[0:00] All right, welcome to the Tier One podcast. And today I’m very pleased to
[0:06] announce that I’ve got David Holt, owner of Hol Law Firm. And David, I’d like you to tell us a little bit about yourself.
[0:12] Uh today’s topic is of course going to be the world of peptides. And I’m hoping that you can shed some light on the
[0:18] information or therefore misinformation regarding peptides. So once again, a pleasure to have you, David.
[0:23] Hey, thanks for having me. Really excited to be here. Kick the new year off, right? Yeah. I’m David Holt. go by
[0:28] DJ, transactional healthcare business attorney, work a lot and only with healthc care providers and so have
[0:35] gotten a lot of questions over the last year in 2025 about peptides, what’s
[0:41] legal, what’s not legal, what if I am doing it anyway type questions. And so
[0:46] I’m excited to explore more as to what the law actually says with you.
[0:51] Well, let’s uh get right into it. as I you know I research I’m on the health and wellness practice so I do a lot of
[0:57] research a lot of literature reviews and of course every day I get a question on peptides multiple questions on peptides
[1:04] from patients and I used to take the time to write a extensive you know letter back to them but now I just
[1:10] typically refer your website to them and specifically what you’ve written on your website because the information I found
[1:16] there was extremely valuable and I want everyone to understand that this is not a podcast about peptides as far as good
[1:24] or bad. This is not what it’s about. It’s simply about trying to shed light
[1:31] on the truth about the prescribing of peptides by providers and the risk that they may be taking in doing so. And so,
[1:38] David, if you can uh kind of lead us into this u you know on your website and I’m going to this will be attached to
[1:43] our to our podcast of course, but the unregulated world of peptides, what you need to know before you inject. Can you
[1:49] kind of lead us through? I’ll just start as a highlevel overview assuming we know you know very little about peptides and
[1:56] so um the the United States does not make it easy uh in my opinion as an
[2:02] attorney you know trying to explain this day in and day out as to what we can and can’t do. So I will I will say that
[2:08] right out of the gate. What I tried to do here, and I’m sure we could share it in the show notes, is state specifically
[2:15] what the FDA or the federal government has said we can and cannot do. You know,
[2:20] right on the website, straight bulletin guidance from the FDA. And the FDA in
[2:28] the United States has full authority to regulate and say what can and cannot be
[2:35] used in humans. Period. Um, some people may not like that. Some people may um
[2:41] not be thrilled about that, but those are the rules. Um high level uh effectively a peptide such
[2:51] as you know BPC157 or you know the whole other list of peptides, it needs to be
[2:57] on what’s called a a final bulk list or um it has to be an FDA approved drug.
[3:04] And a lot of these are not yet all the way FDA approved, which therefore means
[3:09] it’s then illegal to compound inside of the United States. So I’ll say that again. If the FDA hasn’t either put it
[3:17] on one of its list or giving it given it a blessing, I’ll just paraphrase, then it is illegal to compound in the United
[3:24] States. So then everyone, you know, usually says, well then how are all these other providers doing it? or how
[3:30] are all these peptides making their way into gyms and, you know, shipping to my front door and and things like that? To
[3:38] which, you know, I I say, well, I don’t have all of the facts, but I could make some educated guesses on how that might
[3:44] be happening. I will say this, um, first off, as a licensed attorney, I take my
[3:49] marching orders from federal law, state law, and that’s it. You know, I I can
[3:54] talk about what it says if there are exceptions, but if exceptions don’t exist, that’s where my advice and and
[4:01] the party would be over. But I will say this, the FDA has their hands full with a lot of stuff right now as we move into
[4:07] 2026. Enforcement of uh pharmacies as well as
[4:12] the providers themselves. I just don’t think that there is currently the enforcement priority and power for them
[4:19] to be able to do so. But that does not make it legal. So, an analogy I would give is uh I was, you know, driving on
[4:25] the highway today. Everyone on that highway was going, you know, probably 10 to 15 over. I’m not going to say whether
[4:31] I was going 10 to 15 over, but you know, there just aren’t a lot of cops on the
[4:36] highway. And so, not a lot of people get pulled over. That doesn’t make it legal. But uh I I would use that analogy to a
[4:43] small degree as to what I’m seeing happening in the current market just with how many people are landing on you
[4:48] know my the articles that I put out plus the questions that I’m getting. Uh so
[4:54] I’ll I’ll pause there. I know that’s a long- winded answer but um on the blog
[5:00] what I try to go through and it’s very confusing. I I did not set the system up. I just comment on it. There are a
[5:06] few different things that that happen and I’ll try and paraphrase them without getting too technical. And so there’s
[5:12] what’s there’s there what are called compounded drugs which are technically we’ll just say unapproved new drugs but
[5:19] they got a little legal pass because they met certain requirements by the FDA. So that’s a mouthful right there,
[5:26] right? Why can’t we just have yes or no? Well, you know, it’s it’s on its way to a yes and a potential approval. But in
[5:33] the meantime, the FDA is giving it a classification. So the first type of compounding or
[5:40] traditional compounding would be uh 503A. And so this is this regulates pharmacies
[5:47] that compound medications for individual identified uh patients and um there’s a
[5:55] valid prescription, right? Okay, good. That that kind of makes sense. And
[6:00] thosearmacies are primarily going to be overseen by the local pharmacy boards. Okay, I can kind of follow with that.
[6:07] Then we got these uh 503b. So not A but B and those would be outsourcing
[6:14] facilities. Effectively what they do is they allow a large bulk batch of you
[6:21] know patient specific prescriptions to be manufactured and then sell for office
[6:26] use at the local you know clinic hospital. Um they have to follow I think
[6:32] you mentioned um CG GMP guidelines or um the good manufacturing practices. That’s
[6:39] a lot stricter than 503A. So in order to ship a bulk peptide to a provider, you
[6:45] got to meet this very specific uh list of requirements. Um there are also other
[6:50] peptides like BPC57 where the FDA has got gone even further and said there is
[6:57] no specific human use that’s approved at this time. That that may change in the
[7:03] future. Therefore, not allowed for human use. And so providers will say, well,
[7:11] okay, uh, there’s clinical and then there’s, uh, research. So research is a
[7:16] known exception to that rule. Well, you know, research has a very specific
[7:22] framework for how it’s done in the United States. And just saying that something is for research, but then
[7:28] handing it over to a patient for you as a doctor hypothetically would not only
[7:34] be putting your professional license at jeopardy, but you’re also exposing yourself. Um, and I say this with
[7:40] respect to plaintiffs attorneys out there, you know, the personal injury attorneys. They have now basically unlimited access
[7:49] to you because you technically violated federal law. So, you violated law, any
[7:55] damages, we have unlimited reign over you. So, high level, that’s what’s going
[8:02] on. Um, I know that was a mouthful, so I’ll pause there. It’s excellent information and let let’s
[8:08] go with that a little bit. Um, so one thing that some of the prescribers may not understand or may not realize is
[8:15] their malpractice policies, malpractice insurance. Now, uh, Rick Collins, good friend of mine, he’s a very well-known
[8:21] attorney in the United States that deals with, um, uh, performance enhancement, uh, issues, uh, people that get arrested
[8:27] or get in trouble for performance enhancement drugs. But, uh, Rick is very knowledgeable in in that in that area.
[8:33] But I specifically asked Rick about peptides and, uh, Rick looked right at me. He’s a, you know, a defense attorney, and he said, “Keith, whatever
[8:39] you do, never prescribe peptides.” I’m like, “I don’t plan on it, Rick, but why?” He go, “It’s because if a if a patient has a problem with it, if they
[8:46] have an issue, they blame it on the peptide. It’s indefensible. I cannot defend you. No one can.” That struck
[8:53] home. And and once again, this is not a uh these this is not a tyrant against BPC 157. It’s about the legalities of
[9:00] prescribing as a provider. We’re trying to pro protect the providers with this podcast today. So, I did contact as many
[9:06] malpractice uh insurers as I could before our podcast today. Not a single
[9:11] malpractice provider covers non-FDA approved drugs or research chemicals or
[9:17] peptides like we’re talking about that are on the do not compound list. Not one. So, anybody that literally is
[9:23] accused of uh giving a peptide that may have caused a problem to a patient, they will have no defense and their practice
[9:29] policy will not cover them. And those and as you know, defending yourself can run into the tens if not hundreds of
[9:34] thousands of dollars at times. All right. So that’s that’s the that’s the one issue that that’s very concerning is
[9:40] is just that alone. And so a lot of our listeners, I see this on uh the social media as well. They’ll say, “Well, it’s
[9:45] just the FDA. They’re just, you know, they just don’t want you to have things that work.” Well, uh you know, whether I
[9:51] agree or disagree with that statement. You know, I’m not a big fan of FDA, but nonetheless, the FDA
[9:57] is trying to look after the uh the the health of the individuals. And and what I mean by that is that look, in order
[10:04] for us to prescribe a drug, an FDA approved drug, we have to have USPI information, which is prescribing
[10:10] information, the package insert that we get as physicians, and those are based off of randomized control trials in
[10:15] humans. So they develop so we develop this prescribing information for these peptides, the non-FDA approved, we don’t
[10:21] have any of that information. And what is literally involved with an FDA approved drug? This is what is required
[10:28] in order for us to be able to prescribe it legally. You have to have certain information and this is the information.
[10:35] You have to have a boxed warning. You have to have a section of indications and usage, dosage and administration,
[10:42] dosage forms and strengths, contraindications, warnings and precautions, adverse reactions, drug
[10:48] interactions, use in specific population such as pregnancy, lactation, uh females and male reproductive potential,
[10:54] pediatric use, geriatric use, drug abuse and dependence, overdoses, description,
[11:00] clinical pharmacology, mechanism of action, pharmacodnamics, pharmacocinetics, pharmaccogenomics,
[11:06] imogenicity, nonclinical toxicology and then clinical studies. Those are all
[11:12] part of the package inserts we have for the drugs that we prescribe every day, even when we use them off label. We have
[11:18] none of that information for BPC1257 or CJC1295, you name it. None of those that
[11:23] are on the do not compound list. And that’s why the FDA has not approved it for for human uh consumption. Do you
[11:30] have anything to add to that, David? Yeah, 100% on the malpractice. I’ll start there. So, that’s the biggest one.
[11:37] you any event and uh if you’ve ever been through a patient complaint or a medical
[11:44] malpractice allegation, a lot of that um can become a he said, she said, you
[11:50] know, medical record uh is the best we can do. But again, uh your malpractice
[11:57] carrier would not cover it because you are not following the law. So you have prescribed or you’ve broken the law in
[12:04] your administration of or your practice of medicine. Therefore, that’s an excluded event. Just like if I
[12:11] committed, you know, legal malpractice, but I knew that I was doing something wrong, right? My my malpractice carrier
[12:17] would say, well, that’s excluded, right? You uh it’s the same reason why some uh
[12:22] well, why most policies don’t cover intentional tors. Like, I can’t just go around and punch people and then expect
[12:28] my insurance company to pay the bill. like there are things that are excluded. This would be one of them. So, you’d
[12:33] have to pay out of pocket. I would agree that $100,000 would be a good day for some of those personal injury attorneys,
[12:40] especially medical malpractice or sorry, um medical malpractice plaintiffs
[12:45] attorneys. And the reason that plaintiff’s attorneys like this is that
[12:51] unlike, you know, maybe a slip and fall case where you actually have to kind of prove, you know, well, was that a
[12:57] reasonable standard of care? here right here. They just say unapproved peptide, therefore law broken, therefore all
[13:03] damages that result, right? So, we’re really only arguing about damages, which is never where you want to be as a
[13:10] provider. On top of that, now we’re probably getting the attention of the local medical board right now. You know,
[13:17] inadvertently us having to deal with that patient complaint. I wouldn’t be surprised if they also put, you know, a
[13:24] little complaint in with the medical board. You know, I won’t comment on whether that’s a good strategy from the plaintiff’s perspective. I’m on the
[13:30] provider side, but now not only are you paying out damages and dealing with this
[13:35] patient and their attorney that’s coming at you, but now you’re also fending off a a complaint from the medical board for
[13:42] which I don’t think you’re going to have a great defense. I’ll even go one step further. Um, and I wanted to make sure I
[13:49] got this right, but um, in Ohio this year, they actually, um, the board of
[13:55] pharmacy, um, suspended a license of a effectively a medical spa. And they did this by just
[14:02] going in, looking at some of the labeling, and then saying, “Hey, this is
[14:08] according to our rules bad.” And effectively, they’re just kind of drawing upon FDA rules. Now simply
[14:15] saying the FDA is overburdened and you know the state isn’t going to do anything. Medical boards, boards
[14:20] ofarmacies are starting to get involved. Also in New York and New Jersey specifically for you know well peptides
[14:26] but set in a different way. It’s being regulated for minors. So we’re already starting to see a wave of state
[14:32] regulation come in. I actually think to go you know another step further on on
[14:38] what you were saying. your biggest risk and some of the videos we were watching earlier, you know, I don’t have all the
[14:44] facts. I can’t comment on their situations, but I think actually your biggest risk now is the FTC or the
[14:50] Federal Trade Commission. So, we have the FDA. Okay, that’s one federal agency. Now, we have the FTC. The FTC is
[14:58] generally in charge of regulating how advertising and how things are
[15:05] represented to consumers. a consumer in this situation being a patient. So if I
[15:10] have a website or a real on a social media platform saying that something is
[15:16] pharma grade or or misleading as to whether it’s legal to to use or not, the
[15:23] FD the FDC has public record of you saying something and the FDC under
[15:29] federal rules does not mess around in terms of cease and desist as well as fines. And they’re also allowed in some
[15:36] situations not just to go after you civil civil, right? So, okay, a fine
[15:42] season to say stop doing that. You know, money is one thing, but criminal charges as well, which is not never a good place
[15:48] to be. Well, do you mind if we, since you referred to the videos, there are YouTube shorts that anybody can go look
[15:54] at. There are hundreds of them probably, but do you mind if we play those videos? So, or Sure. Yeah.
[16:01] I’ll watch them. When my patients get peptides from me, they come from a licensed FDA registered compounding
[16:06] pharmacy or from pharmaceutical grade suppliers that have voluntarily had all of their products independently tested
[16:12] and verified for sterility and potency. More importantly, I discuss the treatment plan, including proper dosing
[16:18] based on the medical literature, and I pair the right peptide for your specific goal. Peptides are powerful, but they’re
[16:23] only as effective as the precision behind how they’re used. So whether your goal is to heal, lose weight, grow
[16:29] muscle, or just live longer, remember the peptide isn’t the magic. The science, safety, and supervision behind
[16:35] the peptide is. Here’s the part most people fail to understand. And this part’s the critical part. When I started
[16:41] prescribing peptides about say 15 years ago or so, they were thought of as something kind of fringe that only
[16:46] compounding made and they had to be administered via subcutaneous injection. And then about 10 years ago, the FDA
[16:53] began very strict oversight ofarmacies that compounded peptides and medications. And that’s why a lot of
[16:58] peptides now, you’re going to see online on some pop-up website that says for research use only or not for human
[17:06] consumption. What that really means is they’re not regulated. There’s no FDA to enforce testing for purity or sterility.
[17:12] So when someone orders peptides off a random website, they’re taking on major risks. Is this peptide even real? Is it
[17:18] 5 millig? or maybe it’s only 3 milligrams or worse, what if the peptide’s not sterile and you inject it
[17:24] and now you’re injecting bacteria into your system? Yes, these are injectable medications that go directly into your
[17:29] body. So, sterility and quality control are non-negotiable. When my patients get peptides from me, they come from a
[17:35] licensed FDA registered compounding pharmacy or from pharmaceutical grade suppliers that have voluntarily had all
[17:41] of their products independently tested and verified for sterility and potency. Dr. your board certified anti-aging and
[17:47] regenerative medicine MD here to talk to you guys about something very important which is the difference between pharmaceutical grade or pharmagra
[17:54] peptides and research grade peptides. So pharmagra peptides are always going to be from a licensed pharmacy. Research
[18:00] peptides are going to be from a research facility. Pharmagra peptides are regulated by the FDA the pharmacy board
[18:05] they are licensed under as well as the DEA whereas research peptides are unregulated because they are not meant
[18:11] for human use. They’re meant for research purposes only. Pharma grade peptides have to be prescribed by a licensed physician in the state that you
[18:18] are getting them prescribed into. Research peptides can be given out by anybody including naturopaths, chiropractors, therapists, health
[18:25] coaches, fitness trainers, influencers, the guy at the gym or even you can get them yourself through the gray market
[18:30] online by yourself. Pharmagra peptides require strict lab testing which is regulated under cgmp and USP sterile
[18:37] pharmacy guideline rules meaning that they have to be thoroughly tested for purity as well as for bacterial
[18:43] endotoxin to make sure they’re safe that you don’t develop any serious life-threatening reactions just like every other pharmaceutical that we have.
[18:49] There’s strict rules that regulate and govern pharma grade peptides. Research grade peptides do not have these rules. There are some research peptide
[18:55] companies that are doing cgmp testing. I would recommend those over the ones that aren’t. But just keep in mind this still
[19:01] is not a requirement because they’re research grade or they’re meant for research purposes only. Pharma grade peptides because there is a licensed
[19:07] physician obtaining the medication from a licensed pharmacy and a physician patient relationship. There has to be an informed consent to take place which
[19:14] means the physician has to talk to the patient about safety risks and benefits actually discuss and create an informed
[19:19] consent to see if the patient is not at increased risk and if the patient is then this needs to be discussed with the
[19:24] patient. With research grade peptides, people are able to get them without the patient physician risk and benefit
[19:30] stratification and assessment. So pharma grade peptides come to you from the pharmacy on ice generally in a vial
[19:35] that’s reconstituted ready to inject. It doesn’t need to be mixed. Research peptides come to you generally in a liophalized powder which either you have
[19:42] to mix yourself or the person giving them to you has to mix them for you or they might give them to you in pre-filled syringes. Generally these
[19:47] would come as a powder that needs to be mixed. So make sure you ask these questions when somebody’s giving you peptides. Are these research grade? Are
[19:53] they pharmaceutical grade? For your own long-term health and your own knowledge, it’s important to know if it is research
[19:58] grade. Look for that third party testing. See if it’s from a CGMP certified facility. Look at the third party testing. See if it’s pure. And
[20:04] also see if other people have used that same company. Have a good experience with it. If you want to know more about
[20:10] our pharmaceutical grade offerings for peptides, all of them are pharmaceutical grade and all of them are meeting all
[20:16] the criteria that I mentioned on this side of the table. But it’s important to know what you’re taking so you can make the right appropriate actionable changes
[20:22] in your health and the safe changes that you need to make to optimize your health. the most I don’t know the exact legal setup and
[20:28] all the facts with these uh individuals but there is only one set of rules uh
[20:33] they are the federal rules that are administered by the FDA right so suggesting that something is you know
[20:39] pharmaceutical grade versus um intended for research only it it misses how
[20:45] things are legally classified and I think is slightly misleading the you’re
[20:50] either approved or you’re not okay that’s step one for the FDA and then unapproved D, you basically get placed
[20:57] into various different uh well, we’re on our way to approval. It’s okay. You know, here’s the public bulletin or holy
[21:04] cow, stay away from this one, like BPC 157. So, uh there is I mean there’s no
[21:10] secret that there is a lot of money and there are a lot of consumers for peptides period. I will just say that
[21:17] and acknowledge that because I think that’s why there’s a lot of pressure here. And I don’t think uh consumers or
[21:23] doctors are thrilled that the FDA is saying what it’s saying. I have, you
[21:29] know, no real uh input on that. But that doesn’t mean that you can supersede the
[21:35] FDA or argue with science, uh, you know, and and say, well, you know, best interest of the patient type arguments.
[21:42] And I also don’t like the fact that there aren’t any qualifiers on these videos. So, I would have liked to have
[21:49] seen more of a reference to, well, if you want to know more, please visit the FDA uh website and then boom, boom, here
[21:56] is the current list because I think that would give a lot more context. Um, how
[22:02] they actually got a hold of these peptide compounded peptides, I’m I’m I’m
[22:07] just going to assume we’re referencing BPC57, but that may not be the case. Uh, that’s my main question back to the
[22:15] video uh producers. So, uh, gray area, yellow area, I have a lot of questions.
[22:21] Period. No respectable compounding pharmacy is is compounding peptides. None. And
[22:26] because they know that it’s illegal to do so. Uh, so the ones the ones that these doctors are promoting are
[22:32] illegally obtained. It’s it’s not even a gray area. We both, you know, know that. So, a couple of things to piggyback on
[22:38] what you’ve said. So, I do think uh I hope I’m going to be wrong on this, but I do think you’re going to see uh a wave
[22:43] of lawsuits and it’s going to be a new avenue for pliff attorneys because once again, this been going on for a year or
[22:48] two or more now. And any problems that a person may have that’s going to blame it on that peptide, no defense for that
[22:54] prescriber. None at all. And that’s a dangerous spot to be in. And also, you mentioned the medical board. So, before
[23:00] our podcast today, I’m licensed in several states. So I did contact some representatives of several medical boards and asked them specifically about
[23:07] not FDA approved peptides for instance once again not standard of care. You’re risking your medical license suspension
[23:14] or revoke or being revoked by doing so. I don’t know why anybody works so hard
[23:19] to you know to get their medical license and degree and then willing to take such a risk to lose it. It just makes no
[23:25] sense to me. Um but nonetheless it is happening and I can’t say this enough. This is not antipeptides. uh you know
[23:32] GLP ones are wonderful. There’s some wonderful peptides out there, FDA approved ones that are miracle drugs, but we’re talking specifically about the
[23:38] non FDA approved ones uh that the FDA has put on the do not compound list. So, let me read from your from your website
[23:44] real quick uh just so they can get the you know that this straightforward response. So, you you in bold print you
[23:50] say can physicians prescribe non-FDA approved drugs and the answer is the short answer is no. Physicians may
[23:57] legally prescribe FDA approved drugs for either their approved uses or for other off label uses supported by medical
[24:03] judgment. But if a drug has never received FDA approval for any indication, it cannot be prescribed,
[24:09] dispensed, or marketed for patient care. Doing so is considered the use of an unapproved new drug which is prohibited
[24:16] under federal law and it can expose providers to FDA enforcement, state medical board discipline, and liability
[24:22] risk for providers. The critical takeaway is that administering or prescribing a substance classified as an
[24:28] unapproved new drug is a violation of federal law. This category includes many
[24:33] popular peptides and biologics marketed as research chemicals which lack FDA approval for any therapeutic use.
[24:40] Engaging in such activity can be deemed unprofessional conduct by state medical boards and may attract federal scrutiny.
[24:46] I don’t think you could have said it any more clearly in your in your in your website. I don’t know what more we can really say on the subject.
[24:52] Uh it took me a while to write. it succinctly. So, thank you. I appreciate it. It’s not easy to to write it. It
[24:58] seems like it. It’s uh I’ll go one step further too to your previous um because
[25:04] I see a lot of the loopholes that people believe are exceptions is just treating
[25:10] yourself as a health coach. So, I’m not using my medical license. I’m actually now, you know, magically relabeled
[25:16] myself quickly as a a coach. Um, I will say to this, uh, I will say this, um, it
[25:24] would be like, uh, somebody saying, “Oh, I’m not an attorney now. I’m just a lay person.” But I’m still going to give legal advice, right? That the FDA looks
[25:33] down to the intended use and what is actually being done. They’re not dumb. And on top of that, unlicensed practice
[25:41] of medicine, right, or unlicensed practice of X is usually uh also again a
[25:49] criminal offense as opposed to a civil offense, which is a bigger is a big deal. Damages, money is one thing. Jail
[25:56] a very different thing or the threat of jail. And so, um, magically saying that
[26:01] you’re a health coach or well, actually, I’m not prescribing. I’m just recommending or educating
[26:08] you need to be very careful in your belief system that that is a legal loophole and now you’re out of the reign
[26:14] of the FDA now that you’re not prescribing. So, I just want to hammer that home, too.
[26:20] I’m so glad you brought that up because what we’re seeing in this space especially are a lot of non-medical
[26:26] trained individuals that want to use the word as coaching and you hire them for coaching but what they’re actually doing
[26:32] is an interpreting your labs recommending dosage of different medic uh different hormones for instance or
[26:38] even other medications and they are actually practicing medicine without a license and uh no matter how many
[26:44] disclaimers they have no matter how many you know consent forms you may sign they’re not worth the paper they’re
[26:49] written on. Once you take money, interpret labs, give medical advice,
[26:55] especially with dosage or, you know, adding or subtracting certain drugs, you are practicing medicine, and it is a
[27:00] criminal offense. It’s it’s a felony in most states, if not all. And so, you’re seeing that a lot uh presently in our
[27:06] space as well. Yeah. Uh not a client of mine, and uh not, you know, uh but I can comment in
[27:13] general terms. Uh there was a a matter where uh basically a doctor um was using
[27:20] the health coach defense, we’ll call it, and uh the medical board when they received a complaint and that lawyer uh
[27:28] made the argument, well actually this you you don’t have jurisdiction because he is not using his medical license. And
[27:35] the medical board effectively their response was, you’re right, this is unlicensed practice of medicine. we’re
[27:41] going to refer to the attorney general’s office for criminal prosecution. So, it’s really a slap in the face when they
[27:47] tried to use a a loophole. But just to, you know, put that point home. Um,
[27:54] yeah. So, that’s So, so if you could look in the eye, any of my colleagues or, you know, other
[27:59] providers that are thinking about tomorrow starting to prescribe these non-FDA approved peptides, what would be
[28:07] the take-home message that you would tell them? Yeah, don’t do it unless you’re you’re willing to assume a lot of
[28:13] risk. Put your license on the line and also put yourself and your practice and
[28:18] your business on the line. Um, hold tight. I would say if you if this really
[28:24] is where you want to make your stand then uh you know lobby the FDA, go dig
[28:31] into the science and you know go talk to representatives but don’t put your as it
[28:37] currently stands as of the recording of this episode. Uh more guidance is needed unless you want to put your license on
[28:43] the line. That’s what I tell my colleagues and patients as well every day. I say look I I can’t tell you which of these non-FDA
[28:49] approved peptides work or don’t work. I’m not saying they work or they don’t work. I don’t have the medical studies
[28:54] in humans to tell you if they work or don’t work and what population they would work in versus one that they wouldn’t. So, we just don’t have the
[29:00] information. So, it’s not worth the medical license to do so. There are plenty other ways that we can, you know, improve people’s health without
[29:07] resorting to to presently what are known as research chemicals. So, what patients do on their own, that’s that’s on them.
[29:13] But what these doctors are getting, what the patients are getting, there’s really not any difference. you know, they can they can claim, well, I’ve got it from a
[29:19] special pharmacy and it’s much better than what you’re going to buy. No, they’re not. No, they’re not. They’re not. Yeah.
[29:25] So, um and so, but I really appreciate you sharing
[29:30] your knowledge with us today and I know you’re going to be doing some lectures uh coming up for for Worldink Medical and that’s going to be wonderful. I
[29:35] think that uh that we as physicians sometimes we we get busy in our practice. we don’t always, you know,
[29:42] understand the uh the consequences of our actions and uh especially when it comes to to doing along something like
[29:48] these peptides because if everybody’s doing it, it must be okay. That that’s kind of the the attitude they take and they certainly should be a little bit
[29:54] more cautious when it comes to these drugs. I would agree. I I don’t enjoy being the party pooper. I usually like to have
[30:00] the, you know, the workaround, the exception, the, you know, something that I can give a lot of the prospective
[30:06] clients in this category. But a lot of what that advice has centered around is
[30:13] okay, what you’re doing is technically illegal. How severe are the consequences and what does enforcement look like?
[30:19] Which effectively you’re going against legal advice. We’re approaching, you know, what I might consider a criminal
[30:27] defense attorney needed. But um that’s the value that I’m offering now. And uh
[30:34] a lot of people aren’t thrilled with what I say, but uh largely I’m just regurgitating what federal law says. I’m
[30:41] breaking it down. Read the blogs. Uh I always welcome feedback if uh I I’ll I’ll try and circle around the comments
[30:48] for this episode, too. But uh I take a very conservative reading of the rules.
[30:53] I will also say uh just this last week um I had a well more of a we’ll just say
[31:00] prospective client um get a large amount of um unapproved peptides effectively
[31:06] seized at customs. So they’re sitting on a ship right now. They’ll probably be destroyed and we’ll see I mean what what
[31:14] they need to do. uh it wouldn’t be something that I would work with, but the FDA is starting to seize unapproved
[31:20] peptides that are coming in through, you know, China, Korea, wherever at the border, and that is starting to become a
[31:26] um a bigger enforcement priority. That again is not a fun place to be because
[31:32] not only do you lose all the money that you use to try and work around the US uh
[31:38] pharmacies that are not allowed to do that, now you could potentially face federal prosecution. So, uh, just
[31:44] another thing that I remembered from last week. Well, let let me reiterate this is not anything anti-peptide. Those peptides
[31:52] have to approve are miracle and wonderful drugs. I am propeptid. Uh, what I’m trying to do is help protect my
[31:58] colleagues from themselves sometimes. And, uh, you know, once again, if a person has a problem with it, like you
[32:04] say, it could be criminal, civil, and deal with your medical boards. So, who wants to who wants to have to deal with
[32:09] that? Well, David, I cannot thank you enough for coming on and uh providing us with this valuable information that
[32:15] you’ve given us today. Uh I just I hope it helps so many providers or at least makes them think twice before they do
[32:21] anything to potentially harm not only their reputation but once again face any criminal uh civil or even even board uh
[32:28] actions. So if people want to learn more uh like I said, I refer your website to
[32:34] every one of my patients that ask about peptides. Now I say this is this is all correct information that that that Mr.
[32:39] Hold has on his website. Please go read it and you understand why I can’t write you a prescription for PPC127 or CJC1
[32:45] 1295. So this is why I can’t do it. And they all seem to be very understanding. I didn’t know that, doc. Nobody told me.
[32:50] Everybody’s doing it. I see it all over the YouTube and Tik Tok and Instagram. And I said, I know, but I I know you do.
[32:56] But uh but nonetheless, David, if people want to get in touch with you or if they want to learn more, how can we go about
[33:01] doing that? It’ probably be my website. So that’s the one with the blog you referenced. It’s just uh djholtlaw.com
[33:08] and uh in the search function or if you say DJ Holtaw peptide it’ll pro the the
[33:14] blogs that you want will probably be the top two search results. Uh I will note we work with the healthc care providers
[33:20] uh not the patients but we we always strive and we’re happy to have anyone read our resources and we do a really
[33:26] good job of keeping those uh updated as guidance comes out. And I’ll just say
[33:31] from a personal perspective, not an attorney perspective, uh I am very
[33:36] optimistic for what we could do with peptides in the health and wellness space being a a big wellness guy myself
[33:42] and benefiting quite a bit from supplements and uh you know working on
[33:48] my own health individually. So I I am a big fan. I I just from a legal
[33:54] perspective that’s my my allegiance is to my license which therefore is federal
[33:59] and state law. So happy to have people visit the blog. Well, I couldn’t agree with you more. And once again, my perspective is that I
[34:06] want doctors to be able to prescribe it in the future whenever it’s uh legal and
[34:11] we have all the studies and and they’re not putting their license at risk. So, thank you once again for coming on. I
[34:17] think it’s going to be valuable information. It’s been valuable information for me and I’m sure it’s going to be for many others. So, thank you once again.
[34:23] Thank you. Appreciate it.
