Wednesday, 15 January 2020

How bad is anti-vaccination among (and for) homeopaths?

This blog has looked several times at anti-vaccination sentiment among homeopaths (here, here and here). These posts give a flavour of how extreme homeopaths can be in their opinions as well as at hinting at the how widespread anti-vaccination is. It goes without saying that CEASE therapy and homeoprohylaxis are considered anti-vaccination.

There could be severe consequences for UK homeopathy.

Some history
To understand the current situation, it is necessary to understand some of the history of UK homeopathy. Anti-vaccination sentiment is nothing new in homeopathy and neither is anti-vaccination sentiment in general although the type of individuals/organisations involved has changed as have some of the objections to vaccination.

The early history of UK homeopathy has been documented by a number of people but perhaps the most important is Peter Morrell. Some of Morrell's work is in the public domain which is very helpful but Morell is pro-homeopathy, anti-vaccination and somewhat bonkers.

Because of a shared language, there has always been a strong interchange between UK and US homeopathy. The predominant direction of that influence shifts and changes over time. However, there are profound regulatory and legal differences between the UK and the US that do to a degree act as a barrier to certain ideas.

Homeopathy is very conservative in that it places great store on the teachings of Hahnemann and other homeopaths of history. However, the language used in their books is often impenetrable to the modern reader. It can be very aphoristic, couched in terms that are obsolete and now pretty meaningless. There is also homeopathic literature devoted to what the "Great Masters" actually meant in their writings and it will come as no surprise that there are differences in interpretation, which are often at the heart of doctrinal differences between different "schools" of homeopathy.

Homeopaths quibble over whether Hahnemann himself was pro or anti-vaccination. Hahnemann was a contemporary of Edward Jenner. But James Tyler Kent certainly was anti-vaccination and is infamous for his germ theory denialism -
The microbe is not the cause of disease. We should not be carried away by these idle allopathic dreams and vain imaginations but should correct the Élan vital.
Kent was an adherent of Swedenborgianism and believed that disease had spiritual causes. This belief is still found among modern homeopaths. Swedenborgianism never caught on in the UK. James Compton Burnett was an English homeopath and was one of the first to write about "vaccinosis", a term that homeopaths still use. Bear in mind Burnett was writing in 1884 - the smallpox vaccine was commonly used and the first chlorea vaccine was only introduced in that year. There were no other vaccines. Early smallpox vaccines were not as safe as modern ones and some of the methods used in vaccination were unsanitary. Burnett's "vaccinosis" is very different to, say, Tinus Smit's notions of it before he changed his language to talk more of "vaccine injury" and "vaccine damage".

Historically, most UK homeopaths were doctors. There were few lay practitioners and often medical homeopaths were opposed to them. UK homeopathy, whether medical or lay came very close to dying out in the decades after the Second World War. It was only in the 1970s that interest started to pick up again and it was largely lead by lay homeopaths who went onto form to the Society of Homeopaths (SoH). Morrell has a fairly detailed piece on the history of UK lay homeopathy. Medical homeopathy also seems to have become more popular from the 1970s onwards. Both are now in decline.

Some of the founders of the SoH certainly do not think of homeopathy as a "complementary" therapy. They see homeopathy as an alternative to conventional medicine and are very hostile towards it. There was a tendency to see homeopathy as some sort of anti-establishment radical social movement and most medical homeopaths as part of the establishment. 

Bear in mind some of these people went on to found homeopathic colleges and if they didn't, often taught at them, wrote books and so on. It is difficult to guage what impact their thinking had on the homeopaths that they taught and to what degree that that thinking has been passed down. One thing that became very clear during research of current anti-vaccination homeopaths is that many do see themselves as part of a generalised radical movement centered on left wing politics and environmental issues although there are a minority that hold to more right-wing/libertarian positions.

The recent history of anti-vaccination isn't just about the MMR controversy and the claim that it causes autism. One of the main US anti-vaccination organisations the National Vaccine Information Center (NVIC) was formed in 1982, way before Andrew Wakefield appeared on the scene (1998). NVIC's initial focus was the DPT vaccine brought about by a TV documentary DPT: Vaccine Roulette which drew on the views of Gordon Stewart. Stewart was later strongly associated with AIDS denialism during a particularly ugly period in South African history. But prior to Stewart there was Dr John Wilson who made the claim that DPT caused brain damage (do read this by Brian Deer - it also mentions Stewart). Wilson's claims caused DPT vaccine rates to plummet and there was a huge outbreak of whooping cough in the UK during the 1970s. 

So, in addition to an instrinsic strand of anti-vaccination in homeopathy, the revival of homeopathy was taking place at a time when there were vaccine scares. It is difficult to piece together how prevalent anti-vaccination was among UK homeopaths but there are some clues. The paper The Reluctant Profession - Homoeopathy and the search for legitimacy (Cant and Sharma, 1995) is fascinating in many ways (and a very different perspective from the writing of Morrell). It tells us - 
During the last fifteen years there have also been changes in the claims that the Society has made. For instance, the Society issued a leaflet about the potential hazards associated with child vaccination, but in 1993 they decided not to print the leaflet as it was regarded as too contentious:
We had to ask whether it was in our professional interests to cover this area, some members may see this as a climb down, but we have decided not to reprint the article because basically the Department of Health told us that if we continued to promote the non vaccination stance then we would find it very hard to begin a process of state recognition and at the same time we were beginning to see it was not our function to give out this advice. (Officer of Society)
This 1995 letter from the British Journal of General Practice states -
The homoeopaths were asked whether they used or recommended orthodox immunization for children and whether they only used and recommended homoeopathic immunization. Seven of the 10 homoeopaths who were medically qualified recommended orthodox immunization but none of the 13 non-medically qualified homoeopaths did. One non-medically qualified homoeopath only used and recommended homoeopathic immunization. 
A 2002 letter in the British Medical Journal says -
We contacted 168 homoeopaths, of whom 104 (72%) responded, 27 (26%) withdrawing their answers. We contacted 63 chiropractors, of whom 22 (44%) responded, six (27%) withdrawing their responses. No general practitioners responded. The table shows that only a few professional homoeopaths and a quarter of the chiropractors advised in favour of the MMR vaccination. Almost half of the homoeopaths and nearly a fifth of the chiropractors advised against it.
Bear in mind that this is post-Wakefield.

The 2005 thesis The body, health, and healing in alternative and integrated medicine: An ethnography of homeopathy in South London is very long and quite difficult to read online. Again, a fascinating document with a somewhat different perspective than that of homeopaths themselves. It is very illuminating of the belief systems of homeopaths and their clients. There is also a great deal on anti-vaccination sentiment among both. 

From page 90 -
I asked two of the homeopaths, at the time of much press debate on the public's failure to take up the MMR vaccination for their children, why homeopaths didn't speak out in the press, giving their view of the harmfulness of vaccinations to the immune system? They told me that this message had been forbidden by their parent organisation, the Society of Homeopaths. In Cant and Sharma's analysis, this instruction had been made in order to reduce possible friction with the biomedical system and the government, during a period in which the Society moves towards hopeful government recognition of homeopathy as a profession through parliament. It was interesting to see this played out in the communications between these homeopaths and their clients. They still told them that vaccination was harmful to their children's developing immune systems, but stressed the need for each parent to make up their own mind about vaccinating or not. Had the research been done a couple of years prior, the more radical nature of the homeopath's stance against vaccination might have been more openly communicated. So when I asked the homeopaths why letters to the press defending the homeopathic position of the harmfulness of vaccines had not been sent, I was told that this view must be suppressed for political reasons. 
Plus ça change, plus c'est la même chose. Although if the SoH did forbid the message, many did not get the message or it was rapidly forgotten. 

The section "The Vaccine Support Group" starts on page 225.
Jenny started The Vaccination Support Group 3 years ago. The impetus to start the group came from her clients. At the time she was running sessions for mothers to lear about homeopathic first-aid to use on their children. The people attending had a lot of issues around vaccination, wanting to make decisions but not knowing where to get the information. Jenny recruited her friend from homeopathic college, Eve an ex-midwife, to help her start a vaccination group. The group meets one evening every month for a couple of hours in Jenny's house or the house of one of the group members, Sally. Jenny has a list of topics for discussion and negotiated with the group their preferred topics for a particular session. The women who attend the group are mostly mothers of babies and small children, although quite often homeopath friends of Jenny and Eve's attend, or other alternative therapists, to find out more about the vaccination debate to support their clients. The evenings cover childhood vaccines, the research on their side effects, and information about homeopathic strategies to boost immune systems and treat symptoms should mothers choose not to vaccinate.
It is clear that Jenny is Liz Bevan-Jones and Eve is Yvonne Stone. Both still actively promote anti-vaccine information and are involved with Arnica Group. They authored the No Nonsense Vaccine Handbook. Stone has been mentioned on this blog.

There is more but the above should be sufficient to give a flavour.

Current Situation - anti-vaccination movement
Anti-vaccinationists in the UK are nowhere near as organised, well-funded or influential as they are in the US. There is not political support for anti-vaccination in the UK. Not are there big donors. What groups there are tend to be either focused on "vaccine injury" that want to obtain compensation, legal action, etc or based on a more generalised anxiety about vaccines who are supportive of the former. UK anti-vaccination groups tend to be less aggressive in their claims. Whilst UK individuals can be just as nasty as US ones, it's much less frequent.

Some US arguments apply less or even not at all to the UK. For example, although mandatory vaccination is discussed, it is unlikely to happen in the UK. There is a view that if vaccination rates have fallen to the point where mandatory vaccination is the solution then public health education has failed. Decisions about mandatory vaccination in the UK would be made at a national level, whereas in the US they are made at the State level.

The fellow travellers are different in the US too. It should be noted that Church of Scientology front groups have become involved in lobbying. And of course there is the health freedom movement which is more of a lobby group that serves the interests of certain manufacturers and their lawyers than a grass roots consumer movement. Neither have much influence in the UK. 

The politics of US anti-vaccinationists can be very different too. Right wing libertarianism is rare in the UK but not in the US. Even the appeal to the "natural" is more commonly couched in terms of an alternative to the Big Pharma conspiracy to poison the population than being linked to concerns about the environment.

The UK population is prossibly less prone to conspiracy theories than the US and there are likely differences in the popularity of various conspiracy theories between the two. Cultural, economic and political differences militate towards that. This Guardian story is interesting because it compares UK Leave/Remain supporters with US Trump/Clintion supporters. It mentions anti-vaccination and curiously Leave supporters are more likely to believe in anti-vaccination conspiracy theories. This is curious given that the majority of anti-vaccination homeopaths looked at, if they expressed an opinion, were Remainers. Conversely, the populist right have picked up on anti-vaccination in other countries such as Italy.

There have not been any really big media stories since Wakefield that anti-vaccinationists have successfully used or that gained traction with the UK media. It might be thought that stories like the H1N1 vaccine Pandemrix increasing the risk of nacrolepsy in a certain age group might have been picked up on in a big way but they weren't. Whilst there is some resistance to flu vaccination, Pandemrix isn't mentioned. Flumist seems to be the main focus along with the supposed lack of efficacy for flu vaccines in general. There is also opposition to HPV vaccination the motivations for which are complicated. However, the claim that MMR causes autism is still central to most anti-vaccinationists.

Wakefield's initial claim was that autism was somehow linked to changes in the gut caused by measles RNA in the MMR vaccine, his imaginary autistic enterocolitis. This idea has largely lost favour with anti-vaccinationists although the related imaginary leaky gut syndrome still has adherents, including homeopaths (and others) who claim to treat autism with restrictive diets. More common is the claim that vaccines contain mercury which causes autism. Most vaccines no longer contain thiomersal, no link has been found between the levels used in vaccines and any condition. But some anti-vaccinationists still trot this out. Some anti-vaccinations have abandoned this line in favour of the claim that is aluminium in vaccines that cause autism. This comes from the discredited work of Christopher Exley.

It doesn't matter to anti-vaccinationists that no link between vaccination and autism has been found. It doesn't matter that putative mechanisms of action are discredited. Their counter-factual beliefs are resistant to rational argument. Challenging those beliefs often leads to entrenchment of their position.

Society of Homeopaths
Anti-vaccination poses a huge threat to the SoH and may tear it apart.

A previous post talks about a sampling exercise. This was expanded to look at all SoH members with websites. The percentage of SoH of members with their own websites who expressed anti-vaccine sentiment on their website or on linked to social media was 32%.

A further piece of analysis was also done. In February 2019 the PSA and SoH were supplied with a list members offering CEASE therapy and the related Homeopathic Detox Therapy. This list was used as the basis of an analysis that looked at Facebook accounts, whether or they were linked to by the member's website. The results were mixed.

People use the internet in different ways. Not everyone distrusts as Facebook as much as they should and some use it extensively. Some consmers may find homeopaths via Facebook rather than Google or using a third party directory. Facebook is probably the primary route for anti-vaccination misinformation transmission.

There were a small number of members who very frequently shared/posted anti-vaccination misinformation on Facebook. One posted over 110 items in less than 11 months, sometimes posting multiple items in a day. Those members shared some truly awful posts including -


It is difficult to say whether the dismissive attitude towards unnecessary deaths, disability or just suffering caused by vaccine preventative diseases in far away countries is one of racism or parochialism. Whether anti-vaccinationists played any role in the Samoa measles outbreak is currently unclear but their activities have been linked to outbreaks in the US

The sharing of extreme US anti-vaccine material cropped up a lot. The claims made go far beyond "vaccines cause autism". Claims that vaccines kill more people than the diseases they prevent, that HPV is not a cause of cervical cancer. Incredibly bizarre conspiracy theories.

Faculty of Homeopathy
The Faculty of Homeopathy (FoH) describes itself as -
Founded in 1844 and incorporated by Parliament in 1950 the Faculty of Homeopathy supports registered medical professionals with their homeopathic practice. We are the only homeopathic organisation to be recognised by professional bodies such as the General Medical Council (GMC) and we have nine course providers, including four overseas.
This isn't strictly true as they have members who are not registered medical professionals. Also, the General Medical Council (GMC) doesn't recognise homeopathy as a specialty, it recognises that FoH as a revalidation body, which is rather different.

The FoH is legally exempt from publishing accounts. It hasn't made the number of members public for some years. Because of the way its search facility works, it's difficult to determine how many members it does have, but there are estimated 150 on its register in UK and Ireland. There are lower levels of membership but the expectation is that unsupervised homeopathy doesn't go on.

Not all regulated medical practitioners who practice homeopathy are members of the FoH. The FoH only admit those who have completed their approved training courses. Some practitioners have chosen to do lay homeopathy training courses. There are some medical practitioners who are members of the FoH and another homeopathic association but it seems like that they gained membership of the latter by a different route than simply having completed a certain training course. 

FoH members are far less likely to have their own online presence. As a result, it is far more difficult to determine whether they hold anti-vaccination views. It's understood that anti-vaccination views are not uncommon in Anthroposophy, but they are not universal and anthroposophic doctors have their own organisation (partly because the training is different) but some FoH mention that they are interested in anthroposophic medicine. 

The FoH's official position is that it supports vaccination. As discussed in a previous post, it is suspected that a statement from 4Homeopathy was actually written by the British Homeopathic Association (BHA) which is so closely linked to the FoH to pretty much be the same organisation but Gary Smyth, President of the FoH, said in the FoH house magazine -
Dr Smyth said: “As has happened too many times in the past, we are being tarred with the same brush as some other practitioners who take an anti-vaccination stance, so it’s important that we make it clear that we are certainly not anti-vaccination. It is frustrating that our detractors know exactly the right buttons to press to generate division among homeopaths and also to get front-page headlines.”
It is known that there are FoH members who are anti-vaccination. Jayne Donegan is the most obvious example. The FoH have long known about Donegan but have never dealt with her. Problematic in a different way was the reporting of Ainsworths producing a booklet that on the face of it promotes homeoprophylaxis. Anthony Pinkus is behind Ainsworths. It's not clear if he had any hand in writing the booklet (he has written others) but Pinkus is Pharmacy Dean of the FoH. Yubraj Sharma is a problem. Christine Suppelt too. There are also concerns that some veterinary surgeons are suggesting homeoprophylaxis to clients even if they don't mention it publicly.

The General Medical Council (GMC) are looking into Donegan's case. This will likely take a long time. 

Alliance of Registered Homeopaths
The Alliance of Registered Homeopaths (ARH) is the second largest homeopathy association in the UK with around 530 members. It was formed in 2001.  It's about half the size of the SoH. It differs from the SoH in a number of key ways. Firstly, it recognises additional courses that the SoH doesn't and entry via other routes is easier. The leadership of the ARH is essentially static - it has had the same directors for a number of years and how one becomes a director of the ARH is unclear. That leadership is very distrustful of conventional medicine and cares very little for what external authorities might think of it and its members. It doesn't even try to pretend professionalism in the way that the SoH does. Inaction seems its default position. As an organisation, it rarely says anything publicly although some of its members are extremely vocal.

The ARH has no obvious position on vaccination unlike the SoH and FoH. It is more than happy to publish anti-vaccination (which imply vaccines cause autism etc) and homeoprohylaxis articles in its magazine. 

One difference between the SoH and the ARH is that the Professional Standards Authority (PSA) require the SoH to keep their register up to date. The ARH is under no such obligation. Its register contains quite a lot of errors and omissions.

Researching anti-vaccination among ARH members certainly gave the impression they were more likey to stress homeopathy as alternative to medical treatment, that esoteric beliefs, especially related to neo-shamanism and the Goddess movement were more common than with SoH members. Identification with social and political movements was less stressed and sometimes environmental concerns were linked to esoteric belief.

To begin with the same methodology as with SoH members - that is to say member websites that were listed on the register were examined. If those websites belonged to a clinic or where in a foreign language they were excluded. Social media accounts linked to from the member website were also examined. Any anti-vaccination sentiment or direct links to anti-vaccination websites etc were noted. The results were slightly surprising. Only arond 26% of those members expressed anti-vaccination views.

When looking at member's websites that were either not recorded in the register or wrongly recorded and likewise searched for social accounts, a different picture emerges. Of those members that had any online presence that was their own, 44% expressed anti-vaccination views. 

The ARH has some very problematic members. Trevor Gunn was discussed here and Cathy Lemmon here. Melissa Wakeling appeared in a Daily Mail story offering homeoprophylaxis - and is involved with Free and Healthy Children International (FHCi) discussed here. Lorraine Whitby was caught out by the Daily Telegraph. The Advertising Standards Authority (ASA) recently made it public that members Carolyn Stevens (mentioned here) and Paula Lattimer have been referred to Trading Standards who have the powers to prosecute. There are others not (yet) referred to Trading Standards who still make the "Complete Elimination of Autistic Spectrum Expression" claim such as Mary Harper. And of course ARH Communications Director Steve Scrutton spews anti-vaccination and anti-medicine nonsense on his blog.

There is good reason to believe that the ARH will do nothing to rein in the dubious claims of members. It never has before and given the prevalence of anti-vaccination, it probably can't. Whether it would actually support the likes of Stevens and Lattimer if they faced prosecution is unknown. That would involve doing something.

The ARH hasn't had any real dealings with the media. It is likely not to respond to enquiries, "no comment" or at most offer up some empty words. Notionally, 4Homeopathy can provide help in dealing with the media but...

Homeopathic Medical Association
The Homeopathic Medical Association (HMA) looks like the third largest homeopathy association in the UK. It was formed in 1985 but there is very little on the internet about its history. It is even lower profile than the ARH. It used to be involved with 4Homeopathy but at some point withdrew.

The HMA does not have a stated position on vaccination. However it published a petition from Natural News regarding the infamous anti-vaccinationist Sheri Tenpenny on its website. There isn't a lot on its website. It is almost as if the HMA stopped functioned some time ago. The last published new item is from 2015. The website doesn't appear to have been updated in a long time. Its Facebook page hasn't been updated since 2014. There is a 2017 conference brochure but it is not clear if it took place.  Unless the organisation operates purely by post, email or on a members only part of the website, it looks largely moribund. Companies House records reveal it had one employee in prior to 2019 accounts but none now. 

It has 257 members but many of them are Japanese. Both the SoH and the ARH have a few Japanese members, but the HMA has 137 of them. Only around 105 are UK based. This is very odd. Again, using the same methodology as in the intial SoH analysis, there were only 32 member websites. Of these, only 7 contained anti-vaccination statements or linked to social media with such statements. This is around 22%.

Keith Smith was caught out by the Daily Telegraph in the same undercover operation as Lorraine Whitby and Alan Freestone. 
Keith Smith in Eastbourne warned the reporters not to listen to "unqualified workers in the National Health Service, and politicians," and instead "go to the top" – to authors like Trevor Gunn, a homeopath whose books include "Vaccines: This book could remove your fear of childhood illness". 
He declined to comment on this story.
It is telling that Smith references Gunn who is extremely anti-vaccination.

The Federation of Holistic Therapists (FHT) like the SoH is accredited by the PSA. It has a number of homeopath members but the FHT effectively has two registers - one accredited by the PSA, one not. The numbers are so small it isn't worth doing any analysis. The same is true for a number of non-PSA accredited registers such as the Complementary Medicine Association and the Complementary Therapists Association

Of course, some of the worst anti-vaccination homeopaths don't belong to any association. Their position is extremely exposed.

It's clear that anti-vaccination poses a serious threat to the SoH but it is a threat to UK homeopathy in general, particularly in the area of cooperation between associations in the promotion of homeopathy to the public.

Quite clearly, anti-vaccination among lay homeopaths poses real problems for the FoH. Although they are a minority of homeopaths, they have considerably more power than other associations. Partly this stems from their status as medical professionals, partly because they have Royal patronage and other links to the establishment but also because of money (or rather the BHA's money). The FoH/BHA are suspected to provide a lot of the funding and some of the manpower for 4Homeopathy. It should be noted that it is generally FoH members that turn up in national media interviews, although lay homeopaths sometimes turn up in local specialist media. Donegan and Pinkus aside, it is lay homeopaths that get caught by the media.

Media interviews with FoH members are tedious to watch/listen to but could be very different in the present climate if an interviewer brings up the subject of anti-vaccination. Of course, the FoH are pro-vaccination and the interviewee is likely to trot that out. Some FoH members are obviously anti-vaccination and the FoH have known about them for a long time and done nothing. An interviewer may not know that and not ask the right questions. It depends how good the researchers are. But that there are homeopaths who are anti-vaccination is pretty widely understood by some in the media now. The interviewee could respond that they aren't their members and that's where the trouble could start.

There have been antipathies between medical and lay homeopaths in the past and old wounds could be reopened. In short, medical homeopaths regard lay homeopaths as potentially dangerous amateurs. Lay homeopaths regard medical homeopaths as not true homepaths. There have been accusations that medical homeopaths seek to control lay homeopathy. 

When Newsnight carried out undercover investigations in 2006, it caused all sorts of havoc. The late Peter Fisher spoke out against lay homeopaths offering malaria "prevention" in the report -
I'm very angry about it because people are going to get malaria - there is absolutely no reason to think that homeopathy works to prevent malaria and you won't find that in any textbook or journal of homeopathy so people will get malaria, people may even die of malaria if they follow this advice.
The FoH will have to start distancing itself from lay homeopaths or at least those that continue with anti-vaccination unless it wants to find itself tarred with the brush (it should deal with its anti-vaccination members). It could pull the funding/resources from 4Homeopathy. The Find a Homeopath website is registered to Karin Mont, Chair of the ARH. Not that the ARH makes any mention of 4Homeopathy and it's not clear if it has any real involvement with it. If there is prosecution of ARH members, depending on how the ARH deal with it, that would be the end of whatever involvement it has with 4Homeopathy. 

And mere "distancing" may not be enough. It could come to denouncement. Condemning extremists who don't belong to any organisation is easier than denouncing those that do because that is an implicit criticism of the organisation. 

Smyth is only partially right when he said "our detractors know exactly the right buttons to press to generate division among homeopaths". Those divisions already existed and there more than a few of them. UK homeopathy tries to pretend they aren't there or downplays them in the name of "stronger together". Perhaps, the FoH could continue to cooperate with the SoH and its accredited colleges if they managed to deal with their anti-vaccination members. The price might be higher than that. The SoH might have to condemn anti-vaccination, it might have to publicly support vaccination rather than just say giving "advice" about anti-vaccination is beyond the competence of members.

That would still leave other divisions, including those that revolve around the competence of lay homeopaths to treat anything.

Existential Threats
In the short term, UK homeopathy associations may be in for a rough ride but homeopathy and homeopaths are not going to disappear. They maybe more marginalised than before, the market may shrink but homeopaths will likely keep on doing whatever it is that they actually do.

There have been moves in the past towards statutory regulation of homeopathy and other forms of CAM. It did happen with chiropractic and osteopathy in the UK but nothing else. Government enthusiasm waxes and wanes. Of course, the obstacles to statutory regulation of homeopathy are such that it could never happen but previously governments have said things to the effect of sort yourselves out or we will legislate. Legislation doesn't have to involve statutory recognition of homeopathy or any other form of CAM. As discussed here, it can prohibit medically unqualified persons from performing certain activities. An absolute prohibition on homeopathy would very difficult but, for example, preventing lay homepaths (and other medically unqualified lay persons) from treating children would not be. 

Playacting at medicine is bad. Spreading anti-vaccination propaganda is bad. If there are hundreds of lay persons doing both in the UK and it does not stop, Government may eventually react. The worst case scenario is that there is a localised outbreak of a vaccine preventable disease in an area where anti-vaccination homeopaths operate. 

UPDATE: 29/01/2020
Homeopathy International (HINT) saw fit to make a statement on vaccination. It is bizarre to say the least. 
The position of Homeopathy International (HINT) on vaccination and informed consent is simple and straightforward and is in line with the current legal situation in the UK. People must be free to make decisions about their health and their children’s health, and they must have all the information required to reach their decisions.
HINT is pro children and pro informed consent, in full agreement with UK law. It is not “anti vaxx”, a phrase increasingly used to demean the undecided. 
Several of HINT's steering committee are anti-vaccination. And no, "anti vaxx" is not used to describe the undecided, it is used to describe those who spread anti-vaccine propaganda etc.

HINT makes much of informed consent and Montgomery v Lanarkshire Health Board. Montgomery revolves around the non-disclosure of risks and HINT attempts to argue that the risks of vaccination are not spelled out to patients and that the risks are underplayed or even suppressed. The irony is that non-disclosure is almost universal in homeopathy. Also, it can be argued very strongly that the provision of misinformation (eg vaccines cause autism) is negligent. 
HINT agrees with the current UK legal position. Unless adults and the parents of young children are made fully aware of all material risks, they cannot give valid consent to any procedure. HINT expects all professionals who are asked for information about vaccination by adults and the parents of children, to be in possession of sufficient information to enable them to point those people in the direction of available and reliable information, so that adults and parents can make their own decisions. 
Healthcare professionals who are asked for information about vaccination may find that adults and parents of children may need to read or research widely. 
Reliable information? 
HINT is aware, as are other observers of the vaccination question, that some adults and parents wish to look further for information, as is their right. HINT considers that when healthcare professionals are sought out for information, those professionals must exercise their duty to listen carefully, and to give financially disinterested and up to date information, within the limits set by their knowledge. The perception of ambivalence and uncertainty in the NHS that some people experience is perhaps understandable.
"Limits set by their knowledge"? This is different from the SoH line that advising on vaccination is beyond the competence of lay homeopaths. The Dunning-Kruger effect and other cognitive biases mean that lay homeopaths are often incapable of recognising the limits of their knowledge and evaluating information. 

HINT fails to distinguish between information, misinformation and conspiracy theories.
Information about vaccination in the public media is influenced by the nature of the vaccine industry and controlled by a few large corporations. Corporate law requires them to put shareholder benefit before all else. To maximise shareholder return, in a vaccine marketplace worth nearly $50 Billion annually, those corporations employ huge advertising budgets. The public media depend on advertising income, and not surprisingly, feel obliged to reflect the views of their important advertisers. This seriously distorts the balance of information provided to readers and viewers.
Really? Vaccines are prescription only in the UK. The Human Medicines Regulation 2012 prohibits the advertising of prescription only medicines.  However, it does allow public health campaigns. Information about vaccination is far from controlled by large corporations.
The United States and New Zealand are the only two countries that allow direct-to-consumer advertising of prescription medicines. This belief is very common among UK homeopaths and anti-vaccinationists. It's also very wrong.

HINT has one member who is clearly anti-vaccination. Although HINT does not be seem to be actively recruiting members, they may see an opportunity to if the SoH clamps down on anti-vaccination.

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