MHRA Review: Homeopathy
As Zeno has pointed out, the MHRA are conducting a review of UK medicines legislation. As part of this, the MHRA are looking at aspects of the regulation of homeopathy.
I thought I’d write to the MHRA and give them my two penn’orth. I decided to focus on the labelling of magic beans.
Dilution
Homeopathic products, whatever scheme they are regulated under, should be labelled in such a way that consumers are not misled as to their nature. Products diluted above 24X or 12C are unlikely to contain a single molecule of the alleged active ingredient. If a product is labelled as “Arnica 30C”, it implies that the product actually contains some arnica. This is misleading to potential consumers.
Perhaps all homeopathic products at dilutions higher than 12C should be labelled “contains no active ingredient” and those at 12C and below should be labelled “may contain no active ingredient”.
Evidence of Efficacy
Products that come under the National Rules Scheme should require a higher standard of evidence of efficacy than at present [see below for more]. These products should be labelled to indicate the possibility that no active ingredient is present as per my above comments.
Products that come under the Simplified Scheme should be clearly labelled to indicate that no evidence of efficacy has been required or provided for the licensing of the product. I think that it would be reasonable to require a statement along the lines of “There is no good evidence that this product is effective“.
Competing interests
I write a blog called Stuff And Nonsense, in which I am sometimes critical of pseudoscientific nonsense masquerading as medicine.
More
In the post I mention in the introduction, Zeno links to this PDF. This is apparently the only homeopathic product in the National Rules Scheme category. Here’s something from the lay summary:
Arnicare Arnica 30c pillules is a homeopathic medicinal product used within the homeopathic tradition for the symptomatic relief of sprains, muscular aches and bruising and swelling after contusions. The pillules’ active ingredient is Arnica montana 30c. These indications are based on:
– Published scientific literature
– Homeopathic provings (a homeopathic proving is the method by which the profile of a homeopathic remedy is determined and can be used to establish its potential applications.)No new or unexpected safety concerns arose from this application and it was, therefore, decided that a homeopathic marketing authorisation could be granted.
The italics are mine. I would question the wisdom of considering homeopathic provings in the course of making a decision on the regulation of a homeopathic product.
I’m not sure what published scientific literature the MHRA reviewed in the course of making their decision, but I do hope that they were aware of this systematic review.
Links
Andy Lewis of the Quackometer blog has suggested this label: JPG.
I have referred throughout to “homeopathic products” rather than “remedies” or “medicine”. This is deliberate.
I’ve previously written A Beginners Guide To Homeopathy and a post on Cochrane Reviews Of Homeopathy. (Note for connoisseurs of the homeopathy advocate: the comment threads on both posts feature Oliver Dowding.)
Stuff And Nonsense 
Kausik Datta said,
February 5, 2011 at 6:11 am
A bit more to add to the dilution business: As I pointed out elsewhere, in homeopathy, dilutions of 1:10 are designated by the Roman numeral X (1X = 1:10, 3X = 1:1,000, 6X = 1:1,000,000). This is the designation popular in amongst Indian homeopaths.
In course of a conversation with a friend of mine it emerged that my molecular biologist friend was apparently under the impression that the ‘X’ designations used for homeopathic dilutions in India (such as 6X, 30X, 200X) referred to concentrations rather than dilutions!
Now, I realize that this may easily be a common mis-perception for those of us that work at the bench, because there we often do refer to concentrations of stock solutions in terms of ‘X’ (higher X = more concentrated; e.g. 2X phosphate buffer, with double quantities of all components in a given volume; 5X NaCl, a five times concentrated saline solution; 6X Gel-loading buffer, and so forth).
What I don’t know is whether homeopaths, especially Indian homeopaths, knowing this, deliberately play up the X designations for their dilutions. As the post author has pointed out, any dilution at 24X and beyond will not likely have any molecule of the starting active principle left in the solution. Yet, many of the homeopathic nostrums are happily sold at 30X and 200X dilutions.
Admin Edit: Duplicate comment removed at request of author