Memorandum submitted by Professor David Colquhoun (HO02)

 

(1) Government policy on licensing of homeopathic products

(1.1) By their own admission, the government has simply ignored the evidence. The Government's responses to the Committee's questions (http://www.parliament.uk/documents/upload/091021_Final_Evidence_Check_response.pdf ) said

"Thirdly, no scientific evidence was examined in drawing up the National Rules Scheme,"

 

This is a quite astonishing admission for a government that claims to base policies on the best scientific advice. The same document asserts

"Homeopathy has a long tradition in Europe and is a recognised system of medicine across the EU".

 

It is most certainly not a "recognised system of medicine" for anyone with the most rudimentary scientific education. Quite on the contrary. Throughout my life time homeopathy has been a sort of bad joke. Indeed it has been a joke ever since Oliver Wendell Holmes famous essay "Homeopathy and Its Kindred Delusions", written in 1842.

(1.2) It is however, a joke in poor taste. Homeopaths endanger the lives of patients when they try to treat serious conditions like malaria and AIDS, which they routinely do. The government must be aware that two homeopaths in Australia were charged with manslaughter and sentenced to 6 and 4 years in prison, when their own daughter died for lack of proper treatment. It is only a matter of time before the same thing happens here. If and when it does, the Department of Health will bear some of the blame because of its shameful disregard for evidence.

 

(1.3) For some reason that I have never been able to discover, the MHRA was pushed in 2006 into allowing highly misleading labelling of homeopathic products. It should be investigated whether the new labelling is legal under the Consumer Protection Unfair Trading Regulations of May 2008. These regulations state, inter alia, 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"

Such claims are, of course, rife in the homeopathic industry and in my opinion the labelling that has been allowed by the MHRA is illegal because the regulations refer to the way labels will be interpreted by the "average consumer". I do not believe that the average consumer will interpret the words "traditionally used for the treatment of" as a synonym for "ineffective in the treatment of ", though that is the actual meaning.

(1.4) It is nothing short of surreal that the MHRA should have a committee to earnestly consider whether pills, which mostly contain nothing whatsoever, are safe and manufactured properly (http://careers.bmj.com/careers/view-job.html?id=20018826 ). This sort of absurdity makes a mockery of any claim that the government is interested in evidence. It is surely the ultimate example of the precedence of mindless process and procedure over common sense. Pure comedy.

 

(2) Government policy on the funding of homeopathy through the NHS

(2.1) At present the government (disgracefully) has no policy on this. Every time the government is asked about it, no answer has been forthcoming. The question is merely referred to PCTs. DH has consistently evaded its responsibility to assess the evidence and it should now live up to that responsibility. Many PCTs have stopped, or greatly reduced their funding for homeopathy. One homeopathic hospital has shut altogether, and funding for homeopathy at the Royal London Homeopathic Hospital has been greatly reduced. But there is no consistency in policy whatsoever, because the DH has offered no direction and has ignored scientific advice.

(2.2) To allow sugar pills to be paid for by the NHS is an absurdity. If it is not sufficiently absurd for the DH to take action itself then they should refer homeopathy as a whole to NICE, just as any other proposed treatment would be (and it must be made sure that NICE does the evaluation properly, and not appoint a lot of homeopaths to do the evaluation). This was recommended in the House of Lords report (2000). It was recommended again in the Smallwood report (sponsored by the Prince of Wales). It is beyond comprehension that DH has still not done it.

(2.3) If it is thought that a placebo is something worth having available (a highly contentious idea) then it should be done honestly. The present practice combines the worst of both worlds. Doctors are not allowed to prescribe an honest placebo, even if they think that is the best they can do for the patient. But they are allowed to prescribe a dishonest placebo by referring the patient to a homeopath.

 

(3) The evidence base on homeopathic products and services.

(3.1) I see no point in my going through the evidence yet again. It has all been done very well in, for example, Singh & Ernst's book, Trick or Treatment. There is clearly no convincing evidence that it works. In addition, the prior odds of a pill that contains no active ingredient having an effect is so small that enormously strong evidence would be needed to persuade one that it worked. After 150 years the homeopaths have still failed to produce any remotely convincing evidence.

(3.2) The homeopaths who submit responses to this committee will, as always, pick out the few small and badly designed trials that appear to support their cause. Their approach to evidence is, in my view, nothing short of dishonest. I can only presume that one of the reasons for this is that they have the ultimate vested interest insofar as they would lose their livelihoods if they were to admit that there was no worthwhile evidence for the efficacy of their pills.

(3.3) If homeopathy worked the whole of chemistry and physics would have to be overturned. The idea is quite simply preposterous. It is a waste of time and money to look for evidence if you aren't, at the same time, willing to abandon chemistry and physics. To pretend otherwise is simple duplicitous double-think. It is time that the government decided whether or not it believes in Avogadro's number or not. Government policy at the moment is based on the absurd proposition that Avogadro's number is right if you are talking about chemistry but wrong if you are talking about homeopathy.

 

(4) Declaration of interests

I am a pharmacologist. My research has been funded entirely by the MRC and the Wellcome Trust, never by the pharmaceutical industry. I have financial interests in neither the pharmaceutical industry nor the alternative medicine industry. I do have a strong interest in the quality of evidence and in how to distinguish what works from what doesn't. I have written a textbook of statistics (Lectures on Biostatistics, Clarendon Press Oxford, 1970) and so have knowledge of that field and particular its application to clinical trials of treatments.

(You will, no doubt, be aware that many of those who write to you to advocate homeopathy make their living from it.)

 

David Colquhoun FRS

Professor of Pharmacology
University College London

November 2009