Evidence Based Policy: Interesting Times
By Keir Liddle
Yesterday, the government published this report: Statutory Regulation of Practitioners of Acupuncture, Herbal Medicine, Traditional Chinese Medicine and Other Traditional Medicine Systems Practised in the UK. The report concluded that the Health Professions Council (HPC) be used to regulate traditional Chinese medicine, acupuncture and herbal medicine, based largely upon recommendations made in this report, which Prof David Colquhoun tears down here.
Yesterday’s report may only have been a summary of the consultation work carried out thus far, but the Medicines and Healthcare products Regulatory Agency (MHRA) has been asked to set up a statutory register for practitioners supplying unlicensed herbal medicines:
A scheme would be created enabling registered practitioners to commission unlicensed herbal medicines to meet the special needs of their individual patients. Safeguards for the public would be provided by a combination of professional regulation and linked medicines regulation, for example, to safeguard manufacturing standards.
You can see the MHRA statement in full here. This is in direct contravention of the HPC’s own guideline that to be regulated, professions must “practise based on evidence of efficacy”, as well as a previous House of Lords report on regulation that stated:
“… we recommend that three important questions should be addressed in the following order . .
- (1) does the treatment offer therapeutic benefits greater than placebo?
- (2) is the treatment safe?
- (3) how does it compare, in medical outcome and cost-effectiveness, with other forms of treatment?
Is the enacting of statutory regulation evidence based in the light of these reccomendations? In short, no.
Far asides from efficacy beyond placebo (of which there is little evidence for any of the above treatments), there have been genuine safety concerns in the past. There was the case of Ms Wu, who sold “safe and natural” remedies contanimated with the banned substance aristolochic acid, which lead to one of her customers developing kidney failure, and later, cancer. There was the case of Quebec Health Authorities calling on 1,200 people to be tested for HIV and Hepatitis after an acupuncturist used unsterilised needles. This is not to mention the tragic cases of patients who treat such therapies not as complementary, but as alternatives to medicine, and die due to lack of treatment.
Practitioners of alternative therapies often deride “allopathy” or “Western traditional medicine” as being disease-centric, or the product of a greedy pharmaceutical industry bent on keeping people ill to peddle drugs. Yet they also seem to crave the respectability that the regulation and research base of health and medicine provide. To this end, they founded their own journals’ numerous regulatory bodies, including OfQuack, The Association of Traditional Chinese Medicine and The Acupuncture Society. All of this serves seemingly to give the impression that there is an evidence base for the treatments they provide, and that people can trust those treatments to be safe and effective.
To my mind, the government’s plans to introduce statutory regulation via the HPC are misconceived at best, and may prove to be a danger to public health at worst. They confer a respectability on to practitioners of treatments that are no better than placebo. I fear that this may lead to severe health issues, perhaps even deaths, for those who would take the government’s rubber stamping of such treatments as evidence that they work.
Is statutory regulation for traditional Chinese medicine and acupuncture evidence-based policy?
No. It is about as far from evidence-based policy as it is possible to get.