Black Salve, The Australian Vaccination Network and the Therapeutic Goods Administration

As The Australian Vaccination-risks Network celebrate thirty years of spreading anti-vaccine and dangerous health advice to unsuspecting Australians, some satisfying memories of yesteryear have come to mind. Foremost is the delightful own goal scored by AVN founder Meryl Dorey, when promoting Black Salve as she bemoaned the Therapeutic Goods Administration (TGA) for taking action against the AVN for advertising a DVD, which itself promoted Black Salve. Let me explain.

It all began way back in 2012 with increasing interest in a fraudulently marketed so-called skin cancer “cure”. Namely, a corrosive salve known as an escharotic, being marketed as the near-miraculous Black Salve. A DVD sold by the (then) Australian Vaccination Network (AVN) titled One Answer to Cancer, was packed with anecdotal testimonies praising Black Salve and criticising Aldara, the medically approved treatment for keratoses and superficial basal cell carcinomas. I blogged about this at the time, and you can catch up here. It’s indicative of how quickly interest in Black Salve and the dubious DVD was spreading, to see that on 19 March 2012 the TGA published a warning about black and red salves in treating cancer. This included:

The recent use of  products marketed as containing ‘Black salve’ in Australia has resulted in serious harm to the skin of three Australian consumers who used the black salves for various skin conditions including the treatment of a skin cancer.

The TGA is not aware of any credible, scientific evidence which shows that any black or red salve preparation is effective in treating cancer. These types of salves have not been formally assessed by the TGA and are not included in the Australian Register of Therapeutic Goods or exempted from inclusion.

All therapeutic goods, including those used for treating cancer, must be included in the Register unless exempted. Penalties of up to $5.5m apply to the illegal importation or supply of therapeutic goods.

The TGA was investigating importation and a complaint made about supply via the internet. The Australian Pesticides and Veterinary Medicines Authority were also investigating sales purportedly proffered for pets. The TGA stressed that the problem with corrosive salves is that they “essentially burn off layers of the skin and surrounding normal tissue. They can destroy large parts of the skin and underlying tissue, and leave significant scarring.” The corrosive quality is unpredictable and almost impossible to control. Indeed Black Salve is also referred to as a pro-necrotic agent, which I blogged about in 2019. Once the process begins, widespread necrosis follows, leading to the release of enzymes which cause the breakdown of neighbouring cell membranes. A domino effect ensues causing widespread cell death. It brings to mind the “acid for blood” scene in the movie, Alien.

Necrosis of left nostril and surrounding tissue caused by Black Salve (Wikipedia)

Proponents misleadingly call it Nature’s Scalpel. The purpose of One Answer to Cancer was to promote Black Salve and offer instructions on how to prepare your own batch, using zinc chloride and sanguinaria canadensis, also known as bloodroot. This way the DVD producers could side step charges of selling the illegal corrosive. In December 2018, The Royal Australian College of General Practitioners published a comprehensive article on Black Salve, its history and use, noting that the main ingredient is the synthetic corrosive, zinc chloride. Thus claims of a “natural alternative” are inaccurate, and “catastrophic consequences can occur”. The dangers were well documented in 2012 and warnings were abundant. Nonetheless, in the AVN shop Meryl Dorey had included the following blurb with the DVD ad’.

50% of us will face cancer in our own lives at one time or another… we will have to face the choice of how to treat our illness – using toxic drugs or safe, effective, time-tested natural remedies… If you or someone you know is facing this issue or if you just want to be prepared for any future cancer diagnoses, this will be the best $25 you have ever spent!

The advertisement was in breach of the Therapeutic Goods Act 1989 (the Act) and numerous sections of the TGA Advertising Code (the Code). The Code is an effective legislative device for drawing up complaints against the peddling of quack remedies. Once content meets the definition of an advertisement, that content is subject to a number of principles outlined in the Code. More so, persons who publish what meets the definition of an advertisement may be guilty of an offence if other other medications are criticised or if a risk of harm applies. To read the advertisement and understand how the Code and the Act applied in 2012 you can check out the complaint I lodged on 19 April that year.

Prior to 1 July 2018, advertising complaints lodged with the TGA were handled by a Complaints Resolution Panel (CRP). A media release announcing that the TGA would take on the role of complaint management is available here. Way back in 2012 my complaint was handled by the CRP, and their findings from December 2012, can be accessed here. Fifteen sections of the Code and one section of the Act were found to have been breached. The AVN were told to remove the advertisement and publish the notice below.

However long before this, the TGA informed Meryl Dorey that a complaint had been lodged, as is her right. Unsurprisingly, Meryl felt both the complaint and the request of the TGA to remove the offending advertisement was an abuse of her network’s rights. On 5 May 2012, which was about two weeks after being notified, Meryl gave an interview on Fairdinkum Radio, a production of Resistance Media. This was an early freedom fighter production, and host Leon Pittard opened the show announcing the title as, The Australian Government’s Assault on Health Freedom. For me, the highlight of the show was Meryl’s interview which you can access below, or download here.

Meryl waxed lyrical about the benefits of Black Salve and the horror of Aldara, which she falsely claimed was “banned in many parts of the world”. Meryl also managed to call the TGA Cost Recovery model, “a fairly evil policy”. She provided a dubious anecdote of her own apparent use of Black Salve and wrongly claimed it has a “two thousand year history”. She mentioned the DVD and wrongly claimed Black Salve was a combination of herbs and minerals. The interview went on for over five minutes and easily met the definition of an advertisement. An advertisement for Black Salve published in broadcast media, no less. I lodged a second complaint.

The complaint makes clear how both Meryl and host Leon Pittard were liable as advertisers. It also contains a transcript of the interview. Application of appropriate sections of the Code, the Act and the Therapeutic Goods Regulations 1990, justified removal of the interview/advertisement and publication of a retraction (below). By the end of January 2013 the CRP had published their findings which can be accessed here. Thirteen sections of the Code were breached along with two sections of the Act. No sections of the Code raised in the complaint were found not to be breached. More so, over five paragraphs the panel raised additional matters not in the complaint. These included a possible breach of the Act relating to the Register of Therapeutic Goods, and nine possible breaches of the Code relating to criticism of Aldara, promoting a dangerous compound for serious disease, comments about the TGA and more (see pp. 2-3).

Page 3 of the CRP report includes reference to a somewhat bizarre response to a member of the panel from both Dorey and Pittard. In essence they would cop to the findings of the panel if the member would, in his private capacity, present “true, complete and correct proof” that relating a personal condition to anyone constitutes advertising, that the person making the claim is aware of fees paid for advertising, that free speech is not an inherent right, that any corporation has the right to sue an individual and that the matter couldn’t be settled in private. Leon Pittard had long boasted of monitoring the New World Order, employed a watered-down sovereign citizen logic to his world view and, like Dorey, was a fan of conspiracy theorist, Senator Malcolm Roberts. Pittard no doubt penned the response attributed to both he and Dorey (summarised below).

To my surprise, a short time after lodging the complaint I stumbled across this ridiculous video from the USA which was defending the position of Leon Pittard and Meryl Dorey. I wonder if in the rush to defend free speech the producers did any serious research on Black Salve, or understood the danger their support posed to an unsuspecting public.

Ultimately it was rewarding to have these particular complaints upheld. The second complaint – a veritable own goal – was particularly satisfying. However as is often the case with groups beholden to anti-science ideologies and belief in a fight for “health freedom”, such advertisements aren’t always removed when requested. Non-compliance is met with further warning notices, whilst more serious penalties reflect the nature of the breach and risk to the public. There’s little doubt that Black Salve caused serious injuries at the time and a quick search reveals that it continues to cause harm and generate health authority warnings in developed nations. The TGA seized Black Salve capsules on the Gold Coast in May 2019 and again in Brisbane, in December 2023.

The TGA publish regulatory decisions and announcements and the outcomes of advertising compliance investigations. As members of the public it’s up to us to report harmful products and dodgy advertisements to the TGA. It may involve a bit of reading but not every complaint needs to begin with every potential breach.

You can report perceived breaches or questionable practices here. There’s more information on reporting, what you need to provide and accessing support to complete forms here.


Complaints & Findings:

Complaint to TGA re One Answer to Cancer advertisement

Complaints Resolution Panel findings December 2012

Complaint to TGA re Fairdinkum Radio interview

Complaints Resolution Panel findings January 2013

Complaint re One Answer to Cancer DVD

CRP Determination for 16 August 2012

Complaint re Fair Dinkum Radio and Meryl Dorey

CRP Determination for 20 September 2012

Vaxxed III: Unmitigated disinformation

On 23 August this year, Robert F. Kennedy Jr. suspended his independent US presidential campaign in ten battleground states, choosing to endorse Donald Trump. He cited the same causes, “that persuaded me to leave the Democratic Party and run as an independent”, according to AP News. Namely, free speech the war in Ukraine and “a war on our children”.

Kennedy: Anti-vaccine activist

There is, of course, no war on American children. Nor a war on any children in developed nations, in the sense Kennedy is alluding to. In fact as the chairman of Children’s Health Defense (CHD), Kennedy has himself waged a long battle against one of public health’s most important pillars; childhood immunisation. As with every anti-vaccine activist, COVID-19 presented Kennedy with an opportunity to manipulate and exploit a growing pool of misguided and misinformed individuals. Those who blame COVID-19 vaccines for virtually every illness or cause of death. Let me stress, I’m not referring to the known side effects but rather, those pushed by COVID conspiracy theorists and tireless anti-vaxxers. Ultimately, Kennedy’s profile expanded markedly, as did CHD revenue.

So comfortable with deceit, when he began his independent trot toward the White House, Kennedy insisted he was not anti-vaccine. This, despite telling a supportive crowd in December 2021, “It is criminal medical malpractice to give a child one of these vaccines”. Despite his influence in bringing about the measles tragedy in Samoa. He worked hard at the presidential pretence, even temporarily stepping down from his position as CHD Chair. Still today, the “chairman on leave” video message on every CHD website page lacks any reference to vaccines. Yet Kennedy mentions “unnecessary injuries” suffered by children, includes studies of autism and developmental disorder rates and packs in 16 snippets of autistic individuals – mostly with pronounced symptoms. Children are chronically sicker than ever before, “wandering around in a toxic soup”, Kennedy tells viewers. In search of the cause he will die with his boots on, fighting for them. Kennedy originally wrongly linked vaccines to autism in a, now removed, 2005 Rolling Stones article. This fact check piece offers an excellent deconstruction of the misconceptions used to make that link.

Vaxxed

Kennedy’s Children’s Health Defense has been hard at work targeting vaccine evidence during the COVID pandemic. This includes the making of the third Vaxxed film, Vaxxed III: Authorised to Kill, by CHD Films. True to the Vaxxed brand, it is a slick cornucopia of fear-mongering and falsehood. A key figure in this ghastly enterprise is interviewer and co-producer Polly Tommey, who has been involved with the first two Vaxxed films. Readers may remember Tommey was banned from Australia for three years following her antics in promoting the original Vaxxed film here in 2017. Trundling about with the (then) Australian Vaccination-skeptics Network, Tommey, who wrongly believes the MMR vaccine caused her son, Billy, to develop autism, told Australian audiences “doctors were murderers”. The Tommey named as producer of Vaxxed III and Vaxxed II: The people’s truth, is her other son, Tobias. The second and third Vaxxed films have been directed by Brian Burrowes. The first Vaxxed was directed by Andrew Wakefield and produced by Del Bigtree.

In doing some basic research for this post, I noted that Polly Tommey has changed not at all. On 6 September she used CHD’s X account to peddle the falsehood that “an experimental” oral polio vaccine is being used in Gaza. She added the sweeping claim that “the oral polio vaccine” is responsible for the poliovirus infecting “hundreds each year”. Like most persistent anti-vaccine lies there is a kernel of truth here. A prior oral polio vaccine caused disease in ~1 in 2.9 million. However, the new oral vaccine in Gaza does not contain the vaccine-derived strain responsible for past infections. More so, it is the lack of vaccination and the presence of poliovirus in human waste causing the problem. In addition, removal of the problematic weakened virus in 2016, in an attempt to prevent vaccine-derived outbreaks, resulted in greater infection rates. Citing a draft report for the World Health Organisation, AP News explain:

The polio strain in question evolved from a weakened virus that was originally part of an oral vaccine credited with preventing millions of children worldwide from being paralyzed. But that virus was removed from the vaccine in 2016 in hopes of preventing vaccine-derived outbreaks.

Public health authorities knew that decision would leave people unprotected against that particular strain, but they thought they had a plan to ward off and quickly contain any outbreaks. Instead, the move resulted in a surge of thousands of cases.

Suffice it to say, facts are anathema to CHD and Tommey. Which brings us to the quality of Vaxxed III: Authorised to Kill. As with the prior two films the main content is of people interviewed about so-called “vaccine injuries”, deaths and negative health system experiences, filmed in a Vaxxed bus driving across the USA. Like all Vaxxed buses this one was wrapped in Vaxxed brand colour and font. This time the message was Vax – UnVax: The People’s Study. The journey took nine months. All the COVID-19 anti-vaccine tropes are there. Countless testimonies of “life-altering injuries and deaths”, frightening symptoms, scans of brain tumours and pulmonary bleeds, suicidal tendencies and futile hospitalisations. Whistleblowers, medical professionals and lawyers apparently serve to legitimise what is unmitigated disinformation. Viewers are primed to accept that any response to COVID was a “fundamental violation of human rights”.

Vaxxed films are slick productions. Well edited to give the impression of government and health-authority deception, feeding viewers a misleading narrative that casts vaccines as harmful toxins pushed onto an unsuspecting public for nefarious reasons. A conspiracy to hide the truth is always present. As with all Vaxxed buses the names of the “vaccine injured” and dead are written on the outside of the bus. The dedication page for these most recent names contains over 1,350 entries, many of which list autism from MMR or “childhood vaccinations”. Apart from harm done to perception of vaccine safety and public health, individuals exploited and coaxed into a victim mindset, experience genuine pain and distress. Nothing good comes from these films.

Message on the CHD Vaxxed bus

This latest Vaxxed chapter raises a few questions for those of us in Australia who followed the antics of The Australian Vaccination-risks Network (AVN) and their much troubled journeys in their own Vaxxed II: The People’s Truth, bus. The AVN hit the road in July 2020 in their bus, sticking closely to the Vaxxed script. They clocked up seven seperate tours in two buses, as the first was irreversibly damaged in NSW flood waters. On 8 July 2020, AVN founder Meryl Dorey revealed parents “will be filmed for an up-coming Australian documentary”. Five weeks earlier president Anita Hafemeister had boldly claimed, “This will be the Australian version of Vaxxed II, I assume”. All that excitement led this humble author to speculate that the Vaxxed II bus tour would yield material for Vaxxed III. In fact the AVN was still advertising the bus, with sponsorship requests, in February this year. One can only assume that the reality of CHD dollars, Kennedy’s backing and the ambition of Polly Tommey has for now, kept content from Down Under off the big screen.

Polly Tommey and CHD are pushing to fill theatres in the US for an 18 September screening. A host of graphics are offered to assist fans to spread the word on social media. All contain the image of a driverless bus emerging from the mist in the dead of night. The film is being advertised with an unabashed call for donations. Or if you’d like to be an associate, co-‘ or executive producer with a minimum donation of $10,000, that privilege is a mere phone call away. No doubt Vaxxed III will make a profit for Kennedy’s CHD.

Of more concern, is that acceptance of COVID vaccine misinformation has grown in developed nations under the labour of anti-vaccine activists. The USA is currently experiencing a growth in the belief of COVID vaccine falsehoods and this film, along with the discussion that follows, may well worsen that trend in the US and elsewhere. Australian anti-vaxxers will have to wait for an online release.


Polly Tommey and Co discuss pre-release debunking of Vaxxed III