As a naturopathic doctor, I support regulations that ensure the products I recommend to my patients are safe, effective, and of high quality. Unsubstantiated health claims, misrepresentation of content, and shady manufacturing and importation practices, do not enhance the health of Canadians and can pose a health risk. Therefore, regulating natural products for the purposes of reducing risks to one's health, enhancing safety and accuracy of products makes sense.

From a bird's eye view, Bill C-51 appears well intended and seems to strengthen the manner in which all health products will be regulated. But as you delve into the details of the bill you discover the potential for disaster it poses for the practice of naturopathic medicine in Canada. The ramifications include reduced public access to certain natural medicines that naturopathic doctors recommend and that Canadians depend on.

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To fully understand the impact this bill has on naturopathic doctors you need to link the history, practice, and training of naturopathic doctors with the proposed language found in this bill.

Naturopathic doctors (NDs) are primary health-care providers with a minimum of seven years of post-secondary education in medical, naturopathic and clinical sciences. NDs are trained to diagnose, order labs, treat conditions, compound and recommend natural medicines, drugs and devices.

Naturopathic doctors are experts in natural medicine with extensive knowledge and training in the use of pharmaceutical and natural health products. NDs are regulated in many provinces and states in the same fashion that nurses, dentists and medical doctors are.

The demand for naturopathic doctors is growing by leaps and bounds. Canadians are searching for complementary health care to address not only a broader range of therapeutic choices but also to address our aging population and the lack of qualified health-care providers to meet those needs. Today, licensed naturopathic doctors across Canada are successfully delivering safe, ethical, and accountable health care to over three million patients a year.

There are several concerns regarding the impact that Bill C-51 will have on a naturopathic doctor's ability to treat patients:

1. Bill C-51 claims not to change the way natural health products are currently regulated. This appears to be true for some but not all natural substances. The bill introduces a new term called "prescription therapeutic products" to refer to any product, including a natural product that is not included under the current natural health product regulations and states that they will be accessible only by a "practitioner." Which products will become prescription therapeutic products is unclear and this concerns NDs. Of greater concern is that under this bill, prescription therapeutic products require a prescription from a "practitioner." Practitioner is defined as an individual who is authorized under the law of a province to prescribe or dispense prescription therapeutic products. Currently naturopathic doctors do not have prescribing authority and are not designated as a practitioner in Canada. The result is naturopathic doctors are excluded from access to those natural products that are or may be designated as a prescription therapeutic product. These are the same products that naturopathic physicians have been using safely and effectively to treat patients for over a century.

Here is a scenario as to how this could play out. St. John's Wort is a common natural health product that is used by naturopathic doctors in therapeutic dosages to treat mild to moderate depression. Under the bill, St. John's Wort could be designated as a prescription therapeutic product, thus requiring a prescription by a practitioner. A naturopathic doctor will not be able to prescribe it to a patient as they do not presently have prescribing rights and are not considered a practitioner. A medical doctor, dentist, veterinarian or podiatrist who is considered a practitioner, would be able to prescribe it; however, they are not trained in natural medicine and therapeutics. Why would such a practitioner choose to use this natural remedy for a patient? This scenario creates a situation whereby safe, natural and effective treatments might not be used as the practitioner would opt to use treatments they are more comfortable with such as riskier drug therapy. Bill C-51 restricts the naturopathic doctor's access to natural substances and this in turn restricts their patients and the public access to natural substances for their health-care needs.

2. Further Bill C-51 specifically adds cells, tissues, and organs to the list of therapeutic products. For over 100 years naturopathic doctors have prescribed both homeopathic remedies or standardized extracts of these substances such as adrenal gland extract in the treatment of certain conditions. This form of therapy is called organotherapy. This bill has the potential to exclude ND access to these products.

In choosing to see a naturopathic doctor, my patients have demonstrated their desire to take an active role in their health care through the use of natural therapies and natural health products. If naturopathic doctors are unable to access products in line with their training and appropriate for treatment, patients' health is compromised, which ironically is in part what the bill is supposed to prevent.

The only solution to this problem is to have the provincial ministries of health in coordination with the federal ministry of health deal with the issue of practitioner status and prescribing authority for NDs prior to the implementation of Bill C-51. The scope of practice of licensed naturopathic doctors must be revised to reflect their current training and education.

At minimum, begin by including naturopathic doctors in the definition of "practitioner" and allow NDs prescribing rights with access to prescription therapeutic products.

Unfortunately, Bill C-51 puts the cart ahead of the horse with the potential to radically alter and then destroy the practice of naturopathic medicine and subsequent access to natural products and devices that Canadians have come to depend on from their ND.

Lorne Swetlikoff is a licenced naturopathic physician in Nelson, B.C. He is the current president of the College of Naturopathic Physicians of British Columbia.

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