Homeopaths respond to the FTC’s new position on homeopathy. The universe laughs.

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.