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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  https://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 https://www.dcscience.net/?p=215#sfh, but are still preposterous make believe.

9. A very bad report: gamma minus for the vice-chancellor

10. A Patients’ Guide to Magic Medicine,  and also in the Financial Times.

11.  An excellent submission to the consultation on statutory regulation of alternative medicine (Pittilo report)

12.  NICE fiasco, part 2. Rawlins should withdraw guidance and start again

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”. https://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.

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.

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
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.

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 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..

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

slide 1

Just a lot of old myths. Sheer gobbledygook,

slide 2

SO much for a couple of centuries of physiology,

slide 7

It gets worse.

slide 8

Plain wrong.

slide 21

Curious indeed.  The fantasy gobbledygook gets worse.

slide 16

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).

slide 1

First get them scared with some bad statistics.

slide 2

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.

cance death rates

Straight on to a truly disgraceful statement in slide 3

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

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. 

 

slide 16

“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.

slide 21

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.

slide 23

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.

slide 25

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.

slide 27

Pure snake oil, and not even spelled correctly, Harry Hoxsey’s treatment centres in the USA were closed by court order in the 1950s.

slide 28

At least this time it is stated that there is no hard evidence to support this brand of snake oil.

slide 30

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.

slide 31

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.

slide 36

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).

Wharton slide 2
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.

Baltimore smallpox, 1939
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”.

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.

Q1

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

Q5

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”.

TCM slide 2

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.

TCM slide 1

There are more mind-boggling slides from lectures on Chinese medicine and cancer: they show that what students are being taught is terrifyingly dangerous to patients.

It is entirely unacceptable that students are being taught these ancient myths as though they were true, and being encouraged to treat sick people on their basis.  The effect of the Pittilo recommendations would be to force new generations of students to have this sort of thing forced on them.  In fact the course for which this exam was set has already closed its doors.  That is the right thing to do.

Here’s another example. The course leader for “BSc (Hons) Herbal Medicine” at the Univsrsity of Central Lancashire is Graeme Tobyn BA. But Tobyn is not only a herbalist but also an astrologer. In an interview he said

“At the end I asked her if I could cast her horoscope. She threw up her hands and said, ‘I knew this would happen if I came to an alternative practitioner.”

“I think the ruler of the ascendant was applying to Uranus in the ninth house, which was very pertinent.”

This would be preposterous even in the life style section of a downmarket women’s magazine,  The Pittilo report wants to make degrees run my people like this compulsory. Luckily the Univerity of Central Lancashire is much more sensible and the course is being closed.

The matter is, in any case, being taken out of the hands of the government by the fact that universities are closing degrees in complementary medicine, including courses in some of those under discussion here, The University of Salford and the University of Central Lancashire have recently announced the closure of all the degree programmes in complementary and alternative medicine. The largest provider of such degrees, the University of Westminster has already shut down two of them, and the rest are being assessed at the moment. It is likely that the rest will be closed in the future.

The revelation that Westminster had been teaching its first year students that “amethysts emit high yin energy” and that students had been taught to diagnose disease and choose treatments by means of a dowsing pendulum, showed very clearly the sort of utter nonsense that undergraduates were being forced to learn to get a ‘bachelors degree with honours’. It stretches credulity to its limits to imagine that the public is protected by degrees like this. Precisely the opposite is true. The universities have recognised this, and shut the degrees. One exception is Professor Pittilo’s own university which continues to run a course in homeopathy, the most discredited of all the popular types alternative medicine.

A simpler, more effective and cheaper way to protect the public

I must certainly agree with the minister that protection of the public is an important matter. Having established that the Pittllo recommendations are more likely to endanger the public than protect them, it is essential to suggest alternative proposals that would work better.

Luckily, that is easy, because mechanisms already exist for dealing with the dangers that were listed above. The matter of adulteration, which is serious in traditional Chinese medicine, is a matter that is already the responsibility of the Office of Trading Standards. The major problem of false claims being made for treatment is also the responsibility of the Office of Trading Standards, which has a statutory duty to enforce the Unfair Trading Consumer Protection Regulations of May 2008. These laws state, for example, that

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

The monitoring of false claims, and of side effects of treatments, is also the responsibility of the Medicines and Health Regulatory Authority (MHRA).

Rather than setting up complicated, expensive and ineffective ‘regulation’ by the HPC, all that need to be done is to ensure that the MHRA and/or Trading Standards have the funds to enforce existing laws. At the moment, they are not being implemented effectively, so I’d recommend that responsibility for enforcing the law against false health claims be transferred entirely to the MHRA, which has much more expertise in such matters than Trading Standards This would be both cheaper and more effective than the present system in which the responsibility is divided between the two organisations in an unclear way.

This proposal would protect the public against unsafe and adulterated treatments, and it would protect the public against false and fraudulent claims. That is what matters. It would do so more effectively,
more cheaply and more honestly than the Pittilo recommendations. There would be no reduction in patient choice either, There is no proposal to ban acupuncture, herbal medicine or traditional Chinese medicine. All that is necessary is to ensure that they don’t endanger the public.

Since the root of the problem lies in the fact that the evidence for the effectiveness is very weak. the question of efficacy, and cost-benefit ratio, should be referred to NICE. This was recommended by the House of Lords Report (2000). It is recommended again by the Smallwood report (sponsored by the Prince of Wales Foundation). It is baffling that this has not been done already. It does not seem wise to spend large amounts of money on new research at the moment, in the light of the fact that the US National Institutes of Health has already spent over $1 billion on such research without finding a single useful treatment.

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

Conclusion

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

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

In the Independent, Dominic Lawson wrote

So now we will have degrees in quackery.

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

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

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

Follow-up

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

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

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

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

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

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

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

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

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

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

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

Q1

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

Q5

Oh really. Perhaps protons neutrons and electrons?

Q22

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

Q23

Perhaps an elementary textbook of embryology would help?

Q24

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

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

NICE neglected the cultural cost of their guidance

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

Pittilo and statutory regulation

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

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

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

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

Follow-up

Jump to follow-up

.The University of Central Lancashire (UCLAN) is the first place I asked to see teaching materials that were used on its homeopathy “BSc” course. The request was refused, and subsequent internal appeals were refused too, Clearly UCLAN had something to hide.

UClan-logo

An appeal to the information commissioner took almost two years to be judged, but the case was won. The eventual decision by the Information
Commissioner rejected all the grounds that UClan had used to evade the Freedom of Information Act.

UClan appealed against the judgement and I still haven’t got the stuff but that hardly matters now, because the course in question shut its doors. In any case, plenty of stuff from similar courses has leaked out already.

Meanwhile, in September 2008, UCLAN announced an internal review of all its courses in magic medicine, The review seemed to be genuine. For a start they asked me to give evidence to the review (something that no other university has done). They also asked Michael Eslea to give evidence. He is the UCLAN psychologist, whose magnificent open letter probably tipped the authorities into holding the review.

Just in case it is useful to anyone, here is a copy of the written evidence that I sent [download pdf],

Report of the Working Party on the Review of issues associated with Homeopathy, Acupuncture and Chinese Herbal Medicine

1. Introduction

As a consequence of concerns expressed by some colleagues within the University of Central Lancashire (UCLan) Dr Malcolm McVicar, Vice Chancellor appointed a working party to review the issues associated with the University offering courses in Homeopathy, Acupuncture and Chinese Herbal Medicine.

MEMBERSHIP:

Eileen Martin (Chair)                Pro-Vice Chancellor and Dean of Faculty of Health and Social Care 
Professor Gordon Bromage      Head of Centre for Astrophysics
Professor Malcolm Edmunds    Emeritus; Built and Natural Environment
Professor Doris Schroeder        Director of Centre for Professional Ethics
Elaine Austin                               Project Manager, Faculty of Health and Social Care


The report was the subject of a special meeting of UCLAN’s Academic Board on 9th July 2009. The following resolutions were passed.

Resolutions

R1    That further minor revisions be made to the report prior to publication on the University’s website;

R2   That the University refrain from offering any practitioner-qualifying courses in Homeopathy, Acupuncture and Chinese Herbal Medicine until such disciplines have achieved statutory regulation status;

R3    That the University consider offering a limited number of postgraduate research studentships (leading to Masters by Research of PhD) to suitably qualified UCLan students and staff in these disciplines. They should have interdisciplinary supervisory teams to facilitate development of a broad range of research skills and to contribute to the generation of knowledge in CAM;

R4   That the University consider how more interdisciplinary teaching can be achieved, where appropriate, within both undergraduate and postgraduate teaching to facilitate greater exposure to subject expertise and different paradigms.

Resolutions 1, 3 and 4 say very little. Resolution 4 sounds thoroughly relativist. We are talking about medicine, about treating sick patients. There is only one “paradigm”. That is to find treatments that are as effective and safe as possible. There aren’t two sorts of medicine, regular and alternative. There is just medicine that works and medicine that doesn’t work. It’s a good illustration of DC’s rule number 2, “never trust anyone who uses the word paradigm”.

Resolution 2 is the really interesting one, because none if the topics, Homeopathy, Acupuncture and Chinese Herbal Medicine, is subject to statutory regulation.

If taken literally, resolution 2 means that all the UCLan courses in alternative medicine will close their doors. Bafflingly, this inevitable conclusion is not stated explicitly.

At least resolution 2 means that homeopathy, already closed, will stay closed. It is never likely to get statutory regulation.

For practical purposes, we can ignore for the moment the obvious fact that statutory regulation of nonsense subjects results only in nonsense. The only forms of alternative medicine that have got “statutory regulation” at the moment are chiropractic and osteopathy. The public has not been safeguarded by the General Chiropractic Council (GCC). The GCC, on the contrary, has endangered the public by allowing false health claims to be made with impunity. Perhaps the members of the review committee had not noticed that the Simon SIngh affair has resulted in almost 600 complaints being made to the GCC? The faith of the review in statutory regulation is clearly misplaced.

The Pittilo report is critical for what happens next

Acupuncture and Chinese Herbal Medicine are not subject to statutory regulation at present, so one would suppose that these degrees will close their doors too. However the infamous Pittilo report has proposed that they should become regulated by the Health Professions Council (HPC). The many problems of the Pittilo report have been documented here, in “A very bad report: gamma minus for the vice-chancellor“. There was also a high-profile critique of the report in The Times (and on this blog).

The HPC has, as one of its criteria for regulation, “evidence-based practice”. Disgracefully, the HPC has already shown its willingness to ignore its own rules and to act as statutory regulator for Acupuncture and Chinese Herbal medicine. This rather disgraceful behaviour is documented in “Health Professions Council ignores its own rules: the result is nonsense“.

The UCLAN report seems to assume that the recommendations of the Pittilo report will be accepted. But the long-awaited consultation has still not opened. We can be sure that when it does, the opposition to it will be very strong indeed.

The report in full

Here are a few comments on the report itself.    Download the full report (as of July 15th).

i have to say that when I visited Preston to give evidence, my views seem to be treated seriously, even sympathetically, so it was a great disappointment to see the outcome. So what’s wrong? The major disaster is declared early in the report.

Section 2, Context

The debate is centred on a number of key themes which relate to:-

1. The quality of and/or absence of an evidence base to support claims of the efficacy and benefits of such treatments, linked to issues of public safety/protection and professional regulation.

Sounds good. What matters about any sort of medicine is whether or not it works and whether it is safe. It therefore verges on the incredible that we read in section 4.1

“conclusions from research into the efficacy of the various CAM’s are outside the remit of this report.”

The whole point about CAM is that there is very little evidence that any of it works. So the review committee decided to ignore the most important problem of the lot.  I can’t see how any rational decision can be made without first deciding whether the treatment is better than placebo.  That, surely, is the main question, and it was dodged.

UCLAN has failed to grasp the nettle, just as the Department of Health has also consistently failed to do so.

Section 4,1  Efficacy   This section repeats the assertion, absurd to my mind, that it is possible to judge CAM courses while declining to assess whether they work or not.

Section 4.2 Role of Universities in Society.

There is universal agreement that critical thinking is crucial to the idea of a university, but the judgement of whether CAM teaches critical thinking is simply fudged. Again the report fails to grasp the nettle.

“Disagreements about critical thinking within CAMs arises because some will argue that such substantiation and assessment can occur within the discipline, whilst others will argue that the methodology for substantiation, that is evidence provision, is universal. As a result, the latter will demand that evidence is provided using methods from one field (e.g. randomised controlled trials) for use in another.”

Sadly, the report dodged the crucial judgement once again. The most obvious characteristic of every form of alternative medicine is their total lack of critical self-appraisal. It is very sad that the review committee could not bring itself to say so.

Section 4.4   Nomenclature of degrees

Recommendation
The nomenclature of courses, leading to a professional as well as an academic award, should reflect the professional route; for example Bachelor with Honours in Complementary Medicine, B Comp. Med.(Hons) or B Acupuncture (Hons).

This sounds to me like another truly pathetic fudge. What on earth is solved by changing the name of the degree? You’d still be teaching students the same load of gobbledygook and then letting them loose on sick people, whether you call it a Bachelor of Science, a Bachelor of Arts, or, as is recommended here, a Bachelor of nothing whatsoever.

Well, I suppose there is a (doubtless unintended) irony in calling CAM degrees “Bachelor of nothing whatsoever”.

Section 4.4   Ethical, non-harm and economic considerations

This section list a lot of reasons why teaching alternative medicine should be unethical. but nevertheless manages to conclude that

” . . . it is not unethical to offer courses in Homeopathy, Acupuncture and Chinese Herbal Medicine at a university.”

I find the logic by which this bizarre conclusion was reached quite impossible to follow. Like much of the rest of the report this conclusion seems to stem from a reluctance to grapple with the really important questions, like ‘does it work or not?’.

Despite this the recommendation is perhaps the most interesting of all.

Recommendation
• The University refrains from offering any CAM courses until such disciplines have achieved statutory regulation status.”

This recommendation was accepted, and passed as a resolution at Academic Board. If it is implemented now, than there will be no more alternative medicine degrees next year at the University of Central Lancashire. If and when this happens, the University must be congratulated on its return to rational medicine.

Follow-up

Michael Eslea, UCLAN’s hero in resisting nonsense from the inside, has posted on this topic.

17 July 2009. It seemed odd that that no announcement was made about the future if the remaining CAM courses at UCLAN. So I asked deputy Vice-Chancellor Patrick McGhee for clarification. After a couple of days, I got this response.

From: CTheobald@uclan.ac.uk

To: d.colquhoun@ucl.ac.uk
Subject: uclan clarification

Hi David,

I have been asked to respond to your question below on the running of acupuncture and Chinese herbal medicine at UCLan. It is correct to assume that UCLan will not be taking any new entrants onto these programmes until further notice.

Best Wishes

Chris

Chris Theobald
Corporate Communications
University of Central Lancashire

So the report may have been disappointing, but it has done the job. As several people have pointed out in comments, it would be asking too much to expect a university to say “sorry we just noticed that we have been running junk-science courses for years”. But they have done the right thing anyway.

Jump to follow-up

It seems that bits of good news don’t come singly. First honours degrees in acupuncture vanish, Now a big chain of shops selling Chinese herbs and acupuncture has gone into administration.

It seems that, at last, people are getting fed up with being conned out of their hard-earned money



Herbmedic Barking

A local newspaper, The North Herts Comet reported thus.

Customers of Herbmedic, which trades under the name Herbs and Acupuncture, on Queensway in Stevenage have been left counting the cost after shelling out hundreds of pounds for treatment they never received.

The company, which has practices across the country, is now in the hands of receivers, Macintyre Hudson.

Sandra Emery, of The Paddocks in Stevenage, paid £350 for 10 treatment sessions, but only received one before the practice closed.

She said: “A standard course of treatment is 10 sessions, so most customers will have bought this package.

Claudia Gois, of Walden End in Stevenage, paid £240 for 12 treatment sessions but only received four before the practice closed.

She said: “I went there on Friday and it was closed. There was no warning or anything.

“I got in touch with head office and they said it’s very unlikely I will get money back.

This report was on 1st April,  The company’s web site shows no sign of any problems, In fact they are still advertising jobs. So was this an April Fool joke?

No it wasn’t.  A visit to Companies House soon settled the matter. The whole company is insolvent, as of 27 March 2009..

Download the whole administration notice and the company report.

 

Criticisms of Herbmedic

This chain of shops was investigated by the BBC’s
Inside Out
programme. (September 25th 2006).

“We sent an undercover reporter to branches of the Herbmedic chain in southern England.

On each occasion, the reporter claimed to be suffering from tiredness and was prescribed herbal remedies after a consultation lasting less than five minutes.

The herbalists, who describe themselves as “doctors”, didn’t ask any questions about the patient’s medical history or take any notes.”

This is so bad that even Andrew Fowler, a past President of the Register of Chinese Herbal Medicine, described it as “malpractice”.

“Herbmedic has been investigated by the authorities in the past.

In 2002, trading standards officers prosecuted the branch in Southampton for selling herbal remedies with 26 times the permitted legal limit of lead.

And in October 2003, the Advertising Standards Authority banned Herbmedic from describing its practitioners as “doctors”.

Despite the ban, all three of the stores visited by Inside Out referred to the herbalist as the doctor.”

See also the BBC report Herbalists’ customers ‘at risk’, and a report in the Sunday Times, Herbmedic accused of high-pressure selling.

Read the Advertising Standards report. Seven different complaints against Herbmedic were upheld.

This is entirely consistent with my own experience. I went into one of their shops and asked about a cure for diabetes (hoping the be able to refer them to Trading Standards, but the young lady behind the counter had such a poor grasp of English that her reply was incomprehensible. She just kept trying to push me into having a consultation with “the doctor” who appeared to speak no English at all. I left.

The chequered history of Herbmedic

The company that his just gone into administration is Herbmedic Centre Ltd.  It has been in existence for only two years. Its predecessor, known simply as Herbmedic, was dissolved on 13 March 2007, Companies House said

Type Date Description Order
Company Filing History
GAZ2(A) 13/03/2007 FINAL GAZETTE: DISSOLVED VIA VOLUNTARY STRIKE-OFF
GAZ1(A) 28/11/2006 FIRST GAZETTE NOTICE FOR VOLUNTARY STRIKE-OFF
652a 16/10/2006 APPLICATION FOR STRIKING-OFF

Another Chinese medicine chain seems to be having a few problems too

Harmony Medical Distribution Ltd (“specialists in acupuncture and holistic medicine”) seems to be still in business(web site here), but several very similar companies have been dissolved,  Harmomy Medics Ltd (dissolved 19 Sep 2006) ,, Harmony Medical Services (UK ) Ltd. (dissolved 6 May 2008) and Harmony Medical Services Ltd (dissolved 17 Oct 2008)

Given this history of companies that dissolve every couple of years and then mysteriously reincarnate with a slightly different name, one wonders if this really is the end of herbmedic, or it is just a device for shedding bad debts.  Is this just another “pre-pack administration“?

Watch this space for more.

What’s the latest evidence on acupuncture anyway?

A correspondent drew my attention to the 2009 Annual Evidence Update on acupuncture complied by the NHS Complementary and Alternative Medicine Specialist Library. This includes no fewer than 56 systematic reviews and meta-analyses.  Although the reviews are complied by alternative medicine sympathisers, they seem mostly to be pretty fair.  Well apart form one thing. 

Almost all of the reviews fail to come up with any positive evidence that acupuncture works well enough to be clinically useful.  Only two come close, and they are the two singled out as “editor’s picks”. Perhaps that’s not entirely surprising given that the editor is Dr Mike Cummings.

Again and again, the results are inconclusive: #8 is pretty typical

Acupuncture for tension-type headache: a meta-analysis of randomized, controlled trials.

This meta-analysis suggests that acupuncture compared with sham for tension-type headache has limited efficacy for the reduction of headache frequency. There exists a lack of standardization of acupuncture point selection and treatment course among randomized, controlled trials. More research is needed to investigate the treatment of specific tension-type headache subtypes.

Vast effort and a lot of money is being put into trials, yet there are very few (if any) positive results. Very often there are no results at whatsoever. All we hear, again and again, is “more research is needed”.

At some point someone will have to decide it is all a charade and start to spend time and money on investigating things that are more promising. 

Follow-up

A correspondent checked with Companies House to discover more about two of the directors of Herbmedic, Mr. Li Mao and Mr Xiao Xuan Chen.  They have a chequered history indeed. [download the complete list]

Mr. Li Mao is, or has been, on the board of 31 different companies. Of these 6 are active, 5 are in administration, 14 were dissolved, 4 were liquidated and 2 are active with proposal to strike off.  Not only is Her Medic centre Ltd in administration, but so is Dr China (UK) Ltd, and Great Chinese Herbal Medicine Ltd

With record like that, my correspondent wonders whether they should be disqualified.

In March 2007 I wrote a piece in Nature on Science degrees without the science.  At that time there were five “BSc” degrees in homeopathy. A couple of weeks ago I checked the UCAS site for start in 2009, and found there was only one full “BSc (hons)” left and that was at Westminster University.

Today I checked again and NOW THERE ARE NONE.

A phone call to the University of Westminster tonight confirmed that they have suspended entry to their BSc (Hons) homeopathy degree.

They say that they have done so because of “poor recruitment”.   It was a purely financial decision.  Nothing to do with embarrasment.  Gratifying though it is that recruits for the course are vanishing, that statement is actually pretty appalling   It says that the University of Westminster doesn’t care whether it’s nonsense, but only about whether it makes money.

Nevertheless the first part of this post is not entirely outdated before it even appeared, because homeopathy will still be taught as part of Complementary Therapies. And Naturopathy and “Nutritional Therapy” are still there..

According to their ‘School of Integrated Health‘, “The University of Westminster has a vision of health care for the 21st Century”. Yes, but it is what most people would call a vision of health care in the 18th century.

The revelation that the University of Westminster teaches that Amethysts emit high Yin energy caused something of a scandal.

Since then I have acquired from several sources quite a lot more of their teaching material, despite the fact that the university has refused to comply with the Freedom of Information Act.

In view of the rather silly internal review conducted by Westminster’s Vice-Chancellor, Professor Geoffrey Petts, this seems like a good moment to make a bit more of it public,

I think that revelation of the material is justified because it is in the
public interest to know how the University if Westminster is spending taxpayers’ money.  Another motive is to defend the reputation of the post-1992 universities.   I have every sympathy with the ex-polytechnics in their efforts to convert themselves into universities.  In many ways they have succeeded.  That effort
is impeded by teaching mystical versions of medicine. 

If the University of Westminster is being brought into disrepute, blame its vice-chancellor, not me.

Homeopathic spiders

Here are a few slides from a lecture on how good spider venom is for you.  It is from Course 3CTH502 Homeopathic Materia Medica II.  No need to worry though, because they are talking about homeopathic spider venom, so there is nothing but sugar in the pills. The involvement of spiders is pure imagination. No more than mystical gobbledygook.

You are in hurry, or play with your fingers?  You need spider venom pills (that contain no spider venom).

You break furniture? Time goes too fast for you?  Try the tarantula-free tarantula pills.

You are preoccupied with sex? You play with ropes?  What you need is Mygale (which contains no Mygale)

Much more seriously, the same sugar pills are recommended for serious conditions, chorea, ‘dim sight’, gonorrhoea, syphilis and burning hot urine.

This isn’t just preposterous made-up stuff.  It is dangerous.

There is a whole lot more fantasy stuff in the handouts for Homeopathy Materia Medica II (3CTH502). Here are a couple of examples.

Aurum metallicum (metallic gold) [Download the whole handout]

Affinities  MIND, VASCULAR SYSTEM, Nerves, Heart, Bones, Glands, Liver, Kidneys, RIGHT SIDE, Left side.

Causations Emotions. Ailments from disappointed love and grief, offence or unusual responsibility, abuse of mercury or allopathic drugs.

Aurum belongs to the syphilitic miasm but has elements of sycosis (Aur-Mur).

Potassium salts are the subject of some fine fantasy, in “The Kali’s” [sic]. (there is much more serious stuff to worry about here than a few misplaced apostrophes.). [Download the whole handout]

“The radioactive element of potassium emits negative electrons from the atom nucleus and is thought to be significant in the sphere of cell processes especially in relation to functions relating to automatism and rhythmicity.”

“Kali people are very conscientious with strong principles. They have their rules and they stick to them, ‘a man of his word’.”

“Potassium acts in a parasympathetic way, tending towards depression”

“They [“Kali people=] are not melancholic like the Natrum’s but rather optimistic.”

Radioactive potassium is involved in automaticity?  Total nonsense.

Where is the science?

Yes, it is true that the students get a bit of real science.  There isn’t the slightest trace that I can find of any attempt to resolve the obvious fact that what they are taught in the science bits contradict directly what they are told in the other bits.  Sounds like a recipe for stress to me.

They even get a bit of incredibly elementary statistics.  But they can’t even get that right.  This slide is from PPP – Res Quant data analysis.

“Involves parameters and/or distributions”. This has no useful meaning whatsoever, that I can detect.

“Tests hypotheses when population distributions are skewed”. Well yes, though nothing there about forms of non-Gaussian properties other than skew, nothing about normalising transformations, and nothing about the Central Limit theorem. 

“Ranks data rather than the actual data itself”. This is plain wrong. Randomisation tests on the original data are generally the best (uniformly most powerful) sort of non-parametric test. It seems to have escaped the attention of the tutor that ranking is a short-cut approximation that allowed tables to be constructed, before we had computers. 

The students are told about randomised controlled trials.  But amazingly in the lecture PPP-RCTs, the little matter of blinding is barely mantioned.  And the teacher’s ideas about randomisation are a bit odd too.

Sorry, but if you fiddle the randomisation, no amount of “careful scrutiny” will rescue you from bias.

An Introduction to Naturopathic Philosophy

Naturopathy is just about as barmy as homeopathy. You can see something about it at the University of Wales.  How about this slide from Westminster’s An Introduction to Naturopathic Philosophy.

So if you get tuberculosis, it isn’t caused by Mycobacterium tuberculosis?   And the symptoms are “constructive”?   So you don;t need to do anything. It’s all for the best really.

This isn’t just nonsense.  It’s dangerous nonsense.

Traditional Chinese Medicine

Ever wondered what the mysterious “Qi” is?   Worry no more. All is explained on this slide.

It means breath, air, vapour, gas, energy, vitalism.  Or perhaps prana?  Is that quite clear now?

What can we make of this one?  Anyone can see that the description is barely written in English and that vital information is missing (such as the age of the woman). And it’s nonsense to suggest that “invasion of cold” (during keyhole surgery!) would cause prolonged constriction of blood vessels (never mind that it would “consume yang qi”). Not being a clinician, I showed it to an oncologist friend.  He said that it was impossible to tell from the description whether the problem was serious or not, but that any abdominal pain should be investigated properly. There isn’t anything here about referral for proper investigation.  Just a lot of stuff about ginger and cinnamon. Anyone who was taught in this way could be a real danger to the public. It isn’t harmless nonsense  It’s potentially harmful nonsense.

And finally, it’s DETOX

Surely everyone knows by now that ‘detox’ is no more than a marketing word?  Well not at the University of Westminster.  They have a long handout  that tells you all the usual myths and a few new ones.

It is written by Jennifer Harper-Deacon, who describes herself modestly, thus.

Jennifer Harper-Deacon is a qualified and registered Naturopath and acupuncturist who holds a PhD in Natural Health and MSc in Complementary Therapies. She is a gifted healer and Reiki Master who runs her own clinic in Surrey where she believes in treating the ‘whole’ person by using a combination of Chinese medicine and naturopathic techniques that she has qualified in, including nutritional medicine, Chinese and Western herbalism, homoeopathy, applied kinesiology, reflexology, therapeutic massage, aromatherapy and flower remedies.

It seems that there is no limit on the number of (mutually incompatible) forms of nuttiness that she believes.  Here are a few quotations from her handout for Westminster students.

“Detoxification is the single most powerful tool used by natural health professionals to prevent and reverse disease”

What? To “prevent and reverse” malaria? tuberculosis? Parkinson’s disease? AIDS?  cancer?

“When you go on to a raw food only diet, especially fruit, the stored toxins are brought up from the deep organs such as the liver and kidneys, to the superficial systems of elimination.”;

Very odd. I always though that kidneys were a system of elimination.

“The over-use and mis-use of antibiotics has weakened the body’s ability to attack and destroy new strains of resistant bacteria, virulent viruses, which have led to our immune system becoming compromised.”

Certainly over-use and mis-use are problems. But I always thought it was the bacteria that became resistant.

“The beauty about detoxification therapy is that it addresses the very causative issues of health problems”

That is another dangerous and silly myth. Tuberculosis is not caused by mythical and un-named “toxins”. It is caused by Mycobacterium tuberculosis.

“Naturopathy follows the logic of cause and effect therefore believes that we simply need pure food and water, sunshine, air, adequate rest and sleep coupled with the right amount of exercise for health.”

Try telling that to someone with AIDS.

“Colon cleansing is one of the most important parts of any detoxification programme.”

The strange obsession with enemas in the alternative world is always baffling.

“Frankincense: holds the capacity to physically strengthen our defence system and can rebuild energy levels when our immune system is weak. Revered as a herb of protection, frankincense can also strengthen our spiritual defences when our Wei qi is low, making us more susceptible to negative energies. This calming oil has the ability to deepen the breath, helping us to let go of stale air and emotions, making it ideal oil to use inhale prior to meditating.”

This is so much hot air. There is a bit of evidence that frankincense might have some anti-inflammatory action and that’s it.

But this has to be my favourite.

“Remember when shopping to favour fruits and vegetables which are in season and locally grown (and ideally organic) as they are more vibrationally compatible with the body.”

Locally grown vegetables are “more vibrationally compatible with the body”? Pure mystical gobbledygook. Words fail me.

OK there’s a whole lot more, but that will do for now.

It’s good that Westminster is shutting down its Homeopathy BSc, but it seems they have a bit further to go.

The Health Professions Council (HPC) is yet another regulatory quango.

The HPC’s strapline is

“Working with health professionals to protect the public”

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.

These are thirteen very respectable jobs. With the possible exception of art therapists, nobody would doubt for a moment that they are scientific jobs, based on evidence. Dietitians, for example, are the real experts on nutrition (in contrast to “nutritional therapists” and the like, who are part of the alternative industry).  That is just as well because the ten criteria for registration with the HPC say that aspirant groups must have

“Practise based on evidence of efficacy”

But then came the Pittilo report, about which I wrote a commentary in the Times, and here, A very bad report: gamma minus for the vice-chancellor, and here.

Both the Pittilo report, the HPC, and indeed the Department of Health itself (watch this space), seem quite unable to grasp the obvious fact that you cannot come up with any sensible form of regulation until after you have decided whether the ‘therapy’ works or whether it is so much nonsense.

In no sense can “the public be protected” by setting educational standards for nonsense.  But this obvioua fact seems to be beyond the intellectual grasp of the quangoid box-ticking mentality.

That report recommended that the HPC should regulate also Medical Herbalists, Acupuncturists and Traditional Chinese Medicine Practitioners. Even more absurdly, it recommended degrees in these subjects, just at the moment that those universities who run them are beginning to realise that they are anti-scientific subjects and closing down degrees in them.

How could these three branches of the alternative medicine industry possibly be eligible to register with the HPC when one of the criteria for registration is that there must be “practise based on evidence of efficacy”?

Impossible, I hear you say.  But if you said that, I fear you may have underestimated the capacity of the official mind for pure double-speak.

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.

But the last conclusion contradicts directly the requirement for “practise based on evidence of efficacy”.  I was curious about how this contradiction
could be resolved so I sent a list of questions.  The full letter is here.

The letter was addressed to the president of the HPC, Anna van der Gaag, but with the customary discourtesy of such organisations, it was not answered by her but by Michael Guthrie, Head of Policy and Standards   He said

“Our Council considered the report at its meeting in July 2008 and decided that the regulation of these groups was necessary on the grounds of public protection. The Council decided to make a recommendation to the Secretary of State for Health that these groups be regulated.
http://www.hpc-uk.org/assets/documents/100023FEcouncil_20080911_enclosure07.pdf
“.

This, of course, doesn’t answer any of my questions. It does not explain how the public is protected by insisting on formal qualifications, if the qualifications
happen to teach mythical nonsense. Later the reply got into deeper water.

“I would additionally add that the new professions criteria are more focused on the process and structures of regulation, rather than the underlying rationale for regulation – the protection of members of the public. The Council considered the group’s report in light of a scoring against the criteria. The criteria on efficacy was one that was scored part met. As you have outlined in your email (and as discussed in the report itself) the evidence of efficacy (at least to western standards) is limited overall, particularly in the areas of herbal medicines and traditional Chinese medicine. However, the evidence base is growing and there was a recognition in the report that the individualised approach to practice in these areas did not lend themselves to traditional RCT research designs.”

Yes, based on process and structures (without engaging the brain it seems). Rather reminiscent of the great scandal in UK Social Services. It is right in one respect though.

The evidence base is indeed growing, But it is almost all negative evidence. Does the HPC not realise that? And what about “at least by Western standards”?   Surely the HPC is not suggesting that UK health policy should be determined by the standards of evidence of Chinese herbalists?  Actually it is doing exactly that since its assessment of evidence was based on the Pittilo report in which the evidence was assessed (very badly) by herbalists.

One despairs too about the statement that

“there was a recognition in the report that the individualised approach to practice in these areas did not lend themselves to traditional RCT research designs”

Yes of course the Pittilo report said that, because it was written by herbalists! Had the HPC bothered to read Ben Goldacre’s column in the Guardian they would have realised that there is no barrier at all to doing proper tests. It isn’t rocket science, though it seems that it is beyond the comprehension of the HPC.

So I followed the link to try again to find out why the HPC had reached the decision to breach its own rules. Page 10 of the HPC Council report says

3. The occupation must practise based on evidence of efficacy This criterion covers how a profession practises. The Council recognizes the centrality of evidence-based practice to modern health care and will assess applicant occupations for evidence that demonstrates that:

  • Their practice is subject to research into its effectiveness. Suitable evidence would include publication in journals that are accepted as
    learned by the health sciences and/or social care communities
  • There is an established scientific and measurable basis for measuring outcomes of their practice. This is a minimum—the Council welcomes
    evidence of there being a scientific basis for other aspects of practice and the body of knowledge of an applicant occupation
  • It subscribes to the ethos of evidence-based practice, including being open to changing treatment strategies when the evidence is in favour
    of doing so.

So that sounds fine. Except that research is rarely published in “journals that are accepted as learned by the health sciences”. And of course most of the good evidence is negative anyway. Nobody with the slightest knowledge of the literature could possibly think that these criteria are satisfied by Medical Herbalists, Acupuncturists and Traditional Chinese Medicine Practitioners.

So what does the HPC make of the evidence?  Appendix 2 tells us. It goes through the criteria for HPS registration.

“Defined body of knowledge:  There is a defined body of knowledge, although approaches to practice can vary within each area.”

There is no mention that the “body of knowledge” is, in many cases, nonsensical gobbledygook and, astonishingly this criterion was deemed to be “met”!.

This shows once again the sheer silliness of trying to apply a list of criteria without first judging whether the subject is based in reality,

Evidence of efficacy. There is limited widely accepted evidence of efficacy, although this could be partly explained by the nature of the professions in offering bespoke treatments to individual patients. This criterion is scored part met overall.

Sadly we are not told who deemed this criterion to be “part met”. But it does say that “This scoring has been undertaken based on the information outlined in the [Pittilo] report”. Since the assessment of evidence in that report was execrably bad (having been made by people who would lose their jobs if
they said anything negative). it is no wonder that the judgement is overoptimistic!
Did the HPC not notice the quality of the evidence presented in the Pittilo report?   Apparently not.  That is sheer incompetence.

Nevertheless the criterion was not “met”, so they can’t join HPC, right?   Not at all. The Council simply decided to ignore its own rules.

On page 5 of the Council’s report we see this.

The Steering Group [Pittilo] argues that a lack of evidence of efficacy should not prevent regulation but that the professions should be encouraged and funded to strengthen the evidence base (p.11, p. 32, p.34).

This question can be a controversial area and the evidence base of these professions was the focus of some press attention following the report’s publication. An often raised argument against regulation in such circumstances is that it would give credibility in the public’s eyes to treatments that are not proven to be safe or efficacious.

This second point is dead right, but it is ignored. The Council then goes on to say

In terms of the HPC’s existing processes, a lack of ‘accepted’ evidence of efficacy is not a barrier to producing standards of proficiency or making decisions about fitness to practise cases.

This strikes me as ludicrous, incompetent, and at heart, dishonest.

There will be no sense in policy in this area until the question of efficacy is referred to NICE.  Why didn’t the HPC recommend that?  Why has it not been done?

One possible reason is that I discovered recently that, although there are two scientific advisers in the Department of Health,. both of them claim that it is “not their role” to give scientific advice in this area.  So the questions get referred instead to the Prince of Wales Foundation. That is no way to run a ship.

The fact of the matter is that the HPC, like so many other regulatory agencies, fails utterly to protect the public from fraudulent and incompetent practitioners. In fact it actually protects them, in the same way that the financial ‘regulators’ protected fraudulent bankers.  They all seem to think that ticking boxes and passing exams is an effective process. Even if the exams require you to memorise that amethysts “emit high Yin energy so transmuting lower energies and clearing and aligning energy disturbance as all levels of being”.

Jump to follow-up

It’s only a matter of weeks since a lot of young scientists produced a rather fine pamphlet pointing out that the “detox” industry is simply fraud.  They concluded

“There is little or no proof that these products work, except to part people from their cash.”

With impeccable timing, Duchy Originals has just launched a “detox” product.

Duchy Originals is a company that was launched in 1990 by the Prince of Wales,  Up to now, it has limited itself to selling overpriced and not particularly healthy stuff like Chocolate Butterscotch Biscuits and Sandringham Strawberry Preserve.  Pretty yummy if you can afford them.

The move of HRH into herbal concoctions was first noted in the blogosphere (as usual) in December, by Quackometer.   It was reported recently in the Daily Telegraph (23rd January).

Expect a media storm.

Aha so it is a “food supplement” not a drug. Perhaps Duchy Originals have not noticed that there are now rather strict regulations about making health claims for foods?

And guess who’s selling it? Yes our old friend, for which no deception is too gross, Boots the Chemists.

That’s £10 for 50 ml. Or £200 per litre.

And what’s in it?

Problem 1.  The word detox has no agreed meaning. It is a marketing word, designed to separate the gullible from their money

Problem 2.  There isn’t the slightest reason to think that either artichoke or dandelion will help with anything at all. Neither appears at all in the Cochrane reviews.  So let’s check two sources that are both compiled by CAM sympathisers (just so I can’t be accused of prejudice).

National Electronic Library of CAM (NELCAM) reveals nothing useful.

  • There is no good evidence that artichoke leaf extract works for lowering cholesterol.   No other indications are mentioned.
  • Dandelion doesn’t get any mention at all.

The US National Center for Complementary and Alternative Medicine (NCCAM) has spent almost $1 billion on testing alternative treatments  So far they have produced no good new remedies (see also Integrative baloney @ Yale).They publish a database of knowledge about herbs. This is what they say.

  • Dandelion.  There is no compelling scientific evidence for using dandelion as a treatment for any medical condition.
  • Artichoke isn’t even mentioned anywhere.

If “detox” is meant to be a euphemism for hangover cure, then look at the review by Pittler et al (2005), ‘Interventions for preventing or treating alcohol hangover: systematic review of randomised controlled trials’.

Conclusion No compelling evidence exists to suggest that any conventional or complementary intervention is effective for preventing or treating alcohol hangover. The most effective way to avoid the symptoms of alcohol induced hangover is to practise abstinence or moderation.”

Problem 3. The claim that the product is “cleansing and purifying” is either meaningless or false.  Insofar as it is meaningless, it is marketing jargon that is designed to deceive.  The claim that it supports “the body’s natural elimination and detoxification processes, and helps maintain healthy digestion” is baseless. It is a false health claim that, prima facie, is contrary to the Unfair Trading law, and/or European regulation on nutrition and health claims made on food, ref 1924/2006 , and which therefore should result in prosecution.

Two more Duchy herbals

Duchy are selling also Echinacea and Hypericum (St John’s Wort).

The evidence that Echinacea helps with colds is, to put it mildly, very marginal.

Of St John’s Wort, NCCAM says

“There is some scientific evidence that St. John’s wort is useful for treating mild to moderate depression. However, two large studies, one sponsored by NCCAM, showed that the herb was no more effective than placebo in treating major depression of moderate severity.”

As well as having dubious effectiveness it is well known that St John’s Wort can interact with many other drugs, a hazard that is not mentioned by Duchy Originals

These two are slightly different because they appear to have the blessing of the MHRA.

The behaviour of the MHRA in ignoring the little question of whether the treatment works or not has been condemned widely.  But at least the MHRA are quite explicit. This is what the MHRA says of St. John’s Wort (my emphasis).

“This registration is based exclusively upon evidence of traditional use of Hypericum perforatum L. as a herbal medicine and not upon data generated from clinical trials.. There is no requirement under the Traditional Herbal Registration scheme to prove scientifically that the product works.

But that bit about “There is no requirement under the Traditional Herbal Registration scheme to prove scientifically that the product works” does not appear in the Duchy Originals advertisement. On the contrary, this is what they say.

Yes, they claim that “the two tinctures [echinacea and hypericum] -in terms of their safety, quality and efficacy -by the UK regulatory authorities”

That is simply not true.

On the contrary, anyone without specialist knowledge would interpret bits like these as claims that there will be a health benefit.

That is claim to benefit your health. So are these.

Who makes them?

Michael McIntyre is certainly a high profile herbalist.

He was founder president of the European Herbal Practitioners Association and a trustee of the Prince of Wales’s Foundation for Integrated Medicine.  It seems that he a great believer in the myth of “detox”, judging by his appearance on the Firefly tonics web site. They will sell you

“Natural healthy energy” in a drink

That’s what we wanted…

A Wake up for that drowsy afternoon… Detox for a dodgy Friday morning…

Sharpen up for that interminable meeting.

We left the herbs to our wonderful herbalists.

Their De-tox contains lemon, lime, ginger, sarsparilla and angelica. I expect it tastes nice. All the rest is pure marketing rubbish. It does not speak very well of Michael McIntyre that he should lend his name to such promotions.

Nelsons, who actually make the stuff, is better known as a big player in the great homeopathic fraud business. They will sell you 30C pills of common salt at £4.60 for 84. Their main health-giving virtue is that they’re salt free.

If you want to know what use they are, you are referred here, where it is claimed that it is “used to treat watery colds, headaches, anaemia, constipation, and backache”.  Needless to say there isn’t a smidgeon of reason to believe it does the slightest good for them.

And remember what Nelson’s advisor at their London pharmacy told BBC TV while recommending sugar pills to prevent malaria?

“They make it so your energy doesn’t have a malaria-shaped hole in it so the malarial mosquitos won’t come along and fill that in.”

You couldn’t make it up.

The Prince of Wales has some sensible things to say in other areas, such as the world’s over-reliance on fossil fuels. Even his ideas about medicine are, no doubt, well-intentioned. It does seem a shame that he just can’t get the hang of the need for evidence. Wishful thinking just isn’t enough.

Follow-up

Some more interesting reading about the Prince of Wales.

Michael Baum’s An open letter to the Prince of Wales: with respect, your highness, you’ve got it wrong”

Gerald Weissman’s essay Homeopathy: Holmes, Hogwarts, and the Prince of Wales.

Channel 4 TV documentary HRH “meddling in politics”

11 March 2009 The MHRA have censured Duchy Originals for the claims made for these products. and in May 2009, two complaints to the Advertising Standards Authority were upheld.

Herbal medicine is, unlike homeopathy, not ridiculous, It is merely Pharmacology, as practised up to circa 1900.  Whereas good trials have now shown acupuncture to be sham and homeopathy to be a placebo, there has been very little good research on herbs.

Most herbalism could fairly be described giving to sick patients an unknown dose of a substance with unknown efficacy and unknown safety.

How odd, then, to visit the Royal Society of Medicine to be greeted thus.

Just look at the words!

“Traditional Chinese Medicine (TCM) has developed over thousands of years”

That’s partly true

“and provides a comprehensive and systematic understanding of the natural world and the treatment of the human body.”

and that is total nonsense. TCM provides no understanding and virtually none of it is known to be useful for treating anything.

Another poster at the RSM exhibition provides some of the explanation.


What on earth, one wonders, do they mean by “making efforts to modernise TCM “? So far, the idea of modernising TCM doesn’t seem to include any great effort to find out if it works.


Much of the promotion of TCM seems to be not so much ‘ancient wisdom’, but modern nationalist propaganda by the Chinese government.



The history is fascinating, but you won’t learn it from the posters on display at the exhibition.

“The Daoguang emperor though it [acupuncture] was a barrier to medical progress and removed it from the curriculum of the Imperial Medical Institute,”

“By the start of the twentieth century, acupuncture was extinct in the West and dormant in the East. It might have fallen out of favour permanently, but it suddenly experienced a revival in 1949 as a direct result of the communist revolution and the establishment of the People’s Republic of China. Chairman Mao Tse-tung engineered a resurgence in traditional Chinese medicine, which included not just acupuncture but also Chinese herbal medicine and other therapies ”

“His motivation was partly ideological, inasmuch as he wanted to reinforce a sense of national pride in Chinese medicine. However he was also driven by necessity. He had promised to deliver affordable healthcare .. . . ”

“Mao did not care whether traditional Chinese medicine worked, as long as he could keep the masses contented. In fact, his personal physician, Zhisui Li, wrote a memoir entitled ‘The Private Life of Chairman Mao’, in which he quoted Mao as saying”

“Even though I believe we should promote Chinese medicine, I personally do not believe in it. I don’t take Chinese medicine.” “

Or, as put more succinctly by Shapiro

“You would never know that TCM was fashioned in the twentieth century, as we shall see, from a ragbag of therapies in post-revolutionary China.”

Rose Shapiro, Suckers, how alternative medicine makes fools of us all.

Why is the Royal Society of Medicine allowing such mendacious posters?  As it happens, I and a friend were visiting the RSM to see their Academic Dean, with a view to finding out why the RSM had failed to take any public position on alternative medicine.  The answer appeared to be money, and that was the answer to why the TCM exhibition was being held on their premises too.  The Dean no more believed in TCM than we did, but, well, they need the income.  He pointed out (looking suitably sheepish) that the address given for the exhibition was not the RSM, but Number 1 Wimpole Street (that, of course, is also the address of the RSM).

Ah, so that’s OK then.

It has to be said that the RSM isn’t alone in its spineless attitude.  Both the British Medical Association (BMA) and the Royal College of General Practitioners (RCGP) have failed to make any clear condemnation of mystical medicine.  This is in stark contrast to just about every relevant scientific society (here is a summary).

It is a mystery to me why much of medicine should still be dominated by a mindset that seems to have lagged 200 years behind every other science. Perhaps medicine  is just too complicated.

UCL Hospitals’ skeleton in the cupboard

Make no mistake, University College London Hospital is top class.  The UCLH Trust. runs seven hospitals All but one of them are excellent.  But in 2002 the Royal London Homeopathic Hospital was acquired as part of the UCLH group, to the intense embarrassment of UCL scientists.

Let’s start with the good bit.  Usually I don’t like anecdotes, so just think of this as a vote of thanks, not evidence.

A personal history of UCH

I owe UCLH a lot personally.  On December 13th 1984, my wife had
a subarachnoid haemorrhage when she was seven months pregnant.  After misdiagnosis at St Peter’s Hospital, Chertsey, she was moved to UCH and diagnosed very quickly.  The next day she had neurosurgery to pin an aneurysm at the Maida Vale Neurosurgical Hospital, part of the UCLH group (it no longer exists).  The surgeon, Alan Crockard, came out of theatre after five hours, looking rather tired and said “it was adhered to the optic chiasma on one side and about a millilmetre from the pituitary on the other.  It was a bit tricky but I think we got it”.

After a week in intensive care, under heavy sedation, Margaret’s blood pressure was not low enough and they decided to deliver the baby.  At about 4 pm on a snowy Christmas Eve, a team of neurosurgeons and a team of obstetricians gathered and soon after, Andrew Stuart Colquhoun emerged in a small incubator to be whisked off in an ambulance to the Special Care Baby Unit at UCH (run, at that time, by Osmund Reynolds).. Christmas day was spent in the hospital, with Margaret’s mother.  Andrew weighed 1.4 kg at birth, but by Christmas day he had pulled out his ventilator himself, and was doing fine. He was so tiny that it was a couple of days before I dared to hold him. The Unit had racks of doll-sized clothes, knitted by volunteers. Andrew's birth

Andrew (at 9 days) and Dad. Jan 2, 1985. Click for album..



Once Margaret was well enough, she was given a side room in a neurosurgical ward with a cot for Andrew by her bed, an arrangement that gave the neurosurgical nurses some fun. They were in UCLH continuously until 27th April before Margaret had recovered enough to go home, [Full photo album here]

Now they are both fine.and Andrew is 6′ 7″ (200.5 cm)..

It is episodes like this that make one very proud of the NHS.  Heaven knows what it would have cost in the USA.

Margaret & Andrew, with carer, Anna, June 2, 1985

Andrew playing cricket in Bangladesh, Feb 2005.



But now the the less desirable side of UCLH

Herbs and homeopaths at UCLH

Recently I was sent the UCLH Annual Review 2007 – 2008.  There was a lot of good stuff in it and worth a read despite there being too much hyperbole and too many pictures of men in dark suits.  But buried among all the high tech stuff, what do we find but an advertisement for 1900-style pharmacology in the form of the herbal clinic at the Royal London Homeopathic Hospital, accompanied by a load of utterly inaccurate information from the TV botanist, David Bellamy.

Take, for example, the claim about Devil’s Claw for osteoarthritis. Even alternative medicine advocates said “The authors concluded that there are insufficient high-quality trials to determine the safety and efficacy of Devil’s Claw (Harpagophytum procumbens) in the treatment of osteoarthritis, and that definitive trials are needed.”


Unbelievably, they are actually boasting that it is the first herbal clinic in the UK to be based in an NHS hospital.  In fact, of course, it is a step backwards by about 100 years.

Reading between the lines, I’d guess that the opening of this clinic has a subtext.  It is well known that funding for homeopathy has dried up (partly as a result of our letter to NHS Trusts that appeared in the
Times in May 2006
).  No doubt the advocates of mystical medicine are trying to fill the gaps left by the departure of some of the homeopathy.  .

There have been problems before with the herbal activities at the RLHH before (see Conflicts of Interest at the Homeopathic Hospital). It appeared that the Khans, who run the Marigold homeopathic podiatry clinic (no, seriously, it is real) were largely prescribing a herbal product that was made by their own company. without even the hospital trust, never mind the patients, being made aware of it.   In normal medicine this would be regarded as a rather serious offence, but as far as I know, nothing was ever done about it.


The ethics of alternative medicine are truly one of life’s great mysteries.

Reading further in the annual review, we come to the page about the RLHH.   The homeopathy side must really have run down because it seems to have diversified into selling cosmetics and groceries. That sounds like desperation.


Good heavens, they sell “chemical-free sun cream”. One wonders what it can be made of, if not chemicals. This is the language of low-grade advertising agencies, not what one expects from an NHS hospital trust.

But next to this there is a much more interesting item. Just look at the last sentence.

“Changing the name of the hospital to reflect its status as a centre of excellence for the integration of the best of conventional and complementary medicine is currently being considered, “

I wonder if this could possibly have anything to do with the fact that Michael Baum and I visited the Trust headquarters in August 2006 to propose that the RLHH might be turned into a centre of supportive and palliative care?

It would be nice to think so. But it seems they haven’t gone nearly far enough yet. If all they do is replace the waning homeopathy
with herbalism and acupuncture, we won’t be much closer to the 21st century.

We know they are under pressure from their royal patrons, but that, in a constitutional monarchy, is simply not acceptable.



Michael Baum is a cancer surgeon who has taken a particular interest in palliative and supportive care.  He is someone whose views should be taken seriously.  He is also the author of the magnificent “An open letter to the Prince of Wales: with respect, your highness, you’ve got it wrong” Here is a quotation from that letter.  The UCLH Trust should bear it in mind.

The power of my authority comes with a knowledge built on 40 years of study and 25 years of active involvement in cancer research. I’m sensitive to the danger of abusing this power and, as a last resort, I know that the General Medical Council (GMC) is watching over my shoulder to ensure I respect a code of conduct with a duty of care that respects patients’ dignity and privacy and reminds me that my personal beliefs should not prejudice my advice.


Your power and authority rest on an accident of birth. Furthermore, your public utterances are worthy of four pages, whereas, if lucky, I might warrant one. I don’t begrudge you that authority and we probably share many opinions about art and architecture, but I do beg you to exercise your power with extreme caution when advising patients with life threatening diseases to embrace unproven therapies. There is no equivalent of the GMC for the monarchy, so it is left either to sensational journalism or, more rarely, to the quiet voice of loyal subjects such as myself to warn you that you may have overstepped the mark. It is in the nature of your world to be surrounded by sycophants (including members of the medical establishment hungry for their mention in the Queen’s birthday honours list) who constantly reinforce what they assume are your prejudices. Sir, they patronise you! Allow me this chastisement.



Baum is a truly good man.


Follow-up

The photo album chronicling the birth of my son, is really just for family and friends, but at least one blog picked up on the wider significance.


Jump to follow-up

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

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

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


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

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

Unit abstract

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

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

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

Then later

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

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

The really revealing bit comes when you get to the

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

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

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

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

The Teacher

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

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

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

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

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

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

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

shortly followed by

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

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

What does Edexcel say?

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

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

Dear Professor Colquhoun

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

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

‘  ‘  ‘  ‘  ‘

Stephen Harris

Head of Customer Support



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

19 November

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

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

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

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

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

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



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

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

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

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

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

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

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

What does the QCA say?

The strapline of the QCA is

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

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

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

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

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

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

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

Here are some of the questions that I asked.

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

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



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

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

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

Isabel Nisbet

Acting Chief Executive



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

A nightmare maze of quangos

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

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

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

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

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

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

What next?

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

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

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

Follow-up

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

Edexcel. I sent them this request.

Freedom of Information Act

Hello

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

David Colquhoun

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

Dear Mr Colquhoun,

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

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

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



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

International Therapy Examination Council (ITEC)

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

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

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

“Who is this course for?

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

“What will I be doing on the course?

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

.VTCT stands for the Vocational Training Charitable Trust.

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

The crystals are here. I quote.

Objectives

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

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

Cornwall College has many courses run by ITEC.

The College says

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

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

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

The ITEC web site says

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

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

The pancreas reflex:

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

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

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

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

A Heart
B Liver
C Spleen
D Pancreas


Or perhaps this?

Which incantation makes hot stones work best?

A Incarcerous
B Avada Kedavra,
C Dissendium
D Expelliarmus.

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

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

Ofsted

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

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

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

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

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

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


Jump to follow-up

Thames Valley University is one of those shameful institutions that offer Bachelor of Science degrees in homeopathy. They don’t stop there though. They’ll teach you several other forms of make-believe medicine. Among these is “nutritional medicine”. This is taught at the Plaskett Nutritional Medicine College which is now part of Thames Valley University.

Everyone is for good nutrition of course, but ‘nutritional medicine’, or ‘nutritional therapy’ pretends to be able to cure all sorts of diseases by changes in diet or by buying expensive nutritional supplement pills. It has no perceptible relationship to the very important subjects of ‘nutrition’ or ‘dietetics’.  Nutritional therapy is very firmly part of alternative medicine, in other words it is largely quackery. If you don’t believe that, read on.

The subject of nutritional therapy was in the news recently because of Matthias Rath. He is the person who is reponsible for the death of many Africans because of his advocacy of vitamin pills for the treatment of HIV/AIDS. He didn’t just (mis)treat people, but also played a role in persuading the recently departed Thabo Mbeki, and his health minister (“Mrs Beetroot”) to abandon effective therapies for AIDS sufferers. See reports in The Guardian, by Ben Goldacre, and here,

I’ve written a lot about the penetration of quackery into universities, and I thought I’d seen the worst with ‘amethysts emit high yin energy‘.  But, as Goldacre said, let me tell you how bad things have become. .

Recently I came into possession of a lengthy set of notes for a first year course on “The Holistic Model of Healthcare”.  The notes are from the 2005 course at Thames Valley University,  They are not signed, but appear to have been written by Dr Lawrence Plaskett himself. . You can download the whole set of notes here.

Here are a few choice quotations. The basis of them is pure vitalism. They read like a throwback to the dark ages.  Little comment is needed.  They speak for themselves.

1.3 What do Orthodox Dieticians know about Food and Health?

Dieticians working in the National Health Service and private clinics and hospitals are usually well trained in the basics of the subject, though they too have an entirely orthodox slant.  By and large they seem to accept the general view of most of the medical profession that nutrition does not affect illness much. Hence, they restrict themselves to designing diets required by the doctors for whom they work – usually for specified narrow purposes, such as low fat diets, low sodium diets etc. Such diets are, indeed, important in the hospital management of certain diseases (once these have become established) but they represent extremely limited horizons. Much that is in the basic and essential training of alternative nutritional practitioners is missing from the training of dieticians. As a result, most hospital diets are not very good for health judging from the parameters that will be set down in the following Sessions

Well, it is true that real dietitians prefer not to base their practice on mediaeval vitalism. That is what marks them out as professionals.

1.4 Relationship to Science and the Limitations of Orthodox Methods

However, the subject of Wholistic Nutrition transcends the area of human understanding for which science, alone, is appropriate. The reason is that it is ‘vitalistic’. It recognises the presence in all life forms including the human body, of subtle (or ‘etheric’) energy forces not easily measurable by the physicist’s equipment.  It shares that position with the ‘energy medicine’ disciplines such as homoeopathy, traditional acupuncture and spiritual healing. It follows an approach to those subtle energies that is embodied in the discipline and philosophy of naturopathy.

Vitalism is the notion that life in living organisms is sustained by a vital principle that cannot be explained in terms of physics and chemistry.   This vital principle, often called “the life force”, is something quite distinct from the physical body and is responsible for much that happens in health and disease.

Naturopathy is a relatively modem term for an ancient concept (dating back to 400 BC). This concept embraces the notion that the body is inherently self-healing and that it is the practitioner’s job to stimulate and support this process.  Each patient is recognised as having a unique life experience and a unique genetic inheritance. All diseases are seen as one and as attempts by the body to purify itself of toxins. Treatment focuses on causes rather than on symptoms and always addresses the whole person. The wise words of Hippocrates (often called the Father of Medicine) express some of the main tenants of naturopathic thought. He said:

  • It is only nature that heals and wherever and whenever possible nature should be given the opportunity to do so.
  • Disease is only an expression of purification.
  • All disease is one.
  • Let food be your medicine and medicine be your food.”

Hence, most ‘alternative’ nutritionists see conventional nutrition. as being rather rigid and unmoving. Hence, they also see it as very limited. This happens because orthodox nutritionists tend to be locked into science alone. They fail to grasp the significance (or the reality of) the subtle energies and they reject the philosophy of vitalism. It is generally the view of ‘alternative’ nutritionists that understanding these things is a major step to healing the patient.

“Understanding” vitalism sounds more like a way of harming patients than healing patients.

1.5 The Pressure of the Orthodox model

Almost everyone who takes steps towards ‘alternative’ medicine experiences a backlash from others around them who have not been able to make the same conceptual change. Patients wanting to settle into an ‘alternative’ approach can be subject to negativity from their doctors (and as a result many patients do not ask the doctor’s opinion). But students and practitioners alike are frequently subject to negative expressions and even frank hostility from relatives
who can understand only orthodox, symptomatic treatment. It is therefore best to be forewarned that your adherence to ‘alternative’ principles will be tested in these ways.

The “Life Force” gets capital letters, like God, But what is it? Pure fantasy.

2 THE LIFE FORCE

2.1 What does our Energy Consist of?

At the root of most hoIistic therapies lies the belief that all life is animated by a subtle force. We call this the Life Force. You either believe it or you do not. It cannot exactly be proved at the moment and the belief is not in accord with the yardsticks that we call ‘scientific’, The belief is a little akin to the belief in God or in spirits or ghosts, and yet at the same time it is not,
because the Life Force is by no means so remote from us. It is not necessarily difficult for an agnostic to accept the Life Force. The writer was once asked for a definition of the Life Force and wrote:

” The Life Force is that non-material. non-physical force that animates all life forms and distinguishes them from non-living matter. It Is seen as a determining Force, not as a mere accompaniment to the phenomenon of Life. That is, it determines whether Life can exist or not. It determines the physical form that a life form takes: by its quality and its strength it determines the health, vigour and vitality of the life form. Hence it determines our freedom from, or our  susceptibility to illnesses, and our general ability to come through and to recover from Life’s stresses and traumas.”

A bit later it gets even better, when we get to astral travel and even survival after death. Truly bonkers.

The postulate of a subtle Life Force makes a natural connection with such topics as out of body experiences, astral travel and even survival after death. This happens because the subtle Life Force appears by its very nature to be “life within a different medium” and if life can exist in
a different medium, then why should it not exist quite independently of the physical body?

So what’s the evidence?

2.2 Evidence Concerning the Life Force

Since our ‘usual’ human senses only work through the medium of the human body we can only expect to detect the Life Force or other subtle forces, through their interactions with matter. It is clear that these interactions are themselves subtle and sensitive because one level or state is impinging upon another. It is postulated that they are not entirely of our world, not physical, only detectable with physical apparatus under special conditions.
Often they are described as “that which science cannot see”. Not surprisingly, therefore, when investigators come forward convinced that they have a phenomenon that demonstrates the Life Force. the physicists, looking at it with a steely scientific eye, are not usually ready to accept the conclusions claimed. Hence, we have several delicate phenomena that are often claimed to be manifestations of the Life Force, yet not accepted as such scientifically.

• The experiments done by Harold Saxton Burr on the “Fields of Life”.

• The experimen1s performed on detecting and measuring “Electrodynamic fields”

• The phenomenon of “Capillary dynamolysis”

• Homoeopathic effects.

• The Chinese ‘energy pulses’ at the human wrists.

From experience it is clear that many students will simply accept the Life Force as ‘obvious’.  Some will say they have always known about it. Others are able to accept the concept now as a reasonable principle.  Others perhaps (though we have rarely come across it) will never accept the Life Force. If that occurs, it seems a shame, for it removes some of the excitement from wholistic nutrition, . . .

What’s said about the homeopathic evidence?

2.6 Homoeopathic Effects

It is not until Nutritional Medicine students have qualified and got into practice that they usually employ any homoeopathy as an adjunct to their therapy in anything other than a first-aid role. That is because homoeopathy is a complex training in its own right and a quite separate discipline. However, any demonstration of the effectiveness of homoeopathic medicines at potencies higher than 12C is evidence for the existence of the subtle etheric energies. Such remedies have been diluted beyond the point at which the last traces of material substance derived from the Mother tincture, have been removed, leaving only the residual energy associated with the original material.

Of course the notes go on to misrepresent the clinical trials which actually show that homeopathy is mere placebo.

2.9 Toxic Effects upon the Life Force

The Life Force is generally seen as an abundant ebullient and beautiful manifestation of Nature’s energy. Although some forms of acupuncture take in the concept of a form of polluted Life Force called Aggressive Energy”, that idea is not shared much by other whoIistic disciplines. We are left for the most part with the idea of a rather perfect form of energy.

In Western Naturopathic thought, the enemy of the Life Force is toxicity. The Life Force inhabits a potentially perfect physical body. The main threat to the integrity of that body consists of the body’s own metabolic wastes, if they are not properly cleared out. Plus environmental toxins that gain access to the body from outside, or that are generated in the bowel. In that way the bowel gains a high level of importance in Naturopathy and ‘”Nature Cure”.

The Life Force, then, with its almost holy purity, is in danger of being inhibited, dampened down and threatened by what amounts to some entirely physical dirt that gains access to that temple of the soul the human body. Whilst in Traditional Chinese Medicine impurities in the mind, emotions or spirit are just as important as physical impurity, it is naturopathy that focuses upon the actual physical sewers of the body.

Aha, that’s it. Holy water.

The inability of naturopaths in the past to identify specific toxins or to point with sufficient exactitude to the ways in which they can be removed, has been the Achilles Heel of the naturopaths in trying to represent their views in the past to orthodox doctors or medical scientists.

And it still is. The alleged toxins have never been identified, still less removed. Detoxification is a myth of downmarket women’s magazines and profiteering spas. And, of course, of some Bachelor of Science  degrees.

2.10 Nutritional Effects upon the Life Force

2.10.1 Bulk nutrients

Next comes the consideration of the bulk nutrients – the protein, carbohydrate and fat. These are our source of biochemical energy and we obviously starve without them. Their purity is crucial.  If they have been chemically modified or damaged by toxic interactions, then they will entrain toxicity and also be hard to break down. Even at best, their digestion and assimilation costs energy, which may well be both biochemical and subtle.

What “toxic interactions”? This is all sheer fantasy.

2.10.3 The micronutrients

When you practice [sic] nutritional therapy in a naturopathic setting, being aware at the same time of the on-going biochemistry, you become critically aware of the role of the  micronutrients in a way that the classical naturopaths were not.

Biochemical reactions will flow better when they are present in the correct balance. Therefore the minerals have a key interaction with the Life Force. Without the right minerals the Life Force can be conceived of as pushing forward to achieve high activity in the body, yet being blocked through the chemical composition not being correct. If you apply the minerals in this situation, there may, indeed. be a surge forward of the energy.

Whatever that may mean.

3 THE EBULLIENCE OF THE LIFE FORCE: STOPPING THE ROT AND STARTING TO RECOVER

3.1 The Horror of Deterioration: The Chronic State

All that has gone before has already shown that the grassroots of deterioration in the physical body are:

  • Weakened Life Force
  • Nutritional Deficiency and Imbalance
  • Toxic Attack

If nutritional error or deprivation are the more strongly implicated primary cause, then the Life Force struggles with an unbalanced physical body, getting the tissue biochemistry to work at full integrity is impossible; hence. the body’s detoxification system becomes incompetent and the body’s toxic burden may rise steeply. At the same time the Life Force ails.

So, focusing as we do now upon elimination of toxins (the very nub of classical naturopathy), we perceive that it is a process that depends upon a good strong Life Force and also upon adequate nutrient intake. Therapies that directly stimulate the Life Force (homoeopathy, acupuncture and spiritual healing) therefore make an indirect, though real, contribution to toxic elimination through increasing the Life Force or otherwise improving its health and balance.

So according to this, all CAM is much the same. That idea will provoke bitter internecine warfare.

3.5 The Law of Cure

We have above depicted the move from relative health to chronic illness as a downward path. Equally, the route back from the edge of the abyss of chronic illness is one of revitalisation and detoxification. The idea of the ‘route back’ was spotted years ago by the homoeopath, Constantine Hering, and has become known as ‘Hering’s Law of Cure’.

The Law further embodies the notion that toxins, and therefore symptoms, tend to move outward from within as recovery or cleansing occurs. This is fully in accord with the classical naturopath’s idea. Toxins close to the surface of the body are conceived to be most likely on their way out. The skin is an eliminatory organ and toxins at or near the skin level are not so much of a threat to well being. Naturally, the patient may well be horrified at the disfiguring
rash that may be seen by all. Nonetheless, the patient is seen to be far better off than when having these toxins deep within the body, held, perhaps within essential organs that are becoming progressively damaged.

This sounds increasingly like a ‘do-nothing’ approach (much like homeopathy then).

3.6 Suppression

Boils used to swell up into a red sore and then burst. Very bad ones, or carbuncles, might be lanced to cause the pus (morbid matter) to run out. These days, boils and carbuncles tend to occur much less than formerly, presumably because of the lower Life Force of the population and the generally suppressive medical culture. The chances are that they get treated with an antibiotic long before they get a chance to come to a head and burst. Such treatment is suppressive in the strictly naturopathic sense of the word. The same is absolutely true with regard to bringing down artificially the temperature during a fever, whereas ‘sweating it out’ is the natural thing to do.

More of the do-nothing approach.

4.2 How lridology Helps us to See Toxic Foci

As mentioned above, toxic foci (deposits) in the body show up in the iris of the eye. The iris is arranged so as to encompass a complete ‘map’ of the body. with all the organs and systems laid out upon it. Hence the location of a toxic deposit in the iris shows the iridologist its position within the body. The toxins may appear as colours, spots. blobs and smears in particular
places in the iris, or as darkened areas.

Now iridology, another sort of fantasy medicine, creeps in.

5.5 What Place for Immunisations?

Here we shall restrict ourselves to saying as little as possible. We shall. indeed, make no recommendations. However. the classical naturopaths and homoeopaths have all been of one voice in condemning the use of morbid diseased matter for injection into the human body to prevent disease. It was not, they said, a proper procedure. There has also been much disagreement about how effective such measures are. Of course, whenever there is danger of infection. it is wrong to do nothing. At least you should use the homoeopathic equivalent treatment. As to the effectiveness of those methods, that is beyond the scope of this course.

As to the personal view of the writer, it is that the natural therapists who have declared thernselves on this topic in the past are probably right. They have maintained that immunisation is just another form of toxin and an especially potent one capable, on its own, of sparking a downward spiral into ill health in susceptible people. As to what extent that effect might be balanced by benefit, that is an unresolved argument.  The writer does not use immunisations himself.

Well there is a surprise. Just like almost every other quack, the writer would endanger the whole population by opposing immunisation.

The quiz

The notes contain a number of questions, and, more interestingly, model answers are given at the end. Here is one example.

Question.    Why do some patients respond well to very little treatment?

Answer.  The size of the toxic burden, the strength of the Life Force and micro nutrient status strongly influence a person’s response to treatment. Therefore a person with a low toxic burden, high micro nutrient status and strong life force should respond well to very little treatment.

Or, to put it differently, echinacea cures your cold in seven days, when otherwise it would have taken a week.

Conclusion

We’ll always have crackpot ideas about medicine, at least until real medicine gets much more effective than it is now. For example, in low back pain, the cause is usually not known, the treatments are only palliative, and it isn’t very effective palliation either. The big difference between real medicine and crackpot medicine, is that in real medicine you aren’t allowed to invent the answer when you don’t know it.

No doubt the author of these fantasy notes was entirely sincere in his delusions.  But how can any self-respecting vice-chancellor tolerate having this sort of stuff as part of a Bachelor of Science degree?   Professor Peter John, vice-chancellor of Thames Valley University is not a scientist. His background is in education. But you don’t need to be a scientist to see what nonsense is being taught as science in his university.

Perhaps he didn’t know what is going on. Well, he does now.

Follow-up

Thanks to Ben Goldacre for the link from his miniblog.?

Thames Valley University and their degree in “Nutritional Medicine”

Why? Why do they pretend it’s science? Why don’t they just call it “some stuff we made up”