Testing homeopathy - an idea

[Soapy Sam]

So.
If I go to the pharmacist at Boots, buy a packet of 24 codeine and a bottle of 30C Belladonna and announce my intention to swallow both lots at once.

How should I expect him to respond?

 

[Badly Shaved Monkey]

The ASA didn't cope very well when I complained some time ago about the insidiously deceptive nature of the National Lottery's publicity campaign with its slogan "Think Lucky"

Having got the brush-off I wrote to the president of the Royal Statistical Society, but I received no reply sadly. Here is an excerpt of my letter, which gives some of the background;

"First, a television commercial sought to imply a connection between a person’s positive or negative outlook, their “luck”, and hence their chances of success in the Lottery. Secondly, a radio commercial dealing specifically with jackpot “rollovers” saying that “it’s not just the money that rolls over, but the luck does too” (with apologies for any minor mis-quotation), which rather neatly encapsulates the gamblers fallacy.

The person who dealt with the complaint appeared unable to follow the train of her own logic: a lottery company may invoke the notion of luck and may imply that mental attitude might alter luck and you have to be “a very lucky person to win” the lottery, yet the advert “is not implying that by having a positive attitude the statistical chance of winning the lottery will increase”."

My point was that they are legally obliged to run a fair game, but ther campaign depends on lay-people's notions that a lottery can be influenced by factors like personal feelings of luck.

National Lottery's campaign is still going and remains just as deceptive now as it was when they first started it.

It is of course all symptomatic with our society's inability to deal with risk and chance in an era when "God's will" is not a generally acceptable explanation of random events. See also MMR. See also post hoc ergo propter hoc fallacy deployed by sCAMmers.

 

[Mojo]

See also post hoc ergo propter hoc fallacy deployed by sCAMmers.

With a bit of luck the ASA might not be susceptible to that one. For example:

The Authority took expert advice and understood that the advertisers' evidence was unpublished and non-peer reviewed and that the product trials the advertisers had sent were uncontrolled.
From here (My emphasis)

They also came down fairly heavily on Penta recently, for example. It's certainly worth a try if any SCAMsters can be pinned down to actual claims in a medium covered by the ASA.

It's just a shame they don't cover claims made on websites, or in shop windows.

 

[Asolepius]

The ASA didn't cope very well when I complained some time ago about the insidiously deceptive nature of the National Lottery's publicity campaign with its slogan "Think Lucky"

Having got the brush-off I wrote to the president of the Royal Statistical Society, but I received no reply sadly. Here is an excerpt of my letter, which gives some of the background;

"First, a television commercial sought to imply a connection between a person’s positive or negative outlook, their “luck”, and hence their chances of success in the Lottery. Secondly, a radio commercial dealing specifically with jackpot “rollovers” saying that “it’s not just the money that rolls over, but the luck does too” (with apologies for any minor mis-quotation), which rather neatly encapsulates the gamblers fallacy.

The person who dealt with the complaint appeared unable to follow the train of her own logic: a lottery company may invoke the notion of luck and may imply that mental attitude might alter luck and you have to be “a very lucky person to win” the lottery, yet the advert “is not implying that by having a positive attitude the statistical chance of winning the lottery will increase”."

My point was that they are legally obliged to run a fair game, but ther campaign depends on lay-people's notions that a lottery can be influenced by factors like personal feelings of luck.

National Lottery's campaign is still going and remains just as deceptive now as it was when they first started it.

It is of course all symptomatic with our society's inability to deal with risk and chance in an era when "God's will" is not a generally acceptable explanation of random events. See also MMR. See also post hoc ergo propter hoc fallacy deployed by sCAMmers.

Another hobby horse of mine! I don't mean to derail the thread, but I am rather irritated when someone presses the button and cries "Good luck everybody". By definition 14 million people are not all going to have good luck.

 

[Asolepius]

I just went into the local health food shop, and perused the homeopathy section. Most of the packs didn't have indications, but quite a few did. I could not find any bearing the obligatory wording "homeopathic medicine without therapeutic indication". Of course the section was surrounded by loads of literature containing completely false claims of efficacy.

But all this is not new. It's a matter for the MHRA, but they won't (or can't) enforce the law. My OP was a subtly different approach, by putting the onus on retailers to prove the conformity of the products they are selling. Documentation provided by manufacturers on dilution, succussion, provings, and all the other rubbish, will not do. What I am asking is, how can the paying public possibly know that any homeopathic medicine (and I use the latter term loosely) is what it says it is? Is there any independent testing laboratory that could show that? I believe this is a legal point which should be tested in the courts. If a court concludes that there is no way of proving that, then the law is at last saying that there is nothing in the product.

 

[Rolfe]

I could not find any bearing the obligatory wording "homeopathic medicine without therapeutic indication".

To be fair to Boots, the pack I bought did indeed have that wording on it.

My OP was a subtly different approach, by putting the onus on retailers to prove the conformity of the products they are selling. Documentation provided by manufacturers on dilution, succussion, provings, and all the other rubbish, will not do. What I am asking is, how can the paying public possibly know that any homeopathic medicine (and I use the latter term loosely) is what it says it is? Is there any independent testing laboratory that could show that? I believe this is a legal point which should be tested in the courts. If a court concludes that there is no way of proving that, then the law is at last saying that there is nothing in the product.

You'd think there ought to be some way to test this point. Are we really in Catch 22?

Rolfe.

 

[moopet]

So.
If I go to the pharmacist at Boots, buy a packet of 24 codeine and a bottle of 30C Belladonna and announce my intention to swallow both lots at once.

How should I expect him to respond?

As with the mass "suicides" various skeptics have performed for the media over the years by taking many times the stated dose of a homeopathic sleeping draught, for example, it completely misses the point.
A homeopath would just say that the preparation had no harmful side-effects, and the process of succession was there because it was either "just as" or "more" effective when the dilution was higher. By their own standards, taking less of the drug should heighten the effect, so said skeptics might have been asleep still if they'd only taken a tiny sip.

Or something.

If anyone said, "Stop! No! Call an ambulance!" then they wouldn't be on one side of the fence or the other - they'd have no idea what homeopathic medicines are purported to be.

 

[Asolepius]

I have done a bit more research on the UK scene. Firstly, the MHRA requirements for registering a homeopathic medicine. Download the PDF entitled "The Homoeopathic Registration Scheme:guidance.....". Briefly, there are 2 types of licence. When the Medicines Act came into force in 1971 all medicines already on the market were given licences of right. This was to avoid retrospectively assessing all existing products, which would have been impossible. For homeo ones, these are identified by licence numbers starting with PLR. All medicines introduced after 1971 must be registered with the MHRA. These have licence numbers starting with PL. What amazed me was the amount of fuss being made about nothing. Homeo medicines have to meet the same standards for documentation and manufacture as orthodox ones. They have to comply with Good Manufacturing Practice (GMP), and there has to be a Qualified Person (an EU requirement) who signs off documents and products for release. What made me fall about laughing was the requirement for stability testing! I shall be phoning the MHRA to find out how they can demand this, when there's nothing in the product to start with (why don't we all do this? All the phone numbers are at the back of the PDF). It all seems to be a monumental waste of time.

Regarding labelling, any PLR products are allowed to have indications on the labelling. This presumably is because they had it for centuries before so they could not be stopped in 1971. PL licensed products must not have indications, and must bear the words `homoeopathic medicine without approved therapeutic indication'.

Armed with all this, I went into Boots this evening. There on the shelf, among all the black cohosh, devil's claw, Bach flower etc, were 2 interesting Boots own brand homeopathic products. One was labelled a teething remedy for infants, and the other was for hay fever. Product licences were PL 01175/5798 and PL 01175/5020. Neither bore the mandatory wording as above. But they did say "Do not exceed the stated dose`. One has to wonder why. I marched up to the pharmacist with the latter pack in my hand, and explained what I have set out above. He diligently wrote it all down, promising to phone head office next day. I asked him what he thought of the ethics of selling this stuff, and he replied that there is a debate going in the profession right now about it. He did not leap to Boots' defence when I said it was unethical to sell products which did nothing at all.

I strongly recommend reading the MHRA guidance. It opened my eyes on how an entire edifice of regulation can be built on a foundation of crap. I feel another article coming on.

 

[Rolfe]

Les, can you find out where I can find a list of all products which have these licences? This is of extreme relevance to the veterinary legal situation, believe it or not.

Rolfe.

 

[Asolepius]

Les, can you find out where I can find a list of all products which have these licences? This is of extreme relevance to the veterinary legal situation, believe it or not.

Rolfe.

Do you mean the split between PLR and PL? I would know where to look for proper drugs, but not sure about homeo. I'll have a rummage.

 

[Rolfe]

Do you mean the split between PLR and PL? I would know where to look for proper drugs, but not sure about homeo. I'll have a rummage.

I just mean everything that has a licence. As we're constantly being told that these are the only homoeopathic remedies it's lawful for a vet to use under the cascade. (And even then, with very significant restrictions.)

Rolfe.

 

[Asolepius]

Further clarification from the MHRA.

Stocks
For the uninitiated, these are extracts from base material. They are characterised using chemical markers, as defined by a homeopathic pharmacopoea (usually the German one). Markers are used for TLC or HPLC (thin layer or high pressure liquid chromatography) – not clear how they are selected. There seem to be no particular criteria for selecting any marker out of the millions in an extract (or `tincture'). Stocks have to satisfy stability testing requirements – but this will depend on the marker selected. I could not get any clear answer on how a particular marker detectable by TLC (usually) or HPLC (less often used) was selected. It seems to me that there's scope to select the marker that suits what you want to show. I asked how the selected marker could be shown to have any relevance at all to the claimed therapeutic effect, and the answer was that it could not be. So why do stability testing, if we are not testing anything to do with efficacy or even distantly connected with it?

Manufacture
MHRA relies on manufacturer's documents, and inspections. I have seen some interesting calculations on the volumes involved in dilution - could be litres per finished dose. I asked how they could be sure that manufacturers were really doing this, but they did not really understand my question.

Stability Testing
There is no stability testing of finished products, only on the stocks (see above). MHRA accepts that there is nothing to test. This is quite misleading in the guidance document, which says that stability testing must be the same as for normal pharmaceuticals. This is quite incorrect.

Are products genuine?
This goes back to my OP on this thread. If challenged, manufacturers will rely on their licences, and MHRA compliance. There is of course no way that products can be independently tested. I am sure that if anyone did test this principle, the MHRA would gladly accept whatever the manufacturer wants to invent.

List of homeopathic product licences
There are apparently thousands - might be possible to get a list via the MHRA info desk. I will try, and failing that will hit them with an FOI request. I asked whether most are PLR, but they don't really know. I would guess so as most carry indications on the labelling.

So overall, I think my idea is a non-starter because the MHRA is happy to carry on collecting licence fees from these quacks, and will not want any boats rocked. Actually they quite rightly point out that they are just implementing EU and UK law, which requires these things to be regulated. It's interesting that homeopathy was selected by the EU for regulation, which ignores all sorts of other products with health claims (eg Penta-Water).

 

[bruto]

But getting back to the original post, what could a manufacturer do if one took a bottle of homeopathic preparation and with apparent sincerity complained, "I think this is a fake. I, a believer in the science of homeopathy, demand that it be tested to determine whether or not it contains the correct substance." After all, it is alleged to contain something. The manufacturer can point to the procedure, but can they prove that the bottle in question was prepared according to that procedure? Unless you can find a way to record and verify the career of each bottle from preparation to packaging, how can you prove that without testing the contents?

It's easy for the industry to shrug off charges that homeopathy is a fake, but it might be harder to fend off a charge of fake homeopathy.

 

[Soapy Sam]

bruto- It's simple. The manufacturer would tell you to take the medecine.
If you get better, it was homoeopathic.
If not, you had the wrong disease.

 

[bruto]

bruto- It's simple. The manufacturer would tell you to take the medecine.
If you get better, it was homoeopathic.
If not, you had the wrong disease.

Yeah, you're probably right. I think I'm just getting punchy from arguing with Iacchus, and had momentarily forgotten that it really is not possible to nail jello to the wall.