Volume 108 Number 2
AJHM Summer2015 59
Homeopathic Product Regulation
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Testimony of Karl Robinson, MD
Texas Society of Homeopathy
I would like to suggest that homeopathic medicines are
currently utilized in three ways and then segue into the
question of labeling.
Level One: People who know very little about home-
opathy use it in a very specific manner. They give, say,
Ar-
nica montana
for tissue trauma,
Symphytum
to speed bone
healing,
Belladonna
for any and all fevers or they buy a
homeopathic mixture containing a number of homeopathic
medicines all mixed together with a general label saying
“Allergy” or “Headache” or “Diarrhea” or “Fever” and on
and on. We sometimes call this type of prescribing
This
for That
.
Level Two: Acute prescribing. The person starts to
study homeopathy and, with the use of a book or two,
learns how to treat simple, self-limiting illnesses. They
use a single homeopathic medicine. Nancy Peplinsky of
Holistic Moms Network did that when she successfully
treated her children and avoided using antibiotics. Such
people become fascinated with homeopathy and prefer to
use single medicines rather than mixtures.
Level Three: Using a single homeopathic medicine
and taking into account not only the chief complaint but
a panoply of mental, emotional and physical factors, one
attempts to treat multiple problems all at once. This kind
of homeopathy is what Samuel Hahnemann, the founder,
expounded in his seminal work,
Organon of Medicine
. We
call this way of prescribing
classical homeopathy
. It is
what I and my colleagues from the American Institute of
Homeopathy, the North American Society of Homeopaths
and the naturopathic physicians practice. We attempt, with
varying degrees of success to halt, perhaps cure, a chronic
disease that can only be palliated or managed by conven-
tional pharmacological products.
We don’t do Level One homeopathy. We don’t use
mixtures and we don’t recommend our patients use them
either
but
we’re not against them. Level One is “gateway
homeopathy” and we hope more and more users will move
up into single medicine classical homeopathy. When one
uses mixtures one is using the “shotgun” approach hoping
one or more of the ingredients will give some relief. The
classical approach uses a “silver bullet” – one medicine
designed to bring about a radical transformation in the or-
ganism. Level One homeopathy is big and growing and is
mostly what this hearing is about.
Now, about labeling: In a typical proving done by
Hahnemann there were often more than 2,000 symptoms
recorded and these were recorded not in a word or two but
in complete sentences. Two centuries later some of these
same medicines now have many thousands of symptoms in
their pathogenesis. In the Repertory I use there are 16,800
symptoms attributable to homeopathic
Sulphur
. The idea
of compacting that kind of data into one or two or at most
three words to put on a label, well...frankly, it makes little
sense to me and it misleads the consumer.
I would propose the FDA consider removing labels indi-
cating usage from all single homeopathic medicines simply
because the present labeling system makes no sense. At the
same time, the FDA might consider more extensive label-
ing of OTC homeopathic mixtures even to the extent of a
package insert suggesting that this product is no substitute
for conventional medical treatment and must be used with
caution.
I shall briefly touch on two of the FDA’s queries.
Query 1
: What are consumer and health care provider at-
titudes towards products labeled homeopathic?
First, the attitudes of health care providers: Chiroprac-
tors, naturopaths, traditional Chinese Medical doctors and
other alternative health care givers widely support home-
opathy. As for medical doctors, some think homeopathy is
ineffective but more and more MDs are open to its playing
a role especially in chronic disease. My patients report to
me with greater and greater frequency that their physician
has said, Well I don’t know much about it but it’s helping
you, so keep doing it. Over the years, a number of medi-
cal doctors have come for treatment and sent their family
members.
As for the attitude of consumers toward homeopathic
products, it is clearly mostly positive judging by the surge
in sales of homeopathic medicines. People are voting with
their pocketbooks. The question is, Why?
Some answers:
1. Daily I hear patients say of their ailment, I’ve had this
for a long time. I’ve been taking the prescribed medi-
cine for months and still I’m not getting better. Now
I’m having side effects. Can homeopathy help?
2. Another says, I have been to one doctor after another,
one specialist after another. Nobody knows what’s
wrong with me. Do you think homeopathy can help?
3. Someone else, They tell me my condition is incurable,
that I’ll have to stay on this medicine for the rest of my
