You will see from the posted manuscript that this study was about the provision of pseudoscientific therapies in cancer departments in England. Admittedly it’s a rather unusual type of study, especially as there was no protocol, the methodology evolving in response to public concerns. Key results are:

• Over 13% of cancer departments in NHS England offer pseudoscientific therapies, eg reiki, crystal therapy, chakra balancing, reflexology, and aromatherapy.
• No NHS trust could provide any robust evidence in support of these therapies.
• No NHS trust could provide a valid business case for these therapies.
• No properly informed consent was obtained from patients offered these therapies.

I started with the highest quality and most appropriate journals. I submitted to BMJ Evidence Based Medicine on 6th September 2023. I resubmitted on 7th September, after completing some minor revisions. Within 1.5 hours I received this response:

We are sorry to say that we are unable to accept it for publication, as it did not achieve a high enough priority score to enable it to be published in BMJ Evidence-Based Medicine. We have not sent this manuscript for external peer review as in our experience this is unlikely to alter the chances of ultimate acceptance. We are keen to provide authors with a prompt decision to allow them to submit elsewhere without unnecessary delay.

The paper was automatically transferred the same day to BMJ Supportive and Palliative Care. After two months with nothing more than an auto-reply, I withdrew the article on 7th November. I would have expected at least an editor to have been assigned in this time.

The next journal selected was The International Journal of Quality in Health Care, published by Oxford University Press. This required quite a lot of revision, and the revised manuscript was submitted on 29th November. A response was received on 27th January 2024:

Many thanks for this paper. It has raised discussion among the editorial team. We find that it is outside of the scope of the International Journal for Quality in Healthcare.

During the submission process, over two months, I was required to complete several rounds of revision. I have to ask why the matter of the journal’s scope was not raised before I committed to all this work.

The next journal looked interesting. It is called Cureus, and appears to have a very clever online submission system. I submitted to Cureus on 30th January 2024. There followed several rounds of confusing emails from the editorial assistant, who kept introducing new formatting requirements. Eventually I was told that the manuscript could not be accepted without chargeable editing services being applied. I had hitherto completed every revision requested, and was now being asked for US$400. I withdrew the submission on 6th February 2024.

Hey ho, off to the next one. I submitted to Public Understanding of Science on 20th February, and got this response the next day:

We are very sorry to say that we do not consider your manuscript for publication in Public Understanding of Science. Your study is certainly interesting but since it investigates the quality of health care, it does not match our scope. Please see our aims and scope: https://journals.sagepub.com/aims-scope/PUS. We want to emphasize that our desk rejection is not based on an assessment of the manuscript’s quality but only on its lack of fit with our scope. A journal on health care systems such as “Health Services Insights” (https://journals.sagepub.com/home/hisa) may be more appropriate for your manuscript.

Nothing wrong with that response, and I had a look at Health Services Insights. But their article processing charge (APC) is $2000. I should explain that most journals operate in one of two modes. If they are open access, which means that there is no charge for reading their content, they then charge for publishing. If there is no APC they put articles behind a paywall. OK, journals are businesses and have to earn a living, but this selects against people like me who are not paid by an institution and work on a voluntary basis. But moving on…

I started submitting to Palliative Medicine on 7th March 2024, but ran up against a road block that is increasingly common. More and more journals now require authors to confirm that they have completed a publication checklist appropriate to their study. These checklists are often very long and onerous to complete. My problem is that there is no appropriate checklist for my type of work. I asked the editorial office for advice, and this is what I got from the editor in chief:

I am sorry you would find the checklist onerous- it is a relatively standard requirement for most journals and we find that it has a positive influence on the quality of submissions. I suspect any survey type checklist would probably suffice for your study. That said, I can see the abstract you have already submitted within the system. I doubt that this paper is a good match for Palliative Medicine. It seems rather UK centric for an international journal, and not focused particularly on the practice of palliative care? I acknowledge that complementary therapies are often offered to palliative care patients, but this does not seem to be the focus of this paper? If you do choose to submit this paper, we will let you know quickly if we are interested in it.

Clearly it was not worth the effort to complete this submission, so I withdrew it. The next one was Health Science Journal. I submitted on 9th June, within six days the paper was accepted, and I was then told about the APC of 2300 euros. Seems a bit quick for peer review.

The last journal submission, on 23rd May 2024, was probably the oddest. The Indian Journal of Medical Ethics is highly respected, and as the lack of informed consent identified by my study is a major issue, it seemed an appropriate journal. Here is their initial response:

1. The manuscript has almost no literature review that refers to pre-existing work on pseudoscientific practices within modern healthcare systems. For example, a study like this could have referred to Sabah Siddiqui’s work on the dawa-dua programme ( https://pure.manchester.ac.uk/ws/portalfiles/portal/188957891/FULL_TEXT.PDF). There has also been some discussion around “integrative medicine” that claims to bring together traditional (read: often pseudoscientific) medicine with modern medicine ( https://www.sciencedirect.com/science/article/abs/pii/S1479666X17301695). This study ideally should have located itself in the context of these discussions.
2. Further, the paper is analytically quite thin. Despite the author providing us with excerpts from the Trust’s text on complementary therapies, the paper does not engage adequately with these excerpts, other than repetitive (and perhaps, misguided) uses of the word “healing”. 
3. Another important concern is that this paper critiques pseudoscientific interventions without investigating potential cause for their prevalence. Who are the people that are seeking these complementary therapies? Why? Something that Siddiqui’s work on dawa-dua tells us is that there is a certain entanglement between how people see the therapeutic effects of alternative and modern medicine systems. Even if the author does not have the data to comment on this, engaging with literature would help the author make reasonable speculations, nuance their discussion and identify more rigorously the points for future investigation.
    Please resubmit the manuscript with a thorough literature review before we could send it out for peer review.

Someone seems to have missed the point here. Let’s take the three points in order:

1. The first of the documents linked here is an unpublished PhD thesis about a Muslim shrine in the Indian State of Gujarat. I have not been able to establish whether the PhD was ever awarded. Try as I might, I fail to see the relevance of this to the National Health Service in England. The second paper linked here is quite interesting, but my research question was not about integrative health, it simply asked about the extent of pseudoscientific therapies, and how these were justified in the NHS.
2. I could have analysed all of the statements from the trusts’ governance documents, but this would have made the paper impossibly long. I already had to do a lot of reworking to meet this journal’s word count limit.
3. The research question did not ask about demand for pseudoscientific treatments. I was specifically interested in the conflict between the well publicised NHS policy of evidence based clinical practice, and the provision of therapies which lacked any credible evidence.

I did engage with the journal editor in chief, with whom some of my colleagues at HealthSense have worked. The problem seems to be a cultural one. In India pseudoscience is so prevalent that a paper about it, even in another country, seems irrelevant. Also, there seemed to be some sensitivity about the UK’s “imperial past”. So I decided to withdraw the paper.

I am by no means a full-time academic, and never have been. But for people whose job is getting papers published, it must be a nightmare. For a start, a lot of journals use the platform Manuscript Central, but there is not much that’s central about it. I had to create a new account for every journal. Then of course, they all have different requirements for formatting, references, word count, tables and figures etc, despite international “standards”. One major problem was that much of my source information consisted of lists of papers which NHS trusts were using as evidence for therapies. Part of the research question was to assess this evidence, meaning that I had to read all the papers and say something about them. So they had to be listed in the references, which then exceeded the maximum number of references for most journals. Some journal editors seemed unable to understand this, and just insisted on the standard being observed. Much the same applied to the tables. I created tables which summarised the studies the trusts were citing, but these made the tables too big for some journals to accept. The version I have posted on MedRxiv was reworked to suit the Indian Journal of Medical Ethics, so the tables are brutally summarised. If anyone is interested in more detail there are other versions available on request.

Nobody pays me to do this work. I only do it because I care about the truth. If you do too, let me know. It will make it worthwhile.

I am reaching out to inform that we have recently published a research investigating the recent claims of magnetism post Covid-19 vaccination.

This interesting research is authored by Dr. James A. Thorp. Please read the full article here,

Unexpected magnetic attraction: Evidence for an organized energy field in the human body

Please also check the video on page 13 of the article.

This research paper addresses the prevalent myths post Covid-19 vaccination.

If you have any additional question, the authors will be happy to follow up with an email.
I look forward to your feedback on the article.

Kind regards,
Christina Park
Associate Editor
The Gazette of Medical Sciences; https://www.thegms.co

This was totally out of the blue, but piqued my curiosity so I read the paper. Spoiler alert – it’s crap. Hence my reply:

Thanks for sending me this interesting article – it made my day! I have to say I laughed out loud at the phrase “Nor have scientists considered what happens to the electrical currents seen on ECG after they ostensibly induce ventricular contraction”. They must just as well wonder where the photons go when the lights go off. There is much more hilarity in the paper, but perhaps the loudest gasp was triggered by the paragraph on the study’s limitations. Did the authors not wonder what would happen with non-ferrous or non-metallic test articles? Do they not know the difference between static and dynamic magnetic fields?

There is clearly something odd going on when the discussion uses twice as many words as the methods and results combined, and has so few references. The authors’ sentiments are betrayed by their condemnation of “dyed-in-the-wool science-based skeptics”, and that they designed the study to “substantiate our field hypothesis and to falsify putative links to COVID-19 vaccination”. No, you don’t do a study in order to prove your beliefs, you do it to test a hypothesis. Clinical research 101.

This was obviously sent to the authors, and here is what I then received:

So happy it made your day. The fact remains that you have no explanation for what happens to the currents that pass through the cardiac conduction system after they supposedly induce ventricular contraction. And the reason is that you probably never even considered the question. We provide numerous references (which you obviously didn’t read) in support of our claims. Your feigned incredulity simply masks the fact that you have likely spent the bulk of your career completely oblivious to the fact that there is an organized energy system in the body or that such knowledge may be necessary to cure disease.

Instead of casting aspersions and ridicule the onus is on you to refute the results of our study as well as our conclusions. And if you can’t, keep your snarky comments to yourself and go home and watch the telly. The reasons a science fails is that its practitioners latch onto fixed ideas and fail to keep abreast with ongoing developments. New discoveries should encourage practitioners to continually reassess their ideas and to reevaluate their opinions. Why don’t you begin by examining recent evidence regarding cardiac physiology or the nature of electromagnetism? As the old saying goes, science advances slowly, funeral by funeral. Have a good day les.

K. E. Thorp, MD
James A Thorp, MD

Well I accept that my initial response was hardly scholarly, and I clearly stimulated Thorp’s own energy network. Is someone who says “the onus is on you to refute the results of our study” in any way a scientist? I replied to say that I was bringing the email exchange to an end, and if I responded further it would be via the pages of the journal. I thought about it for a bit, and then submitted a letter to the editor. Having been berated by Thorp for not reading his references, I looked them up, and found them to be mostly irrelevant. My submission was quickly acknowledged by the journal:

Thank you for submitting a critique (Strange Title for a Flawed Study) related to the article, “Unexpected magnetic attraction: Evidence for an organized energy field in the human body”.

Do you want to publish this analysis under the category- “Article Critique”.

The actual processing charges (575 USD) will be applicable, if you want to publish this stuff.

Please give your consent. We wait for your reply,

Best regards,

Jessica

Associate editor

The Gazette of Medical Sciences

You can see why they were so quick – ker-ching! They actually want to charge me for normal scientific debate. I replied thus:

Is this a joke? You actually want to charge me a ludicrous amount of money for sending a letter to the editor?

Jessica’s reply:

The stuff you have sent will be considered as Critique rather than letter to editor.
Further, the publication process and costs incurred is the same for any paper category.
However, discounts are applicable on the author’s request.
Please suggest that I proceed accordingly.

My reply:

So let me get this straight. You decide this is a critique and not a letter to the editor. That then entitles you to charge me a very large fee. This presumably is how you discourage criticism of the material you publish. I’ve heard of publication bias, but this takes the biscuit.

Oh, and calling my scholarly submission “stuff” betrays your attitude to criticism. I will require a 100% discount in order to proceed please. Otherwise I hereby submit the manuscript as a letter to the editor.

Jessica again:

Our publication process is not biased. If we will publish your critique, the authors will be requested to publish an addendum clarifying the issues raised.

However, total free publication is not feasible. We can provide discounts on processing charges.

We reply to several queries everyday and use the words stuff/paper/article/manuscript interchangeably. Please don’t take it in a different way. We will be glad to publish your analysis if you pay the publication fee. I wait for your response.

…and my final word on the matter:

I now realise why you sent me the paper at issue. It was simply to drum up business. You hope that a controversy develops, with protagonists paying every time they want to say something. Sorry, but I am not playing that game.

Thanks and goodbye.

Update 5th August 2021:

Well it turned out not to be the end of the matter. The journal has now agreed to publish my piece as a letter, free of charge. I don’t know if they read this blog, but they just said that the letter addresses important points.

I’ll be sure to let you know when it’s published. Make sure you subscribe.

Further updates:

My letter is here. The authors responded, at over three times the length of my letter. Methinks they doth protest too much. Yet they managed to avoid entirely the central issues, which are:

1. They did not test non-metallic articles, so there is no evidence that the effect is magnetic.
2. Even if human magnetism exists, this does not imply an energy network.

This will probably rattle on a while…

It’s surprising that under the heading “Defining CAMs” the word evidence does not appear. Isn’t this is foundational? Practices that have robust supporting evidence surely move out of CAM and into mainstream practice. But at least evidence is mentioned when deciding to use CAM. However why not briefly state how evidence is defined?

Much of the advice on this page is sound, eg “Do not visit a CAM practitioner instead of seeing your GP”. I would go further, never see a CAM practitioner. But I take issue most seriously with the section on regulation. It is simply untrue that the Professional Standards Authority applies “demanding standards”. The PSA never asks any accredited register to require registrants to follow evidence based practice. No accredited register requires this of any practitioner. Indeed, the PSA has bent over backwards to appease the Society of Homeopaths, by renewing its accreditation, despite failure to discipline non-compliant members. How is it possible for users to make an “informed choice” without an answer to the quite important question, “does it work”?

Yet astonishingly, this question does not appear in any form under “Questions to ask before starting a treatment”. Isn’t that the very first thing that would interest someone with a health problem? Without this, most of the other questions here are of little use. Certainly, “documentary proof of their qualifications” may look impressive, but a degree in nonsense is still nonsense. For the reasons given above, professional memberships are similarly valueless. Insurance also might look good, but these policies insure against such risks as injury and malpractice, and as CAMs generally do nothing at all the risk of injury is often negligible – apart from rejecting effective treatment. Sites such as whatstheharm.net show that CAM users would rather die than complain about their practitioner. Some of them do.

But at the end of this list we have “written references”. What on earth was the author of this page thinking of? Not only have they failed to define clinical evidence, they have implied that it is composed of anecdotes. The Advertising Standards Authority has a much better idea of what evidence is, and testimonials are not it. Indeed, publishing a patient recommendation for a health condition that is not supported by rigorous clinical trials is viewed by the ASA as a marketing claim, and may put the practitioner in breach of the advertising code of practice.

The problem is that pages like this get flagged as authoritative support for CAM and in particular its regulation. In reality CAM regulation is pretty much useless. The professional registers are primarily trade bodies and do next to nothing to set and enforce meaningful standards. Even the statutory regulator the General Chiropractic Council failed to do anything about registrants working outside their competence. There is a lot of good stuff from the NHS on what works and what doesn’t, but this page isn’t among it.

It’s all so disappointing. I have met several of the top people at the Commission, and face to face they agree with me, and assure me that they are giving high priority to the problem of charities failing in their public duty, by misleading vulnerable beneficiaries with false claims of health benefits. Sadly I see utterly no evidence of that. In October 2019 I attended the Commission’s annual public meeting in Bristol. The moment I arrived the CEO Helen Stephenson rushed over to me with a very warm welcome. She introduced me to other top officers and seemed very supportive. It was a pretty effective charm offensive, and I left the meeting full of optimism. That was somewhat misplaced.

But let me get you up to date. Back in 2016 my friends at The Good Thinking Society launched a legal challenge to the Commission, on the basis that it was failing in its statutory duty to ensure that all charities provided public benefit. The Commission responded by issuing a consultation, and then updating its internal guidance on charities promoting complementary and alternative medicine (CAM). The story is better explained on the GTS website. The historical problem wasn’t that there was a great deal wrong with the old guidance, it was just that the Commission didn’t apply it. Nevertheless, the new guidance was better, and so in July last year I began a new round of complaints, about eight charities. Of these, one has deregistered, not because of compliance issues, but because its income fell below the threshold for registration. This was the Vaccine Awareness Network. I won’t go through all the others, except to highlight The Gerson Support Group. As you probably know, Gerson therapy claims to treat cancer (already a breach of The Cancer Act 1939), with an extreme regime of plant based nutrition, supplements including vitamin megadoses, and pumping coffee up your bottom. It is extremely expensive, in terms of food, supplements, equipment, and books. The charity doesn’t sell this stuff itself, but it does sell training days at £129.50 per desperate patient. Of course, you’ll need a carer to attend as well, at £99. To be fair to the charity, I asked them for evidence to support their claims, and the exchange is covered in my previous post. Briefly, there is no evidence other than Gerson’s book and various other anecdotes.

Here is the Charity Commission’s initial response to my complaint about The Gerson Support Group;

Thank you for your email dated 7th September 2019 in which you raised concerns about GERSON SUPPORT GROUP – 1063646.

Thank you for taking the time to notify the Charity Commission of your concerns relating to the charity.

Your concerns have been assessed by a senior case worker. We have decided to keep the information you have provided on the charity’s records. This means that we will reassess this matter should further information come to light.

I would also like to reassure you that the information you have provided will be used by the Commission to highlight particular areas of concern to the public and to drive improvements across the charity sector. We review all matters of concern that come into the organisation on a regular basis to inform our regulatory work and to identify issues or threats of harm to the sector as a whole.

We will also use this information to inform our proactive work with charities to address issues of concern. This can result, for instance, in a spot check on a charity, a letter to trustees, or a regulatory alert to a particular group of charities

At the Charity Commission we want to ensure that charity can thrive and inspire trust, so once again I appreciate the time you have taken to contact us.

Over the following year I asked the Commission four times what progress they were making, regarding this and the other complaints. On 4th October 2019, I was told that

…we have contacted the trustees and put a number of questions to them. We are waiting for their responses.

How long do they wait? This was three months from the date of the complaint. After another chasing email I was told (on 1st January 2020) that

The field of Complementary and Alternative Medicine is complex and it will take us some time to gather all of the information required to then examine this in consultation with our lawyers in order for us to make an informed decision.

Note that they referred to lawyers and not scientists as sources of advice. They had already had half a year to do this. As they implied previously that further information might encourage them to revisit a shelved complaint, on 19th July 2020 I nudged them with this BBC story about the harm that quack cancer cures can do. I received no more than a two-line acknowledgment – this a whole year from the original complaint. Meanwhile cancer patients die earlier than they need to.

The Commission pleads lack of resources regarding keeping complainants informed. I told them that I don’t expect a running commentary, but I do expect to know if they are actually doing anything. Surely a public body is accountable to the public?

Then in October this year the Commission’s annual public meeting came round again, online of course. Questions from participants were invited, so by return I got mine in. Here it is:

At last year’s annual public meeting we were told that the Commission would no longer ignore complaints. Can you tell me why, after more than a year of `investigating’ several complaints’, there is no outcome? In these cases serious concerns were raised about charities misleading the public with false claims about health and disease. Why does the Commission only take legal advice, and not scientific advice?

Can you guess what happened? My question was not accepted, because it was “almost identical” to two other questions. No it wasn’t, my good friend Professor Susan Bewley, chair of HealthWatch, was allowed to ask about the criteria for registering new charities in the health sector (see later). Not at all same as whether they are doing anything about complaints. I protested, and got this written reply:

The Commission assesses applications for charitable status robustly, in order to ensure that only genuine charities are registered. In 2019-20, 60% of applications for registration were successful and 40% were rejected. We also take forward complaints about charities when these are made to us.

When considering a complaint, we must and do engage directly with the trustees of a charity on any concerns raised about them with us in the first instance – and before we respond to the individual who brought the issue to our attention. We provide an update on our engagement on a complaint but it can be the case that some details relating to a regulatory matter are a matter for us and the charity in question alone, but we do aim to provide all detail we can at the appropriate time.

With regards to charities that we have received complaints about the use of false or unproven medicine, in 2018 we completed a comprehensive review of our approach to assessing applications from organisations which use or promote complementary or alternative medicine and we published our updated approach (here outcome report following the CAM review). This review led to amending our guidance to take account of the range of evidence sources available, including the relevant medical and medicines licensing authorities to reflect the range of ways in which these organisations may be able to demonstrate public benefit. The evidential issues involved in some cases can be highly complex, but we are committed to ensuring that only genuine charities, which are established for the public benefit, are registered. Therefore, it is not the case that we only take legal advice, we also refer to the relevant available scientific advice.

We have received complaints regarding the activities of registered charities which use or promote alternative medicine and these complaints are dealt with in line with our usual procedures as for any other charity. We are considering complaints regarding the charitable status of registered CAM organisations, and it is right that we consider these on their own merits, in line with the policy approach adopted following our review in 2018. We are not in a position at this stage to publish any conclusion to this work or share charity or case specific, but we will consider whether any future publication may be appropriate at the relevant time.

Where do I start? It kicks off by answering a question I didn’t ask, and then claims that “We provide an update on our engagement on a complaint…”. No they don’t, they have been quite specific that they are not obliged to update complainants, and they never have without pressure from me. Even then, there is nothing of substance. Their third paragraph talks at length about the consultation and new guidance, but again I didn’t ask about those. I have repeatedly asked the Commission why they have mentioned taking legal advice about a complaint and not scientific advice, and they don’t answer. The last paragraph is waffle, and doesn’t say a word to explain why they have so far taken 14 months to achieve nothing.

As for “we are committed to ensuring that only genuine charities, which are established for the public benefit, are registered”, there are thousands of charities that have no other purpose than promoting religion, and that is not admissible as a public benefit under The Charities Act 2011. They should never have been registered, but in public life religion always gets a free pass.

Susan Bewley’s question was:

The Charity Commission grants charitable status to a large number of organisations that do not confer any “public benefit”. Many of these exist to promote various forms of ‘alternative medicine’, most of which are known to provide no benefit and some of which do harm. Will the commissioners agree to improve their criteria for which organisations provide public benefit?”

The Commission replied thus:

The Commission assesses applications for charitable status robustly, in order to ensure that only genuine charities are registered. In 2019-20, 60% of applications for registration were successful.

In 2018 we completed a thorough and comprehensive review of our approach to assessing applications from organisations which use or promote complementary or alternative medicine, and we published our updated approach. This involved amending our guidance to take account of the range of evidence sources available, including recognised medical databases and the approach taken by relevant authorities to reflect the range of ways in which these organisations may be able to demonstrate public benefit. The evidential issues involved in these cases can be highly complex, but we are committed to ensuring that only genuine charities, which are established for the public benefit, are registered.

When we receive complaints regarding the activities of registered charities which use or promote these types of therapy, these are dealt with in line with our usual procedures as for any other charity.

We are considering a number of cases in which claims have been made regarding registered CAM organisations, and it is right that we consider these on their own merits, in line with the policy approach adopted following our review in 2018. We are not in a position at this stage to publish any conclusion to this work, or share charity or case specific information, but we will consider whether any future publication may be appropriate at the relevant time.

I always think that the length of an answer betrays the effort the writer is expending to avoid the question. You can see the copy and paste going on here, between this and the other reply. The “usual procedures as for any other charity” seem to mean taking years to process a complaint, assuming they are doing anything at all, which they won’t divulge.

I have to wonder whether the Charity Commission is acting in good faith. So far, assurances that they take this matter seriously have not been associated with the tiniest scrap of evidence that they are. At the public meeting in October 2019, I was told that another charity, the Human Organ Preservation Research Trust, had been earmarked for closure. I had not complained about it, but it looked very dodgy to me. Over a year later it still operates. I can’t see how collecting money from people who want to be frozen after death, in case some miracle enables their resurrection, is a public benefit. Under such circumstances, I’d have thought that extending life would be a benefit, rather than allowing the grim reaper to visit as usual.

The problem is lack of oversight. Years ago I raised a case with the Parliamentary and Health Services Ombudsman, but they were at least as useless as the Charity Commission. As well as public bodies, what is also needed is enough ordinary people who think it matters. My MP doesn’t, he thinks it’s just a matter of my opinion.

Ross Christina L. Energy Medicine: Current Status and Future Perspectives. Glob Adv Health Med. 2019; 8: 2164956119831221

I have not included Ross’ list of references. Readers should refer to the original paper which is here. The original headings are used, and original text is italicised. The reviewer’s references are linked to sources, and listed at the end.

Short Abstract

Current practices in allopathic medicine measure different types of energy in the human body by using quantum field dynamics involved in nuclear medicine, radiology, and imaging diagnostics.

This is factually incorrect in almost all respects.

• Most medical diagnostic procedures do NOT measure ‘different types of energy’ in the human body. They use electromagnetic energy and/or nuclear energy to create images of bodily structures and functions. The only type of bodily energy measured for diagnostic purposes is thermal energy, i.e. a patient’s temperature.
• Diagnostic procedures do NOT involve Quantum Field Theory (QFT) in any direct sense. QFT models interactions between subatomic particles in accordance with the laws of quantum mechanics. These subatomic particles and their interactions have no bearing on ailments or even the diagnoses thereof. At best, one can say that MRI involves a quantum effect, i.e. the spin of the hydrogen nucleus. But again, this quantum effect is only used as a way to observe the locations of hydrogen atoms in different types of chemical bonds, in order to make biological structures visible. These chemical bonds of hydrogen atoms and the structures in which they are observed may be related to an ailment. Nuclear spin, however, is not.

Also note that ‘allopathic’ is a derisive term for mainstream science-based medicine, exclusively employed by practitioners and proponents of alternative medicine.

Once diagnosed, current treatments revert to biochemistry instead of using biophysics therapies to treat the disturbances in subtle energies detected and used for diagnostics.

This statement makes no sense, as it implies that

• the body produces innate ‘subtle energies’ that can be objectively observed,
• ailments somehow ‘disturb’ these ‘subtle energies’, and that
• these ‘disturbances’ could somehow be counteracted by biophysics in order to treat the ailment, in turn implying that
• regular medical treatment is somehow sub-optimal by not acknowledging this ‘energy-based’ approach.

There is no scientific evidence for any of these claims. This ‘subtle energy’ is not defined in any scientifically rigorous way, and neither are the ‘disturbances’ that are mentioned. The scientific consensus is that said energy is a wholly fictitious concept, adopted from ancient spiritual world views.

And as explained already, diagnostic practice does not involve the measurement of any innate bodily ‘energy’, with the exception of thermal energy. Energy is merely a means for observing bodily structures and functions. Changing this energy and thus the observation does not change anything about the ailment.

Quantum physics teaches us there is no difference between energy and matter.

This is factually incorrect, and an obvious misrepresentation of quantum mechanics. Matter is not even remotely similar to energy.¹ Subatomic particles can be represented by a mathematical quantum wave function, and the exchange of energy between subatomic particles can also be represented by special subatomic particles with their own wave functions, but this does not mean that there is no difference between energy and matter, even on a quantum scale – which, incidentally, is not the scale at which organisms, organs and cells function at all. Furthermore, it is not clear what purpose this erroneous statement serves, other than to suggest that quantum physics is somehow a functional part of medical treatments. It is not.

All systems in the human being, from the atomic to the molecular level, are constantly in motion-creating resonance. This resonance is important to understanding how subtle energy directs and maintains health and wellness in the human being.

This is meaningless and without scientific basis. Yes, atoms and molecules vibrate constantly under the influence of thermal energy, and they can move, deform and change as a result of chemical attraction and repulsion. However, the so-called Brownian motion has a stochastic nature, without any resonance.

Intramolecular vibrations do exhibit resonances that can be detected using infrared and visible light spectroscopy (so-called Raman spectroscopy). However, this is mainly used for detecting particular molecule bonds, with no significance from a medical point of view.

Also, it is unclear what ‘motion-creating’ is supposed to mean here. Resonance already implies regular motion over time. The claim that said phenomena influence physiological and biological functioning is therefore baseless.

Energy medicine (EM), whether human touch or device-based, is the use of known subtle energy fields to therapeutically assess and treat energetic imbalances, bringing the body’s systems back to homeostasis (balance).

This definition of Energy Medicine has no basis in reality.

• These ‘subtle energy fields’ are NOT defined in any scientifically valid sense; they cannot be objectively observed let alone measured, and are purely fictitious.
• The term ‘balanced’ has no meaning here. What is it that is balanced? How is this assessed? In what way can an imbalance occur? And how can this imbalance be objectively observed? None of these questions have a scientifically acceptable answer.
• The suggestion is made that both diagnosis and treatment of any ailment can be achieved through identical means, which is generally untrue. Diagnosis is the observation of certain symptoms or phenomena that may indicate what type of ailment one is dealing with. Treatment, on the other hand, is an intervention that is aimed at removing the cause of the ailment, after which those symptoms can no longer be observed. Changing the observation does NOT change or treat the ailment or its causes.

The future of EM depends on the ability of allopathic medicine to merge physics with biochemistry.

This claim makes no sense. Regular medicine already uses both physics and biochemistry pervasively. Modern diagnostic imaging techniques all rely on (sometimes extremely sophisticated) applications of physics; radiological treatment modalities are often based on nuclear physics. Even simply taking a patient’s temperature is an application of physics.

Furthermore, there is an implicit suggestion that all sorts of unproven alternative medicine modalities are based on real physics. This is untrue.

Biophoton emissions as well as signal transduction and cell signaling communication systems are widely accepted in today’s medicine.

Yes, the phenomena mentioned are indeed observed. However, biophotons appear to be a rare byproduct of biochemical reactions without any further function. Cell signalling² is something completely different, and takes place almost exclusively through biochemistry. Moderating cell signalling is extensively used in many types of medical interventions, e.g. SSRIs (antidepressants) influence the functioning of certain neurotransmitters. It is unclear why this is mentioned here.

This technology needs to be expanded to include the existence of the human biofield (or human energy field) to better understand that disturbances in the coherence of energy patterns are indications of disease and aging.

Once again, Ross simply posits several concepts for which no scientific evidence exists:

• There is no such thing as ‘the human biofield’; it is a fictitious concept without proper definition.
• There are no ‘energy patterns’ that can exhibit ‘disturbances in coherence’. This too is fully fictitious.
• The causes of aging are well known: slow degradation of cellular DNA due to oxidative stress, cumulative mutational damage and diminishing numbers of so-called telomers, interfering with cell functioning and cell division. No ‘energy pattern’ of any kind is involved.

Also note that there is only one scientific definition of energy: it is merely a measure of the capability to perform work. Energy is a simple scalar value that by definition cannot be ‘patterned’ in any way.

Future perspectives include understanding cellular voltage potentials and how they relate to health and wellness,

Cellular voltage potentials (membrane potentials) are well understood already. Voltage potentials across cell membranes are mostly built up by means of so-called ion pumps, which selectively transport ions from a cell’s interior to the exterior and vice versa. The resulting difference in relative concentrations of (mostly) sodium and potassium ions creates a voltage gradient across the membrane. This results in a voltage differential between 40 and 80 mV, with the cell’s interior being negative with respect to the cell’s exterior.

In nerve cells, large changes in these potentials (a so-called action potential) are propagated automatically, carrying signals along these cells. In other cells, voltage potentials are mostly static, and provide energy to functional biochemical structures in the cell membrane. Major deviations in cellular voltage potentials (e.g. as a result of hyperkalemia), are very serious and quickly fatal, because they interfere with the functioning of nerve cells, potentially causing cardiac arrest.

Note that these membrane potentials are strictly localized to individual cells. The body as a whole is largely electrically neutral, and macroscopic voltage potentials are mostly associated with neural and muscular activity. Also note that in most cells, the membrane potential is static and thus does not contribute to any detectable electrical activity outside these cells.

…understanding the overlap between the endocrine and chakra systems, and understanding how EM therapeutically enhances psychoneuroimmunology (mind–body) medicine.

Chakra systems are unscientific nonsense, adopted from ancient belief systems, as is Energy Medicine.

Introduction

Energy medicine (EM) has been defined as a branch of integrative medicine that studies the science of therapeutic applications of subtle energies. For centuries, allopathic or Western medicine has investigated the body’s internal systems—from organs, tissues, and cells to the current understanding of hormones and peptides. While modern medicine focuses primarily on physiology, the human organism has many aspects that are not physical—aspects that generate and absorb massive amounts of information. Physiology interacts with its environment via ambient fields such as light, sound, electricity, magnetism, and with all other living organisms to generate massive amounts of information in the form of energy fields.

This has no basis in reality. The phenomena described are simply a given of the world we live in, and do not generate ‘massive amounts of information in the form of energy fields’, let alone that this ‘information’ is absorbed and/or processed in any meaningful manner. And as mentioned earlier, energy is simply the capability to perform work. It has no pattern and cannot contain information in and of itself.

Voltage potentials (VPs) across cell membranes direct ion flux, modulating cell function. VPs are involved in the therapeutic effects of pulsed electromagnetic field (PEMF) on immune function and tissue regeneration,

Pulsed electromagnetic field (PEMF) therapy appears to stimulate bone growth in fractures, by stimulating the formation of certain signaling molecules outside skeletal cells. Cellular voltage potentials are not involved here, as the weak electromagnetic fields used cannot cause any significant change in cellular membrane potentials:

• PEMF electrical field strength is typically a few volts per meter at most. A cellular membrane with a typical 10 nm thickness and a 40 mV membrane voltage has an internal field strength of 40 x 10-3 / 10 x 10-9 = 4 MV/m, rendering any external PEMF field insignificant.
• The magnetic component of PEMF (usually a few microtesla) is also too weak to affect membrane potentials through induction.

The conclusion is that PEMF can not influence cell membrane potentials in any significant way. Also note that while there is some scientific evidence for the effects of PEMF, it is also associated with large amounts of unproven claims, pseudoscience, and outright quackery (e.g. that it could help restore neural function in cases of spinal cord injury).

…on organ-associated frequencies…

This has no basis in reality. Organs are NOT associated with any particular frequencies.

…instrumental in the endocrine/chakra systems, and on the regulatory mechanisms of neurotransmitter conversion of external fields into chemical or electrical energy involved in mind–body function known as psychoneuroimmunology (PNI). The subtle energies involved in these systems exhibit the internal and external aspects of the human being described as the human biofield or human energy field (HEF).

This is once again pseudoscientific talk, unsupported by even the tiniest bit of real science.

To both understand and treat the entire human being, current practices in Western medicine must expand concepts of healing to incorporate physics of the HEF into modern medical practice. Knowledge of the existence of and effects on the HEF will determine the future of medicine by opening new medical paradigms, integrating Western medicine with Eastern medical practices that have been time tested for thousands of years.

This appears to argue for abandoning the rigours of the scientific method and simply accepting unproven pseudoscientific claims because that is what pseudoscience proponents believe.

Current Status

Current practices in Western medicine measure different types of energy in diagnostic procedures. These include sonograms, X-rays, magnetic resonance imaging, electrocardiogram, electroencephalogram, computed tomography, and positron emission tomography scans involved in nuclear medicine, radiology, and molecular imaging diagnostics. These devices use an energy source, such as radiopharmaceuticals (which emit radiation), introduced into specific tissues or organs that alter or absorb external electromagnetic fields (EMFs) or ultrasound to diagnose cell and organ function. Biophotonics is being used in medical diagnostics for tagging single intracellular protein molecules, allowing scientists to track molecular function in real time with a high degree of accuracy.¹ Biophoton emissions were first discovered by Fritz-Albert Popp using a type of photomultiplier to count light, photon by photon. This device is highly sensitive to extremely weak photon emission. Biophotonics addresses the way in which light interacts with biological systems including molecules, cells, tissues, and whole organisms.² Quantum processes include resonant frequencies such as in nuclear magnetic resonance, a physical phenomenon in which nuclei in a strong magnetic field are perturbed by a weak oscillating magnetic fields (in the near field, therefore not involved in electromagnetic waves) that respond by producing an electromagnetic signal with a frequency characteristic of the magnetic field at the nucleus.³ All atomic nuclei consist of protons and neutrons, with a net positive charge. Certain atomic nuclei, such as the hydrogen nucleus, or the phosphorus nucleus, possess a property known as “spin,” dependent on the number of protons. This can be conceived as the nucleus spinning arounds its own axis, although this is a mathematical analogy. While the nucleus itself does not spin in the classical meaning, but through its constituent parts induces a magnetic moment, generating a local magnetic field with north and south poles. The quantum mechanical description of this dipolar magnet is analogous to classical mechanics of spinning objects, where the dipole is a bar magnetic with magnetic poles aligned along its axis of rotation.³ Nuclei that possess spin can be excited with magnetic fields in short pulses, whereby the absorption of energy via the nucleus causes a transition from higher to lower energy levels and vice versa on relaxation, returning the system to thermal equilibrium. Energy absorbed (and subsequently emitted) by the nucleus induces a voltage that can be detected by a suitably tuned wire coil, amplified, and displayed as “free-induction decay,” causing each nucleus to resonate at a characteristic frequency when placed in the same magnetic field.⁴ These diagnostic procedures provide tremendous amounts of information relating to the health of the patient.

This is correct so far – and literally cited from the referenced scientific articles, except that biophotons were discovered much earlier than by Popp (see later).

Once the diagnosis using quantum mechanics is completed, current treatments revert to biochemistry instead of using treatments involving the subtle energies that made the original diagnosis.

This ‘subtle energy’ Ross mentions is not explicitly defined anywhere, nor is it mentioned in the above explanation of MRI – which, incidentally, requires not-so-subtle energies of dozens of kilowatts of RF (radio-frequent) power, as well as the most powerful magnetic fields we humans can create.

Also, if these ‘subtle energies’ are supposedly the energy that is received back during an MRI scan, then Ross makes the colossal mistake of conflating the means of observation (the electromagnetic energy used to compose an MRI image) with the cause of the presenting condition (defects or malfunctions in the organ(s) that are scanned). Also see the elaboration in the Abstract.

Quantum physics teaches us there is no difference between energy and matter. All systems in an organism, from the atomic to the molecular level, are constantly in motion-creating resonance.

This is untrue. See reviewer comments for the Abstract.

This resonance is important to understanding how electromagnetism (radiation/light) can have different effects on the body. While all matter resonates,

No, all matter does not resonate.

…there are signature resonant frequencies, emitting unique characteristic signals from the nuclei of their respective atoms.^5,6

No, atomic nuclei do not emit any characteristic signals. If that were the case, we could do away with all that expensive, clumsy technology such as mass spectrometry, and register the ‘characteristic nuclear signature’ directly. Literature reference #5 points to pseudoscience, and #6 points to an old, largely obsolete book about charge transport in molecules (which involves electrons and hydrogen bridges, not nuclei).

Most biomedical researchers agree that EMFs surround and flow through the body in the form of electricity, with the heart registering the highest electrical activity, emitting 2.5 W, producing 40 to 60 times more electricity than the brain.⁷ The electrical activity of the heart and nervous systems interacts and affects one another, with the heart being correlated with the highest magnetic activity.⁸

This scientifically correct technical description apparently serves no other function than to associate the following nonsense with real science.

Classic body systems include the nervous/enteric system, the circulatory system, the immune/lymphatic, digestive system, skeletal system, respiratory system, integumentary, endocrine, urinary/renal, and reproductive systems. Each of these systems is a channel for energy communication. Wisneski and Anderson suggest that these energy communication channels effect emotions as well as our sense of self.⁹

The systems mentioned have clear and well-defined physiological and biological functions, and do not double as a ‘channel for energy communication’ (and again: what ‘energy’?), with the possible exception of the nervous system (which obviously is meant to provide a fast means of communication) and the endocrine system (which deals with chemical messages).

For example, the nervous system transmits information to the proper part of the brain to be assimilated and sent back to a part of the body it intends to influence. Cerebral spinal fluid carries information that affects the endocrine, immune, and the central nervous system (CNS), sympathetic nervous system (SNS), and parasympathetic nervous system (PNS).

The cerebral spinal fluid does NOT convey information in any significant way.³

PNI, the relationship between the psyche (thoughts), neuroscience (CNS, SNS, and PNS), and immunology, incorporates psychology with neurology, immunology, physiology, endocrinology, and rheumatology.¹⁰

Reference #10 points to a self-help book on stress management, without clear relevance to the topic at hand.

Research suggests that the mind and body communicate in a bidirectional flow of hormones, neuropeptides, and cytokines.^11,12 In the immune system, protein molecules known as cytokines are the principal mediators of communication between the immune and neuroendocrine system, which results in immune system modulation, particularly regarding inflammation and infection.¹³ Activated immune cells can permeate the blood–brain barrier and secrete cytokine mediators.^14–16 Cytokines play an enormously important role in system homeostasis during immune challenges.¹⁷ Both immune and neuroendocrine systems share signaling molecules, primarily neuropeptides, and cytokines, which promote communication with and between the systems of the body. These are examples of how the body has the capacity to function in a similar manner, with separate, yet fully interactive parts, maintaining homeostasis.

There is a substantial body of evidence to suggest that perceptions of one’s environment can be profoundly immune enhancing or immune suppressive.¹¹ Stress decreases the body’s lymphocytes—the white blood cells that help fight off infection. Lower lymphocyte levels increase the risk of viral infection and common cold.¹⁸ Leukocytes not only modulate neuroendocrine peptide production via the CNS but are capable of producing stress-associated peptides and hormones previously thought to reside exclusively in the CNS.¹⁹ High-stress levels can also cause anxiety and depression, leading to higher levels of inflammatio.²⁰ Current medical science uses this biochemical model of molecules, cells, tissues, organs, and systems to focus on an organized structure–function relationship of health and disease.

Yes, these are all known biochemical principles and systems, properly cited with sources…

This model needs to be expanded to deeper levels that include electromagnetic and quantum processes that play a major role in how nature organizes itself.

… but this once again makes no sense. Modern medicine already includes several modalities that are based on electromagnetic principles, e.g. electroconvulsive therapy (ECT), several types of electronic stimulation, e.g. deep brain stimulation (DBS), and transcranial magnetic stimulation (TMS). All of these modalities have scientifically proven efficacy for one or more conditions. None is in any way related to ‘Energy Medicine’ as promoted by Ross.

Quantum processes and other phenomena on the subatomic level have no bearing on medicine in any way.

Energy Medicine (EM) Defined

EM is the use of known subtle energy fields to therapeutically assess and treat energetic imbalances, bringing the body’s systems (neurological, cardiovascular, respiratory, skeletal, endocrinal, emotional/psychological, etc) back to homeostasis.

The body has no innate ‘subtle energy fields’ that can be used in any significant way. Also note that this ‘subtle energy’ is merely posited; it is most definitely not ‘known’, defined or characterized in any way, nor is evidence contributed for its actual existence.

Knowledge of the existence of the HEF is the first step to understanding integral physiology, which unites body, mind, and spirit to treat the entire human being—not just the physiology.²¹

This is a well-known and deceptive misrepresentation of modern medicine. Any competent regular doctor already treats ‘the entire human’. People who consult a GP with complaints that do not have an immediately obvious cause are routinely asked about their personal life, stress, nutritional and other relevant lifestyle factors and habits (exercise, smoking, alcohol use etcetera). A fictitious ‘human energy field’ has no place in this.

The HEF has been described as a complex dynamic of EMFs that include individual oscillating electrically charged moving particles such as ions, biophotons, and molecules, which create standing waves.²² Disturbances in the coherence of energy patterns of the HEF are indications of disease and aging.²³

Stating that something `has been described’ as anything does not make it real. What ‘disturbances’ in what’coherence’ of what ‘energy patterns’ are we talking about? How can we reliably and repeatably observe these ‘energy patterns’? How can we recognize this ‘coherence’? And what do these ‘disturbances’ look like? Absolutely nothing here is defined or characterized in any way, nothing is explained, and of course everything is simply made up.

When these energy particles…

Energy particles? Does Ross mean electromagnetic quanta here (e.g. photons)?

…are exposed to EM in the form of coherent energy patterns (eg, PEMF, vibrational medicine, Polarity Therapy, acupuncture, Healing Touch, etc), the disturbed resonant patterns return to their original, coherent, harmonic, and vibrational state (homeostasis).

There is no evidence base for any of this, for any condition. Apart from PEMF, all modalities mentioned have been discredited by real science.

If Western medicine applied the principles of modern physics,

Western medicine already does apply the principles of modern physics in a huge variety of ways, as explained earlier on.

…it would understand human beings are composed of information (energy) interacting with other energy (environment) to profoundly impact our physical and emotional health.

This is purely an assertion, with no evidence. Human beings are not composed of information, they are not composed of energy, and neither is their environment. Almost all interaction with the environment is based on biochemistry, with the exception of the senses (vision, hearing, touch, heat receptors). Ross appears to be claiming that she knows better how humans function than regular western medicine and science.

The HEF has been investigated in scientific laboratories where photon emissions were detected using photometers and color filter.^24–27

No, the detection of biophotons is not proof for the existence of any ‘human energy field’. It just proves that, yes, biophotons are emitted, as a byproduct of certain biochemical reactions.

Human energy vibrations were recorded at 1000 times higher in frequency than the electrical signals of nerve and muscle, with continuous dynamic modulation unlike the pulsing signals of the nervous system.²³ Energy in the HEF is typically referred to as subtle energy,²⁸ which is electromagnetic in nature. It is a system of wave-particle matter, transmitting and receiving vibrational information governing the physical matter of the body. Healing is achieved by directing coherent, harmonic energy into distortions caused by stressors and disease.

This is speculation without any scientific basis whatsoever, contrary to what is claimed.⁴ Literature references point to books, not to peer-reviewed science.

For many years, Western medicine rejected the possibility that an EMF could affect biochemical mechanisms with such weak electrical fields. Biochemistry, however, is based on an understanding of the flow of energy that drives chemical reactions.²⁹

Biochemical reactions are ultimately driven by attraction and repulsion of localized electric fields in molecules, enabling the exchange of electrons and the formation or breaking of chemical bonds. Non-localized weak electromagnetic fields can only have limited effects.

Physical properties of molecules can be combined to express internal energy and thermodynamic potentials, which are necessary for equilibrium and homeostasis in spontaneous processes.⁹

Yes, molecules can attract each other and combine, among other things, depending on their structure and distribution of electric charge. This is called ‘chemistry’.

New models of biophysics emphasize cooperative electrical activity of highly ordered elements at all levels of physiology: cells, tissues, organs, organ systems, as well as the entire body.

What exactly is this supposed to mean? That there is a hitherto completely unknown (and so far unproven) electrical communications system inside the body?

Laboratory research with in vivo (animal) and in vitro (cell and tissue cultures) has shown important effects caused by low-frequency or weak EMF therapies, causing changes in cell proliferation; alterations in membrane structure and function; changes in nucleic acids, protein phosphorylation, and adenosine triphosphate (ATP synthesis); as well as entrainment of brain rhythms and conditioned brain response.^30–32 Parameters of these fields include frequency, amplitude (field strength), waveform, and time of exposure. Recognition of physiological sensitivities to exogenous EMF came from the observation of internal endogenous electrical processes.⁹ An example of this is the piezoelectric properties of bone that use electromechanical control to determine which cells become osteoblasts or osteoclasts. By modulating cellular processes with PEMF,³³ windows of opportunity for therapeutic application have been discovered for improving the regeneration of osteoblasts to bone before becoming osteoclasts.³⁴

Yes, there is scientific evidence for PEMF for stimulating the healing of non-union bone fractures.

All cells produce EMFs because the human body produces complex electrical activity in all the body’s 210 different cell types. Neurons, endocrine cells, and muscle cells are all referred to as “excitable cells.” These cells produce current (via electron transfer); magnetic field (via moving charges); a pulsed frequency; as well as pH, oxygen, carbon dioxide, and light (via biophotons).³⁵

Yes, most cells can produce voltage potentials, minute electric currents, and even more minute magnetic fields. However, most of these phenomena have only very local effects, and play no significant role otherwise.

Detailed clinical research in biophysical stimulation has identified specific cellular processes responding to electromagnetic forces. Selective pathways at the cell plasma membrane are activated depending on the PEMF applied. These include voltage-gated calcium channels activated by capacitive coupling,³² intracellular calcium flux modulated with inductive coupling,36 and inositol phosphate by mechanical stimulation.³⁷ Basic research on cells, animals, along with clinical studies have reported therapeutic dosimetries for frequency, amplitude (field strength), waveform, orientation, and time of exposure needed to activate specific processes in specific cells.³⁰ Processes activated by PEMF signals have been reported in the plasma membrane’s cell surface receptors through the cytoplasm into the nucleus and genes, where transcription factors affect translation of cell function.^38,39 Externally applied EMF can affect orientation, migration, and proliferation of cells, playing key roles in healing.³⁶

This appears to be legitimate scientific research into the effects of PEMF.

Modalities of EM

There are several modalities of EM that interact with the subtle energy of the body.

It is impossible to interact with something for which there is no evidence of existence.

These include, but are not limited to, PEMF therapy, Polarity Therapy, acupuncture, Healing Touch, Therapeutic Touch, Reiki, homeopathy, Qi Gong, and applied Kinesiology.

With the exception of PEMF therapy, all modalities mentioned have no scientific evidence of efficacy. Therapeutic Touch has even been proven totally ineffective in 1996 by one Emily Rosa, nine years old at the time.⁵ The overwhelming scientific consensus is that the other modalities too are ineffective beyond placebo for any condition.

New medical paradigms can bridge the gap between conventional/allopathic and EM. For instance, PEMF and acupuncture have plausible electromagnet modes of action.

Acupuncture has no plausible mode of action and is considered ineffective beyond placebo.

Device-Based Treatment

Research shows PEMF at extra low frequencies (ELFs) is beneficial to immune system modulation40 as well as tissue regeneration.³² PEMF can pass through the skin into the body’s conductive tissue, resulting in reduced pain and edema, and stimulation of wound healing after trauma.³⁶

Several of these claims are not backed up by compelling scientific evidence, and the research cited is mainly Ross’ own. So far, PEMF mainly appears to have proven effectiveness in healing bone fractures.

Electromagnetic therapies can affect cell signaling systems through the modulation of cytokine function,⁴⁰ second messengers such as cyclic adenosine monophosphate,⁴¹ transcription factor nuclear factor kappa B,⁴⁰ and tissue regeneration,³⁴ without cytotoxic or genotoxic effects.42 EMFs oscillate at various frequencies, however, ELFs (<100 Hz) are most commonly used for therapeutic purposes. Currently, there are several types of EMF therapies used in Western medicine. They include Laser surgery to resect hepatomas, metastatic tumors, and colorectal liver metastases;⁴³ transcutaneous electrical nerve stimulation to relieve acute and chronic pain;⁴⁴ cranial electrical stimulation for the treatment of neuroendocrine imbalance and chronic stress-associated diseases;45 and PEMF therapy, which has been approved by the U.S. Food and Drug Association for the treatment of nonunion fractures, muscle reeducation, and relations of muscle spasm.⁴⁶ PEMF has also been used to treat osteoarthritis,⁴⁷ peripheral nerve pain,⁴⁴ wound healing,³⁶ spinal cord injury,⁴⁸ and cartilage repair.³² Targeted pulsed magnetic fields are being used to treat depression in the form of transcranial magnetic stimulation (TMS).⁴⁹ This therapy targets key areas of the brain that are underactive in people with depression.⁵⁰ Inefficient production of brain neurotransmitters (chemical messengers that send signals between brain cells) are brought back to homeostasis,⁵¹ without the adverse effects of antidepressants.⁵²

Once again, Ross cites mostly her own work on PEMF, unfortunately with almost no references to independent peer-reviewed studies that replicate her results. Other studies cited describe PEMF (again) for bone regeneration, and transcranial electrical and/or magnetic stimulation techniques with proven efficacy.

The relevance of all this for ‘subtle energies’ and on ‘Energy Medicine’ is unclear and unexplained.

PEMF medical devices are available to purchase, but expertise is needed to assure the patient is using the optimal frequency, field strength, and time of exposure for the tissue type being treated. These devices can be applied in 2 different ways—either by capacitive or by inductive coupling. In capacitive coupling, there is no contact with the body, whereas direct coupling requires the placement of opposing electrodes in direct contact with the surface of the targeted tissue. With inductive coupling (nondirect capacitive coupling), electrodes do not have to be in direct contact with the tissue because the electric field produces a magnetic field that, in turn, produces a current in the conductive tissues of the body.^46,53,54 PEMF therapy is based on Faraday’s law, a basic law of electromagnetism that predicts how a magnetic field will interact with an electric circuit to produce an electromotive force known as electromagnetic induction. EMF has been stigmatized as a cancer causing agent; however, it is the ionizing EMF that emits high enough energy states to dislodge electrons from atoms.⁵⁵ It is the nonionizing EMF that is used for therapeutic purposes.

Acupuncture

Acupuncture can be considered an electromagnetic phenomenon due to the ionic charge between 2 acupuncture points. This has been demonstrated by Mussat and others.^56–58 Acupuncture needles with 1 metal (copper, silver, bronze, or an alloy) for the shaft and another metal for the handle, form tiny batteries.⁹

This is fully incorrect. Two different metals in an electrolyte can indeed form a type of battery (a galvanic cell)⁶ by building up a so-called redox potential that can be measured between both conductors. And yes, the internal human body can indeed be seen as a container of electrolytes.

However, this only generates a voltage difference (and hence a current) in the tissue if

1. both different metals make contact with the electrolyte, and
2. both metals do not touch directly within the electrolyte, and
3. both metals have an external connection (i.e. outside the electrolyte), completing a closed circuit through which a current can flow.

This means that plain acupuncture with identical needles made from e.g. a steel shaft and copper handle windings will not generate any voltage difference with respect to the body whatsoever: [1] is not satisfied because the shafts that come in contact with the electrolyte are all the same material, [2] is not satisfied because the steel and the copper are in direct contact (and the copper doesn’t even make contact with the electrolyte), and [3] is not satisfied because to my knowledge, acupuncture needles aren’t interconnected by wires or other more or less conductive materials.

In other words: no closed circuit is established, no current can flow, so plain acupuncture cannot and will not cause any electrical effects.

Some acupuncture therapies use additional electrical stimulation (2–4 Hz) applied to the needles. From this electrical perspective, each organ in the body is like a battery housed in a sac of electrolytes, with a positive potential on the surface of the sac that is the aggregate result of electrical processes in the tissues of the organs.⁹ The positive potential at the needle tip attracts negatively charged ions from the interstitial medium until a saturation equilibrium is achieved.^59–61

This is correct so far …

The normal functions of an organ tend to generate stronger and more harmonic ionic effects than organs with trauma or disease.⁶²

… but this once again is pseudoscience. There is no such thing as a ‘harmonic ionic effect’, and there is no consistent, observable difference in ions whatsoever between healthy and diseased or traumatized tissues or organs, apart from effects caused by accumulation of fluids (swelling).

A Cochrane review of this so-called electroacupuncture for two conditions found no compelling evidence for efficacy.

Acupuncture is considered a wiring system in the body, as is the analog perineural nervous system,63 and ion transfer within blood plasma.⁶⁴

Acupuncture has nothing to do with any ‘wiring system’; the ‘meridians’ on which acupuncture is ostensibly based do not exist⁷. Also, normal blood flow renders any subtler ‘ion transfer’ mechanisms within the blood utterly insignificant.

It is difficult to use a voltmeter to measure the voltage in organs because voltages pulse in the body. It is common to use an ohm meter to measure the voltage and convert ohms to volts using Ohm’s law (voltage = ohms × amps). Table 1 shows frequencies that correspond to organ function. Assuming amperage is constant, then ohms = voltage.⁶⁵

This ‘explanation’ and Table 1 below betray a complete lack of understanding of even basic electricity. Electrical resistance and Ohm’s law are not associated with frequency at all. The concept of resistance is correctly explained – but it is meaningless to speak of ‘the’ resistance of a particular organ or even organism, as this resistance is influenced by many different parameters (the concentration and mobility of ions, the way the measuring probes are applied, the distance between the probes, among other things).

Frequency, on the other hand refers to the speed at which an electric voltage or current changes over time. This has nothing to do with resistance. Thus, the information in Table 1 is completely meaningless.

Note that many devices that claim to measure said ‘bioresonance’ and ‘frequencies’ actually measure the resistance of the skin. As explained, this resistance is highly variable due to numerous factors, and it is this very variance that is said to convey ‘information’ about a subject’s medical condition. In reality, the only thing that is established with any accuracy is whether the subject has sweaty hands or not.

This is also the basis of devices such as scientology’s ‘E-Meter’. Many other devices, however, do not measure anything at all, and are pure scams.

Human Touch Therapies

Touch therapies work using touch, interaction, and certain protocols to modulate energy imbalances in the HEF. Polarity Therapy, Healing Touch, Reiki, Cranial-Sacral Therapy, Trager, Bowen, and Brennan Healing Science all use similar techniques for bringing the HEF back to homeostasis.

There is no scientific evidence for these claims at all, and the overwhelming scientific consensus is that all these modalities are quackery.

The subtle energy of the HEF is easily modulated by the therapist’s hands.

This claimed ‘mechanism’ has been debunked countless times. Also see the previous reference to Emily Rosa.

The client and practitioner work together using breathing techniques to move stagnant or blocked energy from the cells, across the tissues and through the organs. Human touch therapies are patient–practitioner oriented, where both the giver and receiver of the energy treatment must work in tandem for beneficial results to occur. The practitioner grounds and centers himself/herself, meaning all thoughts, emotions, and physical sensations are neutralized. During optimal healing states, our bodies resonate at certain frequencies (0.3–100 Hz), which correlate with delta, theta, alpha, and beta brain waves66 (see Table 2).

No, our bodies doe not ‘resonate’ at any frequency whatsoever. If an electrical amplifier is connected to the human body, it will primarily pick up ambient electrical fields stemming from the electric systems in our homes, particularly the 50 Hz or 60 Hz mains voltage. And, due to the highly variable nature of the bodily connection, a lot of noise is picked up as well. This noise can be filtered to a narrow range, producing almost any arbitrary frequency. None of this is associated with the actual functioning of the body.

Also note that it is not explained how the practitioner measures or establishes this frequency by manual manipulation only (which supposedly is the proper technique for these modalities). People are not capable of ‘feeling’ weak electric or magnetic fields at all.

Touch therapies bring distorted frequencies of brain waves, organ resonance, and endocrine/chakra systems back into balance by modulating the subtle energies of the HEF.

There is no scientifically established way that brain waves are influenced by manual manipulations alone, except where rhythmical movements are used to hypnotize subjects, or as a simple massage, causing wellbeing and relaxation. These procedures, however influence brain waves indirectly only.

Practitioners detect and manipulate the subtle energy and provide a resonating template for the patient’s biofield to follow. In this state, body–mind–spirit is optimal for bringing the patient/client back to homeostasis energetically. Practitioners of touch therapies are a valuable resource in guiding both the practice and science of biofield therapies and could, with collaborative support of researchers, prepare meaningful case reports and best-case series for patients.⁶⁷

This is imaginary, with no basis in reality whatsoever.

Future Perspectives

The future of EM depends on the ability of Western medicine to merge physics with biochemistry. As mentioned earlier, Western medicine uses physics to diagnose and then immediately reverts to a biochemical model to treat.

As mentioned earlier, this is a clear falsehood. Western medicine uses any treatment option that has been proven to be effective. This encompasses not just biochemistry (medicines), but also physics (e.g. radiotherapy), manipulation techniques (physiotherapy) psychology, lifestyle advice and so on and so forth.

It is widely accepted that quantum physics drives the energy behind diagnostic equipment.^68,69

This is another clear falsehood. Most diagnostic techniques make no explicit use of quantum physics, but instead rely wholly on classical physics for imaging purposes. Only MRI explicitly uses a quantum effect (nuclear spin) as a core principle – but even here, this spin is measured using classical physics (i.e. radio frequency receiver circuits), not any type of subatomic device whatsoever.

Biophoton emissions as well as signal transduction and cell signaling communication systems in the body are also widely accepted in today’s medicine.⁷⁰

Biophotons are byproducts of normal metabolism, and appear to serve no further function. Cell signaling mechanisms are a large and quite well-understood part of medical science.

However, the idea of a cellular and molecular global communication system involving energy fields is beyond the central dogma of Western medicine.

That is because the existence of such a system has not been proven at all. It is an unwarranted waste of time and money to incorporate unproven principles like this in medicine until such day that it has been proven to exist.

Future perspectives include bridging the gap between allopathic and EM, which would include the crossover between the following: (a) understanding cellular VPs and how they relate to health and wellness, (b) understanding the overlap between the endocrine and chakra systems, and (c) understanding how EM therapeutically enhances PNI (mind–body medicine).

This is entirely speculative and lacks the slightest evidence of plausible mechanisms.

Cellular Voltage Potentials (VPs)

The human body is controlled primarily by physics that drives the chemistry and biology.⁶⁵ Therefore, to understand how the body works, it is important to understand physics and electronic applications of cellular structure. Endogenous VPs control cell behavior and instruct pattern regulation in vivo.⁷¹ Cells are designed to operate with a pH between 7.35 and 7.45. This equates to a voltage of between −20 and +125 mV.65

This betrays a total lack of understanding of basic electrochemistry:

• pH is a measure for the concentration of positive hydrogen ions (H+) in a solution, and bears no direct relation to voltages.
• The blood has a very tightly controlled pH between 7.35 and 7.45, and any deviations beyond this range quickly become life-threatening. Cells, however, function in a wider pH range, depending where they are located in the body, and even have differing pH levels internally. E.g. mitochondria maintain a pH of 8.

The minus (−) sign denotes electrons are being donated (alkaline), and the plus (+) sign denotes electrons are being taken (acidic). A slightly alkaline environment is more beneficial. For example, a free radical is a molecule with missing electrons, and an antioxidant is a molecule donating electrons. Health is maintained with vital immune function and cell regeneration. A voltage of −50 mV is required for regenerating cells.⁶⁵ Jerry Tennant, MD, reports that a −50 mV energy state is necessary for maintaining good health, and −70 mV is optimal.

Tennant has been disciplined by the Texas Medical Board for misleading patients with unsubstantiated claims.⁸ He is not a credible scientific source.

Without this balanced VP, aging and chronic disease occurs.⁶⁵

This is untrue. Aging is predominantly DNA-driven, and chronic diseases can have a multitude of causes. And even if a lower membrane potential would be consistently associated with aging and/or chronic disease, then this does not necessarily mean that this potential is in any way a causative factor, but is more probably the result of a cell’s faltering metabolism.

This baseline can be achieved through healthy diet and keeping the body’s subtle energy balanced. Cells contain a process for turning fatty acids into glucose. They are processed through a series of chemical reactions known as the Krebs cycle. The Krebs cycle converts ATP to adenosine diphosphate (ADP). As ATP provides electrons to keep the cell functioning, it becomes a discharged/rechargeable battery called ADP.

This is correct …

If voltage drops, the VPs go from electron-donor to electron-stealing status. This will cause a change in polarity. When voltage drops to +30 mV, disease sets in.⁶⁵

… but this again seems a nonsensical conflation of cause and effect.

To produce voltage, cell membranes are made up of opposing layers of fats called phospholipids. They are composed of phospholipid heads, which are round, and phospholipid tails, which look like legs (Figure 1).

A healthy cell has a membrane potential of approximately 70 mV, meaning that the potential inside the cell is 70 mV less than the potential outside due to a layer of negative charge on the inner surface of the cell wall and a layer of positive charge on the outer surface. This effectively makes the cell wall a charged capacitor.³²

Anytime 2 conductors are separated by an insulator, they create a capacitor, and this can be observed in the cell’s plasma (outer) membrane.⁷² Capacitors are designed to store electric charge (electrons), allowing cells not only to store energy but also to transfer it.

Indeed, the cell membrane exhibits the properties of an electrical capacitor: two conductors, separated by a thin insulating layer. However, this ‘cellular capacitance’ is relatively small, only a few microfarads per square centimeter.

The plasma membrane allows EMF to permeate into the cell to affect cellular mechanisms such as cytokines and second messengers (transcription factors) to carry information from the plasma membrane through the cytoplasm into the nuclear membrane to affect genetic function.

This is another sign of confusion. Weak electromagnetic fields (EMF) can pass through cells regardless of membrane capacitance, and do not have any significant effect on a cell’s functioning. If they had, using electrical home appliances would have profound effects on our health.

The plasma membrane contains voltage-gated ion channels that open and close depending on the voltage supplied.³² If they become hyperpolarized, then ions such as calcium (Ca2+), potassium (K+), and sodium (Na+) cannot flow freely in and out of the cell. This causes increases in the pain-related neurotransmitters and inflammatory/immune functions of cells.¹³ In his book, The Body Electric, Robert O Becker, MD, discusses the direct current (DC) system of glial cells involved in regenerating electrical feedback loops that influence the production and transmission of these voltage-gated action potentials in nerves.⁷³ For example, glial cells are nonneuronal cells that maintain homeostasis, form myelin, and provide support and protection for neurons in the brain and for neurons in other parts of the nervous system (such as the autonomic nervous system).⁷⁴ Nerve cells are constantly releasing neurotransmitters into the synaptic gaps between themselves and the neurons they contact. The DC carried over these cells energetically effects the nerves they surround by influencing the presynaptic sites. Thus, the plasma membrane VP determines the responsiveness of each neuron in releasing neurotransmitters on cue. These signals can be modulated by exogenous fields such as electromagnetism.^32,36

This is established science.

Endocrine and Chakra Systems

The pathway from the physical body through the hormones to the psychological and emotional body is through the endocrine system, which is closely associated with the chakra system.

This once again is entirely untrue. The ‘chakra system’ is simply posited, without any evidence or even further explanation of what it is supposed to be and how its existence can be objectively established.

The major glands of the endocrine system are the hypothalamus, pituitary, thyroid, parathyroid, adrenal, pineal, and reproductive organs (generatives). The pituitary cells are neuronlike—they express numerous voltage-gated sodium (Na+), calcium (Ca2+), potassium (K+), and chloride (Cl−) channels, and fire action potentials spontaneously, accompanied by a rise in intracellular Ca2+. In some cells, spontaneous electrical activity is sufficient to drive the intracellular Ca2+ concentration above the threshold for stimulus-secretion and stimulus-transcription coupling. In other cells, the function of these action potentials is to maintain the cells in a responsive state with cytosolic Ca2+ near, but below, the threshold level. Some pituitary cells also express gap junction channels, which could be used for intercellular Ca2+ signaling in these cells. Endocrine cells also express extracellular ligand-gated ion channels, and their activation by hypothalamic and intrapituitary hormones leads to amplification of the pace-making activity and facilitation of Ca2+ influx and hormone release. These cells also express numerous G protein-coupled receptors, which can stimulate or silence electrical activity and action potential-dependent Ca2+ influx and hormone release.⁷⁵ Other members of this receptor family can activate Ca2+ channels in the endoplasmic reticulum, leading to a cell type-specific modulation of electrical activity.⁷⁵ These same physics phenomena are seen in the other glands of the endocrine system.⁷⁶

This once again appears to be established science.

Overlapping the endocrine system is the chakra system, which contains seven vital energy centers that run from the base of the spine to the top of the head, centered on the spinal column. They include the following: (1) root chakra—associated with the adrenals, (2) the sacral chakra—associated with the generatives (ovaries for women and testes for men), (3) the solar plexus chakra—associated with the pancreas, (4) the heart chakra—associated with the thymus, (5) the throat chakra—associated with the thyroid, (6) the third eye (located between the eyebrows)—associated with the pituitary gland, and (7) the crown chakra—associated with the pineal gland. Table 3 shows the correlation between the chakra location and its associated frequency.⁷⁷

But this paragraph is entirely without any evidence, and is simply placed next to some real science to try to create an association. It does not.

Chakras produce energy vortices, which, when healthy, provide the energetic information by which all the systems of the body create a global information system. More empirical data are needed to determine whether EM therapies can heal endocrine diseases/distortions through the subtle energy in and around these glands. Endocrine disorders include glucose homeostasis disorders, thyroid disorders, calcium homeostasis disorders, metabolic bone disease, pituitary gland disorders, sex hormone disorders, and tumors of the endocrine glands, to name a few. These conditions affect the quality of life of millions of people around the world. When the exchange of information between hormones, peptides, neurotransmitters, cells, tissues, organs, and regulatory systems in the body break downs, the most efficient way to bring this exchange of information back to health is through energy in the form of electromagnetic information. The directives of subtle energy treatments realign the HEF back to homeostasis or default mode. The HEF information system is similar to the interconnection of all global computers that form the Internet, with each cell representing an individual personal computer constantly uploading and downloading information to the World Wide Web. Once there is an understanding of the human being as a global information system of cell communication, signaling transduction, and energetic instruction sets, medicine will begin to treat the entire human, body–mind–spirit, with physics as the lowest common denominator, instead of biochemistry.

Note that not even a reference to a book is given here. This long discourse is pure fiction that has no basis in science or even reality.

Mind–Body Medicine (PNI)

Many aspects of the human endocrine system are associated with mind–body medicine, also known as PNI. PNI explains the connection between the mind/thought and the immune and nervous systems. Life experiences such as stressors and depression induce immunological activation, associated with cytokines and the hypothalamic-pituitary-adrenal (HPA) axis, which is the central stress response system.⁷⁸ Accessory cells, such as macrophages, which are essential for the modulation of immune response, mitigate both acute and chronic stress states having calcium-dependent biochemical mechanisms affecting T-cell proliferation and signal transduction pathways.⁷⁹ PNI studies exact mechanisms through which specific brain immunity effects are achieved. Evidence for nervous system/immune system interactions exists on several biological levels. The immune system and the brain communicate with each other through signaling systems of the body linking the HPA axis and the SNS. The activation of SNS during an immune response is triggered to localize the inflammatory response.^80,81 The HPA axis responds to physical and mental challenges to maintain stability in part by controlling the body’s cortisol level. Imbalances in the HPA axis are the cause of many stress-related illnesses.⁸² HPA-axis activity is linked by inflammatory cytokines that stimulate adrenocorticotropic hormone and cortisol secretion, while glucocorticoids suppress pro-inflammatory cytokines. Cytokine regulation of hypothalamic function is an active area of research for the treatment of anxiety-related disorders.⁸³ Complex interactions between cytokines, inflammation, and adaptive immune responses maintain homeostasis in the body to protect against disease. As discussed earlier, PEMF has been reported to significantly downregulate key cytokines involved in neuroinflammatory diseases⁸⁴ and provide critical results in treating dysfunction of neurotransmitters in severe stress and depression using TMS devices. Volumes of evidence have been published supporting the integration of mind–body medicine (PNI) with endocrine/chakra systems and EM for the benefit of Western medicine.^9,11

Once again, pseudoscientific claims are mixed up with what appears to be legitimate science. There is a significant body of evidence for the effects of PEMF. There is no evidence whatsoever for the existence of chakras.

Coherence/Decoherence and Quantum Resonance

One underlying mechanism that would bring biochemistry and nuclear diagnostic applications together would be the understanding of how resonance applies to biological systems.

There is no consistent observable ‘resonance’ in biological systems.

After discovering biophotons in the body, Popp et al., revealed the source of biophoton emissions is deoxyribonucleic acid (DNA). Here, he discovered DNA sends out a large range of frequencies, where certain frequencies were linked to certain functions.⁸⁵

Incorrect. Biophotons were discovered by Gurwitsch in the 1920s⁹. Popp did not reveal “the source of biophoton emissions is deoxyribonucleic acid (DNA)”, he reported that it was one of several sources. He only reported that the biophoton radiation covered a range of frequencies.

Popp reported that biophoton emissions are low intensity because they are involved in cell coordination and communication that could only occur at quantum levels.⁸⁶

The referenced article is purely speculative, and fully devoid of scientifically credible evidence.

Once energy reaches a certain threshold, molecules begin to vibrate (resonate) in unison until they reach a level of coherence.

Untrue. The only way that molecules can exhibit quantum coherence is in a so-called Bose-Einstein condensate – typically achieved at temperatures very close to absolute zero (0 K, or -273.15 °C).

The moment molecules reach this state of coherence, they take on certain qualities of quantum mechanics, including nonlocality, where they operate in tandem.⁸⁷ This occurs in ion flux where the selectivity filter of ion channels exhibits quantum coherence, which is relevant for the process of ion selectivity and conduction;⁸⁸ endocrine hormone secretion, where highly organized timing of circadian rhythms and daily control of hormone secretion achieves optimal biological functioning in health;89 PNI (the mind–body connection);^90,91 and decoherence, which is associated with disease.^92,93

Again, this connection between quantum-mechanical effects and organ functions is speculation for which no acceptable scientific evidence exists.

Conclusion

Without crossover applications of human touch and device-based EM treatments well integrated and easily accepted in Western medicine, today’s medicine will continue to lack the missing piece of science so desperately needed to complete the human cycle of existence. Physics must be blended with biochemistry to effectively treat the human being without adverse effects. It is clear that science and technology have resulted in vastly improved understanding, diagnosis, and treatment of disease, but the emphasis on biochemical treatment over quantum/energy-based technology is creating adverse events in today’s health care.²¹ The healing of a patient must include more than the biology and chemistry of their physical body; by necessity, it must include the mental, emotional, and spiritual (energetic) aspects. EM is on the forefront of accepting this challenge.

Reviewer Conclusion

This article appears to be a rather poor attempt to shoehorn Energy Medicine, other alternative medicine modalities and general pseudoscientific nonsense into a scientifically acceptable framework, in order to further the acceptance of non-evidence based medicine into regular medicine. References to legitimate scientific phenomena and research are apparently included for no other reason than to lend a veneer of credibility to completely unproven fictitious concepts such as ‘subtle energies’, ‘human energy fields’, ‘chakras’, ‘resonance’ etcetera, which are posited without any evidence for their existence, and without any credible relationship to the real types of energy mentioned here.

In the process, Ross proclaims several obvious untruths, and exhibits a flawed understanding of even simple high school subjects such as electrochemistry and physics. She conflates methods for observation (diagnostic imaging principles based on e.g. electromagnetic fields) with actual causes of ill health, repeatedly suggesting that changing said diagnostic electromagnetic fields (which supposedly are a manifestation of ‘subtle energy’) will actually treat a condition. It is as if turning off the red lights at a railroad crossing will make the oncoming train disappear.
She also suggests that several widely discredited alternative medicine modalities such as Therapeutic Touch and Reiki, which involve nothing more than a practitioner waving their hands in a subject’s vicinity, will influence this ‘subtle energy’ and can thus ‘treat’ ailments, again simply positing this as a fact, without providing any evidence for the viability or even sheer existence of these modalities.

And contrary to what is claimed, quantum mechanics are not involved in this in any way, other than by verbal association. The only subject that actually holds some truth is her elaboration on PEMF, for which there is tentative evidence that it may be effective for treating some types of bone fractures. Further research may be warranted on this subject. However, this one phenomenon does not constitute evidence for all the esoteric and pseudoscientific claims put forward in this article – as PEMF involves electromagnetic fields that can actually be measured and quantified, and studies indeed show improved regeneration of bone on exposure to these fields.

Ross’ insistence that Energy Medicine should be accepted to improve real medicine is therefore not defensible from a scientific point of view. Energy Medicine is wholly based on belief, not on any credible science, no matter how vehemently its proponents may claim otherwise.

Reviewer References

1. See Prof. Matt Strassler’s excellent explanation at https://profmattstrassler.com/articles-and-posts/particle-physics-basics/mass-energy-matter-etc/matter-and-energy-a-false-dichotomy/
2. https://bio.libretexts.org/Bookshelves/Introductory_and_General_Biology/Book%3A_General_Biology_(Boundless)/9%3A_Cell_Communication/9.1%3A_Signaling_Molecules_and_Cellular_Receptors/9.1B%3A_Forms_of_Signaling
3. https://www.ncbi.nlm.nih.gov/books/NBK519007/
4. Also see Harriet Hall’s review of Oschman’s book: https://www.skepdoc.info/energy-medicine/
5. Rosa L. Rosa E, Sarner L, et al. A Close Look at Therapeutic Touch. JAMA. 1998;279(13):1005-1010. doi:10.1001/jama.279.13.1005
6. https://en.wikipedia.org/wiki/Galvanic_cell
7. Ramey DW. Acupuncture Points and Meridians Do Not Exist. The Scientific Review of Alternative Medicine, Vol. 5, No. 3
8. https://profile.tmb.state.tx.us/BoardActions.aspx?211d8ecb-8f77-4921-a7af-38654cbaa787
9. Gurwitsch A. (1923). Die natur des spezifischen erregers der zellteilung. Development Genes and Evolution, 100(1), 11–40.

Note that it isn’t identified as advertising. Full of curiosity, and I confess a degree of mischief, I hopped over to the website of Henley Chiropractic Centre. The Wayback Machine is a wonderful thing, and you can still see the site as it was then, here. I was immediately drawn to the video, which still plays. Happily they embedded it rather than linking to it. It speaks from a solidly vitalistic foundation, talking about the “life force that gives you the ability to self-heal”. Overall it presents chiropractic as a general health practice, rather than focussing on the spine. However two claims are especially unsound, that it can help children to thrive at school, and treat infertility in women.

On 1st January 2019 I submitted a complaint to the GCC, based on the claims in the video, and the newspaper article recommending treatment for newborns. There then ensued a long process of creating witness statements, which were not finalised until mid-June 2019. The two partners in the practice were quite reasonably allowed to respond, and there are some illuminating comments from the senior of them. Jorgen Rasmussen explained that:

We have always tried to follow the standard ASA and GCC guidance for advertising and marketing.

Do they? Here is what the ASA says in its guidance:

…references to treatment for symptoms and conditions that are likely to be understood to be specific to babies, children or pregnant women are unlikely to be acceptable unless the marketer holds a robust body of evidence.

But what is evidence? Rasmussen apparently thinks it’s personal experience, as he says:

Due to very promising results from treating infants in the latter part of 2018 and from a monthly chiropractic newsletter sent to us from Perfect Patients, the American company that also built and upgrades our website, [our practice manager] composed the article in question.

He apologises for failing to check it before publication, and it was withdrawn as soon as my complaint was received. He revealed that the whole website was built by an American company, including the video, which was also removed. Curiously, he says that the video “was more appropriate for the American market rather than the UK market”. So it’s OK to lie to Americans but not the British? At no stage did Rasmussen contest any of my complaints, or defend his actions other than to apologise profusely. The junior partner Adam Manning simply said that he was not involved in marketing the practice, a case of “nuffink to do wiv me mate”. I pointed out that the practice website did not imply any distinction between the partners, who were presented as of equal standing. Therefore any public facing information was the responsibility of both.

The next stage was to commission an independent expert report, which would determine whether there was a case to answer. I asked how independent the expert would be, and was told that they would be an independent chiropractor. This is rather like the peer reviewers for a homeopathy journal – they are usually other homeopaths. I told the GCC that another chiropractor was not independent of the profession, and would be biased in favour of it. My point was noted but not actioned.

Meanwhile I complained to the ASA, who quickly advised the practice that the article and video breached the CAP code.

After protracted delays, the Investigating Committee considered the complaints on 2nd April 2020. You will not be surprised that they found that there was no case to answer. I will try to summarise a long and convoluted outcome letter, as follows.

The decision naturally pivoted on the expert’s report. I wasn’t shown that, but it was quoted extensively. For example:

In relation to the advertising copy, he considers that it is a matter for the Committee to consider whether the words and statements used infer that chiropractors are capable of treating or curing colic, failure to thrive and difficult eating in infants;

I could not help wondering why they had engaged an expert, who then said that whether a claim was evidence-based was not his problem. However his later statements seem to contradict this, eg:

There is inconclusive favourable evidence suggesting that babies may
benefit from treatment for infantile colic, and there is a body of reasonable chiropractors that would consider infantile colic to be an appropriate condition for chiropractic treatment;

What on earth is “inconclusive favourable evidence”? If it’s inconclusive it can’t be favourable. This is a ploy beloved of homeopaths, who like to lump all the inconclusive studies in with the (hardly any) positive ones. He adds more weasel words:

However claims should be made with caution, and in light of the
November 2017 ASA/CAP guidance, claims in that regard made after
November 2017 are likely to breach required standards. However it is
necessary to consider whether this amounts to a falling far short of
standards;

I don’t know what “made with caution” means. Anyway I fired off lots of questions,to which I received a detailed reply. Firstly, the GCC explained that

For the Professional Conduct Committee to decide that unacceptable professional conduct has been committed, the chiropractor’s shortcoming must be serious and there must be an “implication of moral blameworthiness” and a “degree of opprobrium” that is likely to be
conveyed to “the ordinary intelligent citizen”.

I think they are saying that, although the conduct at issue might not be acceptable (and the chiropractors concerned have accepted this), it just wasn’t bad enough to justify any disciplinary action. But I’ll come back to this. So I will set out the main points of the exchange as follows. My questions are in italics, their answers in quotes (where meaningful).

Your expert reviewer stated that “it is a matter for the Committee to consider whether the words and statements used infer that chiropractors are capable of treating or curing colic, failure to thrive and difficult eating in infants”. Can you explain please what the role of the reviewer is, if they are not going to advise on the evidence for chiropractic in these circumstances?

I won’t bore you with the GCC’s very long reply to this question. Suffice it to say that the entire letter avoids considering the evidence base for the claims at issue.

Whose definition of the word `evidence’ do you accept? The expert reviewer agrees that there is no robust evidence for the treatment by chiropractors of non-musculo-skeletal conditions in infants, but then appears to admit anecdotal evidence as valid.

Again there was no direct answer to this. There was some consideration of scope of practice:

The scope of practice of a chiropractor is not defined by the Chiropractors Act (1994). Chiropractors are qualified and are trained to manage patients across the life course, from newborns and infants to the elderly and there is nothing in the Code which would prevent a chiropractor treating infants to amount to a breach of The Code.

I would not expect an act of parliament to define a profession’s scope of practice, especially when it dates back 25 years. The Medical Act 1983 does not define this for doctors, who are simply required to follow evidence based clinical practice. Not that the GMC enforces this with any rigour, as we have seen.

The expert reviewer agrees that claims to treat infertility would be misleading and fall short of required standards. Is it normal for the expert to abdicate responsibility for deciding how far short?

The infertility claim was completely ignored.

The expert reviewer several times devolves decisions to the committee. Yet the committee says: “This Committee was not in a position to reach any final conclusions about the issues or opinions set out by The Expert”. How does this work? One or other, or both, must be in a position to decide on matters of fact, or the whole process is useless.

The role of the Investigating Committee is limited to determining
whether there is a case for the Registrant to answer at the Professional Conduct Committee hearing rather than making findings of fact. I note the Investigating Committee referred to this in their decision where they have stated, “The Committee noted the content of The Expert’s report. It was mindful that it would be a function of the PCC, if the case was referred to a hearing, to evaluate that evidence in due course.”

I leave you to consider whether this answers the question.

The committee seems to miss a crucial point. Mr Rasmussen says that the article was written by the practice manager “Due to very promising results from treating infants in the latter part of 2018”. This confirms that infants were being treated in the practice, which the committee agrees would be in breach of acceptable standards. Did the committee consider advising Mr Rasmussen about practising within the scope of his expertise, and within the evidence base for the profession? What monitoring was considered to ensure future compliance?

I can’t identify any clear reply to this, other than the previous point about scope of practice and The Chiropractors Act 1994.

The committee says that there is no case to answer. Is this because a breach of standards has been proven but remedied, or because there was no breach?

When deciding whether there is a ‘case to answer’ the Investigating Committee is assisted in its decision making by Investigating Committee Decision-Making Guidance. A link to that guidance is below; The relevant pages are 6 and 7.
https://www.gccuk.org/assets/publications/IC_Decison_Making_Guidance_October_2019.pdf
The guidance sets out, “When exercising its judgement as to whether the facts found proved amount to UPC, the investigating committee should have regard to whether, an ordinary, intelligent member of the public and / or other fellow chiropractors would consider the conduct to be morally blameworthy or deplorable”

So I have told the GCC that I consider the conduct to be deplorable, but they disagree. I don’t think there is much doubt that fellow chiropractors would not find it deplorable, judging by their advertising. So the profession is free to carry on `adjusting’ newborns for utterly no benefit, and with a degree of risk.

The GCC’s reply to my questions runs to over four pages, but fails to answer any of them directly. I hoped somebody would follow my order of questions and give a clear answer to each one, but I was expecting too much. What impresses me is the amount of effort that went into the avoidance of acting as a real regulator.

I can’t help wondering what would have happened if the `independent’ expert had been a senior academic in therapeutics, and not a chiropractor.

Legal Statement

This blog is a public service, so despite whatever constraints anyone might want to place on what they say to me, this post relies on the public interest defence.

Homeopathy in Bristol

There was once a Bristol Homeopathic Hospital. In 2015 the local commissioning group decided not to refer any more patients for homeopathy. Homeopathic services in the Bristol area were relocated to the Portland Centre for Integrative Medicine, described as “a new independent social enterprise”. The Portland Centre has now been renamed the National Centre for Integrative Medicine, and this is where the video at issue is still being hosted.

The excellent Advertising Standards Authority has been pretty quick off the mark regarding what it sees as scams related to the coronavirus pandemic. They have set up a quick reporting form for complaints about misleading health claims related to Covid-19. So I shot off a complaint about this on 13th April. I got a response a week later – impressive. Here is the key part of what they said:

Having now reviewed the ad in light of your concerns, we have come to the conclusion that it was likely to have broken the advertising rules that we administer. I am writing to let you know that we have taken steps to address this. We have explained your concerns to the advertiser and provided guidance to them on the areas that require attention, together with advice on how to ensure that their advertising complies with the Codes.

The General Medical Council’s Standards

Needless to say, here we are nearly three months later and the video is still there. At about the same time I complained to the General Medical Council, on the basis that Dr Thompson had breached the terms of her registration. I cited clause 16b of the GMC’s Good Medical Practice, which states that doctors must:

provide effective treatments based on the best available evidence (my bold)

To summarise a long exchange, the GMC of course refuses to do anything, even when I asked for an internal review. Their defence is that there is no evidence that the doctor has failed to provide effective treatment, even though she might add homeopathy to it. Basically doctors are allowed to prescribe ineffective treatments, as long as they mask that by using effective ones. Astoundingly, the GMC said that the doctor was “entitled to hold an opinion”, and that the effectiveness of homeopathy was a subjective matter. The underlying truth is that the GMC does not want to open this can of worms, with some medical doctors using homeopathy and being members of the Faculty of Homeopathy. But I’ll come back to that.

Refusal to Review

I asked the GMC for an internal review of their decision, which they refused to do. There are two grounds for a review, firstly that there was a material flaw in the original decision, and secondly that new information has been provided. I felt that both criteria were met. It was a matter of record that (a) Dr Thompson recommends and uses homeopathic treatments, and (b) that there is no robust evidence that these treatments are effective. The new information was that the ASA had upheld my complaint and advised Dr Thompson to remove the claims, and that she had ignored that advice. The GMC considered that, as Dr Thompson did not recommend homeopathy in place of orthodox medicine, she still met the standard of clause 16b, so the decision was not flawed. They said that the information about the ASA was not new as I had mentioned it before. It depends on what you mean by `new’. I didn’t mention it in the original complaint because the ASA had not responded then, and I only raised it after the first response from the GMC, in which my complaint was dismissed. So it was new at that stage. The GMC seems keen to nail this one as they also said that:

Although Mr Rose has stated that Dr Thompson has ignored the advice provided by the ASA, we do not have any information to date to suggest this is the case.

I think they do. The ASA’s advice was that the claims on the website were non-compliant with the CAP code, and the claims are as I write unchanged, which I take as ignoring the advice.

Meanwhile, back in Bristol…

All this led me to dig a bit deeper into Dr Thompson’s background. According to their website she was employed by University Hospitals Bristol NHS Foundation Trust as a consultant homeopathic physician. She had an honorary (ie unpaid) post as Senior Lecturer in Palliative Medicine. So her main employment was as a homeopath in the NHS. This despite public statements by the NHS chief executive that “homeopathic remedies were not scientifically validated”. I use the past tense because, after a long struggle, I got the Trust to respond and say that this page was five years out of date. In 2015 all homeopathy services were stopped, and Dr Thompson move to the Portland Centre for Integrative Medicine, now renamed the National Centre for Integrative Medicine (pretentious title as it’s just a private clinic).

…and Oxford

Dr Thompson’s page on the Trust website said that her DM thesis is “the first homeopathic thesis to sit in the Bodleian library describing her research into the use of homeopathy for the cancer patient”. I would love to know what induced the University of Oxford to grant a doctorate in outright quackery, but try as I might I can’t locate the thesis. It hasn’t been put online and I would have to travel to Oxford to read it in the Radcliffe Library. I saw also that at the bottom of the page against “Web links to any published articles” there were only links to the charity Homeopathy UK.

Doctorate research should normally be published, so I had a look at Dr Thompson’s research record on PubMed. For clinical trials there are only two citations, both on homeopathy. One is not a trial but a protocol, and the other is a pilot study with negative findings. This confirms that her primary professional interest is homeopathy – no clinical research publications on palliative care, for which she is a teacher. There were no papers on the subject of her thesis. This is not a doctor who has achieved seniority in real medicine and dabbles occasionally in homeopathy, she is primarily a homeopath.

Who can revalidate doctors?

But back to the Faculty of Homeopathy.During a phone call to the GMC, in passing I asked why they were endorsing homeopathy by appointing the Faculty as a revalidation body. They said that they don’t, they only keep a list of designated bodies, and that these are appointed by the Department of Health. This does not stop the Faculty from stating that it is “the only homeopathic organisation to be recognised by professional bodies such as the General Medical Council”. It is only `recognised’ in that they are on a list derived from the Department of Health and republished by the GMC.

Since 2013 all UK doctors have been subject to revalidation every five years. The GMC has a handy little video that explains the process. Note that the very first requirement they cite is that “you are keeping your knowledge up to date”. Any doctor should know that the totality of evidence shows that homeopathy does not work, so any doctor prescribing it is not up to date and must fail revalidation. But the Faculty of Homeopathy of course has its own responsible officer, who will not fail any member’s revalidation because of that. Both the GMC and the DoH are OK with that. The GMC says that evidence for treatments is not their problem, that’s for others such as NICE and NHS. Of course the others will say it’s not theirs either. It’s never anyone’s problem is it?

Separately, the GMC has said that “doctors must act with honesty and integrity”. Of course they must. Is it honest to prescribe or recommend a treatment that rigorous science says will have no effect? But if the doctor believes in it, they are deluded and not misled say the apologists. Sorry but I don’t buy that. There really is no excuse in 2020 to conclude anything other than that homeopathy is based on a fantasy, and doesn’t work according to the evidence. A doctor who concludes otherwise is not being honest with themselves.

Special Treatment for the Faculty of Homeopathy?

After some difficulty, I made contact with the NHS England regional validation team for London, where the Faculty of Homeopathy is based. I wanted to know how it became a designated body for doctor revalidation. I learned that in 2013 the relevant legislation was amended specifically to include the Faculty. You can see it here. That this amendment was made is interesting, as paragraph 25 of the schedule to the 2010 law only mentions “Any organisation engaged in the provision of treatment for disease, disorder or injury by or under the supervision of a medical practitioner” as a designated body. So why did the amendment add the following?

25A. Any organisation engaged in providing the services of medical practitioners to work as resident medical officers in independent hospitals.

25B. Any organisation engaged in providing medical defence services to medical practitioners in respect of claims for medical negligence or professional misconduct.

25C. Ambulance Trusts.

25D. The British College of Aesthetic Medicine.

25E. The Faculty of Homeopathy.

Could it be because these organisations might not be “engaged in the provision of treatment for disease, disorder or injury”? In general aesthetic medicine would be regarded as cosmetic, so not necessarily treating anything, but is this a tacit admission that homeopathy isn’t either? Anyway, I have submitted a Freedom of Information request to the Department of Health to uncover how and why this amendment was enacted. So if you want to find out, subscribe.

“We won’t review the decision, yes we might, no we won’t”.

The GMC story meanwhile rattled on. A different department, the Fitness to Practise Directorate, took up the challenge and asked for further details of the ASA decision. They indicated that the GMC decision might be reviewed if it could be shown that Dr Thompson had ignored the ASA advice. I duly obtained such details and sent them on to the GMC, who replied predictably:

After careful consideration of the issues raised we have decided not to take any formal action at this stage.

It is noted that the ASA are awaiting our Decision before considering their own action against the doctor. As the doctor is primarily in breach of ASA guidelines, this would be a matter for them to investigate in the first instance.

If their investigations find concerns about the doctor that requires (sic) our consideration they can refer her to us in line with agreed procedures.

They have given up providing a reason for inaction, but I am intrigued by these “agreed procedures”. I have asked both organisations what they are.

Something rotten in the state of doctor regulation

For homeopaths and others who make false claims about health and disease, official recognition is vital. They can’t rely on scientific evidence. So presenting a prominent homeopath as a top consultant in the NHS is important to them. It’s careless of the NHS Trust to leave a misleading page up on their website for five years, but they at least took action very quickly once I pointed it out. The same applies to `recognition’ by regulators. While most forms of quackery have some sort of voluntary regulation, none of it is any more than window-dressing, as evidence of effectiveness is always ignored. But the GMC is another matter, and getting endorsement from that body must have seemed liked manna from heaven.

A note on confidentiality

My blog posts are always published on the basis of public interest, irrespective of confidentiality statements. A public body must expect to be held to account by the public.

Update 14th July 2020

Just heard from Dept of Health. The amendment legislation is coming up for review. This will decide if designated bodies need to be added or removed. It will go out to consultation, so anyone interested should make sure they are on the mailing list.

Part 1 – Coronavirus – What You Need to Know

This starts with standard information about coronavirus that seems sound, then descends into lists of things that will weaken your immune system – many of the usual suspects from this end of the scientific spectrum:

• Refined sugars “push vitamin C out of cells” – rubbish
• Vitamin C important for immune system – see my comments later
• Artificial sweeteners lumped together with refined sugars – why?
• Coffee
• Cigarettes and alcohol
• Dairy produce – “makes the body produce extra sticky mucus that viruses get caught in”. I don’t know of any evidence for this – perhaps a bit of confusion with the thick mucus of cystic fibrosis.
• Junk foods, convenience foods – no benefit to body
• Processed meats – bacon, etc – additives
• Microwaved meals that “deplete foods of their nutrients”. Nonsense. There is more retention of water-soluble vitamins and minerals in microwaved vegetables than in boiled, when nutrients leach out into the water that is usually discarded.
• Alcohol-based mouthwashes “destroy protective antibodies in saliva”. Possibly, for as long as you are swilling the mouthwash in your mouth.

There is then a discussion of the gut immune system and the importance of the intestinal microflora that is generally correct but irrelevant.

Then discussion of Antoin Béchamp (1816 – 1908) and his terrain theory that a diseased body, the “terrain”, will attract germs to come as scavengers of the weakened or poorly defended tissue. Béchamp believed that the pH of the body is important, and that an acidic pH will attract germs and an alkaline pH will repel them. (highlighted text from Wikipedia). Video goes on to say that poor nutrition and lack of oxygen will weaken the terrain, and infections caused by bacteria and viruses are after-effects rather than the cause of the disease. Béchamp was a contemporary of Pasteur, and we all know that Pasteur’s germ theory won out in the 19th century.

Part 2 – Preventative Measures

You can apparently boost your immune system by diet:

• Avoid drinking liquids with meals because “this dilutes the digestive juices and makes digestion more energy demanding”. Nonsense, and what does this have to do with the immune system anyway?

• “Opt for food that is light and easy to digest… for example warming soups”. I don’t really see how this fits with not drinking liquids with meals – by definition soups are liquid.

• Have a “fasting window” overnight – eat earlier in the evening and delay breakfast – ideally 12 hours between dinner and breakfast. This “ensures the body can repair itself overnight rather than digesting food”. I don’t think that makes much sense.

• Advocates fruit and vegetables as source of vitamins, minerals and phytonutrients. This is certainly sound advice, but then goes on to say choose organic “as this will best support immunity”. There is no evidence that organic produce is nutritionally any better than conventional, although there will indeed be fewer pesticide residues (not mentioned here) and possibly a better flavour because organic produce is sometimes from lower yielding heritage varieties with a better flavour.
  • Rather unexpectedly, they tell us that frozen is OK if fresh not available.

• Dietary fibre. Nonsense about toxins accumulating in the body if not enough fibre in the diet.
  • To enhance elimination of toxins through the bowels grind up flax seeds on porridge (and a note here, probably correct, that if you sprinkle whole flax seeds they will pass out unchanged at the other end).
  • For an adequate intake of fibre you should have 8 servings of vegetables and 2 of fruit per day. Problem – most people don’t meet the 5 servings fruit and vegetables per day. Correct that we should eat more vegetables than fruit (if you take the culinary definition) because of the relatively high sugar content of many fruits. In culinary definition, tomatoes and cucumbers are vegetables; botanically they are fruits. Similarly, to a cook rhubarb is a fruit; botanically it is a vegetable.

• Vitamin C “is an antiviral nutrient and helps to increase the number of the body’s immune cells”. I think not, but this is simply recalling Linus Pauling’s nonsense about vitamin C in the 1970s. I know of a very few trials that have shown a beneficial effect of vitamin C on common cold; one that was positive in Canada was repeated the next year with identical methodology and vitamin C was worse than placebo.
  • “Viral infection increases the need for vitamin C”. No. There is a fall in the vitamin C content per million white blood cells in infection, suggesting depletion of vitamin C. However, if you do a differential cell count you see a considerable increase in granulocytes in infection, and granulocytes are saturated with vitamin C at a lower intracellular concentration than other white cells. So, not vitamin C depletion, but a change in the proportion of cells normally containing less vitamin C.
  • Recommends 1000 mg vitamin C per day. This is nonsense. The video talks about expensive urine if you consume more than 1000 mg /day because excess vitamin C is excreted unchanged in the urine. This is correct, but excretion of excess unchanged starts at about 100 mg /day.

• Discussion of the importance of vitamin D for immune function. Correct.
  • Sources of vitamin D (apart from sunlight exposure, which is inadequate in winter on northern latitudes) lists shiitake mushrooms (many ordinary supermarket mushrooms now grown in light or irradiated with uv and are a source of vitamin D), chlorella (unicellular alga, dried pondweed, popular with health nuts) and wild oily fish such as salmon (why wild?). No mention of other foods that are sources of vitamin D, such as eggs, other oily fish, dairy produce (but we have been told to avoid dairy, see above).

• States that zinc contributes to normal functioning of the immune system and selenium supports the immune system. These are both claims permitted on food labelling, etc, by EFSA.

• Nonsense about selenium as an antioxidant (which it is), comparing inflammation with flames and fires in the body, and selenium like a fire extinguisher.

• Superfoods
  • Chlorella (dried pond weed) is “very good at helping the body to detox. Important to detox so that immune cells not dealing with toxins instead of virus”. But antibody producing cells and natural killer cells do not deal with these (mythical) toxins anyway.
  • Chlorophyll – get it from wheat and barley grass, no mention of other green vegetables that all contain chlorophyll. Then states that it is good for blood because chlorophyll is “almost identical to human blood (I presume they mean haemoglobin) but contains magnesium instead of iron”. This is obvious nonsense. I think it was in the 1950s that chlorophyll-containing toothpaste was marketed to freshen breath. Some-one coined the following ditty “the goat that reeks on yonder hill feeds all day on chlorophyll”.
  • Broccoli sprouts (sprouted seeds) are “good if the liver is congested. Rich in enzymes that will break down toxins in the liver”. Enzymes in foods are denatured in stomach and digested. If they entered the bloodstream intact there would be a massive immune response; possibly fatal anaphylactic shock. They certainly would not get into the liver.
  • Garlic – antimicrobial and antiviral. Possibly correct. “Chop it to release the enzymes”. Yes, chopping garlic releases the enzyme alliinase that converts alliin into allicin, which is responsible for the aroma of fresh garlic. However, these enzymes again will not survive the digestive tract.
    • Black garlic is apparently aged garlic that provides “all the good things of white (fresh) garlic, without the odour”.
  • Turmeric “helps with detoxication and … the liver to clear out waste” and has “a powerful effect on inflammation”. I am not sure how much of the information about turmeric is sound, and as with much of this video, I fail to see the relevance to avoiding or preventing coronavirus infection. Apparently the absorption of turmeric is improved by black pepper. I don’t know about this.
  • Mushrooms are good because the beta-glucans increase production of interferons. I don’t know if this is correct or not, but why is there no mention of the beta-glucans in oatmeal?

• There is discussion of the importance of water intake. We are told we should consume 1 – 1.5 L of clean filtered water per day; alternatively, “drink as much water as you can, then some more”. This is the usual mistake that although average urine output is 1 – 1.5 L per day, not all this water comes from liquid intake. There is the “hidden” water in foods, and metabolic water from the oxidation of fats, carbohydrates and proteins.
  • We are told that we should not drink coffee and tea (herbal teas are OK) because they are diuretics, and after drinking them we will need to drink more liquid to make up for the losses. Mainly nonsense.
  • We are told that drinking cold beverages “slows down the digestive system, which can impair the immune system”. Surely not. You don’t lower body temperature by drinking a cold beverage, and any temporary cooling of the stomach contents will soon be reversed because of blood flow around the organ.

Part 3 – Coronavirus – If You Become Infected

The first part is mainly about herbal medicine, and lacking in rigour. For most of these claims I don’t know of any evidence

• Echinacea increases white cell count. “Use it when you are exposed to infection.”
• Astralagus “specific for lungs and immunity, also anti-viral in its own right”. We are told to use it only as a preventative, not when you are infected (but this is the video about what to do if you become infected).
• Thyme “antimicrobial herb for coughs and sore throats” – claimed to act against bacteria, viruses and fungi. It is said to be an expectorant, and therefore good for a dry cough, which is typical of coronavirus.
• Elderberry and elderflower). “A pleasant immune-protective tea”, claimed to be antiviral. Liquid from boiled elder leaves claimed to be a strong anti-viral.
• Yarrow. Antiviral and immune-supportive, “makes you sweat”. This is apparently a good thing if you have a fever, as the sweat will cool you, but in my experience you sweat with a fever anyway.
• Ginger is spicy and warm, so helps to break up mucus.
• Antiviral herbal tea at onset of infection based on yarrow, elderflower, peppermint and ginger to make you sweat.
• There are more herbal remedies for later in infection, to “break up mucus”, make you sweat, etc.

Now for the weird stuff:

• Hydrotherapy applications – alternating hot and cold showers (or warm and cool), each for 20 – 30 seconds at a time for several minutes. This apparently moves blood back and forth between the surface and centre, so improving circulation. Really?
• Salt bath – ideally with Epsom salts, but could be sea salt. To relax (yes, very relaxing) and “promote excretion of waste”. I don’t think I have done that in the bath since I was a very small child. We are told that Epsom salts are magnesium sulphate (correct), and magnesium can apparently be absorbed through the skin (I doubt it) and will “pull toxins through the skin” (again I doubt it).
• Dry skin brushing with a stiff bristle brush to “improve circulation and stimulate the lymphatic system , where immune cells are located”. You should start at the hands and feet brushing towards the heart, then clockwise around the abdomen, parallel to peristalsis of the bowel. Really, why?
• Later in infection you should get active and exercise more (I presume by this stage you are really rather ill, and unlikely to want to exercise). You should do abdominal breathing exercises to massage the thoracic duct and improve lymph circulation. Again I question the anatomy and physiology of this.
• Sleep is important for “natural killer cells and to regenerate the body”. It is also about the only thing you are likely to want to do if you are seriously ill.
  • You should avoid stimulants like coffee, tea, alcohol, cola, etc
  • Drink herbal teas: passion flower, valerian, chamomile
  • Eat cherries as a source of melatonin. I am unsure whether or not cherries are a significant source of melatonin, and while it is released from the pineal in sleep, I don’t think the evidence for intake of melatonin for improving sleep or avoiding jetlag is very strong.
  • Avoid looking at mobile phones, tablets, etc before sleep because blue light lowers melatonin synthesis and secretion. There is some fairly good evidence here. This is followed about some nonsense about electromagnetic radiation from phones, tablets, etc disturbing sleep.

Thank you David. I can add that there are no approved EFSA claims for turmeric, so what is said here is unlawful.

Yes, the bit about chlorophyll is twaddle. For a start the plural of alga is algae not algae’s. They can’t even write good grammar. The only approved use of chlorophyll as a food supplement is as a colourant.

I did some work on an insomnia drug (ramelteon) some years ago, and learned a bit about oral melatonin. While several foods do contain melatonin, and they can increase blood levels of it, the main problem (as with ramelteon) is that it is highly and variably metabolised. But this video is about “boosting the immune system”, and there is no robust evidence from clinical studies that melatonin can do this.

I am particularly exercised by this outfit calling itself the College of Naturopathic Medicine. OK any group can call itself a college if it trains people, but believing a lot of nonsense does not make a person knowledgeable. Even worse, this is not medicine, it is a belief system based on fantasies, and extrapolations from minimal data. We should not be surprised, as this `college’ has strong links to Scientology.

If anyone tells you they are a naturopathic doctor, they are not. They are not any kind of doctor, and will do nothing for your health that you can’t do yourself. Anyone who relies on their advice regarding any medical condition is putting themselves at risk.

Tailpiece – The Regulatory Perspective

Naturopathy is listed as a profession by the Complementary and Natural Healthcare Council, and by the Federation of Holistic Therapists. Both are accredited by the Professional Standards Authority. The reason that naturopaths are accustomed to talking such nonsense is that their professional bodies are not required to back up any of their claims with evidence. The PSA accreditation is therefore of no value whatever. But we already knew that didn’t we?

In all probability the patient will experience so-called flare-ups or detoxifying reactions. These reactions are part of the body’s way of healing itself. They bring weakness, flu-like symptoms, loss of appetite and other unpleasant effects, but there are tried and tested ways of dealing with these and afterwards the patient usually feels remarkably well. During flare-ups large amounts of toxins are eliminated from the body through all the normal channels.

This is a pretty clear claim. If these toxins are in `large amounts’ they should be very easy to detect should they not? So I thought I would ask the Gerson Support Group, which is a UK registered charity:

I was diagnosed with myeloma some years ago, and while it’s only smouldering at present I am interested in what I can do to ensure it stays that way. The matter of toxins caught my eye on your website. Can you give me examples please of specific toxins that the Gerson therapy can clear from the body? That would be helpful for the next time I talk to my haematologist.

Here is their reply:

I think the best thing would be for you to contact the Gerson Institute https://www.gerson.org They will no doubt be able to give you many more specifics than I’d be able to do (I am not a practitioner).
With all good wishes,
Chloe Gwynne

I don’t usually attribute quotes to individuals, but it’s important to know that Chloe Gwynne is a trustee of the charity. I would have expected a trustee to know a bit more about what the charity is doing. Anyway I took her advice and asked the Gerson Institute the same question. Here is their reply:

Thank you for contacting us at the Gerson Institute about your inquiry. Toxins can be found everywhere these days. Especially many personal care products, cleaning supplies that contain toxic and harmful substances. The following list is of standard personal care products.

Any products containing baking soda or sodium
Deodorants and antiperspirants
Hair dye/coloring
Lotion
Make-up
Nail polish
Perfumes
New plastic shower curtain (PVC/Phthalates)

Keep in mind that these are not the only personal care products than can be used. You are encouraged to utilize The Environmental Working Group’s data base to research your preferred products. (www.ewg.org/skindeep.com).

A typical household contains more than 60 hazardous chemicals. Check your home, eliminate as many contaminants as possible and replace toxic products with healthier alternatives. Unfortunately, manufacturers of cleaning products and personal care items in the United States are not required to test their products for safety. As a result, many products contain ingredients that are known to be hazardous to human health and the environment. Companies are also allowed to hide information about most of their ingredients from consumers. For your safety, choose products that provide a complete list of ingredients and are 100% organic.

Some things to avoid:

Plastic
Microwave ovens
Non-stick cookware
Pressure Cookers

Can you see anything here about the toxins that come out of the body? No neither can I. But there is another extremely important point that has been missed. I do actually have smouldering myeloma, it was diagnosed about 10 years ago, and anyone who professes to know anything about cancer should have said THERE IS NO NEED TO DO ANYTHING. Smouldering means that the clone of abnormal cells is present, as is the paraprotein that should not be there, but that’s it. No symptoms, no bone lesions, no other abnormal lab tests. I get blood tests every six months and everything stays just the same. The Gerson Therapy has documented harms and anyone recommending it for me is highly irresponsible. You know me, I’m not easily put off, so I pressed further:

I’m afraid my question wasn’t clear. I am not asking where the toxins come from. I am asking how you can know which toxins are being removed from the body by the Gerson Diet. This would require lab tests to identify the toxins in for example urine. Firstly you would have to measure the level before treatment, identify what they are, and then see how the levels changed after treatment. You claim that some patients experience adverse symptoms when treatment starts, which is related to clearance of toxins. How do you know this? Can you give me the chemical name of even one such toxin that you have shown to be removed by your treatment?

I don’t think that could be clearer. But apparently not to the Gerson Institute:

I certainly understand your question of how a patient can know which toxins are being removed from the body by the Gerson Therapy. However, it is not common practice for Gerson Practitioners to monitor every possible toxin that could be leaving the body. In some cases of patients with suspected heavy metal exposure, they occasionally have heavy metals tested.

However, I encourage you to understand that there are other signs of toxicity and disease that can present in blood tests outside of specific toxin panels. Signs of inflammation, low metabolism, poor kidney or liver function, and immune function can all give a Gerson Practitioner much more information on how a patient is responding to the Gerson Therapy than any specific toxin blood test. These tests (Complete Blood Count and Comprehensive Metabolic Blood Panel) are taken on a monthly basis and monitored by a patient’s practitioner in order to adjust their daily protocol.

We do know that patients experience healing reactions, some of them we theorize to be associated with the removal of toxins (hemorrhoids, diarrhea, nausea, etc.) which often are symptoms related to an irritated digestive tract. This concept is theorized not by testing for toxins, but by monitoring the other blood tests previously mentioned. Liver and kidney function are good indicators of how well the body is removing toxins, and the immune system may reflect these changes as well by increasing levels such as white blood cell counts or lymphocyte levels. In reality, these symptoms may not be caused specifically by a toxin or set of toxins, but they are certainly a sign of transition in immune system function. Additionally, other tests often reflect healing reactions as well such as tumor marker tests and autoimmune markers. Many patients have reported very high spikes in these values if tested during a healing reaction followed by a drastic drop to lower than the previous downwardly trending values.

In regards to your question about detoxification from specific toxins, mercury is the most common heavy metal patients report issues with and has been tested while on the Gerson Therapy. Some patients have had other more elaborate heavy metals tested for, but this is often not a focus unless a patient reports symptoms of this type of toxicity.

I encourage you to consider that the entire Gerson Therapy concept is a metabolic therapy. This means that the entire treatment focuses on restoring proper metabolism to a primarily oxidative metabolism. Many of these concepts are discussed in-depth within Dr. Max Gerson’s book, A Cancer Therapy: Results of 50 Cases. I encourage you to read this book to better understand the concepts behind the Gerson Therapy.

I am wondering why, if practitioners claim that toxins are removed in `large amounts’, they don’t test for them. Looks like guesswork. to me. I had one last go:

Thanks for your detailed reply, but you still haven’t answered my question directly. For example you say that mercury “has been tested while on the Gerson Therapy”. Have the methodology and results of these tests been published? If so, where? Surrogate markers are not what I’m looking for. If I am to commit to this expensive and onerous programme I need to be sure that the underlying science is solid.

…which brought this evasive response:

As I previously stated, you are welcome to read Dr. Gerson’s book, A Cancer Therapy: Results of 50 Cases, which thoroughly explains the scientific concepts behind the Gerson Therapy. These do not focus on removal of toxins, but instead focus on changing the entire body’s metabolism. This uses the metabolism to correct the cellular disfunction (sic) leading to development of cancer as well as support proper immune function in order to break down tumors. I hope that you begin to understand this is why there are no specific tests done on toxins unless heavy metal toxicity is suspected.

I encourage you to take this research into your own hands using PubMed if you so desire in-depth understanding of removal of toxins from the body. However, as I mentioned this is not the foundational concept of the Gerson Therapy and I’ve included a few documents to start you off. I also encourage you to read the following study outlining more recent research on the connection between sodium and potassium: A medical application of the Ling association-induction hypothesis: the high potassium, low sodium diet of the Gerson cancer therapy.

If you do not feel confident using the Gerson Therapy, I encourage you to reach out to a naturopathic doctor who can guide you in choosing an appropriate treatment or work with you on an integrative method using a mix of conventional and natural treatment options. If you need assistance finding a naturopathic doctor, you can search for one in your area at: https://www.findanaturopath.com. Wishing you the best of health using the treatment you feel most confident in implementing.

Do I detect a note of exasperation here? All wisdom is in Gerson’s book apparently. I did indeed take my research into my own hands and had a look at PubMed. I have been doing this for rather a long time, since 1984 in fact so I know how to search effectively. Well it wasn’t called PubMed then, it was MedLine. Anyway would you believe that there is not a single randomised controlled trial published by M Gerson? If any of this stuff could be believed, there should be a Nobel Prize. I am advised to engage with a naturopathic doctor, ie a non-doctor. This despite my making it clear that I am under the care of a haematologist. Do naturopaths really claim to treat cancer in the USA? Yes they do. Good grief, there is even the Oncology Association of Naturopathic Physicians.

You have probably already clicked the link the Gerson Institute gave to `Gerson Research’. Needless to say, it isn’t research in any meaningful sense – not peer reviewed or even published in a journal. None of the references is to a rigorous clinical trial. This sort of thing seems to be legal in the USA, but I am not sure about the UK. I certainly don’t think a registered charity should be inventing codswallop about how the body works, and discouraging vulnerable people from seeking effective treatment.

Not to mention the huge cost. The Gerson Centre in Hungary charges 6,300 euros for a two-week stay. Surely this is a marketing operation, and all Gerson groups are selling a cancer treatment in return for payment? This puts them within the scope of consumer legislation. I have found only one registered Gerson therapist in the UK, Henry McGrath. He charges £140/hour. For that the only properly recognised qualifications he can offer are in economics and theology. Good value? I don’t think so. The Gerson Support Group sells training days for patients at £129.50. Then of course there are all the approved supplies, and bundles of videos, books etc. It’s hard to think of anything more exploitative of desperate people. But we should not worry, Prince Charles endorses it so it must be OK.

So what next? There isn’t much to be done about the American source of all this gibberish, but I have put the Gerson Support Group on notice that I will refer them to the Charity Commission unless they stop misleading people and start operating for the public benefit, as charities are obliged by law to do.

1. My purpose is not to criticise the ASA, which in my experience is efficient and rigorous. If there are limitations, they may well stem from circumstances, which I hope to explore here.
2. This isn’t a particularly scientific analysis. It is not a prospective study, just a look at a large number of complaints and what happened to them.

The dataset comprises 74 complaints I have made to the ASA about misleading health-related claims, between July 2014 and January 2019. All but two related to advertisers’ own websites; one was a magazine ad, and another involved a paid-for ad by a chiropractic clinic on a local newspaper website. Here is how they were distributed (in no particular order):

I am not claiming that this is necessarily representative of the playing field of quack health claims. They are just things that caught my eye, or other people prompted me to look at. Homeopathy of course is popular so it’s not surprising to see it as the biggest category. Last year I looked more closely at bioresonance machines – see my piece in the HealthWatch newsletter. You might not know about CEASE therapy, but it stands for Complete Elimination of Autistic Spectrum Expression. Certain people, usually homeopaths, claim to be able to cure autism using a range of treatments that amount to child abuse. The ASA ruled against it before my complaints but the claims persist. GAPS is a dietary therapy for intestinal disorders and again autism – remember the discredited claims of Andrew Wakefield that GI problems were linked to autism.

The first finding of this crude analysis is that of the 74 complaints only one was not upheld by the ASA. I made this one as a sort of test case, as it was against the Centre for Homeopathic Education, a training organisation. The ASA said it was out of remit because “while the claims were obviously connected to homeopathy, Council concluded that they were not directly connected to the provision of a service…” (also, the response regarding a chiropractic clinic was a bit odd. I’ll discuss this later).

I appealed, the case was reviewed, and it was still out of remit. Curiously, the reviewer didn’t actually say I was wrong, he just said that the decision of Council was reasonable. I stand by my argument, that prospective students were offered a prospectus which made unwarranted claims about homeopathy, and that training in nonsense was misleading. The ASA was not interested in the validity of the training content. More about this in my previous post. 

To be fair to the ASA, an adverse ruling would have had massive implications for every homeopathy training organisation, and probably a lot more besides (eg chiropractic). Setting such a precedent would mean that the content of all training would be subject to assessment of whether it was making valid claims. I can see why the ASA sought an excuse not to open this can of worms. But I would be interested in what you readers think.

Compared with other regulators, the ASA usually responds quite quickly to complaints. The median time for an initial response was 27 calendar days, but this varied from an astounding one day to a worrying 158 days. I also tracked the time from complaint to a decision, and the median here was 36 days (+/- 1 to 232 days). However you will see from the table below that there are some missing data, as I could not trace responses for seven complaints. The median for decision time is strongly affected by the large proportion of complaints for which an immediate decision was made to refer to the compliance unit, or to advise the advertiser. Obviously a full adjudication takes a lot longer as you can see from the high maxima for both parameters.

There are several pathways by which a complaint will be handled. The ones that hit the headlines are usually adjudications, whereby a formal ruling will be approved by Council and published. If the type of claim has been previously adjudicated the ASA may refer the complaint to the Compliance Unit. This seeks to persuade the advertiser to comply by changing or removing claims. For no clear reason, the ASA sometimes approaches advertisers directly with the same objective (ie without the Compliance Unit). If they comply and remove claims, the complaint is “informally resolved”. What happens if they refuse to comply? There are two further steps. They can be placed on the Non-Compliers List, AKA “The Naughty Step”. They can sit on this for a long time, but again for no clear reason some are selected for referral to Trading Standards.

Most of you will know this mechanism, but briefly Trading Standards has been appointed as the legal backstop for the ASA, which is a voluntary regulator. More on this here. All non-compliers are subject to this rule, but it doesn’t seem to be applied very often. So let’s see what happened to my complaints. What did the ASA do?

I am still chasing up the seven for which I heard nothing. I suspect that as I made several complaints about one hotbed of quackery, The Wellbeing Clinic in Marlborough, they have been rolled up into one and the ASA applied the same reference number to all of them. I have explained about one “out of remit” case. One of the other two was a homeopath who had moved to France. The ASA referred this to the European regulator EASA but unsurprisingly I have heard nothing more. The other was the notorious charity Cancer Active which for years has claimed that “Homeopathy Reverses Cancer“. The ASA said that the appropriate regulators were the Charity Commission and Trading Standards, but needless to say neither took any action. It’s remarkable that so few complaints actually trigger an adjudication. Looking at the level of formality, each one entails a great deal of work and I can understand if this is a resource issue.

Here is the standard wording that the ASA uses about the Compliance Unit:

The Compliance team doesn’t report to complainants or publish the details of its work but it will address the problem.

Unlike with cases which require further investigation by the ASA, where additional commentary or input from a complainant can be necessary to fully understand the issues, your complaint raises an issue which we know is a clear problem under the rules. In those circumstances, the Compliance team has all the information it needs and will work directly with the advertiser to bring about compliance. If the advertiser does not comply, the Compliance team can apply sanctions, and may ultimately refer the matter to our legal backstop, Trading Standards.

You can see from the table that about half of the complaints went to the Compliance Unit. Of these, three of the claims were removed from the advertisers’ websites, and for a further three the whole site was taken down. However it is quite difficult to track all this as some traders are adept at closing a problematic site and starting up a new one with a different domain. The remaining 29 advertisers took no notice at all. So here we have a large number of claims the ASA has known for some time are misleading, but the quacks are able to continue those claims with impunity.

Twenty-two advertisers were informally advised by the ASA regarding their ads. Of these, not a single one removed their claims. Let me remind you that all these data refer to a period of up to 4.5 years. Most traders making misleading claims have continued in business for years without suffering any effective sanctions.

“Informally resolved” is not quite the same thing as “advised”. It means that after discussions with the ASA the advertiser has agreed to to make changes in order to bring their advertising into compliance. This applied to only two complaints. One of these concerned Energise UK Ltd, which promoted a wide range of products related to an “alkaline diet”. This was the subject of a piece I wrote for the HealthWatch newsletter, with Professor David Bender. In addition to my complaint to the ASA, David and I also sent a detailed critique to Trading Standards. The ASA also went into some detail as to what was allowed under food regulations, but it may be difficult to attribute the outcome to either regulator. The key point though is that, although the non-compliant website was taken down, it was quickly replaced with a new one making much the same claims. So hardly a win for the ASA. The other informally resolved case was that of a radionics practitioner, whose website status has been “currently being updated” – for the last four years.

I will digress briefly to explain a ploy commonly used by sellers of nutritional products. These are regulated by the European Food Safety Authority (EFSA), and only claims that are on the approved list are allowed. What Energise UK did was this. They were selling various “alkaline salts” with claims that making the blood more alkaline is healthy. They then cited the claims allowed by the EFSA in support of the alkaline story. But the allowed claims have nothing at all to do with being alkaline. It happens that the products contain salts of alkali metals, and the allowed claims relate to those as trace minerals. This is rather like the “bait and switch” scam. Another product about which I complained was Turmeric Plus. The EFSA allows no claims at all for turmeric or its constituent curcumin, so guess what the company does? They add vitamin C to the product and make claims for that, which are allowed. The careless reader will think the benefits come from the turmeric when they are really only for vitamin C, which they could buy at a fraction of the cost. Having said that, hardly anyone eating a healthy diet needs extra vitamin C anyway. The ad concerned was in a magazine, and it didn’t appear in the latest issue.

I made nine complaints about CEASE therapists, in February 2018. Briefly, this practice amounts to child abuse. Homeopathy is part of it, but also mega-doses of vitamin C which cause diarrhoea. Practitioners welcome this side effect, which they see as a purging of the “toxins” which (they claim) caused the victim’s autism. They are usually vehemently anti-vaccination, and thus are a danger to public health. They are subject not only to ASA and Trading Standards regulation, but also to regulation by their professional bodies (if they have one). The Society of Homeopaths (SoH) is accredited by the Professional Standards Authority (PSA), which has placed certain conditions on renewal of registration until CEASE therapists who are SoH members are disciplined. As well as my complaints to the ASA, I reported 30 CEASE therapists to the SoH, notifying the PSA at the same time. Almost a year later only one of them has removed CEASE claims from their website. The SoH appears to have done absolutely nothing. There is far more about CEASE therapy at the excellent UK Homeopathy Regulation.

I mentioned above the non-compliers list. This only relates to online ads, ie on traders’ own websites. Hence that should be representative of my sample of ads, as all but one were in that category. There are currently 41 advertisers on the non-compliers list, the earliest dated August 2015. The ASA told me last year that advertisers stay on this list until they are referred to Trading Standards, or they decide to comply. In my sample, only two advertisers appear on this list, but one of those – Teddington Homeopathy – was there before I complained. This one, another CEASE therapist, has been listed as non-compliant since August 2015, 2.5 years before my complaint. They still have not been referred to Trading Standards as far as I can see.

Not much of this paints an encouraging picture. Here is a summary of the outcomes:

So 74% of complaints since 2015 resulted in advertisers continuing exactly as before, with a further 10% only partly complying. Even when the ASA goes to the considerable effort of a full adjudication, the results are far from optimal. Of the four adjudications, the outcomes were:

Not one of these appears on either the non-compliers list or the referrals to Trading Standards list, after a year. Previous discussion with the ASA did not reveal any particular rule for when such referrals were made. I should mention that, as recommended by the ASA, I also complained to Trading Standards directly about cancer claims by the Shambhallah Healing Center. As you can see, there was no result from that either.

I promised to enlarge on my complaint about a chiropractic clinic. My attention was drawn to the website of the Henley Standard local newspaper, which carried a paid advertorial for Henley Chiropractic. This recommended taking newborn babies for `adjustment’, claiming that this could treat “colic, failure to thrive, and difficulty eating”. It also recommended adjustment in the absence of any symptoms. The ASA’s response included this:

We have decided not to take forward your concerns that the advertiser encourages parents to bring their babies to the clinics even if there are no symptoms, as we do not consider this issue is in breach of our rules.

I have read the ASA’s guidance for chiropractors and nothing is said there specifically about unsymptomatic babies. I suspect that the focus is on therapeutic claims, and if nothing specific is claimed in that regard then treating babies for nothing specific (in reality for nothing at all) seems to slide through the net. I maintain that there are risks with chiropractic, and as there is no evidence of benefit for unsymptomatic infants the risk:benefit balance is unfavourable. In passing, I am aware that complaints have been made to the General Chiropractic Council and both the advertorial and the video have been deleted.

Let me repeat that I am not trying to denigrate the ASA, or any other regulator. I am interested in why this situation is so dire. Let’s look first at how the ASA is funded. This comes from a 0.1% levy on the sale of advertising space, which does not include ads on businesses’ own websites. In 2006 the ASA began to regulate the latter, and you guessed it, without funding that specifically comes from that sector. The huge growth in online marketing must be creating resource issues for the ASA, and the annual report to the latest accounts (December 2017) list among the risks to the business:

• online advertising not being able to pay its way …as a result of insufficient income collected;
• difficulties of enforcing the CAP code against online advertiser “owned” advertising.

So the ASA recognises both the funding and enforcement problems. Looking at the latter, while the Committee on Advertising Practice (CAP) code, which the ASA applies, is voluntary, as I have said the legal backstop is Trading Standards. I’ll repeat here the ASA’s explanation of the background and history (it was in my previous post):

In 1988, the introduction of the Control of Misleading Advertisements Regulations (the CMARs) provided the ASA with legal backing from the Office of Fair Trading (OFT). Those regulations enabled the ASA, for the first time, to refer advertisers who made persistent misleading claims, and refused to co-operate with the self-regulatory system, to the OFT for legal action. The Regulations provided that in considering complaints about misleading advertising, the OFT was obliged to have regard to “the desirability of encouraging the control, by self-regulatory bodies, of advertisements”. The DTI (as it then was) recognised the ASA as one such body.

Guidance produced by the Office of Fair Trading (in conjunction with BERR, as it then was) on the implementation of the Unfair Commercial Practices Directive in the UK, by the Consumer Protection from Unfair Trading Regulations 2008 (the CPRs, which replaced the CMARs), recognised that there are alternative well-founded and effective systems of regulation (including self-regulation) in place in the UK (known in the legislation – in Regulation 19(4) – as “established means”). If enforcers are satisfied that complaints and cases are clearly within the scope of these systems and can be adequately dealt with by them, they will be able to refer such complaints and cases to the relevant body (to ensure that businesses comply with the CPRs).

While the CMA has powers under the CPRs to take enforcement action in response to a complaint concerning misleading advertising, in practice the CMA will give existing compliance partners, in this case the ASA, the opportunity to deal with complaints in the first instance (see here, page 26 footnote 31).

The Government and the Courts recognise the ASA and CAP as the established means of regulating non-broadcast advertising. Both the ASA and CAP are accepted by the Department for Business, Energy and Industrial Strategy (BEIS) Trading Standards and the courts as the first line of control in protecting consumers and businesses from misleading advertising.

Now, in 2013 Trading Standards took over from the OFT as the ASA’s legal backstop. So all should be well? Not quite. Trading Standards is not a single organisation, it’s a lot of small departments operated by local government. In reality there is just one of those that takes referrals from the ASA, Camden. The last I heard, Camden had a headcount of 2.5 people. The ASA handles 30,000 complaints a year, and two and a half people are supposed to deal with the non-compliant proportion. I have found that about 75% of my small sample are non-compliant. I accept that the quackery sector may well be far less compliant than others, but even so it hardly seems reasonable to expect Camden to be fit for purpose.

Because of its quasi-official role as a regulator, the ASA provides a vital public service. But it is a private limited company, hence not subject to the Freedom of Information Act. Indeed transparency is less than optimal overall. The Compliance Unit does not publish anything about its decisions, which I find frustrating. Surely it is high time that this whole function was put on a more secure footing. The ASA should be a properly funded public body. Trading Standards should be resourced to fulfil its role as legal backstop. But it isn’t quite as simple as that.

As a voluntary regulator, the ASA does not have to worry about whether a case will stand up in court. As legal backstop Trading Standards has to do just that. Hence the threshold for action is higher for the latter than for the former. I am not sure why more cases are not referred by the ASA, but I wonder whether it’s a combination of resource constraints in both bodies, and awareness at the ASA that it will be hard to get over Trading Standards’ threshold.

As I said at the outset, this isn’t a particularly scientific analysis. The period between date of complaint and outcome endpoint varies between 4.5 years and less than one month. Hence the 74% non-compliance which I observed may be pessimistic – if we wait a few more months perhaps some ads will become compliant. Indeed as I mentioned above Henley Chiropractic removed its video, and the newspaper removed the advertorial. However for online ads changes can be made in minutes and there is no excuse for taking months to do it, so I would not expect a significant effect of waiting longer.

I hope that both Trading Standards and the ASA read this post, and comment on my guesswork as to what’s going on. They should both rest assured that I know they are doing their best in difficult times.