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[ Home ] [ Dietary Supplements or Functional Foods ] [ Darwinian Medicine ] [ Adaptation & Darwinian Medicine ] [ TGA & the Pan Crisis ] [ Pan Crisis ] [ Health Trends ] [ Medical Rationing ] [ Do Not Resuscitate ] [ Alternative Medicine Takeover ] [ Holistic or Reductionist? ] [ Orthodox Medicine ] [ Science Today, Quackery Tomorrow ] [ Integrated Medicine ] [ Medical Bias ] [ Health Topics ] [ Hypophobia ] [ Nutrition Breakthroughs ] [ Nutrition & Megavitamins ]
Misinformation About Pan, & Increased
Regulatory Control of Alternative Medicines in Australia & NZ: Codex & the Global Agenda
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Anti-nutrition Bias, & Bizarre Beliefs About Codex and Pan: don't let the
truth get in the way of a good biased story
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Orthodox medicine has a very long history of vitaminphobia or
anti-nutrition bias (Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis).
Deliberate medical bias of course is rooted in the desire to deceive and
mislead, usually for personal or commercial gain, and therefore
represents an abandonment of science (Medical Bias). I have repeatedly drawn attention to the false, misleading, or
scientifically baseless statements made by governments, health
authorities and others as a result of the Pan witch hunt
(see Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free).
Since those who have made such false or misleading statements have
consistently refused to apologise or explain their actions one is left
with the distinct impression that their actions represent a deliberate
and devious attempt to justify the increased control of alternative
medicines by causing widespread
fear and panic about the safety of such products. Any deliberate
attempts to exploit the fears of consumers are absolutely despicable,
especially if such exploitation is based upon deliberate deceit.
Some of the bizarre beliefs demonstrated by opponents of alternative
medicine or those who have been relentlessly
pursuing
increased regulatory control of complementary or alternative medicines include the following:
- When a pharmaceutical drug is shown to be toxic, as occurred
during the Pan debacle, what is needed is tighter regulatory control
of alternative medicines, not drugs (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill).
- When alternative medicines are shown to be much safer than
drugs, as occurred during the Pan debacle, what is needed is tighter
regulatory control of alternative medicines, not drugs (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill).
- Following on from this is the belief that if one drug (or
alternative medicine), can be shown to be toxic then this justifies
urgent regulatory control of all alternative medicines unlike the
situation in the drug industry where the toxicity of one drug is
considered to have no relevance to the safety of other different drugs (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill, Dietary Supplements).
- The best way of increasing confidence in alternative or
complementary medicines is to make false scientifically baseless
claims about the dangers of such products and even blame alternative
medicines for adverse reactions to toxic drugs and then offer to 'save' the industry by introducing new regulations (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill).
- Adverse reactions to alternative medicines do not need to be
caused by the alternative medicine itself as long as there is an
"association" - in this regard a different standard of evidence
applies compared to pharmaceutical drugs (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free,
Dietary Supplements).
- Although falsely based public fear about safety should be
exploited to justify increasing regulatory control of alternative
medicines, commercial considerations such as "market exclusivity"
and "data protection" should be central to new regulations (Alternative Medicine Takeover,
Response
to Government Inquiry).
- Although most modern drugs have a symptomatic effect only (Symptom
Suppression, Darwinian Medicine) whereas nutritional supplements like folic acid
have a curative effect when used to treat the relevant nutritional
deficiency (Nutrition and Megavitamins,
Nutrition is for
the Birds), supplements must be prevented from carrying label
claims stating they have a curative effect or they may be used to
treat or prevent serious diseases such as birth deformities or heart
disease (Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill, Nutrition Breakthroughs)
even in spite of the fact that foods containing these same
supplements may make various health claims (Dietary
Supplements or Functional Foods).
- There should be a persistent avoidance of any commitment to
guarantee the future availability of the current range or potency of retail dietary
supplements and a refusal to include health freedoms and the right to
freedom of choice of
supplements in legislation (Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill).
There has also been a consistent campaign to
discourage the public from establishing any connection between the
simultaneous campaigns to control dietary supplements which are
occurring in numerous countries throughout the world (TGA &
Pan,
Codex in Australia,
Pan Crisis
& Future of Alternative Medicines,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free,
Dietary Supplements,
Dietary Supplements or Functional Foods,
Nutrition Breakthroughs). Those pursuing
increased regulatory control of alternative medicines in Australia and
New Zealand for instance, consistently try to distance themselves from
simultaneous campaigns to erode health freedoms in other countries,
especially by stating "Codex" does not apply to Australia (Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill). Since they deny a common global theme for these
changes promoters of such campaigns have demonstrated the
following beliefs.
- The simultaneous campaigns to introduce stricter controls of
alternative medicines in different countries is just an amazing
coincidence. There has been no communication between these countries
- they just all decided to make the same changes at the same time (TGA &
Pan,
Codex in Australia,
Pan Crisis
& Future of Alternative Medicines,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free)!
- 'Codex' is the ONLY way of imposing restrictions upon
alternative medicines. It is not possible to restrict alternative
medicines by new regulations unless the new regulations are referred
to as 'Codex' (Alternative Medicine Takeover).
Since I have already considered the above matters elsewhere (Pan Crisis,
TGA &
Pan,
Codex in Australia,
Pan Crisis
& Future of Alternative Medicines,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free,
Dietary Supplements,
Dietary Supplements or Functional Foods,
Nutrition Breakthroughs) I would like to
focus here on recent claims in New Zealand that supporters of
complementary medicine in that country have resorted to false
advertising in their attempts to prevent the passage of the Therapeutic
Products and Medicines Bill (Therapeutic
Products Bill).
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On 2nd May 2007 an organisation called 'Natural
Products New Zealand' (NPNZ) issued a media release stating that they
had lodged a complaint with the
Advertising Standards Authority alleging that an advertisement
opposing the
Trans Tasman Bill placed in the New Zealand Herald by Health Freedom
New Zealand involved false claims (1).
According to Natural
Products New Zealand (NPNZ), which claims to represent (1)
"a substantial portion of the Natural Products industry"(1):
"NATURAL PRODUCTS NZ LAYS COMPLAINT WITH ASA
OVER FALSE CLAIMS
Natural Products New Zealand (NPNZ), the industry body
representing a significant proportion of New Zealand natural
health product manufacturers and marketers, has laid a
formal complaint with the Advertising Standards Authority (ASA)
regarding an advertisement appearing in 26 April’s New
Zealand Herald. The advertisement, headed “NZ Govt Moves to
Outlaw Vitamins”, placed by a group calling themselves
Health Freedom (NZ)) is misleading and deceptive and
specifically breaches the Advertising Code of Ethics on no
less than nine counts, according to NPNZ executive director,
Michelle Beckett. “NPNZ is concerned about the amount of
misinformation and scaremongering that has been circulating
in a bid to stop the bill being introduced.
“This advertisement makes ridiculous, unsubstantiated claims
that are designed to mislead the public and create fear in
the minds of those who currently use vitamin supplements.
Most of the statements are untrue and in many cases, there
is no evidence to support their claims,” says Ms Beckett.
Note:
Natural Products New Zealand (NPNZ) represents a substantial
portion of the Natural Products industry. Based on a survey
of wholesale and retail sales information, export data and
industry surveys, NPNZ’s members make up the overwhelming
majority of the natural products industry in terms of
product lines, turnover, employment and exports. For further
information about NPNZ visit www.naturalproductsnz.org." |
While NPNZ makes claims they represent a "substantial
portion of the Natural Products industry" they do not claim to represent consumers of natural health products or health
freedom advocates. In fact they carefully emphasize that they have a
commercial agenda which is (2)
"focused on international trade" and full membership of the
organisation will not be granted unless the applicant is involved in the
exporting of natural health products. Unlike consumers of natural health
products however, NPNZ is an extremely new kid
on the block, having been in existence for only 4 years (3).
Interestingly, according to the
New Zealand Health Trust, claims that NPNZ represent the natural
health industry in New Zealand are (4)
"demonstrably false" since they claim it (5)
"does not represent the views of the majority of NZ businesses in the
natural health sector" (4). It should be noted that when I recently contacted NPNZ and asked them
the following question I received no response:
| "You claim that you represent a substantial portion
of the natural products industry in NZ. Can you quantify
your support level more precisely in percentage terms?" |
While false advertising cannot be justified regardless of who is responsible
for it, when an organisation which claims to support complementary
medicines complains about an advertisement which supports the retail
complementary medicine industry and the maintenance of health freedoms
it is worth a closer look. It is vitally important that the public is
not misled by claims that an organisation represents the "natural
products industry".
Why would an organisation which claims to
support the complementary medicine industry complain about the allegedly
misleading nature of advertisements supporting consumers of
complementary medicines? Are they simply impartially seeking truth in
all advertising? Do they have a clear track record of impartially
criticising all types of misinformation in the public health arena or is
there evidence of selective concerns? It would seem to me that most
organisations concerned with public health and safety of complementary
medicines would object most vocally to those matters which pose the
greatest public health risk OR which represent the most severe injustice
and departure from truth.
The most serious public health matter as far as therapeutic
substances are concerned continues to be the scientifically proven
dangers of pharmaceutical drugs and the complete inability of our
current drug regulatory system to prevent the thousands of deaths which
occur every year as a result of consumption of drugs which have
allegedly been
shown to be safe by double blind trials. This is an absolute scandal
which should be at the top of the list of concerns for anyone genuinely
interested in the safety of therapeutic products. On the other hand, the
most important injustice and departure from truth in the natural health
industry in Australia and New Zealand in the past 5 years has undoubtedly been the
condemnation of complementary medicines when the pharmaceutical drug Travacalm was shown to be toxic
(Pan Crisis). Condemning all complementary medicines
when a drug was shown to be toxic represents a new low in dishonesty and
mass deceit and a new high in the exploitation of consumers and the
propagation of misinformation. Especially since the proposed legislative
changes and tighter control of complementary medicines in New Zealand are clearly based upon the misinformation
resulting from the Pan witch hunt (Therapeutic
Products Bill) it is most noteworthy that NPNZ makes
very little comment about this falsely based exploitation of fear (6):
"“While NPNZ understands the Australian TGA’s
choice to err on the side of caution in calling for the
recall of all products manufactured by Pan in the last year,
many of these products are of relatively low risk. The
proximate cause of the further scrutiny of Pan was not a
natural product, but was an over-the-counter pharmaceutical
product. To our knowledge, no natural health product had
been the subject of a complaint in the period of further
scrutiny, although some are now surfacing in Australia that
shall have to be investigated for their merit.”
“We support the recall of any Pan-manufactured product in
the New Zealand market, and are confident that our respected
marketing companies not only have the records to identify
any Pan product, that they also have the ability to trace
these products to specific product names and batch codes." |
While acknowledging that "the proximate cause of the further
scrutiny of Pan was not a natural product, but was an over-the-counter
pharmaceutical product" according to their media releases (7)
NPNZ avoid any specific reference to the monumental injustice and mass deceit
perpetrated upon the New Zealand people by this attempt to falsely blame
complementary medicines for the toxicity of a pharmaceutical drug.
Neither do their media releases (7)
mention the enormous insult to the collective intelligence of the New
Zealand people perpetrated by those who seem to expect New Zealanders
to believe that all complementary medicines should be blamed for the
toxicity of a pharmaceutical drug. And neither did they complain (7)
when the New Zealand government sought to exploit the falsely based
fears generated by the Pan debacle to justify a legislative campaign (Therapeutic
Products Bill) to harmonise with Australia and introduce tighter
control of complementary medicines (Therapeutic
Products Bill). Not only did NPNZ fail to issue any media release
about this monumental injustice (7),
other than the brief mention above they completely avoided these matters in their news releases (7).
Of course this matter may be partly rectified if NPNZ were to
issue an urgent news release stating that the Pan drug crisis
demonstrated once again the safety of complementary medicines (as
compared to drugs) and condemning the exploitation of fear about the
safety of such products and the use of the Pan drug crisis to justify
trans Tasman harmonisation.
In spite of the lack of concern displayed by NPNZ regarding the
exploitation of falsely created fear amongst consumers which resulted
from the Pan witch hunt, on 27th April 2007 they issued the following
news release because of what they claimed was "scaremongering"
and "misinformation" being circulated by people who opposed Trans
Tasman Harmonisation and the Therapeutic Products Bill (which resulted
from the dangers allegedly demonstrated by the Pan witch hunt) (8):
"THE TRUTH STANDING IN THE WAY OF A GOOD STORY
Trans Tasman Agency: FACT v FICTION
Natural Products New Zealand, the industry body representing
a significant proportion of New Zealand natural health
product manufacturers and marketers, is taking a stand
against the misleading information circulating around the
proposed Trans Tasman joint agency for natural health
products. Michelle Beckett, executive director of NPNZ says
over the past few months opponents to the Bill have
circulated information with omissions, misleading
information and some significant distortion of the facts.
'We are concerned that scaremongering by opponents of the
Bill and the circulation of misinformation through the media
is painting an erroneous picture for the natural health
industry and it is time to set the record straight,' says Ms
Beckett.
'The New Zealand industry has been actively involved in the
development of the treaty, establishing the rules and
processes that will result in a world-class system for the
regulation of complementary medicines increasing the
standing and acceptance of New Zealand products in the
international marketplace.'
'Regulation of natural products in New Zealand will provide
consumers with the full assurance they need that all
products are true to label and contain only the highest
quality ingredients. Any company that has a problem with
that, should not be in business,' concluded Ms Beckett.
FACT v FICTION
Opponents : 60% of products on shelves now, will not
be there once ANZTPA comes into effect.
Fact : If you look at independently measured market
share data for the New Zealand Nutritional Supplements
market for both the Supermarket and Pharmacy channels, over
80% are products and brands that currently sell in both New
Zealand and Australia that will therefore already qualify
with the new standards and will be available under the new
regulations.
Opponents : 1000s of ingredients will not be
available
Fact : Many 1000s of ingredients are now approved for
use in Australia under the TGA “white list”, and there are
over a 100 more nominated by New Zealand industry that are
on a short list for addition with the rollout of ANZTPA.
Curious consumers are invited to view the current list of
ingredients at http://www.tga.gov.au/cm/listsubs.pdf
Opponents : 60% of businesses in Australia
disappeared after regulation introduced there.
Fact : This is an apocryphal claim not based in fact.
There were businesses that exited the industry, as there
would be in any change in the regulatory function of any
industry sector. However, since that time Australian
industry has expanded and prospered. Most industry
organisations and businesses agree that on balance the
implementation of the regulatory system in Australia has
been good for the sector, and has increased confidence in
complementary medicines and the ability to make claims.
Opponents : Traditional Maori medicines will not be
available after the Agreement comes into affect.
There will not be a loss of opportunity to commercialise
Maori traditional medicines. Any commercialised ingredient
would be subject to the same assessment as any new
ingredient so the opportunity for commercialisation still
exists, however, safety and efficacy would need to be
demonstrated. If the traditional use is demonstrated (three
generations is the suggested time frame) and the preparation
is in the traditional method, then it could be
commercialised subject to assessment that would be
streamlined. If traditional medicines are produced by Maori
practitioners preparing their own materials for treatment of
their immediate patients, then this bill does nothing to
stop that.
Opponents : All rules will be made by Australia
Fact : The agreement provides for the 50/50 voice of
NZ and Australia. All Rules are made jointly, and in joint
consultation with industry on both sides of the Tasman.
Opponents: The agency would be an Australian
corporation.
Fact : The joint agency will be incorporated in
Australia for technical reasons because as with all
agencies, it must be incorporated somewhere. They key to the
operation however is the 50/50 governance and management
structure created for the joint agency. New Zealand has done
very well to achieve equal status with a partner many times
our size.
Opponents: The Agency will regulate all natural
products and medical devices immediately.
Fact: The agency will NOT ‘regulate all natural
products’ rather it will regulate only products classified
as complementary medicines in dose form. There is a five
year transition period for the regulation to come into
being, during which most products will remain on sale while
they achieve legal status under the new Agency.
Opponents: All rules will be made by the managing
director of the Agency at his or her total discretion and
will not have to be approved by the NZ Parliament
Fact: The managing director will NOT be able to make
ANY rules. The Treaty says that only the Ministerial council
can make the rules, NOT the managing director. The Rules are
also disallowable in New Zealand as we retain the right to
autonomy and to opt out of a rule if it is not in the
national interest.
Opponents : All products will be illegal until a
licence is granted
Fact: INGREDIENTS may be illegal until approved or
proven safe – not products. Approximately 4000 ingredients
are already pre-cleared as safe ingredients for Class 1
complementary Medicines and ingredients for export-only
complementary medicines are not required to be pre-approved
in New Zealand.
Opponents : Breach of a product licence means fines
up to $5.5 million for each transgression
Fact : There is a solid process anticipated for
breaches: First, education. Secondly, a letter of warning.
Thirdly, a small fine or infringement notice. A fine of
$5.5million would be issued only for an enormously serious
breach with dire consequences such as significant harm or
criminal activity. All criminal activity can be met with a
very strict penalty where the offending warrants it.
Opponents : This proposal is the same one that was
assessed as being likely to cripple the NZ natural health
industry while at the same time giving commercial advantage
to Australia. This is the same proposal that the Select
Committee have rejected twice as not being in the best
interests of NZ.
Fact : The proposal is not the same. There has been
significant progress including the support package offered
by the NZ government to NZ industry only. (Note, there is no
support provided to Australian industry)" |
Following the above allegations about scaremongering in April 2007, NPNZ
lodged their complaint with the
Advertising
Standards Authority (ASA) in May (1)
and the ASA upheld the complaints on 10th July and released the results
on the 19th July (9,10,11,12).
Since those who supported the Trans Tasman Bill and the control of
complementary medicines in NZ have enthusiastically embraced the
findings of the ASA, describing those who opposed the Bill as (10,11,12)
"going ballistic", "telling lies", "chanting", and "scaremongering",
it is vitally important we take a closer look at the initial complaint
by NPNZ (1)
and the findings of the ASA (9).
Indeed, according to Annette King (10),
"this decision epitomises the misinformation and lies that a minority
of opponents used to pervert the democratic process." But these
concerns about the democratic process are not consistent with the fact
that Ms King preferred to do a deal in parliament rather than take the
matter to the New Zealand people (10).
Recently Gordon Copeland has again challenged Ms King to adopt a more
democratic approach by listening to the people (13):
| "However, as I said in the House last week to Ms
King, and say now also to Mr Key, any proposal should be
taken out by way of a road show so that it can be properly
explained to the thousands of people who have sent postcards
etc to all members of Parliament.” “In my view it
is simply not good enough to stitch a 'we know best' deal
together here in Parliament and to continue to ignore the
opinion of the people in these circumstances.”
“It is time that both Labour and National relearnt
some of the basics of participatory democracy. Who knows,
following the road show, we may find strong grass roots
support for a two-tier approach but we’ll never know unless
we ask. It is time that we all learnt to do some listening." |
If democracy is uppermost on the mind of Ms King why the reluctance to
take the matter to the people? Truth and the democratic process also
seemed to be shamefully inconspicuous when Ms King used the Pan drug crisis to justify harmonisation and enhanced legislative control of supplements in NZ (14).
And Michelle Beckett of NPNZ apparently claimed that those who opposed the Bill
have (15)
"vested interests" in the industry and (15)
"her group will continue to give what she calls the honest version of
what the bill is about." But if Ms Beckett is concerned about the
corrupting influence of vested interests why not be guided by consumers
rather than by the commercially motivated NPNZ? Perhaps Ms Beckett is
recommending the matter should be taken to the people in a referendum so
that the influence of vested interests may be minimised. Anger from
doctors and medical associations in New Zealand (12)
which has been directed at the complementary medicine industry because
they claim defeat of the Bill will result in more difficulty (12)
"accessing new and improved drugs", is also seriously misdirected to
say the least. If doctors will be unable to access "new and improved
drugs" then this would be the direct result of the intransigence of
both Australian and New Zealand governments who have both absolutely
refused to accept a compromise solution by exempting complementary
medicines from the Bill (16,
25,
26).
The anger of
New Zealand doctors should therefore be directed totally at both
Australian and New Zealand governments who have persistently refused to
pass the Bill the doctors require. Their anger certainly should not be
directed towards the complementary medicine
industry since they have done absolutely nothing to reduce access to ""new
and improved drugs".
Are the conclusions of the ASA consistent with all the available
evidence? And why would an organisation which claims to represent the
natural products industry fail to issue any public complaint
about probably the most monumental injustice ever perpetrated upon the natural
products industry (the Pan debacle) and yet issue media releases and complaints about
advertisements in support of natural products? Do the above matters
justify expressing more concern than the misinformation resulting from
the Pan witch hunt which the New Zealand government used to justify the
current legislative crackdown on complementary medicines? Why express
more concern about alleged "scaremongering" in support of
complementary medicine while ignoring "scaremongering" which is
falsely critical of complementary medicines? Does NPNZ consider
scaremongering which falsely criticises complementary medicines to
be unimportant? If so, why? It is worthwhile examining the basis for the
concerns of NPNZ and the conclusions of the ASA.
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| The details of the complaints to the ASA by Michelle Beckett of NPNZ (9)
are reproduced below in
Appendix 1. I will consider each of the nine complaints separately, all of which were
subsequently upheld by the ASA, followed by the response of the
advertiser. The comments below should be read in conjunction with the
response of Health Freedom to the ASA decision (17). 1. NZ Govt Moves to Outlaw Vitamins
The advertiser offered the following statement in response to this
complaint (9):
| "The Australian approved list
(white list) does not list the full number of vitamins that
are freely available at the present time to New Zealanders.
There are many ingredients present in imported and New
Zealand made products that are not permitted in Australia as
they are not on the Australian approved list." |
In my view the claim that "NZ Govt Moves to
Outlaw Vitamins" is unnecessarily vague and I take
little issue with this complaint although in the world of false
advertising, concern about this statement seems to me to be extremely
petty, if not mischievous. Supporters of dietary supplements have so
much factual information at their disposal it is disappointing that
sometimes ammunition is given to opponents of natural health by poorly
expressed publicity campaigns. If this statement had been qualified as
being the opinion of the advertisers it would have been acceptable.
Alternatively, it could be stated thus: "NZ Gov Fails to Guarantee
Future Availability of Present Range of Retail Supplements."
2. Did you vote for Australian Bureaucrats to
make your health decisions?
The advertiser offered the following statement in support of this claim
(9):
| "The fact that this bill has been
promulgated by Australian Bureaucrats that New Zealanders
did not vote for affirms the right to publish this
statement. The parent Bill for the current Therapeutic
Products and Medicines Bill was in point of fact rejected by
two select committees of parliament.
Our statement is fair comment in view
of the fact that if the bill is passed in its present form
thousands of dietary supplements will no longer be available
to New Zealand consumers. This is a statement of fact and
not speculation." |
There are two issues here, although it must be noted that this is a question and not a statement of fact. How can a question
be incorrect? Firstly, does the Bill have the potential to affect the "health
decisions" of consumers? There is absolutely no doubt that this is
so since there is no argument that the Bill will effect the cost and/or
availability of supplements (Therapeutic
Products Bill). Even NPNZ, who lodged the complaint with ASA, have acknowledged this is so in a news release entitled "Good
Health Comes at Increased Cost" (7).
According to NPNZ (7):
| "Consumers taking a proactive approach to maintaining
good health will have to pay more, and have less choice, if
the Trans Tasman regulatory scheme for complementary
medicines goes ahead in its current proposed
form.......Executive Director of Natural Products New
Zealand, Michelle Beckett, says the natural health industry
is concerned with what appears to be a high level of
unnecessary cost burden that will ultimately get passed on
to consumers and will reduce the real benefits of regulation
to consumers and the industry. “Many New Zealand companies
will face substantial cost increases – both capital
investment and compliance costs - when the Joint Agency is
introduced and the customer will suffer. If these companies
decide to rationalise ranges or delete particular substances
due to the high cost of compliance then consumers may lose
access to particular forms of healthcare. Compliance costs
will end up being added onto the retail price and consumers
will have to pay more to maintain good health and well being." |
This has also been confirmed by many others (see
Therapeutic
Products Bill) including Dr Jonathan
Coleman, National Party MP for Northcote and Associate Health Spokesman,
who stated in regard to the proposed Therapeutic Products and Medicines
Bill (18):
| "we believe it should not proceed mainly because of
the costs and excessive bureaucracy it will impose on New
Zealand businesses. We have not been given any evidence from
the Minister that proves that this will not be the case.
These increased costs will also result in a reduction of
choice for consumers as businesses exit the market, as well
as higher prices for products that continue to be available." |
Secondly, since the proposed health bill would undeniably affect "health
decisions", would "Australian bureaucrats" have played any role
in these effects? Since Australian bureaucrats played a fundamental role
in the Pan crisis and the ensuing proposed regulations in NZ (Therapeutic
Products Bill), a fact which was conceded by Ms King (Therapeutic
Products Bill), there is absolutely no doubt about this. I cannot
therefore see anything inaccurate in asking the question "Did
you vote for Australian Bureaucrats to make your health decisions?"
3. 494 pgs of `safety' legislation yet no one
has ever died from supplements
The advertiser offered the following statement in support of this
claim (9):
| "According to the Ministry of
Health's own statistics, over the last 20 years there have
been no recorded deaths from the use of Dietary Supplements.
The Coronal Council Chairman Dr W. Bain instructed
Government Departments to search the records and confirmed
that there had been one alleged death attributed to a
dietary supplement. This allegation was found to be
non-factual and the cause of death was adjusted accordingly.
The authority quoted by M. Beckett accepts uninvestigated
allegations which when investigated by the Chairman of the
Coronal Council were found to be incorrect in regard to
coronal findings.
M. Beckett is basing her claim on
uninvestigated allegations and not factual mortality
statistics." |
Since opponents of complementary medicines and natural therapies have
a long tradition of exploiting fears in consumers (Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free), and considering the fact that "fear" is
central to the complaints of Ms Beckett of Natural Products New
Zealand, I will consider this matter in more detail in a separate
section below entitled "Fear and Its Exploitation by Opponents of
Natural Therapies".
4. NZ Acting chair of the coroners council Dr
Bain (a lawyer and pharmacist) states that a thorough search of all
records indicated that not one person has ever died from consuming a
health supplement in New Zealand's history"
I will also consider this complaint below in the section "Fear and Its Exploitation by Opponents of
Natural Therapies".
5. 60% of New Zealand made supplements &
vitamins forced from the shelves.
The following statement was offered in support of this claim (9):
| "This figure was publicly stated
by one of Australasia's leading dietary supplement
manufacturers. Government reports also state that 60 per
cent of natural health products made in New Zealand for New
Zealand could be taken off the shelves. Also the Australia
New Zealand Therapeutic Products Authority (ANZTPA) will
enact the Vitamin and Mineral Guidelines (VMG) developed by
the European Food Supplements Directive eliminating over 300
vitamin and mineral forms, many being food state nutrients
from the marketplace." |
The interesting thing about this claim is that the figure of 60% was
cited by Tony Ryall (and not refuted), in NZ parliament, apparently from
the governments own research (19).
According to Ryall (19):
| "Can the Minister understand why New Zealanders
are so strongly opposed to her plan to cover natural health
products when the Government's own papers state that 60
to 65 percent of the products that are currently on shop
shelves now will be wiped from those shelves under this
proposal* and when the advice of one of New Zealand's
leading natural health products companies is that the cost
of regulating a product will go from $2,700 to $64,000 under
her plan-a plan that she has mucked up completely?" *
Emphasis added |
How is it possible to find the claim "60% of New Zealand made supplements &
vitamins forced from the shelves" is untrue when it was cited
in parliament allegedly from the government's own figures? It seems the
ASA is not only accusing the advertiser of untrue claims, they are also
accusing Tony Ryall and the government of not telling the truth. Who is
telling the truth here? Is the ASA accusing the politicians?
6.
Prices will increase by 20% and 100%
The advertisers offered the following support of this claim (9).
| "It
has been reported by a former Australian Therapeutic Goods Administrator
that the Australian operation increased fees by 15 percent per annum
over the last 15 years and last year the increase was 25%. Therefore the
figure for New Zealand could be expected to be between the 20 -100%
range." |
Since according to Ms King (14),
the proposed legislative changes in NZ have been structured in response
to problems highlighted as a result of the Pan drug crisis, as also
occurred in Australia, it is interesting to observe the affects of these
changes in Australia according to Marcus Blackmore (20):
| "In Australia, regulatory creep exacerbated by
the recent Pan crisis has resulted in a model of
over-regulation and unnecessary red tape that is too
complex, too costly and bears little relativity to the level
of public risk involved. As a result, Australians are paying
more for their vitamins and herbs than most other countries
around the world..........After
the Pan recall, Australian industry has faced massive
increases in government fees, charges and regulatory
compliance and it would be grossly unfair to suddenly
overlay these costs on a significant sector of the New
Zealand industry that has survived under the Dietary
Supplement regulations with minimal compliance cost and
little or no safety risk to the New Zealand population." |
To suggest this claim is untrue seems petty in the extreme. As I have
considered above, even NPNZ, who complained about this claim, have
acknowledged there will be significant price increases. This fact is
generally agreed (see
Therapeutic
Products Bill) so there seems no issue to complain about
as far as this statement is concerned, unless of course NPNZ is
preoccupied with precise percentages. However if this is so it implies a
mischievous obsession with pettiness.
7. 50% of New Zealand manufacturers will close - associated loss of
jobs
The advertisers offered the following statement in support of this
claim (9).
| "Subsequent to the Ministry of Health's financial impact report it was
estimated by the health industry group which was in consultation with
the ministry of health at that time that over 200 small New Zealand
manufacturers would be forced to close due to registration fees,
compliance fees, auditing fees and additional fees." |
Widespread job losses are expected as a result of this Bill (see
Therapeutic
Products Bill) so there seems little to worry about with
this claim although the use of the precise figure of 50% may not have
been necessary. In the words of McCully (21):
| "The trans-Tasman Therapeutic Goods (TTTG)
regime was designed to have a single Australasian regulator
for everything from pharmaceuticals, to blood products to
complementary medicines. The problem was that the heavy-duty
regime proposed, would have very heavy up-front costs for
the players in the market. For pharmaceutical manufacturers
planning to have access to a 20 million person trans-Tasman
market, that was fine. But imposing those same costs on
small domestic suppliers of complementary medicines was
going to be crippling, even terminal." |
8.
It just gets worse - all decisions regarding what
supplements and vitamins you are allowed - and levels - are to be made
by unelected, unaccountable Australian bureaucrats, heavily lobbied by
the pharmaceutical industry
The advertisers defended this claim thus (9):
| "M.
Beckett fails to point out for the benefit of the Advertising Standards
Authority that 97% of the employees of this so-called Joint Agency will
be Australian employees and Australian based. The Joint Agency Treaty
document and its supporting legislation the Therapeutic Products and
Medicines Bill in their detail and with critical examination confirm
that the Australia New Zealand Therapeutic Products Authority will in
effect be an expanded version of the present Australian Therapeutic
Goods Authority (TGA). The Agency will be headquartered in Australia
under Australian domestic law. It will be the first time in
the world where an agency in one country has total control
to regulate and enforce an industry in another country. This
observation is in the detail of both documents and not
speculation as M. Beckett suggests." |
As has been noted by NZ politicians (see
Therapeutic
Products Bill), it is expected that the new Therapeutic
Products Agency will be comprised of only about 7% New Zealanders while
the remainder will be Australians. This simple fact demonstrates quite
clearly that most of the bureaucratic processing will be done by
Australians, unless of course Ms Beckett is suggesting the 7% of New
Zealanders will do more work than the 93% of Australians! The final
decision will be left to an unelected Managing Director who clearly
cannot be both an Australian and New Zealander so there seems no
significant error
in this statement.
9.
You deserve to know... that this is a move to limit your access
to natural health products, thereby driving you toward pharmaceutical
"solutions"
The advertisers offered the following statement supporting this claim (9):
| "If
the Australia New Zealand Therapeutic Products Authority is implemented
therapeutic dosages of vitamins and minerals (and all other nutrients
soon to follow) will become unavailable because they will literally
become illegal. Australia was the first country to adopt the
international regulatory model developed by the Global Harmonisation
Task Force, and the Joint agency will form a new trans-Tasman regulator
of therapeutic goods. This Joint agency will automatically operate under
the terms of the World Trade Organisation (WTO) United Nations' Food and
Agriculture Organisation (FAO) and the World Health Organisation (WHO)
and align with all the international treaties Australia has signed
including their pharmaceutical patent obligations under their free trade
agreement with the United States of America, which will undermine
advantages in patent law for New Zealand.
The
Australia New Zealand Therapeutic Products Authority (ANZTPA) will enact
the Vitamin and Mineral Guidelines (VMG) developed by Codex Alimentarius
which classify nutrients as toxins. Therapeutic grade vitamins,
minerals, and amino acids would be eliminated from the marketplace.
Therefore any products that may be available will be at minimum dosage
levels that may or may not compensate for dietary deficiencies.”
|
Since politicians in NZ have readily acknowledged that the proposed
Bill would have the effect of reducing the availability and increasing
the cost of complementary medicines (see
Therapeutic
Products Bill) there seems no doubt that these reduced
options would tend to force consumers to utilise cheaper and more
readily available pharmaceutical alternatives. In fact, according to
Thomas Faunce, senior lecturer in law and medicine at the Australian
National University, the ANZTPA is being deliberately structured to
favour the views of the drug industry (22):
| "Faunce said the "stakeholder consultation"
sessions held by the Australian government to shape the
development of ANZTPA were "a sham and a farce" were
designed to accept only department and drug industry views.
And he claimed that had the joint regulator gone
ahead, it would have forced New Zealand to also accept the
obligations foisted on Australia as part of the free-trade
agreement with the US that came into effect in 2005.
” |
Faunce concluded that the rejection of the Bill by NZ parliament was
a (22)
"good thing" for NZ. It seems however, that
according to the ASA, these experts are all wrong.
General Comments Made By Advertiser in Support of Claims
In addition to these itemised explanations the advertisers made the
following general comments regarding the complaint by Natural Products
New Zealand (9).
"The Natural Health Alliance Inc, on behalf of the
Advertiser Health Freedom New Zealand, said:
(Response dated 26 June 2007)
“The
publication that M. Beckett refers to in her complaint to the
Advertising Standards Authority is not an advertisement as she claims.
It is in fact a public notice placed by the Public Campaign Group and
concerned citizens as to their opinion of pending legislation and could
only be displayed prominently in the front section of the New Zealand
Herald as an "advertisement".
While
the statement that appeared in the New Zealand Herald on Thursday the
26th of April 2007 is the political opinion of the authors and the
Health Freedom Movement it needs to be recognised that the parent
legislation known as the (JTA) Joint Therapeutic Agency Treaty, was
twice unanimously rejected by a Parliamentary Select Committee, which
accounts for the abbreviated statement published on the 26th of April
2007. If we had been aware that any section of this public notice could
have been misconstrued as a statement of claim we would have consulted
with the Therapeutic Advertising Pre-Vetting System (TAPS) accordingly
for their approval.
As
far as we are concerned M. Beckett is using the Advertising Standards
Authority for her own political ends to create a mischief, due to the
fact that she now holds a contrary political position, which does not
necessarily represent the majority view held by members of the
organisation she represents.
M.
Beckett has the right to publish her own opinion in a similar manner and
not create a time consuming nuisance for the Advertising Standards
Authority and individuals who may hold an opinion contrary to M.
Beckett’s.
We recognise that the Advertising Standards Authority
and the Therapeutic Advertising Pre-Vetting System (TAPS) have been
established to ensure that statements of claim are not published in
relation to health care products as a primary role cognisant to the New
Zealand 1981 Medicines Act.
We
are aware of the vital role that the Advertising Standards Authority
plays in regard to spurious statements of claim.
We do
not believe that the Advertising Standards Authority should be used to
promote a political vendetta, as appears to be the situation in regards
to the complaint presented by M. Beckett supposedly on behalf of Natural
Products New Zealand.
We
feel exonerated by the findings of the Government Administration Select
Committee who after examining the Therapeutic Products and Medicines
Bill were unable to reach agreement. The committee has advised that it
cannot recommend that the bill be passed.”
|
|
|
|
History
Mainstream medicine has a very long history of anti-nutrition bias
and utilising politicians
or the media to discredit and marginalise alternative medicine (Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Dispelling the Vitamin E Myths, Global
Trends in Health Care). As I have stated elsewhere (Global
Trends in Health Care):
| "Medicine became dominant not entirely
because of the zeal with which the influence of social and
political elites was utilised to promote it, but also
because of their relentless attempts to outlaw and (14)*
"marginalise other models of health". It is this process of
outlawing opposing paradigms which is particularly relevant
today given current moves to reassert medicine's dominance
over increasingly popular alternative medicine (see
Alternative Medicine Takeover). Tactics
used to eliminate competing alternative health paradigms
include (14,15,16)*,
"subordination", "incorporation",
"limitation", "exclusion",
and "reformulation
............When it comes to the
current crisis between alternative medicine and orthodox
medicine, it is clear that the battle will not be fought in
the laboratory - and it will not be won in the laboratory.
The battle will be fought in the court of public opinion,
with the assistance of politicians, because medical
authorities know from experience they can never obtain the
dominance they seek by laboratory research and scientific
evidence. They are dependent upon the type of distortions
and sensationalism which were employed during the Pan crisis
(see
Pan Crisis,
Alternative Medicine Inquiry).”
* See Global Trends in Health
Care for references. |
One of the main tactics used to discredit complementary medicines by
supporters of mainstream medicine is the exploitation of public fears
about the safety of such products (Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Dispelling the Vitamin E Myths). The practice of exploiting public
fears is referred to as
'scaremongering' (23).
As has recently been pointed out (23);
"one thing that is not seen with scaremongering tactics is reference
to quality clinical trials or studies. Claims have to be substantiated
with evidence to have any value." In other words, as I indicated
above (Global Trends in Health Care), "it
is clear that the battle will not be fought in the laboratory - and it
will not be won in the laboratory. The
battle will be fought in the court of public opinion, with the
assistance of politicians, because medical authorities know from
experience they can never obtain the dominance they seek by laboratory
research and scientific evidence." This was demonstrated very
effectively during the Pan drug crisis when various 'experts' caused
widespread community fear and alarm about complementary medicines when a
drug was found to be toxic (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry). Rather than provide scientific
evidence of the alleged dangers of complementary medicines however,
resort was given instead to the use of false or unscientific claims in the media (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry). Orthodox medicine has traditionally
been much more interested in any claim, no matter how spurious, about
the dangers of vitamins rather than scientific evidence of their
effectiveness (Medical Bias).
This inability to scientifically justify the widespread
community fears they generate is a central part of scaremongering or the
deliberate exploitation of fear.
Often those who cannot prove their case adequately using scientific
evidence resort to emotive terms such as "quackery", "snake oil" or "expensive
urine" to support their cause (Pan Crisis,
Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Dispelling the Vitamin E Myths). Supporters of
mainstream or so called 'evidence based' medicine (EBM) often seem to claim that randomised clinical trials are the only
scientific truth and the only way of knowing (When
There is Evidence for Nutrition but Little Evidence for Evidence Based
Medicine) but strangely, such advocates of EBM often claim
that vitamins are dangerous although it seems they cannot cite one double blind
placebo controlled
clinical trial confirming the toxicity of vitamins (24).
They cite double blind trials as the gold standard by which the safety
and effectiveness of therapies are judged (Medical
Evidence or Medical Ignorance?) but yet they totally abandon their
own gold standard when it comes to the safety of vitamins, preferring
instead to use other scientifically inconclusive studies (Dietary Supplements,
Nutrition Breakthroughs,
Dispelling the Vitamin E Myths) or unscientific emotive terms like 'snake oil' in the popular media
(Pan Crisis, Nutrition and Megavitamins, Holistic or
Reductionist).
Another popular tactic employed by those who promote public
fears about the alleged dangers of complementary medicines is to
persistently avoid
any scientific comparison between the safety of complementary medicines
as compared to pharmaceutical drugs (Pan Crisis,
Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs,
Dispelling the Vitamin E Myths,
Alternative Medicine Takeover,
Response
to Government Inquiry). Whereas genuine concern about public health
will be clearly manifested by concerns which are obviously prioritised
according to degree of toxicity and evidence of known risk, in reality
most medical experts seem to express the most concern about the safest
products (ie. supplements) and the least concern about the most
dangerous (ie. drugs)(Pan Crisis,
Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs,
Dispelling the Vitamin E Myths,
Alternative Medicine Takeover,
Response
to Government Inquiry, Holistic or
Reductionist). Such an attitude suggests a contemptuous disinterest
in scientific evidence and public health and the safety of therapeutic
substances.
Strangely, although NPNZ and the ASA have suggested the Health
Freedom advertisements in NZ were intended to promote or "play on"
community fears about the future cost and availability of complementary
medicines in NZ, when it comes to the safety of such products NPNZ has
taken precisely the opposite stance and claimed these products are MORE
dangerous than depicted in the advertisements. In other words it seems,
when it comes to the safety of complementary medicines, Michelle Beckett
and NPNZ seem to be complaining that the Health Freedom advertisements
do not promote sufficient community fear! While Ms Beckett expresses her
concern about scaremongering in regard to
Health Freedom's claims about the impact of the proposed legislation
upon the marketing and availability of complementary medicines (1,8,12),
it seems that when it comes to safety she is complaining that there is
not enough scaremongering! So according to NPNZ it seems, we should
be promoting more fear about the safety of complementary medicines and
less fear about the effects of the proposed legislation on the cost and
availability of complimentary medicines! But if we promote more fear
about the safety of complementary medicines would not this be expected
to have a negative impact upon the cost and availability of such
products?
Especially in view of the fact that allegations of unjustified fear, scaremongering,
and the safety of complementary medicines, were absolutely fundamental to the complaint of Ms
Beckett of NPNZ and the decision of the ASA, let us consider the truth
about the safety record of complementary medicines and examine recent
attempts to justify increased regulatory control of complementary
medicines in Australia and NZ on the basis of safety or exploitation of
community fears.
|
|
|
|
Since the advertisements complained about by NPNZ were intended to
support the retail complementary medicine industry it would seem, since
NPNZ also claims to represent the complementary medicine industry, that
NPNZ would seek to promote the industry by advertisements which contrast
very sharply indeed with those authorised by Health Freedom. In regards to safety for instance, and the claims by
Health Freedom (items 3 & 4) that the safety of complementary
medicines is demonstrated by the fact that "no one
has ever died from supplements" , Michelle Beckett of NPNZ states (Appendix
1):
| "Unfortunately, according to the reports
of The Centre for Adverse Reactions Monitoring (CARM) also
known as the New Zealand Pharmacovigilance Centre, deaths
have occurred in people taking `supplements' therefore we
contend this statement is wholly untrue. It is therefore in
breach of Item 2 (Truthful presentation) of the Code of
Ethics. CARM reports summary for Serious Reports
to Complementary and Alternative Medicines received by NZ
Pharmacovigilance since 1992 to 31st December 2006 lists 3
deaths, 24 Life Threatening Events, and 25 cases requiring
hospitalization associated with Complementary and
Alternative Medicines. It is therefore in breach of Item 2
(Truthful presentation) of the Code of Ethics." |
Michelle Beckett of
NPNZ points out that scaremongering or causing community fear is
fundamental to her complaints about these advertisements. In their news
release of 27th April NPNZ state (8):
|
"We are concerned that scaremongering by opponents
of the Bill and the circulation of misinformation through
the media is painting an erroneous picture for the natural
health industry and it is time to set the record straight,'
says Ms Beckett."
|
And when Michelle
Beckett lodged the NPNZ complaint with the ASA she stated (Appendix
1):
|
"This advertisement is designed to create fear through the
use of false information......" |
And when NPNZ welcomed
the findings of the ASA she further stated (11):
|
"While the ASA’s decision justifies our
claims that this group and others conducted a campaign
opposing the Therapeutic Products and Medicines Bill based
on misinformation and scaremongering; unfortunately for the
public of New Zealand this has come a little too late." |
Does NPNZ regard
the Health Freedom claims that complementary medicines have caused
no fatalities in NZ as scaremongering or promoting fear? Of course, if claims that complementary
medicines are safe and have not been proven to kill anyone are
scaremongering, then the position of NPNZ would be the opposite of
scaremongering. In other words it seems, the best way to restore
confidence in complementary medicines would be to make public claims
such products are so dangerous that urgent legislative reforms are
required! Strange as it may seem, politicians and health authorities
have expressed similar views, especially as a result of the
Pan drug debacle (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free).
Although the Pan
drug debacle demonstrated yet again the safety of complementary
medicines as compared to pharmaceutical drugs such as hyoscine
hydrobromide (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill), it was astonishing to witness so many authorities
or traditional opponents of alternative medicine attempting to
blame alternative medicines and discredit the industry as a result
of the toxicity of this drug (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill). After falsely
condemning the safety of complementary medicines because of this
example of drug toxicity for instance (Pan
Crisis), the Australian government issued a media release
entitled (27)
"Government moves to restore confidence in complementary
medicines industry". Similarly, after the Australian
government and the TGA specifically targeted the safety of
complementary medicines as a result of the toxicity of the drug
hyoscine hydrobromide during the Pan drug debacle, Parliamentary
Secretary, Trish Worth stated (28);
"it is therefore important that all sectors of the community,
including the Government, industry, and health care practitioners,
work together to restore public confidence in the complementary
medicines industry." According to then AMA President Dr Kerryn
Phelps (30):
|
"where things presently stand, the evidence
clearly tells us that complementary medicine faces a crisis
of confidence in the wake of the Pan Pharmaceuticals’
scandal......Public confidence in the sector is
low......What is most vital is that community confidence be
restored." |
The Pan
debacle demonstrated the eagerness of various authorities or opponents of
complementary medicines to falsely blame such products for the
safety issues resulting from consumption of the toxic drug hyoscine
hydrobromide and then offer a solution for this drug
toxicity problem which involved tighter regulation of complementary
medicines! Claims were repeatedly made that tighter
regulation of complementary medicines was necessary in order to
"restore confidence" in the complementary products
which made no one ill during the Pan debacle while in stark contrast
no specific action was deemed necessary to restore confidence in the
toxic
pharmaceutical drugs which caused life threatening illness and which
instigated the entire Pan
drug crisis (Pan Crisis,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill). Expecting the community to believe that confidence
in complementary medicines can best be achieved by exploitation of
fear achieved by falsely blaming them for the toxicity of drugs is
not just a new low in misinformation and scaremongering, it also
represents an unprecedented insult to the collective intelligence of
the community.
The facts are of
course, that complementary medicines are infinitely safer than
pharmaceutical drugs or even food. Food related illness causes
around 5000 deaths in the US alone each year (31)
with another 100 Americans dying each year from food allergies (33).
In Australia around 4 million people suffer from food poisoning each
year but apparently there is so little concern about this issue that
it is not even known how many of these 4 million actually die (32).
Why is there so little legislative concern about food safety and
restoring confidence in the food industry?
Unlike the use of
fear to allegedly 'promote' complementary or alternative medicine,
which seems to be a strange new phenomena, the exploitation of public
fears to condemn or justify increased control of such products or
practices, has a very long history indeed (Medical Bias,
Nutrition is for the
Birds, Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Dispelling the Vitamin E Myths). This exploitation of fear is
usually achieved by the use of loosely based or exaggerated claims
about the safety of complementary medicines, most commonly made by
those who have been traditionally opposed to alternative forms of
health care or those who may reap rewards from legislative
reforms ( Nutrition and Megavitamins,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Dispelling the Vitamin E Myths). Additionally, those who make
such claims frequently seem to avoid comparing the safety of
alternative medicines with pharmaceutical drugs or expressing
appropriate concern about the suffering caused by the toxicity of
drugs. These practices are very popular amongst traditional
opponents of alternative medicine who may feel threatened in some
way by the
popularity of such products (34,35,36,37,38;
see also Medical Bias, Nutrition and Megavitamins, Pan Crisis).
The complaint by
Michelle Beckett of NPNZ regarding the safety of complementary
medicines depends upon her allegation that the claim by Health
Freedom that "no one
has ever died from supplements in NZ", is untrue.
Although NPNZ claims to represent the natural products industry they
also apparently seek to point out the alleged dangers of such
products by citing the report entitled "Serious
Reports to Complementary and Alternative Medicines received by NZ Pharmacovigilance
since 1992 to 31st December 2006" which was issued by
The Centre for Adverse Reactions Monitoring (CARM) or the
New Zealand Pharmacovigilance
Centre. According to Michelle Beckett and NPNZ this report
by the New Zealand Pharmacovigilance
Centre disproves the claim by Health Freedom that ""no one
has ever died from supplements in NZ" and therefore this report
is of fundamental importance.
Because of the
importance of this report I contacted various sources in NZ in an
attempt to obtain a copy of it and assess the reported dangers of
complementary medicines. However, to date my efforts have been in
vain with no one apparently wishing to release what seems to be
rather secretive evidence. Indeed, when I contacted the
New Zealand Pharmacovigilance
Centre they informed me that the information I requested
would only be released to "NZ health professionals". Even
though I pointed out to them that this information was very much in
the public interest my request was refused. And when I contacted
Michelle Beckett of NPNZ, who supplied a copy of this report to ASA
as part of her complaint, she would not comply with my request but
merely referred me to CARM
who had already refused to supply a copy of the report. Just why the alleged
dangers of complementary medicines is such a secret is indeed a
mystery. Especially since publicity of the alleged dangers of
complementary medicines is of fundamental importance to those
seeking to justify increased legislative control of such products,
why has this information seemingly been classified 'top secret'.
Let us all the see the full details of the evidence of the alleged
dangers of complementary medicines. I appeal to the relevant
authorities to publicise the full details so everyone can clearly
see the truth.
Regrettably I am compelled to respond
to this issue without the secretive report in question and therefore
I can only offer general comments.
Firstly I should point out that
allegations of the dangers of complementary medicine traditionally
are usually based upon very flimsy evidence (Pan Crisis,
Medical Bias,
Dietary Supplements,
Functional Foods or Dietary Supplements,
Nutrition Breakthroughs,
Dispelling the Vitamin E Myths,
Alternative Medicine Takeover,
Response
to Government Inquiry,
Therapeutic
Products Bill,
Regulatory Changes in the Land of the Free)
and this may be a very significant reason why there is such a
reluctance to publicise the full details of the report in question. This is hardly surprising since
health experts, including the TGA and the Australian government's own
Expert Committee appointed to examine complementary medicines
following the Pan debacle, have all stressed the safety of such
products (Pan Crisis,
Nutrition Breakthroughs,
Alternative Medicine Takeover,
Response
to Government Inquiry). Usually experts consider that adverse reactions to pharmaceutical
drugs outnumber adverse reactions to complementary
medicines by around 99 to 1 or, at worst, 98 to 2 (Alternative Medicine Takeover,
Response
to Government Inquiry), a fact which clearly indicates, given the
claimed risk based nature of legislative reforms, that safety
legislation should be at least 49 times more strict for
pharmaceutical drugs than for alternative products.
Since complementary medicines have
such a long history of safe use, especially when compared to the
safety of pharmaceutical drugs or foods, traditional opponents of
natural medicines or supplements tend to blame such products for
adverse effects even when there is no clear evidence but merely a
vague 'association' with the alternative product (Dietary Supplements,
Nutrition Breakthroughs, Pan Crisis,
Dispelling the Vitamin E Myths). In fact, it is considered
acceptable to blame alternative medicines for adverse reactions to
drugs which are being taken concurrently, with some experts even
suggesting adverse 'events' can be blamed on complementary
medicines (39,40)
"whether or not it is confirmed to be related to the therapy."
According to the Australian
Paediatric Surveillance Unit (39,40):
|
"An “adverse event” is any unfavourable and
unintended sign (including an abnormal laboratory finding),
symptom or disease associated with the use of CAM, whether
or not it is confirmed to be related to the therapy." |
This guilt by association or
the blaming of complementary medicines for adverse reactions which
may actually be caused by drugs which are being taken concurrently
seems to represent a total abandonment of the normally accepted
criteria for scientific evidence and therefore, in the absence of
any other justification, suggests a
considerable degree of desperation amongst those who seek to
discredit the alternative medicine industry. Strangely, though this
type of flimsy evidence is often sufficient to judge the
adverse effects of complementary medicines, when it comes to the
benefits of such products even anecdotal evidence from millions of
people is frequently considered irrelevant.
In New Zealand it seems similar
principles were recently applied during a survey of the toxicity of
complementary medicines by Nicholson (41).
Although Nicholson found that (41)
"the majority of people reported that CAM had helped them"
and "reported no adverse effects from CAM", she also reported
the following two "most serious adverse effects"; "The two
most serious reactions reported were serotonin syndrome (when
paroxetine was prescribed to a person already taking St John’s wort),
and excessive post-surgical bleeding (in a patient taking
Gingko biloba
preoperatively)." Like so many reported adverse reactions to
complementary medicines, these two incidents were also 'associated'
with standard medical treatments such as drugs or surgery.
Interestingly, neither of these adverse events occurred until the
patients were either given drugs or surgery. It would be
interesting to know how long these patients had been safely taking
their alternative medicines prior to the incriminated medical
interventions but unfortunately this information was omitted from
the report of Nicholson. Although St John's Wort is blamed here for
the serotonin syndrome when the antidepressant paroxetine was given
to the patient (41),
antidepressants have a well known history of causing this disorder
irrespective of herb use (42).
Krone and colleagues have also
recently noted the low risk of alternative medicines in New Zealand
and made the following recommendations (43):
|
"Thus, current levels of vitamin and mineral
supplementation do not appear to pose a health risk for most
of the population. Furthermore, there are important roles
for supplements in treating deficiency states. Conceivably,
supplements could form the basis for inexpensive and easy
methods for preventing various disorders, including
malignancies. These potential benefits of dietary
supplements deserve further study." |
Returning to the matter at hand, it
is interesting to note that the
CARM report cited by Michelle Beckett to
refute the claim by Health Freedom that no New Zealander "has
ever died from supplements" may only be a report listing an 'association'
of adverse effects with "complementary and alternative medicines"
(Appendix 1).
Since she has claimed that the assertion by Health Freedom that "
no one has ever died from supplements" is untrue, Michelle
Beckett should be able to prove this is so by supplying
scientific evidence. But in her statement she describes the report
she uses to refute the claim of Health Freedom as merely showing
adverse events which have been 'associated' with
"complementary and alternative medicines" (Appendix
1):
|
"CARM reports summary for Serious Reports
to Complementary and Alternative Medicines received by NZ
Pharmacovigilance since 1992 to 31st December 2006 lists 3
deaths, 24 Life Threatening Events, and 25 cases requiring
hospitalization associated* with Complementary and
Alternative Medicines*. It is therefore in breach of Item 2
(Truthful presentation) of the Code of Ethics."
* Emphasis added |
Quite clearly, guilt by
association does not necessarily prove the complementary medicines in
question were at all responsible for the adverse effects reported and
the determination of New Zealand authorities to conceal the full details
of these cases therefore makes it impossible to draw any firm
conclusions. In general terms however, the specific claim that no New Zealander "has
ever died from supplements" cannot be conclusively disproved by
a report which provides no scientific proof but merely
describes an "association" of certain symptoms or health
outcomes with the use of "complementary and alternative medicines".
Given these facts it is amazing to me that the ASA could uphold this
complaint of NPNZ. I can only assume they have access to concrete
scientific evidence rather than reports describing an "association",
however, I cannot understand their reluctance to release this
information to me when I requested it.
The top secret nature
of the evidence in question, and the persistent refusal to publicise the
full details is not in the public interest and raises huge questions
about the credibility of anyone endorsing such a secretive attitude. If
complementary medicines are so so dangerous why hide the facts? I
challenge the authorities concerned to publicise the full details of
these alleged cases of adverse reactions to complementary medicines.
I expect that the urgency of their action will reflect their concerns about
public health and the safety of complementary medicines.
If I am provided with
the required details I will happily amend this article and provide any
corrections if needed. Until then......... |
| |
| References 1.
http://www.naturalproductsnz.org/newsfile_gateway.php?newsid=186
Natural Products NZ Lays Complaint with ASA over False Claims,
Media Release, NPNZ, 2nd May, 2007; see also
http://www.scoop.co.nz/stories/BU0705/S00043.htm ,
Scoop Independent News, 2nd May, 2007.
2.
http://www.naturalproductsnz.org/about.htm
3.
http://www.naturalproductsnz.org/newsfile_gateway.php?newsid=49
Natural Products Summit Hears of Sector's Need for Scientific Support,
Media Release, NPNZ, 26th March, 2003.
4.
http://www.nzhealthtrust.co.nz/pdf/ANZTPA_Public_Briefing_Points_Summary_11_Feb_07%20.htm
ANZTPA Public Briefing Points Summary 11 Feb 07, NZ Health Trust.
5.
http://www.nzhealthtrust.co.nz/pdf/rebuttal_Kings_article.htm
Rebuttal to Annette Kings Article, 13th March 2007, NZ Health Trust.
6.
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