FDA Homeopathy Circus, Day 2

Yesterday was day two of homeopathy hearings at the FDA. There were some audio and connectivity problems, and again, I was distracted, but I tried to pay some attention.

One or two presenters tried to explain why you can’t perform randomized double-blind clinical trials to demonstrate the efficacy of homeopathic remedies. Apparently it boils down to “homeopathy doesn’t work that way”, though I didn’t catch the specifics. Apparently you can’t test homeopathic remedies on animals because, um… I’m not sure. Also, a homeopath will prescribe a whole array of remedies, tailored to the needs of the individual patient; just like what oncologists do, and somehow that gets in the way of studying homeopathy, but not cancer. And homeopathy often involves evaluating subjective self-reported symptoms, so you can’t study homeopathy clinically, even though doctors study self-reported subjective symptoms like pain all the time. So the upshot of this line of argument was that homeopaths should be exempt from the rules that say you have to demonstrate that your medical treatment actually works.

In fact, one presenter, if I heard him correctly, went so far as to claim that all the other homeopaths have it wrong. This guy had a slide saying that when you dilute a substance, the “Initial substance transits to a new physical condition”. I’ll just leave that authentic frontier gibberish there for you to marvel at.

Another line of argumentation, advanced by several presenters, particularly those on the business end of things, was that homeopathy is big business and growing, and therefore it should not be regulated. I think one person at least tried to make that into a coherent argument by claiming that regulating homeopathy would throttle innovation. You know, kind of like how you never hear from Novartis, Pfizer, or Merck these days because they’ve closed up shop.

Throughout the day, there was a steady drumbeat of “homeopathic remedies are safe”, although usually with an caveat: “properly-prepared homeopathic remedies are safe”. Properly-prepared homoepathic remedies are just distilled water, which I agree is safe. But homeopathy is currently unregulated, or nearly so, and thus no one is checking to make sure there’s nothing bad in your expensive distilled water.

In fact, as we heard in the previous day’s testimony, a lot of times manufacturers will combine things, e.g., take a regular zinc supplement and sprinkle homepathic water on it, and sell it as a hybrid or stick a “homeopathic” sticker on the box. People who have heard that homeopathy, whether it works or not, is at least safe, can and do take more than the recommended dose, and ingest unhealthy amounts of zinc. That by itself should be an argument for regulation and proper labeling.

But perhaps the most depressing aspect of the hearings were the practicing doctors testifying in favor of homeopathy, using the same arguments as everyone else: “I’ve seen it work. And it’s popular. Plus, it’s safe”. These are smart, well-educated people, who every day prescribe medications that have gone through rigorous controls to eliminate things like personal bias and proof by anecdote, committing those very errors.

At any rate, the current phase of the circus is over. With any luck, the FDA will start cracking down on this woo. I’d call it snake oil, but statistically speaking, there’s probably not a single molecule of the original oil left.

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