Humpty Dumpty regulation

The phrase Humpty Dumpty chiropractic cropped up in a Google Alert a few days ago. It was the fitting title of an editorial (cached) in the December 2010 issue of Clinical Chiropractic, which discussed the slippery and nebulous meaning of vertebral subluxation complex (VSC).

For those who don’t remember their childhood, in Lewis Carroll’s Through the Looking Glass, Humpty Dumpty is discussing the meaning of words with Alice. HD remonstrates:

‘When I use a word,’ Humpty Dumpty said in rather a scornful tone, ‘it means just what I choose it to mean — neither more nor less.’

Such equivocation is typical of on-line conversations with chiropractic supporters discussing the VSC, but it applies elsewhere as well.

First decisions

It has been a long and winding road, but we’re finally getting to the end of my complaints after 18 months. Although the General Chiropractic Council (GCC) recently published some of their Professional Conduct Committee (PCC) decisions (‘Notice of Finding’) about complaints I had made about chiropractors misusing the title ‘Dr’ on their websites (I’ll have more to say about them another time), they have just published the first decisions on actual claims.

The two PCC decision notices published last Tuesday are 11 pages long but make fascinating reading. I thoroughly recommend you wade through one to get the full flavour of them.

I’m going to take a look at one: the Notice of Finding for Michelle Carrington (cached). It’s a pretty long, yet interesting, process, and one that needs to be documented. However, the next section cuts to the chase and is a summary of what I believe went wrong and what the GCC needs to correct before any further cases are considered by the PCC. Read that if you read nothing else.

Unacceptable Professional Misconduct?

The process the GCC follow is, in summary: the GCC receive a complaint; the Investigating Committee (IC) investigate it; if the IC considers there is a case to answer, they draw up the allegations; the GCC prosecute the allegations on my behalf before the PCC; the PCC, on the basis of what’s presented in the allegations, consider the allegations and decide whether or not they are proved; if proved, the PCC decide the punishment. (Please note that it is sometimes easy to confuse GCC and PCC!)

It should be noted that the PCC are selected from a pool of 11 non-chiropractic members and 8 chiropractors. However, I do not know which ones heard my complaints. I also note that at the start of December, Sheila Hollingworth, who had been the Chair of the Investigating Committee became a member of this pool of PCC members. I do not know whether she was on the PCC that considered my complaints, but I note the Chiropractors Act 1994 says at Schedule 1:

24.—(1) A person may be a member of more than one statutory committee.

(2) No member of the Professional Conduct Committee or the Health Committee shall take part in dealing with an allegation referred to either committee by another committee if he is also a member of the committee which referred the allegation.

However, for my complaint against this chiropractor, the PCC found that (in summary), although claims were being made that were not supported by high or moderate positive evidence from randomised controlled trials (RCTs), the chiropractor was not misleading the public and therefore not guilty of unacceptable professional misconduct. She was let off with no sanction.

How did this happen? Read below.

As I see it, there are numerous things wrong with the way the case was presented to the PCC and the way the PCC came to their decision.

1. The PCC totally ignored the requirement of the Code of Practice (CoP) C1.6 that:

…information used must be factual and verifiable. The information must not be misleading or inaccurate in any way.

They appear to have decided that, because it’s on paper somewhere, it must be factual and verifiable, but they have completely ignored the ‘misleading and inaccurate’ requirement. Carrington’s observations on my complaint were similar to most of the others I received and it referred to a plethora of guidelines, leaflets, articles, opinion pieces, papers and books (I was not allowed to comment on any of it). In view of the fact there is very significant high quality contradictory evidence, I cannot see how this amounts to a balanced view of all available evidence and is thus a serious breach of the CoP.

2. The GCC did not justify their setting of the threshold for evidence as RCTs, allowing any evidence to be admitted as substantiation.

The GCC interpreted the ‘relevant law’ as being the Consumer Protection from Unfair Trading Practices Regulations 2008 (CPUTR) and opined that ‘advertised claims for chiropractic care must be based on best research of the highest standard’ and that this ‘will almost certainly mean randomised controlled trials that produce high or moderate positive evidence’. However, they failed to anticipate that the PCC could consider that the use of other, far less robust evidence might not constitute ‘a failure to attain the standard of the reasonable chiropractor’.

3. The GCC failed to get a definitive view from Trading Standards or their lawyers as to what standard of evidence was required by the CPUTR.

This is a serious failing. The GCC had had some discussions with Trading Standards (the guardians of the CPUTR) about evidence, but had not justified their ‘interpretation’ of the required standard of evidence. The PCC ‘noted’ the GCC’s interpretation, but didn’t bother to query further. The IC should have foreseen that all the complaints hinged on standards of evidence and should have put a robust case for the prosecution — one that fully protects the public from being misled, not one that could be knocked down with a feather.

4. The PCC failed to form a view of what standard of evidence was required by the CPUTR. Instead, they simply and erroneously decided that, since the GCC had assumed that claims that ‘do not rely on RCT evidence are relying on inconclusive evidence’, there was no threshold at all.

There is probably a whole other blog post that could be written about the CPUTR and what it has to say about misleading actions and misleading omissions. In allowing the Respondent to rely on all sorts of evidence to substantiate the claims, they have ignored the requirements of the CPUTR.

5. In setting the evidence bar so low, the PCC has failed to protect vulnerable members of the public.

Also, the CoP also says:

[advertising] must not, in any way, abuse the trust of members of the public nor exploit their lack of experience or knowledge about either health or chiropractic matters.

By allowing chiropractors to cite any evidence, they have ensured that members of the public will not be given a balanced view of the available evidence. This restricts choice and could lead the vulnerable to believe that chiropractic is effective for many conditions and may delay or prevent them from seeking proper medical advice from a registered medical practitioner. Caveat emptor should not apply to health claims.

6. The GCC submitted that it was reasonable for chiropractors to rely on information published by the GCC in their Patient Information Leaflets.

The GCC’s Code of Practice (CoP) is not binding on the GCC, but it is binding on all chiropractors. The CoP is absolutely clear that it is the chiropractor’s own responsibility to ensure all advertising is compliant with the clause C1.6. It might have been hugely embarrassing and costly for the GCC to admit the information they published in their leaflets was wrong, but that is not the concern of the case against a chiropractor making misleading claims.

7. The GCC only provided evidence for manual therapies and the GCC did not anticipate the question of what else a chiropractor might do.

This is something that should have been anticipated by the GCC because it was mentioned forcefully in many of the observations chiropractors made about my complaints. This has opened a huge loophole, allowing all sorts of misleading claims to slip through. The GCC must now grasp this nettle. If they don’t, they are still left in the position of not having a clue about what their charges do and what the evidence for them is.

8. The PCC declared that ‘general words’ on websites were not claims and therefore could not be verified by RCT evidence.

If they are serious about protecting the public, they need to look at it from the point of view of the public. The GCC need to decide that, in line with the guidance issued by the Advertising Standards Authority (ASA), indirect claims are claims nonetheless. It is not credible that a member of the public, viewing a web page that lauds the experience and training in treating children would not believe that the chiropractor was claiming to treat children.

9. The PCC did not take into account the requirement of complying with all ASA guidance as required by the CoP.

The ASA guidance that chiropractors are required to follow has been consistently ignored by the GCC. It should be remembered that ‘the guidance issued by the Advertising Standards Authority’ consists of the CAP Code and other guidance, including adjudications. This will be the subject of a future blog post.

10. The PCC — somewhat oddly — did refer to the ASA, saying that ASA guidance required robust evidence, but that there was ‘no explicit reference to high or moderate positive evidence from RCTs’.

Whilst the ASA’s guidance may not repeat the phrase the GCC used in the allegation, it is very clear that the ASA have a requirement for a very high standard of evidence. This is formed in their Codes, other guidance and their adjudications and many ASA adjudications have reinforced this. However, it is curious that the PCC used the ASA as a measure of what standard of evidence was acceptable, but ignored the requirement for chiropractors to comply with the guidance the ASA have issued (see point 9).

With each of these issues — and taking them as a whole — it’s an interesting exercise to consider whether Hanlon’s razor can be applied to this contorted mess, but several of these issues amount to errors in law and grounds for appealing the decisions.

The GCC need to show some backbone and provide a decent prosecution case to the PCC for all future cases. It is not too late. The Notices of Allegation have already (conveniently, some might say) been issued to other chiropractors. However, the GCC still have the option to submit applications to amend the particulars to take into account these first decisions and ensure all future cases are prosecuted robustly.

If the GCC does not do this, all credibility as a competent regulator, with a statutory duty to protect the public, is utterly lost.

Abuse of process

Now, let’s get back to the Decision Notice itself and see what went wrong.

There is obviously a need for some legal technicalities. However, after some preliminaries, there is a section titled Abuse of process submission. This concerns submissions by some chiropractors that the whole process should be stayed (ie halted) because of an ‘abuse of process’. This concerns the (flawed) Bronfort Report that the GCC commissioned a year ago to look at what evidence existed for the list of conditions I complained about. The crux of the abuse of process submission is that the Registrar (Margaret Coats) had ‘tainted the process’ with her involvement in obtaining the report.

Until its publication, the GCC seemed to have had little idea about the evidence for any particular condition that their charges were making claims about. This is a disgraceful state of affairs for a statutory regulator, charged with regulating such a narrow field. How could they discharge their duty to protect the public if they had little or no idea of the evidence for chiropractic? How have they managed to regulate chiropractors for the last ten years? Perhaps they relied on what the chiropractic members of their Council and Committees told them? How would they class that level of evidence? If there was ever a case for having a truly independent regulator, this is it.

Having been forced to consider the evidence because of my complaints, they commissioned the Bronfort Report from five chiropractic experts.

However, in this case, the chiropractor concerned didn’t make that abuse submission specifically, but submitted a document headed ‘Further Submissions’. I was told about ‘addendum submissions’ by some chiropractors on 03 November 2010 and I assume these are the ‘Further Submissions’ now referred to. I thought it perfectly reasonable that I be informed what these further submissions were, but was eventually told:

Having taken advice, we will not be supplying you with any detail in respect of the addendum submissions received by the Professional Conduct Committee. Following referral of an allegation to the Professional Conduct Committee, the original complainant is no longer a party to the proceedings and therefore information provided to the Committee, such as submissions, is not disclosed to the complainant.

Hmmm…

The PCC considered the submission to stay the process at a meeting on 17 November and had decided not to. It saw no reason to change that decision, but it wasn’t clear to them whether this chiropractor wanted to renew an application to stay the proceedings. In fact, it made little difference:

Rather than adjourn the meeting in this case, the Committee decided to look first at the strength of the evidence in this case. In view of the outcome of this process, any application for a stay is now likely to be academic. Accordingly, the Committee has determined the case, as set out below.

This does not bode well.

Particulars

The decision notice moves on to the substantive issue: what my complaint was all about. The chiropractor has a right to attend the hearing but she waived that right and it was held ‘on papers’, ie with just the PCC members meeting and without either parties being present (I get no choice in this and I am not asked). Note that, as the quote above says, they are no longer my complaints: the GCC takes them over at this stage and becomes the prosecutor on my behalf, with the chiropractor being the Respondent.

We are reminded that the standard of proof for any allegation to be found proved is the civil standard, which is the balance of probabilities.

The ‘Particulars’ of the allegations are the ‘charges’ that the IC think are appropriate. The PCC have to decide whether each of them is proved or not proved. In summary:

Particular 1: Establishing who the chiropractor is.

Particular 2: That he/she was responsible for the statements on the website I had complained about.

Particular 3: That the highlighted statements were not ‘supported by high or moderate positive evidence from randomised controlled trials’.

Particular 4: That these statements were ‘potentially misleading’.

Particular 5: That these had the potential to ‘put pressure on members of the public…and had the potential to exploit the lack of experience or knowledge of members of the public’.

Once these have been decided, the PCC considers whether this amounts to ‘unacceptable professional conduct’ and what punishment, if any, should be meted out.

In this case, the Respondent admitted the first two particulars and they were therefore found proved. Before looking at the other particulars, we need to look at the statements I complained about and the Bronfort Report.

Claims

The PCC accepted the Bronfort Report as part of the GCC’s submission, but declared that it was just ‘an academic report and not an expert report’.

They said:

This Committee regarded the Report as a comprehensive statement of those conditions for which randomised controlled trial (RCT) evidence exists for the efficacy of manual therapy. The Report provides a summary of the scientific evidence regarding the effectiveness of ‘manual treatment’ in relation to a number of conditions.

At least they noted it was about ‘manual treatment’ and not just chiropractic — see Where the evidence leads.

Getting back to the point of my complaints:

The Committee considered each of the Particulars of the Allegation and in doing so it was mindful of the provisions of Cl .6 of the Code of Practice (effective from 8 December 2005).

The PCC created three categories for the statements made on her website:

(1) Statements which were incapable of being verified by RCT evidence, such as statements about the usual practice of the registrant or general words and headings.

(2) Statements which were capable of being verified by RCT evidence but which, in the opinion of the committee, fell within the categories where the GCC had decided to offer no evidence.

(3) Other statements which were capable of being verified by RCT evidence, typically claims that chiropractic could provide effective treatment for a particular condition.

These three categories are interesting. I’ll pick through some of the choicest claims and see how they have been dealt with by the GCC.

Category 1 claims

The claims on this chiropractor’s website at Haselmere Chiropractic Clinic (current website) that I highlighted in my complaint were:

Back & leg pain, sciatica, “Trapped nerves”, Tension & migraine headaches, Neck, shoulder and arm pain, Hip, knee and foot pain, Tennis & golfers elbow, Jaw pain, Sports injuries, Birth trauma, Colic, vomiting & wind, Feeding problems, Persistent crying, Positional discomfort, Irritability, Crawling and gait problems, Ear infections, Constipation, Sleep disturbance, Asthma, Bedwetting, Dyspraxia, ADHD, Learning difficulties, Cerebral palsy, Cranial support for orthodontic work.

Compare this with the list in the decision notice and see how the PCC categorised the claims.

The claims made on the ‘Welcome‘ page were:

Our team of highly trained and experienced chiropractors offers post-graduate expertise in rehabilitation, antenatal care, paediatrics and cranial work.

This ‘Welcome’ page will usually be the first page a visitor will see: the words ‘rehabilitation, antenatal care, paediatrics‘ are in bold and link to the relevant pages. The PCC have decided that this belongs in Category (1) and they are therefore ‘incapable of being verified by RCT evidence’. Are these claims to treat? If not, why are they there?

But the GCC’s Investigating Committee have already stated to me and many of their chiropractors:

The Investigating Committee did note the reference to ‘Paediatric care’. The Investigating Committee considered that this could give a member of the public reading the webpage the impression that you provide treatment to babies.

It was mindful that there is no high or moderate positive evidence from randomised controlled trials that would support a claim to treat children using manual therapy.

So which is it? Is chiropractic for children incapable of being verified by RCT evidence or is there no RCT evidence that supports chiropractic for children?

However, last time around, the IC concluded:

In the absence of such evidence, it concluded that it could be inappropriate to make such an advertised claim.

Regardless, whether there is no evidence for the treatment of children and babies with chiropractic or whether the GCC think that such things are incapable of being verified, it remains that they are still stating that such claims should not be being made by chiropractors.

Childhood ailments

Before Carrington’s case was considered by the IC, she made some observations on my complaint, and admitted:

This complaint has caused me to reflect on the content of my website and modify it accordingly.

She also received advice from her ‘professional association’ and removed references to the following conditions:

Until such time that more robust research evidence becomes available…

  • sciatica
  • trapped nerves
  • jaw pain
  • colic, vomiting and wind
  • persistent crying
  • irritability
  • feeding problems
  • positional discomfort, crawling and gait problems
  • ear infections
  • asthma
  • bed wetting (nocturnal enuresis)
  • constipation
  • sleep disturbance
  • dyspraxia
  • ADHD
  • learning difficulties
  • cerebral palsy
  • cranial support for orthodontic work
  • abdominal discomfort
  • foetal positioning
  • indigestion
  • preparation for labour
  • aching between the shoulder blades
  • ‘back and leg pain’ replaced by ‘low back and leg pain’

This is an excellent result and many other chiropractors have done the same, leaving fewer opportunities for the public to be misled by claims for which there is no good evidence. It’s just a pity it needed my complaint to make this happen.

So, in the light of what her ‘professional association’ told her and what the IC concluded, what is she currently saying on her website (cached)?

Chiropractic treatment is suitable for children of all ages, including new born babies.

Michelle Carrington is our chiropractor who has a special interest in treating babies, and cranial work.

You are welcome to bring your child along to discuss any specific problems that they are experiencing, and whether chiropractic treatment might be able to help – Ring Reception on 01428 642778 and book a 20 minute “Free Screening” with Michelle.

At Haslemere Chiropractic Clinic we are pleased to offer you chiropractic care from an experienced practitioner with training in techniques specially developed for younger patients. These skills combine to provide a gentle and safe treatment for babies and children.

It looks like there is still more to be done.

Category 2 claims

These were claims for which the PCC said were capable of being verified by RCT, but fell within the categories where the GCC had decided to offer no evidence.

Curious. Why decide not to offer any evidence?

Remember the saga of the Patient Information Leaflets? Some chiropractors I complained about asserted that they were only repeating claims made by the GCC in their Patient Information Leaflet and the BCA in their Happy Families leaflet (cached) leaflet.

I’ve already mentioned the untenable position the GCC would get themselves into if they tried to pursue such complaints. But that legal quagmire is of no concern here. The issue at hand is very simple: whether claims were being made by chiropractors in violation of their Code of Practice. The CoP says that claims must be ‘consistent with the law and the guidance issued by the Advertising Standards Authority’ and that ‘the information used must be factual and verifiable’. There is no additional ‘but it’s OK to repeat claims that the GCC or BCA make whether or not there is any good evidence for them’. That would allow all sorts of claims and is no way to protect the public from misleading information.

Category 3 claims

Having neatly disposed of a whole load of claims, there is one more sleight of hand to be performed.

The Committee went on to consider Particular 3 [that claims were not supported by robust RCT evidence] only in relation to the statements highlighted in Schedule I that fell into Category 3. The Committee noted that the [Bronfort] Report did not identify any high or moderate positive evidence from RCTs in respect of manual therapy to support a publicised claim in respect of these conditions. Therefore, the Committee has found Particular 3 proved in respect of the statements highlighted in Schedule I that fall into Category 3 (as set out in Appendix I).

This is about the claims they decided could be verified by RCT. These claims included golfer’s elbow, jaw pain, abdominal discomfort, poor foetal positioning, sleep disturbance, birth trauma, feeding problems, positional discomfort, irritability and persistent crying and ear infections.

Most of these did not appear in the Bronfort Report, so they were unable to find any relevant RCT for them, as confirmed by the GCC to Skeptic Barista:

Where any condition does not appear in the [Bronfort] report, this is because no relevant randomised controlled trials were identified.

So, the PCC decided that my complaint against these claims was found proved because they were not supported by moderate or high positive evidence from RCTs (Particular 3).

Fantastic!

However — and there has to be a ‘However’ — they added:

However, the Committee is mindful that this conclusion only relates to manual therapies. The Committee has not been provided with any comprehensive evidence about RCTs relating to other forms of treatment practised by chiropractors.

But then they stop and move on to whether making any of these claims, including the ones for which there was no RCT evidence, were misleading. But don’t worry, the question of what constitutes evidence has not been forgotten and I’m sure many of you will see what’s coming…

Misleading?

Were any of the three categories of claims misleading?

After sensibly disposing of the issue of whether someone actually had to have been misled by a claim for the claim to have been misleading, they dealt with the Category 1 and 2 claims.

The Committee found Particular 4 [that the statements were misleading] not proved in respect of the general statements in Category 1. The Committee was not satisfied, on the balance of probabilities, that such statements were inaccurate.

The Committee found Particular 4 not proved in respect of the conditions falling into Category 2 as no evidence was offered by the GCC.

So, the PCC’s decision is that claims such as:

Our team of highly trained and experienced chiropractors offers post-graduate expertise in rehabilitation, antenatal care, paediatrics and cranial work.

Chiropractic treatment is suitable for children of all ages, including new born babies.

Michelle Carrington is our chiropractor who has a special interest in treating babies, and cranial work.

Back & leg pain, Sciatica, “Trapped nerves”, Tension & migraine headaches, Neck, shoulder and arm pain, Hip, knee and foot pain, Tennis & golfers elbow, Jaw pain, Sports injuries, Many other joint and muscle disorders.

…were not misleading, despite the GCC and Bronfort saying that there was no good evidence to substantiate such claims.

What does it take for a chiropractor to have been considered to have mislead the public? Suggestions on a postcard, please.

But Category 3 is where it gets even more interesting.

The Committee concluded that the statements highlighted in Schedule 1 which fell into Category 3 were not misleading. These were statements to the effect that chiropractors provide treatment for the conditions in question. The Committee considered the submissions made by the Respondent in relation to these conditions. In each case the respondent provided evidence that there was support from a variety of sources for the chiropractic treatment of these conditions. These included undergraduate and postgraduate training and/or materials by the Anglo European College of Chiropractic (“AECC”); research, peer reviewed journals and publications from a variety of bodies including the GCC and the British Chiropractic Association (“BCA”).

On this basis, the Committee has concluded that it was not misleading or potentially misleading for the Respondent to make the statements highlighted in Schedule 1, which fell into Category 3 and, therefore, this Particular is not found proved.

So, even though the PCC decided it was proven that there was no good evidence for the treatment of these conditions with chiropractic, they decided that making these claims was not misleading. And they decided this because the Respondent had provided evidence that there was support for chiropractic for these conditions. And this ‘evidence’ included AECC training materials, ‘research’, peer reviewed journals and leaflets from the GCC and the BCA.

Evidence? What evidence?

So what the decisions boil down to is what counts as evidence. Is it the robust scientific evidence that the ASA require for advertising claims; the ‘randomised controlled trials that produce moderate or high positive evidence’ of the GCC’s IC; or is it the  leaflets, case studies and teaching materials the PCC would have us believe is all that is required? The PCC have set out an unbelievably low threshold — in fact, it’s difficult to see how they could have set a lower one.

The ASA have far higher standards; why should a statutory body, charged with protecting the public set such low standards?

Does this mean that chiropractors now have carte blanche to advertise whatsoever they want? It would seem so. But this cannot be good for the public: if such a low threshold continues, then the public is not being protected. Chiropractors can claim to treat anything. Presumably they could claim to treat ADHD? After all, there is evidence in a peer-reviewed journal to support it, so (presumably) the PCC would be quite happy with such a claim.

Chiropractors may rejoice at this decision, but I don’t think they should be popping champagne corks — or backs — just yet.

Unacceptable Professional Conduct

The PCC then move on to deliberating whether the particulars they have found proven (that the claims highlighted were not supported by high or moderate positive evidence from RCTs) amounted to unacceptable professional conduct.

They did not.

The problem was that, although the GCC argued that there was no robust evidence (ie from high or moderate positive evidence from RCTs, as the GCC had stated in the particulars), there was still other evidence. And because there was other evidence, and because the CoP didn’t specifically demand robust evidence, the charge of not having robust evidence could not amount to unacceptable professional misconduct.

That was a whirlwind tour of one decision but the GCC, as prosecutors of all the cases, now have a dilemma. They could just sit back and let the remaining cases go ahead on the same basis and, no doubt, the PCC would decide them all the same way and all the remaining 500-odd chiropractors would be found not proven.

Humpty Dumpty had a great fall

I would urge them to examine the failings of the cases so far and decide whose interests they are there to protect. And, to protect the public, the question the statutory regulator of chiropractors has to ask itself — and then comprehensively answer — is: what exactly are the meanings of the words chiropractic, evidence, regulation and protecting the public?

‘You seem very clever at explaining words, Sir,’ said Alice. ‘Would you kindly tell me the meaning of the poem called “Jabberwocky”?’

‘Let’s hear it,’ said Humpty Dumpty. ‘I can explain all the poems that were ever invented — and a good many that haven’t been invented just yet.’

This sounded very hopeful, so Alice repeated the first verse:

‘Twas brillig, and the slithy toves
Did gyre and gimble in the wabe;
All mimsy were the borogoves,
And the mome raths outgrabe.

‘That’s enough to begin with,’ Humpty Dumpty interrupted: ‘there are plenty of hard words there. “Brillig” means four o’clock in the afternoon — the time when you begin broiling things for dinner.’

‘That’ll do very well,’ said Alice: and “slithy“?’

‘Well, “slithy” means “lithe and slimy.” “Lithe” is the same as “active.” You see it’s like a portmanteau — there are two meanings packed up into one word.’

Quite.

46 thoughts on “Humpty Dumpty regulation”

  1. You think she’ll have sour grapes because she’s had to remove references to that huge list of ailments she was implying she could treat? Let’s have a look it again:

    sciatica
    trapped nerves
    jaw pain
    colic, vomiting and wind
    persistent crying
    irritability
    feeding problems
    positional discomfort, crawling and gait problems
    ear infections
    asthma
    bed wetting (nocturnal enuresis)
    constipation
    sleep disturbance
    dyspraxia
    ADHD
    learning difficulties
    cerebral palsy
    cranial support for orthodontic work
    abdominal discomfort
    foetal positioning
    indigestion
    preparation for labour
    aching between the shoulder blades

    Hmmm….yes. You’re probably right. Mortified too at the sight of your…ahem…’regulatory body’ being exposed as a Mickey Mouse organisation, I should think.

  2. That is scandalous. So, basically it all boils down to this…

    With regard to chiropractors:

    • The Code of Practice is absolutely clear that it is the chiropractor’s own responsibility to ensure all advertising is compliant with the clause C1.6. – there being no additional “but it’s OK to repeat claims that the GCC or BCA make whether or not there is any good evidence for them”.

    With regard to the GCC:

    • Although it has been discharging its duty to protect the public by regulating chiropractors for nearly 10 years, until the Bronfort Report was published it seems it had little idea about the evidence for any particular condition that its charges were making claims about, and a huge loophole remains due to it only providing (flawed) evidence for manual therapies and not for what else a chiropractor might do.
    The threshold of evidence required by the ASA, TS and CPUTR appears to never have been ascertained by the GCC, and, as a result, the PCC has decided that there’s no threshold.

    With regard to the PCC:

    • It appears to have totally ignored the requirement of the Code of Practice that information supplied by chiropractors must not be ‘misleading or inaccurate’, and has used the ASA as a measure of what standard of evidence was acceptable. However, it appears to have ignored the requirement for chiropractors to comply with the guidance the ASA have issued.
    • In measuring the acceptable standard of evidence required by the ASA, the PCC claimed that ASA guidance requires *robust* evidence, but that there is no ‘explicit’ reference to high or moderate positive evidence from RCT’ (despite it being very clear that the ASA have a requirement for a very high standard of evidence which is formed in their Codes, other guidance and their adjudications and many ASA adjudications have reinforced this).
    • Regarding chiropractic for children, it is unknown which of the following two claims is the correct one: The PCC claims chiropractic for children is incapable of being verified by RCT evidence; but the IC says there is no RCT evidence that supports chiropractic for children.

    Outcome:

    • What the PCC had to determine was whether the claims (direct or indirect) being made by chiropractors were in violation of their Code of Practice which says that claims must be “consistent with the law and the guidance issued by the Advertising Standards Authority” and that “the information used must be factual and verifiable”.
    • Although the GCC provided evidence that there was no robust evidence (ie from high or moderate positive evidence from RCTs, as it had stated in the particulars), there was still *other evidence*. Because there was *other evidence*, and because the Code of Practicedidn’t specifically demand robust evidence, the charge of not having robust evidence could not (in the PCC’s eyes) amount to unacceptable professional misconduct.

    If that’s correct, then Zeno seems to be spot on with his observation that the exact meanings of the words ‘chiropractic’, ‘evidence’, ‘regulation’ and ‘protecting the public’ must be clearly defined by the GCC – as a matter of urgency.

    BTW, fantastic work, Zeno!

  3. I believe the ASA will cover websites from early next year? Will this offer an opportunity to submit a new raft of complaints to an authority that might take real action over the new, more-weasely-worded, claims?

  4. Excellent post Alan. I find it extremely difficult to understand how they could possibly get around their requirements for chiropractors to follow ASA guidelines. Come March, when the ASA regulates claims made on web sites, a large number of ASA complaints which will no doubt produce adjudications can then be followed up with GCC complaints.

  5. The GCC’s actions are really quite extraordinary. It really did not seem possible that they could not find that the rules had been transgressed by the various claims cited in your complaints. As far as I could see, the wriggle room would be in how they dealt with those transgressions. Given what it takes to be struck off as a doctor or vet it seemed likely that the Respondents would be given formal advice on conduct or some sort of mild ticking off, but in terms of the wider campaign against unsubstantiated chiro claims we would have obtained a significant victory. Instead, it looks like the GCC has distorted its own rules and create a series of internal contradictions in the stance they have chosen to adopt in order to avoid saying that the Respondents were at fault and having the spotlight thrown straight back onto things like their own leaflets, which surely the Respondents would have cited in pleas of mitigation when arguing that the penalty imposed should be minimal, “It’s not just me, Guv, I never realised. Even the GCC was at it.”

    Can the complainant, i.e. Zeno, appeal?

  6. Great work. I am not a bit surprised at the lack of clarity on CPUTR standards of evidence. The regulations themselves, and the attached guidance, are reasonably clear, but Trading Standards officers can be staggeringly obtuse and ignorant. Some of them still cling to the old Trade Descriptions Act definitions even though they have been repealed.

    I am not surprised either at the GCC’s abuse of basic logic and due process, as the GMC can be pretty poor also. I have direct personal experience of a complaint for which the GMC’s Fitness to Practice panel completely ignored its own written procedures and exonerated a respondent, despite extensive documentary evidence from another public body. The GMC never responded to our protestations about that. It’s clear that the entire field of health care professional regulation is hopelessly inadequate at protecting the public.

  7. Been following your blog for a while and this article is astonishing.

    it does seem that the GCC are more concerned with the fate of the chiros than with protecting the public, which is the opposite of what they should be doing.

    is the GCC actually fit for the purpose of prosecuting these claims or is it too entangled (partially responsible) due to its own incorrect information sheets? Is it this conflict of interest that had turned this into a farce? and if they are too conflicted who regulates the regulators behavior?

    keep up the good work Zeno.

  8. BSM wrote:

    Can the complainant, i.e. Zeno, appeal?

    Interestingly, the comments made to me by those that have followed this business are more along the lines of “Can’t the chiropractors sue this bloke for causing trouble once it’s clear that they’re not guilty and have been exonerated?”

  9. Zeno,

    She also received advice from her ‘professional association’ and removed references to the following conditions until such time that more robust research evidence becomes available…

    This is an excellent result and many other chiropractors have done the same, leaving fewer opportunities for the public to be mislead (sic)by claims for which there is no good evidence. It’s just a pity it needed my complaint to make this happen.

    I find your response to this quite interesting. I can see why you would be happy that this and other chiropractors have removed certain claims from their websites, after all, wasn’t that the point of the exercise? But it seems that you are unhappy this chiropractor hasn’t been punished.

    That suggests a degree of malevolence that contradicts the notion of humanism.

  10. @David,
    I personally read no malevolence in the work above but accept that the course of action taken by Zeno may appear that way to you. I personally think that the exercise is primarily an intellectual one and does actually not do anything that most chiropractors were not already aware of but were too busy/distracted/lazy/apathic to do anything about. Some people would argue that the structure of power in the GCC is intimidating and does not allow for the little individual clinician to take action but eventually the false structure will collapse (as it always does-which I think is very much a humanist and babylonic notion). I think chiropractors can look at this situation and get bogged down with what people in the blog-o-sphere think they know and assume that this is the held view. I would urge every chiropractor to focus on what they are here to do as clinicians and that is to make individual patients better, regardless of what Blue Wode, the GCC, Brontfort et al or the BCA think, whilst not going into denial about the acute lacking in evidence. It is quite simple indeed: claims have to be backed by evidence, the evidence for certain number of things just isn’t there, therefore certain claims cannot be made. This in itself does not mean that there wouldn’t possibly be any evidence for these things were the studies conducted at all or conducted correctly, just that there isn’t any right now. Bottom line is that if we get the patient better, the patient will be happy and will refer others to us. If they in turn get better they will do the same. All this means is that the development of a chiropractic clinic on the basis of certain advertised claims is dead and this only serves to reinforce what all good chiropractors I know have done: build practices on word of mouth. The growing of a chiropractic clinic on certain advertised claims should simply never have been born. Until evidence comes to light as to why and in which cases they are getting these results, it is in my opinion the only thing that can be done truthfully.
    Some will argue that the lack of evidence is meaningful. It isn’t, it is just symptomatic of where we’re at as a profession. Some will argue that in the face of lack of evidence risk becomes a serious issue. It doesn’t, it just puts the onus on the clinician to be open and honest about the state of evidence and allow the patient to make informed choices and take informed risks. All in all it just means that we have to work better and harder for our reputations and that cannot be a bad thing.
    Regards,
    Stefaan Vossen

  11. Stefaan,

    I agree with you.

    You’re quite right, chiropractors have got into the habit of namimg conditions they treat because people quite often don’t realise the range of problems that chiropractic can help with. However, the basic principle remains that chiropractors simply improve and maintain function, irrespective of the symptoms that are expressed by the dysfunction.

    It does seem though, that whatever problems might exist with making specific claims, there is a desire among “sceptics” for retribution rather than a simple clarification of the evidence for making certain claims.

  12. David,

    The trouble is the evidence that chiropractic is effective is so far outweighed by the evidence it is not effective (both in quantity and quality) that “clarification of the evidence for making certain claims” would result in their being no good evidence for efficacy whatsoever!

    If a practitioner of a different branch of medicine (or “medicine”) was claiming to treat conditions with no proof of efficacy then we would want them to be punished to. It is effectively a form of fraud!

  13. @David
    Funny how these things go full circle isn’t it? For the chiropractors: you may recognise in this the old proverbs of the “dinosaurs of chiropractic” like “find it fix it and leave it alone” or another gem “look after the patient and the patient will look after you” and finally “adjust the subluxation and the rest will take car of itself”.
    Good old dinos! The problem really is that those people who don’t understand what these things really meant didn’t do very well in practice and ended up employing practice management consultants and non-sense technology creating a completely fallacious understanding of their practice. All this stuff rolled in together over two or three decades created the perfect circumstances for Zeno, Simon Perry and Andy to discover a scenery that was not only filled with error but also deluded. For me, personally, whatever their intentions, I am grateful to them, as the result of tehir efforts could be that chiropractic now stands a chance to actually get back to doing what it is supposed to do.
    Kind regards,
    Stefaan

  14. @Stefan

    If you’d actually bothered to read the article, you would have found links to Cochrane reviews for:

    “Spinal manipulative therapy for low back pain”,
    “Combined chiropractic interventions for low-back pain”,
    “Manipulation or mobilisation for neck pain”,
    “Manual therapy for asthma”,
    “Spinal manipulation for primary and secondary dysmenorrhoea” and “Non-surgical treatment (other than steroid injection) for carpal tunnel syndrome”.

    Concluding, respectively, that “The review shows that while combined chiropractic interventions slightly improved pain and disability in the short term and pain in the medium term for acute and subacute low-back pain, there is currently no evidence to support or refute that combined chiropractic interventions provide a clinically meaningful advantage over other treatments for pain or disability in people with low-back pain. Any demonstrated differences were small and were only seen in studies with a high risk of bias. Future research is very likely to change the results and our confidence in them. Well conducted randomised trials are required that compare combined chiropractic interventions to other established therapies for low-back pain.”

    And no evidence for any efficacy for the other treatments.

    “It” is advertising treatments claiming them to be effective for certain conditions, with no evidence to suggest that they are effective.

  15. @Matt
    ah you see the thing is that what those studies researched is not actually chiropractic practice, but that’s ok, we now know that generically manipulating backs to alleviate conditions which may have nothing to do with spinal dysfunction don’t elicit significant stats. But that just isn’t chiropractic practice.
    I fully agree that “it” is effectively a form of fraud, let’s punish those fraudsters!

  16. Good work Alan.

    #Although the General Chiropractic Council (GCC) recently published some of their Professional Conduct Committee (PCC) decisions (‘Notice of Finding’) about complaints I had made about chiropractors misusing the title ‘Dr’ on their websites (I’ll have more to say about them another time),#

    I have complained three times to the ASA about “Dr” Joanne Middleton (Chiropractor) who not only calls herself “Dr” on her website but also in the phone book and the local newspaper.

    All I’ve had back from them are acknowledgements of my complaints and she continues to be allowed to deceive people.

  17. Oh and in case anybody checks the GMC website, there is a Joanne Middleton registered but I can assure you it’s not our Joanne Middleton.

  18. Stefaan Vossen wrote:

    I would urge every chiropractor to focus on what they are here to do as clinicians and that is to make individual patients better, regardless of what Blue Wode, the GCC, Brontfort et al or the BCA think, whilst not going into denial about the acute lacking in evidence.

    It’s interesting that Stefaan acknowledges the “acute lacking in evidence”. It makes one wonder precisely what chiropractors are being taught during their 4-5 years of training. A (real) doctor of neuroscience recently wrote to the Welsh Institute of Chiropractic (WIoC) at the University of Glamorgan to express his concerns about the claims and information available (or not, in some cases) on its official website. He requested clarification as to the website’s accuracy/intent. You can read his letter here:
    http://sciencedigestive.blogspot.com/2010/06/email-to-university-of-glamorgan.html

    Apparently the WIoC’s reply, which hasn’t been published, was wholly evasive in that it sent a run down of the modules taught, but not what was actually in them.

    Stefaan Vossen wrote:

    Bottom line is that if we get the patient better, the patient will be happy and will refer others to us.

    But the patient getting better may have had nothing to do with chiropractic. For example, the following factors could very easily be at play:

    The condition may have run its natural course
    Many conditions are cyclical
    Spontaneous remission
    Some allegedly cured symptoms were probably psychosomatic to begin with
    Misdiagnosis

    Also, you seem to be forgetting that most people lack the basic knowledge and critical thinking skills to make an informed choice when deciding whether a highly touted healthcare product is a sensible buy or not.

  19. Stefaan Vossen wrote:

    If they [patients referred by other patients] in turn get better they will do the same. All this means is that the development of a chiropractic clinic on the basis of certain advertised claims is dead and this only serves to reinforce what all good chiropractors I know have done: build practices on word of mouth. … Some will argue that the lack of evidence is meaningful. It isn’t, it is just symptomatic of where we’re at as a profession.

    And where chiropractic is at as a profession could very well be where it is going to stay – dependent on the ritual induced placebo of its manipulative techniques, as described not so long ago by a senior lecturer at the Anglo European College of Chiropractic:
    http://tinyurl.com/32l9o5e

    Indeed, David Byfield, Susan King, and Peter McCarthy, chiropractic academic staff members at the University of Glamorgan, seem to support that view:

    “…it has [also] been shown that patients are very pleased and satisfied with chiropractic care whether they get better or not….Furthermore, it has been said that chiropractic’s greatest contribution to health care has been the development of a solid doctor-patient relationship. So, let’s not kid ourselves. It may not be what we say…..but simply the way in which we say it that stimulates some measurable change in patient’s general health care status. Some studies support this view.”

    http://tinyurl.com/32odolf

  20. Stefaan Vossen wrote:

    Some will argue that in the face of lack of evidence risk becomes a serious issue. It doesn’t, it just puts the onus on the clinician to be open and honest about the state of evidence and allow the patient to make informed choices and take informed risks.

    Some might ask what’s been preventing chiropractors from being open and honest all along. After all, its lack of evidence and its risks have been published in the medical literature for some time now.

  21. @BW
    you could be very right on all of the comments, but then this is what I, and many colleagues of mine have been telling you for a very long time now, and it’s all wearing a bit thin. But it is very good to see that you are finally actually reading what is being written, Well done!
    Stefaan

  22. An excellent post, the humpty dumpty quote seems very appropriate!

    Problems are always going to exist in chiropractic as long as the question of what constitutes good, robust evidence is left open to interpretation by individuals. Particularly so when those individuals have a vested interest (in this case a commercial one) in accepting any evidence that supports their cause and rejecting non supportive evidence (often of far higher quality).

    This becomes even more difficult when there is a huge division between groups of chiropractors in the beliefs of what chiropractic actually is! Many chiropractors have differing (and in some cases opposing) views on a number of topics that are quite fundamental to chiropractic, so the evidence each one needs to justify their position will differ accordingly.

    That is why there needs to be unambiguous guidance issed by regulatory bodies and that guidance needs to be effectively enforced. Not everybody will like it, but at least there would be something resembling regulation and everybody would know the boundries. The guidance can always be adjusted as new evidence (of an acceptable quality) comes to light.

    The GCC’s decisions show that an organisation coming under scrutiny, both from inside and outside the profession, cannot be trusted to act as a reliable prosecutor, judge and jury.
    In the interests of the public ( and dare I say it the chiros ) complaints need properly investigating and people need to have confidence in the results.

    At some level there are always going to be those who disagree with a decision or the arguments used to reach those decisions, but there should at least be an open, consistent and reliable process in place by which those decisions are made.

  23. @David: (Wednesday 15 December 2010 at 09:15)

    You say: “Interestingly, the comments made to me by those that have followed this business are more along the lines of “Can’t the chiropractors sue this bloke for causing trouble once it’s clear that they’re not guilty and have been exonerated?”

    So what you are saying is that no one should question chiropractors? The arrogance (and sheer stupidity) is truly shocking!

  24. Stefaan Vossen wrote:

    @BW you could be very right on all of the comments…

    In which case it is of some concern that the GCC is currently approaching UK University Deans with a view to creating more chiropractic degrees:
    http://www.gcc-uk.org/files/link_file/C-120510-Open1.pdf

    Item C-120510-17(a)

    Minutes of Education Committee 17 November 2009

    Members noted the content of the minutes, and in particular that as a result of the chair’s contact with the Council of Deans of Healthcare network ( http://www.councilofdeans.org.uk/ ), several institutions had expressed an interest in exploring the development of a chiropractic degree programme.

    Item C-120510-17(b)

    Minutes of Education Committee 13 April 2010

    Members noted the contents of the minutes, and in particular that representatives of two institutions in north west England had visited the Welsh Institute of Chiropractic. The purpose of the visits was to inform the early stages of their exploration of the feasibility of developing chiropractic degree programmes.

    Humpty Dumpty degree courses?

  25. Andrew Gilbey wrote:

    @David: (Wednesday 15 December 2010 at 09:15)

    You say: “Interestingly, the comments made to me by those that have followed this business are more along the lines of “Can’t the chiropractors sue this bloke for causing trouble once it’s clear that they’re not guilty and have been exonerated?”

    It’s true. That is what people who understand and have benefited from chiropractic have been saying to me. That’s not what I said, simply what others have said.

    Andrew Gilbey wrote:

    So what you are saying is that no one should question chiropractors?

    No, that is not what I’m saying. Only an idiot would draw that conclusion from what I wrote.

    Andrew Gilbey wrote:

    The arrogance (and sheer stupidity) is truly shocking!

    I couldn’t agree more.

  26. @david

    Well actually, you didn’t say “people who understand and have benefited from chiropractic have been saying to me”, you actually said “those that have followed this business”. I think it was reasonable I took that to mean other chiropractors. And surely the bottom line is that most chiropractors have and many still are making or implying claims that are not supported by sound scientific evidence.

    Care to comment about the conclusions of the ADHD ‘study’ I mentioned before your last post?

  27. The issue of advertising and scientific evidence goes much further than chiropractic or even CAM. I suggest you google colic and physiotherapy, you may be surprised. It is also interesting that the level of evidence “high or moderate” set by the GCC is not explicitly that used by the ASA. If we take this further many claims used for physiotherapy would also be inappropriate. Additionally, many private hospitals are offering spinal facet joint injections for low back pain yet this treatment is not supported by robust evidence (see NICE low back pain guidance).

    We need a sensible approach to this so that all professions take the same view and we have a level playing field rather than starting a vendetta against a particular profession. If people like Zeno really want to make a difference then they should try an engage with chiropractors and others so that changes are made that are truely in the public interest.

  28. Zeno, can I ask if a Sheila Holingsworth was on the PCC panel for any of the cases processed so far?

    And if so, are you aware that until a few weeks ago, she was chair of the Investigating Committee?

    I wonder if it is legal for the Chair of the committee that investigated a complaint to be part of the PCC pool that hears the same complaint?

    Maybe Jakc of Kent could advise?

  29. dizzyblonde

    I got this from the GCC:

    I can confirm that as part of segregation of duties, Sheila Hollingsworth [sic], has not and will not be empanelled to consider any allegation referred to the Professional Conduct Committee by the Investigating Committee, during the period when she was a member of the Investigating Committee. This extends back to August 2009 when she was appointed as the Chair of the Investigating Committee.

  30. andy wrote:

    “The issue of advertising and scientific evidence goes much further than chiropractic or even CAM. I suggest you google colic and physiotherapy, you may be surprised.”

    OK, let’s have a look using google.co.uk:

    >physiotherapy colic About 51,300 results (0.14 seconds)

    Tried it again but this time subtracting a couple of other terms:

    >physiotherapy colic -chiropractic -osteopathy About 21,900 results (0.21 seconds)

    In the interests of balance, here are some more results:

    >chiropractic colic About 251,000 results (0.06 seconds)
    >chiropractic colic -physiotherapy -osteopathy About 228,000 results (0.19 seconds)
    >osteopathy colic About 195,000 results (0.14 seconds)
    >osteopathy colic -physiotherapy -chiropractic About 169,000 results (0.13 seconds)
    >chiropractic colic -singh -bca -libel -court -guardian -article -bogus About 160,000 results (0.14 seconds)
    >physiotherapy colic -singh -bca -libel -court -guardian -article -bogus About 19,900 results (0.16 seconds)

    Nothing very surprising so far. I decided to have a closer look at the first ten practitioners’ websites that the first (physiotherapy colic) search brought up. Out of these ten practitioners’ websites, the number featuring physiotherapists who claimed to treat colic was five. Of these:

    One sole practioner, a physio, claimed to have “sorted out” out a baby’s “colic problems” using “connective tissue manipulation”.
    One sole practitioner had qualified (abroad) as both a physiotherapist and an osteopath. She claimed to treat infantile colic with cranial osteopathy.
    One sole practitioner was a physio who claims to treat colic with cranial osteopathy and mentions she has “attended training” in the latter.
    One sole practitioner was a physio who used a range of quack therapies (including craniosacral and reiki) and claims to treat all manner of ailments including colic.
    One practice comprised just two physios, both of whom claimed to treat colic but don’t say how.

    The remaining five websites advertise practices that are staffed by a team of two or more practitioners, including a physio and an osteo. All of these claimed or implied that infantile colic could be treated with cranial osteopathy; at one of them the cranial osteopathy is “combined with visceral treatments”.

    Nothing is particularly surprising about any of the above so I have to wonder what Andy’s point is. It will come as no surprise to anybody that some healthcare practitioners who are in private practice make misleading claims on their websites. They do it because they can and that is why an initiative like Nightingale is long overdue.

  31. Andy also wrote:

    “We need a sensible approach to this so that all professions take the same view and we have a level playing field rather than starting a vendetta against a particular profession. If people like Zeno really want to make a difference then they should try an engage with chiropractors and others so that changes are made that are truely in the public interest.”

    I’m sure Zeno is flattered at Andy’s high estimation of him but I’m mystified as to why he thinks Zeno or any other member of the public should have any say in any changes made involving chiropractors, beyond having the right to complain when they make misleading claims in their self-promotion.

    And, given that Zeno and other complainants are only members of the public, I’m mystified as to why the ambassadors for the chiro profession who comment here and elsewhere think an appropriate and professional response to having their misleading claims complained about is to launch repeated attacks on the character and integrity of Zeno and anyone else who has the temerity to criticise chiropractors for the misleading claims they make.

    As for the need for a “sensible approach”, given the evident disunity among chiropractors themselves, isn’t the suggestion that they will ever manage to take the same view as each other, let alone any other profession, a bit ambitious?

    How is the playing field not level? I presume private osteos and physios could stand in shopping malls haranguing hapless shoppers and have national weeks promoting themselves if they wanted to. The point is that chiropractors, more than any other healthcare profession, have drawn attention to the fact that they promote bogus therapies on their websites and elsewhere. (Homeopaths aren’t far behind, IMO.) So what appears to be a “vendetta against a particular profession” to them is simply the consequence of their waving their misleading claims in our faces more than anyone else. I don’t doubt that “many private hospitals are offering spinal facet joint injections for low back pain yet this treatment is not supported by robust evidence.” But I have yet to see a single one accost people outside Sainsbury’s to tell them about it.

    Interestingly, homeopaths also think they are being singled out. Try googling “first they came for the homeopaths” and you’ll realise chiros are not the only ones with a persecution complex. Why is it so difficult for both groups to realise it’s all about how visible they are?

  32. @Skepticat

    There are some physiotherapists that practice magic medicine in the form of cranio-sacral therapy, Reiki and reflexology. Very odd for me to witness this considering physiotherapy is supposed to be a science based profession, but you are right to pojnt out that their “advertising” is modest compared to chiropractors.

    However, it might also be worth mentioning the thousands of physiotherapists who practice TCM acupuncture on the NHS. It would be bad enough if they all only believed in the endorphin theory (given that there is no evidence that enough endorphins can be produced by needling), but is is depressing to hear physios talking about Qi and ‘weak spleens’!

    Remember the tax payer is paying for all this.

  33. @malucachu

    Interesting. I didn’t know physios practised acupuncture at all, let alone on the NHS though I was aware that the NHS funds acupuncture and a whole range of other unsupported therapies at the RLHIM and have in fact submitted a number of complaints to the ASA about the content of their leaflets advertising these.

  34. Steefan, you seem to miss a double standard here with regard to claiming to treat and fraud.

    Proper doctors dish out painkillers for arthritis, that’s not treating the cause either, there is no proof of efficacy either with regard to painkiller treatment being synonymous with cure of arthritis.

    With regard to fraudulent advertising the flu jab has no efficacy evidence either, quite the opposite and we are all paying for a massive toxic placebo here, surely that’s more important than privately funded chiropractors.

  35. Skepticat, the vast majority of alternative practitioners don’t need to advertise what they do, their reputation is what brings in the work. I don’t know anyone who has been affected by this blogslaught, quite the opposite as the public are learning that centralised, organised state regulation is quackery. There is no evidence that governmental control has made much safer, particularly medical science, why should anyone trust a politician, researcher or WHO exec when they are all drinking from the same well.

    You won’t ever have an impact on good practitioners doing good work however much you don’t like it. I am sure you have freaked out a few people but the vast majority watch this kind of Mary Whitehouse stuff with large amusement.

    Skepticat we are also paying for the annual flu jab, the EBM for efficacy is non existent, this is far more worrying than a few physios playing pins and needles surely.

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