Naturopathy and Homeopathy Act Amendments
Submission from the OAND
Prescribing, Selling, Dispensing and Compounding
Summary of Need for Change:
Access to this controlled act is necessary for naturopathic doctors (NDs) to be able to maintain their current
scope and to preserve access to required natural substances while federal classification of these
substances continues to undergo changes.
The change in Schedule L of Bill 171 deeming that Natural Health Products (NHPs) are not considered
drugs is insufficient because this only addresses that subset of natural substances (Natural Health
Products) intended for “Over The Counter” self-care selection by consumers. There are many natural
substances traditionally used in naturopathic medicine that do not fall within the definition or purview of the
Natural Health Products Regulations (such as higher dosages of folic acid) or are presently listed in
restricted schedules (i.e. Schedule F) or are combination products cross-listed as drugs.
Compounding, as well as dispensing and selling, are necessary in order to continue to provide the
individualized preparations that are integral to naturopathic care.
Access to this controlled act was recommended by HPRAC and is currently part of the scope of practice of
NDs in Ontario under the Drugless Practitioners Act (DPA).
NDs are prepared to work with the Transition Council to develop a schedule of natural substances
designated as drugs suitable for use by NDs.
Without this controlled act, NDs and their patients will lose access to natural substances that are currently
available, effectively limiting the ability of NDs to practice to their full scope and likely resulting in a loss of
care for patients.
4. (1) In the course of engaging in the practice of naturopathic medicine, a member is authorized,
subject to the terms, conditions and limitations imposed on his or her certificate of registration, to
perform the following: