Royal College of Veterinary Surgeons - Statement on Homeopathy

The regulation of Veterinary homeopathy was dealt with in this post and the following one. The latter includes some of the text of the previous RCVS position statement on homeopathy.

Before examining the statement and various actions to it, it is important to realise that there is no such thing as a "homeopathic vet". There are vets who prescribe homeopathy but any vet that prescribed homeopathy 100% of the time would i) not get a lot of business, ii) could find themselves in legal trouble and iii) run the risk of being struck off by the RCVS.

The Statement

“We have recently been asked questions about complementary and alternative medicines and treatments in general and homeopathy in particular. 

“We would like to highlight our commitment to promoting the advancement of veterinary medicine upon sound scientific principles and to re-iterate the fundamental obligation upon our members as practitioners within a science-based profession which is to make animal welfare their first consideration. 

“In fulfilling this obligation, we expect that treatments offered by veterinary surgeons are underpinned by a recognised evidence base or sound scientific principles. Veterinary surgeons should not make unproven claims about any treatments, including prophylactic treatments. 

“Homeopathy exists without a recognised body of evidence for its use. Furthermore, it is not based on sound scientific principles. In order to protect animal welfare, we regard such treatments as being complementary rather than alternative to treatments for which there is a recognised evidence base or which are based in sound scientific principles. It is vital to protect the welfare of animals committed to the care of the veterinary profession and the public’s confidence in the profession that any treatments not underpinned by a recognised evidence base or sound scientific principles do not delay or replace those that do.”

Reaction to this statement by supporters of homeopathy were predictably hostile. As with the response to the NHS England consultation Items which should not be routinely prescribed in primary care: A Consultation on guidance for CCGs, predictably wrong.

The RCVS felt it necessary to point out some of the errors in some of the early responses.

• The RCVS is not banning homeopathic veterinary medical products (VMPs)
• The RCVS is suggesting that vets should only prescribe homeopathic VMPs as adjunctive to conventional treatment
• The RCVS has the legal power to set standards of practice for vets
• The RCVS has no power to prevent animal owners from treating their own animals with homeopathy
• The RCVS did not try to stop a petition raised on the Care2 platform. It requested that inaccuracies in the petition were amended.

Responses

Media reporting of the RCVS statement was sparse but unsurprisingly focused on the dramatic. Homeopathy is killing people’s pets screamed the Metro. In themselves, the probability of a homeopathic VMP killing an animal is virtually zero. 

The British Association of Homeopathic Veterinary Surgeons (BAHVS) issued a statement. As might be expected, it is full of special pleadings.

The RCVS failed to consult at all with stakeholders actually involved in CAM, despite representations to be so consulted, before considering and issuing their statement. This failure is contrary to the usual manner in which the RCVS conducts itself.

The RCVS did not consult, per se, but to quote from the RCVS statement -

The statement comes after long-standing discussions within the veterinary community about the efficacy and ethics of complementary and alternative medicines.

 The BAHVS go on to state -

It is commonly accepted that it is not the role of a regulator to seek to influence clinical judgement nor to resolve differences of scientific opinion. The RCVS has stated many times that it does not get involved. Yet the current RCVS Council has seemingly, willingly, allowed itself to be seduced by a belief-based irresponsible diatribe from a vocal minority into a precedent-setting restriction of the clinical freedoms the profession has always enjoyed. In doing so it has ignored advice from its own advising committees and it has embarked on a course that will stifle future innovation, research and evolution of new treatment modalities.

The irony of this statement will be lost on the BAHVS and their supporters. The RCVS remit includes setting professional standards for veterinary surgeons and nurses. As the overwhelming consensus of science, especially medical science, is that there is no homeopathic medicince can demonstrate an effective that is greater than would be consistent with placebo, it can be argued that this objection is invalid.

It is perhaps no coincidence that it should do so when there is an explosion of interest in CAM, including Homeopathy, in the agricultural sector where the drive is to reduce and replace dependence on antibiotics in light of Antibiotic Resistance (AMR) concerns, and some of the most successful methods so far are proving to be those defined as CAM. It is fact that some of the largest “conventional” veterinary practices in the UK dealing with animal production for food are the ones leading the way on this, seeking out treatments as “alternative”, and Homeopathy is proving one of the successful modalities. In singling out the issue of prophylactic treatments – the very use of CAM for which in agriculture significantly threatens the finances of the Pharmaceutical Industry – the RCVS puts itself into a position where it can be accused of putting profits before probity, and corporations before conscience – or is it just naïve and completely out of touch?

Conscience? One of the most important ways to reduce dependence on antibiotics is by improved animal husbandry. It is the case that homeoprophylaxis is considered by many homeopaths to be ineffective and unethical. It is also the case that nosodes - homeopathic medicines made from diseased tissue and often used in homeoprophylaxis - are considered unsafe by the Veterinary Medicines Directorate (VMD) and it is forbidden to place them on the market. But there are such products on the market.

Placing an irrational, quasi-regilious belief above evidence and legal restriction is not exactly a good move.

So what of the evidence argument against CAM? There is in fact very good evidence for much of CAM, including and especially Homeopathy, with many peer-reviewed papers in a number of Journals. However, these papers are routinely ignored by the establishment as they are published in CAM journals. This is bizarre when one considers that a parasitologist will publish in a journal of parasitology, a pharmacist in a journal of pharmacology, so why not a homeopath in the journal “Homeopathy”?

A level playing field regarding evidence it is not. The bar is raised so high by the RCVS for CAM that it can never compete. Funding for research has been historically blocked by bodies such as the BVA. When the mainstream journals are sponsored by Big Pharma and other vested interests, so that Editors dare not publish CAM papers, it is unfair and corrupt to criticise CAM in this way. The RCVS’s own Science Committee in this debate noted that the evidence base for a number of accepted “conventional” treatments is lacking so why pick on CAM, which has as good if not better in place, and is not subject to the same fallacies that can contaminate the most prestigious journals when researcher and publisher bias and fraud are led by the money men?

The idea that CAM treatments are held to a different, higher standard than conventional treatments is not the case. In fact, homeopathic VMPs are not required to demonstrate efficacy in order to be registered whereas conventional VMPs must in order to be granted a Marketing Authorisation.

The manufacturers of homeopathic medicines - both human and veterinary - have traditionally spent very little on research. But research does exist. It is almost uniformly very poor - bad trial design, statistically underpowered and full of cognitive bias. The manuacturers either don't particularly care about research or they know something the BAHVS doesn't. The BVA has no power to influence the decisions of manufacturers.

Clients actively seek out CAM therapies for their animals as conventional medicines regularly fail or produce unacceptable side effects. Homeopathy has previously been recognised in the RCVS register as having a specialist qualification (it still does), and is independently examined and regulated, which is perhaps why it attracts the most ire of the CAM options. Homeopathy is in fact provided for in UK and EU Legislation. It is required to be available, cannot be banned without a change in the Law, and it behoves the profession to embrace it, even if in the minority.

All that EU Regulation does is create a scheme by which homeopathic VMPs can be registered and placed on the market. In fact, UK legislation could be read in such as a way as to suggest that the prescribing of homeopathic VMPs is de facto illegal and has been for many years.

Why clients seek out CAM therapies is not relevant to the argument as it is about prescribing by veterinary surgeons. If a conventional medicine fails or produces unacceptable side effects, another one should be tried. The cascade (see below) makes this clear. It is NOT a first line treatment.

A witch-hunt has been conducted on an unprecedented scale in the profession. This has been aided by the support on social media of some Past Presidents of the RCVS and BVA, RCVS Council members and by the profession’s media chiefs. It is time for it to stop. It discredits those making and supporting the attacks on colleagues, discredits the profession and, by disseminating false conclusions to the media, adds to the growing and damaging public distrust of science and of our profession.

Again, BAHVS seem blind to the irony in their statement.

The Faculty of Homeopathy (FoH) largely regurgitate the BAHVS statement. Other groups do as well.

Some on social media did talk about "rights" and "freedoms". They percieve some sort of right to engage the services of a "homeopathic vet" and ignore animal protection legislation. Use of homeopathy can, in certain circumstances, be considered neglect.

The Petition
From the Care2 Petitions website -

On Friday 3rd of November the (RCVS) Royal College Veterinary Surgeons has released a statement showing its intent to prevent vets from using natural medicine, especially homeopathy but also other forms of Complementary and Alternative Medicine (CAM). 

The statement effectively prevents vets and animal guardians from having the option to treat animals with CAM, esp homeopathy as first-line medicine.
In making this statement, they have been swayed by a vociferous minority and failed to consult experts in the field or stakeholders, so it has been imposed upon the profession without due process. 

RCVS council members have made statements online, in forums and on social media, that clearly indicate that this is just a prelude to them seeking a change in legislation and thus potentially a complete ban on vets using all CAM therapies that they deem not to fit within their limited pharmaceutical - based paradigm. 

It is plain to see that they feel threatened by the success of Complementary and Alternative Medicines, in particular Homeopathy. 

Please help to save The Homeopathic Vets and those practicing Complementary Alternative Medicines that have healed so many animals

There are a number of errors in this petition. It is not clear if this is the original text or whether the RCVS did persuade Care2 to get the author to amend it.

The prescribing of homeopathic VMPs as first line treatment is legally questionable but has nothing to do with the RCVS and everything to do with the Veterinary Medicines Regulations 2013 and the cascade.

The idea that the RCVS is influenced by a "vociferous minority" is laughable. It is understood that no member of the current RCVS council supports the use of homeopathy. Previous surveys revealed that the majority of the veterinary profession do not support it either. There was also an online petition against veterinary use of homeopathy that was signed by over 1,000 vets. 

The "success" of CAM treatments for animals? This is an unevidenced statement. It is clear from the RCVS statement and from statements by individual vets that they not perceive CAM as a threat to their practice but rather a threat to animal welfare. 

The March
Apparently, the BAHVS have organised a march to deliver their petition to RCVS offices in London. The goal of this is to get the RCVS to withdraw the statement.

The march is unlikely to attract large numbers of supporters. Historically, protests by supporters of homeopathy have attracted very low numbers. For example, they protested against the Advertising Standards Authority (ASA). A huge turn out of 20.

Cascade
This was discussed in a previous post. It is not intended to repeat the content here. Suffice to say, the cascade provides rules as to what products can be prescribed if there is not suitable VMP for a particular species and condition. It makes no direct mention of homeopathic VMPs but it is clear that the products do not fit into the cascade. It is certainly the case that if a suitable product exists, it must be tried first. It is not clear whether homeopathic VMPs are permitted as a 3rd line treatment but their use as a 1st line treatment certainly isn't.

Violating the cascade can be a criminal offence. Having said that, the VMD do not seem to have ever prosecuted anyone with regards to homeopathic VMPs but it is known that they have requested certain products to be removed from the market.

Would the RCVS discipline a "homeopathic vet"?
This is unknown. However, a veterinary surgeon prosecuted by the VMD for violation of the cascade certainly would be. Likewise, if the RSPCA prosecuted for neglect.

Conclusion
It is clear that supporters of veterinary homeopathy do not understand the role of the RCVS. It is also clear that they do not understand the regulation of VMPs.

No mention is made anywhere by supporters of the cascade or the VMD. The RCVS is the wrong target.

If the RCVS managed to get the VMD to issue a clear statement on the position of homeopathic VMPs in the cascade, that would have a much greater effect than their own position statement.

UPDATE
Supporters of the BAHVS had their march. The turn out was around 30. There have been suggestions that the Metropolitan Police restricted the numbers. This seems unlikely. A video of the march can be found here. There is a somewhat amusing story associated with this video in that it contains footage from a different, much larger demonstration. It is reasonable to suppose this was done with the intention of creating an impression of much larger support. The story also involves Roger Meacock.

The BAHVS have updated their website. This will be discussed at a later date but there are many problems with it.

Various other websites that were previously not mentioned have been set up to support veterinary homeopathy (although some predate the RCVS statement).

Vets4InformedChoice.org would seem to be set up by non-practising vet "Jack" Hoare. It has a link to an email. 

If new to this list then please visit www.vets4informedchoice.org and sign up to our email list for updates as the situation evolves. This is a new site that explores the evidence for conventional and alternative medicines in animals. The site will be expanding rapidly over the next few months.

No sign of rapid expansion yet.

At the time of writing the 4 Homeopathy website was not responding. This is likely to be a temporary thing. From a cached webpage -

The Council of the Royal College of Veterinary Surgeons (RCVS) issued a statement on the 2nd November 2017 effectively threatening legal action under the Animal Welfare Act if a vet, and potentially the owner, use homeopathy or other complementary medicines before using conventional pharmaceuticals. 

Suspicious? You should be. The intentions of the Council of the RCVS are clear. After Brexit complementary medicines won’t be protected by EU law and the corporate pharmaceutical industry could reign supreme. 

Amazingly, the RCVS council made this statement without consulting any homeopathic vets, academics or researchers. Instead the council were influenced by a group of skeptics, none of whom have ever studied, qualified in and practiced homeopathy. There is poor evidence for much of conventional veterinary practice and procedures. However the basis of this RCVS council statement is that homeopathy does not have a recognised body of evidence. This is totally incorrect. 

Do you believe in your right to decide what is best for the welfare of your animal and your right to complementary medicine? Ultimately do you believe in freedom of choice? 

Please join many thousands of others and sign the petition below, share to Facebook and send to all email contacts.https://www.thepetitionsite.com/219/768/240/we-need-to-stop-the-rcvs-from-banning-homeopathic-vets-from-treating-animals/ 

If you have any expertise or resources and want to help the campaign please get in touch with the British Association of Homeopathic Veterinary Surgeons (BAHVS) http://www.bahvs.com/contact-us/ 

You can view the response of the British Association of Homeopathic Veterinary Surgeons at http://www.bahvs.com/rcvs-statement/

Join the support group on Facebook: We Support Veterinary Homeopathy and Complementary Therapies.

The 4 Homeopathy group, for those unaware, is essentially a PR group set up by the various homeopathic trade associations. It attempts to coordinate PR activity. To a degree, it has been successful in UK homeopathy presenting a mostly less shrill and irrational face to the public but in this case, it falls back into that trap. The RCVS do not have the power to prosecute for one thing. A vet treating animals with homeopathic medicines as a first line treatment would be in breach of the Veterinary Medicinces Regulations 2013 and the cascade. It is for the Veterinary Medicines Directore to enforce these Regulations.

The idea that Brexit would somehow cause homeopathic VMPs to disappear is questionable - this was touched on in this post. The Facebook group mentioned is a closed group. It may be associated with this LinkedIn profile. There are concerns that some of those associated with the Facebook group etc are involved in treating other people's animals when they are not qualified veterinary surgeons.

Supporting Veterinary Homeopathy and Complementary and Alternative Medicine (CAM) would appear to be linked to this group. The website promotes a postcard campaign. More worrying, it has a Testimonials page - basically some of them contain evidence of violation of the Regulations.

CAM4ANIMALS is a website set up by someone who works at Scott Dunn's Equine Clinic. As per usual, it contains a link to the erroneous petition and repeats the usual mistakes. It has a Get Involved page which contains links to the petition, the above mentioned postcard campaign and templates for letters to the RCVS and MPs. The letters are ill-informed but also include worrying suggestions.