This topic was one of a number of discussions held as part of the Council meeting on April 26, 2017.  From the Council’s perspective, the question being posed was whether there was a general awareness among the profession and the public that the answer to this question was “YES”.

Vitamins A, D, K1, and K2, among others become a drug at certain dosages when a patient is being directed to take them orally.  Vitamin A, for example, requires a prescription when a practitioner recommends that a patient take more than 10,000 international units (IU) per dose or in the total daily intake.  Similarly, vitamin D becomes a drug when taken at more than 1,000 IUs, K1 and K2 at more than 0.120 mg.

Why is this important?  For naturopaths who commonly incorporate recommendations for supplements and vitamins as part of their practice, this is extremely important.  In order to do so at the levels noted above, a naturopath must first have successfully completed the Ontario Therapeutic Prescribing course and examination.  It is fairly common for naturopaths to recommend high dose vitamins to patients; however, naturopaths who recommend patients take vitamins at levels that are above the limits and who have not completed the necessary course and exam will have breached the regulation and are subject to prosecution by the College for professional misconduct.

The Council noted that many people who are not regulated health professionals may be recommending vitamins at levels that make them drugs.  The Council also noted that those individuals are breaching the Regulated Health Professions Act, 1991 as they are performing a controlled act that they are not authorized to perform and that those individuals are also subject to prosecution by the Attorney General in Provincial Offence Court.