Regulating the magic that is homeopathy: I have a very bad feeling about the upcoming FDA public hearing

Once again, repeat after me: Homeopathy is quackery. In fact, it’s what I like to refer to as The One Quackery To Rule Them All. You would think that, in a modern world and given the incredible advancements in our scientific understanding of biology, physiology, chemistry, and physics over the course of the over 200 years since Samuel Hahnemann pulled the concepts behind homeopathy out of his nether regions, it never ceases to depress me that there are large numbers of people who think that homeopathy could ever work. But they do.

A couple of weeks ago, I took notice of a, well, notice from the FDA announcing that it was considering revamping its regulation of homeopathic remedies. What? you’re thinking (if you haven’t read this blog before or somehow missed my post on this). The FDA regulates homeopathic remedies? WTF? Why would the FDA regulate water? The long version of the explanation is in the link above. The short version follows. Basically, when the law authorizing the FDA was amended in the 1930s, a provision was added that defined any remedy listed in the Homeopathic Pharmacopeia of the United States (HPUS) as a drug. Consequently, any magic pixie dust homeopaths want to call a remedy and put it into the HPUS gets a pass from the FDA, even though, as Jann Bellamy argues, just because the law defines anything in the HPUS as a drug doesn’t mean the FDA can abdicate its responsibility to regulate it. After all, one of the charges of the FDA is to require that drugs be safe and effective before they are marketed, and it doesn’t do that for homeopathy, even for homeopathic asthma remedies.

Whatever the reason, the FDA announced that it was going to hold a hearing on the regulation of homeopathic remedies in Bethesda on April 21 and 22. With the public hearing less than a week away, the FDA has released the list of people who will be giving testimony at the hearing.

I have a bad feeling about this.

Why do I say this? Consider this. I count 37 people giving testimony over two days. Can you guess how many could be considered to be on the side of science? There are only three on the list whom I can identify through knowledge or an educated guess as definitely or likely being on the side of science:

  • Edward P. Krenzelok, Rocky Mountain Poison and Drug Center
  • Michael DeDora, Center For Inquiry (whom I have offered advice to, as have other skeptical physicians).
  • Barbara A. Kochanowski, Consumer Healthcare Products Association

As for the rest? It appears to be representatives from various naturopathic organizations, homeopaths, manufacturers of homeopathic remedies, law offices, and “integrative” medical centers where quackery and scientific medicine are “integrated” to the detriment of science. The only good thing about the rest of the list is that at least Dana Ullman isn’t one of the people giving testimony. That would have truly pushed the hearing into the realm of the surreal, although at least it would have provided some entertainment value in a sad, freak show sort of way.

Still, the homeopaths are leaving nothing to chance. They’re flying in a representative from the UK, specifically Peter Fisher from the Royal London Hospital for Integrated Medicine (formerly known as the Royal London Homeopathic Hospital. He’s definitely a heavy hitter in the brave new world of integrating homeopathic quackery with real medicine, having chaired the World Health Organisation’s working group on homeopathy and served as a member of WHO’s Expert Advisory Panel on Traditional and Complementary Medicine. He’s also Editor-in-Chief of Homeopathy, published by Elsevier, the only journal dedicated to homeopathy indexed in Medline. (If you want a giggle, just read its table of contents over the last few months.) He also serves as Clinical Lead for the UK’s National Library for Health’s online Complementary and Alternative Medicine Specialist Library, the NHS’s official knowledge website for Complementary and Alternative Medicine and of the Complementary and Alternative Medicine Library and Information Service. He was awarded the Albert Schweitzer Gold Medal of the Polish Academy of Medicine in 2007. Somehow, I doubt that Fisher will be advocating stricter regulation.

What about some of the others? Given my background and blogging, my eyes weren’t first drawn to the homeopaths. After all, I know what they’re going to say. They believe magic is real, and they’re going to try to argue that the FDA shouldn’t regulate homeopathic remedies, that the FDA should leave things just the way they are. And why not, at least from their perspective? Things are just ducky for them now. The FDA doesn’t bother them. No one can access the HPUS without paying a rather hefty subscription fee; so there isn’t even any transparency as to how homeopathic remedies are chosen to be in the HPUS. Tighter regulation of homeopathic remedies or—gasp!—actually regulating them as drugs would be a major threat to the ability of homeopaths to practice their quackery; so it’s no wonder they’re flocking to the hearing. No, what I’m more interested in are some of the representatives of academic integrative medicine programs who are testifying. If you want some insight into quackademic medicine, it’s useful to take a look.

The reason is simple. I want to see if any of them will defend the current hands-off approach to homeopathy. If there’s one thing I’ve learned, it’s that most integrative medicine practitioners and researchers based in academic medical centers tend to be profoundly embarrassed by homeopathy and try to deny it as being part of “integrative medicine” because it is so obviously based on magic. Remember, though. That’s most, but not all. One good thing that can come from this hearing is that it’s possible that one or more of these academic practitioners who’ve dedicated their lives to “integrating” quackery with medicine might let his true colors show by defending homeopathy.

For example, there is Adriane Fugh-Berman of the Georgetown University Medical Center. I can’t say for sure which way her testimony will go, but I rather suspect it will be sympathetic to integrative medicine, given that she is the director of PharmedOut, which is known for keeping pharmaceutical company influence out of CME activities. That in and of itself is not a bad thing, but couple that with the fact that she is also very heavily into herbal medicine and has been quoted as the “other side” in news reports about Paul Offit’s critical book on alternative medicine. Her attitude appears to be relatively hostile to pharmaceutical companies. That wouldn’t be a bad thing (after all Ben Goldacre, someone whom I admire, is not what one would call friendly to pharmaceutical companies), but Fugh-Berman combines that with troubling advocacy:

Dr. Fugh-Berman noted that, while research is essential to discover effective treatments, it is only part of the equation in encouraging CAM. Even when physicians and consumers know that particular CAM therapies are useful, they may not choose to recommend or practice them. Dr. Fugh-Berman called for a paradigmatic shift in conventional medicine to integrate effective CAM modalities into treatment, education, and coverage. Yet, so long as the medical system remains profit-driven—and physicians unduly influenced by pharmaceutical companies—this is unlikely to occur.

Yep. That’s a common alt-med trope used to make excuses for why “complementary and alternative medicine (CAM)/integrative medicine is not more widely accepted in the medical profession, and it does not give me confidence to have found her saying such things in interviews. I get the feeling that Fugh-Berman will probably be advocating mostly for the status quo. On the other hand, she does study natural products pharmacology; so maybe a curve ball is possible, the sort where she agrees that homeopathy is quackery that works through placebo effects but accepts the rebranding of a science-based modality like natural products pharmacology as somehow being “CAM” or “integrative.” I doubt it, though.

Another faculty member giving testimony is Luana Colloca of the University of Maryland. She’s another one whose testimony could go either way. An associate professor in the Department of Anesthesia, she’s published with Fabrizio Benedetti on placebo effects. I imagine she will be likely to testify that homeopathy “works”—such as it does—through placebo effects. What I can’t be sure of is whether she will conclude that this is a good thing or not. I rather suspect that Colloca was asked to testify by the FDA, given her very specific expertise in the science of placebo effects and her track record of scientific publications on the topic. She’s also in Baltimore; so she’s local.

There’s also a faculty member from the Northwestern University Feinberg School of Medicine in Chicago, Youngran Chung from the Ann & Robert H. Lurie Children’s Hospital of Chicago, and a representative of a very quacky clinic founded by a Northwestern faculty member, the Raby Institute for Integrative Medicine at Northwestern, which is being represented by Robert C. Dumont, an “integrative pediatrician” specializing in acupuncture and homeopathy. I hadn’t heard of the Raby Institute before; so I checked out its website. It turns out that it’s not just the Cleveland Clinic that’s offering the prescientific nonsense retconned by Chairman Mao or the quackery that is functional medicine. It’s there at the Raby Institute, overseen by a clinical faculty member of Northwestern.

To be fair, the relationship between the Raby Institute and Northwestern appears to be arm’s length at best. The founder of the Raby Institute, Dr. Their Raby, started her career combining quackery with real medicine by getting Northwestern’s Center for Integrative Medicine off the ground. Then after several years running the center, she apparently decided the grass was greener on Michigan Avenue and founded the Raby Institute. Right now, she’s still a member of the Northwestern Physicians Group, has privileges at Northwestern Memorial Hospital, and remains clinical faculty for the Northwestern University Feinberg School of Medicine in Internal Medicine and Geriatrics, but appears to be in private practice now in a nice swanky office on Michigan Avenue just a few blocks from Northwestern in downtown Chicago offering woo to the well-off sort of Chicagoans who tend to go to an address on North Michigan Avenue for their health care needs. In addition to the usual TCM treatments like acupuncture, the Raby Institute even offers cupping, which is one of the more ridiculous nonsensical treatments out there, and claims to be able to treat everything from AIDS to cancer to cardiac disease to infertility with TCM! Oh, and it also offers homeopathy, as well as the faith healing equivalent known as “energy medicine,” including reiki, qi gong, functional medicine/a>, vibrational medicine, craniosacral therapy, and healing touch. Maybe it’s a good thing that Dr. Raby is no longer affiliated with the Center for Integrative Medicine. Perhaps she had become too quacky even for Northwestern. On the other hand, she’s probably why the center still offers naturopathy, acupuncture, functional medicine, chiropractic, and other nonsense mixed with some sense.

Call me crazy, but I get the feeling that representing the Raby Institute Dr. Dumont will not be testifying against homeopathy, given that Dr. Raby has a naturopath, acupuncturist, and energy healer on her payroll and that Dr. Dumont has shilled in the past for a major manufacturer of homeopathic remedies, Boiron, as an expert witness. Hilariously, in open court he admitted that no one in the homeopathic community has a hypothesis for how homeopathy “works,” including him and that he’d have the Nobel Prize if he did know. Maybe he will be able to provide the entertainment value that is missing without Dana Ullman testifying.

Even though Dr. Dumont is not Northwestern faculty (although his partner and the founder of the Raby Institute is) what about Youngran Chung? She’s pediatric pulmonologist at Northwestern’s Lurie Children’s Hospital of Chicago who’s listed as being interested in CAM, asthma, chronic cough, and cystic fibrosis. Her profile lists her thusly:

Integrative medicine (Complementary/Alternative medicine) in pediatrics. I am board certified by the American board of Integrative & Holistic Medicine (ABIHM). Having been trained/certified in Medical Acupuncture,Homeopathy, and Medical Hypnosis, I am interested in the integration of Complementary/Alternative medicine modalities along with conventional medicine to provide safe and effective ways to treat patients.

Another profile describes her thusly:

She integrates homeopathy extensively in her pulmonary practice, and has authored articles in medical journals as well as book chapters on the topic of homeopathy. She has given symposiums and presentations on homeopathy at conferences in the United States as well as abroad.

Yes, Northwestern University has a bona fide physician/homeopath on it damned faculty in the Department of Pediatrics treating the children of Chicago! In fact, it’s right there on her Northwestern Medicine profile that her clinical interests include “Acupuncture, Asthma, Cough, Cystic Fibrosis, Homeopathy, Medical Hypnosis.” Interestingly (well, not really), she’s presented a poster with Dr. Dumont entitled Homeopathy, an Effective, Practical, and Safe Therapeutic Approach: Principles, Evidence and Examples of Practical Application. Get a load of the abstract:

Homeopathy has been in use for more than 200 years and is currently practiced by thousands of physicians worldwide. Homeopathic medicines are safe, non-toxic, without adverse effects or drug interactions and are regulated as drugs by the US Food and Drug Administration in the United States. While homeopathy is gaining popularity in the United States, there is poor understanding and misconceptions about it among physicians. Many medical conditions (eg, pertussis cough, recurrent croup) do not have effective drugs and cannot prevent recurrences or require medications with undesirable side effects. Due to the nature of its preparation, homeopathy is an extremely safe modality that can be used as first-line treatment for many acute or chronic conditions or in conjunction with conventional or other nonconventional therapies. While formal training is necessary in order to use homeopathy for chronic conditions, many acute medical problems can be effectively treated by physicians with a basic understanding of homeopathic principles through the use of simple protocols for certain commonly encountered conditions. The poster will cover basic homeopathic principles, review the evidence for efficacy, and present cases from the authors’ experiences. Protocols for common acute medical problems that the participants can use immediately in their clinics or offices will be presented and discussed.

In fact, Dr. Chung is apparently married to Dr. Dumont. They’ve presented at the same conference before, and her presentation was Homeopathic Treatment of Psychosomatic Disorders of a Respiratory Nature : A Case Series while his was, horrifyingly, Use of Clinical Homeopathy in Autism Spectrum Disorder. There’s even a presentation by Dr. Chung posted at the Chicago Asthma Consortium website on CAM that credulously discusses homeopathy, even going so far as to describe a case of a 14 year old with sore throat including burning, stinging pain that was worse with warm food and drink but better with cold food or drink. Her prescription? Homeopathic APIS (bee venom), because like cures like and bee venom causes burning and stinging pain. She even has a slide that shows various homeopathic dilutions up to 1M (or 1,000C), which is a 10-2000 dilution, admitting that everything over around 12C (10-24 dilution) is beyond Avogadro’s number.

I repeat again. This is a member of the faculty of the Northwestern University Feinberg School of Medicine! I remember the last time when I did my Academic Woo Aggregator, homeopathy was uncommon in medical schools and academic medical centers. I wonder if that’s the case now. In fact, I really should update the Woo Aggregator. In the meantime, all I can do is lament that Northwestern would have practitioners of homeopathy on its faculty such as Dr. Chung, who practices the prescientific vitalistic sympathetic magic known as homeopathy and Dr. Raby, a credulous doctor who has monetized nonsense. At this rate, Northwestern might as well rename itself Hogwarts. Even worse, in my opinion they’re both using the academic reputation of Northwestern to promote homeopathy as they testify with the likes of Peggy O’Mara, publisher and editor of, one of the wretchedest of the many wretched hives of scum and quackery on the Internet and Nancy Peplinsky, founder of the Holistic Moms Network, which is just as bad as it sounds from the name. If you want to know how deeply quackademic medicine has infiltrated medical academia, just look for homeopathy in academic medical centers.

As I said, I have a bad feeling about how this hearing will go.

That makes it all the more critical that as many people and organizations devoted to science-based medicine as possible submit written commentary before the deadline. I described how to do it. Jann Bellamy described how to do it. Mark Crislip provided an example of how to do it. So just do it. Otherwise, the preponderance of testimony from homeopathy supporters is likely to have considerable influence. The status quo will continue, and magical “cures” for what ails you will remain unregulated.