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Marc Clement – DC's Improbable Science

Download Lectures on Biostatistics (1971).
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Marc Clement

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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

“Any advertising you undertake in relation to your professional activities must be accurate. Advertisements must not be misleading, false, unfair or exaggerated”. 

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.

Trading Standards offices and the Office of Fair Trading.

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).

Astoundingly, Trading Standards officers refused to do anything about it.

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.


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.



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.”

Jump to follow-up

The mainstream media eventually catch up with bloggers. BBC1 TV (Wales) produced an excellent TV programme that exposed the enormous degree validation scam run by the University of Wales. It also exposed the uselessness of the Quality Assurance Agency (QAA). Both these things have been written about repeatedly here for some years. It was good to see them getting wider publicity.

Watch the video of the programme (Part 1, and Part 2) "Week In Week Out – University Challenged." “The programme examines how pop stars and evangelical Christians are running colleges offering courses validated by the University of Wales.” (I make a brief appearance, talking about validation of degrees in Chinese Medicine).

U of W

In October 2008 I posted Another worthless validation: the University of Wales and nutritional therapy. With the help of the Freedom of Information Act, it was possible to reveal the mind-boggling incompetence of the validation process used by the University of Wales.

McTimoney College of Chiropractic

The Chiropractic “degrees” from the McTimoney College of Chiropractic are also validated by the University of Wales by an equally incompetent, or perhaps I should say bogus, procedure. More details can be found at The McTimoney Chiropractic Association would seem to believe that chiropractic is “bogus”, and in a later post, Not much Freedom of Information at University of Wales, University of Kingston, Robert Gordon University or Napier University.

Andy Lewis has also written about chiropractic in The University of Wales is Responsible for Enabling Bogus* Chiropractic Claims to be Made.

Sadly the BBC programme did not have much to say about these domestic courses, but otherwise it was excoriating. In particular it had extensive interviews with Nigel Palastanga, whose astonishing admission that courses were validated withour seeing what was taught on them was revealed here two years ago. After that revelation, the vice-chancellor of UoW, Marc Clement BSc PhD CEng CPhys FIET FInstP, promoted Palastanga to be pro-vice-chancellor in charge of Learning, Teaching and Enhancement (I know, you couldn’t make it up).


In the documentary Palastanga said

"It’s a major business. We earn a considerable amount of money."

That was obvious two years ago, but it’s good to hear it from the horse’s mouth.

After a section that revealed a bit about what goes on at two very fundamentalist bible colleges which gave University of Wales degrees, A. C. Grayling commented thus.

"They are there to train advocates for the biblical message and that is absolutely not, by a very very long chalk, what a university should be doing.. . . A respectable British Higher education institution like the University of Wales shouldn’t be touching them with a bargepole."

Undaunted, Palastanga responded

“That’s his opinion. I would say they are validated to the highest standards. They match what are called QAA benchmark. We have serious academics looking at them, and their academic standards are established at the very highest level.”

And if you believe that, you will truly believe anything.

You can download here one of many moderator’s reports obtained under the Freedom of Information Act. This one is for the BSc (Hons) Chiropractic. It is entirely typical of theuncritical boxticking approach to validation, Nowhere does it say "subluxation is nonsense", though even the GCC now admit that.

Traditional Chinese Medicine

The University of Wales validates several courses in what almost everyone but them classifies as quackery. As well as chiropractic and “nutritional therapy”, there is herbalism. For example a course at a college in Barcelona issues University of Wales degrees in Traditional Chinese medicine, a subject that is a menace to public health.. I was asked to comment on the course, and on a bag of herbs that the presenter had been sold to treat depression.

Radix Bupleuri Chinensis
Radix Angelicae Sinensis
Radix Paeoniae Lactiflorae
Rhizoma Atractylodis Macrocephalae
Sclerotium Poriae Cocos
Radix Glycyrrhizae Uralensis
Cortex Moutan Radicis (Paeonia Suffruticosa)
Fructus Gardeniae Jasminoidis
Herba Menthae Haplocalycis
Zingiber officinale rhizome-fresh
Ingredients of a custom mixture.

There is no good evidence that any of the ingredients help depression, in fact next to nothing is known about most of them, apart from liquorice and ginger. Swallowing them would be rather reckless. They fall right into the description of any herbal medicine, in the Patients’ Guide, "Herbal medicine: giving patients an unknown dose of an ill-defined drug, of unknown effectiveness and unknown safety. "

Univ Wales prog

Of the degrees, I said

"There’s no evidence that it [the herbs] does you any good. It may be dangerous because you have no idea of the dose. Degrees in Chinese Medicine consist of three years spent memorising myths and pre-scientific, er, untruths. That isn’t a degree, it’s a travesty."

Palastanga. responded

"We’ve had long debates in the Health Committee about where we would draw the line about what we validate. They have to demonstrate to us that there is some scientific basis for the practice, that there is an established curriculum, that there is an established safe practice."

The presenter asked him "So you are confident that Chinese medicine works? Palastanga replied

" I didn’t say that. I said that there is evidence that it does work . . We are trying to enforce these professions to undertake effective research."

That statement is simply not true, as shown by the response of the validation committee to the application for validation of the course in “Nutritional Therapy” at the Northern College of Acupuncture, documented previously. The fact of the matter is that the validation proceeded without looking at what was actually taught, and without even a detailed timetable of lectures. The committee looked only at the official documents presented to it and was totally negligent in failing to discover some of the bizarre beliefs of the people who were giving the course.

Palastanga went on to raise the usual straw man argument, about how little regular medicine is based on good evidence (though admittedly that is certainly true in his own field -he is a physiotherapist).

Fazley International College Kuala Lumpur


This business college in Kuala Lumpur offered University of Wales degrees. Its 32-year old president is a part time pop star with impressive looking qualifications

Fazley 2

The presenter pointed out that

" His doctorate and his MBA were awarded in that citadel of education, Cambridge. Here he is, pictured at the city’s prestigious business school. He was there for all of four days and walked away with a doctorate. But the degree was not from the University of Cambridge, but from the now defunct "European Business School Cambridge". It never had the right to award degrees."

Neither the University of Wales nor the QAA had noticed this unfortunate fact. Once the TV team had done their job for them, the UoW withdrew support. though, as of 15 November 2010, that is not obvious from Fazley’s web site.

Mr (not Dr) Fazley seemed rather pleased about how students were attracted by the connection with the Prince of Wales. The fact that he is Chancellor of the University of Wales seems not inappropriate, given the amount of quackery they promote.

Quality Assurance Agency (QAA)

In 2007, I wrote, in Nature (see also here),

“Why don’t regulators prevent BSc degrees in anti-science? The Quality Assurance Agency for Higher Education (QAA) claims that “We safeguard and help to improve the academic standards and quality of higher education in the UK.” It costs taxpayers £11.5 million (US$22 million) annually. It is, of course, not unreasonable that governments should ask whether universities are doing a good job. But why has the QAA not noticed that some universities are awarding BSc degrees in subjects that are not, actually, science? The QAA report on the University of Westminster courses awards a perfect score for ‘curriculum design, content and organization,’ despite this content consisting largely of what I consider to be early-nineteenth-century myths, not science. It happens because the QAA judges courses only against the aims set by those who run the QAA, and if their aims are to propagate magic as science, that’s fine.”

That was illustrated perfectly in the documentary when Dr Stephen Jackson of the QAA appeared to try to justify the fact that the QAA had, like the University of Wales, failed entirely to spot any of the obvious problems. He had a nice dark suit, tie and poppy, but couldn’t disguise the fact that the QAA had given high ratings to some very dubious courses.

The QAA sent nine people to the other side of the globe, at a cost of £91,000. They could have done a lot better if they’d spent 10 minutes with Google at home.

Universities UK (UUK)

Needless to say, the Committee of Vice-Chancellors and Principals has said nothing at all. As usual, Laurie Taylor had it all worked out in Times Higher Education (4th November).

Speaking to our reporter Keith Ponting (30), he commended UUK’s decision to say absolutely nothing whatsoever about the abolition of all public funding for the arts and humanities.

He also praised UUK’s total silence on Lord Browne’s view that student courses should primarily be evaluated by their employment returns.

When pressed by Ponting for his overall view of UUK’s failure to respond in any way at all to any aspect of the Browne Review, he described it as “welcome evidence, in a world of change, of UUK’s consistent commitment over the years to ineffectual passivity”.

Meanwhile, a University of Wales video on YouTube

UOW video

Caveat emptor


A couple of days later, a search of Google news for the “University of Wales” shows plenty of fallout. The vice-chancellor claims that ““The Minister’s attack came as a complete and total surprise to me”. That can’t be true. It is over two years since I told him what was going on, and if he was unaware of it, that is dereliction of duty. It is not the TV programme that brought the University into disrepute, it was the vice-chancellor.

It seems very reasonable to suggest that taxpayers have an interest in knowing what is taught in universities.  The recent Pittilo report suggested that degrees should be mandatory in Acupuncture, Herbal Medicine and Traditional Chinese Medicine. So it seems natural to ask to see what is actually taught in these degrees, so one can judge whether it protects the public or endangers them.

Since universities in the UK receive a great deal of public money, it’s easy.  Just request the material under the Freedom of Information Act.

Well, uh, it isn’t as simple as that. 

Every single application that I have made has been refused.  After three years of trying, the Information Commissioner eventually supported my appeal to see teaching materials from the Homeopathy "BSc" at the University of Central Lancashire.  He ruled that every single objection (apart from one trivial one) offered by the universities was invalid.  In particular, it was ruled that univerities were not "commercial" organisations for the purposes of the Act.

So problem solved?  Not a bit of it.  I still haven’t seen any of the materials from the original request because the University of Central Lancashire appealed against the decision and the case of University of Central Lancashire v Information Commissioner is due to be heard on November 3rd, 4th and 5th in Manchester. I’m joined (as lawyers say) as a witness. Watch this space.

UCLan  is not the exception.  It is the rule.  I have sought under the Freedom of Information Act, teaching materials from UClan (homeopathy), University of Salford (homeopathy, reflexology and nutritional therapy), University of Westminster (homeopathy, reflexology and nutritional therapy), University of West of England, University of Plymouth and University of East London, University of Wales (chiropractic and nutritional therapy), Robert Gordon University Aberdeen (homeopathy), Napier University  Edinburgh (herbalism).

In every single case, the request for teaching materials has been refused. And that includes the last three, which were submitted after the decision of the Information Commissioner.  They will send things like course validation documents, but these are utterly uninformative box-ticking documents.  They say nothing whatsoever about what is actually taught.

The fact that I have been able to discover quite a lot about what’s being taught owes nothing whatsoever to the Freedom of Information Act. It is due entirely to the many honest individuals who have sent me teaching materials, often anonymously. We should be grateful to them. Their principles are rather more impressive than those of their principals.

Since this started about three years ago, two of the universities, UCLan and Salford, have shut down entry to all of their CAM courses. And Westminster has shut two of them, with more rumoured to be closing soon. They are to be congratulated for that, but is far from being the end of the matter. The Department of Health, and some of the Royal Colleges, have yet to catch up with the universities, The Pittolo report, which recommends making degrees compulsory, is being considered by the Department of Health. The consultation ends on November 2nd:  if you haven’t yet responded, please do so now (see how here, and here).

A common excuse: the university does not possess teaching materials (yes, really)

Several of the universities claim that they cannot send teaching materials, because they have no access to them. This happens when the university has accredited a course that is run by another, privately run, institution. The place that does the actual teaching, being private, is exempt from the Freedom of Information Act.

The ludicrous corollary of this excuse is that the university has accredited the course without checking on what is taught, and in some cases without even having seen a timetable.

The University of Wales

In fact the University of Wales doesn’t run courses at all. Like the (near moribund) University of London, it acts as a degree-awarding authority for a lot of Welsh Universities. It also validates a lot of courses in non-university institutions, 34 or so of them in the UK, and others scattered round the world. 

Many of them are theological colleges. It does seem a bit odd that St Petersburg Christian University, Russia, and International Baptist Theological Seminary, Prague, should be accredited by the University of Wales.

They also validate the International Academy of Osteopathy, Ghent (Belgium), Osteopathie Schule Deutschland,  the Istituto Superiore Di Osteopatia, Milan,  the Instituto Superior De Medicinas Tradicionales, Barcelona, the Skandinaviska Osteopathögskolan (SKOS) Gothenburg, Sweden and the College D’Etudes Osteopathiques, Canada.

The 34 UK institutions include the Scottish School of Herbal Medicine,  the Northern College of Acupuncture and the Mctimoney College of Chiropractic.

The case of the Nutritional Therapy course has been described already in Another worthless validation: the University of Wales and nutritional therapy. It emerged that the course was run by a grade 1 new-age fantasist. It is worth recapitulating the follow up.

What does the University of Wales say? So far, nothing. Last week I sent brief and polite emails to Professor Palastanga and to

Professor Clement to try to discover whether it is true that the validation process had indeed missed the fact that the course organiser’s writings had been described as “preposterous, made-up, pseudoscientific nonsense” in the Guardian.

So far I have had no reply from the vice-chancellor, but on 26 October I did get an answer from Prof Palastanga.

As regards the two people you asked questions about – J.Young – I personally am not familiar with her book and nobody on the validation panel raised any concerns about it. As for P.Holford similarly there were no concerns expressed about him or his work. In both cases we would have considered their CV’s as presented in the documentation as part of the teaching team. In my experience of conducting degree validations at over 16 UK Universities this is the normal practice of a validation panel.

I have to say this reply confirms my worst fears. Validation committees such as this one simply don’t do their duty. They don’t show the curiosity that is needed to discover the facts about the things that they are meant to be judging. How could they not have looked at the book by the very person that they are validating? After all that has been written about Patrick Holford, it is simply mind-boggling that the committee seems to have been quite unaware of any of it.

It is yet another example of the harm done to science by an unthinking, box-ticking approach.

Incidentally, Professor Nigel Palastanga has now been made Pro Vice-Chancellor (Quality) at the University of Wales and publishes bulletins on quality control. Well well.

The McTimoney College of Chiropractic was the subject of my next  Freedom of Information request to the University of Wales. The reasons for that are, I guess, obvious. They sent me hundreds of pages of validation documents, Student Handbooks (approx 50 pages), BSc (Hons) Chiropractic Course Document. And so on. Reams of it. The documents mostly are in the range of 40 to 100 pages. Tons of paper, but none of it tells you anyhing whatsover of interest about what’s being taught. They are a testament to the ability of universities to produce endless vacuous prose with
very litlle content.

They did give me enough information to ask for a sample of the teaching materials on particular topics. But I gor blank refusal, on the grounds that they didn’t possess them. Only McTimoney had them. Their (unusually helpful) Freedom of Information officer replied thus.

“The University is entirely clear about the content of the course but the day to day timetabling of teaching sessions is a matter for the institution rather than the University and we do not require or possess timetable information. The Act does not oblige us to request the information but there is no reason you should not approach McTimoney directly on this.”

So the university doesn’t know the timetable. It doesn’t know what is taught in lectures, but it is " entirely clear about the content of the course".

This response can be described only as truly pathetic.

Either this is a laughably crude form of obstruction of my request, or perhaps, even more frighteningly, the university really believes that its endless box-ticking documents actually provide some useful control of quality. Perhaps the latter interpretation is more charitable. After all, the QAA, CHRE, UUK and every HR department share similar delusions about what constitutes quality.

Perhaps it is just yet another consequence of having science run largely by people who have never done it and don’t understand it.

Validation is a business. The University of Wales validates no fewer than 11,675 courses altogether. Many of these are perfectly ordinary courses in universities in Wales, but they validate 594 courses at non-Welsh accredited institutions, an activity that earned them £5,440,765 in the financial year 2007/8. There’s nothing wrong with that if they did the job properly. In the two cases I’ve looked at, they haven’t done the job properly. They have ticked boxes but they have not looked at what’s being taught or who is teaching it.

The University of Kingston

The University of Kingston offers a “BSc (Hons)” in acupuncture. In view of the fact that the Pittilo group has recommended degrees in acupuncture, there is enormous public interest in what is taught in such degrees, so I asked.

They sent the usual boring validation documents and a couple of sample exam papers . The questions were very clinical, and quite beyond the training of acupuncturists.  The validation was done by a panel of three, Dr Larry Roberts (Chair, Director of Academic Development, Kingston University), Mr Roger Hill (Accreditation Officer, British Acupuncture Accreditation Board) and Ms Celia Tudor-Evans (Acupuncturist, College of Traditional Acupuncture, Leamington Spa).   So nobody with any scientific expertise, and not a word of criticism.

Further to your recent request for information I am writing to advise that the University does not hold the following requested information:

(1) Lecture handouts/notes and powerpoint presentations for the following sessions, mentioned in Template 3rd year weekend and weekday course v26Aug2009_LRE1.pdf

(a) Skills 17: Representational systems + Colour & Sound ex. Tongue feedback 11

(b) Mental Disease + Epilepsy Pulse feedback 21

(c) 18 Auricular Acupuncture

(d) Intro. to Guasha + practice Cupping, moxa practice Tongue feedback 14

(2) I cannot see where the students are taught about research methods and statistics. I would like to see Lecture handouts/notes and PowerPoint presentations for teaching in this area, but the ‘timetables’ that you sent don’t make clear when or if it is taught.

The BSc Acupuncture is delivered by a partner college, the College of Integrated Chinese Medicine (CICM), with Kingston University providing validation only. As such, the University does not hold copies of the teaching materials used on this course. In order to obtain copies of the teaching materials required you may wish to contact the College of Integrated Chinese Medicine directly.

This completes the University’s response to your information request.

So again we see that Kingston has validated the course but has not seen a timetable, far less what is taught.  My reply was thus

Yes I am exceedingly unhappy about it.  The university attaches its name to the course so it must obviously be able to get the material simply by asking for it (I’m surprised that the university should endorse a course without knowing what is taught on it, but that’s another matter).

I request formally that you obtain this material.  If necessary please read this as a formal appeal.

I await with interest. In every single case so far, the internal review has merely confirmed the initial refusal.  It means a bit of a delay before the case goes to the Information Commisssioner’s Office.

Napier University Edinburgh

Napier University runs a "BSc (Hons) Herbal medicine". (brochure here).  Since herbal medicine is a subject of the Pittilo recommendations, there is enormous public interest in what they teach. So I asked, under the Freedom of Information (Scotland) Act (2002).  They sent quite quickly validation and accreditation documents, some examination papers, timetables and lecture lists.

The validation was the usual vacuous box-ticking stuff though it did reveal that the course “made extensive use of techniques such as tongue and pulse diagnosis”, which are well known phoney diagnosis methods, about as much use as a pendulum (as used at Westminster University).

As at Kingston University, the exam papers they chose to send were mostly "pretend doctor" stuff. One of them was

Discuss the herbal practitioner’s role in the management of IHD [ischaemic heart disease)

How one would like to see what the students said, and, even more one would like to see the model answer.  Amateurs who try to treat potentially serious conditions are a danger to the public.

So then we got to the interesting bit, the request for actual teaching materials.

I have looked at the material that you sent and I’d now like to make the following supplementary request

(A) Lecture notes/handouts and powerpoint slides for the following small smaple of lectures

HRB09102 Materia Medica 4
(1) Zingiber officinalis, Eleutherococcus senticosus, Valeriana officinalis
(2) Gelsemium sempervirens, Cimicifuga racemosa, Datura stramonium, Piscidia erythrina
(3) Betula pendula, Capsella bursa-pastoris, Ephedra sinica, Solidago virgaurea

Materia Medica 3 HRB08103
(1) Cardiovascular system
(2) Nervous system

Clinical Medicine and Diagnosis 4 (HRB09104)
(1) Neuro-sensory deficits, paraesthesiae, head pain

HRB09100 Materia Medica & Herbal Practice
Week 7  Compiling a therapeutic plan and prescription building

BSc Herbal Medicine : Materia Medica HRB07102
Week 3   History of Herbal Medicine Gothean tasting session
Week 10  Energetics  the basic concepts Ayurveda

Lastly, I can see nowhere in the timetable, lectures that deal with

Research methods, clinical trial design and statistics.
If such lectures exist, please send notes and powerpoints for them too

No prizes for guessing the result   Total refusal to send any of them.  To make matters worse, the main grounds for refusal were the very "commercial interests" which, after careful legal examination, the Information Commissioner (for England and Wales) had decided were invalid.  They say too that "The public interest in withholding the information is greater than the public interest in its release".. It is hard to see how the public interest is served by concealing from the people who pay for the degrees what is taught on degrees that Pittilo wants to make compulsory. [Download the whole response]

The matter is now under internal appeal (read the appeal) and eventually we shall find out whether the Scottish Information Commissioner backs the judgement.

Robert Gordon University Aberdeen

This case has particular interest because the Vice-Chancellor of Robert Gordon University is Professor Michael Pittilo, chair of the highly contentious steering group that recommended degress in CAM.  Robert Gordon University (RGU) does not teach herbal medicine or acupuncture. But they do run An Introduction to Homeopathy. All the degrees in homeopathy have closed. It is perhaps the daftest and most discredited of all the popular forms of Magic Medicine.  But Professor Pittilo thinks it is an appropriate subject to teach in his university.

So again I asked for information under the Freedom of Information (Scotland) Act 2002. They sent me quite quckly a list of the powerpoint presentations used on the courses [download it]. I asked for a small sample of the powerpoints.  And again the university did not possess them!

I should like to see only the following three powerpoint presentations in the first instance, please.

Please can you let me know also who produced the powerpoints.

(1) Evidence for homeopathy
(2) First aid remedies
(3) Allergies

I note that you will have to request them but since they are being offered as part of a course offered by RGU, so RGU is responsible for their quality, I presume that this should cause no problem.

The request was refused on much the same grounds as used by Napier University.  As usual, the internal review just confirmed the initial proposal (but dropped the obviously ludicrous public interest defence).  The internal review said

“it is mainly the quality of our courses (including course material) and teaching which has given us the position of "the best modern university in Scotland"

I am bound to ask, if the university is so proud of its course material, why is it expending so much time and money to prevent anyone from seeing a small sample of it?

My appeal has been sent to the Scottish Information Commissioner [download the appeal].

What are vice-chancellors thinking about?

I find it very difficult to imagine what is going through the heads of vice-chancellors who run courses in mumbo-jumbo.   Most of them don’t believe a word of it (though Michael Pittilo might be an exception) yet they foist it on their students. How do they sleep at night?

Recently the excellent Joe Collier wrote a nice BMJ blog which applauded the lack of respect for authority in today’s students, Joe Collier says good riddance to old-fashioned respect. I couldn’t resist leaving a comment.

I couldn’t agree more. There is nothing quite so unnerving as being addressed as “Sir”.

It is an advantage of age that you realise what second-rate people come to occupy very grand positions. Still odder since, if occasionally they are removed for incompetence, they usually move to an even grander position.

I guess that when I was an undergraduate, I found vice-chancellors somewhat imposing. That is, by and large, not a view that survives closer acquaintance.

Should teaching materials be open to the public?

There is only one university in the world that has, as a matter of policy, made all of its teaching material open to the public,  that is the Massachusetts Institute of Technology (MIT).  I can recommend strongly course 18.06, a wonderful set of lectures on Linear Algebra by Gilbert Strang.  (It is also a wonderful demonstration of why blackboards may be better than Powerpoint for subjects like this). Now they are on YouTube too.

A lot of other places have made small moves in the same direction, as discussed recently in Times Higher Education, Get it Out in the Open

Now the OU is working with other British universities to help them develop and share open course materials. In June, at the celebrations for the 40th anniversary of the OU, Gordon Brown announced funding to establish the Support Centre for Open Resources in Education at the OU, as part of a £7.8 million grant designed to enhance the university’s national role.

The funding follows a separate grant of £5.7 million from the Higher Education Funding Council for England for universities across the sector to make thousands of hours of free learning materials available. 

Much material is available on the web, when individual teachers choose to place it there, but at the same time there is a move in the other direction. In particular, the widespread adoption of Moodle has resulted in a big decrease in openness. Usually you have to be registered on a course to see the material. Even other people in the university can’t see it. I think that is a deplorable development (so, presumably, does HEFCE).


I was told by the Univerity of Kingston that

“The course is one which the University has validated and continues to be subject to the University’s quality assurance procedures, such as internal subject reviews, annual monitoring and external examining”

The only conclusion to be drawn from this is that “quality arrurance procedures” work about as well in universities as they did in the case of baby Peter. No doubt they were introduced with worthy aims. But in practice they occupy vast amounts of time for armies of bureaucrats, and because the brain does not need to be engaged they end up endorsing utter nonsenes. The system is broken.

Resistance is futile.  You can see a lot of the stuff here

It is hard to keep secrets in the internet age. Thanks to many wonderful people who have sent me material. you can see plenty of what is taught, despite the desperate attempts of vice-chancellors to conceal it.  Try these links.

What is actually taught

Chinese medicine -acupuncture gobbledygook revealed

Consultation opens on the Pittilo report: help top stop the Department of Health making a fool of itself 

Why degrees in Chinese medicine are a danger to patients 

More make-believe from the University of Westminster. This time its Naturopathy
The last BSc (Hons) Homeopathy closes! But look at what they still teach at Westminster University.
The opposite of science
Bad medicine. Barts sinks further into the endarkenment.
A letter to the Times, and progress at Westminster
Nutritional Fairy Tales from Thames Valley University
Westminster University BSc: amethysts emit high yin energy

References for Pittilo report consultation
A very bad report: gamma minus for the vice-chancellor

The Times (blame subeditor for the horrid title)

Some follow up on the Times piece

The Health Professions Council breaks its own rules: the result is nonsense

One month to stop the Department of Health endorsing quackery.  The Pittilo questionnaire,

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


Jump to follow-up

It seems that validation committees often don’t look beyond the official documents. As a result, the validations may not be worth the paper they are written on. Try this one.

One of the best bits of news recently was the downfall of Matthias Rath.  He’s the man who peddled vitamin pills for AIDS in Africa, and encouraged the AIDS denialists in the South African government.  Thabo Mbeki and his Health Minister, Mrs Beetroot, have gone now, thank heavens.

Rath was one of the best illustrations of the murderous effect of selling ineffective treatments.  The fact that nobody in the “nutritional therapy” industry has uttered a word of condemnation for this man illustrates better than anything one can imagine the corrupt state of “nutritional therapy”.  The people who kept silent include the British Association of Nutritional Therapists (BANT).

It might be surprising, then, to find the Northern College of Acupuncture proudly adding a course in alternative nutrition to its courses in acupuncture (now known to be a theatrical placebo) and Chinese herbal medicine (largely untested and sometimes toxic).  It might be even more surprising to find the boast that the course is validated by the University of Wales.  It seemed a good idea to find out a bit more about how this came about.  Thanks to the Freedom of Information Act, some interesting things can be discovered.

Polly Toynbee’s superb article, Quackery and superstition – available soon on the NHS,  written in January 2008, mentioned diplomas and degrees in complementary therapies offered by, among others, the University of Wales.  This elicited a letter of protest to Toynbee from the Vice-Chancellor of the University of Wales, Professor Marc Clement BSc, PhD, MInstP, CEng,CPhys,FIET.   He invited her to visit the university to see their “validation and monitoring procedures (including the University’s very specific guidelines on health studies disciplines”.

So let’s take a look at these validation procedures and guidelines.

The validation process

The Northern College of Acupuncture submitted a 148 page proposal for the course in October 2007.   The document has all the usual edu-bollocks jargon, but of course doesn’t say much about clinical trials, though it does boast about an unblinded trial of acupuncture published in 2006 which, because of lack of appropriate controls, served only to muddy the waters.  : This submission was considered by the University’s validation committee last December.

Panel of Assessors:

Professor Nigel Palastanga (Chair), Cardiff University

Dr Celia Bell (School of Health and Social Sciences Middlesex University)

Dr John Fish (Moderator designate) (Institute of Biological Sciences University of Wales, Aberystwyth)

Ms Rhiannon Harris (Centre for Nutrition & Dietetics University of Wales Institute,
Cardiff (UWIC))

Ms Felicity Moir (School of Integrated Health University of Westminster)

The whole validation document is only four pages long [download it]. The most interesting thing about it is that the words ‘evidence’ or ‘critical’ do not occur in it a single time.  It has all the usual bureaucratic jargon of such documents but misses entirely the central point.

Does that mean that the University of Wales doesn’t care about evidence or critical thinking?  Well, not on paper. Two years previously a short document called Health Studies Guidelines had been written by Dr Brian Spriggs (Health Studies Validation Consultant, since retired) for the Health Studies Committee, and it was approved on 21 April 2005.  It starts well.

“Degrees in the Health Studies field are expected to promote an understanding of the  importance of the scientific method and an evidence-base to underpin therapeutic interventions and of research to expand that base.”

It even goes on to say that a BSc degree in homeopathy is “unacceptable”.  Don’t get too excited though, because it also says that acupuncture and Chinese herbal  stuff is quite OK.  How anyone can imagine they live up to the  opening sentence beats me.   And it gets worse. It says that all sorts of rather advanced forms of battiness are OK if they form only part of another degree.  They include Homeopathy, Crystal therapy. Dowsing, Iridology; Kinesiology, Radionics, Reflexology, Shiatsu, Healing, and Maharishi Ayurvedic Medicine.

Dowsing? Crystal therapy?  Just let me remind you. We are living in 2008. It is easy to forget that when ploughing through all this new age junk.

The Validation Handbook of Quality Assurance: Health Studies (2007) runs to an astonishing 256 pages [download the whole thing]. On page 12 we find the extent of the problem.

“The University of Wales validates a number of schemes in the Health Studies field. At the current time we have undergraduate and/or postgraduate degree schemes in Acupuncture, Animal Manipulation, Chiropractic, Herbal Medicine, Integrative Psychotherapy, Osteopathy, Osteopathic Studies, Traditional Chinese Medicine and Regulatory Affairs, both in the UK and overseas.”

That sounds pretty shocking.   Further down on page 12, though, we find this.

“Degrees in the Health Studies field are expected to promote an understanding of the importance of the scientific method and an evidence-base to underpin therapeutic interventions and of research to expand that base. The mission is to promote and require the critical evaluation of the practices, doctrines, beliefs, theories and hypotheses that underlie the taught therapeutic measures of the discipline.”

They are indeed fine words. The problem is that I can detect no sign in the submission, nor in its consideration by the validation committee, that any attempt whatsoever was made to ensure that the course complied with these requirements.

The only sign of concern I could detect of any concern about the quality of what was being taught came in a minute to a meeting of the Health Studies Committee meeting on 24th April 2008.

“Members received a copy of an article entitled Quackery and superstition available soon on the NHS which appeared in The Guardian newspaper in January 2008, and a copy of the Vice- Chancellors response. Members agreed that this article was now historical but felt that if/when the issue were to arise again; the key matter of scientific rigour should be stressed. The Committee agreed that this was the most critical element of all degree schemes in the University of Wales portfolio of health studies schemes. It was felt it would be timely to re-examine the schemes within the portfolio as well as the guidelines for consideration of Health Studies schemes at the next meeting. The Committee might also decide that Institutions would be required to include literature reviews (as part of their validation submission) to provide evidence for their particular profession/philosophy. It was agreed that the guidelines would be a vital document in the consideration of new schemes and during preliminary visits to prospective Institutions. “

The Press Office had passed Polly Toynbee’s article to them.  Curiously the Health Studies Committee dismissed it as “historical”, simply because it was written three months earlier.  That is presumably “historical” in the sense that the public will have forgotten about it, rather than in the sense that the facts of the matter have changed since January.  So, at least for the nutrition degree, Toynbee’s comments  were simply brushed under the carpet.

After a few cosmetic changes of wording the validation was completed on 16th January 2008. For example the word “diagnosis” was removed in 43 places and “rewritten in terms of evaluation and assessment”.  There was, needless to say, no indication that the change in wording would change anything in what was taught to students.

You may think that I am being a bit too harsh. Perhaps the course is just fine after all? The problem is that the submission and the reaction of the validation committee tell you next to nothing about what actually matters, and that is what is taught. There is only a vague outline of that in the submission (and part of it was redacted on the grounds that if it were made public somebody might copy ;it.  Heaven forbid).

That is why I have to say, yet again, that this sort of validation exercise is not worth the paper it’s written on.

How can we find out a bit more? Very easily as it happens. Just Google. What matters is not so much formal course outlines but who teaches them.

The nutrition course

The title of the course is just “Nutrition”, not ‘Nutritional Therapy’ or ‘Alternative Nutrition’.  That sounds quite respectable but a glance at the prospectus shows immediately that it is full-blown alternative medicine.

Already in July 2007, the glowing press releases for the course had attracted attention from the wonderfully investigative web site HolfordWatch.   I see no sign that the validation committee was aware of this. But if not, why not? I would describe is as dereliction of academic duty.

“This pioneering course is unique in that it is firmly rooted in both Western nutritional science and naturopathic medicine and also covers concepts of nutrition within traditional Chinese, Japanese, Tibetan and Ayurvedic medicine.

This means that graduates will gain comprehensive understanding of both modern scientific knowledge and ancient wisdom concerning nutrition and dietetics.”

Ancient wisdom, of course, means something that your are supposed to believe though there is no good reason to think it’s true.  In the end, though, almost the only thing that really matters about any course is who is running it.  The brochure shows that all of the people are heavily into every form of alternative nuttiness.

Course Director and Tutor: Jacqueline Young nutritionist, naturopath, clinical psychologist and Oriental medical practitioner

Nutrition Tutors:

Elaine Aldred  (qualified as a chiropractor with the Anglo European Chiropractic College, as an acupuncturist with the British College of Acupuncture and as a Western Medical Herbalist with the College of Phytotherapy. She recently also qualified in Chinese herbal medicine with the Northern College of Acupuncture.)

Sue Russell (3 year diploma in nutritional therapy at the Institute of Optimum Nutrition. She currently practises as a nutritional therapist and also works part-time as a manager at the Northern College of Homeopathic Medicine.)

Anuradha Sharma (graduated as a dietician from Leeds Metropolitan University in 2002 and subsequently completed a Naturopathy certificate and a post-graduate diploma in acupuncture).

Guest Lecturers include : Dr John Briffa, Professor Jane Plant, M.B.E. (a geochemist turned quack), and, most revealingly, none other than the UK’s most notorious media celebrity and pill peddler, Patrick Holford.

So much has been written about Holford’s appalling abuse of science, one would have thought that not even a validation committee could have missed it.

“The course has been created by Jacqueline Young“, so let’s look a bit further at her track record.

Jacqueline Young has written a book, ‘Complementary Medicine for Dummies’ [Ed: ahem shouldn’t that be Dummies for Complementary Medicine?].  You can see parts of it on Google Books. Did the validation committee bother to look at it?  As far as I can tell, the words ‘randomised’ or ‘clinical trial’ occur nowhere in the book.

The chapter on Tibetan medicine is not very helpful when it comes to evidence but for research we are referred to the Tibetan Medical and Astrology Institute.  Guess what? That site gives no evidence either. So far not a single university has endorsed Astrology (there is a profitable niche there for some vice-chancellor).

Here are few samples from the book. The advice seems to vary from the undocumented optimism of this

Well researched?  No. Safe? Nobody knows.  Or this

Mandarin peel prevents colds and flu?  Old wive’s tale.  Then there are things that verge on the weird, like this one

or the deeply bizarre like this

The problem of Jacqueline Young’s fantasy approach to facts was pointed out at least as far back as 2004, by Ray Girvan., who wrote about it again in May 2005. The problems were brought to wider attention when Ben Goldacre wrote two articles in his Badscience column, Imploding Researchers (September 2005), and the following week, Tangled Webs.

“we were pondering the ethics and wisdom of Jacqueline Young dishing out preposterous, made-up, pseudoscientific nonsense as if it was authoritative BBC fact, with phrases such as: “Implosion researchers have found that if water is put through a spiral its electrical field changes and it then appears to have a potent, restorative effect on cells.” “

and later

“Take this from her article on cranial osteopathy, riddled with half truths: “Sutherland found that the cranial bones (the skull bones encasing the brain) weren’t fused in adulthood, as was widely believed, but actually had a cycle of slight involuntary movement.” In fact the cranial bones do fuse in adulthood.

She goes on: “This movement was influenced by the rhythmic flow of cerebrospinal fluid (the nourishing and protective fluid that circulates through the spinal canal and brain) and could become blocked.” There have now been five studies on whether “cranial osteopaths” can indeed feel these movements, as they claim, and it’s an easy experiment to do: ask a couple of cranial osteopaths to write down the frequency of the rhythmic pulses on the same person’s skull, and see if they give the same answer. They don’t. A rather crucial well-replicated finding to leave out of your story.

That was in 2005 and since then all of Young’s “preposterous, made-up, pseudoscientific nonsense” (along with most of the other stuff about junk medicine) has vanished from the BBC’s web site, after some people with a bit of common sense pointed out what nonsense it was.  But now we see them resurfacing in a course validated by a serious university.  The BBC had some excuse (after all, it is run largely by arts graduates). I can see no excuses for the University of Wales.

Incidentally,  thanks to web archive you can still read Young’s nonsense,  long after the BBC removed it.  Here is a quotation.

“Implosion researchers have found that if water is put through a spiral its ,field changes and it then appears to have a potent, restorative effect on cells. In one study, seedlings watered with spiralised water grew significantly faster, higher and stronger than those given ordinary water.”

The vice-chancellor of the University of Wales, Marc Clement, is a physicist (Department of Electrical and Electronic Engineering), so can he perhaps explain the meaning of this?

Selection committees for jobs (especially senior jobs) and validation committees for courses, might make fewer mistakes if they didn’t rely so much on formal documents and did a little more investigation themselves. That sort of thing is why the managerial culture not only takes a lot more time, but also gives a worse result.

It would have taken 10 minutes with Google to find out about Young’s track record, but they didn’t bother. As a result they have spent a long time producing a validation that isn’t worth the paper it’s written on. That makes the University of Wales a bit of a laughing stock. Worse still, it brings science itself into disrepute.


What does the University of Wales say? So far, nothing.   Last week I sent brief and polite emails to Professor Palastanga and to Professor Clement to try to discover whether it is true that the validation process had indeed missed the fact that the course organiser’s writings had been described as “preposterous, made-up, pseudoscientific nonsense” in the Guardian.

So far I have had no reply from the vice-chancellor, but on .26 October I did get an answer from Prof Palastaga.

As regards the two people you asked questions about – J.Young – I personally am not familiar with her book and nobody on the validation panel raised any concerns about it. As for P.Holford similarly there were no concerns expressed about him or his work. In both cases we would have considered their CV’s as presented in the documentation as part of the teaching team. In my experience of conducting degree validations at over 16 UK Universities this is the normal practice of a validation panel.

I have to say this reply confirms my worst fears. Validation committees such as this one simply don’t do their duty. They don’t show the curiosity that is needed to discover the facts about the things that they are meant to be judging. How could they not have looked at the book by the very person that they are validating? After all that has been written about Patrick Holford, it is simply mind-boggling that the committee seems to have been quite unaware of any of it.

It is yet another example of the harm done to science by an unthinking, box-ticking approach.

Pharmacology. A Handbook for Complementary Healthcare Professionals

Elsevier were kind enough to send me an inspection copy of this book, which is written by one of the nutrition course tutors, Elaine Aldred. She admits that pharmacology is “considered by most students to be nothing more that a ‘hoop-jumping’ exercise in the process of becoming qualified”.  She also says. disarmingly. that “I was certainly not the most adept scientist at school and found my university course a trial”.

The book has all the feel of a cut and paste job. It is mostly very simple (if not simplistic). though for no obvious reason it starts with a long (and very amateur) discussion of chemical bonding  Then molecules are admitted to be indivisible (but, guess what, the subject of homeopathy is avoided).  There is a very short section on ion channels, though, bizarrely, it appears under the heading “How do drugs get into cells?”. Since the author is clearly not able to make the distinction between volts and coulombs, the discussion is more likely to confuse the reader than to help.

Then a long section on plants. It starts of by asserting that “approximately a quarter of prescription drugs contain at least one chemical that was originally isolated and extracted from a plant”.. This cannot be even remotely correct.  There are vast tables showing complicated chemical structures, but the usual inadequate
list of their alleged actions  This is followed by a quick gallop through some classes of conventional drugs, illustrated again mainly by chemical structures not data.  Hormone replacement therapy is mentioned, but the chance to point out that it is one of the best illustrations of the need for RCTs is missed.

The one thing that one would really like to see in such a book is a good account of how you tell whether or not a drug works in man. This is relegated to five pages at the end of the book, and it is, frankly, pathetic.  It
is utterly uncritical in the one area that matters more than any other for people who purport to treat patients. All you get is a list of unexplained bullet points.

If this book is the source of the “scientific content” of the nutrition course, things are as bad as we feared.

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