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Federal Trade Commission Workshop: Submit YOUR Comments to the FTC

October 20, 2015
The Federal Trade Commission (FTC) held a workshop in Washington, DC on September 21, 2015 to evaluate advertising for over-the-counter (OTC) homeopathic products. There were three panels presenting the homeopathic industry, science and legality. Speakers on the panels represented the FTC, the Food and Drug Administration (FDA), the homeopathic community, research, advertising, and mainstream medicine. NCH Board member Tina Quirk and NCH member Glenna Tinney attended the workshop as NCH’s representative and observer.
 
In the first two panels the homeopathic speakers attempted to explain the important differences between homeopathic and conventional OTC products and the deep research on the individual homeopathic medicines that has been accepted by the FDA through the Homeopathic Pharmacopeia of the U.S. (HPUS) for decades. However, many of the mainstream science speakers on these panels were clearly unfamiliar with the principles of  homeopathy and the use of homeopathic medicines.The mainstream medicine speakers were particularly critical and dismissive of any documentation that did not employ randomized placebo-controlled drug trials. They presented a unified voice communicating strongly the opinions that: there is no scientific evidence that homeopathy works; homeopathic products are potentially unsafe and dangerous to consumers; homeopathic OTC products should have a higher level of regulation by the FDA; the FTC should crack down on the claims being made about homeopathic products to eliminate false and misleading marketing and advertising.  
 
The FTC and homeopathic participants stress that this workshop was a listening and information-gathering workshop and does not indicate what, if anything, the FTC will act on. As well, the Commissioner stated that the FTC is not focused on the practice of homeopathy, only the advertising of its products.The FTC also is planning to interface with the FDA and pursue further discussions as they negotiate their roles of regulating safety and quality (FDA) and protecting the consumer and promoting competition (FTC). 
 
A full report on the FTC proceedings will appear in the Winter 2015 issue of Homeopathy Today magazine, scheduled to mail to current NCH members in December of 2015. Join NCH today to start your complimentary subscription.
 
It is very informative to watch the proceedings of the workshop. Not only is this your government in action, but it is about the health care modality that you have strong feelings about. To watch the archived video of the workshop, the links (2 of them) can be found on: https://www.ftc.gov/news-events/events-calendar/2015/09/homeopathic-medicine-advertising
Under "Event Deatils" click on the VIDEO triangle to reveal the links to the morning video session  and the afternoon video session.  
 
A transcript of the FTC workshop and archived video of part of the proceedings is available on the FTC website here. Have a look. It makes for interesting reading!
 

Action Alert Information: 

It is important for homeopathic consumers, practitioners, researchers, and educators to make comments to the FTC. To ensure productive dialogue, the American Association Homeopathic Pharmacists (AAHP) has developed guidelines for making comments to the FTC. As with the FDA, the AAHP has a productive historical relationship to the FTC and is best placed to understand the intricacies and create a strategic plan forward with both agencies. 
 
The FTC has opened their public comment page and is accepting comments until 11:59pm ET November 20, 2015.  The American Association for Homeopathic Pharmacists (AAHP) encourages the homeopathic community to respond in a positive and productive way to the FTC on the following points:
 
1. Share your shopping experiences of homeopathic OTC products. How did you learn about the products you have bought? How did you decide which one to purchase? How much did you rely on advertising to guide you? How does purchasing homeopathic OTC products fit within your overall wellness practices for you and your family? 
 
The FTC is concerned that advertising claims are misleading consumers. However, according to a survey of shoppers by Candace Corlett of WSL Strategic Retail presented to the FTC workshop:
• 37% learned about their homeopathic medication through some form of  recommendation, as from a friend, family member, or practitioner 
• 18% have done their own online research. 
• 12% learned through traditional advertising, in newspapers, ads, commercials. 
 
2. Suggest ways for the FTC staff to learn more about the unique principles and methodology of homeopathy.  What are your brief, simple and clear recommendations to read about homeopathy principles, homeopathic provings, theory of dilutions, nano-research? What has been most helpful to you to understand the scientific mechanisms of homeopathy? You can upload your suggested articles to the FTC response page.
 

FDA Commenting Period Reminder

In addition, the comment period to the FDA has been extended to November 9, 2015. If you have not submitted comments to the FDA, you have more time.Tell them about your experiences in choosing the appropriate homeopathic remedy. It is important for them to know that the current labeling of homeopathic OTC products, which have been in place for decades, are clear and do not cause confusion or safety issues for the consumer. Again, the focus is on labeling, not on practice, and the FDA needs to hear your positive experiences. We’ve provided detailed guidance on how to best draft and submit your FDA comment here