At Boots, it's 3 for the price of 2 on quackery

At 2pm on the 14th July, Skeptic Kash Farooq alerted me via Twitter to a quack medicine product on the Boots web site that he was going to make an Advertising Standards Authority complaint about.

The only problem was that the ASA does not regulate web site content. And this has been a problem stopping us from tackling Boots for some time. If Boots has false or unjustifiable claims to make about a product, they only seem to make them in areas where the ASA can’t touch them. They use packaging, point of sale materials and their web site to make their claims – all outside of the ASA’s remit. I’ve personally never seen widespread false claims made by Boots on posters, leaflets or in the press where the ASA can start issuing adjudications against them.

Whether this is a deliberate strategy by Boots, or just through chance alone I cannot be sure. But yesterday, they slipped up.

Kash had noticed that Boots had a 3 for the price of 2 offer “across all vitamins, complementary medicines and herbal products”. There are a couple of exceptions where the ASA will regulate claims made on the web. One is:

“We regulate sales promotions, such as special offers, prize draws and competitions wherever they appear.”

Boots appeared to have put their entire range of alternative health products – the products for which they regularly make unjustified claims of health benefits – fully within the remit of the Advertising Standards Authority.

I had no idea of how long this promotion would last, and with the ASA sometimes taking over a week to look at a case, I did not want the claims to fall out of remit before my complaint went in. Boots may have seen the tweets about them and realised they needed to withdraw the promotion. For the best chance of success, the complaint had to go in by the start of business the next morning.

I started going through the claims and realised that there was no possible way I could get through them by myself. Boots had 679 products in the range, many of which were making clearly unjustifiable claims. And in comes the power of Twitter. With a couple of Tweets, I suddenly had a small army of helpers.

I created a shared Google Spreadsheet in which a team of 9 or 10 people started adding URLs from the Boots web site and copying and pasting next to them the unjustifiable claims made about the product. With a little help from technical wizard @tommorris answering my call for help, I found a program that would automatically download the large number of web pages and print them to a local PDF to hold as evidence.

Watching what was happening on the Google Spreadsheet was awe-inspiring. When I started letting people into the document, there were 80 URLs copied and pasted into the list. By the time I got 15 more URLs into it, @the_beacon, @richardtomsett, @HelenaThomas, @dellybean, @kashfarooq, @nwoolhouseuk, @cherryblack, @RoisinThomas and @kingmuskar had pretty much copied and pasted all of the claims and were now waiting on me.

By the end of the evening, we’d sent off complaints to the Advertising Standards Authority about 107 Boots products.

The claims they were making varied from shocking – claiming that a homeopathic remedy is “to relieve the pain of teething.” To the bizarre – a magnet which you put in your knickers which they claimed “helps to reduce or completely eliminate the symptoms of menopause” – something one of my helpers described as a “Fanny Magnet”. There were some less serious claims such as listing “30c Aconitum napellus” as an active ingredient on a product when I can say with 99.999999999999999999999999999999999994% certainty that if manufactured carefully contains no Aconitum napellus (and I worked that number out, it’s not just a guess).

But my helpers continued after I finished. @nwoolhouseuk, @ScepticLetters,
@GDLockUK, @kashfarooq and @the_beacon together sent in a second complaint with another 133 products listed. @nwoolhouseuk was still going at 1:30 in the morning, and @ScepticLetters finally finished it off at 4am.

Boots will now hopefully be held to account. For years, whether accidentally or by design, they been keeping the misleading claims they make about their products just beyond the remit of the ASA. One slip up, and with excellent teamwork we caught them out in one night with a total of 240 complaints.

Letters to the Gideons

I did my Skeptical Activism & The Quacklash talk at Westminster Skeptics in the pub last night. My opening gag for the talk is related to a letter I wrote some years ago.

Several years ago I was inspired by the hilarious Timewaster letters and went through a period of writing daft letters to various organisations for no other reason than my own personal amusement. Last night, someone suggested I should publish these letters on my blog. While I don't want to ruin my opening gag by publishing the one I refer to in the talk, here's a series of letters I wrote to The Gideons, the people that leave Bibles in hotel rooms.

GCC investigations committee refers 36 Chiropractors to Professional Conduct Committee

The GCC has now updated me on the status of 50 of my complaints.

In 36 cases, the Investigations Committee has decided that there is a case to answer and they will be referring an allegation of unacceptable professional conduct against them to the Professional Conduct Committee.

In eight cases, the GCC is awaiting further information.

But in the remaining six cases, the GCC has decided not to pursue the allegation. It reads as though a determining factor was that those chiropractors immediately removed the claims upon being advised to do so by their association. The only explanation I can think of is that the BCA wrote to their members advising them not to make the claims while simultaneously pursuing a case against Simon Singh for referring to those same claims as "bogus".

Looks like the BCA does sometimes give good advice after all.

OfQuack launches six-month bullshit amnesty: the regulator that doesn’t regulate

Regular readers of this blog will know that some time ago I began making complaints to the Complementary and Natural Healthcare Council about reflexologist members who happily promote their bogus treatments despite the fact that there was not a jot of evidence to support them.

The CNHC has now informed me that for the next six months, they will no longer be processing any complaints that are similar to the ones I’ve submitted. By similar, I take this to mean complaints regarding practitioners who mislead their clients by making unjustifiable or false statements, including practitioners who have already been cautioned by the CNHC for doing it before.

The CNHC ruled in my favour of my original complaints, and told the members to stop making the claims, giving them until the end of March 2010 (4 months!) to remove them from their web sites. So now the four months are up, how many web sites have changed? I went back to look at 13 of the web sites I originally complained about.

Of the 13, two of the websites no longer exist which left 11 I could check.

Three of reflexologists seem to have toned down the claims, though continue to make them:

• Linda Pate seems to have prefixed her claims with the statement “there is a view that”.
• Lina Ramchand perhaps believes that her claims that reflexology releases toxins, can help with "infertility issues" and can "lead to easier child birth" comply now that she’s put them within quotation marks.
• Siobhan Elliot seems to have removed the claims to treat colic, IBS and arthritis from her site but now states “it is believed reflexology may be useful” for pregnancy and fertility. Her site invites you to request more info on reflexology, when I asked I was sent a word doc that claimed to treat IBS. Her page on reflexology links to another site that makes the claim that reflexology has anecdotally been shown effective for migraines, fertility, sleep disorders and hormonal imbalances.

Only one reflexologist has removed the bogus claims from their site. The other seven continue to happily promote their bogus treatments on their web sites on April 1st 2010, the day after the deadline they were given to remove the claims:

• Carole Armstrong claims that reflexology "may help with a variety of conditions both acute & chronic including sleep or hormonal problems, back pain & neck pain, digestive problems such as IBS".
• Linda Walker still makes claims for hay fever & arthritis
• Nuala Bent still claims that Reflexology “is helpful for many conditions including: Sinusitis, Menstrual Problems, Menopausal Problems, Stress, Migraine, Back Pain, Arthritis, Sciatica, Frozen Shoulder”
• Hazel Parry still promotes reflexology for “migraine, arthritis, sleep disorders and fertility issues.”
• Marguerite Gunn still mentions reflexology as a treatment for asthma, joint problems, back pain, colds/flu, hay fever, allergies and infertility.
• Mascha Mieris still advertises reflexology for “Back Pain, Migraine, Headache, Infertility, Arthritis, Sleep Disorders, Sports Injuries, Hormonal Imbalances, Digestive Disorders, stress-related Conditions.”
• Alison Graham continues to promote reflexology to “improve digestive function, lower blood pressure, improve sleeping patterns, balance hormonal problems and benefit the immune system.”

But maybe all of these practitioners had made the changes within their practices, and just failed to update their sites?

No.

I phoned four of the practitioners. Carole Armstrong was more than happy over the phone to tell me that reflexology “can help” with arthritis. Linda Walker claimed to treat both arthritis and hay fever. Hazel Perry said that reflexology “can help her” referring to my mother’s fictitious arthritis. Sharon Dean, the only reflexologist who had removed the claims from their web site, was told me that “some people believe it can” help with infertility problems, though she did clarify that this was “not proven”.

To see what the CNHC would do about their members continuing to flout their regulations in spite of an existing ruling against them, I submitted a second complaint about Linda Walker. I included email evidence that Linda Walker was still making the same claims as before.

The CNHC told me that they would not be investigating this complaints, or any complaints like it. They “would not be able to action any complaints of a similar nature to those you have already submitted for six months from the date of this letter”.

The CNHC, it seems, now refuses to investigate complaints about its members making misleading or unjustifiable claims – even against those it has already ruled against.

Its members have shown their lack of respect for any decision made by the CNHC by not removing the claims from their web sites.

How can the CNHC still consider itself to be a regulatory body if it no longer regulates?

Scientist to take on Tredinnick MP in next election

Dr Michael Brooks, an author, journalist, broadcaster and consultant to New Scientist with a PhD in quantum physics will be taking on David Tredinnick MP in the next election. For anyone who knows anything about Tredinnick’s hopeless understanding of science and almost fanatical commitment to mumbo jumbo, the reasons will be clear.

Michael’s announcement, in his own words, are below.

But most importantly, we urgently need the signatures of 10 people who are registered to vote in the Bosworth constituency. Without this, we cannot register Michael as a candidate. If you do not live in this constituency, do you know anyone who does?

Bosworth constituency covers the towns of Ambien, Barlestone, Nailstone and Osbaston, Barwell, Burbage St Catherines, Lash Hill, Burbage Sketchley, Stretton, Cadeby, Carlton, Market Bosworth with Shackerstone, Earl Shilton, Hinckley Castle, Hinckley Clarendon, Hinckley De Montfort, Hinckley Trinity, Markfield, Stanton, Fieldhead, Newbold Verdon, Desford, Peckleton, Ratby, Bagworth, Thornton, Twycross, Witherley and Sheepy.

Please email Michael on mb@michaelbrooks.org if you are in the constituency and able to offer support.

Michael's announcement follows:

Dear All,

I’m a science writer and a consultant to New Scientist magazine. I’m looking for 10 people who would be willing to sign my nomination form to stand in the general election in the Bosworth-Hinckley constituency.

The point of standing is to highlight the fact that science is not just an indulgence for the curious, but is vital to British life, culture and economic well-being.

Science contributes more to Britain's GDP than the financial services sector. It also seeds future economic benefit. Science-based healthcare has made all of our lives immeasurably better.

And yet science does not really figure on political agendas; it is an add-on, at best. The Conservative shadow science minister has already said science funding will almost certainly be cut under a Tory government. Labour is promising more, but funding for science has actually flatlined under Labour, and is lower than it was in 1986, when Margaret Thatcher was Prime Minister.

It's not just about science and scientists. Science feeds into most aspects of modern life -- this is about what kinds of qualification we want our MPs to have. Do we want politics and economics graduates making the decisions? Or do we want MPs who are qualified to deal with scientific and technological questions, and able to analyse a problem using a skillset that has proved the most powerful tool we have: rational, scientifically-based thinking?

I will stand for Parliament in order to get people across the country talking about what they want from their MP. Hopefully that will cause them to ask difficult questions of all their candidates, such as whether their children will be able to work in science in Britain, or whether they will have to go abroad to the countries who are currently increasing their science funding: France, Germany, China and the US, for example.

Why Bosworth-Hinckley?

The sitting MP, David Tredinnick is symptomatic of the problem facing the future of Britain. Not just because he was involved in cash-for-questions and in the expenses scandal, but because he is exactly the kind of MP who undermines science. Tredinnick’s expenses included a claim for astrology software. Do we want MPs to be making decisions about the future of our country based on where Saturn happens to be in the sky on the night before a vote in the House of Commons? Tredinnick has also tabled an “Early Day Motion” suggesting that the House of Commons Select Committtee’s report into homeopathy, which recommended that the NHS no longer fund homeopathic treatments, was poorly researched and should not be taken seriously. He is a champion of pseudo-science and a hindrance to rational governance.

If we are to secure the future of science and engineering research, and thus secure the future of Britain’s economy, we need to make sure that our MPs will not ignore and undermine the scientific traditions on which this country is built.

Getting Tredinnick out of office will be a good start. Hopefully we can populate the House of Commons with people who understand what really makes the world go round – literally and metaphorically. We need a scientific government for this scientific age.

I write regularly for New Scientist and the New Statesman, and hope to highlight all these issues in various blogs, magazines and newspapers during the campaign.

But in order to get this off the ground, I need ten people who are registered to vote in the constituency. You don’t have to vote for me, but I’d be grateful for the chance to get on the ballot paper!

If you would be willing to do this, please let me know by email (mb@michaelbrooks.org) or Twitter (@DrMichaelBrooks). If you want to know more about me, please visit www.michaelbrooks.org

Thanks very much for your time, and I look forward to hearing from you.

With best wishes,

Michael Brooks

The CNHC won't be publishing my complaints

Following my complaints to the CNHC about 14 reflexologists claiming to treat specific diseases without any credible evidence, you may have noticed that nothing has yet appeared on the CNHC’s decisions page.

I contacted Maggie Dunn about this matter. It appears that because my complaints were dealt with before it got through to the conduct and competence committee, they do not intend to publish the details on the web site, nor do they intend on ever naming the offending practitioners.

I do not believe that they intend to go any further than this press release published in December 2009 congratulating themselves on a job well done.

With still no clarification from the CNHC on what practitioners are allowed to claim, it seems likely that there are many more CNHC members continuing to do exactly the same with no worry about regulation.

Maybe it’s time to submit a few more complaints.

Boots avoid admitting there's nothing in it. 10:23

If you thought I'm too old for this sort of childish moron-baiting, I'm afraid you're sorely mistaken. This month I've been emailing Boots to ask how much Arnica is in one of their Arnica 30C remedies. Obviously I know the answer - there is none. Boots also know the answer.

It's quite amusing however, to see them trying to avoid giving me this answer. The email trail follows.

10:23.

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8 January 2010 21:03

Hi,

I'm used to seeing the quantity of ingredients listed in mg rather that as "6C" or "30C" as your homeopathic remedies are labelled.

Can you clarify for me how many mg of Arnica is in one of your "Arnica 30C" tablets? I tried to work it out, but I think I got confused at some point.

Thanks,

Simon

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11 January 2010 17:39

Dear Simon

Thank you for taking the time to email me regarding Boots Arnica 30c (item code 37-71-814) with regard to converting the content of Arnica into milligrams.

I am afraid, however, that it is not possible to convert "centesimal" (c) dilutions of Homoeopathic remedies into milligrams (mg) or micrograms (mcg).

During the manufacturing of Homoeopathic remedies the amount of Arnica is not quantified in milligrams or micrograms. Instead one drop of Arnica (or other Homoeopathic ingredient) is added to ninety-nine drops of diluent (carrier) to produce a 1 centesimal (1c) potency, which is then further diluted to produce a 6c or 30c product.

I hope that this information is of use to you.

Regards

Paul Williams MRPharmS
Medical Information (Pharmacist) Officer

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11 January 2010 18:17

Hi,

Sorry, I'm confused by this. Surely there is a specific amount of Arnica in the pills which can be measured in mg?

If, as you suggest, that a 1C remedy is 1% Arnica then surely if it was a 100mg pill, then this would be 1mg Arnica. Why isn't this correct?

Simon

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14 January 2010 13:27

Dear Simon

Thank you for your second e-mail regarding Boots Arnica 30c (item code 37-71-814).

Unfortunately, the amount of Arnica (or other Homoeopathic ingredient) in the drop that is then subsequently diluted with 99 drops of diluent (carrier) is not quantified in milligrams (mg) or micrograms (mcg).

Thus, although it is true to say that a 1 centesimal (1c) Homoeopathic remedy contains 1 part of Arnica, as the amount of Arnica is not initially quantified then it is not possible to convert this into milligrams (mg) or micrograms (mcg).

Therefore, with regard to Homoeopathic remedies we are not able to state the quantity of Arnica in milligrams (mg) or micrograms (mcg) for the reason outlined above.

The labelling of our products is in accordance with guidelines on the labelling of Homoeopathic remedies, which are derived from The Medicines and Healthcare Products Regulatory Agency (known as the MHRA), which is the UK medicines regulator. These guidelines state that the scientific name of the "stock" (i.e. Arnica) and centesimal dilution should be declared on the labelling.

I hope that this further information is of use to you.

Kind Regards

Paul Williams MRPharmS
Medical Information (Pharmacist) Officer
Medical Services

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14 January 2010 15:39

Dear Paul,

Thank you for your reply, and I understand that without knowing the mass of the original drop of Arnica it would be impossible to determine the subsequent mass of Arnica in the final product. However, it should easily be possible to determine the percentage of Arnica in the final 30C remedy.

Am I correct that a 1C remedy is 1% active ingredient? That it is 99% water and 1% Arnica?

What is the percentage of Arnica in the final 30C product?

I've been trying to work this out myself, but I think I've gone wrong somewhere. This will allow me to make an approximate estimate of the number of mg of Arnica.

Many thanks for your help,

Simon

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18 January 2010 16:29

Dear Simon

Thank you for you further e-mail regarding Boots Arnica 30c (item code 37-71-814).

I can confirm that a 1c Homoeopathic remedy comprises of 1% of the Homoeopathic ingredient i.e. Arnica and 99% of the diluent (carrier).

I can also confirm that to produce a 2c Homoeopathic remedy 1 drop of the 1c Homoeopathic dilution is then further diluted with 99 drops of diluent (carrier). This would equate to 0.01% of the Homoeopathic ingredient i.e. Arnica.

To produce a 3c Homoeopathic remedy this method of dilution is repeated with one drop of the 2c dilution and so on in order to produce a 30c Homoeopathic remedy.

The labelling of our products is in accordance with guidelines on the labelling of Homoeopathic remedies, which are derived from The Medicines and Healthcare Products Regulatory Agency (known as the MHRA), which is the UK medicines regulator. These guidelines state that the scientific name of the "stock" (i.e. Arnica) and centesimal dilution should be declared on the labelling.

I hope that this information is of use to you and is sufficient to allow you to calculate the percentage of Arnica.

If you require further support in understanding Homoeopathic remedies then you may wish to contact the supplier for this product, Nelsons, via enquiries@nelsons.net.

Regards


Paul Williams MRPharmS
Medical Information (Pharmacist) Officer

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18 January 2010 18:02

Hi Paul,

Thanks for your reply, however I'm still having problems with my calculation. While the figures seem to make sense from a mathematical point of view, the percentage of Arnica seems to reduce fairly rapidly to seemingly absurd quantities.

As you said in your email, these products are licensed by the MHRA and of course they are sold by Boots, so I've no doubt as to their effectiveness.

So the only logical conclusion I can draw is that I've made a mess of the mathematics.

Can you confirm the answer you get for a 30C remedy?

Many thanks,

Simon

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22 January 2010 15:37

Dear Simon

Thank you for your further e-mail regarding Boots Arnica 30 c (item code 37-71-814) with regard to calculating the percentage of Arnica.

Whilst the information about the dilutions of Homoeopathic remedies is freely available from validated reference sources, the actual percentage in a 30 c Homoeopathic remedy is not stated and, therefore, I am afraid I am unable to provide this information.

At Boots we take our responsibilities as the leading Pharmacy-led Health & Beauty retailer in the UK very seriously and as part of this we pride ourselves on being able to offer all of our customers a choice of products that support them in their day-to-day lives. We know that many people believe in the benefits of complementary medicines and we aim to offer the products we know our customers want.

I can confirm that Boots Arnica 30 c are a licensed Homoeopathic product without approved therapeutic indications. The pack is labelled in accordance with the requirements placed upon the Marketing Authorisation holder, Nelsons, by the Medicines and Healthcare Products Regulatory Agency. If you would like to contact the Marketing Authorisation holder to discuss the formulation of this product and the manufacturing process in more detail they are contactable at enquiries@nelsons.net.

Our Pharmacists are trained Healthcare Professionals and are on hand to offer advice on the safe use of complementary medicines. The Royal Pharmaceutical Society of Great Britain issues guidance to Pharmacists on the correct selling of Homoeopathy, which our Pharmacists adhere to.

I would like to conclude by confirming that Boots support the call for scientific research and evidence gathering on the efficacy of Homoeopathic medicines as this would help our patients and customers make better informed choices about using Homoeopathic medicines.

I hope that this information is of use to you.

Regards
Paul Williams MRPharmS
Medical Information (Pharmacist) Officer
Medical Services

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23 January 2010 08:52

Hi Paul,

I get the impression that you are trying hard to avoid answering my question.

In an earlier email you say that it is possible to calculate the percentage of Arnica in a 1C and 2C remedy but then without reason you say you cannot do it for a 30C remedy. Yet in a previous email you state that the information you gave me should be sufficient for the calculation.

The problems I was having when calculating the amount of Arnica is that every time I did the maths, the result came out that there was no Arnica remaining in the 30C remedy.

This is a perfectly simple and clear question: is there any Arnica remaining in an Arnica 30C remedy?

Many thanks,

Simon

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As yet - no response.