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Transforming and Supporting Patient Care - Health Professions ...

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263Chapter 11 – Profession of NaturopathyNDs are already safely <strong>and</strong> effectively using natural substances whenadministered parenterally (e.g., by injection, through intravenous,subcutaneous <strong>and</strong> intramuscular routes). They recognize that high dosesof nutrients <strong>and</strong> herbs should be administered only by an experiencedpractitioner, due to the possibility of toxicities <strong>and</strong> drug-herb interactions.The training that NDs receive, through their foundational clinical <strong>and</strong>didactic education <strong>and</strong> continuing education programs, indicates that NDshave the knowledge, skill <strong>and</strong> judgment to ensure they are competent tosafely administer these substances.There is also adequate foundational education to consider the requests fornew prescribing authority for a limited number of Schedule I drugs. Many ofthe drugs <strong>and</strong> conditions are similar to those proposed by pharmacists forminor ailments treatment protocols.The joint submission reiterates requests made in submissions to HPRAC inits 2005 review of the profession of naturopathy. Based on its initial work,including consultation <strong>and</strong> research, in its New Directions report to theMinister in April 2006, HPRAC recommended that NDs be authorized to“prescribe, dispense, sell <strong>and</strong>/or compound drugs that are consistent withnaturopathic practice, as prescribed in regulations”. 32At the time, HPRAC was advised that the federal Natural <strong>Health</strong> ProductsDirectorate (NPHD) <strong>and</strong> the Natural <strong>Health</strong> Product (NHP) regulations,which came into force in January 2004, excluded from the “natural healthproducts” regulation a number of products or substances that havetraditionally been safely prescribed, compounded or dispensed by NDsbut are considered to have additional risks of harm in over-the-counterdistribution. As a result, NHPD has created a separate schedule forbotanical medicines <strong>and</strong> natural health products that are of higher risk,<strong>and</strong> that should only be used under the advice <strong>and</strong> supervision of a healthprofessional who is trained <strong>and</strong> educated in their use. The profession iscontinuing to evolve <strong>and</strong> is showing that it is ready to receive thisprescribing authority.HPRAC also notes the proponents’ statements that the legislative evolutionof NDs scope of practice has not kept pace with advancing clinicalknowledge, increases in training <strong>and</strong> competencies, evolutions in otherjurisdictions <strong>and</strong> trends in consumer dem<strong>and</strong>s.What Leading Jurisdictions DoInformation from other jurisdictions provides evidence that NDs areequipped to prescribe within their scope of practice. Evidence fromjurisdictions such as Oregon <strong>and</strong> Arizona that currently authorizeprescribing for NDs indicates a high safety record. While prescribing rightsfor NDs are still limited to natural substances in many jurisdictions, someleading jurisdictions are moving to include Schedule I drugs in anaturopathic formulary. In British Columbia, for example, NDs are subject to32HPRAC. New Directions:183.HPRAC Critical Links January 2009

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