Dr. Gloria Dodd-A Case Study in the Failure of Government Regulation of Veterinary Medicine

I have written at length about the relationship between unproven, unscientific, and pseudoscientific alternative medicine and the legal and regulatory systems intended to protect the public from quackery (including Medical Licensure, Malpractice Law, and Regulation of Drugs, Supplements, and Homeopathy). In researching these issues, I discovered how little importance scientific validity has as a criterion for establishing and judging the legality of medical practices. Politicians, lawyers, and judges are more concerned with the issues of their own domains, including what the public wants, the tension between the public good and the rights of the individual, the right of individuals to earn a living, and others. These are all legitimate issue, but the debates and legal decisions related to alternative medicine often seem backwards to me. If a therapeutic approach is clearly ineffective or dangerous then it makes no sense to protect it as a “choice” or a “right.” And if the claims a provider makes about their therapies are manifestly untrue by objective scientific standards, then how can they have a “right” to lie to people, even unknowingly? How is prohibiting people from selling false hope and ineffective therapies to the sick or dying an inappropriate government interference with individual rights?

In any case, past attempts of government to regulate medical practices have certainly had some beneficial effects. Though most “healthcare choice” and alternative medicine advocates ignore or don’t recognize it, there is ample evidence (and here) that in the freewheeling days before the Food and Drug Administration and state medical licensure quacks of innumerable varieties sold useless or outright harmful nostrums and procedures that hurt or killed people. Unfortunately, there is also clear evidence that these efforts have been far less successful than we might hope, and quackery continues to thrive.

A case example in the veterinary field is Dr. Gloria Dodd. According to her web site, Dr. Dodd graduated from the University of California at Davis School of Veterinary Medicine in 1960. She is a bit of a celebrity and well-regarded in the alternative veterinary medicine community. She is an author and speaker and is involved in the American Holistic Veterinary Medical Association and other CAVM organizations. Her state veterinary license is current, though she states that she is retired, and she has a consulting business and an internet-based store for selling a variety of healthcare products, Everglo Natural Veterinary Services.

Dr. Dodd is a proponent of truly alternative medicine. Apart from a few emergency measures, such as intravenous fluids, fracture repair, blood transfusions and so on, she universally condemns conventional medical treatments as “toxic” and “traumatic and foreign to the body.”  Her overall philosophy of healthcare is classic vitalism, which views illness in the physical body as a secondary symptom of primary abnormalities in the spirit of “Life Force” of the patient, most of which are due to unnatural human activities. Here is a selection of descriptions of her theoretical approach from her web site.

3000 years of oriental medicine has proven there is a Life Force energy (Chi) that flows like the arborization of a tree throughout the entire body, touching every cell of every organ of every system in the body…Health is maintained by a balance of two opposing energy flows, Yin and Yang, which make up this Life Force. Each cell of each organ of each system has both Yin and Yang energy flows. Any imbalance, either deficiency or excess of these energies produce aberrations that filter down into the physical body and produce what we see as “symptoms”. Any “cure” in the patient as seen by the doctor as a relief of these symptoms, MUST occur in the balancing of this excess or deficiency of these two opposing energy flows.

Cure CANNOT be achieved in the physical body alone…It is as if there is a dirty spot on a lens of a slide projector that is projecting an image on a screen. The traditional doctor works away on scrubbing the spot off the screen, while the holistic doctor cleans the lens, the cause of the spot on the screen.

…WE GET SICK FROM ANY AND ALL THINGS THAT WEAKEN THE BODY’S PROTECTIVE ELECTROMAGNETIC FORCE FIELD OR LIFE FORCE. We have to stop thinking of our animals as physical beings alone. All things exist in physical and energy forms…

Why Do Animals Get Sick?

  • Inheritance of a genetic code that is flawed and produces a weakened constitution. This may produce impaired organ function, immune response or coping with stress. Yes animals do suffer illnesses due to stress as we do.
  • Environmental toxins– chemicals in the food, water and air that is foreign to the metabolism of the body. To this I add the toxic affects of drugs and vaccines.
  • Trauma to any part of the body but especially to the head, which deranges the natural flow of Chi or Life Force. This touches every cell in the body depriving it of the needed energy for health.
  • Noxious energy fields where we work and live. These are EMF’s of the earth known as Geopathic forces and man-made noxious EMF’s. Geopathic forces are produced where two underground streams of water intersect, giving up a ray of energy. Any animal confined over this point for a period of time will develop painful arthritis, malfunction of the internal organs and impairment of the immune system. I have seen cases of cancer in animals in such areas. In Europe there are documented areas known as “Cancer” houses where people and animals living there, have developed this disease down through the years… Man-made noxious energy fields are more important, because this element is becoming more omnipresent. Every electrified building, system of telephones, computers, radios, television, telecommunication of every nature from cellular telephones to military and commercial satellites in the stratosphere, which circle this planet, are radiating an ever widening destructive force field to our bodies.  
  •  
  • Chronic Stress of emotional, physical illness, and toxicity and exposures to noxious energy fields in the environment. Please see my new product Anti-Stress Support Formula 30C
  • CHANGE THE ENERGY OF THE ENVIRONMENT BOTH INTERNALLY AND EXTERNALLY.

Despite the best health care that this country has available, many animals and people still suffer from chronic degenerative diseases. There are many reasons for this; i.e., misdiagnosis, failure of the patient to follow through with therapy, adverse affects of combining different drug therapies prescribed by more than one doctor (iatrogenics), the deleterious affects of persistent chemical exposures of environmental pollutants and pesticides, poor nutrition, genetic weaknesses and persistent stress.

However, there is one more factor that has just come to light in the United States and this is the noxious energy radiation fields from the earth…What are geopathic noxious energies? These are noxious earth rays that come where underground water veins cross; locations of earthquake fracture faults, underground voids (caverns or hollows) in the rock structure and certain deposits of coal, oil and minerals.

These are natural disturbances in energy flows, but there are noxious energies that are man-made too. These are microwave, television, electrical transformers, high- energy electrical power lines, and all electrical units; fluorescent lights (which are insidiously weakening to the health), computers, printers, copiers, cellular telephones, your electrical typewriter and radio. Additional noxious energy fields by man are the increasing numbers of satellites launched overhead by both the military and commerce…There is an increased griding[sic] of this planet by telecommunications on land, in the air and within the oceans. Especially damaging are the ELF rays, (extremely low frequency bands) broadcasted by the military and foreign countries.

Many of these ideas are truly alternative in the sense that for them to be true, many fundamental established principles of science must be false. And many of these are fundamentally faith claims because they cannot be proven or disproven by any objective means but must be believed in and understand through personal intuition and experience.

Such untestable beliefs are, of course, common. Most people in the world believe in things science cannot test, examine, or prove true or false. The problem with basing medical therapies on such beliefs, however, is that there is no way beyond the experience and faith of the individual to know if you are right or wrong. And as I have discussed many times, the evidence is overwhelming that individual judgment and experience is unreliable in deciding which medical therapies work and which don’t.

Science functions on the basis of doubt and skepticism, and these have been stunningly successful strategies in compensating for the natural tendency of people to believe what they want and to seek only confirmation of these beliefs. In contrast, trying to prove something wrong is actively discouraged in vitalist philosophies such as that of Dr. Dodd because such “negative” thinking supposedly interferes with the processes involved in maintaining and restoring health.

Such intuitive, faith-based theories were the basis for medicine, such as it was, for most of human history, and these medical approaches were a dismal failure. Human life remained short and uncomfortable for thousands of years, and the scourges of malnutrition and infectious disease raged unchecked. The scientific approach has changed this dramatically in a mere couple of centuries. The evident failure of so many methods based on such beliefs, and the successes of scientific medicine, argue strongly that a scientific, naturalistic approach to medicine works better, regardless of how one feels about the underlying issue of belief in supernatural forces.

Dr. Dodd does stray out of the territory of pure mysticism and into pseudoscience in her theories as well, by claiming to be able to photograph the Life Force and both measure and manipulate it with electronic devices. The specific processes she uses have been soundly disproven, as have most of the more “mainstream” alternative methods she uses.

In the interest of brevity, rather than critiquing all of the specific methods she uses and why they are, in most cases, utterly useless and without merit, I will simply list a number of those she highlights on her web site with a brief description and links to more detailed discussions of each. In general, her therapies involve underlying principles that contradict well-established principles of science, have not been and perhaps cannot be objectively proven or disproven, and have primarily or exclusively testimonial evidence to support them. None of them come close to meeting the prevailing standards of acceptable care in mainstream, science-based medicine which, theoretically at least, state licensing laws and malpractice laws require doctors to adhere to.

1. Kirlian Photography: This is a pseudoscientific practice that advocates claim can take pictures of the “aura” or “Life Force” of a patient and identify abnormalities and response to treatment. Dr. Dodd has several examples of such photos purporting to show abnormalities and improvements with treatment. (1, 2)

2. Dowsing: Dr. Dodd claims “health hazard earth-made energies can only be detected and diverted by a skilled dowser.” Dowsing is a process of locating water, minerals, or apparently “energies” through mystical intuition and some sort of tool, from a simple forked stick to complex devices. Apparently, Dr. Dodd does not even need to come to your house to detect and “divert” noxious energies. You just have to email her a plan of the house and a list of health symptoms and for only $200 she will deal with the problem remotely. (3)

4. Hair Analysis for Heavy Metals: A classic quack medical test designed to provide a rationale for equally bogus “detoxification” treatments. (4, 5)

5. Color Therapy: In this bit of nonsense, the body is believed to have locations (chakras) which are magical energy centers that somehow have associated colors, and thus diseases in particular organs are due to energy imbalances which can be corrected by exposing the patient to that color. (6, 7).

6. Crystal Healing: Yet another form of “energy medicine” in which mystical energies are thought to be manipulated through magic crystals. (8, 9)

7. Oral Oxygen Therapy: This relies on the mistaken belief that disease is caused by inadequate oxygen in the blood (wait, I thought it was caused by unbalanced Chi, or Yin/Yang. Or was it noxious geopathic energy waves? Toxins? How many “most important” causes of disease are there?). Of course all living things need oxygen, but this is pure pseudoscience, mixing bits of basic chemistry, atmospheric science, and biology with magical thinking. In cases where a patient needs more oxygen is needed in their blood (such as carbon monoxide poisoning or anemia), they certainly won’t be helped by drinking hydrogen peroxide or Dr. Dodd’s magical “crystal-charged” spring water. And too much oxygen can be toxic. Fortunately, she also sells anti-oxidants! (10, 11)

7. Homeopathy: The old classic but with one new twist (new to me anyway): “I see a bright future for homeopathy in eugenic treatment, treating animals in utero. Homeopathy lessens genetic tendency toward disease and by strengthening the breeding stock, “super babies” are produced.” (12, 13)

8. Radionics Broadcasting: This bit of quackery speaks for itself (14):

Today our planet’s air, water, food crops and livestock are polluted by Man’s intervention into Nature. It is his alphabet soup of chemicals, vaccines and doctor produced illness by drugs that must be sequentially detoxed with homeopathic nosodes made from these specific causative agents before acupuncture can be of benefit…A wonderful adjunct therapy to my use of German Sequential

Detoxification and Support with German homeopathic Nosodes/ Support homeopathy, is the European method of Radionics Broadcasting. Strange as it may seem, one can take the exact homeopathics that are needed to treat a patient, and make them into the highest potencies of DCM and place them in an electromagnetic machine (a Radionics machine) and broadcast this energy to the patient via the patient’s own witness.

A witness can be a photo, blood spot or hair sample of the patient. This energy is received and utilized by the patient! Many times, the patient improves with this broadcasting alone, even before giving the remedies orally.

This list could go on for a long, long time, with a lot of other truly bizarre nonsense as well as a solid dose of the standard “mainstream” CAVM  like acupuncture and chiropractic. But the big picture should be pretty clear:

A) Most disease is caused by unnatural human activities, with scientific medicine and nutrition being a leading culprit despite the apparent (but I suppose imaginary) improvements these have brought about in human and animal health.

B) All unscientific or pseudoscientific medical theories are true so long as they make some reference to some kind of mystical energy or Life Force and avoid imaging that the cause and solution to disease lies in the bodies of our patients. The fact that the details of chakras, Chi, chiropractic’s innate intelligence, and all the other vitalist theories contradict one another is not a concern.

C) There is no scientific evidence accepted as legitimate outside of the circle of CAM true believers to support any of these therapies. This is also not a problem because Dr. Dodd has actually seen these things work for herself, and she spent 16 years practices the inferiors kind of scientific medicine the rest of us still believe in so she knows it doesn’t work.

Apart from the extremity of her views and practices, Dr. Dodd is not unlike many notable figures in alternative veterinary medicine. She has some background in conventional medicine, which she has rejected as inadequate. She has adopted a wide variety of theoretically incompatible treatment methodologies that are also mostly incompatible with established science. She truly believes, based on her personal experiences, that these therapies work, and she dismisses any objective evidence that contradicts her beliefs. She is also deeply religious and sees faith in the unseen as an indispensible part of understanding how the world works, including understanding health and disease. I have no doubt she is a nice, caring, and sincere person.

The reason I chose to use Dr. Dodd as a case study is because her interactions with the government mechanisms intended to regulate veterinary medicine and, in theory, ensure some standard of legitimate, effective care illustrate especially well the problems with such mechanisms. She makes her living providing healthcare products and treatments that mainstream scientific medicine judges as questionable at best and often outright useless. She deliberately and openly rejects both the mainstream scientific approach to disease, all the evidence for it and against her methods, and any attempt by government to require her to adhere to standards of care the veterinary profession believes are appropriate.

Dr. Dodd was the subject of a California Veterinary Medical Board (VMB) action which was decided by an administrative law judge and ultimately reviewed in superior court. The superior court decision is available on the internet and describes the  VMB allegations and the administrative law judge’s ruling, though it does not detail the evidence presented to support and defend against the allegations. The accusations of the VMB were as follows:

The accusations three cause[s] for discipline were characterized as Sales of Products via Internet, Treatment of Phido,  and Violation of Local Rabies Ordinance. These charged Dodd with false or misleading advertising, violation of federal drug laws, violation of a local rabies ordinance, and fraud, deception, negligence and/or incompetence in the practice of veterinary medicine. (See Bus. & Prof. Code,  4883, subds. (f), (g)(3) & (i).) They also alleged she had dispensed dangerous drugs or devices without a license. (Health & Saf. Code,  11352.1.) Additionally, they stated Dodd had, in treating Phido, violated two state regulations. (See Bus. & Prof. Code,  4883, subd. (o).) The first regulation requires veterinarians to act in a manner consistent with current veterinary medical practice in this state. (Cal. Code Regs., tit. 16,  2032 (regulation section 2032).) The other regulation section 2032.1requires establishment of the veterinarian-client-patient relationship.

According to an account of the original judicial review (written by a supporter of Dr. Dodd who testified as an “expert” witness on radionic therapy), the VMB presented facts about Dr. Dodd’s practices and the relevant laws and regulations, while Dr. Dodd responded with client and colleague testimonials to her skill and efficacy. According to the same source, VMB documents had characterized Dr. Dodd’s practices this way:

Its[sic] a smoke and mirror power of magic type of practice…bizarre…no medically scientific basis for the idea that she can detect disease in a patient who is 3000 miles away…ludicrous that she can broadcast therapy across the same distance…claims defy basic established principles of physics

These certainly seem fair, even self-evident characterizations to me, and it is not surprising that the VMB might have expected the courts to view them in the same light. But unfortunately, as I discussed in my articles on medical law, courts rarely take a scientific perspective on medical matters.

The Dodd supporter and “expert” witness records being optimistic that the administrative law judge would rule in Dr. Dodd’s favor because he appeared to be ethnically Chinese and so “may have been familiar with Chinese medicine and the functions of “chi”, which, in the Chinese system, is a kind of “vital fluid” or “force” operating on a non-mechanical “subtle” level.” I’m not sure if this witness was correct, but according to his report the judge seemed convinced by the testimonial evidence Dr. Dodd presented that her practices were generally appropriate.

In any case, according to the summary from the superior court judgment, the ruling was overwhelmingly in Dr. Dodd’s favor:

In the revised proposed opinion adopted as the Boards decision, the ALJ noted the Board had the burden of proving cause for discipline under the clear and convincing standard of proof. (See Ettinger v. Board of Medical Quality Assurance (1982) 135 Cal.App.3d 853, 856.) With respect to the cause for discipline entitled Violation of Local Rabies Ordinances, the ALJ concluded the Board had not met its burden of proof. Similarly, regarding the cause for discipline relating to Sales of Products via Internet, the ALJ concluded that the Board had failed to show that Dodd had engaged in false or misleading advertising, or that she had committed fraud, deception, negligence and/or incompetence…On the other hand, the ALJ concluded that the Board had shown cause for discipline for violation of a federal drug law (Bus. & Prof. Code,  4883, subd. (g)(3)), in that Dodd herself had acknowledged such a violation in connection with federal regulations requiring licenses for the preparation and production of biological products. The ALJ noted, however, that Dodd was now in compliance with federal requirements.[this refers to an FDA action against Dr. Dodd, discussed below]

As for the cause for discipline concerning Treatment of Phido,  the ALJ concluded the Board had shown a cause for discipline for unprofessional conduct. (Bus. & Prof. Code,  4883, subd. (g).) Again, this was based not so much on the evidence presented by the Board as on Dodds acknowledgment that she was subject to discipline on this ground after dispensing lactated ringers and hypodermic needles to G.E. Otherwise, the ALJ concluded the Board had not proved any false or misleading advertising, any violation of federal drug laws, or any fraud, deception, negligence and/or incompetence in connection with her treatment of Phido.

The judge did find against Dr. Dodd on the issue of not conducting physical examinations of her patients, and revoked her license. However, he immediately suspended the revocation and put her on probation with the understanding that she would actually see and examine patients if she intended to be their primary doctor. He did allow that she might not have to meet this requirement if she were to act only as a “consultant,” which is how she now advertises her services.

On balance, the judge felt that the VMB had not proved its allegations. This may have been the fault of the VMB, which may have assumed as I would have that the conduct at issue was so manifestly irrational and incompatible with accepted medical standards that providing extensive evidence and testimony to this effect would not be necessary. If the characterization of her methods attributed to the VMB above accurately reflects the Board’s attitude, then this may well be the case.

However, there are suggestions that the judge also found in Dr. Dodd’s favor for reasons that have more to do with how lawyers and lay people see the issues of medical regulation than a simple failing of the VMB to adequately argue its case. Again, from the superior court’s summary:

[the administrative law judge] detailed other circumstances mitigating against the license revocation sought by the Board, including evidence that she had changed or ceased the conduct found to be a cause for discipline, the lack of evidence she had ever actually harmed an animal, the lack of any prior disciplinary action in over 45 years of practice, and scores of testimonials from clients and fellow veterinarians attesting to Dodds[sic] integrity and the quality of her care.

The lack of evidence of direct harm is often a point raised in favor of permitting the practice of ineffective or bogus therapies. This argument is mistaken on several bases. First, there often is direct harm from therapies marketed as safe or “natural.” Even something like homeopathy, which is usually nothing more than water, can be harmful when it actually contains some of the original compound, such as the teething remedy for babies containing poisonous belladonna. And far more difficult to quantify is the indirect harm caused by discouraging patients from seeking truly effective therapies or blaming imaginary causes for illness rather than finding and dealing with the real cause.

The issue of testimonials as evidence is, of course, a core issue distinguishing science-based medicine from alternative medicine. As non-scientists, judges are unfortunately rather likely to mistakenly imagine that scientific truth is a popularity contest, and if they are presented with testimony from doctors or patients/clients that a quack therapy has been effective, they may accept this regardless of the state of the actual objective evidence.

Dr. Dodd appealed even the limited probationary terms that required she “obey all federal and state laws and regulations substantially related to the practice of veterinary medicine” because she argued they would prevent her from practicing her profession and deny clients access to her services. The supporting briefs filed on Dodd’s behalf by clients and other veterinarians argued “the Boards[sic] interpretation of regulation section 2032.1, so as to require a physical examination of an animal patient in order to establish a veterinarian-client-patient relationship, is calculated solely to attack [Dodds] form of alternative veterinary medicine without any substantive justification.”

The administrative law judge did not accept this reasoning, but concluded that while “the Boards[sic] interpretation was reasonable as a general rule…it may be possible to comply with the regulation in other ways (for example by remote video, telemetry, other technology, or as a consulting veterinarian).” Claiming status as a consultant has allowed Dodd’s to practice legally without even the minimal requirement that she ever see the patients she treats, so long as another veterinarian who does see the patient agrees to take formal responsibility for the case.

This seems a bit of a sham on the face of it, and it doesn’t of course address the issue of Dr. Dodd’s selling products intended to diagnosis, treat, and cure disease over the internet without any kind of relationship with client or patient at all. That, of course, would fall under the jurisdiction of the FDA rather than the state veterinary medical board. And interestingly enough, Dr. Dodd has had some interactions with the FDA over this very issue.

In 2004, the FDA sent Dr. Dodd a letter informing her that her sale of nosodes, so-called “homeopathic vaccines,” for West Nile Virus was in violation of federal law. The claims made for the safety and efficacy of these products can only be made for approved drugs which have objective research to substantiate claims about their risks and benefits. Essentially, she was selling water and claiming it could protect people and animals against a dangerous infectious disease, and the FDA quite reasonably told her to stop. This was her response:

In response to your letter of Feb. 25, 2003, I called your office to clarify the USDA’s definition of “biologics”. Essentially I learned it is any product that has the claim of immunizing an animal against disease. I sell homeopathic Nosode remedies, which do not contain any biological agents, yet historically they have proven to not only detox drug vaccines noxious effects but confer immunity. We have over 300 years written documentation of homeopathic nosodes being used to immunize livestock (re: Dr. Wilhelm Lux in Germany circa 1700’s) against Anthrax, Black Leg etc. and more recently in Great Britain, homeopathic veterinarians are using homeopathic Detox Vaccinosis nosodes to immunize against the common dog and cat virus/bacterial diseases with much success, and no serious side effects like the drug vaccines cause. However in this country in order to be licensed, I would be unable financially to undergo the rigid and expensive testing to prove their efficacy.

I have instructed my web master to edit my web page, to delete any reference to these remedies being used to immunize animals…I hope this settles the matter satisfactorily for you.

She then provides a link to a page full of myths, misinformation, and propaganda that urges voters to lobby sympathetic legislators for an exemption of nosodes from federal vaccine laws.

Of course, the claims that nosodes contain no biologic materials is true. The claim that they confer immunity is completely false. And while there are risks to vaccination, they are far smaller than Dr. Dodd claims and they must be balanced against the risk of the diseases against which they protect. (See this article for a more detailed discussion of veterinary vaccines). Unfortunately, even this extremely limited effort to apply public health protection laws to rein in Dr. Dodd’s use of ineffective therapies was itself ineffective. Dr. Dodd still sells these products, and her description of them still claims safety and efficacy in an unmistakable way, though in a way that just might comply with the letter of the law:

Detox noxious affects of the drug vaccine given and strengthen the EMF with my newly developed Detox Homeopathy West Nile Virus nosode 30C. The safe, non-toxic and effective way. There is a killed virus vaccine being sold under governmental limited license by Fort Dodge for horses, but like any drug vaccination we have found many horses develop “Vaccinosis “ following vaccination with this drug vaccine. Vaccinosis is a medical term for illness caused by vaccines. We have seen mare abortions, fetal anomalies, very high fever, lethargy and some cases of paralysis and death after the vaccine is administered. I recommend using the homeopathic nosodal form to Detox Vaccinosis and strengthen the EMF to keep your horses healthy and strong.. My Detox Vaccinosis nosode comes in two forms: Homeopathic Detox WNV nosode 30C for dogs, and orses[sic] or combined with Leptospirosis Pomona ( Homeopathic Detox WNV /Lepto Pomona nosode 30C for horses) Lepto Pomona bacteria has been incriminated in producing uveitis and blindness in horses. So I am giving you two very important nosodes for the price of one for horses. Available in 250 tab bottles for $69.95 plus S/H. [emphasis in original]

West Nile Virus Vaccinosis Detox Nosode Formula 30C- to build EMF after detoxing with 12X, 30C, 60C or if animal that has never had the drug vaccines yet, use this in lieu of drug vaccines. FDA #1042 [emphasis added]

As I stated before, I have no doubt Dr. Dodd sincerely believes she is doing good work, and that she is a caring veterinarian. I also believe she is utterly deluded in her approach to medicine, and that her remedies do little to no good and potentially harm her patients by discouraging them from receiving appropriate disease prevention and treatment. I have no doubt that her activities violate any conceivable mainstream, scientific standard of care. So why, then, do the laws and regulations in place ostensibly to enforce such a standard and protect the public against irrational and ineffective medical care fail to interfere in any meaningful way with her practice?

I think the answer is simply that government cannot be an effective arbiter of scientific truth nor an effective force of restraint against nonsense that is sufficiently popular and not sufficiently obvious and direct in the harm it causes. Scientific truth may not be a popularity contest, but of course in a democracy government largely is.

The features of our system which protect our freedom of thought and expression and our right to hold unpopular views also hamstring government efforts to enforce reasonable objective standards on medicine. The tension between individual freedom and the public good tends to be resolved in favor of the individual, and while one can debate whether this is right or wrong, it is a fact of our culture and our government.

Legislators are likely to write laws with more concern for such ideological issues, and the wishes of their constituents, than for what is actually true or false. And judges are likely to be as or more concerned about the right of an individual to practice their profession, or to choose the medical therapy they want, than about whether the therapies involved actually work or not. And not being trained as scientists, judges are often fooled by pseudoscientific arguments and the psychological power of anecdote and testimonial, and they are likely to interpret the laws from this perspective, with the objective scientific facts being a secondary consideration.

Certainly, this is not always true. And there have been cases in which even judges expected to favor a pseudoscientific position due to their personal biases have appreciated and respected the true scientific position, such as in the Dover, PA case concerning the teaching of the pseudoscientific notion of  intelligent design in public schools. However, as a general rule, we cannot expect government to have the resources or the political will to retrain any but the most dangerous and extreme forms of medical nonsense, as Dr. Dodd’s case illustrates.

So while I certainly support educating and lobbying legislators to enact and enforce laws based on sound science, I think the more productive avenue to maintaining a marginal status for ineffective or quack therapies is through education. Pet owners, and the public in general, may not have the knowledge and training to see through the pseudoscientific fog around many of these ideas, but they are not stupid, and they are highly motivated to seek the best care for their pets.

One of the most important reasons scientific medicine has largely replaced traditional folk medicine so rapidly and thoroughly is simply that it works better and people can see this. My grandmother may have only had a limited rural education, but she saw the terror of polio and how effectively vaccination destroyed it, and this and many other examples of the success of scientific medicine gave her a pragmatic skepticism of snake oil that did not require her to care about abstract philosophical principles of epistemology and the scientific method.

Of course, such principles are the cornerstone of why the edifice of science is stronger than that of opinion-based and faith-based medicine, and we certainly should teach them and good critical thinking skills. And it is important that we try to emphasize the unreliability of such empty, though compelling, forms of evidence as personal anecdotes and testimonials. But we also shouldn’t let the perfect be the enemy of the good, and this means we must use all the tools at our disposal. Web sites like What’s the Harm are an important educational tool, and though I am by temperament more inclined towards the more abstract and philosophical forms of public education, I fully support such efforts as well.

And, of course, we must educate veterinarians. As I so often repeat, the biases and blind spots that lead people to mistaken beliefs in medicine are an intrinsic part of how our brains work, and being intelligent and educated in the sciences is not enough to immunize us against them. Veterinarians, like pet owners, are highly motivated to help their patients, and though they want to do so effectively, they may not always realize the limitations of the kinds of evidence that comes from clinical experience. That is why the work of organizations such as the Evidence-Based Veterinary Medicine Association are so important.

When I first became concerned about the proliferation of unproven or ineffective veterinary approaches, I had hopes that government regulation might be an effective way to guard against the infliction of these methods on our patients and clients. Unfortunately, the more I have learned the more I understand that for better or worse the role of government in this effort is necessarily very limited. So while I will continue to advocate for the implementation and enforcement of sound laws and regulations, I will emphasize my personal efforts, as a clinician, a blogger, and a pet owner, to promote science-based veterinary medicine and challenge unfounded claims about veterinary health care.

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47 Responses to Dr. Gloria Dodd-A Case Study in the Failure of Government Regulation of Veterinary Medicine

  1. ellen says:

    i wonder how many pet owners actually fall for this quackery?

    Healing Halter™
    http://www.holisticvetpetcare.com/healinghalter.htm
    “There are 6 healing energy principles incorporated in the Healing Halter™:
    Color Therapy, Quartz Crystal Mandalas, Pyramid Configuration Energy, Heart Chakra Energy, The Light Invocation, and Anti-radiation bead.”

  2. Dr. Narda says:

    What’s worse, I think, is how many holistic practitioners do.

  3. What’s worse, I think, is how many holistic practitioners do.>>>>

    how may fall for it or how many sell it?
    art malernee dvm
    fl lic 1820

  4. Dr. Narda says:

    I don’t know number-wise, but the American Holistic Veterinary Medical Association is aggressively lobbying state boards put pressure on the RACE committee to approve just about anything holistic practitioners wish to teach.

    http://www.ahvma.org/index.php?option=com_docman&task=doc_download&gid=134&Itemid=58

    http://www.ahvma.org/index.php?option=com_docman&task=doc_download&gid=135&Itemid=58

    This type of pressure is what Skeptvet is talking about, in part. We are seeing it unfold before our eyes.

  5. ellen says:

    Dr. Narda said: “What’s worse, I think, is how many holistic practitioners do.”

    omg. that’s scary.

  6. ellen says:

    Dr. Narda said: “…the American Holistic Veterinary Medical Association is aggressively lobbying state boards put pressure on the RACE committee to approve just about anything holistic practitioners wish to teach.”

    this is an unsettling trend.

    hopefully the veterinary schools are teaching critical thinking and evidence-based medicine to the new generation of future practitioners. i understand that some schools have “holistic clubs” which are student chapters of the american holistic veterinary medical association. are there any student chapters of the evidence-based veterinary medicine association?

  7. Dr. Narda says:

    I don’t know of any student EBVMA chapters, and I’m also not that sure how much critical thinking and EBM emphasis there is in veterinary school. I encourage the third-year PVM students in my Critical Overview of Complementary and Alternative Medicine class to not only consider the scientific/evidential support for CAM treatments, but to apply that lens to conventional therapies as well. Seems subversive to ask them to question whether a TPLO is in fact better than an extracapsular repair for cruciate injury and if so why, but I do anyway.

    I fear that EBM is not currently as “sexy” as what AHVMA peddles, but I think it just needs more exposure. I have found that once students get a taste of critical thinking, they begin applying it in creative ways, such as questioning the food company reps about the claims for their diets.

    We definitely have an urgent need to raise awareness about the truth about CAM in veterinary medicine and to “stop giving alternative medicine a free ride” as was written in an NEJM editorial a while back.

  8. ellen says:

    AHVMA letter to state boards: “If a veterinarian does not know about them [CAVM], or dismisses them, the public has no recourse except to turn to lay practitioners, which can result in harm to their pets.”

    that’s a clever appeal. snake oil is snake oil, no matter who sells it. unfortunately, gullible pet owners are more likely to believe in a bogus therapy if it’s “sold” by a veterinarian (appeal to authority). misdiagnosis and delay in proper treatment can harm pets too.

  9. “Unfortunately, gullible pet owners are more likely to believe in a bogus therapy if it’s “sold” by a veterinarian (appeal to authority). misdiagnosis and delay in proper treatment can harm pets too.”

    Good point.

    And, CAVM instructors and self-proclaimed masters can still teach their courses, regardless of RACE approval.

  10. skeptvet says:

    There are not currrently any EBVMA Student Chapters that I am aware of. However, integration of EBVM into the veterinary professional curriculum is a key element of the EBVMA strategic plan. There is a standing committee dedicated to this task that is working towards this goal:

    Veterinary Curriculum/University Liaison
    Chair: Amy Kapatkin

    The first goal of this subcommittee is to survey all AVMA approved veterinary school curriculums on how they integrate and teach EBVM at their school. The second goal is to help Veterinary schools either establish or facilitate teaching of EBVM in their curriculum. The third goal is to promote EBVM as an integral component of al professional course at the Veterinary schools. This subcommittee is interested in volunteers from the general membership that can help with goal # 1 that is led by Dr. Virginia Fajt. Any interested members should contact Amy Kapatkin or Stuart Turner to get involved.

    And as Dr. Robinson illustrates, there are individual faculty members dedicated to EBVM who are introducing these concepts and skills to their students. I agree that the real hope for the future of effective, science-based veterinary medicine is to train veterinary students to think critically about all the interventions they are taught to emply, conventional and alternative. The tradition of opinion-based medicine and the habit of doing things the way one’s mentors in school did them or the way a charismatic conference speaker advises needs to be challenged, and hoefully this will improve conventional veterinary medicine while also keeping irrational and ineffective approaches marginalized.

  11. Seems subversive to ask them to question whether a TPLO is in fact better than an extracapsular repair for cruciate injury and if so why, but I do anyway.>>>>>>

    lets hope you let them know about cruciate surgery knee scars that denote a unproven remedy. Many respected academic veterinary experts believe that TPLO offers a faster and fuller return of function. But published proof of that theory is lacking, prompting some to avoid the procedure. For instance, surgeons don’t perform it at the University of Pennsylvania School of Veterinary Medicine, says Gail Smith, chairman of the department of clinical research. He calls TPLO “a fashionable procedure.”

    Still, TPLO now is used for an estimated 50 percent of cruciate-ligament procedures in the U.S., and by all accounts that percentage is growing.

    Such treatments have helped fuel a doubling of the number of veterinary surgeons in the U.S. in the last decade to 1,219 from 660. It is also the largest factor in a near doubling of the average annual cost of veterinary surgery visits — to $574 in 2004 from $289 in 2000, says the American Pet Products Manufacturers Association.
    art malernee dvm
    fla lic 1820

  12. I agree with you that there’s a problem, Art. It saddens me greatly when I hear about clients who cannot afford the TPLO procedure (but could likely afford an extracapsular repair or other approach) and consequently euthanize their dog because they aren’t given other options.

  13. ellen says:

    this is an interesting discussion. i thought the TPLO procedure was reserved for large dogs. my dog had successful surgery for a complete CCL rupture; the ACVS board-certified surgeon recommended extracapsular repair and patella trochleoplasty.

  14. my dog had successful surgery for a complete CCL rupture;>>>

    your dog got better after surgery.

    Some vets in other countries think cruciate surgery works only because the pain from surgery gets the dog to rest the leg to let it heal itself. They inject the dogs own blood into the joint to help. If true maybe thats why joint injections of stem cells into joints seem to work so well.
    art malernee dvm
    fla lic 1820

  15. skeptvet says:

    Well, there is pretty good evidence that TPLO is an effective surgery for restoring comfort and function and minimizing DJD progression in dogs with CCL ruptures. The question which is not clearly answered is whether it is superior to less aggressive/expensive surgical approaches or in what subset of these dogs no surgery at all is just as effective. The problem with TPLO is not that it isn’t a reasonable therapy, but that it has been widely adotped in advance of definitive evidence that it is better than the cheaper and less invasive alternatives. It may very well be, but the strength of some people’s conviction in this conclusion is probable greater than the strength of the evidence to support it.

    Unfortnately, in cases of reasonable, science-based approaches just as in cases of more questionable alternative approaches, people have a tendency to adhere rigidly to their opinions without sufficient evidence or even in the face of contradictory evidence. Once something is widely accepted, questioning it tends to generate hostility even if there isn’t really a solid evidence-based justification for the practice. I think that’s ust human nature, and part of our task in improving veterinary medicine is to help vets understand the superiority of objective scientific evidence over opinion, authority, and tradition, within conventional as well as alternative approaches.

  16. ellen says:

    Dr. Malernee said: “your dog got better after surgery.”

    yes, my dog had a swift and complete recovery.

    Dr. Malernee said: “Some vets in other countries think cruciate surgery works only because the pain from surgery gets the dog to rest the leg to let it heal itself.”

    that’s interesting. i thought conservative management only works if there is a partial tear, not a complete rupture. my vet told me that an ECR procedure would result in less osteoarthritis and minimize the chance of later tearing. is that true?

  17. is that true?>>> i do not true false questions. Lets just say its not been proven and if its been disproven the study is in a desk somewhere unpublished.

    my vet told me that an ECR procedure would result in less osteoarthritis >>>>

    Numerous human studies with follow-up periods of 5 years or longer do not support the theory that surgical treatment is the best treatment for restoring knee function. In fact, in 1994 a study examining scintigraphic and radiographic changes in knees managed surgically versus non-surgically found that 5 years after the injury the reconstructed knees showed markedly greater degeneration than those treated non-surgically.
    *****

    CRUCIATE DISEASE – WHAT CAN WE LEARN FROM THE HUMAN LITERATURE

    Christopher M. Hill, VMD, Diplomate ACVS
    ACVS Symposium Equine and Small Animal Proceedings
    October 1, 2001

    CRUCIATE DISEASE – WHAT CAN WE LEARN FROM THE HUMAN LITERATURE

    Christopher M. Hill, VMD, Diplomate ACVS, Mobile Veterinary Surgical Associates, Charleston, South Carolina

    2001 ACVS Veterinary Symposium Small Animal Proceedings

    Keywords: Cruciate disease, non-operative, surgery, graft, dog, cat, small animal

    The anterior cruciate ligament (analogous to the cranial cruciate ligament in canines) plays several roles in the maintenance of stability and function of the knee. It prevents cranial translation of the tibia, resists excessive internal rotation of the tibia, and prevents hyperextension of the knee. It also acts as a secondary restraint against varus or valgus angulation.

    Cruciate rupture, resulting in abnormal anterior-posterior movement of the tibia, was first described in humans in the mid-1800’s. Treatment at that time consisted of immobilization with a removable splint and application of cold water to reduce inflammation. In the early 1900’s operative treatment began to gain popularity with various extra-articular and intra-articular techniques being tried out in humans and, experimentally, in dogs. Most of these procedures utilized fascia lata grafts, patellar tendon grafts, or silk suture to appose the torn ligament. Beginning in the 1940’s the tendon of insertion of the semitendinosus and gracilis muscles were also used as intra-articular grafts. In 1976 Feagin and Curl published follow-up of West Point cadets who had cruciate repair during their college years. The availability of complete military medical records provided an unprecedented accurate follow-up of the surgical procedures. The disappointing news was that a large percentage of the repairs were unsuccessful. Since then surgeons have been refining the various techniques by identifying the most isometric placement of the grafts, using tissues of high strength and stiffness and minimizing operative morbidity via the use of arthroscopes and early rehabilitation.

    The goals of surgical reconstruction are to stabilize the knee, return the patient to pre-injury activity level, and prevent the progression of osteoarthritis. So far no procedure has reliably produced these results, consequently there is much controversy regarding the best way to reconstruct the cruciate deficient knee. Clinical studies in humans have shown that simple suturing of the acutely torn ligament produces a similar outcome as non-operative treatment

    Grafts can be autogenous tissue, synthetic prostheses, or allografts. Each has its advantages and disadvantages, and none are an ideal substitute for the cruciate ligament. Placement of the graft can be either extra-articular, intra-articular, or a combination of the two.

    The concept of muscle transfers to “dynamically stabilize” the knee has never been validated scientifically and it is thought that the speed with which injury occurs is much faster than any reflex arc that may attempt to protect the knee via muscle contraction.

    Extra-articular Repairs

    Most extra-articular repairs create a restraining band on the lateral side of the knee extending from the lateral femoral condyle to Gerdy tubercle on the tibia, in a line parallel to the cranial cruciate ligament. This type of repair was commonplace in humans during the 1970’s and 1980’s. Kinematic studies to determine the optimal attachment points in humans found the best femoral attachment to be just proximal to the lateral collateral ligament and the best tibial attachment to be on the anteriolateral aspect, just at or in front of the Gerdy tubercle. These studies also showed that the stress exerted on the reconstruction depended mostly on the location of the femoral attachment and much less so on the tibial attachment. Extra-articular repairs have the advantage of providing good blood supply to the grafted tissue, thus minimizing the chance of necrosis and failure. Outcome of one series of extra-articular repairs performed in humans in 1985 showed 35% excellent, 43% good, 13% fair and 9% poor. The good/excellent group had a mean follow-up period of 4.4 years and the fair/poor group had a mean follow-up period of 6.7 years, which suggests there may be stretching and deterioration of the repair with time.

    Intra-articular Repairs Using an Autograft

    Intra-articular repairs are the current “gold standard” for reconstruction of the human knee. Although both allografts and autografts are commonly used, autografts seem to have gained wider acceptance. Two of the most commonly used autografts are bone-patellar tendon-bone and semitendinosus-gracilis tendon constructs. A major advantage of using the patellar tendon is that it provides the immediate stability of bone to bone fixation which allows rapid rehabilitation and immediate full weight-bearing. Disadvantages of the patellar tendon graft are weakening of the quadriceps muscle, patellofemoral pain, and occasionally, rupture of the remaining patellar tendon. Studies in dogs, goats and rabbits have shown harvesting the central third of the patellar tendon will significantly decrease the strength and stiffness of the remaining tendon even in the long term. The semitendinosus-gracilis graft is technically easier to harvest and is associated with less operative dissection and post-operative morbidity. Follow-up studies of hamstring strength have shown no significant decrease at 2 years after surgery. Initially there were concerns that the time required for the tendon to heal to bone might prolong the post-operative rehabilitation period. This has since been proven untrue. Studies directly comparing the two techniques have shown no difference in either functional outcome or laxity on instrumented testing even when immediate full weight-bearing and full range of motion exercises were performed. There are numerous minor variations of these two intra-articular grafting techniques, however almost all studies in human patients report 85-90% excellent/good results and 10-15% fair/poor results.

    All autogenous grafts undergo the process of necrosis, revascularization, and maturation. Experimental studies have shown patellar tendon grafts become enveloped by a highly vascular synovial-like tissue during the first 4-6 weeks, while the core undergoes ischemic necrosis. By 20 weeks revascularization and repopulation of the entire graft with new cells takes place, although the process of remodeling goes on longer. Concomitant with the revascularization, numerous morphologic, biochemical, and biomechanical changes take place involving changes in cell morphology, collagen cross-linking patterns and glycosaminoglycan content. The bone-patellar tendon-bone and semitendinosus-gracilis tendon grafts have an initial strength superior to that of a normal ACL in humans, however they both undergo an initial significant decrease in strength followed by a gradual increase as remodeling takes place. The mature graft never attains 100% of its initial strength. Experimental studies in monkies and goats have shown that one year after reconstruction the strength and stiffness of the graft is only 30% to 50% of the normal cruciate ligament.

    Intra-articular Repairs Using an Allograft

    Bone-patellar tendon-bone, Achilles tendon, and fascia lata are the most commonly used allografts in humans. The major advantages are no donor site morbidity for the recipient, various sizes to choose from, and since there is no need to do any type of antigenic matching between donor and recipient, an ample supply is available. A potential disadvantage is the time required for graft incorporation. Canine studies have shown allografts become incorporated in a manner similar to that of an autograft, however it occurs at a slower rate. During this time the graft is vulnerable to failure if too much stress is placed on it, consequently rehabilitation takes longer. Potential for disease transmission is a major disadvantage of using allografts.

    There are three different methods to process and preserve bone and soft-tissue allografts: deep freezing (-70° C), freeze drying, and cryopreservation. Deep freezing is an excellent preservation technique that decreases antigenicity of the graft and maintains structural integrity. This is the preferred method for cruciate ligament grafts. The majority of allograft tissue is collected under aseptic conditions and undergoes repeated bacterial and fungal culturing episodes in order to ensure sterility. Because of the risk of viral transmission some sort of secondary sterilization procedure is usually performed. Ethylene oxide and gamma radiation are two of the most commonly used methods. Ethylene oxide has been associated with reactive synovial and bony changes after graft implantation and has been shown to be ineffective in eradicating feline leukemia virus from feline bone. For these reasons it is not recommended for virus sterilization of biologic tissues. The American Association of Tissue Banks recommended irradiation dosage is between 1.5 and 2.5 Mrads, although some spore forming organisms and certain viruses, such as HIV, are not inactivated by this dose. Some studies have suggested that approximately 3.6 Mrad is needed to inactivate HIV in bone, however, there is a significant, and dose-dependent deterioration of the mechanical properties of tissues sterilized above 2.0 Mrads. Studies using goat patellar ligament showed that 3.0 Mrads of irradiation decreased force to maximum failure by 27%. Gamma irradiation also affects the strength of the graft after incorporation in the host body. In a goat model it was found that 4 Mrads decreased graft stiffness by 33% to 40% at 6 months post-op. Compared to control knees, 2.0 Mrads did not significantly decrease any mechanical properties measured 6 months post-operatively.

    There are no studies directly comparing success rates of allograft reconstructions with autograft reconstructions, although they are thought to be similar. A review of the literature shows a good or excellent outcome in 60-90% of human patients receiving bone-patellar tendon-bone allografts.

    Non-operative Treatment

    There is still considerable debate as to whether operative treatment provides superior results to non-operative treatment for anterior cruciate injuries in people. Numerous studies with follow-up periods of 5 years or longer do not support the theory that surgical treatment is the best treatment for restoring knee function. In fact, in 1994 a study examining scintigraphic and radiographic changes in knees managed surgically versus non-surgically found that 5 years after the injury the reconstructed knees showed markedly greater degeneration than those treated non-surgically. Other follow-up studies, in 1996 and 1997, have revealed that 10 years post-operatively reconstructed knees continue to show greater degenerative changes on radiographs than those treated non-surgically. An ongoing study following patients with unstable knees in particular, has confirmed that knees may remain free of degenerative changes despite chronic, abnormal laxity. This study also showed no difference in activity level between patients receiving surgical stabilization and those left unstable.

    Non-operative treatment does not imply no treatment. Successful rehabilitation focuses on strengthening the muscles, improving balance and coordination, and restricting loads put on the knee. Functional bracing and anti-inflammatory therapy are also used in non-operative management of cruciate injuries. Approximately 80-90% of patients treated in this manner will have a satisfactory outcome.

    guest

  18. Skeptvet, did I miss this in your article?

    “All of Dr. Dodd’s Cancer Detox Nosodes are FDA registered and approved.”

    From: http://www.holisticvetpetcare.com/cancer_and_autoimmune.htm, under “FACTORS TO CONSIDER ADDITIONALLY IN DEFEATING CANCER IN YOUR ANIMAL: CANCER DETOX NOSODES”

  19. ellen says:

    good catch, dr. robinson. 🙂

    dr. dodds makes that claim again here:
    Feline Infectious Peritonitis, Feline Leukemia, Feline, Infectious Anemia, Feline Autoimmune Diseases and other Serious Infections
    http://tinyurl.com/23zlqwp

    “1. Detox Feline Leukemia Viruses Nosode Formula : 12X, 30X, 60X, 100X, 200X, 400X, 600X, 800X, M, 10M, 50M. The 11 bottle set comes with full instructions and all are FDA registered and approved.

    2. Detox Feline Immune Suppressive (FIV or Aids) Viruses Nosode Formula 12X, 30X, 60X, 100X, 200X, 400X, 600X, 800X, M, 10M, 50M. The 11 bottle set comes with full instructions and all are FDA registered and approved.

    3.Detox Feline Infectious Peritonitis Virus Nosode Formula 12X, 30X, 60X, 100X, 200X, 400X, 600X, 800X, M, 10M, 50M. The 11 bottle set comes with full instructions and all are FDA registered and approved. “

  20. v.t. says:

    Did anyone notice the antifungal diet, looks as if she took it straight off Rachel Ray’s evil dog food recipe pages. The protein amounts, vegetable smorgasboard, onion and garlic and extra virgin olive oil are giveaways.

    I’m wondering if in addition to arguing her medical ethics through the courts, if she shouldn’t be required to undergo psychotherapy before allowing her to continue practicing medicine or even consulting. It appears she could be (is?) downright dangerous, to society in general and to pets.

  21. Rita says:

    “arborization of a tree……….” ARBORIZATION OF A TREE? I wouldn’t accept an aspirin from someone with a brain function like that!

  22. ““ ‘arborization of a tree……….’ ARBORIZATION OF A TREE? I wouldn’t accept an aspirin from someone with a brain function like that!”

    Trees? Trees are special.

    From the AHVMA 2010 Convention Brochure “We’ll wander among them, learning from story, song, shamanic trance, and facts. Oak, ash, linden, birch, maple, sycamore, beech .. each has a story.”

    This is a description in the brochure of a lecture from last year’s meeting in Kentucky.

    How does entering a shamanic trance better prepare a veterinarian to treat an animal? Is this CE activity protecting consumers? Are the students attending this conference becoming better educated? The reports I received were that the students in the audience were left scratching their heads about the relevancy of tree-hugging to their education as scientifically trained medical professionals.

    http://www.ahvma.org/files/Final%20Program%20to%20printer.pdf

    The holistic groups, including Gloria Dodd, have been defending newly invented and unfounded practices for decades:

    “Gloria Dodds along with others have been organizing to defend the position of holistic medicine (with all it’s (sic) aspects) in California. The more of us in an organized group, perhaps the more political clout we may have.”
    -From an AHVMA Newsletter, September 3, 1982.

    One year later, the 1983 newsletter noted, “Received a letter from Gloria Dodd informing me of the formation of the California Veterinary Holistic Medical Association.”

    And now, we see the new head of AHVMA, Dr. Nancy Scanlan, following in Gloria Dodd’s footsteps by re-creating the California Veterinary Holistic Medical Association as a work-around mechanism to ensure that vets in that state receive CE hours for holistic practices of their choosing toward renewal of their licenses.

    Mounting pressure on public figures seems to be the default approach from the holistic camp, given that they often don’t have science in their corner. From another Gloria Dodd moment as recent as 2003:

    “We need to do something folks, and that is change the law. You know that means literally an act of congress at the national level because this is a Federal Act. Congress is in recess this month and won’t be back until Sept. so that gives us time to mount a massive letter writing to your representatives and senators in congress, as professionals and any animal owner you know of who has suffered vaccinosis in their animals. Contact the media (TV, Radio and newspapers). Also write Congressman Dan Burton (Indiana) who chairs the committee on Human Rights and Health. His grandson suffers from vaccinosis. I think he will be a sympathetic ally.”

    http://www.cavm.net/Files/Dodd.pdf

  23. ellen says:

    dr. robinson said: “Trees? Trees are special.” ;D

    tree hugger
    http://tinyurl.com/299plwt

    canine version
    http://tinyurl.com/2d8eeyb

  24. skeptvet says:

    This is part of the grey area that is homeopathy regulation. Technically, homeopathic remedies for humans are grandfathered into the food and drug act so that they are “officially” approved. Though there are some limitation on the claims that can be made about them, but it is much more lax than the rules under DSHEA for dietary supplements and herbal remedies. It appears that te FDA has interpreted the law to exclude veterinary use of homeopathic remedies form this grandfathering, so technically they should be treated like any other drugs or biologics. However, as a practical matter the FDA almost never tries to enforce that rule. And, as we see with Dr. Dodd, it doesn’t seem to have much effect even when they do. Still, it might be worth a try to report such violations, and perhaps if enough complaints come in they might act.

  25. ellen says:

    v.t. said: “Did anyone notice the antifungal diet, looks as if she took it straight off Rachel Ray’s evil dog food recipe pages.”

    as a veterinarian, you would think that dr. dodd would know better than to post a recipe (http://www.holisticvetpetcare.com/mycotic.htm) that isn’t nutritionally balanced and includes onions, which are toxic to dogs and cats.

    as for rachel ray’s “pet-friendly” recipes (http://tinyurl.com/3x7o2z9), they don’t even include a calcium source! at the very least she should have a board-certified veterinary nutritionist evaluate these homemade recipes to make sure they’re complete and balanced before publishing them on the web. it’s irresponsible.

  26. I agree with you, Skeptvet, that the FDA Center for Veterinary Medicine would likely regard these as unapproved new animal drugs, since they did not adopt the DSHEA guidelines like the human counterpart did.

    Here is a paper on “The Current Regulatory Status of Veterinary Homeopathic Drugs in the United States” by Joerg Zimmer and Mark Land. Available at:

    http://www.homeopathicpharmacy.org/pdf/articles/vet_drugs.pdf

    There is no date or other identifying information on the paper. They do, however, state this in the paper:

    “No homeopathic drugs for veterinary use are approved under existing veterinary
    drug regulations. FDA has communicated to the industry that it believes
    homeopathic drug products for veterinary use which lack approved new animal
    drug applications are misbranded drugs and subject to further action, including
    recall. It is FDA’s position that over-the-counter veterinary “homeopathic”
    products making significant drug claims are to be regulated and held to the same
    scientific standards of safety and efficacy as any veterinary drug. In addition,
    FDA has communicated to the industry that the parenteral route of administration
    of any drug product without established therapeutic benefit would place an animal
    at unnecessary risk, regardless of whether or not the product is administered by
    or on the order of a veterinarian. Consequently, when promotional materials are
    established as labeling, the products may be considered unapproved new animal
    drugs which are adulterated under section 501(a)(5) of the act.
    Equally important, a number of liability insurance carriers have considered that
    they will not provide products liability coverage to a manufacturer and/or
    distributor who promotes a product for an unapproved use.”

    Furthermore, because nosodes are derived from diseased tissues, I’m curious how one produces a cancer nosode safely without seeding a tumor into the recipient, or a viral nosode without contaminating the recipient:

    Dodd recommends, among other things: “4. Cancer Detox Nosodes: It is necessary to order the full Kuff series of the 11 potencies: 15X, 30X, 60X, 100X, 200X, 400X, 600X, 800X, M, 10M, 50M All come with detailed instructions. Be sure the cancer has been identified to type:

    1. Adenocarcinoma Kuff series
    2. Hemangiosarcoma Kuff series
    3. Lymphosarcoma Kuff series
    4. Feline Leukemia Viruses Nosode
    5. Feline Immune Suppressive (AIDS) Viruses Nosode”

    From http://www.holisticvetpetcare.com/cancer_and_autoimmune.htm

  27. ellen says:

    skeptvet said: “Still, it might be worth a try to report such violations, and perhaps if enough complaints come in they might act.”

    great idea. how does one go about doing that?

  28. skeptvet says:

    The FDA has a web-based process for complaints here: http://www.fda.gov/Safety/ReportaProblem/ucm059315.htm

    Quackwatch also offers some contact information for reporting fraudulent medical claims: http://www.quackwatch.org/02ConsumerProtection/complain.html

    I have found that a written letter often gets taken more seriously than an electronic report. I would include printouts and links to the relevant web pages as well as a copy of the original warning letter from the FDA, which is available at the link in my post.

    I have spoken with FDA representatives at meetings, and they have very candidly informed me that they have inadequate resources to address the widespread violation of theri regulations on the internet, and they tend to focus in the veterinary area of concerns about the effect of drugs under their jurisdiction on humans or the human food supply. But the fact that they issued the original warning indicates that at least sometimes they are able to take some action on egregious violations.

  29. great idea. how does one go about doing that?>>>> If your married first thing is to get his or her ok to do it.
    art malernee dvm
    fla lic 1820

  30. ellen says:

    dr. malernee said: “If your married first thing is to get his or her ok to do it.”

    LOL! what does one’s marital status (or domestic partnership) have to do with filing a complaint?

  31. ellen says:

    dr. robinson said: “Furthermore, because nosodes are derived from diseased tissues, I’m curious how one produces a cancer nosode safely without seeding a tumor into the recipient, or a viral nosode without contaminating the recipient.”

    i’ve always wondered about this. years ago, a holistic vet recommended a nosode for my dog. i didn’t buy it (the product or the sales pitch) because i thought if it really did contain biologically active ingredients, it might give my dog the disease it was supposed to prevent.

  32. LOL! what does one’s marital status (or domestic partnership) have to do with filing a complaint?>>>> I just “believe” its better to pick your battles together. The owner of quackwatch is requesting funds now to help pay for his lawyer fees. I always wondered what the conversation was like when he told his wife he had to come up with 40 thousand dollars for his efforts to try and fight quackery.
    art malernee dvm
    fla 1820

  33. Rita says:

    It’s the grammar of the tree remark which worries me, not whether trees are a good thing or not: George Orwell points out that this sort of language use (or abuse) (I don’t think “arborization even exists”) is an infallible sign of sloppy thinking, and I try not to let sloppy thinkers anywhere near my animals.

  34. ellen says:

    Rita said: “I don’t think “arborization even exists”

    here’s the definition of “arborization” from the American heritage medical dictionary: 🙂

    ar·bo·ri·za·tion (ärbr–zshn)
    n.
    1. The treelike terminal branching of nerve fibers or blood vessels.
    2. The leaflike pattern formed under certain conditions by a dried smear of cervical mucus.

  35. Rita says:

    Oh, many thanks, I just looked in my OED English etymology. I’d still rather not talk about the treelike branching of trees, though….”arborization of a tree” in Dr. Dodd’s original.

  36. Aleja says:

    PLEASE add a disclaimer under each post in which you reference Gloria Dodd that she and Dr. Jean Dodds, DVM (also of CA) are not the same! I cringe whenever I see the latter assumed to be the former.

  37. skeptvet says:

    Yes, I’m sure it is frsutrating to be confused with a veterinarian like Dr. G Dodd. Dr. J. Dodds is pretty well-kown, so I would expect most people in the profession not to make that mistake, but I’ll try to ensure I am clear about which I am referring to.

  38. zyrcona says:

    “She has some background in conventional medicine, which she has rejected as inadequate.”

    Probably it’s more likely she rejected it because it wasn’t a get-rich-quick fix.

    Presumably Dr Gloria Dodd is no relation to Dr W. Jean Dodd, a vet who studies vaccination and proposes a different immunisation schedule based around replacing most of the ‘booster’ shots with titres.

  39. Aaron says:

    Hilarious on both sides of the argument greedy crystal ball gazers or greedy fat cat vets that work for pet food companies. They’re both useless outside of trauma care.

  40. pam says:

    Aaron, I wholeheartedly agree with you. I can’t believe that all of these people have nothing better to do than pick apart Dr. Dodd anyway. I know her, and she’s not crazy. She probably has more education in her little finger than all of them combined. This is typical …. someone proposes ideas that are non-conformist, and out of fear and lack of knowledge the posse starts a witch hunt. By the way, it’s Dr Jean Dodds with an “s” at the end, no relation to Dr Gloria Dodd.

  41. linda says:

    I find this article and comments very interesting. I am not in the health field so my knowledge is limited, so maybe you folks can answer this question. You mention the live nosodes as being dangerous because they are derived from diseased tissues, then explain to me why vaccines are being promoted as safe, yet they contain dangerous ingredients. What is the difference between the two?

  42. skeptvet says:

    A nosode would only be dangerous if infectious material remained in the final product. Most homeopathic remedies are diluted well beyond the point where this is possible, but if not diluted sufficiently or correctly, contamination could occur.

    Vaccines are made with a legitimate understanding of how infectious disease biology actually works. Potentially infective organisms are killed, inactivated, or removed from them before they are used, so the chances of their being infectious are very, very small. The differences is simply diluting stuff based on an 18th myth about disease versus preparing a vaccine in a way that removes most of the risk based on actually knowing how these diseases work.

  43. Pingback: RenAvast™ for Kidney Disease: Sloppy Science and Snake Oil Marketing | The SkeptVet Blog

  44. MK James says:

    I for one used Dr. Gloria Dodd years ago, and, had great outcomes (yes, more than once) when typical allopathic means bore no good results.
    I use holistic and conventional means of healing for my pets, depending on the circumstances.
    Energetic medicine is a new concept in America. Hell, just the term “energy”, can ruffle a lot of feathers and people typically fear and bash what they don’t understand.

    If you’re old enough, you might recall when M.D.s called chiropractors and acupuncturists quacks because what they did wasn’t scientific enough. Wasn’t tangible. Couldn’t be explained. It took about 30 years but now their acceptance is universal.
    Get ready to be ruffled:
    Everything is energy. And get this, despite what some think, even colors have an energy!
    This has been known in other cultures for thousands of years.

    The healing arts are ever evolving. Even Dr. Oz said that he saw the future of medicine moving towards energy.
    The easy way is to sit back on one’s high horse, criticize and judge. Experience is the true teacher. My personal experience with her work was very positive with excellent outcomes.
    My question would be:
    Did you even bother trying energetic medicine with an open mind with Dr. Dodd before you spent so much time and energy verbally assaulting her methods?
    Seems to me that you’d already made up your mind.

  45. skeptvet says:

    If you’re old enough, you might recall when M.D.s called chiropractors and acupuncturists quacks because what they did wasn’t scientific enough. Wasn’t tangible. Couldn’t be explained. It took about 30 years but now their acceptance is universal.

    Actually, if you read some of my articles, there is widespread recognition that most claims for chiropractic are false and most of the things they do are quackery. They have some utility for treating low back pain which is about equivalent to standard physical therapy, but “quack” still describes the theory and the majority of the practice. Likewise, the evidence is very strong that acupuncture is an elaborate placebo.

    So you are engaging in pretty flawed reasoning here. You claim that we should take one form of quackery seriously because a couple of things that were once viewed as quackery are now widely accepted. However, apart from the fact that these things are not actually scientifically validated and that popular acceptance isn’t good evidence for effectiveness, even if they were this would have nothing to do with whether or not Dr. Dodd’s bizarre ideas are true. It’s like saying that because people once mocked the idea of a round Earth and now they mock the idea of Alien abduction we should accept the idea of alien abduction as reasonable or even true.

    Everything is energy.

    This is so vague as to be meaningless. People who claim they use “energy” to heal can’t even define or demonstrate that what they use as a healing method even exists. From healing touch to acupuncture to homeopathy, these people expect the rest of us to passively accept their claims without even having to prove the core idea is anything more than a metaphor. Just because you say “Energy is everything” doesn’t mean that something called “energy medicine” works or that the thing you are calling “energy” is even real. You’re making the claim here, so the burden of proof is on you. No one else is obligated to take your word for anything without evidence.

    Did you even bother trying energetic medicine with an open mind with Dr. Dodd before you spent so much time and energy verbally assaulting her methods?
    Seems to me that you’d already made up your mind.

    1. Trying something for oneself is not the way to evaluate a claim about medicine. For one thing, personal experience is deeply unreliable, which is why we have benefited so dramatically from the discovery of the scientific method, which works much better. And secondly, such a strategy would be impractical. I haven’t tried chemotherapy, but I know that some chemotherapy drugs effectively treat or even cure some cancers. I haven’t had a rattlesnake bite, but I would sure want anti-venin rather than Reiki if I got one because there is evidence that anti-venin works, and Reiki is based entirely on blind faith.

    2. Since when is saying that a claim makes little sense and has no evidence to support it “verbal assault?” Why would you think it ok for anyone to claim anything they like, even with no evidence that it is true, yet feel offended by someone challenging that claim? If I claim that I am the reincarnation of Socrates and you suggest that is unlikely and ask me to prove it, is that unfair/ Is that “assault?” It seems you just don’t like someone criticizing something you believe in, but that doesn’t entitle you to be free from all criticism.

    3. I have made up my mind, after thoughtful reflection and investigation. The fact that I have a different opinion than you do doesn’t mean my opinion was based on any less open-minded or thoughtful a process of reasoning than yours. In fact, since I have based my judgment on science and you on personal experience, I would suggest that you are the one allowing personal bias to form your opinion rather than being open to the possibility that things may not be as they appear on the surface.

  46. Rich Bennett DVM says:

    It appears the VMB filed a motion to revoke the probation in January 2013 (http://www.vmb.ca.gov/public/vet3086_2013_28_01_acc.pdf), but Dr Dodd passed away sometime in 2013 (http://www.holisticvetpetcare.net/Gloria_Dodd_Memorial.htm).

    Her husband appears to be carrying on the business (Everett E Dodd PhD). [http://www.bbb.org/greater-san-francisco/business-reviews/services-general/everglo-natural-veterinary-services-in-gualala-ca-182977]

  47. boxer says:

    ” Scientific truth may not be a popularity contest, but of course in a democracy government largely is.” – Wise words!

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