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‘We know little about the effect of diet on health. That’s why so much is written about it’. That is the title of a post in which I advocate the view put by John Ioannidis that remarkably little is known about the health effects if individual nutrients. That ignorance has given rise to a vast industry selling advice that has little evidence to support it.

The 2016 Conference of the so-called "College of Medicine" had the title "Food, the Forgotten Medicine". This post gives some background information about some of the speakers at this event. I’m sorry it appears to be too ad hominem, but the only way to judge the meeting is via the track record of the speakers.

Quite a lot has been written here about the "College of Medicine". It is the direct successor of the Prince of Wales’ late, unlamented, Foundation for Integrated Health. But unlike the latter, its name is disguises its promotion of quackery. Originally it was going to be called the “College of Integrated Health”, but that wasn’t sufficently deceptive so the name was dropped.

For the history of the organisation, see

The new “College of Medicine” arising from the ashes of the Prince’s Foundation for Integrated Health

Don’t be deceived. The new “College of Medicine” is a fraud and delusion

The College of Medicine is in the pocket of Crapita Capita. Is Graeme Catto selling out?

The conference programme (download pdf) is a masterpiece of bait and switch. It is a mixture of very respectable people, and outright quacks. The former are invited to give legitimacy to the latter. The names may not be familiar to those who don’t follow the antics of the magic medicine community, so here is a bit of information about some of them.

The introduction to the meeting was by Michael Dixon and Catherine Zollman, both veterans of the Prince of Wales Foundation, and both devoted enthusiasts for magic medicne. Zollman even believes in the battiest of all forms of magic medicine, homeopathy (download pdf), for which she totally misrepresents the evidence. Zollman works now at the Penny Brohn centre in Bristol. She’s also linked to the "Portland Centre for integrative medicine" which is run by Elizabeth Thompson, another advocate of homeopathy. It came into being after NHS Bristol shut down the Bristol Homeopathic Hospital, on the very good grounds that it doesn’t work.

Now, like most magic medicine it is privatised. The Penny Brohn shop will sell you a wide range of expensive and useless "supplements". For example, Biocare Antioxidant capsules at £37 for 90. Biocare make several unjustified claims for their benefits. Among other unnecessary ingredients, they contain a very small amount of green tea. That’s a favourite of "health food addicts", and it was the subject of a recent paper that contains one of the daftest statistical solecisms I’ve ever encountered

"To protect against type II errors, no corrections were applied for multiple comparisons".

If you don’t understand that, try this paper.
The results are almost certainly false positives, despite the fact that it appeared in Lancet Neurology. It’s yet another example of broken peer review.

It’s been know for decades now that “antioxidant” is no more than a marketing term, There is no evidence of benefit and large doses can be harmful. This obviously doesn’t worry the College of Medicine.

Margaret Rayman was the next speaker. She’s a real nutritionist. Mixing the real with the crackpots is a standard bait and switch tactic.

Eleni Tsiompanou, came next. She runs yet another private "wellness" clinic, which makes all the usual exaggerated claims. She seems to have an obsession with Hippocrates (hint: medicine has moved on since then). Dr Eleni’s Joy Biscuits may or may not taste good, but their health-giving properties are make-believe.

Andrew Weil, from the University of Arizona
gave the keynote address. He’s described as "one of the world’s leading authorities on Nutrition and Health". That description alone is sufficient to show the fantasy land in which the College of Medicine exists. He’s a typical supplement salesman, presumably very rich. There is no excuse for not knowing about him. It was 1988 when Arnold Relman (who was editor of the New England Journal of Medicine) wrote A Trip to Stonesville: Some Notes on Andrew Weil, M.D..

“Like so many of the other gurus of alternative medicine, Weil is not bothered by logical contradictions in his argument, or encumbered by a need to search for objective evidence.”

This blog has mentioned his more recent activities, many times.

Alex Richardson, of Oxford Food and Behaviour Research (a charity, not part of the university) is an enthusiast for omega-3, a favourite of the supplement industry, She has published several papers that show little evidence of effectiveness. That looks entirely honest. On the other hand, their News section contains many links to the notorious supplement industry lobby site, Nutraingredients, one of the least reliable sources of information on the web (I get their newsletter, a constant source of hilarity and raised eyebrows). I find this worrying for someone who claims to be evidence-based. I’m told that her charity is funded largely by the supplement industry (though I can’t find any mention of that on the web site).

Stephen Devries was a new name to me. You can infer what he’s like from the fact that he has been endorsed byt Andrew Weil, and that his address is "Institute for Integrative Cardiology" ("Integrative" is the latest euphemism for quackery). Never trust any talk with a title that contains "The truth about". His was called "The scientific truth about fats and sugars," In a video, he claims that diet has been shown to reduce heart disease by 70%. which gives you a good idea of his ability to assess evidence. But the claim doubtless helps to sell his books.

Prof Tim Spector, of Kings College London, was next. As far as I know he’s a perfectly respectable scientist, albeit one with books to sell, But his talk is now online, and it was a bit like a born-again microbiome enthusiast. He seemed to be too impressed by the PREDIMED study, despite it’s statistical unsoundness, which was pointed out by Ioannidis. Little evidence was presented, though at least he was more sensible than the audience about the uselessness of multivitamin tablets.

Simon Mills talked on “Herbs and spices. Using Mother Nature’s pharmacy to maintain health and cure illness”. He’s a herbalist who has featured here many times. I can recommend especially his video about Hot and Cold herbs as a superb example of fantasy science.

Annie Anderson, is Professor of Public Health Nutrition and
Founder of the Scottish Cancer Prevention Network. She’s a respectable nutritionist and public health person, albeit with their customary disregard of problems of causality.

Patrick Holden is chair of the Sustainable Food Trust. He promotes "organic farming". Much though I dislike the cruelty of factory farms, the "organic" industry is largely a way of making food more expensive with no health benefits.

The Michael Pittilo 2016 Student Essay Prize was awarded after lunch. Pittilo has featured frequently on this blog as a result of his execrable promotion of quackery -see, in particular, A very bad report: gamma minus for the vice-chancellor.

Nutritional advice for patients with cancer. This discussion involved three people.
Professor Robert Thomas, Consultant Oncologist, Addenbrookes and Bedford Hospitals, Dr Clare Shaw, Consultant Dietitian, Royal Marsden Hospital and Dr Catherine Zollman, GP and Clinical Lead, Penny Brohn UK.

Robert Thomas came to my attention when I noticed that he, as a regular cancer consultant had spoken at a meeting of the quack charity, “YestoLife”. When I saw he was scheduled tp speak at another quack conference. After I’d written to him to point out the track records of some of the people at the meeting, he withdrew from one of them. See The exploitation of cancer patients is wicked. Carrot juice for lunch, then die destitute. The influence seems to have been temporary though. He continues to lend respectability to many dodgy meetings. He edits the Cancernet web site. This site lends credence to bizarre treatments like homeopathy and crystal healing. It used to sell hair mineral analysis, a well-known phony diagnostic method the main purpose of which is to sell you expensive “supplements”. They still sell the “Cancer Risk Nutritional Profile”. for £295.00, despite the fact that it provides no proven benefits.

Robert Thomas designed a food "supplement", Pomi-T: capsules that contain Pomegranate, Green tea, Broccoli and Curcumin. Oddly, he seems still to subscribe to the antioxidant myth. Even the supplement industry admits that that’s a lost cause, but that doesn’t stop its use in marketing. The one randomised trial of these pills for prostate cancer was inconclusive. Prostate Cancer UK says "We would not encourage any man with prostate cancer to start taking Pomi-T food supplements on the basis of this research". Nevertheless it’s promoted on Cancernet.co.uk and widely sold. The Pomi-T site boasts about the (inconclusive) trial, but says "Pomi-T® is not a medicinal product".

There was a cookery demonstration by Dale Pinnock "The medicinal chef" The programme does not tell us whether he made is signature dish "the Famous Flu Fighting Soup". Needless to say, there isn’t the slightest reason to believe that his soup has the slightest effect on flu.

In summary, the whole meeting was devoted to exaggerating vastly the effect of particular foods. It also acted as advertising for people with something to sell. Much of it was outright quackery, with a leavening of more respectable people, a standard part of the bait-and-switch methods used by all quacks in their attempts to make themselves sound respectable. I find it impossible to tell how much the participants actually believe what they say, and how much it’s a simple commercial drive.

The thing that really worries me is why someone like Phil Hammond supports this sort of thing by chairing their meetings (as he did for the "College of Medicine’s" direct predecessor, the Prince’s Foundation for Integrated Health. His defence of the NHS has made him something of a hero to me. He assured me that he’d asked people to stick to evidence. In that he clearly failed. I guess they must pay well.

### Follow-up

This post was written for the Spectator Health section, at short notice after the release of the spider letters. The following version is almost the same as appeared there, with a few updates. Some of the later sections are self-plagiarised from earlier posts.

Picture: Getty

The age of enlightenment was a beautiful thing. People cast aside dogma and authority. They started to think for themselves. Natural science flourished. Understanding of the natural world increased. The hegemony of religion slowly declined. Eventually real universities were created and real democracy developed. The modern world was born.

People like Francis Bacon, Voltaire and Isaac Newton changed the world for the better. Well, that’s what most people think. But not Charles, Prince of Wales and Duke of Cornwall.

In 2010 he said

"I was accused once of being the enemy of the Enlightenment,” he told a conference at St James’s Palace. “I felt proud of that.” “I thought, ‘Hang on a moment’. The Enlightenment started over 200 years ago. It might be time to think again and review it and question whether it is really effective in today’s conditions."

It seems that the Prince preferred things as they were before 1650. That’s a remarkable point of view for someone who, if he succeeds, will become the patron of that product of the age of enlightenment, the Royal Society, a venture that got its Royal Charter from King Charles II in1622.

I suppose that the Prince cannot be blamed for his poor education. He may have been at Trinity College Cambridge, his 2.2 degree is the current euphemism for a fail (it seems that he even failed to learn the dates of the enlightenment).

His behaviour has brought to the fore the question of the role of the monarchy.

A constitutional monarch is purely ceremonial and plays no part in politics. Well actually in the UK it isn’t quite as simple as that. The first problem is that we have no constitution. Things haven’t changed much since the 19th century when Walter Bagehot said “the Sovereign has, under a constitutional monarchy… three rights—the right to be consulted, the right to encourage, the right to warn.”.

These are real powers in a country which is meant to be run by elected representatives. But nobody knows how these powers are used: it is all done in secret. Well, almost all. The Prince of Wales has been unusually public in expressing his views. His views bear directly on government policy in many areas: medicine, architecture, agriculture and the environment. These are mostly areas that involve at least an elementary knowledge of science. But that is something that he lacks. Worse still, he seems to have no consciousness of his ignorance.

The Royal family should clearly have no influence whatsoever on government policies in a democracy. And they should be seen to have no influence. The Queen is often praised for her neutrality, but the fact is that nobody has the slightest idea what happens at the weekly meetings between the Prime Minister and the Queen. I doubt that she advises the prime minister to create a National Health Service, or to tax the rich. We shall never know that. We should do.

Almost the only light that has been thrown on the secret activities of Charles was the release, on 13 May, of 27 letters that the Prince wrote to government ministers in the Blair government between 2004 and 2005. It has take 10 years of effort by the Guardian to get hold of the letters. It was ike getting blood from a stone. When the Information Commissioner ruled that the letters should be made public, the decision was vetoed by the Conservative attorney general, Dominic Grieve. He said. of the "particularly frank" letters,

" Disclosure of the correspondence could damage The Prince of Wales’ ability to perform his duties when he becomes King."

That, of course, is precisely why the documents should be revealed.

If Charles’ ability to perform his duty as King is damaged, should his subjects be kept unaware of that fact? Of course not.

In this case, the law prevailed over the attorney general. After passing through the hands of 16 different judges, the Supreme Court eventually ruled, in March, that the government’s attempts to block release were unlawful. The government spent over £400,000 in trying, and failing, to conceal what we should know. The Freedom of Information Act (2000) is the best thing that Tony Blair did, though he, and Jack Straw, thought it was the worst. I expect they are afraid of what it might reveal about their own records. Transparency is not favoured by governments of any hue.

What do the letters say?

You can read all the letters on the Guardian web site. They give the impression of being written by a rather cranky old man with bees in his bonnet and too much time on his hands. The problem is that not all cranky old men can write directly to the prime minister, and get an answer.

Not all the letters are wrong headed. But all attempt to change government policy. They represent a direct interference in the political process by the heir to the throne. That is unacceptable in a democracy. It disqualifies him from becoming king.

Some letters verged on the bizarre.

 21 October 2004 To Elliot Morley (Minister for the Environment) I particularly hope that the illegal fishing of the Patagonian Toothfish will be high on your list of priorities because until the trade is stopped, there is little hope for the poor old albatross.

No doubt illegal fishing is a problem, but not many people would write directly to a minister about the Patagonian Toothfish.

Others I agree with. But they are still attempts to influence the policies of the elected government. This one was about the fact that supermarkets pay so little to dairy farmers for milk that sometimes it’s cheaper than bottled water.

 To Tony Blair 8 September 2004 ". . . unless United Kingdom co-operatives can grow sufficiently the processors and retailers will continue to have the farmers in an arm lock and we will continue to shoot ourselves in the foot! You did kindly say that you would look at this . . . ". Yours ever, Charles

He wrote to the minister of education to try to influence education policy.

 22 February 2005 Ruth Kelly "I understand from your predecessor, Charles Clarke, that he has spoken to you about my most recent letter of 24th November, and specifically about the impact of my Education Summer School for teachers of English and History. This Programme, which involves up to ninety state school teachers each year, has been held over the past three years in Dartington, Devon, at Dunston, in Norfolk and at Buxton, in Derbyshire. I believe that they have added fresh inspiration to the national debate about the importance of English Literature and History in schools." Despite having made substantial progress, as you may be aware I remain convinced that the correct approaches to teaching and learning need to be challenged

It’s interesting that the meeting was in Dartington. That’s near Totnes ("twinned with Narnia") and it’s a centre for the bizarre educational cult promoted by the mystic and racist, Rudolf Steiner.

Then we get a reference to one of Charles’ most bizarre beliefs, alternative medicine.

 24 February 2005 Tony Blair Dear Prime Minister,  We briefly mentioned the European Union Directive on Herbal Medicines, which is having such a deleterious effect on complementary medicine sector in this country by effectively outlawing the use of certain herbal extracts. I think we both agreed this was using a sledgehammer to crack a nut. You rightly asked me what could be done about it and I am asking the Chief Executive of my Foundation for Integrated Health to provide a more detailed briefing which I hope to be able to send shortly so that your advisers can look at it. Meanwhile, I have given Martin Hurst a note suggesting someone he could talk to who runs the Herbal Practitioner’s Association. Yours ever, Charles

In this he opposes the EU Directive on Herbal Medicines. All this directive did was to insist that there was some anecdotal evidence for the safety of things that are sold to you. It asked for no evidence at all that they work, and it allowed very misleading labels. It provided the weakest form of protection from the deluded and charlatans. It was put into effect in the UK by the Medicines and Healthcare Products Regulatory Authority (MHRA). They even allowed products that were registered under this scheme to display an impressive-looking “kite-mark”. Most people would interpret this as a government endorsement of herbal medicines.

This got a sympathetic response from Tony Blair, someone who, along with his wife, was notoriously sympathetic to magic medicine.

 30 March 2005 Response from Tony Blair Dear Prince Charles Thanks too for your contacts on herbal medicines who have been sensible and constructive. They feel that the directive itself is sound and the UK regulators excellent, but are absolutely correct in saying that the implementation as it is currently planned is crazy. We can do quite a lot here: we will delay implementation for all existing products to 2011; we will take more of the implementation upon ourselves; and I think we can sort out the problems in the technical committee – where my European experts have some very good ideas. We will be consulting with your contacts and others on the best way to do this we simply cannot have burdensome regulation here. Yours ever, Tony

Note "absolutely correct in saying that the implementation as it is currently planned is crazy. We can do quite a lot here: we will delay implementation for all existing products to 2011".

Government support for acupuncture and herbal medicine was made explicit in a letter from Health Secretary, John Reid (February 2005). He assures the prince that government is taking action to "enhance the status of the herbal medicine and acupuncture professions".

Nothing could reveal more clearly the clueless attitude of the then government to quackery. In fact, after 15 years of wrangling, the promised recognition of herbalism by statutory regulation never happened. One is reminded of the time that an equally-clueless minister, Lord (Phillip) Hunt, referred to ‘psychic surgery’ as a “profession”.

We got a preview of the Prince’s letters a month before the release when Max Hastings wrote in the Spectator

I have beside me a copy of a letter allegedly written by him some years ago to a cultural institution, asserting the conviction that ‘there is a DIVINE Source which is ultimate TRUTH… that this Truth can be expressed by means of numbers… and that, if followed correctly, these principles can be expressed with infinite variety to produce Beauty’.

You can’t get much barmier than that.

Are the letters harmless?

That has been the reaction on the BBC. I can’t agree. In one sense they so trivial that it’s amazing that the government thought it was a good use of £400,000 to conceal them. But they are all the evidence that we’ll get of the Prince’s very direct attempts to influence the political process.

The Prince of Wales is more than just a crank. He has done real harm. Here are some examples.

When the generally admirable NHS Choices re-wrote their advice on homeopathy (the medicines that contain no medicine) the new advice took two years to appear. It was held up in the Department of Health while consultations were made with the Prince’s Foundation for Integrated Health. That’s Charles’ lobby organisation for crackpot medicine. (The word "integrated" is the euphemism for alternative medicine that’s in favour with its advocates.) If it were not for the fact that I used the Freedom of Information Act to find out what was going on, the public would have been given bad advice as a direct result of the Prince’s political interference.

The Prince’s Foundation for Integrated Health (FIH) folded in 2010 as a result of a financial scandal, but it was quickly reincarnated as the "College of Medicine". It was originally going to be named the College of Integrated Medicine, but it was soon decided that this sounded too much like quackery, so it was given the deceptive name, College of Medicine. It appears to be financed by well-known outsourcing company Capita. It’s closely connected with Dr Michael Dixon, who was medical advisor to the FIH, and who tried to derail the advice given by NHS Choices.

Perhaps the worst example of interference by the Prince of Wales, was his attempt to get an academic fired. Prof Edzard Ernst is the UK’s foremost expert on alternative medicine. He has examined with meticulous care the evidence for many sorts of alternative medicine.Unfortunately for its advocates, it turned out that there is very little evidence that any of it works. This attention to evidence annoyed the Prince, and a letter was sent from Clarence House to Ernst’s boss, the vice-chancellor of the University of Exeter, Steve Smith. Shamefully, Smith didn’t tell the prince to mind his ow business, but instead subjected Ernst to disciplinary proceedings, After subjecting him to a year of misery, he was let off with a condescending warning letter, but Ernst was forced to retire early. In 2011and the vice-chancellor was rewarded with a knighthood. His university has lost an honest scientist but continues to employ quacks.

Not just interfering but costing taxpayers’ money

The Prince’s influence seems to be big in the Department of Health (DH).  He was given £37,000 of taxpayers’ money to produce his Patients’ Guide (I produced a better version for nothing). And he was paid an astonishing £900,000 by DH to prepare the ground for the setting up of the hapless self-regulator, the Complementary and Natural Healthcare Council (CNHC, also known as Ofquack).

The Prince of Wales’ business, Duchy Originals, has been condemned by the Daily Mail, (of all places) for selling unhealthy foods. And when his business branched into selling quack “detox” and herbal nonsense he found himself censured by both the MHRA and the Advertising Standards Authority (ASA) for making unjustifiable medical claims for these products.

It runs in the family

The Prince of Wales is not the only member of the royal family to be obsessed with bizarre forms of medicine. The first homeopath to the British royal family, Frederick Quin, was a son of the Duchess of Devonshire (1765-1824).  Queen Mary (1865-1953), wife of King George V, headed the fundraising efforts to move and expand the London Homeopathic Hospital.  King George VI was so enthusiastic that in 1948 he conferred the royal title on the London Homeopathic Hospital.

The Queen Mother loved homeopathy too (there is no way to tell whether this contributed to her need for a colostomy in the 1960s).

The present Queen’s homeopathic physician is Peter Fisher, who is medical director of what, until recently was called the Royal London Homeopathic Hospital (RLHH).  In 2010 that hospital was rebranded as the Royal London Hospital for Integrated medicine (RLHIM) in another unsubtle bait and switch move.

The RLHIM is a great embarrassment to the otherwise excellent UCLH Trust.  It has been repeatedly condemned by the Advertising Standards Authority for making false claims.  As a consequence, it has been forced to withdraw all of its patient information.

The patron of the RLHIM is the Queen, not the Prince of Wales.  It is hard to imagine that this anachronistic institution would still exist if it were not for the influence, spoken or unspoken, of the Queen.  Needless to say we will never be told.

The royal warrant for a firm that sells "meningitis vaccine" that contains nothing

Ainsworth’s homeopathic pharmacy is endorsed by both Prince Charles and the Queen: it has two Royal Warrants, one from each of them.  They sell “homeopathic vaccines” for meningitis, measles, rubella and whooping cough. These “vaccines” contain nothing whatsoever so they are obviously a real danger to public health.

Despite the fact that Ainsworth’s had already been censured by the ASA in 2011 for selling similar products, Ainsworth’s continued to recommend them with a “casual disregard for the law”.

The regulator (the MHRA) failed to step in to stop them until it was eventually stirred into action by a young BBC reporter, Sam Smith who made a programme for BBC South West.  Then, at last, the somnolent regulator was stirred into action.  The MHRA “told Ainsworths to stop advertising a number of products” (but apparently not to stop making them or selling them).

They still sell Polonium metal 30C and Swine Meningitis 36C, and a booklet that recommends homeopathic “vaccination”.

Ainsworth’s sales are no doubt helped by the Royal Warrants.  The consequence is that people may die of meningitis. In 2011, the MHRA Chief Executive Professor Kent Woods, was knighted. It was commented, justly, that

"Children will be harmed by this inaction. Children will die. And the fault must lie with Professor Sir Kent Woods, chairman of the regulator "

But the regulator has to fight the political influence of the Queen and Prince Charles. They lost.

The attorney general, while trying to justify the secrecy of Charles’ letters, said

“It is a matter of the highest importance within our constitutional framework that the Monarch is a politically neutral figure”.

Questions about health policy are undoubtedly political, and the highly partisan interventions of the Prince in the political process make his behaviour unconstitutional.

The Prince’s petulant outbursts not only endanger patients. They endanger the monarchy itself.  Whether that matters depends on how much you value the tourist business generated by the Gilbert & Sullivan flummery at which royals excel.

The least that one can ask of the royal family is that they should not endanger the health of the nation. It would help if they refrained from using their influence on matters that are beyond their intellectual grasp..

If I wanted to know the winner of the 2.30 at Ascot, I’d ask a royal. For any other question I’d ask someone with more education.

### Follow-up

The Times had a front page story "Revealed: how Charles got Blair to alter health policy" [pdf]

The British Medical Journal wrote "Prince Charles delayed regulation of herbal medicines" [pdf]

For me, the most shocking item was an interview given by Jack Straw, on Radio 4’s Today Programme. He was Home Secretary from 1997 to 2001 and Foreign Secretary from 2001 to 2006 under Tony Blair. From 2007 to 2010 he was Lord Chancellor. His response to the letters sounded like that of a right-wing conservative.

Like Blair. he deplored the Freedom of Information Act that his own government passed. He defended the secrecy, and supported the Conservative attorney-general’s attempt to veto the release of the letters. Perhaps his defence of secrecy is not surprising, He has a lot to hide, His involvement in the mendacity that led to the Iraq war, the dodgy dossier, his role in covering up torture (the "rendition" scandal). And He was suspended by the Labour party in February 2015 due to allegation of cash bribes.

He is certainly a man with plenty of things to hide.

Listen to the interview, with John Humphrys

The Scottish Universities Medical Journal asked me to write about the regulation of alternative medicine. It’s an interesting topic and not easy to follow because of the veritable maze of more than twenty overlapping regulators and quangos which fail utterly to protect the public against health fraud. In fact they mostly promote health fraud. The paper is now published, and here is a version with embedded links (and some small updates).

We are witnessing an increasing commercialisation of medicine. It’s really taken off since the passage of the Health and Social Security Bill into law. Not only does that mean having NHS hospitals run by private companies, but it means that “any qualified provider” can bid for just about any service.  The problem lies, of course, in what you consider “qualified” to mean.  Any qualified homeopath or herbalist will, no doubt, be eligible.  University College London Hospital advertised for a spiritual healer. The "person specification" specified a "quallfication", but only HR people think that a paper qualification means that spiritual healing is anything but a delusion.

### The vocabulary of bait and switch

First, a bit of vocabulary.  Alternative medicine is a term that is used for medical treatments that don’t work (or at least haven’t been shown to work).  If they worked, they’d be called “medicine”.  The anti-malarial, artemesinin, came originally from a Chinese herb, but once it had been purified and properly tested, it was no longer alternative.  But the word alternative is not favoured by quacks.  They prefer their nostrums to be described as “complementary” –it sounds more respectable.  So CAM (complementary and alternative medicine became the politically-correct euphemism.  Now it has gone a stage further, and the euphemism in vogue with quacks at the moment is “integrated” or “integrative” medicine.  That means, very often, integrating things that don’t work with things that do.  But it sounds fashionable.  In reality it is designed to confuse politicians who ask for, say, integrated services for old people.

Put another way, the salespeople of quackery have become rather good at bait and switch. The wikepedia definition is as good as any.

Bait-and-switch is a form of fraud, most commonly used in retail sales but also applicable to other contexts. First, customers are “baited” by advertising for a product or service at a low price; second, the customers discover that the advertised good is not available and are “switched” to a costlier product.

As applied to the alternative medicine industry, the bait is usually in the form of some nice touchy-feely stuff which barely mentions the mystical nonsense. But when you’ve bought into it you get the whole panoply of nonsense. Steven Novella has written eloquently about the use of bait and switch in the USA to sell chiropractic, acupuncture, homeopathy and herbal medicine: "The bait is that CAM offers legitimate alternatives, the switch is that it primarily promotes treatments that don’t work or are at best untested and highly implausible.".

The "College of Medicine" provides a near-perfect example of bait and switch. It is the direct successor of the Prince of Wales’ Foundation for Integrated Health. The Prince’s Foundation was a consistent purveyor of dangerous medical myths. When it collapsed in 2010 because of a financial scandal, a company was formed called "The College for Integrated Health". A slide show, not meant for public consumption, said "The College represents a new strategy to take forward the vision of HRH Prince Charles". But it seems that too many people have now tumbled to the idea that "integrated", in this context, means barmpottery. Within less than a month, the new institution was renamed "The College of Medicine". That might be a deceptive name, but it’s a much better bait. That’s why I described the College as a fraud and delusion.

Not only did the directors, all of them quacks, devise a respectable sounding name, but they also succeeded in recruiting some respectable-sounding people to act as figureheads for the new organisation. The president of the College is Professor Sir Graham Catto, emeritus professor of medicine at the University of Aberdeen. Names like his make the bait sound even more plausible. He claims not to believe that homeopathy works, but seems quite happy to have a homeopathic pharmacist, Christine Glover, on the governing council of his college. At least half of the governing Council can safely be classified as quacks.

So the bait is clear. What about the switch? The first thing to notice is that the whole outfit is skewed towards private medicine: see The College of Medicine is in the pocket of Crapita Capita. The founder, and presumably the main provider of funds (they won’t say how much) is the huge outsourcing company, Capita. This is company known in Private Eye as Crapita. Their inefficiency is legendary. They are the folks who messed up the NHS computer system and the courts computer system. After swallowing large amounts of taxpayers’ money, they failed to deliver anything that worked. Their latest failure is the court translation service.. The president (Catto), the vice president (Harry Brunjes) and the CEO (Mark Ratnarajah) are all employees of Capita.

The second thing to notice is that their conferences and courses are a bizarre mixture of real medicine and pure quackery. Their 2012 conference had some very good speakers, but then it had a "herbal workshop" with Simon Mills (see a video) and David Peters (the man who tolerates dowsing as a way to diagnose which herb to give you). The other speaker was Dick Middleton, who represents the huge herbal company, Schwabe (I debated with him on BBC Breakfast), In fact the College’s Faculty of Self-care appears to resemble a marketing device for Schwabe.

### Why regulation isn’t working, and can’t work

There are various levels of regulation. The "highest" level is the statutory regulation of osteopathy and chiropractic. The General Chiropractic Council (GCC) has exactly the same legal status as the General Medical Council (GMC). This ludicrous state of affairs arose because nobody in John Major’s government had enough scientific knowledge to realise that chiropractic, and some parts of osteopathy, are pure quackery,

The problem is that organisations like the GCC function more to promote chiropractic than to regulate them. This became very obvious when the British Chiropractic Association (BCA) decided to sue Simon Singh for defamation, after he described some of their treatments as “bogus”, “without a jot of evidence”.

In order to support Singh, several bloggers assessed the "plethora of evidence" which the BCA said could be used to justify their claims. When, 15 months later, the BCA produced its "plethora" it was shown within 24 hours that the evidence was pathetic. The demolition was summarised by lawyer, David Allen Green, in The BCA’s Worst Day.

In the wake of this, over 600 complaints were made to the GCC about unjustified claims made by chiropractors, thanks in large part to heroic work by two people, Simon Perry and Allan Henness. Simon Perry’s Fishbarrel (browser plugin) allows complaints to be made quickly and easily -try it). The majority of these complaints were rejected by the GCC, apparently on the grounds that chiropractors could not be blamed because the false claims had been endorsed by the GCC itself.

My own complaint was based on phone calls to two chiropractors, I was told such nonsense as "colic is down to, er um, faulty movement patterns in the spine". But my complaint  never reached the Conduct and Competence committee because it had been judged by a preliminary investigating committee that there was no case to answer. The impression one got from this (very costly) exercise was that the GCC was there to protect chiropractors, not to protect the public.

The outcome was a disaster for chiropractors, wno emerged totally discredited. It was also a disaster for the GCC which was forced to admit that it hadn’t properly advised chiropractors about what they could and couldn’t claim. The recantation culminated in the GCC declaring, in August 2010, that the mythical "subluxation" is a "historical concept " "It is not supported by any clinical research evidence that would allow claims to be made that it is the cause of disease.". Subluxation was a product of the fevered imagination of the founder of the chiropractic cult, D.D. Palmer. It referred to an imaginary spinal lesion that he claimed to be the cause of most diseases. .Since ‘subluxation’ is the only thing that’s distinguished chiropractic from any other sort of manipulation, the admission by the GCC that it does not exist, after a century of pretending that it does, is quite an admission.

The President of the BCA himself admitted in November 2011

“The BCA sued Simon Singh personally for libel. In doing so, the BCA began one of the darkest periods in its history; one that was ultimately to cost it financially,”

As a result of all this, the deficiencies of chiropractic, and the deficiencies of its regulator were revealed, and advertisements for chiropractic are somewhat less misleading. But this change for the better was brought about entirely by the unpaid efforts of bloggers and a few journalists, and not at all by the official regulator, the GCC. which was part of the problem. not the solution. And it was certainly not helped by the organisation that is meant to regulate the GCC, the Council for Health Regulatory Excellence (CHRE) which did nothing whatsoever to stop the farce.

At the other end of the regulatory spectrum, voluntary self-regulation, is an even worse farce than the GCC. They all have grand sounding "Codes of Practice" which, in practice, the ignore totally.

The Society of Homeopaths is just a joke. When homeopaths were caught out recommending sugar pills for prevention of malaria, they did nothing (arguably such homicidal advice deserves a jail sentence).

The Complementary and Natural Healthcare Council (CNHC) is widely know in the blogosphere as Ofquack. I know about them from the inside, having been a member of their Conduct and Competence Committee, It was set up with the help of a £900,000 grant from the Department of Health to the Prince of Wales, to oversee voluntary self-regulation. It fails utterly to do anything useful.. The CNHC code of practice, paragraph 15 , states

When Simon Perry made a complaint to the CNHC about claims being made by a CNHC-registered reflexologist, the Investigating Committee upheld all 15 complaints.  But it then went on to say that there was no case to answer because the unjustified claims were what the person had been taught, and were made in good faith.
This is precisely the ludicrous situation which will occur again and again if reflexologists (and many other alternative therapies) are “accredited”.  The CNHC said, correctly, that the reflexologist had been taught things that were not true, but then did nothing whatsoever about it apart from toning down the advertisements a bit. They still register reflexologists who make outrageously false claims.

Once again we see that no sensible regulation is possible for subjects that are pure make-believe.

The first two examples deal (or rather, fail to deal) with regulation of outright quackery. But there are dozens of other quangos that sound a lot more respectable.

European Food Standards Agency (EFSA). One of the common scams is to have have your favourite quack treatment classified as a food not as a medicine. The laws about what you can claim have been a lot laxer for foods. But the EFSA has done a pretty good job in stopping unjustified claims for health benefits from foods. Dozens of claims made by makers of probiotics have been banned. The food industry, needless to say, objects very strongly to be being forced to tell the truth. In my view, the ESFA has not gone far enough. They recently issued a directive about claims that could legally be made. Some of these betray the previously high standards of the EFSA. For example you are allowed to say that "Vitamin C contributes to the reduction of tiredness and fatigue" (as long as the product contains above a specified amount of Vitamin C. I’m not aware of any trials that show vitamin C has the slightest effect on tiredness or fatigue, Although these laws do not come into effect until December 2012, they have already been invoked by the ASA has a reason not to uphold a complaint about a multivitamin pill which claimed that it “Includes 8 nutrients that can contribute to the reduction in tiredness and fatigue”

The Advertising Standards Authority (ASA). This is almost the only organisation that has done a good job on false health claims. Their Guidance on Health Therapies & Evidence says

"Whether you use the words ‘treatment’, ‘treat’ or ‘cure’, all are likely to be seen by members of the public as claims to alleviate effectively a condition or symptom. We would advise that they are not used"

"Before and after’ studies with little or no control, studies without human subjects, self-assessment studies and anecdotal evidence are unlikely to be considered acceptable"

"Before and after’ studies with little or no control, studies without human subjects, self-assessment studies and anecdotal evidence are unlikely to be considered acceptable"

They are spot on.

The ASA’s Guidance for Advertisers of Homeopathic Services is wonderful.

"In the simplest terms, you should avoid using efficacy claims, whether implied or direct,"

"To date, the ASA has have not seen persuasive evidence to support claims that homeopathy can treat, cure or relieve specific conditions or symptoms."

That seems to condemn the (mis)labelling allowed by the MHRA as breaking the rules.. Sadly, though, the ASA has no powers to enforce its decisions and only too often they are ignored. The Nightingale collaboration has produced an excellent letter that you can hand to any pharmacist who breaks the rules

The ASA has also judged against claims made by "Craniosacral therapists" (that’s the lunatic fringe of osteopathy). They will presumably uphold complaints about similar claims made (I’m ashamed to say) by UCLH Hospitals.

The private examination company Edexcel sets exams in antiscientific subjects, so miseducating children. The teaching of quackery to 16 year-olds has been approved by a maze of quangos, none  of which will take responsibility, or justify their actions. So far I’ve located no fewer than eight of them. The Office of the Qualifications and Examinations Regulator (OfQual), Edexcel, the Qualifications and Curriculum Authority (QCA), Skills for Health, Skills for Care, National Occupational Standards (NOS), private exam company VTCT and the schools inspectorate, Ofsted.. Asking any of these people why they approve of examinations in imaginary subjects meets with blank incomprehension. They fail totally to protect tha public from utter nonsense.

The Department of Education has failed to do anything about the miseducation of children in quackery. In fact it has encouraged it by, for the first time, giving taxpayers’ money to a Steiner (Waldorf) school (at Frome, in Somerset). Steiner schools are run by a secretive and cult-like body of people (read about it). They teach about reincarnation, karma, gnomes, and all manner of nonsense, sometimes with unpleasant racial overtones. The teachers are trained in Steiner’s Anthroposophy, so if your child gets ill at school they’ll probably get homeopathic sugar pills. They might well get measles or mumps too, since Steiner people don’t believe in vaccination.

Incredibly, the University of Aberdeen came perilously close to appointing a chair in anthroposophical medicine. This disaster was aborted by bloggers, and a last minute intervention from journalists. Neither the university’s regulatory mechanisms. nor any others, seemed to realise that a chair in mystical barmpottery was a bad idea.

It is the statutory duty of Trading Standards to enforce the Consumer Protection Regulations (2008) This European legislation is pretty good. it caused a lawyer to write " Has The UK Quietly Outlawed “Alternative” Medicine?". Unfortunately Trading Standards people have consistently refused to enforce these laws. The whole organisation is a mess. Its local office arrangement fails totally to deal with the age of the internet. The situation is so bad that a group of us decided to put them to the test. The results were published in the Medico-Legal Journal, Rose et al., 2012. "Spurious Claims for Health-care Products: An Experimental Approach to Evaluating Current UK Legislation and its Implementation". They concluded "EU directive 2005/29/EC is
largely ineffective in preventing misleading health claims for consumer products in
the UK"

Skills for Health is an enormous quango which produces HR style "competences" for everything under the son. They are mostly quite useless. But those concerned with alternative medicine are not just useless. They are positively harmful. Totally barmy. There are competences and National Occupational Standards for every lunatic made-up therapy under the sun. When I phoned them to discover who’d written them, I learned that the had been drafted by the Prince of Wales’ Foundation for Magic Medicine. And when I joked by asking if they had a competence for talking to trees, I was told, perfectly seriously, “You’d have to talk to LANTRA, the land-based organisation for that.”

That was in January 2008. A lot of correspondence with the head of Skills for Health got nowhere at all. She understood nothing and it hasn’t improved a jot.

This organisation costs a lot of taxpayers’ money and it should have been consigned to the "bonfire of the quangos" (but of course there was no such bonfire in reality). It is a disgrace.

The Quality Assurance Agency (QAA) is supposed to ensure the quality of university courses. In fact it endorses courses in nonsense alternative medicine and so does more harm than good. The worst recent failure of the QAA was in the case of the University of Wales: see Scandal of the University of Wales and the Quality Assurance Agency. The university was making money by validating thousands of external degrees in everything from fundamentalist theology to Chinese Medicine. These validations were revealed as utterly incompetent by bloggers, and later by BBC Wales journalist Ciaran Jenkins (now working for Channel 4).

The mainstream media eventually caught up with bloggers. In 2010, BBC1 TV (Wales) produced an excellent TV programme that exposed the enormous degree validation scam run by the University of Wales. The programme can be seen on YouTube (Part 1, and Part 2). The programme also exposed, incidentally, the uselessness of the Quality Assurance Agency (QAA) which did nothing until the scam was exposed by TV and blogs. Eventually the QAA sent nine people to Malaysia to investigate a dodgy college that had been revealed by the BBC. The trip cost £91,000. It could have been done for nothing if anyone at the QAA knew how to use Google.

The outcome was that the University of Wales stopped endorsing external courses, and it was soon shut down altogether (though bafflingly, its vice-chancellor, Marc Clement was promoted). The credit for this lies entirely with bloggers and the BBC. The QAA did nothing to help until the very last moment.

Throughout this saga Universities UK (UUK), has maintained its usual total passivity. They have done nothing whatsoever about their members who give BSc degrees in anti-scientific subjects. (UUK used to known as the Committee of Vice-Chancellors and Principals).

Council for Health Regulatory Excellence (CHRE), soon to become the PSAHSC,

Back now to the CHRE, the people who failed so signally to sort out the GCC. They are being reorganised. Their consultation document says

"The Health and Social Care Act 20122 confers a new function on the Professional Standards Authority for Health and Social Care (the renamed Council for Healthcare Regulatory Excellence). From November 2012 we will set standards for organisations that hold voluntary registers for people working in health and social care occupations and we will accredit the register if they meet those standards. It will then be known as an ‘Accredited Register’. "

They are trying to decide what the criteria should be for "accreditation" of a regulatory body. The list of those interested has some perfectly respectable organisations, like the British Psychological Society. It also contains a large number of crackpot organisations, like Crystal and Healing International, as well as joke regulators like the CNHC.

They already oversee the Health Professions Council (HPC) which is due to take over Herbal medicine and Traditional Chinese Medicine, with predictably disastrous consequences.

Two of the proposed criteria for "accreditation" appear to be directly contradictory.

Para 2.5 makes the whole accreditation pointless from the point of view of patients

2.5 It will not be an endorsement of the therapeutic validity or effectiveness of any particular discipline or treatment.

Since the only thing that matters to the patient is whether the therapy works (and is safe), accrediting of organisations that ignore this will merely give the appearance of official approval of crystal healing etc etc. This appears to contradict directly

A.7 The organisation can demonstrate that there either is a sound knowledge base underpinning the profession or it is developing one and makes that explicit to the public.

A "sound knowledge base", if it is to mean anything useful at all, means knowledge that the treatment is effective. If it doesn’t mean that, what does it mean?

It seems that the official mind has still not grasped the obvious fact that there can be no sensible regulation of subjects that are untrue nonsense. If it is nonsense, the only form of regulation that makes any sense is the law.

Please fill in the consultation. My completed return can be downloaded as an example, if you wish.

Medicines and Healthcare products Regulatory Agency (MHRA) should be a top level defender of truth. Its strapline is

"We enhance and safeguard the health of the public by ensuring that medicines and medical devices work and are acceptably safe."

The MHRA did something (they won’t tell me exactly what) about one of the most cruel scams that I’ve ever encountered, Esperanza Homeopathic Neuropeptide, peddled for multiple sclerosis, at an outrageous price ( £6,759 for 12 month’s supply). Needless to say there was not a jot of evidence that it worked (and it wasn’t actually homeopathic).

The MHRA admit (when pushed really hard) that there is precious little evidence that any of the herbs work, and that homeopathy is nothing more than sugar pills. Their answer to that is to forget that bit about "ensuring that medicines … work"

Here’s the MHRA’s Traditional Herbal Registration Certificate for devils claw tablets.

The wording "based on traditional use only" has to be included because of European legislation. Shockingly, the MHRA have allowed them to relegate that to small print, with all the emphasis on the alleged indications. The pro-CAM agency NCCAM rates devil’s claw as "possibly effective" or "insufficient evidence" for all these indications, but that doesn’t matter because the MHRA requires no evidence whatsoever that the tablets do anything. They should, of course, added a statement to this effect to the label. They have failed in their duty to protect and inform the public by allowing this labelling.

But it gets worse. Here is the MHRA’s homeopathic marketing authorisation for the homeopathic medicinal product Arnicare Arnica 30c pillules

It is nothing short of surreal.

Since the pills contain nothing at all, they don’t have the slightest effect on sprains, muscular aches or bruising. The wording on the label is exceedingly misleading.

If you "pregnant or breastfeeding" there is no need to waste you doctor’s time before swallowing a few sugar pills.

"Do not take a double dose to make up for a missed one". Since the pills contain nothing, it doesn’t matter a damn.

"If you overdose . . " it won’t have the slightest effect because there is nothing in them

And it gets worse. The MHRA-approved label specifies ACTIVE INGREDIENT. Each pillule contains 30c Arnica Montana

No, they contain no arnica whatsoever.

It truly boggles the mind that men with dark suits and lots of letters after their names have sat for hours only to produce dishonest and misleading labels like these.

When this mislabeling was first allowed, it was condemned by just about every scientific society, but the MHRA did nothing.

### The Nightingale Collaboration.

This is an excellent organisation, set up by two very smart skeptics, Alan Henness and Maria MacLachlan. Visit their site regularly, sign up for their newsletter Help with their campaigns. Make a difference.

### Conclusions

The regulation of alternative medicine in the UK is a farce. It is utterly ineffective in preventing deception of patients.

Such improvements as have occurred have resulted from the activity of bloggers, and sometime the mainstream media. All the official regulators have, to varying extents, made things worse.

The CHRE proposals promise to make matters still worse by offering "accreditation" to organisations that promote nonsensical quackery. None of the official regulators seem to be able to grasp the obvious fact that is impossible to have any sensible regulation of people who promote nonsensical untruths. One gets the impression that politicians are more concerned to protect the homeopathic (etc, etc) industry than they are to protect patients.

Deception by advocates of alternative medicine harms patients. There are adequate laws that make such deception illegal, but they are not being enforced. The CHRE and its successor should restrict themselves to real medicine. The money that they spend on pseudo-regulation of quacks should be transferred to the MHRA or a reformed Trading Standards organisation so they can afford to investigate and prosecute breaches of the law. That is the only form of regulation that makes sense.

### Follow-up

The shocking case of the continuing sale of “homeopathic vaccines” for meningitis, rubella, pertussis etc was highlighted in an excellent TV programme by BBC South West. The failure of the MHRA and the GPC do take any effective action is a yet another illustration of the failure of regulators to do their job. I have to agree with Andy Lewis when he concludes

“Children will die. And the fault must lie with Professor Sir Kent Woods, chairman of the regulator.”

Although many university courses in quackery have now closed, two subjects that hang on in a few places are western herbalism, and traditional Chinese medicine (including acupuncture). The University of Westminster still runs Chinese medicine, and Western herbal medicine (with dowsing). So do the University of Middlesex and University of East London.

Since the passing of the Health and Social Security Act, these people have been busy with their customary bait and switch tactics, trying to get taxpayers’ money. It’s worth looking again at the nonsense these people talk.

Take for example, the well known herbalist, Simon Mills. At one time he was associated with the University of Exeter, but no longer. Perhaps his views are too weird even for their Third Gap section (the folks who so misrepresented their results in a trial of acupuncture). Unsurprisingly, he was involved in the late Prince’s Foundation for Magic Medicine, and, unsurprisingly, he is involved with its successor, the "College of Medicine", where he spoke along similar lines. You can get a good idea about his views from the video of a talk that he gave at Schumacher College in 2005. It’s rather long, and exceedingly uncritical, so here’s a shorter version to which some helpful captions have been added.

That talk is weird by any standards. He says, apparently with a straight face, that "all modern medicines are cold in the third degree"..And with ginger and cinnamon "You can stop a cold, generally speaking, in its tracks" (at 21′ 30" in the video). This is simply not true, but he says it, despite the fact that the Plant Medicine with site (of which he’s a director) which he is associated gives them low ratings

Simon Mills is also a director of SustainCare. Their web site says

SustainCare Community Interest Company is a social enterprise set up to return health care to its owners: “learning to look after ourselves and our families in ways that make sense and do not cost the earth“. It is founded on the principle that one’s health is a personal story, and that illness is best managed when we make our health care our own. The enterprise brings clinical expertise, long experience of academia, education and business, and the connections and resources to deliver new approaches.

"As its own social enterprise contribution to this project Sustaincare set up and supported Café Sustain as a demonstration Intelligent Waiting Room at Culm Valley Integrated Centre for Health in Devon". (yes, that’s Michael Dixon, again]

In the talk (see video) Mills appears to want to take medicine back to how it was 1900 years ago, in the time of Galen. The oblique speaking style is fascinating. He never quite admits that he thinks all that nonsense is true, but presumably it is how he treats patients. Yet a person with these bizarre pre-scientific ideas is thought appropriate to advise the MHRA

It’s characteristic of herbalists that they have a very long list of conditions for which each herb is said to be good. The sort of things said by Mills differ little from the 1900-year old ideas of Galen, io the 17th century ideas of Culpepper.

You can see some of the latter in my oldest book, Blagrave’s supplement to Culpepper’s famous herbal, published in 1674.

See what he has to say about daffodils

It is "under the dominion of Mars, and the roots hereof are hot and dry almost in the third degree".

"The root, boyled in posset drink, and drunk, causeth vomiting, and is used with good successe in the beginning of Agues, especiallyTertians, which frequently rage in the spring-time: a plaister made of the roots with parched Barley meal, and applied to swellings and imposthumes do dissolve them; the juice mingled with hony, frankincense, wine and myrrhe, and dropped into the Eares, is good against the corrupt filth and running matter of the Eares; the roots made hollow and boyled in oyl doth help Kib’d heels [or here]: the juice of the root is good for Morphew, and discolourings of the skin."

It seems that daffodils would do a lot in 1674. Even herbalists don’t seem to use it much now. A recent herbal site describes daffodil as "poisonous".

But the descriptions are very like those used by present day herbalists, as you can hear in Simon Mills’ talk.

Chinese medicine is even less tested than western herbs. Not a single Chinese herb has been shown to be useful for treating anything (though in a very few case, they have been found to contain drugs that are useful when purified, notably the anti-malarial compound, artemesinin). They are often contaminated, some are dangerously toxic. And they contribute to the extinction of tigers and rhinoceros because of the silly myths that these make useful medicines. The cruelty of bear bile farming is legendary.

In a recent report in China Daily (my emphasis).

In a congratulation letter, Vice-Premier Li Keqiang called for integration of TCM and Western medicine.

TCM, as a time-honored treasure of Chinese civilization, has contributed to the prosperity of China and brought impacts to world civilization, Li said.

He also urged medical workers to combine the merits of TCM with contemporary medicine to better facilitate the ongoing healthcare reform in China.

The trade in Chinese medicines survives only for two reasons. One is that thay are a useful tool for promoting Chinese nationalism. The other is that they are big business. Both are evident in the vice-premier’s statement.

I presume that it’s the business bit that is the reason why London South Bank University (ranked 114 ou ot 114) that led to one of their main lecture theatres being decorated with pictures like this.“Mr Li Changchun awarding 2010 Confucius Institute of the year to LSBU Vice Chancellor” . I’ll bet Mr Li Changchun uses real medicine himself, as most Chinese who can afford it do.

Presumably, what’s taught in their Confucius Institute is the same sort of dangerous make-believe nonsense.that’s taught on other such courses.

The "College of Medicine" run a classical bait and switch operation. Their "First Thursday lectures" have several good respectable speakers, but then they have Andrew Flower, He is "a former president of the Register of Chinese Herbal Medicine, a medical herbalist and acupuncturist. He has recently completed a PhD exploring the role of Chinese herbal medicine in the treatment of endometriosis". He’s associated with the Avicenna Centre for Chinese Medicine, and with the University of Southampton’s quack division The only bit of research I could find by Andrew Flower was a Cochrane review, Chinese herbal medicine for endometriosis. The main results tell us

"Two Chinese RCTs involving 158 women were included in this review. Both these trials described adequate methodology. Neither trial compared CHM with placebo treatment."

But the plain language summary says

"This review suggests that Chinese herbal medicine (CHM) may be useful in relieving endometriosis-related pain with fewer side effects than experienced with conventional treatment."

It sounds to me as though people as partisan as the authors of this should not be allowed to write Cochrane reviews.

Flower’s talk is followed by one from the notorious representative of the herbal industry, Michael McIntyre, talking on Herbal medicine: A major resource for the 21st century. That’s likely to be about as objective as if they’d invited a GSK drug rep to talk about SSRIs.

The people at Kings College London Institute of Pharmaceutical Sciences are most certainly not quacks. They have made a database of chemicals found in traditional Chinese medicine. It’s sold by a US company, Chem-TCM and it’s very expensive (Commercial license: $3,740.00. Academic/government license:$1,850.00). Not much open access there. It’s a good idea to look at chemicals of plant origin, but only as long as you don’t get sucked into the myths. It’s only too easy to fall for the bait and switch of quacks (like TCM salespeople). The sample page shows good chemical and botanical information, and predicted (not observed) pharmacological activity. More bizarrely, it shows also analysis of the actions claimed by TCM people.

It does seem odd to me to apply sophisticated classification methods to things that are mostly myth.

The multiple uses claimed for Chinese medicines are very like the make-believe claims made for western herbs by Galen, Culpepper and (with much less excuse) by Mills.

They are almost all untrue, but their proponents are good salesmen. Don’t let them get a foot in your door.

### Follow-up

10 June 2012. No sooner did this post go public when I can across what must be one of the worst herbal scams ever: “Arthroplex

31 July 2012. Coffee is the subject of another entry in the 1674 edition of Blagrave.

Blagrave evidently had a lower regard for coffee than I have.

“But being pounded and baked, as do it to make the Coffee-liquor with, it then stinks most loathsomly, which is an argument of some Saturnine quality in it.”

“But there is no mention of an medicinal use thereof, by any Author either Antient of Modern”

Blagrave says also

“But this I may truly say of it [coffee]: Quod Anglorum Corpora quae huic liquori, tantopere indulgent, in Barbarorum naturam degenerasse videntur,”

This was translated expertly by Benet Salway, of UCL’s History department

“that the bodies of the English that indulge in this liquor to such an extent seem to degenerate into the nature of barbarians”

My boss, Lucia Sivolotti got something very like that herself. Be very impressed.

Salway suggested that clearer Latin would have been “quod corpora Anglorum, qui tantopere indulgent huic liquori, degenerasse in naturam barbarorum videntur”.

I’d have passed that on to Blagrave, but I can’t find his email address.

I much prefer Alfréd Rényi’s aphorism (often misattributed to Paul Erdös)

“A mathematician is a machine for turning coffee into theorems”

 Hot off the press The Prince’s Foundation for Integrated Health (FIH) has been spreading misinformation about medicine since 1993.  It has featured often on this blog. Now it has closed its doors.

An announcement has appeared on the FIH website

 30 April 2010 The Trustees of The Prince’s Foundation for Integrated Health have decided to close the charity.

The announcement goes on

"Whilst the closure has been planned for many months and is part of an agreed strategy, the Trustees have brought forward the closure timetable as a result of a fraud investigation at the charity."

"The Trustees feel that The Foundation has achieved its key objective of promoting the use of integrated health. Since The Foundation was set up in 1993, integrated health has become part of the mainstream healthcare agenda, with over half a million patients using complementary therapies each year, alongside conventional medicine. . . "

While the immediate precipitating cause may have been the fraud (see below), the idea that the Foundation "has achieved its key objective of promoting the use of integrated health" seems like a ludicrous bit of make-believe. Well, make-believe is something with which the Foundation was quite familiar. At a time when university courses in quackery are vanishing like the snow in springtime, they can hardly believe that their aims have been achieved. But I guess one could not expect them to say "sorry folks, we were wrong all along".

The 2010 Conference is cancelled too

Judging by the quality of the 2009 conference, which I analysed at length last year, the cancellation of the 2010 conference is very welcome news (except perhaps to a few sycophants looking for honours).

What next? A College?

The rumour is that a “College of Integrated Medicine” may arise from the ashes of FIH. Or even, heaven forbid. a Royal College of Integrated baloney. Since universities seem to be deciding that it isn’t sensible to teach myth as truth, i is not unlikely.

Prince Charles’s aide at homeopathy charity arrested on suspicion of fraud

This headline, of an article in the Guardian, by Robert Booth, was not entirely unexpected.

The parlous state of the accounts at the Prince’s Foundation for Integrated Health has been documented already at
Gimpy’s blog
.

“An aide in Prince Charles’s campaign for wider use of complementary medicine in the NHS was arrested at dawn today on suspicion of fraud and money-laundering at the prince’s health charity.

A 49-year old man, understood to be a former senior official at the Prince’s Foundation for Integrated Health, was taken into custody at a police station in north London. He was arrested alongside a 54-year-old woman, who was being held at the same address.

The arrests follow a police investigation into £300,000 unaccounted for in the books of the charity, of which the Prince is president.”

More news will appear here, as it comes in.

### Follow-up

Other posts on this topic appeared rapidly.

The Guardian 30 April. Robert Booth Prince of Wales’s health charity wound up in wake of fraud investigation

Dr Aust’s Spleen 30 April In memoriam. In which Dr Aust gets a bit poetic

Followed by the rest of the mainstream media.

Edzard Ernst 1 May 2010, in the Indepenndent. Better than any journalist. Why alternative medicine wins from the foundation’s demise. Read it! Here are some quotations.

“I therefore think that the FIH has become a lobby group for unproven and disproven treatments populated by sycophants.”

“The FIH has repeatedly been economical with the truth. For instance when it published a DoH-sponsored patient guide that was devoid of evidence. They claimed evidence was never meant to be included. But I had seen a draft where it was and friends have seen the contract with the DoH where “evidence” was an important element. “

“I hope that, after the demise of FIH, the discussion about alternative medicine in the UK can once more become rational. I also hope that Prince Charles has the greatness of selecting advisers who actually advise rather than “Yes Men” who are hoping to see their names on the next Honours List. “

1 May 2010. According to Martin Delgado, in the Daily Mail, the people who were arrested on suspicion of fraud were accountant George Gray and his wife. Gray was Finance Director and acting Chief Executive of FIH. About as senior as you can get.

Gray spent two weeks (two weeks?) at Diabetes UK in 2004 before becoming finance director at the Leadership Foundation For Higher Education.

Yet another university has stopped its homeopathy course. The particular interest of this course was that it was being run at Robert Gordon University, Aberdeen, the vice-chancellor which was Michael Pittilo, until his recent premature death. Pittilo is the person who recommended to the government that herbalists and Chinese medicine practitioners should get honours degrees and be regulated like doctors. His report, was, in my opinions, disastrously bad

It recently emerged that this, very bad, advice would not be accepted by the Department of Health (DH), so the campaign against the Pittilo proposals, on this blog and elsewhere was successful. The alternative DH proposals look pretty silly, but we won’t really know until after the election exactly what will happen.

Robert Gordon University (RGU): is the ‘post-1992’ university in Aberdeen, as opposed the the University of Aberdeen (where my son is at the moment). Much of RGU does an excellent job, but like so many post-1992 universities they harm themselves by running courses in barmy alternative medicine. RGU ran an Introduction To Homeopathy module (saved 9 April 2010).

In July 2009, I asked RGU to see some samples of the teaching materials on this module, partly as part of the campaign against Pittilo’s proposals. I asked to see the powerpoints and handouts for three lectures, (1) evidence for homeopathy, (2) first aid remedies, and (3) allergies.

In September 2009, this request, made under the Freedom of Information Act (Scotland), was, as always, rejected by RGU, though they did tell me that the evidence lecture had been produced by a lecturer from The Faculty of Homeopathy and the other two had been produced by a local GP.

So, as usual, I asked for the mandatory internal review of the decision. In October, the review upheld the original decision, as they almost always do. I referred the decision to the Scottish Information Commissioner (the law is slightly different in Scotland) and they have still not responded.

But on 8 April 2010 I got a letter from RGU.

 “The above course requested is no longer part of the School of Nursing and Midwifery’s provision, and it was cessated [sic] in Semester One 2009/10. This followed a formal review of all Nursing and Midwifery modules and their viability. In the light of this the university has decided to release the information.”

So yet another university has done the sensible thing. The course has been shut. Just for the record, I’ll reproduce a few of the slides from the lecture on “homeopathic remedies for allergies”.

Allergies can be dangerous, and occasionally lethal. To treat them with homeopathic pills, medicines that contain no medicine, is not just delusion, but a dangerous delusion which risks the lives of patients.

The "remedies" include nettles, sulphur, petroleum and arsenic.  They’d be pretty scary but in fact the pills contain, in most cases, not a jot of nettle, sulphur, petroleum or arsenic.  Homeopathic pharmacies stock thousands of bottles of identical sugar pills, each with a different label.

These dangerous delusions were being taught as fact in a UK university.  The shame of it..

This post recounts a complicated story that started in January 2009, but has recently come to what looks like a happy ending.  The story involves over a year’s writing of letters and meetings, but for those not interested in the details, I’ll start with a synopsis.

### Synopsis of the synopsis

In January 2009, a course in "integrated medicine" was announced that, it was said, would be accredited by the University of Buckingham. The course was to be led by Drs Rosy Daniel and Mark Atkinson.   So I sent an assessment of Rosy Daniel’s claims to "heal" cancer to Buckingham’s VC (president), Terence Kealey,  After meeting Karol Sikora and Rosy Daniel, I sent an analysis of the course tutors to Kealey who promptly demoted Daniel, and put Prof Andrew Miles in charge of the course.  The course went ahead in September 2009.  Despite Miles’ efforts, the content was found to be altogether too alternative. The University of Buckingham has now terminated its contract with the "Faculty of Integrated Medicine", and the course will close. Well done.Buckingham.

### Synopsis

• January 2009. I saw an announcement of a Diploma in Integrated Medicine, to be accredited by the University of Buckingham (UB).  The course was to be run by Drs Rosy Daniel and Mark Atkinson of the College of Integrated Medicine, under the nominal directorship of Karol Sikora (UB’s Dean of Medicine). I wrote to Buckingham’s vice-chancellor (president), Terence Kealey, and attached a reprint of Ernst’s paper on carctol, a herbal cancer ‘remedy’ favoured by Daniiel.
• Unlike most vice-chancellors, Kealey replied at once and asked me to meet Sikora and Daniel. I met first Sikora alone, and then, on March 19 2009, both together. Rosy Daniel gave me a complete list of the speakers she’d chosen. Most were well-known alternative people, some, in my view, the worst sort of quack. After discovering who was to teach on the proposed course, I wrote a long document about the proposed speakers and sent it to the vice-chancellor of the University of Buckingham, Terence Kealey on March 23rd 2009..  Unlike most VCs, he took it seriously.  At the end of this meeting I asked Sikora, who was in nominal charge of the course, how many of the proposed tutors he’d heard of.  The answer was "none of them"
• Shortly before this meeting, I submitted a complaint to Trading Standards about Rosy Daniel’s commercial site, HealthCreation, for what seemed to me to be breaches of the Cancer Act 1939, by claims made for Carctol. Read the complaint.
• On 27th April 2009, I heard from Kealey that he’d demoted Rosy Daniel from being in charge of the Diploma and appointed Andrew Miles, who had recently been appointed as Buckingham’s Professor of Public Health Education and Policy &Associate Dean of Medicine (Public Health). Terence Kealey said "You’ve done us a good turn, and I’m grateful". Much appreciated. Miles said the course “needs in my view a fundamental reform of content. . . “
• Although Rosy Daniel had been demoted, she was still in charge of delivering the course at what had, by this time, changed its name to the Faculty of Integrated Medicine which, despite its name, is not part of the university.
• Throughout the summer I met Miles (of whom more below) several times and exchanged countless emails, but still didn’t get the revised list of speakers. The course went ahead on 30 September 2009. He also talked with Michael Baum and Edzard Ernst.
• By January 2010, Miles came to accept that the course was too high on quackery to be a credit to the university, and simply fired The Faculty of Integrated Medicine. Their contract was not renewed. Inspection of the speakers, even after revision of the course, shows why.
• As a consequence, it is rumoured that Daniel is trying to sell the course to someone else.  The University of Middlesex, and unbelievably, the University of Bristol, have been mentioned, as well as Thames Valley University, the University of Westminster, the University of Southampton and the University of East London. Will the VCs of these institutions not learn something from Buckingham’s experience? It is to be hoped that they would at the very least approach Buckingham to ask pertinent questions? But perhaps a more likely contender for an organisation with sufficient gullibility is the Prince of Wales newly announced College of Integrated Medicine. [but see stop press]

### The details of the story

The University of Buckingham (UB) is the only private university in the UK. Recently it announced its intention to start a school of medicine (the undergraduate component is due to start in September 2011). The dean of the new school is Karol Sikora.

Karol Sikora shot to fame after he appeared in a commercial in the USA. The TV commercial was sponsored by a far-right Republican campaign group, “Conservatives for Patients’ Rights” It designed to prevent the election of Barack Obama, by pouring scorn on the National Health Serrvice. A very curious performance.  Very curious indeed. And then there was a bit of disagreement about the titles that he claimed to have.

As well as being dean of medicine at UB. Karol Sikora is also medical research director of CancerPartnersUK. a private cancer treatment company. He must be a very busy man.

Karol Sikora’s attitude to quackery is a mystery wrapped in an enigma.  As well as being a regular oncologist, he is also a Foundation Fellow of that well known source of unreliable information, The Prince of Wales Foundation for Integrated Health. He spoke at their 2009 conference.

In the light of that, perhaps it is not, after all, so surprising thet the first action of UB’s medical school was to accredit a course a Diploma in Integrated Medicine. This course has been through two incarnations. The first prospectus (created 21 January 2009) advertised the course as being run by the British College of Integrated Medicine.But by the time that UB issued a press release in July 2009, the accredited outfit had changed its name to the Faculty of Integrated Medicine That grand title makes it sound like part of a university.  It isn’t.

Rosy Daniel runs a company, Health Creation which, among other things, recommended a herbal concoction. Carctol. to "heal" cancer, . I wrote to Buckingham’s vice-chancellor (president), Terence Kealey, and attached a reprint of Ernst’s paper on Carctol. . Unlike most university vice-chancellors, he took it seriously. He asked me to meet Karol Sikora and Rosy Daniel to discuss it.  After discovering who was teaching on this course, I wrote a document about their backgrounds and sent it to Terence Kealey.  The outcome was that he removed Rosy Daniel as course director and appointed in her place Andrew Miles, with a brief to reorganise the course. A new prospectus, dated 4 September 2009, appeared. The course is not changed as much as I’d have hoped, although Miles assures me that while the lecture titles themselves may not have changed, he had ordered fundamental revisions to the teaching content and the teaching emphases.

In the new prospectus the British College of Integrated Medicine has been renamed as the Faculty of Integrated Medicine, but it appears to be otherwise unchanged. That’s a smart bit of PR. The word : “Faculty” makes it sound as though the college is part of a university.   It isn’t.  The "Faculty" occupies some space in the Apthorp Centre in Bath, which houses, among other things, Chiropract, Craniopathy (!) and a holistic vet,

The prospectus now starts thus.

Most of these advisory board members are the usual promoters of magic medicine.  But three of them seem quite surprising,Stafford Lightman, Nigel Sparrow and Nigel Mathers.

Stafford Lightman? Well actually I mentioned to him in April that his name was there and he asked for it to be removed, on the grounds that he’d had nothing to do with the course. It wasn’t removed for quite a while, but the current advisory board has none of these people. Nigel Sparrow and Nigel Mathers, as well as Lightman, sent letters of formal complaint to Miles and Terence Kealey, the VC of Buckingham, to complain that their involvement in Rosy Daniel’s set-up had been fundamentally misrepresented by Daniel.   With these good scientists having extricated themselves from Daniel’s organisation, the FIM has only people who are firmly in the alternative camp (or quackery, as i’d prefer to call it). For example, people like Andrew Weil and George Lewith.

Andrew Weil, for example, while giving his address as the University of Arizona, is primarily a supplement salesman.  He was recently reprimanded by the US Food and Drugs Administration

“Advertising on the site, the agencies said in the Oct. 15 letter, says “Dr. Weil’s Immune Support Formula can help maintain a strong defense against the flu” and claims it has “demonstrated both antiviral and immune-boosting effects in scientific investigation.”

The claims are not true, the letter said, noting the “product has not been approved, cleared, or otherwise authorized by FDA for use in the diagnosis, mitigation, prevention, treatment, or cure of the H1N1 flu virus.”

This isn’t the first time I’ve come across people’s names being used to support alternative medicine without the consent of the alleged supporter.  There was, for example, the strange case of Dr John Marks and Patrick Holford.

Misrepresentation of this nature seems to be the order of the day. Could it be that people like Rosy Daniel are so insecure or, indeed, so unimportant within the Academy in real terms (where is there evidence of her objective scholarly or clinical stature?), that they seek to attach themselves, rather like limpets to fishing boats, to people of real stature and reputation, in order to boost their own or others’ view of themselves by a manner of proxy?

### The background

When the course was originally proposed, a brochure appeared. It said accreditation by the University of Buckingham was expected soon.

Not much detail appeared in the brochure, Fine words are easy to write but what matters is who is doing th teaching. So I wrote to the vice-chancellor of Buckingham, Terence Kealey. I attached a reprint of Ernst’s paper on carctol, a herbal cancer ‘remedy’ favoured by Daniel (download the cached version of her claims, now deleted).

Terence Kealey

Kealey is regarded in much of academia as a far-right maverick, because he advocates ideas such as science research should get no public funding,and that universities should charge full whack for student fees. He has, in fact, publicly welcomed the horrific cuts being imposed on the Academy by Lord Mandelson. His piece in The Times started

“Wonderful news. The Government yesterday cut half a billion pounds from the money it gives to universities”

though the first comment on it starts

"Considerable accomplishment: to pack all these logical fallacies and bad metaphors in only 400 words"

He and I are probably at opposite ends of the political spectrum. Yet he is the only VC who has been willing to talk about questions like this.  Normally letters to vice-chancellors about junk degrees go unanswered.  Not so with Kealey.  I may disagree with a lot of his ideas, but he is certainly someone you can do business with.

Kealey responded quickly to my letter, sent in January 2009, pointing out that Rosy Daniel’s claims about Carctol could not be supported and were possibly illegal. He asked me to meet Sikora and Daniel. I met first Sikora alone, and then, on March 19 2009, both together. Rosy Daniel gave me a complete list of the speakers she’d chosen to teach on this new Diploma on IM.

After discovering who was to teach on the proposed course, I wrote a long document about the proposed speakers and sent it to Terence Kealey on March 23rd 2009. It contained many names that will be familiar to anyone who has taken an interest in crackpot medicine, combined with a surprisingly large element of vested financial interests. Unlike most VCs, Kealey took it seriously.

The remarkable thing about this meeting was that I asked Sikora how many names where familiar to him on the list of people who had been chosen by Rosy Daniel to teach on the course. His answer was "none of them". Since his name and picture feature in all the course descriptions, this seemed like dereliction of duty to me.

After seeing my analysis of the speakers, Terence Kealey reacted with admirable speed. He withdrew the original brochure, demoted Rosy Daniel (in principle anyway) and brought in Prof Andrew Miles to take responsibility for the course. This meant that he had to investigate the multiple conflicts of interests of the various speakers and to establish some sort of way forward in the ‘mess’ of what had been agreed before Miles’ appointment to Buckingham

Andrew Miles.

Miles is an interesting character, a postdoctoral neuroendocrinologist, turned public health scientist.  I’d come across him before as editor-in-chief of the Journal of Evaluation in Clinical Practice    This is a curious journal that is devoted mainly to condemning Evidence Based Medicine.  Much of its content seems to be in a style that I can only describe as post-modernist-influenced libertarian.

The argument turns on what you mean by ‘evidence’ and, in my opinion, Miles underestimates greatly the crucial problem of causality, a problem that can be solved only by randomisation, His recent views on the topic can be read here.

An article in Miles’ journal gives its flavour: "Andrew Miles, Michael Loughlin and Andreas Polychronis, Medicine and evidence: knowledge and action in clinical practice". Journal of Evaluation in Clinical Practice 2007, 13, 481–503 [download pdf].  This paper launches an attack on Ben Goldacre, in the following passage.

“Loughlin identifies Goldacre [36] as a particularly luminous example of a commentator who is able not only to combine audacity with outrage, but who in a very real way succeeds in manufacturing a sense of having been personally offended by the article in question. Such moralistic posturing acts as a defence mechanism to protect cherished assumptions from rational scrutiny and indeed to enable adherents to appropriate the ‘moral high ground’, as well as the language of ‘reason’ and ‘science’ as the exclusive property of their own favoured approaches. Loughlin brings out the Orwellian nature of this manoeuvre and identifies a significant implication.”

"If Goldacre and others really are engaged in posturing then their primary offence, at least according to the Sartrean perspective adopted by Murray et al. is not primarily intellectual, but rather it is moral. Far from there being a moral requirement to ‘bend a knee’ at the EBM altar, to do so is to violate one’s primary duty as an autonomous being.”

This attack on one of my heroes was occasioned because he featured one of the most absurd pieces of post-modernist bollocks ever, in his Guardian column in 2006. I had a go at the same paper on this blog, as well as an earlier one by Christine Barry, along the same lines. There was some hilarious follow-up on badscience.net.  After this, it is understandable that I had not conceived a high opinion of Andrew Miles.  I feared that Kealey might have been jumping out of the frying pan into the fire.

After closer acquaintance I have changed my mind, In the present saga Andrew Miles has done an excellent job. He started of sending me links to heaven knows how many papers on medical epistemology, to Papal Encyclicals on the proposed relationship between Faith and Reason and on more than one occasion articles from the Catholic Herald (yes, I did read it). This is not entirely surprising, as Miles is a Catholic priest as well as a public health academic, so has two axes to grind. But after six months of talking, he now sends me links to junk science sites of the sort that I might get from, ahem, Ben Goldacre.

### Teachers on the course

Despite Andrew Miles best efforts, he came in too late to prevent much of the teaching being done in the parallel universe of alternative medicine,  The University of Buckingham had a pre-Miles, legally-binding contract (now terminated) with the Faculty of Integrated Medicine, and the latter is run by Dr Rosy Daniel and Dr Mark Atkinson.  Let’s take a look at their record.

Rosy Daniel BSc, MBBCh

Dr Rosy Daniel first came to my attention through her commercial web site, Health Creation. This site, among other things, promoted an untested herbal concoction, Carctol, for "healing" cancer.

Carctol: Profit before Patients? is a review by Edzard Ernst of the literature, such as it is, and concludes

Carctol and the media hype surrounding it must have given many cancer patients hope. The question is whether this is a good or a bad thing. On the one hand, all good clinicians should inspire their patients with hope [6]. On the other hand, giving hope on false pretences is cruel and unethical. Rosy Daniel rightly points out that all science begins with observations [5]. But all science then swiftly moves on and tests hypotheses. In the case of Carctol, over 20 years of experience in India and almost one decade of experience in the UK should be ample time to do this. Yet, we still have no data. Even the small number of apparently spectacular cases observed by Dr. Daniel have not been published in the medical literature.

On this basis I referred Health Creation to Trading Standards officer for a prima facie breach of the Cancer Act 1939. ]Download the complaint document]. Although no prosecution was brought by Trading Standards, they did request changes in the claims that were being made.  Here is an example.

A Google search of the Health Creation site for “Carctol” gives a link

Dr Daniel has prescribed Carctol for years and now feels she is seeing a breakthrough. Dr Daniel now wants scientists to research the new herbal medicine

But going to the link produces

You can download the cached version of this page, which shows the sort of claims that were being made before Trading Standards Officers stepped in.  There are now only a few oblique references to Carctol on the Health Creation site, e.g. here..

Both Rosy Daniel and Karol Sikora were speakers at the 2009 Princes’s Foundation Conference, in some odd company.

Mark Atkinson MBBS BSc (Hons) FRIPH

Dr Mark Atkinson is co-leader of the FiM course. He is also a supplement salesman, and he has promoted the Q-link pendant.  The Q-link pendant is a simple and obvious fraud designed to exploit paranoia about WiFi killing you. When Ben Goldacre bought one and opened it. He found

“No microchip. A coil connected to nothing. And a zero-ohm resistor, which costs half a penny, and is connected to nothing.”

“As someone who used to get tired sitting in front of computers and used to worry about the detrimental effects of external EMF’s, particularly as an avid user of mobile phones, I decided to research the various devices and technologies on the market that claim to strengthen the body’s subtle energy fields. It was Q Link that came out top. As a Q link wearer, I no longer get tired whilst at my computer, plus I’m enjoying noticeably higher energy levels and improved mental performance as a result of wearing my Q Link. I highly recommend it.” Dr Mark Atkinson, Holistic Medical Physician

Mark Atkinson is also a fan of Emo-trance. He wrote, In Now Magazine,

"I wanted you to know that of all the therapies I’ve trained in and approaches that I have used (and there’s been a lot) none have excited me and touched me so deeply than Emotrance."

"Silvia Hartmann’s technique is based on focusing your thoughts on parts of your body and guiding energy. It can be used for everything from insomnia to stress. The good news is that EmoTrance shows you how to free yourself from these stuck emotions and release the considerable amounts of energy that are lost to them."

Aha so this particular form of psychobabble is the invention of Silvia Hartmann. Silvia Hartmann came to my attention because her works feature heavily in on of the University of Westminster’s barmier “BSc” degrees, in ‘naturopaths’, described here. She is fanous, apart from Emo-trance, for her book Magic, Spells and Potions

“Dr Hartmann has created techniques that will finally make magic work for you in ways you never believed to be possible.”

Times Higher Education printed a piece with the title ‘Energy therapy’ project in school denounced as ‘psychobabble’. They’d phoned me a couple of days earlier to see whether I had an opinion about “Emotrance”.  As it happens, I knew a bit about it because it had cropped up in a course given at, guess where, the University of Westminster .   It seems that a secondary school had bought this extreme form of psychobabble.  The comments on the Times Higher piece were unusually long and interesting.

It turned out that the inventor of “Emotrance”, Dr Silvia Hartmann PhD., not only wrote books about magic spells and potions, but also that her much vaunted doctorate had been bought from the Universal Life Church, current cost $29.99. ### The rest of the teachers The rest of the teachers on the course, despite valiant attempts at vetting by Andrew Miles, includes many names only too well-known to anybody who has taken and interest in pseudo-scientific medicine. Here are some of them. Damien Downing:, even the Daily Mail sees through him. Enough said. Kim Jobst, homoepath and endorser of the obviously fraudulent Q-link pendant . His Plaxo profile says About Kim A. Jobst Consultant, Wholystic Care Physician [sic!] , Medical Homoeopath, Specialist in Neurodegeneration and Dementia, using food state nutrition, diet and lifestyle to facilitate Healing and Growth; Catherine Zollman, Well known ally of HRH and purveyer of woo. Harald Walach, another homeopath, fond of talking nonsense about "quantum effects". Nicola Hembry, a make-believe nutritionist and advocate of vitamin C and laetrile for cancer Simon Mills, a herbalist who is inclined to diagnoses like “hot damp”, ro be treated with herbs that tend to “cool and dry.” David Peters, of the University of Westminster. Enough said. Nicola Robinson of Thames Valley University. Advocate of unevidenced treatmsnts. Michael Dixon, of whom more here. And last but not least, Karol Sikora. ### The University of Buckingham removes accreditation of the Faculty of Integrated Medicine The correspondence has been long and, at times, quite blunt. Here are a few quotations from it, The University of Buckingham, being private, is exempt from the Freedom of Information Act (2000) but nevertheless they have allowed me to reproduce the whole of the correspondence. The University, through its VC, Terence Keeley, has been far more open than places that are in principle subject to FOIA, but which, in practice, always try to conceal material. I may post the lot, as time permits, but meanwhile here are some extracts. They make uncomfortable reading for advocates of magic medicine. Miles to Daniel, 8 Dec 2009 ” . . . now that the University has taken his [Sikora’s] initial advice in trialing the DipSIM and has found it cost-ineffective, the way forward is therefore to alter that equation through more realistic financial contribution from IHT/FIM at Bath or to view the DipSIM as an experiment that has failed and which must give way to other more viable initiatives." "The University is also able to confirm that we hold no interest in jointly developing any higher degrees on the study of IM with IHT/FIM at Bath. This is primarily because we are developing our own Master’s degree in Medicine of the Person in collaboration with various leading international societies and scholars including the WHO and which is based on a different school of thought. " Miles to Daniel 15 Dec 2009 "Dear Rosy It appears that you have not fully assimilated the content of my earlier e-mails and so I will reiterate the points I have already made to you and add to them. The DipSIM is an external activity – in fact, it is an external collaboration and nothing more. It is not an internal activity and neither is it in any way part of the medical school and neither will it become so and so the ‘normal rules’ of academic engagement and scholarly interchange do not apply. Your status is one of external collaborator and not one of internal or even visiting academic colleague. There is no “joint pursuit” of an academically rigorous study of IM by UB and IHT/FIM beyond the DipSIM and there are no plans, and never have been, for the “joint definition of research priorities” in IM. The DipSIM has been instituted on a trial basis and this has so far shown the DipSIM to be profoundly cost-ineffective for the University. You appear to misunderstand this – deliberately or otherwise." Daniel to Miles 13 Jan 2010 "However, I am aware that weather permitting you and Karol will be off to the Fellows meeting for the newly forming National College (for which role I nominated you to Dr Michael Dixon and Prof David Peters.) I have been in dialogue with Michael and Boo Armstrong from FIH and they are strongly in favour of forming a partnership with FIM so that we effectively become one of many new faculties within the College (which is why we change our name to FIM some months ago). I have told Michael about the difficulties we are having and he sincerely hopes that we can resolve them so that we can all move forward as one. " Miles to Daniel 20 Jan 2010 "Congratulations on the likely integration of your organisation into the new College of Integrative Health which will develop out of the Prince’s Foundation for Integrated Health. This will make an entirely appropriate home for you for the longer term. Your image of David Colquhoun "alive and kicking" as the Inquisitor General, radiating old persecutory energy and believing "priestess healers" (such as you describe youself) to be best "tortured, drowned and even burnt alive", will remain with me, I suspect, for many years to come (!). But then, as the Inquisitor General did say, ‘better to burn in this life than in the next’ (!). Overall, then, I reject your conclusion on the nature of the basis of my decision making and playfully suggest that it might form part of the next edition of Frankfurt’s recent volume ["On Bullshit] http://press.princeton.edu/titles/7929.html I hope you will forgive my injection of a little academic humour in an otherwise formal and entirely serious communication. The nature of IM, with its foundational philosophy so vigorously opposed by mainstream medicine and the conitnuing national and international controversies which engulf homeopaths, acupuncturists, herbalists, naturopaths, transcendental meditators, therapeutic touchers, massagers, reflexologists, chiropractors, hypnotists, crystal users, yoga practitioners, aromatherapists, energy channelers, chinese medicine practitioners et al, can only bring the University difficulties as we seek to establish a formal and internationally recognised School of Medicine and School of Nursing. I do not believe my comments in relation to governance at Bath are "offensive". They are, on the contrary, entirely accurate and of concern to the University. There have been resignations at senior level from your Board due to misrepresentation of your position and there has been a Trading Standards Authority investigation into further instances of misrepresentation. I am advised that an audit is underway of your compliance with the Authority’s instructions. You have therefore not dealt with my concerns, you have merely described them as "offensive". I note from your e-mail that you are now in discussions with other universities and given the specific concerns of the University of Buckingham which I have dealt with exhaustively in this and other correspondences and the incompatibility of the developments at UB with the DipSIM and your own personal ambitions, etc., I believe you to have taken a very wise course and I wish you well in your negotiations. In these circumstances I feel it appropriate to enhance those negotiations by confirming that the University of Buckingham will not authorise the intake of a second cohort of students and that the relationship between IHT and the University will cease following the graduation of those members of the current course that are successful in their studies – the end of February 2011." From Miles 2 Feb 2010 "Here is the list of teachers – you can subtract me (I withdrew from teaching when the antics ay Bath started) and also Professor John Cox (Former President of The Royal College of Psychiatrists and Former Secretary General of the World Psychiatric Association) who withdrew when he learned of some of the stuff going on…. Karol Sikora continues to teach. Michael Loughlin and Carmel Martin are both good colleagues of mine and, I can assure you – taught the students solid stuff! Michael taught medical epistemology and Carmel the emerging field of systems complexity in health services (Both of them have now withdrawn from teaching commitments). The tutors shown are described by Rosy as the finest minds in IM teaching in the country. I interviewed tham all personally on (a) the basis of an updated CV & (b) via a 30 min telephone interview with me personally. Some were excluded from teaching because they were not qualified to do so academically (e.g. Boo Armstrong, Richard Falmer, not even a first degree, etc, etc., but gave a short presentation in a session presided over by an approved teacher) and others were approved because of their academic qualifications, PhD, MD, FRCP etc etc etc) and activity within the IM field. Each approved teacher was issued with highly specific teaching guidance form me (no bias, reference to opposing schools of thought, etc etc) and each teacher was required to complete and sign a Conflicts of Interest form. All of these documentations are with me here. Short of all this governance it’s impossible to bar them from teaching because who else would then do it?! Anyway, the end is in sight – Hallelujah! " From Miles 19 Feb 2010 "Dear David Just got back to the office after an excellent planning meeting for the new Master’s Degree in Person-centred Medicine and a hearty (+ alcoholic) lunch at the Ath! Since I shall never be a FRS, the Ath seems to me the next best ‘club’ (!). Michael Baum is part of the steering committee and you might like to take his thoughts on the direction of the programme. Our plans may even find their way into your Blog as an example of how to do things (vs how not to do things, i.e. CAM, IM, etc!). This new degree will sit well alongside the new degrees in Public Health – i.e. the population/utilitarian outlook of PH versus the individual person-centred approach., etc. " And an email from a senior UB spokesperson "Rumour has it that now that Buckingham has dismissed the ‘priestess healer of Bath’, RD [Rosy Daniel] , explorations are taking place with other universities, most of which are subject to FoI request from DC at the time of writing. Will these institutions have to make the same mistakes Buckingham did before taking the same action? Rumour also has it that RD changed the name of her institution to FIM in order to fit neatly into the Prince’s FIH, a way, no doubt, of achieving ‘protection’ and ‘accreditation’ in parallel with particularly lucrative IM ‘education’ (At £9,000 a student and with RD’s initial course attracting 20 mainly GPs, that’s £180,00 – not bad business…. And Buckingham’s ‘share of this? £12,000!” ### The final bombshell; even the Prince of Wales’ FIH rejects Daniel and Atkinson? Only today (31 March) I was sent, from a source that I can’t reveal, an email which comes from someone who "represent the College and FIH . . . ".. This makes it clear that the letter comes from the Prince of Wales’ Foundation for Integrated Health  Dr Rosy Daniel BSc MBBCh Director of the Faculty of Integrated Medicine Medical Director Health Creation 30th March 2010 RE: Your discussion paper and recent correspondence Thank you for meeting with [XXXXXX] and myself this evening to discuss your proposals concerning a future relationship between your Faculty of Integrated Medicine and the new College. As you know, he and I have been asked to represent the College and FIH in this matter. We are aware of difficulties facing your organisations and the FIM DipSIM course. As a consequence of these, it is not possible for the College to enter into an association with you, any of your organisations nor the DipSIM course at the present time. It would, therefore, be wrong to represent to others that any such association has been agreed. You will appreciate that, in these circumstances, you will not receive an invitation to the meeting of 15th April 2010 nor to other planned events. I am sorry to disappoint you in this matter. Yours sincerely ### Conclusions I’ll confess to feeling almost a little guilty for having appeared to persecute the particular individuals involved in thie episode. But patients are involved and so is the law, and both of these are more important than individuals, The only unfair aspect is that, while it seems that even the Prince of Wales’ Foundation for Integrated Health has rejected Daniel and Atkinson, that Foundation embraces plenty of people who are just as deluded, and potentially dangerous, as those two. The answer to that problem is for the Prince to stop endorsing treatments that don’t work. As for the University of Buckingham. Well, despite the ‘right wing maverick’ Kealey and the ‘anti-evidence’ Miles, I really think they’ve done the right thing. They’ve listened, they’ve maintained academic rigour and they’ve released all information for which I asked and a lot more. Good for them, I say. ### Follow-up 15 April 2010. This story was reported by Times Higher Education, under the title “It’s terminal for integrated medicine diploma“. That report didn’t attract comments. But on 25th April Dr Rosy Daniel replied with “‘Terminal’? We’ve only just begun“. This time there were some feisty responses. Dr Daniel really should check her facts before getting into print. 3 March 2011. Unsurprisingly, Dr Daniel is up and running again, under the name of the British College of Integrated Medicine. The only change seems to be that Mark Atkinson has jumped ship altogether, and, of course, she is now unable to claim endorsement by Buckingham, or any other university. Sadly, though, Karol Sikora seems to have learned nothing from the saga related above. He is still there as chair of the Medical Advisory Board, along with the usual suspects mentioned above. Jump to follow-up The King’s Fund recently published Assessing complementary practice Building consensus on appropriate research methods [or download pdf]. It is described as being the “Report of an independent advisory group”. I guess everyone knows by now that an “expert report” can be produced to back any view whatsoever simply by choosing the right “experts”, so the first things one does is to see who wrote it. Here they are. • Chair: Professor Dame Carol Black • Harry Cayton, Chief Executive, Council for Healthcare Regulatory Excellence • Professor Adrian Eddleston, then Vice-Chairman, The King’s Fund • Professor George Lewith, Professor of Health Research, Complementary and Integrated Medicine Research Unit, University of Southampton • Professor Stephen Holgate, MRC Clinical Professor of Immunopharmacology, University of Southampton • Professor Richard Lilford, Head of School of Health and Population Sciences, University of Birmingham We see at once two of the best known apologists for alternative medicine, George Lewith (who has appeared here more than once) and Stephen Holgate Harry Cayton is CEO of Council for Healthcare Regulatory Excellence (CHRE) which must be one of the most useless box-ticking quangos in existence. It was the CHRE that praised the General Chiropractic Council (GCC) for the quality of its work. That is the same GCC that is at present trying to cope with 600 or so complaints about the people it is supposed to regulate (not to mention a vast number of complaints to Trading Standards Offices). The GCC must be the prime example of the folly of giving government endorsement to things that don’t work. But the CHRE were not smart enough to spot that little problem. No doubt Mr Cayton did good work for the Alzheimer’s Society. His advocacy of patient’s choice may have helped me personally. But it isn’t obvious to me that he is the least qualified to express an opinion on research methods in anything whatsoever. According to the Guardian he is “BA in English and linguistics from the University of Ulster; diploma in anthropology from the University of Durham; B Phil in philosophy of education from the University of Newcastle.” Adrian Eddlestone is a retired Professor of Medicine. He has been in academic administration since 1983. His sympathy for alternative medicine is demonstrated by the fact that he is also Chair of the General Osteopathic Council, yet another “regulator” that has done nothing to protect the public from false health claims (and which may, soon, find itself in the same sort of trouble as the GCC). Richard Lilford is the only member of the group who has no bias towards alternative medicine and also the only member with expertise in clinical research methods His credentials look impressive, and his publications show how he is the ideal person for this job. I rather liked also his article Stop meddling and let us get on.. He has written about the harm done by postmodernism and relativism, the fellow-travellers of alternative medicine. Most damning of all, Lewith, Eddlestone and Holgate (along with Cyril Chantler, chair of the King’s Fund, and homeopaths, spiritual healers and Karol Sikora) are Foundation Fellows of the Prince of Wales Foundation for Magic Medicine, an organisation that is at the forefront of spreading medical misinformation. I shall refer here to ‘alternative medicine’ rather than ‘complementary medicine’ which is used in the report. It is not right to refer to a treatment as ‘complementary’ until such time as it has been shown to work. The term ‘complementary’ is a euphemism that, like ‘integrative’, is standard among alternative medicine advocates whose greatest wish is to gain respectability. ### The Report The recommendations On page 10 we find a summary of the conclusions. The report identifies five areas of consensus, which together set a framework for moving forward. These are: • the primary importance of controlled trials to assess clinical and cost effectiveness. • the importance of understanding how an intervention works • the value of placebo or non-specific effects • the need for investment and collaboration in creating a sound evidence base • the potential for whole-system evaluation to guide decision-making and subsequent research. The first recommendation is just great. The rest sound to me like the usual excuses for incorporating ineffective treatments into medical practice. Notice the implicit assumption in the fourth point that spending money on research will establish “a sound evidence base". There is a precedent, but it is ignored. A huge omission from the report is that it fails to mention anywhere that a lot of research has already been done. ### Much research has already been done (and failed) The report fails to mention at all the single most important fact in this area. The US National Institutes of Health has spent over a billion dollars on research on alternative medicines, over a period of more than 10 years. It has failed to come up with any effective treatments whatsoever. See, for example Why the National Center for Complementary and Alternative Medicine (NCCAM) Should Be Defunded; Should there be more alternative research?; Integrative baloney @ Yale, and most recently,$2.5B Spent, No Alternative Med Cures found. .

Why did the committee think this irrelevant? I can’t imagine. You guess.

The report says

“This report outlines areas of potential consensus to guide research funders, researchers, commissioners and complementary practitioners in developing and applying a robust evidence base for complementary practice.”

As happens so often, there is implicit in this sentence the assumption that if you spend enough money evidence will emerge. That is precisely contrary to the experence in the USA where spending a billion dollars produced nothing beyond showing that a lot of things we already thought didn’t work were indeed ineffective.

And inevitably, and tragically, NICE’s biggest mistake is invoked.

“It is noteworthy that the evidence is now sufficiently robust for NICE to include acupuncture as a treatment for low back pain.” [p ]

Did the advisory group not read the evidence used (and misinterpeted) by NICE? It seems not. Did the advisory group not read the outcome of NIH-funded studies on acupuncture as summarised by Barker Bausell in his book, Snake Oil Science? Apparently not. It’s hard to know because the report has no references.

George Lewith is quoted [p. 15] as saying “to starve the system of more knowledge means we will continue to make bad decisions”. No doubt he’d like more money for research, but if a billion dollars
in the USA gets no useful result, is Lewith really likely to do better?

### The usual weasel words of the alternative medicine industry are there in abundance

“First, complementary practice often encompasses an intervention (physical treatment or manipulation) as well as the context for that intervention. Context in this setting means both the physical setting for the delivery of care and the therapeutic relationship between practitioner and patient.” [p. 12]

Yes, but ALL medicine involves the context of the treatment. This is no different whether the medicine is alternative or real. The context (or placebo) effect comes as an extra bonus with any sort of treatment.

“We need to acknowledge that much of complementary practice seeks to integrate the positive aspects of placebo and that it needs to be viewed as an integral part of the treatment rather than an aspect that should be isolated and discounted.” [p. 13]

This is interesting. It comes very close (here and elsewhere) to admitting that all you get is a placebo effect, and that this doesn’t matter. This contradicts directly the first recommendation of the House of Lords report (2000).. Both the House of Lords report on Complementary and Alternative Medicine, and the Government’s response to it, state clearly

“. . . we recommend that three important questions should be addressed in the following order”. (1) does the treatment offer therapeutic benefits greater than placebo? (2)  is the treatment safe? (3) how does it compare, in medical outcome and cost-effectiveness, with other forms of treatment?.

The crunch comes when the report gets to what we should pay for.

“Should we be prepared to pay for the so-called placebo effect?

The view of the advisory group is that it is appropriate to pay for true placebo (rather than regression to the mean or temporal effects).” [p 24]

Perhaps so, but there is very little discussion of the emormous ethical questions:that this opinion raises:

• How much is one allowed to lie to patients in order to elicit a placebo effect?
• Is is OK if the practitioner believes it is a placebo but gives it anyway?
• Is it OK if the pratitioner believes that it is not a placebo when actually it is?
• Is it OK for practitioners to go degrees taught by people who believe that it is not a placebo when actually it is?

The report fails to face frankly these dilemmas.  The present rather absurd position in which it is considered unethical for a medical practitioner to give a patient a bottle of pink water, but
perfectly acceptable to refer them to a homeopath. There is no sign either of taking into account the cultural poison that is spread by telling people about yin, yang and meridians and such like preposterous made-up mumbo jumbo.  That is part of the cost of endorsing placebos. And just when one thought that believing things because you wished they were true was going out of fashion

Once again we hear a lot about the alleged difficulties posed by research on alternative medicine. These alleged difficulties are, in my view, mostly no more than excuses. There isn’t the slightest
difficulty in testing things like herbal medicine or homeopathy, in a way that preserves all the ‘context’ and the ways of working of homeopaths and herbalists. Anyone who reads the Guardian knows
how to do that.

In the case of acupuncture, great ingenuity has gone into divising controls. The sham and the ‘real’ acupuncture always come out the same. In a non-blind comparison between acupuncture and no acupuncture the latter usually does a bit worse, but the effects are small and transient and entirely compatible with the view that it is a theatrical placebo.

Despite these shortcomings, some of the conclusions [p. 22] are reasonable.

“The public needs more robust evidence to make informed decisions about the use of complementary practice.

Commissioners of public health care need more robust evidence on which to base decisions about expenditure of public money on complementary practice.”

What the report fails to do is to follow this with the obvious conclusion that such evidence is largely missing and that until such time as it is forthcoming there should be no question of the NHS paying for alternative treatments.

Neither should there be any question of giving them official government recognition in the form of ‘statutory regulation’. The folly of doing that is illustrated graphically by the case of chiropractic which is now in deep crisis after inspection of its claims in the wake of the Simon Singh defamation case. Osteopathy will, I expect, suffer the same fate soon.

In the summary on p.12 we see a classical case of the tension

Controlled trials of effectiveness and cost-effectiveness are of primary importance

We recognise that it is the assessment of effectiveness that is of primary importance in reaching a judgement of different practices. Producing robust evidence that something works in practice – that it is effective – should not be held up by the inevitably partial findings and challenged interpretations arising from inquiries into how the intervention works.

The headline sounds impeccable, but directly below it we see a clear statement that we should use treatments before we know whether they work.  “Effectiveness”, in the jargon of the alternative medicine business, simply means that uncontrolled trials are good enough. The bit about “how it works” is another very common red herring raised by alternative medicine people. Anyone who knows anything about pharmacology that knowledge about how any drug works is incomplete and often turns out to be wrong. That doesn’t matter a damn if it performs well in good double-blind randomised controlled trials.

One gets the impression that the whole thing would have been a lot worse without the dose of reality injected by Richard Lilford. He is quoted as a saying

“All the problems that you find in complementary medicine you will encounter in some other kind of treatment … when we stop and think about it… how different is it to any branch of health care – the answer to emerge from our debates is that it may only be a matter of degree.” [p. 17]

I take that to mean that alternative medicine poses problems that are no different from other sorts of treatment. They should be subjected to exactly the same criteria. If they fail (as is usually the case) they should be rejected.  That is exactly right.  The report was intended to produce consensus, but throughout the report, there is a scarcely hidden tension between believers on one side, and Richard Lilford’s impeccable logic on the other.

### Who are the King’s Fund?

The King’s Fund is an organisation that states its aims thus.

“The King’s Fund creates and develops ideas that help shape policy, transform services and bring about behaviour change which improve health care.”

It bills this report on its home page as “New research methods needed to build evidence for the effectiveness of popular complementary therapies”. But in fact the report doesn’t really recommend ‘new research methods’ at all, just that the treatments pass the same tests as any other treatment. And note the term ‘build evidence’.  It carries the suggestion that the evidence will be positive.   Experience in the USA (and to a smaller extent in the UK) suggests that every time some good research is done, the effect is not to ‘build evidence’ but for the evidence to crumble further

If the advice is followed, and the results are largely negative, as has already happened in the USA, the Department of Health would look pretty silly if it had insisted on degrees and on statutory regulation.

The King’s Fund chairman is Sir Cyril Chantler and its Chief Executive is Niall Dickson.  It produces reports, some of which are better than this one. I know it’s hard to take seriously an organisation that wants to “share its vision” withyou, but they are trying.

“The King’s Fund was formed in 1897 as an initiative of the then Prince of Wales to allow for the collection and distribution of funds in support of the hospitals of London. Its initial purpose was to raise money for London’s voluntary hospitals,”

It seems to me that the King’s Fund is far too much too influenced by the present Prince of Wales. He is, no doubt, well-meaning but he has become a major source of medical misinformation and his influence in the Department of Health is deeply unconstitutional.  I was really surprised to see thet Cyril Chantler spoke at the 2009 conference of the Prince of Wales Foundation for Integrated Health, despite having a preview of the sort of make-believe being propagated by other speakers. His talk there struck me as evading all the essential points. Warm, woolly but in the end, a danger to patients. Not only did he uncritically fall for the spin on the word “integrated”, but he also fell for the idea that “statutory regulation” will safeguard patients.

Revelation of what is actually taught on degrees in these subjects shows very clearly that they endanger the public.

But the official mind doesn’t seem ever to look that far. It is happy ticking boxes and writing vacuous managerialese. It lacks curiosity.

### Follow-up

The British Medical Journal published today an editorial which also recommends rebranding of ‘pragmatic’ trials.  No surprise there, because the editorial is written by Hugh MacPherson, senior research fellow, David Peters, professor of integrated healthcare and Catherine Zollman, general practitioner. I find it a liitle odd that the BMJ says “Competing Interests: none. David Peters interest is obvious from his job description. It is less obvious that Hugh MacPherson is an acupuncture enthusiast who publishes mostly in alternative medicine journals. He has written a book with the extraordinary title “Acupuncture Research, Strategies for Establishing an Evidence Base”. The title seems to assume that the evidence base will materialise eventually despite a great deal of work that suggests it won’t. Catherine Zollman is a GP who is into homeopathy as well as acupuncture. All three authors were speakers at the Prince of Wales conference, described at Prince of Wales Foundation for magic medicine: spin on the meaning of ‘integrated’.

The comments that follow the editorial start with an excellent contribution from James Matthew May. His distinction between ‘caring’ and ‘curing’ clarifies beautifully the muddled thinking of the editorial.

Then a comment from DC, If your treatments can’t pass the test, the test must be wrong. It concludes

“At some point a stop has to be put to this continual special pleading. The financial crisis (caused by a quite different group of people who were equally prone to wishful thinking) seems quite a good time to start.”

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

That was followed by NICE fiasco, part 2. Rawlins should withdraw guidance and start again.

Since then, something of a maelstrom has engulfed NICE, so it’s time for an update.

It isn’t only those who are appalled that NHS should endorse voodoo medicine on the basis of very slim evidence who are asking NICE to rethink their guidance on low back pain. Pain specialists are up in arms too, and have even started a blog, ‘Not Nearly as NICE as you think …‘, to express their views. Equally adverse opinions are being expressed in the Britsh Medical Journal. A letter there is signed by over 50 specialists in pain medicine. It ends thus

“Because of these new guidelines patients will continue to experience unnecessary pain and suffering and their rights to appropriately individually tailored treatment have been removed on the basis of a flawed analysis of available evidence. We believe the guidelines do not reflect best practice, remove patient choice and are not in our patients’ best interests.”

In a contribution headed “NICE misguidance”. Dr Michel Vagg ends

It seems to me that this guideline has been used as a propaganda vehicle to allow cherry-picked evidence to be enshrined as doctrine. This is an abuse of the guideline development process . . . ”

I have to say, though, that it seems to me that some of these people are promoting their own interests as much as chiropractors and acupuncturists. The evidence that spinal injections produce worthwhile benefits seems to be as thin as the evidence that chiropractic and acupuncture produce worthwhile benefits. But no doubt the injections are good for the budgets of PCTs or private practice doctors.. Could it perhaps be the case that some of the clinicians’ anger is being generated by doctors who are rushing to defend their own favourite ineffective treatment?

Why, oh why, can’t either NICE or the pain consultants bring themselves to state the obvious, that nothing works very well. The only thing that can be said for most of the regular treatments is that although they may not be much more effective than acupuncture or chiropractic, at least they don’t come with the intellectually-offensive hokum that accompanies the latter. Very sensible attempts have been made to identify the cause of low back pain [reviewed here], Occasionally they succeed. Mostly they don’t.

One clinician’s letter deserves special attention because it goes into the evidence, and the costs, in some detail. Its conclusions are very different from those in the NICE guidance.

The letter, a Review of NICE guidance, is from Dr C.J.D. Wells [download the whole letter].   He is a pain relief consultant from Liverpool.

Let’s look at some highlights.

Wells points out the absurdity of the cost estimates

“In the pricing section, they estimate that this will require an increase of facilities so that 3,500 patients can be treated instead of 1,000 at present (again see comments on pricing). This is not many treatments for the 20 million sufferers, of whom we can estimate that at least 2 million will have significant long-term disability and psychological distress”

And that is without even costing all the secondary costs of miseducating a new generation of students in fables about “Qi”, meridians, energy flow, subluxations and innate intelligence.

“The abysmal ignorance of the committee is reflected in the poor overall advice. So if you have a committee with special interests in Exercise, Manipulation, PMP’s, and Surgery, and you call an expert on Acupuncture, you get advice to use Exercise, Manipulation, Acupuncture, PMP’s and Surgery. Amazing.”

Another pain consutant, Charles Guaci, says in a comment in the Daily Mail.

I am a Pain Consultant of 30 years experience, have published two books (one translated into different languages).

NICE never asked me for my opinion.

This is the most ridicuculous pseudo-scientific document I have ever seen.

The panel consisted of a surgeon, psychologist, osteopath, acupuncturist a physiotherapist and an academic; not one pain consultant! The conclusions are simply a means of increasing the employment of their friends!

All evidence submitted to NICE was ignored.

It is almost certain than unless NICE rethink their ideas that Pain Consultants will be seeking a judicial review as well as full disclosure of how the panel arrived at their bizarre findings under the Freedom of information act.

Patients should realise that they are being taken for a ride.

Despite the outcry from opponents of magic medicine and from pain specialists, the assessment by the normally excellent NHS Choices site was disappointing. It made no mention at all of the secondary consequences of recommending CAM and described the assertions of the guidance group quite uncritically.

### The reputation of NICE

NICE has been criticised before, though usually unjustly. In the past I have often supported them. For example. when NICE said that treatment of dementia with anticholinesterase drugs like galantamine was ineffective, there was a great outcry, but NICE were quite right. There is little or no rationale for such treatments, and more importantly, very little evidence that they work. But patients, especially when they are desperate, have greater faith in drug treatments than most pharmacologists, They want to clutch at straws. A bit like the NICE guidance committee, faced with a bunch of treatments most of which are almost ineffective, clutched at the straws of acupuncture and chiropractic. But this time it isn’t only the patients who are cross. It is most of the medical and scientific world too.

One interpretation of these bizarre events is that they represent a case of medical/scientific arrogance. Ben Goldacre wrote of another aspect of the same problem thus week, in Dodgy academic PR [download the paper on which this is based].

The first job of a scientist is to say openly when the answer to a question is not known. But scientists are under constant pressure to exaggerate the importance of their results. Last year we published an article which I feel may, if verified, turn out to be the second most important that I have ever been an author on. Because it happened to be published in Nature (not because of its quality), a press release was written (by an arts graduate!). It took some argument to prevent the distorted and exaggerated account being imposed on the public. This is typical of the sort of thing reported in Goldacre’s column. I reported a similar case a while ago, Why honey isn’t a wonder cough cure: more academic spin.

If NICE does not reconsider this guidance, it is hard to see how it can be taken seriously in the future. I hope that when NICE’s director, Professor Sir Michael Rawlins, returns from his trips abroad, he will find time to look at the case himself.

Indirectly, then, it can be argued that NICE’s bizarre guidance is just another manifestation of the management of science being passed from the hands of scientists into the hands of administrators and spin experts. It is yet another example of DC’s rule

Never trust anyone who uses the word ‘stakeholder’

Some bone-headed bureaucrat decides that any charlatan or quack is a ‘stakeholder’ in the provision of NHS care and gives them a quite disproportionate say in how taxpayers’ money is spent. The bureaucrats are so busy following processes and procedures, ticking boxes, and so deficient in scientific education, that they failed to notice that they’ve been caught out by the old trick of used car salesmen, bait and switch.

### The consequences

The expected consequences have already started to materialise. The Prince of Wales’ Foundation for Magic Medicine is jubilant about having been endorsed by NICE. And I’m told that “The chiropractors have now just written letters to all health boards in Scotland asking for contracts for their services to deal with back pain”.

There could hardly have been a worse time for NICE to endorse chiropractic. We are in the middle of a storm about free speech because of the disgraceful action of the British Chiropractic Associaton in suing one of our best science writers, Simon Singh, for defamation because he had the temerity to express an opinion, Of course, even if the BCA wins in court, it will be the overall loser, because chiropractic claims are now being scrutinised as never before (just look at what they told me).

### Follow-up

A much-cited paper. The paper that is most often cited by chiropractors who claim to be able to cure colic by spinal manipulation is Klougart N, Nilsson N and Jacobsen J (1989) Infantile Colic Treated by Chiropractors: A Prospective Study of 316 Cases, J Manip Physiol Ther,12:281-288. This is not easy to get hold of but Steve Vogel has sent me s scanned copy which you can download here. As evidence it is about as useless as the infamous Spence study so beloved of homeopaths. There was no control group at all. It simply follows 316 babies and found that most of them eventually got better. Well, they do, don’t they? It is a sign of the pathetic standard of reaearch in chiropractic that anyone should think this paper worth mentioning at all.

June 6 2009. More flak for NICE from the Royal College of Anaesthetists, and more adverse comment in the BMJ. And of course the blogs. for example, “If this is “evidence based medicine” I want my old job back“.

“Acupuncture on the NHS: a dangerous precedent”: a good analysis at counterknowledge.com.

June 6 2009, Comment sent to the BMJ. The comment was submitted, as below, early on Friday 5th June. The BMJ said it was a “sensitive issue” and for the next five days lawyers pondered over it.

Underwood and Littlejohns describe their guidance as being a “landmark”. I can only agree with that description. It is the first time that NICE has ever endorsed alternative medicine in the face of all the evidence. The guidance group could hardly have picked a worse moment to endorse chiropractic. Chiropractors find it so hard to find evidence for their practices that, when one of our finest science writers, Simon Singh, asked to see the evidence they sued him for defamation. I suggest that the guidance group should look at the formidable list of people who are supporting Singh, after his brave decision to appeal against this iniquitous persecution.

Of course I’m sure this bizarre decision has nothing to do with the presence on the guidance group of Peter Dixon, chair of the General Chiropractic Council. Nevertheless, I am curious to know why it is that when I telephoned two of the practices belonging to Peter Dixon Associates, I was told that they could probably treat infantile colic and asthma. Such claims have just been condemned by the Advertising Standards Authority.

The low back pain guidance stands a good chance of destroying NICE’s previously excellent reputation for dispassionate assessment of benefits and costs. Yes, that is indeed a landmark of sorts.

If NICE is ever to recover its reputation, I think that it will have to start again. Next time it will have to admit openly that none of the treatments work very well in most cases. And it will have to recognise properly the disastrous cultural consequences of giving endorsement to people who, when asked to produce evidence, resort to legal intimidation.

Eventually, on Wednesday 10 June the comment appeared in the BMJ, and it wasn’t greatly changed. Nevertheless if is yet another example of legal chill. This is the final version.

Underwood and Littlejohns describe their guidance as being a “landmark”. I can only agree with that description. It is the first time that NICE has ever endorsed alternative medicine in the face of all the evidence. The guidance group could hardly have picked a worse moment to endorse chiropractic. Chiropractors are so sensitive about criticisms of their practices that, when one of our finest science writers, Simon Singh, queried the evidence-base for their therapeutic claims they sued him for defamation. I suggest that the guidance group should look at the formidable list of people who are supporting Singh, after his brave decision to appeal against an illiberal court ruling in this iniquitous persecution.

One wonders whether this bizarre decision by NICE has anything to do with the presence on the guidance group of Peter Dixon, chair of the General Chiropractic Council. I am also curious to know why it is that when I telephoned two of the practices belonging to Peter Dixon Associates, I was told that chiropractic could be effective in the treatment of infantile colic and asthma. Similar claims about treating colic have just been condemned by the Advertising Standards Authority.

The low back pain guidance stands a good chance of destroying NICE’s previously excellent reputation for dispassionate assessment of benefits and costs. Yes, that is indeed a landmark of sorts.

If NICE is ever to recover its reputation, I think that it will have to start again. Next time it will have to admit openly that none of the treatments works very well in most cases. And it will have to recognise properly the disastrous cultural consequences of giving endorsement to people who, instead of engaging in scientific debate, resort to legal intimidation.

Bait and switch. Oh dear, oh dear. Just look at this. British Chiropractic Association tell their members to hide their sins from prying eyes.

Excellent round-up of the recent outburst of writing about “chiroquacktic” (Tut, tut, is there no respect?).

Dr Crippen writes “NICE recommends a cure for all known disease” [Ed some exaggeration, surely]

### Notice

I heard, in January 2011, that Barts has a new Dean of Education, and no longer teaches about alternative medicine in the way that has caused so much criticism in the last two years. That’s good news.

What on earth has gone wrong at the Barts and The London School of Medicine and Dentistry (SMD)?

It is not so long ago that I discovered that the very sensible medical students at Barts were protesting vigourously about being forced to mix with various quacks.  A bit of investigation soon showed that the students were dead right: see St Bartholomew’s teaches antiscience, but students revolt.

Now it seems that these excellent students have not yet succeeded in educating their own  Dr Mark Carroll who, ironically, has the title Associate Dean (Education Quality) in the Centre for Medical Education (SMD), specialising in all aspects of quality assurance in the SMD,

Recently this letter was sent to all medical students.  They are so indignant at the way they are being treated, it didn’t take long for a copy of the letter to reach me via a plain brown email.

 Does any medical student have a particular interest in Complementary Medicine?  If so, a group at Westminster University would like to contact you (see email message below) with a view to some collaborative work.  Further details from Dr Mark Carroll ( m.carroll@qmul.ac.uk ). I am writing this email to put you in contact with **** ******, who is a Naturopathy student at Westminster University and who has set up a Society for Integrated Health, which is closely affiliated with the Society of Complementary Medicine at University College London Hospital.  **** is keen to create a network of connections between student complementary practitioners and medical students and, given Barts’ teaching commitment to integrated approaches, I wondered if you could have put **** in contact with any individual student or group of students that might be interested in joining her developing network of practitioners “crossing the divide”.  Given that Barts is “ahead of the game” I have suggested to **** that she should affiliate Barts among a number of other hospitals to her fast developing group. — Dr Mark Carroll

A student of naturopathy?  Does Mark Carroll have the slightest idea what naturopathy is (or pretends to be)?   If so, why is he promoting it? If not, he clearly hasn’t done his homework.

You can get a taste of naturopathy in Another worthless validation: the University of Wales and nutritional therapy, or in Nutritional Fairy Tales from Thames Valley University.

It is a branch of quackery that is so barmy that it’s actually banned in some US states. A pharmacist was fined $1 miilion for practising it. But Barts encourages it. Or read here about the College of Natural Nutrition: bizarre teaching revealed. They claim to cure thyroid cancer with castor oil compresses, and a holder of their diploma was fined £800 000 for causing brain damage to a patient. I removed the name of the hapless naturopathy student, I have no wish for her to get abusive mail. It isn’t her fault that she has been misled by people who should know better. If you feel angry about this sort of thing then that should be directed to the people who mislead them. The poor student has been misled in to taking courses that teach amethysts emit high yin energy by the University of Westminster’s Vice-chancellor, Professor Geoffrey Petts, But note that Professor Petts has recently set up a review of the teaching of what he must know to be nonsense (though it hasn’t got far yet). In contrast, Dr Carroll appears to be quite unrepentant. He is the person you to whom you should write if you feel indignant. He claims Barts is "ahead of the game". Which game? Apparently the game of leading medicine back to the dark ages and the High Street quack shop. But, Dr Carroll, it isn’t a game. Sick people are involved. Dr Carroll is the Associate Dean (Education Quality) in the Centre for Medical Education (SMD), specialising in all aspects of quality assurance in the SMD. This has to be the ultimate irony. It’s true that the Prince of Wales approach to medicine has penetrated slightly into other, otherwise good, medical schools (for example, Edinburgh) but I’m not aware of any other that has gone so far down the road of irrationality as at Barts. Dr Carroll, I suggest you listen to your students a bit more closely. You might also listen to President Obama. He has just allocated$1.1 billion “to compare drugs, medical devices, surgery and other ways of treating specific conditions“. This has infuriated the drug industry and far-right talk show host Rush Limbaugh. Doubtless it will infuriate quacks too, if any of it is spent on testing their treatments properly.

### Follow-up

I’m perfectly happy to think of alternative medicine as being a voluntary, self-imposed tax on the gullible (to paraphrase Goldacre again). But only as long as its practitioners do no harm and only as long as they obey the law of the land.  Only too often, though, they do neither.

When I talk about law, I don’t mean lawsuits for defamation.  Defamation suits are what homeopaths and chiropractors like to use to silence critics. heaven knows, I’ve becomes accustomed to being defamed by people who are, in my view. fraudsters, but lawsuits are not the way to deal with it.

I’m talking about the Trading Standards laws   Everyone has to obey them, and in May 2008 the law changed in a way that puts the whole health fraud industry in jeopardy.

The gist of the matter is that it is now illegal to claim that a product will benefit your health if you can’t produce evidence to justify the claim.

I’m not a lawyer, but with the help of two lawyers and a trading standards officer I’ve attempted a summary.  The machinery for enforcing the law does not yet work well, but when it does, there should be some very interesting cases.

The obvious targets are homeopaths who claim to cure malaria and AIDS, and traditional Chinese Medicine people who claim to cure cancer.

But there are some less obvious targets for prosecution too.   Here is a selection of possibilities to savour..

• Universities such as Westminster, Central Lancashire and the rest, which promote the spreading of false health claims
• Hospitals, like the Royal London Homeopathic Hospital, that treat patients with mistletoe and marigold paste. Can they produce any real evidence that they work?
• Edexcel, which sets examinations in alternative medicine (and charges for them)
• Ofsted and the QCA which validate these exams
• Skills for Health and a whole maze of other unelected and unaccountable quangos which offer “national occupational standards” in everything from distant healing to hot stone therapy, thereby giving official sanction to all manner of treatments for which no plausible evidence can be offered.
• The Prince of Wales Foundation for Integrated Health, which notoriously offers health advice for which it cannot produce good evidence
• Perhaps even the Department of Health itself, which notoriously referred to “psychic surgery” as a profession, and which has consistently refused to refer dubious therapies to NICE for assessment.

The law, insofar as I’ve understood it, is probably such that only the first three or four of these have sufficient commercial elements for there to be any chance of a successful prosecution.  That is something that will eventually have to be argued in court.

But lecanardnoir points out in his comment below that The Prince of Wales is intending to sell herbal concoctions, so perhaps he could end up in court too.

### The laws

We are talking about The Consumer Protection from Unfair Trading Regulations 2008.  The regulations came into force on 26 May 2008.   The full regulations can be seen here,  or download pdf file. They can be seen also on the UK Statute Law Database.

The Office of Fair Trading, and Department for Business, Enterprise & Regulatory Reform (BERR) published Guidance on the Consumer Protection from Unfair Trading Regulations 2008 (pdf file),
Statement of consumer protection enforcement principles (pdf file), and
The Consumer Protection from Unfair Trading Regulations: a basic guide for business (pdf file).

Has The UK Quietly Outlawed “Alternative” Medicine?

On 26 September 2008, Mondaq Business Briefing published this article by a Glasgow lawyer, Douglas McLachlan.   (Oddly enough, this article was reproduced on the National Center for Homeopathy web site.)

“Proponents of the myriad of forms of alternative medicine argue that it is in some way “outside science” or that “science doesn’t understand why it works”. Critical thinking scientists disagree. The best available scientific data shows that alternative medicine simply doesn’t work, they say: studies repeatedly show that the effect of some of these alternative medical therapies is indistinguishable from the well documented, but very strange “placebo effect” ”

“Enter The Consumer Protection from Unfair Trading Regulations 2008(the “Regulations”). The Regulations came into force on 26 May 2008 to surprisingly little fanfare, despite the fact they represent the most extensive modernisation and simplification of the consumer protection framework for 20 years.”

The Regulations prohibit unfair commercial practices between traders and consumers through five prohibitions:-

• General Prohibition on Unfair Commercial
Practices (Regulation 3)
• Prohibition on Misleading Actions (Regulations 5)
• Prohibition on Misleading Omissions (Regulation 6)
• Prohibition on Aggressive Commercial Practices (Regulation 7)
• Prohibition on 31 Specific Commercial Practices that are in all Circumstances Unfair (Schedule 1).  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 definition of “product” in the Regulations includes services, so it does appear that all forms medical products and treatments will be covered.

Just look at 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”

Section 5 is equally powerful, and also does not contain the contentious word “cure” (see note below)

5.—(1) A commercial practice is a misleading action if it satisfies the conditions in either paragraph (2) or paragraph (3).

(2) A commercial practice satisfies the conditions of this paragraph—

(a) if it contains false information and is therefore untruthful in relation to any of the matters in paragraph (4) or if it or its overall presentation in any way deceives or is likely to deceive the average consumer in relation to any of the matters in that paragraph, even if the information is factually correct; and

(b) it causes or is likely to cause the average consumer to take a transactional decision he would not have taken otherwise.

These laws are very powerful in principle, But there are two complications in practice.

One complication concerns the extent to which the onus has been moved on to the seller to prove the claims are true, rather than the accuser having to prove they are false. That is a lot more favourable to the accuser than before, but it’s complicated.

The other complication concerns enforcement of the new laws, and at the moment that is bad.

### Who has to prove what?

That is still not entirely clear.  McLachlan says

“If we accept that mainstream evidence based medicine is in some way accepted by mainstream science, and alternative medicine bears the “alternative” qualifier simply because it is not supported by mainstream science, then where does that leave a trader who seeks to refute any allegation that his claim is false?

Of course it is always open to the trader to show that his the alternative therapy actually works, but the weight of scientific evidence is likely to be against him.”

On the other hand, I’m advised by a Trading Standards Officer that “He doesn’t have to refute anything! The prosecution have to prove the claims are false”.  This has been confirmed by another Trading Standards Officer who said

“It is not clear (though it seems to be) what difference is implied between “cure” and “treat”, or what evidence is required to demonstrate that such a cure is false “beyond reasonable doubt” in court. The regulations do not provide that the maker of claims must show that the claims are true, or set a standard indicating how such a proof may be shown.”

The main defence against prosecution seems to be the “Due diligence defence”, in paragraph 17.

Due diligence defence

17. —(1) In any proceedings against a person for an offence under regulation 9, 10, 11 or 12 it is a defence for that person to prove—

(a) that the commission of the offence was due to—

(i) a mistake;

(ii) reliance on information supplied to him by another person;

(iii) the act or default of another person;

(iv) an accident; or

(v) another cause beyond his control; and

(b) that he took all reasonable precautions and exercised all due diligence to avoid the commission of such an offence by himself or any person under his control.

If “taking all reasonable precautions” includes being aware of the lack of any good evidence that what you are selling is effective, then this defence should not be much use for most quacks.

Douglas McLachlan has clarified, below, this difficult question

### False claims for health benefits of foods

A separate bit of legislation, European regulation on nutrition and health claims made on food, ref 1924/2006, in Article 6, seems clearer in specifying that the seller has to prove any claims they make.

Article 6

Scientific substantiation for claims

1. Nutrition and health claims shall be based on and substantiated by generally accepted scientific evidence.

2. A food business operator making a nutrition or health claim shall justify the use of the claim.

3. The competent authorities of the Member States may request a food business operator or a person placing a product on the market to produce all relevant elements and data establishing compliance with this Regulation.

That clearly places the onus on the seller to provide evidence for claims that are made, rather than the complainant having to ‘prove’ that the claims are false.

On the problem of “health foods” the two bits of legislation seem to overlap.  Both have been discussed in “Trading regulations and health foods“, an editorial in the BMJ by M. E. J. Lean (Professor of Human Nutrition in Glasgow).

“It is already illegal under food labelling regulations (1996) to claim that food products can treat or prevent disease. However, huge numbers of such claims are still made, particularly for obesity ”

“The new regulations provide good legislation to protect vulnerable consumers from misleading “health food” claims. They now need to be enforced proactively to help direct doctors and consumers towards safe, cost effective, and evidence based management of diseases.”

In fact the European Food Standards Agency (EFSA) seems to be doing a rather good job at imposing the rules. This, predictably, provoked howls of anguish from the food industry There is a synopsis here.

“Of eight assessed claims, EFSA’s Panel on Dietetic Products, Nutrition and Allergies (NDA) rejected seven for failing to demonstrate causality between consumption of specific nutrients or foods and intended health benefits. EFSA has subsequently issued opinions on about 30 claims with seven drawing positive opinions.”

“. . .  EFSA in disgust threw out 120 dossiers supposedly in support of nutrients seeking addition to the FSD’s positive list.

If EFSA was bewildered by the lack of data in the dossiers, it needn’t hav been as industry freely admitted it had in many cases submitted such hollow documents to temporarily keep nutrients on-market.”

Or, on another industry site, “EFSA’s harsh health claim regime

“By setting an unworkably high standard for claims substantiation, EFSA is threatening R&D not to mention health claims that have long been officially approved in many jurisdictions.”

Here, of course,”unworkably high standard” just means real genuine evidence. How dare they ask for that!

### Enforcement of the law

19. —(1) It shall be the duty of every enforcement authority to enforce these Regulations.
(2) Where the enforcement authority is a local weights and measures authority the duty referred to in paragraph (1) shall apply to the enforcement of these Regulations within the authority’s area.

Nevertheless, enforcement is undoubtedly a weak point at the moment. The UK is obliged to enforce these laws, but at the moment it is not doing so effectively.

A letter in the BMJ from Rose & Garrow describes two complaints under the legislation in which it appears that a Trading Standards office failed to enforce the law. They comment

” . . . member states are obliged not only to enact it as national legislation but to enforce it. The evidence that the government has provided adequate resources for enforcement, in the form of staff and their proper training, is not convincing. The media, and especially the internet, are replete with false claims about health care, and sick people need protection. All EU citizens have the right to complain to the EU Commission if their government fails to provide that protection.”

This is not a good start.   A lawyer has pointed out to me

“that it can sometimes be very difficult to get Trading Standards or the OFT to take an interest in something that they don’t fully understand. I think that if it doesn’t immediately leap out at them as being false (e.g “these pills cure all forms of cancer”)  then it’s going to be extremely difficult. To be fair, neither Trading Standards nor the OFT were ever intended to be medical regulators and they have limited resources available to them. The new Regulations are a useful new weapon in the fight against quackery, but they are no substitute for proper regulation.”

Trading Standards originated in Weights and Measures.   It was their job to check that your pint of beer was really a pint. Now they are being expected to judge medical controversies. Either they will need more people and more training,  or responsibility for enforcement of the law should be transferred to some more appropriate agency (though one hesitates to suggest the MHRA after their recent pathetic performance in this area).

### Who can be prosecuted?

Any “trader”, a person or a company. There is no need to have actually bought anything, and no need to have suffered actual harm. In fact there is no need for there to be a complainant at all. Trading standards officers can act on their own. But there must be a commercial element. It’s unlikely that simply preaching nonsense would be sufficient to get you prosecuted, so the Prince of Wales is, sadly, probably safe.

Universities who teach that “Amethysts emit high Yin energy” make an interesting case. They charge fees and in return they are “falsely claiming that a product is able to cure illnesses”.
In my view they are behaving illegally, but we shan’t know until a university is taken to court.  Watch this space.

The fact remains that the UK is obliged to enforce the law and presumably it will do so eventually. When it does, alternative medicine will have to change very radically. If it were prevented from making false claims, there would be very little of it left apart from tea and sympathy

### Follow-up

New Zealand must have similar laws.
Just as I was about to post this I found that in New Zealand a

“couple who sold homeopathic remedies claiming to cure bird flu, herpes and Sars (severe acute respiratory syndrome) have been convicted of breaching the Fair Trading Act.”

They were ordered to pay fines and court costs totalling \$23,400.

A clarification form Douglas McLachlan

On the difficult question of who must prove what, Douglas McLachlan, who wrote Has The UK Quietly Outlawed “Alternative” Medicine?, has kindly sent the following clarification.

“I would agree that it is still for the prosecution to prove that the trader committed the offence beyond a reasonable doubt, and that burden of proof is always on the prosecution at the outset, but I think if a trader makes a claim regarding his product and best scientific evidence available indicates that that claim is false, then it will be on the trader to substantiate the claim in order to defend himself. How will the trader do so? Perhaps the trader might call witness after witness in court to provide anecdotal evidence of their experiences, or “experts” that support their claim – in which case it will be for the prosecution to explain the scientific method to the Judge and to convince the Judge that its Study evidence is to be preferred.

Unfortunately, once human personalities get involved things could get clouded – I could imagine a small time seller of snake oil having serious difficulty, but a well funded homeopathy company engaging smart lawyers to quote flawed studies and lead anecdotal evidence to muddy the waters just enough for a Judge to give the trader the benefit of the doubt. That seems to be what happens in the wider public debate, so it’s easy to envisage it happening a courtroom.”

The “average consumer”.

(3) A commercial practice is unfair if—

(a) it contravenes the requirements of professional diligence; and

(b) it materially distorts or is likely to materially distort the economic behaviour of the average consumer with regard to the product.

It seems,therefore, that what matters is whether the “average consumer” would infer from what is said that a claim was being made to cure a disease. The legal view cited by Mojo (comment #2, below) is that expressions such as “can be used to treat” or “can help with” would be considered by the average consumer as implying successful treatment or cure.

The drugstore detox delusion. A nice analysis “detox” at .Science-based Pharmacy

It’s hard enough to communicate basic ideas about how to assess evidence to adults without having the effort hindered by schools.

The teaching of quackery to 16 year-olds has been approved by a maze of quangos, none  of which will take responsibility, or justify their actions. So far I’ve located no fewer than eight of them.

[For non-UK readers, quango = Quasi-Autonomous Non-Governmental Organisation].

A lot of odd qualifications are accredited by OfQual (see here).  Consider, for example, Edexcel Level 3 BTEC Nationals in Health and Social Care (these exams are described here), Download the specifications here and check page 309.

Unit 23: Complementary Therapies for Health and Social Care
NQF Level 3: BTEC National
Guided learning hours: 60

Unit abstract

“In order to be able to take a holistic view towards medicine and health care, health and social care professionals need to understand the potential range of complementary therapies available and how they may be used in the support of conventional medicine.”

Well, Goldacre has always said that homeopathy makes the perfect vehicle for teaching how easy it is to be deceived by bad science, so what’s wrong?  But wait

“Learners will consider the benefits of complementary therapies to health and wellbeing, as well as identifying any contraindications and health and safety issues in relation to their use.”

Then later

“The holistic approach to illnesses such as cancer could be used as a focus here. For example, there could be some tutor input to introduce ideas about the role of complementary therapies in the treatment and management of cancer, this being followed up by individual or small group research by learners using both the internet and the services available locally/regionally. If available, a local homeopathic hospital, for example, would be an interesting place to visit.”

It’s true that to get a distinction, you have to “evaluate the evidence relating to the use of complementary therapies in contemporary society”, but it isn’t at all clear that this refers to evidence about whether the treatment works.

The really revealing bit comes when you get to the

There are many resources available to support this unit.

Websites
www.acupuncture.org.uk British Acupuncture Council
www.bant.org.uk British Association for Nutritional Therapy
www.exeter.ac.uk/sshs/compmed Exeter University’s academic department of Complementary medicine
www.gcc-uk.org General Chiropractic Council
www.nimh.org.uk National Institute of Medical Herbalists
www.nursingtimes.net The Nursing Times
www.osteopathy.org.uk General Osteopathic Council
www.the-cma.org.uk The Complementary Medical Association”

This list is truly astonishing. Almost every one of them can be relied on to produce self-serving inaccurate information about the form of “therapy” it exists to promote. The one obvious exception is the reference to Exeter University’s academic department of complementary medicine (and the link to that one is wrong). The Nursing Times should be an exception too, but their articles about CAM are just about always written by people who are committed to it.

It is no consolation that the 2005 version was even worse.  In its classification of ‘therapies’ it said “Pharmaceutically mediated: eg herbalism, homeopathy “. Grotesque! And this is the examinng body!

### The Teacher

This particular educational disaster came to my attention when I had a letter from a teacher.  She had been asked to teach this unit, and wanted to know if I could provide any resources for it.  She said that Edexcel hadn’t done so. She asked ” Do you know of any universities that teach CT’s [sic] so I could contact them about useful teaching resources?.” She seemed to think that reliable information about homeopathy could be found from a ‘university’ homeopathy teacher.  Not a good sign. It soon emerged why.
She said.

“My students are studying BTEC National Health Studies and the link is Edexcel BTEC National Complimentary [sic] studies.”

“I am a psychotherapist with an MA in Education and Psychology. I am also trained in massage and shiatsu and have plenty of personal experience of alternative therapy”

Shiatsu uh? It seems the teacher is already committed to placebo medicine.  Nevertheless I spent some time looking for some better teaching material for 16 year-old children.  There is good stuff at Planet
Science
, and in some of the pamphlets from Sense about Science, not least their latest, I’ve got nothing to lose by trying it – A guide to weighing up claims about cures and treatments.  I sent all this stuff to her, and prefaced the material by saying

“First of all, I should put my cards on the table and say that I am quite appalled by the specification of Unit 23. In particular, it has almost no emphasis at all on the one thing that you want to know about any therapy, namely does it work?  The reference list for reading consists almost entirely of organisations that are trying to sell you various sorts of quackery, There is no hint of balance; furthermore it is all quite incompatible with unit 22, which IS concerned with evidence.”

At this point the teacher the teacher came clean too, As always, anyone who disagrees with the assessment (if any) of the evidence by a true believer is unmeasured and inflammatory.

“I have found your responses very unmeasured and inflammatory and I am sorry to say that this prejudicial attitude has meant that I have not found your comments useful.”

shortly followed by

“I am not coming from a scientific background, neither is the course claiming to be scientific.”

That will teach me to spend a couple of hours trying to help a teacher.

### What does Edexcel say?

I wrote to Edexcel’s science subject advisors with some questions about what was being taught. The response that I got was not from the science subject advisors but from the Head of Customer support, presumably a PR person.

 From: (Bola Arabome) 12/11/2008 04.31 PM Dear Professor Colquhoun Thank you for email communication concerning the complementary therapies unit which is available in our BTEC National in Health and BTEC National in Health and Social Care qualifications. I have replied on behalf of Stephen Nugus, our science subject advisor, because your questions do not refer to a science qualification. I would like to answer your questions as directly as possible and then provide some background information relating to the qualifications. The units and whole qualifications for all awarding bodies are accredited by the regulator, the Qualifications and Curriculum Authority. The resource reading list is also produced by us to help teachers and learners. The qualification as a whole is related to the National Occupational Standards for the vocational sectors of Health and Health and social care with consultation taken from the relevant sector skills councils . As you will be aware many of these complementary therapies are available in care centres and health centres under the NHS and in the private sector. The aim of BTEC qualifications is to prepare people for work in these particular sectors. Clearly a critical awareness is encouraged with reference to health and safety and regulation. There are other units, in some cases compulsory, within the qualification with a scientific approach. ‘  ‘  ‘  ‘  ‘ Stephen Harris Head of Customer Support

Aha, so it seems that teaching people to treat sick patients is “not a science qualification”.  Just a business qualification perhaps?.  I haven’t yet managed to reach the people who make these decisions, so I persisted with the PR man. Here is part of the next letter (Edexcel’s reply in italic).

 19 November I find it quite fascinating that Edexcel regards the treatment of sick patients as not being part of science (“do not refer to a science qualification”). Does that mean Edexcel regard the “Health” part of “Health and Social Care” as being nothing to do with science, and that it therefore doesn’t matter if Health Care is unscientific, or even actively anti-scientific? I am sorry if my answer lacked clarity. My comment, that I had taken your enquiry on behalf of our Science Advisor because  this was not a science qualification, was intended to explain why I was replying. It was not intended as a comment on the relationship between Health and Social  Care and science. At Edexcel we use bureaucratic categories where we align our management of qualifications with officially recognised occupational sectors. Often we rely on sector bodies such as Sector Skills Councils to endorse or even approve the qualifications we offer. Those involved in production of our Science qualifications and our Health and Social care qualifications are, as far as I can ascertain, neither anti-scientific nor non-scientific in their approach (4) You say “The qualification as a whole is related to the National Occupational Standards for the vocational sectors of Health and Health and social care with consultation taken from the relevant sector skills councils”. Are you aware that the Skills for Health specifications for Alternative medicine were written essentially by the Prince of Wales Foundation? When I asked them if they would be writing a competence in talking to trees, they took the question totally seriously!! (You can see the transcript of the conversation at http://dcscience.net/?p=215 ). The qualification was approved by both ‘Skills for Health’ and ‘Skills for Care and Development’ prior to being accredited by QCA. It uses the NOS in Health and Social Care as the basis for many of the mandatory units. The ‘Complementary Therapies’ NOS were not used. This was not a requirement of a ‘Health and Social Care’ qualification. “Are the NOS in Health and Social Care that you mention the ones listed here? http://www.ukstandards.org/Find_Occupational_Standards.aspx?NosFindID=1&ClassificationItemId=174 If so, I can see nothing there about ‘complementary therapies’. if I have missed it, I’d be very grateful if you could let me know where it is. If it is not there, I remain very puzzled about the provenance of Unit 23, since you say it is not based on Skills for Health.”

Now we are immediately at sea, struggling under a tidal wave of acronyms for endless overlapping quangos.  In this one short paragraph we have no fewer than four of them. ‘Skills for Health’, ‘Skills for Care and Development’ , ‘Quality and Curriculum Authority (QCA) and NOS.

It seems that the specification of unit 23 was written by Edexcel, but Harris (25 Nov) declines to name those responsible

“When I refer to our “Health and Social care team” I mean the mix of Edexcel Staff and the associates we employ on a contract basis as writers, examiners and  external verifiers.   The writers are generally recruited from those who are involved in teaching and assessment the subjects in schools and colleges. The editorial responsibility lies with the Edexcel Staff. I do not have access to the names of the writers and in any case would not be able to pass on this information. Specifications indicate the managers responsible for authorising publication”

“Edexcel takes full responsibility for its ethical position on this and other issues. However we can not accept responsibility for the opinions expressed in third party materials. There is a disclaimer to this effect at the beginning of the specification. ”
” You have the correct link to the Health NOS . These are the standards, which where appropriate, influence our qualifications. However in the case of Unit 23 I understand that there is no link with the Health NOS. I don’t know if the NOS cover the unit 23 content.”

So, contrary to what I was told at first, neither Skills for Health, nor NOS were involved  Or were they (see below)?

So who does take responsibility?  Aha that is secret.  And the approval by the QCA is also secret.

“I cannot provide you with copies of any correspondence between Skills for Health and  Edexcel. We regard this as confidential. “

### What does the QCA say?

The strapline of the QCA is

“We are committed to building a world-class education and training framework. We develop and modernise the curriculum, assessments, examinations and qualifications.”

Referring school children to the Society of Homeopaths for advice seems to be world-class bollocks rather than world-class education.

When this matter was brought to light by Graeme Paton in the Daily Telegraph, he quoted Kathleen Tattersall, CEO of the QCA. She said

“The design of these diplomas has met Ofqual’s high standards. We will monitor them closely as they are delivered to make sure that learners get a fair deal and that standards are set appropriately.”

Just the usual vacuous bureaucratic defensive sound-bite there. So I wrote to Kathleen Tattersall  myself with some specific questions. The letter went on 2nd September 2008.  Up to today, 26 November, I had only letters saying

“Thank you for your email of 12 November addressed to Kathleen Tattersall, a response is being prepared which will be forwarded to you shortly.”

“Thank you for your email of 25th November addressed to Kathleen Tattersall. A more detailed response is being prepared which will be sent to you shortly.”

Here are some of the questions that I asked.

 I wrote to Edexcel’s subject advisors about unit 23 and I was told “your questions do not refer to a science qualification”. This seems to mean that if it comes under the name “Health Care” then the care of sick patients is treated as though it were nothing to do with science, That seems to me to be both wrong and dangerous, and I should like to hear your view about that question. Clearly the fundamental problem here is that the BTEC is intended as a vocational training for careers in alternative medicine, As a body concerned with education, surely you cannot ignore the view of 99% of scientists and doctors that almost all alternative medicine is fraud. That doesn’t mean that you can’t make a living from it, but it surely does create a dilemma for an educational organisation. What is your view of that dilemma?

Eventually, on 27th November, I get a reply (of sorts)  It came not from the Kathleen Tattersall of the QCA but from yet another regulatory body, OfQual, the office of the Qualifications and Examinations Regulator.  You’d think that they’d know the answers, but if they do they aren’t telling, [download whole letter.  It is very short.  The “more detailed response” says nothing.

 Ofqual does not take a view on the detailed content of vocational qualifications as that responsibility sits with the relevant Sector Skills Council which represents employers and others involved in the sector. Ofqual accredits the specifications, submitted by sector-skilled professionals, after ensuring they meet National Occupational Standards.  Ofqual relies on the professional judgement of these sector-skilled professionals to include relevant subjects and develop and enhance the occupational standards in their profession. The accreditation of this BTEC qualification was supported by both Skills for Health, and Skills for Care and Development, organisations which represent the emerging Sector Qualifications Strategies and comply with the relevant National Occupational Standards Isabel Nisbet Acting Chief Executive

So no further forward. Every time I ask a question, the buck gets passed to another quango (or two, or three). This letter, in any case, seems to contradict what Edexcel said about the involvement of Skills for Health (that’s the talking to trees outfit),

### A nightmare maze of quangos

You may well be wondering what the relationship is between Ofqual and the QCA.  There is an ‘explanation’ here.

Ofqual will take over the regulatory responsibilities of the Qualifications and Curriculum Authority (QCA), with stronger powers in relation to safeguarding the standards of qualifications and assessment and an explicit remit as a market regulator. The QCA will evolve into the Qualifications and Curriculum Development Agency (QCDA): supporting Ministers with advice and undertaking certain design and delivery support functions in relation to the curriculum, qualifications, learning and development in the Early Years Foundation Stage, and National Curriculum and Early Years Foundation Stage assessments.

Notice tha QCA won’t be abolished. There will be yet another quango.

The result of all this regulatory bureaucracy seems to be worse regulation, Exactly the same thing happens with accreditiation of dodgy degrees in universities.

At one time, a proposal for something like Unit 23 would have been shown to any competent science teacher, who would have said”you must be joking” and binned it.  Now a few hundred bureaucrats tick their boxes and rubbish gets approved.

There seems to be nobody in any of these quangos with the education to realise that if you want to know the truth about homeopathy, the last person you ask is the Society of Homeopaths or the Prince of Wales.

### What next?

So the mystery remains. I can’t find out who is responsible for the provenance of the appallingly anti-science Unit 23, and I can’t find out how it got approved.  Neither can I get a straight answer to the obvious question about whether it is OK to encourage vocational qualifications for jobs that are bordering on being fraudulent.

.All I can get is platitudes and bland assurances.  Everything that might be informative is clouded in secrecy.

The Freedom of Information requests are in.  Watch this space. But don’t hold your breath.

### Follow-up

Here are some attempts to break through the wall of silence.

Edexcel. I sent them this request.

Freedom of Information Act

Hello

I should like to see please all documents from Edexcel and OfQual or QCA (and communications between then) that concern the formulation and approval of Unit 23 (Complementary Therapies) in the level3 BTEC (page 309 in attached document). In vew of the contentious nature of the subject matter, I believe that is is in the public interest that this information be provided

David Colquhoun

The answer was quite fast, and quite unequivocal, Buzz off.

 Dear Mr Colquhoun, Thank you of your e-mail of today’s date. I note your request for information pursuant to The Freedom of Information Act. As you may know this Act only applies to public bodies and not to the private sector. Edexcel Limited is privately owned and therefore not subject to this Act. Edexcel is therefore not obliged to provide information to you and is not prepared to give you the information you seek. Please do not hesitate to contact me again if you have any further queries. Kate GregoryDirector of Legal ServicesPearson Assessments & TestingOne90 High Holborn, London, WC1V 7BHT: +44 (0)20 7190 5157 / F: +44 (0)207 190 5478Email: kate.gregory@pearson. com

This lack of public accountability just compounds their appalling inability to distinguish education from miseducation.

### International Therapy Examination Council (ITEC)

Mojo’s comment, below, draws attention to the Foundation degree in Complementary Therapies offered by Cornwall College, Camborne, Cornwall (as well as to the fact that the Royal National Lifeboat Institution has been wasting money on ‘research’ on homeopathy –write to them).

At least the courses are held on the Camborne campus of Cornwall College, not on the Duchy campus (do we detect the hand of the Quacktitioner Royal in all this nonsense?).

Cornwall College descends to a new level of barminess in its course Crystal Healing VTCT Level 3

“Who is this course for?

This course is designed to enhance the skills of the Holistic Therapist. Crystals may be used on their own in conjunction with other therapies such as Indian Head Massage, Aromatherapy and Reflexology. Due to the nature of the demands of the holistic programme this course is only suitable for students over the age of 18.”

“What will I be doing on the course?

Students will study the art of Crystal healing which is an energy based treatment where crystals and gemstones are used to channel and focus various energy frequencies.”

 .VTCT stands for the Vocational Training Charitable Trust. It is yet another organisation that runs vocational exams, and it is responsible for this particular horror

The crystals are here. I quote.

Objectives

• the use of interpersonal skills with client
• how to complement other therapies with crystals
• the types and effects of different crystals
• uses of crystals including cleansing, energising, configurations
• concepts of auras and chakras

This is, of course, pure meaningless nonsense. Utter bollocks being offered as further education

Cornwall College has many courses run by ITEC.

The College says

“You will become a professional practitioner with the International Therapy Examination Council (ITEC), study a number of essential modules to give a vocational direction to your study that include: Homeopathy and its application,”

 Who on earth, I hear you cry, are ITEC? That brings us to the seventh organisation in the maze of quangos and private companies involved in the miseducation of young people about science and medicine. It appears, like Edexcel, to be a private company though its web site is very coy about that.

After the foundation degree you can go on to “a brand new innovative BSc in Complementary Health Studies (from Sept 2009)”

The ITEC web site says

Oddly enough, there is no mention of accreditation by a University (not that that is worth much).  So a few more Freedom of Information requests are going off, in an attempt to find out why are kids are being miseducated about science and medicine.

Meanwhile you can judge the effect of all that education in physiology by one of the sample questions for ITEC Unit 4, reflexology.

The pancreas reflex:

A Extends across both feet
B Is on the right foot only
C Is on the left foot only
D Is between the toes on both feet

Uhuh, they seem to have forgotten the option ‘none of the above’.

Or how about a sample question from ITEC Unit 47 – Stone Therapy Massage

Which organ of the body is associated with the element fire?

A Heart
B Liver
C Spleen
D Pancreas

Or perhaps this?

Which incantation makes hot stones work best?

A Incarcerous
C Dissendium
D Expelliarmus.

(OK I made the last one up, with help from Harry Potter, but it makes just about as much sense as the real ones).

And guess what? You can’t use the Freedom of Information Act to find out how this preposterous rubbish got into the educational system because ” ITEC is a private organisation therefore does not come under this legislation”. The ability to conduct business in secret is a side effect of the privatisation of public education is another reason why it’s a bad idea.

### Ofsted

 Ofsted has inspected Cornwall College. They say “We inspect and regulate to achieve excellence in the care of children and young people, and in education and skills for learners of all ages.”. I can find no mention of this nonsense in their report, so I’ve asked them.

Ofsted has admitted a spectacular failure in its inspection of child care in the London Borough of Haringey. Polly Curtis wrote in the Guardian (6 Dec 2008) “We failed over Haringey – Ofsted head”. It was the front page story. But of course Ofsted don’t take the blame, they say they were supplied with false information,

That is precisely what happens whenever a committee or quango endorses rubbish. They look only at the documents sent to them and they don’t investigate, don’t engage their brains.

In the case of these courses in utter preposterous rubbish, it seems rather likely that the ultimate source of the misinformation is the Princes’ Foundation for Integrated Health. Tha views of the Prince of Wales get passed on to the ludicrous Skills for Health and used as a criterion by all the other organisations, without a moment of critical appraisal intervening at any point.

2 December 2008 A link from James Randi has sent the hit rate for this post soaring.  Someone there left are rather nice comment.

“A quango seems to be a kind of job creation for the otherwise unemployable ‘educated ‘( degree in alternative navel contemplation) middle classes who can’t be expected to do anything useful like cleaning latines ( the only other thing they seem qualified for ). I really hate to think of my taxes paying for this codswollop.”