Analysis of the April 2003 Draft Report of the
New Zealand Ministerial Advisory Committee
on Complementary and Alternative Health (MACCAH)

Section 2: Policy Issues Surrounding CAM

2.2 Consumer Information Needs

[Comments in red by Stephen Barrett, M.D.]

What sort of information do consumers require?

Provision of consumer information is currently fragmented. Action is required to find out what consumers need to know, and to give them better access to comprehensive, reliable ,and objective information about CAM. The proposed CAM database should go some way to meeting consumers' needs for information on safety and efficacy (see page 13).

Questions 10   11 Do you think that consumers need more, or better quality, information about CAM?   On what aspects of CAM do you feel consumers need more, or better quality, information? For example:   -- safety -- effectiveness -- practitioners (eg, qualifications, contact details) -- regulation -- complaints procedures -- other (please specify).

[Consumers definitely need better quality information about "CAM." At the present time, most information sources exaggerate what "CAM" methods can do and very few provide appropriate criticism.]

Who should be responsible for informing consumers about CAM?

A variety of organisations currently provide information on different aspects of CAM., These include the Ministry of Health, consumer associations and various groups and individuals within the CAM sector (eg, practitioners, professional bodies, supplement manufacturers). However, no agency has overall responsibility for providing or co-ordinating consumer information on CAM in general, or for ensuring the quality and reliability of such information. [Throughout the world most government agencies are unwilling to advise consumers about the negative aspects of "CAM."]

Through Medsafe, the Ministry of Health has taken the lead in providing safety information on herbal medicines (eg, product alerts) and has developed guidelines for manufacturers on providing consumer medicine information (CMI) (Medsafe 2001). The CMI guidelines could be adapted for use by CAM product manufacturers. [Most information about the danger of herbs comes after serious harm has been done. As far as I know, no government agency has developed or disseminated comprehensive information about the fact that (a) most herbal products do not work as advertised; (b) many herbal products do not contain what their label states; and (c) most people who preferentially prescribe them do not have sufficient training to make appropriate diagnoses or render appropriate treatment. Nor, as far as I know, has any government agency told the simple truth about homeopathic products -- that they are a fake and a fraud and completely worthless.]

If the responsibility for informing consumers is left primarily to the CAM sector, there may be concerns about the quality and independence of the information available. ["May be" concerns? The vast majority of "CAM" sector sources do not provide trustworthy information.] Similarly, should the Ministry of Health decide to take on greater responsibility for the provision of consumer information, or adopt a co-ordinating role, the CAM sector may have concerns about objectivity, particularly regarding areas such as efficacy and risk. It might therefore be appropriate for the Ministry to collaborate closely with CAM practitioners, practitioner associations and industry groups to agree roles in relation to information provision. It may not be desirable for all consumer information on CAM to come from one source, as consumers may want access to different viewpoints. [Most consumers want accurate information. The way to provide accurate information is to assemble people who will provide it. There is only one reality. Truth is established by the scientific method, a procedure for exposing hypotheses (assumptions) to critical examination and testing. The scientific method provides an objective way to collect and evaluate data. Findings must not be contaminated by the personal beliefs, perceptions, biases, values, wishful thinking, or fraudulent conduct of the researcher. Scientific research requires proper sampling techniques, the highest possible accuracy of measurement or observation, and appropriate statistical analysis of the findings. Reputable scientists strive to publish their findings in peer-reviewed journals so that scientific knowledge can advance.]

Question 12                       13                   14 In your opinion, who should provide information on CAM? For example:   ­ individual CAM practitioners ­ practitioner associations ­ consumer groups ­ the Ministry of Health ­ other (please specify). How do you think the information should be made available? For example, through:   ­ internet sites ­ printed booklets or information sheets ­ consultation with a health professional ­ other (please specify). Do you have any other comments about consumer information needs in relation to CAM?

[Individual CAM practitioners and practitioner associations almost never provide reliable information. Many voluntary and mainstream professional organizations do provide reliable information, but this is usually limited to topics within the scope of the organization. For example, the American Cancer Society provides reliable information on more than 100 dubious cancer methods. Many government agencies provide reliable information, but the scope of this information is not as broad as it could be. The U.S. Food and Drug Administration and the U.S. Federal Trade Commission provide more useful information than any other government agencies. Consumers Union (also in the United States) also provides high-quality information on major topics but its scope is not broad. The two most comprehensive information sources are Quackwatch and the National Council Against Health Fraud, which are aptly described as antiquackery groups.]