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NHMRC Draft Information Paper: Evidence on the effectiveness of homeopathy for treating health conditions submission

This submission reflects the views of
Organisation Name: 
International Council for Homeopathy
Please identify the best term to describe the Organisation: 
Legal association / organisation
Personal Details
Q1. Is the draft Information Paper presented and written in a manner that is easy to understand?: 

AS an international council representing the homeopathy profession we do not pretend to be an expert body in research that can comment on the specificities of the NHMRC’s paper. We leave any detailed comment on its content to those individuals and institutes with the expertise to do so.

However we are concerned about the lack of accuracy in the wording in the report as a symptom of a overall approach to the report. As an example on Page 3 in the Introduction part of the definition of homeopathy is inaccurately written.

For example,  the sentences below indicate a lack of precision in the authors’ understanding of the preparation of homeopathic medicines in modern pharmacies.

Specifically, homeopathic remedies are repeatedly diluted and agitated in a process known as ‘potentisation’ or ‘dynamisation’.

Homeopathic medicines are prepared by taking a substance (e.g. plants, animal material, or chemical), diluting it in water or alcohol, then forcefully hitting the container against a hand or a surface. This process is repeated several times.

The failure to mention the fact that potentisations are carried out serially in precise steps using precise measures of volume and numbers of succussions indicates a lack of understanding of one of the basic aspects of modern homeopathic pharmacy.   Scientific papers should be written accurately and based on knowledge and understanding.   

 Had the NHRMC Working Committee had at least one member with an expert knowledge of homeopathy in its membership such inaccuracy could have been avoided here and in other areas of the paper.

Q2. Does the draft Information Paper clearly outline how the evidence was reviewed and interpreted by the Homeopathy Working Committee?: 

In response to this question we refer to the last sentence of our response to Question 1 and ask how a committee title ‘Homeopathy Working Committee’  can be deemed a ‘committee of experts’ when it contains no expert in homeopathy or in homeopathy research who could have at the very least advised on points of accuracy throughout the enquiry process?  We see the omission or ‘non-inclusion’ of such expertise as a fundamental flaw in the NHMRC’s process. Would a committee constituted to look at conventional pharmaceutical medicine not include a representative from the medical profession or a pharmacist?

We also consider that in the name of transparency the members of the research group of Optum commissioned by the MHMRC to carry out a highly important part of the review process should have been identified in the paper.    

The emphasis on evidence based on enquiries carried out by other governments is unfortunate. The 2010 so-called enquiry carried out by a group of MPs in the UK Parliament, none of whom were experts in research or homeopathy, and some of whom were clearly driven by an agenda to negate homeopathy from the start, is hardly an authoritative body of evidence from which to draw any conclusions. The final report was only signed off by three of the whole S&T Committee and never discussed or ratified by the UK Parliament. The Swiss government enquiry too has been accused of bias, perhaps for the opposite reasons, but at least its membership included some expertise on homeopathy and on homeopathy research.       

Q3. Is there additional evidence on the effectiveness of homeopathy for the treatment of clinical conditions in humans that needs to be considered? To be considered in public consultation any additional evidence must:: 

We believe that several studies were excluded that should have been included but we are happy to leave the recommendations in this area to experts in homeopathy research.

Page reviewed: 11 March, 2015