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The much-delayed public consultation on the Pittilo report has just opened.

It is very important that as many people as possible respond to it.  It’s easy to say that the consultation is sham. It will be if it is left only to acupuncturists and Chinese medicine people to respond to it. Please write to them before the closing date, November 2nd 2009. The way to send your evidence is here.

There is a questionnaire that you can complete, with the usual leading questions.  Best do it anyway, but I’d suggest also sending written evidence as attachment too. I just got from DoH the email address where you can send it. They said

 if you have material you wish to send which you can’t easily “shoehorn” into the questionnaire, please send it to the following mailbox: HRDListening@dh.gsi.gov.uk

Here are three documents that I propose to submit in response to the consultation.I ‘d welcome criticisms that might make it more convincing. Use any parts of them you want in your own response.

• Submission to the Department of Health, for the consultation on the Pittilo report [download pdf].
• $2.5B Spent, No Alternative Med Cures [download pdf]  I’ve written quite a lot about the Pittilo report already, in particular A very bad report: gamma minus for the vice-chancellor, and in The Times (see also the blog version). Intriguingly, these posts are at number 2 in a Google search for “Michael Pittilo”. Briefly, the back story is this. It is now over a year since the Report to Ministers from “The Department of Health Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK” [download the report]. The chair of the steering group was Professor R. Michael Pittilo, Principal and Vice-Chancellor of The Robert Gordon University, Aberdeen. The reason thet the report is so disastrously bad in its assessment of evidence is that it was written entirely by people with vested interests. The committee consisted of five acupuncturists, five herbalists and five representatives of traditional Chinese medicine (plus eleven observers). There was not a single scientist or statistician to help in the assessment of evidence. And it shows: The assessment of the evidence in the report was execrable. Every one of the committee members would have found themselves out of work if they had come to any conclusion other than that their treatment works, Disgracefully, these interests were not declared in the report, though they are not hard to find. The university of which the chair is vice-chancellor runs a course in homeopathy, the most discredited of the popular forms of alternative medicine. That tells you all you need to know about the critical faculties of Michael Pittilo. The two main recommendations of this Pittilo report are that • Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine should be subject to statutory regulation by the Health Professions Council • Entry to the register normally be through a Bachelor degree with Honours Let’s consider the virtue of these two recommendations. Regulation by the Health Professions Council (HPC) breaks their own rules For a start, this should be ruled out by the HPC’s own rules, which require “Practise based on evidence of efficacy” as a condition for registration. Since there is practically no “evidence of efficacy”, it follows that the HPC can’t regulate acupuncture, herbal and Chinese medicine as Pittilo recommends. Or so you’d think. But the official mind seems to have an infinite capacity for doublespeak. The HPC published a report on 11 September 2008, Regulation of Medical Herbalists, Acupuncturists and Traditional Chinese Medicine Practitioners. The report says 1. Medical herbalists, acupuncturists and traditional Chinese medicine practitioners should be statutorily regulated in the public interest and for public safety reasons. 2. The Health Professions Council is appropriate as the regulator for these professions. 3. The accepted evidence of efficacy overall for these professions is limited, but regulation should proceed because it is in the public interest. In other words, the HPC simply decided to ignore its own rules, Its excuse for doing so is that regulation would protect “public safety” . But it simply would not do that. It is ell known that some Chinese herbs are adulterated with dangerous substances, but laws against that already exist. Trading Standards are much more likely to take appropriate action than the HPC. The Medicines and Health Regulatory Authority (MHRA) already deals with the licensing of herbal medicines. and, despite the fact that it recently betrayed its trust by allowing them to be labelled in a misleading way, they are the people to do it, not the HPC. The Pittilo report (page 11) says In future, it is hoped that more Government funding can be allocated to research into traditional/herbal medicines and acupuncture and that grants will become available to encourage practitioners to undertake postgraduate research work. So they are asking for more government money. In March 2007, the Chinese Government pledged to spend over$130 million over the next five years on research into the effectiveness of traditional Chinese medicine. It is to be hoped that this money will be targeted effectively to evaluate TCM.

It seems to have escaped the notice of Pittilo that roughly 100 percent of trials of Chinese medicine done in China come out positive. Elsewhere, very few come out positive,(see Vickers et al., 1998, Controlled Clinical Trials, 19, 159-166: download reprint) The Department of Health would be unwise to rely on Chinese research. Remember that modern acupuncture was not so much a product of ancient wisdom, but rather it stems from nationalist propaganda by Mao Tse-Tung, who needed a cheap way to keep the peasants quiet, though he was too sensible to use it himself.

The HPC report (page 5) cites these with the words

” . . . a lack of evidence of efficacy should not prevent regulation but that the professions should be encouraged and funded to strengthen the evidence base.”

This sentence seems to assume that the outcomes of research will be to strengthen the evidence base. Thus far, precisely the opposite has been the case. The Pittilo group has apparently not noticed that the US National Institutes of Health has already spent a billion dollars on research in alternative medicine and failed to come up with a single effective treatment. There are better ways to spend money on health. See, for example $2.5B Spent, No Alternative Med Cures found. .An enornous amount of research has already been done and the outcomes have produced no good treatments, The proposed regulation would endanger the public, not protect it. The excuse given by the HPC for breaking its own rules is that it should do so to protect the public. Likewise Ann Keen, Health Minister, said: “Patient safety is paramount, whether people are accessing orthodox health service treatments or using alternative treatments” So first we need to identify what dangers are posed by acupuncture, herbal medicine and traditional Chinese medicine. • Acupuncture is fairly safe. Its biggest danger lies in the unjustified claims that are routinely made for what can be achieved by being impaled by needles. This poses a danger that people may use acupuncture in place of treatments that work • Herbal medicines are unstandardised, so even the very few that may work are dangerous to patients because the dose of active principle is unknown and varies from one batch to another. Taking a herbal medicine is a bit like swallowing a random number of tablets, False health claims pose a danger to patients too, when they cause patients to avoid treatments that work. • Traditional Chinese Medicine is probably the most dangerous. Like the other two, the medicines are unstandardised so the dose is never known. False health claims abound. And in addition to these dangers, many cases have been found of Chinese medicines being adulterated with poisonous substances or with conventional drugs. The form of regulation proposed by Pittilo would do little or nothing to protect the public from any of these dangers. The proposals accept the herbal and Chinese medicine as traditionally practised. Nothing would be done about one of the major dangers, the lack of standardisation. That is a problem that was solved by pharmacologists in the 1930s, when international standards were set for the biological activity of things like tincture of digitalis, and assays were devised so that different batches could be adjusted to the same potency. Now, 80 years later, it is being proposed by Pittilo that we should return to the standards of safety that existed at the beginning of the last century. That is a threat to public safety., but the proposed regulation would do nothing whatsoever to protect the public from this dangerous practice. On the contrary, it would give official government sanction to it. The other major danger is that patients are deceived by false health claims. This is dangerous (as well as dishonest) because it can cause patients to avoid treatments that work better, The internet abounds with claims that herbs can cure anything from diabetes to cancer. Many are doubtless illegal, but regulators like the HPC have traditionally ignored such claims: they are left to Trading Standards, Advertising Standards and the Medicines and Health Regulatory Authority (MHRA) to deal with. The MHRA already also has responsibility for monitoring side effects. The HPC would not do this. The analogy with chiropractic and the GCC The foolishness of allowing statutory regulation for unproven treatments has recently been illustrated quite dramatically by the case of chiropractic. Chiropractors have had statutory regulation by the General Chiropractic Council, which was established by the Chiropractors Act of 1994. The British Chiropractic Association (BCA) recently decided to sue the science writer, Simon Singh, for defamation when he cast doubt on some of the claims made by chiropractors, in particular their claims to be able to cure colic and asthma in children. That led to close examination of the claims. In fact there is no reason to think that spinal manipulation works for asthma, or that it works for colic. In fact there is quite good evidence that the claims are false. The result was that about 600 well-justified complaints have been lodged with the GCC (enough to bankrupt the GCC if the complaints are dealt with properly). The point of this story is that the statutory regulator had nothing whatsoever to prevent these false health claims being made. Two of the complaints concern practices run by the chair of the GCC. Worse, the GCC actually endorsed such claims. The statutory regulator saw its duty to defend chiropractic (apart from a handful of cases of sexual misdemeanours), not to protect the patient from false health claims. The respectability conferred by statutory regulation made false health claims easier and endangered the public. It would be a disaster if the same mistake were made again. On 11th December 2008 I got a letter form the HPC which said in our opinion a lack of evidence of efficacy would not impede our ability to set standards or deal with complaints we receive. The vast majority of cases we consider are related to conduct. But perhaps that is because they haven’t tried “regulating” quacks before. Now that the public is far more conscious about health fraud than it used to be, one can predict confidently that the HPC would be similarly overwhelmed by a deluge of complaints about the unjustified health claims made by acupuncturists, herbal medicine and traditional Chinese medicine practitioners. There is no shortage of them to complain about. The education problem The Pittilo report recommends that the entry level for registration should be a bachelors degree with honours. At first sight it seems reasonable to ask that practitioners should be ‘properly qualified’, but when one looks at what is actually taught on these degrees it becomes clear that they endanger, rather than protect, the public, There are two very big problems with this recommendation. Firstly, you can’t have a bachelors degree with honours until after you have decided whether or not there is anything useful to teach. If and when any of the subjects under consideration and shown to work to a useful extent, then it would be quite reasonable to establish degrees in them. Even the report does not pretend seriously that that stage has been reached. The proposal to set up degrees in subjects, at least some of which are quite likely to have no more than placebo value, is self-evidently nonsense, The time for degrees, and the time for government endorsement by statutory regulation, is after the therapies have been shown to work, not before. The absurdity of thinking that the public will be protected because a practitioner has a degree in, say, acupuncture, is shown with startling clarity by a recently revealed examination paper in acupuncture’ You can download the entire exam paper. Here are a few highlights from it. So students, in 2009, are being taught the crudest form of vitalism. Teaching of traditional Chinese medicine is just as bad. Here are two slides from a course run by the University of Westminster. The first ‘explains’ the mysterious and entirly mythical “Qi”. So “Qi” means breath, air, vapour, gas, energy, vitalism. This is meaningless nonsense. The second slide shows the real dangers posed by the way Chinese medicine is taught, The symptoms listed at the top could easily be a clue to serious illness, yat students are taught to treat them with ginger. Degrees like this endanger the public. There are more mind-boggling slides from lectures on Chinese medicine and cancer: they show that what students are being taught is terrifyingly dangerous to patients. It is entirely unacceptable that students are being taught these ancient myths as though they were true, and being encouraged to treat sick people on their basis. The effect of the Pittilo recommendations would be to force new generations of students to have this sort of thing forced on them. In fact the course for which this exam was set has already closed its doors. That is the right thing to do. Here’s another example. The course leader for “BSc (Hons) Herbal Medicine” at the Univsrsity of Central Lancashire is Graeme Tobyn BA. But Tobyn is not only a herbalist but also an astrologer. In an interview he said “At the end I asked her if I could cast her horoscope. She threw up her hands and said, ‘I knew this would happen if I came to an alternative practitioner.” “I think the ruler of the ascendant was applying to Uranus in the ninth house, which was very pertinent.” This would be preposterous even in the life style section of a downmarket women’s magazine, The Pittilo report wants to make degrees run my people like this compulsory. Luckily the Univerity of Central Lancashire is much more sensible and the course is being closed. The matter is, in any case, being taken out of the hands of the government by the fact that universities are closing degrees in complementary medicine, including courses in some of those under discussion here, The University of Salford and the University of Central Lancashire have recently announced the closure of all the degree programmes in complementary and alternative medicine. The largest provider of such degrees, the University of Westminster has already shut down two of them, and the rest are being assessed at the moment. It is likely that the rest will be closed in the future. The revelation that Westminster had been teaching its first year students that “amethysts emit high yin energy” and that students had been taught to diagnose disease and choose treatments by means of a dowsing pendulum, showed very clearly the sort of utter nonsense that undergraduates were being forced to learn to get a ‘bachelors degree with honours’. It stretches credulity to its limits to imagine that the public is protected by degrees like this. Precisely the opposite is true. The universities have recognised this, and shut the degrees. One exception is Professor Pittilo’s own university which continues to run a course in homeopathy, the most discredited of all the popular types alternative medicine. A simpler, more effective and cheaper way to protect the public I must certainly agree with the minister that protection of the public is an important matter. Having established that the Pittllo recommendations are more likely to endanger the public than protect them, it is essential to suggest alternative proposals that would work better. Luckily, that is easy, because mechanisms already exist for dealing with the dangers that were listed above. The matter of adulteration, which is serious in traditional Chinese medicine, is a matter that is already the responsibility of the Office of Trading Standards. The major problem of false claims being made for treatment is also the responsibility of the Office of Trading Standards, which has a statutory duty to enforce the Unfair Trading Consumer Protection Regulations of May 2008. These laws state, for example, that “One of the 31 commercial practices which are in all circumstances considered unfair is “falsely claiming that a product is able to cure illnesses, dysfunction or malformations” The monitoring of false claims, and of side effects of treatments, is also the responsibility of the Medicines and Health Regulatory Authority (MHRA). Rather than setting up complicated, expensive and ineffective ‘regulation’ by the HPC, all that need to be done is to ensure that the MHRA and/or Trading Standards have the funds to enforce existing laws. At the moment, they are not being implemented effectively, so I’d recommend that responsibility for enforcing the law against false health claims be transferred entirely to the MHRA, which has much more expertise in such matters than Trading Standards This would be both cheaper and more effective than the present system in which the responsibility is divided between the two organisations in an unclear way. This proposal would protect the public against unsafe and adulterated treatments, and it would protect the public against false and fraudulent claims. That is what matters. It would do so more effectively, more cheaply and more honestly than the Pittilo recommendations. There would be no reduction in patient choice either, There is no proposal to ban acupuncture, herbal medicine or traditional Chinese medicine. All that is necessary is to ensure that they don’t endanger the public. Since the root of the problem lies in the fact that the evidence for the effectiveness is very weak. the question of efficacy, and cost-benefit ratio, should be referred to NICE. This was recommended by the House of Lords Report (2000). It is recommended again by the Smallwood report (sponsored by the Prince of Wales Foundation). It is baffling that this has not been done already. It does not seem wise to spend large amounts of money on new research at the moment, in the light of the fact that the US National Institutes of Health has already spent over$1 billion on such research without finding a single useful treatment.

The results of all this research has been to show that hardly any alternative treatment are effective. That cannot be ignored.

Conclusion

Recent events show that the halcyon days for alternative medicine are over. When the Pittilo report first appeared, it was greeted with derision in the media. For example, in The Times Alice Miles wrote

“This week came the publication of the Report to Ministers from the Department of Health Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK. Otherwise known as twaddle.”

In the Independent, Dominic Lawson wrote

So now we will have degrees in quackery.

What, really, is the difference between acupuncture and psychic surgery?

People will no doubt continue to use it and that is their right and their responsibility. But if the government were to accept the recommendations of the Pittilo report it would be seen, quite rightly, as being anti-scientific and of posing a danger to the public.

Fortunately there is a better, and cheaper, way to protect the public.

### Follow-up

Margaret McCartney’s blog in the Financial Times puts rhw view of a GP with her usual sense, humour and incisiveness.

“This report would, if implemented, create lots more nonsense exam papers funded by a lot more public money – and would produce practitioners without the absolutely crucial skill of how to assess evidence and reject or use it appropriately”

The Times has covered the story (with some interesting comments) Consultation on how to regulate complementary and alternative therapies

Times Higher Education UK-wide consultation on CAM regulation is launched Excellent response from Andy Lewis.

The Sun has by far the best coverage up to now, Jane Symons writes “Regulating quacks helps them prey on gullible patients

Acupuncture has been in the news since, in a moment of madness, NICE gave it some credence,

Some people still seem to think that acupuncture is somehow more respectable than, say, homeopathy and crystal healing. If you think that, read Barker Bausell’s book ot Trick or Treatment. It is now absolutely clear that ‘real’ acupuncture is indistinguishable from sham, whether the sham control uses retractable needles, or real needles in the ‘wrong’ places. There has been no clear demonstration of long-lived benefits in any condition, and it is likely that it is no more than a theatrical placebo.

In particular, the indistinguishability of ‘real’ and sham acupuncture shows, beyond reasonable doubt that all the stuff about “energy flow in meridians” is so much hokum.

There is a small group of ‘medical acupuncturists‘ that believes that it is hokum. but who nonetheless maintain that acupuncture works, despite the evidence to the contrary. But most acupuncturists go for the wholesale gobbledygook.

If you don’t believe that, take a look at the exam paper that has come into my possession. It is this year’s exam from the University of Salford. Salford has, very sensibly, now decided to stop all its degrees in alternative medicine, so don’t hold this against the university too much.

You can download the entire exam paper. Here are a few highlights.

So students, in 2009, are being taught the crudest form of vitalism.

Oh really. Perhaps protons neutrons and electrons?

OK I’d fail that one because the words have no obvious meaning at all.

Perhaps an elementary textbook of embryology would help?

How one would love to see a set of model answers for these questions.

All this is ancient hokum being taugh to hapless students in the 21st century as though it were fact. The University of Salford has understood that and closed the course. All we need now is for NICE and the Department of Health to understand what it is that they are promoting.

### NICE neglected the cultural cost of their guidance

When National Institute for Health and Clinical Excellence (NICE) included an acupuncture option on their low back pain guidance, they quite forget that one effect of their decision would be to ensure that new generations of students would have their minds poisoned with intellectual junk like this. That is why NICE really must think again. . See also
NICE falls for bait and switch by acupuncturists and chiropractors
NICE fiasco part 2 Rawlins should withdraw guidance and start again
NICE fiasco Part 3. Too many vested interests, not enough honesty

### Pittilo and statutory regulation

Public consultation is due to open shortly on the appalling report of the Department of Health Steering Group on the Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK (see also, The Times)

One of the recommendations is that acupuncture and Chinese herbal medicine should have statutory regulation by the Health Professions Council (HPC), despite the fact that that would involve the HPC breaking its own rules. Another recommendation of Pittilo is that entry to the “profession” (his word, not mine) should be by means of honours degree only. So he wants to impose on students exams like this one in order to “protect the public”? The absurdity of that proposal should be obvious now. This exam paper will form part of my evidence to the consultation.

And there is one other small problem. Universities are busy shutting down their degrees in alternative medicine, now that the ridiculousness of what is taught has been exposed. They have shut down entirely at the University of Salford and at the University of Central Lancashire, And even the University of Westminster is working on closing them.

All we need now is for the common sense and integrity that has been shown by these universities to spread to the Department of Health (and NICE).

### Follow-up

This letter appeared in the Times on Friday 30 January, 2009. It was prompted by the news from the University of Salford, but its main purpose was to try to point out to the Department of Health that you can’t hope to regulate alternative treatments in any sensible way while continuing to push under the carpet the crucial question of which ones work and which don’t.

 Sir We would like to congratulate the vice-chancellor of the University of Salford, Professor Michael Harloe for his principled decision to drop “all the University’s programmes associated with complementary medicine within the School of Community, Health Sciences & Social Care”. This includes their “Homeopathy in Practice” degree. It is also encouraging that the University of Central Lancashire recently closed its BSc in Homeopathy to new students, and announced a review of all its activities in alternative medicine. Although universities are now taking sensible actions, government policy in the area of regulation of alternative medicine is in urgent need of revision. In May 2008 the Steering Group chaired by Professor Pittilo recommended to the Department of Health that entry into acupuncture, herbal medicine and traditional Chinese medicine should “normally be through a bachelor degree with honours”. But, in the same month, new regulations on Unfair Trading came into effect. 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”. One part of government seeks to endorse unproven and disproved treatments, at the same time as another part makes them illegal. The reason for this chaotic situation is simple. The Department of Health, and the Medicines and Healthcare products Regulatory Agency (MHRA), have consistently failed to grasp the nettle of deciding which treatments work and which don’t. That is the first thing you want to know about any treatment. Vice-chancellors seem now to be asking the question, and the government should do so too. The ideal mechanism already exists.  The question should be referred to the National Institute for Health and Clinical Excellence (NICE). That was recommended by a House of Lords report in 2000, and it was recommended again by the Smallwood report (commissioned by the Prince of Wales) in 2005. Now it should be done. Sir Walter Bodmer FRCPath, FRS, FMedSci, FRCP (hon)  FRCS(hon) Cancer & Immunogenetics Laboratory Weatherall Institute of Molecular Medicine, Oxford Professor David Colquhoun, FRS Research Professor of Pharmacology University College London Dame Bridget Ogilvie , AC, DBE, FRS, FAA, Visiting Professor at UCL, Past director of the Wellcome Trust Professor Dame Nancy Rothwell, FRS, FMedSci, FRCP (hon) MRC Research Professor, University of Manchester

(Actually, the Times removed the qualifications of the signatories, but left the titles!)

An earlier, longer, version of the letter tried to preempt the obvious criticism by including, as the second paragraph, this passage.

“It makes no sense to offer Bachelor of Science degrees in subjects that have no scientific basis. Not only is homeopathy scientifically absurd, but also the best quality clinical trials show that it is not distinguishable from placebo. From the point of view of the patient, there is nothing wrong with placebo effects. Conventional drugs benefit from them too. There is everything wrong with surrounding the placebo effect with mystical mumbo-jumbo and awarding degrees in it.”

Universities drop degree courses in alternative medicine

In the same issue, there was a related article by the Times’ education editor, Alexandra Frean: Universities drop degree courses in alternative medicine..

“Universities are increasingly turning their backs on homoeopathy and complementary medicine amid opposition from the scientific community to “pseudo-science” degrees.

The University of Salford has stopped offering undergraduate degrees in the subjects, and the University of Westminster announced yesterday that it plans to strengthen the “science base” content of its courses after an internal review which examined their scientific credibility.

Both universities are following the lead of the University of Central Lancashire, which last year stopped recruiting new students to its undergraduate degree in homoeopathic medicine.

The decisions by Salford and Westminster open a new chapter in the fierce debate about the place of awarding of Bachelor of Science degrees in subjects that are not science.”

The article ends thus.

“Other universities are more robust in their defence of their courses

Ian Appleyard, principal lecturer in acupuncture at London South Bank University, said that acupuncture should be studied for the very reason that it was not well understood from the standpoint of Western scientific medicine. Acupuncture had been used by a significant proportion of the world’s population for thousands of years.

“Recent large-scale clinical trials such Haake and meta-analysis from reputable institutions such as The Cochrane Collaboration, have shown that there is evidence to support the therapeutic benefits of acupuncture treatment for back pain and migraine,” he said.”

Uhuh, it seems that Ian Appleyard has been reading the misleading BBC report on the recent trials. In fact they show precisely the opposite of what he claims. The fact that advocates of alternative medicine can misinterpret the evidence so badly is, I guess, at the heart of the problem.

### What’s happening at the University of Westminster?

Westminster has regularly been labelled as the University that has more quackery courses than any other.

It is also the only university for which we have much idea about what is taught.  The university, like all others, has tried to keep secret what they teach.  That itself shows that they aren’t very proud of it.  But a surprising amount has leaked out from Westminster, nonetheless. The set of “vibrational medicine” slides, including “Amethysts emit high Yin energy”, have caused much hilarity.  The Westminster “miasmatic” examination question gets some laughs too, after it was published in Nature. The set of homeopathic materia medica notes that have come into my possession are pretty good too (coming on line soon).

Recently it emerged that the University of Westminster had followed the example of the University of Central Lancashire (UCLAN), and set up a review of its activities in alternative medicine.  But unlike UCLAN it was kept secret, and as far as one can tell, it asked for no input from critics.

Well the outcome of this review turned up in my mail recently. Click the picture to read the whole letter from the Vice-Chancellor.

There is no doubt that the outcome, so far, is rather disappointing.  Here are some quotations from this letter, with my comments interleaved.

“The Audit was Chaired by Professor Alan Jago and carried out its review using a comprehensive evidence base”

Alan Jago is a pro- vice chancellor, and formerly from Westminster’s School of Architecture and the Built Environment, so no specialist knowledge there.

“The panel made a number of recommendations to me as a result of their Audit.  Many of these recommendations concern the University’s processes for review and validation of courses and these will be passed to the Pro Vice Chancellor responsible for Quality to consider.”

Uhuh, sounds like box-ticking again When will universities learn that validation procedures are, on the whole, not worth the paper they are written on.

“The overarching aim of these actions then is to strengthen and make more explicit the ‘scientific’ nature of the Integrated Health undergraduate degrees.

In order to do this we will:

Strengthen learning outcomes particularly in discipline and clinical modules to reflect the science outcomes embedded in the courses.

Revise course specific regulations to explicitly identify that the core health sciences modules have to be passed to complete a degree of the BSc Scheme.

Strengthen the final year project offer to provide more scientific projects through working with Biosciences staff.

Strengthen the scientific/academic qualifications of staff through development
of existing staff and appointments where they become available.”

This seems to me to be whistling in the wind. Remember, we are talking about “bachelor of science” degrees in things like homeopathy and naturotherapy.  These are things that are not science at all. In fact they are antiscience to their core.

If you were successful in raising the increasing the scientific level of the staff, many of the subjects they are meant to be teaching would vanish in a puff of smoke.

Certainly the responses of the Westminster staff to earlier enquiries (here,  and here) showed little sign of scientific thinking.

And I wonder what Westminster’s admirable biomedical scientists think about taking on homeopathy students for projects?

“I am certain that this work will place Complementary therapies courses in an extremely strong position to meet the external challenges of the future.

I’m sorry to say, Professor Petts, that the scientific community is not likely to share your certainty.

Remember, Peter Fisher is on record as saying that there is not enough science in homeopathy to justifiy offering a BSc degree in it (watch the movie).  He is the Queen’s Homeopathic Physician, and Clinical Director of the Royal London Homeopathic Hospital   But Westminster still seems to know better.

It seems, so far, that Westminster has missed a chance to change for the better.

### Follow-up

Times Higher Education published a pretty pathetic report on the Westminster audit. They did ask me for comments but then failed to publish most of them. I suppose a magazine like that is so dependent on advertising that they can’t afford to upset the authorities. Nevertheless, do they really have to be quite so bland?

I hear that the internal audit has made everyone at the University of Woominster Westminster more nervous and that staff and students have been advised not to share teaching material with people outside the university. Having seen some of them, I’m not surprised they are ashamed of them.

Congratulations to the vice-chancellor of the University of Salford, Michael Harloe.

Times Higher Education announced on 15th January 2009 Salford to shut complementary medicine BSc.

“The University of Salford is to stop offering undergraduate degrees in acupuncture and complementary medicine because they are no longer considered “a sound academic fit”.”

This is the first time that a University has decided to stop teaching quackery altogether.  The university’s press officer told me (22 January 2009)

 “all the University’s programmes associated with complementary medicine within the School of Community, Health Sciences & Social Care will be run out. This includes the Homeopathy in Practice programme. “
 Salford, before it became a university, was home to the great L.S. Lowry Salford’s Peel building, where L.S.Lowry worked

“Managers concluded last year that the BSc traditional Chinese medicine and other degrees with a complementary medicine element “cannot really be held to be a good fit with the strategic direction of the school, and resource and energy would be better directed elsewhere”.

There are more than 70 students registered on the Chinese medicine degree course.

The university will continue to offer these subjects at postgraduate level, as short courses and as part of continuing professional development programmes.  Traditional Chinese medicine work will also be linked to the university’s allied
health professions courses.”

Another report appeared in the Manchester Evening News: “Needle over acupuncture course”. “A UNIVERSITY has scrapped a course in acupuncture and aromatherapy branded anti-science’ by critics.

Salford University said the three-year degree in traditional Chinese medicine didn’t fit with the strategic direction’ bosses want to adopt.

The move is part of wider cuts which will see 150 teaching and support staff jobs axed.”

One of their students raised the question that the university must dread.

“First-year student Gary Leese, who is organising a petition, said: “Why did the university launch the course if they didn’t think it was good enough?”

The comments left by the readers of the Manchester Evening News were mostly very sensible. The first to come in, from someone with the beautifully Lancastrian name, Gladys Rowbotham, said “Some common sense at last!”.

A brief report appeared also in the Manchester Confidential

### Why now?

This is rather an interesting development.  On 19th April 2007, I sent a Freedom of Information request to Salford to ask for course validation documents for their courses in Homeopathy and in Traditional Chinese Medicine.  I also asked for course materials for specified courses.  This request was even less successful than usual.  Not only were the course materials refused (as they always are), but, unusually, the validation documents were refused too.  The excuse for this was more pathetic than usual too.  They claimed it would cost more than £450 to email a few documents and powerpoints, and claimed exemption under Section 21 of the Freedom of Information Act, “Information Reasonably Accessible to the Applicant by Other Means”, rather than the more usual excuse (Section 43, “Commercial interests”).
It was never explained what “other means” were meant to be available. Perhaps they thought I should pay £3000 in fees and enrol for the course?

On 6th April 2007, Times Higher Education (THE) ran an opinion piece “Credible endeavour or pseudoscience?“.  In this, I wrote, as follows.

“Clearly the buck stops with university vice-chancellors who award the degrees. Two weeks ago, after the publication of my opinion article and a special report on university homoeopathy courses in the journal Nature , the BBC tried to get one of the vice-chancellors to defend themselves. They did not succeed. Letters to vice-chancellors on this go unanswered. Requests to see course materials have repeatedly been refused. The QAA is exempt from the Freedom of Information Act. Teaching materials and the names of examiners are kept secret. This I find incomprehensible and indefensible.”

After this appeared, I was sent by the University of Salford a copy of Michael Harloe’s defence of their position at that time, as sent to THE. It relied heavily on validation by the Quality Assurance Agency.  But the QAA is merely a box-ticking organisation that would give top marks to a course in astrology, given a sufficient mound of paperwork, as I pointed out in Nature, “Their own rules prevent them from doing anything useful”.

The statement also said that the courses teach critical thinking about alternative medicine. But it has been pointed out over and over again that what alternative medicine advocates lack, above anything else, is any faculty of critical self-appraisal.

One has to have some sympathy with a vice chancellor who is put on the spot and forced to defend courses in which he probably does not really believe himself. Perhaps it is not surprising that letters so often go unanswered. What can they say?  There really is no answer that doesn’t leave the hapless VC with egg on his face.

If there is one lesson from this, it is not to be discouraged if you get no answer from a vice-chancellor. It has probably been read and may well get acted on eventually.   Shutting down a course is no easy matter.  It takes time.

I said the buck stops with the vice chancellor. Professor Harloe has grasped the nettle and done the right thing.  Let’s hope a few more now follow his excellent lead..

### What does this mean for the Pittilo report?

The gamma-minus Pittilo report (see also. The Times) recommended more degrees in alternative medicine, but there seems to be something of a trend developing in exactly the opposite direction.

The University of Central Lancashire has closed the first year entry to its “BSc”  in Homeopathy, and announced a review of all its activities in the area of alternative medicine. Now we have Salford.  There are stirrings among the good scientists even at the University of Westminster which has a new Dean and VC.

This rather absurd situation has arisen because of the adamant refusal of the government, and of a dozen or more quangos, to grasp the nettle of whether or not the alternative treatments work. Time and time again, the one important question that you want to know about any sort of treatment, namely, is it effective, has been pushed under the carpet.

The sort of absurd political correctness that leads to the fraudulent conjurers known as ‘psychic surgeons’ being referred to as a “profession” by the Department of Health has obscured reality. Even the MHRA was persuaded to allow misleading labelling of homeopathic and herbal “remedies”. thus betraying its job.  In its own words “The MHRA is the government agency that is responsible for ensuring that medicines and medical devices work, . . .”.

There is a lesson here.  You can’t go on avoiding reality for ever.  One consolation is that, in the end, it is the universities who are leading the way, albeit slowly.

All we need now is for the Department of Health, the MHRA and the endless box-ticking quangos to wake up too.