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A rare win for science: The FTC issues its enforcement policy on homeopathic remedies

Whenever I write about homeopathy, I almost always refer to it at least once as “The One Quackery To Rule Them All.” It’s a phrase I’ve used to describe homeopathy for several years now, and for good reason. Of all the quackery out there, with the possible exception of reiki, homeopathy is the one that is most obviously quackery. Its two main “Laws” are so clearly pseudoscience that you’d think it incredibly unlikely that anyone would fall for such nonsense, but fall for it they do.

I’ll briefly show you what I mean. That I can do so this briefly should show those unfamiliar with homeopathy how ridiculous it is. All I have to do is to describe the Two Laws of Homeopathy. The first is the Law of Similars, which states that to relieve a symptom you must use a substance that causes that symptom. Not only does this law make no sense on an intuitive level, but there is no biological or medical basis for it. Of course, the Law of Similars doesn’t really matter, because the second law of homeopathy renders it completely irrelevant. The Second Law, the Law of Infinitesimals, states that diluting a remedy makes it stronger. That’s not nearly enough pseudoscience, though. Because of this law, homeopaths often dilute remedies to, in essence, nonexistence. For example, a typical 30C dilution (where C=100) means thirty 100-fold dilutions, which, if you do the math, you’ll find to be a 10-60 dilution. Avogadro’s number is only on the order of 6 x 1023, which means that a 30C dilution is at least 1036-fold higher than a dilution where we’d expect to see a single molecule of the original substance; that is, if you start with what chemists call a mole of starting compound. No wonder homeopathy is considered the king of pseudoscience, and that’s not even considering that some homeopathic remedies (like Oscillococcinum, the infamous homeopathic flu remedy) use starting ingredients like extract of duck liver and heart—and at 200C (10-400), yet!

That is why I greeted an enforcement policy statement from the FTC regarding regulation of health claims for homeopathic remedies. It’s more or less win for skeptics, but it’s not perfect. Even so, it’s definitely way better than the situation that existed before, because it provides clarity and states clearly that advertising claims for homeopathic remedies will be held to the same standards as advertising claims for any other over-the-counter (OTC) medicine.

By way of background, in January I asked the question: Will 2016 be the year when the FDA and FTC finally crack down on homeopathy?, a question that was asked in the New England Journal of Medicine as well. I based that question on hearings about homeopathy held by both the FDA and the FTC. First, the FDA announced that it was considering modernizing how it regulates homeopathic remedies and held a hearing for public input. Not surprisingly, there were few skeptics and plenty of industry representatives and homeopaths who testified. Ironically, the FTC submitted testimony to the FDA hearing that echoed the testimony of skeptics.

Basically, the FTC recommended that the FDA reconsider the framework that it uses to regulate homeopathic medication because that framework may appear to conflict with the FTC’s advertising substantiation doctrine, which requires that health-related efficacy claims be “supported by competent and reliable evidence,” in ways that could harm consumers and cause confusion for advertisers. The FTC also noted that supplement manufacturers could get around even the lax FDA regulations on dietary supplements by having their product classified as a homeopathic remedy by adding homeopathic remedies to it. Basically, the FTC told the FDA to do its job regulating homeopathy because lax FDA regulation of homeopathic remedies interferes with FTC regulation of advertising claims for them. Part of the problem comes from a quirk in the law authorizing the FDA, an amendment to which was passed in the 1930s 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. As I’ve pointed out before, 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.

Even though the representatives of the homeopathic remedy industry who testified before the FDA workshop last year made a rather poor showing, relying a lot of special pleading and bad science, nothing much has happened at the FDA in terms of making actual policy changes or changing its regulations on homeopathic medicines in over a year. True, it recently did warn about homeopathic teething products but mainly because such products actually tend to contain actual belladonna in them, sometimes toxic amounts.

The FTC, in essence, has beaten the FDA to the punch, publishing its enforcement policy statement. The complete statement here. The FTC notes first:

The FTC’s authority over disease and other health-related claims comes from Sections 5 and 12 of the FTC Act. Section 5, which applies to both advertising and labeling, prohibits unfair or deceptive acts or practices in or affecting commerce, such as the deceptive advertising or labeling of OTC drugs.3 Section 12 prohibits the dissemination of false advertisements in or affecting commerce of food, drugs, devices, services, or cosmetics. Under these provisions, companies must have a reasonable basis for making objective product claims, including claims that a product can treat specific conditions, before those claims are made.

Homeopathy, which dates back to the late-eighteenth century, is based on the view that disease symptoms can be treated by minute doses of substances that produce similar symptoms when provided in larger doses to healthy people. Many homeopathic products are diluted to such an extent that they no longer contain detectable levels of the initial substance. In general, homeopathic product claims are not based on modern scientific methods and are not accepted by modern medical experts, but homeopathy nevertheless has many adherents.

This is, in a nutshell, the whole basis of the FTC’s decision boils down to the contrast between the FTC’s mission and the lack of science behind homeopathy. A major part of the FTC’s mission is to protect the public against false advertising claims and false marketing. When it comes to OTC medications, in order to do that it has traditionally relied on its advertising substantiation doctrine. However, it notes:

The FTC Act does not exempt homeopathic products from the general requirement that objective product claims be truthful and substantiated. Nevertheless, in the decades since the Commission announced in 1972 that objective product claims must be substantiated the FTC has rarely challenged misleading claims for products that were homeopathic or purportedly homeopathic.

Personally, I wondered why this might be. Why, over 46 years, has the FTC rarely challenged claims for homeopathic remedies that are not infrequently overblown and virtually never based on science. (It is, after all, homeopathy.) Perhaps it wasn’t a priority. Perhaps the FTC used to defer more to the FDA, whose authority overlaps that of the FTC. Remember what skeptics like to call the “Quack Miranda Warning”? That’s a statement that sellers of dubious medical therapies frequently append to their advertising or their claims saying roughly, that the claims have not been evaluated by the FDA and that the product is not intended to treat, diagnose, or prevent any medical disease. The words are supposed to inoculate the company selling such products from legal action by the FDA because, whatever load of nonsense the company has laid down before about its wonder supplement or product, it just denied that it was making any health claims. Let the buyer beware!

As a result, as the FTC notes, consumers are confused by these advertising claim. They do not know what homeopathy is, which is not surprising because my experience with medical students and residents tells me that even they do not know what homeopathy is or about how many homeopathic remedies are diluted to the point where no starting material remains. They also assume that because these products are permitted to be sold in pharmacies. This is a telling passage from the workshop:

Focus group participants in both groups were likely to group or categorize products in a number of ways including conventional versus non-conventional. They tended to group all non- conventional products, including homeopathic products, into a single category, using the terms “natural,” “herbal,” and “homeopathic” interchangeably. Most adults and parents struggled when asked to distinguish between herbal and homeopathic products. They did not understand what “homeopathic” means. Most participants associated homeopathic products with natural or “non-chemical” products.

Many adults and parents did not readily differentiate between different product types in terms of the evidentiary requirements for product claims or regulatory oversight. While they generally believed that manufacturers of conventional non-prescription products were required to support their claims with scientific evidence, they had varying opinions regarding the evidentiary requirements and federal oversight for herbal and homeopathic products. Some participants indicated there were no requirements, others insisted there must be some governmental oversight, and still others were unsure but hopeful that there were requirements.

Whatever the reason for the FTC’s laissez-faire attitude in the past towards claims made for homeopathic remedies, those days appear to be over. In this statement, the FTC clearly states that advertising claims for homeopathic remedies used for self-limited conditions must meet the same standards as advertising claims for other OTC drugs used for self-limited conditions:

The policy statement explains that the FTC will hold efficacy and safety claims for OTC homeopathic drugs to the same standard as other products making similar claims. That is, companies must have competent and reliable scientific evidence for health-related claims, including claims that a product can treat specific conditions.

That’s pretty clear, as is this:

For health, safety, or efficacy claims, the FTC has generally required that advertisers possess “competent and reliable scientific evidence,” defined as “tests, analyses, research, or studies that have been conducted and evaluated in an objective manner by qualified persons and [that] are generally accepted in the profession to yield accurate and reliable results.”12 In general, for health benefit claims, particularly claims that a product can treat or prevent a disease or its symptoms, the substantiation required has been well-designed human clinical testing

This is not what homeopathic remedies have to support them, of course. The FTC notes that homeopathic remedies are “based solely on traditional homeopathic theories and there are no valid studies using current scientific methods showing the product’s efficacy” and that marketing claims therefore “lack a reasonable basis and are likely misleading in violation of Sections 5 and 12 of the FTC Act.”

There is a caveat, though, a way for the manufacturers of homeopathic remedies not to be considered to be misleading by the FTC. Those manufacturers aren’t going to like it much though. Behold, the one way that the FTC says that claims for a homeopathic remedy won’t be considered misleading, barring strong clinical trial evidence for efficacy and safety (which none of them have):

Accordingly, 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. To be non-misleading, the product and the claims must also comply with requirements for homeopathic products and traditional homeopathic principles. Of course, adequately substantiated claims for homeopathic products would not require additional explanation.

Ouch. That one’s going to leave a mark. So will these additional observations. Here are the first two:

  • Any disclosure should stand out and be in close proximity to the efficacy message; to be effective, it may actually need to be incorporated into the efficacy message.
  • Marketers should not undercut such qualifications with additional positive statements or consumer endorsements reinforcing a product’s efficacy.

These are, of course, time-dishonored advertising techniques. Basically, the Quack Miranda Warning is an example of this. Supplement manufacturers make claims based on little or no evidence and push the limit of what is permitted (i.e., “structure-function claims” such as “supports the immune system”) and then say in fine print at the bottom of the page or web page that the FDA hasn’t examined these claims.

Then there’s this:

  • In light of the inherent contradiction in asserting that a product is effective and also disclosing that there is no scientific evidence for such an assertion, it is possible that depending on how they are presented many of these disclosures will be insufficient to prevent consumer deception. Marketers are advised to develop extrinsic evidence, such as consumer surveys, to determine the net impressions communicated by their marketing materials.
  • The Commission will carefully scrutinize the net impression of OTC homeopathic advertising or other marketing employing disclosures to ensure that it adequately conveys the extremely limited nature of the health claim being asserted. If, despite a marketer’s disclosures, an ad conveys more substantiation than the marketer has, the marketer will be in violation of the FTC Act.

So, it’s not enough for marketers of homeopathic remedies just to say there’s no evidence that their products work or that they’re based on 18th century ideas and not accepted by science. Marketers will also be expected to show that their positive messages aren’t preventing the disclaimers from etting true, that its customers understand that there’s no scientific evidence to support their assertions.

I was happy to see the FTC statement, because in it the FTC does what should have been done long ago and what the FDA should have done by now. I was not happy to see close to zero news coverage on this, which struck me as distinctly weird. All I could find was a law review article and an article in a website on regulatory affairs. This is in marked contrast to when the FDA and FTC both held their workshops to consider more rigorously regulating homeopathic products, when there were lots of news articles and coverage. It’s almost as though the FTC’s decision was anticlimactic. Or maybe the news coverage was drowned out by the continuing news coverage of the 2016 election. Whatever the reason, people need to know: The FTC will now regulate advertising claims for homeopathic remedies the same way it treats advertising claims for OTC medications.

Now if only the FDA would follow suit and do its job with respect to homeopathic remedies.

By Orac

Orac is the nom de blog of a humble surgeon/scientist who has an ego just big enough to delude himself that someone, somewhere might actually give a rodent's posterior about his copious verbal meanderings, but just barely small enough to admit to himself that few probably will. That surgeon is otherwise known as David Gorski.

That this particular surgeon has chosen his nom de blog based on a rather cranky and arrogant computer shaped like a clear box of blinking lights that he originally encountered when he became a fan of a 35 year old British SF television show whose special effects were renowned for their BBC/Doctor Who-style low budget look, but whose stories nonetheless resulted in some of the best, most innovative science fiction ever televised, should tell you nearly all that you need to know about Orac. (That, and the length of the preceding sentence.)

DISCLAIMER:: The various written meanderings here are the opinions of Orac and Orac alone, written on his own time. They should never be construed as representing the opinions of any other person or entity, especially Orac's cancer center, department of surgery, medical school, or university. Also note that Orac is nonpartisan; he is more than willing to criticize the statements of anyone, regardless of of political leanings, if that anyone advocates pseudoscience or quackery. Finally, medical commentary is not to be construed in any way as medical advice.

To contact Orac: [email protected]

158 replies on “A rare win for science: The FTC issues its enforcement policy on homeopathic remedies”

This is really good. I wonder, though, how the transition to Trumpistan will change things? He’s already talked about pressuring the FDA to release backlogs of approval (Trump’s new reality show: finding the next Thalidomide), and has also made worrying comments about the CDC. Doubly worrying since he has been pictured with perennial winner of Most Punchable Face, Andy Wakefield. Trump seems to favour big business special interests every time, and there is no big business more adept at manipulating politics than Big Herba.

I predict that there will be a lot of money to make by testing the efficiency of sugar pills in RCT.

This is awesome news. Finally step forward in ensuring that people are truly informed that they are using magic fairy shit to treat their problems and not actual medication. I’m sure the usual suspects in Congress will raise a shit-storm about how unfair this is, but with luck it will stand.

I agree that this is good news, but Guy is right. It’s not just Trump, it’s that he will have a Republican Congress that is eager to get rid of “burdensome” regulations like this. It would be easy for them to slip in a measure preventing the FTC from enforcing this rule, and if the FTC doesn’t take the hint Congress can resort to more drastic measures.

Call me a pessimist, but how many folks can be expected to read the fine print on the package or ad? Probably about as many as read the legalese before clicking “accept” on computer apps.

Ah, but that’s the beauty of this policy. The FTC says that the disclaimers that homeopathy doesn’t work and that it’s based on 200+ year old idea not accepted by modern science must be presented with the same prominence as the positive claims and in such a way that the positive claims don’t distract from them.

One might think that while labeling was on the table, they might have gotten around to the “ingredients” list too.

I am not familiar with FDA/FTC regulations, but would any ingredients listed under a new policy be required by either agency to actually be detectable at some level? I don’t know the current limits of detection, but at a 6X dilution, it would be parts-per-million and at 12X dilution it would be parts-per-trillion. Not even getting into the C dilutions, would this put the manufacturers into Catch-22 territory: lying about ingredients if they aren’t detectable or not being homeopathy if they are? Am I hoping for too much reason and logic?

@sirchon,

In principle, the levels don’t have to be detectable if you can verify the purity and quality of the starting materials (substance and water) and have a verified and consistent production line. That way you are verifying the production claims made by homeopathy (starting material and number of dilutions) which is more important to homeopaths than the final product. However, checks of the final product could determine the levels of any contaminant.

@tonylurker, #12
even a “consistent production line” may be hard to have.
On 7/26/12 FDA issued a warning to A nelson & Co (UK) for many violations of Good Manufacturing Practice. For example, a FDA inspection found that
“…one out of every six bottles did not receive the dose of active homeopathic drug solution due to the wobbling and vibration of the bottle assembly during filling of the active ingredient. The active ingredient was instead seen dripping down the outside of the vial assembly. Your firm lacked controls to ensure that the active ingredient is delivered to every bottle”.
But then, probably, users couldn’t tell the difference.

Good news indeed! Just this week I taught my in-laws about the Quack Miranda warning (although I didn’t call it that) and how to use the search-in-page function to find it.

Now what they need is to set a minimum font size for the warning. One time I was helping my MIL find some UTI treatment at a drug store and it took us 3 tries to find the thing she wanted that *wasn’t* homeopathic, and if I hadn’t been there with my young (skeptical) eyes she would have simply grabbed the first box and never noticed the 8-point-font “homeopathic”.

Or all drug stores need reading glasses chained to every shelf.

C=10²

6.023(10²³)=10ⁿ(10²)

6.023(10²¹)=10ⁿ

6.023(10²¹)=10ⁿ

log(6.023(10²¹))=n

log(6.023)+log(10²¹)=n

(.78)+(21)=n

(21.78)=n

Statistically, anything over (21.78)C is pure water.

[email protected]: Your math isn’t quite right. nC means (10^2)^n, or 10^(2n). So you pass Avogadro’s number in going from 11C to 12C.

It gets worse. There are about 10^80 atoms in the observable Universe. So a dilution of 40C will get you one atom out of the entire Universe: (10^2)^40 = 10^80. There are homeopathic remedies out there that have 40C or higher dilutions.

These calculations, of course, assume that your distilled water really is pure water. But there are practical limits on how pure you can make distilled water. By the time you get to 6C, it’s likely that other impurities in the water will swamp the alleged active ingredient.

I thought we were at ‘anger’ over the election, but it seems we’ve regressed to ‘denial’, as Guy Chapman presents the obvious outcome in question form, and no one answers or even addresses the change in Washington.

Yes, Guy, this policy will be Trumped.

The only thing Boiron has to worry about from the Trumpers is competition from Ivankakokkkinum which will be available for order on the FDA website, as well as at the Trump boutique shops in all federal buildings.

@Eric Lund

Sorry. How about this!

C=10²

6.023(10²³)=Cⁿ

6.023(10²³)=(10²)ⁿ

6.023(10²³)=(10²ⁿ)

log(6.023(10²³))=2n

log(6.023)+log(10²³)=2n

(.7798)+23=2n

23.7798=2n

11.8899=n

Anything over (11.8899)C is statistically pure water.

To those of you pointing out how insanely diluted homeopathic remedies are:

Water has memory of the molecules it once bumped Van der Waals radii with. Even statistically pure water still has memories of oscillococcinum and rhododendrons and whatever else they put in there.

Ben, you obviously have a computer. You can increase its memory by simply pouring a bottle of water over the memory chips; works just like water in any homeopathic potion.

Ben @21: So that means that all water is full of sewage, industrial waste, and everything else since the beginning of the water cycle? Then how are we all not dead of cholera?

There are about 10^80 atoms in the observable Universe. So a dilution of 40C will get you one atom out of the entire Universe: (10^2)^40 = 10^80. There are homeopathic remedies out there that have 40C or higher dilutions.

Well, sure, but they’re mostly “Rx only.”

@ sadmar 17

I thought we were at ‘anger’ over the election

In your flippancy, you forget a little detail. This thread is about a federal agency cracking on homeopathy, it’s not about Trump (yet).

Mentioning the president-elect en passant, as Guy did, is OK. But further talking about Trump, at the risk of derailing this thread into yet another fruitless exchange about whose fault it is, would be just rude to our host.
I was tempted to put a comment mentioning Ben Carson, but no matter how I wrote it, it was out of topic (and Narad already mentioned it in another more appropriate thread).

Now that we are a little further down the thread, I will give you an answer.

You want anger? Try me.
Denial, pleading, I went through it in 2 min the morning after election day, when I learned of the results. Now I’m just simmering.

I have spent during these last days an unhealthy amount of time perusing blogs and news, both French and English.
I am lurking at various places over at Freethoughtblogs, reading the opinions full of mistrust and despair of the PoC, LGBT bloggers and regulars over there. A number of them are rape victims; can you imagine their anguish at having to watch full-frontal a smug, self-professed, unrepentant groper everywhere in the media, now and for the next four years? As a victim of bullying, I can start to imagine.
I am catching some new reasons to be angry at your president-elect over at the Wankette website. The websites which keep track of the recorded cases of racist/bigoted events or outright assaults in the past days are also very good at keeping me awake at night.

As a blogger at Freethoughtblogs said, the Normalization has begun, I can personally attest to it. Smug deplorables are prancing around online (and IRL in the US), and ordinary citizens, usually of the white, male, hetero persuasion are babbling about how Trump may Not Be That Bad – completely blind (or selfishly fully aware) to the fact that, with the future POTUS, his VP and the rest of the gang, hetero white males are precisely the ones who have the less to be afraid of.

I would be reading some news, and have memory flashes of stuff I have read or witnessed, sometimes a long time ago.
– fellow students trying to convince me I should vote LePen (the previous one) to “flush the socialist sh!t”. And no, absolutely no racism whatsoever.
– a former French president, also a populist (and maybe running for a 2nd term, we will know this week), who during his mandate put his 20-ish, law-school drop-out son in charge of a very posh business center. At least he waited to be in office, and it was that only one son; Trump has started last week to get all of his offspring White House security clearances.
– the same French president also strongly disrupted our gouvernemental agencies by redirecting their resources toward catching and kicking away illegal immigrants. Work safety? Who cares, focus on asking them their carte de séjour. No place in jail for a murderer? Eh, we have a busload of brown people to process, he will have to wait.
– more on-topic: this French president also targeted French science agencies with his wrath. Apparently, we eggheads are just incompetent parasites. He also wrecked the public news media. Oh, and those nasty judges are “red” (commies). Why do I have this feeling of déjà vu?
– a US Black veteran was denied a free meal at Chilly’s during Veteran day last week. A white guy decided he must be a fraud with a false ID. Where did I read similar stories of racists denying that a non-Caucasian may have well served their nation? Oh, Vercors, Le Silence de la Mer et autres histoires
– Let’s nail the Godwin point down with Au bon beurre (Jean Dutourd), a story about French collaborators. Eh, the nazi soldiers are very korrect, nothing to worry about. Trump may turn out to be a good leader, and his more ardent followers are totally peachy guys, if a bit enthusiastics.
– French Renaissance philosophers are also quite present to my mind right now, starting with Montaigne and some of his assays about humanism, empathy, and personal responsibility.

tl;dr:
Of course Trump may interfere with and reverse the FTC policies.
But didn’t you get the memo? We are not supposed to concern ourselves with little issues, like gender or race equity, we should focus on serious issues, and on the Big Picture.
I’m afraid homeopathy, or more generally access to proper medicine, is an even smaller issue. And frankly, pray that’s the only “small” issue you Americans will have in the coming years.
Some dude once talked about hanging together vs hanging separately. Please, Yankees, remember him.

**deep breath**

OK, I’m leaving the thread now, I have nothing of substance to say about the actual current topic .

@Jessika #15

Well, there will be plenty of room on the label for said ingredients. After all there’s only one:

Water.

But further talking about Trump, at the risk of derailing this thread into yet another fruitless exchange about whose fault it is, would be just rude to our host.
I was tempted to put a comment mentioning Ben Carson, but no matter how I wrote it, it was out of topic (and Narad already mentioned it in another more appropriate thread).

Since its still pretty early in the thread, and Trump is even more off-topic here, and since there’s already a thread devoted to the Orange One at this point, I’ve replied here.

(Couldn’t help but reply, I’m still heavily in the anger/venting/disgust mode, and I don’t want to do it on social media, since I have multiple “friends” (relatives) who are Trump supporters and I get tired of deleting all their gross, gloating comments on things I post/say.)

“I was not happy to see close to zero news coverage on this, which struck me as distinctly weird. All I could find was a law review article and an article in a website on regulatory affairs.”

The American Herbal Products Association alerted its readers to the FTC policy on homeopathic products only yesterday, as did the Consumerist. I devoured the policy over breakfast. Not only delicious, it was one of the most satisfying ‘meals’ I’ve had in years.

@Ben, #21

Even statistically pure water still has memories of oscillococcinum and rhododendrons and whatever else they put in there.

If you are serious, you are arguing facts not in evidence.

P.S. @ Eric Lund, #11,

If that is a reference to The Student Who Shall Not Be Named, I don’t seem to get it. But I am known for my idiosyncratic sense of humor and obliviousness.

[email protected]: It’s a riff off a famous movie line: “Forget it, Jake, it’s Chinatown.” I had forgotten that said student shared a given name with the character to whom that line was addressed.

These calculations, of course, assume that your distilled water really is pure water.

Now, now, as Dullman never tires of pointing out, it’s double (secret) distilled water.

So, I ran into an old friend from high school the other day who’d become a surgeon. Over a beer we discussed homeopathy and he was adamant that it was actually working medicine, offering this reasoning:

1) He said, studies with animals had shown efficacy above the Placebo effect (still waiting on link on that)

2) Even if the science doesn’t make sense (dilution/cure like with like), there might be some yet uncovered mechanisms like back when people did not know X-Rays existed

3) his killer argument: health insurance companies (in Germany) would not cover it, if it weren’t effective.

So how would you respond to that?

So how would you respond to that?

By asking why laparoscopic cholecystectomy hasn’t been eliminated by “Cheledonium,” perhaps.

@34

1: the animal studies I’ve seen quoted all depended on reports from humans, e.g. owners of pets, and did not have any hard measures, e.g. broken bones mending quicker ‘cos of magic water. So no objective evidence.

2: So? Then they need to get out there and do some science and find it. As things stand, no feasible mechanism and IF one is found then science will change its view accordingly.

3: Oh goody. Insurance company loss adjusters are the new arbiters of scientific evidence? What an insurance company will or won’t pay for is not evidence of anything other than what a commercial entity thinks the market will bear.

Homeopathy… should be more properly spelled Home0pathy

1. You’re better off staying home than spending your hard-earned money on it.
2. When all is said and done, there’s nothing to it, zero, insubstantial in efficacy.
3. (please forgive my atrocious spelling) It’s utterly pathytic the way homeopathy companies flog their pseudoscience – water retains memory.

If water retained memory, it’d taste like dinosaur piss.

@Moon #35
I get the “animals can’t have placebo effects so there!” a lot from defenders of the faith. Fake cures “work” for more reasons than placebo though. Go to this link: http://www.dcscience.net/2015/12/11/placebo-effects-are-weak-regression-to-the-mean-is-the-main-reason-ineffective-treatments-appear-to-work/
Number 2 is covered by number 1 answer, there is no effect so no cause needs to be found.
Search german cancer clinics here and at Science Based Medicine for some insight into the odd world of German health care.

If it is just water and does not work, has no effect….why do you people care??? Why waste all this energy if it is bunk? With bunk/ fad diet pills and gimmicks, people realize real quick it does not work and they fade out quickly. Yet, you guys seem to be keeping homeopathy alive with all this worrying and trying to waste the FDA’s time on this…for what, water? ???? News flash, NO ONE is dying from homeopathy, lol

Gilbert @28:
1) Facts not in evidence.
2) Why are you so against preventing some of the most horrifying birth defects?
3) If you just buy organic you don’t have to worry about it, because a large proportion of organic processed food is not enriched with folic acid.
4) But if you really hate folic acid that much don’t forget that it’s in tortillas and tortilla chips now! (And naturally occurs in tons of other foods.)

Robin @42: Except that it also has terrible manufacturing controls, which means that more than once homeopathic “teething tablets” have actually contained enough belladonna (deadly nightshade) to make kids sick.

Because not even the craziest herbalist would give *deadly* nightshade to a baby.

why laparoscopic cholecystectomy hasn’t been eliminated by “Cheledonium,”

Chelidonium majus! I remember that from the ‘Ukrain’ cancer-cure scam.

(And naturally occurs in tons of other foods.)

No it does not. ‘folic acid’ is made from petroleum and not known until 1943– The natural stuff is methyltetrahydrofolic acid; A build up of unmetabolized ‘folic acid’ is detrimental and downregulates absorption and metabolism of the real stuff.

@David Burke

If water retained memory, it’d taste like dinosaur piss.

Maybe you do?

…we will never know….unless we find a mosquito frozen in amber…

Reading about folic acid, you will quickly realize that MTHFR does not mean what you want it to mean.

It stands for MethyleneTetraHydroFolate Reductase.

BTW, Samuel L Jackson has very high MTHFR levels.

But if you really hate folic acid that much don’t forget that it’s in tortillas and tortilla chips now!

I take it that you either are or are not familiar with the episode in which Joe Harris’s lips fell off as a result of GMO corn Triffids.

@42

In which case it should be marketed as water, not with spurious health claims. If that happened I, for one, would not have a problem with it.

As pointed out it is part of a tendency to persuade folk to avoid stuff which works (y’know, actual medicines) with inevitable deleterious effects. See also “homeopathic remedies” for malaria and the like.

No Jessika, I meant 5-MTHF.

Levomefolic acid (INN) (also known as L-5-MTHF, L-methylfolate and L-5-methyltetrahydrofolate and (6S)-5-methyltetrahydrofolate, and (6S)-5-MTHF) is the primary biologically active form of folate used at the cellular level

https://en.wikipedia.org/wiki/Levomefolic_acid

There are people with genetic mutations such that they are not able to fully utilize MTHFR — excess folic acid is poisonous to them.

The use of folic acid in general populations without MTHFR or DHFR mutation is most likely of limited concern; but even for them, it is considered safe only when the dose is 100 – 200 mcg. For those people having fortified flour or cereal, energy drinks, protein bars and supplement, the dose of folic acid is exceeding the limit easily and considerably.

Beside efficacy differences, when comparing folic acid and 5-MTHF, folic acid is a synthetic compound with no biological function until reduced to its subsequence formats, unmetabolised folic acid starts appearing at dose > 200 mcg, and individuals show wide variations in folic acid reduction ability in vivo. On the other hand, 5-MTHF is a better alternative especially in those countries without folic acid fortification of foods, because it is a natural form of folate readily available in vivo for transport and metabolism, and it has no upper intake limit.

http://www.mthfrsupport.com.au/folic-acid-vs-5-mthf-treating-mthfr-deficiency/

I’m pretty sure that pregnant women are no longer given supplements of raw folic acid but rather the prescription folate, Deplin ( (6S)-5-MTHF).

Narad @50: Nope! I did a project for school recently on the new regulation that permits the addition of folic acid to products made with corn masa to prevent neural tube defects.

There was a scary cluster of NTDs in central Washington State that was eventually tied to low folate among a lot of the farm workers there because the staple of their diet was corn masa rather than enriched wheat flour or rice.

And Gilbert of course cares nothing for the major public health triumph of fortification. Hey Gilbert, did you know that folate is essential for fetal development in the first 20-28 days, well before most women know they are pregnant? So prescription folate is only useful if you already know that you have low folate. Which for poor women comes from losing a pregnancy.

What a stupid waste of mice. And what a stupid study! I mean, I could show that saline causes all kinds of bad reactions if I gave it with huge doses of LPS too.

The amazing thing is that they manipulated their “experimental system” that much and *still* didn’t get any kind of meaningful difference. If you’re going to fake that much you might as well go all the way. (No, don’t, but still.)

Yes, JustaTech. The fact remains that fortification gives better quality of life to those with poor nutrition. But that life is derated in people with otherwise good nutrition — A great equalizer.

concerns have been raised about the potentially untoward effects of unmetabolized synthetic folic acid with regard to cancer, depression, and cognitive impairment. With all these concerns, early data suggest supplementation with l-methylfolate rather than folic acid may mitigate these risks.

http://ncbi.nlm.nih.gov/pmc/articles/PMC3218540/

Mothers that take excessive amounts of folic acid during pregnancy may predispose their daughters to diabetes and obesity later in life, according to a new study. With high dose supplements [and fortification] being widely available, the study calls for a need to establish a safe upper limit of folic acid intake for pregnant women.

https://www.sciencedaily.com/releases/2015/02/150210083651.htm

‘folic acid’ is made from petroleum

You’re really not familiar with this whole O-chem thingamabob, are you, Gildo?

I am not sure how Folic Acid is usually produced, but I found a patent called Method for producing folic acid US 5968788 A.

This is a biosynthetic process that involves yeast, bacteria, and sugar.

I would assume that Folic Acid, Like Ascorbic Acid, is exclusively produced biosynthetically.

But Gilbert should be thanked for bringing this to our attention; I had no idea that oxidized monoglutyl folate could present challenges for human metabolism.

The government would not have had to do this if everyone ate plants. The entire Atkins fiasco probably created many folate deficiencies.

Folate comes from the latin word folium, which means leaf.

To be defoliated means to be without leaves. When a human is on Atkins they become defoliated.

http://www.google.com/patents/US5968788

But Folic Acid may be synthesized chemically as well. Here is a quote from the patent:

At present, PteGlu of folic acids is industrially produced through chemical synthesis. Briefly, three components of 2,4,5-triamino-6-hydroxypyrimidine, 1,1,3-trichloroacetone and p-aminobenzoylglutamic acid are condensed in the presence of sodium nitrite in a solution of sodium acetate to give a crude product of folic acid, PteGlu, and the product is purified through recrystallization.

I would avoid fortified flour for the ferrous iron and the bromine content anyway. This Folic Acid stuff just gives me another reason to avoid it.

@ Helianthus

My #17 was just a reaction to the celebration of a policy decision establishing a limited check on a relatively harmless health scam, since it is sure never to take effect, and we do indeed face “general access to proper medicine” going into the toilet, as well as, oh, rampant racism, sexism, homophobia, xenophobia… not just unchecked by government but practiced by the federal law enforcement apparatus. [Not to mention even greater abandonment of the alienated white blue-collar economic cast-offs who drank the kool-aid.] Trump may only be president elect, but he is already making policy. Today we learned the next Attorney General will be Jeff Sessions. If you don’t know who he is, save yourself the angst and stay off the Google.

But, ‘rude’ or ‘kind’, I did not want to derail the tread into “another fruitless exchange about whose fault it is.” or even ‘talk about Trump.’ If ya’all want to talk about homeopathy while Rome burns America turns into Germany circa 1933 (great infrastructure initiatives there to, fahren on die Autobahn), go for it. Seriously, I’m still watching basketball and my new ‘find’ Four Nations Rugby Union on the tube, so far be it from me to be self-righteous about how anyone spends their time NOT-talking Trump.

The thing is, I think it’s bad form for folks who want others to approach science issues within the strictures of ‘reality’ to ignore or be cavalier about not-science sectors of ‘reality’, like, in this case, the political realities surrounding the regulation of ‘health products’. So, if we’re going to talk about the FTC recommendations, at a minimum I think that ought to be framed by an acknowledgement that they’re almost certainly DOA, and the discussion should look forward by addressing, ‘OK, where do we go from here?’ in some realistic way.

Whatever the reason, people need to know: The FTC will now regulate advertising claims for homeopathic remedies the same way it treats advertising claims for OTC medications.

If it’s rude to our host to observe how rude that quote is to reality, to note that the only sense I can make of it is an unconsciously generated endorsement of See-No-Evil, Hear-No-Evil denial, then pull out those old Clash records, and put the old VHS of The Harder They Come in the VCR, cause a rude boy I amma be.

OK, since federal regulation of homeopathy will almost surely get trumped in the US, lets talk about sharpening arguments against it to present elsewhere in hopes of curtailing folks from wasting money on nothing and emboldening scammers.

Toward this end, I’ll suggest we prepare for ‘the best cases’ for homeopathy and in defense of critiques against it, even when the actual arguments of actual homeopathy advocates are lame in one way or another.

Playing ‘devil’s advocate’ and looking for weaknesses in the FTC recommendation, I see one (I’ll amp up the language a bit for greater accuracy) ‘ the claims are based only on theories from the 1700s that have been flatly rejected by modern medical science,’

Well, that’s just false. The basis for the claims has now expanded to ‘water memory’, “nanomedicine”, and, of course, Quantum!

Since ‘water memory’ is obviously a figure-of-speech, if that can be explicated literally in any way that’s even remotely plausible, then poof! goes the fundamental skeptic complaint about the infinitesimal or absent ‘active ingredients’ –> total implausibility. And if we define ‘plausibile mechanism of action’ as ‘incapable of exclusion by existing science’ it doesn’t take a genius to make a case for that in regards to homeopathy, since we’ve shifted the focus from the no-longer-there to the water, which IS there. For example, what would a wily homeopath say in response to “If water retained memory, it’d taste like dinosaur piss”? Or, to remove the figurative again, how is a finished homeopathic potion different from the water the homeopath started with, if all the molecules of that water water had in fact been mixed with dog piss before it was distilled? [Hint, as we’ve established, it ain’t because it actually has any of the source HPUS listed ingredients in it. We’re just talking about the water…]

Where we wind up then, sans further argument, is the basic principle of sbm: it shouldn’t be offered unless you can prove it works. Unfortunately, that’s not the existing standard for OTC health products. Homeopathy just gets re-categorized with the ‘natural and/or ‘herbal’ supplements the public thinks it is anyway, and the health claims just need to be reworked with the minor hedges already in use for supplements that haven’t been totally proven as ‘no way this works at all’.

So, as futile as the FTC recommendation may be, it does present a variety of other concerns about homeopathic products beyond “it’s just water’, and some of these seem to me to have good, and not easily assailable, persuasive potential.. What I’m suggesting here is a ‘be prepared’ strategy that looks to identify the most useful of these tacks for different situations/audiences, and looks too for ways to fine tune them and bolster their effectiveness.

@ Sadmar

Since ‘water memory’ is obviously a figure-of-speech

Careful, this started with a paper from Jacques Benveniste which showed activation of immune cells by a hyper-diluted solution of an antibody.
This study was never successfully replicated and there are a number of ways for the initial experience to have led to spurious results. The scientists knew which tubes were the diluted antibodies and which ones were “plain” water, to start with.
There have been since articles trying to show that water can form multi-dimensional structures – and thus “remember” the shape of molecules which were in solution. Except that none of these studies managed to prove that these structures could survive even one millisecond. Now, if we add the shaken violence* of a good homeopathic succussion in the mix…

So, not fully a figure of speech, but also a case of science which turned badly, and now veering toward Cargo cult science.
IOW, for homeopathic proponents, water memory has been proved. Our counter-arguments have to take this into account.

* maybe homeopathic solutions should be stirred, not shaken.

So, not fully a figure of speech, but also a case of science which turned badly, and now veering toward Cargo cult science.

Indeed. sadmar is woefully ignorant about some basic history of homeopathy, isn’t he? When homeopaths say “memory of water,” these days, they mean “memory of water.” On a strictly linguistic basis, you can say it’s a figure of speech, but it’s a figure of speech that conveys a concept that homeopaths not only believe, but have made central to their defense of homeopathy against the rather obvious observation that many homeopathic remedies are diluted far beyond a level where a single molecule of the starting remedy could reasonably be expected to remain.

My own knowledge or lack thereof of the history of homeopathy is irrelevant to the thought experiment, because homeopathy advocates (who are, after all, quacks) are not beholden to that history in making claims, and some have already gone beyond not just Hahnemann, but Benveniste as well.. The question is what arguments might be made, and how those who the debate is intended to influence will evaluate them.

‘The rather obvious observation that homeopathic remedies are diluted far beyond a level where a sufficient number of molecules of the starting remedy remain to reasonably expect any effect beyond placebo’ is indeed a neat, tidy, simple case for a total rejection of homeopathy — not just truth in labeling, but far more serious restrictions if not chucking it out altogether. However, those conclusions rest on the premise that it’s only the remaining ‘stuff’ that could have any effect on whatever physiology is ailing the patient. Put that premise in dispute, and the case isn’t neat, tidy and simple any more. Helianthus’s reply bears that out.

I checked the Wikipedia article on ‘water memory’ linked by Helianthus, which explained that the term was coined by a journalist (I couldn’t find who, and whether the coinage accompanied credulity or skepticism). The closest to a pithy literal summary of Benveniste’s idea I located: “Water could act as a ‘template’ for the [antibody] molecule, for example by an infinite hydrogen-bonded network, or electric and magnetic fields.” I’m not sure if the electro-magnetic fields are different way of explaining the same proposed mechanism as the hydrogen bonds, or a different mechanism. Anyway , the discussion seems to have focused on the idea that those hydrogen bonds “could somehow cluster into long-lived mimics of the antibody.”

Now, if actual proponents of homeopathy are indeed using ‘water memory’ only as a reference to Benveniste’s hydrogen-bond-antibody-template thesis, they do have a challenge to the “it has to be stuff” premise, but not a good one, since that trhesis seems quite concrete and testable, and to have failed all subsequent tests it has undergone.

However, I don’t think the pro-homeos are just bonded to bonding, and I referenced ‘nano-‘ because it was used in this passage from a paper on an RCT of ‘Hyland’s 4 Kids Cold ‘n Cough’ sponsored by… Hyland’s, [quoted in a critique by Clay at SBM]:

There is presently no definitive explanation for the possible biological activity of such highly diluted homeopathic preparations. Current speculation about a mechanism of action centers on the field of nanomedicine with the possibility of immune system modulation.

In the SBM, Science Monkey offered another mechanism explanation attributed to a “Board Certified Homeopath”:

The specific herbs and poisons used in the first dilution determine the velocity and direction of the negative quantum spin of the electrons of the water molecules. This is why we strike the dilutions in such a specific manner. Each successive succussion and dilution transfers these same spin directions and velocities to more and more of the water molecules. When the homeopathic water molecules are ingested, the negative quantum spins of the water molecules interact with the negative energy of whatever is making the patient sick and cancels out the negative energy.

Whether this is real or a Poe, is of course, per Poe, irrelevant. it sounds pretty damn silly.to me. However, as far as our hypothetical debate goes, it’s bad argument because it’s trying to hard. Since homeopathy is a socially established practice, protected by existing statutes/regulations, it’s on ‘defense’. The burden of proof is on the ‘prosecution’. Faced with the claim of ‘it can’t work’ it’s advocates don’t have to establish a provable account of how it does work. They merely have to present a plausible case that it might work, one that its opponents cannot disprove. Now, we here might all agree that this state of affairs is wrong. We might all agree that the sbm principle of ‘only what good science prove works’ should be the standard, but it isn’t.

I’m still not going to do the pro-homeos work for them by detailing how to present an effective argument within these conditions .But Helianthus misses the mark with “For homeopathic proponents, water memory has been proved. Our counter-arguments have to take this into account.” That’s to easy. Our counter-arguments have to take into account any theory of ‘potentized’ water, including especially ones that have some plausiblity-to-non-scietists, and are not subject to DIS-proof with existing science. IOW, what’s the response to “Current speculation about a mechanism of action centers on the field of nanomedicine with the possibility of immune system modulation” if that’s based on the water, not the phantom source ingredient?

Again, IANAS, so there might be a response any reasonable physicist would consider strong. I just have the feeling it wouldn’t be as neat, and defintiive and potentially persuasive to non-scientists as the ‘it’s just water’ argument.

At this point I’ll ask the reader to recall that this thought experiment relates only to the ‘no plausible mechanism’ aspect of the case, and the FTC recommendation includes a number of other tacks against homeopathy that aren’t dependent on this at all, and I advocated a “strategy that looks to identify the most useful of these tacks for different situations/audiences, and looks too for ways to fine tune them and bolster their effectiveness.”

Also, going back to the mechanism issue… While the FTC recommendations address homeopathy generally, the commission bases its brief on it’s responsibility in relation to OTC ‘homeopathic’ products. One of the reasons I repeatedly point out that these are NOT ‘just water’ is that this points to the fact homeopathy is not a unified and univocal field with interests shared up and down the line. These divisions yield vulnerabilities, and the potential of ‘divide and weaken’ by exploiting methods that may set one faction against another. Case in point: it’s one thing to argue, ‘it doesn’t matter the stuff isn’t there anymore because it transformed the water while it was in there’ if that water is actually in the remedy. But it’s another if the remedy is a just 0.85g sucrose, 0.15g lactose and less than a proton of muscovy duck liver.

I checked the Wikipedia article on ‘water memory’ linked by Helianthus

Okey-dokey.

which explained that the term was coined by a journalist

That’s an excellent reason to check the references. I’m just not going to root around in G—le Books for invocations of the same concept.*

Whether this is real or a Poe, is of course, per Poe, irrelevant.

Unless, of course, it’s neither.

One of the reasons I repeatedly point out that these are NOT ‘just water’ is that this points to the fact homeopathy is not a unified and univocal field with interests shared up and down the line.

There are three sets, not necessarily disjoint: True Beliveroonies, scammers, and marks. That’s it. If you think the union of these sets constitutes “socially established,” we have different definitions when it comes to niche crankery.

There is no point to rambling about “vulnerabilities” when the main issue is deceptive labeling.

* But see here, from 1977.

I did check the references, and I tried about 10 links chasing the source of the quote, getting only references to an anonymous journalist. including articles by Beauvais. I did not, for some reason, hit that Google book link that IDs the two reporters from Le Monde who created the headline.

What I mean by ‘socially established’ is “About 3.3 million Americans spent $2.9 billion on homeopathic treatments in 2007, according to CDC,” What I mean by ‘vulnerabilities” (among other things) are means to get convince people who presently don’t see a problem that the advertising is, in fact, deceptive.

You do not get to decide how many sets there are, that always being arbitrary anyway. ‘There are only two kinds of people, those who separate everyone into two kinds of people, and those who don’t.’

“Computer memory” is just a figure of speech, but people have a fairly concrete idea of what they mean by it.

You do not get to decide how many sets there are, that always being arbitrary anyway.

Tell it to Zermelo & Fraenkel.

sadmar, have you ever tried to rip you old CDs into the memory of water? I don’t think the ions will hold much.

“About 3.3 million Americans spent $2.9 billion on homeopathic treatments in 2007, according to CDC,”

Argument from popularity does not mean much… especially when it is just about 10% of the total population.

“What I mean by ‘socially established’ is “About 3.3 million Americans spent $2.9 billion on homeopathic treatments in 2007, according to CDC,””

Out of a population of over 300 million, that is 1%. Very much a fringe activity/belief.

There are probably more people who believe in bigfoot.

“Our counter-arguments have to take into account any theory of ‘potentized’ water, including especially ones that have some plausiblity-to-non-scietists, and are not subject to DIS-proof with existing science.”

I don’t see how immunity to disproof is possible:
give a homeopath some unlabelled magic “memory” water and get them to read it.
If the water has something imprinted on it, then it is obviously readable.

I suspect a success rate of close to “0” would apply.

Well, L.O. f***ing L.

Orac has written countless posts over the years about The One Quackery to Rule Them – excuse me, “niche crankery” very much a fringe activity/belief less important than belief in Bigfoot – excuse me, “soft targets”, and I don’t remember any of you guys ooh-poohing their significance. The replies to the OP make the topic sound kinda important. “A rare win… This is really good… This is awesome news… ”

Oh, there was at least one killjoy upthread who seemed to agree with your suggestion that homeopathy is no big deal:

If ya’all want to talk about homeopathy while Rome burns America turns into Germany circa 1933 (great infrastructure initiatives there to, fahren on die Autobahn), go for it. Seriously, I’m still watching basketball and my new ‘find’ Four Nations Rugby Union on the tube, so far be it from me to be self-righteous about how anyone spends their time NOT-talking Trump.

Oh, wait! That was me! I’m sure sorry I confused you all by deciding – just for the heck of it – to imagine homeopathy is a serious enough business to give a tiddly-damn about how many folks might be sucked into wasting money on ‘homeopathic’ products, such that what the FDA might do about regulating them in response to the FTC recommendations could be worth 2,500 words. I also apologize for not realizing the concept of a ‘thought experiment’ is so alien commenters think _I_ don’t understand that ‘water memory’ won’t hold water no matter how you define it. And I shall don another layer of hairshirt for suggesting that the level of popularity demonstrated by the behavior of 3.3 million Americans constitutes ‘socially established’. Dictionaries: can’t trust ’em, I guess.*

Anyway, as odd as it seems that my role-playing as a modestly clever homeopathy advocates drew out the jabs, I thank you, thank you, thank you!! <3 <3

I knew homeopathy was soft target, fringe belief, niche crankery of sub-Bigfoot-level concern all along. [/sarcasm]

Now I can go back to the replay of the Australia/NZ Four Nations final.

* 'existing for some time, widely recognized and accepted within a group of people broadly distinguished from other groups by mutual interests, and participation in characteristic relationships’.

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