Who Has Actually Acted?
Five reference tables covering electrodermal screening and breast thermography: what the provincial naturopathic regulators have published, what Health Canada's device branch has done, and which other Canadian bodies stepped in instead. The second table has entries. The first is very nearly empty — and not because nobody asked.
Two devices, documented elsewhere in this section: electroacupuncture according to Voll and its commercial descendants, and digital infrared thermal imaging sold as breast cancer screening. Both have been used in Canada for decades. Both are used predominantly, though not exclusively, by practitioners the provinces licence and hold out to the public as regulated professionals.
The question this page exists to answer is narrow and factual: when a registrant uses one of these machines, has anyone with authority over that registrant ever done anything about it?
How to read a null result
An empty cell in these tables means no published decision, order, notice or advisory could be located in a search of the regulator's own public register and decision database, conducted in July 2026. It does not mean nothing happened.
Regulators resolve a great deal without publishing. Complaints are dismissed, advice is given, undertakings are signed, and cautions are delivered in private. In several provinces only a fraction of outcomes are published at all, and the British Columbia case noted below establishes that a college can discipline a registrant over advertising and issue no public notification whatsoever. So absence of a record is evidence about the public record, and nothing more. If a decision exists that we have not found, we want the citation and will publish it.
These tables are also about Canada. Where we say no regulator has acted, we mean no Canadian regulator, and that claim should not be read more widely. One North American licensing board has published exactly such a record, and it is set out immediately after Table 1.
Table 1 — The provincial naturopathic regulators
| Province | EAV / electrodermal | Breast thermography | What the public record shows |
|---|---|---|---|
| British Columbia | None located | None located | The province's naturopathic college was folded into a larger complementary-health regulator on 7 June 2024. Its predecessor ran a genuine advertising enforcement drive — a prohibition on CEASE therapy claims in May 2018, a compliance deadline of 21 January 2019, twenty-seven registrants investigated, and a stated minimum penalty of $500 per infraction. Not one published outcome names either device. Separately, the province's health professions review board confirmed that the college had disciplined a registrant over advertising without issuing any public notification — direct evidence that non-publication is systemic rather than incidental. |
| Alberta | None located | None located | No published discipline decision naming either device. |
| Saskatchewan | None located | None located | No published discipline decision naming either device. |
| Manitoba | None located | None located | Nothing from the profession's own regulator. The action taken in Manitoba in November 2012 came from the provincial health minister, who ordered a Winnipeg clinic to stop — a ministerial act, not a professional one. See Table 3. |
| Ontario | One, anonymised | None located | The College of Naturopaths of Ontario reported an anonymised letter of counsel in the Fall 2019 issue of its registrant newsletter. It is the only naturopathic outcome on record anywhere in Canada touching either device — and it names no one, so it warns no patient and disciplines no practice. The province's naturopathic regulator was, however, directly consulted on breast thermography in 2012–13 and published nothing of its own. See below. |
| Nova Scotia | None located | None located | No published discipline decision naming either device. |
| Quebec, New Brunswick, Prince Edward Island, Newfoundland and Labrador, and the three territories | No regulator | No regulator | Naturopathy is not a regulated profession in these jurisdictions. There is no register, no complaints process and no professional forum. A patient harmed by a device in these places has no college to complain to, because no college exists. |
Across six provinces, over roughly three decades of documented use, the entire published naturopathic disciplinary record on these two devices is one letter of counsel with the name removed.
What a licensing board can do, when it decides to
The blanks above invite an obvious defence: perhaps a professional regulator simply cannot reach conduct of this kind, or perhaps the machine is too marginal to be worth a file. Neither holds, and the counter-example is a matter of public record.
In March 2023 a chiropractor in California surrendered his licence to the state's Board of Chiropractic Examiners, resolving an accusation that was almost entirely about breast imaging. The Board's published allegations included providing thermography as a stand-alone diagnostic tool, failing to refer a patient after finding symptoms of breast cancer, advertising the service in a false and misleading way, and exceeding the scope of chiropractic practice by using thermography to detect cancer. A surrender is a settlement and not a finding, and we say so plainly wherever we describe it. But it demonstrates that a licensing board of exactly the kind Table 1 lists can build such a file, name the registrant, publish the allegations and end the licence. The full account — together with the six FDA warning letters and the absence of any criminal charge anywhere — is on Who has actually been charged.
The school spoke. The regulator did not.
The blank in Table 1 is not the result of the profession never having been asked. It was asked directly, at the highest level, within weeks of the federal advisory — and the answer came from the wrong institution.
After issuing its November 2012 advisory, Health Canada did not simply publish and move on. It sent a direct communication to the Canadian Association of Naturopathic Doctors restating its concerns. A discussion followed among the profession's principal Ontario bodies: the association, Naturopathic Doctors Ontario, the Clinical Therapeutics Committee of the Canadian College of Naturopathic Medicine, and the Board of Directors of Drugless Therapy — Naturopathy, which was then the province's naturopathic regulator and whose functions passed to the College of Naturopaths of Ontario when the new regulatory framework came into force in 2015.
So the regulator of the day was in the room. It had the federal advisory in hand, it had the association's attention, and it had a specific question in front of it about a device its registrants were selling to women as cancer screening.
What emerged publicly was a position statement from the Clinical Therapeutics Committee of the Canadian College of Naturopathic Medicine, signed by seven naturopathic doctors including the committee's chair. It concluded that the committee does not recommend screening breast thermography in naturopathic practice, and that it was concerned about uncertain benefits in the face of substantial harm. On the evidence it reported that the base is a few small studies pointing in incompatible directions — sensitivity of 25% in one and 97% in another, specificity of 85% and 44% respectively, and a positive predictive value in the first of 24%, meaning roughly a quarter of the women with a positive thermogram actually had a malignancy. No large study has evaluated the technique against death from cancer.
Two things about this source, stated plainly
The committee's principal concern is overdiagnosis, not the false negative. Its worry is that thermography escalates the detection of lesions — particularly ductal carcinoma in situ — that would never have become clinically significant, carrying women into treatment they never needed. That is the opposite failure mode from the one this site most often describes. Both are real: a test with poor sensitivity and poor specificity produces both, in different women, at once. But we are not going to present the committee as agreeing with our emphasis when it does not.
The same document is sceptical of mammography screening. It reproduces Canadian Task Force figures for women aged 40 to 49 and cites the Nordic Cochrane Centre for the view that breast screening may produce no net benefit at any age. This site treats mammography as the established standard of care, so that is a genuine disagreement with a source we are otherwise relying on. We cite the document for what it says about thermography, which is directly within its authors' expertise, and we would rather readers went to the original than took our summary of the rest.
Note which body issued it
The Canadian College of Naturopathic Medicine is the teaching institution — the accredited school that trains naturopathic doctors. Despite the word in its name, it is not a regulator. The committee's remit is narrower still: by its own description it advises on clinical safety and efficacy in CCNM's own teaching clinics, reporting to the school's chief naturopathic medical officer on best practices, standards of care, record keeping, diagnostic procedures and therapies.
So the body that published had authority over the school's own clinics and nowhere else. It could not investigate a registrant in private practice, impose a term or condition on a certificate, issue a caution, or remove anyone from practice. The bodies in that same discussion which could have done any of those things published no equivalent statement that we have been able to locate, and took no published action in the thirteen years since.
This matters for how the empty cells in Table 1 should be read, and here we are arguing rather than reporting. An absence of decisions might otherwise be explained by an absence of awareness — a regulator cannot act on what never reaches it. In our view that explanation is not available here. The federal advisory reached the profession's national association directly, the regulator took part in the resulting discussion, and the school went on to publish a position against the practice. Everyone involved knew. The only body that said anything to the public was the one with no power to do anything about it.
A further wrinkle worth knowing, because it compounds the confusion the silence leaves behind: practitioners were being certified to write and interpret breast thermography reports after roughly three days of training, by a private body trading under the name “College of Medical Thermography.” A member of the public trying to work out whether a thermogram provider is properly credentialled encounters that word attached to a certifying business, while the actual colleges — the ones with statutory authority — have published nothing on the subject at all.
The sequence, 2001 to today
Set the promotion and the regulation side by side in date order and two things become visible that neither table shows on its own.
Red marker = the device being promoted or sold · Purple = Health Canada · Grey = other markers: evidence assessments, press coverage, and the closing null finding
- Jul 1995A major American insurer classifies thermography as unprovenAetna Clinical Policy Bulletin 0029, effective 21 July 1995, treats thermography — including digital infrared thermal imaging — as experimental, investigational or unproven for all indications. Not a regulator, but a documented evidence assessment, in public, six years before the earliest Canadian marketing in this timeline.
- 2001A screening company is already operating in CanadaMobile clinics touring the country in partnership with alternative health-care providers, per the company's own account given to a newspaper in 2011.
- Jun 2002A clinic is advertised — and the objection is publishedOwen Sound front page. The area's acting medical officer of health and a University of Toronto breast-disease epidemiologist dispute the promotional claims and warn of false reassurance.
- Dec 2003The case is made inside the hospitalsA trade paper circulating to hospital staff carries an article promoting first-step breast screening by thermography, written by the co-founder of a thermography company whose advertisement occupies the same page. It sets out the grading scale and describes the lowest grade as reassurance.
- Jun 2006The ten-year claim, on air, unchallengedThe founder of what is now a multi-country thermography network sets out the whole case across a long internet radio interview, including the argument that a tumour visible on a mammogram has been growing nine or ten years and that thermography may see it at year one. See The 2006 broadcast.
- 2006A syndicated feature runs in three citiesCalgary, Saskatoon and Vancouver within five weeks, carrying practitioners' claims and their prices.
- 2009–2011Paid advertising, including a full broadsheet pageA seminar advertisement in Regina, a full page in Welland, a mobile clinic at a Moncton day spa.
- Mar 2012Canada's own health technology agency reviews the evidenceCADTH, funded by the federal, provincial and territorial governments, publishes an assessment finding no randomized controlled trials comparing thermography with mammography for screening well women, and performance worse than mammography on sensitivity, specificity and predictive values. Eight months before the advisory.
- 27 Nov 2012A CBC investigation airsNational television coverage of thermography clinics operating in Canada.
- 28 Nov 2012Health Canada issues Information Update 2012-178The machines are not approved for breast cancer screening; the department knows of no scientific evidence supporting that use; advertising or selling them for it is illegal.
- Nov 2012A border alert, letters to manufacturers, notice to the provincesAll three announced in the same week. No published record confirming what any of them produced has been located.
- 2016The advertising is still runningAn Ontario advertising feature carrying a detection-rate claim and a price list; a British Columbia news item announcing a mobile clinic, with no mention of the advisory.
- 2017The advisory is restatedHealth Canada clarifies that these cameras are licensed only to measure skin temperature, in the way a thermometer does.
- Mar 2023A licensing board elsewhere ends a licence over itA California chiropractor surrenders his licence to the state board, resolving an accusation almost entirely concerned with breast thermography. No Canadian equivalent exists. See Who has actually been charged.
- Jul 2026No Canadian enforcement action locatedNo seizure, prosecution, fine or licence action naming a breast thermography device has been found, federally or provincially. The device is still being advertised in Ontario, by a network described on One reader, many clinics.
The first gap is about ten and a half years. The device was being sold in Canada from at least 2001 and the clinical objection was in print in June 2002. The federal advisory came in November 2012.
Measured from the Aetna policy the interval is longer still — seventeen years and four months. That comparison needs a caveat, and we make it ourselves: an insurer is not a regulator, and a coverage decision is not a finding. But an insurer that declines to pay for a test has done the evidence review, published the conclusion, and kept it under periodic reassessment. That policy has been in continuous effect since 1995 and its most recent review is dated March 2026. Whatever else can be said about the evidence on thermography, it has not moved in thirty-one years.
The second gap is one day. The broadcast aired on 27 November 2012. The advisory followed on the 28th.
That one is sharper than it first appears, because of the entry above it. Canada's own health technology assessment agency had reviewed this evidence and published in March 2012. Eight months later the department had still issued nothing. Then a television programme aired, and the advisory followed the next day.
The third gap cannot be measured, because the interval has not closed. Health Canada announced three administrative measures in November 2012 — the border alert, the manufacturer letters and the notice to the provinces. Each was announced as done, and we have found no published record of what any of them produced: no count of devices stopped at the border, no compliance outcome, no follow-up report. Beyond the 2017 restatement, there is nothing further on the federal record. Thirteen years on, the interval between the announcement and a first enforcement action naming one of these devices is still open.
This next part is our opinion, not the record
The dates above are documentary. What we make of them is not, and readers should weigh it accordingly.
In our view the sequence does not describe a regulator gradually accumulating evidence until action became justified. The evidence did not change during the week of 27 November 2012. What changed was that the practice appeared on national television. A department that can move within twenty-four hours of a broadcast is a department that could have moved in 2003, or 2006, or in October 2012 when a radiologist's doubts were in a daily newspaper headline. We think the honest reading is that the trigger was publicity rather than proof.
We also think an announced measure with no published outcome should not be counted as an action. It may well have been carried out. But a border alert whose results are never reported cannot be assessed by the public it was meant to protect, and it should not be allowed to stand in for enforcement that can be.
Table 2 — Health Canada
The federal picture is different. Health Canada has acted, repeatedly and on the record. What it has not done is follow through into a clinic.
| Date | Action | Detail |
|---|---|---|
| 2002 | Four device licences suspended Acted | The Vegasom, Vega Audiocolor, Vegaselect and Vegatest Expert licences were suspended, which prohibits both sale and importation. This is the single most concrete federal action on the EAV family, and it is now more than two decades old. The successor instruments are sold under different names. |
| Feb 2009 | Reported prohibition on sale Unverified | The EPFX / QXCI / SCIO family is widely reported to have been barred from sale in Canada following a CBC Marketplace broadcast. We have not retrieved a primary Health Canada instrument confirming it, and flag it here as secondary-sourced. A citation would be welcome. |
| 27–28 Nov 2012 | Information Update 2012-178 Acted | Issued by the Health Products and Food Branch Inspectorate the day after a CBC investigation aired. Warned Canadians and health-care providers that thermography machines are not approved in Canada for breast cancer screening, that the department was unaware of scientific evidence supporting that use, and that advertising or selling them for it is illegal. |
| Nov 2012 | Joint border alert with the CBSA Acted | Directed at stopping unlicensed thermographic devices entering the country. |
| Nov 2012 | Letters to manufacturers and importers; notice to the provinces Acted | Provincial and territorial health authorities were notified that clinics under their jurisdiction should not be promoting or using thermal imaging for breast cancer screening. What each province then did with that notice is Table 1. |
| 2017 | Advisory restated Acted | Health Canada repeated the warning and clarified the distinction the marketing depends on blurring: these cameras are licensed in Canada to measure skin temperature, in the way a thermometer does. A licence to measure temperature is not a licence to detect cancer. |
| 2 Mar 2018 | Comparison — premises seizure, drugs | A clinic in Williams Lake, British Columbia was the subject of an advisory and a seizure of injectables and unauthorised prescription drugs. The target was drugs rather than devices, and Health Canada confirmed with both provincial colleges that neither the owner nor any staff member was licensed as a physician or naturopath. An unlicensed operator, over drugs — so it is not an example of what this page is looking for. |
| Dec 2021 – Jan 2022 |
Comparison — prosecution and conviction Acted | A Laval, Quebec company pleaded guilty in Quebec Provincial Court over unlicensed laser and IPL devices and was fined a total of $68,593, including penalties for selling unlicensed devices, advertising them, making false statements to inspectors, and interfering with devices already seized. This is the proof of capability: Health Canada does physically seize hardware and does prosecute. It has simply never been recorded doing so over either device on this page. |
Where the two tables meet
Health Canada regulates the device — its licensing, importation, sale and advertising. The provincial colleges regulate the practitioner — what they may do to a patient and what they may claim. Neither reaches all the way into a treatment room on its own.
A machine that has already been imported and paid for, sitting in a licensed practitioner's office and being used on patients who were not sold the device but a service, falls into the space between the two. Health Canada's compliance instruments are establishment-facing. The colleges' instruments are practitioner-facing and, on this evidence, almost entirely unused. That gap is not a theory; it is what the two tables above show when read together.
Table 3 — Everyone else who acted
The most striking feature of the record is who moved when the profession's own regulators did not.
| Body | Date | What it did |
|---|---|---|
| Collège des médecins du Québec | 28 Nov 2012 | Opened an investigation into the illegal practice of medicine. Note the jurisdiction: Quebec does not regulate naturopathy at all, so the province's medical regulator was the only body available to act — and it did, the same week, while colleges that did have jurisdiction elsewhere in the country did not. |
| Manitoba Ministry of Health | Nov 2012 | The health minister ordered a Winnipeg clinic to stop operating. |
| Newfoundland and Labrador Ministry of Health | Nov 2012 | Issued a cease-and-desist. Newfoundland and Labrador has no naturopathic regulator, so again the province acted directly because nobody else could. |
| College of Physicians and Surgeons of Ontario | 1990–2010 | The Krop case — the only Canadian adjudicated proceeding located in which use of a Vegatest formed part of a misconduct finding. Charges were laid in 1990, hearings ran from 1994, a finding of failure to meet the standard of practice across six patients was made in 1998, and the penalty in June 1999 included a reprimand and conditions requiring prior approval before any further use of the device. The Divisional Court dismissed his appeal and the Court of Appeal refused leave in 2003; he relinquished his licence in 2010. He was a physician. Twenty years of proceedings, and the profession that uses these machines most was not involved. |
| CADTH (Canadian Agency for Drugs and Technologies in Health) |
Mar 2012 | Published Infrared Thermography for Population Screening and Diagnostic Testing for Breast Cancer in its Issues in Emerging Health Technologies series, issue 118. Findings: no randomized controlled trials compare thermography with mammography for screening in well women; no cost-effectiveness evidence for screening use; cohort studies of symptomatic patients or patients with abnormal mammograms do not supply the evidence that would justify screening use; and thermography performs worse than mammography on sensitivity, specificity and predictive values. It fairly records that some study authors have suggested a possible role as an adjunct diagnostic test in some cases. CADTH is funded by the federal, provincial and territorial governments. It assesses; it does not regulate, license or pay. |
| Competition Bureau / Competition Tribunal | 25 Sep 2006 | Obtained administrative penalties totalling $70,000 and a ten-year prohibition order against the marketer of a thermal device, over performance claims not based on adequate and proper testing. Read the detail carefully: the device was a weight-loss machine sold through slimming clinics, not a breast screening camera. It is included because it is the closest Canadian analogue we have found — the same statutory route, the same kind of claim, an actual financial penalty — and not because it is a case on point. This route does not require the target to hold a professional licence; it applies to anyone making a performance claim. The Bureau and Health Canada signed a formal information-sharing agreement in March 2024. |
Table 4 — Has anyone ever been fined?
It is the question that cuts through everything else, so it deserves a direct answer: no financial penalty against anyone selling, importing or operating a breast thermography device for cancer screening in Canada has been located. Not a fine, not an administrative monetary penalty, not a forfeiture, not a costs award. The table below sets out what does exist, including the near misses, so the size of the gap is visible.
| Who | Amount | What it was for — and why it is not the case you want |
|---|---|---|
| Breast thermography Canada |
Nothing | No fine or penalty against any vendor, importer, clinic or practitioner has been located, in any province or federally, at any point since the device entered the Canadian market. |
| EAV / Vegatest Canada |
Nothing | The 2002 action suspended four device licences. A suspension stops sale and importation; it takes no money from anyone and imposes no penalty for what was sold beforehand. |
| Weight-loss thermal device Quebec, 2006 |
$70,000 | Competition Tribunal, 25 September 2006. Administrative penalties of $20,000 and $50,000 plus a ten-year prohibition order against a company and its president over claims made for a slimming machine and associated products. A weight-loss device, not a breast screening one. |
| Unlicensed lasers and IPL Quebec, 2021 |
$68,593 | Guilty plea and sentence in Quebec Provincial Court, December 2021, announced by Health Canada the following month. Selling unlicensed devices, advertising them, false statements to inspectors, and interfering with devices already seized. Hair-removal equipment, not a diagnostic device. Included because it proves the federal machinery works when it is used. |
| Thermography businesses United States |
Letters only | Between January 2011 and February 2019 the FDA sent six warning letters to businesses marketing thermography for breast cancer — among them, in March 2011, a well-known osteopathic physician and health publisher. Every letter named the same three possible consequences: seizure, injunction, civil money penalties. We can find no instance of any of the three being used in a thermography case. A warning letter carries no fine. Set out in full on Who has actually been charged. |
| Chiropractic licence California, 2023 |
No money | The one licensing action on record anywhere in North America arising from breast thermography: an accusation resolved by surrender of the licence in March 2023. It cost the licensee his practice, but it is not a fine and it produced no payment to anyone. Note the shape of the whole table — across two countries and three decades, the enforcement that touched breast thermography took a licence, and never took a dollar. |
Our reading of that table
The largest sum anyone in Canada has been made to pay in connection with a thermal device is $70,000, and it was for a machine that promised to slim people rather than one that promised to find their cancer. That is not a statement about the law's reach. The Competition Act route that produced it was available the entire time and remains available today.
We would go further, and readers are free to disagree: an advisory that is never followed by a penalty is not enforcement, it is publication. Thirteen years of publication have not removed these devices from Canadian clinics, and the 2016 advertising in our press file is the evidence of that — as is the advertising running in Ontario today.
Table 5 — What the people who pay for tests decided
Regulators are not the only institutions that assess a diagnostic test. Insurers do it too, for their own reasons, and they publish the result because they have to defend a refusal to pay. That makes the payer record a parallel evidence trail — and on this device it runs four decades deep.
| Payer | Determination | In force since | Detail |
|---|---|---|---|
| Medicare US federal |
Non-covered | 1984 / 1992 | Breast lesions were excluded from Medicare coverage on 20 July 1984. The general exclusion for thermography in any indication was published as a Final Notice in the Federal Register on 20 November 1992 and took effect that December, on the stated ground that the available evidence does not support the test as a useful aid in diagnosing or treating illness or injury, and that it is therefore not considered effective. The determination is numbered 220.11 and has never been reversed. |
| Aetna US |
Unproven | 21 Jul 1995 | Clinical policy bulletin 0029 classes thermography — expressly including digital infrared thermal imaging, magnetic resonance thermography and temperature gradient studies — as experimental, investigational or unproven for all indications. Still in force, reviewed March 2026, next review January 2027. |
| Cigna US |
Not covered | by 2012 | Does not cover thermography or temperature gradient studies for any indication. Its current breast imaging guidelines, effective February 2026, list thermography as experimental or investigational for both the screening and the diagnosis of breast cancer, alongside scintimammography, PET mammography and impedance mammography. |
| Capital Blue Cross US |
Investigational | current | Treats all forms of thermography as investigational for insufficient evidence, and records that no major organisation issuing screening recommendations recommends it. Notes the American Cancer Society's position that no study has shown it effective for finding breast cancer early, and the American College of Radiology's refusal to endorse it for detecting clinically occult breast cancer. Also notes there are no studies at all on its effect on patient management or health outcomes. |
| Moda Health US regional |
Non-covered | current | A smaller regional plan, included to show the pattern is not confined to the national carriers. Its medical necessity criteria cite the Medicare determination directly. |
| Provincial plans Canada |
Not insured | — | Thermography does not appear in any provincial schedule of benefits, so it is not an insured service anywhere in Canada. But note the mechanism: it goes unpaid by omission from a positive list, not by determination. No Canadian public document says the test was assessed and found wanting. |
| Private insurers Canada |
None located | — | No published coverage policy on thermography from any Canadian private insurer could be found. See below for why we think that is, and why it is not the same as approval. |
Why the Canadian column is empty
The gap is structural rather than sinister, and it is worth understanding because it explains a good deal else on this page.
American health insurers adjudicate individual procedures against medical necessity criteria, and when they refuse to pay they must give reasons that can be appealed and reviewed. That obligation is what produces the published policy bulletin. Medicare goes further still: its national coverage determinations are made through a public, evidence-based process and published by statute, which is why a 1984 decision is still readable today.
Canadian private insurance does not work that way. Under the Canada Health Act the provinces insure medically necessary physician and hospital services, and private carriers are largely barred from duplicating that coverage. What they sell instead is supplementary benefit — drugs, dental, vision, and paramedical services such as naturopathy, chiropractic and massage — and paramedical benefit is typically administered as an annual dollar cap per practitioner type. The plan reimburses a visit to a naturopath up to the limit. Nobody adjudicates what happened during the visit.
The consequence worth noticing
If a Canadian extended health plan reimburses naturopathic visits, and a naturopath performs a thermogram during one of those visits, the plan may well be paying for it — without ever having assessed it, because the benefit is defined by who provided the service rather than by what was done. That is the opposite of the American position, where the test is named in a policy and refused.
If you have paramedical coverage, it is a fair question to put to your insurer in writing: does our plan reimburse breast thermography, and has the company ever assessed it?
As for corporate links between the two markets — there are real ones, and the most direct is worth stating. The US health insurance business of a major Canadian insurer was sold to Cigna, completing on 1 April 2008. Cigna is one of the carriers in the table above with a published non-coverage policy. Other Canadian insurers own or have owned substantial American operations.
What we draw from this, and what we do not
We do not think the corporate links mean much on their own. A Canadian insurer's American subsidiary publishes coverage policies because American law and the American appeals process require it; its Canadian parent does not, because Canadian supplementary benefit involves no procedure-level adjudication to publish. Different regulatory environments, different documents. We are not alleging that anyone suppressed anything.
What we do draw is this. Five American payers assessed thermography across four decades and reached the same answer. The earliest of those decisions predates the Canadian marketing documented on this site by nearly twenty years. None of it was secret, none of it was hard to find, and any Canadian editor, regulator, college or insurer who wanted a second opinion before 2012 could have had one for the cost of a phone call.
But we should be precise about what the empty Canadian column does and does not show, and we have corrected ourselves on this point. A Canadian public body did assess thermography. CADTH — the health technology agency funded by the federal, provincial and territorial governments — published an evidence review in March 2012, eight months before Health Canada's advisory, and reached the same conclusion the American payers had. What Canada lacks is not the assessment. It is anything built on top of one: no payer policy, no enforcement proceeding, no college decision, no penalty. The evidence work was done here, at public expense, and then nothing was done with it.
If you find one of these devices still in use
This is the practical section, and it is deliberately kept separate from our opinions. Everything below is a route that exists for any member of the public, about any product or practitioner. None of it requires you to prove anything first — that is the regulator's job, not yours.
Write down what you saw before you do anything else. The date, the clinic name and address, the name and stated credentials of the person operating or interpreting the scan, the price, and exactly what was claimed. Photograph or screenshot the advertisement, the website page, the price list and the intake form. Websites are edited quickly once a complaint lands, and a screenshot with a visible date is worth more than a recollection. If you were given a written report, keep it.
- If a device is being sold, imported or advertised for breast cancer screening — Health Canada, Regulatory Operations and Enforcement Branch, using the Consumer Medical Device Report Form. This is the federal route and the one that matches the 2012 advisory directly. Note the branch name: the advisory was issued in 2012 by the Health Products and Food Branch Inspectorate, which has since been reorganised, so older references — including elsewhere on this page — name a branch you can no longer write to. Current contact details for this and every other route are on How to complain, and to whom.
- If the operator is a regulated professional — the provincial college that licenses them: the naturopathic college, the college of chiropractors, or the college of physicians and surgeons, depending on their profession. Complaints must generally be in writing. Ask specifically whether the outcome will be published, and if the answer is no, ask why not.
- If the operator is not regulated — and in Quebec, New Brunswick, Prince Edward Island, Newfoundland and Labrador and the territories a naturopath will not be, because those jurisdictions do not regulate the profession — there is no college to complain to. The provincial health ministry and the Competition Bureau are the available routes. In Quebec, the practice of medicine by an unlicensed person is a matter for the Collège des médecins, which is how that college came to be involved in 2012.
- If a performance or efficacy claim is being made — the Competition Bureau of Canada. This is the most under-used route on this page and the only one in the record that has actually produced a financial penalty. It applies to any claim about what a product does that is not based on adequate and proper testing, and it does not matter whether the person making it holds a licence.
- If the images are read somewhere other than where they were taken — note that too, and say so in the complaint. Who interprets a scan, what qualification that person holds, and in which jurisdiction they sit are all material facts, and they are frequently not disclosed to the patient. See One reader, many clinics.
- If the advertisement appeared in a newspaper, magazine or broadcast — complain to the publication as well. Ad Standards handles complaints about Canadian advertising. Editors and advertising managers respond to being told, and our press file shows how rarely anyone told them.
What to tell someone who has already had a scan
A normal thermogram is not evidence that a person does not have breast cancer, and an abnormal one is not evidence that they do. Anyone who has relied on one instead of the screening their doctor or provincial programme recommends should raise it with their physician, and should not wait for a symptom to appear before doing so. If a scan produced an alarming result, that also needs a doctor rather than another scan.
This site cannot give medical advice and is not attempting to. The point is narrower: a thermogram is not a substitute for the conversation.
What these tables add up to
The whole of this section is argument, not record
Everything above this line is sourced and checkable. Everything below it is what we think the record means. We have separated the two deliberately, because a reader who disagrees with our conclusions should still be able to use our tables.
- The federal record exists but stops at the door. Licences suspended, advisories issued, a border alert raised, manufacturers written to. All of it aimed at importation and sale. None of it aimed at the room where the machine is actually used.
- The professional record is a blank. One anonymised letter of counsel, in one province, in one year. Six regulated provinces and roughly thirty years of documented use produced nothing else that a member of the public can read.
- That blank is not ignorance. Health Canada took its 2012 advisory directly to the profession's national association; Ontario's naturopathic regulator of the day joined the discussion that followed; and the position against screening breast thermography was then published by the profession's school. The one body in that conversation without any power to investigate, restrict or discipline is the only one that said anything publicly.
- Nor is the blank inevitable. A licensing board of the same kind — California's chiropractic regulator — built a file on breast thermography, named the registrant, published the allegations and ended the licence in 2023. The instrument exists. No Canadian college has used it.
- Bodies with no jurisdiction did more than bodies with jurisdiction. Quebec's medical college opened an investigation in a province where naturopathy is unregulated. Two health ministries issued orders. A competition regulator obtained penalties and a decade-long prohibition. The naturopathic colleges published nothing.
- The one adjudicated device case in the country was against a physician. Twenty years of process, ending in a relinquished medical licence — and it tells us nothing about how the profession that dominates the use of these devices handles them, because that profession was never party to it.
- Canada did the evidence work, in March 2012, and built nothing on it. CADTH's review predates the federal advisory by eight months and reached the same conclusion American payers had reached decades earlier. It produced no coverage policy, no enforcement, no college decision and no penalty. The gap in the Canadian record is not the assessment; it is everything that should have followed one.
- Five payers assessed it and none would pay. Medicare excluded thermography for breast lesions in 1984 and for all indications in 1992; Aetna has classed it unproven since 1995; Cigna, Capital Blue Cross and a regional plan reach the same result today. The Canadian side of that table is blank — not because anyone here looked and disagreed, but because the payment model never required anyone to look.
- None of this is history. Breast thermography is being advertised in Ontario now, by a network run from a single Toronto office with clinics in five provinces and four other countries, and mobile units visiting towns that have no cancer centre. See One reader, many clinics.
- How the machines reach the office is documented separately. See the supply chain for the import and training channels, and the newspaper record for how the devices were advertised to the public — including for years after the 2012 advisory said that advertising was illegal.
Corrections wanted
These tables are built from public registers, published decisions, government advisories and contemporaneous reporting. They are certain to be incomplete. If you know of a discipline decision, order, undertaking, caution, advisory or payer coverage policy naming either device that is not listed here — in any province, from any body, public or private — please send the citation and it will be added. A published Canadian insurer policy on thermography would be particularly welcome, since we could not find one. Corrections that fill in an empty cell are the most valuable thing anyone can send this page, and they will be published whether or not they suit the argument above.
Nothing on this page asserts that any practitioner, clinic or company has contravened any statute. Licensing and compliance determinations belong to Health Canada and to the provincial regulators, not to this site.
Related pages
- Who has actually been charged The enforcement record beyond Canada: six FDA warning letters between 2011 and 2019, the California licence surrendered in 2023, and no criminal charge over breast thermography anywhere.
- One reader, many clinics Who is selling this in Canada today — a Toronto-run network, a single reporting hub, private certification, and mobile units in towns with no cancer centre.
- The 2006 broadcast The ten-year claim set out on air nine years before the advisory, the hedges that came with it, and the public register of the physician whose wellness centre stood next door.
- EAV and the Vegatest The device class behind Table 1's first column — six marketing claims against the record, and the two blinded studies that tested the Vegatest directly.
- Breast thermography The November 2012 week in which Health Canada, the CBSA, two provincial ministers and Quebec's medical college all moved at once — and the years of quiet that followed.
- The supply chain How the hardware enters the country and where practitioners learn the method, documented from the distributors' own published statements.
- What the newspapers ran Nineteen items, 2002 to 2019. The medical objection ran on a front page ten years before the federal advisory, and the advertising continued for three and a half years after it.
- The Zapper and the Syncrometer A Saskatchewan-born naturopath's two devices, prosecuted in the United States under a campaign Health Canada had joined by name — with no Canadian action and no refunds for Canadians.