Contrasting the USFDA and Social Skepticism Definitions of ‘Homeopathy’
Any man can be made to appear irrational and vile, if his enemies only are allowed to speak on his behalf.
Homeopathy, as defined by a particular series of strawman fallacies, is a completely ridiculous pseudoscience, yes. The problem is that the United States Food and Drug Administration, the manufacturers of homeopathic product and the industry in general do not define homeopathy by means of these strawman fallacies. Only Social Skepticism does. Why?
As it turns out, the claims from Social Skepticism that homeopathy is defined as employment of extreme dilutions, placebo, metaphysical entities, vital energies or adherence to antiquated science, all reveal themselves upon diligent investigation, to be false.
The Ethical Skeptic is forced to ask: Why? (Note: I am not a homeopathy proponent, I believe there should be one standard for OTC medicinals, and efficacy (not safety) approval should come through a qualified consumer review panel – anonymous so that it cannot be corrupted by SSkeptics and Big Pharma – and not have the process left to an overwhelmed FDA, or prejudiced SSkeptic and Big Pharma lobby groups. The most informed researchers are mom’s and dad’s – we just need to harness the power of enough of their ethics and knowledge. And in today’s data and intelligence technology environment, this can be done. Unfortunately lobbyists, money and Social Skepticism are getting in the way of science.)
In order to give that inquiry justice, that will have to be the subject of another blog article altogether. But I suppose we will find a hint below with respect to the FDA’s 1962 delineation of HPUS qualified substances. An issue which begs the question, and forces us too examine the all-to-common milieu around SSkeptic definitions, and in particular theirs of ‘homeopathy’:
– Who Loses? and
– Who Benefits?
An exercise I command regularly in my advisement services with nations suffering from corruption and oppression. We have already published a blog study (see the graphic below) showing that homeopathic cold remedies sold in drug stores over the counter were exactly the same ingredients and dosages as employed in the big pharma equivalents; so The Ethical Skeptic has suspected that some chicanery was afoot in the Social Skepticism movement regarding homeopathy. It appears to be a whipping boy subject to further a furtive oligarch agenda. The definitions below elicit this dishonesty and the specific fallacies involved:
From The Skeptic’s Dictionary, Social Skepticism’s definitions of homeopathy:¹
“…the less you use it, the stronger it gets.” – Phil Plait
“…helping the vital force restore the body to harmony and balance.”
“…involves the appeal to metaphysical entities and processes.”
“…trying to balance “humors” by treating a disorder with its opposite (allos).”
“…generally defined as a system of medical treatment based on the use of minute quantities of remedies…”
“…potency could be affected by vigorous and methodical shaking (succussion).”
“…succussion could release “immaterial and spiritual powers,” thereby making substances more active.”
“Homeopaths refer to “the Law of Infinitesimals”… The law of infinitesimals seems to have been partly derived from his notion that any remedy would cause the patient to get worse before getting better and that one could minimize this negative effect by significantly reducing the size of the dose. Most critics of homeopathy balk at this “law” because it leads to remedies that have been so diluted as to have nary a single molecule of the substance one starts with.”
“…homeopathic remedies work by altering the structure of water, thereby allowing the water to retain a “memory” of the structure of the homeopathic substance that has been diluted out of existence.”
“…homeopathic remedies, if effective, are no more effective than placebos.”
“…homeopaths believe, …that the [scientific practice of a] placebo-controlled randomised (sic) controlled trial is not a fitting research tool with which to test homeopathy.”
“…homeopathy claims a special exemption from the rules of logic and science…”
This array of mis-definitions and prejudicial portrayals suffers from not only the fact that they are incorrect – homeopathy, as defined by the professional organizations who regulate and manufacture in that industry (in other words the “authorities” as SSkeptics like to cite), employs standard industry effective ingredients in standard OTC dilutions – but also suffers employment of
6 fatal, non-trivial fallacies in the definition of homeopathy foisted by Social Skepticism
- a fallacy of composition in that one historical person or fringe idea is used as rationale to dismiss an entire equivocal subject
- a lie of equivocation, in employing a mis-definition to impugn a similarly titled topic ‘homeopathy’
- a characterization from a negative premise, in that they presume all users of the term ‘homeopathy’ practice pseudo science or adhere to anti-scientific agendas
- a fictus scientia fallacy, wherein one claims that science has tested industry defined homeopathy, when indeed it has only tested SSkeptic defined homeopathy
- a scarecrow error, in fabricating completely fictitious, ridiculous or expired beliefs as constituting the claims of a disdained group, in order to discredit the group
- an antiquing fallacy, showing its false, hoax based or dubious past inside a set of well known anecdotal cases. Also the instance where a thesis is deemed incorrect because it was commonly held when something else, clearly false, was also commonly held.
But in the real world, where real professional business is done, it’s the same damn stuff, same damn substrate, same damn dilutions, same damn product – Just costs 15-55% less than the products pushed by the sponsors of Social Skepticism (see below).
And here is why. The United States Food and Drug Administration defines homeopathy² in its jurisdictional provisions under Section CPG 400.400 of its Compliance Policy Guidelines regarding homeopathy
The following terms are used in this document and are defined as follows:
1. Homeopathy: The practice of treating the syndromes and conditions which constitute disease with remedies that have produced similar syndromes and conditions in healthy subjects.
2. Homeopathic Drug: Any drug labeled as being homeopathic which is listed in the Homeopathic Pharmacopeia of the United States (HPUS), an addendum to it, or its supplements. The potencies of homeopathic drugs are specified in terms of dilution, i.e., 1x (1/10 dilution), 2x (1/100 dilution), etc. Homeopathic drug products must contain diluents commonly used in homeopathic pharmaceutics. Drug products containing homeopathic ingredients in combination with non-homeopathic active ingredients are not homeopathic drug products.
According to the Homeopathic Pharmacopeia of the United States, a homeopathic drug does not have to involve the principle of dilution at all.³ In fact the seven criteria, recognized by the FDA and the HPUS, which selectively or collectively qualify a drug as being homeopathic are
1) US FDA compliant as safe and effective
2) prepared according to the specifications of the General Pharmacy
3) submitted documentation to USFDA and HPUS
4) drug proving and clinical verification in accordance with modern evolved scientific practices
5) substance was in use prior to 1962 – Note Public Domain Medicinal – ‘Who loses and who benefits?’
6) two adequately controlled double blind clinical studies
7) clinical experience or data documented in the medical literature
Not a single one of these requirements for listing on the HPUS involves or required extreme dilutions, placebo, metaphysical entities, vital energy or adherence to antiquated science. Imagine that. The FDA and SSkepticism definitions do not match in the least. An all too common occurrence.
Again, I am not a proponent of homeopathy. I buy the product if it is a low cost alternative to the big pharma inflated equivalent. But given the rancor with which Social Skepticism deals with the subject, and the patterns of habitual corruption employed in their opposition, the natural question I then must ask is: Why?
¹ homeopathy, The Skeptic’s Dictionary, October 11 2014; http://skepdic.com/homeo.html. Note that the employment of the definition is shrouded in its recitation offing, yet the contention that this constitutes the definition of homeopathy remains logically clear once the text is removed of antiquing fallacy, misdirection and equivocation prejudice employed in the history of the subject outlined in the reference. In this context the ‘history of the subject’ is employed in a context in which no other definition is offered, and is employed in such a way to discredit the subject as a whole – an invalid form of argument – and thus, substantiates the argument’s employment as a method of tendering a definition.
² The United States Food and Drug Administration, Inspections Compliance Enforcement and Criminal Investigations Section “CPG Sec. 400.400 Conditions Under Which Homeopathic Drugs May be Marketed,” http://www.fda.gov/iceci/compliancemanuals/compliancepolicyguidancemanual/ucm074360.htm.
³ The HPUS Criteria for Eligibility, http://www.hpus.com/eligibility.php.
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