The MHRA and their Double Failure over Homeopathy
The Medicines and Healthcare products Regulatory Agency (MHRA) have been heavily criticised in recent years for abandoning their core mission by allowing homeopathic sugar pills to contain statements about what symptoms and illnesses they can be used for without having to provide evidence that this is true.
The MHRA mission and values:
Mission
The MHRA’s mission is to enhance and safeguard the health of the public by ensuring that medicines and medical devices work, and are acceptably safe.Values
In pursuing our mission we will strive to act with:
- integrity;
- openness;
- courtesy;
- responsiveness;
- timeliness;
- professionalism;
- impartiality; and
- consistency.
The MHRA allow sellers to submit evidence from homeopathic ‘provings’ as evidence. A proving is where a homeopath takes a new type of homeopathic pill to see what symptoms it generates. Homeopaths believe ‘like cures like’, so an onion, which makes your eyes stream, can cure hayfever – allegedly. However, homeopathic pills have been so diluted that no ingredients actually remain. What homeopaths ‘prove’ is plain sugar pills – any symptoms they note are either coincidental or imaginary. This is the first failure of the MHRA to allow such nonsense methods to act as a guide to efficacy.
In order for a homeopathic pharmacy to make claims, they must submit the evidence from their provings. So, far few submissions have been made. And yet, homeopathic pharmacists continue to sell many sugar pills, with indications, with no license and apparently with impunity. Is the MHRA even failing to uphold its own rules?
I tested this out.
Over a year ago I was invited to speak at London’s Skeptics in the Pub. I chose to speak about the dilemmas of regulating quackery. As part of my preparation, I visited London’s Nelson’s Homeopathic Pharmacy just off Oxford Street. I went in and said I needed something for an upset stomach and that I had diarrhoea. “Do you have anything like Imodium?” I was told that the stuff they has would not just ‘suppress my symptoms’ but get to the bottom of my problem – so to speak.
I was handed a little green container of white sugar pills labelled ‘Traveller’s Diarrhoea’. The full label read:
TRAVELLER’S DIARRHOEA
RELIEVES SYMPTOMS OF DIARRHOEA & VOMITING DUE TO
CONSUMPTION OF UNWASHED FRUITS, VEGETABLES, BAD MEAT
OR FISH. DOSAGE. TAKE 2 TABLETS EVERY HOUR UNTIL BETTER
ARSENICUM 30/PODOPHYLUM 30/PYROGEN 6/CARBO VEG 30/NUX
VOMICA 30
EXP 12/12 KEEP OUT OF CHILDRENS REACH
NELSON’S HOMEOPATHIC PHARMACY
73 DUKE STREET, LONDON W1K 5BY 020 7629 3118 P
The number 30 is significant because it means the ingredients have been diluted to 1 part in 10 to the power of 60. (that is 30 sequential dilutions of 1 part in 100). In other words – the pills I got were just plain sugar pills with no active ingredients.
Now, remember – like cures like. So being actually healthy at the time, if I had taken one of these pills I would have ‘proved’ the pill and developed the symptoms. Not wanting to do a crude experiment of n=1, during my talk at Skeptics in the Pub I handed them out to the crowd so that dozens of brave and selfless sceptics had the chance to develop a rather uncomfortable journey home.
We downed our pills, and thankfully, due to science, we all remained rather intact and the pub landlord did not have to clear up a rather horrible mess.
On the 28th of March 2008, I submitted an enquiry to the MHRA suggesting that this might be an illegal product as it had no marketing authorisation. On the 14th of April 2008 I was told that the case had been passed onto the MHRA’s Enforcement and Intelligence Group.
Now you may have noticed that the MHRA’s listed values include
- responsiveness;
- timeliness;
- professionalism;
25th August 2009
I have been informed by our Enforcement Unit that an investigation has taken place in response to your complaint below. The outcome of the investigation is that following advice from the Enforcement Unit, Nelson’s have removed the product you mentioned from their display shelves.
Regards,
Yes, timeliness in this case means 17 months.
It may also come as a bit of a shock to find this product still for sale on Nelson’s website. It may have been ‘removed from the shelves’ but is still advertised on the web. You can also see other similar products that are intended to cure constipation, accident & injury, allergic reactions, bites & stings, hangover & indigestion, heat exhaustion, jet lag, and sun exposure. All the same sugar pill.
In fact, the Nelson’s web site is riddled with products that make specific claims and that do not appear to have any marketing authorisation.
Some examples:
- Migraine Headaches (Helps with migraine symptoms.) http://www.nelsonshomeopathy.com/shop-online/Migraine-Headaches_prod1628.aspx
- Morning Sickness Relief (To help relieve symptoms of morning sickness….) http://www.nelsonshomeopathy.com/shop-online/Morning-Sickness-Relief_prod1629.aspx
- PMT (To help relieve symptoms of premenstrual tension.) http://www.nelsonshomeopathy.com/shop-online/P.M.T._prod1634.aspx
- Sore Throat (To help relieve symptoms of sore throat) http://www.nelsonshomeopathy.com/shop-online/Sore-Throat_prod1639.aspx
- The Nelsons Quit Smoking Kit http://www.nelsonshomeopathy.com/shop-online/The-Nelsons-Quit-Smoking-Kit_prod1664.aspx
So, what’s the harm? On the face of it, all the consumer will be getting is some sugar pill placebos and so there can be no more harm than any other homeopathic remedy. But the harm comes when the purchaser may well be relying on specific effects.
We saw recently how Neal’s Yard Remedies were selling sugar pills to customers and telling them that these could prevent malaria. The BBC undertook an investigation and interviewed their ‘Medicines’ Director, who stormed out of the meeting after being asked if this was ethical and legal.
After the BBC forwarded on their evidence, the MHRA investigated and slapped their wrists. That was it. Despite the appallingly irresponsible nature of Neal’s Yard behaviour the MHRA saw fit not to prosecute. I for one, was quite shocked.
The MHRA appear to be quite tolerant of homeopathic pharmacies sales processes. Why should this be? Could the MHRA think it not worth the effort to better police this sector? Are they under other influences to tread softly here?
I do not know. But the problem is deeper and more entrenched than even these problems suggest. Homeopaths are a group explicitly opposed to real medicine. They define their product in terms of direct opposition to medicine. From its first invention, homeopathy made grand claims to universality and having found the true philosophy of curing illness. All other approaches were heresy and to be opposed. This is what makes the vipers nest of homeopathy so insidious as a source of anti-scientific thinking about disease which leads to more widespread problems such the stubbornly unreasonable anti-vaccine movement.
We can see this foundation of anti-vaccine thinking in many homeopathic products. A large fraction of the Ainsworths medicine cabinet consists of homeopathic versions of vaccines. These are often in the form of what homeopaths call nosodes where some diseases tissue or some other ‘infectious’ agent is taken and serially diluted and shaken and probably banged against a leather bible many times to create the homeopathic witchcraft pill. Look at the remedy lists of Ainsworths and you will see a product for each Influenza strain going back 20 years. You will find homeopathic replacements for Measles vaccine, Parotitis vaccine (mumps) and Rubella. You find homeopathic sugar pills for all forms of Hepatitis, strains of TB, and Typhoid, as well as the usual comedy remedies such as shipwreck, trout and Ayres rock.
These products are making implicit claims to be alternatives to real vaccines. All of them are the same useless sugar pill pulled from the same large tub at Ainsworths, some hocus pocus spouted over them, bottled, labelled and shipped.
Why the MHRA do not prosecute for straightforward fraudulent trading I just do not know.
***********************************************************************************
Update
18th September 2009
Simon Perry from the excellent Adventures in Nonsense blog wrote to the MHRA to see what their response to this criticism would be. I have also written, but not received a reply.
Dear Mr Perry,
Thank you for your recent enquiry to the MHRA and please accept our apologies for the wait you have experienced. We have liaised with our enforcement team and the investigator involved and we can confirm that our response to this blog post is as follows:
“This referral was allocated to an investigator and concluded by way of a compliance visit when the product was removed from the shelves. The matter of the product being available via the company internet site has been referred to our enforcement group to take the appropriate action.”
Please contact us again if you need further assistance with this, or any other queries.
Kind Regards,
Ben, on behalf of the
Central Enquiry Point
Information Centre
Medicines and Healthcare products Regulatory Agency
At the time of writting, Nelsons are still selling the product online.
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