Back in 2008, Ben Goldacre made a two part radio series called The Rise of the Lifestyle Nutritionists. It seems that the show may have been made at the peak of the modern lifestyle nutritionists’ popularity. I looked at Google Trends and the Google News archives to see how much exposure various lifestyle nutritionists received [...]

Yesterday I was fired from the Conduct and Competence Committee of the CNHC. That is the organisation that was very quickly dubbed Ofquack in the blogosphere.  So now I am free to write what I like about about it. It has now become clear that voluntary self-regulation can not work. Recent events at the CNHC [...]

Suggested twitter tag: #buckgate

Number 19 Buckingham Street, London WC2N 6EF.is to be the home of the proposed "College of Medicine" that has arisen from the ashes of the late unlamented Prince’s Foundation for Integrated Health (their last accounts can be seen at Quackometer).
Naturally one must ask if the "College [...]

The vitamin pill trade has been described as the very corporate $50bn food supplement industry by Ben Goldacre on the Bad Science blog. Although there is some regulation of the industry, there will likely always be a way to promote unnecessary pills, powders, and liquids by making claims that do not withstand examination. Personally, I [...]

Science: So What? So Everything offers a poor account of the evidence on garlic and cancer.

Bad nutrition from Science: So What? So Everything: they go beyond the evidence when discussing turmeric, ginger and cancer

This post recounts a complicated story that started in January 2009, but has recently come to what looks like a happy ending.  The story involves over a year’s writing of letters and meetings, but for those not interested in the details, I’ll start with a synopsis.
Synopsis of the synopsis
In January 2009, a course in "integrated [...]

There is no topic more widely discussed than what one should eat in order to stay healthy. And there are few topics where there evidence is so lacking in quality. This post isn’t about quackery, but about something much more important. it is about the real science (if it merits that description) behind dietary [...]

The Yuletide edition of the BMJ carries a lovely article by Jeffrey Aronson, Patent medicines and secret remedies. (BMJ 2009;339:b5415).
I was delighted to be asked to write an editorial about it, In fact it proved quite hard work, because the BMJ thought it improper to be too rude about the royal family, or [...]

We have listed many reasons hear why you should never trust Boots.  Here are the previous ones.
Can you trust Boots?
Don’t Trust Boots
Boots reaches new level of dishonesty with CoQ10 promotion
This post is about a "functional food".  That is about something a bit more serious than homeopathy, though I’ll return to that standing joke in [...]

Chocolate, like many of the things we eat regularly, is a potentially fatal poison, and so it should come as no surprise that a study by the unimaginatively-named John Johnston (at the USDA National Wildlife Research Center) shows that our favourite sweet could prove to be an effective pesticide, for use against coyotes [1].

Chocolate, or rather the theobromine and caffiene it contains, is potentially fatal to many creatures, but of course “the poison is the dose.” Humans are particularly efficient metabolizers of theobromine, but the same isn’t true for dogs or cats. Whereas it would take dozens of pounds of chocolate to kill a human (probably more than you could physically eat), just 20 mg per kg of theobromine is enough to cause symptoms, while more than 60mg per kg can induce seizures (see the Merck Veterinary Manual).

To put those figures into perspective, milk chocolate contains around 60mg of theobromine per ounce, so if you have a dog weighing 20kg (44lbs), about a pound and a quarter (or half a kilo) of milk chocolate could bring on seizures.

The full set of symptoms for chocolate toxicosis are described in the manual thus:

Clinical signs of chocolate toxicosis usually occur within 6-12 hr of ingestion. Initial signs may include polydipsia, vomiting, diarrhea, abdominal distention, and restlessness. Signs may progress to hyperactivity, polyuria, ataxia, tremors, and seizures. Tachycardia, premature ventricular contractions, tachypnea, cyanosis, hypertension, hyperthermia, bradycardia, hypotension, or coma may occur. Hypokalemia may occur late in the course of the toxicosis, contributing to cardiac dysfunction. Death is generally due to cardiac arrhythmias, hyperthermia, or respiratory failure. The high fat content of chocolate products may trigger pancreatitis in susceptible animals.

Cats are actually somewhat more sensitive than dogs, but they have a useful defense - cats don’t find chocolate tasty. Dogs on the other hand love it, which is bad for dogs, but handy if you’re a farmer with a major coyote problem that you’d like to deal with without introducing too many nasty chemicals into the environment. And that brings us to the device below - a CLOD, or as only Americans would call it, a Coyote Lure Operative Device.

Coyotes are to American agriculture what Professor Nutt is to the Daily Mail or Katie Price is to people who want to read a newspaper without being confronted by giant fake breasts every two minutes. As well as being responsible for around three-quarters of all livestock losses due to animal predators (costing some US$44m in losses), other damage caused by coyotes apparently includes:

“…collisions with aircraft, attacks on pets and children, damage to fruit and vegetable crops, predation on game species such as elk and deer, and predation on poultry. In addition to directly damaging fruit and vegetable crops, coyotes also contribute to crop losses via damage to hose irrigation systems. Coyotes have also been implicated in the transmission and spread of epizootic rabies in the United States.”

In short, coyotes are responsible for pretty much everything from the global recession to 9/11. If you’re living in America and you can’t find a pen, the chances are that a coyote has nicked it. Clearly it’s time for some mass extermination. We’re talking US$40m here. That’s, like, Arnie’s fuel budget for a month.

Leaving skepticism about the need for this aside, chocolate - or rather the engineered chocolate-mimic used in the trial has a number of advantages as a pesticide. It’s safe for humans and many other animals while fatal to coyotes, who love it. Better yet, by carefully adjusting the ratio of theobromine to caffeine in their chocolate mimic (to 5:1), the USDA researchers were able to pretty much remove pre-mortality symptons - the coyotes ate the chocolate, and then later they died. As the researchers point out:

“The results from this research clearly demonstrate that theobromine/caffeine mixtures have potential as a pest coyote toxicant that is effective, selective, and potentially more socially acceptable than fluoroacetate or sodium cyanide.”

Of course, numerous coyotes were killed in the course of establishing the 5:1 ratio as the best proportion of theobromine to caffeine to use. ” Coyotes dosed with the 1:1 and 1:2 mixtures exhibited undesirable symptoms of toxicosis and were euthanized. “ The search for safer pesticides is always a noble one, but personally I’d like to see evidence of a larger problem than a measly US$44m of damage caused before we start breaking out the toxic Mars Bars.

[1] Johnston, J. (2005). Evaluation of Cocoa- and Coffee-Derived Methylxanthines as Toxicants for the Control of Pest Coyotes Journal of Agricultural and Food Chemistry, 53 (10), 4069-4075 DOI: 10.1021/jf050166p

Last week, I wrote about the regulation of those promoting food supplements. I was less than impressed with the lack of action taken by Trading Standards and the MHRA.
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I contacted each organisation once more to follow up on my original correspondence. Yet again, Trading Standards have failed to respond - even to acknowledge receipt of my email.

The MHRA, on the other hand, have not only responded promptly to my follow-up email, but have also said this:

Thank you for your message. I can confirm we shall be investigating this complaint and taking any appropriate action.

The MHRA took just one day to respond to my email, and have confirmed that they are at least investigating the complaint and action will be taken, should they deem it appropriate. Trading Standards, meanwhile, are yet to respond to me - having had a week in which to do so. In the four months since I originally contacted them, I haven’t had any kind of response whatsoever from Trading Standards.

Here is the email I sent to North Yorkshire County Council:

Dear Sir or Madam,

I am writing to you with regard to a company based in Skipton and my correspondence with North Yorkshire Trading Standards regarding this company.

I contacted North Yorkshire Trading Standards in July regarding possible breaches of consumer protection and health and nutrition claims regulations and did not receive a response. I followed up on this 7 days ago, having noted that the website that may breach said regulations remains unaltered. I am yet to receive any kind of response either to the original contact made in July, or to my follow-up email (sent a week ago).

Given that North Yorkshire Trading Standards have failed to respond to my emails, neither to inform me of what action (if any) would be taken nor even to acknowledge that they are in receipt of my emails, I thought the best course of action would be to contact North Yorkshire County Council itself and ask for guidance on this matter.

The company in question is Principle Healthcare Limited, and the address on their website is recorded as being in “Skipton, North Yorkshire” - http://www.principlehealthcare.com/about_us.cfm

Yours faithfully,
James Cole.

I have at least received an automated acknowledgement from North Yorkshire County Council, which is better than North Yorkshire Trading Standards managed.

Back in July, I wrote three blog posts about claims made on the website of a food supplement manufacturer. As well as writing about their claims, I contacted the MHRA and Trading Standards.
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The first post pointed out that the firm were selling industrially-produced herbal remedies and making medicinal claims for them. I wrote to the MHRA, linking to the relevant page, and enquired as to whether the claims made were acceptable. I got the following response:

Thank you for your e-mail and for bring this matter to our attention. We do regard these to be inappropriate medicinal claims.

Despite the MHRA regarding the claims made by Principle Healthcare in promoting their herbal remedies to be “inappropriate medicinal claims”, they still appear on the Principle Healthcare website.

Parts two and three dealt with what I saw as breaches of the Consumer Protection from Unfair Trading Regulations 2008 and the EU Regulations 1924/2006 on food labelling.

I contacted the Office of Fair Trading regarding the alleged breaches of the former regulations, who advised me to contact the Advertising Standards Authority. The problem with that suggestion is that material on a business’s website does not come under the jurisdiction of the ASA.

I also made contact (regarding the alleged breaches of the latter regulations) with the relevant branch of Trading Standards. North Yorkshire Trading Standards have yet to respond to my email - which was sent four months ago.

Rather than waste time chasing up regulatory bodies who have either (a) referred me to another regulatory body that does not have the power to investigate the alleged breaches or (b) failed to even respond to my complaint, I thought it might be worth contacting my MP.

Before doing so I will, out of courtesy, contact the regulatory bodies once more and see if they are willing to actually take some kind of action against the firm in question. Even if it is just to request they remove the offending material from their website.

Wish me luck.

There seems to be a perception among some that the alternative medicine industry is somehow warm and cuddly in comparison to everyone’s favourite baddie, ‘Big Pharma’. I’m sorry to say that ‘Big Altie’ is every bit as bad as Big Pharma. These are not charities - they are businesses like any other. Their responsibilities are to their shareholders, not to the public.
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There has been much talk this year of legal chill: Big Pharma suing Nancy Olivieri (note the reference to a confidentiality clause) and Peter Wilmshurst; Trafigura with their injunctions and superinjunctions; and the BCA suing Simon Singh.

Whether we’re talking about oil companies, pharmaceutical firms, or the alternative medicine industry, these organisations are not slow to use the law to protect their interests. I know of one firm operating in the sphere of alternative medicine that requires employees to sign a remarkably wide-ranging confidentiality agreement.

Employees are forbidden from divulging:

Any information known to [them] from any source regarding [name of firm redacted] now or in the future or for a period of 10 (ten) years after [their] leaving the company.

They are also specifically forbidden from mentioning details regarding particular areas of the business and from divulging “verbal information of any nature known to [them].”

They must also “agree to indemnify the company, its shareholders, staff and asociated consultants for any losses which occur as a direct or indirect result of [their] actions.”

While there may be good reasons for a company to require employees to agree to a confidentiality clause, something this wide-ranging must be a disincentive to ‘whistle-blowing’ of any kind. While I am not aware of anybody being sued for breaching this confidentiality agreement, I note that it is possible that a similar situation to that of Nancy Olivieri may occur.

From the article I linked to earlier:

Olivieri is a haematologist at the University of Toronto who became prominent in 1996 when, during a drug trial of deferiprone she was conducting, she spoke out, saying that she thought it was harming patients. Apotex invoked a confidentiality clause in their agreement with Olivieri threatening to sue her if she published any results or even told patients the drug they were taking could be harmful.

In Olivieri’s case, the University of Toronto refused to intervene, while Peter Wilmhurst has not been supported by either his employer or the Medical Defence Union. It is a sad state of affairs when someone can be sued for speaking out and they are left to face the consequences alone, so the charity HealthWatch should be congratulated for their support of Wilmhurst (having set up a fund to aid his defence).

I believe that my comparison between Big Altie and Big Pharma is a reasonable one, but also one that is rather apt. After all, there are many links between the two industries.

Patrick Holford, media nutritionist, “managed to sell his Health Products for Life business to Biocare (owned by Neutrahealth, who [are] 30% owned by Elder Pharmaceuticals) for £464,000.” According to the NeutraHealth website, their Chief Executive was previously at Galpharm, “the UK’s biggest supplier of non-prescription [OTC] medicine.” Meanwhile, Equazen (perhaps best known for the Durham trial-that-wasn’t-a-trial) are, as Ben Goldacre reminds us, owned by the £1.6bn pharmaceutical company Galenica.

As Dr Goldacre also notes in the above article:

… despite the rather desperate anti-establishment swagger of the $60bn food supplement pill industry, time and again we see that they use the exact same tricks as the $600bn pharmaceutical industry.

I suspect that use of subgroup analyses is just the tip of the iceberg and that Dr Goldacre might be surprised to find out exactly what tricks certain sectors of the alternative medicine industry are prepared to use. But if confidentiality agreements are widely used (and adhered to) then how will he, or any of us, ever find out?

It seems very reasonable to suggest that taxpayers have an interest in knowing what is taught in universities.  The recent Pittilo report suggested that degrees should be mandatory in Acupuncture, Herbal Medicine and Traditional Chinese Medicine. So it seems natural to ask to see what is actually taught in these degrees, so one can judge whether [...]

Earlier this evening I stumbed across the minutes of the meetings of the Cranial Forum, a body set up in 1999 to look at voluntary self-regulation in craniosacral therapy, a form of alternative medicine whose practitioners believe manipulation of the spine and skull can treat various ailments.

In recent months they have been debating affiliation with the Complementary and Natural Healthcare Council, the government-funded alternative medicine regulator dubbed “OfQuack” by critics. Browsing through the relevant minutes, I found something rather interesting.
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Earlier this year, Tony Brooks and ‘Le Canard Noir’ of Quackometer used the Freedom of Information Act to obtain a document from the Department of Health, detailing the number of practitioners that the CNHC had managed to sign up by the end of April. The total figure stood at 232, of whom 194 were massage therapists (the remainder being nutritionists). In addition the document provided projections drawn up by the CNHC, which predicted that they would have 607 members by the end of May.

Throughout the spring and summer, the Cranial Forum have been firing off requests to the CNHC for further information, as they contemplate whether to align with the regulator. The responses of the CNHC have been recorded in the minutes of various meetings of the Forum, in April, June and July.

This is where things start to get interesting, for in the minutes dated <a href=”April 6th, under a section entitled “Update from CNHC”, we find the following (my emphasis):

“Three hundred massage practitioners are already registered and more are expected. The aromatherapy register will open on the 5th May. Nutrition is in the process of agreeing their registration process but it is taking time.”

And in the minutes of their June meeting, they relate the following information from the CNHC:

“Four hundred massage practitioners are already registered and six hundred are awaiting processing which has been delayed by a computer glitch. The aromatherapy register will open on the 5th May.”

So let’s get this clear:

1) At some point prior to April 6th, the CNHC told the Cranial Forum that they had already signed up 300 massage therapists.

2) At some point prior to May 5th, the CNHC told the Cranial Forum that they had already signed up 400 massage therapists, and were in the middle of processing 600 further applicants - 1,000 in total.

3) At the end of April the CNHC told the Department of Health that they had signed up only 194 massage therapists, and projected a total of around 600 members in all professions by the end of May.

These figures simply do not match in any way.

The figure that the CNHC gave the Cranial Forum at the start of April was at least 55% higher than the official number they reported to the DoH. And for the figures given to the Forum in May to be accurate, the CNHC would have had to have received over eight hundred applications in the space of a few days, and to have conveniently experienced their “computer glitch” in the same period.

This discrepancy is documented fact, and the CNHC have some very serious questions to answer regarding how they managed to give two completely different figures to the government and to a fellow alternative medicine body.

But as well as the figures reported to the Department, it’s possible to count the number of practitioners yourself by searching the electronic register on their website. (Hat tips to Alan Henness and Simon Perry who have been compiling these figures.) Doing so produces 928 results as of October 17th. At the ends of September and August the figures were 797 and 607 respectively. Going back to the end of July, 528 members were listed.

This is curious, given that the CNHC informed the Cranial Forum prior to the end of July that “the CNHC has 1,000 registrants.”

One can only assume that is has taken them three months to add the missing 400+ names to the online register. Perhaps they should divert some of their PR budget to hiring a better typist?

At some point, the Department of Health will make the official figures for July available to the public under the Freedom Of Information Act. The CNHC already have some explaining to do; but if the DoH figures for July are as far from the figure given to the Cranial Forum as we think they will be, then the fall-out could be catastrophic.

Update - Massaging the Figures:
Alan Henness has very kindly provided a graph of the number of massage therapists registered by the CNHC over the last several months, as recorded on their online registry. Note that we still don’t appear to have seen the 1,000 massagers promised back in May. That’s quite some computer glitch.

For more background on the CNHC see - Tags:OfQuack.

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Go and follow me on Twitter! @mjrobbins

In July 2008 I wrote an editorial in the New Zealand Medical Journal (NZMJ), at the request of its editor.
The title was  Dr Who? deception by chiropractors.  It was not very flattering and it resulted in a letter from lawyers representing the New Zealand Chiropractic Association.  Luckily the editor of the NZMJ, Frank [...]

The CNHC have released the minutes of their July board meeting, and the contents provide a fascinating insight into the actions of the alternative medicine regulation company dubbed ‘OfQuack’ by critics. In this post I’ll trawl through a wealth of tid-bits concerning their response to criticism, openness, and the activities of Mandate, the PR company they’re spending public money to hire.

Transparency:

The first big revelation from the company is that they plan to open up their board meetings to observers, as part of their somewhat debatable commitment to transparency. Interested members of the public can apply for the three guest slots that will be opened at each meeting. I’ve applied, and it’ll be interesting to see how they respond to a critical freelance journalist (so far, no response). They also plan to release a “Performance Indicators Paper” online, but this has yet to appear.

Previously, the CNHC’s approach to transparency has been verging on the comical; blocking attempts to find out the number of registered members, changing their policy on releasing minutes and then hilariously pretending that the minutes from last November had never been posted.

On the Freedom of Information Act, the minutes state that policy now will be to refer requests to the Department of Health. Since the regulator is a private company, that leaves people reliant on information provided voluntarily, or documents filed at Companies House. Needless to say, this is hardly an ideal situation for a body responsible for public health.

Membership:

It’s especially worrying when the regulator itself has such an… eccentric approach to its task. Take for instance this announcement from the new minutes:

MW reported that she was discussing the possibility of a celebratory event when the number of registrants reached 2,000, in the autumn but that no decisions had yet been made.

Holding a celebration upon reaching 2,000 registrants may not seem that weird, until you remember that OfQuack’s stated target in December was to have signed up 10,000 members by the end of 2009. So the board are planning an event to celebrate falling eighty percent short of their target. It does beg the question, what exactly would you have to do to disappoint a CNHC board member?

While the CNHC claim to be dedicated to transparency, they make no such commitment to reality. One easy way around this headache-inducing cognitive dissonance was to simply change history by rewriting their December press release, changing 10,000 to 4,000.

The reason for this abject failure to bring alternative medicine practitioners on board is simple - most of the relevant professions already have their own cosy regulatory arrangements, and are loathe to sign up for membership of some new government-approved body.

And so the CNHC’s target of 10,000 was retrospectively changed to 4,000, and they now plan to celebrate getting 2,000 this Autumn. As it happens, this is a still a bit optimistic as by our count they have a grand total of, er, 661 people signed up (602 massage therapists, 52 nutritionists, 7 aromatherapists - Hat Tip to Alan Hennessy).

They might indeed reach 2,000 members by autumn, but it probably won’t be this autumn. Still, you can say what you like about the CNHC, but at least they don’t allow their commitment to positive thinking to be undermined by anything as trivial as ‘facts’.

Report to the Dept. of Health:

Indeed, if you really want to enjoy some comedy fiction you can read their May 2009 report to the DoH (thanks to FOIA requests by Tony Brooks and Andy Lewis), in which their totals are outlined next to their projected estimates; estimates which seem to have been simply plucked from thin air.

They admit that as of the end of April only 232 members had registered, but then claim that their target for January through April was to register only 61 members per month. It seems frankly incredible that anyone predicting 4,864 members by the end of the year (interestingly this report disagrees with the press release mentioned earlier) would predict getting only 243 of them in the first third of the year!

This monthly prediction then suddenly and inexplicably jumps to 364 in May, 410 in June, 678 in July, 678 in Augist and 702 in September, by the end of which they project a cumulative total 3075 members. As we know, they currently have 661. Their business plan predicts cumulative income of £115,570 from registrations by the end of September, yet they will be lucky if they reach £30,000, a short-fall of over 60%.

The numbers are even harder to explain when you remember that in December they originally predicted 10,000 members would sign in 2009. This was only changed on their website in June, very shortly after this report with its odd numbers was released to the DoH. I’ll leave you to draw your own conclusions from that.

Public Relations Spending:

Section 9 of the board minutes is largely devoted to the activities of Mandate, the public relations company they hired back in May, whose pages on health lobbying make the bold claim that “evidence is everything”, an ideology they presumably don’t require their clients to adhere to.

9.1.3 MD reported on a meeting she and MW had had with Mandate to formulate a strategy to help publicise CNHC activities with local newspapers and radio. Some suggestions were made for targeting specific radio programmes such as You and Yours and Women’s Hour. It was noted that the Media Tool Kit for PAs currently being prepared would be available shortly and would be sent to Board members for information. It was also noted that Board members may be required to help out with exhibition and conference attendance.

The real question is what they’re planning to promote. If they’re trying to let the public know that there’s a new service you can complain to in the event that you get stiffed by a quack, then fair enough. The problem is that in previous board meetings members have advocated promoting alternative medicine itself:

JG suggested the possible use of patients with ‘good news’ regarding complementary therapies on www.patientvoices.co.uk.

This would obviously be an enormous conflict of interest for a regulator. It would be helpful if the CNHC could clarify what they plan to promote, and make it clear that they will not in any way promote the alternative medicine industry. It will be interesting to see what this PR campaign looks like.

Wider Engagement:

Staying with PR, but moving away from Mandate’s activities, there are a couple of further points of interest.

10.1.6 It was agreed that CNHC should not have a presence on the WhatDoTheyKnow.com website.

For those who don’t know what “WhatDoTheyKnow” is, it’s a website that publishes FOIA requests and their responses. Several requests relating to the CNHC are on the site, and frankly given their content it’s not surprising that the CNHC are not planning to engage with it.

Finally, it’s nice to see that the company are still dwelling on their difficult relationship with the blogosphere.

10.1.7 It was agreed that CNHC should not respond explicitly to inaccurate information in blogs.

This is not the first time that the CNHC have alluded to false or inaccurate information circulated by their detractors. As before, they make no reference to specific claims, nor any attempt at rebuttal. I can’t speak for other bloggers, but armed with the raw numbers and their own words, I’m pretty comfortably with my position.

Their own is looking increasingly untenable. With the next government likely to have a mandate to crack down on public spending excess, a company sucking in DoH money to fund a business plan that looks indistinguishable from fantasy has to be a prime target. In signing up just 661 members against an original target of 10,000, the CNHC is dying. The kindest option would to put the lame duck out of its misery.

You don’t need to be qualified to give advice on nutrition or to call yourself a nutritionist. Anyone can do it. We can *all* be nutritionists. Anecdotes, old wives’ tales and personal opinion will suffice - there’s no need for evidence.

[BPSDB]Mike Adams, editor of NaturalNews and self-styled “Health Ranger” thinks we’re all ignorant when it comes to our health. He writes:-
“As an observer of human behavior, one of the most fascinating things I’ve ever witnessed is really smart people dying of diseases that are easily preventable through basic nutrition”
Basic nutrition is this: “eat food, [...]

Earlier this week, the Food Standards Agency upset the organic apple cart when they published a review of available literature that failed to find any health benefits associated with organic food. Moreover, the nutritional value of organically-produced food was little different to that produced by conventional farming.

As the Islington set choked on their (Duchy Originals) cornflakes, the backlash was as quick as it was predictable. Nobody likes to feel they’ve been taken for a fool, especially those who can afford to pay £3 for a loaf of bread.

Read the rest of this post… | Read the comments on this post…

The case of Katie Peck casts an interesting sidelight on the issue that, very soon, if nutritional therapists are employed by the NHS, then there is no mechanism for challenging them for dispensing the sort of advice that might lead to a hearing before the Health Professions Council if it were given by a Registered Dietician. How would this not lead to confusion for patients?

When all else fails, go online and buy another doctorate:

Hat tip to le Canard Noir.

Read the comments on this post…

The regulations on nutrition and health claims apply to all nutrition and health claims made in commercial communications. I aim to find out whether companies can legally claim on their websites that Apple Cider Vinegar is a detox agent that can curb your appetite and block fat formation, while boosting your immune system. So, are fat-busting, immune-boosting, detoxing claims legal? I asked Trading Standards…

The Eating within recommended dietary guidelines and on a budget project is having some difficulties. Not, oddly, on the actual shopping, cooking or budgeting fronts but the dietary analysis that I want to perform. On the upside, I have located some useful figures relating to low income diet, nutrient intake and food spend budgets.
I have [...]

Here is a short break from the astonishing festival of chiropractic that has followed the British Chiropractic Association (BCA) v Simon Singh defamation case, and the absurd NICE guidance on low back pain.

Singh’s statement already has over 10000 signatories, many very distinguished, Sign it now if you haven’t already. And getting on for 600 [...]

Simon Singh has announced, with the support of Sense About Science, that he will fight on in the courts to defend his 2008 article about chiropractic. You can see the details here, along with a petition signed by a host of famous names that you add your name to. I’ve reproduced the statement and the first 100 signatures below. I’d like to add a few thoughts of my own (and apologies in advance for the Jim Hacker style hand-waving).

It is impossible to say which way the appeal will go. The odds are probably not good, and the process could take years as the incomparable legal blogger Jack of Kent has warned. There is every possibility that Simon will lose the legal case.

But there are many different kinds of victory and defeat. As a result of this court action and appeal, the reputations of the British Chiropractic Association specifically, and chiropractors in general, are being dragged through the mud. Chiropractors are complaining of receiving letters from angry people across the country. Mass complaints have been sent to Trading Standards and the ASA. The General Chiropractic Council have been deluged with complaints about their members. In short, the chiropractic profession in Britain is now under siege from an aggressive grass-roots campaign, and facing a public relations nightmare that the BCA have created for themselves. What must have looked at the time like a clever response to silence a skeptic has turned into a catastrophe, as their increasingly angry and desperate press releases appear to show.

Against this backdrop we have successfully framed this as a freedom-of-speech issue. All of the major newspapers are carrying stories about the appeal, and with the likes of Stephen Fry, Jonathan Ross, a cross-party group of MPs, many journalists and the entire scientific community behind this one hopes that this stream of publicity turns into a river and then a torrent. This is no longer about Simon Singh and the BCA, this is about the defense of fair criticism against censorship, of enlightenment against ignorance. It is about the freedom of you or I to stare a quack in the eye and say “your claim, sir, is bogus.”

And that is no trivial matter, in an age when AIDS denialism in South Africa spread by our own crackpot colonialists is estimated to have cost upwards of 300,000 lives. The freedom to criticise claims is vital to a healthy democracy, and freedom itself is a right fiercely protected by the British people. In taking on freedom, the BCA have made a monumental error.

And it is up to us now to compound that error. That means doing more than just tossing a fiver into a pot, but going out and taking action. If you have a computer, and a spare hour this evening, find the website of a chiropractic, see if their claims fall foul of previous ASA rulings, and if so spend ten minutes writing an e-mail to Trading Standards and to the GCC asking them to take action. We should make sure that every bogus claim by every chiropractor is the subject of a complaint, and if we achieve that then we should go back to the beginning of the list and start again, and keep going until every last one has been appropriately sanctioned.

If we can do that, then regardless of the outcome of Singh’s adventures in our legal system, he will be the winner.

—————————————————-

The law has no place in scientific disputes

We the undersigned believe that it is inappropriate to use the English libel laws to silence critical discussion of medical practice and scientific evidence.

The British Chiropractic Association has sued Simon Singh for libel. The scientific community would have preferred that it had defended its position about chiropractic for various children’s ailments through an open discussion of the peer reviewed medical literature or through debate in the mainstream media.

Singh holds that chiropractic treatments for asthma, ear infections and other infant conditions are not evidence-based. Where medical claims to cure or treat do not appear to be supported by evidence, we should be able to criticise assertions robustly and the public should have access to these views.

English libel law, though, can serve to punish this kind of scrutiny and can severely curtail the right to free speech on a matter of public interest. It is already widely recognised that the law is weighted heavily against writers: among other things, the costs are so high that few defendants can afford to make their case. The ease and success of bringing cases under the English law, including against overseas writers, has led to London being viewed as the “libel capital” of the world.

Freedom to criticise and question in strong terms and without malice is the cornerstone of scientific argument and debate, whether in peer-reviewed journals, on websites or in newspapers, which have a right of reply for complainants. However, the libel laws and cases such as BCA v Singh have a chilling effect, which deters scientists, journalists and science writers from engaging in important disputes about the evidential base supporting products and practices. The libel laws discourage argument and debate and merely encourage the use of the courts to silence critics.

The English law of libel has no place in scientific disputes about evidence; the BCA should discuss the evidence outside of a courtroom. Moreover, the BCA v Singh case shows a wider problem: we urgently need a full review of the way that English libel law affects discussions about scientific and medical evidence.

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Science

Igor Aleksander FREng
Professor Emeritus in Neural Systems Engineering, Imperial College London

Professor Jim Al-Khalili OBE
Professor of Physics and of Public Engagement in Science, University of Surrey

Dr Sabine Bahn

Cambridge Centre for Neuropsychiatric Research, University of Cambridge

Harriet Ball
Voice of Young Science network

Professor Michael Baum MB FRCS ChM MD FRCR
Emeritus Professor of Surgery and Visiting Professor of Medical Humanities, University College London

Professor Jocelyn Bell Burnell FRS
University of Oxford and President, The Institute of Physics

Willem Betz
Emeritus Professor, Vrije Universiteit Brussel and Chair, SKEPP

Susan Blackmore
Visiting Professor, School of Psychology, University of Plymouth

Professor Colin Blakemore FRS
University of Oxford

Sir Tom Blundell FRS

University of Cambridge and President, The Biochemical Society

Dr Petra Boynton
University College London

Jean Bricmont
Professor of Theoretical Physics, University of Louvain and Honorary President, Association Francaise pour l’Information Scientifique

Tracey Brown
Managing Director, Sense About Science

Sir Iain Chalmers
Editor, The James Lind Library

Professor David Colquhoun FRS
University College London

Professor David Cope

Professor Brian Cox
University of Manchester

Dr Tim Crayford MB BS MSc FFPH FRSA
Former President, Association of Directors of Public Health

Professor Richard Dawkins FRS
University of Oxford

Professor Edzard Ernst MD PhD FRCP FRCP (Edin)
Peninsula Medical School, Exeter University

Dr Oliver Fenwick

Voice of Young Science Network

Professor Elizabeth Fisher FMedSci
Institute of Neurology, University College London

Dr Ron Fraser
Chief Executive, The Society for General Microbiology

Professor Christopher C French
Head, The Anomalistic Psychology Research Unit, Goldsmiths University and Editor, The Skeptic Magazine

Carlos Frenk
Ogden Professor of Fundamental Physics, Durham University

Diana Garnham
Chief Executive, The Science Council

John Garrow MD PhD FRCP FRCP (Edin)
Emeritus Professor of Clinical Nutrition, University of London and Former Chairman, HealthWatch

Professor David Gordon

President, Association of Medical Schools in Europe

Professor Trisha Greenhalgh
University College London

Professor Hugh Griffiths FREng
University College London and Chairman and on behalf of The Campaign for Science and Engineering in the UK

Dr John Haigh
Former Reader in Mathematics, University of Sussex

Kristoffer R Haug

Master of Science, Nanotechnology, University of Oslo

Professor Martin Humphries
University of Manchester and Chair, The Biochemical Society

Sir Tim Hunt FRS
Cancer Research UK

Sir Roland Jackson
Chief Executive, The British Science Association

Professor Steve Jones
University College London

Dr Stephen Keevil
King’s College London

Professor Sir David King FRS
Former Chief Scientific Adviser to the UK Government and Director, Smith School of Enterprise and the Environment, University of Oxford

Dr Chris Kirk

Chief Executive, The Biochemical Society

Professor Sir Peter Lachmann FRS FMedSci
University of Cambridge and Founder President, Academy of Medical Sciences

Jennifer Lardge
Voice of Young Science network

Armand Leroi
Professor of Evolutionary Developmental Biology, Imperial College London

Dr Robin Lovell-Badge FRS FMedSci

MRC National Institute for Medical Research

Dr Daniella Muallem
Voice of Young Science network

Professor Dame Bridget Ogilvie FRS FMedSci
Former Director, Wellcome Trust

Professor Clive Orchard
University of Bristol and President, The Physiological Society

Professor Ole H Petersen CBE
University of Liverpool

Lord Rees of Ludlow
Professor of Cosmology and Astrophysics, University of Cambridge

Les Rose
Clinical Science Consultant

Dame Nancy Rothwell FRS

MRC Research Professor and President, Biosciences Federation

Wallace Sampson
Clinical Professor of Medicine, Stanford University

Alan Sokal
Professor of Physics, New York University and Professor of Mathematics, University College London

Professor Beda Stadler
University of Bern, Switzerland

John Stevens CSci FIBMS
President and on behalf of The Institute of Biomedical Science

Professor Ian Stewart FRS
Mathematician and Science Writer

Professor Raymond Tallis FMedSci
Emeritus Professor of Geriatric Medicine, University of Manchester

Lord Taverne

Chair, Sense About Science

Hazel Thornton
Independent Advocate for Quality in Research and Healthcare

Sir Mark Walport
Director, The Wellcome Trust

Professor Robin A Weiss FRS
University College London and President, The Society for General Microbiology

Tom Wells
Voice of Young Science network

Robin Wilson
Professor of Pure Mathematics, Open University

Richard Wiseman
Professor of the Public Understanding of Psychology, University of Hertfordshire and Author

Journalism and Publishing

David Aaronovitch
Columnist, The Times and Author

Yasmin Alibhai-Brown
Journalist and Columnist

Julian Baggini
Journalist and Writer

Wendy Barnaby
Editor, People and Society

David Bodanis
Journalist and Author

Rosie Boycott
Former Editor, The Independent and Independent on Sunday

Geoffrey Carr

Science Editor, The Economist

Duncan Campbell
Journalist and Author

Dr Philip Campbell
Editor-in-Chief, Nature

Nick Cohen
Columnist, The Observer

Clive Cookson
Science Editor, Financial Times

Nick Davies
Journalist and Author of Flat Earth News

Kendrick Frazier
Editor, Skeptical Inquirer

Martin Gardner

Author, Former Scientific American columnist and prominent skeptic

James Gleick
Science Writer and Journalist

Dr Ben Goldacre
Writer, Broadcaster and Medical Doctor

Nigel Hawkes

Director, Straight Statistics and Former Health Editor, The Times

Mark Henderson
Science Editor, The Times

Roger Highfield
Editor, New Scientist

Dr Richard Horton FRS FMedSci
Editor, The Lancet

Alok Jha
Science and Environment Correspondent, The Guardian

Rohit Jaggi
Columnist, Financial Times

Barry Karr
Skeptical Inquirer and Committee for Skeptical Inquiry

Dr Karl Kruszelnicki

Author, Broadcaster and Scientist

Sam Lister
Health Editor, The Times

Brenda Maddox
Journalist and Biographer

Kenan Malik
Journalist and Author

Dr Margaret McCartney
Columnist, Financial Times and GP

Robin McKie
Science Correspondent, The Observer

George Monbiot
Journalist

Andrew Mueller

Journalist and Author

Steven Novella
Editor, Science-Based Medicine; Director of General Neurology, Yale University School of Medicine and Author

Vivienne Parry
Science Writer and Broadcaster

John Rennie
Former Editor-in-Chief, Scientific American

Nick Ross
Journalist and Broadcaster

Ian Sample
Science Correspondent, The Guardian

Ariane Sherine
Comedy, Writer and Journalist

Michael Shermer

Publisher, Skeptic Magazine; Columnist Scientific American and Author of Why People Believe Weird Things

Rebecca Smith
Medical Editor, The Daily Telegraph

Andrew Sugden
Deputy Editor, Science

Mike Swain
Science Correspondent, The Daily Mirror

Bill Thompson
Technology Journalist

Margaret Wertheim
Science Writer

Arts, Humanities and Entertainment

Martin Amis
Novelist

Joan Bakewell
Broadcaster and Journalist

Antony Beevor
Historian

Jo Brand

Performer

Derren Brown
Psychological Illusionist

Alain de Botton
Author

Carol Ann Duffy
Poet Laureate

Peter Florence

Director of The Guardian Hay Festival

Stephen Fry
Broadcaster and Author

Ricky Gervais
Writer and Performer

Anthony Grayling
Professor of Philosophy, Birkbeck College University of London

Dave Gorman
Writer and Performer

Harry Hill
Performer

Robin Ince
Performer

Tim Minchin

Performer

Dara O’Briain
Performer

Penn Jillette
Illusionist, Juggler and Libertarian

Libby Purves
Broadcaster, Journalist and Author

Jonathan Ross
TV presenter

David Starkey
Historian

Teller
Illusionist, Juggler and Libertarian

Sandi Toksvig

Broadcaster, Comedian and Author

Dr Richard Vranch
Performer and Ex-physicist

Skeptics and Campaign Groups

Luis Alfonso
The Spanish Skeptics group Circulo Esceptico

The Association for Skeptical Enquiry, UK

Australian Council Against Health Fraud

Australian Skeptics Inc

Peter Bowditch
Editor, www.ratbags.com

Neil Denny

Little Atoms podcast

Rachael Dunlop
Reporter, Skeptic Zone podcast

Hanno Essen
Chairman and on behalf of the Swedish sceptics Vetenskap och Folkblidning

European Council of Skeptical Organisations

Gesellschaft zur wissenschaftlichen Untersuchung von Parawissenschaften

The German Skeptics group

Jonathan Heawood
Director, English PEN

Gabor Hrasko
Executive President and on behalf of The Hungarian Skeptic Society

Narisetti Innaiah
Chairman, Center for Inquiry, India

The Irish Skeptics Society

Dr Massimo Polidoro
On behalf of Italian Skeptics CICAP

Andy Lewis
Blogger, quackometer.net

Ronald A Lindsay
President and CEO, Center for Inquiry, USA

Simon Perry
Founder, Skeptics in the Pub (Leicester)

Dr Philip Plait
President, James Randi Educational Foundation, USA

James Randi

CEO, James Randi Educational Foundation, USA

Padraig Reidy
Index on Censorship

Sid Rodrigues
Chairman, Skeptics in the Pub (London)

Amardeo Sarma
Chairman, German Skeptics (GWUP)

Eran Segev
President, Australian Skeptics Inc

Law

David Allen Green
Solicitor

Jonathan Morgan
Fellow in Law, University of Cambridge

Baroness Helena Kennedy QC
Barrister and Labour Member of the House of Lords

This statement has been sent to the Department for Culture Media and Sport, No 10 and the Department of Justice on Thursday 4th June and with every additional 1000 names we will be sending the statement again to Government until there is a commitment and a timetable from the parties for the necessary legislation. Next 1000 names here (these will be added as quickly as we can).

The European Elections are taking place this week, when millions of people will go to the polls to decide how they are represented in Europe. The European Parliament is a stage on which countless battles are played out, influencing aspects of our economy, law, judiciary, technology, environment, trade, culture, immigration, research, education, and many more. However, in the lead up to the elections, European politics have been eclipsed by the furore over our own MPs’ expenses. Those who with an appetite for political debate over Europe have been forced to subsist on the amuse-bouches of party political broadcasts and tedious jingoism.

When it comes to the Europe elections, only three issues seem to matter: immigration, immigration and immigration. Euro-sceptics, nationalists and outright racists use the election as a canvas on which to paint Goya-esque murals of the massed hordes of some plague-ridden medieval Eastern Europe beating a path to Britain. But these tired arguments only exist because they are pulled into centre view by the vacuum of public debate about our place in Europe and its relation to our lives. And it’s this lack of debate that breeds widespread apathy toward European elections. Twice as many people voted in the 2001 series of Big Brother than the 1999 election. Admittedly, it’s a lot easier to vote (and vote often) in Endemol’s election, but I can’t help wondering if this would still be the case if the European elections were given as much column space as Big Brother (or it’s current equivalent, Britain’s Got Talent).

To play a small part in remedying this, myself and fellow blogger Martin Robbins of the Lay Scientist decided to investigate the science policies of the major political parties, to see where they stood on issues such as stem cell research, environmental protection, energy security and alternative medicine. We drew up nine questions to be sent out to the press offices of UKIP, Labour, the Conservatives, the Liberal Democrats, and the Green Party.

ENVIRONMENT
Recently a ship chartered by the British offices of a Dutch petroleum company illegally dumped tonnes of toxic waste in the Ivory Coast. The European Commission has proposed the creation of criminal sentences for “ecological crimes” - do you support this action?

ENERGY
Currently the EU imports over half of its energy. Recent disputes between Russia and it neighbours have highlighted Europe’s precarious dependency on these imports. What are your proposals for increasing energy security?

CLIMATE CHANGE Current EU approaches to combating climate change include limits on carbon emissions, investments in alternative energy technologies, and carbon trading. Which of these would you prioritise and how else will you use a seat in the European Parliament to tackle climate change and its impact on the UK?

OPEN ACCESS
Although the EU distributes billions in research funding, the results are often locked in pay-for-access journals. How will you improve open access to publicly-funded research findings?

SPACE Last week Major Timothy Peake was selected as an astronaut for the European space programme. How important is continuing space research, particularly manned missions, and what role should Britain play in this process?

STEM CELL RESEARCH
It has been said that there are serious incompatibilities between member states on regulations governing stem cell research. How will you work to resolve these differences?

ALTERNATIVE MEDICINE Do you believe that complementary and alternative medicine has a role in public health care, and do you believe it should be subjected to the same regulations as conventional medicine?

GM FOOD AND RESEARCH The field of genetics has the potential to improve human health and nutrition, but many people are concerned about the effects of genetic modification both in humans and in agriculture. What is the right policy balance between the benefits of genetic advances and their potential risks?

CHEMICAL SAFETY
In 2007, The REACH act came into force, addressing the potential harm to humans and the environment of all chemicals imported to and manufactured in the EU. Critics point out that this will require a significant increase in animal testing. How will you balance these concerns with the need to assess the safety of chemicals in our food and products?

Their responses were in equal parts good, bad, astonishing, surprising and informative. Did you know, for instance, that UKIP wish to overturn the most stringent laws on chemical safety ever created? Or that the Green Party are proposing legislation that would stop almost basic biological research in the UK if passed?

All of the people we questioned deserve a tremendous amount of praise for gathering together answers on such a wide spectrum of subjects. It wasn’t easy for them, often it wasn’t even clear who the questions should be addressed to. That this is the case, when we have been involved in wide-scale scientific endeavours with the European Union for over 20 years, is nothing short of a travesty. Science is at the centre of our lives, from the food that we eat to the cars we drive and the buildings we live in. That few of the parties could even point to a single manifesto of their attitudes toward science and how it should be carried out on a European stage is a terrible indication of our lack of interest in our own well-being.

Voters in the 2008 US presidential elections were able to make science a key issue in the race for the White House. Meanwhile, our own European parliament swims with Creationists, opponents of genetic science, and climate-change denialists, who are able to carry out their duties in the absence of rational, evidence-based policies because of our own disinterest. Remember, these are your MEPs, and if you don’t want to wake up in a year’s time to find a moratorium on stem cell research, Creationism in your classroom, unknown chemicals in your food, or crystal healing in your health service, it’s up to you to push science into the mainstream of political debate. Write to your MEP, ask questions of your political party, make your voice heard. Open democracy starts with you.

Read the comments on this post…

Myself and Frank Swain of Science Punk have questioned the leading parties ahead of the European Elections this week to find out more about their science policies. The results were interesting, and sometimes shocking. We’ve split our research into nine policy areas, listed below. Some are here, and some are over on Science Punk. Click on the index to take you to the policy area that interests you. (Note: Frank’s pieces have ‘(SP)’ next to them and will be online shortly).
<!–break–>
ENVIRONMENT (SP)
ENERGY (SP)
OPEN ACCESS (SP)
STEM CELL RESEARCH (SP)
CHEMICALS (SP)
SPACE
ALTERNATIVE MEDICINE
GM FOOD AND RESEARCH
CLIMATE CHANGE
SUMMARY

Space:
We asked:

Last week Major Timothy Peake was selected as an astronaut for the European space programme. Where do you stand on the need for manned space flight, and how important is it for Britain to play in this process?

UKIP and the Conservative party failed to respond with any vision of space policy. The Conservatives in particular are surprisingly vague on the subject, criticising the government’s support for manned space-flight while talking about the exciting possibilities of Britain’s general involvement in space.

The other parties gave more detailed responses. Labour suggeste that they “have no plans to review our position on funding human space flight,” with their policies focused on “commercial telecoms, navigation and Earth science.” Business as usual then.

The Liberal Democrats made the valid point that Europe should focus on adding value to efforts by the US, Russia and China, rather than necessarily competing with them. The Green Party were cold on manned space-flight, and sought to “take the military out of the arena”, while also wishing to increase funding to clean up the debris accumulating in near Earth orbit.

Overall then, there seems to be a broad consensus on space research that reaches across political parties and can be summed up as “keep doing what we’re doing, but let’s leave the human flight to the Yanks.”

Alternative Medicine:
We asked:

Do you believe that complementary and alternative medicine has a role in public health care, and do you believe it should be subjected to the same regulations as conventional medicine?

We posed this question as a bit of a curve-ball, trying to see if we could draw out any weird and whacky answers from the parties. We

Tim Worstall of UKIP gave the best response, pointing out that if ‘alternative medicine’ worked then it would just be ‘medicine’, while accepting that people should be free to spend their money on quackery if they so choose. Likewise, the Liberal Democrats - who gave consistently strong answers to our questions - warned of “quackery” and the need for consumer protection through regulation.

Labour and the Conservatives were silent on the issue, which is concerning. Neither seems to have a clear policy that we could find, and it is no surprise that this vagueness has been exploited by organisations like the CNHC (”OfQuack”), who are stepping in to fill the void with ineffective regulation of their own. As for the Greens, their answer on this was so bad that I’ll be devoting an article to them later this week - stay tuned for that.

GM Food and Research
We asked:

The field of genetics has the potential to improve human health and nutrition, but many people are concerned about the effects of genetic modification both in humans and in agriculture. What is the right policy balance between the benefits of genetic advances and their potential risks?

Of the minor parties, UKIP called for a greater understanding of the risks, while the Green Party asserted that any risk would outweigh any possible benefits of research, and stated that they sought to ban any sort of GM organism from entering the UK, essentially the luddite option.

The three main parties have formed a broad consensus on GM policy that essentially follows the precautionary principle as it’s stated in EU policy. In other words they agree that GM could be beneficial, but that it is not a magic bullet for world hunger, and that those seeking to commercialise the technology must demonstrate its safety. These answers were pretty fair, and it was encouraging to see that the three parties demonstrated sufficient knowledge to go beyond our question and make a range of pertinant points related to food security.

Climate Change
We asked:

How will you use a seat in the European Parliament to tackle climate change and its impact on the UK?

Again, we found a strong consensus among the main parties in terms of their stated policies. Labour pointed to their legally-binding targets committing the “UK to cutting emissions by 80% by 2050 and by 34% by 2020,” as well as their target of producing 15% of our energy from renewables by 2020, and a commitment to carbon trading and supporting new, low-carbon technologies.

The Liberal Democrats called for more ambitious targets and stricter regulation, complaining that the existing European trading scheme (EU-ETS) contained too many loopholes. In fact though, their immediate targets were less strict than Labour’s, calling for a 30% cut in emissions by 2020 rather than Labour’s 34%. The Conservatives supported the same broad range of policies outlines above, and indeed supported the same target of an 80% reduction in emissions by 2050.

The smaller parties are less promising. The Greens call for a reduction of 10% per year, or 90% by 2030, which while admirable is frankly unrealistic. Still, at least they support action, which is more than can be said for UKIP. Tim Worstall’s response to us suggested a lack of any real policy, and their is a hint of climate denialism about the UKIP party.

Overall though it’s a very positive outlook, which suggests that the political battle over the reality of man-made climate change is - as the scientific debate has been more many years - over, that broad agreement has been reached on the next steps and targets, and that debate now is focused on the details of policy.

Summary

This was a fascinating exercise, and the first question one has to ask is why the mainstream media aren’t giving more attention to actual party policy ahead of the European Elections. Instead, there is a worrying likelihood that this election will be a protest against expenses and the Labour party.

Nonetheless, we were pleasantly surprised by the main parties, who seem to have reached a consensus on a variety of scientific issues. One notable exception to this was in the area of alternative medicine, where there appears to be a crippling lack of action on government and opposition benches.

The minor parties are a much more mixed bunch, and one wonders if voters seeking to register protest votes with the likes of UKIP and the Greens realise that they are supporting parties that apparently contain creationists, climate denialists, and supporters of quackery.

Follow me on Twitter! @mjrobbins

Two days ago I wrote NICE falls for Bait and Switch by acupuncturists and chiropractors: it has let down the public and itself
Now the official ‘guidance’ is out, and it is indeed quite as bad as the draft.
The relevant bits now read thus.

Offer one of the following treatment options, taking into account patient preference: [...]