Karlo Berger
Whole Health Solutions, LLC
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Home > Publications > Can We Heal the FDA?

Can We Heal the FDA?


The FDA “will classify every alternative practice as medicine so that only licensed physicians can carry out the procedure AND vitamins, minerals, herbs, etc., will suddenly become ‘untested drugs’ which will be forbidden…. Bad? Real Bad!”

So warned the first of many emails I was to receive last April concerning the FDA’s draft Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration, which drew a flood of complaints by its April 30th submission deadline.

But as I learned more*, it dawned on me that my freedom to practice holistic healthcare was not going to be taken away on April 30th. The FDA regulates the safety and labeling of drugs and dietary supplements. It has never regulated the practice of medicine or the off-label uses of drugs or dietary supplements—that is what states do.

It is time that CAM practitioners and their allies show more awareness and vision in how they approach the FDA, our bÍte noire. An October 2006 Harris Poll indicated that only 45 percent of Americans trust the FDA. The institution has lost its moral leadership and grown dysfunctional, and I believe it is up to the CAM community to help heal it.

CAM practitioners must first acknowledge the ways in which the FDA benefits public health, and the ways in which certain practitioners have not.

When we go the corner drugstore to buy a medication, we go with general confidence that: 1) the amount of active ingredients per capsule are what the label indicates, so we don’t unintentionally overdose; and 2) that the drug does not contain mercury, lead, or other unlisted additives that might poison us. We have this confidence thanks to the FDA. A century ago, in the days when alleged caregivers could advertise cures for blindness and diabetes to the desperate with impunity, and when the public was far more at risk from toxic additives, this confidence might have been misplaced.**

We need to acknowledge that, as allopathic medicine began to take over the healthcare industry in the beginning decades of the 20th century, not all the herbalists, naturopaths, homeopaths, and healers whom the FDA and other federal bodies ran out of business were angels. There are still charlatans among us (if you don’t believe me, I’ve got a case of “herbal tamiflu” to sell you!). The more that we CAM practitioners are willing to face the darker aspects of our professional histories, the better we will be able to exercise moral leadership in fundamentally reforming the FDA.

CAM practitioners need to join forces with public health activists who are working to rescue the FDA from the pharmaceutical industry.

The part of the FDA that reviews new drugs receives over half of its budget in “user fees” from the very pharmaceutical manufacturers it is supposed to regulate. This industry influence has lead to fast-tracking approval of expensive brand-name drugs, sometimes without adequate testing. Casualties of the FDA’s rush to market include those harmed from Vioxx and other medications whose dangers became apparent years (and billions of dollars in profits) later.

Undue influence by industry—whether it’s the pharmaceutical industry or the dietary supplement industry—is harmful to the FDA and to public’s health. CAM practitioners should link arms with progressive doctors and healthcare advocates and demand that the user fee system be scrapped, and that the FDA’s 18 advisory committees prohibit their members from working as consultants for drug or dietary supplement companies.

CAM practitioners need to re-envision a FDA that embraces diverse healing traditions while protecting the public from fraud and physical harm—and then vigorously work towards that vision.

Let us imagine a FDA that is free of corporate influence and has rededicated itself to the public’s health and well-being. A FDA whose advisors include not only MDs, PhDs, and PharmDs, but also talented naturopathic physicians, homeopaths, herbalists, and traditional healers (no regulation without representation!). A FDA that acknowledges that its research methodologies have a pharmaceutical bias, and that assuring the safety of herbal products and evaluating their health promises present new methodological challenges that require close collaboration with expert holistic practitioners to address. A FDA that is as dedicated as the best CAM practitioners are to routing out fraudulent or harmful healthcare products wherever they find them, with special citizen panels ultimately deciding whether these products should be restricted or even banned.

This is a FDA that the public could trust again. Good? Real Good!

*For a highly informative article on this debate, see John Weeks’s Integrator Blog.

** For more on how the FDA was formed, see www.fda.gov/oc/history/historyoffda/section1.html

Originally published in the Fall 2007 issue of the American Public Health Association's Alternative and Complementary Health Practices SPIG newsletter.

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