Posted by: Kash Farooq | February 17, 2011

Dear MHRA. Please can you sort homeopathy out? Many thanks, The Thought Stash.

The MHRA (Medicines and Healthcare products Regulatory Agency) are asking for the public’s view on homeopathy, and specifically on the labelling of homeopathic remedies.

The Nightingale Collaboration has produced an official response to the “Review of Medicines Act 1968: informal consultation on issues relating to the PLR regime and homeopathy” [PDF], but I thought I’d join the party and submit by own message too.

If you want to send your own thoughts, the email address is: andrea.farmer@mhra.gsi.gov.uk. But you’ll need to be quick as the deadline is tomorrow, 18th February 2011.

[Many thanks to @dellybean for proof reading my hurried and typo strewn response!]

Dear Andrea,

I understand that you are collecting the public’s views on homeopathy and how it should be labelled.

My main concern is that even though homeopathy is safe (as clearly, “there’s nothing in it“), the labelling approved by the MHRA legitimises it.
As we have recently seen, homeopaths fully believe that these inert remedies can cure and/or prevent disease.

We have seen homeopaths (via BBC Scotland) recommend that parents drop the MMR vaccine in favour of homeopathic preparations.
Imagine parents who feel that their colds get better faster due to a homeopathic remedy then only to make other health decisions by extrapolating from this. Imagine these parents thinking: “We’re worried about all the scare stories about MMR, we’re going to immunise our child using homeopathy instead”.

We have also seen (again, via the BBC) pharmacies recommending remedies to protect against malaria. A placebo is not going to protect a person from a parasite!

Both these situations could lead to deaths.

As Homeopathic institutions are failing to regulate their members and refuse to condemn such actions, I believe it is up to the MHRA to protect the public.
By not being clearly and honestly labelled, the uninformed public could be making dangerous decisions about their healthcare.
I believe that the MHRA should enforce clear labelling; labelling that can explain, in plain English, the truth that there is absolutely no evidence that homeopathic remedies work beyond a placebo effect.

In particular, remedies for anything more severe than a cold or a sore throat should be made illegal; children cannot protect themselves from homeopaths who have persuaded parents to forgo vaccination in favour of homeopathy. They have to rely on organisations such as the MHRA.

Please bear in mind the severe implications of showing the public your approval of such therapies. It’s dangerously misleading and could cost lives. It is up to the MHRA to stop this from happening.

Yours sincerely,

Kash Farooq.


Responses

  1. Excellent!

  2. Kash – you prodded me into action. Here’s my submission:

    Dear Ms. Farmer,

    As a concerned layperson who is interested in medical subjects, and homeopathy especially, I would like to add my voice to the review of the Medicines Act 1968.

    First, since homeopathic preparations are marketed and described as medicines, I would like to see them regulated in the same way as all other medicines, with the same clear and unambiguous requirements for labelling, safety and efficacy. To do otherwise would lead to the situation where MHRA approval for one class of product implies all of the above, but for another product does not. This is not a clear and transparent regulatory regime.

    Thus, I would urge you to remove the remaining Product Licenses of Right (PLRs) for homeopathic preparations and either bring them in line with the licensing requirements for other medicinal products, or remove them from the “medicinal products” category completey. This latter course is already the plan of record for dealing with Bach flower remedies, for which I applaud the MHRA.

    I would also welcome clarifications to the wording of the labels on homeopathic products. The current text does not make it clear enough that the preparation has no evidence of efficacy, and in my view the phrase “medicinal product” is much clearer and easier to understand than the phrase “without approved therapeutic indications”. The sentence can easily be misconstrued to imply that this is an approved medicinal product.

    The new proposed wording is, I believe, also misleading, since it emphasises “safety” and “quality” without any mention of lack of evidence for efficacy. This is a serious omission since it again leads to a very unbalanced impression from the wording of the statement. Although homeopathy is, with few exceptions, completely safe in and of itself, selling an ineffective medicinal product for treatment of a serious condition can produce very real and lasting harm. Conventional medicines must pass this test, and are withdrawn if found to be ineffective; homeopathic preparations should be regulated under the same rules.

    I hope that the MHRA will take steps toward eliminating the special treatment of homeopathic preparations, thus making sure that MHRA certification is uniformly respected across all medicines.

    Yours,

    Sean Ellis

    • Good work Sean!


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