Memorandum submitted by Professor David
Colquhoun (HO 02)
1. Government policy on licensing of homeopathic
1.1 By their own admission, the government
has simply ignored the evidence. The Government's responses to
the Committee's questions
"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 six and four 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
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
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.
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. The Department of Health (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
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
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
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
David Colquhoun FRS
Professor of Pharmacology
University College London