Download Lectures on Biostatistics (1971). Corrected and searchable version of Google books edition
Download review of Lectures on Biostatistics (THES, 1973).
Monthly Archives: October 2009
This is a post about Markovian queuing theory. But hang on, don’t run away. It isn’t so hard.
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The idea came from my recent experience. On Friday 23 October, I was supposed to have a kidney removed at the Royal Marsden Hospital. At the very last minute the operation was cancelled. That is more irritating than serious. A delay of a few weeks poses no great risk for me. . |
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The cancellation arose because there was no bed available in the High Dependency Unit (HDU), which is where nephrectomy patients go for a while after the operation. Was this a failure of the NHS? I think not and here’s why
The first reaction of a neighbour to this news was to say "that’s why I have private insurance". Well, wrong actually. For a start, at the Marsden private patients and NHS patients get identical treatment (the only difference on the NHS is that "you don’t get hot and cold running margaritas at your bedside", my surgeon said). And secondly, the provision of emergency beds poses a really difficult problem, which I’ll attempt to explain.
Bed provision raises a fascinating statistical question. How many beds must be available to make sure nobody is ever turned away? The answer, in principle, is an infinite number. In practice it is more than anyone can afford.
The HDU has eleven beds but let’s think about a simpler case to start with. If patients arrived regularly at a fixed rate, and each patient stayed for a fixed length of time. there would be no problem. Say, for example, that a patient arrived regularly at 10 am and 4 pm each day, and suppose that each patient stayed for exactly 46 hours. It’s pretty obvious that you’d need four beds. Each bed could take a patient every two days and there are two patients per day coming in. Allowing two hours for changing beds, all four beds would be occupied for essentially 100 percent of the time, actually 95% = 46 hours/48 hours).
Random arrivals
The problem arises because patients don’t arrive regularly and they don’t stay for a fixed length of time. What happens if patients arrive at random and stay for a random length of time? (We’ll get back to the meaning of ‘random’ in this context later.)
Suppose again that two patients per day arrive on average, and that each patient stays in the HDU for 46 hours on average. So the mean arrival rate, and the mean length of stay in the HDU are the same as in the first example. When there was no randomness, four beds coped perfectly.
But with random arrivals and random length of stay the situation is very different. With four beds, if a queue were allowed to build up, the average number of patients in the queue would be 21 and the average length of time a patient would spend waiting to get a bed would be 10.5 days. This would be an efficient use of resources because every time a bed was vacated it would be filled straight away from the queue. The resources would be used to the maximum possible extent:, 95%. But it would be terrible for patients. The length of the queue would, of course, fluctuate, as shown by this distribution (see below) of the queue length. Occasionally it might reach 100 or more.
The histogram shows the total number of people in the system.The first five bins (red) represent the probabilities of 0, 1, 2, 3 or 4 beds being occupied. All the rest are in the queue.
What if you can’t queue?
For a High Dependency Unit or an Intensive Care Unit you can’t have a queue. If there is no bed, you are turned away. In the example just described, 91% of patients would have to wait, and that’s impossible in an HDU or ICU. The necessary statistical theory has been done for this case too (it is described as having zero queue capacity). Let’s look at the same case, with 4 beds, mean time between arrival of patients, 0.5 days, mean length of stay 1.917 days (46 hours).
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In this case there is no queue so the only possibilities are that 0, 1, 2, 3 or all 4 beds are occupied. The relative probabilities of these cases are shown on the right (they add up to 100% because there are no other possibilities). |
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Despite the pressure on the unit, the randomness ensures that beds are by no means always occupied. All four are occupied for only 29% of the time and the average occupancy is 2.7 so the resources are used only 68% of the time (rather than 95% when a queue was allowed to form). Worse still, there is a 29% chance of the system being full, so you would be turned away.
So how many beds do you need? Clearly the more beds you have, the smaller the chance of anyone being turned away. But more beds means more cost and less efficiency. This is how it works out in our case.
To get the chance of being turned away below 5%, rather than 29%, you’d have to double the number of beds from 4 to 8. But in doing so the beds would not be in use 68% of the time as with 4 beds, but for only 47% of the time.
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Looked at another way, if you try to increase the utilisation of beds, above 50 or 60%, then the rate at which patients get turned away goes shooting up exponentially. |
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This isn’t inefficiency. It is an inevitable consequence of randomness in arrival times and lengths of stay.
A real life example
McManus et al. (2004) looked at all admissions to the medical–surgical Intensive Care Unit (ICU) of a large, urban children’s hospital in the USA during a 2-year period. (Anesthesiology 2004; 100:1271–6. Download pdf). Their Figure 2 shows the monthly average rejection rates mostly vary between 10 and 20%, so there is nothing unusual in there being no bed available in the private US medical system. For a period the rate of rejection reaches disastrous values, up to 47%. This happens, unsurprisingly, at times when the utilisation of beds was high.
The observed relationship (McManus, Fig. 3) is very much as predicted above.with a very steep (roughly exponential) rise in rejection rate when the beds are in use for more than half the time.
How to do the calculations
You can get the message without reading this section. It’s included for those who want to know a bit more about what we mean when we say that patients arrive at random rather than at fixed intervals, and that durations of stay in the unit have random rather than fixed durations.
Consider the durations of stay in the unit. They are variable in length and the usual way to represent variability is to plot a distribution of the variable quantity. The best known sort of probability distribution is the bell-shaped curve known as the Gaussian distribution. This is shown at the top of the Figure (note that pdf stands for probability density function, not portable document format).
Not every sort of variability is described by a symmetrical bell-shaped curve. Quite often distributions with a positive skew are seen, like the middle example in the Figure. The distribution of incomes in the population have this sort of shape. Notice that more people earn less than average than earn more than average (the median is less than the mean). This can happen because those that earn less than average can’t get much less than average (unless we allow negative incomes), whereas bankers can earn (or at least be paid) a great deal more than average. The most frequent income (the peak of the distribution) is still smaller than the median.
An extreme form of a positively-skewed distribution is shown at the bottom. It is called the exponential distribution (because it has the shape of a decaying exponential curve). If this described personal incomes (and we are heading that way) it would mean that the most frequent income was zero and 63.2% of people earn less than average.
It is this last, rather unusual, sort of distribution that, in the simplest case, describes the lengths of random time intervals. This is getting very close to my day job. If an ion channel has a single open state, the lengths of individual ion channel openings is described by an exponential distribution.
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The observation of an exponential distribution of durations is what would be predicted for a memoryless process, or Markov process. In the case of an ion channel, memoryless means that the probability of the channel shutting in the next microsecond is the same however long the channel has been open, This is exactly analogous to the fact that the probability of throwing a six with a die is exactly the same at each throw, regardless of how many sixes have been thrown before. |
Andrei A. Markov, 1856-1922 |
It is the simplest definition of a random length of time. For those who have done a bit of statistics, it is worth mentioning that if the number of events per unit time is described by a Poisson distribution, then the interval between events are exponentially-distributed. They are different ways of saying the same thing.
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The lengths of stays in ICU in the McManus paper were roughly exponentially-distributed (right). The monthly average duration of stay ranged from 2.4 to 5.5 days, and average monthly admission rates to the 18 bed unit ranged from 4.6 to 6.2 patients per day. |
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The monthly average percentage of patients who were turned away because there were no vacant beds varied widely, ranging from 3% up to a disastrous 47%
A technical note and an analogy with synapses
It’s intriguing to note that, in the simplest case, the time you’d spend waiting in a queue would have a simple exponential distribution (plus a discrete bit for the times when you don’t have to wait at all). The time you have to wait is the sum of all the lengths of stay of the people in front of you, and each of these lengths, in the case we discussing, is exponentially-distributed. If the queue was constant in length you can use a mathematical method known as convolution to show that the distribution of waiting time would follow a gamma distribution, a sort of distribution that goes through a peak, and eventually becomes Gaussian for long queues), However the queue is not fixed in length but its length is random (geometrically-distributed). It turns out that the distribution of the sum of a random number of exponentially distributed times is itself exponential. It is precisely this beautiful theorem that shows why the length of a burst of ion channel openings (which consists of the sum of a random number of exponentially-distributed open times, if you neglect the time spent in short shuttings) is, to a good approximation itself exponential, And that explains why the decay of synaptic currents is often close to following a simple exponential time course.
The calculations
The calculations for these graphs were done with a set of Excel add-in functions, Queueing Toolpak 4.0, which can be downloaded here. If this had been a paper of my own, rather than a blog post written in one weekend, I’d have done the algebra myself, just to be sure, The theory has much in common with that of single ion channels. Transitions between different states of the system can be described by transition rates or probabilities that don’t vary with time. The table, or matrix, of transition probabilities can be used to calculate the results, And if you want to know about the algebra of matrices, you could always apply for our summer workshop. There are some pictures from the workshop here.
Follow-up
Of course it is quite impossible for anyone who was around in the 60s to hear the name of a Russian mathematician without thinking of Tom Lehrer’s totally unjustified slur on another great Russian mathematician, Nicolai Ivanovich Lobachevsky. If you’ve never heard ‘Plagiarize’, you can hear it on Youtube. Sheer genius.
Why the size of the unit matters
This section was added as a result of a comment, below, from a statistician
At first glance one might think that if we quadruple the number of beds to 16 beds rather than 4, and we also quadruple the arrival rate to 8 rather than 2 per day, then the arrival rate per bed is the same and one might expect everything would stay the same.
As you say, it doesn’t.
If queueing was allowed, the mean queue length would be only slightly shorter, 18,7 rather than 20.9, but the mean time spent in the queue would fall from 10.5 days to 2.3 days.
In the more realistic case, with no queuing allowed, the rejection rate would fall from 29.4% to 15.5% and bed utilisation would increase from 68% to 81%. The rejection rate seems to fall roughly as the square root of the number of beds.
Clearly there is an advantage to having a big hospital with a big HDU.
Stochastic processes quite often behave unintuitive ways (unless you’ve spent years developing the right intuition).
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.
They also validate the International Academy of Osteopathy, Ghent (Belgium), Osteopathie Schule Deutschland, the Istituto Superiore Di Osteopatia, Milan, the Instituto Superior De Medicinas Tradicionales, Barcelona, the Skandinaviska Osteopathögskolan (SKOS) Gothenburg, Sweden and the College D’Etudes Osteopathiques, Canada.
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.
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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
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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.
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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 Materia Medica 3 HRB08103 Clinical Medicine and Diagnosis 4 (HRB09104) HRB09100 Materia Medica & Herbal Practice BSc Herbal Medicine : Materia Medica HRB07102 Lastly, I can see nowhere in the timetable, lectures that deal with Research methods, clinical trial design and statistics. |
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!
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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 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.
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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
https://www.dcscience.net/?p=1950
Consultation opens on the Pittilo report: help top stop the Department of Health making a fool of itself
https://www.dcscience.net/?p=2007
Why degrees in Chinese medicine are a danger to patients
https://www.dcscience.net/?p=2043
More make-believe from the University of Westminster. This time its Naturopathy
https://www.dcscience.net/?p=1812
The last BSc (Hons) Homeopathy closes! But look at what they still teach at Westminster University.
https://www.dcscience.net/?p=1329
The opposite of science
https://www.dcscience.net/?p=1191
Bad medicine. Barts sinks further into the endarkenment.
https://www.dcscience.net/?p=1143
A letter to the Times, and progress at Westminster
https://www.dcscience.net/?p=984
Nutritional Fairy Tales from Thames Valley University
https://www.dcscience.net/?p=260
Westminster University BSc: amethysts emit high yin energy
https://www.dcscience.net/?p=227
References for Pittilo report consultation
A very bad report: gamma minus for the vice-chancellor
https://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
https://www.dcscience.net/?p=251
The Health Professions Council breaks its own rules: the result is nonsense
https://www.dcscience.net/?p=1284
One month to stop the Department of Health endorsing quackery. The Pittilo questionnaire,
https://www.dcscience.net/?p=2310
An excellent submission to the consultation on statutory regulation of alternative medicine (Pittilo report)
https://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.
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Executive Summary
Instead, safe regulation of alternative practitioners should be through:
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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.
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“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 https://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
https://www.dcscience.net/?p=251
The Health Professions Council breaks its own rules: the result is nonsense
https://www.dcscience.net/?p=1284
Chinese medicine -acupuncture gobbledygook revealed
https://www.dcscience.net/?p=1950
Consultation opens on the Pittilo report: help top stop the Department of Health making a fool of itself https://www.dcscience.net/?p=2007
Why degrees in Chinese medicine are a danger to patients https://www.dcscience.net/?p=2043
One month to stop the Department of Health endorsing quackery. The Pittilo questionnaire, https://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..