Dubious Rx · Ontario · Electrodermal screening
A complaint about an unlicensed diagnostic device, a website that contradicted its own consent form, and an outcome the public was never meant to be able to find.
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Dawn Cormier has not been found guilty of professional misconduct by the College of Naturopaths of Ontario or by any tribunal. She was never referred to the College's Discipline Committee and does not appear on the College's published discipline outcomes.
The outcome documented below is a letter of counsel. A letter of counsel is advice from the Inquiries, Complaints and Reports Committee. It is not discipline, not a caution, and not a finding of misconduct. It carries no penalty and creates no public record.
We were never sent the committee's decision. The identification set out below rests on a documentary match, and we lay out the documents so readers can judge it for themselves.
Electrodermal screening — also sold as EAV, electroacupuncture according to Voll, EDS, or Vega testing — traces back to a German physician, Reinhold Voll, in the 1950s. The patient holds an electrode in one hand while the practitioner presses a probe against points on the other hand or the feet. A meter reads skin resistance. Departures from a nominal value are interpreted as telling you something about organs, allergies, food intolerances, toxic burdens, or which remedy the patient needs.
The claimed capabilities go well beyond a resistance reading. Devices in this family have been marketed as able to scan tens of thousands of substances held in a "virtual inventory," to detect allergies to specific foods and pollens, and to imprint frequencies into custom remedies. In 2000 the Australian Competition and Consumer Commission obtained an undertaking from a distributor to stop advertising exactly those three claims.
When the underlying question has been tested — can experienced practitioners using these devices distinguish people with a real allergy from people without one — the answer has been no. The method has no demonstrated diagnostic validity. Canadian regulators have acted on the hardware: in 2002 Health Canada suspended the licences for the Vegasom, Vega Audiocolor, Vegaselect and Vegatest Expert, barring their sale or importation.
On 6 December 2018 the College of Naturopaths of Ontario received a complaint from Terry Polevoy, MD about Dr. Dawn Cormier, ND of Stratford. The College acknowledged it four days later, in a letter from Deputy Registrar Jeremy Quesnelle, and assigned it file 18-035. The College summarised the allegations as:
On 9 January 2019 the College's Manager of Complaints and Discipline, Natalia Vasilyeva, wrote to the complainant enclosing Cormier's response, received the previous day and dated 3 January 2019. Attached to it were her clinic's EAV web page, her practice disclaimer, and her informed-consent form for EAV.
Then the file goes quiet. Under the Health Professions Procedural Code a panel must dispose of a complaint within 150 days and send the complainant a written decision with reasons unless the matter goes to discipline. No decision was ever received.
Cormier's submission made three substantive arguments.
First, that the device is lawful to use. She wrote that EAV machines may legally be used in Canada by anyone, including naturopathic doctors, because Health Canada regulates the sale of such devices and not their use.
Second, that EAV is not a diagnostic tool at all. She described it as measuring small electrical currents through acupuncture meridians, said an energetic interference does not imply a medical condition, and stated that medical conditions should be diagnosed and treated by physicians. She said she had more than 25 years of experience with the technique, described her training, and said the device is never used on its own but alongside history, physical examination, and conventional blood, hair, stool, saliva and urine testing.
Third — and this is the part that matters — that the advertising had been a problem, and had already been fixed. She wrote that the wording of her EAV web page may have been misleading, that she had originally drawn on European literature in which EAV-for-diagnosis is accepted, and that she had since changed the wording on her website and dropped the word "diagnose" so as not to mislead patients.
Her response also included personal criticism of the complainant, reproducing material published about him online, and asked the College to dismiss the complaint and to decline to take his future complaints seriously. We note it because it is part of the record; we do not reproduce it.
Cormier attached both her public EAV page and the consent form her patients signed. Read side by side, they do not describe the same device.
| What the public web page said | What the patient consent form said |
|---|---|
| The device is an electronic FDA approved device designed by Dr. Voll. | The FDA has not approved EAV for the treatment of any disease or condition. It is approved only as a biofeedback device and ohm meter, and is not a diagnostic device. |
| Clients often find swift and full recovery using this highly accurate assessment of health and function that would otherwise go undetected by conventional tests. | The device is being used for investigational purposes only and is not being interpreted for a diagnosis. There are no guarantees of a successful outcome. |
| EAV is unique in providing a functional assessment of organs before symptomatic dysfunction or the development of disease. | The device is one of many tools used for evaluation; it is not a stand-alone diagnostic tool. |
A prospective patient reading the website was promised accuracy, early detection and recovery. A patient in the chair, signing before the probe touched them, was told the opposite: investigational only, no guarantees, not diagnostic, not approved. The marketing and the consent form were written for two different audiences and only one of them had already paid.
In the autumn of 2019 the College published a case study in its members' newsletter, iNformeD, under the heading "ICRC Corner: Medical devices." The College states at the top that details have been altered to protect confidentiality, and names no one.
The case it describes is a complaint from a member of the public about electrodermal screening advertised by a College member. The member responded that the Health Canada licence for the device had expired in 2017, that they had bought the device in 2018, and — in the same terms used in the response to complaint 18-035 — that Health Canada regulates only the sale of such devices and not their use, so they were entitled to use it. The member added that the device was not used as a stand-alone diagnostic tool.
The committee accepted the legal point. Confirming through Health Canada's Medical Devices Active Licence Listing that the device was no longer licensed for sale in Canada, it noted that the Medical Devices Regulations bind manufacturers, importers and distributors rather than practitioners. It nonetheless recorded that Health Canada advises practitioners not to buy devices that are not licensed for sale, that unlicensed devices have undergone no assessment for safety, quality or effectiveness, and that naturopaths using them may be putting patients at risk.
It also reviewed the member's clinic website, and specifically the page devoted to electrodermal screening. It flagged three things: the description of EAV as a unique device, a claim of highly accurate assessment, and a statement that patients find swift and full recovery. Those, it said, may constitute unsubstantiated claims of effectiveness and a promise of success.
The match
Those three flagged phrases are the three phrases on Cormier's EAV page, as attached to her own submission: that EAV is unique in assessing organ function before disease develops, that it is a highly accurate assessment, and that clients often find swift and full recovery. The legal argument the newsletter attributes to the member is the argument her letter makes. The complaint is the same subject, made by a member of the public, in the window in which 18-035 would have been decided.
The College has altered details and named no one, so this cannot be stated as certain. On the documents we hold, we consider it the disposition of complaint 18-035.
The outcome was a letter of counsel — about exercising due diligence in confirming the licensing status of any device used in practice — together with a direction to bring the EAV advertising into compliance with the advertising standard.
Of the outcomes available to the Inquiries, Complaints and Reports Committee, only two are published on the public register: requiring a member to appear and be cautioned, and requiring a specified continuing education or remediation programme. A letter of counsel, a letter of advice, an "other action," or a decision to take no action leaves no public trace at all.
So the complainant's own regulator counselled a member about an unlicensed device and about advertising that promised recovery, and no patient choosing that clinic could ever have found that out. The only reason this page can describe the outcome is that the College published an anonymised version of it in a newsletter intended for its own members.
| Who regulates what | Coverage |
|---|---|
| Health Canada, under the Medical Devices Regulations | The manufacture, importation, sale and advertising of the device. Not its use. |
| The health regulatory college | The practitioner's conduct — but only while the practitioner remains a member. |
| Nobody | A device already sitting in a clinic, used by someone who has resigned from the college. |
A device can lose its Canadian licence, and a practitioner can then buy it and go on using it, because the regulation that governs the device does not reach the person operating it, and the regulator that governs the person is not the one that assesses the device. The College closes that circle only by exhortation: it advises naturopaths to be well informed about their devices, to base use on sound scientific evidence, and, if a device is unlicensed, to tell the patient the Health Canada approvals are not in place and document their consent.
Dawn Cormier practised in Stratford for more than three decades. She holds an honours degree in health science from the University of Waterloo and graduated from the Canadian College of Naturopathic Medicine, and has practised under both Dawn Cormier and Dawn Cormier-Hazen, at Sunrise Health Services, The Hazen Clinic and the Naturopathic Health and Wellness Centre.
Her clinic site advertised a broad remit: identifying food intolerances, overcoming diabetes or heart disease, maximising genetic potential, healing from chronic disease, detoxifying heavy metal and chemical burdens, overcoming limiting subconscious beliefs, and managing energy flow in and around the body. It also carries a four-part video series made with a self-described building biologist on "electro-smog" — Wi-Fi, Bluetooth, dirty electricity, electromagnetic fields, smart devices, LED bulbs — presented as well documented to interfere with human biology in harmful ways. The same electromagnetic framework that underwrites the screening device is being applied to the patient's bedroom.
She now describes herself publicly as a former Naturopathic Doctor. Her current practice is offered under a separate banner as energy healing: she advertises herself as Canada's first Level 2 certified practitioner of a proprietary "light medicine" system, and describes weaving Shamanic, Reiki, Priestess and Arcturian healing into sessions, using a trademarked form of muscle testing to identify hidden stressors and connecting to a client's quantum field.
That last move is the one that matters. A naturopath advertising electrodermal screening is at least answerable to a college that can review her website, apply an advertising standard, and issue a letter of counsel. An energy healer is answerable to no one. Ontario does not regulate energy healing: there is no register, no complaints process, and no advertising standard to fall short of.
We have seen the same exit elsewhere. Anke Zimmermann allowed her BC naturopathic registration to lapse and continued advertising the homeoprophylaxis her college would not have permitted. Leaving a profession is not evidence of wrongdoing — practitioners retire and change direction for every ordinary reason — but it does remove the only oversight that existed.
What we could not verify. We were unable to retrieve the current practice website directly — it blocks automated requests — and have relied on its indexed text. We have not reviewed printed material, office signage, or social media accounts. We do not hold the committee's decision in complaint 18-035; the identification above is an inference from matching documents, presented as such.
Concerned about a naturopath in Ontario? The College of Naturopaths accepts complaints from anyone — you do not have to have been a patient. Its process is described at collegeofnaturopaths.on.ca. This is a general public resource. Complaints about a medical device itself go to Health Canada's Health Products and Food Branch Inspectorate. Practitioners who are not members of a regulated profession fall outside both.
Corrections. If anything here is inaccurate, write to us and cite the record. We will correct it.