Monday, August 23, 2010

What VT NDs Apparently Didn't Know About Silver

What Vermont Naturopaths Apparently Didn’t Know Until I Told Them -
Silver Can Make You Look Like Me Or Paul Karason, The Blue Man Of Oprah Fame. We have argyria. I’m gray. Paul is blue.

What the naturopaths did not know is that silver, the natural element they think is a drug, is a heavy metal toxin which should never be taken internally or put in your eye. It can disfigure you by permanently discoloring your skin (argyria) and eyes (argyrosis). Silver has no known function in the body and does not prevent or cure any illness. It is snake oil! Doctors who learn scientific medicine in school rather than an archaic, pre-scientific, belief-based system like naturopathy have known this for over fifty years. If naturopaths had any knowledge of pharmacology or toxicology, they would have known it too.

This isn’t about one or two ignorant naturopaths, one or two bad apples. It is about a whole barrel full. How do I know that? Because naturopaths included silver in their Vermont Naturopathic Formulary, the list of drugs that they are permitted to use!

When I pointed out their mistake, they brushed me off! What does that tell you about their concern for patients?

Rosemary Jacobs

Denial Is A Naturopath In Vermont

Several years ago I used to see a bumper sticker on a car around town that read, Denial is not a river in Egypt. Not knowing what it meant, I asked the driver who explained that while in therapy trying to gain insight into how to deal effectively with her emotional problems she had learned that her habitual way of relating to the world, denying that everything bad or unpleasant existed, was counterproductive and the cause of her unhappiness and coping difficulties. Others who realized that they too were guilty of living with their heads buried deep in the sand understood that her sticker meant: denial exists; it isn’t a myth; when taken to an extreme, it debilitates those it infects who, in order to, in New Age lingo become “whole” and “balanced”, or in traditional terms, become emotionally stable, happy, well adjusted adults, have to change their pattern of behavior.

Can anyone tell me where to get a bumper sticker that reads, “Denial is a naturopath in Vermont”?

I get furious with people like Ken Adachi who publish erroneous statements about me. Ken, who has claimed that I am paid to say what I do about silver, something blatantly untrue, wrote that I am a poor woman from KY or WV who took silver for 35 years before turning gray when in fact I had never set foot in either of those states and only took silver for three years before developing argyria. By the time I was 35, I had been gray for 20 years!

Because of the way I feel about people making false statements about me as well as in the interest of fairness and because getting the facts right is very important to me, on August 13, 2010 I sent the following message to the New Hampshire Association of Naturopathic “Doctors”, NHAND,

I've posted several blogs dealing with NDs.

Please add comments correcting any errors you see and adding your views.

An automated response arrived immediately:

Thanks, Rosemary Jacobs!

We appreciate your taking the time to visit the NHAND website, and for contacting us.

Your message has just been sent; we'll do our best to get back to you at the email address you provided — — in a reasonable amount of time!



Also on August 13, 2010 I sent the following email to five of the 32 NDs listed on the Vermont Association of Naturopathic “Physicians” website,, choosing the five simply because their email addresses were easy to locate.

Subject: Dangers of Naturopathy

I cannot begin to tell you how utterly horrified I was to discover that silver is included in the Vermont ND formulary. Neither can I put into words the disgust I felt when the complaint I sent to the licensing board was forwarded to the naturopathic advisor and brushed off.

Doctors who practice scientific medicine learned the uselessness and danger of ingesting silver and putting "colloidal silver" in the eyes well over 50 years ago. Silver causes argyria, gray skin. I have had a general case since I was about 15. I am now 68.

After alerting the licensing board to my concerns and being brushed off, I started reviewing ND websites and have posted several blogs reporting what I found and my opinions about it. You will find them here:

If you find factual errors, I would appreciate it if you point them out in the comments section along with any views you have opposing mine and I certainly hope that you REMOVE SILVER from your formulary NOW and have both a toxicologist and pharmacologist review the other substances you include to make sure they will at the very least not harm anyone.

Please forward this to any of your colleagues whom you believe may be interested in it.


(There was another ND listed on the Vermont association’s site who I had linked to who I very much wanted to send the same message to but gave up when I couldn’t locate her email address, not even on her own website.)

On August 15th, I sent the following to a California ND site that I had linked to:

I recently discovered that NDs in my state, Vermont, include silver in their formulary. Having had argyria for over 50 years and a webpage warning people about the uselessness and danger of ingesting silver for over 10, I was absolutely horrified, but even more horrified when my concerns were brushed off. I started looking at material on the Internet posted by and about NDs and have started a blog on which I have posted several articles on the topic. One includes a link to your site.

I would appreciate it if you looked at my material and in the comment section note any factual errors as well as opinions disagreeing with mine.

Also on the 15th, I sent this to an Oregon ND quoted in a newspaper article that I linked to:

I recently discovered that NDs in my state, Vermont, include silver in their formulary. Having had argyria for over 50 years and a webpage warning people about the uselessness and danger of ingesting silver for over 10, I was absolutely horrified, but even more horrified when my concerns were brushed off. I started looking at material on the Internet posted by and about NDs and have started a blog on which I have posted several articles on the topic. One includes a link to an article in the Oregonian that quotes you.

I would appreciate it if you looked at my material and in the comment section note any factual errors as well as opinions disagreeing with mine.

To date I have received two auto-replies telling me that the “doctor” was out of the office. One from a Vermonter sent August 17th read:

Dr. Pretty Plant (not her real name) will be away from the office from August 5 thru August 16. She will return on Tuesday, August 17. Our office assistant, Moldy, (pseudonym) will be available Monday, Tuesday and Wednesday mornings to schedule appointments, fill supplement orders, and answer any general questions you may have.

Fill supplement orders? Does that mean Pretty Plant sells supplements to the patients she sees, a common alt med practice which I think should be illegal? I mean it doesn’t take a rocket scientist to see the conflict of interest there, to figure out that a greedy practitioner, and there are greedy practitioners in every profession, will be very tempted to tell patients they need products which he very well knows they don’t just to increase his own bottom line. But since Pretty Plant has not responded to my message I have to assume that she has no intention of talking to me so that there is no way to ask her what she pitches and sells to her patients. Neither is there a way to discover if she feels that she has to choose between being an alternative pharmacist (really a herbalist) and an alternative “physician” or if she believes that she is trained and at liberty to practice both alt pharmacy and alt med simultaneously in Vermont.

Of all the emails I sent, one real person, a Vermont ND, did respond. She wrote:

Please remove me from your email list. Thank you.

She signed her one liner with the honorific “Doctor” in front of her name.

I responded:

I don't have an email list. You can bury your head in the sand but the real world won't go away. I have no intention of contacting you again, but will be more than happy to speak with you if you ever contact me.

Since I haven’t heard back, I assume that her head is still covered with a pile of sand or some other natural product.

While there may be a law permitting this ND to use the title “doctor” in Vermont, there is no law saying that anyone else has to address her that way, and I most certainly won’t. As far as I can tell, the only titles that she deserves are “Natural Denialist” and “Naturally Deluded”.

How can anyone practice as a doctor who cannot deal with the harsh realities of life? How many things are worse than serious disease, especially the terminal kind? How can anyone go into medicine if he can’t face people like me, people upset and frightened by the drugs and therapies he uses and who fear that he lacks the knowledge, training and skill to safely treat patients?

Years ago I met a lady who was so terrified of breast cancer that she ignored a lump in her breast till it ate through her skin creating a repulsive looking open sore. She is not the only person who has denied and refused to deal with such an frightening reality who this has happened to. The German artist Michaela Jakubczyk-Eckert’s fear of breast cancer drove her directly into the hands of a quack who convinced her not to undergo evidence-based treatments for her disease. As a result she died a very painful death at the age of 41. There is a photo of her cancer disfigured breast here:

As I told Natural Denialist, "You can put your head in the sand but the real world won't go away."

If a woman with a small breast lump that is invisible to the eye and only detectable by touch, as my malignant tumor was when I discovered it, visits Natural Denialist, is she going to call the growth a harmless, little natural lump and suggest that the patient take some botanicals, exercise, eat lots of fruit and vegetables, hopefully organic, and maybe throw in a relaxing massage, or is she going to have the lump biopsied immediately to see if it is malignant? For the patient’s sake, I certainly hope it is the latter, but I have to wonder if someone emotionally unable to talk to me, an angry upset stranger, about the dangers of the belief-based medical system she practices, is emotionally able to have an honest discussion with a patient about breast cancer and the possibility that she may have it. While I’m sure that there are some MDs like people everywhere who do their best to avoid all of life’s unpleasantries, I suspect that they are few and far between simply because not many could survive the hospital residency programs which are an integral part of an MD’s medical training but not a part of an ND’s. In a hospital residency an MD is forced to face the unpleasant reality of serious illness and death on a daily basis and is trained to deal rationally with it. Burying his head in the sand isn’t an option, and there are lots of malpractice lawyers breathing down his back ready to pounce if he does slip up and ignore or miss something that he should see and deal with realistically.

Thursday, August 12, 2010

Naturopaths Using Heavy Duty Pharmaceuticals

I know little about pharmacy and am not about to investigate it trying to re-invent the wheel when there are so many people already expert in the field, although I’d be amazed if any of them are NDs (naturopaths). Hopefully, real scientists will notice what naturopaths are up to and report what they discover to the public be it good, bad or neutral.

With my limited knowledge it looks bad, very, very bad. Looking at the NH Naturopathic Formulary which lists things like: insulin - synthetic and human; erythromycins; dosycycline; tetracycline; vancomycin; ephedrine; epinephrine, including auto-inject forms; yohimbine; nicotine; heparin; lovastatin; benzodiazepines; lithium; hydrocortisone; tamoxifen; estrogen; progesterone; testosterone; growth hormone; oxygen; a long list of vaccinations; under botanicals - cocaine, codeine, morphine and opiates are excluded while needles, syringes and IV tubing are included under periphenalia, I get the impression that NDs have, for quite some time, been using heavy duty pharmaceuticals, prescription medications, derived from both natural animal and vegetable sources, drugs like insulin and penicillin, drugs made from isolated active ingredients which scientists have identified, extracted or synthesized and standardized into pill and liquid forms - well studied drugs which have been dispensed by pharmacists and prescribed by MDs for decades. I suspect that NDs have been using these real drugs everywhere where they have formularies that permit them to use drugs “derived from natural products” even when those formularies don’t spell out the drugs as NH’s does. I also suspect that NDs who claim that they use “science-based natural treatments” do so because they believe that using real drugs derived from natural sources, the FDA approved kind, makes their practices "science-based" even when they don't understand what science is. If they did they wouldn't study and practice Classical Homeopathy or include silver in their formulary.

I also get the feeling that today at least some NDs are learning what our ancestors learned a few generations ago, which is that many synthetic drugs are far superior to the natural kind. This would explain why naturopaths who identify themselves as practitioners of "natural medicine", have been slipping synthetic drugs into their formularies. Apparently experience has been leading some of them to conclude that many if not most synthetic, or man made drugs, work better and are safer and cheaper than the natural stuff NDs have used traditionally.

Sounds like they are re-inventing the wheel to me. Those who practice scientific or evidence-based medicine and those of us who have studied history learned long ago why herbal concoctions or “remedies” were replaced by standardized pharmaceuticals, often synthetic, starting around 100 years ago. Where have the NDs been all that time? Ironing their white coats? Out picking weeds?

From looking at promotional material produced by NDs that is posted on the Internet, including their personal websites, I get the feeling that there is a split taking place in their ranks with some favoring keeping to their original path as natural healers and others trying to become MDs by slipping in the back door undetected without ever earning their place in the clinic or hospital.

I respect those who practice their belief-based system of medicine even though I don’t believe it offers health benefits and know it can harm people, like those who use silver internally and in their eyes, but I consider the others very dangerous. The others being those who believe or try to make others believe that they practice scientific medicine and who use pharmaceutical drugs when they lack the knowledge and understanding of science and evidence-based medicine to do so. I believe that NDs who really believe that their education has trained them to work as MDs or that they practice scientific medicine are naturally deluded.

Lacking the time and resources to investigate the old-fashioned way by interviewing NDs, I will do it the new-fashioned way by posting my views and asking those I’ve linked to to review them, correct factual errors and make comments if they care to.

Naturopathic Doctors, NDs or Naturally Deluded?

Whenever I encounter an ND who calls or considers himself a doctor, physician, general practitioner or scientist rather than a faith or natural healer, I think of him as naturally deluded. How else can one explain how, despite all the objective, scientific evidence to the contrary, Vermont NDs include silver in their formulary? How else can one explain why, despite all the evidence to the contrary, they believe that the doctorate degrees their institutions award them accurately portray who they are and qualify them to practice scientific medicine?

Having been permanently disfigured by an ignorant, though not deluded, MD over fifty years ago, it scares the hell out of me to see that NDs, most of whom probably weren’t even alive then, are still wallowing in the same ignorance that he did. For me it’s very personal.

But naturopaths’ use and promotion of silver isn’t the only reason that I think that NDs are deluded in their belief that they are qualified to work as doctors, physicians and general practitioners or that they understand scientific or evidence-based medicine as many claim in the reams of promotional material they publish. At least two MDs who have investigated the matter agree wholeheartedly.

Another MD who looked at their VT formulary told me that he had no idea where they got it from because it isn’t grounded in pharmacology or toxicology as they are currently understood. I know at least one layperson who shares these views and fears, a lady who corresponded with me a few years ago who calls them naturopathetics.

Yes. I know name-calling isn’t nice, but on a moral scale it is a whole lot better than believing that you practice scientific medicine when you are so ignorant of the subject that you include in your formulary a heavy metal toxin like silver which, if taken internally or in your eyes, offers no benefits whatsoever but can permanently disfigure you.

Although NDs are required to study scientific disciplines like biochemistry and pharmacology in their four year naturopathic colleges, either: they are taught alternative biochemistry and alternative pharmacology, as in the alternative to or opposite of scientific biochemistry and pharmacology; they don’t understand what they are taught; or, they simply don’t believe in science and objective evidence other than when it supports their natural healing belief-based philosophy. Their religion. Otherwise how could they include in their studies and practice the archaic belief-based medical system of Classical Homeopathy,, that maintains that well shaken water and sugar pills have miraculous healing properties? Scientifically speaking that is sheer and utter nonsense that doesn’t have a shred of objective evidence to substantiate it unless you think that testimonials about famous people using it, like the lady with the funny hats, count as scientific evidence.

My guess is that Her Majesty, Queen Elizabeth, uses homeopathic “remedies” because she simply hates to abandon her ancient family traditions like silly hats, a throne, a crown, a luxurious lifestyle and the little black box of homeo “remedies” said to accompany her on her travels, which probably contains the exact same “remedies” that her ancestors took with them before the advent of scientific medicine as they traveled about by horse-drawn coaches. And again, my assessment of the scientific merits of homeopathy is shared by the vast majority of scientists and medical doctors.

(Please don’t make the erroneous assumption that all homeo “remedies” are benign, harmless or devoid of active ingredients because they are not. Like all unscientific systems of medicine, homeopathy and its “remedies” aren’t well regulated or standardized and the philosophies of belief-based medical systems can mutate quickly. People have been injured by products labeled “homeopathic” such as the “cold remedy” which really did contain zinc that caused anosmia, loss of smell. See p. 26:

Also homeopathy is highly individualized and not every homeopath follows the principles of Classical Homeopathy.)

NDs also study “botanical medicine” which for many certainly seems to mean herbalism,, a healing system built on the belief that many plants have medicinal properties which our ancestors discovered over the centuries by trial and error. Herbalists, unlike scientists, believe that those properties are contained in the entire plant or an entire part of a plant like the leaf or flower and make their remedies, often tinctures, using them as the raw ingredients. They think that all the ingredients in the plant work together in “synergy”, and unlike scientists, they believe that there is no need to challenge their beliefs regarding safety and efficacy by conducting controlled scientific studies to determine if the objective evidence supports their opinions.

While many plants do have medicinal properties as well as toxic properties, plants are kind of like soup, full of many different ingredients or chemicals which can vary widely depending on many things.

That is why pharmacognosists, who are scientists specializing in pharmacy, work to identify and isolate active ingredients found in natural products, not just plants. When they succeed, they extract those chemicals and use them as drugs or synthesize them in labs, producing medicines that are standardized for purity and potency, things very important to scientists and MDs who are fanatical about making sure that the medicines they use consistently provide the correct dose and who are also fanatically about only using drugs that have been adequately and objectively studied before they use them on patients to make sure that they offer benefits, the amount that offers those benefits, the amount that is toxic to the average person, the side effects they produce, and the interactions they have with other drugs, food and now supplements.

Since “dietary supplements”, many of which are herbs, have become so popular, scientists have started to study some of them too, but as yet they haven’t come up with any scientific evidence that would make me take a “medicinal herb” or “botanical remedy”.

NDs also study and use Chinese medicine, another medical system not based on science that uses "remedies" that are often harmful.

If it wasn’t all so very dangerous, it would be funny - grownups dressing up and playing doctor like children do and a former president of a naturopathic college alleged to be “one of the world's leading authorities on science-based natural/integrative medicine” claiming that the cure for the common cold has been found.

Joseph Pizzorno, who was the president of Bastyr naturopathic school at the time, was quoted as saying on p. 114 of the 1998 April issue of Good Housekeeping magazine that, “There really is a cure for the common cold, and it’s echinacea. I take it when I feel a cold coming on, and I virtually never get sick.” Yea. Sure Joe. Scientific studies didn’t support your claim then and they don’t support it now, twelve years later. Look at what NCCAM, National Center for Complementary & Alternative Medicine says under the heading “What the Science Says". "Study results are mixed on whether echinacea can prevent or effectively treat upper respiratory tract infections such as the common cold.” Scientifically speaking that means the evidence isn’t in yet, Joe. Not that we’ve found The Cure even if you take it when you feel a cold coming on and don't get sick.

But wait that isn’t all. NCCAM also states, “Side Effects and Cautions: When taken by mouth, echinacea usually does not cause side effects. However, some people experience allergic reactions, including rashes, increased asthma, and anaphylaxis (a life-threatening allergic reaction). In clinical trials, gastrointestinal side effects were most common.”

Anaphylaxis! Wow. That kills you very quickly unless you have some epinephrine on hand to inject immediately. If you have ever heard of someone allergic to bees or peanuts who died suddenly after being exposed to them, they died of anaphylactic shock. That’s a hefty price to pay to cure a cold or worse yet hoping to cure a cold. Of course, it is my guess that there are very few people who would have such a serious allergic reaction to echinacea, but how many would want to risk dying over a cold? My guess is that most of those practicing scientific medicine would think that the hoped for benefit does not outweigh the risk just the way that they think that the lack of benefits derived from ingesting silver do not outweigh the risk of being permanently discolored by it and that it is a waste of money to use any product as a drug, even one known to be safe, unless there are many solid, objective, studies, the results of which have been consistently reproduced, showing that it offers benefits outweighing the risks its use entails. But that line of thought is alien to those practicing belief-based systems of medicine. But then they do not choose their drugs on the basis of objective, scientific evidence showing benefits and risks. They choose them based on their philosophies of healing.

Monday, August 2, 2010

Naturopaths & Silver

A student of mine who taught English in Japan liked to tell the story of how when he first arrived there and applied for jobs teaching English, he met several people who had studied English for years and spoke it with each other, only he, an American, had no idea what they were talking about. Seems their “English” had been passed down by teachers who weren’t native speakers and who had had little or no contact with native speakers.

Naturopaths (NDs) think of themselves as physicians and doctors as do several US states as well as a few governments in other countries. According to the website of the American Association of Naturopathic Physicians, “Currently, 15 states, the District of Columbia, and the United States territories of Puerto Rico and the United States Virgin Islands have licensing laws for naturopathic doctors.” My state, Vermont, is one of them. In licensing NDs as physicians it grants them the legal right to call themselves doctors, practice “medicine”, treat patients and sometimes get reimbursed by insurance.

According to the website posted by a San Francisco naturopathic clinic,,: NDs are educated as general practitioners who specialize in natural medicine and focus on prevention and treatment of disease, and use a variety of treatment modalities such as nutrition, herbal medicine, homeopathy, and lifestyle counseling to restore and maintain good health. NDs can perform complete physical examinations including women's health exams and can order laboratory tests and diagnostic imaging.

Many NDs also try to make the point visually that they are doctors or practitioners of scientific or evidence-based medicine by decking themselves out in white coats, scrubs and stethoscopes, the traditional symbols of MDs, which they are not, even though visually the letters ND look very similar to MD. At least one Vermont ND prominently displays a caduceus, in her ads,, you know, “…two serpents criss-crossed around a staff topped by a round knob and flanked by wings” which “has been the symbol of the American medical profession for nearly a hundred years…”

Many NDs also think of themselves as scientists and advertise themselves as such claiming that they use “science-based natural treatments”.

But like my student who didn’t recognize the English spoken by the Japanese, the vast majority of scientists and doctors who have spent many years studying scientific or evidence-based medicine don’t recognize ND’s treatments as being the least bit scientific or evidence-based and they don't recognize naturopaths as colleagues who practice scientific or evidence-based medicine. In their opinions and mine, NDs practice an antiquated, pre-scientific, belief-based type of medicine built on the philosophy that “Natural is good” and that “natural” things naturally benefit us. That philosophy is the only rational explanation I can think of for why silver, a naturally occurring element, is included in the 2009 Vermont Naturopathic Formulary, the list of substances NDs can use as drugs: Physician Formulary 20091211.pdf

On page 1 it reads: Antibacterial Agents: Topical And Ophthalmic Antibacteials: Silver Sulfadiazine Cream, Mupirocin, Neomycin, Chlorhexidine, Clioquinol, Colloidal Silver Preparations

On page 5: Minerals, their derivatives and compounds (May be administered IV): Manganese, Molybdenum, Nickel, Potassium, Selenium, Silicon, Silver, Tin, Fanadium, Trace Mineral compounds, Zinc.

If NDs knew anything about pharmacology or toxicology, neither colloidal silver nor silver ever would have made their list. If they knew how to review the medical literature and had done so, like I, who am neither a physician nor a scientist have done, they would know that colloidal silver is snake oil and that ingesting it is all risk and no benefit. They would know that: silver was used before the advent of antibiotics; it didn’t work; it discolored many people. The well known, well documented skin condition is called argyria. I have had argyria for over fifty years and have had a webpage warning of the danger and uselessness of ingesting silver for more than ten.

If NDs had searched the medical literature as I have done, and as my FAQ tells others how to do,, they would have found the warnings in the medical journals going back to at least 1919 alerting doctors and pharmacists to the fraudulent ads published by companies selling silver drugs in an era when the pharmaceutical industry was not regulated.

If they had used Google to search the Internet, NDs would have seen the warnings about the danger and uselessness of ingesting silver issued by the FDA, the National Center for Complementary and Alternative Medicine (NCCAM), many doctors, scientists and concerned human beings. Here are just a few:

If NDs had read those warnings, they would have learned that silver has no known function in the human body, there is absolutely no reason to ingest it and it can permanently turn your skin gray, blue or even a metallic black.

If NDs had glanced at the news once in awhile, they would have caught at least one of the numerous media reports on The Blue Man, Paul Karason, who was even on Oprah or Stan Jones, the wacky Montana Libertarian, who is always running for office and always losing. Likewise they would have found both Paul, Stan and maybe me if they had googled “colloidal silver”. They certainly would have found all of us if they had googled “argyria”, but if they hadn’t reviewed the med. lit. they never would have learned the term “argyria” to google in the first place since it doesn't seem to have come up in any of the classes they took at naturopathic school.

Either NDs: don’t believe in scientific medicine; don’t believe in reviewing the medical literature, something all MDs and scientists are taught to do in their schools in order to learn what is known, unknown and suspected about the drugs they use or want to use; or else NDs simply have never learned how to review the med. lit. the way that real doctors and scientists have.

But what is their excuse for not seeing the NCCAM alerts? Since they call themselves “alternative medical doctors”, wouldn’t you think that they would have someone following and passing on all the information put out by NCCAM, the government agency setup specifically to study “alternative” and “complementary” medicine?

THEIR DEGREE OF IGNORANCE IS TRULY TERRIFYING. At least to me, a woman who was facially disfigured by an ignorant MD over 50 years ago, one who like the NDs of today, never read medical journals or verified the claims in the ads he read.

But it gets worse. At least I think it does. I’m not a lawyer. I could be wrong. However, looking at the rules governing the VT ND formulary, my guess is that the naturopaths are violating them since section 3.2 states that their formulary may not include substances “prohibited by other Vermont or federal law.” If my interpretation is correct, they are either ignoring or ignorant of the rule the FDA posted in the FR (Federal Register) stating that: “…all over-the-counter (OTC) drug products containing colloidal silver ingredients or silver salts for internal or external use are not generally recognized as safe and effective and are misbranded.” [Federal Register/Vol. 64, No. 158/Tuesday, Aug. 17, 1999/Rules & Regulations, p. 44653-44658]

What other explanation is there besides ignorance of the FDA rule that would explain the listing of “colloidal silver preparations” and “silver” in the formulary and in section 15 c of this same rules document which states that NDs can use “Topical antibiotics - Silver sulfadiazine cream, colloidal silver preparations”? Silver sulfadiazine is an FDA approved topical drug. So there is no problem with violating the rule there, but there are no FDA approved “colloidal silver preparations” and there is a specific rule stating that colloidal silver preparations are “misbranded” which is FDA-speak for saying that drug claims cannot legally be made for them.

When I learned that the NDs in my state included silver in their formulary, I contacted their licensing board at the Secretary of State’s office about my concerns. They forwarded them to the naturopathic advisor who, in my opinion, simply brushed them off completely failing to understand how disturbed I am and how frightened I am about the danger he and his colleagues are subjecting their patients to. THE THING THAT FRIGHTENS ME FAR MORE THAN THE INCLUSION OF SILVER IN THE ND FORMULARY IS THE ASTOUNDING DEGREE OF IGNORANCE AND LACK OF CONCERN ON THE PART OF PEOPLE LICENSED TO TREAT PATIENTS AND PERMITTED TO CALL THEMSELVES DOCTORS WHICH THEY HAVE DEMONSTRATED BY THEIR INCLUSION OF SILVER IN THEIR FORMULARY. I also worry about the other substances listed in the formulary which sound bizarre to me, but which I presently lack the expertise to evaluate.

The correspondence in question follows. Judge for yourself whether or not my views are correct and my fears well founded.

From: Rosemary Jacobs

Subject: VT Naturopathic Formulary

Date: May 24, 2010 2:21:17 PM EDT

To: Terry Gray

Dear Mr. Gray, I have questions about the Vermont Naturopathic formulary: Physician Formulary 20091211.pdf

My questions specifically relate to the following excerpts:


“Use of medications included in the following formulary is limited to FDA approved indications, routes and dose regimens. However, ‘off-label’ indications, routes and dose regimens may be prescribed for patients and conditions the naturopathic physician is competent to treat based on that physician’s training and experience. ‘Off-label- shall conform to the generally acceptable standards of practice, including safety and efficacy, for both allopathic and naturopathic practitioners. See, generally, Food and Drug Admin., Guidance for Institutional Review Boards and Clinical Investigators 1988 Update: ‘Off-Label” and Investigational Use of Marketed Drugs, Biologics and Medical Devices,


p. 1

Antibacterial Agents: Topical And Ophthalmic Antibacteials: Silver Sulfadiazine Cream, Mupirocin, Neomycin, Chlorhexidine, Clioquinol, Colloidal Silver Preparations


p. 5

Minerals, their derivatives and compounds (May be administered IV): Manganese, Molybdenum, Nickel, Potassium, Selenium, Silicon, Silver, Tin, Fanadium, Trace Mineral compounds, Zinc.


Questions: How can NDs use “colloidal silver preparations” as topical or ophthalmic antibacterials and how can they administer silver IV when:

· The FDA issued a rule in the Federal Register stating, “…that all over-the-counter (OTC) drug products containing colloidal silver ingredients or silver salts for internal or external use are not generally recognized as safe and effective and are misbranded.” [Federal Register/Vol. 64, No. 158/Tuesday, Aug. 17, 1999/Rules & Regulations, p. 44653-44658]

· The FDA’s Pharmacy Compounding Advisory Committee (5/7/99) advised against including Mild Silver Protein (MSP), a type of colloidal silver, on the list of bulk substances that pharmacists are permitted to manufacture. Compounding pharmacists had wanted to be able to compound MSP specifically for ophthalmic use.

· The NCCAM (National Center for Complementary and Alternative Medicine) has warned consumers about silver supplements.

· Many others including doctors and scientists have issued similar warnings. Here are 3.;;

A review of the links I am providing shows that silver is dangerous. It can discolor a person’s skin (argyria) and eyes (argyrosis). It is also useless when taken internally. Argyria is well known and well documented in the scientific medical literature. There was even a book written about it in 1939 called Argyria. I have had argyria for over fifty years. When I first learned that silver, often called “colloidal silver” or “CS”, was being sold as a dietary supplement, I predicted that new cases would soon appear. Salesmen said I didn’t know what I was talking about. Unfortunately, they were wrong. There are now many cases of argyria caused by silver supplements of which Paul Karason’s case is the best known. You will find other cases if you search PubMed, using the term “argyria” or “colloidal silver”. I have had a webpage posted for about 10 years warning the public about the danger and uselessness of ingesting silver. I presented oral and written testimony to the FDA advisory committee cited above.

In light of this how can any health care provider use silver on patients? How can anyone administer silver IV? How can it be included in a legally recognized formulary? I do not have the expertise to evaluate the other items in the Vermont ND formulary but suggest that you ask a medical scientist like a pharmacologist or toxicologist to do so because I find the idea of naturopath's using silver, especially IV, terrifying. It shows a complete and utter lack of knowledge of the basics of the pharmacology and toxicology of silver as well as of the FDA’s rulings about it, things which I think anyone using a substance to treat patients with should know backwards and forwards before even considering its use and because the idea of deliberately putting things like tin into the human body sounds to me as if it could be as bad or worse than doing that with silver. Thank you.

[address & phone #]


From: Terry Gray

Subject: FW: VT Naturopathic Formulary

Date: May 27, 2010 7:27:27 AM EDT

To: Rosemary Jacobs

Rosemary: I have forwarded your email to our Naturopathic Advisor for their input. Below is their response. I will keep your information for review of the Advisors. Thank you. Terry

Sent: Wednesday, May 26, 2010 5:10 PM

To: Terry Gray

Subject: Re: VT Naturopathic Formulary

Terry, This is interesting. Antibiotics are not allowed to be administered IV which includes colloidal silver. In the minerals section it says "may be administered IV". The list of minerals is an example of minerals that are prescribed, some but may used IV. Silver is not intended to be administered IV. Other minerals are meant to be administered IV. There are no NDs in the state that I know of administering silver IV. Silver is generally used in medicine as a topical antimicrobial in other forms than the colloidal form and we will consider updating the language of the formulary to reflect this. None the less, you should probably respond thanking her for her comments which we will take into consideration as we annually update the formulary which is done with the opportunity for review of professionals from other professions.


From: Rosemary Jacobs

Subject: Re: VT Naturopathic Formulary

Date: May 27, 2010 9:50:26 AM EDT

To: Terry Gray

On May 27, 2010, at 7:27 AM, Terry Gray wrote:

I have forwarded your email to our Naturopathic Advisor for their input. Below is their response. I will keep your information for review of the Advisors. Thank you.

Terry, thank you for getting back to me. If I understand correctly, the VT Health Commissioner who is an MD has oversight of the ND formulary. Please forward my emails and the advisor's responses to her. There is a very serious problem here that she may not be aware of.

Sent: Wednesday, May 26, 2010 5:10 PM

To: Terry Gray Subject:

Re: VT Naturopathic Formulary

This is interesting.

It may be interesting to Sam. To me it is terrifying - terrifying that NDs have included silver in their formulary and terrifying that the information I sent appears to have been previously unknown to them.

Antibiotics are not allowed to be administered IV which includes colloidal silver.

Sam seems to have misunderstood me. "Minerals" are permitted to be administered IV (p.5 of the formulary) and I assume that they can be given orally too and, the formulary specifically lists "silver" as one of the minerals that can be given this way. This in spite of the fact that silver has no known function in the body, offers no benefits when taken internally and is dangerous when taken internally.

The formulary, p. 1, also permits the topical and ophthalmic use of "colloidal silver preparations" even though the FDA forbids both uses and that putting any form of silver in the eye can permanently discolor it.

In the minerals section it says "may be administered IV".

"May be administered IV" means that it is legally permissible for NDs to administer it IV. Why would it be legally permissible, especially for people seeing patients, to put a substance into a human being when that substance is known to be dangerous and has no known physical function? Why would NDs want that legal right to do that? This is what truly terrifies me.

The list of minerals is an example of minerals that are prescribed, some but may used IV.

Does that mean that NDs can prescribe other minerals not specifically named in the formulary?

Silver is not intended to be administered IV.

Then why on earth does the formulary permit it to be used that way? Why would NDs even consider including it in their formulary when it is dangerous and useless? I suspect it is because they didn't know any of that until they got my email. Once more. That is what is terrifying. What else are they using that is useless and dangerous? And do they administer silver orally or tell patients to take it orally? I assume that including it by name in the mineral section of the formulary (p.5) that they do, but if not, they have obtained the legal right to do so by listing it in their formulary. Do they sell silver supplements to the patients they see? Do any of them manufacture silver supplements?

Other minerals are meant to be administered IV. There are no NDs in the state that I know of administering silver IV.

Thank God he doesn't know of any, but that doesn't mean that there aren't any. Furthermore, right now any of them who wanted to could. And again are there NDs selling, giving or advising people to take silver internally such as by mouth?

I don't think Sam realizes the degree of my concern. Unless the NDs can present solid scientific evidence demonstrating that the FDA and scientific community are wrong about the danger and uselessness of taking silver internally and putting it in the eye, it should be removed immediately from the formulary. Including it there puts people at risk and exhibits an utter lack of knowledge that NDs have about the safety and efficacy of the substances they use to treat patients with.

Again, please ask a medical scientist to review the formulary to see if there are other dangerous products on it besides silver and please forward this correspondence to the Health Commissioner who may have overlooked silver and other dangerous or useless products.

Terry, I am not a crank. I am a woman who has been facially disfigured for over fifty years ago by snake oil that NDs in my state are legally allowed to use on human beings in spite of the overwhelming scientific evidence demonstrating that ingesting silver is at best useless and at worst harmful! I can't put into words how much this terrifies me. I am also very concerned about the other products NDs in their ignorance my be using on people and intend to do all that I can to alert the public to the problem. I will also gladly meet with and discuss this issue with anyone who is interested.

I was a trustee, water and sewer commissioner for the little village of Derby Center for 7 years serving 3 terms and refusing to run for a fourth. (Agreeing to run when everyone else was smart enough to refuse is one of the dumbest things I've ever done, but if you check with the village, I am sure they will tell you that I am not a crank and that my concerns about silver are very real and both rational and reasonable.)

Thank you so much for your help to date. I really appreciate it.