The Association of Systematic (aka Bullshit) Kinesiology

The Association of Systematic Kinesiology lives by the motto "Prevention Our Shield".

Their flyer (available here and here) does a rather fine job of shielding its readers from the truth.

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Systematic Kinesiology - a sort of wibbly-wobbly twisty-turny variant of chiropractic - is more commonly known as Applied Kinesiology.

The therapy is a confused mish-mash of bogus pseudo-scientific ideas from around the world and is not to be confused with Kinesiology, an entirely different branch of mainstream medicine.

Applied Kinesiology - let's call it Bullshit Kinesiology - was invented less than fifty years ago. Amazingly, the central practice - monitoring small muscle movements in a patient - was demonstrated to be nothing but a trick of the mind a full one hundred and fifty-eight years ago!

The advertisers claim that their Bullshit Kinesiology can treat

"...flatulence... arthritis... depression... dyslexia... infections... hyperactivity ... Irritable Bowel Syndrome... migraines... Repetitive Strain Injury... spots... poor skin... "

I simply don't believe them, and in my ASA complaint I call upon a series of altogether more recent clinical studies to show why.

"I write to complain about a leaflet I picked up at the CamExpo exhibition in London on 24th October this year.

The leaflet promotes the Association of Systematic Kinesiology.

I suspect that the leaflet may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original leaflet by post, if necessary.

1. (i) The therapy promoted by the leaflet is more usually known as "Applied Kinesiology", an invention of the American George Goodheart in 1964.

(ii) It is not to be confused with Kinesiology, a more mainstream (and regulated) medical discipline prevalant in the USA and Canada.

2. (i) The leaflet describes how the therapy is conducted:

"Kinesiology...is a way of identifying any imbalances a person has by monitoring their ability to hold their muscles against light pressure. Each muscle is related to an organ, and also to an energy pathway called a meridian...Together the muscle, organ and meridian form a 'circuit'. If there are chemical, emotional, structural or energetic stresses affecting the circuit, the muscle tested will feel 'spongy', indicating an imbalance. Once an imbalance is found the kinesiologist uses the muscle test again to get feedback..."

(ii) The leaflet continues:

"Based on this feedback the kinesiologist...[will] devise a treatment plan. It may include nutritional supplements...Bach Flower remedies, acupressure...chakra balancing...and more..."

(iii) The explanation is appended by the witticism "There is no guess work with Systematic Kinesiology".

3. The first scientific paper on the ideomotor effect - a phenomenon in which a subject makes unconscious movements in response to certain ideas or stimuli - was published one hundred and twelve years before the invention of Applied Kinesiology [1].

4. I have found no clinical studies lending support to the ideas expressed in the leaflet's explanation, but a great number which refute them, for example:

(i) Kenny JJ, Clemens R, Forsythe KD. Applied kinesiology unreliable for assessing nutrient status. Journal of the American Dietetic Association 88:698-704, 1988.

(ii) Triano JJ. Muscle strength testing as a diagnostic screen for supplemental nutrition therapy: a blind study. Journal of Manipulative and Physiological Therapeutics 5:179-182, 1982

(iii) Haas M and others. Muscle testing response to provocative vertebral challenge and spinal manipulation: a randomized controlled trial of construct validity. Journal of Manipulative and Physiological Therapeutics 17:141-148, 1994.

(iv) Applied kinesiology - Double-blind pilot study. Journal of Prosthetic Dentistry 45:321-323, 1981.

(v) Ludtke R and others. Test-retest-reliability and validity of the kinesiology muscle test. Complementary Therapy in Medicine 9:141-145, 2001.

(vi) Hyman R. The mischief-making of ideomotor action. by ideomotor action. The Scientific Review of Alternative Medicine, Fall-Winter issue, 1999.

5. Therefore, under Section 12.1, I challenge whether the advertisers can substantiate their claim that the following conditions "can be treated using Systematic Kinesiology":

(i) Acid stomach, indigestion
(ii) Flatulence
(iii) Depression
(iv) Phobias
(v) Arthritis
(vi) Asthma
(vii) Catarrh
(viii) "Candida, thrush and bloating"
(ix) Constipation
(x) Digestive disorders
(xi) Dyslexia
(xii) Eczema
(xiii) Tennis elbow
(xiv) "Frequent infections"
(xv) Restless leg syndrome
(xvi) "Hyperactivity in children"
(xvii) Insomnia
(xviii) Irritable Bowel Syndrome
(xix) Lower back pain
(xx) Migraines
(xxi) Repetitive Strain Injury
(xxii) Tennis elbow
(xxiii) Sinus problems
(xiv) "Skin problems, spots, poor skin"
(xv) (Since the leaflet claims "these are just some of the complaints that can be treated") - any other medical condition

6. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] http://www.sgipt.org/medppp/psymot/carp1852.htm
"

Myofascial Release UK - A Tissue of Claims

After getting my hands on a flyer for Myofascial Release UK, I've been trying to get a handle on what the "therapy" actually entails.

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It's not easy, though. Lots of people around the world practise the "art" but their explanations are couched in meaningless mumbo-jumbo like

"this 3D living matrix responds in a natural in intuitive way by releasing and reorganising itself throughout the body"

In fact, the most I can say about myofascial release is that it's some kind of magical soft-tissue prodding therapy. (If you can help, use the comments form below!)

The advertiser's flyer (available here, here and here) isn't quite so evasive about the conditions it thinks the therapy can treat, which include

"...backache, sciatica and pelvic pain - sporting injuries - frozen -shoulder - fibromyalgia, CFS [Chronic Fatigue Syndrome] / ME - carpal tunnel [syndrome] - chronic pain - ...TMJ [Temporomandibular Joint] disorder - injury and surgical scarring - tinnitus - scoliosis [curvature of the spine] - back pain - RSI [repetitive strain injury..."

Evidence? Well, none appears to exist, although there's a single trial concerning the effects of the therapy on an athlete's heart rate.

The advertising regulations require advertisers to hold evidence before making claims. ASA complaint follows!

"I write to complain about a flyer I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for Myofascial Release UK, promotes a "postgraduate training programme in MYOFASCIAL RELEASE".

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. (i) "Myofascial Release" is a soft-tissue therapy.

(ii) The main flyer contains an insert. Both the flyer and the insert makes claims that the therapy treats named medical conditions.

(iii) A number of practitioners promote the therapy. From them, I have been able to find a single clinical trial. The placebo-controlled trial concerns the effects of myofascial release therapy following high-intensity (interval) exercise.

(iv) The trial's authors concluded [1]:

"Myofascial release massage favors the recovery of HRV [heart rate variability] and diastolic BP [blood pressure] after high-intensity exercise (3 Wingate tests) to preexercise levels."

2. The advertisers claim their "Integrated Myofascial Therapy" can "help" with a number of medical conditons.

3. Under Section 12.1 of the CAP Code, I challenge whether the advertisers can substantiate their claims in the main flyer that the therapy can "help with...backache, sciatica and pelvic pain - sporting injuries - frozen -shoulder - fibromyalgia, CFS [Chronic Fatigue Syndrome] / ME - carpal tunnel [syndrome] - chronic pain - ...TMJ [Temporomandibular Joint] disorder - injury and surgical scarring - tinnitus - scoliosis [curvature of the spine] - ...and many others".

4. Under Section 12.1 of the CAP Code, I challenge whether the advertisers can substantiate their claims in the insert that the therapy can "effectively treat...sports injuries, fibromyalgia, chronic fatigue and chronic pain syndrome, trigger point pain, RSI [Repetitive Strain Injury]...back pain, jaw pain and many others".

5. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] Effects of myofascial release after high-intensity exercise: a randomized clinical trial, J Manipulative Physiol Ther. 2008 Mar;31(3):217-23. http://www.ncbi.nlm.nih.gov/pubmed/18394499
"

A Miracle Cure for Societal Malaise

Often I spend a few hours researching and submitting a complaint because of an advert that's dangerous, implausible or just plain misleading.

Sometimes, though, I do it just because the advert makes me laugh.

Let me introduce you to International Flower Essence Repertoire of Argyll!

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Some of the sprays pictured are claimed to have the usual wacky properties, namely

"protection against electromagnetic pollution"

and

"help with adjusting to the local time-zone after long distance air travel"

The punchline, though, is this claim for the firm's "Positive Flow Aura Spray".

"Positive flow was created to help one deal more effectively with the global economic challenges of this time. Positive Flow has a strong action on both the solar plexus as well as the...eyebrows...Positive Flow helps us to cut through the societal malaise brought about by the media's incessant reporting of financial bad news..."

ASA complaint follows! (The flyer is available here, here, here and here)

"I write to complain about a flyer I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for www.healingorchids.com, promotes various "aura-cleansing sprays".

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. Under Section 3.7 (or 12.1) I challenge whether the advertisers can substantiate any of the following claims:

(i) "Electromagnetic pollution such as mobile phone masts, cordless phones in houses and offices, and wireless internet 'hotspots' all contribute to erratic sleep patterns. In the UK by far the worst source of sleep disruption is the national network of Tetra masts for the police...This 'electro-caffeine' is broadcast 24 hours a day throughout the year...Gentle Sleep [can] help address this government-funded assault on our sleep patterns. Gentle sleep helps one to achieve a deeper and more relaxed sleep..."

(ii) "Soul Shield Psychic Protection Aura Spray provides protection for the body's aura or a living space against the incursion of negative psychic energies..."

(iii) "Temple of Light Aura Spray...meet[s] a specific problem in that there can be an incongruity between the Bai-Hui point and the inner chamber of the heart chakra...Real healing is frustrated...To bring about a rapid resolution of this problem, this essence was called into being..."

(iv) The "Being Present Travel & Therapy Aura Spray" is "very helpful for adjusting to the local time-zone after long distance air travel..." and can cause the "healing work of [a complementary] therapist" to be "deeper & more effective"

(v) The "Angelic Canopy Aura & Space Cleansing Spray" is "very powerful" at "clearing...office & living spaces of negative energies" and "cleansing [healing] crystals"

(vi) The "Positive Flow Aura Spray" helps to "cut through the societal malaise brought about by the media's incessant reporting of financial bad news..."

2. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser."

Dr Andre's "miracle" "cancer" treatment

The Vision of Hope Clinic in Brighton offers a novel cancer treatment which consists of injecting their hapless patients with high doses of vitamins.

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The Clinic's flyer (available here and here) makes some interesting claims about other conditions, besides cancer, which their therapies can treat:

"...depression... chronic and degenerative conditons... other metabolic disorders..."

I believe the flyer's claims are highly misleading and probably illegal. I wonder what Dr. Andre Young-Snell will have to say in his defence?

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Unusually for a quack, Dr Andre is actually a real doctor licensed to practise by the General Medical Council.

Nevertheless - another ASA complaint follows!

"I write to complain about a leaflet picked up at the CamExpo exhibition in London on 24th October this year.

The leaflet, for the "Vision of Hope Clinic", promotes an intravenous treatment for "depression", "cancer" and other unspecified "metabolic disorders".

1. (i) The leaflet is titled:

"Vision of Hope Clinic - Complementary metabolic therapies for cancers, depression, chronic and degenerative conditions"

(ii) The leaflet describes the clinic thus:

"The Vision of Hope Clinic is a metabolic therapy and nutritional clinic situated in the beautiful seaside city of Brighton. We specialise in metabolic therapy, a nutritional approach to the treatment of metabolic disorders..."

2. The leaflet describes the "treatment":

"...the latest integrative approach to treat patients with metabolic disorders, primarily cancer...The aim is to boost the patient's immune system to its maximum potential to allow the body to detoxify and repair itself..."

3. (i) A "consultation" at the clinic begins with an assessment from "Dr. Young-Snell", a doctor registered with the General Medical Council (GMC).

(ii) The second hour of the "consultation" is devoted to "...our nutritionist [who] provides a detoxification regime and diet tailored specifically to the patient..."

(iii) The leaflet assures us that "Natural nutrition therapy works" because it:

"...support[s] the whole body by addressing the biochemistry of each cell, while clearing and energising the body's routes of elimination so toxicity can be properly released."

4. Two "treatment regimes" are promoted. The "Intravenous Regime", for patients who are able to stay in the vicinity the clinic for "3 weeks", consists of a high-dose vitamin regime applied to the patient intravenously:

"The Intravenous regime has the advantage of a much higher vitamin and nutrient dosage [than the "Oral Regime"] over the three weeks using at the cornerstone, daily high dose [sic] Vitamin C intravenous infusions..."

5. Under Section 12.1, I challenge whether the advertisers can substantiate any of the following claims:

(i) The clinic's therapies, including "a high-dose vitamin regime applied to the patient intravenously", are able to "treat patients with metabolic disorders, primarily cancer" and "boost the patient's immune system to its maximum potential to allow the body to detoxify and repair itself"

(ii) The clinic's therapies are likewise able to treat "...depression, chronic or degenerative conditions"

(iii) The clinic's dietary regime, prepared after a consultation with the in-house nutritionist, is able to detoxify the body

(iv) "Natural nutrition therapy works" because it "[clears] and [energises] the body's routes of elimination so toxicity can be properly released"

(v) Courses of high-dose vitamins, whether taken orally or intravenously, are capable of treating any disease

6. The leaflet contains two testimonials. The second reads:

(i) "...After much family deliberation and consultations with Dr. Young-Snell it was decided to go ahead with the treatment, which centered [sic] around a series of daily intravenous injections over three weeks, plus a dietary regime. Since completion I am virtually back to normal - no more pain, walking unaided and feeling generally good. My doctors tell me - from the scans - that everything is looking good - the word miracle was even mentioned..."

(ii) I submit that the words "doctors", "scans" and "miracle" in this testimonial may be trying to imply that the clinic's treatment offers a cure for the disorder "primarily" treated by the clinic, namely "cancer".

7. Regarding this testimonial,

(i) Under Section 3.45 I challenge whether the advertisers hold documentary evidence that it is genuine

(ii) Under Section 3.47, I challenge whether it is likely to mislead consumers

8. Under Section 12.2, I challenge whether the leaflet fails to "encourage consumers to take independent medical advice before committing themselves to significant treatments, including those that are physically invasive".

9. Under Section 12.6, I challenge whether the advertisers have falsely claimed that their treatments are able to cure illness and dysfunction.

10. Under Section 12.10, I challenge whether the phrase "Natural nutrition works to support the whole body by addressing the biochemistry of each cell, while clearing and energising the body's routes of elimination so toxicity can be properly released" suggests the treatments are safe because they are "natural".

11. Under Section 15.6.2, I challenge whether the leaflet's promoted nutrition regimes "state or imply a food prevents, treats or cures human disease".

12. Under Section 3.1, I challenge whether the leaflet is misleading.

13. Under Section 1.3, I challenge whether the leaflet is irresponsible.

14. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser."

Nicola Phoenix the Finger-Tapping Psychologist

This is Nicola Phoenix, who describes herself as a "trained and experienced Psychologist".

Nicola promotes a quirky finger-tapping therapy called the Emotional Freedom Technique (EFT).

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EFT is widely touted as a treatment for anxiety and phobias.

Despite its pseudoscientific leanings, there's some evidence that EFT can treat anxiety - but only because it seems to act as a distraction for the mind. (It's thought that acupuncture can reduce back pain for the same reason.)

Inevitably, Nicola goes a step too far in her flyer (available here and here).

The flyer claims EFT can treat serious conditions like depression, irritable bowel syndrome, addictions and migraines.

I've had a look for some scientific evidence to support these impressive breakthroughs, but I've drawn a blank. Maybe the ASA can help!

"I write to complain about a flyer I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer promotes the "Emotional Freedom Technique", a service offered by "Nicola Phoenix".

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. Nicola Phoenix describes herself as "a trained and experienced psychologist". She offers a number of "holistic based [sic]" therapies.

2. The flyer reads:

"Emotional Freedom Techniques (EFT)...EFT can bring very powerful and rapid relief, releasing longstanding [sic] chronic problems..."

3. (i) The flyer continues:

"How Does EFT work? ... Gently tapping the energy meridians, whilst tuning into the issue/situation causing emotional disturbances, the body's energy system is balanced. Disturbances to the flow of energy are removed."

(ii) EFT was invented by the American Gary Craig. The "technique" consists of rapidly tapping on specific areas of the body which its practitioners imagine correspond to "meridians".

(iii) A number of studies have been conducted upon EFT, but I have found few which could be described as rigorous clinical trials.

(iv) One significant placebo-controlled trial of 119 subjects, who described themselves as suffering from anxiety and phobias, has been published [1]. The study found:

"The results of the present study indicate that EFT was effective in decreasing fear in a nonclinical population. However, EFT was no more effective than either a placebo or modeling control procedure..."

4. The subject of my complaint is the conditions which the advertiser claims EFT can treat.

5. (i) The flyer reads:

"EFT is applicable to emotional and physical problems. It can bring relief from many problems including - Addictive Cravings - Anxiety & Panic Attacks - Headaches & Migraines - Compulsions - Post Traumatic Stress Disorder - Irritable Bowel Syndrome"

(ii) The flyer continues:

"It has been found to assist depression, insomnia, addictions caused by traumatic incidents or painful childhood memories"

(iii) With the exception of the claim to bring relief from anxiety (which has been established in the above-quoted study), under Section 12.1 I challenge whether the advertiser can substantiate her claim that EFT can treat any of the named conditions.

6. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] Waite W, Holder M. Assessment of the Emotional Freedom Technique. http://www.srmhp.org/0201/emotional-freedom-technique.html
"

Ayurveda Pura - Pura Rubbish

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Simon Perry has written an excellent beginner's guide to writing ASA complaints. But where can novice sceptical letter writers find the adverts?

A great place to start is just about any "Ayurvedic Beauty Salon" - such as this one.

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Ayurveda Pura - a beauty salon a stone's throw from the O2 Arena in London - produce a handy 8-page booklet (available here, here, here and here) listing the treatments they offer.

It's full of dubious claims for "detox" therapies, weight-loss massages and the like. ASA complaint follows!

"I write to complain about a booklet I picked up at the CamExpo exhibition in London on 24th October this year.

The booklet promotes the "Ayurveda Pura London Health Spa & Beauty Centre".

I suspect that the booklet may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original booklet by post, if necessary.

1. The UK's leading authority on complementary medicine, Professor Edzard Ernst, has recently written about "detox" therapies [1]:

"Detox, as used in alternative medicine, is based on ill-conceived ideas about human physiology, metabolism, toxicology etc. There is no evidence that it does any good and some treatments...can be harmful. The only substance that is being removed from a patient is usually money."

2. Under Section 12.1, I challenge whether the advertiser can substantiate any of the following claims:

(i) The "Aromatherapy Facial" (p3) can "eliminate toxins" from the skin

(ii) The "Detoxifying Back Cleanse" (p3) is capable of detoxifying any part of the body

(iii) The "Ayurvedic Detoxifying Face Massage" (p4) can "assist is detoxifying the facial skin..."

(iv) The "Nasya - Nasal Cleansing Treatment" (p4) is "highly effective in relieving...migraines"

(v) The "Abhyanga - Ayurvedic Whole Body Massage..." (p4) "...stimulates the immune system, detoxifies...the entire body"

(vi) The "Marma Abhyanga - Ayurvedic Energy Point Massage..." (p4) "...stimulates the...imune...systems"

(vii) The "Vishesh - Ayurvedic Deep Tissure Massage" (p5) is capable of "removing toxins and impurities from the body"

(viii) The "Hridaya Basti" treatment (p5), in which "the heart area is continuously bathed with warm Ayurvedic oils" can help with "ailments like high blood pressure and heart conditions"

(ix) The "facial treatment" included in the "Rejuvenation Package" (p6) is capable of "detoxifying" any part of the body

(x) The "Panchakarma - Ayurvedic Detoxification Packages" (p6) are capable of detoxifying any part of the body, and are capable of "internal cleansing", "restor[ing] and maintain[ing] good health", "strengthen[ing] the immune system", "protect[ing] the body against diseases by removing toxins and rejuvenating your body's internal systems"

3. Regarding Shiatsu, Ernst has written [2]:

"Shiatsu is based on the biologically implausible theory of yin and yang. There is no evidence that it is effective for any specific conditions. Shiatsu massage therefore seems to be a waste of effort and expense, which offers nothing above conventional massage."

4. Under Section 12.1, I challenge whether the advertiser can substantiate the following claim:

(i) "Shiatsu" (p7) can "help in a wide range of conditions" including "specific injuries"

5. Under Section 13.1, I challenge whether the following claim can be substantiated, under 13.4, I challenge whether the advertisers have established that weight-reduction is caused by loss of body fat, and under Section 13.9, I challenge whether the advertisers are claiming that weight or fat can be lost from specific parts of the body:

(i) The "Nabhi Abhyanga - Abdominal Massage..." (p5) "...assists in weight loss around the stomach area"

6. Under Sections 12.1 and 12.7, I challenge whether the following claim can be substantiated:

(i) The "Mukhabhyanga - Traditional Ayurvedic Face-Lift Massage" (p4) is capable of "keeping away wrinkles" and "promoting the regeneration of healthy, younger looking [sic] skin"

7. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] Simon Singh, Edzard Ernst, "Trick or Treatment? Alternative Medicine on Trial", American edition 2008, p308
[2] Ibid., p326"

The Practitioners Select Purchasing Club

Attention all complementary therapists! Would you like to earn "£1800" every year with virtually no effort?

How about "£3000"? Or "£5000"? Or maybe even "£13,500"?

Welcome to the "Practitioners' Select Purchasing Club"!


The "club" is a new venture from my old friend, Nutri Centres Ltd - a company whom I've already caught red-handed in the act of breaking the law.

Nutri Centre's flyer (available here and here) helpfully explains how a therapist can get rich quick - all she has to do is hand out leaflets to her patients.

When the grateful patients buy something from the "club", the therapist earns a 10% commission.

"What Happens If I Give Away 10 Leaflets Each Week?

"If...they all start to use it, you'll be earning extra revenue very quickly. But say 9 out of 10 never use it - and only 1 of them chooses to use it regularly; spending around £30 a month; you will receive around £1,800 EXTRA PROFIT this year.... and every year afterwards."

£1800 is a decent sum, but if 3 out of 10 patients visit the "club" and each spend £50 a month, the therapist can expect to earn £9,000.

Better still, if the therapist is a member of the Complementary Medical Association, that figure rises to a staggering £13,500.

Sounds too good to be true? Well...it is.


Unfortunately, Nutri Centre's profit forecasts are completely fictional. It seems that, as well as a prediliction for breaking the law and telling porkies, the firm has a problem with basic arithmetic.

Let's take that £1800 figure, for example. If our hypothetical therapist were to give leaflets to five hundred of her patients on January 1st each year - and none throughout the rest of the year - the figure would be correct.

However, the "club" is asking her to give out leaflets to ten clients each week - ten in the first week, ten more in the second week and so on. When you add up the numbers, her actual commission drops to £936.

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The "club" has a rather high opinion of itself. It arrogantly assumes that once a patient has spent £30 with it, he will continue spending the same amount, every month, for the rest of the year.

It's an absurd suggestion, of course. Consumers in the real world simply don't behave this way. Still, let's be charitable and assume that only a quarter of the patients stop buying from the club every month.

The therapist's commission then drops to £453.

What's more, if we assume that half the patients drop out every month, the commission falls to just £267.

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The flyer predicts that at least 1 in 10 patients will start shopping with the "club" - a figure which is absurdly high. (1 in 1000 would be nearer the mark, I think.)

Still, let's give the "club" the benefit of the doubt and say that 1 in 20 patients actually buy something.

The therapist's annual commission has now dropped to just £105 - and even that figure relies on some pretty unrealistic expectations!

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The Complementary Medical Association (CMA) - who wittily describe themselves as "the world's largest multi-disciplinary body" for complementary therapists - feature prominently in the flyer as having officially "approved" the scheme.

The "club", by the way, is being operated by a sub-contractor, Magic Bullet TV Ltd.

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The sole shareholder of Magic Bullet TV is Jayne Goddard, the ageless beauty depicted above.

If you've ever had any dealings with the CMA, the name might be familiar to you - their President is the aforementioned Jayne Goddard!!

The scam (did I say, 'scam'? I meant, 'scheme') hasn't got off to a good start. Anyone taken in by the sales pitch has to sign up at a website which, hilariously, doesn't exist!


My complaint to the ASA explains, in unfathomable detail, why the firm's promises are misleading. (If you don't believe my results, check the sums for yourself.)

I've also complained that the CMA's financial interest in the "club" hasn't been made clear, and that the flyer is guilty of a few technical infractions of the advertising codes.

(I wonder if anyone has told Nutri Centre's parent company about their dastardly deeds?)

(Grateful thanks to a number of people, especially Alan of Zeno's Blog, for their generous assistance in preparing this complaint. Any mathematical mistakes or defamatory comments to be found in the article are, of course, my responsibility alone.)

"I write to complain about a flyer I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for the Nutri Centres Ltd, promotes a commission-based business opportunity.

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. (i) The "Practitioners Select Purchasing Club" is a promotion for an online mail-order service.

(ii) The flyer encourage practitioners of complementary therapies to "join" the "club". In exchange for handing out promotional leaflets to their clients, the therapists receive a 10% commission on anything purchased from the "club"'s mail-order service.

2. (i) The flyer is titled:

"Earn up to £5000 or more, EXTRA PROFIT from your practice this year...Without having to become a 'salesperson'"

(ii) The flyer presents a number of worked examples explaining how therapists can expect to earn "£1,800", or "£5,000", or even "£13,500" during "this year...and every year afterwards".

3. The essence of my complaint is threefold:

(i) The sums in the worked examples don't add up

(ii) The calculations in the worked examples are based on false assumptions

(iii) The assumed percentage of clients who, having received the leaflet, will make purchases at the "club" is unrealistically high

4. (i) The first worked example reads:

"What Happens If I Give Away 10 Leaflets Each Week?

"If you simply give The...leaflet to 10 patients every week and they all start to use it, you'll be earning extra revenue very quickly. But say 9 out of 10 never use it - and only 1 of them chooses to use it regularly; spending around £30 a month; you will receive around £1,800 EXTRA PROFIT this year.... and every year afterwards.

"(1 out of 10 'active users' a week; (x50 weeks a year) = 50 'active users' a year; spending around £30 p.m. each (£360 p.a. each); and you get 10% = £36 p.a. per active customer x 50 active customers = £1,800.)"

5. (i) The calculation is incorrect. If the therapist sees 500 clients in a year (10 clients per week for 50 weeks), the calculation can only be correct if the therapist were to hand out leaflets to all 500 clients in the first week of the year.

(ii) However, the text states that 10 new clients are given a leaflet every week - 10 in the first week, 10 in the second week (making a total of 20) and so on.

(iii) In this case, 40 clients will receive leaflets in the first month (4 weeks). 4 of them will spend £30, and the therapist will receive a commission of £12 (£30 x 4 clients x 10% commission).

(iv) In the second month (4 weeks), 8 clients will each spend £30 and the therapist will receive a commission of £24 (£30 x 8 clients x 10% commission).

(v) In the final month of the year, 48 clients will make purchases.

(vi) After 12 months (48 weeks), the therapist will receive a total commission of £936 (12+24+36+48+60+72+84+96+108+120+132+144) - a sum much less than the promised £1800.

(vii) In the second worked example, the therapist would receive £2496 (not the promised £5000). In the third example, the therapist would receive £4680 (not the promised £9000).

(viii) All of the worked examples contain this same error.

6. (i) The calculation is based on the manifestly false assumption that all the clients who pick up a leaflet and spend £30 at the club will never stop spending that amount every month.

(ii) If we assume that just a quarter of the therapist's clients who have made purchases with the "club" drop out every month, the promised £1800 commission drops even further.

(iii) In the first month (four weeks), 40 clients will receive leaflets and 4 of them make purchases at the club. Of these 4, only 3 will make purchases in the second month.

(iv) In that case, the number of clients making purchases in the final month will be reduced from 48 (in paragraph 5. v) to just 15.

(v) In the following calculation, all numbers are round to the nearest integer - thus 75% of 7 clients is 5 clients, not 5.25 clients: (4 + ([4 x 0.75] + 4) + ([7 x 0.75] + 4) + ([11 x 0.75] + 4) + ([12 x 0.75] + 4) + ([13 x 0.75] + 4) + ([14 x 0.75] + 4) + ([15 x 0.75] + 4) + ([15 x 0.75] + 4) + ([15 x 0.75] + 4) + ([15 x 0.75] + 4) + ([15 x 0.75] + 4)) = 151 total purchases in a year.

(vi) Thus, the therapist will receive a total commission of £453 (151 purchases x £30 each purchase x 10% commission) - a sum far less than the promised £1800.

(vii) If the drop-out is higher than a quarter, the commission would of course be even lower. Assuming a drop-out rate of 50% - still a fabulously generous figure - the therapist would receive a commission of just £267 - a sum far less than the promised £1800.

(viii) All of the worked examples contain this same false assumption.

7. (i) I believe that the promise that 1 in 10 clients who receive a leaflet will make purchases from the "club" is unrealistically high. In fact, I would describe it as a fantasy.

(ii) Even using a generous expectation - purchases made by 1 in 20 clients - the promised sum of £1800 falls dramatically again.

(iii) In the first year, assuming 40 customers receive a leaflet every four weeks and 2 of them make purchases, and assuming a drop-out rate of 50% per month, the number of clients making purchases every month never rises above 3. In that case, the therapist would receive an annual commission of just £105 (35 purchases x £30 each purchase x 10% commission) - a tiny proportion of the promised £1800.

(vi) All of the worked examples contain this same unrealistically high claim.

8. (i) Section 20.7 of the CAP Code (2010) says:

"Marketing communications for business opportunities must neither contain unrepresentative or overstated earnings figures nor exaggerate the support available to investors."

(ii) Therefore I challenge whether the flyer contains unrepresentative and overstated earnings figures, in which promised earnings of £1800 are actually likely to be £105 or even less.

9. (i) The flyer states "Save 10% On every purchase of every major healthcare brand you buy. Simply come online to NutriCentre.com or call us on 0208 752 8463..."

(ii) Due to a DNS configuration error the advertised webpage does not exist (as of 29th October).

(iii) The correct webpage is www.nutricentre.com (a fact which may not be obvious to those who are not technology-savvy), but it contains no mention of the "club".

10. Since there is apparently no follow-up material available, under Section 20.8 I challenge whether:

(i) The full name and geographical address of the marketer is unavailable to potential "club" members

(ii) A clear description of the work involved is unavailable to potential "club" members

(iii) A statement of the extent of investors’ commitments, including any financial investment or outlay, is unavailable to potential "club" members

11. (i) The flyer notes, in small print, "This programme is operated for us by Magic Bullet TV Limited".

(ii) The flyer boasts the the "club" is "Approved By The Complementary Medical Association...the world's largest multi-disciplinary body for HealthCare Practitioners [which] has approved The Practitioners' Select Purchasing Club".

(iii) Indeed, members of the CMA enjoy a further 5% discount on purchases made with the "club".

(iv) The President of the CMA is Jayney Goddard.

(v) A check at Companies House reveals that the only director, and sole shareholder, of Magic Bullet TV Limited is the same Jayney Goddard. (I enclose a copy of the company's annual return.)

(vi) Therefore, under Section 3.1 I challenge whether the flyer is misleading, because it does not make clear that the president of the CMA, which has "approved" the club, has a direct financial interest in it.

12. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser."

The College of Naturopathic Medicine Talks Shit

I haven't written nearly enough complaints about colonic irrigation - a bizarre and unpleasant therapy that is both ineffective and highly dangerous.

(Image credit)

How can I be sure? The UK's leading expert on complementary therapies has written:

"There is no reliable clinical evidence that colonic irrigation does any good at all and some evidence it causes serious harm by, for example, perforating the colon or depleting our body of electrolytes...Colonic irrigation is unpleasant, ineffective and dangerous. In other words, it's a waste of money and a hazard to our health."

A waste of money, eh? You'd never have guessed it from reading the College of Naturopathic Medicine's promotional flyer (available here and here).

"Colon hydrotherapy is the most powerful method available for restoring optimum bowel function... Colon hydrotherapy [has] a huge range of health benefits... including: Restoration of regular bowel movements - Improvements in conditions such as diverticulosis or [sic] irritable bowel syndrome (IBS) - Reduced gas or bloating - Clearer skin - Improved mental clarity - Increased energy - Fewer headaches"

I hope no-one falls for the College's faecal sales pitch. My contacts in the industry tell me there are already more therapists than customers - in fact, the only people making money are the ones selling the poo-extraction machines.

ASA complaint follows!

"I write to complain about a flyer I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for the College of Naturopathic Medicine, promotes their courses in colon hydrotherapy.

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. "Colon Hydrotherapy" is better known as "Colonic Irrigation".

2. The UK's leading authority on complementary medicine, Professor Edzard Ernst, has recently written about colonic therapies [1]:

"There is no reliable clinical evidence that colonic irrigation does any good at all and some evidence it causes serious harm by, for example, perforating the colon or depleting our body of electrolytes...Colonic irrigation is unpleasant, ineffective and dangerous. In other words, it's a waste of money and a hazard to our health."

3. Therefore, under section 12.1 of the CAP Code, I challenge whether the advertisers can substantiate any of the following claims, and under Section 3.1 I challenge whether they are misleading:

(i) "Many people are becoming toxic throughout their bodies, suffering from unexplained symptoms such as skin complaints and headaches, due to impaired colon function...As a natural medicine practitioner, you and your patients will benefit from adding colon hydrotherapy to your therapeutic armoury."

(ii) "Colon hydrotherapy is the most powerful method available for restoring optimum bowel function..."

(iii) "Colon hydrotherapy...is at the same time gentle and rejuvenating"

(iv) "Colon hydrotherapy" has a "huge range of health benefits" including "Restoration of regular bowel movements", "Improvements in conditions such as diverticulosis or [sic] irritable bowel syndrome (IBS)", "Reduced gas or bloating", "Clearer skin", "Improved mental clarity", "Increased energy", "Fewer headaches"

(v) "Colon hydrotherapy may also be useful in cases of circulatory, immune, inflammatory and weight problems when accompanied by diet and lifestyle changes"

4. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] Simon Singh, Edzard Ernst, "Trick or Treatment? Alternative Medicine on Trial", American edition 2008, p304"

Dr Red's Spearole Tea (for rats)

Drink Dr Red Spearole Tea, says the publicity, and just "3 cups a day help the pounds melt away"!

(Image credit)

Xynergy Health Products describe themselves as the product's UK distributors. Their flyer (available here) proudly boasts of the clinical research that's been conducted on this miracle weight-loss product.

"Dr Red Spearole Tea is...believed to reduce blood pressure and help the body process sugar. In tests, Spearole Tea shows a remarkable capacity to inhibit fat. Just three cups a day could be part of your weight management regime..."

Intrigued, I rushed off to look for the research.

...and found nothing. Nothing, that is, except for an article in the Daily Mail, which said:

"Dr Brown, a pharmacologist at Brisbane's Queensland University, studied the effect of the tea on the health of a group of rats..."

That's rather unfortunate, because the UK advertising regulations insist that

"Any claim made for the effectiveness or action of a weight-reduction method or product must be backed, if applicable, by rigorous trials on people..."

ASA complaint follows!

"I write to complain about a flyer I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for Xynergy Health Products, promotes "dr red SPEAROLE TEA", a weight-loss product.

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. The front side of the flyer contains the text:

"dr red SPEAROLE TEA - 3 cups a day helps the pounds melt away..."

2. The text continues:

"Dr Red Spearole Tea is...believed to reduce blood pressure and help the body process sugar. In tests, Spearole Tea shows a remarkable capacity to inhibit fat. Just three cups a day could be part of your weight management regime. What's more, the antioxidant-rich ingredients also appear to work together to block inflammation. Biochemist and Spearole creator, Greg Jardine says: 'High calorie meals trigger inflammation. Evidence now suggests that anti-inflammatory foods deliver long term and sustainable benefits.'..."

3. It is not easy to find information about these "tests". A search in PubMed produced no results and the manufacturer's website [1] does not link to any research.

4. However, there are a number of articles in the media describing the "tests", which all seem to be based on the same press release. For example, a Daily Mail article [2] reads:

"Dr Brown, a pharmacologist at Brisbane's Queensland University, studied the effect of the tea on the health of a group of rats..."

5. Section 13.1 of the CAP Code says:

"Any claim made for the effectiveness or action of a weight-reduction method or product must be backed, if applicable, by rigorous trials on people..."

6. Therefore, under Section 13.1 of the Code, I challenge whether the advertisers can substantiate any of the following claims, and under Section 3.1 I challenge whether they are misleading:

(i) "3 cups a day helps the pounds melt away..."
(ii) The product "reduce[s] blood pressure and help[s] the body process sugar"
(iii) "In tests, Spearole Tea shows a remarkable capacity to inhibit fat"
(iv) The product's "antioxidant-rich ingredients also appear to work together to block inflammation"

7. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] http://www.drred.com.au/?p=spearoletea
[2] http://www.dailymail.co.uk/health/article-1087134/How-cups-green-tea-day-help-lose-weight--eating-junk-food.html
"

A Vogel - The Nerd Has Turned

I've been harbouring a lingering grudge against the A Vogel Institute for quite some time.

(Image credit - witty comment is mine)

Earlier this year I complained to the ASA about some preposterous claims the company were making for a couple of their flagship products.

The complaint was rejected because each of the claims were appended by the words

"...based exclusively on use as a traditional medicine..."

Despite my disgust, I felt sure that one day I'd get my revenge.

Today I spotted a series of wacky statements in the company's "Cleanse & Revitalise" booklet (available here, here and here).

I also noticed some dodgy research which had been cherry-picked from a wider, more negative pool of clinical studies and duly inserted into another booklet, "Prostrate Health" (available here, here and here).

Both of the adverts are now sitting in the ASA's in-tray. (It's rather odd that no-one at the company spotted the glaring errors, but I suppose that's what comes from accumulating so much bad karma.)


"I write to complain about a booklet I picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for A. Vogel, promotes a number of "detox" products.

I suspect that the booklet may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original booklet by post, if necessary.

1. The booklet is titled:

"Cleanse & Revitalise - Information on detoxification & weight management - Health Information Series"

2. The UK's leading authority on complementary medicine, Professor Edzard Ernst, has recently written about "detox" treatments [1]:

"Detox, as used in alternative medicine, is based on ill-conceived ideas about human physiology, metabolism, toxicology etc. There is no evidence that it does any good and some treatments...can be harmful. The only substance that is being removed from a patient is usually money."

3. (i) The section "Here's what to do about it" starts on p5, and reads

"When attempting to clean up, it is vital to open the exit routes first. This is so that toxins lifted from the tissues and the organs will actually leave the body rather than circulate in the bloodstream (making you feel terrible) before settling back in again. Fasting on organic seaweed...won't help your body to cleanse unless you've got those exit routes open and are encouraging a plentiful emptying of toxins into the outside world."

(ii) In response to this problem, the booklet suggests a number of the advertisers products.

(iii) "Linoforce is an extremely effective remedy for constipation, certain to get your bowels moving again with no delay..."

(iv) "Urinary tract: Drinking...water...will really help reduce fluid retention, allowing toxins to leave through the urinary tract rather than get trapped in the body. Golden Rod Tea [an A Vogel product] is good for this too..."

(v) "User Milk Thistle Complex to cleanse your liver and improve the way it metabolises both toxins and fats...So with Milk Thistle Complex you can give your liver a proper overhaul, leaving it better equipped to deal with toxins and fats."

(vi) "Solidago Complex will cleanse and support your kidneys, helping them to deal with toxins and keep your fluid [sic] balanced properly"

(vii) "...pay some attention to your lymphatic system...with a dose of Calendula Complex"

(viii) Under Section 12.1, I challenge whether any of these claims can be substantiated.

4. Under Section 3.1, I challenge whether the claim in the section "What should I eat whilst detoxifying?" that the named foods should be eaten in order to detoxify the body is misleading.

5. Under Section 3.1, I challenge whether the claim in the section "Will my skin improve with all this detoxifying?" that "Doing regular detoxing of your liver and kidneys to keep toxicity levels down" is misleading.

6. Under Section 12.1, I challenge whether the claim that the "Viola tricolor" product can "[increase] the flow of nutrients to the skin and the removal of wastes from the skin, as well as reducing inflammation in the skin cells" can be substantiated.

7. (i) The section "How will detoxifying help my metabolism?" promotes more of the advertiser's products.

(ii) "Taking Linoforce will move things along nicely [in your bowel]"

(iii) "Restoring the balance of friendly bacteria in your gut...Do this by drinking a couple of glasses of Molkosan Vitality every day...It provides the kind of environment that friendly bacteria like and is also very good for your pancreas."

(iv) "Milk Thistle Complex to improve liver function will have a beneficial knock-on effect on weight control."

(v) "Improving kidney function with Solidago Complex...can do wonders for your weight..."

(vi) Under Section 12.1, I challenge whether any of these claims can be substantiated.

8. (i) More products are promoted in on p10.

(ii) "Helix Slim improves the way your body extracts the energy from carbohydrates, keeping your blood sugar on an even keel...the one to use if you are a sugar addict and find dieting makes you famished..."

(iii) "[The advertiser's] Kelp [Tablets]...ha[ve] the ability to bind toxins such as heavy metals and carry them out of the body. This detoxifying effect is also energising."

(iv) "Craving Essence" is good for people who feel "unhappy or stressed" and thus "eat badly"

(v) Under Section 12.1, I challenge whether any of these claims can be substantiated.

9. (i) The "A Vogel Detox Box" is prominently promoted on p11.

(ii) Under Section 12.1, I challenge whether the product label description, clearly visible in the photo, that the product is a "10 day toxin elimination programme" can be substantiated, and under Section 3.1 I challenge whether it is misleading.

10. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser."


"I write to complain about a booklet picked up at the CamExpo exhibition in London on 24th October this year.

The booklet, for A. Vogel, promotes Saw Palmetto as a treatment for an enlarged prostrate gland. The advertisers have a number of Saw Palmetto products in their product range.

I suspect that the booklet may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original booklet by post, if necessary.

1. (i) The booklet makes the following claim for Saw Palmetto, an extract from the fruits of the palm "Serenoa repens":

"Research has now shown that Saw Palmetto extract provides mild to moderate improvement in urinary symptoms for men with an enlarged prostrate gland. Saw palmetto extracts have been shown to reduce inflammatory activity within the prostrate..."

(ii) (Benign prostatic hyperplasia is the medical term for an enlarge prostrate gland.)

2. The claim is presumably referring to a 2002 study, "Serenoa repens for benign prostatic hyperplasia" [1], whose conclusions were:

"The evidence suggests that Serenoa repens provides mild to moderate improvement in urinary symptoms and flow measures. Serenoa repens produced similar improvement in urinary symptoms and flow compared to finasteride and is associated with fewer adverse treatment events. The long-term effectiveness, safety and ability to prevent BPH complications are not known. The results of this update are in agreement with our initial review.

3. However, other more recent studies do not demonstrate any effect beyond placebo.

4. (i) A 2006 study, "Saw Palmetto for Benign Prostatic Hyperplasia" [2], found the following result:

"There was no significant difference between the saw palmetto and placebo groups...during the one-year study. The incidence of side effects was similar in the two groups."

(ii) The study's conclusion was:

"In this study, saw palmetto did not improve symptoms or objective measures of benign prostatic hyperplasia."

5. A 2008 review, "Phytotherapy for Lower Urinary Tract Symptoms Secondary to Benign Prostatic Hyperplasia" [3], investigated a number of plant extracts, among them saw palmetto. The review concluded:

"Most clinical trials of investigating the efficacy of botanicals suffer from well documented methodological flaws. Saw palmetto has been clearly shown as comparable to placebo in a trial of sound methodology. While preliminary results appear promising, to our knowledge the remaining botanicals have yet to be evaluated in a trial of similar quality."

6. (i) The booklet seems to claim that saw palmetto's effects are supported by moderate quality evidence, yet there is no mention of more recent studies that each conclude the effects of saw palmetto are indistinguishable from placebo.

(ii) Therefore under Section 3.1 of the CAP Code (2010), I challenge whether the claim is misleading.

7. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:

[1] Wilt T, Ishani A, Mac Donald R (2002). "Serenoa repens for benign prostatic hyperplasia". Cochrane Database Syst Rev (3): CD001423. doi:10.1002/14651858.CD001423. PMID 12137626.

[2] Bent S, Kane C, Shinohara K, et al (February 2006). "Saw palmetto for benign prostatic hyperplasia". N. Engl. J. Med. 354 (6): 557–66. doi:10.1056/NEJMoa053085. PMID 16467543.

[3] Dedhia RC, McVary KT (June 2008). "Phytotherapy for lower urinary tract symptoms secondary to benign prostatic hyperplasia". J. Urol. 179 (6): 2119–25. doi:10.1016/j.juro.2008.01.094. PMID 18423748.
"

Harmony Cone Ear Candles - already illegal in the US

Harmony Cone Ear Candles are banned in the USA - partly because they are so dangerous - but mostly because its manufacturers and marketers keep breaking the law.

(Image credit)

Luckily for "Doc Harmony", the fake doctor pictured below, our very own Bodytox Ltd - regular guests on this blog - are more than willing to flog them on this side of the pond.

(Image credit)

Now when I say fake, I'm talking about "Doctor" Gillian McKeith fake.

You see, both Gillian and "Doc Harmony" are graduates of the unaccredited, and now defunct, Clayton College of Natural Health.

Gillian has been ordered to stop using the title "doctor" in her marketing promotions. I suspect "Doc Harmony" will soon have to stop, too.

But the bogus claim is the least worrying thing from Bodytox's flyer (available here and here).

The promotion contains a thoroughly irresponsible suggestion that inserting burning hot wax into someone's ear is "simple", and to prove it, provides a step-by-step guide.

Just as recklessly, Bodytox suggest that ear infections can be treated with their bullshit candles. (Most doctors would, I think, recommend an immediate course of antibiotics.)

Let's see what Bodyquacks have to say for themselves, shall we? ASA complaint follows!

"I write to complain about a leaflet picked up at the CamExpo exhibition in London on 24th October this year.

The flyer, for Bodytox Ltd, promotes "Harmony Cone Ear Candles".

I suspect that the flyer may be in breach of the British Code of Advertising, Sales Promotion and Direct Marketing (CAP Code). I can provide the original flyer by post, if necessary.

1. The ASA Council has in the past ruled against health claims made for ear candles (for example, complaint ref 120878, in which I was the complainant.)

2. In February this year, the USA's Food and Drug Administration (FDA) banned the sale of Harmony Cone Ear Candles [1].

3. Under Section 12.1 of the CAP Code, I challenge whether the advertisers can substantiate any of the following claims, and under Section 3.1 I challenge whether the claims are misleading:

(i) "Harmony Cone Ear Candles are the safest...ear candles on the market"
(ii) "Harmony Cone Ear Candles are the ...most effective ear candles on the market"
(iii) "Harmony Cone Ear Candles...support the body's own natural defenses [sic]"
(iv) "Harmony Cone Ear Candles...help with allergies, headaches, cold & flu, congestion, sore throat, ear infections and sinus infection"
(v) "Ear candling has been an ancient practice through the ages"
(vi) "...ear candle therapy is a rewarding...remedy"
(vii) The advertisers have "establish[ed] the truth" about the "safe...use" of "Harmony Cone Ear Candles"
(viii) "Harmony Cone Ear Candles" induce "the body into a relaxed state"
(ix) "...This encourages the lymphatic system, sinuses, and eustachian tubes to function and support the body's natural defenses [sic]"
(x) "Current worldwide research indicates that ear candles function as an energetic modality comparable to the field or reflexology and acupuncture. These modalities encourage healing as the body shifts from a sympathetic to a parasympathetic state with the autonomic nervous system (ANS)"
(xi) This "shift in the ANS encourages the proper function and balance of the ear"

4. (i) The leaflet describes the use of ear candles as "simple", providing instructions and a short list of things that "you need".

(ii) Under Section 1.3, I challenge whether the leaflet's exhortation to the general public that inserting a column of boiling hot wax into someone's ear is "simple" is irresponsible.

5. Under Section 12.2, I challenge whether the leaflet's claim that "Harmony Cone Ear Candles...help with...ear infections" may discourage essential treatment.

6. (i) The leaflet describes the apparent designer of Harmony Cone Ear Candles, "Doc Harmony", who achieved "highest honours upon gaining her Doctorate in Natural Health from Clayton College of Natural Health".

(ii) The College is a non-accredited institution. For this reason, the ASA has apparently instructed another graduate of the college, "Dr" Gillian McKeith, to stop using the title in her marketing materials [2].

(iii) Therefore, under Section 3.1 I challenge whether the description of "Doc Harmony" as a PhD graduate is misleading.

(iv) Under Section 3.1, I challenge whether the description of the "Doc Harmony branded products" as being "trusted" by retailers "throughout America" is misleading, given that the advertised product has been banned from sale there.

7. I confirm I have no connections with the advertiser. I confirm I am not involved in legal proceedings with the advertiser.

Footnotes:
[1] http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm202182.htm
[2] http://www.badscience.net/2007/02/ms-gillian-mckeith-banned-from-calling-herself-a-doctor/
"