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Two weeks left to stop the Department of Health making a fool of itself. Email your response to tne Pittilo consultation to this email address HRDListening@dh.gsi.gov.uk

I’ve had permission to post a submission that has been sent to the Pittilo consultation. The whole document can be downloaded here. I have removed the name of the author. It is written by the person who has made some excellent contributions to this blog under the pseudonym "Allo V Psycho".

The document is a model of clarity, and it ends with constructive suggestions for forms of regulation that will, unlike the Pittilo proposals, really protect patients

Here is the summary. The full document explains each point in detail.

Executive Summary
Statutory regulation lends prestige, but needs to be balanced by a requirement for practitioners to be competent, as is the case for doctors and nurses. Regulation almost exclusively deals with conduct, but the unique risks posed by alternative medicine are not addressed by this. The harms which will arise from licensing practitioners who are not required to show evidence of competence and efficacy are:

  • Harm 1. Misdiagnosis of serious conditions.  Alternative practitioners offer to diagnose illnesses without proper training. This can lead to avoidable death, such as treating an ectopic pregnancy with ginger.
  • Harm 2. Withdrawal from treatment. Clients of alternative practitioners risk being encouraged to withdraw from life saving treatments in favours of treatments without evidence, as in the death of baby Gloria Thomas.
  • Harm 3. Harms arising from the nature of the alternative practice, but not covered by the regulatory framework, such as adulterated herbal remedies.
  • Harm 4.  Lack of informed consent. If alternative practitioners are not required to study or show evidence of efficacy, how can they inform patients of their options?
  • Harm 5. Equity. Doctors and nurses have to use evidence based methods, but it is proposed that alternative practitioners are not held to this standard. Is this fair? Health Minsters should ask themselves if they advocate withdrawing the requirement for evidence based treatment from doctors and nurses. If not, why not? And if not, why should alternative practitioners be treated differently?
  • Harm 6. Promotion of irrationality. If no evidence of efficacy is required, where do you draw the line? Witch doctoring is a ‘traditional practice’ in communities in the UK, and astrology is used by some herbal healers.
  • Harm 7. Opportunity Costs. If no evidence of efficacy is required of alternative medicine, significant sums will be wasted by individuals and by the NHS.
  • Harm 8. Reputational harms for UK Higher Education. UK Honours Degrees are based on the ability to think critically and to assess evidence. Alternative medicine Degree programmes do not require this. These positions are not compatible.
  • Harm 9.  Health care futures. We are making slow but steady progress on health indicators through the use of evidence based methods. Why should the requirement for evidence be abandoned now?

Instead, safe regulation of alternative practitioners should be through:

  • The Medicines and Healthcare Products Regulatory Agency
  • The Office of Trading Standards via the Unfair Trading Consumer Protection Regulations,
  • A new Health Advertising Standards Authority, modelled on the successful Cancer Act 1939.

The first two recommendations for effective regulation are much the same as mine, but the the third one is interesting. The problem with the Cancer Act (1939), and with the Unfair Trading regulations, is that they are applied very erratically. They are the responsibility of local Trading Standards offices, who have, as a rule, neither the expertise nor the time to enforce them effectively. A Health Advertising Standards Authority could perhaps take over the role of enforcing existing laws. But it should be an authority with teeth. It should have the ability to prosecute. The existing Advertising Standards Authority produces, on the whole, excellent judgements but it is quite ineffective because it can do very little.

A letter from an acupuncturist

I had a remarkable letter recently from someone who actually practises acupuncture. Here are some extracts.

“I very much enjoy reading your Improbable Science blog. It’s great to see good old-fashioned logic being applied incisively to the murk and spin that passes for government “thinking” these days.”

“It’s interesting that the British Acupuncture Council are in favour of statutory regulation. The reason is, as you have pointed out, that this will confer a respectability on them, and will be used as a lever to try to get NHS funding for acupuncture. Indeed, the BAcC’s mission statement includes a line “To contribute to the development of healthcare policy both now and in the future”, which is a huge joke when they clearly haven’t got the remotest idea about the issues involved.”

“Before anything is decided on statutory regulation, the British Acupuncture Council is trying to get a Royal Charter. If this is achieved, it will be seen as a significant boost to their respectability and, by implication, the validity of state-funded acupuncture. The argument will be that if Physios and O.T.s are Chartered and safe to work in the NHS, then why should Chartered Acupuncturists be treated differently? A postal vote of 2,700 BAcC members is under-way now and they are being urged to vote “yes”. The fact that the Privy Council are even considering it, is surprising when the BAcC does not even meet the requirement that the institution should have a minimum of 5000 members (http://www.privy-council.org.uk/output/Page45.asp). Chartered status is seen as a significant stepping-stone in strengthening their negotiating hand in the run-up to statutory regulation.”

“Whatever the efficacy of acupuncture, I would hate to see scarce NHS resources spent on well-meaning, but frequently gormless acupuncturists when there’s no money for the increasing costs of medical technology or proven life-saving pharmaceuticals.”

“The fact that universities are handing out a science degree in acupuncture is a testament to how devalued tertiary education has become since my day. An acupuncture degree cannot be called “scientific” in any normal sense of the term. The truth is that most acupuncturists have a poor understanding of the form of TCM taught in P.R.China, and hang on to a confused grasp of oriental concepts mixed in with a bit of New Age philosophy and trendy nutritional/life-coach advice that you see trotted out by journalists in the women’s weeklies. This casual eclectic approach is accompanied by a complete lack of intellectual rigour.

My view is that acupuncturists might help people who have not been helped by NHS interventions, but, in my experience, it has very little to do with the application of a proven set of clinical principles (alternative or otherwise). Some patients experience remission of symptoms and I’m sure that is, in part, bound up with the psychosomatic effects of good listening, and non-judgemental kindness. In that respect, the woolly-minded thinking of most traditional acupuncturists doesn’t really matter, they’re relatively harmless and well-meaning, a bit like hair-dressers. But just because you trust your hairdresser, it doesn’t mean hairdressers deserve the Privy Council’s Royal Charter or that they need to be regulated by the government because their clients are somehow supposedly “vulnerable”.”

Earlier postings on the Pittilo recommendations

A very bad report: gamma minus for the vice-chancellor http://www.dcscience.net/?p=235

Article in The Times (blame subeditor for the horrid title)
http://www.timesonline.co.uk/tol/comment/columnists/guest_contributors/article4628938.ece

Some follow up on The Times piece
http://www.dcscience.net/?p=251

The Health Professions Council breaks its own rules: the result is nonsense
http://www.dcscience.net/?p=1284

Chinese medicine -acupuncture gobbledygook revealed
http://www.dcscience.net/?p=1950

Consultation opens on the Pittilo report: help top stop the Department of Health making a fool of itself  http://www.dcscience.net/?p=2007

Why degrees in Chinese medicine are a danger to patients  http://www.dcscience.net/?p=2043

One month to stop the Department of Health endorsing quackery.  The Pittilo questionnaire, http://www.dcscience.net/?p=2310
 

Follow-up

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12 Responses to An excellent submission to the consultation on statutory regulation of alternative medicine (Pittilo report)

  • The suggestion to extend Trading Standards regulation along the lines of the Cancer Act 1939 is an excellent one.

    Many alt-med pseudo-regulators, such as the Society of Homeopaths, have clauses in their ethics code that forbid offering to treat named diseases. The problem is that these bodies never enforce such infringement by allowing weasle wording such as “they were offering to treat the whole person not just the named disease”.

    There is a tension between those that might advocate banning all pseudo-medical diagnosis and treatments (such as in France) and the more libertarian ‘British way’ of allowing everything not specifically banned. An extended Cancer Act is a good half-way house that would allow prosecution of those that make unsubstantaited claims without explicit banning of the practices of alt med, such as sticking burning candles in your ears, digging pins into you, consuming herbs and ingesting sugar pills.

    A decent British compromise? I think so.

  • Yes, but one of the problems with having legislation like the Cancer Act 1939 is that is rarely used in anger.

  • The acupuncturist’s statement above highlights one very important aspect of acupuncture practice in this country: “The truth is that most acupuncturists have a poor understanding of the form of TCM taught in P.R.China”.

    I believe this is exactly what NHS physiotherapists do (my tribe). In defense of doctors, the British Medical Society of Acupuncture (BMAS) advocates ‘Western ‘ acupuncture and argues on the basis of evidence based practice (however weak this base may be).

    Ironically the British Acupuncture Society, that represents licentiate trained TCM acupuncturists, is not at all happy with UK physiotherapists dabbling in half-baked TCM.

    I believe UK physiotherapists should stick to Western Acupuncture. The evidence may be weak, but the theories of endorphin production and pain gating have at least some scientific basis, albeit not overwhelming.

  • Allo V Psycho really has said all that needs to be said.

    One must worry, though, that in the scales of public policy decision-making it may only count as just one more contribution, whereas its quality means that it should be recognised as having greater weight than an infinite number of pro-woo advocacy submissions.

    Do you know, David, whether the raw material of the submissions will be made public in due course?

  • @BadlyShavedMonkey
    Very good question. I have no idea if responses will be made public in this case, though might be obtainable under Freedom of Info, if not.

    No doubt they will have been deluged with responses from herbalists etc, as urged on various quack sites. They might, though, be influenced a bit by the internecine warfare that is so common among quacks. As of today, 1726 herbalists have voted against the proposals.

  • @DC
    I wish to add another comment. The acupuncturist above rightly worries that if BCA acupuncturists gain chartered status they may demand to provide services in the NHS. He says there are over 2000 members of the BCA.

    Indeed they are, but there are already 10,000 physiotherapists in the UK delivering acupuncture, mostly in the NHS.

    Fortunately physiotherapists are taught medicine to a fairly high level (although obviously not to the standard of doctors).

    Nevertheless they have the ability to identify ‘red flags’ in patients that might need more expert medical attention. Would BCA members have that level of training?

    I am not against NHS physios using acupuncture, but as I mention in a previous comment above, it worries me that many of them apply TCM concepts or assume that the clinical evidence for any form of acupuncture is strong, when it clearly isn’t.

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