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The much-delayed public consultation on the Pittilo report has just opened.

It is very important that as many people as possible respond to it.  It’s easy to say that the consultation is sham. It will be if it is left only to acupuncturists and Chinese medicine people to respond to it. Please write to them before the closing date, November 2nd 2009. The way to send your evidence is here.

There is a questionnaire that you can complete, with the usual leading questions.  Best do it anyway, but I’d suggest also sending written evidence as attachment too. I just got from DoH the email address where you can send it. They said

 if you have material you wish to send which you can’t easily “shoehorn” into the questionnaire, please send it to the following mailbox: HRDListening@dh.gsi.gov.uk

Here are three documents that I propose to submit in response to the consultation.I ‘d welcome criticisms that might make it more convincing. Use any parts of them you want in your own response.

• Submission to the Department of Health, for the consultation on the Pittilo report [download pdf].
• $2.5B Spent, No Alternative Med Cures [download pdf]  I’ve written quite a lot about the Pittilo report already, in particular A very bad report: gamma minus for the vice-chancellor, and in The Times (see also the blog version). Intriguingly, these posts are at number 2 in a Google search for “Michael Pittilo”. Briefly, the back story is this. It is now over a year since the Report to Ministers from “The Department of Health Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK” [download the report]. The chair of the steering group was Professor R. Michael Pittilo, Principal and Vice-Chancellor of The Robert Gordon University, Aberdeen. The reason thet the report is so disastrously bad in its assessment of evidence is that it was written entirely by people with vested interests. The committee consisted of five acupuncturists, five herbalists and five representatives of traditional Chinese medicine (plus eleven observers). There was not a single scientist or statistician to help in the assessment of evidence. And it shows: The assessment of the evidence in the report was execrable. Every one of the committee members would have found themselves out of work if they had come to any conclusion other than that their treatment works, Disgracefully, these interests were not declared in the report, though they are not hard to find. The university of which the chair is vice-chancellor runs a course in homeopathy, the most discredited of the popular forms of alternative medicine. That tells you all you need to know about the critical faculties of Michael Pittilo. The two main recommendations of this Pittilo report are that • Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine should be subject to statutory regulation by the Health Professions Council • Entry to the register normally be through a Bachelor degree with Honours Let’s consider the virtue of these two recommendations. Regulation by the Health Professions Council (HPC) breaks their own rules For a start, this should be ruled out by the HPC’s own rules, which require “Practise based on evidence of efficacy” as a condition for registration. Since there is practically no “evidence of efficacy”, it follows that the HPC can’t regulate acupuncture, herbal and Chinese medicine as Pittilo recommends. Or so you’d think. But the official mind seems to have an infinite capacity for doublespeak. The HPC published a report on 11 September 2008, Regulation of Medical Herbalists, Acupuncturists and Traditional Chinese Medicine Practitioners. The report says 1. Medical herbalists, acupuncturists and traditional Chinese medicine practitioners should be statutorily regulated in the public interest and for public safety reasons. 2. The Health Professions Council is appropriate as the regulator for these professions. 3. The accepted evidence of efficacy overall for these professions is limited, but regulation should proceed because it is in the public interest. In other words, the HPC simply decided to ignore its own rules, Its excuse for doing so is that regulation would protect “public safety” . But it simply would not do that. It is ell known that some Chinese herbs are adulterated with dangerous substances, but laws against that already exist. Trading Standards are much more likely to take appropriate action than the HPC. The Medicines and Health Regulatory Authority (MHRA) already deals with the licensing of herbal medicines. and, despite the fact that it recently betrayed its trust by allowing them to be labelled in a misleading way, they are the people to do it, not the HPC. The Pittilo report (page 11) says In future, it is hoped that more Government funding can be allocated to research into traditional/herbal medicines and acupuncture and that grants will become available to encourage practitioners to undertake postgraduate research work. So they are asking for more government money. In March 2007, the Chinese Government pledged to spend over$130 million over the next five years on research into the effectiveness of traditional Chinese medicine. It is to be hoped that this money will be targeted effectively to evaluate TCM.

It seems to have escaped the notice of Pittilo that roughly 100 percent of trials of Chinese medicine done in China come out positive. Elsewhere, very few come out positive,(see Vickers et al., 1998, Controlled Clinical Trials, 19, 159-166: download reprint) The Department of Health would be unwise to rely on Chinese research. Remember that modern acupuncture was not so much a product of ancient wisdom, but rather it stems from nationalist propaganda by Mao Tse-Tung, who needed a cheap way to keep the peasants quiet, though he was too sensible to use it himself.

The HPC report (page 5) cites these with the words

” . . . a lack of evidence of efficacy should not prevent regulation but that the professions should be encouraged and funded to strengthen the evidence base.”

This sentence seems to assume that the outcomes of research will be to strengthen the evidence base. Thus far, precisely the opposite has been the case. The Pittilo group has apparently not noticed that the US National Institutes of Health has already spent a billion dollars on research in alternative medicine and failed to come up with a single effective treatment. There are better ways to spend money on health. See, for example $2.5B Spent, No Alternative Med Cures found. .An enornous amount of research has already been done and the outcomes have produced no good treatments, The proposed regulation would endanger the public, not protect it. The excuse given by the HPC for breaking its own rules is that it should do so to protect the public. Likewise Ann Keen, Health Minister, said: “Patient safety is paramount, whether people are accessing orthodox health service treatments or using alternative treatments” So first we need to identify what dangers are posed by acupuncture, herbal medicine and traditional Chinese medicine. • Acupuncture is fairly safe. Its biggest danger lies in the unjustified claims that are routinely made for what can be achieved by being impaled by needles. This poses a danger that people may use acupuncture in place of treatments that work • Herbal medicines are unstandardised, so even the very few that may work are dangerous to patients because the dose of active principle is unknown and varies from one batch to another. Taking a herbal medicine is a bit like swallowing a random number of tablets, False health claims pose a danger to patients too, when they cause patients to avoid treatments that work. • Traditional Chinese Medicine is probably the most dangerous. Like the other two, the medicines are unstandardised so the dose is never known. False health claims abound. And in addition to these dangers, many cases have been found of Chinese medicines being adulterated with poisonous substances or with conventional drugs. The form of regulation proposed by Pittilo would do little or nothing to protect the public from any of these dangers. The proposals accept the herbal and Chinese medicine as traditionally practised. Nothing would be done about one of the major dangers, the lack of standardisation. That is a problem that was solved by pharmacologists in the 1930s, when international standards were set for the biological activity of things like tincture of digitalis, and assays were devised so that different batches could be adjusted to the same potency. Now, 80 years later, it is being proposed by Pittilo that we should return to the standards of safety that existed at the beginning of the last century. That is a threat to public safety., but the proposed regulation would do nothing whatsoever to protect the public from this dangerous practice. On the contrary, it would give official government sanction to it. The other major danger is that patients are deceived by false health claims. This is dangerous (as well as dishonest) because it can cause patients to avoid treatments that work better, The internet abounds with claims that herbs can cure anything from diabetes to cancer. Many are doubtless illegal, but regulators like the HPC have traditionally ignored such claims: they are left to Trading Standards, Advertising Standards and the Medicines and Health Regulatory Authority (MHRA) to deal with. The MHRA already also has responsibility for monitoring side effects. The HPC would not do this. The analogy with chiropractic and the GCC The foolishness of allowing statutory regulation for unproven treatments has recently been illustrated quite dramatically by the case of chiropractic. Chiropractors have had statutory regulation by the General Chiropractic Council, which was established by the Chiropractors Act of 1994. The British Chiropractic Association (BCA) recently decided to sue the science writer, Simon Singh, for defamation when he cast doubt on some of the claims made by chiropractors, in particular their claims to be able to cure colic and asthma in children. That led to close examination of the claims. In fact there is no reason to think that spinal manipulation works for asthma, or that it works for colic. In fact there is quite good evidence that the claims are false. The result was that about 600 well-justified complaints have been lodged with the GCC (enough to bankrupt the GCC if the complaints are dealt with properly). The point of this story is that the statutory regulator had nothing whatsoever to prevent these false health claims being made. Two of the complaints concern practices run by the chair of the GCC. Worse, the GCC actually endorsed such claims. The statutory regulator saw its duty to defend chiropractic (apart from a handful of cases of sexual misdemeanours), not to protect the patient from false health claims. The respectability conferred by statutory regulation made false health claims easier and endangered the public. It would be a disaster if the same mistake were made again. On 11th December 2008 I got a letter form the HPC which said in our opinion a lack of evidence of efficacy would not impede our ability to set standards or deal with complaints we receive. The vast majority of cases we consider are related to conduct. But perhaps that is because they haven’t tried “regulating” quacks before. Now that the public is far more conscious about health fraud than it used to be, one can predict confidently that the HPC would be similarly overwhelmed by a deluge of complaints about the unjustified health claims made by acupuncturists, herbal medicine and traditional Chinese medicine practitioners. There is no shortage of them to complain about. The education problem The Pittilo report recommends that the entry level for registration should be a bachelors degree with honours. At first sight it seems reasonable to ask that practitioners should be ‘properly qualified’, but when one looks at what is actually taught on these degrees it becomes clear that they endanger, rather than protect, the public, There are two very big problems with this recommendation. Firstly, you can’t have a bachelors degree with honours until after you have decided whether or not there is anything useful to teach. If and when any of the subjects under consideration and shown to work to a useful extent, then it would be quite reasonable to establish degrees in them. Even the report does not pretend seriously that that stage has been reached. The proposal to set up degrees in subjects, at least some of which are quite likely to have no more than placebo value, is self-evidently nonsense, The time for degrees, and the time for government endorsement by statutory regulation, is after the therapies have been shown to work, not before. The absurdity of thinking that the public will be protected because a practitioner has a degree in, say, acupuncture, is shown with startling clarity by a recently revealed examination paper in acupuncture’ You can download the entire exam paper. Here are a few highlights from it. So students, in 2009, are being taught the crudest form of vitalism. Teaching of traditional Chinese medicine is just as bad. Here are two slides from a course run by the University of Westminster. The first ‘explains’ the mysterious and entirly mythical “Qi”. So “Qi” means breath, air, vapour, gas, energy, vitalism. This is meaningless nonsense. The second slide shows the real dangers posed by the way Chinese medicine is taught, The symptoms listed at the top could easily be a clue to serious illness, yat students are taught to treat them with ginger. Degrees like this endanger the public. There are more mind-boggling slides from lectures on Chinese medicine and cancer: they show that what students are being taught is terrifyingly dangerous to patients. It is entirely unacceptable that students are being taught these ancient myths as though they were true, and being encouraged to treat sick people on their basis. The effect of the Pittilo recommendations would be to force new generations of students to have this sort of thing forced on them. In fact the course for which this exam was set has already closed its doors. That is the right thing to do. Here’s another example. The course leader for “BSc (Hons) Herbal Medicine” at the Univsrsity of Central Lancashire is Graeme Tobyn BA. But Tobyn is not only a herbalist but also an astrologer. In an interview he said “At the end I asked her if I could cast her horoscope. She threw up her hands and said, ‘I knew this would happen if I came to an alternative practitioner.” “I think the ruler of the ascendant was applying to Uranus in the ninth house, which was very pertinent.” This would be preposterous even in the life style section of a downmarket women’s magazine, The Pittilo report wants to make degrees run my people like this compulsory. Luckily the Univerity of Central Lancashire is much more sensible and the course is being closed. The matter is, in any case, being taken out of the hands of the government by the fact that universities are closing degrees in complementary medicine, including courses in some of those under discussion here, The University of Salford and the University of Central Lancashire have recently announced the closure of all the degree programmes in complementary and alternative medicine. The largest provider of such degrees, the University of Westminster has already shut down two of them, and the rest are being assessed at the moment. It is likely that the rest will be closed in the future. The revelation that Westminster had been teaching its first year students that “amethysts emit high yin energy” and that students had been taught to diagnose disease and choose treatments by means of a dowsing pendulum, showed very clearly the sort of utter nonsense that undergraduates were being forced to learn to get a ‘bachelors degree with honours’. It stretches credulity to its limits to imagine that the public is protected by degrees like this. Precisely the opposite is true. The universities have recognised this, and shut the degrees. One exception is Professor Pittilo’s own university which continues to run a course in homeopathy, the most discredited of all the popular types alternative medicine. A simpler, more effective and cheaper way to protect the public I must certainly agree with the minister that protection of the public is an important matter. Having established that the Pittllo recommendations are more likely to endanger the public than protect them, it is essential to suggest alternative proposals that would work better. Luckily, that is easy, because mechanisms already exist for dealing with the dangers that were listed above. The matter of adulteration, which is serious in traditional Chinese medicine, is a matter that is already the responsibility of the Office of Trading Standards. The major problem of false claims being made for treatment is also the responsibility of the Office of Trading Standards, which has a statutory duty to enforce the Unfair Trading Consumer Protection Regulations of May 2008. These laws state, for example, that “One of the 31 commercial practices which are in all circumstances considered unfair is “falsely claiming that a product is able to cure illnesses, dysfunction or malformations” The monitoring of false claims, and of side effects of treatments, is also the responsibility of the Medicines and Health Regulatory Authority (MHRA). Rather than setting up complicated, expensive and ineffective ‘regulation’ by the HPC, all that need to be done is to ensure that the MHRA and/or Trading Standards have the funds to enforce existing laws. At the moment, they are not being implemented effectively, so I’d recommend that responsibility for enforcing the law against false health claims be transferred entirely to the MHRA, which has much more expertise in such matters than Trading Standards This would be both cheaper and more effective than the present system in which the responsibility is divided between the two organisations in an unclear way. This proposal would protect the public against unsafe and adulterated treatments, and it would protect the public against false and fraudulent claims. That is what matters. It would do so more effectively, more cheaply and more honestly than the Pittilo recommendations. There would be no reduction in patient choice either, There is no proposal to ban acupuncture, herbal medicine or traditional Chinese medicine. All that is necessary is to ensure that they don’t endanger the public. Since the root of the problem lies in the fact that the evidence for the effectiveness is very weak. the question of efficacy, and cost-benefit ratio, should be referred to NICE. This was recommended by the House of Lords Report (2000). It is recommended again by the Smallwood report (sponsored by the Prince of Wales Foundation). It is baffling that this has not been done already. It does not seem wise to spend large amounts of money on new research at the moment, in the light of the fact that the US National Institutes of Health has already spent over$1 billion on such research without finding a single useful treatment.

The results of all this research has been to show that hardly any alternative treatment are effective. That cannot be ignored.

Conclusion

Recent events show that the halcyon days for alternative medicine are over. When the Pittilo report first appeared, it was greeted with derision in the media. For example, in The Times Alice Miles wrote

“This week came the publication of the Report to Ministers from the Department of Health Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK. Otherwise known as twaddle.”

In the Independent, Dominic Lawson wrote

So now we will have degrees in quackery.

What, really, is the difference between acupuncture and psychic surgery?

People will no doubt continue to use it and that is their right and their responsibility. But if the government were to accept the recommendations of the Pittilo report it would be seen, quite rightly, as being anti-scientific and of posing a danger to the public.

Fortunately there is a better, and cheaper, way to protect the public.

### Follow-up

Margaret McCartney’s blog in the Financial Times puts rhw view of a GP with her usual sense, humour and incisiveness.

“This report would, if implemented, create lots more nonsense exam papers funded by a lot more public money – and would produce practitioners without the absolutely crucial skill of how to assess evidence and reject or use it appropriately”

The Times has covered the story (with some interesting comments) Consultation on how to regulate complementary and alternative therapies

Times Higher Education UK-wide consultation on CAM regulation is launched Excellent response from Andy Lewis.

The Sun has by far the best coverage up to now, Jane Symons writes “Regulating quacks helps them prey on gullible patients

## 36 Responses to Consultation opens on Pittilo report: help to stop Department of Health making fool of itself

• Lindy says:

I hope there is a chance of preventing this consultation being a total sham. Usually in these exercises the government has already decided on the course of action under scrutiny and I am afraid this won’t be much of an exception.

The report from the Dept of Health Working group on Extending Professional and Occupational Regulation (July 16th 2009) contains the following:

1.15 Government has also agreed to extend regulation to practitioners of acupuncture, herbal medicine, and traditional Chinese medicine practised in the UK. Much work has taken place concerning regulation of these practitioners over the last decade including a report from the House of Lords’ Committee on Science and technology and three Working Groups and a public consultation. The most recent Steering Group on Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK, who delivered their report to Ministers in the UK in June 2008, strongly recommended regulation of these groups in order to provide the public seeking such treatment with assurance of safe and competent practice. The Working Group understands that a public consultation on the issues raised by the Steering Group is imminent.

and at para 3.9
‘The Working Group recommends that, for fields of practice where benefits are unproven or controversial, there may nonetheless be a need for more formal regulation or registration because the treatments used pose a significant risk to patients and the public. The Working Group also agreed that, in any regulatory system, patients and the public should be able to have confidence in the health professionals who are registered within that system. It is therefore important that the expectations of the patients and public in terms of both the treatment being offered, and the evidence-base for that treatment, are well recognised and transparent’.

So a bit of logic and consistency won’t go amiss. A flood of scientific responses needed…………………

• zeno says:

I was going to do a short blog on it, but you beat me hands down with your knowledge of it! Excellent.

I may still write something about what Dixon has said about it.

• Julian Stirling says:

MHRA’s regulation is currently poor from my experience. I sent a complaint to trading standards about a Kalms advert that claimed they have been proven to help you sleep (yet an email to Kalms confirmed they had never even been tested). Trading standards replied that Kalms had permission to make the claim from the MHRA.

• @Julian Stirling
You have put your finger on one of the problems. Existing law is not really being enforced. Trading Standards still operates through local offices, which is rather absurd in the internet age, and they haven’t much experience of dealing with health claims. The plit between them and the MHRA doesn’t help either -each can blame the other for doing nothing, as you just found.

• twaza says:

The motivation for regulation seems to be safety, but the report offers no evidence that regulation prevents harm, and their list of possible incidents are all things that have occurred in regulated professions. By demonstrating that regulation does not remove all risk, they rather score an own goal.

Why pick on just three professions? The bogus practitioners that most need control can easily escape regulation by calling themselves something similar but different. For example, osteomyology for chiropractic, acupressure or reflexology for acupuncture; phytotherapy for herbal medicine. They can also escape the rules by using euphemisms and codewords such as: “help” instead of “treat”; “wellness” instead of “disease”; “is traditionally used” for is “effective and safe”.

• Lindy says:

These three are not the only ones wanting to be regulated. The report I mentioned in comment 1 above also lists nutritionists as wanting to be considered for regulation (page 17 Box D). In addition to which, the loosely defined training and qualifications that could qualify quacks for regulation are of course abysmal and dangerous.

The case of Dawn Page comes to mind (see this site http://www.dcscience.net/?p=384#more-384). She was ‘treated’ by nutritionist Barbara Nash who put her on a de-tox ‘super-hydration diet with disastrous consequences. But, as Ben G pointed out, Nash was only doing what she had been trained to do, and this case for damages was settled out of court.

I think there was a chiropractic case in which the ‘therapist’ was not found guilty of any misconduct or negligence because he was following normal practice. Please could someone remind me of this as it could be a useful example?

And yes, they do get round the rules on what they can claim by using silly words. ‘Supporting the immune system’ is one of the nutri-quacks’ favourites. It would be interesting to see how the judge in the Singh case might interpret such terminology if it came before him!

I am not sure where to start with responding to this stuff, it is so full of pitfalls and so lacking in logic. Depressing.

• […] Well, this is a real exam paper, and it isn’t funny. It is an exam paper from Salford University’s Traditional Chinese Medicine course. The wonderful David Colquhoun gives access to the full paper plus the story behind the Pittilo report.  […]

• Corkyb says:

The consultation seems flawed in part by not separating “the public” from “practitioners and businesses”. For example, question nine asks –

What would you estimate would be the regulatory burden and financial costs, to the public, to practitioners and to businesses, for the alternatives to statutory regulation suggested at Question 8?

It comes across as a leading question which is quite inappropriate. They might want to ask the question with regard the cost to humanity of potentially down-funding scientific research into chronic and terminal illnesses for the sake of casting a veneer of respectability to disproven and/or unscientific forms of treatment.

• Corkyb says:

While I’m here, what’s this about?

Q12: Would it be helpful to the public for these practitioners to be regulated in a way which differentiates them from the regulatory regime for mainstream professions publicly perceived as having an evidence base of clinical effectiveness? If so, why? If not, why not?

Well, er, yes, of course, but what’s this about “Publicly perceived”? It’s either evidence based or it isn’t! Was this written by a politician, or a staunch advocate of alt med, or both?!

• @Corkyb
Yes there are a lot of leading questions in the questionnaire. Only too typical of bureaucracy, I fear.
I think it would be better to send in a written response as well as, or instead of, the online questionnaire. DoH have promised to give me an email address to which attachments can be sent, and I’ll post it as soon as I get it (this afternoon I hope).

• Claire says:

just passing on a recent ref from SBM , which “…argues that if the effects of “real” and “sham” acupuncture do not significantly differ in well-conducted trials, it is because traditional theories for selecting points and means of stimulation are not based on an empirical rationale, but on ancient cosmology, astrology and mythology. These theories significantly resemble those that underlined European and Islamic astrological medicine and bloodletting in the Middle-Ages. In addition, the alleged predominance of acupuncture amongst the scholarly medical traditions of China is not supported by evidence, given that for most of China’s long medical history, needling, bloodletting and cautery were largely practiced by itinerant and illiterate folk-healers, and frowned upon by the learned physicians who favored the use of pharmacopoeia. …”

• The email address for responses to the Department of Health is now at the top of this post

• Anti-D says:

The only sensible response to this consultation is: show us the facts! Where is the evidence that herbal medicine (particularly the indigenous variety) poses a risk to the public? And, where is the evidence that SR itself is able to shield the public from said risk? As far as the Pittilo report and this Government are concerned, the facts are on Mars & we’re all living in Disneyland…

• Mojo says:

Looking at the questionnaire, I find there are several questions that are quite impossible to answer with the options they give, for example: “What do you envisage would be the benefit to the public, to practitioners and to businesses, associated with introducing statutory regulation?”, with a single set of “Significant benefit/Some benefit/No benefit/Unsure”. Personally, I suspect tha there would be little or no benefit to the public, but a considerable benefit to practitioners in the form of the spurious authority their therapies would gain as a result of statutory regulation (as if the govt. could legislate for them to be effective).

Hasn’t it occurred to the D’oH that the benefits may not be uniform for these three groups?

• Mojo
You are quite right. I don’t suppose that has occured to them because the whole mode of thinking (if that is the right word) seems to be dominated by the HR-like box-ticking mentality that brought us the Baby P tragedy.

I wonder whether Ben Goldacre’s description applies also to the DoH.

“My basic hypothesis is this: the people who run the media are humanities graduates with little understanding of science, who wear their ignorance as a badge of honour. Secretly, deep down, perhaps they resent the fact that they have denied themselves access to the most significant developments in the history of Western thought from the past two hundred years.” (Bad Science, Chapter 11, p. 207)

• hamletsghost says:

I’m pondering about the distinction in medical anthropology betweenhealing and curing. I think it is fully accepted that the way patients are treated as people, as well as the treatment regimes they are put on can have an effect. Does this qualify as pure placebo? I think while alternative therapies have no standing in any scientifici terms, people go to such practitioners because they get treated well as people, even if the treatment is a load of codswallop. And unless anti-woo practitionsers accept that that is a rational behaviour, they won’t get very far

• hamletsghost
If you have a minor self-limiting condition, the distinction between healing and curing doesn’t matter very much. if you have cancer or malaria then it matters a great deal. Being “treated well as a person” isn’t much help if you die.

I don’t think I would call it rational to visit an alternative practitioner unless you are sure that you have nothing serious.

There are sadly, quite a lot of things that real medicine still can’t help much with. Some of the people who are in this unfortunate situation will go to alternative medicine in desperation. If it makes them feel happier, then it is not a wholly unreasonable thing to do from the patients’ point of view. It seems to me that we need, in such cases, some sort of supportive and palliative healthcare worker who can cheer up the patient without resorting to ancient mumbo jumbo and dishonest degrees.

• Derrik says:

David

Were any University to try to open courses in CAM again, is there any prospect of organised opposition from academic scientists. I’m thinking of some kind of academic boycott. Possibly refusing your services as outside examiners, although I’m concerned that idea might impact unfairly on the students of such an institution.

It isn’t the nineties any more. Bloggers like yourself have made science based activism possible. The BCA has learnt to its cost what this movement is capable off. Perhaps it’s time to flex a little more muscle?

• Derrik
Sounds good to me. I’m not sure about the external examiner idea though. Courses that teach dangerous nonsense are not likely to ask you or me to be external examiners. They pick people who believe the dangerous nonsense. The idea that externals maintain standards is obviously farcical.

Perhaps we just need a few more people like Michael Eslea who are willing to stand up and be counted.

• Derrik says:

Ah, you missunderstand, which is probably to your credit as my example idea is fairly nasty. I was suggesting withdrawing external examination from these universities OTHER courses.

This is unacceptably cruel to students already involved at such universities. It would also isolate those within such institutions such as Michael who we would want to support.

I just think the academic community at its best is a self regulating democracy of ideas. There must be some way of exerting pressure on universities which might otherwise be coerced into providing BSc degrees in quackery by the DoH to provide their BSc entry level quacks.

• Derrik
Yes that would certainly be a bit extreme. There are some excellent people in places like Westminster, and of course they are pretty upset at having to live with nonsense degrees. Mostly, though, they feel too intimidated to say so openly, and that itself is an indictment of the administration in these universities.

What is really upsetting is that the QAA has positively hindered the effort to improve quality in these places, and Universities UK appears to be totally uninterested. Intellectual standards are being undermined right from the top.

• Dr Aust says:

No worries, David. The politlcal parties seem to be thinking about “enhanced” QAA type regimes, and “central standards trained external examiners” as part of making standards comparable, or whatever they were bleating on about last week.

Why does this prospect fill me with foreboding, I wonder? While the QAA has been a waste of time, a centralised neo-QAA with real powers would be far worse.

• Dr Aust
Yes, that did seem to be an amazingly daft suggestion. Usually Phil Willis is rather good. The objection to his idea is nothing to do with the desirability of the aims. It is just to do with the fact that the “super QAA” couldn’t possibly work. Are they going to check every slide and every exam? It is simply not achievable.

• […] sc_project=233721; sc_invisible=0; sc_partition=0; sc_security=""; ← Consultation opens on Pittilo report: help to stop Department of Health making fool of itself […]

• zeno says:

http://www.zenosblog.com/2009/08/regulating-nonsense.html

• Corkyb says:

Zeno –

Hoho, I love this from Dr Michael Dixon; “There is good evidence for herbal medicine, acupuncture and Chinese medicine in the treatment of some conditions but, as in all healthcare, these therapies require properly trained practitioners.”

What conditions is he referring to? Man flu?

• […] This post was Twitted by bengoldacre […]

• doschick says:

There are some good scientists and potential students at Westminster and yes, the intimidation re: criticising your own course is very real and pathetic. Not all complementary therapies are created equally, however, which is rarely addressed. There’s an interesting debate. In the University environment it is assumed I will embrace all of the crystal-waving, water memory horseshite, when all I want to do is look at evidence-based western herbal medicine. I hear the laughing, but yes there is some. Some manufacturers also take standardisation and quality control very seriously. Is there any hope for those of us who want to investigate a different option, yet apply the badscience principles. Some of us are even happy to admit when we’re wrong.

• @doschick
I’m not laughing at ;ll. I’m very aware that there are some good people in western herbal medicine but they don’t seem to be in charge and that must lead to a lot of internecine squabbling. Not good.

I’m interested in what you say about standardisation, because lack of standardisation seems to me one of the real problems with herbal stuff. Can you give us some details?

• twaza says:

This is the response that I have submitted to the public consultation on the Pitillo report.
================================

I am submitting my response by email because the questionnaire has been poorly designed and many questions will provide results that cannot be interpreted. For example, one question asks “What do you envisage would be the benefit to the public, to practitioners and to businesses, associated with introducing statutory regulation?”, and answers have to be chosen from the following alternatives: “Significant benefit/Some benefit/No benefit/Unsure”. This shows that questionnaire was designed and approved by people who could not conceive that statutory regulation is likely to be of benefit to the practitioners of acupuncture, herbal medicine, and traditional Chinese medicine, but of no benefit to the public.

I agree with Professor David Colquhoun’s submission, and will not repeat what he said, but will focus on three points he either did not mention or did not emphasize sufficiently.

First point: no evidence was produced that regulation could reduce the risk of dangerous practice.

The proposal provides no evidence that regulation will reduce the risk to the public from dangerous practitioners. All the examples of hazardous events and unethical behaviours have occurred (and, given human nature, will continue to occur) in the regulated healthcare professions. Yet no evidence was given that regulation has reduced the risk to patients and the public.

Second point: regulation cannot stop a practitioner continuing to practice.

The main sanction that a regulator can exercise on a dangerous practitioner is removal from the register. However, there is nothing to stop them continuing to their practice while calling it a different name such as acupressure, or osteomyotherapy, or Asian phytotherapy. There are already legal remedies for the public such as laws on assault, rape, and fraud, and institutions to protect the public such as the Advertising Standards Authority, Trading Standards Offices, and the MHRA. What is required is for these remedies and institutions be made to function more efficiently and effectively.

Third point: regulating acupuncture, herbal medicine, and traditional Chinese medicine would give the public the impression that these practices are effective, however, there is no good evidence for any of these practices.

Acupuncture is often mentioned as having the best evidence of effectiveness of these three practices. The best evidence that acupuncture is effective comes from pragmatic randomized controlled trials, for example(1, 2, 3). However these trials are not blinded. This means that the measured effects could be due to any combination of (i) a specific effect, (ii) non-specific (placebo) effects, and (iii) biases. There is good evidence that acupuncture is as effective as sham acupuncture, and this means that the specific effects of acupuncture are not clinically important(4). There is evidence from a large Cochrane systematic review that true placebo effects are of little or no clinical benefit(5). It is thus likely that the most important contribution to the measured effects in pragmatic trials of acupuncture come from cognitive biases. However, the evidence from the cognitive sciences on the risks of such biases is never considered by acupuncturists. Is this because it would be inconvenient?

References

(1) Longer term clinical and economic benefits of offering acupuncture care to patients with chronic low back pain. Thomas KJ, MacPherson H, Ratcliffe J, Thorpe L, Brazier J, Campbell M, Fitter M, Roman M, Walters S, Nicholl JP. Health Technol Assess. 2005 Aug;9(32):iii-iv, ix-x, 1-109.

(2) Acupuncture in patients with chronic low back pain: a randomized controlled trial. Brinkhaus B, Witt CM, Jena S, Linde K, Streng A, Wagenpfeil S, Irnich D, Walther HU, Melchart D, Willich SN. Arch Intern Med. 2006 Feb 27;166(4):450-7

(3) German Acupuncture Trials (GERAC) for chronic low back pain: randomized, multicenter, blinded, parallel-group trial with 3 groups. Haake M, Müller HH, Schade-Brittinger C, Basler HD, Schäfer H, Maier C, Endres HG, Trampisch HJ, Molsberger A. Arch Intern Med. 2007 Sep 24;167(17):1892-8. Erratum in: Arch Intern Med. 2007 Oct 22;167(19):2072.

(4) Acupuncture treatment for pain: systematic review of randomised clinical trials with acupuncture, placebo acupuncture, and no acupuncture groups. Madsen MV, Gøtzsche PC, Hróbjartsson A. BMJ. 2009 Jan 27;338:a3115

(5) Is the placebo powerless? Update of a systematic review with 52 new randomized trials comparing placebo with no treatment. Hróbjartsson A, Gøtzsche PC. J Intern Med. 2004 Aug;256(2):91-100

• […] should there be any question of giving them official government recognition in the form of ’statutory regulation’. The folly of doing that is illustrated […]

• mikekocan says:

Have filled in the questionnaire and agree that the questions were very leading.
I particularly liked the question asking if practitioners should have passed an English language test as a requirement for registration. Bearing in mind the bollocks they spout I think perhaps failing an English language test would be preferable.

• mikekocan
Agreed. I’d suggest that you send a separate document, to the email address above. That way you could give your opinion in your own words, rather than in their words.

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• […] announced what was happening. It seems that there may, after all, have been some effect of all the sensible submissions which pointed out the impossibility of regulating nonsense. The question of regulation has, yet […]

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