The Homeopaths’ Desperate Campaign to the MHRA

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More leaks from homeopathy land…

Tomorrow is the last day that you can submit a response to the MHRA regarding how they should regulate the sale of homeopathic products – or ‘medicines’ as homeopaths like to call them.

Meanwhile, it would appear that the homeopaths have been wanting to bombard the MHRA with responses. It would appear that the homeopaths, at all costs, do not want honest labelling on their products – labelling that would simply state that the sugar pills contain no active ingredient and there is no good evidence that they are effective for any known condition. Instead they want the MHRA to be obscure in its wording and deceptive as to the true nature of the pill.

What is quite clear from their campaign is that they do not want to have to provide any scientific evidence about their products – understandably, as homeopathic products are usually so diluted that nothing active remains in them.  Homeopaths want to make claims about health benefits to the public purely on the back of their ‘tradition’, that is, their long standing delusions about the magic in their pills.

As a starting point for understanding the issues, please visit DCScience.

So, in my email inbox this morning was this plea for help…

Dear EVERYONE,

This is urgent. TOP PRIORITY!!! The deadline is the 18th of February. The practice of homeopathy by lay homeopaths is at stake, and if the MHRA changes the wording to the document mentioned below, we will …not be allowed to practice any longer. This will take effect immediately. The new wording which is being suggested by sense against science, and is being considered by the MHRA will effectively put us in catch 22 so that we can no longer give out remedies – basically, it is about the difference between dispensing and prescribing. all homeopaths dispense remedies as a normal part of daily practice. the new rules will mean that it will be illegal to dispense without a license, and only a qualified doctor can make a prescription. without the ability to dispense, all we can do is sit and listen to people’s problems, but can do nothing else about it. this will also have an affect on the homeopathic pharmacies, who will only be allowed to dispense licensed remedies (currently, only arnica and possibly one or two others are licensed) unless prescribed by a physician, and this means the potential loss of thousands of remedies. The key words in the version we want, which help keep homeopathy going are “…use within the homeopathic tradition”. This avoids the need to prove the science behind prescribing of remedies and allows us to practise as normal.

Could you please send this template to EVERYONE and inundate Ms Farmer with requests to keep the wording as shown below, so that homeopaths can continue to practise homeopathy legally.

Please contact everyone on your database, if you are a homeopath, please send it in yourself and contact all your patients to do the same. we can counteract sense about science with numbers. we just proved we have greater numbers than they do, and that when we mobilise, we can beat them at their own game. last week, they started a poll against homeopathy in an irish newspaper ( see link – http://www.thejournal.ie/do-you-have-faith-in-homeopathy-2011-02/?voted=1) and inundated it with votes against. it was 435 against 67 for. we started a campaign on facebook, and within 24 hours, we shifted the balance of power to what you see here in the link – 67% for 27% against. they gave up and went away with their tails between their legs, and we showed them that people don’t want what they have to offer.

Please help us to do this again. many people don’t realise this new risk we are facing. it only takes a minute to copy and paste the below template and email it. Apologies in advance if you have acted on this already.

Thank you to everyone in advance – i know if we all work together, we can beat this.
email address: andrea.farmer@mhra.gsi.gov.uk
Ms Andrea Farmer
MHRA, Area 5M
151 Buckingham Palace Road
Victoria, London SW1W 9SZ

Dear Ms Farmer,

I am writing to you about the MHRA consultation document entitled; Review of Medicines Act 1968: informal consultation on issues relating to the PLR regime and homeopathy. As a member of the public who chooses to use homeopathy and benefits from its application/practicing homeopath (delete as applicable), I am deeply concerned by the current orchestrated campaign against homeopathy, which is led by a self-appointed pressure group, Sense About Science, and a number of bloggers.

I consider it to be a fundamental right of any citizen living in a country which purports to be a democracy, to have ready access to the healthcare option of their choice. This includes homeopathy, which as you know is included in the original NHS charter.

I find your statement below acceptable for the new registration labels, and can see no reason to change this statement:

“A homeopathic medicinal product licensed only on the basis of safety, quality and use within the homeopathic  tradition”

Yours sincerely,

27 comments for “The Homeopaths’ Desperate Campaign to the MHRA

  1. David Waldock
    February 16, 2011 at 7:55 am

    It’s just possible the information commissioner will be interested in this…

  2. February 16, 2011 at 9:21 am

    Love this, “…all we can do is sit and listen to people’s problems…”

    Perfect! Then they should see no drop in efficacy.

  3. Sean
    February 16, 2011 at 9:57 am

    Might I suggest changing the graphic at the top from “Safety: No known side effects…” to “No known effects”?

  4. Rocko
    February 16, 2011 at 10:00 am

    “This avoids the need to prove the science behind prescribing of remedies”

    How profoundly depressing that they think this could be in any way a good thing.

  5. Neal
    February 16, 2011 at 10:10 am

    Incredible really, but this sort of thing removes any faint veneer of credibility from their position.

    Apparently they see no dissonance with accepted standards on medical intervention, accurate selling of all goods etc. and their own position.

    Even the assertion that the rational and sceptical amongst us had been somehow proved wrong on the basis of a poll. What are facts? Oh, whatever a random plebecite say they are. Having revisited the poll I was amused to see the against figure is now in fact about 80%. But that’s by the by, though heartening.

    Keep up the good work Andy. Thanks for all your informative and often amusing posts.

    Cheers

  6. David J Mudkips
    February 16, 2011 at 11:09 am

    This level of frothing panic and bullshit is something I normally only associate with the infamous quack-farm known as Scientology.

    (Inb4 Homeopaths try to start a religion)

  7. Arraz
    February 16, 2011 at 11:16 am

    “we can counteract sense about science with numbers.” – I love that, especially as I misread it as “We can counteract sense with numbers” the first time. Sounds about right given the nature of these “practitioners”.

  8. February 16, 2011 at 11:25 am

    The email is wrong.

    It is already illegal for the homeopathic pharmacies to supply lay homeopaths with the vast majority of homeopathic remedies. It has been since, ooh, 1971. It is the unregistered remedies that are the issue.

    The obvious solution is that the homeopathic pharmacies register their products with the MHRA.

  9. The Founding Mothers
    February 16, 2011 at 1:38 pm

    I consider it to be a fundamental right of any citizen living in a country which purports to be a democracy, to have ready access to the healthcare option of their choice.

    Hear hear! My healthcare option of choice is heroin. By the bucketload. And I must be free to treat my children with this, as I know it certainly has an effect.

  10. Johnnie
    February 16, 2011 at 2:41 pm

    Thanks for the useful template:

    Dear Andrea,

    I am writing to you about the MHRA consultation document entitled Review of Medicines Act 1968: informal consultation on issues relating to the PLR regime and homeopathy. As a scientist who is aware that homeopathy doesn’t work beyond placebo, I am deeply concerned by the current orchestrated campaign for homeopathy, which is led by the homeopathic industry.

    I consider it to be a fundamental right of any citizen living in a country which purports to be a democracy to have ready access to the healthcare option of their choice. This includes homeopathy, so long as the user makes an informed, educated choice and understands the history and science behind the homeopathic tradition.

    I find your statement below totally unacceptable for the new registration labels:

    “A homeopathic medicinal product licensed only on the basis of safety, quality and use within the homeopathic tradition”

    as this implies that it may actually do something. Far better would be a warning, based on the current available evidence, that homeopathic treatments contain no active ingredient and that there is no good evidence that they are effective for any condition.

    Cheers,

    Johnnie

  11. February 16, 2011 at 3:22 pm

    The new wording which is being suggested by sense against science…

    Is this your misprint or theirs?

  12. John H
    February 16, 2011 at 4:48 pm

    Andy – I poached bits from you and DC ( for which apologies)and used the quacks template:

    Dear Ms Farmer,

    I am writing to you about the MHRA consultation document entitled; Review of Medicines Act 1968: Informal consultation on issues relating to the PLR regime and homeopathy.

    As a member of the public who regards homeopathy as scientific nonsense (a view endorsed by the overwhelming majority of scientists and medical practitioners in the UK as well as the House of Commons Select Committee) and who can see no possible (or indeed scientifically demonstrable) benefits from its application I am deeply concerned by the current orchestrated campaign by the homeopathy industry which is led by self-appointed pressure groups and manufacturers who are fearful for their lucrative businesses peddling untested pseudo-medicines to the public.

    This campaign, fuelled by naked self-interest and financial greed is in direct response to the logical and scientific evidence provided by the HoC SC, Sense About Science, and a large and diverse number of scientifically qualified scientists and bloggers.

    I consider it to be a fundamental right of any citizen to have ready access to healthcare. However I also believe that such healthcare should be regulated and should be proved scientifically efficacious, irrespective of its origin (from global pharmaceutical corporations to shops selling herbal medicines). This manifestly excludes homeopathy for which there is no scientific evidence whatsoever as to efficacy.

    The pharmaceutical products I take currently for three crushed vertebrae contain tested and validated ingredients and come with a comprehensive document detailing the ingredients, potential side effects, counter indications and additional information (all of which is based on validated scientific research).

    I believe homeopathic products should all be tested and validated in the same way as “real” pharmaceuticals and should also provide similar information as above. There are no “different” forms of medicine (merely medicine) and as such there should be no different sets of rules for the testing and labeling of any product offered as a medicine.

    In the absence of such rigorous scientific testing and validation homeopathic products should be labeled accordingly. For example they could say:

    * This homeopathic product contains no [insert alleged active ingredient].
    * There is no evidence that it works for any condition, other than possibly as a placebo.

    Alternatively a “traffic light” system could be used – as shown below.

    (I used your rabbit from a hat picture here – formatting does not translate)

    This labeling has been devised by scientifically trained individuals and endorsed by numerous academics and scientists (references available if required).

    I look forward to reading your conclusions.

    Yours sincerely,
    John H

  13. February 16, 2011 at 6:11 pm
  14. Mojo
    February 16, 2011 at 6:17 pm

    I notice that the form letter says:

    “I find your statement below acceptable for the new registration labels, and can see no reason to change this statement.”

    On DC’s blog, someone called “lecanardnoir” posted, back on January 26th, “I would suggest to the MHRA that if they receive responses from homeopaths suggesting that they are happy with the proposed form of words to be put on labels, then that is a very good indication that they have got it wrong.”

    Good call.

  15. Denise
    February 16, 2011 at 6:27 pm

    I wonder if any of those who have posted comments here have ever used homeopathy. If not, how can they possibly know whether it is effective or not? And how many of them have any real knowledge or understanding of the “validated scientific research” upon which they base their blind faith in allopathic medicine (i.e. drugs)?

    I wholly agree with Johnnie’s remark that people should have access to the healthcare option of their choice “so long as the user makes an informed, educated choice and understands the history and science behind the homeopathic tradition.” By that token, shouldn’t people also be informed and educated about the methods used by the pharmaceutical industry to test drugs (and the limitations of those methods), and about all the potential side effects of those drugs, before they choose so-called “conventional” medicine?

    I personally would prefer to keep all my options open.

    • Mojo
      February 16, 2011 at 7:16 pm

      “I wonder if any of those who have posted comments here have ever used homeopathy.”

      Personal anecdotes are not a reliable way of determining whether a treatment works. However, I have tried it, and it didn’t seem to do anything.

      “If not, how can they possibly know whether it is effective or not?”

      http://www.ncbi.nlm.nih.gov/pubmed/

    • Mojo
      February 16, 2011 at 7:18 pm

      “By that token, shouldn’t people also be informed and educated about the methods used by the pharmaceutical industry to test drugs (and the limitations of those methods)”

      http://www.ncbi.nlm.nih.gov/pubmed/

      “…and about all the potential side effects of those drugs”

      Check the leaflet included with the drugs, which the packaging tells you to read, and which must include this information.

    • February 17, 2011 at 12:04 am

      That’s a really dumb thing to say. Think of the reverse. If something doesn’t work for you, can you be sure that is ineffective? I’ve never experienced side effects from the drugs I’ve been prescribed by my GP, ergo, those drugs have no side effects.

      The opposite of the “don’t knock it till you’ve tried it” is “never did me any harm”.

      • Daniel
        February 17, 2011 at 2:02 pm

        Bravo! I will use this beautiful line of reasoning from now on.

    • The Founding Mothers
      February 17, 2011 at 12:54 pm

      Or, to put it more bluntly, how do you know jumping off a 300 ft cliff won’t kill you, until you’ve tried it?

    • hat_eater
      February 17, 2011 at 1:37 pm

      I have used homoeopathic remedies many times, they were very effective at quenching my thirst. I might have been somewhat cavalier with dosage though.

  16. Laura
    February 16, 2011 at 6:43 pm

    Yes,have used it.
    No,was not effective…beyond placebo.
    Yes,have read books,articles,papers etc on problems with “normal” medical research…see Ben Goldacre,who doesn`t just criticise alternative medicine (oxymoron?),but also pulls apart other poor research.
    An “informed” choice should be exactly that…informed.What does history have to do with effectiveness of anything…and as for the science behind homeopathy…pray do tell.

    I agree,people should be informed and educated about drug testing,research..and well, everything really.

    Drugs have side effects..because they have…effects.
    Homeopathic remedies have no side effects because that have no effects.
    (I can never understand how the homeopathic community don`t find the fact their remedies have no side effects,slightly weird)
    If homeopathy is so effective…why on earth did “conventional” medicine need to develop?

  17. Peter
    February 16, 2011 at 9:29 pm

    http://www.thejournal.ie/do-you-have-faith-in-homeopathy-2011-02/
    Doesn’t show the figures they claim. Turns out that whilst you may have a chance against sense about science, your going to be crushed by Pharyngula.

    Maybe Homeopaths think that having less votes, means a more potent opinion.

  18. Badly Shaved Monkey
    February 16, 2011 at 10:54 pm

    My favourite comment from that poll page;

    “Homeopathy isn’t medicine. It’s Dumbo’s feather.”

  19. Badly Shaved Monkey
    February 17, 2011 at 8:46 am

    A monkey speaks out in his submission to the MHRA as follows;

    I write in connection with the current consultation on the PLR regime and homeopathy.

    Doubtless the MHRA will have received many lengthy and impassioned submissions on this subject. I believe the two most important points are the following;

    1. PLRs were created as anomalies and the present opportunity should be taken to withdraw them.

    2. The MHRA says of itself;

    “We enhance and safeguard the health of the public by ensuring that medicines and medical devices work and are acceptably safe. No product is risk free. Underpinning all our work lie robust and fact-based judgements to ensure that the benefits to patients and the public justify the risks.”

    There is no credible evidence that any homeopathic remedy works. The Commons’ Science and Technology Committee reviewed homeopathy and its remedies in detail and there can be no doubt that homeopathic remedies have no efficacy.

    The proposed wording for homeopathic products sold under the NRS “A homeopathic medicinal product licensed only on the basis of safety, quality and use within the homeopathic tradition” is quite plainly an evasion of the truth and it is perverse that the public regulator of medicinal products cannot bring itself to make this clear. A more truthful wording would be “A homeopathic product licensed on the basis of safety. It contains no active ingredients and cannot be expected to have any therapeutic benefit. Do not use in place of medical advice and licensed medicines.”

    It is not the role of the MHRA to protect the financial interests of the homeopathic industry. It is the role of the MHRA to protect the public by robust and fact-based judgements.

  20. February 17, 2011 at 11:32 am

    thejournal.ie need to get better pie-chart software. Last time I checked, 80% was more than three-quarters…

    Excellent response to the MHRA, BSM.

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