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The Society of Homeopaths and Nelsons Pharmacy have teamed up to launch a new website, letpeoplechoose.com , in time for next month's Homeopathy Awareness Week.
It's very generous of them to reveal their publicity materials so far in advance - gives us sceptics plenty of time in which to weed out the misleading claims.
The biggest whopper on the site is this one:
"If you’d like to find your nearest homeopath, use our useful search tool which lists every homeopath in the UK by area..."
This is a new and special usage of the term "every homeopath in the UK" which means something like "some homeopaths in the UK, but not all of them, actually. Not by a long shot, in fact..."
You won't find Karin Mont, Sue Berry, June Sayer, Nigel Bird or Veja Gorania on the list. They've all homeopaths who've made guest appearances in this blog, but because they belong to the wrong professional body, they're not on the list and they're not coming in.
I wonder what the Alliance of Registered Homeopaths think of this blatant discrimination? Also - ASA complaint follows!
"The website promotes the services of professional homeopaths by means of a claim which I think is misleading.
1. ( http://www.letpeoplechoose.com/ )
"If you’d like to find your nearest homeopath, use our useful search tool which lists every homeopath in the UK by area"
I'd like to challenge whether the claim is misleading.
The "useful search tool" does not list "every homeopath in the UK". In fact, it lists only members of the Society of Homeopaths and the Faculty of Homeopaths.
Members of other bodies, such as the Alliance of Registered Homeopaths, do not appear in the list.
I think the page is misleading because it might cause a consumer to engage the professional services of a homeopath, incorrectly believing them to be the only homeopath in the local area.
I've made some screenshots of the relevant pages, which are available at:
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=R0e7xxGwQz
I can confirm that I have no connections with the advertiser or with the alternative medicine industry in general."
Showing posts with label Society of Homeopaths. Show all posts
Showing posts with label Society of Homeopaths. Show all posts
Tuesday, 10 May 2011
The Society of Homeopaths, A Practical Joke Taken Too Far
One of the most engaging practical jokers on the internet has to be The Society of Homeopaths, who have found some ingenious ways to troll both sceptics and their own members simultaneously.
Visitors to the Society's shiny new website are deluged with little jokes on the same intellectual level as a whoopee cushion. Let's start with this one, a cunning ruse to persuade its members to pay for the Society's own marketing costs.
The set of six laminated posters pictured above, with the Society's logo featuring prominently, will set you back £20.
Worse still are these stickers featuring heart-warming messages for kids including "HOMEOPATHY IS COOL!", "REMEMBER TO SEE YOUR HOMEOPATH!" and - this is my favourite one - "BEAT YOUR BUGS WITH HOMEOPATHY!"
That's right, kids. Homeopathy can treat bacterial infections. Cool, eh?
The really interesting thing, though, concerns not the bizarre claims but the web shopping service itself. According to the "About The Society" page,
"The Society of Homeopaths has two further companies in its group: HETRA Ltd and TradCo Ltd... TradCo is The Society’s Trading Company, offering a wide range of affordable homeopathic and practice-support merchandise to homeopaths and the public alike."
The "Shop" page chimes in with
"Through our web shop you can purchase many items in relation to homeopathy. If you would like to purchase an item please contact us on 01604 817890... Brighten up your practice with TradCo! TradCo is The Society’s Trading Company, offering specially designed affordable merchandise for the busy homeopath... "
These claims are interesting because, according to Companies House, "TradCo Ltd" was dissolved in 2008.
Despite this minor inconvenience, the company still seem to be trading. The practical difficulties of running an imaginary company have doubtlessly been eased by the generous loan of two phone lines and a member of staff from, errr, The Society of Homeopaths (who own the website, the two advertised numbers and who employ the advertised "Julie").
ASA complaint follows!
"The website makes a number of marketing claims which I suspect are misleading.
1. ( http://www.homeopathy-soh.org/about-the-society/ )
"The Society of Homeopaths has two further companies in its group: HETRA Ltd and TradCo Ltd... TradCo is The Society’s Trading Company, offering a wide range of affordable homeopathic and practice-support merchandise to homeopaths and the public alike."
2. ( http://www.homeopathy-soh.org/shop/ )
"Through our web shop you can purchase many items in relation to homeopathy. If you would like to purchase an item please contact us on 01604 817890... Brighten up your practice with TradCo! TradCo is The Society’s Trading Company, offering specially designed affordable merchandise for the busy homeopath... Available by mail order, all the items in the product range are designed to assist practitioners in the promotion of homeopathy, in both the clinic and the local community... To add to your convenience, orders may now be placed on line for a fast, efficient service. If you have any queries about the TradCo Shop or wish to place an order by telephone, please contact Julie on 0845 450 6611 or download the current catalogue."
I challenge whether these descriptions of "TradCo Ltd", "The Society's Trading Company", "the TradCo Shop" and "our web shop" are misleading, because the only TradCo Ltd recorded at Companies House was dissolved in 2008, because (by way of contrast) the other subsidiary company mentioned, HETRA Ltd, is still trading, because the two phone numbers advertised belong to the Society of Homeopaths, not to TradCo, and because "Julie" refers to Julie Rowland, who is not an employee of TradCo but the Society's finance manager.
3. ( http://www.homeopathy-soh.org/shop/patient-leaflets/ )
"Offers reassurance and general guidance to patients explaining how homeopathy can assist with the menopause as a natural alternative to Hormone Replacement Therapy."
I challenge whether this advert for patient leaflets, for which the Society charges its members, exaggerates the value, accuracy, scientific validity or practical usefulness of homeopathy.
4.
"Homeopathic medicine has so much to offer when it comes to the treatment of individual men’s health... It goes a necessary part of the way to begin to address the health of those men who wrestle with depression, low self esteem, anger issues, erectile dysfunction, anxiety or any of the myriad symptoms they experience."
I challenge whether this advert for patient leaflets, for which the Society charges its members, exaggerate the value, accuracy, scientific validity or practical usefulness of homeopathy in treating depression and erectile dysfunction.
5. ( http://www.homeopathy-soh.org/shop/posters/ )
"New eye-catching set of six A3 posters to fully complement the patient leaflet range. Incorporates space for you to personalise with your patient details. A good backdrop for health shows and local talks... Set of Six Posters Price: £16 (inc. VAT)"
I challenge whether this advert for posters, for which the Society charges its members, exaggerates the value, accuracy, scientific validity or practical usefulness of homeopathy in the claims "Homeopathy for Stress, Anxiety and Depression - Homeopathy is a safe and effecitve system of medicine...", "Homeopathy in pregnancy and childbirth - Homoepathy is ideal for women during pregnancy as it is a gentle yet effective system of medicine...", "Homeopathy simply explained - Homeopathy is an effection system of healing..." and "Homeopathy and the menopause - Research has shown that menopausal hot flushes, mood swings, headaches and fatigue are successfully helped by homeopathy..."
6. ( http://www.homeopathy-soh.org/shop/stickers/ )
"Children love stickers... A bright and colourful range of eye-catching children’s stickers and balloons are a must for the coolest homeopath in town!Minimum Order Value... Minimum value of £10 applies to all orders."
The advert contains the text, visible on one of the stickers, "BEAT YOUR BUGS WITH HOMEOPATHY". I challenge whether the claim that homeopathy can "beat" bacteria is misleading, whether it can be substantiated, and whether it is irresponsible in a promotion for products likely to appeal to children.
I've made some screenshots of the relevant pages, which are available at:
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=G0dWeXy30N
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=20MIuA72bh
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=NQ6Yw9jqmp
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=kgik1V1ndb
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=SF4gCtNRNW
http://leicester.skepticsinthepub.org/FishBarrel/ci.aspx?id=yrbMEtcivt
I can confirm that I have no connections with the advertiser or with the alternative medicine industry in general."
Monday, 7 March 2011
Richard Barr's Recurrent Memory Problems
It seems that Richard Barr - the strikingly photogenic solicitor pictured below - has a recurrent problem with forgetting to disclose things.
Of the commercial websites he controls, how many do you think are incorrectly registered as belonging to a "non-trading individual"?
The answer - it goes without saying - is all of them*!
http://richardbarrlaw.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
http://www.norfolkbaytreecottage.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
http://theapplehousenorfolk.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
Richard Barr's brother also runs a website. He uses it to flog copies of his latest best-selling** novel, The Carp Club - The Election That Never Was.
Can you see where I'm going with this...?
http://bantheballot.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
Forgetfulness often runs in the family, or at least in the blood family. Richard Barr's stepson somehow managed to remember to comply with his responsibilities.
Barr's fellow Director of the Society of Homeopaths, Mike Andrews, runs a site that's also in full compliance with Nominet's disclosure rules.
One of the reasons for Mike's admirable honesty, of course, is that he had already been caught out eleven months ago - along with ninety-nine of his colleagues!
* The words "all of them" carry the meaning "all of the commercial websites controlled by Richard Barr, which have come to my attention". If anyone knows of any besides the three mentioned above, I would be glad to hear about them.
**Contrary to appearances, the word 'best-selling' is not intended to be satirical. As of the time of writing, The Carp Club is flying off the shelves, and has already reached 1,094,582th place in Amazon's bestseller ranks.
Saturday, 5 March 2011
*Non-Homeopaths Caught In The Act
UPDATE, 10th Mar: Richard Barr, the solicitor linked to an appalling fraud, boasted that bungling doctors were responsible for the deaths of "as many as 30,000 people each year".
My ASA complaint, available below, expressed my doubts about this conclusion. It now seems that my suspicions were right. The ASA have closed their case and the unsubstantiated claim has been removed from Barr's website - as has everything else!
(Sunday 6th March 2011)
(Thursday 10th March)The slightly scary-looking bloke pictured below is Richard Barr. Not surprisingly, he's a solicitor.
What kind of a man is Richard Barr? A man linked to an appalling fraud, according to the British Medical Journal (BMJ):
"Thanks to the recent publication of the GMC [General Medical Council]’s six million word transcript, the BMJ was able to check [a journalist's] findings and confirm extensive falsification... This means that the MMR [vaccination] scare was based not on bad science but on a deliberate fraud"
The journalist in question was Brian Deer of the Sunday Times. He has written:
"[Dr Andrew] Wakefield... had been hired to attack [the MMR vaccine] by a lawyer, Richard Barr: a jobbing solicitor in the small eastern English town of King's Lynn, who hoped to raise a speculative class action lawsuit against drug companies which manufactured the shot...
Barr paid the doctor with money from the UK legal aid fund: run by the government to give poorer people access to justice. Wakefield charged at the extraordinary rate of £150 an hour... eventually totalling, for generic work alone... £435,643 plus expenses. These hourly fees... gave the doctor a direct, personal, but undeclared financial interest in his research... creating an incentive not only for him to launch the alarm, but to keep it going for as long as possible."
Barr's payments were not the only hidden interest. Wakefield had patented his own vaccine and stood to become a very rich man if the MMR vaccine were withdrawn.
Barr now works for Scott Moncrieff Harbour & Sinclair (SCOMO), "a law firm with a difference". He specialises in medical negligence claims, as his website explains:
"It is a grim statistic that possibly as many as 30,000 people die each year and many more are injured, all as a result of mistakes by doctors and medical staff. When I deal with medical claims I try to deal sensitively with the situation respecting the skill of doctors... but acknowledging that claims sometimes must be brought.
30,000 people each year, eh, Dick? I can't find any reference to this figure in any medical journal. I wonder if the claim can be substantiated?
Barr's website doesn't list his sources, but the figure probably comes from a BMJ article from 2004. The article claimed that there were 40,000 deaths in the UK every year caused by medical negligence. It quickly became clear that this claim was baloney. (Free registration is required to read these links.)
"The publication... does not produce any data on hospital deaths but quotes as a reference a conference report in 2001... The alarming headline in the Times is not based on established fact, and, although the [original authors are] committed to putting the available data on medical care in the public arena, the figure of 40 000 patients killed by hospital blunders is not substantiated."
More recently, Barr has been back in the news for threatening his critics with an injudicious libel action.
I wonder if he - or any of his fellow Directors of the Society of Homeopaths - have good cause to sue me? In other words - ASA complaint follows!
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.richardbarrlaw.co.uk
The site promotes the services of Richard Barr, a solicitor.
I've enclosed a screenshot of the page that concerns me, titled "About medical cases" ( http://richardbarrlaw.co.uk/#/about-medical-cases/4533337944 )
1. Mr Barr is a solicitor who describes himself as a "Senior Litigator with the Association of Personal Injury Lawyers" and a "clinical negligence solicitor". His website promotes his services, subject to conditional fee agreements (a.k.a. "no win no fee"), as a solicitor in medical negligence claims.
2. On his website, Barr claims:
"About medical cases - It is a grim statistic that possibly as many as 30,000 people die each year and many more are injured, all as a result of mistakes by doctors and medical staff."
3. On the same page, Barr continues:
"When I deal with medical claims I try to deal sensitively with the situation respecting the skill of doctors... but acknowledging that claims sometimes must be brought."
4. Barr's figure of "as many as 30,000" deaths seems to me to be rather high. I haven't been able to find any published research that supports the claim.
5. Therefore, I'd like to challenge:
(i) Whether the claim that "possibly as many as 30,000 people die each year...all as a result of mistakes by doctors and medical staff", used by Mr Barr to solicit customers for his services as a medical negligence solicitor, can be substantiated;
(ii) Whether the claim is exaggerated;
(iii) Whether the claim may be misleading consumers, because it apparently ignores the fact that many modern drug treatments are known to be toxic, yet still offer better survival rates than no treatment at all.
6. It's not usual for complainants to support their challenges with named research, but there is one paper which I must bring to your attention. It is the most frequently-cited source of iatrogenic deaths in the UK.
7. Aylin et al (BMJ 2004; 329 : 369 doi: 10.1136/bmj.329.7462.369) discusses adverse events in hospitals between 1999 and 2003, and quotes:
"About 850 000 medical errors occur in NHS hospitals every year, resulting in 40 000 deaths."
8. However, the source of the two numbers is not any kind of published research, but a headline in a 1999 issue of the Daily Telegraph. A number of letters published in the BMJ, in response to the paper, confirm this point:
(i) "Adverse events reporting in English hospital statistics: No data were produced" BMJ 2004; 329 : 856 doi: 10.1136/bmj.329.7470.856-c
"The publication by the Dr Foster team does not produce any data on hospital deaths but quotes as a reference a conference report in 2001... The alarming headline in the Times is not based on established fact, and, although the Dr Foster organisation is committed to putting the available data on medical care in the public arena, the figure of 40 000 patients killed by hospital blunders is not substantiated."
(ii) "Adverse events reporting in English hospital statistics: Vague numbers are being perpetuated" BMJ 2004; 329 : 856 doi: 10.1136/bmj.329.7470.856-b
"Aylin et al write in their Dr Foster's case notes that about 850 000 medical errors occur in NHS hospitals every year, resulting in 40 000 deaths. They reference this to a PowerPoint presentation (itself unreferenced) given in Australia in 2001... In fact, the original reads, 'an estimated 850 000 (range 300 000 to 1.4 million) adverse events might occur each year in the NHS hospital sector… some adverse events will be inevitable complications of treatment.' "
9. I can confirm that I have no connections with the alternative medicine industry, no connections with Richard Barr, and no other conflicts of interest to declare."
Friday, 4 March 2011
Homeopaths Caught In The Act
Proponents of alternative medicine often accuse us sceptics of being ill-informed about the things we deign to criticise.
It's not a fair accusation in my experience and, to prove it, I've arranged a little challenge for my readers.
I wonder how many of them will be able to spot the connection between these six people?
(Image credit)If your answer was "You've just written some letters about them!", you'd be right, but you get no points for effort.
If you knew that they were homeopaths, full marks.
Their names are Caroline, Diane, Francis, Imogen, Mike and Phil. They're all practicing homeopaths whose websites make claims for homeopathy which, in my opinion, simply cannot be substantiated.
Today I've fired off complaints about them all to the Advertising Standards Authority. In addition I've complained to Trading Standards, and also to their professional organisation, a body called the Society of Homeopaths.
By the way. These six people happen to be, errr... the Board of Directors of the Society of Homeopaths!
UPDATE, 6 Mar: I've now added to the Advertising Standards (ASA) complaints the text of my complaints to the Society of Homeopaths (SoH). Apologies that this page is now longer than a copy of 'War and Peace'.
MIKE ANDREWS - ASA COMPLAINT
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.westsussexhomeopathy.co.uk
The site promotes the services of Mike Andrews, a homeopath, who operates from clinics in Horsham (Sussex) and another in London.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.westsussexhomeopathy.co.uk/?p=p_2
http://www.freezepage.com/1299277920PAOKIWCXXP
(i) "[Homeopathy] may be of benefit for a wide range of conditions"
(ii) "Homeopathy appears to support the body to regain health in both acute conditions and long standing health problems"
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(iii) Homeopathy can "trigger the body's natural healing system"
2. The site also includes a series of testimonials, "Homeopathy from a patient's perspective".
3. I'd also like to challenge whether the following testimonials, being used to promote the advertiser's services, are likely to be interpreted as factual and therefore mislead the consumer:
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(i) "From being skeptical [sic] there is no doubt in my mind that homeopathy really works for me. In fact it has helped me greatly and I now feel so much more in control of my health."
(ii) "...I developed a skin condition affecting only my hands... Mike Andrews [prescribed] three tablets, within 48 hours the healing process had started. The improvement was rapid and within two weeks my hands were back to normal. This cure has been maintained to the present day."
5. I can confirm that I have no connections with the alternative medicine industry."
MIKE ANDREWS - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Michael Andrews DSH, R.S.Hom.
The matter concerns the contents of Mr Andrews' website (www.westsussexhomeopathy.co.uk).
I argue that Mr Andrews may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Mr Andrews cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims he makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Mr Andrews may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on his website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.westsussexhomeopathy.co.uk/?p=p_2
http://www.freezepage.com/1299277920PAOKIWCXXP
(i) "[Homeopathy] may be of benefit for a wide range of conditions"
(ii) "Homeopathy appears to support the body to regain health in both acute conditions and long standing health problems"
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(iii) Homeopathy can "trigger the body's natural healing system"
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(iv) "From being skeptical [sic] there is no doubt in my mind that homeopathy really works for me. In fact it has helped me greatly and I now feel so much more in control of my health."
13. I further complaint that Mr Andrews may have breached the Society's Code in respect of a claimed cure for a named disease:
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(i) "...I developed a skin condition affecting only my hands... Mike Andrews [prescribed] three tablets, within 48 hours the healing process had started. The improvement was rapid and within two weeks my hands were back to normal. This cure has been maintained to the present day."
RESOLUTION
14. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
15. I have never been a patient of Mr Andrews, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
16. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Mr Andrews to withdraw the claims from his marketing materials and undertake not to repeat them."
PHILIP EDMONDS - ASA COMPLAINT
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.philipedmonds.co.uk
The site promotes the services of Philip Edmonds, a homeopath, who operates from clinics in Horsham, Haywards Heath and Teddington.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.philipedmonds.co.uk/
http://www.freezepage.com/1299278025BOZZWIXSUA
(i) "Millions of people, every day, benefit from Homeopathic treatment"
(ii) Homeopathy "cures a larger percentage of cases than any other method of treatment"
(iii) Homeopathy is "effective"
(iv) People who suffer from "allegies [sic], eczema, migraines, pchildren's problems... hormonal problems... arthritis, asthma, bronchitis, colitis, coughs, chrohn's [sic] disease, dermatitis, depression, diabetes, eating disorders, eczema, hay fever, headaches, hyperactivity, menopause, nausea, panic attacks, post viral [sic] syndrome, P[re-]M[enstraul]T[ension], psoriasis, recurrent infections, rhinitis, sinusitis, stress, tiredness and vomiting" can "USE MY HOMEOPATHIC CONSULTATION SERVICE"
(v) "HOW EFFECTIVE IS IT? During 1997, I did an audit on my practice. Results showed that 90% of patients who attended 3 times over a 3 month period, showed between 50% & 100% improvement..."
(vi) Homeopathy is the "deepest and yet most gentle stimulation possible for the human immune system"
(vii) Homeopathy "also works on animals"
(viii) Conditions such as asthma and eczema occur because "our bodies will run 'old programs' that they have previously found effective in similar circumstances", and homeopathy "seems to give the body the correct information, so that it can make a better immune response... The result is usually a reduction in symptoms, as the body begins to cure itself."
(ix) Homeopathy "may be" capable of resolving medical problems "with the first treatment"
(x) The "action" of a "homeopathic remedy" can "continue for several weeks, or even months"
http://www.philipedmonds.co.uk/pages/what-is-homeopathy.php
http://www.freezepage.com/1299278053FWWKTDVGWM
(xi) "Homeopathy works. In more than twenty years of professional practice I have seen it overcome a huge variety of acute and chronic diseases. More and more people are experiencing the wonderful effects of Classical Homeopathy in restoring their health..."
(xii) Homeopathy will "revolutionize [sic] your family's health"
(xiii) Homeopathy is an "effective, safe alternative" to "pharmaceutical drugs" which "are often not curative and often have harmful and toxic side effects to the human organism"
(xiv) "Homeopathy cannot... cure diseases such as Cancer [sic] and Aids. But there are some individuals, with these diseases, that can be helped by enhancing their immune systems..."
(xv) Homeopathy has "phenomenal success and reputation... in treating epidemic diseases"
2. Regarding the claim that "pharmaceutical drugs...are often not curative and often have harmful and toxic side effects to the human organism", I'd like to challenge whether the advertiser may be discouraging essential treatment.
3. The advertiser quotes five published accounts. Of the five, three are surveys, one is a pilot study, and one is an observational study without controls. None of the accounts appear to be randomised, controlled trials (RCTs).
4. Therefore, I'd like to challenge whether the advertiser's representation of these accounts as meaningful scientific evidence is misleading.
5. I'd like to challenge whether the following testimonial, being used to promote the advertiser's services, is likely to be interpreted as factual and therefore mislead the consumer; I'd also like to challenge whether the portrayal of children living a enjoying "antibiotic and drug-free health" because of homeopathy could discourage essential treatment, and whether it is irresponsible:
http://www.philipedmonds.co.uk/pages/patient-comments-testimonials.php
http://www.freezepage.com/1299278085IPNWXKEPWP
(i) "Phil Edmonds treated my 8yr old son when he was 9 months old for eczema that was very severe... After three weeks of treatment he became a happier baby and over the following month his eczema gradually disappeared. His eczema has never re-appeared... My other two sons have received regular constitutional treatment with Phil to ensure a healthy immune system, and as a result they also enjoy antibiotic and drug-free health".
7. I can confirm that I have no connections with the alternative medicine industry.
PHILIP EDMONDS - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Philip Edmonds R.S.Hom.
The matter concerns the contents of Mr Edmonds' website (www.philipedmonds.co.uk).
I argue that Mr Edmonds may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Mr Edmonds cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims he makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Mr Edmonds may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on his website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.philipedmonds.co.uk/
http://www.freezepage.com/1299278025BOZZWIXSUA
(i) "Millions of people, every day, benefit from Homeopathic treatment"
(ii) Homeopathy "cures a larger percentage of cases than any other method of treatment"
(iii) Homeopathy is "effective"
(iv) People who suffer from "allegies [sic], eczema, migraines, pchildren's problems... hormonal problems... arthritis, asthma, bronchitis, colitis, coughs, chrohn's [sic] disease, dermatitis, depression, diabetes, eating disorders, eczema, hay fever, headaches, hyperactivity, menopause, nausea, panic attacks, post viral [sic] syndrome, P[re-]M[enstraul]T[ension], psoriasis, recurrent infections, rhinitis, sinusitis, stress, tiredness and vomiting" can "USE MY HOMEOPATHIC CONSULTATION SERVICE"
(v) "HOW EFFECTIVE IS IT? During 1997, I did an audit on my practice. Results showed that 90% of patients who attended 3 times over a 3 month period, showed between 50% & 100% improvement..."
(vi) Homeopathy is the "deepest and yet most gentle stimulation possible for the human immune system"
(vii) Homeopathy "also works on animals"
(viii) Conditions such as asthma and eczema occur because "our bodies will run 'old programs' that they have previously found effective in similar circumstances", and homeopathy "seems to give the body the correct information, so that it can make a better immune response... The result is usually a reduction in symptoms, as the body begins to cure itself."
(ix) Homeopathy "may be" capable of resolving medical problems "with the first treatment"
(x) The "action" of a "homeopathic remedy" can "continue for several weeks, or even months"
http://www.philipedmonds.co.uk/pages/what-is-homeopathy.php
http://www.freezepage.com/1299278053FWWKTDVGWM
(xi) "Homeopathy works. In more than twenty years of professional practice I have seen it overcome a huge variety of acute and chronic diseases. More and more people are experiencing the wonderful effects of Classical Homeopathy in restoring their health..."
(xii) Homeopathy will "revolutionize [sic] your family's health"
(xiii) Homeopathy is an "effective, safe alternative" to "pharmaceutical drugs" which "are often not curative and often have harmful and toxic side effects to the human organism"
(xiv) "Homeopathy cannot... cure diseases such as Cancer [sic] and Aids. But there are some individuals, with these diseases, that can be helped by enhancing their immune systems..."
(xv) Homeopathy has "phenomenal success and reputation... in treating epidemic diseases"
http://www.philipedmonds.co.uk/pages/patient-comments-testimonials.php
http://www.freezepage.com/1299278085IPNWXKEPWP
(xvi) "Phil Edmonds treated my 8yr old son when he was 9 months old for eczema that was very severe... After three weeks of treatment he became a happier baby and over the following month his eczema gradually disappeared. His eczema has never re-appeared... My other two sons have received regular constitutional treatment with Phil to ensure a healthy immune system, and as a result they also enjoy antibiotic and drug-free health".
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Mr Edmonds, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Mr Edmonds to withdraw the claims from his marketing materials and undertake not to repeat them."
DIANE GOODWIN - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.edinburghhomeopaths.com
The site promotes the services of Diane Goodwin, a homeopath, who operates from a clinic in Edinburgh.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.edinburghhomeopaths.com/index.html
http://www.freezepage.com/1299278112NKMZWNIWNB
(i) Homeopathy may benefit people with "Allergies... Asthma... Skin disorders such as Eczema, Psoriasis and Acne... Alopecia... Irritable Bowel Syndrome... Digestive Disorders and Food Intolerance... Menstrual Problems... Difficult Menopausal Symptoms... Polycystic Ovaries... Infertility... Rheumatoid Arthritis... Multiple Sclerosis... Sleep disorders... Anxiety... Depression... Recurring infections... ME... Post Viral [sic] Disorders... Behavioural Problems in Children... And many other long term [sic] chronic or recurring illness [sic]"
(ii) "Homeopathy... can be very useful for those experiencing morning sickness... as well as supporting safe, natural, drug free [sic] births..."
http://www.edinburghhomeopaths.com/introtohom.html
http://www.freezepage.com/1299278139ENEOOULBTT
(iii) "Homeopathy is a system of dynamic medicine that works by stimulating and supporting the body’s own ability to restore itself to health."
(iv) "Homeopathy can be used for both acute and chronic diseases..."
http://www.edinburghhomeopaths.com/faq.html
http://www.freezepage.com/1299278169BDIKGGJJKM
(v) "Taking a homeopathic remedy stimulates the healing process..."
(vi) People can use homeopathy to recover more quickly from colds
2. I'd also like to challenge whether the following claim could discourage consumers from seeking essential treatment:
http://www.edinburghhomeopaths.com/faq.html
http://www.freezepage.com/1299278169BDIKGGJJKM
(i) "Also, if you have been suppressing the symptoms of your problem with particular drugs – for example, steroid creams for skin -- you may find that the symptoms surface again. However, they should improve without suppressive drugs once the correct [homeopathic] remedy treatment is prescribed.
3. I can confirm that I have no connections with the alternative medicine industry.
DIANE GOODWIN - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Diane Goodwin RSHom., PCH.
The matter concerns the contents of Ms Goodwin's website (www.edinburghhomeopaths.com).
I argue that Ms Goodwin may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Ms Goodwin cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims she makes in her website, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Ms Goodwin may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on her website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.edinburghhomeopaths.com/index.html
http://www.freezepage.com/1299278112NKMZWNIWNB
(i) Homeopathy may benefit people with "Allergies... Asthma... Skin disorders such as Eczema, Psoriasis and Acne... Alopecia... Irritable Bowel Syndrome... Digestive Disorders and Food Intolerance... Menstrual Problems... Difficult Menopausal Symptoms... Polycystic Ovaries... Infertility... Rheumatoid Arthritis... Multiple Sclerosis... Sleep disorders... Anxiety... Depression... Recurring infections... ME... Post Viral [sic] Disorders... Behavioural Problems in Children... And many other long term [sic] chronic or recurring illness [sic]"
(ii) "Homeopathy... can be very useful for those experiencing morning sickness... as well as supporting safe, natural, drug free [sic] births..."
http://www.edinburghhomeopaths.com/introtohom.html
http://www.freezepage.com/1299278139ENEOOULBTT
(iii) "Homeopathy is a system of dynamic medicine that works by stimulating and supporting the body’s own ability to restore itself to health."
(iv) "Homeopathy can be used for both acute and chronic diseases..."
http://www.edinburghhomeopaths.com/faq.html
http://www.freezepage.com/1299278169BDIKGGJJKM
(v) "Taking a homeopathic remedy stimulates the healing process..."
(vi) People can use homeopathy to recover more quickly from colds
(vii) "Also, if you have been suppressing the symptoms of your problem with particular drugs – for example, steroid creams for skin -- you may find that the symptoms surface again. However, they should improve without suppressive drugs once the correct [homeopathic] remedy treatment is prescribed.
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Ms Goodwin, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Ms Goodwin to withdraw the claims from her marketing materials and undertake not to repeat them."
CAROLINE JURDON - ASA COMPLAINT
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.fivewaysclinic.co.uk
The site promotes the Fiveways Acupuncture Clinic in Brighton. This complaint concerns mainly the page promoting the services of Caroline Jurdon, a homeopath.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.fivewaysclinic.co.uk/homeopathy.html
http://www.freezepage.com/1299278203MOQVJYGKSQ
(i) "Homeopathy helps the body heal itself naturally by boosting the immune system, helping patients deal with the underlying cause of their illness rather than just relieving or suppressing their symptoms as modern medicine sometimes does."
(ii) "Illnesses which respond well to homeopathy include... depression... asthma... eczema... Crohn's disease... Ulcerative Colitis... M(yalgic) E(ncephalomyelitis)... Glandular Fever..."
(iii) "People who have homeopathic treatment generally find their state of health and well-being improves. They are better able to resist infection..."
2. I can confirm that I have no connections with the alternative medicine industry."
CAROLINE JURDON - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Caroline Jurdon BA(Hons), LCCH, R.S.Hom.
The matter concerns the contents of Ms Jurdon's website (www.fivewaysclinic.co.uk).
I argue that Ms Jurdon may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Ms Jurdon cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims she makes in her websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Ms Jurdon may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on her website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.fivewaysclinic.co.uk/homeopathy.html
http://www.freezepage.com/1299278203MOQVJYGKSQ
(i) "Homeopathy helps the body heal itself naturally by boosting the immune system, helping patients deal with the underlying cause of their illness rather than just relieving or suppressing their symptoms as modern medicine sometimes does."
(ii) "Illnesses which respond well to homeopathy include... depression... asthma... eczema... Crohn's disease... Ulcerative Colitis... M(yalgic) E(ncephalomyelitis)... Glandular Fever..."
(iii) "People who have homeopathic treatment generally find their state of health and well-being improves. They are better able to resist infection..."
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Ms Jurdon, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Ms Jurdon to withdraw the claims from her marketing materials and undertake not to repeat them."
IMOGEN SPENCER - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.brackenburyclinic.com
The site promotes the Brackenbury Clinic in Hammersmith. This complaint concerns mainly the pages promoting the services of Imogen Spencer, a homeopath.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.brackenburyclinic.com/hammersmith/002-therapy/036-homeopathy.html
http://www.freezepage.com/1299278236EVRRVZNEPM
(i) "Homeopathic remedies can 'trigger the body's natural healing energy into starting the healing process.' "
(ii) "Patients ask how long it will take before they are cured. This is impossible to predict because each individual case is different and cure depends on how much there is to unravel..."
2. I'd like to challenge whether the following claim may discourage essential treatment:
(i) "Sometimes there may be a temporary release of emotional symptoms. Sometimes old, forgotten symptoms may reappear briefly. Your homeopath will explain that this is a good sign and means that the body is dealing with conditions that were previously suppressed or not dealt with. No visit to the GP is necessary."
3. The site also promotes an "Allergy & Deficiency Testing" service offered by Ms Spencer. The site describes the service:
http://www.brackenburyclinic.com/hammersmith/002-therapy/017-allergy-deficiency-testing.html
http://www.freezepage.com/1299278378YAHNDFDWZF
(i) "...the latest in computerised diagnosis. This entails a non-invasive test suitable for adults and children. For the test sensors are attached to ankles, wrists and head, or around the waist for children. These sensors pick up signals, which are then processed by a computer program [sic] and the information is displayed on the computer screen. The actual testing process with Bodyscan takes about 20 minutes. Bodyscan is a computerised Bio-Resonance system which measures and records a person’s response to 4000 items..."
4. Having read some recent adjudications concerning comparable claims, I understand that the only reliable method for testing for food allergies, at present, is by a slow process of elimination. The advertiser offers a more direct route.
5. I doubt whether the following claims made for the "Bio-Resonance system" are true, and I'd like to challenge whether the advertiser can substantiate them:
(i) Using the "Bio-Resonance system" it is "now possible to find out the underlying cause" of the "headaches, digestive disorders, coughs & colds, thrush, ear infections, sinusitis, hay fever, conjunctivitis, skin & hair problems, backache & joint problems" caused by a "deficiency of minerals or vitamins in the body".
(ii) The "Bodyscan" device is capable of "measur[ing] and record[ing] a person's response to 4000 items", including "tests for intolerance to food gorups, individual foods, inhalant allergies and also vitamin and mineral deficiencies"
(iii) The "Bodyscan" device is also capable of producing a "Back pain diagnosis" and a "Post-viral diagnosis"
(iv) "When testing is combined with homeopathy, this [system] provides a complete treatment approach, which improves the prognosis for a fast and efficient recovery."
6. I can confirm that I have no connections with the alternative medicine industry."
IMOGEN SPENCER - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Imogen Spencer R.S.Hom.
The matter concerns the contents of the website on which Ms Spencer promotes her services (www.brackenburyclinic.com).
I argue that Ms Spencer may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Ms Spencer cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims she makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Ms Spencer may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on her website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.brackenburyclinic.com/hammersmith/002-therapy/036-homeopathy.html
http://www.freezepage.com/1299278236EVRRVZNEPM
(i) "Homeopathic remedies can 'trigger the body's natural healing energy into starting the healing process.' "
(ii) "Patients ask how long it will take before they are cured. This is impossible to predict because each individual case is different and cure depends on how much there is to unravel..."
(iii) "Sometimes there may be a temporary release of emotional symptoms. Sometimes old, forgotten symptoms may reappear briefly. Your homeopath will explain that this is a good sign and means that the body is dealing with conditions that were previously suppressed or not dealt with. No visit to the GP is necessary."
http://www.brackenburyclinic.com/hammersmith/002-therapy/017-allergy-deficiency-testing.html
http://www.freezepage.com/1299278378YAHNDFDWZF
(iv) "...the latest in computerised diagnosis. This entails a non-invasive test suitable for adults and children. For the test sensors are attached to ankles, wrists and head, or around the waist for children. These sensors pick up signals, which are then processed by a computer program [sic] and the information is displayed on the computer screen. The actual testing process with Bodyscan takes about 20 minutes. Bodyscan is a computerised Bio-Resonance system which measures and records a person’s response to 4000 items..."
(v) Using the "Bio-Resonance system" it is "now possible to find out the underlying cause" of the "headaches, digestive disorders, coughs & colds, thrush, ear infections, sinusitis, hay fever, conjunctivitis, skin & hair problems, backache & joint problems" caused by a "deficiency of minerals or vitamins in the body".
(vi) The "Bodyscan" device is capable of "measur[ing] and record[ing] a person's response to 4000 items", including "tests for intolerance to food gorups, individual foods, inhalant allergies and also vitamin and mineral deficiencies"
(vii) The "Bodyscan" device is also capable of producing a "Back pain diagnosis" and a "Post-viral diagnosis"
(viii) "When testing is combined with homeopathy, this [system] provides a complete treatment approach, which improves the prognosis for a fast and efficient recovery."
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Ms Spencer, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Ms Spencer to withdraw the claims from her marketing materials and undertake not to repeat them."
FRANCIS TREUHERZ - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.homeopathyhelpline.com
The site promotes the services of Francis Trueherz via his "Homeopathy Helpline", calls to which cost £1.50 per minutes.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.homeopathyhelpline.com/homeopathy.html
http://www.freezepage.com/1299278292DDWEQDUXVK
(i) "Homeopathy has the power to heal so many problems..."
(ii) Single doses of homeopathy products are "often extraordinarily effective"
(iii) "Homeopathy is a comprehensive medical system that can treat most conditions from arthritis to varicose veins, from constipation to concussion, from piles to complaints during pregnancy..."
(iv) Homeopathy can "help people who [sic] doctors cannot help, and to avoid or reduce reliance on conventional medication, such as antibiotics or steroids..."
(v) "Homeopathy is an effective and scientific system of healing which assists the natural tendnecy of the body to heal itself."
(vi) "...all symptoms of ill health are expressions of disharmony within the whole person..."
2. I can confirm that I have no connections with the alternative medicine industry."
FRANCIS TREUHERZ - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Francis Treuherz MA RSHom FSHom.
The matter concerns the contents of Mr Treuherz' website (www.homeopathyhelpline.com).
I argue that Mr Treuherz may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Mr Treuherz cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims he makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Mr Treuherz may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on his website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.homeopathyhelpline.com/homeopathy.html
http://www.freezepage.com/1299278292DDWEQDUXVK
(i) "Homeopathy has the power to heal so many problems..."
(ii) Single doses of homeopathy products are "often extraordinarily effective"
(iii) "Homeopathy is a comprehensive medical system that can treat most conditions from arthritis to varicose veins, from constipation to concussion, from piles to complaints during pregnancy..."
(iv) Homeopathy can "help people who [sic] doctors cannot help, and to avoid or reduce reliance on conventional medication, such as antibiotics or steroids..."
(v) "Homeopathy is an effective and scientific system of healing which assists the natural tendency of the body to heal itself."
(vi) "...all symptoms of ill health are expressions of disharmony within the whole person..."
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Mr Treuherz, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Mr Treuherz to withdraw the claims from his marketing materials and undertake not to repeat them."
If you knew that they were homeopaths, full marks.
Their names are Caroline, Diane, Francis, Imogen, Mike and Phil. They're all practicing homeopaths whose websites make claims for homeopathy which, in my opinion, simply cannot be substantiated.
Today I've fired off complaints about them all to the Advertising Standards Authority. In addition I've complained to Trading Standards, and also to their professional organisation, a body called the Society of Homeopaths.
By the way. These six people happen to be, errr... the Board of Directors of the Society of Homeopaths!
UPDATE, 6 Mar: I've now added to the Advertising Standards (ASA) complaints the text of my complaints to the Society of Homeopaths (SoH). Apologies that this page is now longer than a copy of 'War and Peace'.
MIKE ANDREWS - ASA COMPLAINT
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.westsussexhomeopathy.co.uk
The site promotes the services of Mike Andrews, a homeopath, who operates from clinics in Horsham (Sussex) and another in London.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.westsussexhomeopathy.co.uk/?p=p_2
http://www.freezepage.com/1299277920PAOKIWCXXP
(i) "[Homeopathy] may be of benefit for a wide range of conditions"
(ii) "Homeopathy appears to support the body to regain health in both acute conditions and long standing health problems"
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(iii) Homeopathy can "trigger the body's natural healing system"
2. The site also includes a series of testimonials, "Homeopathy from a patient's perspective".
3. I'd also like to challenge whether the following testimonials, being used to promote the advertiser's services, are likely to be interpreted as factual and therefore mislead the consumer:
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(i) "From being skeptical [sic] there is no doubt in my mind that homeopathy really works for me. In fact it has helped me greatly and I now feel so much more in control of my health."
(ii) "...I developed a skin condition affecting only my hands... Mike Andrews [prescribed] three tablets, within 48 hours the healing process had started. The improvement was rapid and within two weeks my hands were back to normal. This cure has been maintained to the present day."
5. I can confirm that I have no connections with the alternative medicine industry."
MIKE ANDREWS - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Michael Andrews DSH, R.S.Hom.
The matter concerns the contents of Mr Andrews' website (www.westsussexhomeopathy.co.uk).
I argue that Mr Andrews may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Mr Andrews cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims he makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Mr Andrews may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on his website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.westsussexhomeopathy.co.uk/?p=p_2
http://www.freezepage.com/1299277920PAOKIWCXXP
(i) "[Homeopathy] may be of benefit for a wide range of conditions"
(ii) "Homeopathy appears to support the body to regain health in both acute conditions and long standing health problems"
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(iii) Homeopathy can "trigger the body's natural healing system"
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(iv) "From being skeptical [sic] there is no doubt in my mind that homeopathy really works for me. In fact it has helped me greatly and I now feel so much more in control of my health."
13. I further complaint that Mr Andrews may have breached the Society's Code in respect of a claimed cure for a named disease:
http://www.westsussexhomeopathy.co.uk/?p=productsList&iCategory=55
http://www.freezepage.com/1299277946RZVJNDEYDL
(i) "...I developed a skin condition affecting only my hands... Mike Andrews [prescribed] three tablets, within 48 hours the healing process had started. The improvement was rapid and within two weeks my hands were back to normal. This cure has been maintained to the present day."
RESOLUTION
14. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
15. I have never been a patient of Mr Andrews, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
16. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Mr Andrews to withdraw the claims from his marketing materials and undertake not to repeat them."
PHILIP EDMONDS - ASA COMPLAINT
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.philipedmonds.co.uk
The site promotes the services of Philip Edmonds, a homeopath, who operates from clinics in Horsham, Haywards Heath and Teddington.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.philipedmonds.co.uk/
http://www.freezepage.com/1299278025BOZZWIXSUA
(i) "Millions of people, every day, benefit from Homeopathic treatment"
(ii) Homeopathy "cures a larger percentage of cases than any other method of treatment"
(iii) Homeopathy is "effective"
(iv) People who suffer from "allegies [sic], eczema, migraines, pchildren's problems... hormonal problems... arthritis, asthma, bronchitis, colitis, coughs, chrohn's [sic] disease, dermatitis, depression, diabetes, eating disorders, eczema, hay fever, headaches, hyperactivity, menopause, nausea, panic attacks, post viral [sic] syndrome, P[re-]M[enstraul]T[ension], psoriasis, recurrent infections, rhinitis, sinusitis, stress, tiredness and vomiting" can "USE MY HOMEOPATHIC CONSULTATION SERVICE"
(v) "HOW EFFECTIVE IS IT? During 1997, I did an audit on my practice. Results showed that 90% of patients who attended 3 times over a 3 month period, showed between 50% & 100% improvement..."
(vi) Homeopathy is the "deepest and yet most gentle stimulation possible for the human immune system"
(vii) Homeopathy "also works on animals"
(viii) Conditions such as asthma and eczema occur because "our bodies will run 'old programs' that they have previously found effective in similar circumstances", and homeopathy "seems to give the body the correct information, so that it can make a better immune response... The result is usually a reduction in symptoms, as the body begins to cure itself."
(ix) Homeopathy "may be" capable of resolving medical problems "with the first treatment"
(x) The "action" of a "homeopathic remedy" can "continue for several weeks, or even months"
http://www.philipedmonds.co.uk/pages/what-is-homeopathy.php
http://www.freezepage.com/1299278053FWWKTDVGWM
(xi) "Homeopathy works. In more than twenty years of professional practice I have seen it overcome a huge variety of acute and chronic diseases. More and more people are experiencing the wonderful effects of Classical Homeopathy in restoring their health..."
(xii) Homeopathy will "revolutionize [sic] your family's health"
(xiii) Homeopathy is an "effective, safe alternative" to "pharmaceutical drugs" which "are often not curative and often have harmful and toxic side effects to the human organism"
(xiv) "Homeopathy cannot... cure diseases such as Cancer [sic] and Aids. But there are some individuals, with these diseases, that can be helped by enhancing their immune systems..."
(xv) Homeopathy has "phenomenal success and reputation... in treating epidemic diseases"
2. Regarding the claim that "pharmaceutical drugs...are often not curative and often have harmful and toxic side effects to the human organism", I'd like to challenge whether the advertiser may be discouraging essential treatment.
3. The advertiser quotes five published accounts. Of the five, three are surveys, one is a pilot study, and one is an observational study without controls. None of the accounts appear to be randomised, controlled trials (RCTs).
4. Therefore, I'd like to challenge whether the advertiser's representation of these accounts as meaningful scientific evidence is misleading.
5. I'd like to challenge whether the following testimonial, being used to promote the advertiser's services, is likely to be interpreted as factual and therefore mislead the consumer; I'd also like to challenge whether the portrayal of children living a enjoying "antibiotic and drug-free health" because of homeopathy could discourage essential treatment, and whether it is irresponsible:
http://www.philipedmonds.co.uk/pages/patient-comments-testimonials.php
http://www.freezepage.com/1299278085IPNWXKEPWP
(i) "Phil Edmonds treated my 8yr old son when he was 9 months old for eczema that was very severe... After three weeks of treatment he became a happier baby and over the following month his eczema gradually disappeared. His eczema has never re-appeared... My other two sons have received regular constitutional treatment with Phil to ensure a healthy immune system, and as a result they also enjoy antibiotic and drug-free health".
7. I can confirm that I have no connections with the alternative medicine industry.
PHILIP EDMONDS - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Philip Edmonds R.S.Hom.
The matter concerns the contents of Mr Edmonds' website (www.philipedmonds.co.uk).
I argue that Mr Edmonds may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Mr Edmonds cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims he makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Mr Edmonds may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on his website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.philipedmonds.co.uk/
http://www.freezepage.com/1299278025BOZZWIXSUA
(i) "Millions of people, every day, benefit from Homeopathic treatment"
(ii) Homeopathy "cures a larger percentage of cases than any other method of treatment"
(iii) Homeopathy is "effective"
(iv) People who suffer from "allegies [sic], eczema, migraines, pchildren's problems... hormonal problems... arthritis, asthma, bronchitis, colitis, coughs, chrohn's [sic] disease, dermatitis, depression, diabetes, eating disorders, eczema, hay fever, headaches, hyperactivity, menopause, nausea, panic attacks, post viral [sic] syndrome, P[re-]M[enstraul]T[ension], psoriasis, recurrent infections, rhinitis, sinusitis, stress, tiredness and vomiting" can "USE MY HOMEOPATHIC CONSULTATION SERVICE"
(v) "HOW EFFECTIVE IS IT? During 1997, I did an audit on my practice. Results showed that 90% of patients who attended 3 times over a 3 month period, showed between 50% & 100% improvement..."
(vi) Homeopathy is the "deepest and yet most gentle stimulation possible for the human immune system"
(vii) Homeopathy "also works on animals"
(viii) Conditions such as asthma and eczema occur because "our bodies will run 'old programs' that they have previously found effective in similar circumstances", and homeopathy "seems to give the body the correct information, so that it can make a better immune response... The result is usually a reduction in symptoms, as the body begins to cure itself."
(ix) Homeopathy "may be" capable of resolving medical problems "with the first treatment"
(x) The "action" of a "homeopathic remedy" can "continue for several weeks, or even months"
http://www.philipedmonds.co.uk/pages/what-is-homeopathy.php
http://www.freezepage.com/1299278053FWWKTDVGWM
(xi) "Homeopathy works. In more than twenty years of professional practice I have seen it overcome a huge variety of acute and chronic diseases. More and more people are experiencing the wonderful effects of Classical Homeopathy in restoring their health..."
(xii) Homeopathy will "revolutionize [sic] your family's health"
(xiii) Homeopathy is an "effective, safe alternative" to "pharmaceutical drugs" which "are often not curative and often have harmful and toxic side effects to the human organism"
(xiv) "Homeopathy cannot... cure diseases such as Cancer [sic] and Aids. But there are some individuals, with these diseases, that can be helped by enhancing their immune systems..."
(xv) Homeopathy has "phenomenal success and reputation... in treating epidemic diseases"
http://www.philipedmonds.co.uk/pages/patient-comments-testimonials.php
http://www.freezepage.com/1299278085IPNWXKEPWP
(xvi) "Phil Edmonds treated my 8yr old son when he was 9 months old for eczema that was very severe... After three weeks of treatment he became a happier baby and over the following month his eczema gradually disappeared. His eczema has never re-appeared... My other two sons have received regular constitutional treatment with Phil to ensure a healthy immune system, and as a result they also enjoy antibiotic and drug-free health".
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Mr Edmonds, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Mr Edmonds to withdraw the claims from his marketing materials and undertake not to repeat them."
DIANE GOODWIN - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.edinburghhomeopaths.com
The site promotes the services of Diane Goodwin, a homeopath, who operates from a clinic in Edinburgh.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.edinburghhomeopaths.com/index.html
http://www.freezepage.com/1299278112NKMZWNIWNB
(i) Homeopathy may benefit people with "Allergies... Asthma... Skin disorders such as Eczema, Psoriasis and Acne... Alopecia... Irritable Bowel Syndrome... Digestive Disorders and Food Intolerance... Menstrual Problems... Difficult Menopausal Symptoms... Polycystic Ovaries... Infertility... Rheumatoid Arthritis... Multiple Sclerosis... Sleep disorders... Anxiety... Depression... Recurring infections... ME... Post Viral [sic] Disorders... Behavioural Problems in Children... And many other long term [sic] chronic or recurring illness [sic]"
(ii) "Homeopathy... can be very useful for those experiencing morning sickness... as well as supporting safe, natural, drug free [sic] births..."
http://www.edinburghhomeopaths.com/introtohom.html
http://www.freezepage.com/1299278139ENEOOULBTT
(iii) "Homeopathy is a system of dynamic medicine that works by stimulating and supporting the body’s own ability to restore itself to health."
(iv) "Homeopathy can be used for both acute and chronic diseases..."
http://www.edinburghhomeopaths.com/faq.html
http://www.freezepage.com/1299278169BDIKGGJJKM
(v) "Taking a homeopathic remedy stimulates the healing process..."
(vi) People can use homeopathy to recover more quickly from colds
2. I'd also like to challenge whether the following claim could discourage consumers from seeking essential treatment:
http://www.edinburghhomeopaths.com/faq.html
http://www.freezepage.com/1299278169BDIKGGJJKM
(i) "Also, if you have been suppressing the symptoms of your problem with particular drugs – for example, steroid creams for skin -- you may find that the symptoms surface again. However, they should improve without suppressive drugs once the correct [homeopathic] remedy treatment is prescribed.
3. I can confirm that I have no connections with the alternative medicine industry.
DIANE GOODWIN - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Diane Goodwin RSHom., PCH.
The matter concerns the contents of Ms Goodwin's website (www.edinburghhomeopaths.com).
I argue that Ms Goodwin may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Ms Goodwin cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims she makes in her website, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Ms Goodwin may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on her website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.edinburghhomeopaths.com/index.html
http://www.freezepage.com/1299278112NKMZWNIWNB
(i) Homeopathy may benefit people with "Allergies... Asthma... Skin disorders such as Eczema, Psoriasis and Acne... Alopecia... Irritable Bowel Syndrome... Digestive Disorders and Food Intolerance... Menstrual Problems... Difficult Menopausal Symptoms... Polycystic Ovaries... Infertility... Rheumatoid Arthritis... Multiple Sclerosis... Sleep disorders... Anxiety... Depression... Recurring infections... ME... Post Viral [sic] Disorders... Behavioural Problems in Children... And many other long term [sic] chronic or recurring illness [sic]"
(ii) "Homeopathy... can be very useful for those experiencing morning sickness... as well as supporting safe, natural, drug free [sic] births..."
http://www.edinburghhomeopaths.com/introtohom.html
http://www.freezepage.com/1299278139ENEOOULBTT
(iii) "Homeopathy is a system of dynamic medicine that works by stimulating and supporting the body’s own ability to restore itself to health."
(iv) "Homeopathy can be used for both acute and chronic diseases..."
http://www.edinburghhomeopaths.com/faq.html
http://www.freezepage.com/1299278169BDIKGGJJKM
(v) "Taking a homeopathic remedy stimulates the healing process..."
(vi) People can use homeopathy to recover more quickly from colds
(vii) "Also, if you have been suppressing the symptoms of your problem with particular drugs – for example, steroid creams for skin -- you may find that the symptoms surface again. However, they should improve without suppressive drugs once the correct [homeopathic] remedy treatment is prescribed.
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Ms Goodwin, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Ms Goodwin to withdraw the claims from her marketing materials and undertake not to repeat them."
CAROLINE JURDON - ASA COMPLAINT
"I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.fivewaysclinic.co.uk
The site promotes the Fiveways Acupuncture Clinic in Brighton. This complaint concerns mainly the page promoting the services of Caroline Jurdon, a homeopath.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.fivewaysclinic.co.uk/homeopathy.html
http://www.freezepage.com/1299278203MOQVJYGKSQ
(i) "Homeopathy helps the body heal itself naturally by boosting the immune system, helping patients deal with the underlying cause of their illness rather than just relieving or suppressing their symptoms as modern medicine sometimes does."
(ii) "Illnesses which respond well to homeopathy include... depression... asthma... eczema... Crohn's disease... Ulcerative Colitis... M(yalgic) E(ncephalomyelitis)... Glandular Fever..."
(iii) "People who have homeopathic treatment generally find their state of health and well-being improves. They are better able to resist infection..."
2. I can confirm that I have no connections with the alternative medicine industry."
CAROLINE JURDON - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Caroline Jurdon BA(Hons), LCCH, R.S.Hom.
The matter concerns the contents of Ms Jurdon's website (www.fivewaysclinic.co.uk).
I argue that Ms Jurdon may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Ms Jurdon cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims she makes in her websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Ms Jurdon may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on her website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.fivewaysclinic.co.uk/homeopathy.html
http://www.freezepage.com/1299278203MOQVJYGKSQ
(i) "Homeopathy helps the body heal itself naturally by boosting the immune system, helping patients deal with the underlying cause of their illness rather than just relieving or suppressing their symptoms as modern medicine sometimes does."
(ii) "Illnesses which respond well to homeopathy include... depression... asthma... eczema... Crohn's disease... Ulcerative Colitis... M(yalgic) E(ncephalomyelitis)... Glandular Fever..."
(iii) "People who have homeopathic treatment generally find their state of health and well-being improves. They are better able to resist infection..."
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Ms Jurdon, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Ms Jurdon to withdraw the claims from her marketing materials and undertake not to repeat them."
IMOGEN SPENCER - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.brackenburyclinic.com
The site promotes the Brackenbury Clinic in Hammersmith. This complaint concerns mainly the pages promoting the services of Imogen Spencer, a homeopath.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.brackenburyclinic.com/hammersmith/002-therapy/036-homeopathy.html
http://www.freezepage.com/1299278236EVRRVZNEPM
(i) "Homeopathic remedies can 'trigger the body's natural healing energy into starting the healing process.' "
(ii) "Patients ask how long it will take before they are cured. This is impossible to predict because each individual case is different and cure depends on how much there is to unravel..."
2. I'd like to challenge whether the following claim may discourage essential treatment:
(i) "Sometimes there may be a temporary release of emotional symptoms. Sometimes old, forgotten symptoms may reappear briefly. Your homeopath will explain that this is a good sign and means that the body is dealing with conditions that were previously suppressed or not dealt with. No visit to the GP is necessary."
3. The site also promotes an "Allergy & Deficiency Testing" service offered by Ms Spencer. The site describes the service:
http://www.brackenburyclinic.com/hammersmith/002-therapy/017-allergy-deficiency-testing.html
http://www.freezepage.com/1299278378YAHNDFDWZF
(i) "...the latest in computerised diagnosis. This entails a non-invasive test suitable for adults and children. For the test sensors are attached to ankles, wrists and head, or around the waist for children. These sensors pick up signals, which are then processed by a computer program [sic] and the information is displayed on the computer screen. The actual testing process with Bodyscan takes about 20 minutes. Bodyscan is a computerised Bio-Resonance system which measures and records a person’s response to 4000 items..."
4. Having read some recent adjudications concerning comparable claims, I understand that the only reliable method for testing for food allergies, at present, is by a slow process of elimination. The advertiser offers a more direct route.
5. I doubt whether the following claims made for the "Bio-Resonance system" are true, and I'd like to challenge whether the advertiser can substantiate them:
(i) Using the "Bio-Resonance system" it is "now possible to find out the underlying cause" of the "headaches, digestive disorders, coughs & colds, thrush, ear infections, sinusitis, hay fever, conjunctivitis, skin & hair problems, backache & joint problems" caused by a "deficiency of minerals or vitamins in the body".
(ii) The "Bodyscan" device is capable of "measur[ing] and record[ing] a person's response to 4000 items", including "tests for intolerance to food gorups, individual foods, inhalant allergies and also vitamin and mineral deficiencies"
(iii) The "Bodyscan" device is also capable of producing a "Back pain diagnosis" and a "Post-viral diagnosis"
(iv) "When testing is combined with homeopathy, this [system] provides a complete treatment approach, which improves the prognosis for a fast and efficient recovery."
6. I can confirm that I have no connections with the alternative medicine industry."
IMOGEN SPENCER - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Imogen Spencer R.S.Hom.
The matter concerns the contents of the website on which Ms Spencer promotes her services (www.brackenburyclinic.com).
I argue that Ms Spencer may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Ms Spencer cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims she makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Ms Spencer may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on her website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.brackenburyclinic.com/hammersmith/002-therapy/036-homeopathy.html
http://www.freezepage.com/1299278236EVRRVZNEPM
(i) "Homeopathic remedies can 'trigger the body's natural healing energy into starting the healing process.' "
(ii) "Patients ask how long it will take before they are cured. This is impossible to predict because each individual case is different and cure depends on how much there is to unravel..."
(iii) "Sometimes there may be a temporary release of emotional symptoms. Sometimes old, forgotten symptoms may reappear briefly. Your homeopath will explain that this is a good sign and means that the body is dealing with conditions that were previously suppressed or not dealt with. No visit to the GP is necessary."
http://www.brackenburyclinic.com/hammersmith/002-therapy/017-allergy-deficiency-testing.html
http://www.freezepage.com/1299278378YAHNDFDWZF
(iv) "...the latest in computerised diagnosis. This entails a non-invasive test suitable for adults and children. For the test sensors are attached to ankles, wrists and head, or around the waist for children. These sensors pick up signals, which are then processed by a computer program [sic] and the information is displayed on the computer screen. The actual testing process with Bodyscan takes about 20 minutes. Bodyscan is a computerised Bio-Resonance system which measures and records a person’s response to 4000 items..."
(v) Using the "Bio-Resonance system" it is "now possible to find out the underlying cause" of the "headaches, digestive disorders, coughs & colds, thrush, ear infections, sinusitis, hay fever, conjunctivitis, skin & hair problems, backache & joint problems" caused by a "deficiency of minerals or vitamins in the body".
(vi) The "Bodyscan" device is capable of "measur[ing] and record[ing] a person's response to 4000 items", including "tests for intolerance to food gorups, individual foods, inhalant allergies and also vitamin and mineral deficiencies"
(vii) The "Bodyscan" device is also capable of producing a "Back pain diagnosis" and a "Post-viral diagnosis"
(viii) "When testing is combined with homeopathy, this [system] provides a complete treatment approach, which improves the prognosis for a fast and efficient recovery."
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Ms Spencer, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Ms Spencer to withdraw the claims from her marketing materials and undertake not to repeat them."
FRANCIS TREUHERZ - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (4th March 2011, at 10pm) on the website www.homeopathyhelpline.com
The site promotes the services of Francis Trueherz via his "Homeopathy Helpline", calls to which cost £1.50 per minutes.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. My understanding of the scientific consensus, particularly the five meta-reviews that have been published, is that there is no evidence that homeopathy is effective for any condition. For that reason, I'd like to challenge whether any of the following claims can be substantiated, and whether they are misleading:
http://www.homeopathyhelpline.com/homeopathy.html
http://www.freezepage.com/1299278292DDWEQDUXVK
(i) "Homeopathy has the power to heal so many problems..."
(ii) Single doses of homeopathy products are "often extraordinarily effective"
(iii) "Homeopathy is a comprehensive medical system that can treat most conditions from arthritis to varicose veins, from constipation to concussion, from piles to complaints during pregnancy..."
(iv) Homeopathy can "help people who [sic] doctors cannot help, and to avoid or reduce reliance on conventional medication, such as antibiotics or steroids..."
(v) "Homeopathy is an effective and scientific system of healing which assists the natural tendnecy of the body to heal itself."
(vi) "...all symptoms of ill health are expressions of disharmony within the whole person..."
2. I can confirm that I have no connections with the alternative medicine industry."
FRANCIS TREUHERZ - SoH COMPLAINT
"Dear Sir/Madam,
I write to lodge a formal complaint against Francis Treuherz MA RSHom FSHom.
The matter concerns the contents of Mr Treuherz' website (www.homeopathyhelpline.com).
I argue that Mr Treuherz may be responsible for multiple breaches of the Society's "Code of Ethics and Practice (Revised April 2010)", specifically Key Principles 1.4 and 1.8, and Section 4, paras 38, 39 and 44.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Section 4, para 38 of the Society's "Code of Ethics and Practice" states that all members of the Society are expected to observe the CAP Code in their marketing materials:
(i) "38. All advertising must be published in a way that conforms to the law and to (the guidance issued in the British Code of Advertising Practice).
5. The Society's Code continues:
(i) "39. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims. Advertising may indicate special interests but must not make claims of superiority or disparage professional colleagues or other professionals. No promise of cure, either implicit or explicit, should be made of any named disease. All research should be presented clearly honestly and without distortion, all speculative theories will [sic] be stated as such and clearly distinguished."
6. The Society's Code continues:
(i) "44. Claims, whether explicit or implied, orally or in writing, implying cure of any named disease must be avoided."
REGULATION
7. It is not in dispute that the members of the Society hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
8. The only matter of importance is a member's compliance or non-compliance with the advertising regulations to which they are professionally bound.
9. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
10. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
11. If Mr Treuherz cannot produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate the marketing claims he makes in his websites, the Society's Professional Conduct Department must uphold my complaint.
COMPLAINT
12. I complain that Mr Treuherz may have breached the Society's Code of Ethics and Practice, in respect of the following marketing claims found on his website, on March 4th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.homeopathyhelpline.com/homeopathy.html
http://www.freezepage.com/1299278292DDWEQDUXVK
(i) "Homeopathy has the power to heal so many problems..."
(ii) Single doses of homeopathy products are "often extraordinarily effective"
(iii) "Homeopathy is a comprehensive medical system that can treat most conditions from arthritis to varicose veins, from constipation to concussion, from piles to complaints during pregnancy..."
(iv) Homeopathy can "help people who [sic] doctors cannot help, and to avoid or reduce reliance on conventional medication, such as antibiotics or steroids..."
(v) "Homeopathy is an effective and scientific system of healing which assists the natural tendency of the body to heal itself."
(vi) "...all symptoms of ill health are expressions of disharmony within the whole person..."
RESOLUTION
13. The Society's Code states:
"54. ...members of the public... have the right to complain to the Professional Conduct Department of The Society if they perceive that a registered or student clinical member has not... conducted themselves, in accordance with this Code."
14. I have never been a patient of Mr Treuherz, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
15. If the Society's Professional Conduct Department finds that my complaint is upheld, I would expect Mr Treuherz to withdraw the claims from his marketing materials and undertake not to repeat them."
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