as false or misleading advertising.

Additionally, informed consent is universal and patients cannot be deceived in their care. This presents an issue when confronting pseudoscience; is it deceptive when practitioners seem to believe that their pseudoscientific practices are appropriate and present these beliefs as “information“? Ignorance is not an appropriate defense, but situations like these present additional challenges in establishing a practitioner’s duty to facilitate informed consent.

Other issues vary significantly from profession to profession and may require a nuanced examination of the SoPs. Conflicts of interest arise in many forms and what constitutes a conflict of interest in one profession may be acceptable in another. A common issue you may come across is direct sale of products or pharmaceuticals to patients.

The Complaint Process

Provincial legislation ensures that the complaint process is relatively consistent across health professions. The details presented in this section are largely sourced from Ontario’s Registered Health Practitioners Act, but other provinces follow similar complaint processes. Often, legislation and the colleges will stipulate time constraints both for the conclusion of complaints as well as numerous milestones along the way (such as how long a member is granted to submit a response to a complaint). Specific times are excluded here as they vary between jurisdiction.

The process is as follows:

  1. A complainant submits a complaint to the college.
  2. The college sends a letter to the complainant acknowledging receipt of the complaint.
  3. The college will summarize the complaint and send a letter to the complainant requesting a confirmation of the accuracy and an authorization to forward the complaint to the member (practitioner) in question.
  4. The college will forward their letter detailing the complaint to the member.
  5. The member has a limited timeline to submit a response to the complaint. The member can respond personally or utilize legal services to respond on their behalf.
  6. Some colleges will forward the details of the member’s response to the complainant.
  7. The complainant may now comment on the response from the member to their complaint. Typically, a comment is not required for the complaint to proceed, but this provides an opportunity for the complainant to address the member’s defensive arguments and provide additional evidence if necessary.
  8. If an additional comment is submitted, the college acknowledges receipt and forwards details to the member. The member now has an opportunity to respond to additional details provided in the comment.
  9. If the member responds to the comment, the college will forward the details to the complainant. Unless additional information is required from the complainant, the complaint will proceed at this point.
  10. The complaint is now in the hands of the ICRC (terminology applies in Ontario) who will designate a panel to perform an investigation and determine the merit of the complaint. There are a number of actions that the ICRC may take, which range from dropping the complaint to referring the complaint to a disciplinary panel. You will be notified of the result. The panel will consist of professional members as well as members of the public depending on the province (example).
  11. Following the conclusion of the complaint process, the results may be appealed by either the complainant or the member. The appeals process involves a submission to a health professions appeal board (HPARB in Ontario).

At any point during the complaint process, the complainant can request that a complaint be withdrawn. However, if the complaint has reached the investigatory stage, the investigation will often proceed.

For an alternative resource on this process, check out the guide published by the College of Physicians and Surgeons of British Columbia for filing complaints; while many aspects are college- and province-specific, they provide a detailed overview of this process in a user-friendly format.

Drafting a Complaint

Before you begin drafting your complaint, you should familiarize yourself with the specifics of the college you are submitting to. Some colleges require a specific format/template that they provide (example), while some will accept a complaint in any form. If any form is accepted, you may want to follow the formatting of a business letter for your complaint.

Different colleges permit complaint submission through different channels. While most colleges now permit submission by email, there may be some that require you to print your complaint and mail it or fax it. My preferred approach is to submit a PDF via email. I keep a complaint template that includes an image of my signature so there is no need to print, sign, and scan every complaint that I submit (many colleges request signed documents). If you have supporting media/files to submit, I have found that some colleges allow submission by file transfer platforms such as WeTransfer. When submitting electronically, ensure that you adhere to a consistent and logical file naming convention for your sake and theirs.

Like many others before you, you may feel that the complaint process and regulatory system is working against you. In order to improve the odds of regulatory action, you will need to submit a comprehensive and credible complaint. This will include submission of all relevant information as well as a compelling argument for your case. Unfortunately, unless you seek legal counsel, no one will do this for you. Even if the member you are submitting a complaint against is clearly engaged in unethical practices, good arguments can be made for bad practices, so you will want to put your best effort forward. Especially when it comes to issues of science and evidence, do not consider any claims or information to be self-evident. Indeed, I have submitted complaints against practitioners who deny the germ theory of disease.

Your first step is information gathering. At very least, you need to identify the practitioner you are submitting a complaint against and their practice. If the complaint concerns you personally, you will want to submit all relevant details. You may have to divulge personal information and authorize the college to collect this information if it is pertinent to the complaint. Generally, the college will not release your personal contact information to the member.

If the complaint concerns advertising/marketing material, you will want to submit information regarding the origin (where/when/how it was obtained) of the material as well as a replica of the material itself (such as a scan of a pamphlet). If the material is online, I recommend the following procedure:

  1. Record the URL from your browser’s Address Bar. Include this in the complaint.
  2. Obtain a replica of the material. You can either take a screenshot, print to PDF, or use a browser-based plugin such as FireShot. I often include screenshots of pertinent materials within my written complaint or submit files as supporting documents.
  3. In the event that the validity of the material is disputed, you will want a reliable record that the practitioner has actually published the offending material. For this, I recommend saving the page to an Internet Archive. This will preserve the content as it is and time stamp it as well. This tool has been used in legal proceedings. Mileage may vary when attempting to archive social media pages such as Facebook.
  4. Ideally, submit both the date the resource was retrieved (by you) as well as when it was published (if available).

If your aim is to perform a comprehensive investigation of a practitioner, you may want to make use of tools beyond simply browsing a practitioner’s website and social media. As the Toronto Star revealed in early 2018, such in-depth investigations can reveal troubling information about practitioners that colleges may or may not be aware of. This is particularly prevalent when practitioners have moved between regulatory jurisdictions. Unfortunately, this is not a guide on how to perform such investigations. I may address this in the future, but you can always contact me for assistance.

If you have concerns regarding a specific profession and their policies, processes, standards, and bylaws, you can always try reaching out to the college itself for assistance or information. Some colleges are more transparent and helpful than others. An interesting example that deserves recognition is the College of Veterinarians of Ontario, who run a podcast addressing important issues primarily for members, but of interest to the public as well.

The Response to Your Complaint

You will most likely receive a response to your complaint from the member (although not in all cases and not for all colleges). This may be written by them personally or by their legal representation. Ideally, the response will either admit to wrongdoing and address remediation taken by the member, or provide substantive evidence that supports the actions that prompted the complaint. If this is the case, you may want to consider dropping the complaint. In my experience, the best responses I have received have admitted to some wrongdoing, but defended other practices addressed in the complaint. As a result, I have yet to drop a complaint in entirety (although I welcome the opportunity).

Most likely, the member will put forward their best effort to defend their practices. While you have no obligation to comment on their response, it very well may help your case to deconstruct and rebut their arguments. The response may deny the allegations outright, provide evidence supporting the conduct, or may cite previous regulatory rulings that support (or contend to support) the member’s position. You may even be personally attacked and have your credibility challenged. You should be prepared for all of these possibilities. Cordiality cannot be expected, but its absence certainly reflects poorly on the practitioner.

In composing a response, ensure that you reference the initial complaint. Have all aspects of your complaint been addressed? Did the practitioner comprehend the nature of your complaint? How have they supported their practices? Did they provide citations to back up their claims? Make sure to focus on the nature of their response as well as the specifics of the content.

The member may employ semantic arguments to defend their practices. I find this particularly pervasive among practitioners practicing pseudoscience. Rebuttal can seem tedious, but you should do it. You cannot assume that the regulatory authority will see through the member’s semantic arguments. This process can also help you better form your complaints. As an example, I have typically claimed that there is “no evidence” supporting certain pseudoscientific practices. Practitioners have been quick to respond that this is incorrect. I find this pedantic, but – indeed – they are correct; even the weakest and most invalid evidence is still evidence. There is plenty of evidence, for example, that aliens have made contact with humans. If your standard of evidence is so low that you accept these propositions, however, I contend that you should probably not be a health practitioner. Perhaps instead use the qualifier “no reliable evidence.” It can be helpful to provide scientific literature with your initial complaint, but you also have the chance within your rebuttal.

The nature of the response precludes in-depth cookie-cutter guidelines, so I will not go into additional depth on this issue. I will note that you may be tempted to publish the response, especially if it is particularly absurd. I would caution against this as this process is typically private and you may face legal or other actions that could put your complaint and you personally at risk. If you think there is information worthy of public disclosure, contact legal experts or the media to go forward.

Appealing a Decision

If you are not satisfied with the outcome of a complaint and feel that the college did not satisfactorily address your concerns or perform an effective investigation, you can appeal to a higher authority. Health appeal boards (HPARB in Ontario) exist independent to both the government and the health professions.

Generally, an appeal must be initiated within a strict timeline following the conclusion of the college’s complaints process. Likely, an attempt will be made to resolve the issue without assembling the Board. Should a review proceed, the Board will review whether the investigation and action of the college’s committee was appropriate. The Board typically cannot discipline members directly, but they can deem the investigation insufficient and send the complaint back to the college for additional review and potential discipline.

One advantage of pursuing appeals is that they will end up documented in CanLII regardless of the decision. This can aid in setting precedent as well as bringing exposure to issues through publicly accessible documentation. When you draft your appeal, make sure to offer background, so that someone reading it later on the public record will understand the earlier complaint process and result from the college.

While appeals are worth pursuing, appeal boards are not free from issues. In the case of HPARB, decisions have been made that demonstrate a lack of regard for public safety and complete ignorance of scientific issues. As a result, this mechanism can provide protection of blatant health fraud and set illogical standards that can be referenced as a pseudo-legal precedent in defense of complaints. Indeed, members of HPARB (and other boards) are not domain experts in health nor are they scientifically trained.

Alternative Regulatory Mechanisms

While any unethical or incompetent practices performed by regulated health professionals should first be addressed by their regulating colleges, jurisdictional overlap exists with some issues that open additional avenues for protecting the public.

As mentioned previously, health professionals are not immune from criminal law. Unlawful conduct and abuse should immediately be reported to law enforcement authorities. Some issues may arise when distinguishing between assault and controlled acts performed by health professionals. Involving both law enforcement and the professional authorities (college) is likely always the best approach.

When it comes to advertising and marketing, health professionals are not only bound by their college’s SoP. False and misleading advertising of various forms is not permitted in Canada. Issues regarding improper advertising to consumers are addressed by both Ad Standards – Canada’s advertising self-regulatory body – and the Competition Bureau – an independent law enforcement agency to ensure a prosperous and innovative marketplace. The value of complaints against health professionals is unclear, but may be worth pursuing.

Health Canada is an additional regulatory avenue concerning medical devices and health products. When examining the use and advertising of devices and products, first examine whether a valid registration exists with Health Canada. For example, drugs will have a Drug Identification Number (DIN) and natural health products will have a Natural Product Number (NPN) identifying the respective registrations with Health Canada. If a registration exists, it will outline the authorized uses and advertising, including references product monographs that provide technical and (ideally) scientific information. Complaints can be submitted both for unauthorized uses/advertising and for unregistered products.

As with the colleges, reaching out to these organizations with specific questions or concerns may help you to formulate a complaint or determine whether the issue falls within their purview.

Conclusion

As with all regulatory frameworks, those that govern the health professions are far from perfect. It is virtually effortless for me to identify numerous health practitioners in my province who are either advertising illegally or promoting and practicing blatant pseudoscience that is not only ineffective, but potentially harmful. Further, I expect that complaints against many of these practitioners may fail to bring about regulatory action. Does this demonstrate that our regulatory structure is a failure? Maybe, but our system is designed to rely on public participation and I contend that we should truly exercise our rights in this domain to put the system to the test.

I encourage readers who encounter unethical practices from health practitioners to confront them. If you are not comfortable putting your own name on a complaint, I am happy to submit any complaint on your behalf that I feel is reasonable. Even if you have lost faith in the regulatory colleges to act in the interest of the public, the submission of complaints at very least establishes a paper trail of misconduct. We have the power to demand better. We should use it.

Chiropractic Pediatrics Vs. Reality (Part I)

May 23, 2018

No Adjustment Necessary

On May 8th, Sharon Kirkey published an article in the National Post on the dubious offerings of chiropractors who manipulate children and infants. The article was respectful of responsible chiropractors and instead focused on bogus pediatric claims outside the domain of musculoskeletal conditions. In the worst cases, I have encountered chiropractors who believe that they can use spinal manipulation to treat mental illness, infectious diseases, and even cancer in children. Despite being a regulated health profession, these claims continue nearly unabated on websites, social media, and other advertising mediums, putting the health of Canadians at great risk. I have taken it upon myself to report these practices in my spare time, but I simply do not have enough time to take on every unethical practice.

Following the publication of Kirkey’s piece, the National Post published a response from the Canadian Chiropractic Association’s (CCA) Chair, chiropractor David Peeace. The CCA is generally considered to be among the voices for progressive and evidence-based chiropractic in Canada. How progressive are they? Well, they have accepted vaccination as an effective public health measure outside the scope of chiropractic practice. You might think that is a pretty low bar for a national organization representing health professionals, but it’s a standard that even some chiropractic regulators have failed to meet.

This is why the response from the CCA was so troubling; their letter ignored the issues at hand and instead defended pediatric practices broadly. Of course, it’s worth remembering that the CCA is not a public health organization and not a regulatory body. Rather, they are an advocacy organization for chiropractors whose mission is for chiropractors to be “an integral part of every Canadian’s healthcare team by 2023.” All I will say in response to that is: won’t somebody please think of the children?

While pediatrician Dr. Clay Jones wrote a response to the CCA’s letter at Science-Based Medicine, I wrote my own response which I forwarded to the National Post editors. Since it seems evident at this point that they will not be publishing my response, I will post it here. Enjoy.

Chiropractic Pediatrics Not All It’s Cracked Up to Be

In response to criticism of pediatric practices that “border on the fraudulent,” Canada’s largest chiropractic advocacy organization responded in a fashion that one would expect from politicians rather than registered health professionals; the response ignored the pseudoscientific elephant in the room and mounted a defense of indefensible practices.

While there may be a role for chiropractors to manage musculoskeletal (MSK) conditions in adolescents and children (although not well established in the literature), this was not the issue addressed in Sharon Kirkley’s original piece, which narrowed in on “outlandish” claims that mislead the public on serious medical conditions outside of the scope and expertise of chiropractors. The piece also addressed erroneous claims that “birth trauma” to the spine is a common concern that parents should address with chiropractic care.

Despite claims of “successful outcomes,” there is no credible evidence suggesting that spinal manipulation is indicated for any infantile condition. Though the risk of serious adverse events may be low, unnecessary procedures with no demonstrated benefits and documented risks have no place in our healthcare ecosystem. An additional risk exists with young children who may present with MSK complaints that arise from serious underlying causes, requiring appropriate medical evaluation beyond the scope of chiropractic care.

Unfortunately, unsubstantiated pediatric practices and the deceptive advertising that comes with them are commonplace in Canada. Although the precise prevalence is unknown (neither chiropractic advocacy organizations nor regulators seem to keep track), their existence is no secret to anyone with a web browser.

A small proportion of these chiropractors belong to the International Chiropractic Pediatric Association (ICPA), which boasts almost 600 Canadian members. The ICPA’s mission includes the claim to “improve the health of children,” yet they have propelled anti-vaccination ideas and act as a publication venue for papers of questionable quality, highlighting additional affronts to both public health and science.

These are not just my opinions. Earlier this year, the Canadian Paediatric Society reaffirmed their position on chiropractic, raising concerns regarding lack of evidence, lack of training, misleading vaccination advice, overuse of x-rays, and potential side effects. While I have observed many members of the chiropractic profession lambast the medical profession, at least the Canadian Medical Association is forthcoming about the skeletons in their closet and is actively engaged in public health efforts, including confrontation of the opioid crisis.

To avoid instigating a #notallchiropractors movement, it’s worth acknowledging that the profession has made progress in recent years. Indeed, public health experts are increasingly willing to extend an olive branch to the chiropractic community in recognition of the responsible and knowledgeable practitioners who look after the musculoskeletal health of Canadians. The terms, however, are non-negotiable: it is time to drop the pseudoscience.

Chiropractic: A Modern Threat to Canadian Health

December 17, 2017

A Brief History of Chiropractic

No more than a year ago, my preconception of chiropractic was probably similar to that of most Canadians; I assumed that chiropractors were doctors who specialized in back pain as it relates to the spine and musculoskeletal system. As I began to research chiropractic – dissecting both modern practice and historical origins – I found that this simplistic understanding did not account for the wide variety of diagnostic and treatment paradigms that practitioners adhere to. While many chiropractors are experts in the domains of pain and function in relation to the musculoskeletal system and spine, there are many chiropractors who purport treatment of nearly all medical ailments. These chiropractors hold on to age-old beliefs that are steeped in a spiritual mysticism and vitalism.

The invention of chiropractic is attributed to D.D. Palmer. Palmer was originally a magnetic healer who appropriated the osteopathic technique of joint manipulation. He further appropriated the medical term “subluxation” to refer to what he thought were misaligned vertebrae. Positing that these misalignments impinge on nervous tissue which control healing forces within the body, Palmer implicated subluxations as the root cause for all manner of disease. In his book The Science, Art and Philosophy of Chiropractic, he claimed:

Image retrieved Jan. 2017 from here. 

D.D. Palmer’s practice of chiropractic may never have gained the following it has today if it weren’t for the mythologizing of a particular extraordinary deed. In 1895 – examining the back of the hearing impaired Harvey Lillard – Palmer claimed to have discovered a bony protrusion. By performing a manual adjustment of the offending vertebrae, Palmer was credited with restoring Lillard’s hearing.

Harvey Lillard
Retrieved April 2017 from here.

Although the incident is often said to be instrumental to the proliferation of chiropractic, treatment of the deaf is not something found within the scope of modern chiropractic. In fact, no chiropractor has performed the procedure successfully under controlled conditions. The challenge of repeating this chiropractic miracle is likely attributable to the anatomy of hearing (something we now more clearly understand); the auditory nerves reside exclusively within the skull and at no point travel down the spine. To put it bluntly: chiropractic cannot heal the deaf.

As chiropractic first expanded, some practitioners incorporated radical religious and philosophical beliefs. The adoption of religious symbolism and ideology was – in part – a ploy by Palmer to protect chiropractors from prosecution for practicing medicine without a license. Although much of Palmer’s writings were contradictory and far from concise, his philosophy generally describes a Universal Intelligence (God) that manifests as an Innate healing power channeled through the nervous system and spine.

In essence, Palmer’s principles of chiropractic assert that subluxations result in interference between the Innate vitalistic force and the body by compressing the nerves, causing disease. When chiropractors perform adjustments on patients, they claim to be completing the body’s connection with Innate, allowing it to perform its healing ability. It is this practice that led chiropractors to coin the notion of, “connecting man the physical with man the spiritual,” which is often expressed as turning people’s power on.

Of course, no one would believe these things in this modern age would they? Actually, London’s own celebrity chiropractor B.J. Hardick evidently subscribes to a very similar worldview:

BJ Hardick Universal Intelligence
Image retrieved Jan. 2017 from here.

While many current practices today developed from mythologies of the past, chiropractic is unique for retaining much of its philosophical and religious heritage. It’s not uncommon today to hear chiropractors reference Innate or subluxations within their practice. Although the term subluxation does have an appropriate medical use, chiropractors have manipulated it to fit their own design. The lack of substantiation for vertebral subluxation did little to impede the proliferation of chiropractic.

Image retrieved Jan. 2017 from here.

If subluxations are a valid source of concern, we should be able to identify them, illustrate their causal link to disease, and demonstrate that their treatment has a positive effect on specific disease processes and patient symptoms. In 2009, a group of chiropractic researchers examined the evidence relating to subluxations and found “no supportive evidence . . . for the chiropractic subluxation being associated with any disease process or of creating suboptimal health conditions.” Some chiropractors took issue with the findings, but none put forward a substantive critique. Indeed, when suggesting a novel scientific paradigm, the burden of proof rests on those who make extraordinary claims.

While practitioners of unproven techniques often recall the aphorism that an absence of evidence is not evidence of absence, after years of investigation, evidence of absence is precisely what plagues the chiropractic subluxation. The British General Chiropractic Council denounced the subluxation complex in 2010, followed by additional chiropractic institutions in 2015. Despite the fact that there is no evidence or plausible biological mechanism to validate subluxations as the cause of disease, and despite the fact that chiropractors can’t reliably identify subluxations, some chiropractors continue to apply this philosophy in their clinical treatment. Prominent chiropractors in support of evidence-based practice have noted the detriment to public health that is subluxation theory.

In his book Chiropractic Abuse: An Insider’s Lament, chiropractor Preston Long details how the chiropractic profession is plagued by unscientific beliefs that have persisted in spite of their clash with modern scientific and medical knowledge:

“I am a chiropractor. I do not say this with pride. My profession is full of men and women who exaggerate what they can do and provide unnecessary and sometimes dangerous services to their patients. Most chiropractors are not bad people, but far too many embrace cult-like beliefs.”

Source: Chiropractic Abuse: An Insider’s Lament, pg 21

Chiropractic Abuse by Preston Long

Reformation

Today, a contentious rift exists within the chiropractic community. There even exists terminology to demarcate between those clinging to the ideas of the past and those who incorporate novel techniques: straights (often self-described as principled) are those who follow the classical Palmer doctrine whereas mixers are those who incorporate other techniques including modern scientific understanding of disease processes (although mixers sometimes pursue equally suspect health practices). This leaves us with two different chiropractic philosophies. The former (the straights) generally believe that subluxations are the root cause of most disease and that a lifetime of spinal adjustments is essential for maintaining proper health. The latter (the mixers) apply spinal manipulation therapy to relieve musculoskeletal pain and generally work with patients to improve mobility and function.

So if the subluxation is a mythical concept, what benefits do chiropractors offer? A 2011 Cochrane review examined the use of combined chiropractic interventions for what chiropractors are most known for: treatment of lower back pain. While they found evidence that “chiropractic interventions slightly improved pain and disability in the short term and pain in the medium term for acute/subacute” lower back pain, they concluded that “there is currently no evidence that supports or refutes that these interventions provide a clinically meaningful difference for pain or disability in people with [lower-back pain] when compared to other interventions.” Follow up research examining spinal manipulation therapy reached a similar conclusion in 2013.

In addition to lower back pain, there is some evidence indicating that spinal manipulation may aid migraines, as well as neck pain. While the evidence is weak, this may be a result of biomechanical variability among patients, causing some patients to respond well to treatment but not others. After all, many patients swear by chiropractic; while recent Gallup polls illustrated that the American public finds physical therapy generally more effective and safer than chiropractic for neck and back pain, chiropractic care did rank higher than all other interventions. Indeed, many patients are satisfied with their chiropractic care. Despite the mixed evidence, there may be a future for spinal manipulation therapy in treating some pain and disability. If chiropractors can help curtail the opioid crisis as they purport, then their deployment in conservative musculoskeletal care is welcomed.

Unfortunately, a significant impediment to healthcare integration is the division within the chiropractic community. Chiropractic’s historical baggage has led to disparate professional identities, causing criticism from the medical community, particularly among orthopedic surgeons. It’s not hard to see why. Many chiropractors make outlandish and unsubstantiated claims regarding treatment of conditions unrelated to the musculoskeletal system. While evidence-based practitioners generally offer manipulations with the intent of mobilizing joints, those in the straight community claim to precisely adjust misaligned vertebrae and restore them to their proper positions. These claims are dismissed even by chiropractic researchers, yet many practitioners still offer these unscientific services.

A Legacy of Anti-Science

Subluxation-based chiropractic is a treatment in search of a disease. Unlike most medical research which seeks to evaluate novel treatments and diagnostic techniques, chiropractic research is still trying to vindicate an age-old approach to health. This led the American Medical Association to label chiropractic an “Unscientific Cult” as early as 1969. In response, chiropractors sued. Though the AMA lost in an antitrust suit (not by scientific merit), the war continues to this day and chiropractors have still not demonstrated the existence of the subluxation.

In contrast to health practices like physiotherapy or massage, subluxation-based chiropractors are particularly vocal in their opposition to the medical system. A likely explanation – aside from the obvious history – is that physiotherapy, massage, and even modern chiropractic are exclusively complementary to medical practices. Quite distinctly, subluxation-oriented chiropractors often find themselves in competition with the medical system; after all, subluxation-based chiropractors consider their treatment to remedy the cause of most afflictions (despite the lack of evidence). A simple Google search involving the term ‘chiropractic’ and any disease will produce unsavory results. Even chiropractic’s patriarch D.D. Palmer spent time in jail for practicing medicine without a license.

Perhaps the most repugnant philosophical stance that remains pervasive in the chiropractic world is the fervent opposition to vaccination. While scientists and public health experts unanimously recognize vaccination as an effective approach to prevent disease with little risk, the topic remains a contentious issue within the world of chiropractic. D.D. Palmer’s son, B.J. Palmer – the great promoter of chiropractic – is largely responsible.

“The idea of poisoning healthy people with vaccine virus . . . is irrational. People make a great ado if exposed to a contagious disease, but they submit to being inoculated with rotten pus, which, if it takes, is warranted to give them a disease.”

Source: B.J. Palmer’s The Science of Chiropractic: Its Principles & Adjustments

B.J. Palmer

With a long history of opposition to vaccination, chiropractors who cling to the ideas of the past put children at risk and endanger public health. If you think that chiropractic in Canada has outgrown its superstitious and unscientific views, you would be wrong. A recent investigation uncovered significant promotion of anti-vaccination propaganda among Manitoba chiropractors, leading to calls for proactive oversight and regulation. Some chiropractors are even ignorant enough to make media statements against vaccination.

“My parents chose to opt me out of the routine vaccination schedule many years before the world was paying attention to mercury toxicity, Autism, studies, or anything else … My parents wanted me to develop my immune system naturally, without interference.”

Source: Dr. B.J. Hardick [Facebook]

B.J. Hardick

Steven-Salzberg-on-Vaccinations
Image retrieved Jan. 2017 from here.

Anti-vaccination beliefs aren’t the only risk posed to children by chiropractors. One area in particular where chiropractic has received extensive criticism from the medical community is in the domain of pediatrics. Many chiropractors in Ontario and abroad have made outlandish claims with regards to chiropractic treatment for infants and children. While there are documented consequences from chiropractors working on infants, precise rates of complication are unknown – likely a consequence of poor adverse event documentation and reporting.

“There’s nothing that I love more than seeing a kid jumping up on the table . . . make sure they’re subluxation free and whether it ever elicits a symptomatic change in that child or not, just being able to know that we’ve turned on the power.”

Source: Dr. B.J. Hardick: A Maximized Living Co-Author explains “Why he died.”  [The Chiropractic Philanthropist]

“I check a ton of kids the day that they’re born.”

Source: Kids Chiropractic Adjustment [YouTube]

B.J. Hardick

B.J. Hardick is a prominent example of a chiropractor promoting treatments for infants and children. The following images were all scraped from his professional Facebook page:

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The absurdity of chiropractors treating infants is only eclipsed by what they claim they are treating; many chiropractors advocate for treatment of children with ear infections, asthma, colic, and other non-musculoskeletal conditions. It’s important to note that the vast majority of conditions that chiropractors treat in children are self-limiting – they tend to resolve spontaneously. A prominent example is colic, for which there is no evidence supporting chiropractic treatment.

Dr. Harriet Hall Chiro
Retrieved Jan. 2017 from here.

In Canada, the problem is pervasive enough that the Canadian Pediatric Society released a position paper: “Chiropractic care for children: Controversies and issues”. The original position was posted in 2002 and reaffirmed in 2016. When examining the scientific evidence, they found that there was no evidence for chiropractic to treat any pediatric disorder. Instead, they found that chiropractors put children at risk by spreading misinformation regarding immunization and by attempting to treat acute pediatric conditions that instead need serious medical treatment. These weren’t the only risks identified. The authors noted that “parents should be made aware that there is a lack of substantiated evidence for the theory of subluxated vertebrae as the causality for illness in children, and x-rays taken for this purpose expose the child to unnecessary radiation.” In fact, chiropractors often overuse x-rays. Even for lower back pain, Choosing Wisely Canada recommends against x-rays partly because it has not been shown to improve management of symptoms. Naturally, misuse of X-ray technology has a long history in chiropractic. B.J. Hardick himself claims that it’s dangerous to adjust without x-rays and has showcased x-rays of children in his YouTube videos.

In a further affront (conscious or otherwise) to public health, many chiropractors attribute risk of subluxation to how the baby is delivered (here is a prime example). Not only are they doing a disservice to public health, but they are unnecessarily shaming mothers about their personal choices regarding the birth process.

“The more natural the delivery, the less interference, the fewer interventions medically that are necessary, the less trauma to the skull . . . I had a baby last week where unfortunately based on the way the baby was presented, they had to turn the baby manually inside the mom and then pull the baby out. So the baby’s neck was definitely subluxated.”

Source: Kids Chiropractic Adjustment [YouTube]

“One fact we do know, however, is that the first subluxation usually happens in the birth canal because of the normal trauma associated with vaginal deliveries. Even babies delivered by C-section are subject to birth trauma and vertebral subluxation. This is why it is absolutely critical for parents to bring their babies to their chiropractor as soon after birth as possible. This will ensure that their child’s nervous system is functioning at full capacity, which will provide the framework for a long life of health and vitality.”

Source: http://drhardick.com/kids-chiropractic

B.J. Hardick

Where are the regulators?

In 1991, chiropractors became authorized to use the title ‘doctor’ under the Chiropractic Act. This privilege has been used irresponsibly by chiropractors nation-wide when making public statements on medical concerns unrelated to musculoskeletal issues. When the public is likely to conflate the use of the title ‘doctor’ with ‘medical doctor’, it is irresponsible to apply the title in the context of non-musculoskeletal medical advice; this is especially true when practitioners are disseminating misleading information.

The College of Chiropractors of Ontario is the self-regulating body for chiropractic in Ontario. As authorized in the Chiropractic Act, the chiropractic scope of practice is as follows:

  • The practice of chiropractic is the assessment of conditions related to the spine, nervous system and joints and the diagnosis, prevention and treatment, primarily by adjustment, of,
    • (a) dysfunctions or disorders arising from the structures or functions of the spine and the effects of those dysfunctions or disorders on the nervous system; and
    •  (b) dysfunctions or disorders arising from the structures or functions of the joints.

The problem is that the application and enforcement of this scope is open to broad interpretation. If you subscribe to the classical subluxation philosophy and believe that spinal adjustments channel the healing power of Innate through the body, what could possibly be considered outside of a chiropractor’s scope of practice?

How pervasive is the belief among practitioners that chiropractic can effectively treat a wide range of medical conditions unrelated to the spine? Unfortunately, it is not known. No regulatory body surveys and disseminates this information and existing literature on the topic is unreliable at best. A recent survey of Canadian chiropractors indicated that large proportions of chiropractors in clinical practice use entirely unsubstantiated diagnostic and treatment techniques (for example, 22% claimed to prescribe homeopathy – a treatment that isn’t only unproven but implausible).

Ultimately, the regulatory body has not enforced evidence-based practices, resulting in a vast number of chiropractors who sell useless, even dangerous treatments. My article regarding the Byron-based chiropractor who uses a cheap ear thermometer to diagnose subluxations is a prime example of a chiropractor running a successful business in spite of either having no idea what he is doing, or consciously conning his patients. It’s worth repeating: where are the regulators?

Unfortunately, patients seeking responsible chiropractic care must be extra diligent in screening their care provider. My advice would be to take time to examine the chiropractor’s website. Do they make absurd claims regarding non-MSK conditions? Do they treat infants? Do they treat subluxations? Do they offer long-term treatment/payment plans? Do they advertise testimonials regarding conditions outside of the scope of chiropractic? Do they perform x-rays on every patient? If the answer is yes to any of these, you’re very likely dealing with a quack.

“Good chiropractors are essentially physical therapists who specialize in the spine. Spinal manipulation is an effective option for mechanical low back pain, but physical therapists and some doctors also use that treatment. Some chiropractors want to be primary care providers and treat a variety of non-MSK diseases, but they are not trained to do that. Many chiropractors subscribe to outright quackery like applied kinesiology; and only half of them support vaccination. A medical subluxation is a partial dislocation of a joint that is readily visible on x-ray; the “chiropractic subluxation” is a myth and does not show on x-ray. And chiropractic can be dangerous: stroke is a rare but devastating complication of neck manipulations.”

Source: Interview with Dr. Harriet Hall

Dr. Harriet Hall

The Oil Rush: How Health Canada has Failed to Regulate Deceptive Health Products

December 12, 2017

My former roommate was an early adopter of essential oils. Using a diffuser (ultrasonic humidifier) to spread fragrances house-wide, I would come home to aromas of peppermint, orange, and lavender instead of the familiar musty scent baked into our basement apartment. Sold on the efficacy of essential oils in reinvigorating stagnant air, I too became a user. In a rational world, this is where the story would end. Unfortunately, we do not live in a rational world.

Essential oils have taken upper middle class suburbia (and by extension Instagram) by storm. Social media platforms – once the refuge of dank memes and animal pictures – are now home to the blurred line between people’s personal lives and their multi-level marketing schemes. What’s particularly frightening, however, is how quickly each exciting new business opportunity has become the path to true health and wellness.

If you believe everything you read, you might think that essential oils are here to cure cancer, solve world hunger, reverse climate change, and ultimately prevent the impending heat death of the universe. You might think that essential oils have been divinely bestowed on us to empower stay-at-home parents to become entrepreneurs and health gurus while simultaneously enriching themselves, their communities, and the world around them. You would be wrong, but I can’t blame you.

Essential oils have been marketed relentlessly and deceptively by multi-level marketing organizations that profit from our modern addiction to wellness. Although Young Living pioneered the business of deceptive essential oil marketing, doTERRA made it a household affliction through their consultants’ insistence that oils could treat anything from asthma to Ebola.

The natural Ebola cure.
The natural Ebola cure. Retrieved Dec. 2017 from: http://4.bp.blogspot.com/-H3OdCWW_0to/VCNtk0PL1LI/AAAAAAAADsM/taC1KjoJLr8/s1600/ebolaoregano.PNG

In reality, essential oils have not been demonstrated to be particularly effective at preventing or treating any disease or condition. It wasn’t long before both the EPA and the FDA took action against this blatant pseudoscience, prompting doTERRA to go on the defensive. Now, rather than instructing their consultants to make unsubstantiated health claims that are illegal, doTERRA provides guidelines for consultants that employ semantics to avoid those pesky science-based regulators:

doTERRA Quick Claims Guide
doTERRA Quick Claims Guide. Retrieved Dec. 2017 from: http://media.doterra.com/us/en/flyers/quick-claims-guide.pdf

Of course, there isn’t even good evidence that essential oils satisfy any of the “Structure-Function Claims,” but the mildness of the claims are enough to appease the FDA. As unfortunate as it is for public health, however, doTERRA advocates are not mild people.

In London, we are home to Canada’s first Presidential Diamond doTERRA representative: Ange Peters. In their not-at-all-a-pyramid-scheme compensation plan, the honor of Presidential Diamond is bestowed only on those who have climbed to the top and profited from those below.

doTERRA Compensation plan
doTERRA Compensation plan. Retrieved Dec. 2017 from: https://www.doterra.com/medias/9841222451230.jpg

Of course, it is unlikely that anyone gets to the top of the doTERRA food chain without being a prolific purveyor of pseudoscience.

Ange Peters is not a doctor
Ange Peters is definitely not a doctor. Image retrieved Dec. 2017 from: https://i.ytimg.com/vi/SsGecufx1rw/maxresdefault.jpg

Although Peters claims to guide women to true HEALTH, her social media is not filled with responsible health advice. Instead, her media is a window into a world where self-promotion, product marketing, unsubstantiated health claims, and even her personal life have become intertwined into a caricature of the social media takeover by advertisers.

Ange Peters Promotion
Are we all just props in a social media nightmare? Retrieved Dec. 2017 from: https://www.instagram.com/hol_fit/?hl=en

But I digress; what troubles me more than the content of my social media feed is the content of Peters’ advertising. The sheer magnitude of misleading medical claims that appear on Peters’ various platforms is staggering. Her own “Getting Started with Oils” guide provides a compendium of medical recommendations for essential oil, which can be accessed by clicking the prominently displayed “Health Concerns” graphic:

HOL:FIT Wellness :: Getting Started with Oils
HOL:FIT Wellness :: Getting Started with Oils. Retrieved Dec. 2017 from: https://docs.google.com/document/d/1FgogIRFosPDLelanNgY5e5Tql1Ygvxu3BrtBdRmsSpY/edit#

In this encyclopedia of serious medical conditions, various criticisms are levied against effective medical treatments. Instead, specific essential oil “Protocols” are offered for every affliction you can think of. Of course, none of them are proven to work in any capacity, hence the inclusion of the Quack Miranda Warning. In many cases, these “treatments” likely do more harm than good.

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Although the domain of this site is registered to doTERRA, the content was taken offline some time ago, presumably in response to the crackdown by the FDA. I find it troubling that Peters went to the trouble to link to an archive of the site. I’m further troubled by the vast assortment of dubious health advice Peters offers when promoting her products and services.

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The vitamin and mineral comment likely stems from a landmark 2004 study (and similar studies) that saw a small reduction in some nutrients among cultivated crops, likely attributable to changes in soil composition and changes in cultivated varieties. It’s a worrying trend and certainly something to keep an eye on, but to say we need to eat five times the food today for the same vitamin and mineral intake is nothing short of ignorant. The claim grossly overstates the reduction and doesn’t identify which foods or even which nutrients in those foods are impacted. Further, do these changes even impact our health in any capacity? I get the impression that Peters hasn’t read the primary scientific literature.

Ange Peters Learns from YouTube
At least it was much cheaper than a medical degree. Retrieved Dec. 2017 from: https://www.youtube.com/watch?time_continue=1&v=iXIsRSDPWQA

Peters often claims to be “passionate about educating and empowering women to live their best life through natural solutions”. In reality, Peters is empowering her audience to take big risks with their health and their finances. Unfortunately, doTERRA has laid the foundation for Peters and other like-minded practitioners to prosper unabated while organizations like Health Canada have been complicit and ineffective in preventing false health claims. Whether a result of incompetence or ignorance, Health Canada – the organization mandated to protect the public from dangerous and ineffective health products – has failed.

In what is certainly an effort to find a balance between consumer demand and public health, Health Canada allows for the registration of Natural Health Products – products which are supposed to be screened to ensure they are “safe, effective and of high quality.” The problem, however, is that a vast number of registered products have literally no scientific evidence supporting the claims they are permitted to make. So how did they come to be registered?

In place of scientific evidence, Health Canada will accept “Tradition Use Claims“. So if someone once used an ingredient, made up a claim about it, and then wrote it in a pharmacopoeia, products using this ingredient can register as natural health products and make the same claims – true or not. This is an ongoing failure of Health Canada that the CBC frequently illuminates. It’s the same flaw doTERRA has exploited.

Let’s look at a specific example: doTERRA’s Juniper Berry Essential Oil. On their Approved Claims List, doTERRA permits Canadian representatives to make a number of aromatherapeutic claims:

doTERRA - Juniper Berry
Retreived Dec. 2017 from: http://media.doterra.com/ca-otg/en/flyers/approved-claims-list-ca.pdf

Here’s the problem: Health Canada’s monograph for juniper essential oil doesn’t contain a single scientific or clinical study supporting its use for anything. Nonetheless, the oil is a registered natural health product, citing juniperus communis as a medicinal ingredient – a compound that also lacks scientific evidence from Health Canada for oral use.

A lack of regulatory controls on health products can have serious consequences. Not everyone is privileged enough with time and resources to conduct a thorough review of health claims. When essential oil companies boast that their products are registered natural health products, it lends legitimacy to the outlandish claims, emboldening proponents to believe that they were right all along about every mystical claim attributed to what is simply an aroma. As a result, listening to doTERRA advocates is like listening to a child talking about all the things Santa’s elves can do. Health Canada needs to be the one to tell her that Santa isn’t real.

I should be clear that I don’t believe Ange Peters acts maliciously. Although I wouldn’t say her business is innocent of profiteering, I get the sense that she feels her beliefs are vindicated. After all, she has amassed an audience of happy and healthy followers. Every successful customer is not just a business win, but a philosophical win. These are the people who I worry about the most.

When one of her clients asks “Does terrazyme help fight against disease?” and Peters answers “Yes,” it condemns her audience to spend time and money chasing supplements that have no clinical evidence for preventing disease. Some may seek these products in place of legitimate medical care, but as it stands, doTERRA is not a medical company and essential oils are not medicine.

Despite not living up to their hype, I don’t hold anything against essential oils. In fact, I still use them nightly in my diffuser. Why? They smell nice and I enjoy it. What I won’t do is purchase from unethical companies like Young Living and doTERRA that have profited from misleading health claims and a predatory business model.

The Chiropractor’s Toy

April 19, 2017

I’ve been keeping my ear close to the ground on all things chiropractic lately, often coming across strange and unethical practices that are in need of a well-deserved scientific flogging. Most of these I let pass in anticipation of a bigger catch, but there is one practice that I can’t get over how funny it would be if it weren’t so troubling. First, some history.

Chiropractic originated from the father and son team of D.D. Palmer and his younger counterpart B.J. Palmer. Papa Palmer is largely attributed as the inventor of chiropractic, but B.J. Palmer and his unparalleled marketing skills helped make the profession what it is today. A prolific promoter, B.J. was an author, a radio host, and even at one point a circus hand. He was certainly no stranger to gimmicks.

In expanding the diagnostic scope of chiropractic practice, B.J. introduced two devices into the clinic. The first was the x-ray machine, which is often of no use when treating lower back pain and is recommended against by Choosing Wisely Canada. Despite this, they are used widely by chiropractors in the treatment of lower back pain. The second device, was the neurocalometer – a gadget that B.J. fervently advertised and sold. What’s unique about the neurocalometer is that even many chiropractors agree that its introduction and promotion was unethical.

The Neurocalometer
The Neurocalometer [source]
So what is the neurocalometer? It’s a thermometer. No really, it’s basically just a thermometer.

The idea is that chiropractors use temperature as a gauge to measure subluxations – displacements of the vertebrae that impinge on the spinal nerves. They (I should be clear – not all chiropractors) believe that this interference in the nerves causes dissipation of heat to surrounding tissue, allowing them to precisely diagnose subluxations. There’s just one problem: subluxations don’t exist. In fact, a group of chiropractors and researchers found no evidence that they exist or are causally related to any disease process. Despite this, a large number of chiropractors still claim to be able to diagnose and treat the mythical vertebral subluxation.

As you can imagine, since vertebral subluxations don’t exist, there isn’t much hope for the neurocalometer as an effective diagnostic instrument, but it gets worse; even the Canadian Chiropractors Association stated that the “validity and reliability of measurement are highly doubtful.” This makes sense. Even if we granted the existence of subluxations, do nerves create heat when pinched? If nerves create heat when pinched, is it enough to be measured? Is enough heat created to be measured indirectly at the surface of the skin? The answer to all of these questions is an affirmative no.

Regardless, many chiropractors still make use of variants of the neurocalometer at great expense to their credibility. Luckily, crafty chiropractors at least avoid the great expense to their overhead and recognize that neurocalometers are really just overpriced thermometers. So why not just use a cheap ear thermometer instead? They measure surface temperature and are much more widely available. Even though they might not be very reliable, they make up for it by being cheap and easy to come by. You can even pick them up at Toys R Us:

In fact, one local chiropractor uses a similar (if not the exact same) model in a video “demonstrating” its use:

Source: “London, Ontario Newborn Adjustment” Retrieved from: London, Ontario Newborn Adjustment

That’s not to say the thermometer doesn’t work; it certainly is a real thermometer, but what is the chiropractor using it for? Well, in the video posted by his practice to Facebook (which my good friend Dennis forwarded to me), he is using it to diagnose subluxations. On a 2-week-old infant.

I left a comment on the post expressing my concerns. It was promptly removed and I was blocked from the page. After composing the initial draft of this article, I sent it to the Kay Harris Chiropractic & Wellness Center asking if they would respond or at least offer corrections if they found issues. They haven’t responded. Why is it that chiropractors have the audacity to promote such things without the integrity to defend them?

Remember, subluxations are to chiropractors as the tooth fairy is to children; they don’t exist, but still seem to bring in the money. That’s not all; there is no reason to think that chiropractic offers any benefits to children:

I don’t know of any reason to believe that it might be necessary to refer a child to a pediatric chiropractor or to use spinal manipulation on a child prior to onset of adolescence. “Wellness care” in the form of “subluxation correction” is unnecessary and scientifically indefensible, and it places children at risk. 

 -Sam Homola, Chiropractor

Yet here is a chiropractor with an infant in one hand and a thermometer in the other. He claims that treatment for a subluxation is needed for a 0.2 degree differential in temperature. Well not only are ear thermometers not designed for this purpose, but they are not terribly accurate. The thermometer in question has an accuracy of ±0.2°C even though its display resolution is 0.1 °C. It might be surprising to you at this point, but that means that a 0.2 degree differential cannot be reliably measured with this device. Because the accuracy is even worse outside its normal operating range, it’s likely that the device couldn’t even diagnose Harvey Lillard‘s Mother of all Subluxations. That is, if subluxations existed.

Further, according to the manual, “this thermometer is intended for household use only.” So I hope the chiropractor’s practice is at home; I want him to be comfortable when he hears this: what you are doing in this video is entirely useless.

Stay Scientific.