Paradigm-Specific Risk Conceptions, Patient Safety, and the Regulation of Traditional and Complementary Medicine Practitioners: The Case of Homeopathy in Ontario, Canada

Abstract

While the principle of risk reduction increasingly underpins health professional regulatory models across the globe, concepts of risk are neither static nor epistemically neutral. Conventional biomedicine's risk conceptions are substantially rooted in principles of scientific materialism, while many traditional and complementary medicine systems have vitalistic epistemic underpinnings that give rise to distinctive safety considerations. The statutory regulation of traditional and complementary medicine providers has been identified by the World Health Organization as a strategy for enhancing public safety. However, complex risk-related questions arise at the intersection of medical epistemologies whose concepts are at best overlapping, and at worst incommensurable. Elaborating a theoretical concept of “paradigm-specific risk conceptions,” this work employs Bacchi's poststructural mode of policy analysis (“What's the Problem Represented to Be?”) to critically analyze risk discourse in government documents pertaining to the 2015 statutory regulation of homeopathic practitioners in Ontario, Canada. The Ontario government's pre-regulatory risk assessments of the homeopathic occupation discursively emphasized cultural safety principles alongside homeopathy-specific risk conceptions. These paradigm-specific concepts, rooted in homeopathy's epistemic vitalism, extend beyond materialist constructions of adverse events and clinical omission to address potential harms from homeopathic “proving symptoms”, “aggravation,” and “disruption,” all considered implausible from a biomedical standpoint. Although the province's new homeopathy regulator subsequently articulated safety competencies addressing such vitalistic concepts, the tangible risk management strategies ultimately mandated for practitioners exclusively addressed risks consistent with the scientific materialist paradigm. This policy approach substantially echoes the implicit biomedical underpinnings evident in Ontario's broader legislative context, but leaves a significant policy gap regarding the primary safety considerations originally articulated as substantiation for homeopathy's statutory regulation. To optimally preserve patient safety and full informed consent, regulators of traditional and complementary medicine professionals should favor a pragmatic, epistemically-inclusive approach that actively negotiates paradigm-specific risk conceptions from both biomedicine and the occupation under governance.

A cross-sectional workforce survey of three traditional and complementary medicine professions in Ontario, Canada

“…We interpret these training and linguistic variables as a rough proxy for clinicians’ immigrant status from the aforementioned regions. This interpretation is reasonable given that traditional East Asian medicine and acupuncture are regulated professions in China and other East Asian countries [ 7 ]; and, homeopathy is similarly regulated in both India and Pakistan [ 43 ].…”

“…It would be worth interrogating in future what factors may be contributing to the comparatively low earnings of the province’s T&CM professions, in addition to the fact that these occupations work outside of the provincial public health care reimbursement system. One factor warranting exploration is the impact of these groups’ socio-cultural marginality—in particular for homeopaths, the plausibility of whose occupational epistemology is widely contested by biomedical scientists [ 43 ]. Another potential income-relevant factor warranting exploration is the availability of third-party insurance reimbursement for these professions’ services.…”

Design, delivery and effectiveness of health practitioner regulation systems: an integrative review

“…A similar range of research concerns was found, such as the content of accreditation standards [ 309 , 310 ], implementing evidence-based national examinations [ 24 , 311 – 313 ], regulatory strengthening [ 314 , 315 ], and regulating scopes of practice [ 297 , 304 , 316 – 319 ]. Studies note some of the policy challenges and adjustments required when applying statutory registration to the T&CM occupations, such as evaluating risk, protecting traditional knowledge, applying flexible language requirements, or delivering care to underserved populations [ 291 , 297 , 316 – 318 , 320 – 326 ].…”

Traditional, complementary and integrative healthcare: global stakeholder perspective on WHO’s current and future strategy

“…19 Second, regulation should be part of a broader policy framework for TCIH that also defines and protects indigenous practices. This may include, among others, the protection of indigenous practices, including from unfair use and misappropriation; safety that includes active negotiation of paradigm-specific risk conceptions 20 ; appropriate promotion of practice; and sustainable use of plant and animal species.…”