Tuesday, 16 October 2018

Lord Howe Letter

Back in 2011, a consultation was launched regarding consolidation of the Medicines Act 1968 and the plethora of other medicines legislation/regulations that can grown up around it. Medicines regulation had become fragmented, difficult to comprehend and in places even contradictory.

The intention of consolidation was not to make any substantial changes to legislation, some minor tidying up at most but it did cause some consternation amongst homeopaths, the homeopathic pharmacies and supporters of homeopaths.

This is well documented elsewhere. In essence, the concern was that the consolidation would make the supply of certain homeopathic medicines to/by lay homeopaths illegal. In reality, it was already illegal and still is.

Such was the concern amongst homeopathy supporters that they made representations to the Department of Health (as it was then called). It responded in the form of a letter.

Denial is a common mental state in homeopathy. Selective reading of clear English is a common cognitive problem. Misrepresentation of facts is deeply engrained in homeopathy.

The letter does not say what homeopaths made it out to say. Far from it.

Lord Howe Letter
Earl Howe, Frederick Curzon, was at the time the letter was written, Parliamentary Under-Secretary of State for Health. His letter (to the Society of Homeopaths) is reproduced below -

Thank you for your letter dated 20 June 2012 concerning the Consolidation and review of the Medicines Act 1968 (Consultation MLX 375) and its impact on the continued availability of unlicensed homeopathic products. 
I understand that you have also written to the Medicines and Healthcare products Regulatory Agency (MHRA) about this issue. Please accept this as a response to both letters. 
You asked for clarification as to why Section 10 of the Medicines Act is not being consolidated. The MHRA's response to the consultation is now available on the Agency's website; the document presents a summary of responses received and a commentary on key issues raised, including those raised by homeopathic interests. In summary the response indicates that the decision not to consolidate section 10 of the Medicine Act was made following careful consideration of the potential legal consequences of doing so. Ultimately it was felt that consolidation could not safely be done without compromising the legal effect of these regulations. 
As you know the consolidation does not, and was never intended to, change either the current regulatory status of regulations governing homeopathic medicinal products or their sale and supply. It was also never the intention to change the way the MHRA approached the enforcement of these provisions. I think would be useful if I clarified the effects of Section 10 as they affect homeopathic products. Starting with Section 10(4)(a); this does not apply to the supply of homeopathic products in isolation, but relates to the supply of an extemporaneously prepared medicine in a pharmacy by a pharmacist using their professional judgement as requested so to do by a patient present in the pharmacy at the time of the request. Section 10(4)(a) broadly exempts the pharmacist from the requirements for a manufacturer's licence to be able to prepare the product, and for a product licence, to be able to supply the product to the patient. 
Section 10(3) of the Act on the other hand provides an exemption to pharmacists from the requirements for a product or manufacturer's licence, for the supply of a medicinal product prepared to the specification of the client of the pharmacist. The supply of unlicensed products under Section 10(3) does not require a face-to-face consultation and so a product may be ordered by telephone, mail order or by way of the internet, although such products can only be supplied to an individual for their own use or administration to a member of their immediate family (for example supply to the parent or guardian of a child). I understand it is under the scope of Section 10(3) that the registered homeopathic pharmacies operate their online "remedy stores". 
Changes such as those suggested by the Society and others both to me and in response to the consultation would require detailed consideration of both the policy and legal implications; not only in terms of how they would impact on homeopaths or pharmacists but also on public safety. For example exempting homeopathic medicines prepared at a dilution of one part in a million (6X) or greater, from the provisions of section 10 and regulation 195 of the Act would need detailed consideration of the safety implications. Dilution alone is not sufficient to ensure the biological safety of the first safe preparation and needs to be considered with a number of other factors. 
You are, I know, aware that I recently met with a number of representatives of the homeopathic sector to discuss these issues. At this meeting I made clear that the Government's position on patient choice and the availability of homeopathic products has not changed. It should also be remembered that any proposals for change in medicines legislation to relax regulation in respect of homeopathy would require a full public consultation and therefore would need to be considered separately from these Regulations coming into force. 
It should also be kept in mind that any changes in this area would inevitably prove controversial, and would likely lead to pressure for other changes in an adverse direction for homeopathy. While I cannot realistically see this being a priority in the immediate future I would be happy to meet with representatives of the homeopathy sector if there were any significant changes to the present situation.

What does this mean?
It means that back in 2012 the Society of Homeopaths (SoH) were aware of the legal restrictions on the supply of unlicensed medicines re lay homeopaths. It indicates that "representatives of the homeopathic sector" were also aware - this is understood to include the homeopathic pharmacies. It is believed that other trade associations such as the Alliance of Registered Homeopaths know of the legal restrictions.

Yet these restrictions are widely ignored. Enforcement of regulations pertaining to unlicensed medicines is rarely a priority for the MHRA or the General Pharmaceutical Council (GPhC) which sets standards for pharmacies and pharmacists. However, a very strong case can be made that enforcement re products used in CEASE therapy absolutely should be a priority. Dealing with these products in theory could lead to a situation where regulation was enforced across all unlicensed homeopathic medicines but historically, the MHRA have only ever dealt with individual problem products (the diet scam homeopathic hCG for example).

This is issue is a "loaded gun" for the SoH if they wish to retain Professional Standards Agency (PSA) Accredited Register status.

A next step?
Whilst it would be difficult, it would be possible to create a list of nearly every practising lay homeopath in the UK. This list would also include naturopaths (who often use homeopathy). It could be extended to include those regulated medical professions who used homeopathy but do not have (sufficient) prescribing rights to prescribe unlicensed products.

This list could be supplied to the homeopathic pharmacies, the MHRA and the GPhC and trade associations representing lay homeopaths, naturopaths etc along with text pointing out the legal restrictions on supply.

Individual practitioners could be contacted pointing out the restrictions. It may well be the case that they have no idea that they exist. If they belong to a trade association, there are some questions that need to be asked but...

These kinds of measures would not be required if the UK homeopathy community took public safety seriously, rather than paying mere lip service to them. If it dealt with things like CEASE therapy, restricted its activities to "treating" those able to consent and to minor conditions, did not dispense "advice" and spread misinformation that is injurious to individual and public health, there would be no problem.

Thursday, 28 June 2018

Asyra machine

The Asyra machine has been mentioned in a number of posts. The Advertising Standards Authority (ASA), at the time of writing, have just issued a ruling about a practitioner.

Carolyn Stevens
Stevens is a member of the Alliance of Registered Homeopaths (ARH). Stevens offers CEASE therapy - it is worth discussing what she says about before looking at the ASA ruling. She makes the usual claims, spells out the acronym in full and links to the CEASE therapy website but this -
The majority of the children I see who have ASD labels were born healthy and attentive, but started to display behaviour leading to the ASD diagnosis at a later stage. Generally we can see exposure to toxins and pharmaceutical drugs in childhood, and it seems as if the body just at some point just can’t take any more. There are many theories regarding autism but one thing is for sure, the jump from 1 child in 80 to 1 in 6 over the last few years means that something very wrong is happening to our children, and something needs to change.
1 in 6? Unless the majority of these children are being hidden somewhere, this is obviously not the case. Tracking down the source of these kinds of claim can be difficult. Experience of reserching sources of anti-vaccination misinformation is that a figure can be inflated with retelling or that its scope can grow. The most likely source of the 1 in 6 figure is the Centers for Disease Control and Prevention (CDC) report Key Findings: Trends in the Prevalence of Developmental Disabilities in U. S. Children, 1997–2008. The report puts the prevalence of all development disabilities at 1 in 6. Autism? 0.47% which is less than 1 in 200. Either Stevens naively swallows misinformation, has language comprehension issues or is scaremongering. None of these are positive trait in a "healthcare professional".

Steven claims for Asyra can be found here and they do not make for good reading. Ignoring the list of symptoms -
The Asyra unit emits a low voltage output to check for the body’s response to a variety of issues and imbalances. The software can then run through a database of literally thousands of items (homeopathics, herbs, vitamins) to see which ones the body responds positively to. All consultations will result in a remedy (drops or pillules) to help adjust any imbalances. The testing is painless and results are available instantly.
In essence, Steven is implying the Asyra can diagnose disease and select medicines via a  combination of hardware and software. That's quite a claim, even by implication.

ASA Ruling
Stevens did not respond to the ASA and so far her website has not been amended. The ARH has compliance with advertising regulation in its Code of Ethics and thus is a contractual obligation on members.
The ASA was concerned by Carolyn Stevens’ lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rules 1.7 (Unreasonable delay). We reminded them of their responsibility to provide a substantive response to our enquiries and told them to do so in future.
The antipathy of some homeopaths towards the ASA is well known. This post includes a statement by Karin Mont who is the chair of the ARH in which she clearly implies that compliance with ASA rulings is of no concern.
The ASA noted that the ad included a number of claims, such as “The Asyra can be used for screening for a multitude of issues and imbalances in your system” and “The Asyra will identify issues and help with the start of a balancing, desensitisation or detoxification protocol”, and listed a number of health conditions, including allergies, nutrition levels, infections, alcohol addiction and others. We considered those claims were medical claims for the Asyra Pro device used by Carolyn Stevens that it was effective in screening and diagnosing the various health conditions listed in the ad.
It has to be remembered that the ASA are a voluntary regulator and their codes represent an understanding of the law. Stevens' claims would be in breach of consumer protection legislation for one thing.
The CAP Code required that medicinal or medical claims and indications were made only for a medicinal product that was licensed by the MHRA or under the auspices of the European Medicines Agency (EMA) or for a CE-marked medical advice. We had not seen any documentary evidence to demonstrate that the Asyra Pro Bio-Energetic device used by Carolyn Stevens was a CE-marked medical device and because of that, no medical claims could be made for the product. In addition, we had not been provided with any documentary evidence to substantiate the claims that the device could be used to diagnose the conditions listed in the ad. 
Because the ad made medical claims for a product which was not a CE-marked medical device, and because we had not seen evidence to support the efficacy claims made for the device, we concluded that the ad was misleading.
Medical device regulations are very complex.

Medical Device Regulations
Not only are medical device regulations complex and difficult to read, they are in a period of transition and major changes are pending. Whether or not these changes will apply to the UK post-Brexit (if it happens) is moot - they will certainly apply to any devices that are intended for export.

The Medical Devices Directive (MDD) is the most important part of EU regulation but it is very hard to read. It is implemented in UK law by the Medical Devices Regulations 2002 (Regulations 2002). The Medicines and Healthcare Product Regulatory Agency (MHRA) has copious guidance but there is so much that is hard to follow. However, this is a good place to start. A medical device is -
... described as any instrument, apparatus, appliance, software, material or other article used alone or combined for humans to:
  • diagnose, prevent, monitor, treat or alleviate disease
  • diagnose, monitor, treat, alleviate or compensate for an injury or handicap
  • investigate, replace or modify the anatomy or a physiological process
  • control conception
The claims made by Stevens certainly place Asyra as a medical device. The article then goes onto describe a number of different types of medical device - Asyra is not implantable or for in vitro use so the MDD applies.

One important concept is whether a device is "active". The MDD contain the following definition -
Any medical device operation of which depends on a source of electrical energy or any source of power other than that directly generated by the human body or gravity and which acts by converting this energy. Medical devices intended to transmit energy, substances or other elements between an active medical device and the patient, without any significant change, are not considered to be active medical devices. Stand alone software is considered to be an active medical device. 
The Asyra device whateve the claims made for it, measures skin conductance which requires passing an electric current between two electrodes through the skin. It might be very low current, but MDD isn't concerned with that. The Asyra device connects to a PC and its "results" are analysed by software. So, it is an active device.

Medical devices are divided into classes, which are 
  • Class I - generally regarded as low risk
  • Class IIa - generally regarded as medium risk
  • Class IIb - generally regarded as medium risk
  • Class III - generally regarded as high risk
All medical devices must be registered with the MHRA. All devices require confirmity assessment and bear a CE mark and in the case of Class IIa and above, plus Class I devices that are diagnostic in function or sterile, that assessment must be carried out by a Notified Body. In the case of non-diagnostic, non-sterile Class I devices, self-assessment is sufficient. There is a database which is extremely difficult to navigate but the Asyra device does not seem to appear there.

The rules for determining which class a device belongs to are quite long so only those that may apply to the Asyra device are considered -
Rule 1 - All non-invasive devices are in Class I, unless one of the rules set out hereinafter applies.
Asyra certainly is non-invasive.

But -
Rule 10  - Active devices intended for diagnosis are in Class IIa: 
  • if they are intended to supply energy which will be absorbed by the human body, except for devices used to illuminate the patient's body, in the visible spectrum, 
  • if they are intended to image in vivo distribution of radiopharmaceuticals, 
  • if they are intended to allow direct diagnosis or monitoring of vital physiological processes, unless they are specifically intended for monitoring of vital physiological parameters, where the nature of variations is such that it could result in immediate danger to the patient, for instance variations in cardiac performance, respiration, activity of CNS in which case they are in Class IIb.
 Active devices intended to emit ionizing radiation and intended for diagnostic and therapeutic interventional radiology including devices which control or monitor such devices, or which directly influence their performance, are in Class IIb.
The Asyra website states here that -
The Asyra is not a diagnostic device. All bioenergetic testing devices (as with manual techniques such as kinesiology) work by sending signals of some form to the body and getting a response – balanced or unbalanced, and reporting the response back to the practitioner. 
Diagnosis is the process of dividing people into groups according to the set of signs and symptoms they show, whilst bioenergetic testing reflects back a unique pattern of information that can be used to treat on a like-cures-like basis and to gain insight for the practitioner and client. 
The information you obtain from the system may of course assist you in arriving at a diagnosis, if this is what you are licensed to do.
But it still would appear to be a Class IIa device so it require assessment by a Notified Body. But what form would that assessment take? Most of is concerned with quality management systems (QMS) and compliance with various QMS standards. QMS is a very dull subject. The assessment will involve consideration of whether the device actually does what it claims to do in its specification - which isn't always the same as marketing claims. Those are dealt with by the Consumer Protection Act 1987 etc as explained in the Regulations 2002 . Device regulation is different from medicines regulation in this regard.

The MHRA do have the powers to seek the removal of products from the market as well as prosecute.

What is the Asyra Pro exactly?
As mentioned previously, it consists of hardware that connects to a PC running bespoke software. It appears to connect via USB. The wesbite for the product is full of "information" but none of it tells us very much about the hardware. Short of actually obtaining one and opening it up, it's impossible to be certain but there are some clues...
The Asyra software contains digitally-encoded information relating to a wide range of mental, physiological and emotional factors. The signals are output by the Asyra hardware as electromagnetic signals during testing. Using a simple and safe low voltage circuit formed by holding two brass cylinders, the response of the body to those signals is recorded. The response being measured is small changes in the electrical resistance of the skin. This information is relayed back to the software. A report is generated on the computer of any responses that are outside specific limits.
A low voltage current? Well, it connects via USB but the accessories include a "charger" that looks like a laptop power supply. Apparently, it does have batteries but comes with a "charger" that looks like a laptop power supply. "Signals" suggests that what ever electric current that is supplied is modulated in some way - but that can be as simple as on-off as in Morse code. However, as it says, it measures small changes in resitivity and no mention is made of, say, measuring signal degradation. What is meant by "small" is unclear but sensitive ohmmeters are more expensive than cheaper ones but the chipsets are not expensive. The Asyra does obviously contain some microelectronics. The device has a callibration button but what it does is unclear.

So, the device sends resistance data to a laptop over USB. The Asyra software "compares" this to a database
The Asyra database has been refined over many years of development and now contains a huge array of test libraries spanning physiological, emotional, mental and spiritual factors.
Right. And some of these "libraries" are very odd indeed.
Note that energetic testing with the Asyra against any of the included libraries can never be considered diagnostic of any medical condition, or as conclusive of the physical presence of any pathogen. Asyra merely reveals a change in bio-electrical response to informational signatures output by the system, from which you can draw conclusions or otherwise based on your own expertise and experience.
So, it's effectively useless? What "informational signatures" might be conveyed by small changes in skin resistance is not clear. How "informational signatures" can exist for things that don't exist (eg miasms and chakras) is unclear as is how these "signatures" are determined in the first place. Based on these "signatures", the software makes suggestions on homeopathic and/or herbal products to use. 

Something that's not immediately apparent from the descriptions on homeopaths' websites or the ASA ruling is that Asyra is also a radionic remedy maker. These devices "imprint" blank sugar pills with the "electromagnetic signature" (or equally bizarre justification) of (generally) homeopathic remedies. How the "signatures" are obtained is not explained.  Whether homeopaths mentioned in previous posts actually use the machine to "imprint" remedies is unknown. What is known is that the Society of Homeopaths (SoH) do recognise use of remedy makers as potentially problematic. From 305th Board Meeting (July 2016) minutes -
VG reported that it has been brought to the Society’s attention that there are various views/opinions on the use of Remedy machines. 
Discussion took place regarding the use of Remedy machines and whereabouts the Society stands. The Society needs to remain neutral and clarify its position with regards to insurance. It was AGREED that a statement should be prepared and information published to Members.
Oops. 

The Asyra comes with a laser "pen". There's also a Bluetooth version of the Asyra called Qest4.

Implications
From the perspective of the Professional Standards Authority (PSA) this ruling doesn't just apply to a single homeopath who is not a member of an accredited register, it applies to all members of accredited registers. Of course, this does include SoH members but some other registers too like the Federation of Holstic Therapists (FHT) and the Coomplementary and Natural Healthcare Council (CNHC). Because the Qest4 is essentially the same kind of device but with Bluetooth, it's also going to apply to users of that device too. There are a number of similar devices on the market and similar claims are made for them. By extension, the PSA may well expect accredited registers to interpret claims made for those devices in a similar way.

That the ruling doesn't mention the radionic remedy making aspects of the device but the ASA do say advertisers only mention that radionics is available.

There are other classes of device/tests that the ASA has ruled against/issued statements on that are used by SoH, FHT and CNHC members. This guidance on food allergy testing mentions the Vega device, which does roughly the same thing. The Vega device has been the subject of a fair amount of media reporting. The guidance also mentions this ruling on claims made for hair analyis, another thing that crops up on websites of SoH, FHT and CNHC members. The website cited is dead but has been archived.

The Asyra and Qest4 machines (and similar devices) would never make it through the assessment by a Notified Body and thus can not be registered with the MHRA. In theory, they are illegally on the market but the MHRA does not seem particularly concerned by them.

Tuesday, 26 June 2018

Homeopathic Treatment of Autism - Evidence #6

As discussed in a previous post the Society of Homeopaths (SoH) have been aware of CEASE therapy for some time. Their Annual Review 2016 says -
The CPD audit this year highlights how members are investing in professional development with some clear trends emerging. Of particular note was the number of members investing time and commitment to improving their presence via social media and other electronic mediums. CEASE therapy, nutrition and the sensation method were also noted as popular CPD topics among our membership. 
CEASE therapy has been around for a while but it's not clear when the first English language courses were run or those run in the UK (2011 at a guess). But that the SoH felt it worth mentioning is telling. The SoH have content on their website that relates to CEASE therapy (the link can be seen here) but it is "members only" content. What it says is unknown but it could be of concern to the Professional Standards Authority (PSA).

It's known from a Freedom of Information Act (FOIA) request that the PSA were concerned about a video in the members section featuring Yvonne Stone (mentioned in this post) talking about CEASE therapy. They were concerned that Stone mentioned "insidious levels of vaccination damage" and that this indicated anti-vaccination bias - Stone certainly is biased and...

The SoH were made aware of concerns over CEASE by PSA but were made aware in December 2017 and onwards of this of some of the issues raised in this blog. It is unknown if the SoH or any of its members read this blog but it doesn't matter. What matters is that the SoH were made aware that CEASE is a safeguarding concern. They have had many months to start to deal with the issue but seemingly have done nothing concrete.

Events that have nothing to do with PSA may overtake the SoH and their members.

This post will also look at some of their members and their claims, although in less detail than in previous posts as much of the discussion of issues has already been covered. It will pretty much cover off members whose websites have anything to say about CEASE therapy that have not been mentioned before.

Alison Jones
Jones' website looks initially innocuous but has a blog post on CEASE. It is odd that it mentions autism it makes no mention of vaccination. Something of concern are statements like this -


  • it could be that as part of the preparation for getting pregnant we discover from hair analysis that the patient’s  body has been discharging high levels of metals such as lead which could for example be as a result of  old lead water pipes in their house.
And -

  • So an easy example might be a hair analysis showing what the patient’s body has been getting rid of over the last eight weeks.
Much is made of these lead pipes and pregnancy but hair analysis? It certainly does have uses - it can detect long term exposure to heavy metals for example but most of those vendors that offer it make wildly exaggerated claims. The kind of hair analysis that a homeopath might order is likely of little value - and radionic hair analysis is known of. Lead poisoning is normally diagnosed by blood tests and the treatment is elimination of the source of the lead and chelation therapy. To suggest CEASE as a treatment for lead poisoning is highly irresponsible. Jones links to the CEASE therapy website.
Your remedy will be either given to you at the consultation or sent to you. The remedy may be administered by sugar pills, which have been infused with the remedy, or in liquid form which includes the homeopathic remedy.  You may only be given one pill until your next appointment, or you may need to take your remedy more frequently, even daily, depending on your symptoms.
Except in the case of the relatively few homeopathic remedies that are registered with the Medicines and Healthcare Product Regulatory Agency (MHRA), this would be illegal. As discussed in many other blogposts, unlicensed products have to be obtained by patients themselves.



Aneta Lesniewska
Lesniewska is Polish and unusual that she worked as a Special Needs teacher -
I have been passionate about people since I was very young. I often question myself on how we can realise our potential and optimise any area of our life. I worked with autistic children, ADHD disorder and children with learning disabilities as a Special Needs Teacher when I lived in Poland 
I hold M.A. in Special Needs Education from the Academy of Pedagogy in Warsaw. I moved to UK in 2004 and have been working in the health sector for over 10 years. I'm passionate about alternative therapies and I have been constantly training in therapies such as: Hypnotherapy & NLP, Peak States Therapy and coaching people to increase their potential.
Most readers will be familiar with the concept of hypnotherapy. NLP is Neuro-Linguistic Programming - which is dubious to say the least - some readers may be familiar with it. Peak States Therapy is very obscure. The list of techniques used is biazrre.
I graduated in 2016, I now work full time  as  a Peak States therapist specialising in Traumatic Brain Injury www.peakstates.com  and Homeopathy treating a wide range of conditions, but my main focus is treating children with autism, ADHD disorder and various problems children with learning disabilities. I also treat and help their parents. I believe homeopathy can increase the child's potential and reverse conditions often caused by toxins.
This is disturbing but seems to imply Lesniewska does not use Peak States Therapy on children. On this page  Lesniewska states -
Autism, just like most other modern illnesses, does not have a single cause. Vaccine damage, pharmaceutical drugs, emotional stress, and toxic exposures such as glyphosate in food are at the top of the list of causes.
No. On this page she talks about Homeopathic Detox Therapy (HDT) -
I’m a certified Human Chemistry and Homeopathic Detox therapist and have completed seminars with Ton Jansen -classical homeopath and developer of the Human Chemistry and Homeopathic Detox Therapy method. 
Homeopathic Detox Therapy ( HDT) aims to detoxify, balance and restore. It uses a multi- prolonged approach to reprogram the body at a deep, cellular level. The treatment is extremely gentle and offers a quick and lasting recovery. 
The goal in HDT is to understand the biochemistry behind the pathology and mental destruction
She doesn't mention CEASE and seems not  to have any training in it.Ton Jansen worked with Tinus Smits and HDT is essentially a development of CEASE therapy. Reprogram the body at a deep cellular level? Are cells programmable? Can they be made to perform useful computations? Lesniewska goes onto state what HDT can "detox" -
  • Steroids artificial hormones treating eczema psoriasis and other skin condition.
  • Unbalanced female hormones during menstruations
  • Chemicals such as petrol, vinyl, different radiation
  • Vaccinations: all childhood vaccination , travel vaccines, Influenza vaccine, Hepatitis A&B
  • Other medications: Antibiotics, anti- depressant, statins, salbutamol
  • Minerals: Aluminium, Mercury, Lead, Asbestos, heavy metals as component of vaccines
  • Narcotics: opiates, anaesthetics after operation


Anita Happs
Happs makes no mention of autism but does link to the CEASE therapy website as well as this once anti-vaccination site that seems to have become something else.

Happs' website does not seem to have changed in years and looks dated. This is not a bad thing in itself but it does again raise the question of how important internet marketing is for lay homeopaths.

Anne Do Espirito Santo
Do Espirito Santo's website is very sparse but mentions CEASE and spells out the acronym.

Apparently -
In 1991, I was registered with the Society of Homeopaths and to date remain a member of this acclaimed professional body.During my homeopathic career I have worked in the capacity of lecturer, tutor, supervisor and clinician in various prestigious colleges of homeopathy.

Clinician? No. A clinician is some who diagnoses and treats patients - in the UK that would be understood  to be doctors, nurse practitioners and some allied healthcare practitioners - generally those with statutory recognition. Lay homeopaths aren't qualified to diagnose patients in terms of the marketing claims that they can make and by extension, the term "clinician" should not be either.

Donna Draper
Draper mentions both vaccination and autism on her website
Although my work covers the whole spectrum of conditions that homeopathic medicine can help with, I do have a particular interest in working with children and adults suffering from conditions that may have arisen from vaccinations. This includes all those people who have “never been well since…” they were vaccinated. I have seen the health and behaviour of both adults and children improve considerably following homeopathic treatment.
May have arisen? Curious wording but even mention of this is suggestive of an anti-vaccination stance.
I am one of the few specially trained and qualified homeopaths to offer CEASE Therapy which is a very effective and safe way to manage and improve conditions arising on the Autistic spectrum. It combines homeopathy and nutritional supplements alongside a gentle, structured detoxification. This protocol has not only been successful in helping people on the Autistic Spectrum but also people suffering from a variety of other chronic conditions. (For more information about CEASE: www.cease-therapy.com)
 Effective? CEASE as described certainly is not safe.
I am a fully trained and experienced ‘Asyra’ Practitioner and use this Bio-Energetic Health Screening technology as an additional tool to help me in my practice. Asyra is a computerised system based on Kinesiology, Acupuncture and Chinese energy meridians. This screening technology gives feedback on the energetic status of the body and can indicate toxic stressors, allergens, organ weaknesses and food intolerances. I do offer Asyra health screening as a ‘stand alone’ therapy without a homeopathic consultation if it is requested. Please see elsewhere on my website for further information.
Asyra has been mentioned before. It's a bogus machine that supposedly can diagnose all sorts of things. Draper offers clinics in the same premises as the company behind it Nutrivital Health Limited who also offer the glorified and vastly overpriced TENS device known as SCENAR. Yes, Draper uses that as well. Worryingling Nutrivital sell apricot kernals claiming they contain "vitamin B17" - amygladin is give it its proper name is highly toxic. Nutrivital mentions Draper on this webpage about their clinic.

Draper offers consultations via Skype and telephone.

Emma Dalton
Dalton mentions CEASE on this page as well as linking to the CEASE website.
Emma has trained for 4 years in London and has worked in clinics in London and Suffolk. Emma completed a 4 year post graduate course with Dr Yubraj Sharma, London. She is a trained CEASE therapist and is available to give CPD lectures on many homeopathic topics including the use of herbal medicine. She is a recognised Supervisor for The Society of Homeopaths.
Sharma is/was the Principal of the School of Shamanic Homeopathy - its website would appear to be dead. Yes, it is as peculiar as it sounds. The idea that Dalton is recognised as a supervisor by the SoH is troubling. 
A Qualified Medical Herbalist has a BSc or equivalent in Herbal Medicine, has studied orthodox medicine as well as plant medicine and is trained in the same diagnostic skills as a GP.
No. A GP will have completed 5 years minimum doing a medical degree and then 5 years as a foundation doctor/specialty registrar. General Practitioner training itself takes 5 years. Even if this were true, would Dalton switch from differential diagnosis when performing "medical" herbalism (assuming that's what she actually does) to more bizarre notions when undertaking homeopathy? 
Biopuncture is a therapy whereby specific locations are injected with biological products. The majority of the products are derived from plants. Most of these injections are given into the skin or into muscles.
Dalton injects people? I doubt that the SoH would consider injection acceptable part of practice - it is likely to trouble the PSA. There's nothing illegal in the medically unqualified giving injections - one obvious example would be parents injecting insulin into diabetic children - but injection carries a lot more risks than ingesting an inert sugar pill.
On the continent this is known as Homotoxicology Mesotherapy and has been widely practiced by European Homeopaths for many years. It involves Homeopathic remedies being injected directly into the injured body parts e.g. knees, shoulders, back.
Mesotherapy is a French invention. There is no evidence of efficacy, full stop, and some reports of harm. Using homeopathic preparations which de facto have no efficacy, well, "Homotoxicology Mesotherapy" is all risk with no benefit beyond placebo. 
Are these products safe for me?Yes, because the ampoules do not contain high concentrations of active substances. They usually contain diluted products. As a result, toxic side effects are very unlikely. Additionally, the ampoules used in Biopuncture are manufactured by companies that guarantee the production quality of their products. Most of the ampoules used for injection are made in Germany and are held to very strict quality control regulations.
None of these products are registered in the UK. They are unlicensed medicines. Dalton is legally prohibited from obtaining them.

Dalton on her blog states -
I have been asked why there is little information on my website. The reason is that under current guidelines from the Advertising Standards Authority, I cannot say what I do. Certain words are not allowed to be used including the words treat or cure. So for example if someone contacts me and asks “Can you treat migraines?” I am not allowed to say yes. I have to respond that I have people consult me and I consider the whole person holistically.
Very strange. Dalton also links to the Freedom4Health website. Freedom4Health were mentioned in this previous post.

Emma Field
Field has a whole page on CEASE and makes all sorts of extraordinary claims that certainly would be in breach of any reasonable interpretation of the SoH's position statement let alone advertising regulations, consumer potection law or medicines regulations.
I first learnt about treating autism with homeopathy when I was in college, a friend of mine was doing her project on it and we discussed the basics in class.
A friend doing a project? Conducting unethical trial on autistic children.
Originally I knew of Tinus Smits who formulated the CEASE method of treating children with autistic spectrum expressions. His original ideal was that when you are born you have an empty bucket that equat es to your health. From the time that you are a glint in your father.s eye, you already have the possibility to have many toxicity factors in your make up . each of which is a drop in your bucket of health. So for instance if your father was a regular drug/alcohol user then there are many drops of negative toxicity in the bucket before you are even born. Mum and Dad smoked dope the night you were conceived t hen there are more toxic drops in your bucket and it already has an inch or so of toxicity in the bottom of it before you are even born. 
So comes the day of your birth and you are born with mucus and sticky eyes, because the parents smoked the dope and so in the hospital they give you AB's in order to help clear the discharge and the lungs ..more toxic drops..add to that the fact that every child in the UK is given 34 vaccinations before the age of 4.5 and you have many, many more toxic drops into the system. Add onto that any other possible toxins that the system may well have come into contact with . Mum heated your baby food in a microwave in plastic, mum had a glass of wine whilst breast feeding...Dad decides to DIY the house to prepare for the new baby . so there are paint strippers, paints, etc. more toxins that the baby is breathing in that may have an effect if he is already overloaded and has the susceptibility. 
Smits felt that the bucket getting full and starting towards the point of overflowing was when a child/adult tips over into poor health and is where the Autism comes to the surface. 
Oh the toxins! Oh the bucket! This bears little resemblance to what Smits said in his book. Smits believed that vaccines cause autism in no uncertain terms by disrupting "energetic fields". Field comes across as anti-vaccination.
So the latest concept of treating with CEASE therapy is to treat the patient with a detox made up of a mix of all the toxins in one family group.i.e. AB's, or vaccinations in one remedy. This means you c an move through the detoxes more quickly and often with greater results. You cannot mix the toxins..there are groups of steroids, vaccinations, pregnancy medications, contraceptives, paints . phenols etc., heavy metals, recreational drugs you name it there is probably a mix for it and these mixes we call 'Polys'!
 AB = antibiotic. What is described is Homeopathic Detox Therapy (HDT) - a development of CEASE. And these "Polys" are unlicensed medicines. This is not classical homeopathy - it violates several tenets of mainstream homeopathy. Oh, but the polys are remedies made from families of toxins! But hang on, who determines what toxins belong in which family? Is it based on chemistry? There are different types of antibiotics with different modes of action.
So in my practise now I treat many Autistic/Asperger.s patients with the CEASE method . I also use the method to detox patients who are not Autistic, as this helps to .clear. blockages that may affect an otherwise good prescription and stop it from working. If a patient has used steroid creams, AB's or any other prescription/recreational drugs long term there may be damage to the cells of the body that need to be healed and cleansed before constitutional treatment can work efficiently. I currently treat patients who are alcoholics, drug addicts etc. who all do very well with treatment to detox them from their chosen substance!
So inert sugar pills can treat addiction? The term "detox" is used in terms of alcohol and drug dependency treatment but it is a misnomer based on the discredited "autotoxin" theory. In reality, it often consists of prescribing medicines such as benzodiazepines to reduce withdrawal symptoms - "cold turkey" is unpleasant and can be dangerous, it's often necessary to reduce intake before cessation. This is followed by psychological therapies. Field would appear to have no training in psychological therapies, so arguably she is practicing outside of her competence.

Field used to be a dancer. She describes becoming involved in a number of therapies due to injury. Her price list shows her charging for unlicensed medicines but also food allergy testing. It doesn't describe what is meant by that but this page does.
It is muscle testing/kinesiology. Every living thing or once living thing has a magnetic energy. If you place two magnets together negative to negative they will repel each other. So you hold your arm out and I apply pressure to it whilst you hold a glass vial containing different food substances. 
If you have a negative factor in your gut, i.e. it has been damaged by what you have been eating in some way, when you introduce that damaging substance to the body again (the glass vial of food substance), you will experience muscle weakness as the body repels it (and you will not be able to hold your arm up against my pressure as the muscles go weak). 
If you think about it, not only will the muscle that I am testing be weak should you have an intolerance/allergic reaction to a food substance or other allergen, but your whole system will be weakened including your gut.
Whilst kinesiology is a real thing what Field is talking about isn't kinesiology and certainly can't be used to test for allergies

Geetu Anand
Anand has a page on CEASE. It spells out the acronym in full and also links to the CEASE website.
I am passionate about helping children diagnosed with ASD to balance their mental emotional and physical state and live life to their full potential. 
CEASE Therapy (Complete Elimination of Autistic Spectrum Expression) is a safe, effective and non-toxic step-by-step protocol developed by the late Dr Tinus Smits to help treat Autism, vaccine injury and many other chronic health conditions, as well as conditions that are linked to toxicity caused by environmental factors and conventional medications.
Vaccine injury? No. If Anand were genuine in her desire to help autistic children, she would not offer the medical neglect that is CEASE therapy.

Gill Marshall
Marshall has a page on Children & Special Needs -
As a homeopath, I have been working with this group of children for 15 years. My interest and knowledge has also grown through volunteering: with children with complex physical disabilities, with sensory impairments, with autism and with other additional needs.  
I have worked with youngsters with a range of diagnoses: autism spectrum disorder (ASD)(including what was formerly called Asperger Syndrome), attention deficit hyperactivity disorder (ADHD)cerebral palsy (CP) and Down's Syndrome (DS), also with children with less common diagnoses as well as with those not yet diagnosed.
One would hope that volunteering would involve training in safeguarding. This page also talks about parents seeking her out to "help their child with difficulties they believe stem from vaccinations or other medication side effects". No mention of CEASE is made there but is on her About page.
I am a certified CEASE therapist too. CEASE therapy is an approach that uses homeopathic remedies to address persisting side effects from medications (including the contraceptive pill, vaccinations, antibiotics and more). It is a powerful homeopathic protocol for deeply treating and clearing toxicity in the body.
Powerful? Ineffective and there are no persisting side effects from vaccination.

Marshall talks about treating autistic children on her blog in several posts. This one talks about a "regression" of an autistic child after an operation. It is strange how anesthesia is implicated when very clearly the child was stressed by the experience and no mention is made of the nature of the operation. Marshall talks about constipation here - the contradiction of qouting sensible advice and then recommending bowel nosodes is striking. Bowel nosodes are homeopathic remedies made from faeces - especially diarrhoea from very ill people. Marshall talks about sensory processing issues here.

Of more interest is this post that talks about a "study" of homeopathic treatment of special needs. It talks about MYMOP - Measure Your Medical Outcome Profile. Marshall is not alone amongst homeopaths in using MYMOP. MYMOP is interesting in a number of ways but it is worth pointing out that it is being misused. To begin with, it measures your outcome profile, not that of another person. It is not validated for children - although in theory a children with the necessary maturity and language comprehension skills could complete it. The designer Charlotte Patterson suggests an 11 year old could complete it. MYMOP is also unsuitable for infrequent, periodic problems and better for continuous problems. The study is really feeble to say the least.

Gill Upham
Upham has a page on CEASE therapy. It spells out the acronym in full and links to the CEASE website.
CEASE therapy was developed by a Dutch homeopath, Dr Tinus Smits. CEASE stands for Complete Elimination of Autistic Spectrum Expression, and the treatment involves detoxification of all possible causative factors, including vaccination, medication, environmental toxins, effects of illness, etc. The causes of autism are poorly understood, but in some cases there are strong links to one particular trigger, such as a vaccine. Most children are healthy enough to withstand any possible side effects of vaccination, but if a child is particularly susceptible to this, then in some cases they can be adversely affected; parents sometimes notice that their child’s eczema starts or worsens after one of the routine vaccinations, for example. Susceptibility varies within us all, and you will have noticed that some of us are more prone to catching colds or stomach bugs, for example, and that even within a family or other community, not everybody catches every bug that goes around. So it makes sense that some people are more likely to be affected by a medication or vaccination than others are.
Upham clearly implies that vaccination, among other things, causes autism. No mention of evidence of genetic causes.
I trained as a CEASE therapist in 2014, and my experiences to date are that significant changes can take place in a child’s sleep and behaviour using this method, after initially using more conventional homeopathic treatment. My advice to parents is that it can be life-changing, as long as you are prepared for the process to take time and for the ups and downs it can bring.
Hardly "complete elimination" and how long is the process supposed to take?

Joanna Shipley
Shipley doesn't seem to talk about CEASE therapy or autism in an active sense but talks about going for training. The page repeats the usual nonsense about CEASE and links to the CEASE therapy website as well as Smits' book on Amazon. It also links to an Amy Lansky video. Lansky and claims of "cure" of autism was discussed in this post (see under Simon Taffler).

Shipley is very likely anti-vaccination looking at her Facebook page. She reposts Arnica Group posts. Shipley is involved with the Salisbury Homeopathy College (SHC) which hosted this talk. SHC and Shipley are discussed here. This tweet also gives the impression of anti-vaccination - Donegan is notorious and also gave a talk at SHC.

Julia Lockwood
Lockwood doesn't say much about CEASE but on the What I Treat page -
I am a qualified CEASE practitioner. CEASE was first developed by a Dutch doctor, Tinus Smits MD, to treat autistic children, and is now being practised, refined and developed by more than 500 homeopaths worldwide, who are linked by a strong and collaborative network.
Network? If it exists, no obvious sign of it online. Lockwood also links to the Amy Lansky video mentioned above. On her About Me page -
I am a certified CEASE practitioner, which means I am trained to use homeopathy to detoxify in serious conditions, such as autism.
No.

Karen Sternhell
Sternhell mentions CEASE therapy here and links to the CEASE therapy website.

Lucinda Torabi
Torabi was one of the SoH members (along with Ursula Kraus-Harper) that wrote to the SoH about the Advertising Standards Authority (ASA). Not that much came of that but it does suggest that Torabi might not be particularly willing to comply with the SoH position on CEASE.

Torabi makes mention of CEASE on a Homeopathy and Autism page. The title of that page implies that homeopathy can treat autism - which is not permissible although the SoH are unlikely to interpret the position that was effectively forced on them in that way. 

Margaret Kincade
Kincade mentions CEASE therapy here -
In 2011 I qualified as a CEASE practitioner – this is a methodology that was developed by homeopath Tinus Smits. He was a visionary and worked with many autistic children to relieve symptoms and improve their quality of life as well as their families. For me, CEASE is a methodology that sits along with many other methodologies that I have studied and can employ if classical prescribing is not making the progress I would have expected.
Smits was a visionary? Only if his visions are understood as hallucinations. It has to rememberd that Smits did not invent CEASE therapy - it was the Universal Intelligence acting through him. 

Melissa Foreman
Foreman makes mention of CEASE on her Qualifications page -
I am also qualified as a CEASE therapist. Cease stands for Complete Elimination of Autistic Spectrum Expression and is an effective way of treating autism through elimination of causative toxic exposures such as vaccines and regular medication.
CEASE is not effective. Vaccines and "regular" medications do not cause autism.

Merran Sell
Sell has a page on Autism/Aspergers.
Some years ago I read about Tinus Smits, a Dutch doctor and homeopath, who had developed the CEASE protocol for working with autistic, Asperger’s and ADHD children, as well as many others, to great effect. I started to apply some of his techniques and found that this certainly improved the outcomes.

In October 2011 I attended the first CEASE course in this country, along with 90 other homeopaths from all around the world. It was an extremely useful and enlightening course and I am now a homeopathic CEASE registered practitioner. You can find further information if you Click here www.cease-therapy.com and then to find the register scroll down the righthand side of the home page click on cease-therapy.com/make-appointment and fill in West Byfleet or an area close to Woking.
This tells us when the first CEASE course was held in the UK. An attendance of 90 is quite surprising.
I have worked with autistic, Asperger’s, ADD and ADHD children for over 20 years as a special education needs teacher, in specialist schools and as a Special Education Needs Coordinator in a mainstream junior school. During this time I have also worked with these children in my homeopathic clinic.
Sell should have had extensive safeguarding training. She should be more than aware that medical neglect is a serious concern. Treating children that she worked with as a teacher/coordinator is ethically questionable to say the least. Her entry on the CEASE therapy website seems to imply that she no longer teaches.

Muhammad Hayaat Riaz Khan
Khan has a page on CEASE but it doesn't say anything that hasn't already been mentioned. Of course, it repeats the claim that vaccines, toxins, etc cause autism.

Khan's biography makes for strange reading. It is full of self-promotion and questionable phraseology. To a degree, it reads like the site of homeopaths from the Indian sub-continent.

Muhammad Hayaat R. Khan is a registered Homeopathic Consultant and Director of The Zenith Clinic For Complementary HealthCare and is the visionary behind The Zenith Clinic mantra. Muhammad Hayaat has been studying Homeopathic Medicine for the past 11 years. He has been in private general practice for the past 5 years with a special interest in children’s complaints. His medical studies have spanned Leeds University, BIH London, North West College Of Homeopathy and St Georges Medical School London. He has had the privilege of studying under world renowned emminent Homeopathic Doctors, such as Dr Jonathan Hardy, Dr Jeff Johnson and Dave Mundy.
Homeopathic Consultant? Private general practice? Both of these imply a medical qualification that Khan does not have. Leeds University does have a School of Medicine. St Georges is well regarded. However, Khan does not seem to have a medical degree so what his "medical studies" consisted of is a mysteries. Johnathan Hardy is a member of the Faculty of Homeopathy and does offer training but to medical professionals only. However, he does do seminars that appear to be open to anyone. Jeff Johnson is a vet. He doesn't seem to offer training but does offer to give lectures. Dave Mundy may have studied osteopathy but is not a registered osteopath - he is a lay homeopath and has lectured at the North West College Of Homeopathy.
After completing his theology studies at Darul U Loom Bury, he was advised by his spiritual Shaykh and Mentor, Hadhrat Mowlana Yusuf Motala Saab (D.B) to study Homeopathic Medicine. Muhammad Hayaat has always been deeply interested in medicine; hence after graduating from the University of Leeds in 2001, he subsequently enrolled on the Professional Homeopathic Practitioner course with the B.I.H in London and gained his licence to practice Homeopathy in 2006 after 5 years of study. To further advance his studies and proficiency, he subsequently enrolled on an additional four years advanced course with The North West College of Homeopathy in Manchester, from where he graduated in July 2013.
Khan's religious beliefs are not relevant to this post. Khan has a BA, which if from Leeds likely had nothing had nothing to do with medicine. The BIH is the British Institute of Homeopathy. The history of the BIH is somewhat murky. Currently, it exists as an online course provided based in New Jersey. It previously did seem to be based in the UK. It did offer a D.I.Hom (Diploma of Homeopathy) at one point. However, it is not recognised by any of the UK trade associations but this document from 2005 suggests that at one time it was. It's not clear when it stopped being recognised or when it shifted from the UK to the USA. Khan can only be a member of the SoH by virtue of having qualified from the North West College Of Homeopathy which doesn't offer an "advanced course" - just a 4 year practitioner course. Khan joined the SoH in July 2013. It's suspected he was a member of the Alliance of Registered Homeopaths (ARH) in the past. 

Khan offers a number of peculiar treatments that have nothing to do with homeopathy. Whether he performs all of them himself is different to say. No mention is made of any other practitioners at his Zenith Clinic although the website mentions female practitioner(s) are available. The Facebook page has reviews that mention cupping as well as homeopathy. Khan may be a member of the British Cupping Society (BCS) - he appears to have "certificates" from them - but there doesn't seem to be a way to find practitioners. The BCS seem to be in bed with the dubious General Regulatory Council for Complementary Therapies who have been mentioned in passing several times in previous posts often in conjuction with Freedom4Health.Colonic hydrotherapy is another staple of quackery. Sports massage may seem innocuous but any manipulative therapy carries risks, especially if performed by the unqualified. 

As for food intolerance testing, Khan would appear to have "certificates" in "B.E.R" testing - which turns out to be Bio-Energetic Resonance testing and uses machines like the Asyra.
Khan offers "fat freezing" or more correctly Cryolipolysis and be aware that the article has questionably bias in favour and underplays potential side effects. He uses a 3D Lipomed machine and turns up on this website as a clinic. The world of non-surgical cosmetic procedures is largely unregulated. The machines often used are medical devices yet very few of them seem to be correctly registered and authorised. There generally aren't restrictions on who can use these devices either. 

Teeth whitening? To quote from Khan's website -
At the Zenith Clinic our teeth whitening products are the best on the market, because we care about your teeth. There are two options: In Practice whitening (application by the dentist) or Home Whitening. In Practice whitening costs a little more but guarantees an excellent level of whiteness (known in the industry as a B1 shade). If you ask in one of our practices, they can show you a colour shade sample. Teeth whitening is generally suitable and safe for everyone and will not harm your teeth. 
Khan is not a dentist. The products that he could legally offer are the kind that can be bought over the counter in high street pharmacies. Illegal teeth whitening has become a big concern, see this story for example. If Khan is offering illegal products, rather than making odd marketing claims, he could face huge fines.

Niki McGlynn
McGlynn has a page that mentions CEASE therapy.
CEASE therapy is a particular way of applying homeopathy that was developed for the treatment of children with autism, however it can be effective for anyone who has a bad reaction to a specific conventional treatment or environmental toxin such as antibiotics, vaccinations, lyme disease, mercury exposure etc.
Lyme disease is real but chronic Lyme disease is controversial to say the least. Lyme disease is rarely fatal but delayed treated can result in more severe symptoms and complications in treatment. Given that antibiotics are the first line treatment for Lyme, homeopathy and in particular CEASE therapy with its anti-antibiotic position is not a good idea. It's assumed that McGlynn is making reference to "chronic Lyme disease" and to be blunt it is an area infested with quackery.

McGlynn like a number of other homeopaths mentioned appears on the Thames Valley Homeopaths website. It would appear to be a bubble of CEASE therapy among other things. 
Niki McGlynn RSHom is based in Wokingham, and has a special interest in fertility and pre-conceptual care, autism and children and adults suffering from prolonged side effects of conventional medication, for example post-vaccination.
McGlynn is likely anti-vaccination. Although not touched on previously, the claims that some SoH members make about fertility and pre-conception care are problematic. There is an industry of quackery around fertility, pregnancy, child birth, etc and lay homeopaths often place themselves front and forward in that. It is beyond the scope of this post but it is difficult not to read the marketing as claiming credit for things that just happen and/or preying on anxieties.