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The long-awaited government decision concerning statutory regulation of herbalists, traditional Chinese medicine (TCM) and acupuncture came out today.

Get the Department of Health (DH) report [pdf]

It is not good news. They have opted for statutory regulation by the Health Professions Council (HPC). This is much what was recommended by the disgraceful Pittilo report, about which I wrote a commentary in the Times (or free version here), and A very bad report: gamma minus for the vice-chancellor.

The DH report is merely an analysis of responses to the consultation, but the MHRA says

"The Health Professions Council (HPC) has now been asked to establish a statutory register for practitioners supplying unlicensed herbal medicines. The proposal is, following creation of this register, to make use of a derogation in European medicines legislation (Article 5 (1) of Directive 2001/83/EC) that allows national arrangements to permit those designated as “authorised healthcare professionals” to commission unlicensed medicines to meet the special needs of their patients."

The MHRA points out that this started 11 years ago with the publication of the  House of Lords report (2000). Both that report, and the government’s response to it, set the following priorities. Both state clearly

“… we recommend that three important questions should be addressed in the following order . .

• (1) does the treatment offer therapeutic benefits greater than placebo?
• (2) is the treatment safe?
• (3) how does it compare, in medical outcome and cost-effectiveness, with other forms of treatment?

The report of DH and the MHRA’s response have ignored totally two of these three requirements. There is no consideration whatsoever of whether treatments work better than placebo (point one) and there is no consideration whatsoever of cost-effectiveness (point 3). These two important recommendations in the Houss of Lords report have simply been brushed under the carpet.

Needless to say, herbalists are head over heels with joy at this sign of official endorsement (here is one reaction)

Here are my first reactions. The post will be updated soon.

The DH report is, in a sense, democratic. They have simply counted the responses, for and against each proposal. They seem to be quite unaware that most of the responses come from High Street herbailsts whose main aim is to gain respectability. The response of the Academy of Royal Medical Colleges counts as one vote, just the same as the owner of a Chinese medicine shop. This is not how health policy should be determined. Some intervention of the brain is needed, but that isn’t apparent in the report.

At present the HPC regulates Arts therapists, biomedical scientists, chiropodists/podiatrists, clinical scientists, dietitians, occupational therapists, operating department practitioners, orthoptists, paramedics, physiotherapists, prosthetists/orthotists, radiographers and speech & language therapists. I shudder to think what all these good people will think about being lumped together with people who practice evidence-free medicine (or, worse, forms of medicine where there is good evidence that they don’t work).

The vast majority of herbalists, traditional Chinese medicine (TCM) and acupuncture has no good evidence that it works, In the case of soem herbal medicines and acupuncture, there is good evidence that they don’t work. Yet the HPC has, as one of its criteria, that aspiring to be regulated by them requires

"practise based on evidence of efficacy"

The Department of Health seems to have quietly forgotten about this criterion. It cannot possibly be met. The HPC has already expressed its willingness to go along with this two-faced approach (see Health Professions Council ignores its own rules: the result is nonsense )

Another mistake made by the Department of Health regards the value of "training". The report (page 11) says

Would statutory regulation lessen the risk of harm? (Q2)
Again, the vast majority of respondents thought it would. Reasons given were that statutory regulation would ensure that herbal practitioners and acupuncturists are carefully and thoroughly trained. That training is subject to accreditation, evaluation and periodic review by independent educational and training professionals, and disciplinary oversight by a regulating body. Incompetent or unscrupulous practitioners could be struck off the register and prevented from practising.

Although it is pointed out to them in several responses, the Department of Health seems quite incapable of understanding a simple and obvious truth. Spending three years training people to learn things that are not true, safeguards nobody. On the contrary, it endangers the public. Training in nonsense is obviously a nonsense.

At the end of the report is a list of organisations who responded, As expected, they are predominantly trade bodies that have a vested interest in allowing thinks to be sold freely regardless of whether they work or not. The first four are Alliance of Herbal Medicine Practitioners. European herbal and Traditional Medicine Practitioners Association (ETMPA), Association Chinese Medicine Practitioners (UK) (ACMP) and Acupuncture Society. And so on.

More coming soon.

### Follow-up

16 February 2011. Later the same day, we see one reason why Michael Mcintyre, chair of the European Herbal Practitioners Association, got what he wanted to promote his trade. They had evidently hired a PR Agency, Cogitamus, to push their case. Now they are crowing about their victory. And of course his profits were not harmed by the free publicity that was given to his cause by the BBC,

The pinheads in the Department of Health are more easily persuaded by a PR agency than by any number of people who know a lot more about it, and who have no profit motive.

17 February 2011.

The herbal problem was front page news in the London free paper, the Metro: Chinese medicine and herbal ban to see Britain defy EU laws

The Daily Telegraph covered the story: Herbal medicine to be regulated, says Andrew Lansley. The comments featured some pretty mad rants from herbalists, to which I tried to reply.

The Metro article elicited a fine bit of abuse from a Lynda Kane. I’m constantly amazed at the downright viciousness of cuddly holistic therapists when they get found out. I guess it is just another bad case of cognitive dissonance. I can’t resist a few quotations.

Sir,

“I have just come across your asinine comments quoted in the London Metro newspaper re the EU herbal medicine directive. For a supposed scientist your mis-informed, closed-minded, unsubstantiated bigotry leaves me speechless”

“As a scientist myself, I abide by the virtues of open-minded neutrality and accepting the hypothesis until proven otherwise by null-hypothesis based research.”

“How many of the innumerable studies on the efficacy of herbal medicine have you read? “

“Perhaps in your ‘day’ professors could say whatever they liked and be listened to. That day is long gone, as you must know from the various law-suits you have been party to.”

I love the idea that statistics allow you to accept any hypothesis whatsoever until someone shows it to be wrong.

This would be funny if it were not so sad (and rather painful). As always I replied politely and referred her to NCCAM’s Guide to Herbs, so she can check up on that plethora of evidence that she seems to think exists.

This is Lynda Kane of energyawareness.org. I can recommend her web site, if you want some truly jaw-dropping woo. She’ll sell you a “White Jade Energy Egg – may provide up to 5 times as much protection from wifi and from other peoples’ energies – costs £47.00”. Hmm, sounds good. How does it work? Easy.

“The human energy or “qi” field is shaped like an egg. It is being attacked by many forms of natural and man-made environmental stress 24 hours a day.”

I guess that’s OK according to Ms Kane’s interpretation of statistics which allows you to accept any hypothesis whatsoever until someone shows it to be wrong.

Anyone for Trading Standards or the ASA?

17 February 2011. The excellent Andy Lewis has posted on similar problems “How to Spot Bad Regulation of Alternative Medicine

.20 July 2013

Nothing visible happened after this announcement. Until the government’s resident medical loon, David Tredinnick MP forced a debate on the matter. His introduction to the debate was his usual make-believe. Sadly it made much of an exhibit at the Royal Society Summer Science exhibition -a bit of bait and swich by aromatherapists.

After ploughing your way through pages of nonsense, you get to the interesting bit. At 10.38 am, The Parliamentary Under-Secretary of State for Health, Dr Daniel Poulter, announced what was happening. It seems that there may, after all, have been some effect of all the sensible submissions which pointed out the impossibility of regulating nonsense. The question of regulation has, yet again, been postponed.

"To ensure that we take forward the matter effectively, we want to bring together experts and interested parties from all sides of the debate to form a working group that will gather evidence and consider all the viable options in more detail,"

One wonders who will be on this working group? If they don’t choose the right people, it could be as bad as the Pittilo report. It wasn’t reassuring to read

" we want to set up a working group and to work with my hon. Friend [Tredinnick], and herbalists and others, to ensure that the legislation is fit for purpose."

Research quangos lead to mediocrity is the headline title of a letter to The Times appeared on 6 December 2010. It is reproduced below for those who can’t (or won’t) pay Rupert Murdoch to see it.

The letter is about the current buzzword, "research impact", a term that trips off the lips of every administrator and politician daily. Since much research is funded by the taxpayer, it seems reasonable to ask if it gives value for money. The best answer can be found in St Paul’s cathedral.

The plaque for Christopher Wren bears the epitaph

LECTOR, SI MONUMENTUM REQUIRIS, CIRCUMSPICE.

Reader, if you seek his memorial – look around you.

BUT remember also that these wonderful products did not appear overnight. They evolved slowly over many decades or even centuries, and they evolved from work that, at the time, appeared to be mere idle curiosity. Electricity lies at the heart of everyday life. It took almost 200 years to get from Michael Faraday’s coils to your mobile phone. At the time, Faraday’s work seemed to politicians to be useless. Michael Faraday was made a fellow of the Royal Society in 1824.

. . . after Faraday was made a fellow of the Royal Society[,] the prime minister of the day asked what good this invention could be, and Faraday answered: “Why, Prime Minister, someday you can tax it.”

Whether this was really said is doubtful, but that hardly matters. It is the sort of remark made by politicians every day.

In May 2008, I read a review of ”The myths of Innovation” by Scott Berkun. The review seems to have vanished from the web, but I noted it in diary. These words should be framed on the wall of every politician and administrator. Here are some quotations.

“One myth that will disappoint most businesses is the idea that innovation can be managed. Actually, Berkun calls this one ‘Your boss knows more about innovation than you’. After all, he says, many people get their best ideas while they’re wandering in their bathrobes, filled coffee mug in hand, from the kitchen to their home PC on a day off rather than sitting in a cubicle in a suit during working hours. But professional managers can’t help it: their job is to control every variable as much as possible, and that includes innovation.”

“Creation is sloppy; discovery is messy; exploration is dangerous. What’s a manager to do?
The answer in general is to encourage curiosity and accept failure. Lots of failure.”

I commented at the time "What a pity that university managers are so far behind those of modern businesses. They seem to be totally incapable of understanding these simple truths. That is what happens when power is removed from people who know about research and put into the hands of lawyers, HR people, MBAs and failed researchers."

That is even more true two years later. The people who actually do research have been progressively disempowered. We are run by men in dark suits who mistake meetings for work. You have only to look at history to see that great discoveries arise from the curiosity of creative people, and that,. rarely, these ideas turn out to be of huge economic importance, many decades later.

The research impact plan, has been now renamed "Pathways to Impact". It means that scientists are being asked to explain the economic impact of their research before they have even got any results.

 All that shows is how science is being run by dimwits who simply don’t understand how science works. This amounts to nothing less than being compelled to lie if you want any research funding. And, worse stiil, the pressure to lie comes not primarily from government, but from that curious breed of ex-scientists, failed scientists and non-scientists who control the Research Councils. How much did RCUK pay for the silly logo?

We are being run by people who would have told Michael Faraday to stop messing about with wires and coils and to do something really useful, like inventing better leather washers for steam pumps.

Welcome to the third division. Brought to you be Research Counclls and politicians.

Here is the letter in The Times. It is worded slightly more diplomatically than my commentary. but will, no doubt, have just as little effect. What would the signatories know about science? Several off them don’t even wear black suits.

Now cheer yourself up by reading Captain Cook’s Grant Application.

### Follow-up

Scientists should sign the petition to help humanities too. See the Humanities and Social Sciences Matter web site.

Nobel view. 1. Andre Geim’s speech at Nobel banquet, 2010

"Human progress has always been driven by a sense of adventure and unconventional thinking. But amidst calls for “bread and circuses”, these virtues are often forgotten for the sake of cautiousness and political correctness that now rule the world. And we sink deeper and deeper from democracy into a state of mediocrity and even idiocracy. If you need an example, look no further than at research funding by the European Commission."

Nobel view. 2. Ahmed Zewail won the 1999 Nobel Prize in Chemistry. He serves on Barack Obama’s Council of Advisors on Science and Technology. He wrote in Nature

“Beware the urge to direct research too closely, says Nobel laureate Ahmed Zewail. History teaches us the value of free scientific inquisitiveness.”

“I have emphasized that without solid investment in science education and a fundamental science base, nations will not acquire the ground-breaking knowledge required to make discoveries and innovations that will shape their future.”

“Preserving knowledge is easy. Transferring knowledge is also easy. But making new knowledge is neither easy nor profitable in the short term. Fundamental research proves profitable in the long run, and, as importantly, it is a force that enriches the culture of any society with reason and basic truth.”

How many more people have to say this before the Research Councils take some notice?

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

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

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

McTimoney College of Chiropractic

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

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

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

In the documentary Palastanga said

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

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

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

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

Undaunted, Palastanga responded

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

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

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

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

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

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

Of the degrees, I said

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

Palastanga. responded

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

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

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

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

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

Fazley International College Kuala Lumpur

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

The presenter pointed out that

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

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

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

“Why don’t regulators prevent BSc degrees in anti-science? The Quality Assurance Agency for Higher Education (QAA) claims that “We safeguard and help to improve the academic standards and quality of higher education in the UK.” It costs taxpayers £11.5 million (US$22 million) annually. It is, of course, not unreasonable that governments should ask whether universities are doing a good job. But why has the QAA not noticed that some universities are awarding BSc degrees in subjects that are not, actually, science? The QAA report on the University of Westminster courses awards a perfect score for ‘curriculum design, content and organization,’ despite this content consisting largely of what I consider to be early-nineteenth-century myths, not science. It happens because the QAA judges courses only against the aims set by those who run the QAA, and if their aims are to propagate magic as science, that’s fine.” That was illustrated perfectly in the documentary when Dr Stephen Jackson of the QAA appeared to try to justify the fact that the QAA had, like the University of Wales, failed entirely to spot any of the obvious problems. He had a nice dark suit, tie and poppy, but couldn’t disguise the fact that the QAA had given high ratings to some very dubious courses. The QAA sent nine people to the other side of the globe, at a cost of £91,000. They could have done a lot better if they’d spent 10 minutes with Google at home. Universities UK (UUK) Needless to say, the Committee of Vice-Chancellors and Principals has said nothing at all. As usual, Laurie Taylor had it all worked out in Times Higher Education (4th November). Speaking to our reporter Keith Ponting (30), he commended UUK’s decision to say absolutely nothing whatsoever about the abolition of all public funding for the arts and humanities. He also praised UUK’s total silence on Lord Browne’s view that student courses should primarily be evaluated by their employment returns. When pressed by Ponting for his overall view of UUK’s failure to respond in any way at all to any aspect of the Browne Review, he described it as “welcome evidence, in a world of change, of UUK’s consistent commitment over the years to ineffectual passivity”. Meanwhile, a University of Wales video on YouTube Caveat emptor ### Follow-up A couple of days later, a search of Google news for the “University of Wales” shows plenty of fallout. The vice-chancellor claims that ““The Minister’s attack came as a complete and total surprise to me”. That can’t be true. It is over two years since I told him what was going on, and if he was unaware of it, that is dereliction of duty. It is not the TV programme that brought the University into disrepute, it was the vice-chancellor. Jump to follow-up The Prince of Wales’ Foundation for Integrated Health shut down amidst scandal in April 2010. In July, we heard that a new “College of Medicine” was to arise from its ashes. It seemed clear from the people involved that the name “College of Medicine” would be deceptive. Now the College of Medicine has materialised, and it is clear that one’s worst fears were well justified. At first sight, it looks entirely plausible and well-meaning. Below the logo one reads “There is a new force in medicine. A force that brings patients, doctors, nurses and other health professionals together, instead of separating them into tribes.” "That force is the new College of Medicine. Uniquely, it brings doctors and other health professionals together with patients and scientists.” It is apparent from the outset that the well-meaning words fall into the trap described so clearly by James May (see What ‘holistic’ really means). It fails to distinguish between curing and caring. As always, the clue lies not in the words, but in the people who are running it. ### Who is involved? After a bit of digging on the web site, you find the names of the people on the Science Council of the “College of Medicine”, The preamble says “Good medicine must be grounded in good science as well as compassion. The College’s Science Council brings a depth of knowledge from many senior figures.” But then come the names. With the odd exception the “science council” is like a roll-call of quacks, the dregs left over from the Prince’s Foundation. The link (attached to each name) gives the College’s bio, My links tell a rather different story. It seems that the "Scientific Council" of the College of Medicine could more properly be called an "Antiscientific Council". There are a few gaps in this table, to be filled in soon. One can guarantee that a great deal more will appear about the College on the web, very soon. The Governing Council of the College is equally replete with quacks (plus a few surprising names). It has on it, for example, a spiritual healer (Angie-Buxton King), a homeopath (Christine Glover), a herbalist (Michael McIntyre). Westminster University’s king of woo (David Peters), not to mention the infamous Karol Sikora. Buxton-King offers a remarkable service to heal people or animals at a distance. Meanwhile, it seemed worthwhile to provide a warning that the title of the College is very deceptive. It hides an agenda that could do much harm. It is, quite simply, the Prince of Wales by stealth. ### Follow-up 28 October 2010 Professor Sir Graeme Catto, who has, disgracefully, allowed his name to be used as president of this “College” has said to me “There are real problems in knowing how to care for folk with chronic conditions and the extent of the evidence base for medicine is pretty limited”. Yes of course that is quite true. There are many conditions for which medicine can still do little. There is a fascinating discussion to be had about how best to care for them. The answer to that is NOT to bring in spiritual healers and peddlers of sugar pills to deceive patients with their fairy stories. The “College of Medicine” will delay and pervert the sort of discussion that Catto says, rightly, is needed. 29 October 2010 I need a press card. I see that the BMJ also had a piece about the “College of Medicine” yesterday: Prince’s foundation metamorphoses into new College of Medicine, by Nigel Hawkes. He got the main point right there in the title. As was clear since July, the driving force was Michael Dixon, Devon GP and ex medical director of the Prince’s Foundation. Hawkes goes easy on the homeopaths and spiritual healers, but did spot something that I can’t find on their web site. The “Faculties” will include “in 2011, neuromusculoskeletal care. Two of the six strong faculty members for this specialty are from the British Chiropractic Association, which sued the author Simon Singh for libel for his disobliging remarks about the evidence base for their interventions.” The College certainly picks its moment to endorse chiropractic, a subject that is in chaos and disgrace after they lost the Singh affair. One bit of good news emerges from Hawkes’ piece, There is at least one high profile doubter in the medical establishment, Lord (John) Walton (his 2000 report on CAM was less than blunt, and has been widely misquoted by quacks) is reported as saying, at the opening ceremony “I’m here as a sceptic, and I’ve just told my former houseman that,” he said. The target of the remark was Donald Irvine, another former GMC president and a member of the new college’s advisory council.” 31 October 2010. I got an email that pointed out a remarkable service offered by a member of College’s Governing Council. Angie Buxton-King, a “spiritual healer” employed by UCLH seems to have another web site, The Beacon of Healing Light that is not mentioned in her biography on the College’s site. Perhaps it should have been because it makes some remarkable claims. The page about distant healing is the most bizarre. Absent Healing/Distant Healing "Absent healing is available when it is not possible to visit the patient or it is not possible for the patient to be brought to our healing room. This form of healing has proved to be very successful for humans and animals alike." "We keep a healing book within our healing room and every night spend time sending healing to all those who have asked for it. We have found that if a picture of the patient is sent to us the healing is more beneficial, we also require a weekly update to monitor any progress or change in the patients situation. Donations are welcome for this service." I wonder what the Advertising Standards people make of the claim that it is “very successful”? I wonder what the president of the College makes of it? I’ve asked him. ### Other blogs about the “College of Medicine” 30 October 2010. Margaret McCartney is always worth reading. As a GP she is at the forefront of medicine. She’s written about the College in The Crisis in Caring and dangerous inference. She’s also provided some information about a "professional member" of the College of Medicine, in ..and on Dr Sam Everington, at the Bromley by Bow Centre…. It is one of the more insulting things about alternative medicine addicts that they claim to be the guardians of caring (as opposed to curing), They are not, and people like McCartney and Michael Baum are excellent examples. 19 January 2011 Prince of Wales to become honorary president of the “College of Medicine?” Last night I heard a rumour that the Prince of Wales is, despite all the earlier denials, to become Honorary President of the “College”. If this is true, it completes the wholesale transformation of the late, unlamented, Prince’s Foundation for Integrated Medicine into this new “College”. Can anybody take it seriously now? Text messages to Graeme Catto and Michael Dixon, inviting them to deny the rumour, have met with silence. ### Herbal nonsense at the College 29 July 2011. I got an email from the College if Medicine [download it]. It contains a lot of fantasy about herbal medicines, sponsered by a company that manufactures them. It is dangeroous and corrupt. On Friday 25 August 2006, Michael Baum and I went to visit the rather palatial headquarters of the UCL Hospitals Trust (that is part of the NHS, not of UCL). We went to see David Fish, who was, at that time, in charge of specialist hospitals. That included world-leading hospitals like the National Hospital Queen Square, and Great Ormond Street children’s hospital. It also includes that great national embarrassment, the Royal London Homeopathic Hospital (RLHH). It came as something of a surprise that the man in charge did not know the barmy postulates of homeopathy and he looked appropriately embarrassed when we told him. Michael Baum is not only a cancer surgeon. but he has also taken the lead in thinking about palliative and spiritual needs of patients who suffer from cancer. Listen to his Samuel gee lecture: it is awe-inspiring. It is available in video, Concepts of Holism in Orthodox and Alternative Medicine. The problem for UCLH Trust is that the RLHH has royal patronage One can imagine the frantic green-ink letters that would emanate form the Quacktitioner Royal, if it were to be shut down. Instead, we suggested that the name of the RLHH should be changed. Perhaps something like Hospital for palliative and supportive care? Well, four years later it has been changed, but the outcome is not at all satisfactory. From September it is to be known as the Royal London Hospital for Integrated Medicine. What’s wrong with that? You have to ask what is to be "integrated" with what?. In practice it usually means integrating things that don’t work with things that do. So not much advance there. In fact the weasel word "integrated" is just the latest in a series of euphemisms for quackery. First it was ‘alternative’ medicine. But that sounds a bit ‘new age’ (it is), so then it was rebranded ‘complementary medicine’. That sounds a bit more respectable. Now it is often "integrated medicine" (in the USA, "integrative"). That makes it sound as though it is already accepted. It is intended to deceive. See, for example, Prince of Wales Foundation for magic medicine: spin on the meaning of ‘integrated’, and What ‘holistic’ really means. Of course the amount of homeopathy practised at the RLHH has fallen considerably over the last few years. Already by 2007 there were signs of panic among homeopaths, They are beginning to realise that the game is up. Some of the gaps were filled with other sorts of unproven and disproved medicine. What the hospital is called matters less than what they do, The current activities can be seen on the UCLH web site. Services: It would be tedious to go through all of them, but here are some samples. The Children’s Clinic "The mainstay of treatments offered include Homeopathy, Herbal remedies, Flower essences, Essential oils, Tissue salts and Acupuncture. We also assess nutritional status, provide dietary advice and supplementation. Psychotherapeutic techniques including Neuro-Linguistic Programming (NLP), and Visualisation are sometimes used where indicated, to gain better understanding of the presenting problems". So a wide range of woo there. And they claim to be able to treat some potentially serious problems "What can be treated A wide variety of clinical conditions are being treated including: • Recurrent infections • Skin diseases such as eczema • Allergic disorders including asthma • Food intolerances and eating disorders • Functional developmental and learning problems • Behavioural disorders including ADHD (hyperactivity) and autism." There is, of course, no evidence worth mentioning thar any of these conditions can be treated effectively by “Homeopathy, Herbal remedies, Flower essences, Essential oils, Tissue salts and Acupuncture”. They describe their success rate thus: An internal audit questionnaire showed that 70% of children responded well to homeopathic treatment So, no published data, and no control group. This is insulting to any patient with half a brain. These claims should be referred to the Advertising Standards Authority and/or Trading standards. They are almost certainly illegal under the Consumer Protection Regulations (May 2008). The UCLH Trust should be ashamed of itself. Education Services offers mainly courses in homeopathy, the medicines that contain no medicine, Pharmacy Services stock thousands of bottles of pills, most of which are identical sugar pills. It’s hard to imagine a greater waste of money. The Marigold Clinic – Homeopathic Podiatry and Chiropody I was rather surprised to find this is still running. In 2006, I wrote about it in Conflicts of interest at the Homeopathic Hospital. It turned out that the prescription costs if the clinic were spent on Marigold paste, made by a company owned by the people who run the clinic. UCLH claimed that they were aware of this conflict of interest, but had no obligation to make it public. That is an odd ethics in itself. Even odder when I discovered that the Trust had been notified of the conflict of interest only after I’d started to ask questions. The same people are still running the clinic. They may well be good chiropodists, If so why surround the service with woo. There are, almost needless to say, no good trials of the efficacy of marigold paste (and it isn’t homeopathic). ### Conclusion At the moment, it appears that the renaming of the RLHH is empty re-branding. No doubt UCLH Trust see homeopathy as something that brings shame on a modern medical service. But to remove the name while retaining the nonsense is simply dishonest. Let’s hope that the name change will be followed by real changes in the sort of medicine practised, Changes to real medicine, one hopes. Other blogs on this topic Gimpyblog was first, with Farewell to the RLHH, hello to the RLHIM Quackometer posted An Obituary: Royal London Homeopathic Hospital, 1849-2010 ### Follow-up Systems biology is all the rage, No surprise then, to see the University of Westminster advertising a job for a systems biologist in the The Department of Molecular and Applied Biosciences. Well, no surprise there -until you read the small print. Much has been wriiten here about the University of Westminster, which remains the biggest provider of junk sciencne degrees in the UK, despite having closed two of them. ## Senior Lecturer in Systems Biology ### University of Westminster – Department of Molecular and Applied Biosciences, School of Life Sciences Cavendish Site Salary £37,886 – £50,751 (Inc. LWA) The Department of Molecular and Applied Biosciences wishes to appoint a Senior Lecturer in Systems Biology. The post-holder will teach on the undergraduate and postgraduate degree programmes within the School of Life Sciences, particularly in the areas of Molecular Biology, Bioinformatics and/or statistics, establish their own and participate in ongoing research programmes and undertake external income generation activities. The candidate should have an active interest in bridging the gap between western life sciences and Chinese medicine using emerging systems biology approaches, specifically in metabolomics and proteomics with a goal of developing novel diagnostic technologies facilitating the creation of a personalised approach to medical care. They should therefore be willing to work closely with colleagues in the life sciences as well as with clinicians and clinical researchers from within the East Asian medical tradition. The post is available from 1st October 2010 or as soon as possible thereafter. The closing date for applications, together with a short statement on why you believe you are suitable for the position and a description of your research plans, is Monday 6th September 2010. Interviews are expected to be held later in September. Administrative contact (for queries only): Tayjal Tailor (t.tailor1@wmin.ac.uk) Reference Number: 50000360 Closing Date: Friday 3 September 2010 ### A note about systems biology Systems biology is about about how whole organs behave, as opposed to single cells or single molecules, It has to be the ultimate aim of biology. There is one case in which this has been done with some success, That is the modelling of the behaviour of the whole heart by Denis Noble and his colleagues in the Phyiology department (now gone) in Oxford. They adopted a bottom up approach. They measured the currents that flow though many sorts of ion channels in single cells from various parts of the heart, and how individual cells communicate with each other. Starting from this solid basis, together with a lot of computer power, they were able to model successfully a lot of phenomena that occur in the whole heart, but can’t be investigated in single cells. For example their work cast light on abnormal heart rhythms like ventricular fibrillation, and on the effect of drugs on heart rhythm. This work was mostly done before the term ‘systems biology" thought of. It was called physiology. It is impressive work, and systems biology became a fashionable buzzword among research administrators and funding agencies. Despite the amount of money thrown at the problem, I’m not aware of any success that remotely approaches Noble’s.. One reason for that is that people have not been willing to put in the groundwork. In the case of the heart, the models were built on -many years of basic research on the electrophysiology of single heart cells. People have tried to model from the top down, without doing the spade work first. There has developed a perception that computing power can compensate for lack of basic knowledge about things work. It can’t. The usual aphorism applies: garbage in, garbage out. Here’s an example, which eas noted in the diary pages for 29 June, 2008. While in Edinbuurgh, to give a talk to the European Conference on Mathematical and Theoretical Biology, I noticed a poster. It described an attempt to model on a computer the entire metabolic network of yeast. “81 of the 662 intracellular concentrations were defined . . . The remainder were set to the median concentration of c. 0.2 mM.” Ahem. We didn’t know the concentrations so we just made them up so we could run the program. It’s interesting that even people in the business seem to realise that even that it isn’t living up to the hype. The Fixing proteomics web site shows why. Put another way, if you try to run before you can walk, you risk falling falling on your face. For these reasons, it seems to me that that most attempts at system biology have been disappointing (please correct me if I’m wrong) ### Systems biology for Chinese medicine If systems biology suffers from trying to run before it can walk in regular biology, where at least something is known about the functions of cells, how much more true that must be of Chinese medicine. In Chinese medicine almost all the treatments have never been tested properly in man. The odds are that most don’t work at all, and some are very poisonous (not to mention the cruelty and destruction of endangered species that is involved in making some of their more bizarre medicines). The idea that you can explain it with systems biology, is ludicrous in the extreme. One can’t imagine any vaguely competent biologist who’d want to touch a project as bizarre as this with a bargepole. ### Eastmedicine This advertisement stems presumably from EASTmedicine is the University of Westminster’s research centre for East Asian Sciences and Traditions in Medicine. The proclaimed aims are to focus on “understanding, development and evaluation of East Asian medicines as living traditions”. The director of EASTmedicine, Volker Scheid, is a herbalist and acupuncturist and, as such, a firm believer in alternative medicine. When he isn’t at the University he has a private practice, the Traditional Acupuncture Centre, in London. The website of his private practice makes some astonishing claims "Acupuncture is effective in the treatment of numerous conditions including headache, migraine, digestive problems, menstrual disorders, indeterminate aches and pains, asthma, hayfever, stress, tiredness, depression and anxiety. Also commonly treated are chronic conditions such as arthritis, back pain, ulcerative colitis, irritable bowel syndrome, eczema, sinusitis, high blood pressure and repetitive strain injuries." These claims simply cannot be justified by any worthwhile evidence. It will be interesting to see what Trading Standards make of them. Dr Scheid describes himself as a "scholar physician". Physician seems a rather pretentious description for someone whose qualifications are stated to be PhD, MBAcC, FRCHM. But in similar vein he describes himself thus "I am one of the West’s leading experts on Chinese medical formulas and treatment strategies". Although Scheid sells acupuncture treatments to patients, he seems ro be more anthropologist than medical. In a discussion of two acupuncture papers "From the Perspective of the Anthropologist – Volker Scheid, London, UK From a perspective anchored in the cultural studies of science, technology and medicine my main interest in these papers is their status as cultural artifacts that provide access to the lifeworlds of a particular research community. If any, life-world debate and argument marks sites of contestation." Forsch Komplementärmed 2007;14:371–375 Scheid shows not the slightest interest in whether acupuncture works other than as a placebo. Since he is selling acupuncture, he presumably starts from the premise that it works. Volker Scheid has had a £205,000 Wellcome Trust for the History of Medicine Project Grant: 2009 2012; Treating the Liver: Towards a Transnational History of East Asian Medicine; There’s nothing wrong with writing the history of long-outdated systems of medicine, though one could hardly imagine that the history would be very impartial, when it is written by a true believer. Another taste of his style can be found in his paper on Globalising Chinese Medical Understandings of Menopause. There is lots of rather pretentious stuff about culture, but very little about what actually works, Towards the end of the paper we come to the usual feeble excuse. " . . once traditional medicines allow themselves to be evaluated by biomedical research methods, the odds against receiving fair treatment are heavily stacked against them." The translation of that into plain English is something like ‘when we test our treatments properly we find they don’t work, so we blame the methods and carry on with selling them anyway’. Judging from its web site, EASTmedicine does not to do any serious clinical trials to test whether the treaments work in man, They just know that they do. But they are hoping to add some spurious scientific background to their dubious claims by hiring someone to do compuations that will cast no light whatsoever on the question that really matters, Do they work or not? The agenda is made clear by the statement EASTmedicine seeks to describe and analyse the dynamics of these transformations with a specific view of managing their integration into contemporary health care. So it is just yet another group of people pushing to have unproven and disproved treatments accepted by real medicine. The University of Westminster appears to be determined to make itself the laughing stock by persisting in promoting junk science at a time when most other universities have realise that the harm done to their reputations is not worth the income it generates, Plenty of it has been revealed here. The vice-chancellor of Westminster, Prof Geoffrey Petts, made into the pages of Private Eye (see Crystal balls. Professor Petts in Private Eye when he announced that he wouldn’t get rid of the junk, but would make it more ‘scientific’. Well, credit where it’s due, They have dropped homeopathy. see The last BSc (Hons) Homeopathy closes! But look at what they still teach at Westminster University For 2010 they still off ten different “BSc (Hons)” degrees in pre-scientific forms of medicine. It will take more than a bit od talk about systems biology to make anyone believe that these courses have anything to do with science. For example, look at some slides from their lectures on “energy medicine”, Westminster University BSc: “amethysts emit high yin energy” Why degrees in Chinese medicine are a danger to patients The Dean of the School of the Life Sciences, Jane Lewis, is an entirely respectable marine biologist. She has had the thankless task of merging the real science with the alternative medicine in a single school. I phoned her to get a reaction " outcome of merger of the school and trying to bring various parts of the school together" " "things are much more rigorous than they were". DC: "Why don’t you just phase it out?" "I’m not in a poition to do that. i move things forward as seems best -for the whole school I have to say". We’re retaining those bits thatI think have some good standing -I see NICE has approved the use of acupuncture for lower back pain and some other bits and pieces so I see acupuncture as something that does have some standing, andwe make sure it rigorously taught" "DCHave you looked at the stuff on naturopathy?" "Are amethysts emit high Yin energy still taught?" " i don’t think so". It seems, as so often in this case, that the senior people don’t really know what’s being taught under their noses. Prof Lewis says she has not read about the background to the (unusually) daft advice from NICE . Neither has she read Barker Bausell’s book on acupuncture research. If she had done any of these things,I suspect she would not have such a high opinion of it as appears to be the case. Bait and switch. Astonishingly there is a now a whole organisation devoted to the respectabalisation of Traditional Chinese Medicine Good Practice in Traditional Chinese Medicine Research in the Post-genomic Era It sounds nice and sciencey but, as usual, they are trying to run before they can walk. The first thing has to be to do good clinical trials to find out if there is anything there to be investigated. If, and only if, this is the case, would there be any case for fancy talk about "proteomics" and "the post-genomic era". I do hope that no funding agency would be fooled into parting with money on the basis of the present vacuous rhetoric. Professor Lewis said that I have I have quoted things like "amethysts emit high Yin energy" out of context. There is a simple solution to that. I have asked Westminster to make available the entire contents of the courses. Then we shall all be able to see the context of what their sudents are being taught. Follow up A brief report of this matter has appeared in Times Higher Education. In a statement, the University of Westminster says “its research into Chinese medicine is following the lead of “top research institutions”. I’m not aware of anyhting quite like this from anywhere else. In any case, Westminster should be able to think for themselves. Jump to follow-up There is something very offensive about the idea that a ‘bachelor of science’ degree can be awarded by a university, as a prize for memorising gobbledygook. Once the contents of the ‘degrees’ has been exposed to public ridicule, many universities have stopped doing it. All (or nearly all) of these pseudo-degrees have closed at the University of Salford, the University of Central Lancashire, Robert Gordon University, the University of Buckingham, and even at the University of Westminster (the worst offender), one course has closed (with rumours of more to follow).  I’ve already written about the course in Traditional Chinese Medicine at the University of Salford (Chinese medicine -acupuncture gobbledygook revealed) and at the University of Westminster: see Why degrees in Chinese medicine are a danger to patients. The former has closed, but not the latter. Here is another one. One place that has yet to come under close scrutiny is Middlesex University. Michael Driscoll, VC of Middlesex University. The buck stops with him. Their “Complementary Health” courses are as follows (April 2010). and also two postgraduate courses I asked Middlesex University for samples of their teaching materials under the Freedom of Information Act, and, as usual, the request was refused. As usual, I then asked for the mandatory internal review of the decision, and this time, most unusually, the internal review did not confirm the initial refusal and I was sent a bundle of teaching materials about Chinese Herbal Medicine, It was not all I asked for, but it is quite enough to show the absurd ideas that are still being taught as part of bachelor of Science degree in a UK University. Not only are the ideas absurd, pre-scientific, indeed antiscientific. They are also dangerous. People who have been taught this nonsense are going out and being let loose on sick people. The vice-chancellor of Middlesex University, Professor Michael Driscoll, is an economist, not a biologist. Surely you don’t need to be a scientist to feel a bit suspicious when you read on the Middlesex web site about Traditional Chinese Acupuncture and Moxibustion including distribution of meridians-collaterals and location of acupoints; needling and moxibustion techniques; Have any of the members of the Executive ever thought to ask about what goes on in these courses? Even if it is beyond an economist to see through the nonsense, surely it should be possible for Professor Margaret House, Deputy Vice-Chancellor Academic, whose interests lie in water quality, should be able to, though as Dean of the School of Health and Social Sciences she appears to sponsor the nonsense. And Professor Waqar Ahmad, Deputy Vice-Chancellor Research and Enterprise, who has written a s book on Ethnicity, Health and Health Care, should surely be able to distinguish sense from nonsense in health care? In that respect, I’d have less confidence in Katie Bell, Chief Marketing Officer, who joined Middlesex University in 2009 following a career in brand marketing for Nestlé UK and GlaxoSmithKline Consumer Healthcare. Marketing people seldom have much regard for truth. Have any of the University’s Governors ever asked what is going on in their name? It’s true that none of the long list of distinguished-sounding governors is a scientist. Surely you don’t need to be to question whether or not what follows can be described as ‘science’. My guess is that none of these distinguished people has ever bothered to look at the dangerous nonsense that is being taught in their University. It is not in the nature of ‘managers’ to look far beyond ticked-boxes and profit, They should have done of course, but to make it easier for them, here is a small selection of the slides that I was sent (the copyright for them lies with the university: these few slides come under the heading ‘ ‘fair quotation’ and it is undoubtedly in the public interest to show them). Course CMH 1211 e Uhuh, my spleen qi is well and truly knotted already though when I learned physiology it was not thought that the spleen had much to do with emotions. Ah so at least the problem of heavy breathers is solved. But high temperature, abdominal pain and abnormal pulse can be signs of serious illness. If your only explanation for them is “preponderant evil Qi”, you are a menace to public health. All these symptoms could be the result of a serious disease. It is not only antiquated nonsense to talk about them in terms of Yin, Yang and Qi. It endangers people, Course CMH 2212 Chinese materia medica. Some of the herbs are likely to contain active ingredients (indeed some are very dangerous). It would be quite possible to study the ingredients of these herbs and to investigate how they work in the light of what has been learned about physiology and pharmacology in the last 200 years. Pharmacology has a long history of doing that, But is seems to play no part in this course. Herbs are “cold” or “hot” and may “check the exuberance of yang”. and so on, just preposterous, made-up nonsense from another era. If it were taught as cultural history, it might be interesting. But it is being taught as though it were true, and an appropriate way to treat sick people. Course CMH 3214 Would you trust your child to someone who’d been taught that “causes of paediatric diseases are relatively simple”, and “children are pure yang”? Now some Chinese recipes Course CMH 3100 This may or may not taste good, but to recommend it for diabetes is seriously irresponsible. The programme specification for the “BSc (Hons) Traditonal Chinese medicine” can be found here. [local copy download] It is written with all the official trappings, just as though the degree was about science. It isn’t. It is a danger to public health. I have asked the vice-chancellor, Michael Driscoll, to express his view of these comments ### Follow-up A rather unexpected comment from a London acupuncturist. “At least,I knew that Professor David Colquhoun is very skeptical about Chinese medicine. he comment Chinese medicine study”not only are the ideas absurd, pre-scientific, indeed antiscientific. They are also dangerous. People who have been taught this nonsense are going out and being let loose on sick people.” “ “But,I still like to read his blog as His article very is respectable. I think. Look this…” The skeptic blog featured this post in its weekly roundup. 27 May 2010. Times Higher Education reported the decision of Middlesex University to close its philosophy department. This department seems to have a remarkable reputation, not least for a post-1992 university. Three academics and four students have been suspended and gagged in classical bullying style. This has happened while they continue to teach dangerous rubbish like that described above. I left a comment at Times Higher, as follows. It is a reflection on the quality of university management that Middlesex has chosen to shut its philosophy department while continuing to run degrees in quackery. These courses not only offer an Hons BSc for memorising chunks of anti-scientific nonsense. They also pose a real danger to patients. See http://www.dcscience.net/?p=2923 I can think of no better illustration than this of the crass nature of the judgements made by Middlesex’s management. They are either ignorant of what constitutes science, or they are corrupt. I see no other possibilities. In either case they should not be running a university. I think Prof Michael Driscoll owes the world an explanation. Jump to follow-up Every single request for information about course materials in quack medicine that I have ever sent has been turned down by universities, It is hardly as important as as refusal of FoI requests to see climate change documents, but it does indicate that some vice-chancellors are not very interested in openness. This secretiveness is exactly the sort of thing that leads to lack of trust in universities and in science as a whole. The one case that I have won took over three years and an Information Tribunal decision against the University of Central Lancashire (UCLAN) before I got anything. UCLAN spent £80,307.95.(inc VAT at 17.5%) in legal expenses alone (plus heaven knows how much in staff time) to prevent us from seeing what was taught on their now defunct “BSc (Hons) homeopathy”. This does not seem to me to be good use of taxpayers’ money. A small sample of what was taught has already been posted (more to come). It is very obvious why the university wanted to keep it secret, and equally obvious that it is in the public interest that it should be seen. UCLAN had dropped not only its homeopathy "degree" before the information was revealed, They also set up an internal inquiry into all the rest of their courses in magic medicine which ended with the dumping of all of them. Well, not quite all, There was one left. An “MSc” in homeopathy by e-learning. Why this was allowed to continue after the findings of UCLAN’s internal review, heaven only knows. It is run by the same Kate Chatfield who ran the now defunct BSc. Having started to defend the reputation against the harm done to it by offering this sort of rubbish, I thought I should finish. So I asked for the contents of this course too. It is, after all, much the same title as the course that UCLAN had just been ordered to release. But no, this request too was met with a refusal Worse still, the refusal was claimed under section 43(2) if the Freedom of Information Act 2000. That is the public interest defence, The very defence that was dismissed in scathing terms by the Information Tribunal less than two months ago, To add insult to injury, UCLAN said that it would make available the contents of the 86 modules in the course under its publication scheme, at a cost of £20 per module, That comes to £1,720 for the course, Some freedom of information. Because this was a new request, it now has to go through the process of an internal reviw of the decision before it can ne referred to the Information Commissioner. That will be requested, and since internal reviews have, so far, never changed the initial judgment. the appeal to the Information Commissioner should be submitted within the month. I have been promised that the Information Commissioner will deal with it much faster this time than the two years it took last time. ### And a bit more unfreedom Middlesex University I first asked Middlesex for materials from their homeopathy course on 1 Oct 2008. These courses are validated by Middlesex university (MU) but actually run by the Centre for Homeopathic Education. Thw MU site barely mentions homeopathy and all I got was the usual excuse that the uninsersity did not possess the teaching materials. As usual, the validation had been done without without looking at what was actually being taught. The did send me the validation document though [download it] As usual, the validation document shows no sign at all of the fact that the usbject of the "BSc" is utter nonsense. One wonderful passage says “. . . the Panel were assured that the Team are clearly producing practitioners but wanted to explore what makes these students graduates? The Team stated that the training reflects the professional standards that govern the programme and the graduateness is achieved through developing knowledge by being able to access sources and critically analyse these sources . . . “ Given that the most prominent characteristic of homeopaths (and other advocates of magic medicine) is total lack of critical ability, this is hilarious. If they had critical ability they wouldn’t be homeopaths. Hilarious is not quite the right word, It is tragic that nonsense like this can be found in an official university document. Middlesex, though it doesn’t advertise homeopathy, does advertise degrees in Traditional Chinese Medicine, Herbal Medicine and Ayurveda. On 2nd February 2010 I asked for teaching materials from these courses. Guess what? The request was refused. In this case the exemptions under FOIA were not even invoked but I was told that "All these materials are presently available only in one format at the University – via a student-only accessed virtual learning environment. ". Seems that they can’t print out the bits that I asked for, The internal review has been requested, then we shall see what the Information Commissioner has to say. Two other cases are at present being considered by the Information Commissioner (Scotland), after requests under the Scottish FoIA were refused. They are interesting cases because they bear on the decision, currently being considered by the government, about whether they should implement the recommendations of the execrable Pittilo report. Napier University Edinburgh. The first was for teaching material form the herbal medicine course at Napier University Edinburgh. I notice that this course no longer appears in UCAS or on Napier’s own web site, so maybe the idea that its contents might be disclosed has been sufficient to make the university do the sensible thing. Robert Gordon University Aberdeen The second request was for teaching material from the “Introduction to Homeopathy” course at the Robert Gordon University Aberdeen. The particular interest that attaches to this is that the vice-chancellor of Robert Gordon university is Michael Pittilo. The fact that he is willing to tolerate such a course in his own university seems to me to disqualify him from expressing any view on medical subjects. ### Michael Pittilo, Crohn’s disease and Andrew Wakefield Michael Pittilo has not been active in science for some time now, but Medline does show scientiifc publications for Pittilo RM, between 1979 anf 1998. Between 1989 and 1995 there are five papers published jointly with one Andrew Wakefield. These papers alleged a relationship between measles virus and Crohn’s disease. The papers were published before tha infamous 1998 paper by Wakefield in the Lancet (now retracted) that brought disgrace on Wakefield and probably caused unnecessary deaths.. The link between measles and Crohn’s disease is now equally disproved. The subject has been reviewed by Korzenik (2005) in Past and Current Theories of Etiology of IBD. Toothpaste, Worms, and Refrigerators “Wakefield et al proposed that Crohn’s results from a chronic infection of submucosal endothelium of the intestines with the measles virus [Crohn’s disease: pathogenesis and persistent measles virus infection. Wakefield AJ, Ekbom A, Dhillon AP, Pittilo RM, Pounder RE., Gastroenterology, 1995, 108(3):911-6]” "This led to considerable media interest and< public concern over use of live measles vaccine as well as other vaccines. A number of researchers countered these claims, with other studies finding that titers to measles were not increased in Crohn’s patients, granulomas were not associated with endothelium 49 , measles were not in granulomas50 and the measles vaccine is not associated with an increased risk of Crohn’s disease51–55 " This bit of history is not strictly relevant to the Pittilo report, but I do find quite puzzling how the government chooses people from whom it wishes to get advice about medical problems. ### Follow-up I notice that the Robert Gordon university bulletin has announced that “Professor Mike Pittilo, Principal of the University, has been made an MBE in the New Year Honours list for services to healthcare”. That is a reward for writing a very bad report that has not yet been implemented, and one hopes, for the sake of patients, will never be implemented. I do sometimes wonder about the bizarre honours system in the UK. Postcript. On 16th February, the death of Michael Pittilo was announced. He had been suffeing from cancer and was only 55 years old. I wouldn’t wish that fate on my worst enemy. Jump to follow-up The Yuletide edition of the BMJ carries a lovely article by Jeffrey Aronson, Patent medicines and secret remedies. (BMJ 2009;339:b5415). I was delighted to be asked to write an editorial about it, In fact it proved quite hard work, because the BMJ thought it improper to be too rude about the royal family, or about the possibility of Knight Starvation among senior medics. The compromise version that appeared in the BMJ is on line (full text link). The changes were sufficient that it seems worth posting the original version (with links embedded for convenience). The cuts are a bit ironic, since the whole point of the article is to point out the stifling political correctness that has gripped the BMA, the royal colleges, and the Department of Health when it comes to dealing with evidence-free medicine. It has become commonplace for people to worry about the future of the print media, The fact of the matter is you can often find a quicker. smarter amd blunter response to the news on blogs than you can find in the dead tree media. I doubt that the BMJ is in any danger of course. It has a good reputation for its attitude to improper drug company influence (a perpetual problem for clinical journals) as well as for clinical and science articles. It’s great to see its editor, Fiona Godlee, supporting the national campaign for reform of the libel laws (please sign it yourself). The fact remains that when it comes to the particular problem of magic medicine, the action has not come from the BMA, the royal colleges, and certainly not from the Department of Health, It has come from what Goldacre called the “intrepid, ragged band of bloggers”. They are the ones who’ve done the investigative journalism, sent complaints and called baloney wherever they saw it. This article was meant to celebrate their collective efforts and to celebrate the fact that those efforts are beginning to percolate upwards to influence the powers that be. It seems invidious to pick on one example, but if you want an example of beautiful and trenchant writing on one of the topics dealt with here, you’d be better off reading Andrew Lewis’s piece "Meddling Princes, Medical Regulation and Licenses to Kill” than anything in a print journal. I was a bit disappointed by removal of the comment about the Prince of Wales. In fact I’m not particularly republican compared with many of my friends. The royal family is clearly good for the tourist industry and that’s important. Since Mrs Thatcher (and her successors) destroyed large swathes of manufacturing and put trust in the vapourware produced by dishonest and/or incompetent bankers, it isn’t obvious how the UK can stay afloat. If tourists will pay to see people driving in golden coaches, that’s fine. We need the money. What is absolutely NOT acceptable is for royals to interfere in the democratic political process. That is what the Prince of Wales does incessantly. No doubt he is well-meaning, but that is not sufficient. If I wanted to know the winner of the 2.30 at Newmarket, it might make sense to ask a royal. In medicine it makes no sense at all. But the quality of the advice is irrelevant anyway. The royal web site itself says “As a constitutional monarch, the Sovereign must remain politically neutral.”. Why does she not apply that rule to her son? Time to put him over your knee Ma’am? Two of the major bits that were cut out are shown in bold, The many other changes are small. BMJ editorial December 2009 ### Secret remedies: 100 years on Time to look again at the efficacy of remedies Jeffrey Aronson in his article [1] gives a fascinating insight into how the BMA, BMJ and politicians tried, a century ago, to put an end to the marketing of secret remedies. They didn’t have much success. The problems had not improved 40 years later when A.J. Clark published his book on patent medicines [2]. It is astounding to see how little has changed since then. He wrote, for example, “On the other hand the quack medicine vendor can pursue his advertising campaigns in the happy assurance that, whatever lies he tells, he need fear nothing from the interference of British law. The law does much to protect the quack medicine vendor because the laws of slander and libel are so severe.”> Clark himself was sued for libel after he’d written in a pamphlet “ ‘Cures’ for consumption, cancer and diabetes may fairly be classed as murderous”. Although he initially tried to fight the case, impending destitution eventually forced him to apologise [3]. If that happened today, the accusation would have been repeated on hundreds of web sites round the world within 24 hours, and the quack would, with luck, lose [4]. As early as 1927, Clark had written “Today some travesty of physical science appears to be the most popular form of incantation” [5]. That is even more true today. Homeopaths regularly talk utter nonsense about quantum theory [6] and ‘nutritional therapists’ claim to cure AIDS with vitamin pills or even with downloaded music files. Some of their writing is plain delusional, but much of it is a parody of scientific writing. The style, which Goldacre [7] calls ‘sciencey’, often looks quite plausible until you start to check the references. A 100 years on from the BMA’s efforts, we need once again to look at the efficacy of remedies. Indeed the effort is already well under way, but this time it takes a rather different form. The initiative has come largely from an “intrepid, ragged band of bloggers” and some good journalists, helped by many scientific societies, but substantially hindered by the BMA, the Royal Colleges, the Department of Health and a few vice-chancellors. Even NICE and the MHRA have not helped much. The response of the royal colleges to the resurgence in magic medicine that started in the 1970s seems to have been a sort of embarrassment. They pushed the questions under the carpet by setting up committees (often populated with known sympathizers) so as to avoid having to say ‘baloney’. The Department of Health, equally embarrassed, tends to refer the questions to that well-known medical authority, the Prince of Wales (it is his Foundation for Integrated Health that was charged with drafting National Occupational Standards in make-believe subjects like naturopathy [8]. Two recent examples suffice to illustrate the problems. The first example is the argument about the desirability of statutory regulation of acupuncture, herbal and traditional Chinese medicine (the Pittilo recommendations) [9]. Let’s start with a definition, taken from ‘A patients’ guide to magic medicine’ [10]. “Herbal medicine: giving patients an unknown dose of an ill-defined drug, of unknown effectiveness and unknown safety”. It seems to me to be self-evident that you cannot start to think about a sensible form of regulation unless you first decide whether what you are trying to regulate is nonsense, though this idea does not seem to have penetrated the thinking of the Department of Health or the authors of the Pittilo report. The consultation on statutory regulation has had many submissions [11] that point out the danger to patients of appearing to give official endorsement of treatments that don’t work. The good news is that there seems to have been a major change of heart at the Royal College of Physicians. Their submission points out with admirable clarity that the statutory regulation of things that don’t work is a danger to patients (though they still have a blank spot about the evidence for acupuncture, partly as a result of the recent uncharacteristically bad assessment of the evidence by NICE [12]). Things are looking up. Nevertheless, after the public consultation on the report ended on November 16th, the Prince of Wales abused his position to make a well-publicised intervention on behalf of herbalists [13]Sometimes I think his mother should give him a firm lesson in the meaning of the term ‘constitutional monarchy’, before he destroys it. The other example concerns the recent ‘evidence check: homeopathy’ conducted by the House of Commons Science and Technology Select Committee (SCITECH). First the definition [10]: “Homeopathy: giving patients medicines that contain no medicine whatsoever”. When homeopathy was dreamt up, at the end of the 18th century, regular physicians were lethal blood-letters, and it’s quite likely that giving nothing saved people from them. By the mid-19th century, discoveries about the real causes of disease had started, but homeopaths remain to this day stuck in their 18th century time warp. In 1842 Oliver Wendell Holmes said all that needed to be said about medicine-free medicine [14]. It is nothing short of surreal that the UK parliament is still discussing it in 2009. Nevertheless it is worth watching the SCITECH proceedings [15]. The first two sessions are fun, if only for the statement by the Professional Standards Director of Boots that they sell homeopathic pills while being quite aware that they don’t work. I thought that was rather admirable honesty. Peter Fisher, clinical director of the Royal Homeopathic Hospital, went through his familiar cherry-picking of evidence, but at least repeated his condemnation of the sale of sugar pills for the prevention of malaria. But for pure comedy gold, there is nothing to beat the final session. The health minister, Michael O’Brien, was eventually cajoled into admitting that there was no good evidence that homeopathy worked but defended the idea that the taxpayer should pay for it anyway. It was much harder to understand the position of the chief scientific advisor in the Department of Health, David Harper. He was evasive and ill-informed. Eventually the chairman, Phil Willis, said “No, that is not what I am asking you. You are the Department’s Chief Scientist. Can you give me one specific reference which supports the use of homeopathy in terms of Government policy on health?”. But answer came there none (well, there were words, but they made no sense). Then at the end of the session Harper said “homeopathic practitioners would argue that the way randomised clinical trials are set up they do not lend themselves necessarily to the evaluation and demonstration of efficacy of homeopathic remedies, so to go down the track of having more randomised clinical trials, for the time being at least, does not seem to be a sensible way forward.” Earlier, Kent Woods (CEO of the MHRA) had said “the underlying theory does not really give rise to many testable hypotheses”. These two eminent people seemed to have been fooled by the limp excuses offered by homeopaths. The hypotheses are testable and homeopathy, because it involves pills, is particularly well suited to being tested by proper RCTs (they have been, and when done properly, they fail). If you want to know how to do it, all you have to do is read Goldacre in the Guardian [16]. It really isn’t vert complicated. “Imagine going to an NHS hospital for treatment and being sent away with nothing but a bottle of water and some vague promises.” “And no, it’s not a fruitcake fantasy. This is homeopathy and the NHS currently spends around £10million on it.” That was written by health journalist Jane Symons, in The Sun [17]. A Murdoch tabloid has produced a better account of homeopathy than anything that could be managed by the chief scientific advisor to the Department of Health. And it isn’t often that one can say that. These examples serve to show that the medical establishment is slowly being dragged, from the bottom up, into realising that matters of truth and falsehood are more important than their knighthoods. It is all very heartening, both for medicine and for democracy itself. David Colquhoun. Declaration of interests. I was A.J. Clark chair of pharmacology at UCL, 1985 – 2004. 1. Aronson, JK BMJ 2009;339:b5415 2. Clark, A,J, (1938) Patent Medicines FACT series 14, London. See also Patent medicines in 1938 and now http://www.dcscience.net/?p=257 (A.J. Clark FRS was professor of Pharmacology at UCL from 1919 to 1926, and subsequently in Edinburgh). 3. David Clark “Alfred Joseph Clark, A Memoir” (C. & J. Clark Ltd 1985 ISBN 0-9510401-0-3) 4. Lewis, A. (2007) The Gentle Art of Homeopathic Killing 5. A.J. Clark (1927) The historical aspect of quackery, BMJ October 1st 1927 6. Chrastina, D (2007) Quantum theory isn’t that weak, (response to Lionel Milgrom). 7 Goldacre, B. (2008) Bad Science. HarperCollins 8. Skills for Health web site The ‘competences’ have been revised since the account at http://www.dcscience.net/?p=215#sfh, but are still preposterous make believe. 10. A Patients’ Guide to Magic Medicine, and also in the Financial Times. 13. BBC news 1 December 2009 Prince Charles: ‘Herbal medicine must be regulated’. 14. Oliver Wendell Holmes (1842) Homeopathy and Its Kindred Delusions. 15. House of Commons Science and technology committee. Evidence check: homeopathy. Videos and transcripts available at http://www.viewista.com/s/fywlp2/ez/1 16. Goldacre, B. A Kind of Magic Guardian 16 November 2007. 17. Homeopathy is resources drain says Jane Symons. The Sun 2 December 2009. ### Follow-up There is a good account of the third SCITECH session by clinical science consultant, Majikthyse, at The Three Amigos. 16 December 2009.. Recorded an interview for BBC Radio 5 Live. It was supposed to go out early on 17th. 17 December 2009. The editorial is mentioned in Editor’s Choice, by deputy editor Tony Delamothe. I love his way of putting the problem "too many at the top of British medicine seem frozen in the headlights of the complementary medicine bandwagon". He sounds remarkably kind given that I was awarded (by the editor, Fiona Godlee, no less) a sort of booby prize at the BMJ party for having generated a record number of emails during the editing of a single editorial (was it really 24?). Hey ho. 17 December 2009. More information on very direct political meddling by the Prince of Wales in today’s Guardian, and in Press Association report. 17 December 2009Daily Telegraph reports on the editorial, under the heading “ ‘Nonsense’ alternative medicines should not be regulated“. Not a bad account for a non-health journalist. 17 December 2009. Good coverage in the excellent US blog, Neurologica, by the superb Steven Novella.’ “Intrepid, Ragged Band of Bloggers” take on CAM‘ provides a chance to compare and contrast the problems in the UK and the USA.’ 18 December 2009. Article in The Times by former special advisor, Paul Richards. “The influence of Prince Charles the lobbyist is out of hand. Our deference stops us asking questions.” “A good starting point might be publication of all correspondence over the past 30 years. Then we will know the extent, and influence, of Prince Charles the lobbyist.” Comments in the BMJ Quite a lot of comments had appeared by January 8th, though sadly they were mostly from the usual suspects who appear every time one suggests evidence matters. A reply was called for, so I sent this (the version below has links). After a long delay, this response eventually appeared in the BMJ on January 15 2010. It’s good to see so many responses, though somewhat alarming to see that several of them seem to expect an editorial to provide a complete review of the literature. I ‘ll be happy to provide references for any assertion that I made. I also find it a bit odd that some people think that an editorial is not the place to express an opinion robustly. That view seems to me to be a manifestation of the very sort of political correctness that I was deploring. It’s a bit like the case when the then health minister, Lord Hunt, referred to psychic surgery as a “profession” when he should have called it a fraudulent conjuring trick. Anything I write is very mild compared with what Thomas Wakley wrote in the Lancet, a journal which he founded around the time UCL came into existence. For example (I quote) “[We deplore the] “state of society which allows various sets of mercenary, goose-brained monopolists and charlatans to usurp the highest privileges…. This is the canker-worm which eats into the heart of the medical body.” Wakley, T. The Lancet 1838-9, 1 I don’t think it is worth replying to people who cite Jacques Benveniste or Andrew Wakefield as authorities. Neither is it worth replying to people who raise the straw man argument about wicked pharmaceutical companies (about which I am on record as being as angry as anyone). But I would like to reply directly to some of the more coherent comments. Sam Lewis and Robert Watson. [comment] Thank you for putting so succinctly what I was trying to say. Peter Fisher [comment]. I have a lot of sympathy for Peter Fisher. He has attempted to do some good trials of homeopathy (they mostly had negative outcomes). He said he was "very angry" when the non-medical homeopaths were caught out recommending their sugar pills for malaria prevention (not that this as stopped such dangerous claims which are still commonplace). He agreed with me that there was not sufficient scientific basis for BSc degrees in homeopathy. I suppose that it isn’t really surprising that he continues to cherry pick the evidence. As clinical director of the Royal London Homeopathic Hospital and Homeopathic physician to the Queen, just imagine the cognitive dissonance that would result if he were to admit publicly that is all placebo after all. He has come close though. His (negative) trial for homeopathic treatment of rheumatoid arthritis included the words "It seems more important to define if homeopathists can genuinely control patients’ symptoms and less relevant to have concerns about whether this is due to a ‘genuine’ effect or to influencing the placebo response” [2]. [download the paper ]. When it comes to malaria, it matters a lot. Adrian White [comment] seems to be cross because I cited my own blog. I did that simply because if he follows the links there he will find the evidence. In the case of acupuncture it has been shown time after time that "real" acupuncture does not differ perceptibly from sham. That is true whether the sham consists of retractable needles or real needles in the "wrong" places. A non-blind comparison between acupuncture and no acupuncture usually shows some advantage for the former but it is, on average, too small to be of much clinical significance [3]. I agree that there is no way to be sure that this advantage is purely placebo effect but since it is small and transient it really doesn’t matter much. Nobody has put it more clearly than Barker Bausell in his book, Snake Oil Science [4] White also seems to have great faith in peer review. I agree that in real science it is probably the best system we have. But in alternative medicine journals the "peers" are usually other true believers in whatever hocus pocus is being promoted and peer reveiw breaks down altogether. R. M. Pittilo [comment] I’m glad that Professor Pittilo has replied in person because I did single out his report for particular criticism. I agree that his report said that NHS funding should be available to CAM only where there is evidence of efficacy. That was not my criticism. My point was that in his report, the evidence for efficacy was assessed by representatives of Herbal Medicine, Chinese Medicine and Acupuncture (four from each). Every one of them would have been out of work if they had found their subjects were nonsense and that, no doubt, explains why the assessment was so bad. To be fair, they did admit that the evidence was not all that it might be and recommended (as always) more research I’d like to ask Professor Pittilo how much money should be spent on more research in the light of the fact that over a billion dollars has been spent in the USA on CAM research without producing a single useful treatment. Pittilo says "My own view is that both statutory regulation and the quest for evidence should proceed together" but he seems to neglect the possibility that the quest for evidence might fail. Experience in the USA suggests that is exactly what has, to a large extent, already happened. I also find it quite absurd that the Pittilo report should recommend, despite a half-hearted admission that the evidence is poor, that entry to these subjects should be via BSc Honours degrees. In any case he is already thwarted in that ambition because universities are closing down degrees in these subjects having realised that the time to run a degree is after, not before, you have some evidence that the subject is not nonsense. I hope that in due course Professor Pittilo may take the same action about the courses in things like homeopathy that are run by the university of which he is vice-chancellor. That could only enhance the academic reputation of Robert Gordon’s University. George Lewith [comment] You must be aware that the proposed regulatory body, the Health Professions Council, has already broken its own rules about "evidence-based practice" by agreeing to take on, if asked, practitioners of Herbal Medicine, Chinese Medicine and Acupuncture. They have (shamefully) excluded the idea that claims of efficacy would be regulated. In other word they propose to provide exactly the sort of pseudo-regulation which would endanger patients They are accustomed to the idea that regulation is to do only with censoring practitioners who are caught in bed with patients. However meritorious that may be, it is not the main problem with pseudo-medicine, an area in which they have no experience. I’m equally surprised that Lewith should recommend that Chinese evaluation of Traditional Chinese medicine should be included in meta-analyses, in view of the well-known fact that 99% of evaluations from China are positive: “No trial published in China or Russia/USSR found a test treatment to be ineffective” [5]. He must surely realise that medicine in China is a branch of politics. In fact the whole resurgence in Chinese medicine and acupuncture in post-war times has less to do with ancient traditions than with Chinese nationalism, in particular the wish of Mao Tse-Tung to provide the appearance of health care for the masses (though it is reported that he himself preferred Western Medicine). 1. Lord Hunt thinks “psychic surgery” is a “profession”. http://www.dcscience.net/?p=258 2. Fisher, P. Scott, DL. 2001 Rheumatology 40, 1052 – 1055. [pdf file] 3. Madsen et al, BMJ 2009;338:a3115 [pdf file] 4. R, Barker Bausell, Snake Oil Science, Oxford University Press, 2007 5. Vickers, Niraj, Goyal, Harland and Rees (1998, Controlled Clinical Trials, 19, 159-166) “Do Certain Countries Produce Only Positive Results? A Systematic Review of Controlled Trials”. [pdf file] 15 January 2010. During the SciTech hearings, Kent Woods (CEO of the MHRA) made a very feeble attempt to defend the MHRA’s decision to allow misleading labelling of homeopathic products. Now they have published their justification for this claim. It is truly pathetic, as explained by Martin at LayScience: New Evidence Reveals the MHRA’s Farcical Approach to Homeopathy. This mis-labelling cause a great outcry in 2006, as documented in The MHRA breaks its founding principle: it is an intellectual disgrace, and Learned Societies speak out against CAM, and the MHRA. 22 January 2010 Very glad to see that the minister himself has chosen to respond in the BMJ to the editorial  Rt Hon. Mike O’Brien QC MP, Minister of State for Health Services I am glad that David Colquhoun was entertained by my appearance before the Health Select Committee on Homeopathy. But he is mistaken when he says, “you cannot start to think about a sensible form of regulation unless you first decide whether or not the thing you are trying to regulate is nonsense.” Regulation is about patient safety. Acupuncture, herbal and traditional Chinese medicine involve piercing the skin and/or the ingestion of potentially harmful substances and present a possible risk to patients. The Pittilo Report recommends statutory regulation and we have recently held a public consultation on whether this is a sensible way forward. Further research into the efficacy of therapies such as Homeopathy is unlikely to settle the debate, such is the controversy surrounding the subject. That is why the Department of Health’s policy towards complementary and alternative medicines is neutral. Whether I personally think Homeopathy is nonsense or not is besides the point. As a Minister, I do not decide the correct treatment for patients. Doctors do that. I do not propose on this occasion to interfere in the doctor-patient relationship. Here is my response to the minister  I am very glad that the minister himself has replied. I think he is wrong in two ways, one relatively trivial but one very important. First, he is wrong to refer to homeopathy as controversial. It is not. It is quite the daftest for the common forms of magic medicine and essentially no informed person believes a word of it. Of course, as minister, he is free to ignore scientific advice, just as the Home Secretary did recently. But he should admit that that is what he is doing, and not hide behind the (imagined) controversy. Second, and far more importantly, he is wrong, dangerously wrong, to say it I was mistaken to claim that “you cannot start to think about a sensible form of regulation unless you first decide whether or not the thing you are trying to regulate is nonsense". According to that view it would make sense to grant statutory regulation to voodoo and astrology. The Pittilo proposals would involve giving honours degrees in nonsense if one took the minister’s view that it doesn’t matter whether the subjects are nonsense or not. Surely he isn’t advocating that? The minister is also wrong to suppose that regulation, in the form proposed by Pittilo, would do anything to help patient safety. Indeed there is a good case to be made that it would endanger patients (not to mention endangering tigers and bears). The reason for that is that the main danger to patients arises from patients being given “remedies” that don’t work. The proposed regulatory body, the Health Professions Council, has already declared that it is not interested in whether the treatments work or not. That in itself endangers patients. In the case of Traditional Chinese Medicine, there is also a danger to patients from contaminated medicines. The HPC is not competent to deal with that either. It is the job of the MHRA and/or Trading Standards. There are much better methods of ensuring patient safety that those proposed by Pittilo. In order to see the harm that can result from statutory regulation, it is necessary only to look at the General Chiropractic Council. Attention was focussed on chiropractic when the British Chiropractic Association decided, foolishly, to sue Simon Singh for defamation. That led to close inspection of the strength of the evidence for their claims to benefit conditions like infant colic and asthma. The evidence turned out to be pathetic, and the result was that something like 600 complaints were made to the GCC about the making of false health claims (including two against practices run by the chair of the GCC himself). The processing of these complaints is still in progress, but what is absolutely clear is that the statutory regulatory body, the GCC, had done nothing to discourage these false claims. On the contrary it had perpetrated them itself. No doubt the HPC would be similarly engulfed in complaints if the Pittilo proposals went ahead. It is one thing to say that the government chooses to pay for things like homeopathy, despite it being known that they are only placebos, because some patients like them. It is quite another thing to endanger patient safety by advocating government endorsement in the form of statutory regulation, of treatments that don’t work. I would be very happy to meet the minister to discuss the problems involved in ensuring patient safety. He has seen herbalists and other with vested interests. He has been lobbied by the Prince of Wales. Perhaps it is time he listened to the views of scientists too. Both the minister’s response, and my reply, were reformatted to appear as letters in the print edition of the BMJ, as well as comments on the web.. It seems very reasonable to suggest that taxpayers have an interest in knowing what is taught in universities. The recent Pittilo report suggested that degrees should be mandatory in Acupuncture, Herbal Medicine and Traditional Chinese Medicine. So it seems natural to ask to see what is actually taught in these degrees, so one can judge whether it protects the public or endangers them. Since universities in the UK receive a great deal of public money, it’s easy. Just request the material under the Freedom of Information Act. Well, uh, it isn’t as simple as that. Every single application that I have made has been refused. After three years of trying, the Information Commissioner eventually supported my appeal to see teaching materials from the Homeopathy "BSc" at the University of Central Lancashire. He ruled that every single objection (apart from one trivial one) offered by the universities was invalid. In particular, it was ruled that univerities were not "commercial" organisations for the purposes of the Act. So problem solved? Not a bit of it. I still haven’t seen any of the materials from the original request because the University of Central Lancashire appealed against the decision and the case of University of Central Lancashire v Information Commissioner is due to be heard on November 3rd, 4th and 5th in Manchester. I’m joined (as lawyers say) as a witness. Watch this space. UCLan is not the exception. It is the rule. I have sought under the Freedom of Information Act, teaching materials from UClan (homeopathy), University of Salford (homeopathy, reflexology and nutritional therapy), University of Westminster (homeopathy, reflexology and nutritional therapy), University of West of England, University of Plymouth and University of East London, University of Wales (chiropractic and nutritional therapy), Robert Gordon University Aberdeen (homeopathy), Napier University Edinburgh (herbalism). In every single case, the request for teaching materials has been refused. And that includes the last three, which were submitted after the decision of the Information Commissioner. They will send things like course validation documents, but these are utterly uninformative box-ticking documents. They say nothing whatsoever about what is actually taught. The fact that I have been able to discover quite a lot about what’s being taught owes nothing whatsoever to the Freedom of Information Act. It is due entirely to the many honest individuals who have sent me teaching materials, often anonymously. We should be grateful to them. Their principles are rather more impressive than those of their principals. Since this started about three years ago, two of the universities, UCLan and Salford, have shut down entry to all of their CAM courses. And Westminster has shut two of them, with more rumoured to be closing soon. They are to be congratulated for that, but is far from being the end of the matter. The Department of Health, and some of the Royal Colleges, have yet to catch up with the universities, The Pittolo report, which recommends making degrees compulsory, is being considered by the Department of Health. The consultation ends on November 2nd: if you haven’t yet responded, please do so now (see how here, and here). A common excuse: the university does not possess teaching materials (yes, really) Several of the universities claim that they cannot send teaching materials, because they have no access to them. This happens when the university has accredited a course that is run by another, privately run, institution. The place that does the actual teaching, being private, is exempt from the Freedom of Information Act. The ludicrous corollary of this excuse is that the university has accredited the course without checking on what is taught, and in some cases without even having seen a timetable. ### The University of Wales In fact the University of Wales doesn’t run courses at all. Like the (near moribund) University of London, it acts as a degree-awarding authority for a lot of Welsh Universities. It also validates a lot of courses in non-university institutions, 34 or so of them in the UK, and others scattered round the world. Many of them are theological colleges. It does seem a bit odd that St Petersburg Christian University, Russia, and International Baptist Theological Seminary, Prague, should be accredited by the University of Wales. The 34 UK institutions include the Scottish School of Herbal Medicine, the Northern College of Acupuncture and the Mctimoney College of Chiropractic. The case of the Nutritional Therapy course has been described already in Another worthless validation: the University of Wales and nutritional therapy. It emerged that the course was run by a grade 1 new-age fantasist. It is worth recapitulating the follow up. What does the University of Wales say? So far, nothing. Last week I sent brief and polite emails to Professor Palastanga and to Professor Clement to try to discover whether it is true that the validation process had indeed missed the fact that the course organiser’s writings had been described as “preposterous, made-up, pseudoscientific nonsense” in the Guardian. So far I have had no reply from the vice-chancellor, but on 26 October I did get an answer from Prof Palastanga.  As regards the two people you asked questions about – J.Young – I personally am not familiar with her book and nobody on the validation panel raised any concerns about it. As for P.Holford similarly there were no concerns expressed about him or his work. In both cases we would have considered their CV’s as presented in the documentation as part of the teaching team. In my experience of conducting degree validations at over 16 UK Universities this is the normal practice of a validation panel. I have to say this reply confirms my worst fears. Validation committees such as this one simply don’t do their duty. They don’t show the curiosity that is needed to discover the facts about the things that they are meant to be judging. How could they not have looked at the book by the very person that they are validating? After all that has been written about Patrick Holford, it is simply mind-boggling that the committee seems to have been quite unaware of any of it. It is yet another example of the harm done to science by an unthinking, box-ticking approach. Incidentally, Professor Nigel Palastanga has now been made Pro Vice-Chancellor (Quality) at the University of Wales and publishes bulletins on quality control. Well well. The McTimoney College of Chiropractic was the subject of my next Freedom of Information request to the University of Wales. The reasons for that are, I guess, obvious. They sent me hundreds of pages of validation documents, Student Handbooks (approx 50 pages), BSc (Hons) Chiropractic Course Document. And so on. Reams of it. The documents mostly are in the range of 40 to 100 pages. Tons of paper, but none of it tells you anyhing whatsover of interest about what’s being taught. They are a testament to the ability of universities to produce endless vacuous prose with very litlle content. They did give me enough information to ask for a sample of the teaching materials on particular topics. But I gor blank refusal, on the grounds that they didn’t possess them. Only McTimoney had them. Their (unusually helpful) Freedom of Information officer replied thus. “The University is entirely clear about the content of the course but the day to day timetabling of teaching sessions is a matter for the institution rather than the University and we do not require or possess timetable information. The Act does not oblige us to request the information but there is no reason you should not approach McTimoney directly on this.” So the university doesn’t know the timetable. It doesn’t know what is taught in lectures, but it is " entirely clear about the content of the course". This response can be described only as truly pathetic. Either this is a laughably crude form of obstruction of my request, or perhaps, even more frighteningly, the university really believes that its endless box-ticking documents actually provide some useful control of quality. Perhaps the latter interpretation is more charitable. After all, the QAA, CHRE, UUK and every HR department share similar delusions about what constitutes quality. Perhaps it is just yet another consequence of having science run largely by people who have never done it and don’t understand it. Validation is a business. The University of Wales validates no fewer than 11,675 courses altogether. Many of these are perfectly ordinary courses in universities in Wales, but they validate 594 courses at non-Welsh accredited institutions, an activity that earned them £5,440,765 in the financial year 2007/8. There’s nothing wrong with that if they did the job properly. In the two cases I’ve looked at, they haven’t done the job properly. They have ticked boxes but they have not looked at what’s being taught or who is teaching it. ### The University of Kingston The University of Kingston offers a “BSc (Hons)” in acupuncture. In view of the fact that the Pittilo group has recommended degrees in acupuncture, there is enormous public interest in what is taught in such degrees, so I asked. They sent the usual boring validation documents and a couple of sample exam papers . The questions were very clinical, and quite beyond the training of acupuncturists. The validation was done by a panel of three, Dr Larry Roberts (Chair, Director of Academic Development, Kingston University), Mr Roger Hill (Accreditation Officer, British Acupuncture Accreditation Board) and Ms Celia Tudor-Evans (Acupuncturist, College of Traditional Acupuncture, Leamington Spa). So nobody with any scientific expertise, and not a word of criticism.  Further to your recent request for information I am writing to advise that the University does not hold the following requested information: (1) Lecture handouts/notes and powerpoint presentations for the following sessions, mentioned in Template 3rd year weekend and weekday course v26Aug2009_LRE1.pdf (a) Skills 17: Representational systems + Colour & Sound ex. Tongue feedback 11 (b) Mental Disease + Epilepsy Pulse feedback 21 (c) 18 Auricular Acupuncture (d) Intro. to Guasha + practice Cupping, moxa practice Tongue feedback 14 (2) I cannot see where the students are taught about research methods and statistics. I would like to see Lecture handouts/notes and PowerPoint presentations for teaching in this area, but the ‘timetables’ that you sent don’t make clear when or if it is taught. The BSc Acupuncture is delivered by a partner college, the College of Integrated Chinese Medicine (CICM), with Kingston University providing validation only. As such, the University does not hold copies of the teaching materials used on this course. In order to obtain copies of the teaching materials required you may wish to contact the College of Integrated Chinese Medicine directly. This completes the University’s response to your information request. So again we see that Kingston has validated the course but has not seen a timetable, far less what is taught. My reply was thus  Yes I am exceedingly unhappy about it. The university attaches its name to the course so it must obviously be able to get the material simply by asking for it (I’m surprised that the university should endorse a course without knowing what is taught on it, but that’s another matter). I request formally that you obtain this material. If necessary please read this as a formal appeal. I await with interest. In every single case so far, the internal review has merely confirmed the initial refusal. It means a bit of a delay before the case goes to the Information Commisssioner’s Office. ### Napier University Edinburgh Napier University runs a "BSc (Hons) Herbal medicine". (brochure here). Since herbal medicine is a subject of the Pittilo recommendations, there is enormous public interest in what they teach. So I asked, under the Freedom of Information (Scotland) Act (2002). They sent quite quickly validation and accreditation documents, some examination papers, timetables and lecture lists. The validation was the usual vacuous box-ticking stuff though it did reveal that the course “made extensive use of techniques such as tongue and pulse diagnosis”, which are well known phoney diagnosis methods, about as much use as a pendulum (as used at Westminster University). As at Kingston University, the exam papers they chose to send were mostly "pretend doctor" stuff. One of them was Discuss the herbal practitioner’s role in the management of IHD [ischaemic heart disease) How one would like to see what the students said, and, even more one would like to see the model answer. Amateurs who try to treat potentially serious conditions are a danger to the public. So then we got to the interesting bit, the request for actual teaching materials.  I have looked at the material that you sent and I’d now like to make the following supplementary request (A) Lecture notes/handouts and powerpoint slides for the following small smaple of lectures HRB09102 Materia Medica 4 (1) Zingiber officinalis, Eleutherococcus senticosus, Valeriana officinalis (2) Gelsemium sempervirens, Cimicifuga racemosa, Datura stramonium, Piscidia erythrina (3) Betula pendula, Capsella bursa-pastoris, Ephedra sinica, Solidago virgaurea Materia Medica 3 HRB08103 (1) Cardiovascular system (2) Nervous system Clinical Medicine and Diagnosis 4 (HRB09104) (1) Neuro-sensory deficits, paraesthesiae, head pain HRB09100 Materia Medica & Herbal Practice Week 7 Compiling a therapeutic plan and prescription building BSc Herbal Medicine : Materia Medica HRB07102 Week 3 History of Herbal Medicine Gothean tasting session Week 10 Energetics the basic concepts Ayurveda Lastly, I can see nowhere in the timetable, lectures that deal with Research methods, clinical trial design and statistics. If such lectures exist, please send notes and powerpoints for them too No prizes for guessing the result Total refusal to send any of them. To make matters worse, the main grounds for refusal were the very "commercial interests" which, after careful legal examination, the Information Commissioner (for England and Wales) had decided were invalid. They say too that "The public interest in withholding the information is greater than the public interest in its release".. It is hard to see how the public interest is served by concealing from the people who pay for the degrees what is taught on degrees that Pittilo wants to make compulsory. [Download the whole response] The matter is now under internal appeal (read the appeal) and eventually we shall find out whether the Scottish Information Commissioner backs the judgement. ### Robert Gordon University Aberdeen This case has particular interest because the Vice-Chancellor of Robert Gordon University is Professor Michael Pittilo, chair of the highly contentious steering group that recommended degress in CAM. Robert Gordon University (RGU) does not teach herbal medicine or acupuncture. But they do run An Introduction to Homeopathy. All the degrees in homeopathy have closed. It is perhaps the daftest and most discredited of all the popular forms of Magic Medicine. But Professor Pittilo thinks it is an appropriate subject to teach in his university. So again I asked for information under the Freedom of Information (Scotland) Act 2002. They sent me quite quckly a list of the powerpoint presentations used on the courses [download it]. I asked for a small sample of the powerpoints. And again the university did not possess them!  I should like to see only the following three powerpoint presentations in the first instance, please. Please can you let me know also who produced the powerpoints. (1) Evidence for homeopathy (2) First aid remedies (3) Allergies I note that you will have to request them but since they are being offered as part of a course offered by RGU, so RGU is responsible for their quality, I presume that this should cause no problem. The request was refused on much the same grounds as used by Napier University. As usual, the internal review just confirmed the initial proposal (but dropped the obviously ludicrous public interest defence). The internal review said “it is mainly the quality of our courses (including course material) and teaching which has given us the position of "the best modern university in Scotland" I am bound to ask, if the university is so proud of its course material, why is it expending so much time and money to prevent anyone from seeing a small sample of it? My appeal has been sent to the Scottish Information Commissioner [download the appeal]. ### What are vice-chancellors thinking about? I find it very difficult to imagine what is going through the heads of vice-chancellors who run courses in mumbo-jumbo. Most of them don’t believe a word of it (though Michael Pittilo might be an exception) yet they foist it on their students. How do they sleep at night? Recently the excellent Joe Collier wrote a nice BMJ blog which applauded the lack of respect for authority in today’s students, Joe Collier says good riddance to old-fashioned respect. I couldn’t resist leaving a comment.  I couldn’t agree more. There is nothing quite so unnerving as being addressed as “Sir”. It is an advantage of age that you realise what second-rate people come to occupy very grand positions. Still odder since, if occasionally they are removed for incompetence, they usually move to an even grander position. I guess that when I was an undergraduate, I found vice-chancellors somewhat imposing. That is, by and large, not a view that survives closer acquaintance. ### Should teaching materials be open to the public? There is only one university in the world that has, as a matter of policy, made all of its teaching material open to the public, that is the Massachusetts Institute of Technology (MIT). I can recommend strongly course 18.06, a wonderful set of lectures on Linear Algebra by Gilbert Strang. (It is also a wonderful demonstration of why blackboards may be better than Powerpoint for subjects like this). Now they are on YouTube too. A lot of other places have made small moves in the same direction, as discussed recently in Times Higher Education, Get it Out in the Open Now the OU is working with other British universities to help them develop and share open course materials. In June, at the celebrations for the 40th anniversary of the OU, Gordon Brown announced funding to establish the Support Centre for Open Resources in Education at the OU, as part of a £7.8 million grant designed to enhance the university’s national role. The funding follows a separate grant of £5.7 million from the Higher Education Funding Council for England for universities across the sector to make thousands of hours of free learning materials available. Much material is available on the web, when individual teachers choose to place it there, but at the same time there is a move in the other direction. In particular, the widespread adoption of Moodle has resulted in a big decrease in openness. Usually you have to be registered on a course to see the material. Even other people in the university can’t see it. I think that is a deplorable development (so, presumably, does HEFCE). ### Conclusion I was told by the Univerity of Kingston that “The course is one which the University has validated and continues to be subject to the University’s quality assurance procedures, such as internal subject reviews, annual monitoring and external examining” The only conclusion to be drawn from this is that “quality arrurance procedures” work about as well in universities as they did in the case of baby Peter. No doubt they were introduced with worthy aims. But in practice they occupy vast amounts of time for armies of bureaucrats, and because the brain does not need to be engaged they end up endorsing utter nonsenes. The system is broken. ### Resistance is futile. You can see a lot of the stuff here It is hard to keep secrets in the internet age. Thanks to many wonderful people who have sent me material. you can see plenty of what is taught, despite the desperate attempts of vice-chancellors to conceal it. Try these links. What is actually taught Chinese medicine -acupuncture gobbledygook revealed http://www.dcscience.net/?p=1950 Consultation opens on the Pittilo report: help top stop the Department of Health making a fool of itself http://www.dcscience.net/?p=2007 Why degrees in Chinese medicine are a danger to patients http://www.dcscience.net/?p=2043 More make-believe from the University of Westminster. This time its Naturopathy http://www.dcscience.net/?p=1812 The last BSc (Hons) Homeopathy closes! But look at what they still teach at Westminster University. http://www.dcscience.net/?p=1329 The opposite of science http://www.dcscience.net/?p=1191 Bad medicine. Barts sinks further into the endarkenment. http://www.dcscience.net/?p=1143 A letter to the Times, and progress at Westminster http://www.dcscience.net/?p=984 Nutritional Fairy Tales from Thames Valley University http://www.dcscience.net/?p=260 Westminster University BSc: amethysts emit high yin energy http://www.dcscience.net/?p=227 References for Pittilo report consultation A very bad report: gamma minus for the vice-chancellor http://www.dcscience.net/?p=235 The Times (blame subeditor for the horrid title) http://www.timesonline.co.uk/tol/comment/columnists/guest_contributors/article4628938.ece Some follow up on the Times piece http://www.dcscience.net/?p=251 The Health Professions Council breaks its own rules: the result is nonsense http://www.dcscience.net/?p=1284 One month to stop the Department of Health endorsing quackery. The Pittilo questionnaire, http://www.dcscience.net/?p=2310 An excellent submission to the consultation on statutory regulation of alternative medicine (Pittilo report) http://www.dcscience.net/?p=2329 ### Follow-up Two weeks left to stop the Department of Health making a fool of itself. Email your response to tne Pittilo consultation to this email address HRDListening@dh.gsi.gov.uk I’ve had permission to post a submission that has been sent to the Pittilo consultation. The whole document can be downloaded here. I have removed the name of the author. It is written by the person who has made some excellent contributions to this blog under the pseudonym "Allo V Psycho". The document is a model of clarity, and it ends with constructive suggestions for forms of regulation that will, unlike the Pittilo proposals, really protect patients Here is the summary. The full document explains each point in detail.  Executive Summary Statutory regulation lends prestige, but needs to be balanced by a requirement for practitioners to be competent, as is the case for doctors and nurses. Regulation almost exclusively deals with conduct, but the unique risks posed by alternative medicine are not addressed by this. The harms which will arise from licensing practitioners who are not required to show evidence of competence and efficacy are: Harm 1. Misdiagnosis of serious conditions. Alternative practitioners offer to diagnose illnesses without proper training. This can lead to avoidable death, such as treating an ectopic pregnancy with ginger. Harm 2. Withdrawal from treatment. Clients of alternative practitioners risk being encouraged to withdraw from life saving treatments in favours of treatments without evidence, as in the death of baby Gloria Thomas. Harm 3. Harms arising from the nature of the alternative practice, but not covered by the regulatory framework, such as adulterated herbal remedies. Harm 4. Lack of informed consent. If alternative practitioners are not required to study or show evidence of efficacy, how can they inform patients of their options? Harm 5. Equity. Doctors and nurses have to use evidence based methods, but it is proposed that alternative practitioners are not held to this standard. Is this fair? Health Minsters should ask themselves if they advocate withdrawing the requirement for evidence based treatment from doctors and nurses. If not, why not? And if not, why should alternative practitioners be treated differently? Harm 6. Promotion of irrationality. If no evidence of efficacy is required, where do you draw the line? Witch doctoring is a ‘traditional practice’ in communities in the UK, and astrology is used by some herbal healers. Harm 7. Opportunity Costs. If no evidence of efficacy is required of alternative medicine, significant sums will be wasted by individuals and by the NHS. Harm 8. Reputational harms for UK Higher Education. UK Honours Degrees are based on the ability to think critically and to assess evidence. Alternative medicine Degree programmes do not require this. These positions are not compatible. Harm 9. Health care futures. We are making slow but steady progress on health indicators through the use of evidence based methods. Why should the requirement for evidence be abandoned now? Instead, safe regulation of alternative practitioners should be through: The Medicines and Healthcare Products Regulatory Agency The Office of Trading Standards via the Unfair Trading Consumer Protection Regulations, A new Health Advertising Standards Authority, modelled on the successful Cancer Act 1939. The first two recommendations for effective regulation are much the same as mine, but the the third one is interesting. The problem with the Cancer Act (1939), and with the Unfair Trading regulations, is that they are applied very erratically. They are the responsibility of local Trading Standards offices, who have, as a rule, neither the expertise nor the time to enforce them effectively. A Health Advertising Standards Authority could perhaps take over the role of enforcing existing laws. But it should be an authority with teeth. It should have the ability to prosecute. The existing Advertising Standards Authority produces, on the whole, excellent judgements but it is quite ineffective because it can do very little. ### A letter from an acupuncturist I had a remarkable letter recently from someone who actually practises acupuncture. Here are some extracts.  “I very much enjoy reading your Improbable Science blog. It’s great to see good old-fashioned logic being applied incisively to the murk and spin that passes for government “thinking” these days.” “It’s interesting that the British Acupuncture Council are in favour of statutory regulation. The reason is, as you have pointed out, that this will confer a respectability on them, and will be used as a lever to try to get NHS funding for acupuncture. Indeed, the BAcC’s mission statement includes a line “To contribute to the development of healthcare policy both now and in the future”, which is a huge joke when they clearly haven’t got the remotest idea about the issues involved.” “Before anything is decided on statutory regulation, the British Acupuncture Council is trying to get a Royal Charter. If this is achieved, it will be seen as a significant boost to their respectability and, by implication, the validity of state-funded acupuncture. The argument will be that if Physios and O.T.s are Chartered and safe to work in the NHS, then why should Chartered Acupuncturists be treated differently? A postal vote of 2,700 BAcC members is under-way now and they are being urged to vote “yes”. The fact that the Privy Council are even considering it, is surprising when the BAcC does not even meet the requirement that the institution should have a minimum of 5000 members (http://www.privy-council.org.uk/output/Page45.asp). Chartered status is seen as a significant stepping-stone in strengthening their negotiating hand in the run-up to statutory regulation.” “Whatever the efficacy of acupuncture, I would hate to see scarce NHS resources spent on well-meaning, but frequently gormless acupuncturists when there’s no money for the increasing costs of medical technology or proven life-saving pharmaceuticals.” “The fact that universities are handing out a science degree in acupuncture is a testament to how devalued tertiary education has become since my day. An acupuncture degree cannot be called “scientific” in any normal sense of the term. The truth is that most acupuncturists have a poor understanding of the form of TCM taught in P.R.China, and hang on to a confused grasp of oriental concepts mixed in with a bit of New Age philosophy and trendy nutritional/life-coach advice that you see trotted out by journalists in the women’s weeklies. This casual eclectic approach is accompanied by a complete lack of intellectual rigour. My view is that acupuncturists might help people who have not been helped by NHS interventions, but, in my experience, it has very little to do with the application of a proven set of clinical principles (alternative or otherwise). Some patients experience remission of symptoms and I’m sure that is, in part, bound up with the psychosomatic effects of good listening, and non-judgemental kindness. In that respect, the woolly-minded thinking of most traditional acupuncturists doesn’t really matter, they’re relatively harmless and well-meaning, a bit like hair-dressers. But just because you trust your hairdresser, it doesn’t mean hairdressers deserve the Privy Council’s Royal Charter or that they need to be regulated by the government because their clients are somehow supposedly “vulnerable”.” ### Earlier postings on the Pittilo recommendations A very bad report: gamma minus for the vice-chancellor http://www.dcscience.net/?p=235 Article in The Times (blame subeditor for the horrid title) http://www.timesonline.co.uk/tol/comment/columnists/guest_contributors/article4628938.ece Some follow up on The Times piece http://www.dcscience.net/?p=251 The Health Professions Council breaks its own rules: the result is nonsense http://www.dcscience.net/?p=1284 Chinese medicine -acupuncture gobbledygook revealed http://www.dcscience.net/?p=1950 Consultation opens on the Pittilo report: help top stop the Department of Health making a fool of itself http://www.dcscience.net/?p=2007 Why degrees in Chinese medicine are a danger to patients http://www.dcscience.net/?p=2043 One month to stop the Department of Health endorsing quackery. The Pittilo questionnaire, http://www.dcscience.net/?p=2310 ### Follow-up More boring politics, but it matters. 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 should normally be through a Bachelor degree with Honours For the background on this appalling report, see earlier posts. A very bad report: gamma minus for the vice-chancellor The Times (blame subeditor for the horrid title), and some follow up on the Times piece The Health Professions Council breaks its own rules: the result is nonsense Chinese medicine -acupuncture gobbledygook revealed Consultation opens on the Pittilo report: help stop the Department of Health making a fool of itself Why degrees in Chinese medicine are a danger to patients The Department of Health consultation shuts on November 2nd. If you haven’t responded yet, please do. It would be an enormous setback for reason and common sense if the government were to give a stamp of official approval to people who are often no more than snake-oil salesman. Today I emailed my submission to the Pittilo consultation to the Department of Health, at HRDListening@dh.gsi.gov.uk ### The submission I sent the following documents, updated versions of those already posted earlier. • Submission to the Department of Health, for the consultation on the Pittilo report [download pdf]. • What is taught in degrees in herbal and traditional Chinese medicine? [download pdf] •$2.5B Spent, No Alternative Med Cures [download pdf]
• An example of dangerous (and probably illegal) claims that are routinely made by TCM practitioners [download pdf]f

I also completed their questionnaire, despite its deficiencies. In case it is any help to anyone, this is what I said:

### The questionnaire

Q1: What evidence is there of harm to the public currently as a result of the activities of acupuncturists, herbalists and traditional Chinese medicine practitioners? What is its likelihood and severity?

Harm

No Harm

Unsure

Comment

The major source of harm is the cruel deception involved in making false claims of benefit to desperate patients. This applies to all three.

In the case of herbal and TCM there is danger from toxicity because herbal preparations are unstandardised so those that do contain an active ingredient are given in an unknown dose. This is irresponsible and dangerous (but would not be changed by the proposals for regulation).

In addition TCM suffers from recurrent problems of contamination with heavy metals, prescription drugs and so on. Again this would not be the business of the proposed form of regulation.

Q2: Would this harm be lessened by statutory regulation? If so, how?

Yes

No

Unsure

The proposed form of regulation would be no help at all. The HPC has already said that it is not concerned with whether or not the drug works, and, by implication, does not see itself as preventing false health claims (just as the GCC doesn’t do this). False claims are the responsibility of Trading Standards who are meant to enforce the Consumer Protection Unfair Trading Regulations (May 2008), though they do not at present enforce them very effectively. Also Advertisng Standards. The proposed regulation would not help, and could easily hinder public safety as shown by the fact that the GCC has itself been referred to the Advertisng Standards Authority.

The questions of toxicity and contamination are already the responsibility of Trading Standards and the MHRA. Regulation by the HPC would not help at all. The HPC is not competent to deal with such questions.

Q3: What do you envisage would be the benefit to the public, to practitioners and to businesses, associated with introducing statutory regulation?

Significant benefit

Some benefit

No benefit

Unsure

This question is badly formulated because the answer is different according to whether you are referring to the public, to practitioners or to businesses.

The public would be endangered by the form of regulation that is proposed, as is shown very clearly by the documents that I have submitted separately.

In the case of practitioners and businesses, there might be a small benefit, if the statutory regulation gave the impression that HM and TCM had government endorsement and must therefore be safe and effective.

There is also one way that the regulation could harm practitioners and businesses. If the HPC received a very large number of complaints about false health claims, just as the GCC has done recently, not only would it cost a large amount of money to process the claims, but the attendant bad publicity could harm practitioners. It is quite likely that this would occur since false claims to benefit sick people are rife in the areas of acupuncture, HM and TCM.

Q4: What do you envisage would be the regulatory burden and financial costs to the public, to practitioners, and to businesses, associated with introducing statutory regulation? Are these costs justified by the benefits and are they proportionate to the risks? If so, in what way?

Justified

Not Justified

Unsure

Certainly not justified. Given that I believe that the proposed form of regulation would endanger patients, no cost at all would be justified. But even if there were a marginal benefit, the cost would be quite unjustified. The number of practitioners involved is very large. It would involve a huge expansion of an existing quango, at a time when the government is trying to reduce the number of quangos. Furthermore, if the HPC were flooded with complaints about false health claims, as the GCC has been, the costs in legal fees could be enormous.

Q5: If herbal and TCM practitioners are subject to statutory regulation, should the right to prepare and commission unlicensed herbal medicines be restricted to statutorily regulated practitioners?

Yes

No

Unsure

I don’t think it would make much difference. The same (often false) ideas are shared by all HM people and that would continue to be the same with or without SR.

Q6: If herbal and TCM practitioners are not statutorily regulated, how (if at all) should unlicensed herbal medicines prepared or commissioned by these practitioners be regulated?

They could carry on as now, but the money that would have been spent on SR should instead be used to give the Office of Trading Standards and the MHRA the ability to exert closer scrutiny and to enforce more effectively laws that already exist. Present laws, if enforced, are quite enough to protect the public.

Q7: What would be the effect on public, practitioners and businesses if, in order to comply with the requirements of European medicines legislation, practitioners were unable to supply manufactured unlicensed herbal medicines commissioned from a third party?

Significant effect

Some effect

No effect

Unsure

European laws,especialliy in food area, are getting quite strict about the matters of efficacy. The proposed regulation, which ignores efficacy, could well be incompatible with European law, if not now, then soon. This would do no harm to legitimate business though it might affect adversely businesses which make false claims (and there are rather a lot of the latter).

Q8: How might the risk of harm to the public be reduced other than by orthodox statutory regulation? For example by voluntary self-regulation underpinned by consumer protection legislation and by greater public awareness, by accreditation of voluntary registration bodies, or by a statutory or voluntary licensing regime?

Voluntary self-regulation

Accreditation of voluntary bodies

Statutory or voluntary licensing

Unsure

I disagree with the premise, for reasons given in detail in separate documents. I believe that ‘orthodox statutory regulation’, if that means the Pittilo proposals, would increase, not decrease, the risk to the public. Strengthening the powers of Trading Standards, the MHRA and such consumer protection legislation would be far more effective in reducing risk to the public than the HPC could ever be.  Greater public awareness of the weakness of the evidence for the efficacy of these treatments would obviously help too, but can’t do the job on its own.

Q10: What would you envisage would be the benefits to the public, to practitioners, and to businesses, for the alternatives to statutory regulation outlined at Question 8?

It depends on which alternative you are referring to. The major benefit of enforcement of existing laws by Trading Standards and/or the MHRA would be (a) to protect the public from risk, (b) to protect the public from health fraud and (c) almost certainly lower cost to the tax payer.

Q11: If you feel that not all three practitioner groups justify statutory regulation, which group(s) does/do not and please give your reasons why/why not?

Acupuncture

Herbal Medicine

TCM

Unsure

None of them. The differences are marginal. In the case of acupuncture there has been far more good research than for HM or TCM. But the result of that research is to show that in most cases the effects are likely to be no more than those expected of a rather theatrical placebo. Furthermore the extent to which acupuncture has a bigger effect than no-acupuncture in a NON-BLIND comparison, is usually too small and transient to offer any clinical advantage (so it doesn’t really matter whether the effect is placebo or not, it is too small to be useful).

In the case of HM, and even more of TCM, there is simply not enough research to give much idea of their usefulness,  with a small handful of exceptions.

This leads to a conclusion that DH seems to have ignored in the past. It makes absolutely no sense to talk about “properly trained practitioners” without first deciding whether the treatments work or not. There can be no such thing as “proper training” in a discipline that offers no benefit over placebo. It is a major fault of the Pittilo recommendations that they (a) ignore this basic principle and (b) are very over-optimistic about the state of the evidence.

Q12: Would it be helpful to the public for these practitioners to be regulated in a way which differentiates them from the regulatory regime for mainstream professions publicly perceived as having an evidence base of clinical effectiveness? If so, why? If not, why not?

Yes

No

Unsure

It might indeed be useful if regulation pointed out the very thin evidence base for HM and TCM but it would look rather silly. The public would say how can it be that the DH is granting statutory regulation to things that don’t work?

Q13: Given the Government’s commitment to reducing the overall burden of unnecessary statutory regulation, can you suggest which areas of healthcare practice present sufficiently low risk so that they could be regulated in a different, less burdensome way or de-regulated, if a decision is made to statutorily regulate acupuncturists, herbalists and traditional Chinese medicine practitioners?

Yes

No

Unsure

As stated above, the.only form of regulation that is needed, and the only form that would protect the public, is through consumer protection regulations, most of which already exist (though they are enforced in a very inconsistent way). Most statutory regulation is objectionable, not on libertarian grounds, but because it doesn’t achieve the desired ends (and is expensive). In this case of folk medicine, like HM and TCM, the effect would be exactly the opposite of that desired as shown in separate documents that I have submitted to the consultation.

Q14: If there were to be statutory regulation, should the Health Professions Council (HPC) regulate all three professions? If not, which one(s) should the HPC not regulate?

Yes

No

Unsure

The HPC should regulate none of them. It has never before regulated any form of alternative medicine and it is ill-equipped to do so. Its statement that it doesn’t matter that there is very little evidence that the treatments work poses a danger to patients (as well as being contrary to its own rules).

Q15: If there were to be statutory regulation, should the Health Professions Council or the General Pharmaceutical Council/Pharmaceutical Society of Northern Ireland regulate herbal medicine and traditional Chinese medicine practitioners?

HPC

GPC/PSNI

Unsure

Neither. The GPC is unlikely to care about whether the treatments work any more than the RPSGB did, or the GCC does now. The problems would be exactly the same whichever body did it.

Q16: If neither, who should and why?

As I have said repeatedly, it should be left to Trading Standards, the MHRA and other consumer protection regulation.

Q17:

a) Should acupuncture be subject to a different form of regulation from that for herbalism and traditional Chinese medicine? If so, what?

Yes

No

Unsure

b) Can acupuncture be adequately regulated through local means, for example through Health and Safety legislation, Trading Standards legislation and Local Authority licensing?

Yes

No

Unsure

(a) No -all should be treated the same. Acupuncture is part of TCM

(b) Yes

Q18.

a) Should the titles acupuncturist, herbalist and [traditional] Chinese medicine practitioner be protected?

b) If your answer is no which ones do you consider should not be legally protected?

Yes

No

Unsure

No. It makes no sense to protect titles until such time as it has been shown that the practitioners can make a useful contribution to medicine (above placebo effect). That does not deny that placebos may be useful at times. but if that is all they are doing, the title should be ‘placebo practitioners’.

Q19: Should a new model of regulation be tested where it is the functions of acupuncture, herbal medicine and TCM that are protected, rather than the titles of acupuncturist, herbalist or Chinese medicine practitioner?

Yes

No

Unsure

No. This makes absolutely no sense when there is so little knowledge about what is meant by the ” functions of acupuncture, herbal medicine and TCM”.Insofar as they don’t work (better than placebo), there IS no function. Any attempt to define function when there is so little solid evidence (at least for HM and TCM) is doomed to failure.

Q20: If statutory professional self-regulation is progressed, with a model of protection of title, do you agree with the proposals for “grandparenting” set out in the Pittilo report?

Yes

No

Unsure

No. I believe the Pittilo report should be ignored entirely. The whole process needs to be thought out again in a more rational way.

Q22: Could practitioners demonstrate compliance with regulatory requirements and communicate effectively with regulators, the public and other healthcare professionals if they do not achieve the standard of English language competence normally required for UK registration? What additional costs would occur for both practitioners and regulatory authorities in this case?

Yes

No

Unsure

No. It is a serious problem, in TCM especially, that many High Street practitioners speak hardly any English at all. That adds severely to the already considerable risks. There would be no reliable way to convey what was expected of them. it would be absurd for the taxpayer to pay for them to learn English for the purposes of practising TCM (of course there might be the same case as for any other immigrant for teaching English on social grounds).

Q23: What would the impact be on the public, practitioners and businesses (financial and regulatory burden) if practitioners unable to achieve an English language IELTS score of 6.5 or above are unable to register in the UK?

Significant impact

Some impact

No impact

Unsure

The question is not relevant. The aim of regulation is to protect the public from risk (and it should be, but isn’t, an aim to protect them from health fraud). It is not the job of regulation to promote businesses

Q24: Are there any other matters you wish to draw to our attention?

I have submitted three documents via HRDListening@dh.gsi.gov.uk. The first of these puts the case against the form of regulation proposed by Pittilo, far more fluently than is possible in a questionnaire.
Another shows examples of what is actually taught in degrees in acupuncture, HM and TCM. They show very graphically the extent to which the Pittilo proposals would endanger the public, if they were to be implemented..

The King’s Fund recently published Assessing complementary practice Building consensus on appropriate research methods [or download pdf].

It is described as being the “Report of an independent advisory group”. I guess everyone knows by now that an “expert report” can be produced to back any view whatsoever simply by choosing the right “experts”, so the first things one does is to see who wrote it.  Here they are.

• Chair: Professor Dame Carol Black
• Harry Cayton, Chief Executive, Council for Healthcare Regulatory Excellence
• Professor Adrian Eddleston, then Vice-Chairman, The King’s Fund
• Professor George Lewith, Professor of Health Research, Complementary and Integrated Medicine Research Unit, University of Southampton
• Professor Stephen Holgate, MRC Clinical Professor of Immunopharmacology, University of Southampton
• Professor Richard Lilford, Head of School of Health and Population Sciences, University of Birmingham

We see at once two of the best known apologists for alternative medicine, George Lewith (who has appeared here more than once) and Stephen Holgate

Harry Cayton is CEO of Council for Healthcare Regulatory Excellence (CHRE) which must be one of the most useless box-ticking quangos in existence. It was the CHRE that praised the General Chiropractic Council (GCC) for the quality of its work.  That is the same GCC that is at present trying to cope with 600 or so complaints about the people it is supposed to regulate (not to mention a vast number of complaints to Trading Standards Offices).  The GCC must be the prime example of the folly of giving government endorsement to things that don’t work. But the CHRE were not smart enough to spot that little problem.  No doubt Mr Cayton did good work for the Alzheimer’s Society.  His advocacy of patient’s choice may have helped me personally.  But it isn’t obvious to me that he is the least qualified to express an opinion on research methods in anything whatsoever. According to the Guardian he is “BA in English and linguistics from the University of Ulster; diploma in anthropology from the University of Durham; B Phil in philosophy of education from the University of Newcastle.”

Adrian Eddlestone is a retired Professor of Medicine. He has been in academic administration since 1983. His sympathy for alternative medicine is demonstrated by the fact that he is also Chair of the General Osteopathic Council, yet another “regulator” that has done nothing to protect the public
from false health claims (and which may, soon, find itself in the same sort of trouble as the GCC).

Richard Lilford is the only member of the group who has no bias towards alternative medicine and also the only member with expertise in clinical research methods  His credentials look impressive, and his publications show how he is the ideal person for this job. I rather liked also his article Stop meddling and let us get on.. He has written about the harm done by postmodernism and relativism, the fellow-travellers of alternative medicine.

Most damning of all, Lewith, Eddlestone and Holgate (along with Cyril Chantler, chair of the King’s Fund, and homeopaths, spiritual healers and Karol Sikora) are Foundation Fellows of the Prince of Wales Foundation for Magic Medicine, an organisation that is at the forefront of spreading medical misinformation.

I shall refer here to ‘alternative medicine’ rather than ‘complementary medicine’ which is used in the report. It is not right to refer to a treatment as ‘complementary’ until such time as it has been shown to work. The term ‘complementary’ is a euphemism that, like ‘integrative’, is standard among alternative medicine advocates whose greatest wish is to gain respectability.

### The Report

The recommendations

On page 10 we find a summary of the conclusions.

The report identifies five areas of consensus, which together set a framework for moving forward. These are:

• the primary importance of controlled trials to assess clinical and cost effectiveness.
• the importance of understanding how an intervention works
• the value of placebo or non-specific effects
• the need for investment and collaboration in creating a sound evidence base
• the potential for whole-system evaluation to guide decision-making and subsequent research.

The first recommendation is just great. The rest sound to me like the usual excuses for incorporating ineffective treatments into medical practice. Notice the implicit assumption in the fourth point
that spending money on research will establish “a sound evidence base". There is a precedent, but it is ignored. A huge omission from the report is that it fails to mention anywhere that a lot of research has already been done.

### Much research has already been done (and failed)

The report fails to mention at all the single most important fact in this area. The US National Institutes of Health has spent over a billion dollars on research on alternative medicines, over a period
of more than 10 years. It has failed to come up with any effective treatments whatsoever. See, for example Why the National Center for Complementary and Alternative Medicine (NCCAM) Should Be Defunded;   Should there be more alternative research?;   Integrative baloney @ Yale, and most recently, $2.5B Spent, No Alternative Med Cures found. . Why did the committee think this irrelevant? I can’t imagine. You guess. The report says “This report outlines areas of potential consensus to guide research funders, researchers, commissioners and complementary practitioners in developing and applying a robust evidence base for complementary practice.” As happens so often, there is implicit in this sentence the assumption that if you spend enough money evidence will emerge. That is precisely contrary to the experence in the USA where spending a billion dollars produced nothing beyond showing that a lot of things we already thought didn’t work were indeed ineffective. And inevitably, and tragically, NICE’s biggest mistake is invoked. “It is noteworthy that the evidence is now sufficiently robust for NICE to include acupuncture as a treatment for low back pain.” [p ] Did the advisory group not read the evidence used (and misinterpeted) by NICE? It seems not. Did the advisory group not read the outcome of NIH-funded studies on acupuncture as summarised by Barker Bausell in his book, Snake Oil Science? Apparently not. It’s hard to know because the report has no references. George Lewith is quoted [p. 15] as saying “to starve the system of more knowledge means we will continue to make bad decisions”. No doubt he’d like more money for research, but if a billion dollars in the USA gets no useful result, is Lewith really likely to do better? ### The usual weasel words of the alternative medicine industry are there in abundance “First, complementary practice often encompasses an intervention (physical treatment or manipulation) as well as the context for that intervention. Context in this setting means both the physical setting for the delivery of care and the therapeutic relationship between practitioner and patient.” [p. 12] Yes, but ALL medicine involves the context of the treatment. This is no different whether the medicine is alternative or real. The context (or placebo) effect comes as an extra bonus with any sort of treatment. “We need to acknowledge that much of complementary practice seeks to integrate the positive aspects of placebo and that it needs to be viewed as an integral part of the treatment rather than an aspect that should be isolated and discounted.” [p. 13] This is interesting. It comes very close (here and elsewhere) to admitting that all you get is a placebo effect, and that this doesn’t matter. This contradicts directly the first recommendation of the House of Lords report (2000).. Both the House of Lords report on Complementary and Alternative Medicine, and the Government’s response to it, state clearly “. . . we recommend that three important questions should be addressed in the following order”. (1) does the treatment offer therapeutic benefits greater than placebo? (2) is the treatment safe? (3) how does it compare, in medical outcome and cost-effectiveness, with other forms of treatment?. The crunch comes when the report gets to what we should pay for. “Should we be prepared to pay for the so-called placebo effect? The view of the advisory group is that it is appropriate to pay for true placebo (rather than regression to the mean or temporal effects).” [p 24] Perhaps so, but there is very little discussion of the emormous ethical questions:that this opinion raises: • How much is one allowed to lie to patients in order to elicit a placebo effect? • Is is OK if the practitioner believes it is a placebo but gives it anyway? • Is it OK if the pratitioner believes that it is not a placebo when actually it is? • Is it OK for practitioners to go degrees taught by people who believe that it is not a placebo when actually it is? The report fails to face frankly these dilemmas. The present rather absurd position in which it is considered unethical for a medical practitioner to give a patient a bottle of pink water, but perfectly acceptable to refer them to a homeopath. There is no sign either of taking into account the cultural poison that is spread by telling people about yin, yang and meridians and such like preposterous made-up mumbo jumbo. That is part of the cost of endorsing placebos. And just when one thought that believing things because you wished they were true was going out of fashion Once again we hear a lot about the alleged difficulties posed by research on alternative medicine. These alleged difficulties are, in my view, mostly no more than excuses. There isn’t the slightest difficulty in testing things like herbal medicine or homeopathy, in a way that preserves all the ‘context’ and the ways of working of homeopaths and herbalists. Anyone who reads the Guardian knows how to do that. In the case of acupuncture, great ingenuity has gone into divising controls. The sham and the ‘real’ acupuncture always come out the same. In a non-blind comparison between acupuncture and no acupuncture the latter usually does a bit worse, but the effects are small and transient and entirely compatible with the view that it is a theatrical placebo. Despite these shortcomings, some of the conclusions [p. 22] are reasonable. “The public needs more robust evidence to make informed decisions about the use of complementary practice. Commissioners of public health care need more robust evidence on which to base decisions about expenditure of public money on complementary practice.” What the report fails to do is to follow this with the obvious conclusion that such evidence is largely missing and that until such time as it is forthcoming there should be no question of the NHS paying for alternative treatments. Neither should there be any question of giving them official government recognition in the form of ‘statutory regulation’. The folly of doing that is illustrated graphically by the case of chiropractic which is now in deep crisis after inspection of its claims in the wake of the Simon Singh defamation case. Osteopathy will, I expect, suffer the same fate soon. In the summary on p.12 we see a classical case of the tension Controlled trials of effectiveness and cost-effectiveness are of primary importance We recognise that it is the assessment of effectiveness that is of primary importance in reaching a judgement of different practices. Producing robust evidence that something works in practice – that it is effective – should not be held up by the inevitably partial findings and challenged interpretations arising from inquiries into how the intervention works. The headline sounds impeccable, but directly below it we see a clear statement that we should use treatments before we know whether they work. “Effectiveness”, in the jargon of the alternative medicine business, simply means that uncontrolled trials are good enough. The bit about “how it works” is another very common red herring raised by alternative medicine people. Anyone who knows anything about pharmacology that knowledge about how any drug works is incomplete and often turns out to be wrong. That doesn’t matter a damn if it performs well in good double-blind randomised controlled trials. One gets the impression that the whole thing would have been a lot worse without the dose of reality injected by Richard Lilford. He is quoted as a saying “All the problems that you find in complementary medicine you will encounter in some other kind of treatment … when we stop and think about it… how different is it to any branch of health care – the answer to emerge from our debates is that it may only be a matter of degree.” [p. 17] I take that to mean that alternative medicine poses problems that are no different from other sorts of treatment. They should be subjected to exactly the same criteria. If they fail (as is usually the case) they should be rejected. That is exactly right. The report was intended to produce consensus, but throughout the report, there is a scarcely hidden tension between believers on one side, and Richard Lilford’s impeccable logic on the other. ### Who are the King’s Fund? The King’s Fund is an organisation that states its aims thus. “The King’s Fund creates and develops ideas that help shape policy, transform services and bring about behaviour change which improve health care.” It bills this report on its home page as “New research methods needed to build evidence for the effectiveness of popular complementary therapies”. But in fact the report doesn’t really recommend ‘new research methods’ at all, just that the treatments pass the same tests as any other treatment. And note the term ‘build evidence’. It carries the suggestion that the evidence will be positive. Experience in the USA (and to a smaller extent in the UK) suggests that every time some good research is done, the effect is not to ‘build evidence’ but for the evidence to crumble further If the advice is followed, and the results are largely negative, as has already happened in the USA, the Department of Health would look pretty silly if it had insisted on degrees and on statutory regulation. The King’s Fund chairman is Sir Cyril Chantler and its Chief Executive is Niall Dickson. It produces reports, some of which are better than this one. I know it’s hard to take seriously an organisation that wants to “share its vision” withyou, but they are trying. “The King’s Fund was formed in 1897 as an initiative of the then Prince of Wales to allow for the collection and distribution of funds in support of the hospitals of London. Its initial purpose was to raise money for London’s voluntary hospitals,” It seems to me that the King’s Fund is far too much too influenced by the present Prince of Wales. He is, no doubt, well-meaning but he has become a major source of medical misinformation and his influence in the Department of Health is deeply unconstitutional. I was really surprised to see thet Cyril Chantler spoke at the 2009 conference of the Prince of Wales Foundation for Integrated Health, despite having a preview of the sort of make-believe being propagated by other speakers. His talk there struck me as evading all the essential points. Warm, woolly but in the end, a danger to patients. Not only did he uncritically fall for the spin on the word “integrated”, but he also fell for the idea that “statutory regulation” will safeguard patients. Revelation of what is actually taught on degrees in these subjects shows very clearly that they endanger the public. But the official mind doesn’t seem ever to look that far. It is happy ticking boxes and writing vacuous managerialese. It lacks curiosity. ### Follow-up The British Medical Journal published today an editorial which also recommends rebranding of ‘pragmatic’ trials. No surprise there, because the editorial is written by Hugh MacPherson, senior research fellow, David Peters, professor of integrated healthcare and Catherine Zollman, general practitioner. I find it a liitle odd that the BMJ says “Competing Interests: none. David Peters interest is obvious from his job description. It is less obvious that Hugh MacPherson is an acupuncture enthusiast who publishes mostly in alternative medicine journals. He has written a book with the extraordinary title “Acupuncture Research, Strategies for Establishing an Evidence Base”. The title seems to assume that the evidence base will materialise eventually despite a great deal of work that suggests it won’t. Catherine Zollman is a GP who is into homeopathy as well as acupuncture. All three authors were speakers at the Prince of Wales conference, described at Prince of Wales Foundation for magic medicine: spin on the meaning of ‘integrated’. The comments that follow the editorial start with an excellent contribution from James Matthew May. His distinction between ‘caring’ and ‘curing’ clarifies beautifully the muddled thinking of the editorial. Then a comment from DC, If your treatments can’t pass the test, the test must be wrong. It concludes “At some point a stop has to be put to this continual special pleading. The financial crisis (caused by a quite different group of people who were equally prone to wishful thinking) seems quite a good time to start.” This post has been translated into Belorussian.. Chinese medicine and herbal medicine are in the news at the moment. There is a real risk that the government could endorse them by accepting the Pittilo report. In my view traditional Chinese medicine endangers people. The proposed ‘regulation’ would do nothing to protect the public. Quite on the contrary, it would add to the dangers, by giving an official stamp of approval while doing nothing for safety. The government’s idea of improving safety is to make sure that practitioners are ‘properly trained’. But it is the qualifications that cause the danger in the first place. The courses teach ideas that are plain wrong and often really dangerous. Why have government (and some universities) not noticed this? That’s easy to see. Governments, quangos and university validation committees simply don’t look. They tick boxes but never ask what actually goes on. Here’s some examples of what goes on for them to think about. They show clearly the sort of dangerous rubbish that is taught on some of these ‘degrees’. These particular slides are from the University of Westminster, but similar courses exist in only too many other places. Watch this space for more details on courses at Edinburgh Napier University, Middlesex University and the University of East London Just a lot of old myths. Sheer gobbledygook, SO much for a couple of centuries of physiology, It gets worse. Plain wrong. Curious indeed. The fantasy gobbledygook gets worse. Now it is getting utterly silly. Teaching students that the brain is made of marrow is not just absurd, but desperately dangerous for anyone unlucky (or stupid) enough to go to such a person when they are ill. Here’s another herbal lecture., and this time the topic is serious. Cancer. ### Herbal approaches for patients with cancer. I’ve removed the name of the teacher to spare her the acute embarrassment of having these dangerous fantasies revealed. The fact that she probably believes them is not a sufficient excuse for endangering the public. There is certainly no excuse for the university allowing this stuff to be taught as part of a BSc (Hons). First get them scared with some bad statistics. No fuss there about distinguishing incidence, age-standardisation and death rates. And no reference. Perhaps a reference to the simple explanation of statistics at Cancer Research UK might help? Perhaps this slide would have been better (from CDC). Seems there is some mistake in slide 2. Straight on to a truly disgraceful statement in slide 3 The is outrageous and very possibly illegal under the Cancer Act (1939). It certainly poses a huge danger to patients. It is a direct incentive to make illegal, and untrue claims by using weasel words in an attempt to stay just on the right side of the law. But that, of course, is standard practice in alternative medicine, Slide 11 is mostly meaningless. “Strengthen vitality” sounds good but means nothing. And “enhancing the immune system” is what alternative medicine folks always say when they can think of nothing else. Its meaning is ill-defined and there is no reason to think that any herbs do it. The idea of a ‘tonic’ was actually quite common in real medicine in the 1950s. The term slowly vanished as it was realised that it was a figment of the imagination. In the fantasy world of alternative medicine, it lives on. Detoxification, a marketing term not a medical one, has been extensively debunked quite recently. The use of the word by The Prince of Wales’ company, Duchy Originals recently fell foul of the Advertising Standards Authority, and his herbal ‘remedies’ were zapped by the MHRA (Medicines and Health Regulatory Authority). And of course the antioxidant myth is a long-disproved hypothesis that has become a mere marketing term. “Inhibits the recurrence of cancer”! That sounds terrific. But if it is so good why is it not even mentioned in the two main resources for information about herbs? In the UK we have the National Library for Health Complementary and Alternative Medicine Specialist Library (NeLCAM), now a part of NHS Evidence. It was launched in 2006. The clinical lead was none other than Peter Fisher, clinical director of the Royal London Homeopathic Hospital, and the Queen’s homeopathic physician. The library was developed with the School of Integrated Health at the University of Westminster (where this particular slide was shown to undergraduates). Nobody could accuse these people of being hostile to magic medicine, It seems odd, then, that NeLCAM does not seem to thnk to think that Centella asiatica, is even worth mentioning. In the USA we have the National Center for Alternative and Complementary Medicine (NCCAM), an organisation that is so friendly to alternative medicine that it has spent a billion dollars on research in the area, though it has produced not a single good treatment for that vast expenditure. But NCCAM too does not even mention Centella asiatica in its herb list. It does get a mention in Cochrane reviews but only as a cosmetic cream and as an unproven treatment for poor venous circulation in the legs. What on earth is a “lymph remedy”. Just another marketing term? especially valuable in the treatment of breast, throat and uterus cancer. That is a very dramatic claim. It as as though the hapless students were being tutored in doublespeak. What is meant by “especially valuable in the treatment of”? Clearly a desperate patient would interpret those words as meaning that there was at least a chance of a cure. That would be a wicked deception because there isn’t the slightest reason to think it works. Once again there this wondrous cure is not even mentioned in either NELCAM or NCCAM. Phytolacca is mentioned, as Pokeweed, in Wikipedia but no claims are mentioned even there. And it isn’t mentioned in Cochrane reviews either. The dramatic claims are utterly unfounded. Ah the mistletoe story, again. NHS Evidence (NeLCAM) lists three completed assessments. One concludes that more research is needed. Another concludes that “Rigorous trials of mistletoe extracts fail to demonstrate efficacy of this therapy”, and the third says “The evidence from RCTs to support the view that the application of mistletoe extracts has impact on survival or leads to an improved ability to fight cancer or to withstand anticancer treatments is weak”. NCCAM says of mistletoe • More than 30 human studies using mistletoe to treat cancer have been done since the early 1960s, but major weaknesses in many of these have raised doubts about their findings (see Question 6). • Very few bad side effects have been reported from the use of mistletoe extract, though mistletoe plants and berries are poisonous to humans (see Question 7). • The U.S. Food and Drug Administration (FDA) has not approved mistletoe as a treatment for cancer or any other medical condition (see Question 8). • The FDA does not allow injectable mistletoe to be imported, sold, or used except for clinical research (see Question 8). Cochrane reviews lists several reviews of mistletoe with similar conclusions. For example “The evidence from RCTs to support the view that the application of mistletoe extracts has impact on survival or leads to an improved ability to fight cancer or to withstand anticancer treatments is weak”. Anthroposophy is one of the highest grades of fantasy you can find. A post on that topic is in the works. Indicated for cancers . . . colon/rectal, uterine, breast, lung“. A cure for lung cancer? That, of course, depends on how you interpret the weasel words “indicated for”. Even Wikipedia makes no mention of any claims that Thuja benefits cancer. NHS Evidence (NeLCAM) doesn’t mention Thuja for any indication. Neither does NCCAM. Nor Cochrane reviews. That is not the impression the hapless students of this BSc lecture were given. In my view suggestions that you can cure lung cancer with this tree are just plain wicked. Pure snake oil, and not even spelled correctly, Harry Hoxsey’s treatment centres in the USA were closed by court order in the 1950s. At least this time it is stated that there is no hard evidence to support this brand of snake oil. More unfounded claims when it says “treated successfully many cancer patients”. No references and no data to support the claim. It is utterly unfounded and claims to the contrary endanger the public. Gerson therapy is one of the most notorious and unpleasant of the quack cancer treatments. The Gerson Institute is on San Diego, but their clinics are in Mexico and Hungary. It is illegal in the USA. According to the American Cancer Society you get “a strict low-salt, low-fat, vegetarian diet and drinking juice from about twenty pounds of fresh fruits and vegetables each day. One glass of juice is consumed each hour, thirteen times a day. In addition, patients are given several coffee enemas each day. Various supplements, such as potassium, vitamin B12, pancreatic enzymes, thyroid hormone, and liver extracts, are used to stimulate organ function, particularly of the liver and thyroid.”. At one time you also got several glasses of raw calf liver every day but after infections killed several people] carrot juice was given instead. Cancer Research UK says “there is no evidence to show that Gerson therapy works as a cure for cancer”, and “The Gerson diet can cause some very serious side effects.” Nobody (except perhaps the Price of Wales) has any belief in this unpleasant, toxic and expensive folk-lore. Again patients are endangered by teaching this sort of stuff. And finally, the usual swipe at vaccines. It’s nothing to do with herbalism. but just about every alternative medicine advocate seems to subscribe to the anti-vaccination lobby.. It is almost as though they have an active preference for things that are known to be wrong. They seem to believe that medicine and science are part of an enormous conspiracy to kill everyone. Perhaps this dangerous propaganda might have been ameliorated if the students had been shown this slide (from a talk by Melinda Wharton). Click to enlarge Left to people like this, we would still have smallpox, diphtheria. tetanus and rabies, Take a look at Vaccine-preventable diseases. This is the sort of ‘education’ which the Pittilo report wants to make compulsory. Smallpox in Baltimore, USA, 1939. This man was not vaccinated. ### Conclusion This selection of slides shows that much of the stuff taught in degrees in herbal medicine poses a real danger to public safety and to public health. Pittilo’s idea that imposing this sort of miseducation will help safety is obviously and dangerously wrong. The Department of Health must reject the Pittilo recommendations on those grounds. ### Follow-up Jump to follow-up 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]. • What is taught in degrees in herbal and traditional Chinese medicine? [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