Royal London Homeopathic
This article has appeared, in nearly identical form, on the UK Conversation . You can leave comments there or here.
A constitutional monarch is purely ceremonial and plays no part in politics. Well actually in the UK it isn’t quite as simple as that. The first problem is that we have no constitution. Things haven’t changed much since the 19th century when Walter Bagehot said "the Sovereign has, under a constitutional monarchy… three rights—the right to be consulted, the right to encourage, the right to warn."
These are not inconsiderable powers in a country which is meant to be run by elected representatives. But nobody knows how these powers are used: it is all done in secret. Well, almost all. Charles, Prince of Wales, has been unusually public in expressing his views. He told a conference at St James’s Palace “I was accused once of being the enemy of the Enlightenment” “I felt proud of that.” That’s a remarkable point of view for someone who, if he succeeds, will become the patron of that product of the age of enlightenment, the Royal Society.
I have no doubt that Prince Charles means well. He can’t be blamed for his lack of education. But his views on medicine date from a few centuries ago, and he has lost no opportunity to exploit his privileged position to proclaim them.
Euphemisms for quackery
He set up the Prince’s Foundation for Integrated Health (PFIH) to promote his views. ( “Integrated”, in this context, is, of course, just the latest euphemism for “alternative” or “quack”.) When the Foundation collapsed because of a financial scandal in 2010, it was replaced by the “College of Medicine”. The name changed, but not the people behind it. Initially this phoenix was to be named the “College of Integrated Health”, but by this time the prince’s views on medicine had become sufficiently discredited that the word “integrated” was quickly dropped. This might be thought less than frank, but it is just employment of the classic bait and switch technique, beloved by used car salesmen.
His views were well publicised in a PFIH publication, “Complementary Healthcare: a Guide for Patients”. That volume either omitted or misrepresented the evidence about the one question that matters most to patients – does the treatment work or not? It caused me to write a much shorter, but more accurate, version, the Patients’ Guide to Magic Medicine. The PFIH guide was arguably a danger to public health. When, very properly, it was criticised by Edzard Ernst, a letter was sent from from the prince’s private secretary to Ernst’s vice-chancellor, Steve Smith. Instead of defending Ernst’s public spirited action, Smith instituted disciplinary proceedings against Ernst that lasted for a year. The prince had intervened directly in the affairs of the university. Steve Smith was rewarded with a knighthood in 2011.
None of this criticism has dimmed the prince’s enthusiasm for barmy medical ideas. He is well known to write many letters to government ministers to try to persuade them to adopt his ideas in a whole range of areas. In July 2013, the Minister of Health, Jeremy Hunt, visited the prince at Clarence House. The visit was reported to be to persuade the minister to defend homeopathy, though it was more likely to have been to press the case to confer a government stamp of approval on herbalists and traditional Chinese Medicine practitioners by giving them statutory regulation. This is a matter that was recently raised again in parliament by Charles’ greatest ally, David Tredinnick MP (Con, Bosworth) who got into trouble for charging astrology software to expenses. We shall never know what pressure was applied. A ruling of the Information Commissioner judged, reasonably enough, that there was public interest in knowing what influences were being brought to bear on public policy. But the Attorney General overruled the judgement on the grounds that “Disclosure of the correspondence could damage The Prince of Wales’ ability to perform his duties when he becomes King.” That, of course, is exactly what we are worried about.
Influence on politics
The prince’s influence seems to be big in the Department of Health (DH). He was given £37,000 of taxpayers’ money to produce his guide, and an astonishing £900,000 to prepare the ground for the setting up of the hapless self-regulator, the Complementary and Natural Healthcare Council (CNHC, also known as Ofquack). When NHS Choices (itself set up by DH to assess evidence) tried to rewrite its web page about that most discredited of all forms of quackery, homeopathy, officials in DH referred the new advice to Michael Dixon, the medical director of the Prince’s Foundation and, were it not for the Freedom of Information act, the DH would have caused inaccurate information to be provided. The DH has a chief medical officer and two scientific advisors, but prefers to take the advice of the Prince of Wales.
The Prince of Wales’ business, Duchy Originals, has been condemned by the Daily Mail, (of all places) for selling unhealthy foods. And when his business branched into selling quack “detox” and herbal nonsense he found himself censured by both the MHRA and the Advertising Standards Authority (ASA) for making unjustifiable medical claims for these products.
Ainsworth’s homeopathic pharmacy is endorsed by both Prince Charles and the Queen: it has two Royal Warrants. They sell “homeopathic vaccines” for meningitis, measles, rubella and whooping cough. These “vaccines” contain nothing whatsoever so they are obviously a real danger to public health. Despite the fact that Ainsworth’s had already been censured by the ASA in 2011 for selling similar products, Ainsworth’s continued to recommend them with a “casual disregard for the law”. The regulator (the MHRA) failed to step in to stop them until it was eventually stirred into action by a young BBC reporter, Sam Smith, made a programme for BBC South West. Then, at last, the somnolent regulator was stirred into action. The MHRA “told Ainsworths to stop advertising a number of products” (but apparently not to stop making them or selling them). They still sell Polonium metal 30C and Swine Meningitis 36C, and a booklet that recommends homeopathic “vaccination”. Ainsworth’s sales are no doubt helped by the Royal Warrants. The consequence is that people may die of meningitis. In 2011, the MHRA Chief Executive Professor Kent Woods, was knighted.
It runs in the family
The Prince of Wales is not the only member of the royal family to be obsessed with bizarre forms of medicine. The first homeopath to the British royal family, Frederick Quin, was a son of the Duchess of Devonshire (1765-1824). Queen Mary (1865-1953), wife of King George V, headed the fundraising efforts to move and expand the London Homeopathic Hospital.
King George VI was so enthusiastic that in 1948 conferred the royal title on the London Homeopathic Hospital. The Queen Mother loved homeopathy too (there is no way to tell whether this contributed to her need for a colostomy in the 1960s).
The present Queen’s homeopathic physician is Peter Fisher, who is medical director of what, until recently was called the Royal London Homeopathic Hospital (RLHH). In 2010 that hospital was rebranded as the Royal London Hospital for Integrated Medicine (RLHIM) in another unsubtle bait and switch move.
The RLHIM is a great embarrassment to the otherwise excellent UCLH Trust. It has been repeatedly condemned by the Advertising Standards Authority for making false claims. As a consequence, it has been forced to withdraw all of its patient information.
The patron of the RLHIM is the Queen, not the Prince of Wales. It is hard to imagine that this anachronistic institution would still exist if it were not for the influence, spoken or unspoken, of the Queen. Needless to say we will never be told.
The Queen and Peter Fisher
Observer 8 April 2007
The attorney general, while trying to justify the secrecy of Charles’ letters, said
“It is a matter of the highest importance within our constitutional framework that the Monarch is a politically neutral figure”.
Questions about health policy are undoubtedly political, and the highly partisan interventions of the prince in the political process make his behaviour unconstitutional. They endanger the monarchy itself. Whether that matters depends on how much you value tradition and how much you value the tourist business generated by the Gilbert & Sullivan flummery at which royals excel.
The least that one can ask of the royal family is that they should not endanger the health of the nation. If I wanted to know the winner of the 2.30 at Ascot, I’d ask a royal. For any question concerning science or medicine I’d ask someone with more education.
Here is some more interesting reading
Michael Baum’s “An open letter to the Prince of Wales: with respect, your highness, you’ve got it wrong”
Gerald Weissman’s essay Homeopathy: Holmes, Hogwarts, and the Prince of Wales.
Channel 4 TV documentary HRH “meddling in politics”
Observer April 2007 "Royals’ favoured hospital at risk as homeopathy backlash gathers pace. The Queen loves it. But alternative medicine centre’s future looks uncertain as more NHS trusts axe funding"
The Scottish Universities Medical Journal asked me to write about the regulation of alternative medicine. It’s an interesting topic and not easy to follow because of the veritable maze of more than twenty overlapping regulators and quangos which fail utterly to protect the public against health fraud. In fact they mostly promote health fraud. The paper is now published, and here is a version with embedded links (and some small updates).
We are witnessing an increasing commercialisation of medicine. It’s really taken off since the passage of the Health and Social Security Bill into law. Not only does that mean having NHS hospitals run by private companies, but it means that “any qualified provider” can bid for just about any service. The problem lies, of course, in what you consider “qualified” to mean. Any qualified homeopath or herbalist will, no doubt, be eligible. University College London Hospital advertised for a spiritual healer. The "person specification" specified a "quallfication", but only HR people think that a paper qualification means that spiritual healing is anything but a delusion.
The vocabulary of bait and switch
First, a bit of vocabulary. Alternative medicine is a term that is used for medical treatments that don’t work (or at least haven’t been shown to work). If they worked, they’d be called “medicine”. The anti-malarial, artemesinin, came originally from a Chinese herb, but once it had been purified and properly tested, it was no longer alternative. But the word alternative is not favoured by quacks. They prefer their nostrums to be described as “complementary” –it sounds more respectable. So CAM (complementary and alternative medicine became the politically-correct euphemism. Now it has gone a stage further, and the euphemism in vogue with quacks at the moment is “integrated” or “integrative” medicine. That means, very often, integrating things that don’t work with things that do. But it sounds fashionable. In reality it is designed to confuse politicians who ask for, say, integrated services for old people.
Put another way, the salespeople of quackery have become rather good at bait and switch. The wikepedia definition is as good as any.
Bait-and-switch is a form of fraud, most commonly used in retail sales but also applicable to other contexts. First, customers are “baited” by advertising for a product or service at a low price; second, the customers discover that the advertised good is not available and are “switched” to a costlier product.
As applied to the alternative medicine industry, the bait is usually in the form of some nice touchy-feely stuff which barely mentions the mystical nonsense. But when you’ve bought into it you get the whole panoply of nonsense. Steven Novella has written eloquently about the use of bait and switch in the USA to sell chiropractic, acupuncture, homeopathy and herbal medicine: "The bait is that CAM offers legitimate alternatives, the switch is that it primarily promotes treatments that don’t work or are at best untested and highly implausible.".
The "College of Medicine" provides a near-perfect example of bait and switch. It is the direct successor of the Prince of Wales’ Foundation for Integrated Health. The Prince’s Foundation was a consistent purveyor of dangerous medical myths. When it collapsed in 2010 because of a financial scandal, a company was formed called "The College for Integrated Health". A slide show, not meant for public consumption, said "The College represents a new strategy to take forward the vision of HRH Prince Charles". But it seems that too many people have now tumbled to the idea that "integrated", in this context, means barmpottery. Within less than a month, the new institution was renamed "The College of Medicine". That might be a deceptive name, but it’s a much better bait. That’s why I described the College as a fraud and delusion.
Not only did the directors, all of them quacks, devise a respectable sounding name, but they also succeeded in recruiting some respectable-sounding people to act as figureheads for the new organisation. The president of the College is Professor Sir Graham Catto, emeritus professor of medicine at the University of Aberdeen. Names like his make the bait sound even more plausible. He claims not to believe that homeopathy works, but seems quite happy to have a homeopathic pharmacist, Christine Glover, on the governing council of his college. At least half of the governing Council can safely be classified as quacks.
So the bait is clear. What about the switch? The first thing to notice is that the whole outfit is skewed towards private medicine: see The College of Medicine is in the pocket of
Crapita Capita. The founder, and presumably the main provider of funds (they won’t say how much) is the huge outsourcing company, Capita. This is company known in Private Eye as Crapita. Their inefficiency is legendary. They are the folks who messed up the NHS computer system and the courts computer system. After swallowing large amounts of taxpayers’ money, they failed to deliver anything that worked. Their latest failure is the court translation service.. The president (Catto), the vice president (Harry Brunjes) and the CEO (Mark Ratnarajah) are all employees of Capita.
The second thing to notice is that their conferences and courses are a bizarre mixture of real medicine and pure quackery. Their 2012 conference had some very good speakers, but then it had a "herbal workshop" with Simon Mills (see a video) and David Peters (the man who tolerates dowsing as a way to diagnose which herb to give you). The other speaker was Dick Middleton, who represents the huge herbal company, Schwabe (I debated with him on BBC Breakfast), In fact the College’s Faculty of Self-care appears to resemble a marketing device for Schwabe.
Why regulation isn’t working, and can’t work
There are various levels of regulation. The "highest" level is the statutory regulation of osteopathy and chiropractic. The General Chiropractic Council (GCC) has exactly the same legal status as the General Medical Council (GMC). This ludicrous state of affairs arose because nobody in John Major’s government had enough scientific knowledge to realise that chiropractic, and some parts of osteopathy, are pure quackery,
The problem is that organisations like the GCC function more to promote chiropractic than to regulate them. This became very obvious when the British Chiropractic Association (BCA) decided to sue Simon Singh for defamation, after he described some of their treatments as “bogus”, “without a jot of evidence”.
In order to support Singh, several bloggers assessed the "plethora of evidence" which the BCA said could be used to justify their claims. When, 15 months later, the BCA produced its "plethora" it was shown within 24 hours that the evidence was pathetic. The demolition was summarised by lawyer, David Allen Green, in The BCA’s Worst Day.
In the wake of this, over 600 complaints were made to the GCC about unjustified claims made by chiropractors, thanks in large part to heroic work by two people, Simon Perry and Allan Henness. Simon Perry’s Fishbarrel (browser plugin) allows complaints to be made quickly and easily -try it). The majority of these complaints were rejected by the GCC, apparently on the grounds that chiropractors could not be blamed because the false claims had been endorsed by the GCC itself.
My own complaint was based on phone calls to two chiropractors, I was told such nonsense as "colic is down to, er um, faulty movement patterns in the spine". But my complaint never reached the Conduct and Competence committee because it had been judged by a preliminary investigating committee that there was no case to answer. The impression one got from this (very costly) exercise was that the GCC was there to protect chiropractors, not to protect the public.
The outcome was a disaster for chiropractors, wno emerged totally discredited. It was also a disaster for the GCC which was forced to admit that it hadn’t properly advised chiropractors about what they could and couldn’t claim. The recantation culminated in the GCC declaring, in August 2010, that the mythical "subluxation" is a "historical concept " "It is not supported by any clinical research evidence that would allow claims to be made that it is the cause of disease.". Subluxation was a product of the fevered imagination of the founder of the chiropractic cult, D.D. Palmer. It referred to an imaginary spinal lesion that he claimed to be the cause of most diseases. .Since ‘subluxation’ is the only thing that’s distinguished chiropractic from any other sort of manipulation, the admission by the GCC that it does not exist, after a century of pretending that it does, is quite an admission.
The President of the BCA himself admitted in November 2011
“The BCA sued Simon Singh personally for libel. In doing so, the BCA began one of the darkest periods in its history; one that was ultimately to cost it financially,”
As a result of all this, the deficiencies of chiropractic, and the deficiencies of its regulator were revealed, and advertisements for chiropractic are somewhat less misleading. But this change for the better was brought about entirely by the unpaid efforts of bloggers and a few journalists, and not at all by the official regulator, the GCC. which was part of the problem. not the solution. And it was certainly not helped by the organisation that is meant to regulate the GCC, the Council for Health Regulatory Excellence (CHRE) which did nothing whatsoever to stop the farce.
At the other end of the regulatory spectrum, voluntary self-regulation, is an even worse farce than the GCC. They all have grand sounding "Codes of Practice" which, in practice, the ignore totally.
The Society of Homeopaths is just a joke. When homeopaths were caught out recommending sugar pills for prevention of malaria, they did nothing (arguably such homicidal advice deserves a jail sentence).
The Complementary and Natural Healthcare Council (CNHC) is widely know in the blogosphere as Ofquack. I know about them from the inside, having been a member of their Conduct and Competence Committee, It was set up with the help of a £900,000 grant from the Department of Health to the Prince of Wales, to oversee voluntary self-regulation. It fails utterly to do anything useful.. The CNHC code of practice, paragraph 15 , states
“Any advertising you undertake in relation to your professional activities must be accurate. Advertisements must not be misleading, false, unfair or exaggerated”.
When Simon Perry made a complaint to the CNHC about claims being made by a CNHC-registered reflexologist, the Investigating Committee upheld all 15 complaints. But it then went on to say that there was no case to answer because the unjustified claims were what the person had been taught, and were made in good faith.
This is precisely the ludicrous situation which will occur again and again if reflexologists (and many other alternative therapies) are “accredited”. The CNHC said, correctly, that the reflexologist had been taught things that were not true, but then did nothing whatsoever about it apart from toning down the advertisements a bit. They still register reflexologists who make outrageously false claims.
Once again we see that no sensible regulation is possible for subjects that are pure make-believe.
The first two examples deal (or rather, fail to deal) with regulation of outright quackery. But there are dozens of other quangos that sound a lot more respectable.
European Food Standards Agency (EFSA). One of the common scams is to have have your favourite quack treatment classified as a food not as a medicine. The laws about what you can claim have been a lot laxer for foods. But the EFSA has done a pretty good job in stopping unjustified claims for health benefits from foods. Dozens of claims made by makers of probiotics have been banned. The food industry, needless to say, objects very strongly to be being forced to tell the truth. In my view, the ESFA has not gone far enough. They recently issued a directive about claims that could legally be made. Some of these betray the previously high standards of the EFSA. For example you are allowed to say that "Vitamin C contributes to the reduction of tiredness and fatigue" (as long as the product contains above a specified amount of Vitamin C. I’m not aware of any trials that show vitamin C has the slightest effect on tiredness or fatigue, Although these laws do not come into effect until December 2012, they have already been invoked by the ASA has a reason not to uphold a complaint about a multivitamin pill which claimed that it “Includes 8 nutrients that can contribute to the reduction in tiredness and fatigue”
The Advertising Standards Authority (ASA). This is almost the only organisation that has done a good job on false health claims. Their Guidance on Health Therapies & Evidence says
"Whether you use the words ‘treatment’, ‘treat’ or ‘cure’, all are likely to be seen by members of the public as claims to alleviate effectively a condition or symptom. We would advise that they are not used"
"Before and after’ studies with little or no control, studies without human subjects, self-assessment studies and anecdotal evidence are unlikely to be considered acceptable"
They are spot on.
The ASA’s Guidance for Advertisers of Homeopathic Services is wonderful.
"In the simplest terms, you should avoid using efficacy claims, whether implied or direct,"
"To date, the ASA has have not seen persuasive evidence to support claims that homeopathy can treat, cure or relieve specific conditions or symptoms."
That seems to condemn the (mis)labelling allowed by the MHRA as breaking the rules.. Sadly, though, the ASA has no powers to enforce its decisions and only too often they are ignored. The Nightingale collaboration has produced an excellent letter that you can hand to any pharmacist who breaks the rules
The ASA has also judged against claims made by "Craniosacral therapists" (that’s the lunatic fringe of osteopathy). They will presumably uphold complaints about similar claims made (I’m ashamed to say) by UCLH Hospitals.
The private examination company Edexcel sets exams in antiscientific subjects, so miseducating children. The teaching of quackery to 16 year-olds has been approved by a maze of quangos, none of which will take responsibility, or justify their actions. So far I’ve located no fewer than eight of them. The Office of the Qualifications and Examinations Regulator (OfQual), Edexcel, the Qualifications and Curriculum Authority (QCA), Skills for Health, Skills for Care, National Occupational Standards (NOS), private exam company VTCT and the schools inspectorate, Ofsted.. Asking any of these people why they approve of examinations in imaginary subjects meets with blank incomprehension. They fail totally to protect tha public from utter nonsense.
The Department of Education has failed to do anything about the miseducation of children in quackery. In fact it has encouraged it by, for the first time, giving taxpayers’ money to a Steiner (Waldorf) school (at Frome, in Somerset). Steiner schools are run by a secretive and cult-like body of people (read about it). They teach about reincarnation, karma, gnomes, and all manner of nonsense, sometimes with unpleasant racial overtones. The teachers are trained in Steiner’s Anthroposophy, so if your child gets ill at school they’ll probably get homeopathic sugar pills. They might well get measles or mumps too, since Steiner people don’t believe in vaccination.
Incredibly, the University of Aberdeen came perilously close to appointing a chair in anthroposophical medicine. This disaster was aborted by bloggers, and a last minute intervention from journalists. Neither the university’s regulatory mechanisms. nor any others, seemed to realise that a chair in mystical barmpottery was a bad idea.
Trading Standards offices and the Office of Fair Trading.
It is the statutory duty of Trading Standards to enforce the Consumer Protection Regulations (2008) This European legislation is pretty good. it caused a lawyer to write " Has The UK Quietly Outlawed “Alternative” Medicine?". Unfortunately Trading Standards people have consistently refused to enforce these laws. The whole organisation is a mess. Its local office arrangement fails totally to deal with the age of the internet. The situation is so bad that a group of us decided to put them to the test. The results were published in the Medico-Legal Journal, Rose et al., 2012. "Spurious Claims for Health-care Products: An Experimental Approach to Evaluating Current UK Legislation and its Implementation". They concluded "EU directive 2005/29/EC is
largely ineffective in preventing misleading health claims for consumer products in
Skills for Health is an enormous quango which produces HR style "competences" for everything under the son. They are mostly quite useless. But those concerned with alternative medicine are not just useless. They are positively harmful. Totally barmy. There are competences and National Occupational Standards for every lunatic made-up therapy under the sun. When I phoned them to discover who’d written them, I learned that the had been drafted by the Prince of Wales’ Foundation for Magic Medicine. And when I joked by asking if they had a competence for talking to trees, I was told, perfectly seriously, “You’d have to talk to LANTRA, the land-based organisation for that.”
That was in January 2008. A lot of correspondence with the head of Skills for Health got nowhere at all. She understood nothing and it hasn’t improved a jot.
This organisation costs a lot of taxpayers’ money and it should have been consigned to the "bonfire of the quangos" (but of course there was no such bonfire in reality). It is a disgrace.
The Quality Assurance Agency (QAA) is supposed to ensure the quality of university courses. In fact it endorses courses in nonsense alternative medicine and so does more harm than good. The worst recent failure of the QAA was in the case of the University of Wales: see Scandal of the University of Wales and the Quality Assurance Agency. The university was making money by validating thousands of external degrees in everything from fundamentalist theology to Chinese Medicine. These validations were revealed as utterly incompetent by bloggers, and later by BBC Wales journalist Ciaran Jenkins (now working for Channel 4).
The mainstream media eventually caught up with bloggers. In 2010, BBC1 TV (Wales) produced an excellent TV programme that exposed the enormous degree validation scam run by the University of Wales. The programme can be seen on YouTube (Part 1, and Part 2). The programme also exposed, incidentally, the uselessness of the Quality Assurance Agency (QAA) which did nothing until the scam was exposed by TV and blogs. Eventually the QAA sent nine people to Malaysia to investigate a dodgy college that had been revealed by the BBC. The trip cost £91,000. It could have been done for nothing if anyone at the QAA knew how to use Google.
The outcome was that the University of Wales stopped endorsing external courses, and it was soon shut down altogether (though bafflingly, its vice-chancellor, Marc Clement was promoted). The credit for this lies entirely with bloggers and the BBC. The QAA did nothing to help until the very last moment.
Throughout this saga Universities UK (UUK), has maintained its usual total passivity. They have done nothing whatsoever about their members who give BSc degrees in anti-scientific subjects. (UUK used to known as the Committee of Vice-Chancellors and Principals).
Council for Health Regulatory Excellence (CHRE), soon to become the PSAHSC,
Back now to the CHRE, the people who failed so signally to sort out the GCC. They are being reorganised. Their consultation document says
"The Health and Social Care Act 20122 confers a new function on the Professional Standards Authority for Health and Social Care (the renamed Council for Healthcare Regulatory Excellence). From November 2012 we will set standards for organisations that hold voluntary registers for people working in health and social care occupations and we will accredit the register if they meet those standards. It will then be known as an ‘Accredited Register’. "
They are trying to decide what the criteria should be for "accreditation" of a regulatory body. The list of those interested has some perfectly respectable organisations, like the British Psychological Society. It also contains a large number of crackpot organisations, like Crystal and Healing International, as well as joke regulators like the CNHC.
They already oversee the Health Professions Council (HPC) which is due to take over Herbal medicine and Traditional Chinese Medicine, with predictably disastrous consequences.
Two of the proposed criteria for "accreditation" appear to be directly contradictory.
Para 2.5 makes the whole accreditation pointless from the point of view of patients
2.5 It will not be an endorsement of the therapeutic validity or effectiveness of any particular discipline or treatment.
Since the only thing that matters to the patient is whether the therapy works (and is safe), accrediting of organisations that ignore this will merely give the appearance of official approval of crystal healing etc etc. This appears to contradict directly
A.7 The organisation can demonstrate that there either is a sound knowledge base underpinning the profession or it is developing one and makes that explicit to the public.
A "sound knowledge base", if it is to mean anything useful at all, means knowledge that the treatment is effective. If it doesn’t mean that, what does it mean?
It seems that the official mind has still not grasped the obvious fact that there can be no sensible regulation of subjects that are untrue nonsense. If it is nonsense, the only form of regulation that makes any sense is the law.
Please fill in the consultation. My completed return can be downloaded as an example, if you wish.
Medicines and Healthcare products Regulatory Agency (MHRA) should be a top level defender of truth. Its strapline is
"We enhance and safeguard the health of the public by ensuring that medicines and medical devices work and are acceptably safe."
The MHRA did something (they won’t tell me exactly what) about one of the most cruel scams that I’ve ever encountered, Esperanza Homeopathic Neuropeptide, peddled for multiple sclerosis, at an outrageous price ( £6,759 for 12 month’s supply). Needless to say there was not a jot of evidence that it worked (and it wasn’t actually homeopathic).
Astoundingly, Trading Standards officers refused to do anything about it.
The MHRA admit (when pushed really hard) that there is precious little evidence that any of the herbs work, and that homeopathy is nothing more than sugar pills. Their answer to that is to forget that bit about "ensuring that medicines … work"
Here’s the MHRA’s Traditional Herbal Registration Certificate for devils claw tablets.
The wording "based on traditional use only" has to be included because of European legislation. Shockingly, the MHRA have allowed them to relegate that to small print, with all the emphasis on the alleged indications. The pro-CAM agency NCCAM rates devil’s claw as "possibly effective" or "insufficient evidence" for all these indications, but that doesn’t matter because the MHRA requires no evidence whatsoever that the tablets do anything. They should, of course, added a statement to this effect to the label. They have failed in their duty to protect and inform the public by allowing this labelling.
But it gets worse. Here is the MHRA’s homeopathic marketing authorisation for the homeopathic medicinal product Arnicare Arnica 30c pillules
It is nothing short of surreal.
Since the pills contain nothing at all, they don’t have the slightest effect on sprains, muscular aches or bruising. The wording on the label is exceedingly misleading.
If you "pregnant or breastfeeding" there is no need to waste you doctor’s time before swallowing a few sugar pills.
"Do not take a double dose to make up for a missed one". Since the pills contain nothing, it doesn’t matter a damn.
"If you overdose . . " it won’t have the slightest effect because there is nothing in them
And it gets worse. The MHRA-approved label specifies ACTIVE INGREDIENT. Each pillule contains 30c Arnica Montana
No, they contain no arnica whatsoever.
It truly boggles the mind that men with dark suits and lots of letters after their names have sat for hours only to produce dishonest and misleading labels like these.
The Nightingale Collaboration.
This is an excellent organisation, set up by two very smart skeptics, Alan Henness and Maria MacLachlan. Visit their site regularly, sign up for their newsletter Help with their campaigns. Make a difference.
The regulation of alternative medicine in the UK is a farce. It is utterly ineffective in preventing deception of patients.
Such improvements as have occurred have resulted from the activity of bloggers, and sometime the mainstream media. All the official regulators have, to varying extents, made things worse.
The CHRE proposals promise to make matters still worse by offering "accreditation" to organisations that promote nonsensical quackery. None of the official regulators seem to be able to grasp the obvious fact that is impossible to have any sensible regulation of people who promote nonsensical untruths. One gets the impression that politicians are more concerned to protect the homeopathic (etc, etc) industry than they are to protect patients.
Deception by advocates of alternative medicine harms patients. There are adequate laws that make such deception illegal, but they are not being enforced. The CHRE and its successor should restrict themselves to real medicine. The money that they spend on pseudo-regulation of quacks should be transferred to the MHRA or a reformed Trading Standards organisation so they can afford to investigate and prosecute breaches of the law. That is the only form of regulation that makes sense.
The shocking case of the continuing sale of “homeopathic vaccines” for meningitis, rubella, pertussis etc was highlighted in an excellent TV programme by BBC South West. The failure of the MHRA and the GPC do take any effective action is a yet another illustration of the failure of regulators to do their job. I have to agree with Andy Lewis when he concludes
“Children will die. And the fault must lie with Professor Sir Kent Woods, chairman of the regulator.”
The Prince of Wales’ Foundation for Integrated Health shut down amidst scandal in April 2010. In July, we heard that a new “College of Medicine” was to arise from its ashes. It seemed clear from the people involved that the name “College of Medicine” would be deceptive.
Now the College of Medicine has materialised, and it is clear that one’s worst fears were well justified.
At first sight, it looks entirely plausible and well-meaning. Below the logo one reads
“There is a new force in medicine. A force that brings patients, doctors, nurses and other health professionals together, instead of separating them into tribes.”
"That force is the new College of Medicine. Uniquely, it brings doctors and other health professionals together with patients and scientists.”
It is apparent from the outset that the well-meaning words fall into the trap described so clearly by James May (see What ‘holistic’ really means). It fails to distinguish between curing and caring.
As always, the clue lies not in the words, but in the people who are running it.
Who is involved?
After a bit of digging on the web site, you find the names of the people on the Science Council of the “College of Medicine”, The preamble says
“Good medicine must be grounded in good science as well as compassion. The College’s Science Council brings a depth of knowledge from many senior figures.”
But then come the names. With the odd exception the “science council” is like a roll-call of quacks, the dregs left over from the Prince’s Foundation. The link (attached to each name) gives the College’s bio, My links tell a rather different story.
Professor Simon Gibbons A phytochemist with exaggerated ideas of what you can get from plants.
It seems that the "Scientific Council" of the College of Medicine could more properly be called an "Antiscientific Council".
There are a few gaps in this table, to be filled in soon. One can guarantee that a great deal more will appear about the College on the web, very soon.
The Governing Council of the College is equally replete with quacks (plus a few surprising names). It has on it, for example, a spiritual healer (Angie-Buxton King), a homeopath (Christine Glover), a herbalist (Michael McIntyre). Westminster University’s king of woo (David Peters), not to mention the infamous Karol Sikora. Buxton-King offers a remarkable service to heal people or animals at a distance.
Meanwhile, it seemed worthwhile to provide a warning that the title of the College is very deceptive. It hides an agenda that could do much harm.
It is, quite simply, the Prince of Wales by stealth.
28 October 2010
Professor Sir Graeme Catto, who has, disgracefully, allowed his name to be used as president of this “College” has said to me “There are real problems in knowing how to care for folk with chronic conditions and the extent of the evidence base for medicine is pretty limited”.
Yes of course that is quite true. There are many conditions for which medicine can still do little. There is a fascinating discussion to be had about how best to care for them. The answer to that is NOT to bring in spiritual healers and peddlers of sugar pills to deceive patients with their fairy stories. The “College of Medicine” will delay and pervert the sort of discussion that Catto says, rightly, is needed.
29 October 2010
I need a press card. I see that the BMJ also had a piece about the “College of Medicine” yesterday: Prince’s foundation metamorphoses into new College of Medicine, by Nigel Hawkes. He got the main point right there in the title.
As was clear since July, the driving force was Michael Dixon, Devon GP and ex medical director of the Prince’s Foundation. Hawkes goes easy on the homeopaths and spiritual healers, but did spot something that I can’t find on their web site. The “Faculties” will include
“in 2011, neuromusculoskeletal care. Two of the six strong faculty members for this specialty are from the British Chiropractic Association, which sued the author Simon Singh for libel for his disobliging remarks about the evidence base for their interventions.”
The College certainly picks its moment to endorse chiropractic, a subject that is in chaos and disgrace after they lost the Singh affair.
One bit of good news emerges from Hawkes’ piece, There is at least one high profile doubter in the medical establishment, Lord (John) Walton (his 2000 report on CAM was less than blunt, and has been widely misquoted by quacks) is reported as saying, at the opening ceremony
“I’m here as a sceptic, and I’ve just told my former houseman that,” he said. The target of the remark was Donald Irvine, another former GMC president and a member of the new college’s advisory council.”
31 October 2010. I got an email that pointed out a remarkable service offered by a member of College’s Governing Council. Angie Buxton-King, a “spiritual healer” employed by UCLH seems to have another web site, The Beacon of Healing Light that is not mentioned in her biography on the College’s site. Perhaps it should have been because it makes some remarkable claims. The page about distant healing is the most bizarre.
Absent Healing/Distant Healing
"Absent healing is available when it is not possible to visit the patient or it is not possible for the patient to be brought to our healing room. This form of healing has proved to be very successful for humans and animals alike."
"We keep a healing book within our healing room and every night spend time sending healing to all those who have asked for it. We have found that if a picture of the patient is sent to us the healing is more beneficial, we also require a weekly update to monitor any progress or change in the patients situation. Donations are welcome for this service."
I wonder what the Advertising Standards people make of the claim that it is “very successful”? I wonder what the president of the College makes of it? I’ve asked him.
Other blogs about the “College of Medicine”
30 October 2010. Margaret McCartney is always worth reading. As a GP she is at the forefront of medicine. She’s written about the College in The Crisis in Caring and dangerous inference. She’s also provided some information about a "professional member" of the College of Medicine, in ..and on Dr Sam Everington, at the Bromley by Bow Centre….
It is one of the more insulting things about alternative medicine addicts that they claim to be the guardians of caring (as opposed to curing), They are not, and people like McCartney and Michael Baum are excellent examples.
Prince of Wales to become honorary president of the “College of Medicine?”
Last night I heard a rumour that the Prince of Wales is, despite all the earlier denials, to become Honorary President of the “College”. If this is true, it completes the wholesale transformation of the late, unlamented, Prince’s Foundation for Integrated Medicine into this new “College”. Can anybody take it seriously now?
Text messages to Graeme Catto and Michael Dixon, inviting them to deny the rumour, have met with silence.
Herbal nonsense at the College
29 July 2011. I got an email from the College if Medicine [download it]. It contains a lot of fantasy about herbal medicines, sponsered by a company that manufactures them. It is dangeroous and corrupt.
On Friday 25 August 2006, Michael Baum and I went to visit the rather palatial headquarters of the UCL Hospitals Trust (that is part of the NHS, not of UCL). We went to see David Fish, who was, at that time, in charge of specialist hospitals. That included world-leading hospitals like the National Hospital Queen Square, and Great Ormond Street children’s hospital. It also includes that great national embarrassment, the Royal London Homeopathic Hospital (RLHH).
It came as something of a surprise that the man in charge did not know the barmy postulates of homeopathy and he looked appropriately embarrassed when we told him.
Michael Baum is not only a cancer surgeon. but he has also taken the lead in thinking about palliative and spiritual needs of patients who suffer from cancer. Listen to his Samuel gee lecture: it is awe-inspiring. It is available in video, Concepts of Holism in Orthodox and Alternative Medicine.
The problem for UCLH Trust is that the RLHH has royal patronage One can imagine the frantic green-ink letters that would emanate form the Quacktitioner Royal, if it were to be shut down. Instead, we suggested that the name of the RLHH should be changed. Perhaps something like Hospital for palliative and supportive care? Well, four years later it has been changed, but the outcome is not at all satisfactory. From September it is to be known as the Royal London Hospital for Integrated Medicine.
What’s wrong with that? You have to ask what is to be "integrated" with what?. In practice it usually means integrating things that don’t work with things that do. So not much advance there. In fact the weasel word "integrated" is just the latest in a series of euphemisms for quackery. First it was ‘alternative’ medicine. But that sounds a bit ‘new age’ (it is), so then it was rebranded ‘complementary medicine’. That sounds a bit more respectable. Now it is often "integrated medicine" (in the USA, "integrative"). That makes it sound as though it is already accepted. It is intended to deceive. See, for example, Prince of Wales Foundation for magic medicine: spin on the meaning of ‘integrated’, and What ‘holistic’ really means.
Of course the amount of homeopathy practised at the RLHH has fallen considerably over the last few years. Already by 2007 there were signs of panic among homeopaths, They are beginning to realise that the game is up. Some of the gaps were filled with other sorts of unproven and disproved medicine.
What the hospital is called matters less than what they do, The current activities can be seen on the UCLH web site.
- Allergy Environmental and Nutritional Medicine
- Autogenics Training
- Children’s Clinic
- Complementary Cancer Care Programme
- Education services
- Musculoskeletal Medicine Clinic
- Pharmacy Services
- Skin Services
- Stress and Mood Disorders Clinic
- The Marigold Clinic – Homeopathic Podiatry and Chiropody
- Womens Clinic
It would be tedious to go through all of them, but here are some samples.
The Children’s Clinic
"The mainstay of treatments offered include Homeopathy, Herbal remedies, Flower essences, Essential oils, Tissue salts and Acupuncture. We also assess nutritional status, provide dietary advice and supplementation. Psychotherapeutic techniques including Neuro-Linguistic Programming (NLP), and Visualisation are sometimes used where indicated, to gain better understanding of the presenting problems".
So a wide range of woo there. And they claim to be able to treat some potentially serious problems
"What can be treated
A wide variety of clinical conditions are being treated including:
- Recurrent infections
- Skin diseases such as eczema
- Allergic disorders including asthma
- Food intolerances and eating disorders
- Functional developmental and learning problems
- Behavioural disorders including ADHD (hyperactivity) and autism."
There is, of course, no evidence worth mentioning thar any of these conditions can be treated effectively by “Homeopathy, Herbal remedies, Flower essences, Essential oils, Tissue salts and Acupuncture”.
They describe their success rate thus:
An internal audit questionnaire showed that 70% of children responded well to homeopathic treatment
So, no published data, and no control group. This is insulting to any patient with half a brain.
These claims should be referred to the Advertising Standards Authority and/or Trading standards. They are almost certainly illegal under the Consumer Protection Regulations (May 2008). The UCLH Trust should be ashamed of itself.
Education Services offers mainly courses in homeopathy, the medicines that contain no medicine,
Pharmacy Services stock thousands of bottles of pills, most of which are identical sugar pills. It’s hard to imagine a greater waste of money.
The Marigold Clinic – Homeopathic Podiatry and Chiropody
I was rather surprised to find this is still running. In 2006, I wrote about it in Conflicts of interest at the Homeopathic Hospital. It turned out that the prescription costs if the clinic were spent on Marigold paste, made by a company owned by the people who run the clinic. UCLH claimed that they were aware of this conflict of interest, but had no obligation to make it public. That is an odd ethics in itself. Even odder when I discovered that the Trust had been notified of the conflict of interest only after I’d started to ask questions.
The same people are still running the clinic. They may well be good chiropodists, If so why surround the service with woo. There are, almost needless to say, no good trials of the efficacy of marigold paste (and it isn’t homeopathic).
At the moment, it appears that the renaming of the RLHH is empty re-branding. No doubt UCLH Trust see homeopathy as something that brings shame on a modern medical service. But to remove the name while retaining the nonsense is simply dishonest. Let’s hope that the name change will be followed by real changes in the sort of medicine practised, Changes to real medicine, one hopes.
Other blogs on this topic
Gimpyblog was first, with Farewell to the RLHH, hello to the RLHIM
Quackometer posted An Obituary: Royal London Homeopathic Hospital, 1849-2010
|The Prince of Wales’ Foundation for Integrated Health (FiH) is a propaganda organisation that aims to persuade people, and politicians, that the Prince’s somewhat bizarre views about alternative medicine should form the basis of government health policy.
His attempts are often successful, but they are regarded by many people as being clearly unconstitutional.
The FiH’s 2009 AnnualConferen ce conference was held at The King’s Fund, London 13 – 14 May 2009. It was, as always, an almost totally one-sided affair devoted to misrepresentation of evidence and the promotion of magic medicine. But according to the FiH, at least, it was a great success. The opening speech by the Quacktitioner Royal can be read here. It has already been analysed by somebody who knows rather more about medicine than HRH. He concludes
“It is a shocking perversion of the real issues driven by one man; unelected, unqualified and utterly misguided”.
We are promised some movie clips of the meeting. They might even make a nice UK equivalent of “Integrative baloney @ Yale“.
This post is intended to provide some background information about the speakers at the symposium. But let’s start with what seems to me to be the real problem. The duplicitous use of the word “integrated” to mean two quite different things.
The problem of euphemisms: spin and obfuscation
One of the problems of meetings like this is the harm done by use of euphemisms. After looking at the programme, it becomes obvious that there is a rather ingenious bit of PR trickery going on. It confuses (purposely?) the many different definitions of the word “integrative” . One definition of “Integrative medicine” is this (my emphasis).
” . . . orienting the health care process to engage patients and caregivers in the full range of physical, psychological, social, preventive, and therapeutic factors known to be effective and necessary for the achievement of optimal health.”
That is a thoroughly admirable aim. And that, I imagine, is the sense in which several of the speakers (Marmot, Chantler etc) used the term. Of course the definition is rather too vague to be very helpful in practice, but nobody would dream of objecting to it.
But another definition of the same term ‘integrative medicine’ is as a PR-friendly synonym for ‘alternative medicine’, and that is clearly the sense in which it is used by the Prince of Wales’ Foundation for Integrated Health (FIH), as is immediately obvious from their web site.
The guide to the main therapies supports everything from homeopathy to chiropractic to naturopathy, in a totally uncritical way. Integrated service refers explicitly to integration of ‘complementary’ medicine, and that itself is largely a euphemism for alternative medicine. For example, the FIH’s guide to homeopathy says
“What is homeopathy commonly used for?
Homeopathy is most often used to treat chronic conditions such as asthma; eczema; arthritis; fatigue disorders like ME; headache and migraine; menstrual and menopausal problems; irritable bowel syndrome; Crohn’s disease; allergies; repeated ear, nose, throat and chest infections or urine infections; depression and anxiety.”
But there is not a word about the evidence, and perhaps that isn’t surprising because the evidence that it works in any of these conditions is essentially zero.
The FIH document Complementary Health Care: A Guide for Patients appears to have vanished from the web after its inaccuracy received a very bad press, e.g. in the Times, and also here. It is also interesting that the equally widely criticised Smallwood report (also sponsored by the Prince of Wales) seems to have vanished too).
Conference chair Dr Phil Hammond, GP, comedian and health service writer. Hammond asked the FIH if I could speak at the meeting to provide a bit of balance. Guess what? They didn’t want balance.
09:30 Opening session
Dr Michael Dixon OBE
09:30 Introduction: a new direction for The Prince’s Foundation for Integrated Health and new opportunities in integrated health and care. Dr Michael Dixon, Medical Director, FIH
Michael Dixon is devoted to just about every form of alternative medicine. As well as being medical director of the Prince’s Foundation he also runs the NHS Alliance. Despite its name, the NHS Alliance is nothing to do with the NHS and acts, among other things, as an advocate of alternative medicine on the NHS, about which it has published a lot.
Dr Dixon is also a GP at College Surgery, Cullompton, Devon, where his “integrated practice” includes dozens of alternative practitioners. They include not only disproven things like homeopathy and acupuncture, but also even more bizarre practitioners in ‘Thought Field Therapy‘ and ‘Frequencies of Brilliance‘.
To take only one of these, ‘Frequencies of Brilliance’ is bizarre beyond belief. One need only quote its founder and chief salesperson.
“Frequencies of Brilliance is a unique energy healing technique that involves the activation of energetic doorways on both the front and back of the body.”
“These doorways are opened through a series of light touches. This activation introduces high-level Frequencies into the emotional and physical bodies. It works within all the cells and with the entire nervous system which activates new areas of the brain.”
“Frequencies of Brilliance is a 4th /5th dimensional work. The process is that of activating doorways by lightly touching the body or working just above the body.”
“Each doorway holds the highest aspect of the human being and is complete in itself. This means that there is a perfect potential to be accessed and activated throughout the doorways in the body.”
Best of all, it can all be done at a distance (that must help sales a lot). One is reminded of the Skills for Health “competence” in distant healing (inserted on a government web site at the behest (you guessed it) of the Prince’s Foundation, as related here)
“The intent of a long distance Frequencies of Brilliance (FOB) session is to enable a practitioner to facilitate a session in one geographical location while the client is in another.
A practitioner of FOB that has successfully completed a Stage 5 Frequency workshop has the ability to create and hold a stable energetic space in order to work with a person that is not physically present in the same room.
The space that is consciously created in the Frequencies of Brilliance work is known as the “Gap”. It is a space of nonlinear time. It contains ”no time and no space” or respectively “all time and all space”. Within this “Gap” a clear transfer of the energies takes place and is transmitted to an individual at a time and location consciously intended. Since this dimensional space is in non-linear time the work can be performed and sent backward or forward in time as well as to any location.
The Frequencies of Brilliance work cuts through the limitations of our physical existence and allows us to experience ourselves in other dimensional spaces. Therefore people living in other geographic locations than a practitioner have an opportunity to receive and experience the work.
The awareness of this dimensional space is spoken about in many indigenous traditions, meditation practices, and in the world of quantum physics. It is referred to by other names such as the void, or vacuum space, etc.”
This is, of course, preposterous gobbledygook. It, and other things in Dr Dixon’s treatment guide, seem to be very curious things to impose on patients in the 21st century.
Latest news. The Mid-Devon Star announces yet more homeopathy in Dr Dixon’s Cullompton practice. This time it comes in the form of a clinic run from the Bristol Homeopathic Hospital. I guess they must be suffering from reduced commissioning like all the other homeopathic hospitals, but Dr Dixon seems to have come to their rescue. The connection seems to be with Bristol’s homeopathic consultant, Dr Elizabeth A Thompson. On 11 December 2007 I wrote to Dr Thompson, thus
In March 2006, a press release http://www.ubht.nhs.uk/press/view.asp?257 announced a randomised trial for homeopathic treatment of asthma in children.
This was reported also on the BBC http://news.bbc.co.uk/1/hi/england/bristol/4971050.stm .
I’d be very grateful if you could let me know when results from this trial will become available.
The reply, dated 11 December 2007, was unsympathetic
I have just submitted the funders report today and we have set ourselves the deadline to publish two inter-related papers by March 1st 2007.
Can I ask why you are asking and what authority you have to gain this information. I shall expect a reply to my questions,
I answered this question politely on the same day but nevertheless my innocent enquiry drew forth a rather vitriolic complaint from Dr Thompson to the Provost of UCL (dated 14 December 2007). In this case, the Provost came up trumps. On 14 January 2008 he replied to Thompson: “I have looked at the email that you copied to me, and I must say that it seems an entirely proper and reasonable request. It is not clear to me why Professor Colquhoun should require some special authority to make such direct enquiries”. Dr Thompson seems to be very sensitive. We have yet to see the results of her trial in which I’m still interested.
Not surprisingly, Dr Dixon has had some severe criticism for his views, not least from the UK’s foremost expert on the evidence for efficacy, Prof Edzard Ernst. Accounts of this can be found in Pulse,
and on Andrew Lewis’s blog.
Dixon is now (in)famous in the USA too. The excellent Yale neurologist, Steven Novella, has written an analysis of his views on Science Based Medicine. He describes Dr. Michael Dixon as “A Pyromaniac In a Field of (Integrative) Straw Men”
09:40 Politics and people: can integrated health and care take centre stage in 2009/2010? Rt Hon Peter Hain MP
It seems that Peter Hain was converted to alternative medicine when his first baby, Sam, was born with eczema. After (though possibly not because of) homeopathic treatment and a change in diet, the eczema got better. This caused Hain, while Northern Ireland Secretary to spend £200,000 of taxpayers’ money to set up a totally uninformative customer satisfaction survey, which is being touted elsewhere in this meeting as though it were evidence (see below). I have written about this episode before: see Peter Hain and Get Well UK: pseudoscience and privatisation in Northern Ireland.
I find it very sad that a hero of my youth (for his work in the anti-apartheid movement) should have sunk to promoting junk science, and even sadder that he does so at my expense.
There has been a report on Hain’s contribution in Wales Online.
09:55 Why does the Health Service need a new perspective on health and healing? Sir Cyril Chantler, Chair, King’s Fund, previous Dean, Guy’s Hospital and Great Ormond Street
Cyril Chantler is a distinguished medical administrator. He also likes to talk and we have discussed the quackery problem several times. He kindly sent me the slides that he used. Slide 18 says that in order to do some good we “need to demonstrate that the treatment is clinically effective and cost effective for NHS use”. That’s impeccable, but throughout the rest of the slides he talks of integrating with complementary” therapies, the effectiveness of which is either already disproved or simply not known.
I remain utterly baffled by the reluctance of some quite sensible people to grasp the nettle of deciding what works. Chantler fails to grasp the nettle, as does the Department of Health. Until they do so, I don’t see how they can be taken seriously.
10.05 Panel discussion
10:20 Integrated Health Awards 2009 Introduction: a review of the short-listed applications
10:45 Presentations to the Award winners by the special guest speaker
11:00 Keynote address by special guest speaker
Dr David Peters
12:00 Integration, long term disease and creating a sustainable NHS. Professor David Peters, Clinical Director and Professor of Integrated Healthcare, University of Westminster
I first met David Peters after Nature ran my article, Science Degrees without the Science. .One of the many media follow-ups of that article was on Material World (BBC Radio 4). This excellent science programme, presented by Quentin Cooper, had a discussion between me and David Peters ( listen to the mp3 file).
Marmot stressed the need for proper testing. In the case of
homeopathy and acupuncture, that proper testing has largely been done. The tests were failed.
The University of Westminster has, of course, gained considerable notoriety as the university that runs more degree programmes in anti-scientific forms of medicine than any other. Their lecture on vibrational medicine teaches students that amethysts “emit high Yin energy so transmuting lower energies and clearing and aligning energy disturbances at all levels of being”. So far their vice-chancellor, Professor Geoffrey Petts, has declined to answer enquiries about whether he thinks such gobbledygook is appropriate for a BSc degree.
But he did set up an internal enquiry into the future of their alternative activities. Sadly that enquiry seems to have come to the nonsensical conclusion that the problem can be solved by injection of good science into the courses, as reported here and in the Guardian.
It seems obvious that if you inject good science into their BSc in homeopathy the subject will simply vanish in a puff of smoke.
Nevertheless, Westminster has now closed down its homeopathy degree (the last in the country to go) and there is intense internal discussion going on there. I have the impression that Dr Peters’ job is in danger. The revelation of more slides from their courses on homeopathy, naturopathy and Chinese herbal medicine shows that these courses are not only barmy, but also sometimes dangerous.
Professor Chris Fowler
12:10 Educating tomorrow’s integrated doctors. Professor Chris Fowler, Dean for Education, Barts and The London School of Medicine and Dentistry
I first came across Dr Fowler when I noticed him being praised for his teaching of alternative medicine to students at Barts and the London Medical School on the web site of the Prince’s Foundation. I wrote him a polite letter to ask if he really thought that the Prince of Wales was the right person to consult about the education of medical students. The response I got was, ahem, unsympathetic. But a little while later I noticed that two different Barts students had set up public blogs that criticised strongly the nonsense that was being inflicted on them.
At that point, I felt it was necessary to support the students who, it seemed to me, knew more about medical education than Professor Fowler. It didn’t take long to uncover the nonsense that was being inflicted on the students: read about it here.
There is a follow-up to this story here. Fortunately, Barts’ Director of Research, and, I’m told, the Warden of Barts, appear to agree with my view of the harm that this sort of thing can do to the reputation of Barts, so things may change soon,
Dame Donna Kinnair
12:30 Educating tomorrow’s integrated nurses.
Dame Donna Kinnair, Director of Nursing, Southwark PCT
As far as I can see, Donna Kinnair has no interest in alternative medicine. She is director of nursing at Southwark primary care trust and was an adviser to Lord Laming throughout his inquiry into the death of Victoria Climbié. I suspect that her interest is in integrating child care services (they need it, judging by the recent death of ‘Baby P’). Perhaps her presence shows the danger of using euphemisms like ‘integrated medicine’ when what you really mean is the introduction of unproven or disproved forms of medicine.
12:40 Integrating the care of women: an example of the new paradigm. Michael Dooley, Consultant Obstetrician and Gynecologist
DC’s rule 2. Never trust anyone who uses the word ‘paradigm’. It is a sure-fire sign of pseudoscience. In this case, the ‘new paradigm’ seems to be the introduction of disproven treatment. Dooley is a gynaecologist and Medical Director of the Poundbury Clinic. His clinic offers a whole range of unproven and disproved treatments. These include acupuncture as an aid to conception in IVF. This is not recommended by the Cochrane review, and one report suggests that it hinders conception rather than helps.
13.00 – 14.00 Lunch and Exhibition
Boo Armstrong and Get Well UK
16.00 Integrated services in action: The Northern
Ireland experience: what has it shown us and what are its implications?
Boo Armstrong of Get Well UK with a team from the NI study
I expect that much will be made of this “study”, which, of course, tells you absolutely nothing whatsoever about the effectiveness of the alternative treatments that were used in it. This does not appear to be the view of Boo Armstrong, On the basis of the “study”, her company’s web site proclaims boldly
“Complementary Medicine Works
Get Well UK ran the first government-backed complementary therapy project in the UK, from February 2007 to February 2008″
This claim appears, prima facie, to breach the Unfair Trading Regulations of May 2008. The legality of the claim is, at the moment, being judged by a Trading Standards Officer. In any case, the “study” was not backed by the government as a whole, but just by Peter Hain’s office. It is not even clear that it had ethical approval.
The study consisted merely of asking people who had seen an alternative medicine practitioner whether they felt better or worse. There was no control group; no sort of comparison was made. It is surely obvious to the most naive person that a study like this cannot even tell you if the treatment has a placebo effect, never mind that it has any genuine effects of its own. To claim that it does so seems to be simply dishonest. There is no reason at all to think that the patients would not have got better anyway.
It is not only Get Well UK who misrepresent the evidence. The Prince’s
Foundation itself says
“Now a new, year long trial supported by the Northern Ireland health service has . . . demonstrated that integrating complementary and conventional medicine brings measurable benefits to patients’ health.”
That is simply not true. It is either dishonest or stupid. Don’t ask me which, I have no idea.
This study is no more informative than the infamous Spence (2005) ‘study’ of the same type, which seems to be the only thing that homeopaths can produce to support their case.
There is an excellent analysis of the Northern Ireland ‘study’ by Andy Lewis, The Northern Ireland NHS Alternative Medicine ‘Trial’. He explains patiently, yet again, what constitutes evidence and why studies like this are useless.
His analogy starts
” . . . the Apple Marketing Board approach the NHS and ask for £200,000 to do a study to show the truth behind the statement ‘An apple a day keeps the doctor away’. The Minister, being particularly fond of apples, agrees and the study begins.”
16.30 Social enterprise and whole systems integrated care. Dee Kyne, Sandwell PCT and a GP. Developing an integrated service in secondary care
Dee Kyne appears to be CEO of KeepmWell Ltd (a financial interest that is not mentioned).
Peter Mackereth, Clinical Lead, Supportive Services, Christie Hospital NHS Foundation Trust
I had some correspondence with Mackereth when the Times (7 Feb 2007) published a picture of the Prince of Wales inspecting an “anti-MRSA aromatherapy inhaler” in his department at the Christie. It turned out that the trial they were doing was not blind No result has been announced anyway, and on enquiry, I find that the trial has not even started yet. Surprising, then to find that the FIH is running the First Clinical Aromatherapy Conference at the Christie Hospital, What will there be to talk about?
Much of what they do at the Christie is straightforward massage, but they also promote the nonsensical principles of “reflexology” and acupuncture.
The former is untested. The latter is disproven.
Developing a PCT funded musculoskeletal service Dr Roy Welford, Glastonbury Health Centre
Roy Welford is a Fellow of the Faculty of Homeopathy, and so promotes disproven therapies. The Glastonbury practice also advertises acupuncture (disproven), osteopathy and herbal medicine (largely untested so most of it consists of giving patients an unknown dose of an ill-defined drug, of unknown effectiveness and unknown safety).
Making the best of herbal self-prescription in integrated practice: key remedies and principles. Simon Mills, Project Lead: Integrated Self Care in Family Practice, Culm Valley Integrated Centre for Health, Devon
Simon Mills is a herbalist who now describes himself as a “phytotherapist” (it sounds posher, but the evidence, or lack of it, is not changed by the fancy name). Mills likes to say things like “there are herbs for heating and drying”, “hot and cold” remedies, and to use meaningless terms like “blood cleanser”, but he appears to be immune to the need for good evidence that herbs work before you give them to sick people. He says, at the end of a talk, “The hot and the cold remain the trade secret of traditional medicine”. And this is the 21st Century.
Practical ways in which complementary approaches can improve the treatment of cancer. Professor Jane Plant, Author of “Your life in your hands” and Chief Scientist, British Geological Society and Professor Karol Sikora, Medical Director, Cancer Partners UK
Jane Plant is a geologist who, through her own unfortunate encounter with breast cancer, became obsessed with the idea that a dairy-free diet cured her. Sadly there is no good evidence for that idea, according to the World Cancer Research Fund Report, led by Professor Sir Michael Marmot. No doubt her book on the subject sells well, but it could be held that it is irresponsible to hold out false hopes to desperate people. She is a supporter of the very dubious CancerActive organisation (also supported by Michael Dixon OBE –see above) as well as the notorious pill salesman, Patrick Holford (see also here).
Karol Sikora, formerly an oncologist at the Hammersmith Hospital, is now Dean of Medicine at the University of Buckingham (the UK’s only private university). He is also medical director at CancerPartners UK, a private cancer company.
He recently shot to fame when he appeared in a commercial in the USA sponsored by “Conservatives for Patients’ Rights”, to pour scorn on the NHS, and to act as an advocate for the USA’s present health system. A very curious performance. Very curious indeed.
His attitude to quackery is a mystery wrapped in an enigma. One was somewhat alarmed to see him sponsoring a course at what was, at first, called the British College of Integrated Medicine, and has now been renamed the Faculty of Integrated Medicine That grand title makes it sound like part of a university. It isn’t.
The alarm was as result of the alliance with Dr Rosy Daniel (who promotes an untested herbal conconction, Carctol, for ‘healing’ cancer) and Dr Mark Atkinson (a supplement salesman who has also promoted the Qlink pendant. The Qlink pendant is a simple and obvious fraud designed to exploit paranoia about WiFi killing you.
The first list of speakers on the proposed diploma in Integrated Medicine was an unholy alliance of outright quacks and commercial interests. It turned out that, although Karol Sikora is sponsoring the course, he knew nothing about the speakers. I did and when I pointed this out to Terence Kealey, vice-chancellor of Buckingham, he immediately removed Rosy Daniel from directing the Diploma. At the moment the course is being revamped entirely by Andrew Miles. There is hope that he’ll do a better job. It has not yet been validated by the University of Buckingham. Watch this space for developments.
The role of happy chickens in healing: farms as producers of health as well as food – the Care Farm Initiative Jonathan Dover, Project Manager, Care Farming, West Midlands.
“Care farming is a partnership between farmers, participants and health & social care providers. It combines the care of the land with the care of people, reconnecting people with nature and their communities.”
Sounds lovely, I wonder how well it works?
What can the Brits learn from the Yanks when it comes to integrated health? Jack Lord, Chief Executive Humana Europe
It is worth noticing that the advisory board of Humana Europe includes Micheal Dixon OBE, a well known advocate of alternative medicine (see
above). Humana Europe is a private company, a wholly owned subsidiary of Humana Inc., a health benefits company with 11 million members and 22,000 employees and headquarters in Louisville, Kentucky. In 2005 it entered into a business partnership with Virgin Group. Humana was mentioned in the BBC Panorama programme “NHS for Sale”. The company later asked that it be pointed out that they provide commissioning services, not clinical services [Ed. well not yet anyway].
Humana’s document “Humana uses computer games to help people lead healthier lives” is decidedly bizarre. Hang on, it was only a moment ago that we were being told that computer games rewired your brain.
Day 2 Integrated health in action
09.00 Health, epidemics and the search for new solutions. Sir Michael Marmot, Professor of Epidemiology and Public Health, Royal Free and University College Medical School
It is a mystery to me that a distinguished epidemiologist should be willing to keep such dubious company. Sadly I don’t know what he said, but judging my his publications and his appearence on Natural World, I can’t imagine he’d have much time for homeopaths.
9.25 Improving health in the workplace. Dame Carol Black, National Director, Health and Work, Department of Health
This is not the first time that Dame Carol has been comtroversial.
9.45 Integrated health in focus: defeating obesity. Professor Chris Drinkwater, President, NHS Alliance.
The NHS Alliance was mentioned above. Enough said.
10.00 Integrated healthcare in focus: new approaches to managing asthma, eczema and allergy. Professor Stephen Holgate, Professor of Immunopharmacology, University of Southampton
10.15 Using the natural environment to increase activity. The Natural England Project: the results from year one. Dr William Bird and Ruth Tucker, Natural England.
10.30 Panel discussion
Self help in action
11.10 Your health, your way: supporting self care through care planning and the use of personal budgets. Angela Hawley, Self Care Lead, Department of Health
11.25 NHS Life Check: providing the signposts to
integrated health. Roy Lambley, Project Director, NHS LifeCheck Programme
This programme was developed with the University of Westminster’s “Health and Well-being Network”. This group, with one exception, is separate from Westminster’s extensive alternative medicine branch (it’s mostly psychologists).
11.45 The agony and the ecstasy of helping patients to help themselves: tips for clinicians, practices and PCTs. Professor
Ruth Chambers, FIH Foundation Fellow.
11.55 Providing self help in practice: Department of Health Integrated Self Help Information Project. Simon Mills, Project Lead: Integrated Self Care in Family Practice, Culm Valley Integrated Centre for Health, Devon and Dr Sam Everington, GP, Bromley by Bow.
Simon Mills is the herbalist who says “The hot and the cold remain the trade secret of traditional medicine” .
Sam Everington, in contrast, seems to be interested in ‘integration’ in the real sense of the word, rather than quackery.
Integrated health in action
How to make sense of the evidence on complementary approaches: what works? What might work? What doesn’t work?
Dr Hugh MacPherson, Senior Research Fellow in Health Sciences, York University and Dr Catherine Zollman, Bravewell Fellow
Hugh MacPherson‘s main interest is in acupuncture and he publishes in alternative medicine journals. Since the recent analysis in the BMJ from the Nordic Cochrane Centre (Madsen et al., 2009) it seems that acupuncture is finally dead. Even its placebo effect is too small to be useful. Catherine Zollman is a Bristol GP who is into homeopathy as well as acupuncture. She is closely connected with the Prince’s Foundation via the Bravewell Fellowship. That fellowship is funded by the Bravewell Collaboration, which is run by Christie Mack, wife of John Mack (‘Mack the Knife’), head of Morgan Stanley (amazingly, they still seem to have money). This is the group which, by sheer wealth, has persuaded so many otherwise respectable US universities to embrace every sort of quackery (see, for example, Integrative baloney @ Yale)
The funding of integrated services
14.15 How to get a PCT or practice- based commissioner to fund your integrated service. A PCT Chief Executive and a Practice-Based Commissioning lead.
14.30 How I succeeded: funding an integrated service. Dr John Ribchester, Whitstable
14.45 How we created an acupuncture service in St Albans and Harpenden PBC group. Mo Girach, Chief Executive, STAHCOM
Uhuh Acupunture again. Have these people never read Bausell’s
book? Have they not read the BMJ? Acupuncture is now ell-established to be based on fraudulent principles, and not even to have a worthwhile placeobo effect. STAHCOM seem to be more interested in money than in what works.
Dragon’s Den. Four pitchers lay out their stall for the commissioning dragons
And at this stage there is no prize for guessing that all four are devoted to trying to get funds for discredited treatments
- An acupuncture service for long-term pain. Mike Cummings Chair, Medical Acupuncture Association
- Manipulation for the treatment of back pain Simon Fielding, Founder Chairman of the General Osteopathic Council
- Nigel Clarke, Senior Partner, Learned Lion Partners Homeopathy for long term conditions
- Peter Fisher, Director, Royal Homeopathic Hospital
Sadly it is not stated who the dragons are. One hopes they will be more interested in evidence than the supplicants.
Mike Cummings at least doesn’t believe the nonsense about meridians and Qi. It’s a pity he doesn’t look at the real evidence though.
You can read something about him and his journal at BMJ Group promotes acupuncture: pure greed.
Osteopathy sounds a bit more respectable than the others, but in fact it has never shaken off its cult-like origins. Still many osteopaths make absurd claims to cure all sorts of diseases. Offshoots of osteopathy like ‘cranial osteopathy’ are obvious nonsense. There is no reason to think that osteopathy is any better than any other manipulative therapy and it is clear that all manipulative therapies should be grouped into one.
Osteopathy and chiropractic provide the best ever examples of the folly of giving official government recognition to a branch of alternative medicine before the evidence is in.
Learned Lion Partners is a new one on me. It seems it is
part of Madsen Gornall Ashe Chambers (‘MGA Chambers’) “a grouping of top level, independent specialists who provide a broad range of management consultancy advice to the marketing community”. It’s a management consultant and marketing outfit. So don’t expect too much when it comes to truth and evidence. The company web site says nothing about alternative medicine, but only that Nigel Clarke
“. . . has very wide experience of public affairs issues and campaigns, having worked with clients in many sectors in Europe, North America and the Far East. He has particular expertise in financial, competition and healthcare issues. “
However, all is revealed when we see that he is a Trustee of the Prince’s Foundation where his entry says
“Nigel Clarke is senior partner of Learned Lion Partners. He is a director of Vidapulse Ltd, Really Easy Ltd, Newscounter Ltd and Advanced Transport Systems Ltd. He has worked on the interfaces of public policy for 25 years. He has been chair of the General Osteopathic Council since May 2001, having been a lay member since it was formed. He is now a member of the Council for Healthcare Regulatory Excellence”
The Council for Healthcare Regulatory Excellence is yet another quango that ticks boxes and fails absolutely to grasp the one important point, does it work?. I came across them at the Westminster Forum, and they seemed a pretty pathetic way to spend £2m per year.
Peter Fisher is the last supplicant to the Dragons. He is clinical director of the Royal London Homeopathic Hospital (RLHH), and Queen’s homeopathic physician, It was through him that I got an active interest in quackery. The TV programme QED asked me to check the statistics in a paper of his that claimed that homeopathy was good for fibrositis (there was an elementary mistake and no evidence for an effect). Peter Fisher is also remarkable because he agreed with me that BSc degrees in homeopathy were not justified (on TV –see the movie). And he condemned homeopaths who were caught out recommending their sugar pills for malaria. To that extent Fisher represents the saner end of the homeopathic spectrum. Nevertheless he still maintains that sugar pills work and have effects of their own, and tries to justify the ‘memory of water’ by making analogies with a memory stick or CD. This is so obviously silly that no more comment is needed.
Given Fisher’s sensible condemnation of the malaria fiasco, I was rather surprised to see that he appeared on the programme of a conference at the University of Middlesex, talking about “A Strategy To Research The Potential Of Homeopathy In Pandemic Flu”. The title of the conference was Developing Research Strategies in CAM. A colleague, after seeing the programme, thought it was more like “a right tossers’ ball”.
Much of the homeopathy has now vanished from the RLHH as a result of greatly reduced commissioning by PCTs (read about it in Fisher’s own words). And the last homeopathy degree in the UK has closed down. It seems an odd moment for the FIH to be pushing it so hard.
This fascinating fact seems to have been unearthed first by the admirable NHS Blog Doctor, in his post ‘Imperial College confirm that Karol Sikora does not work for them and does not speak on their behalf‘.
I’m perfectly happy to think of alternative medicine as being a voluntary, self-imposed tax on the gullible (to paraphrase Goldacre again). But only as long as its practitioners do no harm and only as long as they obey the law of the land. Only too often, though, they do neither.
When I talk about law, I don’t mean lawsuits for defamation. Defamation suits are what homeopaths and chiropractors like to use to silence critics. heaven knows, I’ve becomes accustomed to being defamed by people who are, in my view. fraudsters, but lawsuits are not the way to deal with it.
I’m talking about the Trading Standards laws Everyone has to obey them, and in May 2008 the law changed in a way that puts the whole health fraud industry in jeopardy.
The gist of the matter is that it is now illegal to claim that a product will benefit your health if you can’t produce evidence to justify the claim.
I’m not a lawyer, but with the help of two lawyers and a trading standards officer I’ve attempted a summary. The machinery for enforcing the law does not yet work well, but when it does, there should be some very interesting cases.
The obvious targets are homeopaths who claim to cure malaria and AIDS, and traditional Chinese Medicine people who claim to cure cancer.
But there are some less obvious targets for prosecution too. Here is a selection of possibilities to savour..
- Universities such as Westminster, Central Lancashire and the rest, which promote the spreading of false health claims
- Hospitals, like the Royal London Homeopathic Hospital, that treat patients with mistletoe and marigold paste. Can they produce any real evidence that they work?
- Edexcel, which sets examinations in alternative medicine (and charges for them)
- Ofsted and the QCA which validate these exams
- Skills for Health and a whole maze of other unelected and unaccountable quangos which offer “national occupational standards” in everything from distant healing to hot stone therapy, thereby giving official sanction to all manner of treatments for which no plausible evidence can be offered.
- The Prince of Wales Foundation for Integrated Health, which notoriously offers health advice for which it cannot produce good evidence
- Perhaps even the Department of Health itself, which notoriously referred to “psychic surgery” as a profession, and which has consistently refused to refer dubious therapies to NICE for assessment.
The law, insofar as I’ve understood it, is probably such that only the first three or four of these have sufficient commercial elements for there to be any chance of a successful prosecution. That is something that will eventually have to be argued in court.
But lecanardnoir points out in his comment below that The Prince of Wales is intending to sell herbal concoctions, so perhaps he could end up in court too.
We are talking about The Consumer Protection from Unfair Trading Regulations 2008. The regulations came into force on 26 May 2008. The full regulations can be seen here, or download pdf file. They can be seen also on the UK Statute Law Database.
The Office of Fair Trading, and Department for Business, Enterprise & Regulatory Reform (BERR) published Guidance on the Consumer Protection from Unfair Trading Regulations 2008 (pdf file),
Statement of consumer protection enforcement principles (pdf file), and
The Consumer Protection from Unfair Trading Regulations: a basic guide for business (pdf file).
Has The UK Quietly Outlawed “Alternative” Medicine?
On 26 September 2008, Mondaq Business Briefing published this article by a Glasgow lawyer, Douglas McLachlan. (Oddly enough, this article was reproduced on the National Center for Homeopathy web site.)
“Proponents of the myriad of forms of alternative medicine argue that it is in some way “outside science” or that “science doesn’t understand why it works”. Critical thinking scientists disagree. The best available scientific data shows that alternative medicine simply doesn’t work, they say: studies repeatedly show that the effect of some of these alternative medical therapies is indistinguishable from the well documented, but very strange “placebo effect” ”
“Enter The Consumer Protection from Unfair Trading Regulations 2008(the “Regulations”). The Regulations came into force on 26 May 2008 to surprisingly little fanfare, despite the fact they represent the most extensive modernisation and simplification of the consumer protection framework for 20 years.”
The Regulations prohibit unfair commercial practices between traders and consumers through five prohibitions:-
- General Prohibition on Unfair Commercial
Practices (Regulation 3)
- Prohibition on Misleading Actions (Regulations 5)
- Prohibition on Misleading Omissions (Regulation 6)
- Prohibition on Aggressive Commercial Practices (Regulation 7)
- Prohibition on 31 Specific Commercial Practices that are in all Circumstances Unfair (Schedule 1). One of the 31 commercial practices which are in all circumstances considered unfair is “falsely claiming that a product is able to cure illnesses, dysfunction or malformations”. The definition of “product” in the Regulations includes services, so it does appear that all forms medical products and treatments will be covered.
Just look at that!
|One of the 31 commercial practices which are in all circumstances considered unfair is “falsely claiming that a product is able to cure illnesses, dysfunction or malformations”|
Section 5 is equally powerful, and also does not contain the contentious word “cure” (see note below)
5.—(1) A commercial practice is a misleading action if it satisfies the conditions in either paragraph (2) or paragraph (3).
(2) A commercial practice satisfies the conditions of this paragraph—
(a) if it contains false information and is therefore untruthful in relation to any of the matters in paragraph (4) or if it or its overall presentation in any way deceives or is likely to deceive the average consumer in relation to any of the matters in that paragraph, even if the information is factually correct; and
(b) it causes or is likely to cause the average consumer to take a transactional decision he would not have taken otherwise.
These laws are very powerful in principle, But there are two complications in practice.
One complication concerns the extent to which the onus has been moved on to the seller to prove the claims are true, rather than the accuser having to prove they are false. That is a lot more favourable to the accuser than before, but it’s complicated.
The other complication concerns enforcement of the new laws, and at the moment that is bad.
Who has to prove what?
That is still not entirely clear. McLachlan says
“If we accept that mainstream evidence based medicine is in some way accepted by mainstream science, and alternative medicine bears the “alternative” qualifier simply because it is not supported by mainstream science, then where does that leave a trader who seeks to refute any allegation that his claim is false?
Of course it is always open to the trader to show that his the alternative therapy actually works, but the weight of scientific evidence is likely to be against him.”
On the other hand, I’m advised by a Trading Standards Officer that “He doesn’t have to refute anything! The prosecution have to prove the claims are false”. This has been confirmed by another Trading Standards Officer who said
“It is not clear (though it seems to be) what difference is implied between “cure” and “treat”, or what evidence is required to demonstrate that such a cure is false “beyond reasonable doubt” in court. The regulations do not provide that the maker of claims must show that the claims are true, or set a standard indicating how such a proof may be shown.”
The main defence against prosecution seems to be the “Due diligence defence”, in paragraph 17.
Due diligence defence
17. —(1) In any proceedings against a person for an offence under regulation 9, 10, 11 or 12 it is a defence for that person to prove—
(a) that the commission of the offence was due to—
(i) a mistake;
(ii) reliance on information supplied to him by another person;
(iii) the act or default of another person;
(iv) an accident; or
(v) another cause beyond his control; and
(b) that he took all reasonable precautions and exercised all due diligence to avoid the commission of such an offence by himself or any person under his control.
If “taking all reasonable precautions” includes being aware of the lack of any good evidence that what you are selling is effective, then this defence should not be much use for most quacks.
Douglas McLachlan has clarified, below, this difficult question
False claims for health benefits of foods
A separate bit of legislation, European regulation on nutrition and health claims made on food, ref 1924/2006, in Article 6, seems clearer in specifying that the seller has to prove any claims they make.
Scientific substantiation for claims
1. Nutrition and health claims shall be based on and substantiated by generally accepted scientific evidence.
2. A food business operator making a nutrition or health claim shall justify the use of the claim.
3. The competent authorities of the Member States may request a food business operator or a person placing a product on the market to produce all relevant elements and data establishing compliance with this Regulation.
That clearly places the onus on the seller to provide evidence for claims that are made, rather than the complainant having to ‘prove’ that the claims are false.
On the problem of “health foods” the two bits of legislation seem to overlap. Both have been discussed in “Trading regulations and health foods“, an editorial in the BMJ by M. E. J. Lean (Professor of Human Nutrition in Glasgow).
“It is already illegal under food labelling regulations (1996) to claim that food products can treat or prevent disease. However, huge numbers of such claims are still made, particularly for obesity ”
“The new regulations provide good legislation to protect vulnerable consumers from misleading “health food” claims. They now need to be enforced proactively to help direct doctors and consumers towards safe, cost effective, and evidence based management of diseases.”
In fact the European Food Standards Agency (EFSA) seems to be doing a rather good job at imposing the rules. This, predictably, provoked howls of anguish from the food industry There is a synopsis here.
“Of eight assessed claims, EFSA’s Panel on Dietetic Products, Nutrition and Allergies (NDA) rejected seven for failing to demonstrate causality between consumption of specific nutrients or foods and intended health benefits. EFSA has subsequently issued opinions on about 30 claims with seven drawing positive opinions.”
“. . . EFSA in disgust threw out 120 dossiers supposedly in support of nutrients seeking addition to the FSD’s positive list.
If EFSA was bewildered by the lack of data in the dossiers, it needn’t hav been as industry freely admitted it had in many cases submitted such hollow documents to temporarily keep nutrients on-market.”
Or, on another industry site, “EFSA’s harsh health claim regime”
Here, of course,”unworkably high standard” just means real genuine evidence. How dare they ask for that!
Enforcement of the law
19. —(1) It shall be the duty of every enforcement authority to enforce these Regulations.
(2) Where the enforcement authority is a local weights and measures authority the duty referred to in paragraph (1) shall apply to the enforcement of these Regulations within the authority’s area.
Nevertheless, enforcement is undoubtedly a weak point at the moment. The UK is obliged to enforce these laws, but at the moment it is not doing so effectively.
A letter in the BMJ from Rose & Garrow describes two complaints under the legislation in which it appears that a Trading Standards office failed to enforce the law. They comment
” . . . member states are obliged not only to enact it as national legislation but to enforce it. The evidence that the government has provided adequate resources for enforcement, in the form of staff and their proper training, is not convincing. The media, and especially the internet, are replete with false claims about health care, and sick people need protection. All EU citizens have the right to complain to the EU Commission if their government fails to provide that protection.”
This is not a good start. A lawyer has pointed out to me
“that it can sometimes be very difficult to get Trading Standards or the OFT to take an interest in something that they don’t fully understand. I think that if it doesn’t immediately leap out at them as being false (e.g “these pills cure all forms of cancer”) then it’s going to be extremely difficult. To be fair, neither Trading Standards nor the OFT were ever intended to be medical regulators and they have limited resources available to them. The new Regulations are a useful new weapon in the fight against quackery, but they are no substitute for proper regulation.”
Trading Standards originated in Weights and Measures. It was their job to check that your pint of beer was really a pint. Now they are being expected to judge medical controversies. Either they will need more people and more training, or responsibility for enforcement of the law should be transferred to some more appropriate agency (though one hesitates to suggest the MHRA after their recent pathetic performance in this area).
Who can be prosecuted?
Any “trader”, a person or a company. There is no need to have actually bought anything, and no need to have suffered actual harm. In fact there is no need for there to be a complainant at all. Trading standards officers can act on their own. But there must be a commercial element. It’s unlikely that simply preaching nonsense would be sufficient to get you prosecuted, so the Prince of Wales is, sadly, probably safe.
Universities who teach that “Amethysts emit high Yin energy” make an interesting case. They charge fees and in return they are “falsely claiming that a product is able to cure illnesses”.
In my view they are behaving illegally, but we shan’t know until a university is taken to court. Watch this space.
The fact remains that the UK is obliged to enforce the law and presumably it will do so eventually. When it does, alternative medicine will have to change very radically. If it were prevented from making false claims, there would be very little of it left apart from tea and sympathy
New Zealand must have similar laws.
Just as I was about to post this I found that in New Zealand a
“couple who sold homeopathic remedies claiming to cure bird flu, herpes and Sars (severe acute respiratory syndrome) have been convicted of breaching the Fair Trading Act.”
They were ordered to pay fines and court costs totalling $23,400.
A clarification form Douglas McLachlan
On the difficult question of who must prove what, Douglas McLachlan, who wrote Has The UK Quietly Outlawed “Alternative” Medicine?, has kindly sent the following clarification.
“I would agree that it is still for the prosecution to prove that the trader committed the offence beyond a reasonable doubt, and that burden of proof is always on the prosecution at the outset, but I think if a trader makes a claim regarding his product and best scientific evidence available indicates that that claim is false, then it will be on the trader to substantiate the claim in order to defend himself. How will the trader do so? Perhaps the trader might call witness after witness in court to provide anecdotal evidence of their experiences, or “experts” that support their claim – in which case it will be for the prosecution to explain the scientific method to the Judge and to convince the Judge that its Study evidence is to be preferred.
Unfortunately, once human personalities get involved things could get clouded – I could imagine a small time seller of snake oil having serious difficulty, but a well funded homeopathy company engaging smart lawyers to quote flawed studies and lead anecdotal evidence to muddy the waters just enough for a Judge to give the trader the benefit of the doubt. That seems to be what happens in the wider public debate, so it’s easy to envisage it happening a courtroom.”
The “average consumer”.
(3) A commercial practice is unfair if—
(a) it contravenes the requirements of professional diligence; and
(b) it materially distorts or is likely to materially distort the economic behaviour of the average consumer with regard to the product.
It seems,therefore, that what matters is whether the “average consumer” would infer from what is said that a claim was being made to cure a disease. The legal view cited by Mojo (comment #2, below) is that expressions such as “can be used to treat” or “can help with” would be considered by the average consumer as implying successful treatment or cure.
The drugstore detox delusion. A nice analysis “detox” at .Science-based Pharmacy
Herbal medicine is, unlike homeopathy, not ridiculous, It is merely Pharmacology, as practised up to circa 1900. Whereas good trials have now shown acupuncture to be sham and homeopathy to be a placebo, there has been very little good research on herbs.
Most herbalism could fairly be described giving to sick patients an unknown dose of a substance with unknown efficacy and unknown safety.
How odd, then, to visit the Royal Society of Medicine to be greeted thus.
Just look at the words!
“Traditional Chinese Medicine (TCM) has developed over thousands of years”
That’s partly true
“and provides a comprehensive and systematic understanding of the natural world and the treatment of the human body.”
and that is total nonsense. TCM provides no understanding and virtually none of it is known to be useful for treating anything.
|Another poster at the RSM exhibition provides some of the explanation.
What on earth, one wonders, do they mean by “making efforts to modernise TCM “? So far, the idea of modernising TCM doesn’t seem to include any great effort to find out if it works.
Much of the promotion of TCM seems to be not so much ‘ancient wisdom’, but modern nationalist propaganda by the Chinese government.
The history is fascinating, but you won’t learn it from the posters on display at the exhibition.
“The Daoguang emperor though it [acupuncture] was a barrier to medical progress and removed it from the curriculum of the Imperial Medical Institute,”
“By the start of the twentieth century, acupuncture was extinct in the West and dormant in the East. It might have fallen out of favour permanently, but it suddenly experienced a revival in 1949 as a direct result of the communist revolution and the establishment of the People’s Republic of China. Chairman Mao Tse-tung engineered a resurgence in traditional Chinese medicine, which included not just acupuncture but also Chinese herbal medicine and other therapies ”
“His motivation was partly ideological, inasmuch as he wanted to reinforce a sense of national pride in Chinese medicine. However he was also driven by necessity. He had promised to deliver affordable healthcare .. . . ”
“Mao did not care whether traditional Chinese medicine worked, as long as he could keep the masses contented. In fact, his personal physician, Zhisui Li, wrote a memoir entitled ‘The Private Life of Chairman Mao’, in which he quoted Mao as saying”
“Even though I believe we should promote Chinese medicine, I personally do not believe in it. I don’t take Chinese medicine.” “Singh & Ernst Trick or Treatmant, page 46.
Or, as put more succinctly by Shapiro
“You would never know that TCM was fashioned in the twentieth century, as we shall see, from a ragbag of therapies in post-revolutionary China.”
Why is the Royal Society of Medicine allowing such mendacious posters? As it happens, I and a friend were visiting the RSM to see their Academic Dean, with a view to finding out why the RSM had failed to take any public position on alternative medicine. The answer appeared to be money, and that was the answer to why the TCM exhibition was being held on their premises too. The Dean no more believed in TCM than we did, but, well, they need the income. He pointed out (looking suitably sheepish) that the address given for the exhibition was not the RSM, but Number 1 Wimpole Street (that, of course, is also the address of the RSM).
Ah, so that’s OK then.
It has to be said that the RSM isn’t alone in its spineless attitude. Both the British Medical Association (BMA) and the Royal College of General Practitioners (RCGP) have failed to make any clear condemnation of mystical medicine. This is in stark contrast to just about every relevant scientific society (here is a summary).
It is a mystery to me why much of medicine should still be dominated by a mindset that seems to have lagged 200 years behind every other science. Perhaps medicine is just too complicated.
UCL Hospitals’ skeleton in the cupboard
Make no mistake, University College London Hospital is top class. The UCLH Trust. runs seven hospitals All but one of them are excellent. But in 2002 the Royal London Homeopathic Hospital was acquired as part of the UCLH group, to the intense embarrassment of UCL scientists.
Let’s start with the good bit. Usually I don’t like anecdotes, so just think of this as a vote of thanks, not evidence.
A personal history of UCH
I owe UCLH a lot personally. On December 13th 1984, my wife had
a subarachnoid haemorrhage when she was seven months pregnant. After misdiagnosis at St Peter’s Hospital, Chertsey, she was moved to UCH and diagnosed very quickly. The next day she had neurosurgery to pin an aneurysm at the Maida Vale Neurosurgical Hospital, part of the UCLH group (it no longer exists). The surgeon, Alan Crockard, came out of theatre after five hours, looking rather tired and said “it was adhered to the optic chiasma on one side and about a millilmetre from the pituitary on the other. It was a bit tricky but I think we got it”.
|After a week in intensive care, under heavy sedation, Margaret’s blood pressure was not low enough and they decided to deliver the baby. At about 4 pm on a snowy Christmas Eve, a team of neurosurgeons and a team of obstetricians gathered and soon after, Andrew Stuart Colquhoun emerged in a small incubator to be whisked off in an ambulance to the Special Care Baby Unit at UCH (run, at that time, by Osmund Reynolds).. Christmas day was spent in the hospital, with Margaret’s mother. Andrew weighed 1.4 kg at birth, but by Christmas day he had pulled out his ventilator himself, and was doing fine. He was so tiny that it was a couple of days before I dared to hold him. The Unit had racks of doll-sized clothes, knitted by volunteers.||
Andrew (at 9 days) and Dad. Jan 2, 1985. Click for album..
Once Margaret was well enough, she was given a side room in a neurosurgical ward with a cot for Andrew by her bed, an arrangement that gave the neurosurgical nurses some fun. They were in UCLH continuously until 27th April before Margaret had recovered enough to go home, [Full photo album here]
Now they are both fine.and Andrew is 6′ 7″ (200.5 cm)..
It is episodes like this that make one very proud of the NHS. Heaven knows what it would have cost in the USA.
Margaret & Andrew, with carer, Anna, June 2, 1985
Andrew playing cricket in Bangladesh, Feb 2005.
But now the the less desirable side of UCLH
Herbs and homeopaths at UCLH
|Recently I was sent the UCLH Annual Review 2007 – 2008. There was a lot of good stuff in it and worth a read despite there being too much hyperbole and too many pictures of men in dark suits. But buried among all the high tech stuff, what do we find but an advertisement for 1900-style pharmacology in the form of the herbal clinic at the Royal London Homeopathic Hospital, accompanied by a load of utterly inaccurate information from the TV botanist, David Bellamy.
Take, for example, the claim about Devil’s Claw for osteoarthritis. Even alternative medicine advocates said “The authors concluded that there are insufficient high-quality trials to determine the safety and efficacy of Devil’s Claw (Harpagophytum procumbens) in the treatment of osteoarthritis, and that definitive trials are needed.”
Reading between the lines, I’d guess that the opening of this clinic has a subtext. It is well known that funding for homeopathy has dried up (partly as a result of our letter to NHS Trusts that appeared in the
There have been problems before with the herbal activities at the RLHH before (see Conflicts of Interest at the Homeopathic Hospital). It appeared that the Khans, who run the Marigold homeopathic podiatry clinic (no, seriously, it is real) were largely prescribing a herbal product that was made by their own company. without even the hospital trust, never mind the patients, being made aware of it. In normal medicine this would be regarded as a rather serious offence, but as far as I know, nothing was ever done about it.
The ethics of alternative medicine are truly one of life’s great mysteries.
Reading further in the annual review, we come to the page about the RLHH. The homeopathy side must really have run down because it seems to have diversified into selling cosmetics and groceries. That sounds like desperation.
Good heavens, they sell “chemical-free sun cream”. One wonders what it can be made of, if not chemicals. This is the language of low-grade advertising agencies, not what one expects from an NHS hospital trust.
|But next to this there is a much more interesting item. Just look at the last sentence.
I wonder if this could possibly have anything to do with the fact that Michael Baum and I visited the Trust headquarters in August 2006 to propose that the RLHH might be turned into a centre of supportive and palliative care?
It would be nice to think so. But it seems they haven’t gone nearly far enough yet. If all they do is replace the waning homeopathy
We know they are under pressure from their royal patrons, but that, in a constitutional monarchy, is simply not acceptable.
Michael Baum is a cancer surgeon who has taken a particular interest in palliative and supportive care. He is someone whose views should be taken seriously. He is also the author of the magnificent “An open letter to the Prince of Wales: with respect, your highness, you’ve got it wrong” Here is a quotation from that letter. The UCLH Trust should bear it in mind.
|The power of my authority comes with a knowledge built on 40 years of study and 25 years of active involvement in cancer research. I’m sensitive to the danger of abusing this power and, as a last resort, I know that the General Medical Council (GMC) is watching over my shoulder to ensure I respect a code of conduct with a duty of care that respects patients’ dignity and privacy and reminds me that my personal beliefs should not prejudice my advice.
Your power and authority rest on an accident of birth. Furthermore, your public utterances are worthy of four pages, whereas, if lucky, I might warrant one. I don’t begrudge you that authority and we probably share many opinions about art and architecture, but I do beg you to exercise your power with extreme caution when advising patients with life threatening diseases to embrace unproven therapies. There is no equivalent of the GMC for the monarchy, so it is left either to sensational journalism or, more rarely, to the quiet voice of loyal subjects such as myself to warn you that you may have overstepped the mark. It is in the nature of your world to be surrounded by sycophants (including members of the medical establishment hungry for their mention in the Queen’s birthday honours list) who constantly reinforce what they assume are your prejudices. Sir, they patronise you! Allow me this chastisement.