Homeopathy: Medicine for the 21st Century

A hazard to health

A central concern for H:MC21 is the ASA's claim that the only reliable information is from randomised controlled trials (RCTs), since nearly 50% of RCTs of medicines are inconclusive.[1] Every drug which is withdrawn because of its harmful effects or limited benefit has previously been 'proved' safe and efficacious.

The Medicines and Healthcare products Regulatory Agency (MHRA) operates a ‘yellow card scheme’ to monitor problems with drugs, precisely because RCTs are not reliable and the effects of drugs in the real world may be very different.

The ASA is claiming that information from patients themselves is not valid, but “On average, about 85% of the evidence used to reach any definitive medical diagnosis comes entirely from what patients say - from their own stories. Physical examination adds about 7% to this, and investigations like X-rays, blood tests and so on add another 7%.”[2]

The MHRA collects Yellow Card reports from anyone from the UK, not just doctors, but also patients, and “these are used to identify side effects and other problems which might not have been known about before. If a new side effect is found, the MHRA will review the way that the medicine can be used, and the warnings that are given to people taking it to minimise risk and maximise benefit to the patient.”[3]

Patients can die because of failures to listen to what they say about their health.

H:MC21 wants to know why the ASA endorsing such dangerous arguments in contradiction to the position of the MHRA.

The available scientific knowledge

We believe that the H:MC21 case shows that the ASA is not basing its decisions on “the available scientific knowledge” (CAP Code 12.1). Instead of looking at all the evidence in context, the ASA appears to be making decisions on the basis of a narrow ideological position. This position is in contradiction to scientific knowledge, in contradiction to the paradigm of evidence based medicine (EBM) and in contradiction to good medical practice.

H:MC21 wants to know why the ASA is not basing its decisions on "the available scientific knowledge"

Patient choice

H:MC21 is also profoundly concerned at the impact the ASA can have on patient choice. The ASA has informed us that it "had considered very few complaints relating to Homeopathy before the extension  of our remit in 2011 to online marketing communications". Since then, of course, people ideologically opposed to homeopathy and other CAM therapies have used this as an opportunity to attack practitioners and their organisations.

We are concerned that the ASA has accepted the ideological arguments of these opponents of CAM, despite the fact that the arguments are scientifically inaccurate and hazardous to health.

H:MC21 wants to know why the ASA has rejected the requirement to "not arbitrate between conflicting ideologies"

Fighting for a fair and safe regulator

H:MC21 has spent the last two and a half years trying to get the ASA to abide by its own rules, to respect the available scientific knowledge, and to ignore the propagandist arguments against homeopathy. H:MC21's submissions have mainly been attempting to correct the investigation team's mistakes.

After two and a half years our experience has been that the ASA has strenuously resisted all our attempts to get it to act fairly and impartially. When we made a formal complaint about the process, the Chief Executive rejected our complaint, but then had to reverse his position four days later.

Some of our evidence was not even read until we appealed the adjudication. Nor did the ASA employ an 'expert' until the appeal process - and then it was an expert who had no qualifications in homeopathy, but extensive experience in conventional pharmacology. When we pointed out what we considered to be serious errors and omissions in his reports, the ASA failed to justify or correct them.

The protest is not about a single advert, but about the public's right to a fair and safe regulator.