25. We are concerned that homeopathic products were, and continued to be, exempted from the requirement for evidence of efficacy and have been allowed to continue holding Product Licences of Right. We recommend that no PLRs for homeopathic products are renewed beyond 2013. (Paragraph 121)
Response:
See our response to Recommendation 26 below.
26. We conclude that the MHRA should seek evidence of efficacy to the same standard for all the products examined for licensing which make medical claims and we recommend that the MHRA remove all references to homeopathic provings from its guidance other than to make it clear that they are not evidence of efficacy. (Paragraph 128)
Response:
Homeopathic medicines are safe, there is evidence of their effectiveness, and there is considerable public demand and traditional use. In these circumstances it would be oppressive for the state to take draconian measures to restrict their availability, which is what these recommendations imply. Such measures would in any case be ineffective; the main net effect would be to drive the market on to the Internet. Homeopathic medicines are widely available in the EU and it would be illegal to restrict Internet purchases of them in the UK.
I think we've already made the case that the first section is wrong. Although homeopathic medicines are chemically safe, I would argue that they are a harm to society in other ways. There is also no good evidence of effectiveness, although I concede there is considerable public demand for them. Given that a large portion of this premise is wrong, the line "In these circumstances it would be oppressive for the state to take draconian measures to restrict their availability, which is what these recommendations imply." is easily countered simply by realising that these circumstances do not exist. It's not even necessary to consider whether the S&TC recommendations are draconian, which I do not believe they are. I'd also argue it's pretty hard to come up with really draconian legislation for licensing healthcare products - it's one of those areas you want rigorous legislation to protect the consumer.
27. We consider that the MHRA's consultation, which led to the introduction of the NRS, was flawed and we remain unconvinced that the NRS was designed with a public health rationale. (Paragraph 135)
Response:
The legislation was enacted by due process, including an extended consultation period.
I will leave this to more legal minds than mine, but something enacted in a legal manner and with an extended consultation period is not necessarily correct and free of flaws.
28. We fail to see why the label test design should be acceptable to the MHRA given that, first, it considers that homeopathic products have no effect beyond placebo and, second, Arnica Montana 30C contains no active ingredient and there is no scientific evidence that it has been demonstrated to be efficacious. We conclude that the user-testing of the Arnica Montana 30C label was poorly designed with parts of the test actively misleading participants. In our view the MHRA's testing of the public's understanding of the labelling of homeopathic products is defective. (Paragraph 140)
Response:
It is factually incorrect to state there is "no scientific evidence" that Arnica montana, diluted beyond Avogadro's constant, has been demonstrated to be efficacious. The following RCTs have reported positive findings:
I've previously and repeatedly (to the point of it being tiresome) made the point that bad or weak evidence is no evidence at all. I could produce scientific evidence that the entire executive of the BHA are penguins, and technically claim that it is factually incorrect to state that the evidence does not exist. It does - but it is weak and supports a claim that vast amounts of other evidence contradicts and outweighs decisively.
30. We consider that the way to deal with the sale of homeopathic products is to remove any medical claim and any implied endorsement of efficacy by the MHRA--other than where its evidential standards used to assess conventional medicines have been met--and for the labelling to make it explicit that there is no scientific evidence that homeopathic products work beyond the placebo effect. (Paragraph 146)
Response:
See our response to Recommendation 32 below.
The response to recommendation 32 is again that claim there is evidence. I won't bother expanding on that, but I think it is interesting that the quoted section of the report shows clearly that the S&TC report is not draconian - it recommends a change of labelling and licensing in order to inform people, not to completely outlaw homeopathy.
I'm not going to say anything about this next quoted section. I'm just going to emphasise one bit of it, for humour value for those in the know. The emphasis is most definitely mine.
33. By providing homeopathy on the NHS and allowing MHRA licensing of products which subsequently appear on pharmacy shelves, the Government runs the risk of endorsing homeopathy as an efficacious system of medicine. To maintain patient trust, choice and safety, the Government should not endorse the use of placebo treatments, including homeopathy. Homeopathy should not be funded on the NHS and the MHRA should stop licensing homeopathic products. (Paragraph 157)
Response:
Homeopathy is more than a placebo and rightfully belongs in the NHS where patients can best benefit from doctors integrating it into healthcare.
This report and its conclusions represent a rush to judgment, reflecting the narrow and cursory nature of the review. It was systematic only in excluding facts that tend to support homeopathy: it omits or misrepresents any research evidence (including the BHA's), which challenges the view that patients' response to homeopathy is due to placebo. Its conclusions are unsustainable in the light of scientific evidence.
Moving on.
Even more disturbing is the dismissive manner in which the committee deals with the healthcare of patients and their response to homeopathic treatment. Patient-reported outcome measures (PROMs) are increasingly seen by the NHS as a critical component in assessing healthcare interventions. The NHS homeopathic hospitals have excellent PROMs results.
PROMs may be a useful measure of when things in the NHS aren't working right. It does not follow that PROMs are a useful measure of when things are working right. To draw a ridiculously extreme analogy, suppose I am in the business of employing teachers to work in schools. I consider criminal records checks as a 'critical component in assessing teacher suitability'. It does not follow that because a school employs no teachers with a criminal record, that the teachers it employs are excellent or even remotely qualified to teach.
This narrow-minded and illiberal report is highly tendentious, consistently misrepresenting the scientific evidence to denigrate homeopathy, and making unfounded and pejorative allegations against those who advocate, practice or develop research in homeopathy. Repeatedly asserting that it is only placebo does not make that assertion true.
I personally don't find it in the slightest bit illiberal. I think it is narrow-minded only in the sense that it isn't so broad-minded as to include things that aren't true. While repeatedly asserting that homeopathy is only placebo does not make it true, repeatedly claiming there is evidence for homeopathy (even when you list references) equally does not make it true.
These last two sections are not quite so dire as the preceding ones, but the BHA response is still fundamentally founded on the incorrect idea that there is enough evidence for homeopathy to support its outlandish claims. It's down to homeopaths to support and legitimise their claims. Wake me up when they've won their Nobel Prize.
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