Prescribing a Drug


Under the Naturopathy Act, 2007, a naturopath is authorized to perform the controlled act of “prescribing, dispensing, compounding or selling a drug designated in the regulations.”

The designated drugs are listed in table 3 of the General Regulation.  A naturopath may only prescribe those drugs, in accordance with any limitations outlined in the table.  

When prescribing a drug, the general requirements for performing a controlled act, as outlined on the About Controlled Acts page, do not apply.  Instead, the Regulation establishes the requirements that a naturopath must meet to prescribe a drug to a patient:
  • The naturopath can only prescribe a drug to a patient.
  • The drug can only be prescribed for therapeutic purposes.
  • The naturopath must have sufficient knowledge skill and judgment about the drug and the patient’s condition to prescribe the drug.
  • The naturopath must determine that the patient’s condition warrants the prescribed drug, having considered the risks and benefits of prescribing the drug and other circumstances relevant to the patient.
  • The naturopath must notify the patient’s other primary health care providers, if any, within a reasonable amount of time, that they have prescribed the drug for the patient and provide the details about the prescription, unless the patient does not consent to the disclosure.
  • Where a limitation, route of administration or dosage is indicated in table 3, the naturopath can only prescribe the drug in accordance with those conditions.

What is on a Prescription?



Part II (Controlled Acts) of the General Regulation requires that a prescription contain:
  • The name and address of the patient for whom the drug is prescribed.
  • The name, strength (where applicable) and quantity of the prescribed drug.
  • Directions for use of the drug, including dose, frequency, route of administration and any special instructions.
  • The name, signature, address, telephone number and College registration number of the member issuing the instruction.
  • The date the prescription was issued.
  • The number of refills that the naturopath has authorized.
  • Any other information required by law.

A naturopath is required to maintain a patient record for individuals prescribed a drug. That record must include:
  • Details of the rationale for prescribing the drug. 
  • A copy of the prescription given to the patient.
  • A record of the results of any laboratory or other tests that the naturopath considered in deciding to prescribe the drug.
  • The names and addresses of the patient’s other health care providers who were notified, and how the notification was given.

Additional Education and Training



A naturopath may only prescribe a drug to a patient if they have met the Standard of Practice for Prescribing. That requires a member to successfully complete a College- approved course and an examination in Therapeutic Prescribing.  The College’s Naturopathic Doctor Registry includes information about whether a member has met this standard of practice.

When is a Prescription Not Required?


A prescription is not required when a naturopath is recommending that a patient take a natural health product (but note below that certain natural health products have been identified as drugs).  Such substances include:
  • A plant or plant material, an alga, a bacterium, a fungus or a non-human animal material.
  • Any extract or isolate of the above substances, or a synthetic duplicate.
  • Any of these vitamins, or a synthetic duplicate: biotin, folate, niacin, pantothenic acid, riboflavin, thiamine, A, B6, b12, C, D, E, K1, K2 (depending on the dosage recommended).
  • An amino acid, or a synthetic duplicate.
  • An essential fatty acid, or a synthetic duplicate.
  • A mineral.
  • A probiotic.

Some natural health products have been identified as drugs, either entirely or based on certain dosages.  A naturopath is expected to know when a substance is a drug by using the Prescription Drug List, made under the Food and Drugs Act (Canada) or NAPRA Schedule 1.  

What Can or Cannot be Prescribed?


Substances on the Prescription Drug List or NAPRA Schedule 1 are drugs that require a prescription.  A naturopath can write a prescription only for those drugs that appear on these lists and also on table 3 of the General Regulation.  

Substances that do not appear on the Prescription Drug List, NAPRA Schedule 1 or table 3 are not drugs, so a prescription is not appropriate.  In these cases, a naturopath may recommend the substance to a patient for their use in accordance with the standards of practice for Recommending Non-scheduled Substances.

Table 3


The following includes the information in table 3 from the General Regulation.  Every precaution has been made to provide an accurate reproduction; however, in the case of a discrepancy, defer to the actual regulation.  The explanatory notes describe how the limitation on the drug should be applied.  These notes are for information purposes, and do not constitute advice from the College of Naturopaths of Ontario.

 Drug  Limitations, routes of administration, dosages  Explanatory note
Adenosine triphosphate Only if prescribed for intravenous injection to be administered by the member in his or her office to the patient. This is only a drug when it is prescribed for intravenous injection.  It appears on this list to allow NDs to access the drug from pharmacies.  A ND might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection. 
Calcium Chloride Only if prescribed in injectable form for intravenous injection to be administered by the member to the patient. This is only a drug when it is prescribed for intravenous injection.  It appears on this list to allow NDs to access the drug from pharmacies.  A ND might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
Calcium Gluconate  Only if prescribed in injectable form for intravenous injection to be administered by the member to the patient.  This is only a drug when it is prescribed for intravenous injection.  It appears on this list to allow NDs to access the drug from pharmacies.  A ND might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
Colchicine  Must not be prescribed unless the drug is botanical colchicine, compounded from the corm of colchicum autumnale. This limitation requires that only the botanical version of colchicine that is compounded from the corm of colchicum autumnale is prescribed.
Dextrose Injection May only be prescribed when in concentrated solutions for intravenous injection to be administered by the member to the patient. This drug may only be prescribed in concentrated solutions for intravenous injection.  It appears on this list to allow NDs to access the drug from pharmacists.  A ND might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
Digitalis Purpurea and its glycosides Only if prescribed in conjunction with monitoring of patient’s serum levels by member. This drug always requires a prescription.  In addition, a ND must monitor the patient’s blood serum levels when prescribing this drug.
Estrogen (bioidentical) Only if prescribed in topical or suppository form. This always requires a prescription and may only be prescribed in a topical or suppository form.
Folic Acid Only if prescribed in oral dosage containing more than 1.0 mg of folic acid per dosage or, where the largest recommended daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1.0 mg of folic acid. This is only a drug when prescribed in a dosage of more than 1 mg per dose or more than 1 mg of daily dose.  A ND may prescribe at this level or higher where indicated.  Folic acid below 1 mg per dose or per daily dose is not a drug and does not require a prescription.
L-Tryptophan  Only if prescribed for patient’s use in oral dosage form at a concentration of more than 220 mg per dosage unit or per daily dose.  Recommended daily dose must not exceed 12g and must be provided. May be prescribed as a single ingredient intended for intravenous injection.  This is only a drug when it is prescribed in oral dosage at a concentration of more than 220 mg per dosage unit or per daily dose.  The daily dose must not exceed 12g.  The drug may be prescribed as a single ingredient for IV therapy. 
Levocarnitine and its Salts  Only if prescribed for the treatment of primary or secondary levocarnitine deficiency.  This is only a drug when prescribed for the treatment of primary or secondary levocarnitine deficiency in which case a prescription is required. If recommended for any other condition, it is not a drug and a prescription is not required. 
Nitroglycerin Administered to a patient by the member in his or her office only in emergency circumstances and only for angina pectoris. Dosage: 1 to 2 metered doses (0.4 or 0.8 mg nitroglycerin) administered on or under the tongue, without inhaling. The mouth must be closed immediately after each dose (up to 3 doses in total, at least 5 minutes apart). A sublingual tablet may be used (0.3 or 0.6 mg for initial dose). Maximum dose of 1.8 mg.  This drug appears on the prescribing table only to ensure that a ND can obtain it from a pharmacy for in office use.  It may be administered by the member only in office, only in emergency circumstances and only for angina pectoris following the explicit dosing requirements.
Pancreatin  Only if prescribed in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency.  This drug requires a prescription only when it is in a form that provides more than 20,000 USP of lipase activity per dosage or at any dosage amount when prescribed for the treatment of pancreatic exocrine insufficiency. Lower dosages for other conditions do not require a prescription. 
Pancrelipase  Only if prescribed in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency.  This drug requires a prescription only when it is prescribed at more than 20,000 USP of lipase per dose or when it is being prescribed for treatment of pancreatic exocrine insufficiency. Lower dosages for other conditions do not require a prescription. 
Pilocarpine and its salts Must not be prescribed unless, 1. the drug is botanical pilocarpus, compounded from the leaves of pilocarpus microphyllus, 2. the member monitors his or her patient’s drug levels during treatment with the drug and, 3. the drug is never prescribed to treat a patient with glaucoma.  This drug may only be prescribed in its botanical form as identified and requires that the naturopath monitor the patient’s levels during treatment.  The drug cannot be prescribed to treat a patient with glaucoma. 
Podophyllotoxin  Must not be prescribed unless, 1. the drug is botanical podophyllotoxin compounded from podophyllum peltatum and, 2. the drug is never prescribed to treat a patient with rheumatoid arthritis.  This drug may only be prescribed in its botanical form and cannot be prescribed to a patient with rheumatoid arthritis. 
Progesterone (bioidentical form)  Only if prescribed in a topical or suppository form.  Progesterone requires a prescription and may only be prescribed in topical or suppository form. 
Rauwolfia  No limitation, etc., specified.   
Thyroid  No limitation, etc., specified.  
Vitamin A
Only if prescribed in oral dosage form containing more than 10,000 International Units of Vitamin A per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 10,000 International Units of Vitamin A.  Vitamin A requires a prescription only when it is prescribed for oral use at more than 10,000 IU per dose or where the largest daily does would be more than 10,000 IU.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin D  Only if prescribed in oral dosage containing more than 1,000 International Units of Vitamin D per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1,000 International Units of Vitamin D.  Vitamin D requires a prescription only when it is prescribed for oral use at more than 1,000 IU per dose or where the largest daily does would be more than 1,000 IU.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin K1
Only if prescribed in oral dosage when the maximum daily dose is more than 0.120 mg.
Vitamin K1 requires a prescription only when it is prescribed for oral use at more that .120 mg per day.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Vitamin K2  Only if prescribed in oral dosage when the maximum daily dose is more than 0.120 mg.
Vitamin K2 requires a prescription only when it is prescribed for oral use at more that .120 mg per day.  At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration. 
Yohimbine and its salts  Must not be prescribed unless the drug is botanical yohimbine, compounded from the bark of pausinystalia yohimbine. This is always a drug and always requires a prescription.  It may only be prescribed in its botanical form as identified. 



For a copy of the General Regulation, see the Resources section of the College’s website.