Mortar with medicine cross, fresh herbs and essential oil bottle

Mortar with medicine cross, fresh herbs and essential oil bottle“Your writing does not even begin to approach a professional standard,” so say the authors of the Swiss Health Technology Assessment (HTA) on Homeopathy to ASA Chief Executive, Mr Guy Parker.

As to ASA’s ‘bizarre’ claim that the HTA’s main conclusion was based on a re-working of just one negative analysis by Shang, the HTA authors  told them that ASA Ltd. needed to do no more than glance through their book’s contents pages to reveal the falseness of ASA’s absurd claims about it.

The letters in full:

Dear Mr. Parker,
We have read your ‘analysis’ of our ‘Homeopathy in Healthcare’ Health Technology Assessment: we find your writing frankly disquieting.
In your ‘discussion’ of homeopathy’s success in treating chronic disease, you say, bizarrely, that our HTA contains no ‘robust evidence’ such as RCTs. In fact, pages 130 – 140 of the HTA, for example, discuss 17 homeopathic RCTs, all conveniently summarized on page 207. Pages 103 – 106 refer to homeopathic RCTs in the hundreds.
It is certainly correct that RCTs are generally accepted as a ‘gold standard’ in conducting clinical trials. This is however only a convention (i.e. an ‘agreement’) and, albeit science based, is not free from a considerable quantity of biases. Notwithstanding that, our HTA book in any event fully satisfies the requirements of RCT research conventions.
Additional to that, Chapter 5 of Homeopathy in Healthcare examines, within the scientific paradigm of Evidence-Based Medicine, the problems and likely inherent bias of RCT methodology. This is a chapter of central importance which we would expect you to take seriously. You are of course entitled to examine and debate the points that we make, provided you do so from a logically and scientifically evidenced rationale. But to sweep this whole debate under the carpet as if it doesn’t even exist is patently unacceptable: to furthermore airbrush out of existence, so it would appear, all the RCT research that Homeopathy in Healthcare contains is deeply disturbing.
Your ‘analysis’ of our work becomes still more extraordinary. You say our ‘main conclusion regarding efficacy was drawn from a reconsideration of a previous meta-analysis of qualifying trials which found no significant difference between placebo and homeopathic treatment’ (seemingly referring to Shang et al).
Even a glance at our contents page would reveal the falseness of your absurd claim: reading our book in any detail at all would verify that our conclusions are, on the contrary, based on an analysis of:

  • Well over 100 homeopathic RCTs
  • 22 meta-analyses, involving the results of thousands of patients (20 of the 22 found at least a trend in favour of homeopathy – many of them strongly so – while the remaining two were of low validity).
  • a detailed study of homeopathy’s success in treating upper respiratory tract infections. Six out of seven controlled studies showed at least an equivalence with conventional-medical interventions, whilst a further 8 (out of 16) RCT studies showed results from homeopathy treatment that were significantly the superior.
  •  studies into beneficial homeopathic effects on animals and plants.
  •  changes which homeopathy has been shown to produce on cells in test tubes. An explanation of any kind of how this can be effected by mere ‘placebo’ has to our knowledge never yet been postulated.

On the other hand, and as a fact, Shang did not examine over 100 trials, but only 8, and the reasons for exclusion of other trials were not explained, contrary to scientific protocol. Selection of any data other than the 8 chosen trials would have produced a marked result in favour of homeopathy, in line with the overwhelming majority of meta analyses [see].

Throughout our HTA ‘Homeopathy in Healthcare’, the Shang study is mentioned only briefly in the discussion section.Your claim that we based our result on a reworking of Shang is therefore as false as is your statement that Shang carried out ‘a substantial review of over 100 placebo controlled trials showed no convincing evidence that homeopathy was superior to placebo’.

In conclusion, we state that your writing does not even begin to approach a professional standard. We take great exception to your untenable allegation that we researched this important subject with the superficiality that you suggest, an implication that we consider defamatory. You accuse us of basing our conclusions largely on a reworking of one deeply flawed paper, the Shang study. Yet this is the one paper on which you appear to have based your own conclusions, which are flatly contradicted by swathes of contrary evidence of which you revealingly make no mention. We find this bizarre.

It is customary that authors whose work is misrepresented should have the right of a reply to be published in the same location as the attack was published. We therefore demand that you please place our reply on your website, with equal prominence to your own text.
Yours sincerely,

Prof. Dr. med. Peter F. Matthiessen                                            Dr. med. Gudrun Bornhöft
cc Jeremy Hunt, Secretary of State for Health.

Reply from ASA Ltd. –
Dear Prof. Dr. med. Peter F. Matthiessen & Dr. med. Gudrun Bornhöft,
Thank you for contacting us.

You might be aware that the ASA is the UK’s independent advertising regulator, recognised by the Government, Courts and UK Trading Standards Services as the ‘established means’ for regulating misleading and comparative ads in non-broadcast media in the UK.

I’d first like to make clear that it is not the ASA’s role to question the validity of alternative or complementary therapies in and of themselves; nor do we seek to restrict the right of individuals to choose treatment.

We are, however, charged with protecting consumers from potentially misleading advertising.  When advertisers make claims about their products or services, in any sector, they must hold robust evidence to back up those claims.  If they do not, the ASA has no choice but to ensure those ads are amended or withdrawn.

Your work was considered by the ASA, having been submitted by an advertiser as evidence to substantiate claims made in their advertising about the efficacy of homeopathy in treating medical conditions. Having sought expert advice, we considered however that ‘Homeopathy in Healthcare’ did not move the case forward in favour of the efficacy of homeopathy, in light of conventional standards for efficacy.

I appreciate that you disagree with this assessment. It would, however, be irresponsible for the ASA, as an advertising regulator, to ignore mainstream scientific and medical opinion when considering claims about products that are used in a medical or therapeutic context.  The ASA’s current position on the evidence-base for the efficacy of homeopathy is supported by the findings of the House of Commons Science and Technology Committee’s report ‘Evidence Check 2: Homeopathy’, published in 2010.  That report included a thorough review of a wide range of evidence on the efficacy of homeopathy (much of it submitted by homeopaths themselves), but it concluded that “there is a lack of evidence supporting the efficacy of homeopathy”.

Ultimately, if practitioners are concerned that existing methods for considering the efficacy of treatments or therapies are not fit for the task, they should raise these issues with the relevant expert bodies – for example the National Institute for Clinical Excellence or the Department of Health here in the UK.

Whenever the ASA makes a ruling, advertisers have recourse both to an Independent Review process and to judicial review, the latter providing a means for advertisers to have our decisions tested in the courts. If through this process our ruling is found to have been flawed, it will be amended, and the new ruling published on our website.

Thank you for taking the time to contact us.


Rob Griggs.

Dear Mr Parker,

We refer to the reply we received from Mr Griggs, which we found irrelevant to our Email of 24th July which we addressed personally to you.

We do not comment on other countries’ health policies unless specifically invited by that government to do so, and we said nothing about your ‘position’ on homeopathy. Neither have we made any statement on the Science and Technology (2010) committee report: others such as Lord Baldwin and David Tredinnick MP have done so already –

Our complaint, unaddressed by Mr Griggs, concerned exclusively your organization’s false statements about our work; not a matter of ‘opinion’ nor of ‘policy’, but of plain Misrepresentation of Facts.

You say, on the internet, that our book’s conclusion is based largely on a reworking of Shang: as a fact, this is totally false. You say our book contains no RCTs: as a fact, this is equally false.

Aside from a legal incumbency to present facts truthfully and to correct errors made, I hope we can agree as a question of basic morality that members of the public should not be subjected to false or misleading communications – including yours.

Yours sincerely,

Prof. Dr. med. Peter F. Matthiessen                                            Dr. med. Gudrun Bornhöft

Dear Prof. Dr. med. Peter F. Matthiessen & Dr. med. Gudrun Bornhöft,

Thank you for your further email.  Mr Parker has asked me to respond on his behalf.

We disgaree (sic) with your interpretation of the wording of our adjudications.  During our investigation processes, we recieved (sic) expert advice on the various studies submitted by the advertisers as evidence supporting their marketing claims.  We stand by that advice and our use of it.  As you might know, advertisers and complainants involved in investigations have the right to request an Independent Review of our decisions.  However,

I’m afraid our published processes do not give other parties that right.

I‘m sorry that you remain unhappy with the wording of our adjudications, but we cannot assist you further at this time.

Best wishes,


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