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Skills for Care – DC's Improbable Science

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Since writing about anti-scientific degrees in Nature (March 2007), much has been revealed about the nonsense that is taught on these degrees. New Year’s day seems like a good time to assess how far we’ve got, five years on.

At the beginning of 2007 UCAS (the universities central admission service) offered 45 different BSc degrees in quackery, at 16 universities.

Now there are only 24 such degrees.

If you exclude chiropractic and osteopathy, which all run at private colleges, with some sort of "validation" from a university, there are now only 18 BSc/MSc courses being offered in eight universities.

Degrees in homeopathy, naturopathy and "nutritional therapy", reflexology and aromatherapy have vanished altogether from UCAS.

In the race to provide BScs in anti-science, Middlesex University has now overhauled the long-standing leader, Westminster, by a short head.

driscoll
Michael Driscoll, vice-chancellor of Middlesex

Petts
Geoffrey Petts, vice-chancellor of Westminster

Let’s see what’s gone.

The University of Central Lancashire (UCLAN) was the first to see sense. In August 2008 they announced closure of their “BSc” degree in homeopathy. On September 2008 they announced an internal review of their courses in homeopathy. herbalism and acupuncture. The report of this review closed down all of them in July 2009. I first asked for their teaching materials in July 2006. I finally got them in December 2010, after winning an appeal to the Information Commissioner, and then winning an appeal against that decision at an Information tribunal . By the time I got them, the course had been closed for over two years. That is just as well, because it turned out that UCLAN’s students were being taught dangerous nonsense. No wonder they tried so hard to conceal it.

Salford University was the next to go. They shut down their courses in complementary medicine, homeopathy and acupuncture. In January 2009 they announced " they are no longer considered “a sound academic fit” ". Shortly afterwards. a letter appeared in The Times from three heavyweights (plus me) congratulating the vice-chancellor on his decision.

University of Westminster

For many years, Westminster was the biggest supplier of BSc degrees in quackery. At the beginning of 2007 they offered 14 different BSc degrees in homeopathy, naturopathy, nutritional therapy, "complementary therapies", (western) herbal medicine and traditional Chinese medicine with acupuncture. Some of their courses were so bizarre that some of the students and even staff sent me slides which taught things like "amethysts emit high Yin energy". Like UCLAN, Westminster also held an internal review. Unlike UCLAN it came to the absurd conclusion that all would be well if they injected more science into the courses. The incompetence of the review meant that those who wrote it hadn’t noticed that if you try to put science into homeopathy or naturopathy, the whole subject vanishes in a puff of smoke. Nevertheless Westminster closed down entry to BSc homeopathy in March 2009 (though the subject remained as part of other courses).

Three years after the Nature article, all five BSc homeopathy degrees had shut their doors.

During 2011, Westminster shut down Naturopathy, Nutritional therapy, Therapeutic bodywork and Complementary Medicine. See, for example,
More dangerous nonsense from the University of Westminster: when will Professor Geoffrey Petts do something about it?

Professor Geoffrey Petts of the University of Westminster says they “are not teaching pseudo-science”. The facts show this is not true

University of Westminster shuts down naturopathy, nutritional therapy, but keeps Acupuncture and Herbal Medicine

Now Westminster has only four courses in two subjects. They still teach some dangerous and untrue things, but I suspect the writing is on the wall for these too.

I have seen a document, dated 11 April 2011, which states

“The following courses have been identified as ‘at risk’ (School definition) and will be discussed at the APRG and University Review Group2, due to poor recruitment and high cost of delivery:
 Integrated Health Scheme: BSc Complementary Medicine, Naturopathy; BSc Chinese Medicine; BSc Nutritional Therapy; BSc Herbal Medicine”

All but Chinese medicine and Herbal medicine have already gone. Almost there.

University of Wales

Since my first post in 2008 about the validation scam operated by the University of Wales, and some good investigations by BBC Wales TV, the outcome was the most spectacular so far. The entire institution collapsed. They no longer "validate" external degrees at dodgy business colleges, loony religious colleges or magic medicine colleges.

Another worthless validation: the University of Wales and nutritional therapy (October 2008) This is a ‘degree’ in nutrtional therapy. It is even more hilarious than usual, but it passed the validation anyway.

Scandal of the University of Wales and the Quality Assurance Agency (November 2010). This post followed the BBC Wales TV programme. At last the QAA began to notice, yet further confirmation of its utter ineptitude.

The University of Wales disgraced (but its vice chancellor is promoted) (October, 2011) The eventual collapse of the university was well-deserved. But it is very weird that the people who were responsible for it have still got their jobs. In fact the vice-chancellor, Marc Clement, was promoted despite his mendacious claim to be unaware of what was going on.

It remains to be seen how many of the many quack courses that were validated by the University of Wales will be taken on by other universities. The McTimoney College of Chiropractic is owned by BPP University (so much for their quality control, as explained in Private Eye). but still claims to be validated by Wales until 2017.

Some of the more minor players

Edinburgh Napier University. After an FOI request (rejected), Napier closed their herbal medicine degree in 2010.

Hot and cold herbal nonsense from Napier University Edinburgh: another course shuts. (June 2010)

As expected, the Scottish Information Commissioner agreed with that for England and Wales and ordered material to be sent. Edinburgh Napier University teaches reflexology, aromatherapy and therapeutic touch. Scottish Information Commissioner says you should know. Some of the horrors so discovered appeared in Yet more dangerous nonsense inflicted on students by Edinburgh Napier University. The embarrassment seems to have worked. Their remaining degrees in aromatherapy and reflexology have now vanished from UCAS too. All that remains is a couple of part time “Certificates of Credit” for aromatherapy and reflexology

Anglia Ruskin Univerity Not only have BSc degrees gone in aromatherapy and reflexology, but their midwifery degree now states "We are unable to accept qualifications in aromatherapy, massage and reflexology."

University of Derby Reflexology and aromatherapy have gone, though doubtless Spa management therapies have much nonsense left

University of Greenwich. BSc in Complementary Therapies (Nutritional Health) and BSc in Complementary Therapies (Nutritional Health) have been shut. The BSc Acupuncture is listed on their web site but it is under review, and is not listed in UCAS for 2012. (Acupuncture is run at International College of Oriental medicine, validated by Greenwich.). Only osteopathy (MOst) is still running, and that is a validation of an external course run at The European School of Osteopathy, in Maidstone

Thames Valley University was renamed the University of West London in 2010. The nonsense that was run there (e.g. Nutritional Fairy Tales from Thames Valley University) seems to have vanished. Their previous alt med guru, Nicola Robinson, appears now to be at London South Bank University (ranked 116 out of the 116 UK universities)

What’s left?

Chiropractic Surprisingly, given the total discreditation of chiropractic in the wake of the Simon Singh affair, and the internecine warfare that followed it, none of the chiropractic courses have shut yet. Some are clearly in trouble, so watch this space.

Osteopathy has also had no course closures since 2007. Like chiropractic it also suffers from internecine warfare. The General Osteopathic Council refuses to disown the utter nonsense of "craniosacral" osteopathy. But the more sensible practitioners do so and are roughly as effective as physiotherapists (though there are real doubts about how effective that is).

Excluding chiropractic and osteopathy, this is all that’s left. It now consists almost entirely of Chinese medicine and a bit of herbal.

Glyndwr university (Known as North East Wales Institute until 2008)   Ranked 104 out of 116 UK universities

BSc Acupuncture (B341) BSc
BSc Complementary Therapies for Healthcare (B343)

Cardiff Metropolitan University (UWIC) (Known as University of Wales Institute Cardiff (UWIC) until Nov 2011.)   The vice-chancellor of Cardiff Metropolitan, Antony Chapman, is in the QAA’s board of directors, so perhaps it isn’t surprising that the QAA has done nothing.

BSc Complementary Therapies (3 years) (B390)
BSc Complementary Therapies (4 yrs inc Foundation) (B300)

University of Lincoln

Acupuncture (B343) 3FT Hon BSc
Herbal Medicine (B342) 3FT Hon BSc

University of East London   Ranked 113 out of 116 UK universities

Acupuncture (B343) 3FT Hon BSc

London South Bank University   Ranked 116 out of 116 UK universities

Acupuncture (B343) 4FT Deg MCM

The Manchester Metropolitan University   Ranked 93 out of 116 UK universities

Acupuncture (B343) 3FT Hon BSc

Middlesex University

Acupuncture (B348) 3FT Hon BSc
Ayurvedic Medicine (A900) 4FT Oth MCM
Herbal Medicine (B347) 3FT Hon BSc
Traditional Chinese Medicine (BT31) 4FT Hon BSc

University of Westminster

Chinese Medicine: Acupuncture (B343) 3FT Hon BSc
Chinese Medicine: Acupuncture with Foundation (B341) 4FT/5FT Hon BSc/MSci
Herbal Medicine (B342) 3FT Hon BSc
Herbal Medicine with Foundation Year (B340) 4FT/5FT Hon BSc/MSci

It seems that acupuncture hangs on in universities that are right at the bottom of the rankings.

Manchester Metropolitan gets the booby prize for actually starting a new course, just as all around are closing theirs. Dr Peter Banister, who was on the committee that approved the course (but now retired), has told me ” I am sceptical in the current economic climate whether it will prove to be successful”. Let’s hope he’s right.

But well done Westminster. Your position as the leader in antiscientific degrees has now been claimed by Middlesex University. Their "degrees" in Ayurveda mark out Middlesex University as the new King of Woo.

Over to you, Professor Driscoll. As vice-chancellor of Middlesex University, the buck stops with you.

Both still teach Chinese and herbal medicine, which are potentially dangerous. There is not a single product from either that has marketing authorisation from the MHRA, though the MHRA has betrayed its trust by allowing misleading labelling of herbal medicines without requiring any evidence whatsoever that they work, see, for example

Why degrees in Chinese medicine are a danger to patients
More quackedemia. Dangerous Chinese medicine taught at Middlesex University
Why does the MHRA refuse to label herbal products honestly? Kent Woods and Richard Woodfield tell me

Sub-degree courses

In contrast to the large reduction in the number of BSc and MSc degrees, there has actually been an increase in two year foundation degrees and HND courses in complementary medicine, at places right near the bottom of the academic heap. The subject is sinking to the bottom. With luck it will vanish entirely from universities before too long.

Research-intensive Universities

Although all of the degrees in magic medicine are from post-1992 universities, the subject has crept into more prestigious universities. Of these, the University of Southampton is perhaps the worst, because of the presence of George Lewith, and his defender, Stephen Holgate. Others have staunch defenders of quackery, including the University of Warwick, University of Edinburgh and St Batholomew’s.

Why have all these courses closed?

One reason is certainly the embarrassment caused by exposure of what’s taught on the courses. Professors Petts (Westminster) and Driscoll (Middlesex) must be aware that googling their names produces references to this and other skeptical blogs on the front page. Thanks to some plain brown emails, and, after a three year battle, the Freedom of Information Act, it has been possible to show here the nonsense that has been foisted on students by some universities. Not only is this a burden on the taxpayer, but, more importantly, some of it is a danger to patients.

When a course closes, it is often said that it is because of falling student numbers (though UCLAN and Salford did not use that excuse). Insofar as that is true, the credit must go to the whole of the skeptical movement that has grown so remarkably in the last few years. Ben Goldacre’s "ragged band of bloggers" have produced a real change in universities and in society as a whole.

The people who should have done the job have either been passive or an active hindrance. The list is long. Vice-chancellors and Universities UK (UUK), the Quality Assurance Agency (QAA), the Hiigher Education Funding Council England (HEFCE), Skills for Health, the Medicines and Health Regulatory Authority ( MHRA) , the Health Professions Council (HPC), the Department of Health, the Prince of Wales and his reincarnated propaganda organisation, the "College of Medicine", the King’s Fund, the Universities and Colleges Union (UCU), OfQual, Edexcel, National Occupational Standards and Qualifications and the Curriculum Authority (QCA).

Whatever happened to that "bonfire of the quangos"?

Follow-up

2 January 2012 The McTimoney College of Chiropractic (owned by BPP University) claims that its “validation” by the University of Wales will continue until 2017. This contradicts the statement from UoW. Watch this space.

3 January 2012. Thanks to Neil O’Connell for drawing my attention to a paper in Pain. The paper is particularly interesting because it comes from the Southampton group which has previously been sympathetic to acupuncture. Its authors include George Lewith. It shows, yet again that there is no detectable difference between real and sham acupuncture treatment. It also shows that the empathy of the practitioner has little effect: in fact the stern authoritarian practitioner may have been more effective.

Patients receiving acupuncture demonstrated clinically important improvements from baseline (i.e., a 29.5% reduction in pain), but despite this, acupuncture has no specific efficacy over placebo for this group of patients. The clinical effect of acupuncture treatment and associated controls is not related to the use of an acupuncture needle, nor mediated by empathy, but is practitioner related and may be linked to the perceived authority of the practitioner.”

Sadly. the trial didn’t include a no-treatment group, so it is impossible to say how much of the improvement is regression to the mean and how much is a placebo effect. The authors admit that it could be mostly the former.

Surely now the misplaced confidence in acupuncture shown by some medical and university people must be in tatters.

In yet another sign that even acupuncture advovates are beginning to notice that it doesn’t work, a recent article Paradoxes in Acupuncture Research: Strategies for Moving Forward, shows some fascinating squirming.

3 January 2012.  The Daily Telegraph has carried a piece about closure of university courses, written by Michael Hanlon. On 31 January they carried a much longer piece.

3 January 2012.  It is a great pity that some physiotherapists seem to have fallen hook, line and sinker for the myths of acupuncture. Physiotherapists are, by and large, the respectable face of manipulative therapy. Their evidence base is certainly not all one would wish, but at least they are free of the outrageous mumbo humbo of chiropractors. Well, most of them are, but not the Acupuncture Association of Chartered Physiotherapists (AACP), or, still worse, The Association of Chartered Physiotherapists in Energy Medicine, a group that is truly away with the fairies. These organisations are bringing a very respectable job into disrepute. And the Health Professions Council, which is meant to be their regulator, has, like most regulators, done nothing whatsoever to stop it.

5 January 2012. Times Higher Education gives a history of the demise of the University of Wales, Boom or Bust. It’s a useful timeline, but like so many journalists, it’s unwilling to admit that bloggers were on to the problem long before the BBC, never mind the QAA.

There was also a leader on the same topic, Perils of the export business. It again fails to take the QAA to task for its failures.

Interviews for Deutsche Welle and Middle East Broadcasting Center TV.

17 January 2012 Another question answered. I just learned that the ludicrous course in Nutritional Therapy, previously validated by the University of Wales (and a contributor to its downfall), is now being validated by, yes, you guessed, Middlesex University. Professor Driscoll seems determined to lead his univerity to the bottom of the academic heap. His new partnership with the Northern college of Acupuncture is just one of a long list of validations that almost rivals that of the late University of Wales. The course has, of course, an enthusiastic testimonial, from a student. It starts

I work full time as a team leader for a pension company but I am also a kinesiologist and work in my spare time doing kinesiology, reiki and Indian head massage.

Evidently she’s a believer in the barmiest and totally disproved forms of magic medicine. And Middlesex University will give her a Master of Science degree. I have to say I find it worrying that she’s a team leader for a pension company. Does she also believe in the value of worthless derivatives. I wonder?

18 January 2012. the story has gone international, with an interview that I did for Deutsche Welle, UK universities drop alternative medicine degree programs. I’m quoted as saying “They’re dishonest, they teach things that aren’t true, and things that are dangerous to patients in some cases”. That seems fair enough.

There is also an interesting item from July 2010 about pressure to drop payment for homeopathy by German health insurance

31 January 2012

The Daily Telegraph carried a prominent 1200 word account (the title wasn’t mine). The published version was edited slightly.

telegraph 31 Jan

Jump to follow-up

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

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

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

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

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

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

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

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

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

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

The laws

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

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

Has The UK Quietly Outlawed “Alternative” Medicine?

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

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

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

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

  • General Prohibition on Unfair Commercial
    Practices (Regulation 3)
  • Prohibition on Misleading Actions (Regulations 5)
  • Prohibition on Misleading Omissions (Regulation 6)
  • Prohibition on Aggressive Commercial Practices (Regulation 7)
  • Prohibition on 31 Specific Commercial Practices that are in all Circumstances Unfair (Schedule 1).  One of the 31 commercial practices which are in all circumstances considered unfair is “falsely claiming that a product is able to cure illnesses, dysfunction or malformations”. The definition of “product” in the Regulations includes services, so it does appear that all forms medical products and treatments will be covered.

Just look at that!

One of the 31 commercial practices which are in all circumstances considered unfair is “falsely claiming that a product is able to cure illnesses, dysfunction or malformations”


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

Misleading actions

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

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

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

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

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

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

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

Who has to prove what?

That is still not entirely clear.  McLachlan says

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

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

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

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

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

Due diligence defence

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

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

(i) a mistake;

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

(iii) the act or default of another person;

(iv) an accident; or

(v) another cause beyond his control; and

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

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

Douglas McLachlan has clarified, below, this difficult question

False claims for health benefits of foods

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

Article 6

Scientific substantiation for claims

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Enforcement of the law

Article 19 of the Unfair Trading regulations says

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

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

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

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

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

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

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

Who can be prosecuted?

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

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

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

Follow-up

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

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

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

A clarification form Douglas McLachlan

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

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

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

The “average consumer”.

The regulations state

(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

Jump to follow-up

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

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

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


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

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

Unit abstract

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

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

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

Then later

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

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

The really revealing bit comes when you get to the

“Indicative reading for learners
There are many resources available to support this unit.

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

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

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

The Teacher

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

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

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

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

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

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

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

shortly followed by

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

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

What does Edexcel say?

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

From: (Bola Arabome) 12/11/2008 04.31 PM

Dear Professor Colquhoun

Thank you for email communication concerning the complementary therapies unit which is available in our BTEC National in Health and BTEC National in Health and Social Care qualifications. I have replied on behalf of Stephen Nugus, our science subject advisor, because your questions do not refer to a science qualification. I would like to answer your questions as directly as possible and then provide some background information relating to the qualifications.

The units and whole qualifications for all awarding bodies are accredited by the regulator, the Qualifications and Curriculum Authority. The resource reading list is also produced by us to help teachers and learners. The qualification as a whole is related to the National Occupational Standards for the vocational sectors of Health and Health and social care with consultation taken from the relevant sector skills councils . As you will be aware many of these complementary therapies are available in care centres and health centres under the NHS and in the private sector. The aim of BTEC qualifications is to prepare people for work in these particular sectors. Clearly a critical awareness is encouraged with reference to health and safety and regulation. There are other units, in some cases compulsory, within the qualification with a scientific approach.

‘  ‘  ‘  ‘  ‘

Stephen Harris

Head of Customer Support



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

19 November

I find it quite fascinating that Edexcel regards the treatment of sick patients as not being part of science (“do not refer to a science qualification”).

Does that mean Edexcel regard the “Health” part of “Health and Social Care” as being nothing to do with science, and that it therefore doesn’t matter if Health Care is unscientific, or even actively anti-scientific?

I am sorry if my answer lacked clarity. My comment, that I had taken your enquiry on behalf of our Science Advisor because  this was not a science qualification, was intended to explain why I was replying. It was not intended as a comment on the relationship between Health and Social  Care and science. At Edexcel we use bureaucratic categories where we align our management of qualifications with officially recognised occupational sectors. Often we rely on sector bodies such as Sector Skills Councils to endorse or even approve the qualifications we offer. Those involved in production of our Science qualifications and our
Health and Social care qualifications are, as far as I can ascertain, neither anti-scientific nor non-scientific in their approach

(4) You say “The qualification as a whole is related to the National Occupational Standards for the vocational sectors of Health and Health and social care with consultation taken from the relevant sector skills councils”. Are you aware that the Skills for Health specifications for Alternative medicine were written essentially by the Prince of Wales Foundation?
When I asked them if they would be writing a competence in talking to trees, they took the question totally seriously!! (You can see the transcript of the conversation at http://dcscience.net/?p=215 ).

The qualification was approved by both ‘Skills for Health’ and ‘Skills for Care and Development’ prior to being accredited by QCA. It uses the NOS in Health and Social Care as the basis for many of the mandatory units. The ‘Complementary Therapies’ NOS were not used. This was not a requirement of a ‘Health and Social Care’ qualification.

“Are the NOS in Health and Social Care that you mention the ones listed here? http://www.ukstandards.org/Find_Occupational_Standards.aspx?NosFindID=1&ClassificationItemId=174 If so, I can see nothing there about ‘complementary therapies’. if I have missed it, I’d be very grateful if you could let me know where it is. If it is not there, I remain very puzzled about the provenance of Unit 23, since you say it is not based on Skills for Health.”



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

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

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

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

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

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

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

What does the QCA say?

The strapline of the QCA is

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

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

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

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

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

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

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

Here are some of the questions that I asked.

I wrote to Edexcel’s subject advisors about unit 23 and I was told “your questions do not refer to a science qualification”. This seems to mean that if it comes under the name “Health Care” then the care of sick patients is treated as though it were nothing to do with science, That seems to me to be both wrong and dangerous, and I should like to hear your view about that question.

Clearly the fundamental problem here is that the BTEC is intended as a vocational training for careers in alternative medicine, As a body concerned with education, surely you cannot ignore the view of 99% of scientists and doctors that almost all alternative medicine is fraud. That doesn’t mean that you can’t make a living from it, but it surely does create a dilemma for an educational organisation. What is your view of that dilemma?



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

Ofqual does not take a view on the detailed content of vocational qualifications as that responsibility sits with the relevant Sector Skills Council which represents employers and others involved in the sector. Ofqual accredits the specifications, submitted by sector-skilled professionals, after ensuring they meet National Occupational Standards.  Ofqual relies on the professional judgement of these sector-skilled professionals to include relevant subjects and develop and enhance the occupational standards in their profession.

The accreditation of this BTEC qualification was supported by both Skills for Health, and Skills for Care and Development, organisations which represent the emerging Sector Qualifications Strategies and comply with the relevant National Occupational Standards

Isabel Nisbet

Acting Chief Executive



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

A nightmare maze of quangos

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

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

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

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

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

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

What next?

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

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

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

Follow-up

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

Edexcel. I sent them this request.

Freedom of Information Act

Hello

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

David Colquhoun

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

Dear Mr Colquhoun,

Thank you of your e-mail of today’s date. I note your request for information pursuant to The Freedom of Information Act. As you may know this Act only applies to public bodies and not to the private sector. Edexcel Limited is privately owned and therefore not subject to this Act. Edexcel is therefore not obliged to provide information to you and is not prepared to give you the information you seek.

Please do not hesitate to contact me again if you have any further queries.

Kate Gregory
Director of Legal Services
Pearson Assessments & Testing
One90 High Holborn, London, WC1V 7BH
T: +44 (0)20 7190 5157 / F: +44 (0)207 190 5478
Email: kate.gregory@pearson. com



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

International Therapy Examination Council (ITEC)

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

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

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

“Who is this course for?

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

“What will I be doing on the course?

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

.VTCT stands for the Vocational Training Charitable Trust.

It is yet another organisation that runs vocational exams, and it is responsible for this particular horror

The crystals are here. I quote.

Objectives

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

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

Cornwall College has many courses run by ITEC.

The College says

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

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

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

The ITEC web site says

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

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

The pancreas reflex:

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

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

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

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

A Heart
B Liver
C Spleen
D Pancreas


Or perhaps this?

Which incantation makes hot stones work best?

A Incarcerous
B Avada Kedavra,
C Dissendium
D Expelliarmus.

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

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

Ofsted

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

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

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

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

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

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