FDA Homeopathy Circus, Day 1

Today and tomorrow, the FDA is holding hearings to see about updating its regulations for homeopathy. Or, as NPR puts it, FDA Ponders Putting Homeopathy To A Tougher Test. Here, “a tougher test” means applying the same rules to homeopathy as to every other proposed medical treatment: see whether it works.

So to that end, they’re holding two days of hearings. I was able to stream part of the proceedings, and even hear some of it (though I was busy, and thus missed a lot).

If you want to follow along tomorrow, it’ll be at https://collaboration.fda.gov/hprapril2015.

But first, it might be good to review what homeopathy is. homeopathy.com explains:

Homeopathy’s basic premise is called the “principle of similars,” and it refers to recurrent observation and experience that a medicinal substance will elicit a healing response for the specific syndrome of symptoms (or suffering) that it has been proven to cause when given in overdose to a healthy person.


Most homeopathic medicines are made by diluting a medicinal substance in a double-distilled water. It should be noted that physicists who study the properties of water commonly acknowledge that water has many mysterious and amazing properties. […]

Each substance is diluted, most commonly, 1 part of the original medicinal agent to 9 or 99 parts double-distilled water. The mixture is then vigorously stirred or shaken. The solution is then diluted again 1:9 or 1:99 and vigorously shaken. This process of consecutive diluting and shaking or stirring is repeated 3, 6, 12, 30, 200, 1,000, or even 1,000,000 times. Simply “diluting” the medicines without vigorously shaking them doesn’t activate the medicinal effects.

In other words, you find a substance that produces a given symptom in healthy people; you dilute that substance in water until there’s none of it left, and you give your bottle of water to a person who suffers from symptoms like what you found earlier.

Or, as Mitchell and Webb described it, “trace solution of deadly nightshade or a statistically negligible quantity of arsenic”:

[youtube http://www.youtube.com/watch?v=HMGIbOGu8q0&w=560&h=315]

So the question before the FDA is to determine whether homeopathic substances, which are touted as remedies for everything from gout to nonspecific unease, should be subject to the same regulations as, say, Tamiflu or Ibuprofen or Viagra. The sorts of regulations where if you say that your product is good against X, the FDA comes along and says, “proof or STFU”.

Apparently Michael de Dora of the Center for Inquiry testified early on, but I missed it. His testimony can be summed up as “Science has known for a long time that homeopathy doesn’t work. The US government knows this. Hell, the FDA has said as much. This year. Let’s not support pseudoscientific quackery.”

The first speaker I caught was giving an overview of studies on homeopathy. At first, he couldn’t do better than saying that there are studies that show that it works, and others that don’t. But he was able to drag in other factors, like the file drawer effect (that negative results tend not to get published) and the Hawthorne effect (people who know they’re being watched behave differently) to cloud the issue enough to be able to say that the science isn’t settled. Sadly, he was one of the most reasonable speakers of the day.

Several ideas came up in different people’s testimony before lunch:

  • That homeopathy has organizations of practicing professionals, therefore it works.
  • That homeopathy has a standard reference book, therefore it works.
  • That there’s quality control (i.e., people check that your bottle of 99.99999% water really does contain 99.99999% water), therefore it works.
  • That members of the general public don’t really know a lot about homeopathy (this might become significant, later).
  • That I just know that it works, therefore it works. (Who needs double-blind clinical trials when you have feelz?)
  • That homeopathy is popular, therefore it works.

One speaker made the argument that France has an excellent public health-care system, and that homeopathy is popular in France (therefore, presumably, homeopathy works). He also mentioned, or implied, that it had been approved by Swiss healthcare regulatory bodies. During the Q&A period, he was asked how French and Swiss researchers had evaluated the effectiveness of homeopathy, and in response he went off on a tirade against US regulators. I believe that’s called evading the question.

During the afernoon session, several more ideas came up several times:

  • Homeopathy works in conjunction with other treatment (I had a headache, so I took an aspirin and a homeopathic remedy; my headache went away; therefore, homeopathy works).
  • Homeopathy is popular, therefore there’s no need for stricter regulation. (I wonder if that argument also applies to heroin.)
  • Homeopathy is big business, therefore there’s no need for stricter regulation.
  • Homeopathic remedies are already marked “homeopathic”. What more do you people need? Informed customers (which morning testimony said many people aren’t) can make an informed choice.

One shining light was Luana Colloca of the University of Maryland, Baltimore. She actually cited studies and showed empirical results, and even graphs with error bars, mirabile dictu! She gave an overview of the power of the placebo effect, though I’m not sure what her point was. Was it that hey, placebos lessen people’s pain, therefore let’s let people have their sugar pills?

But beyond that, the theme seemed to be that things are fine the way they are; informed consumers can caveat emptor their way through drug store aisles. And besides, it’s popular, and big business. So why should Big Alt-Med be regulated the same way as Big Pharma? Unfair!

What I found notably missing from the proceedings, and which I would gladly have welcomed, was anything along the lines of “Yes, homeopathy is effective against X, Y, and Z. And we have the double-blind, statistically-significant clinical trials to prove it.” I suppose that was too much to expect. Ah, well. I still has feelz. And a tall drink.