Previously I have written that in my opinion homeopathy has no place in pharmacies. In a recent comment on his blog, Stephen Curry pointed to a BBC News article reporting that the governing body of pharmacists in Northern Ireland has

proposed that patients be told that homeopathic products do not work, other than having a placebo effect

A copy of the draft proposed to form the consultation guidelines for pharmacists in Northern Ireland is available on-line (PDF file, 5 pages including title page).

The opening paragraph notes that given an obligation to provide patients with scientific accurate advice,

the only advice a pharmacist could reasonably give about such products is that they are placebos

It is an excellent document, brief and clear; well worth reading.

Following the lead from the early UK House of Commons Science and Technology Committee report, they (timidly?) do not seek removal of the remedies from the stores. Personally, I feel offering a product you know not to be effective is a lack of care and duty to consumers.

If they are to advise people that they don’t work, why should they offer them for sale?

Placing these remedies alongside those that are effective, and in a place that dispenses prescription medication, gives the impression that sound science backs them, when in practice what sound science backs is that they are only as effective as a placebo.

But it is good to hear that they are considering obliging their members to tell their customers that.

They point out that current licensing is for safety and quality, not if the product has a beneficial effect. I suspect many consumers think that the licensing also conveys that the product is ’good’, i.e. beneficial to them.

I know very little about licensing of medical products, but it does makes you wonder if countries need to only issue licenses when there is evidence demonstrating some minimal level of beneficial effect, or to have different levels of licensing levels with a lower level reflecting a lack of evidential support for beneficial effect and carrying with it an obligation for the product to have on it a disclaimer that (say) ’this product has no evidence demonstrating it gives benefit to patients.’

In one sense the latter is already true, but in a way that I don’t think the public are aware of. There are medicines and then there are remedies, which in various ways are able to avoid the medicines legislation.

In New Zealand edition 6.7 of the MedSafe rulings of when an application for approval is required for a new or changed medicine (.doc file; view as HTML) says that:

4. Homeopathic Remedies

A homeopathic remedy which is prepared under the principle of homeopathy in which the active ingredient to be administered is in a concentration not more than 20 parts per million, and the remedy is labelled only with the name of the active ingredient, trade name (if any) and a statement that it is a homeopathic remedy does not normally require Ministerial consent before distribution. The product label or associated advertising material must not contain therapeutic claims or indications for use.

A homeopathic remedy which is labelled or advertised with claims as to its therapeutic purpose is a medicine and subject to the full control of the Medicines legislation.

Sterile homeopathic preparations intended for injection or for administration to the eyes are regarded as medicines and therefore subject to the full control of the Medicines legislation

[My emphasis added.]

This allows homeopathic remedies without having to meet the medicines legislation, provided they don’t make therapeutic claims.

(Philosophical aside: can something be offered in good faith as a remedy if it has no claim to therapeutic benefit?)

One thing I need to learn is if New Zealand pharmacists are obligated, under law that is, to point out that the homeopathic remedies are ineffective when the customer presents them to the counter to purchase them, and if New Zealand pharmacists are obligated to scrutinise the patient, checking that the purchase is appropriate. (Given that customers are aware they are placebos, how are they ever appropriate to purchase as a remedy?)

Unfortunately I haven’t the time to explore this in any realistic way, but the Pharmacy Council of New Zealand Code of Ethics does include this:

1.3 Medicines and therapies not prescribed by another provider *

Where the patient is seeking to purchase, from the pharmacist or from other personnel for whom he or she has responsibility, any medicine, complementary therapy, herbal remedy or other healthcare product not prescribed by another healthcare provider, the pharmacist must ensure that the patient is provided with credible, understandable information about its safe and effective use, expected outcomes of therapy within the limitations of available information, what to do if side effects occur, storage and disposal requirements, and any significant risk of therapy or insufficiency of evidence about efficacy of the therapy, to allow the patient to make an informed choice.

[My emphasis added.]

A simplistic reading of this would be that pharmacists in NZ are obligated by their Code of Ethics to inform customers that homeopathic remedies are only effective to the level of a placebo and that no therapeutic outcome should be expected of them beyond any placebo effect.

Share your thoughts in the comments below.

Other posts on homeopathy on Code for life:

Time for disclaimers on remedies?, ’alternative’ or not

Homeopathic remedies in NZ pharmacies

Popularity does not mean effectiveness or sensibility

Homeopathy check-up: Not in the health system, disclaimers on labels

Undiluted humour: If Homeopathy Beats Science

Alliances of pharmacists & GPs; opportunities to pressure for removal of useless ’remedies’?

Advertising campaigns: homeopathy or a sceptical series?