There are times when I wonder: How on earth did I miss this?

Usually, I pride myself on being pretty timely in my blogging, writing about new stuff that’s fairly fresh. Sure, barring a fortuitous confluence of events and timing, I’m rarely the “firstest with the mostest” on a topic. I do, after all, have a demanding day job and generally don’t mix blogging with my work if I can avoid it (although cranks seem to want to make that impossible with their latest tactic of infiltrating my cancer center’s Facebook page to post rants about how evil I am). There’s no way I can compete with bloggers who have all day to surf the ‘net and blog about things. What I lack in speed and timeliness, I like to think I make up for in depth.

That issue aside, there are times when I find something that I really wish I had blogged about when it first came out and decide that, even though the item’s old enough that normally I’d just shrug, castigate myself for missing my chance, and move on to something else. This time around, even though the article I’m about to apply some Insolence to is over two weeks old. It helps that it was written by homeopaths. It also helps that it is the homeopaths’ response to the FTC’s recent enforcement statement regarding over=the-counter (OTC) homeopathic drugs, which concluded that homeopathy is without a basis in science and that homeopathic remedies can’t advertise that they are effective for anything. The FTC’s statement was, in my view, a rare win for science when it comes to regulating supplements and especially homeopathic remedies. Indeed, even though it held hearings in 2015 about how to regulate homeopathic remedies, the FDA has yet to issue a policy.

So the American Institute of Homeopathy (I didn’t know there even was such a thing!) is unhappy with the FTC policy statement on homeopathy. That’s not surprising. The FTC basically just called homeopathy out as the load of pseudoscientific, vitalistic, mystical nonsense that it is. Of course homeopaths would be upset. it’s also equally predictable that when they make their displeasure known through a public statement it will be comedy gold.

Check it out:

The American Institute of Homeopathy applauds the Federal Trade Commission’s (FTC) goal of protecting the American public from false advertising claims, but in a recent circumstance we believe the FTC has overstepped its jurisdictional bounds and promulgated false information in what appears to be a bid to restrict health care choices available to the American public.

This first paragraph made me laugh out loud, because what is anything that homeopaths say to promote homeopathy but false advertising claims? After all, many homeopathic remedies, as I’ve described so many times before, are so highly diluted that it’s unlike there is even a single molecule of original remedy in them. True some are not as highly diluted, but even those tend to be so highly diluted that there is not a therapeutic dose of anything in them and, even when there is, it tends to be something that can cause harm, like belladonna in homeopathic teething remedies, which recently led to an FDA warning.

But what are the AIH’s specific objections? Well, the AIH registers its “strong concern” about several of the FTC’s findings, for example:

1. “Homeopathy… is based on the view that disease symptoms can be treated by minute doses of substances that produce similar symptoms…”

Homeopathy is not based on a “view” or an opinion. It is based on reliable, reproducible, clinically acquired, empiric evidence gathered through two centuries of corroborated data, assisted by thousands of practitioners worldwide, demonstrating the actions of different medicinal substances in living systems, aka: the science of homeopathy. In fact, the homeopathic scientific community were pioneers of the modern scientific method including the widespread adoption of blinded and placebo controlled studies in 1885, decades before conventional medicine.

Homeopathy is not based on a theory or on conjecture, but on principles that have been confirmed by long-studied clinical data, meticulously gathered and analyzed over many years.

I’m laughing harder here. “Reliable, reproducible, clinically acquired, empiric evidence” from two centuries? Homeopaths were “pioneers” of the modern scientific method? I note that what they are referring to at this point is an article from 1885 on homeopathic provings. Trust me (or don’t and go see for yourselves). Homeopathic provings are about as far from actual clinical trials as you can imagine.

That’s leaving aside the frequent argument I see from homeopaths that true randomized, double-blind studies of homeopathic remedies are not possible. I’ve discussed provings, before; e.g., a proving of homeopathic plutonium and homeopathic antimatter. Remember, a “proving” in homeopathy is when normal, healthy people take the substance to be made into a homeopathic remedy and report how they feel, complete with dreams and anything else that goes through their mind. It’s sort of systematic in that subjects are told to write down everything they feel, but what they feel is frequently not particularly helpful.

No, homeopathy is based on vitalism and 225 year old ideas of how the body works. Discoveries in science as old as 50 years after Samuel Hahnemann pulled homeopathy out of his nether regions was more than enough to show that homeopathy is pseudoscience.

The next objection by homeopaths seems to rely, more than anything else, on pedantry:

2. “Many homeopathic products are diluted to such an extent that they no longer contain detectable levels of the initial substance.”

While the dilution and succussion process of formulating homeopathic medicines does reduce the concentration (and the toxicity) of the original substances, detectable amounts of these materials remain quantifiable in the form of nanoparticles dispersed throughout.4 Multiple independent laboratories, worldwide have confirmed that these nanoparticles persist,5 and that they are biologically active.6 Many other homeopathic products (particularly those sold OTC and described as “low potency”) have dilute amounts of the original substance that remain chemically detectable by straightforward titration.

No, nanoparticles are a homeopathic fantasy. They’re a figment of the imaginations of homeopaths who are bad scientists (but I repeat myself). Also, remember that the FTC said “many.” That’s completely true. Many homeopathic remedies are diluted to such an extent that we shouldn’t expect a single molecule of original compound to remain. The whole “nanoparticle” trope is nothing more than a tortured rationale to try to “explain” that.

Next up:

3. “…homeopathic product claims are not based on modern scientific methods…”

This statement is false and misleading. The active ingredients within most OTC homeopathic products have hundreds or thousands of case reports from physicians who have used these medicines. These reports of direct clinical experiences establish a collective, real-world dataset that demonstrates which conditions have been observed to respond to treatment. Such historical data is similar to the types of information used to demonstrate effectiveness for many conventional OTC medicines on the market today.

No, no, no, no, no. OTC medicines have clinical trial evidence sufficient for FDA approval backing them up. What we have here is nothing more than an appeal to anecdotal evidence above clinical trials. In other words, same as it ever was.

Same as this, which made me laugh more uproariously than any entry. The unintentional hilarity in this next entry is too much:

4. “…the case for efficacy is based solely on traditional homeopathic theories…”

This statement is false. Neither homeopathy nor homeopathic efficacy is based on any theories. Efficacy for various homeopathic medicines has been established by scientifically reproducible clinical empiric research evidence and cured patient cases followed over many years. Homeopathy is an evidence-based medical subspecialty rooted in patient care.

I’m sorry, but when I read that “neither homeopathy nor homeopathic efficacy is based on any theories,” I couldn’t help but laugh at the scientific ignorance embodied in that comment. On the one hand, I agree that homeopathy is not based on any theories. After all, in science, “theory” is a word reserved to describe well-substantiated explanations of some aspect of the natural world acquired through the scientific method and repeatedly tested and confirmed through bservations and experiments. As Wikipedia puts it, scientific theories are the most reliable, rigorous, and comprehensive form of scientific knowledge. So, yes, in that sense, homeopathy is not based on any theories. That’s what made me laugh. Homeopathy is, rather, based on what I like to call wild-assed 220 year old nonsense.

#4 was so funny that I almost stopped right there to end this post. Fortunately for you (or maybe not), having been at this for so long I’m made of much sterner stuff. For instance, AIH claims that there are “hundreds of state-of-the-art double-blinded, randomized, placebo-controlled studies, many in peer-reviewed journals, demonstrate the superior efficacy of homeopathic medicines in a wide range of conditions.” anyone who’s studied homeopathy much knows that these studies are invariably poorly designed, too small, lacking in proper controls, or have any number of flaws that invalidate them. Of course, there are also some well-designed studies that turned out slightly positive, but it’s clear from the preponderance of evidence that these were due to random chance. As I point out over and over again, there’s a rule of studies of homeopathy (and acupuncture, for that matter). The larger and more rigorous the studies, the more often they are completely negative, while the smaller and less rigorous trials tend to be positive. In other words, the results are consistent with no effect due to homeopathy.

Next up:

6. “…marketing claims that such homeopathic products have a therapeutic effect lack a reasonable basis and are likely misleading…”

The conclusion of whether a product has a “reasonable basis” is entirely irrelevant if that product has demonstrable clinical effectiveness. The important question, when it comes to homeopathy, is whether it is effective in clinical settings, not whether it has a “reasonable basis” for how it works. The mechanism by which homeopathy works differs from conventional medicines, but this fact does not make these products “misleading”.

Several recent class-action lawsuits brought against homeopathic manufacturers confirm that marketing practices were neither deceptive nor misleading.25

Because the legal system is the best way to judge questions of science, of course. Wrong.

I mentioned this objection by AIH because it goes to the heart of what science-based medicine is. Evidence-based medicine emphasizes clinical trial results, over everything. Science-based medicine considers the prior probability of an intervention based on basic science. In other words, from a basic science standpoint, homeopathy is about as close to impossible as it is to imagine. I never say that it is actually impossible, but for homeopathy to work multiple laws of chemistry and physics would have to be not just wrong, but spectacularly wrong. So, basically, the prior probability that homeopathic remedies work for pretty much any medical condition is as close to zero as can be without actually being zero. (Some would argue that it is zero, but I can’t quite go there.)

I can, however, make fun of the AIH’s response to the FTC’s quite justifiable conclusion that homeopathy is not backed by modern science (mainly, because it isn’t):

Homeopathy, as a system of medicine, does not fall under the purview of the FTC. Therefore, the FTC has been reckless in expressing an opinion of this magnitude. In this situation, the FTC’s comments can only be construed as being prejudicially biased and intentionally discriminatory against homeopathy. Such statements cause unwarranted harm to public trust and damage to a respected traditional system of medicine in the United States.

Ah, yes. To homeopaths “criticism” = “bias.”

Wrong. There’s plenty of reason to dismiss homeopathy as pure pseudoscience that do not involve bias. None of this stops the AIH from going way, way off the deep end:

The American Institute of Homeopathy strongly objects to the FTC’s characterization of the entire field of homeopathic medicine as being without scientific evidence of efficacy. These comments are unqualified and wholly lacking in merit. The release of this Enforcement Policy Statement serves only to align the FTC with several recently released scientifically fraudulent reports by a variety of pseudoscientists and lowers the credibility of this valued consumer protection agency.

This type of misinformation should be embarrassing to a government organization striving to be nonpartisan and objective. The FTC owes an apology to the American Institute of Homeopathy as well as the many consumer groups that look toward this agency for fair and accurate information.

As I said, comedy gold. To see homeopaths calling real scientists “pseudoscientists” is just too delicious to ignore, particularly coupled with this self-righteous call for an apology—to the AIH itself! I also like the bit about being “nonpartisan,” as though determining that homeopathy is pure pseudoscience has anything to do with partisan politics. (On second thought, I worry that it will in the future.)

Then there’s the issue of “fraudulent” reports. I presume that the AIH is referring to the Swiss report, the Australian report, and the Science and Technology Select Committee report from the UK Parliament from a few years back, all of which examined the scientific and clinical evidence evidence and concluded that homeopathy is lacking in plausibility and evidence that it does anything above and beyond placebo. These are, of course correct conclusions, given that many homeopathic remedies are basically water.

Ya gotta love homeopaths. They’re deluded quacks, and their overwrought language, coupled with the fact that this statement was written by homeopaths, perfectly encapsulates the nonsensical thinking behind homeopathy.

Comments

  1. #1 UK Homepathy Regulation
    United Kingdom
    December 16, 2016

    The situation in the EU is different as indications for homeopathic medicines are more highly restricted. Varies by member state which homeopathic medicines carry no indications and which are permitted some. In the latter case only indications for minor self-limiting conditions are permitted and labeling has to clearly state the homeopathic nature of the medicine. Yes, the EU does consider homeopathic remedies medicines.

    In the UK, the Advertsing Standards Authority (ASA) has clamped down on the claims made for homeopathy and homeopathic medicines (and CAM more generally) over a period of time. It is an ongoing process. And homeopaths are known to squeal about how unfair it is to be subject to the same restrictions on marketing as every other industry in the UK. Some of them want to mount a legal challenge to the authority of the ASA. http://www.quackometer.net/blog/2016/11/homeopaths_legal_advice_asa.html

    Whether the AHI would mount a legal challenge to the FTC’s enforcement policy is moot. As homeopathy in the US is a disorganised rabble it seems unlikely that a challenge could be organised and funded.

  2. #2 BadlyShavedMonkey
    December 16, 2016

    Just as their remedies are diluted exponentially so is their pomposity reciprocally inflated. There’s obviously another of their deep homeopathic ‘Laws’ at work here.

  3. #3 Zach
    United States
    December 16, 2016

    Hahahaha.

    On a serious note, I am really tired of…screw it let’s say Big Homeopathy and other industries talking about consumer choice. Free market economics is all about choice, but a student in econ 101 would tell you that free market econ is also based on everyone having access to the same information, and that said information is legitimate. Deception sharply opposes capitalism. Thus, when someone is lying and uses “consumer choice” and libertarian values to try to push an agenda, they are just piling lies on top of eachother. Homeopaths claim they sell products with value, there is no value, ergo it is just stealing.

  4. #4 Toast
    USA
    December 16, 2016

    They don’t seem to fact check the studies they cited. If I take the passage below from the website it seems they state many RTCs including one for cancer but when I read the abstract it was in vitro. See passage from web page below followed by the citation for cancer

    ” Hundreds of state-of-the-art double-blinded, randomized, placebo-controlled studies, many in peer-reviewed journals, demonstrate the superior efficacy of homeopathic medicines in a wide range of conditions, including asthma,7 depression and anxiety,8 chronic illness,9 allergic rhinitis,10 hypertension,11 headaches/migraines,12 sepsis,13 mild traumatic brain injury,14 otitis media,15 cancer,16 and many other conditions”

    Cancer citation: “Frenkel M, Mishra BM, Sen S, et al. Cytotoxic effects of ultra-diluted remedies on breast cancer cells. Int J Onc 2010; 36:395-403.

    Am I missing something? Is this the BEST they have for breast cancer? This is either incredibility sloppy or they don’t understand what is an RTC

  5. #5 BadlyShavedMonkey
    December 16, 2016

    Homeopaths’ presentation of their own evidence-base does seem to show a cavalier disregard, perhaps ‘post-truth’, attitude to the documented facts, e.g. http://edzardernst.com/2014/12/homeopaty-proof-of-concept-or-proof-of-misconduct/#comment-84324

    It does seem to be a common pattern for them to Gish-gallop a list of citations seemingly without paying attention to their content.

  6. #6 Richard
    December 16, 2016

    In fact, the homeopathic scientific community were pioneers of the modern scientific method including the widespread adoption of blinded and placebo controlled studies in 1885, decades before conventional medicine.

    Oh, yes! In fact, homeopathy was the subject of what well may be the very first rigorous double-blinded placebo-controlled study, the Nuremberg salt test of 1835.
    And what did this rather well-designed test (especially for that day and age) prove? Indeed, that homeopathic proving was nonsense.
    Also see this SBM article

    And if homeopathic ‘remedies’ have proven efficacy for specific conditions, then why aren’t suppliers of OTC homeopathic remedies not allowed to say what their ‘remedies’ are for, at least here in the Netherlands? Could that be because the label can only mention specific ailments if it is proven that the ‘remedy’ actually helps against these ailments? And that not even a single manufacturer/supplier of homeopathic ‘remedies’ has delivered such proof?

  7. #7 Richard
    December 16, 2016

    And oh, when referring to legal cases, I’d say that this one is pretty compelling. Homeopath Frances Sheffield had to cough up well over $120,000 for misleading claims about both the pertussis vaccine and the homeopathic quackery she offered in lieu of those vaccines. Why didn’t she simply deliver the proof for her claims of efficacy? It would have saved her a lot of trouble.
    (yes, the skeptics had an absolute field day over this).

  8. #8 rs
    December 16, 2016

    “So the American Institute of Homeopathy (I didn’t know there even was such a thing!)”

    That’s because it’s a 10C solution of a functioning organization. Even undiluted it was likely minimally effective, and now they are diluting their “facts”. One more C and it might be safe to drink.

  9. #9 Dorit Reiss
    December 16, 2016

    As to FTC’S jurisdiction, it does sometimes require it to assess areas that require expertise. It’s part of their job. That’s where consulting legitimate, established experts helps.

  10. #10 Panacea
    December 16, 2016

    @ Richard #7: The obvious conclusion is she didn’t have any evidence. But even if she did have “some” to offer, there are legal standard for submitting scientific evidence in court.

    She would have to establish her bona fides as a researcher, and her research would have to conform to accepted scientific methods. Even though the Homeopathic Pharmacopeia, when the Food, Drug, and Cosmetic Act of 1938 was implemented, allows those remedies to continue to be sold and new preparations to be added, that is not the same as providing scientific evidence of efficacy, and the act requires that proof to add preparations. Without that proof, she can’t present herself as an expert and her evidence is worthless.

  11. #11 sadmar
    December 16, 2016

    I don’t think this was “written by homeopaths”. but by lobbyist/lawyers* for the homeopathy biz, tuned to the politics of quashing the FTC recommendations, and have done quite a professional job toward that end. It’s not created to establish scientific validity of homeopathy (Hah!). It’s designed to present defenses against the FTC recommendations that might give the regulators at FDA some pause about implementing them, and/or an excuse not to.

    Since this is government, not science, the burden of proof is on the FTC to establish that the advertising claims are clearly over-the-line. The AIH doesn’t have to prove homeopathy works, it just has to argue ‘you haven’t proven we’re wrong’ well enough that public officials will credit it enough to withhold disrupting the status quo.

    In short, it’s a low bar. Even if everyone involved – including both the FDA and the AIH – would consider “it is effective in clinical settings” a form of BS, they still might judge surmounting that defense a bridge too far for justifying action that will cost precious resources of time and money, might cause enough trouble to outweigh any good it might do, could be overturned on appeal to the courts, etc. etc.

    When Orac first wrote about the FTC statement, I suggested it was an error for the FTC to argue ‘the claims are based only on theories from the 1700s that have been flatly rejected by modern medical science.’ as that is just false, the basis for the claims having now expanded to ‘water memory’ metaphors rooted in “nanomedicine”, and Quantum!. I predicted the response to the FTC with go nano, since that offers not-totally-implausible-to-the-layperson explanations of mechansim that can’t be firmly disproven with the current state of physics. To this, several comments replied that ‘water memory’ was indeed a precise and testable thesis offered by Benveniste that has indeed been thoroughly discredited.

    Well, the AIH did go nano, though they didn’t use the phrase ‘water memory’ and cite these folks instead of Benvenistes:

    5. Upadhyay RP, Nayak C: Homeopathy emerging as nanomedicine. International Journal of High Dilution Research 2011, 10(37):299–310.
    6. Bell IR, Schwartz GE, Boyer NN, et al., Advances in integrative nanomedicine for improving infectious disease treatment in public health. Euro J Intregr Med 2012; 5(2): 126-140.

    ______
    Like, maybe, the attorneys who wrote this recently.

  12. #12 Lindsay Gough
    New Zealand
    December 16, 2016

    Being a lay person, although a well-read one, my objection to Homeopathy has always been this: Every drop of water on this planet has at some point likely to have passed through some animal’s digestive system over the past 4 billion odd years that life in some form has existed.

    How does it remember what substances it remembers? And not say that of the various waste products produced by said animal.

  13. #13 croiduire
    Phoenix, AZ
    December 16, 2016

    There is one other explanation for homeopathic success that, in my opinion, keeps consumers coming back, and is the source of the, “But this worked great for my neighbour’s niece” justifications that abound: inactive ingredients that are anything but. I am a case in point; I regularly use homeopathic eyedrops, not for the Schrödinger’s molecules of “active ingredients” that may or may not be present, but because the carrier solution is borate buffered saline, which is isotonic, strong bactericidal, and gentle (https://en.wikipedia.org/wiki/Borate_buffered_saline). That bactericidal effect is probably ramped up by the preservative used, silver sulphate. I have Sjogren’s syndrome, and these drops, which are conveniently packaged and not too expensive, have been an excellent tool to help keep my eyes lubricated and prevent the recurrent eye infections common with Sjogren’s. I am under no delusions as to why they work, but my background is in biology; other consumers might take the homeopathic claims at face value. I would be curious how many other homeopathic drugs are out there that work for reasons wholly unrelated to their specious homeopathic components. That aspect might be worth a bit of FDA attention.

  14. #14 NumberWang
    December 17, 2016

    Ah…but none of these animals have ever been bashed against a padded block ten times while containing the water.

  15. #15 NumberWang
    December 17, 2016

    RSPCA against Homeopaths since 1824.

  16. #16 Richard
    December 17, 2016

    How does it remember what substances it remembers? And not say that of the various waste products produced by said animal.

    That is just one of the many, many glaring inconsistencies of the ‘principles’ of homeopathy. And even if homeopaths say that they start out with “pristine water” (which was somehow treated so as to lose the imprint of previous substances), even the purest water still contains lots of impurities, among which traces of lead, arsenic, and other substances which naturally leach in from the glass container. These trace amounts are completely harmless by any regular science, but are still ‘highly concentrated’ (<6C) according to homeopathy. Yet in a magical way, all these impurities are not 'potentized' at all.
    Not that this would actually matter even if homeopathic principles were true, because when 'potentized', even something as simple and ubiquitous as table salt is associated with literally many hundreds of ‘symptoms’.
    It is truly a miracle that the aforementioned Nuremberg salt test of 1835 came up negative. All those healthy people having taken the ‘remedy’ should have been reporting lots and lots of those symptoms, yet almost none of them did.
    In short: homeopathy is the fine art of delusion by dilution.

  17. #17 Orac
    December 17, 2016

    When Orac first wrote about the FTC statement, I suggested it was an error for the FTC to argue ‘the claims are based only on theories from the 1700s that have been flatly rejected by modern medical science.’ as that is just false, the basis for the claims having now expanded to ‘water memory’ metaphors rooted in “nanomedicine”, and Quantum!. I predicted the response to the FTC with go nano, since that offers not-totally-implausible-to-the-layperson explanations of mechansim that can’t be firmly disproven with the current state of physics. To this, several comments replied that ‘water memory’ was indeed a precise and testable thesis offered by Benveniste that has indeed been thoroughly discredited.

    Not sure I agree on this, at least not entirely. For one thing, all those new ideas are post-hoc rationalizations added after modern science showed that the original ideas upon which Hahnemann based homeopathy are bullshit and not supported by science. They hardly count as “hypotheses,” much less theories, and their sole purpose is to try to justify Hahnemann’s ideas in light of Avogadro’s number. Homeopathy, at its heart, is still based on Hahnemann’s two original laws: The Law of Similars and the Law of Infinitesimals. All the rest is window dressing and handwaving to hide the fact that modern science has shown that these two laws have no basis in reality.

  18. #18 sadmar
    December 17, 2016

    Just to be clear, I completely agree that whatever ‘nano’- theory homeopathy advocates may offer up is just window-dressing and handwaving. I’d even go farther, and say that at this point the ‘laws’ of Similars and Infinitesimals are just window-dressing and handwaving. However much Hahnemann and his followers in the early 19th Century may have believed them, with what science knows now, it’s hard to imagine they’re but posturing, be that consciously or unconsciously.

    My comment that it’s false to say ‘the claims are based only on theories from the 1700s’ is a very literal one based on the noun being ‘claims’. I.e. homeopaths are now, in fact, claiming contemporary physics can either explain how homeoppathy ‘works’, or at least provides grounds to think the Avogadro problem is not definitive proof it can’t work.

    My aim was to consider the FTC’s strategy, and in suggesting an “error’ in that, I was thinking about how the process of argument, it’s order in time, affects how people are likely to judge things. I was worried about this scenario:
    1. The FTC explains how Avogadro’s number seems to scotch any plausibility for higher homeopathic dilutions.
    2. The regulators will understand the science of that, and consider it persuasive.
    3. The homeopaths respond that physics is now exploring all this quantum stuff at a much much smaller level than molecules, and argue that homeopathy can indeed be explained at this ‘nano-‘ level.
    4. This pulls the rug out from under the regulators’ perception that they had a clear case of “no, not possible.”
    5. They’re then faced with a very complicated quagmire of advanced science discourse on whether or not this quantum nano stuff does or might provide an explanation for some therapeutic effect.
    6. They’re also suspicious of the FTC for not having addressed that question.
    7. So they just go ‘OK. Too murky. Moving on. What’s the next point.”

    In short, and I guess I haven’t been clear about this, I’m just saying the FTC would have had a much stronger case if they had anticipated the possible defenses, and addressed them in the policy recommendation statement. Here’s the FTC text:

    For the vast majority of OTC homeopathic drugs, the case for efficacy is based solely on traditional homeopathic theories and there are no valid studies using current scientific methods showing the product’s efficacy…
    The promotion of an OTC homeopathic product for an indication that is not substantiated by competent and reliable scientific evidence may not be deceptive if that promotion effectively communicates to consumers that: (1) There is no scientific evidence that the product works and (2) the product’s claims are based only on theories of homeopathy from the 1700s that are not accepted by most modern medical experts.

    As we now know, “the case for efficacy” while making a quick nod to the ‘nano’ hangs on “demonstrable clinical effectiveness”:

    The important question, when it comes to homeopathy, is whether it is effective in clinical settings, not whether it has a “reasonable basis” for how it works.

    … which the FTC statement did not address at all. This is really an inexplicable whiff by the FTC, since ‘the argument from provings’ has been a prominent feature of homeopathy claims for a long time, if I’m not mistaken. It’s not like the flacks from Venable LLP just pulled it out of their butts earlier this month, yes?

    While we can guess the FTC’s strategic choices are utterly moot with any Trump-appointee-led FDA, there may still be value in thinking about how to frame arguments about homeopathy to non-scientist political actors for future efforts, maybe in other jurisdictions. To that end, then, I’d imagine a better version of the text above would go something like this:

    The vast majority of OTC homeopathic drugs are without a valid scientific case for efficacy. (1) There is no valid scientific explanation for typical homeopathic dilutions being able to have any therapeutic effect. The traditional homeopathic theories dating from the late 1700s have been since been thoroughly disproven by science. More recent attempts by some homeopathy advocates to seek explanations for a therapeutic effect in homeopathic dilutions on the basis of quantum mechanics and other theories in advanced physics are either fanciful manglings of the science, or, at best, totally unsubstantiated speculation. (2) In the end, the claims for the efficacy of homeopathy rest not on any demonstrable principle of action, but the accumulated record of homeopathic “provings”. The case is, in essence, “we know it works because we tried it”. However, this “evidence” is thoroughly unscientific – subjective, anecdotal and contradictory – and rejected as such by the broader scientific community.

    Furthermore, I’d guess that at least a few homeopathic remedies ‘validated’ by ‘provings’ have been subjected to proper RCTs, and that all of these have failed to find the therapeutic effect claimed by the provings (beyond placebo, of course). So, if you could fairly say. “On the contrary, every homeopathic remedy subjected to a scientifically valid RCT has been proven NOT to have the therapeutic effect attributed to it by the documented homeopathic provings,” I’d put that in there too.

    And if was proposing advertising and labeling regulations, I’d call for any homeopathic product that has failed in a proper controlled trial to disclose that in every promo and on every box.

  19. #19 Narad
    December 17, 2016

    The homeopaths respond that physics is now exploring all this quantum stuff at a much much smaller level than molecules

    Wrong direction, and molecules are a challenge as it is. Nanoparticles are even larger. The quantum and nanoparticle claims of homeopathy boosters are basically separate lines of attempted justification.

  20. #20 Orac
    December 17, 2016

    My aim was to consider the FTC’s strategy, and in suggesting an “error’ in that, I was thinking about how the process of argument, it’s order in time, affects how people are likely to judge things. I was worried about this scenario:
    1. The FTC explains how Avogadro’s number seems to scotch any plausibility for higher homeopathic dilutions.
    2. The regulators will understand the science of that, and consider it persuasive.
    3. The homeopaths respond that physics is now exploring all this quantum stuff at a much much smaller level than molecules, and argue that homeopathy can indeed be explained at this ‘nano-‘ level.
    4. This pulls the rug out from under the regulators’ perception that they had a clear case of “no, not possible.”

    Uh, no. No, it doesn’t. All that quantum and nano stuff is utter bullshit, as any reality-based scientist knows. The regulators know it too. It’s not as though that bullshit wasn’t brought up during all the hearings last year when the FTC was considering its rule changes.

  21. #21 Chris
    December 17, 2016

    Sadmar, the term “nano” has an actual meaning. It is this ratio: 1/100000000 . It typically refers to size, as in “something being a certain nanometers long.”

    If you try to use it for dilution, it would be at some where between 4C (ratio 1/100000000) and 5C (ratio 1/10000000000). As Orac says: it is utter bovine excrement.

  22. #22 doug
    December 17, 2016

    Several years back nanostuff became a fairly frequent “thing” in the popular and semi-popular (e.g. Popular Mechanics, name not withstanding) media. Some of it was real, like nanotubes and truly nano particles of actual utility. It became a bandwagon onto which those who couldn’t carry a tune, much less play an instrument, tried to hop (e.g. the business partner of one of my clients thought we should all get into nano-something-or-other in some manner associated with photovoltaic power – but this was a guy, with a degree in electrical something, who believed in over-unity).

    If some ambitious person were to travel through the macrotoobz of the interweb, gathering data, I suspect the rise of the notion of nanobits in homeopathy could be correlated with the rise to appearance of nanoparticles in the popular media. It would probably also correlate fairly well with the rise to the internet itself and the ridicule of the notion of reminiscent water.

    For the physicists & chemists among us: what is the lowest content of impurity that has ever been quantified for any real substance?
    Even if one were to accept the notion of the starting substance and the water being perfectly pure, unless the dilutions were performed in a class eleventy-seven clean room, you wouldn’t get very far along the “C-series” before the content of the dissolved emanations from the diesel truck outside, the Caesar salad from lunch or the bean burrito from yesterday, or the hapless calf whose skin binds your Bible of Succussion, would exceed the nominal content of Likeness in the Sacred Vessel of Succussion. If you accept that the starting substance isn’t perfectly pure and believe in the law of infinitesimals, then the impurities in the starting substance, being more dilute, must surely have greater effect than the intended starting substance, be the pathway water memory or nanoparticles (Memories of King Harold a free bonus for those with arrow-in-eye issues).

  23. #23 doug
    December 17, 2016

    To quote Nero Wolf: “Pfui!” – botched the closing tag for italics for Bible …

    Bible of Succussion, would exceed the nominal content of Likeness in the Sacred Vessel of Succussion. If you accept that the starting substance isn’t perfectly pure and believe in the law of infinitesimals, then the impurities in the starting substance, being more dilute, must surely have greater effect than the intended starting substance, be the pathway water memory or nanoparticles (Memories of King Harold a free bonus for those with arrow-in-eye issues).

  24. #24 Richard
    December 17, 2016

    @ Narad, #19

    The quantum and nanoparticle claims of homeopathy boosters are basically separate lines of attempted justification.

    It’s really all just a case of pushing back the boundaries of ignorance — from the inside, mind you, increasing the total amount of ignorance in the process by adopting new domains to be ignorant in. It would be rather amusing to watch from the outside if these clowns weren’t poisoning real science in the process.

  25. #25 sadmar
    December 17, 2016

    If the FTC staff know the quantum and nano stuff is BS because it was brought up at the hearings last year, it’s all the more dumb-ass they didn’t address it in their recommendations. Any reality based scientist already knows the every extant “case for efficacy of homeopathic drugs” is BS. So why put anything in the recommendations at all?

    Because, at some point, they have to justify all this as policy to not-scientists who are under political pressures. .

    I mentioned my little narrative scenario was what I had been thinking (past tense) exactly because I realized the folks actually involved here may well have been through this before. This is certainly true of the regulators at FTC who made the recommendations., so I wasn’t thinking about them, but whoever might be sitting in the hotseat at FDA faced with the decision to act on this recommendation or reject it, under all the political pressures, and with an eye on all the possible political consequences.

    And ‘rug-pulling’ still applies, even If these not-scientist decision makers take the nano and the quantum as BS in their own thoughts. To make an official ruling that will hold up, they’re going to have to explain WHY the homeopathy claim is BS, as the FTC does for Infinitesimals in writing the products are “diluted to such an extent that they no longer contain detectable levels of the initial substance.” Thus, with nano and quantum now on the table in addition to whatever Hahnemann said circa 1800, the decision-makers need to explain WHY these new claims are BS – in terms of how nano or quantum work, comparable to “there can’t be anything in there since 30C is beyond Avogodro’s number”. If they can’t explain that, they’ll have a harder time justifying new labeling policies against the attacks they know will come. The expertise in physics required to debunk all the variants of these new claims is likely beyond their ken. And, yes, facing those attacks, they will be PO’ed the FTC statement didn’t prep them on that point, didn’t the sort of support material they’re supposed to use in making policy. And, finally, if they feel too much heat, the ‘quantum and nano’ provide an excuse they can use to make a ‘graceful’ exit.

    So, basically, the FTC folks left the FDA far too exposed by basing the argument against legitimacy “solely” on “no detectable levels, and 200 year old false principles (as if new false principles hadn’t been added in the interim).

    Again, it’s not a question of what would or wouldn’t be credible and persuasive to the specific folks who would make the decisions if the recommendations moved forward. It’s a question of there being no excuse for not considering all the arguments your opponent is likely to make, and cutting them off or undermining them as best you can in advance. There’s certainly no reason in a p[olicy debate NOT to acknowledge the familiar lines of BS, and least assert that they are BS,
    _____

    @ Orac:
    Would it be fair to say “Every homeopathic remedy subjected to a scientifically valid RCT has been proven NOT to have the therapeutic effect attributed to it by the documented homeopathic provings”? Close? What would a fair statement along those lines be, then? What do you think of the idea of asking the regulators to put whatever statement of disproof that might apply as a labeling requirement?

    • #26 Dorit Reiss
      December 17, 2016

      A few words about the legal framework here.
      A. The FDA does not implement FTC regulations. The FTC does.

      B. If the decision is challenged, it will be examined, likely, under the arbitrary and capricious standard in the Administrative Procedures Act of 1946. This has several implications that are relevant here. One is that under a specific doctrine, the explanation has to be in the regulation – and has to address the major issues. So they have to refer to no scientific basis if that’s part of the explanation. But they can probably make a good case that they don’t have to refer to every nonsensical claim raised – if they have experts reports that there is no scientific basis, they’re on pretty solid grounds. It’s a court they’ll have to convince, not random non-scientists.

      Whether the standard is deferential or not kind of depends on the court; it’s very murky jurisprudence. So if they’re lucky and fall on a panel of judges who are very strict about scientific evidence, they probably don’t need to go any deeper. If they’re unlucky and fall on a panel with two or more that buy into this stuff, or are susceptible, it’s not clear that going deeper would help.

      At least some of the considerations in writing the decision would be considering future litigation, since administrators are, usually, savvy and experienced people. They can make mistake, of course, but I’m not convinced this is one.

    • #27 Dorit Reiss
      December 17, 2016

      And one more thing: agencies get very high level of deference when they interpret their own regulation. So FTC can expect that if questions come up because of the way the regulation is written, they will have leeway to interpret it to meet their goals.

  26. #28 herr doktor bimler
    December 18, 2016

    If the FTC staff know the quantum and nano stuff is BS because it was brought up at the hearings last year, it’s all the more dumb-ass they didn’t address it in their recommendations.

    I am not convinced that every low-life grifter who crawls out of the woodwork with a “quantum resonance” line of bullsh1t deserves a detailed refutation.

  27. #29 jrkrideau
    At the bottom of the lake (the bottom end that is)
    December 18, 2016

    # 6 Richard
    The ironic thing about the the Nuremberg salt test of 1835 is that most all standard medical treatments of the time would, almost certainly, showed the same result. Anybody know if there has ever been a RCT of bloodletting ?

  28. #30 jrkrideau
    At the bottom of the lake (the bottom end that is)
    December 18, 2016

    # 19 Narad

    The new quantum nanoparticle homeopathic treatments are revolutionizing the field. There is a hope by combining these inspired treatments with the use of Buckminsterfullerene as the delivery mechanism that we will soon conquer even the common cold.

  29. #31 Richard
    December 18, 2016

    @ jrkrideau, #29, #30

    The ironic thing about the the Nuremberg salt test of 1835 is that most all standard medical treatments of the time would, almost certainly, showed the same result.

    Ah, the good old ‘flying carpet’ fallacy(*). The fact that regular medicine wasn’t really much good in those days does not have any bearing on the credibility of homeopathy. The only legitimate conclusion that you can draw from this is that homeopathy was BS, and that regular medicine wasn’t much better at that time.
    Regular medical science has made tremendous progress since then, whereas homeopathy is exactly the same BS it was two hundred years ago. The only difference is that homeopaths didn’t (and mostly couldn’t) know any better in those days — but really should know better now. Only stubborn fools and their victims still believe that homeopathy works.

    *: “The fact that cars aren’t perfect doesn’t mean that flying carpets are a viable transport modality.”

    The new quantum nanoparticle homeopathic treatments are revolutionizing the field.

    Erm, there is no such thing as “quantum nanoparticle”. As Narad explained in #19, nanoparticles are bigger than molecules, whereas ‘quantum’ refers to physical phenomena at a scale smaller than even one atom. Nanoparticles do not exhibit quantum behavior in any significant manner.
    Apart from this, things on a quantum scale don’t have any well-defined complex structure that would be required to intervene in physiological processes in any useful manner (whereas medicinal molecules do have such a structure).
    Simply said: healing a particular ailment by affecting, steering or even starting specific bodily processes requires quite a bit of very specific information. Homeopathic dilutions don’t offer any viable mechanism to convey that sort of information, and invoking ‘quantum’ at this point is merely a demonstration of my point in #24.

  30. #32 jrkrideau
    At the bottom of the lake (the bottom end that is)
    December 18, 2016

    Not the “the good old ‘flying carpet’ fallacy” just noting that RCTs of many, possibly most, early 19th C ‘orthodox’ medical treatments were not likely to show many if any benefits over homeopathy since at the time neither were really well grounded in science. In many cases, it probably was placebo versus placebo and may the best showman win.

    Of course, some regular medical treatments did actually work, I believe, whereas homeopathy could only work by accident as in croiduire’s example @ 13 where it is the buffer/filler not the (non-present) active ingredient that works.

    Regular medicine has advanced as it adopted scientific knowledge and methods; homeopathy remains a rather ridiculous, pre-scientific, fantasy.

  31. #33 jrkrideau
    At the bottom of the lake (the bottom end that is)
    December 18, 2016

    Erm, there is no such thing as “quantum nanoparticle”.
    Well there will be in a day or two when Deepak Chopra or Dr. Oz latches onto it.

    BTW Richard, are you from the USA?

  32. #34 Richard
    December 18, 2016

    BTW Richard, are you from the USA?

    No, I am from the Netherlands (I also hinted at this in #6). Can I ask why you ask?

  33. #35 Richard
    December 18, 2016

    @ jrkrideau, #32
    One more thing about comparing regular medicine and homeopathy in the early 1800’s: anyone who studied this subject, knows that as a treatment, homeopathy often had significantly better outcomes than regular treatments. But that of course was because quite a few regular treatments (bloodletting, ‘medicines’ based on heavy metals, and even wound dressings containing manure) were far worse than doing nothing — which homeopathy basically is. ‘Doing nothing’ is one of the most difficult things for doctors (and patients) to do; when someone is suffering, there is an almost irresistible urge to intervene.

  34. #36 Gilbert
    December 18, 2016

    “” ‘quantum’ refers to physical phenomena at a scale smaller than even one atom. Nanoparticles do not exhibit quantum behavior in any significant manner.
    O RLY, Richard?

    they did show that a tiny resonating strip of metal – only 60 micrometres long, but big enough to be seen without a microscope – can both oscillate and not oscillate at the same time. Alas, you couldn’t actually see the effect happening, because that very act of observation would take it out of superposition.

    https://www.newscientist.com/article/dn18669-first-quantum-effects-seen-in-visible-object/

    The experiment shows that the principles of quantum mechanics can apply to everyday objects as well as as atomic-scale particles.

    http://www.nature.com/news/2010/100317/full/news.2010.130.html

  35. #37 Richard
    December 18, 2016

    @ Gilbert, #36
    Sure, quantum behavior can be observed in larger objects, but as the article you quote shows, this only happens under special circumstances. Normally, these quantum states are not discernible for anything larger than a simple atom. Hence also my qualifier ‘significant’.
    And, of course, quantum behavior can have several macroscopic effects, such as the principles behind MRI and the photoelectric effect, to name just a few. But it most certainly does not give homeopathic dilutions any special, curative properties.

  36. #38 Gilbert
    December 18, 2016

    experimentalists have been working on building ever-larger quantum objects, which are big compared with atoms but small compared with real cats. They are often called “Schrödinger’s kittens,” and they are rapidly growing up.

    http://nautil.us/issue/29/scaling/how-big-can-schr246dingers-kittens-get

  37. #39 sadmar
    December 18, 2016

    I am not convinced that every low-life grifter who crawls out of the woodwork with a “quantum resonance” line of bullsh1t deserves a detailed refutation.

    Greetings, Captain Obvious. But we’re not talking about every low-level grifter. We’re talking about lobbyist/lawyers from the very well-connected DC firm Venable LLP. (though, admittedly, not their ‘A’ team…) And, as it happens, the FTC whiff on the quantum or the nano or the whatever the quacks want to call it tomorrow turned out to be no big deal, while the whiff on ‘provings’ is the major faux pas.

    The principle, again: There no excuse for not considering all the arguments your opponent is likely to make, and cutting them off or undermining them as best you can in advance.

    The opponents in this case aren’t low-level grifters crawling out the woodwork with BS, they’re the professional political operatives serviing a $6.4 billion dollar industry. Fwiw, I said nothing about “a detailed refutation”. The refutation of Infinitesimals that IS in the FTC statement is no more than a couple sentences. Basically, all you need to say is ‘I bet they’ll say this, which might sound good, but it’s just BS and I can tell you why by elaborating [X].’ If, for some reason, there’s no space to make any refutation, you can still anticipate and state that the point can indeed be refuted.

    Why you might feel some need to suspend all critical thinking about the FTC’s strategy, and waste your time defending hack work with a pathetic irrelevant straw-man is beyond me.

  38. #40 Dutchie
    December 19, 2016

    I will go a step further. Every Medical Doctor who entertains homeopathy should have their license be revoked. They clearly have not understood a thing that was taught at University.

  39. […] let that one rest, and Orac, in a deliciously splenetic post at Respectful Insolence (“Homeopaths respond to the FTC’s new position on homeopatrhy. The Universe laughs”, describes and then demolishes the pathetic attempt of The American Homeopathic Institute to defend […]

  40. #42 Delphine
    December 20, 2016

    Took 5 year old Delphinette to the doctor yesterday, we were on Day 3 of nasty cough and mild fever. Our regular GP wasn’t available, so we used a local walk-in. URI. Fluids, rest. Except…she also told me to “get her some Helixia” which is this: http://helixia.com/children/cough/ and it’s useless.

    https://sciencebasedmedicine.org/the-new-cough-and-cold-products-for-children-evidence-is-optional-and-science-is-marketing/

  41. […] this given that the median income is $70,000, with $200,000 going to the more successful ones. As pointed out by surgical oncologist David Gorski, the homeopathic industry’s supposed rigorous […]

  42. […] respond to the FTC’s new position on homeopathy. The universe laughs, Respectful Insolence am 16. Dezember […]

  43. #45 Maddy
    New Zealand
    January 1, 2017

    Oh how I detest how pseudoscientists attempt to use labels like pseudoscience to undermine legitimate opposition to their pseudoscience, when that opposition is actually science science.
    “You’re the puppet, you’re the puppet!”
    All the rest of it too, bandying about ‘evidence-based’ and ’empirical’, taking the very objections to homeopathy and claiming those terms as if they apply to their collection of anecdotes and testimonials. It’s bold. It’s throwing out a lie and seeing if anyone is fooled, anyone is bamboozled. It’s classic charlatanry. Ugh.

  44. #46 titmouse
    January 1, 2017

    Lol cranksplaining.

  45. #47 Chemmomo
    Where it's been 2017 for less than 14 hours
    January 1, 2017

    Maddy from New Zealand
    First of all: Huh?

    Next

    It’s throwing out a lie and seeing if anyone is fooled, anyone is bamboozled. It’s classic charlatanry.

    Did you happen to follow the results of the last United States presidential election?

  46. #48 Dangerous Bacon
    January 1, 2017

    “Oh how I detest how pseudoscientists attempt to use labels like pseudoscience to undermine legitimate opposition to their pseudoscience, when that opposition is actually science science.”

    Quite true, or drivel.

  47. #49 rs
    January 1, 2017

    Speaking pseudoscience, not science but pseudo,
    Wrapped in poorly constructed innuendo,
    …With gibbering incessant,
    …and an odour most puissant
    We welcome our first new year dodo.

  48. […] and nanoparticles” was starting to resemble a couple of things. For one, homeopaths like to invoke “nanoparticles” to “explain” how their quackery works. They even mistake low level contamination for […]

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