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Quality assessment – DC's Improbable Science

Corrected and searchable version of Google books edition

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The consistent failure of ‘regulators’ to do their job has been a constant theme on this blog. There is a synopsis of dozens of them at Regulation of alternative medicine: why it doesn’t work, and never can. And it isn’t only quackery where this happens. The ineptitude (and extravagance) of the Quality Assurance Agency (QAA) was revealed starkly when the University of Wales’ accreditation of external degrees was revealed (by me and by BBC TV Wales, not by the QAA) to be so bad that the University had to shut down.

Here is another example that you couldn’t make up.

Yes, the Professional Standards Authority (PSA) has agreed to accredit that bad-joke pseudo-regulator, the Complementary & Natural Healthcare Council (CNHC, more commonly known as Ofquack)

Ofquack was created at the instigation of HRH the Prince of Wales, at public expense, as a means of protecting the delusional beliefs of quacks from criticism. I worked for them for a while, and know from the inside that their regulation is a bad joke.

When complaints were made about untrue claims made by ‘reflexologists’, the complaints were upheld but they didn’t even reach the Conduct and Competence committee, on the grounds that the reflexologists really believed the falsehoods that they’d been taught. Therefore, by the Humpty Dumpty logic of the CNHC, their fitness to practise was not affected by their untrue claims. You can read the account of this bizarre incident by the person who submitted the complaints, Simon Perry.

In fact in the whole history of the CNHC, it has received a large number of complaints, but  only one has ever  been considered by their Conduct and Competence Committee.  The rest have been dismissed before they were considered properly.  That alone makes their claim to be a regulator seem ridiculous.

The CNHC did tell its registrants to stop making unjustified claims, but it has been utterly ineffective in enforcing that ruling. In May 2013, another 100 complaints were submitted and no doubt they will be brushed aside too: see Endemic problems with CNHC registrants..

As I said at the time

It will be fascinating to see how the CNHC tries to escape from the grave that it has dug for itself.

If the CNHC implements properly its own code of conduct, few people will sign up and the CNHC will die. If it fails to implement its own code of conduct it would be shown to be a dishonest sham.

In February of this year (2013), I visited the PSA with colleagues from the Nightingale Collaboration. We were received cordially enough, but they seemed to be bureaucrats with no real understanding of science. We tried to explain to them the fundamental dilemma of the regulation of quacks, namely that no amount of training will help when the training teaches things that aren’t true. They were made aware of all of the problems described above. But despite that, they ended up endorsing the CNHC.

### How on earth did the PSA manage to approve an obviously ineffective ‘regulator’?

The job of the PSA is said to be “. . . protecting users of health and social care services and the public”. They (or at least their predecessor, the CHRE), certainly didn’t do that during the saga of the General Chiropractic Council.

The betrayal of reason is catalogued in a PSA document [get local copy]. Here is some nerdy detail.

It is too tedious to go through the whole document, so I’ll deal with only two of its many obvious flaws, the sections that deal with the evidence base, and with training.

The criteria for accreditation state

Standard 6: the organisation demonstrates that there is a defined knowledge base underpinning the health and social care occupations covered by its register or, alternatively, how it is actively developing one. The organisation makes the defined knowledge base or its development explicit to the public.

The Professional Standards Authority recognises that not all disciplines are underpinned by evidence of proven therapeutic value. Some disciplines are subject to controlled randomized trials, others are based on qualitative evidence.  Some rely on anecdotes. Nevertheless, these disciplines are legal and the public choose to use them. The Authority requires organisations to make the knowledge base/its development clear to the public so that they may make informed decisions.

Since all 15 occupations that are “regulated” by the CNHC fall into the last category. they “rely on anecdotes”, you would imagine the fact that “The Authority requires organisations to make the knowledge base/its development clear to the public” would mean that the CNHC was required to make a clear statement that reiki, reflexology etc are based solely on anecdote. Of course the CNHC does no such thing. For example, the CNHC’s official definition of reflexology says

Reflexology is a complementary therapy based on the belief that there are reflex areas in the feet and hands which are believed to correspond to all organs and parts of the body

There is, of course, not the slightest reason to think such connections exist, but the CNHC gives no hint whatsoever of that inconvenient fact. The word “anecdote” is used by the PSA but occurs nowhere on the CNHC’s web site.

It is very clear that the CNHC fails standard 6.

But the PSA managed to summon up the following weasel words to get around this glaring failure:

“The professional associations (that verify eligibility for CNHC registration) were actively involved in defining the knowledge base for each of the 15 professions. The Panel further noted that Skills for Health has lead responsibility for writing and reviewing the National Occupational Standards (NOS) for the occupations CNHC registers and that all NOS have to meet the quality criteria set by the UK Commission for Employment and Skills (UKCES), who are responsible for the approval of all NOS across all industry sectors. The Panel considered evidence provided and noted that the applicant demonstrated that there is a defined knowledge base underpinning the occupations covered by its registers. The knowledge base was explicit to the public”.

The PSA, rather than engaging their own brains, simply defer to two other joke organisations, Skills for Health and National Occupational Standards. But it is quite obvious that for things like reiki, reflexology and craniosacral therapy, the “knowledge base” consists entirely of made-up nonsense. Any fool can see that (but not, it seems, the PSA).

Skills for Health lists made-up, HR style, “competencies” for everything under the sun. When I got them to admit that their efforts on distance-healing etc had been drafted by the Prince of Wales’ Foundation, the conversation with Skills for Health became surreal (recorded in January 2008)

DC. Well yes the Prince of Wales would like that. His views on medicine are well known, and they are nothing if not bizarre. Haha are you going to have competencies in talking to trees perhaps?

“You’d have to talk to LANTRA, the land-based organisation for that.”

DC. I’m sorry, I have to talk to whom?

“LANTRA which is the sector council for the land-based industries uh, sector, not with us sorry . . . areas such as horticulture etc.”

DC. We are talking about medicine aren’t we? Not horticulture.

“You just gave me an example of talking to trees, that’s outside our remit ”

You couldn’t make it up, but it’s true. And the Professional Standards Authority rely on what these jokers say.

The current Skills for Health entry for reflexology says

“Reflexology is the study and practice of treating reflex points and areas in the feet and hands that relate to corresponding parts of the body. Using precise hand and finger techniques a reflexologist can improve circulation, induce relaxation and enable homeostasis. These three outcomes can activate the body’s own healing systems to heal and prevent ill health.”

This is crass, made-up nonsense. Of course there are no connections between “areas in the feet and hands that relate to corresponding parts of the body” and no reason to think that reflexology is anything more than foot massage. That a very expensive body, paid for by you and me, can propagate such preposterous nonsense is worrying. That the PSA should rely on them is even more worrying.

National Occupational Standards is yet another organisation that is utterly dimwitted about medical matters, but if you look up reflexology you are simply referred to Skills for Health, as above.

UK Commission for Employment and Skills
(UKCES)
is a new one on me. The PSA says that “the UK Commission for Employment and Skills (UKCES), who are responsible for the approval of all NOS across all industry sectors” It is only too obvious that the UKCES leadership team have failed utterly to do their job when it comes to made-up medicine. None of them know much about medicine. It’s true that their chairman did once work for SmithKline Beecham, but as a marketer of Lucozade, a job which anyone with much knowledge of science would not find comfortable..

You don’t need to know much medicine to spot junk. I see no excuse for their failure.

The training problem.

The PSA’s criteria for accreditation say

Standard 9: education and training

The organisation:

9a) Sets appropriate educational standards that enable its registrants to practise competently the occupation(s) covered by its register. In setting its standards the organisation takes account of the following factors:

• The nature and extent of risk to service users and the public
• The nature and extent of knowledge, skill and experience required to provide
service users and the public with good quality care

and later

9b) Ensures that registrants who assess the health needs of service users and provide any form of care and treatment are equipped to:

• Recognise and interpret clinical signs of impairment
• Recognise where a presenting problem may mask underlying pathologies
• Have sufficient knowledge of human disease and social determinants of health to identify where service users may require referral to another health or social care professional.

Anyone who imagines for a moment that a reflexologist or a craniosacral therapist is competent to diagnose a subarachnoid haemorrhage or malaria must need their head examining. In any case, the CNHC has already admitted that their registrants are taught things that aren’t true, so more training presumably means more inculcation of myths.

So how does the PSA wriggle out of this? Their response started

“The Panel noted that practitioners must meet, as a minimum, the National Occupational Standards for safe and competent practice. This is verified by the professional associations, who have in turn provided written undertakings to CNHC affirming that there are processes in place to verify the training and skills outcomes of their members to the NOS”

Just two problems there. The NOS standards themselves are utterly delusional. And checking them is left to the quacks themselves. To be fair, the PSA weren’t quite happy with this, but after an exchange of letters, minor changes enabled the boxes to be ticked and the PSA said “The Panel was now satisfied from the evidence provided, that this Standard had been
met”.

### What’s wrong with regulators?

This saga is typical of many other cases of regulators doing more harm than good. Regulators are sometimes quacks themselves, in which case one isn’t surprised at their failure to regulate.

But organisations like the Professional Standards Authority and Skills for Health are not (mostly) quacks themselves. So how do they end up giving credence to nonsense? I find that very hard to comprehend, but here are a few ideas.

(1) They have little scientific education and are not really capable of critical thought

(2) Perhaps even more important, they lack all curiosity. It isn’t very hard to dig under the carapace of quack organisations, but rather than finding out for themselves, the bureaucrats of the PSA are satisfied by reassuring letters that allow them to tick their boxes and get home.

(3) A third intriguing possibility is that people like the PSA yield to political pressure. The Department of Health is deeply unscientific and clearly has no idea what to do about alternative medicine. They have still done nothing at all about herbal medicine, traditional Chinese medicine or homeopathy, after many years of wavering. My guess is that they see the CNHC as an organisation that gives the appearance that they’ve done something about reiki etc. I wonder whether they applied pressure to the PSA to accredit CNHC, despite it clearly breaking their own rules. I have sent a request under the Freedom of Information Act in an attempt to discover if the Department of Health has misbehaved in the way it did when it attempted to override NHS Choices.

The responsibility for this cock-up has to rest squarely on the shoulders of the PSA’s director, Harry Cayton. He was director of the CHRE from which PSA evolved and is the person who so signally failed to do anything about the General Chiropractic Council fiasco,

### What can be done?

This is just the latest of many examples of regulators who not only fail to help but actually do harm by giving their stamp of approval to mickey mouse organisations like the CNHC. Most of the worst quangos survived the “bonfire of the quangos”.. The bonfire should have started with the PSA, CNHC and Skills for Health. They cost a lot and do harm.

There is a much simpler answer. There is a good legal case that much of alternative medicine is illegal. All one has to do is to enforce the existing law. Nobody would object to quacks if they stopped making false claims (though whether they could stay in business if they stopped exaggerating is debatable). There is only one organisation that has done a good job when it comes to truthfulness. That is the Advertising Standards Authority. But the ASA can do nothing apart from telling people to change the wording of their advertisements, and even that is often ignored.

The responsibility for enforcing the Consumer Protection Law is Trading Standards. They have consistently failed to do their job (see Medico-Legal Journal, Rose et al., 2012. “Spurious Claims for Health-care Products“.

If they did their job of prosecuting people who defraud the public with false claims, the problem would be solved.

But they don’t, and it isn’t.

### Follow-up

The indefatigable Quackometer has wriiten an excellent account of the PSA fiasco

The purpose of this post is to reveal a few samples of things that are taught on a homeopathy ‘degree’ course. The course in question was the "BSc Hons homeopathy course at the University of Central Lancashire (UCLAN). Entry to this course was closed in 2008 and, after an internal review, UCLAN closed almost all of the rest of its courses in alternative medicine too. The university is to be commended for this .

The purpose of making public some of what used to be taught is not to embarrass UCLAN, which has already done the sensible thing, but to make it clear that the sort of thing taught on such courses is both absurd and dangerous, in the hope of discouraging other courses

 .Three years after I first asked for teaching materials, the Information Commisioner ruled that all the reasons given for refusal were invalid, and they must be handed over. However UCLAN then appealed against the decision, so the appeal went to an Information Tribunal.  That appeal was lost decisively and UCLAN was.obliged to provide the whole of the course material. On Christmas Eve I got five large box files, 13.7 kg of documents, or 30 pounds, in old money.

Because these documents are copyright, I rely on the twin defences of fair quotation (only a tiny proportion is being quoted) and public interest. The Information Tribunal decided very firmly that it was in the public interest that it should be known what is taught on such courses, and that can be achieved if some of it is made public.   Here are a few extracts.

### Code of ethics

The students are given a copy of the code of ethics of the Society of Homeopaths.   This is 25 pages long, but paragraph 48 is especially interesting.

48 Advertisements, stationery and name plates maintain a high standard of propriety and
integrity to enhance the reputation of homeopathy.

• Advertising shall not contain claims of superiority.
• No advertising may be used which expressly or implicitly claims to cure named diseases.
• Advertising shall not be false, fraudulent, misleading, deceptive, extravagant or sensational.

No mention though, of the fact that this code of ethics has been repeatedly breached by the Society of Homeopaths itself, on its own website.  See, for example, here in 2007 and again in 2009. as well as Ernst’s article on this topic.

Anyone who has followed dialogues among homeopaths knows that "claims to cure named diseases" is the norm not the exception. The code of ethics is just a bad joke.  And the (late) course at UCLAN was no exception. Take, for example, course HP3002, Therapeutic Homeopathy, module leader Jean Duckworth.

### Homeopathic treatment of cancer

There was a lecture on HP3002 called "A Homeopathic Approach to Cancer (Ramakrishnan methodology [sic])".. Here are 10 slides from that lecture.  It is illegal to claim to be able to cure cancer under the Cancer Act 1939.  If a homeopath were to make claims like these in public they’d be open to prosecution, not to mention in breach of the SoH’s code of ethics.  If cancer is not a "named disease", what is?

Aha so it is better if the water is diluted in some more water.

Specific treatments for a named disease are recommended.

What happened to treating the whole person?  Now specific organs are being treated.  The term "affinity", as used here, is of course sheer hocus pocus.

It is easy to forget when reading this that none of the “medicines” contain any medicine whatsoeever.

Notice that the term "remedy" is used throughout.  Any reasonable person would interpret "remedy" to imply "cure", though no doubt a homeopath, if challenged, would claim that "remedy" carried no such implication. The last slide is typical of junk medicine: the personal testimonial, supplied with no detail whatsoever. Just an anecdote which is useless as evidence.

This lecture alone strikes me as a cruel (and possibly illegal) hoax perpetrated on desperate patients.  Of course a true believer might get some solace from taking the sugar pills, but that is not sufficient justification.

The same course dealt with quite a lot of other "named diseases", autism, ADHD and coping with a heart attack. And, you are asked, did you think arnica is just a first aid remedy?

If that isn’t a list of "named diseases", what is?   The code of ethics appears to be a total sham.

And of course never forget that the “arnica” doesn’t contain any arnica anyway. And if you don’t believe that you can read the words of Kate Chatfield, module leader on thie very course, as recorded in the minutes of evidence to the Select Committee on Science and Technology .

Q538 Lord Broers: I have a simple, technical question about homeopathy and drugs. Is it possible to distinguish between homeopathic drugs after they have been diluted? Is there any means of distinguishing one from the other?

Ms Chatfield: Only by the label.

You can read a lovely analysis of the views of Kate Chatfield by physicist A.P. Gaylard here.

### Follow-up

The Daily Telegraph. January 8th 2009 Ian Douglas reported on this post: The workings of a BSc in homeopathy

The Lancashire Evening Post carried a big spread on January 15th, Professor seeks out the truth about ‘quackery’.

River’s Edge. News and thoughts from Preston, Lancashire reviewed the Lancashire Evening Post article on Saturday January 16th: Homeopathy at UCLAN, a degree in quackery.

The cost of trying to stop this material being revealed. UCLAN told me on 5 February 2010 that the legal costs alone were £80,307.94 (inc. VAT). That doesn’t include staff time and photocopying.   I’m not convinced that this was a good way to spend taxpayers’ money.

A momentous decision was promulgated (as lawyers say) by the Information Tribunal on December 8th 2009.  It marks a step forward in Freedom of Information about how universities spend your money. It has taken 3.5 years to get to this point. Perhaps now there will be an end to the attempts of every single university that I’ve
approached to conceal what they teach.

### Decision

"The Tribunal upholds the decision notice dated 30th. March, 2009, dismisses the appeal and directs that all the steps required by the Decision Notice be taken within 28 days of the date of this Decision"

### Back story for this case

24th July 2006.  I asked the University of Central Lancashire (UCLAN) for copies of teaching materials and validation documents for their "BSc" degree in homeopathy (this degree no longer exists: it was abolished in 2008). A year later, UCLAN shut the rest of its courses in alternative medicine, after an internal review

21 August 2006. I was sent the validation documents but refused the teaching materials as UCLAN claimed they were exempt under section 43(2) of the Freedom of Information Act (FOIA)(commercial interests). Two days later I sent a request for the mandatory internal review of the refusal.

4th October 2006. The internal review confirmed the original decision (it always does), and cited, as well as section .43(2) of FOIA, section 21.

21 October 2006.  I appealed to the Information Commissioner.  The basis of the appeal was that the university might have financial interests in the outcome, but not commercial interests, because universities are not commercial organisations as defined in section 43(2) of the FOIA.  In addition, even if the commercial argument was not allowed, the public interest in knowing what was taught was sufficient to justify release of the requested materials.

21 January 2008.  The Information Commissioner finally got round to starting on the case.

29 September 2008  The vice-chancellor, Malcolm McVicar, raised an objection to complying with my request under s.36(2)(c) of FOIA. This states that “In the reasonable opinion of a qualified person, disclosure of the information under this Act” “(c) would otherwise prejudice, or would be likely otherwise to prejudice, the effective conduct of public affairs..”

30 March 2009.  The decision of the Information Commissioner was published. It has already been described here.  Apart from one trivial matter, my appeal was upheld, and UCLAN was ordered to release the requested material within 35 days.  However UCLAN did not release the material, but rather launched an appeal against the Information Commissioner.  The appeal was heard by an Information Tribunal.

The full text of the Freedom of Information Act is here.

### The Information Tribunal

The Tribunal heard the case of University of Central Lancashire v Information Commissioner in Manchester on November 3, 4 and 5.  I was an ‘additional party’ to the proceedings and attended in person for the first two days, with the aim of helping the Information Commissioner’s case. This is what the tribunal looked like.

I was amazed to find myself sitting next to the barrister for the Information Commisioner, and still more amazed to be invited to cross-question the witnesses, after she had questioned them.

The witnesses were Malcom McVicar (vice-chancellor of UCLAN), Peter Hyett, (executive director of finance at UCLAN) and David Phoenix (Deputy vice-chancellor, UCLAN).

### The outcome

The decision in full can be read here.

 Decision The Tribunal upholds the decision notice dated 30th. March, 2009, dismisses the appeal and directs that all the steps required by the Decision Notice be taken within 28 days of the date of this Decision.

So we won.

The details of the decision contain some matters of great interest for universities, in particular the dismissal of the idea that the public can be reassured by either internal or external (e.g. QAA) validation procedures. I’ll try to summarise them (paragraph numbering as in the decision
notice
).

Commercial interests

The one disappointing thing about the Tribunal’s decision was that it contradicted the Information Commissioner’s decision on the meaning of commercial interests.

31  "Therefore, whether on a broad or narrow construction of the statutory words, we are satisfied that UCLAN s interests in teaching material produced for its degree courses are properly described as “commercial”.

However, that does not affect the outcome because the Tribunal decided that there was no reason to think that the course materials actually had the commercial value that UCLAN said they did.  For
example:

36  We were not impressed by the claim that third parties with copyright in the disclosed materials would be alienated by UCLAN s compliance with a decision that this information must be provided. None gave evidence to that effect.

37 It was not clear to us how a competitor could significantly exploit access to this material, without infringing UCLAN `s copyright or brazenly aping the content of a course, which would surely attract the scorn of the wider academic community.  Moreover, it seemed to us likely that most potential students would be attracted to a particular course by the reputation of the teaching staff and a range of extra – curricular factors at least as much as by a comparative study of the powerpoint presentations and notes provided to current students.

and

39 Finally, in this particular case, we doubt whether this course had a significant commercial value, given the limited enrolment and the virtual absence of overseas interest.

At this point, the appeal is essentially dismissed.  Nevetheless, the Tribunal went on to discuss the other defences offered by UCLAN, and some of their conclusions are more interesting than the subtle distinction between ‘financial interests’ and ‘commercial interests’.

40 In the light of this finding, it is not strictly necessary to decide the balance of public interest as to disclosure.  Nevertheless, since the issue has been carefully and very fully argued, we shall shortly indicate our view, had the likelihood of prejudice been established.

### Public Interest

The commercial interest defence is subject to the public interest argument in s.1(2((b) of the FOIA’

(b) in all the circumstances of the case, the public interest in maintaining the exclusion of the duty to confirm or deny outweighs the public interest in disclosing whether the public authority
holds the information.

Hence, the decision notice says

41 As ever, the question is whether the public interest in maintaining the exemption outweighs the interest in disclosure.

On the question of public interest, the Tribunal comes down strongly on the side of the Commissioner and me.

46 The public interest in disclosure seems to us appreciably stronger. Apart from the universal arguments about transparency and the improvement of public awareness, we find that there are particular interests here, arising from the nature of a university and the way it is funded.

It is particularly interesting that the Tribunal dismissed the role of internal and external validation as a substitute for transparency.  As part of their case (para 18) UCLAN had argued

"Moreover, standards were ensured by the validation procedures which were required before a course was launched and which involved independent expert external monitors and by quality assurance (Q.A.A.) which demands a continuing compliance with national standards."

This cut no ice with the Tribunal.  In one of his few direct interjections the Tribunal Chairman, David Farrar Q.C., questioned a witness directly about the internal validation processes,  Evidently he was not impressed by the answers.  During my own cross questioning of the deputy vice-chancellor, I put to him the view that since the QAA [Quality Assurance Agency] was not allowed to take any notice of the content of courses, that getting a high mark from the QAA was not a substitute for seeing what was actually taught.  The deputy vice-chancellor did not seem to disagree strongly with that view.

47 First, the public has a legitimate interest in monitoring the content and the academic quality of a course, particularly a relatively new course in a new area of study, funded, to a very significant extent, by the taxpayer. It is no answer, we consider, to say that this function is performed by the process of validation or the continuing monitoring of standards with external input. Whether or not these processes are conducted with critical rigour, it must be open to those outside the academic community to question what is being taught and to what level in our universities. The apparent perception in some quarters that the intellectual demands of some or many degree courses have been relaxed, that higher classes of degree are too lightly earned, may be largely or entirely unfounded. But it is highly important that the material necessary to a fair judgement be available. That material will often, if not always, include the basic content of the course, such as is requested here.

48 Secondly, this is especially the case where, as with the BSc. (Homeopathy), there is significant public controversy as to the value of such study within a university. In this case, that factor standing alone would have persuaded us that the balance of public interest favoured disclosure.

49 We are not attracted by the somewhat patrician argument that the general public, uninstructed in the specialist subject under scrutiny, would be incapable of forming a proper judgement. That might be so, were it impossible to seek independent expertise to assist in making an assessment. Happily, it is not.

50 Finally, there is a public interest in opening up new methods of teaching and new insights as to the content of courses, so as to stimulate the spread of good practice.

So, a hands down win on the public interest argument.

### Prejudice to effective conduct of public affairs

I found incomprehensible the argument that disclosure would ‘prejudice the effective conduct of public affairs’. But it was raised (at the last minute) by UCLAN, and it was considered by the Tribunal. This defence refers to s.36(2)(c) of FOIA. It states that “In the reasonable opinion of a qualified person, disclosure of the information under this Act” “(c) would otherwise prejudice, or would be likely otherwise to prejudice, the effective conduct of public affairs..”

As noted at paragraph 17, it is common ground, established as to (iii), by the jurisprudence of the Tribunal, that this exemption is engaged if three requirements are met. They can be shortly labelled

(i) qualified person

(ii) reasonable opinion

(iii) reasonably arrived at.

The Tribunal seemed to be distinctly unimpressed by the arguments presented by UCLAN.

56 A reasonable opinion may be one with which the Tribunal emphatically disagrees, provided it is based on sound argument and evidence. With great respect to Professor McVicar, whose sincerity is not in question, we can find no adequate evidential basis for this opinion and consider that it rests on two misconceptions as to the application of FOIA. We do not find that it passes the required test of objective reasonableness.

57 We considered separately whether the opinion was reasonably arrived at. Again, our answer is no.

58 Section 36 provides for an exceptional exemption which the public authority creates by its own action, albeit subject to scrutiny of its reasonableness, the likelihood of prejudice and the question of the public interest. That factor of itself justifies a requirement that the authority provide substantial evidence as to the advice (other than legal advice) and the arguments presented to the qualified person upon which his opinion was founded. We emphasise that no set formula is required,  just a simple clear record of the process.

59 The need for such evidence is all the greater where, as here, the authority invokes s.36 for the first time after the complaint to the IC [Information Commissioner].

60 The evidence consists of a briefly argued email from Dr. Bostock suggesting that s.36(2)(c) be invoked on the very broadly argued grounds already reviewed. The tone implicitly acknowledges that the claim is rather speculative. We are not concerned with the slightly uncertain use of possibility and likely but the impression left is of a last  minute idea, not really thought through or investigated
but merely discussed with solicitors to tie it in to the FOIA. It was sent to the Vice  Chancellor at 3.20pm. on a Friday afternoon, 26th. September, 2008, asking for the Vice  Chancellor’s agreement. That agreement was forthcoming in a single sentence without further comment in an email reply timed at 12.05pm.on the following Monday.

61 We find that the process of forming the necessary opinion was, to say the least, perfunctory, indeed far short of the careful assessment and investigation that normally supports a qualified opinion for the purposes of s.36.

62 Accordingly, we do not find that it was reasonably arrived at.

### Conclusion

62 It is for these reasons that we uphold the Decision Notice. We record our gratitude for the helpful and succinct submissions of counsel on both sides and the incisive contribution of Professor Colquhoun. We wish to add that, whilst we have not accepted the great majority of the arguments advanced by UCLAN, we do not in any way seek to cast doubt on the veracity of the evidence of its witnesses, nor the honesty and loyalty with which they have sought to serve its interests.

63 Our decision is unanimous.

Signed David Farrar Q.C.

Watch this space to see what can now be revealed.

### Follow-up

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.

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).

### Conclusion

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
http://www.dcscience.net/?p=1950

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

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

More make-believe from the University of Westminster. This time its Naturopathy
http://www.dcscience.net/?p=1812

The last BSc (Hons) Homeopathy closes! But look at what they still teach at Westminster University.
http://www.dcscience.net/?p=1329

The opposite of science
http://www.dcscience.net/?p=1191

Bad medicine. Barts sinks further into the endarkenment.
http://www.dcscience.net/?p=1143

A letter to the Times, and progress at Westminster
http://www.dcscience.net/?p=984

Nutritional Fairy Tales from Thames Valley University
http://www.dcscience.net/?p=260

Westminster University BSc: amethysts emit high yin energy
http://www.dcscience.net/?p=227

References for Pittilo report consultation

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

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

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

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

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

An excellent submission to the consultation on statutory regulation of alternative medicine (Pittilo report)
http://www.dcscience.net/?p=2329

### Follow-up

Here is a short break from the astonishing festival of chiropractic that has followed the British Chiropractic Association (BCA) v Simon Singh defamation case, and the absurd NICE guidance on low back pain.

 Singh’s statement already has over 10000 signatories, many very distinguished, Sign it now if you haven’t already. And getting on for 600 separate complaints about exaggerated and false claims by chiropractors have been lodged with the General Chiropractic Council and with Trading Standards offices. Click to sign

The BCA has exposed the baselessness of most of chiropractic’s claims more effectively than any sceptic could have done.

### The University of Westminster is seeing the light?

It is only recently that the University of Westminster suspended entry to degrees in homeopathy and remedial massage and neuromuscular therapy.  Luckily for science, they have a new Dean who knows bullshit when she sees it.  I suspect than she has been instrumental in starting to restore Westminster’s reputation.  The job isn’t finished yet though.  According to the UCAS site Westminster still offers

• Chinese Medicine: Acupuncture with Foundation (B341) 4FT Hon BSc
• Health Sciences: Complementary Ther with Foundn (B300) 4FT Hon BSc
• Health Sciences: Complementary Therapies (B255) 3FT Hon BSc
• Health Sciences: Herbal Medicine (B342) 3FT Hon BSc
• Health Sciences: Herbal Medicine with Foundation (B340) 4FT Hon BSc
• Health Sciences: Naturopathy (B391) 3FT Hon BSc
• Health Sciences: Naturopathy with Foundation (B392) 4FT Hon BSc
• Health Sciences: Nutritional Therapy (B400) 3FT Hon BSc
• Health Sciences: Nutritional Therapy with Foundn (B402) 4FT Hon BSc

With the possible exception of herbal medicine, which could be taught scientifically. all the rest is as delusional as homeopathy.

Rumour has it that Naturopathy may be next for the chop, so it seems appropriate to help the dean by showing a bit more of what the hapless students get taught.  Remember that, according to Westminster, this is a bachelor of science degree!

Psychotherapeutic Approaches in Naturopathy 3CMW606

“This module is a core subject for BSc (Hons) Health Sciences: Naturopathy and option for BSc (Hons) Health Sciences: Complementary Therapies; BSc (Hons) Health Sciences: Therapeutic Bodywork; Graduate Diploma in Therapeutic Bodywork.”

Lectures 3 – 5 of this course are about the Theory and Application of EmoTrance.

EMOTRANCE?  No I had never heard of it either. But it takes only two minutes with Google to discover that it yet another product of the enormous navel-gazing self-help industry. A new variant is born almost every day, and no doubt they make buckets of money for their inventors.  You can download a primer from http://emotrance.com/. The web site announces.

“EmoTrance REAL energy healing for the 21st Century”

Here are three quotations from the primer.

 And then I thought of the lady in the supermarket whose husband had died, and I spend the following time sending her my best wishes, and my best space time quantum healing efforts for her void. It doesn’t matter how “bad”; something is or how old, it is ONLY AN ENERGY and energy can be moved with consciousness in quantum time, easily, and just for the asking. Is EmoTrance a Science? Yes! But only if you can accept that all living creatures have an energetic/emotional system. Once you make that leap then EmoTrance is completely logical and just makes sense. Like all great discoveries, EmoTrance is simple, natural and you might find you have always been aware of these processes subconsciously.

Now back to Westminster

Here are a few slides about EmoTrance

So it is pure vitalistic psycho-babble. The usual undefined use of impressive sounding words like “energy” and “quantum” with no defined meaning. Just preposterous made-up gobbledygook.

Before getting to EmoTrance, the course Psychotherapeutic Approaches in Naturopathy (3CMW606) had a lecture on Flower Essences. The evidence says, not surprisingly, that the effects of flower essences is not distinguishable from placebo “The hypothesis that flower remedies are associated with effects beyond a placebo response is not supported by data from rigorous clinical trials.” (See Ernst Wien. Klin. Wochenschr. 2002 114(23-24):963-6).  Here are two of the slides.

This last slide departs from the simply silly  to the totally mad.  Dowsing?  Kinesiology?

Pendulums I’m told from more than one source that the use of pendulums is not uncommon. both in teaching and by students in the Westminster University polyclinic  Apparently they provide an excellent way to choose a ‘remedy’ or make a diagnosis (well, I expect they are as good as the alternatives). If in doubt, guess.

Of course pendulums were popular with Cherie Blair who is reported to have taken her son Leo to a pendulum waver, Jack Temple, rather than have him vaccinated with MMR.  At least her delusions affected fewer people than those of her husband (the latest Iraq body count is about 100,000).

Kinesiology was originally a word that applied to the perfectly sensible science of human movement.  But Applied Kinesiology more often refers now to a fraudulent and totally ineffective diagnostic method invented by (you guessed) a chiropractor.   It has been widely used by alternative medicine to misdiagnose food allergies. It does not work (Garrow, 1988: download reprint).

General Chiropractic Council  It is a mind-boggling sign of the incompetence of the General Chiropractic Council that they manage to include kinesiology within their definition of “evidence based care”. Their definition is clearly sufficiently flexible to include anything whatsoever.  The incompetence of the GCC is documented in superb detail on jdc325’s blog (James Cole).

Council for Healthcare Regulatory Excellence (CHRE) is yet another example of the network of ineffective and incompetent quangos that plague us.. It is meant to ensure that regulation is effective but utterly fails to do so. The CHRE is quoted as saying “[The GCC] takes its role seriously and aspires to, and often maintains, excellence.”. Like endorsing kinesiology and ‘craniosacral therapy’ perhaps? Quangos like the CHRE not only fail to ensure regulatory excellence, they actually endorse rubbish. They do more harm than good.

The reading list for the course includes the following books.  I guess the vibrational medicine (whatever that means) was covered already in the now infamous ‘amethysts emit high yin energy‘ lectures.

Essential:
Hartman S (2003) Oceans of Energy: The Patterns and Techniques of EmoTrance: Vol 1.DragonRising. ISBN: 1873483732.
Lynch V and Lynch P (2001) Emotional Healing in Minutes. Thorsons: London. ISBN: 0007112580

Recommended:
Gerber R (2001) Vibrational Medicine for the 21st Century. Piatkus Publishers: London.
Gurudas (1989) Flower Essences and Vibrational Medicine. Cassandra Press: California, USA
Hartman S (2000) Adventures in EFT: The Essential Field Guide to Emotional Freedom Techniques. DragonRising. ISBN: 1873483635.
Hartman S (2004) Living Energy: The Patterns and Techniques of EmoTrance: Vol 2. DragonRising.ISBN: 1873483740.
Hartman S (2006) Energy Magic: The Patterns and Techniques of EmoTrance: Vol 3. Dragon Rising.ISBN: 1873483767.

Real magic.

Sylvia Hartman’s books seem to feature heavily in the reading list. I just got news of her latest effort

Welcome to a special update to the June 2009 newsletter to announce Silvia Hartmann’s latest book “Magic, Spells & Potions” is now available to pre-order from our site. The eBook edition will be released this Sunday, the most magical day of the year.

http://DragonRising.com/store/magic_spells_and_potions/?r=DR0609MSAP

If you do pre-order this exciting new book, not only will you be amongst the first to receive your copy, but you will also be entered into an exciting competition for Silvia Hartmann’s handmade copal amber magic pendant. Each paperback book pre-ordered will also be signed by the author and contain a unique blessing for the reader.

Because this is a serious book on real magic, potions and fortune telling if you are a beginner Silvia has provided ample sample spells and potions for you to practice working with before you start covering the advanced material.

What? No honestly, I didn’t invent that.

The idea that stuff of this sort is appropriate for a bachelor of science degree is simply ludicrous.  I have no doubt that Westminster’s new dean can see that as well as anyone else. She has the delicate diplomatic job of extirpating the nonsense,  I wish her well.

### 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

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.”

The first major victory in the battle for the integrity of universities seems to have been won. This email was sent by Kate Chatfield who is module leader for the “BSc” in homeopathic medicine at the University of Central Lancashire (UCLAN).

 from Kate Chatfield… Dear All, It’s a sad day for us here at UCLan because we have taken the decision not to run a first year this year due to low recruitment. The course will be put ‘on hold’ for this year and next until we see what happens with the general climate. Fortunately our masters course is thriving and we have been asked to focus upon this area and homeopathy research for the time being. Of late UCLan has been the subject of many attacks by the anti-homeopathy league. Colquhoun et al have kept the university lawyers and us quite fruitlessly busy by making claims for very detailed course information under the Freedom of Information Act. The latest demand is for 32 identified lesson plans with teaching notes, power points, handouts etc. The relentless attacks have taken their toll and it appears that they have won this small victory. The university has been very clear that this decision has been taken solely on the grounds of poor educational experience and is nothing to do with the current furore. They continue to be supportive of us and our efforts. Best wishes Kate and Jean

There is some background here. In July 2006 I made a request to UCLAN under the Freedom of Information Act 2000, in which I asked to see some of their teaching materials. I appealed to UCLAN but Professor Patrick McGhee, Deputy Vice-Chancellor (Academic), also turned down two appeals. A letter sent directly to Professor Malcolm McVicar, vice-chancellor and president of UCLAN, failed to elicit the courtesy of a reply (standard practice I’m afraid, when a vice chancellor is faced with a difficult question). (Ironically, McVicar lists one of his interests as “health policy”.) So then I appealed to the Office of the Information Commissioner, in November 2006. Recently the case got to the top of the pile, and a judgment is expected any moment now.

Kate Chatfield’s letter to her colleagues is interesting. She describes a request ro see some of her teaching materials as an “attack”. If someone asks to see my teaching materials, I am rather flattered, and I send them. Is she not proud of what she teaches? Why all the secrecy? After all, you, the taxpayer, are paying for this stuff to be taught, so why should you not be able see it? Or is the problem that she feels that the “alternative reality” in which homeopaths live is just too complicated for mortals to grasp? Perhaps this attitude should be interpreted as flattering to the general public, because somewhere deep down she knows that the public will be able to spot gobbledygook when they see it. The revelation that the University of Westminster teaches first year undergraduates the “amethysts emit high yin energy” didn’t help their academic reputation much either.

Much credit for this decision must go also to the pressure from the many good academics at UCLAN. When it was revealed recently that UCLAN intended to open yet more courses in forms of medicine that are disproved or unproven, they naturally felt that their university was being brought into disrepute. Opposition to plans to introduce new “degrees” in acupuncture and Chinese herbal medicine were exposed in Times Higher Education recently. It particular, great credit must go to Dr Michael Eslea from UCLAN’s Psychology department. His open letter to his vice-chancellor is an example of scientific integrity in action.

The abandonment of this degree in medicines that contain no medicine is a small victory for common sense, for science and for the integrity of universities. Sadly, there is still a long way to go.

It is my understanding that ‘bringing the university into disrepute’ is a serious offence. Please note, vice-chancellor.

A few more judgments like that to suspend your homeopathy degree could work wonders for your reputation.

### The follow-up

Watch this space.

The Guardian was quick off the mark -this story appeared on their education web site within 3 hours of my posting it “Homeopathy degrees suspended after criticism” by Anthea Lipsett. My comment there disappeared for a while because the Guardian legal people misunderstood the meaning of the last sentence. It’s back now, with blame allocated unambiguously to the vice-chancellors of the 16 or so universities who run this sort of course.

UCLAN’s web site seems to need some updating. The “BSc” in homeopathic medicine is still advertised there. as of 28 August.

UCLAN’s best ally. Dr Michael Eslea, has had some publicity for his attempts to rescue his university’s reputation. The story appeared in the “High Principals” column of Private Eye (Issue 1217, Aug 22, 2008). It also appeared in his local paper, the Lancashire Evening Post.

The Lancashire Evening Post catches up with homeopathy suspension story, two days after you read it here. But the UCLAN web site still advertises it.

The article below is an editorial that I was asked to write for the New Zealand Medical Journal, as a comment on article in today’s edition about the misuse of the title ‘doctor’ by chiropractors [download pdf]. Titles are not the only form of deception used by chiropractors, so the article looks at some of the others too.  For a good collection of articles that reveal chiropractic for what it is, look at Chirobase

THE NEW ZEALAND
MEDICAL JOURNAL

Journal of the New Zealand Medical Association

NZMJ 25 July 2008, Vol 121 No 1278; ISSN 1175 8716

Doctor Who?
Inappropriate use of titles by some alternative “medicine” practitioners

David Colquhoun

Who should use the title ‘doctor’? The title is widely abused as shown by Gilbey1 in this issue of the NZMJ in an article entitled Use of inappropriate titles by New Zealand practitioners of acupuncture, chiropractic, and osteopathy. Meanwhile, Evans and colleagues 2, also in this issue, discuss usage and attitudes to alternative treatments.

Gilbey finds that the abuse of the title doctor is widespread and that chiropractors are the main culprits. An amazing 82% of 146 chiropractics used the title Doctor, andL most of them used the title to imply falsely that they were registered medical practitioners.

Although it is illegal in New Zealand to do that, it seems clear that the law is not being enforced and it is widely flouted. This is perhaps not surprising given the history of chiropractic. It has had a strong element of ruthless salesmanship since it was started in Davenport, Iowa by D.D. Palmer (1845–1913). His son, B.J. Palmer, said that their chiropractic school was founded on “a business, not a professional basis. We manufacture chiropractors. We teach them the idea and then we show them how to sell” (Shapiro 2008)3 It is the same now. You can buy advice on how to build “build high-volume, subluxation-based, cash-driven, lifetime family wellness practices”

In her recent book3 , Rose Shapiro comments on the founder of chiropractic as follows.

“By the 1890s Palmer had established a magnetic healing practice in Davenport, Iowa, and was styling himself “doctor”. Not everyone was convinced, as a piece about him in an 1894 edition of the local paper, the Davenport Leader, shows.

A crank on magnetism has a crazy notion hat he can cure the sick and crippled with his magnetic hands. His victims are the weak-minded, ignorant and superstitious,those foolish people who have been sick for years and have become tired of the regular physician and want health by the short-cut method he has certainly profited by the ignorance of his victim. His increase in business shows what can be done in Davenport, even by a quack.”

D.D. Palmer was a curious mixture: grocer, spiritual healer, magnetic therapist, fairground huckster, religious cult leader—and above all, a salesman. He finally found a way to get rich by removing entirely imaginary “subluxations”.

Over 100 years later, it seems that the “weak-minded, ignorant, and superstitious” include the UK’s Department of Health, who have given chiropractics a similar status to the General Medical Council.

The intellectual standards of a 19th Century Mid-Western provincial newspaper journalist are rather better than the intellectual standards of the UK’s Department of Health, and of several university vice-chancellors in 2007.

### Do the treatments work?

Neither Gilbey nor Evans et al. really grasp the nettle of judging efficacy. The first thing one wants to know about any treatment —alternative or otherwise — is whether it works. Until that is decided, all talk of qualifications, regulation, and so on is just vacuous bureaucratese. No policy can be framed sensibly until the question of efficacy has been addressed honestly.

It is one good effect of the upsurge of interest in alternative treatments that there are now quite a lot of good trials of the most popular forms of treatments (as well as many more bad trials). Some good summaries of the results are now available too. Cochrane reviews set the standard for good assessment of evidence. New Zealand’s Ministry of Health commissioned the Complementary and Alternative Medicine
website to assess the evidence, and that seems to have done a good job too. Their assessment of chiropractic treatment of low back pain is as follows:

There appears to be some evidence from one systematic review and four other studies, although not conclusive, that chiropractic treatment is as effective as other therapies but this may be due to chance. There is very little evidence that chiropractic is more effective than other therapies.

And two excellent summaries have been published as books this year. Both are by people who have had direct experience of alternative treatments, but who have no financial interest in the outcome of their assessment of evidence. The book by Singh and Ernst4 summarises the evidence on all the major alternative treatments, and the book by Bausell5 concentrates particularly on acupuncture, because the author was for 5 years involved in research in that area, Both of these books come to much the same conclusion about chiropractic. It is now really very well-established that chiropractic is (at best) no more effective than conventional treatment. But it has the disadvantage of being surrounded by gobbledygook about “subluxations” and, more importantly, it kills the occasional patient.

Long (2004)7 said “the public should be informed that chiropractic manipulation is the number one reason for people suffering stroke under the age of 45.

The chiropractors of Alberta (Canada) and the Alberta Government are now facing a class-action lawsuit8. The lead plaintiff is Sandra Nette. Formerly she was a fit 41 year old. Now she is tetraplegic. Immediately
after neck manipulation by a chiropractor she had a massive stroke as a result of a torn vertebral artery.

Acupuncture comes out of the assessments equally badly. Bausell (2007) concludes that it is no more than a theatrical placebo.

### Are the qualifications even real?

It is a curious aspect of the alternative medicine industry that they often are keen to reject conventional science, yet they long for academic respectability. One aspect of this is claiming academic titles on the flimsiest of grounds. You can still be held to have misled the public into thinking you are a medical
practitioner, even if you have a real doctorate. But often pays to look into where the qualifications come from.

A celebrated case in the UK concerned the ‘lifestyle nutritionist’, TV celebrity and multi-millionaire, Dr Gillian McKeith, PhD. A reader of Ben Goldacre’s excellent blog, badscience.net did a little investigation. The results appeared in Goldacre’s Bad Science column in the Guardian9.

She claimed that her PhD came from the American College of Nutrition, but it turned out to come from a correspondence course from a non-accredited US ‘college’. McKeith also boasted of having “professional membership” of the American Association of Nutritional Consultants, for which she provided proof of her degree and three professional references.

The value of this qualification can be judged by the fact that Goldacre sent an application and \$60 and as a result “My dead cat Hettie is also a “certified professional member” of the AANC. I have the certificate hanging in my loo”.

### Is the solution government regulation?

In New Zealand the law about misleading the public into believing you are a medical practitioner already exists. The immediate problem would be solved if that law were taken seriously, but it seems that it is not.

It is common in both the UK and in New Zealand to suggest that some sort of official government regulation is the answer. That solution is proposed in this issue of NZMJ by Evans et al2. A similar thing has been proposed recently in the UK by a committee headed by Michael Pittilo, vice-chancellor of Robert Gordon’s University, Aberdeen.

I have written about the latter under the heading A very bad report. The Pittilo report recommends both government regulation and more degrees in alternative medicine. Given that we now know that most alternative medicine doesn’t work, the idea of giving degrees in such subjects must be quite ludicrous to any thinking person.

The magazine Nature7 recently investigated the 16 UK universities who run such degrees. In the UK, first-year students at the University of Westminster are taught that “amethysts emit high yin energy” . Their vice chancellor, Professor Geoffrey Petts, describes himself a s a geomorphologist, but he cannot be tempted to express an opinion about the curative power of amethysts.

There has been a tendency to a form of grade inflation in universities—higher degrees for less work gets bums on seats. For most of us, getting a doctorate involves at least 3 years of hard experimental research in a university. But in the USA and Canada you can get a ‘doctor of chiropractic’ degree and most chiropractic (mis)education is not even in a university but in separate colleges.

Florida State University famously turned down a large donation to start a chiropractic school because they saw, quite rightly, that to do so would damage their intellectual reputation. This map, now widely distributed on the Internet, was produced by one of their chemistry professors, and it did the trick.

Other universities have been less principled. The New Zealand College of Chiropractic [whose President styles himself “Dr Brian Kelly”,though his only qualification is B. App Sci (chiro)] is accredited by the New Zealand Qualifications Authority (NZQA). Presumably they, like their UK equivalent (the QAA), are not allowed to take into account whether what is being taught is nonsense or not. Nonsense courses are accredited by experts in nonsense. That is why much accreditation is not worth the paper it’s written on.

Of course the public needs some protection from dangerous or fraudulent practices, but that can be done better (and more cheaply) by simply enforcing existing legislation on unfair trade practices, and on false advertising. Recent changes in the law on unfair trading in the UK have made it easier to take legal action against people who make health claims that cannot be justified by evidence, and that seems the best
way to regulate medical charlatans.

### Conclusion

For most forms of alternative medicine—including chiropractic and acupuncture—the evidence is now in. There is now better reason than ever before to believe that they are mostly elaborate placebos and, at best, no better than conventional treatments. It is about time that universities and governments recognised the evidence and stopped talking about regulation and accreditation.

Indeed, “falsely claiming that a product is able to cure illnesses, dysfunction, or malformations” is illegal in Europe10.

Making unjustified health claims is a particularly cruel form of unfair trading practice. It calls for prosecutions, not accreditation.

Competing interests: None.
NZMJ 25 July 2008, Vol 121 No 1278; ISSN 1175 8716

Author information: David Colquhoun, Research Fellow, Dept of Pharmacology, University College London, United Kingdom (http://www.ucl.ac.uk/Pharmacology/dc.html)

Correspondence: Professor D Colquhoun, Dept of Pharmacology, University College London, Gower Street, London WC1E 6BT, United Kingdom. Fax: +44(0)20 76797298; email: d.colquhoun@ucl.ac.uk

References:

1. Gilbey A. Use of inappropriate titles by New Zealand practitioners of acupuncture, chiropractic, and osteopathy. N Z Med J. 2008;121(1278). [pdf]

2. Evans A, Duncan B, McHugh P, et al. Inpatients’ use, understanding, and attitudes towards traditional, complementary and alternative therapies at a provincial New Zealand hospital. N Z Med J. 2008;121(1278).

3 Shapiro. Rose. Suckers. How Alternative Medicine Makes Fools of Us All Random House, London 2008. (reviewed here)

4. Singh S, Ernst E. Trick or Treatment. Bantam Press; 2008 (reviewed here)

5. Bausell RB. Snake Oil Science. The Truth about Complementary and Alternative Medicine. (reviewed here)
Oxford University Press; 2007

6. Colquhoun D. Science degrees without the Science, Nature 2007;446:373–4. See also here.

7. Long PH. Stroke and spinal manipulation. J Quality Health Care. 2004;3:8–10.

8. Libin K. Chiropractors called to court. Canadian National Post; June21, 2008.

9. Goldacre B. A menace to science. London: Guardian; February 12, 2007/

10. Department for Business Enterprise & Regulatory Reform (BERR). Consumer Protection from Unfair Trading Regulations 2008. UK: Office of Fair Trading.