Download Lectures on Biostatistics (1971). Corrected and searchable version of Google books edition
Download review of Lectures on Biostatistics (THES, 1973).
coQ10
Alfred Joseph Clark FRS held the established chair of Pharmacology at UCL from 1919 to 1926, when he left for Edinburgh. In the 1920s and 30s, Clark was a great pioneer in the application of quantitative physical ideas to pharmacology. As well as his classic scientific works, like The Mode of Action of Drugs on Cells (1933) he wrote, and felt strongly, about the fraud perpetrated on the public by patent medicine salesmen. In 1938 (while in Edinburgh) he published a slim volume called Patent Medicines. The parallels with today are astonishing.
 
Alfred Joseph Clark FRS (1885 – 1941) |
 |
I was lucky to be given a copy of this book by David Clark, A.J. Clark’s eldest son, who is now 88. I visited him in Cambridge on 17 September 2008, because he thought that, as holder of the A.J. Clark chair at UCL from 1985 to 2004, I’d be a good person to look after this and several other books from his father’s library. They would have gone to the Department of Pharmacology if we still had one, but that has been swept away by mindless administrators with little understanding of how to get good science.
Quotations from the book are in italic, and are interspersed with comments from me.
The book starts with a quotation from the House of Commons Select Committee report on Patent Medicines. The report was submitted to the House on 4 August 1914, so there is no need to explain why it had little effect. The report differs from recent ones in that it is not stifled by the sort of political correctness that makes politicians refer to fraudsters as “professions”.
The problem
“2.2 The situation, therefore, as regards the sale and advertisement of proprietary medicines and articles may be summarised as follows:
For all practical purposes British law is powerless to prevent any person from procuring any drug, or making any mixture, whether patent or without any therapeutical activity whatever (as long as it does not contain a scheduled poison), advertising it in any decent terms as a cure for any disease or ailment, recommending it by bogus testimonials and the invented opinions and facsimile signatures of fictitious physicians, and selling it under any name he chooses, on payment of a small stamp duty. For any price he can persuade a credulous public to pay.”
Select Committee on Patent Medicines. 1914
“The writer has endeavoured in the present article to analyse the reasons for the amazing immunity of patent medicines form all attempts to curb their activity, to estimate the results and to suggest the obvious measures of reform that are needed.”
| Clark, writing in 1938, was surprised that so little had changed since 1914. What would he have thought if he had known that now, almost 100 years after the 1914 report, the fraudsters are still getting away with it? Chapter 2 starts thus. |
 |
THE LAW
The Select Committee appointed by the House of Commons in 1914 ‘to consider and inquire into the question of the sale of Patent and Proprietary Medicines’ stated its opinion in 28 pages of terse and uncompromising invective. Its general conclusions were as follows:
That the trade in secret remedies constituted a grave and widespread public evil.
That the existing law was chaotic and had proved inoperative and that consequently the traffic in secret remedies was practically uncontrolled.
In particular it concluded ‘”that this is an intolerable state of things and that new legislation to deal with it, rather than merely the amendment of existing laws, is urgently needed in the public interest.”
The “widespread public evil”continues almost unabated, and rather than introduce sensible legislation to cope with it, the government has instead given a stamp of approval for quackery by introducing utterly ineffective voluntary “self-regulation”.
Another Bill to deal with patent medicines was introduced in 1931, without success, and finally in 1936, a Medical and Surgical Appliances (Advertisement) Bill was introduced. This Bill had a very limited scope. Its purpose was to alleviate some of the worst abuses of the quack medicine trade by prohibiting the advertisement of cures for certain diseases such as blindness, Bright’s disease [nephritis] , cancer, consumption [tuberculosis], epilepsy, fits, locomotor ataxy, fits, lupus or paralysis.
The agreement of many interests was secured for this measure. The president of the Advertising Association stated that the proposed Bill would not affect adversely any legitimate trade interest. Opposition to the Bill was, however, whipped up amongst psychic healers, anti-vivisectionists and other opponents of medicine and at the second reading in March 1936, the Bill was opposed and the House was counted out during the ensuing debate. The immediate reason for this fate was that the Bill came up for second reading on the day of the Grand National! This is only one example of the remarkable luck that has attended the patent medicine vendors.
(Page 14).
The “remarkable luck” of patent medicine vendors continues to this day, Although, in principle, advertisement of cures for venereal diseases was banned in 1917, and for cancer in 1939, it takes only a few minutes with Google to find that these laws are regularly flouted by quacks, In practice quacks get away with selling vitamin pills for AIDS, sugar pills for malaria and homeopathic pills for rabies, polio anthrax and just about anything else you can think of. Most of these advertisements are contrary to the published codes of ethics of the organisations to which the quack in question belongs but nothing ever happens.
Self-regulation simply does not work, and there is still no effective enforcement even of existing laws..
“It has already been stated that British law allows the advertiser of a secret remedy to tell any lie or make any claim that he fancies will sell his goods and the completeness of this licence is best illustrated by the consideration of a few specific points.
Advertisements for secret remedies very frequently contain a list of testimonials from medical men, which usually are in an anonymous form, stating that ………….. M.D., F.R.C.S., has found the remedy infallible. Occasionally, however, the name and address of a doctor is given and anyone unaware of the vagaries of English law would imagine that such use of a doctor’s name and professional reputation could not be made with impunity without his consent. In 1899, however, the Sallyco Mineral Water Company advertised that ‘Dr. Morgan Dochrill, physician to St. John’s Hospital, London and many of the leading physicians are presenting ‘Sallyco’ as an habitual drink. Dr. Dochrill says nothing has done his gout so much good.
Dr. Dochrill, whose name and title were correctly stated above, sued the company but failed in his case. ”
“The statement that the law does not prevent the recommending of a secret remedy by the use of bogus testimonials and facsimile signatures of fictitious physicians is obviously an understatement since it is doubtful how far it interferes with the use of bogus testimonials from real physicians.”
Dodgy testimonials are still a mainstay of dodgy salesman. One is reminded of the unauthorised citation of testimonials from Dr John Marks and Professor Jonathan Waxman by Patrick Holford to aid his sales of unnecessary vitamin supplements. There is more on this at Holfordwatch.
The man in the street knows that the merits of any article are usually exaggerated in advertisements and is in the habit of discounting a large proportion of such claims, but, outside the realm of secret remedies, the law is fairly strict as regards definite misstatements concerning goods offered for sale and hence the everyday experience of the man in the street does not prepare him for dealing with advertisements which are not merely exaggerations but plain straightforward lies from beginning to end.
Scientific training is undoubtedly a handicap in estimating popular gullibility as regards nostrums. One imagines that no one today would be willing to spend money on pills guaranteed to prevent earthquakes but yet the claims of many of the remedies offered appear equally absurd to anyone with an elementary
knowledge of physiology or even of chemistry. A study of the successes and failures suggests that success depends chiefly on not over-rating the public intelligence. (Page 34)
This may have changed a bit since A.J. Clark was writing in 1938. Now the main clients of quacks seem to be the well-off “worried-well”. But it remains as true as ever that “Scientific training is undoubtedly a handicap in estimating popular gullibility as regards nostrums.” In 2008, it is perhaps more a problem of Ben Goldacre’s dictum ““My basic hypothesis is this: the people who run the media are humanities graduates with little understanding of science, who wear their ignorance as a badge of honour.”
Clark refers (page 36) to a successful conviction for fraud in the USA in 1917. The subject was a widely advertised ‘get fat quick’ pill that contained lecithin, proteins and sugar. The BMA analysis (in 1912)
suggested that the cost of the ingredients in a box of 30 tablets sold for 4/6 was 1 1/4 d. [4/6 meant 4 shillings and six pence, or 22.5 pence since 1971, and 1 1/4 old pence, a penny farthing, is 0.52 new pence]. He comments thus.
The trial revealed many interesting facts. The formula was devised after a short consultation with the expert of one of the largest drug manufacturers in the U.S.A. This firm manufactured the tablets and sold them to the proprietary medicine company at about 3/- per 1000, whilst they were retailed to the public at the rate of £7 10s. per 1000. The firm is estimated to have made a profit of about $3,000,000.
These trials in the U.S.A. revealed the fact that in a considerable proportion of cases the ‘private formula’ department of the large and well known drug firm already mentioned had first provided the formula for the nostrum and subsequently had prepared it wholesale.
Nothing much has changed here either. The alternative medicine industry (and it is a very big industry) is fond of denouncing the evils of the pharmaceutical industry, and sadly, occasionally they are right. One of the less honest practices of the pharmaceutical industry (though one never mentioned by quacks) is buying heavily into alternative medicine. Goldacre points out
“there is little difference between the vitamin and pharmaceutical industries. Key players in both include multinationals such as Roche and Aventis; BioCare, the vitamin pill producer that media nutritionist Patrick Holford works for, is part-owned by Elder Pharmaceuticals.”
And then. of course, there is the deeply dishonest promotion by Boots the Chemists of homeopathic miseducation, of vitamins and of CoQ10 supplements.
The manner in which secret remedies can survive repeated exposure is shown by the following summary of the life history of a vendor of a consumption [tuberculosis] cure.
1904, 1906: Convicted of violating the law in South Africa.
1908: Exposed in British Medical Association report and also attacked by Truth.
1910: Sued by a widow. The judge stated: ‘I think this is an intentional and well-considered fraud. It is a scandalous thing that poor people should be imposed upon and led to part with their money, and to hope that those dear to them would be cured by those processes which were nothing but quack remedies and had not the slightest value of any kind.’
1914: A libel action against the British Medical Association was lost.
1915 The cure was introduced into the United States.
1919 The cure was sold in Canada.
1924 Articles by men with medical qualifications appeared in the Swiss medical journal boosting
the cure.
Secret remedies have a vitality that resembles that of the more noxious weeds and the examples mentioned suggest that nothing can do them any serious harm.
Most of the time, quacks get away with claims every bit as outrageous today. But Clark does give one example of a successful prosecution. It resulted from an exposé in the newspapers -wait for it -in the Daily Mail.
There is, however, one example which proves that a proprietary remedy can be squashed by exposure if this is accompanied by adequate publicity.
The preparation Yadil was introduced as an antiseptic and was at first advertised to the medical profession. The proprietor claimed that the remedy was not secret and that the active principle was ‘tri-methenal allylic carbide’. The drug acquired popularity in the influenza epidemic of 1918 and the proprietor became more and more ambitious in his therapeutic claims. The special virtue claimed for Yadil was that it would kill any harmful organism that had invaded the body. A more specific claim was that consumption in the first stage was cured with two or three pints whilst advanced cases might require a little more. Other advertisements suggested that it was a cure for most known diseases from cancer downwards.
These claims were supported by an extraordinarily intense advertising campaign. Most papers, and even magazines circulating amongst the wealthier classes, carried full page and even double page advertisements. The Daily Mail refused these advertisements and in 1924 published a three column article by Sir William Pope, professor of Chemistry in the University of Cambridge. He stated that
the name ‘tri-methenal allylic carbide’ was meaningless gibberish and was not the chemical definition of any known substance. He concluded that Yadil consisted of :
‘About one per cent of the chemical compound formaldehyde.
About four per cent of glycerine.
About ninety-five per cent of water and, lastly, a smell.
He calculated that the materials contained in a gallon cost about 1/6, whilst the mixture was sold at £4 10s. per gallon.
This exposure was completely successful and the matter is of historic interest in that it is the only example of the career of a proprietary medicine being arrested by the action of the Press.
Clark goes on to talk of the law of libel.
“On the other hand the quack medicine vendor can pursue his advertising campaigns in the happy assurance that, whatever lies he tells, he need fear nothing from the interference of British law. The law does much to protect the quack medicine vendor because the laws of slander and libel are so severe.”
The law of libel to this day remains a serious risk to freedom of speech of both individuals and the media. Its use by rogues to suppress fair comment is routine. My first encounter was when a couple of herbalists
threatened to sue UCL because I said that the term ‘blood cleanser’ is gobbledygook. The fact that the statement was obviously true didn’t deter them for a moment. The herbalists were bluffing no doubt, but they caused enough nuisance that I was asked to take my pages off UCL’s server. A week later I was invited back but by then I’d set up a much better blog and the publicity resulted in an enormous increase in readership, so the outcome was good for me (but bad for herbalists).
It was also good in the end for Andy Lewis when his immortal page “The gentle art of homoeopathic killing” (about the great malaria scandal) was suppressed. The Society of Homeopaths’ lawyers didn’t go for him personally but for his ISP who gave in shamefully and removed the page. As a result the missing page reappeared in dozens of web sites round the world and shot to the top in a Google search.
Chiropractors are perhaps the group most likely to try to suppress contrary opinions by law not argument. The only lawyers’ letter that has been sent to me personally, alleged defamation in an editorial that I wrote for the New Zealand Medical Journal. That was a little scary, but the journal stuck up for its right to speak and the threat went away after chiropractors were allowed right of reply (but we got the last word).
Simon Singh, one of the best science communicators we have, has not been so lucky. He is going to have to defend in court an action brought by the British Chiropractic Association because of innocent opinions expressed in the Guardian.
Chapter 6 is about “The harm done by patent medicines”. It starts thus.
“The trade in secret remedies obviously represents a ridiculous waste of money but some may argue that, since we are a free country and it pleases people to waste their money in this particular way, there is no call for any legislative interference. The trade in quack medicines cannot, however, be regarded as a harmless one. The Poisons Acts fortunately prevent the sale of a large number of dangerous drugs, but there are numerous other ways in which injury can be produced by these remedies.”
The most serious harm, he thought, resulted from self-medication, and he doesn’t mince his words.
“The most serious objection to quack medicines is however that their advertisements encourage self-medication as a substitute for adequate treatment and they probably do more harm in this than in any other manner.
The nature of the problem can best be illustrated by considering a simple example such as diabetes. In this case no actual cure is known to medicine but, on the other hand, if a patient is treated adequately by insulin combined with appropriate diet, he can be maintained in practically normal health, in spite of his disability, for an indefinite period. The expectation of life of the majority of intelligent diabetics, who make no mistakes in their regime, is not much less than that of normal persons. The regime is both irksome and unpleasant, but anyone who persuades diabetics to abandon it, is committing manslaughter as certainly as if he fired a machine gun into a crowded street.
As regards serious chronic disease the influence of secret remedies may be said to range from murderous to merely harmful.
‘Cures’ for consumption, cancer and diabetes may fairly be classed as murderous, since they are likely to cause the death of anyone who is unfortunate enough to believe in their efficacy and thus delay adequate treatment until too late.
The phrase “‘Cures for consumption, cancer and diabetes may fairly be classed as murderous” made Clark himself the victim of suppression of freedom of speech by lawyers. His son, David Clark, wrote of his father in “Alfred Joseph Clark, A Memoir” (C. & J. Clark Ltd 1985 ISBN 0-9510401-0-3)
“Although tolerant of many human foibles, A. J. had always disapproved fiercely of quacks, particularly the charlatans who sold fraudulent medicines. During his visits to London he met Raymond Postgate, then a crusading left wing journalist, who persuaded A.J. to write a pamphlet which was published in an ephemeral series called ‘Fact‘ in March 1938. It was a lively polemical piece. . To A.J.’s surprise and dismay he was sued for libel by a notorious
rogue who peddled a quack cure for for tuberculosis. This man said that A.J.’s remarks (such as “‘Cures’ for consumption, cancer and diabetes may fairly be classed as murderous”) were libellous and would damage his business. A.J. was determined to fight, and he and Trixie decided to put their savings at stake if necessary. The B.M.A. and the Medical Defence Union agreed to support him and they all went to lawyers. He was shocked when they advised him that he would be bound to lose for he had damaged the man’s livelihood! Finally, after much heart searching, he made an apology, saying that he had not meant that particular man’s nostrum”
Talk about déjà vu!
On page 68 there is another very familiar story. It could have been written today.
“The fact that the public is acquiring more knowledge of health matters and is becoming more suspicious of the cruder forms of lies is also helping to weed out the worst types of patent medicine advertisements. For example, in 1751 a bottle of oil was advertised as a cure for scurvy, leprosy and consumption but today such claims would not be effective in promoting the sale of a remedy. The modern advertiser would probably claim that the oil was rich in all the vitamins and the elements essential for life and would confine his claims to a statement that it would alleviate all minor forms of physical or mental ill-health.
The average patent medicine advertised today makes plausible rather than absurd claims and in general the advertisements have changed to conform with a change in the level of the public’s knowledge.
It is somewhat misleading, however, to speak of this as an improvement, since the law has not altered and hence the change only means that the public is being swindled in a somewhat more skilful manner.
The ideal method of obtaining an adequate vitamin supply is to select a diet containing an abundant supply of fresh foods, but unfortunately the populace is accustomed to live very largely on preserved or partially purified food stuffs and such processes usually remove most of the vitamins.”
The first part of the passage above is reminiscent of something that A.J Clark wrote in the BMJ in 1927. Nowadays it is almost unquotable and I was told by a journal editor that it was unacceptable even with asterisks. That seems to me a bit silly. Words had different connotations in 1927.
“The less intelligent revert to the oldest form of belief and seek someone who will make strong magic for them and defeat the evil spirits by some potent charm. This is the feeling to which the quack appeals; he claims to be above the laws of science and to possess some charm for defeating disease of any variety.
The nature of the charm changes with the growth of education. A naked n****r howling to the beat of a tom-tom does not impress a European, and most modern Europeans would be either amused or disgusted by the Black mass that was popular in the seventeenth century. Today some travesty of physical science appears to be the most popular form of incantation.”
A.J. Clark (1927) The historical aspect of quackery, BMJ October 1st 1927
Apart from some of the vocabulary, what better description could one have of the tendency of homeopaths to harp on meaninglessly about quantum theory or the “scienciness” and “referenciness” of
modern books on nutritional therapy?
So has anything changed?
Thus far, the outcome might be thought gloomy. Judging by Clark’s account, remarkably little has changed since 1938, or even since 1914. The libel law in the UK is as bad now as it was then. Recently the United Nations Human Rights Committee said UK laws block matters of public interest and encourage libel tourism (report here, see also here). It is unfit for a free society and it should be changed.
But there are positive sides too. Firstly the advent of scientific bloggers has begun to have some real influence. People are no longer reliant on journalists to interpret (or, often, misinterpret) results for them. They can now get real experts and links to original sources. Just one of these, Ben Goldacre’s badscience.net, and his weekly column in the Guardian has worked wonders in educating the public and improving journalism. Young people can, and do, contribute to the debate because they can blog anonymously if they are frightened that their employer might object.
Perhaps still more important, the law changed this year. Now, at last, it may be possible to prosecute successfully those who make fraudulent health claims. Sad to say, this was not an initiative of the UK government, which remains as devoted as ever to supporting quacks. Remember that, quite shamefully, the only reason given by the Medicines and Health Regulatory Authority (MHRA) gave for allowing false labelling of homeopathic pills was to support the “homeopathic industry”. They suggested (falsely) that the EU required them to take this irresponsible step, which was condemned by just about every scientific organisation. But the new unfair trading regulations did come from the EU. After almost 100 years since the 1914 report, we have at last some decent legislation. Let’s hope it’s enforced.
Postcript
The back cover of the series of ‘Fact‘ books in which A.J. Clark’s article appeared is reproduced below, simply because of the historical portrait of the 1930s that it gives.
Follow-up
This post got a lot of hits from Ben Goldacre’s miniblog which read
- Prof David Colquhoun gets into a time machine and meets himself
A truly classic DC post.
Thanks, Ben.
Today is a good day for anyone who deplores dangerous confidence tricksters. In particular it is a good day for Ben Goldacre, and for the Guardian which defended him at potentially enormous expense.
| Matthias Rath, the Dutch (or is it German) vitamin salesman has dropped his libel action against the Guardian. He is the man who is, without doubt, responsible for many deaths form AIDS in Africa, as a result of peddling vitamin pills as cures. The action was taken after Goldacre said, in the Guardian, that Rath aggressively sells his message to Aids victims in South Africa that Rath vitamin pills are better than medication”. |  |
Here is some of what has appeared already today
Fall of the doctor who said his vitamins would cure Aids – from The Guardian, with a video of the villain.
Goldacre’s Badscience blog article on his victory .
Profile of Zackie Achmat – from The Guardian, Mr Achmat is the founder of the Treatment Action Campaign , instrumental in exposing Rath.
Extract from witness statements from the defence in the trial .
And a lot of publicity from Gimpyblog (“Ben Goldacre and The Guardian triumph over murderous Matthias Rath”), Holfordwatch , Quackometer and jdc325 blogs.
Then more in the Guardian the next day, Chris McGreal investigates the Rath Foundation
Nutritional therapist?
Let’s be clear about what the words mean. Nutritional therapists are not like dietitians, and they are not like nutritionists. Nutritional therapists are solidly in the camp of alternative medicine practitioners, Don’t
take my word for it. They say so themselves.
“For nutritional therapists (who practise Complementary and Alternative Medicine) optimum nutrition encompasses individual prescriptions for diet and lifestyle in order to alleviate or prevent ailments and to promote optimal gene expression through all life stages. Recommendations may include guidance on natural detoxification, procedures to promote colon health, methods to support digestion and absorption, the avoidance of toxins or allergens and the appropriate use of supplementary nutrients, including phytonutrients.”
They love to use imaginary words like “detoxification”, and, much more dangerously, they love to pretend that they can cure diseases by changes in diet. As long as you buy from them a stack of expensive “supplement” pills, of course. That means they are selling medicines, but by pretending they are selling food supplements they manage to evade the law that requires medicines to be safe and effective. That will not be so easy under new legislation though, and we can look forward to a few prosecutions soon.
Guess who runs an “Honours BSc degree” in Nutritional Therapy. No prizes for realising it is the UK’s leading university purveyor of woo.
The University of Westminster
On their web site we learn that the Course Leader is Heather Rosa, and the Deputy Course Leader is Val Harvey. Harvey qualified in the subject at the Institute of Optimum Nutrition, the private college run by none other than the famous pill-peddler, Patrick Holford, about whom so very much has been written (try Holfordwatch, or the masterly chapter in Goldacre’s Bad Science)
We don’t know much about what is taught on the Nutritional Therapy course because the University of Westminster has refused repeated requests to say (but watch this space).. One can only assume that, whatever it is, they are not very proud of it. It seems a little unlikely that they will go as far as Matthias Rath and claim to cure AIDS -we’ll just have to wait and see. Meanwhile we can get an inkling by looking elsewhere.
Course leader, Heather Rosa, pops up for example, on the expert panel of a web site called Supplements Compared.com. “Supplements Compared is designed to help you find the best dietary supplement product for your health needs.” And what sort of advice do you find there? Try the page that compares 10 brands of CoQ10 (that is the stuff I wrote about recently, in “Boots reaches new level of dishonesty with CoQ10 promotion” – their advertising was deemed improper by the ASA ). It isn’t a recommended treatment for anything at all, but you certainly wouldn’t guess that from what is written by the ‘expert panel’. The winners are, according to the ‘expert panel’, Boots’ CoQ10 and Holland and Barrett’s CoQ10. Winners? Perhaps the explanation for that comes elsewhere, under “How are we funded?”. “Manufacturers who are awarded “best product” and “worth a look” are given the opportunity to promote this fact throughout the site for an additional fee.”. Well well.
Deputy Course leader, Val Harvey has her own web site and business (I do hope thar Westminster does not pay these people a full time salary too). What can we glean from there? It has the usual scare tactics “Why
you are at risk?“. Never fear; buy enough vitamin pills and you’ll be saved.
Her home page makes some pretty drastic claims.
“Potential health benefits of your nutritional programme
An appropriate Nutritional Programme can benefit many conditions including:
Allergies
Arthritis
Asthma
Bloating, indigestion
Chronic degenerative diseases
Chronic fatigue, ME
Constipation, diarrhoea
Cystitis
Depression, mood swings
Digestive or bowel problems
Eczema, psoriasis, other skin problems
Food sensitivities
Frequent infections
Hormone imbalanceHypertension or elevated cholesterol
Irritable bowel syndrome
Low energy
Menopausal symptoms
Migraines, headaches
Parasitic and fungal infections
Pre-conceptual issues
Premenstrual syndrome (PMS)
Sinus congestion
Stress
Thrush
Weight problems
and many others ….
These are just some of the wide range of health problems that may be helped by nutritional therapy. Even those who consider themselves well and healthy may be able to enhance their physical and mental health, as well as their performance, including athletic performance, by improving their nutrition.”
There is, in my view, not the slightest bit of good evidence that swallowing vitamin pills can benefit most of these conditions.
But at least the list doesn’t contain AIDS, so is all this really relevant to the case of Matthias Rath?
Yes, I believe it is. The University of Westminster may well not support the views of Matthias Rath (they won’t say), but we have heard no choruses of protests about him from any nutritional therapists, as far as I’m aware. There is no mention of him at all on the web site of the British Association of Nutritional Therapists (BANT), the UK club for these people. BANT, by the way, has a rather curious code of ethics. It allows its members to take undisclosed financial kickbacks for the pills they prescribe to patients. If doctors were caught doing that they’d be struck off the register.
It is the existence of degrees in subjects like “nutritional therapy” that gives the subject a spurious air of respectability which allows seriously dangerous people like Rath to flourish with very little criticism. In an indirect way, the vice-chancellors who allow it to flourish (and Universities UK who do nothing about it) must bear some small part of the responsibility for the deaths of thousands of people from AIDS.
It is about time they did something about it.
Follow-up
ANH. The first reaction from the supplement-peddling industry comes from the Alliance for Natural Health on 16th September. It contains not one word of condemnation for Rath’s murderous activities. It’s hard to believe how low they will sink.
The Prince’s Foundation for Integrated Health remains totally silent about Rath. HRH’s concern for health seems to dry up if things don’t suit his views.
The British Association of Nutritional Therapists shows it’s total irresponsibility after a letter was sent to them to ask about their reaction. Their answer , on jdc325’s weblog was “The association has no opinion to offer on Dr Raths vitamin trials.”.
We have often had cause to criticise Boots Alliance, the biggest retail pharmacist in the UK, because of its deeply unethical approach to junk medicine. Click here to read the shameful litany. The problem of Boots was raised recently also by Edzard Ernst at the Hay Literary Festival. He said
“The population at large trusts Boots more than any other pharmacy, but when you look behind the smokescreen, when it comes to alternative medicines, that trust is not justified.”
Ernst accused Boots of breaching ethical guidelines drawn up by the Royal Pharmaceutical Society of Great Britain, by failing to tell customers that its homeopathic medicines contain no active ingredients and are ineffective in clinical trials.
Another chain, Lloyds Pharmacy, are just as bad. Many smaller pharmacies are no more honest when it comes to selling medicines that are known to be ineffective.
Pharmacists are fond of referring to themselves as “professionals” who are regulated by a professional body, the Royal Pharmaceutical Society of Great Britain (RPSGB). It’s natural to ask where their regulatory body stands on the question of junk medicine. So I asked them, and this is what I found.
| 17 April, 2008
I am writing an article about the role of pharmacists in giving advice about (a) alternative medicines and (b) nutritional supplements. I can find no clear statements about these topics on the RPSGB web site. Please can you give me a statement on the position of the Royal Pharmaceutical Society on these two topics. In particular, have you offered guidance to pharmacists about how to deal with the conflict of interest that arises when they can make money by selling something that they know to have no good evidence for efficacy? This question has had some publicity recently in connection with Boots’ promotion of CCoQ10 to give you “energy”, and only yesterday when the bad effects of some nutritional supplements were in the news. |
Here are some extracts from the first reply that I got from the RPSGB’s Legal and Ethical Advisory Service (emphasis is mine).
| 28 April 2008
Pharmacists must comply with the Code of Ethics and its supporting documents. Principle 5 of the Code of Ethics requires pharmacists to develop their professional knowledge and competence whilst Principle 6 requires pharmacists to be honest and trustworthy. The Code states: 5. DEVELOP YOUR PROFESSIONAL KNOWLEDGE AND COMPETENCE At all stages of your professional working life you must ensure that your knowledge, skills and performance are of a high quality, up to date and relevant to your field of practice. You must: 5.1 Maintain and improve the quality of your work by keeping your knowledge and skills up to date, evidence-based and relevant to your role and responsibilities. 5.2 Apply your knowledge and skills appropriately to your professional responsibilities. 5.3 Recognise the limits of your professional competence; practise only in those areas in which you are competent to do so and refer to others where necessary. 5.4 Undertake and maintain up-to-date evidence of continuing professional development relevant to your field of practice. 6. BE HONEST AND TRUSTWORTHY Patients, colleagues and the public at large place their trust in you as a pharmacy professional. You must behave in a way that justifies this trust and maintains the reputation of your profession. You must: 6.2 Ensure you do not abuse your professional position or exploit the vulnerability or lack of knowledge of others. 6.3 Avoid conflicts of interest and declare any personal or professional interests to those who may be affected. Do not ask for or accept gifts, inducements, hospitality or referrals that may affect, or be perceived to affect, your professional judgement. 6.4 Be accurate and impartial when teaching others and when providing or publishing information to ensure that you do not mislead others or make claims that cannot be justified. |
And, on over-the counter prescribing
| In addition the “Professional Standards and Guidance for the Sale and Supply of Medicines” document which supports the Code of Ethics states:
“2. SUPPLY OF OVER THE COUNTER (OTC) MEDICINES STANDARDS When purchasing medicines from pharmacies patients expect to be provided with high quality, relevant information in a manner they can easily understand. You must ensure that: 2.1 procedures for sales of OTC medicines enable intervention and professional advice to be given whenever this can assist the safe and effective use of medicines. Pharmacy medicines must not be accessible to the public by self-selection. |
Evidence-based? Accurate and impartial? High quality information? Effective use?
These words don’t seem to accord with Boots’ mendacious advertisements for CoQ10 (which were condemned by the ASA).
Neither does it accord with the appalling advice that I got from a Boots pharmacist about Vitamin B for vitality.
Or their bad advice on childhood diarrhoea.
Or the unspeakable nonsense of the Boots (mis)-education web site.
Then we get to the nub. This is what I was told by the RPSGB about alternative medicine (the emphasis is mine).
| 8. COMPLEMENTARY THERAPIES AND MEDICINES
STANDARDS You must ensure that you are competent in any area in which you offer advice on treatment or medicines. If you sell or supply homoeopathic or herbal medicines, or other complementary therapies, you must: 8.1 assist patients in making informed decisions by providing them with necessary and relevant information. 8.2 ensure any stock is obtained from a reputable source. 8.3 recommend a remedy only where you can be satisfied of its safety and quality, taking into account the Medicines and Healthcare products Regulatory Agency registration schemes for homoeopathic and herbal remedies.” Therefore pharmacists are required to keep their knowledge and skills up to date and provide accurate and impartial information to ensure that you do not mislead others or make claims that cannot be justified. |
It does seem very odd that “accurate and impartial information” about homeopathic pills does not include mentioning that they contain no trace of the ingredient on the label. and have been shown in clinical trials to be ineffective. These rather important bits of information are missing from both advertisements and from (in my experience) the advice given by pharmacists in the shop.
If you look carefully, though, the wording is a bit sneaky. Referring to over-the-counter medicines, the code refers to “safe and effective use of medicines”, but when it comes to alternative medicines, all mention of ‘effectiveness’ has mysteriously vanished.
So I wrote again to get clarification.
| 29 April, 2008
Thanks for that information. I’d appreciate clarification of two matters in what you sent. (1) Apropros of complementary and alternative medicine, the code says 8.3 recommend a remedy only where you can be satisfied of its safety and quality I notice that this paragraph mentions safety and quality but does not mention efficacy. Does this mean that it is considered ethical to recommend a medicine when there is no evidence of its efficacy? Apparently it does. This gets to the heart of my question and I’d appreciate a clear answer. |
This enquiry was followed by a long silence. Despite several reminders by email and by telephone nothing happened until eventually got a phone call over a month later (May 3) from David Pruce, Director of Practice & Quality Improvement, Royal Pharmaceutical Society of Great Britain. The question may be simple, but the RPSGB evidently it hard, or more likely embarrassing, to answer.
When I asked Pruce why para 8.3 does not mention effectiveness, his reply, after some circumlocution, was as follows.
Pruce: “You must assist patients in making informed decisions by providing necessary and relevant information . . . we would apply this to any medicine, the pharmacist needs to help the patient assess the risks and benefits.”
DC: “and would that include saying it doesn’t work better than placebo?”
Pruce “if there is good evidence to show that it may, but it depends on what the evidence is, what the level of evidence is, and the pharmacist’s assessment of the evidence”
DC “What’s your assessment of the evidence?”
Pruce, “I don’t think my personal assessment is relevant. I wouldn’t want to be drawn on my personal assessment”. “If a pharmacist is selling homeopathic medicines they have to assist the patient in making informed decisions”
“I don’t think we specifically talk about the efficacy of any other medicine” [DC: not true, see para 2.1, above]
“We would expect pharmacists to be making sure that what they are providing to a patient is safe and efficacious”
DC “So why doesn’t it mention efficacious in para 8.3”
Pruce “What we are trying to do with the Code of Ethics is not go down to the nth degree of detail ” . . . “there are large areas of medicine where there is an absence of data”
DC “Yes, actually homeopathy isn’t one of them. It used to be.”
Pruce. “uh, that’s again a debatable point”
DC I don’t think it’s debatable at all, if you’ve read the literature
Pruce. “well many people would debate that point” “This [homeopathy] is a controversial area where opinions are divided on it”
DC “Not informed opinions”
Pruce “Well . . . there are also a large number of people that do believe in it. We haven’t come out with a categorical statement either way.”
I came away from this deeply unsatisfactory conversation with a strong impression that the RPSGB’s Director of Practice & Quality Improvement was either not familiar with the evidence, or had been told not to say anything about it, in the absence of any official statement about alternative medicine.
I do hope that the RPSGB does not really believe that “there are also a large number of people that do believe in it” constitutes any sort of evidence.
It is high time that the RPSGB followed its own code of ethics and required, as it does for over-the-counter sales, that accurate advice should be given about “the safe and effective use of medicines”.
“The scientist on the High Street”
The RPS publishes a series of factsheets for their “Scientist in the High Street” campaign. One of these “factsheets” concerns homeopathy, [download pdf from the RPSGB]. Perhaps we can get an answer there?
Well not much. For the most part the “factsheet” just mouths the vacuous gobbledygook of homeopaths. It does recover a bit towards the end, when it says
“The methodologically “best” trials showed no effect greater than that of placebo”.
But there is no hint that this means pharmacists should not be selling homeopathic pills to sick people..
That is perhaps not surprising, because the Science Committee of the RPSGB copped out of their responsibility by getting the factsheet written by a Glasgow veterinary homeopath, Steven Kayne. You can judge his critical attitude by a paper (Isbell & Kayne, 1997) which asks whether the idea that shaking a solution increases its potency. The paper is a masterpiece of prevarication, it quotes only homeopaths and fails to come to the obvious conclusion. And it is the same Steven Kayne who wrote in Health and Homeopathy (2001)
“Homeopathy is not very good for treating bacterial infections directly, apart from cystitis that often responds to a number of medicines, including Berberis or Cantharis”.
So there is a bacterial infection that can be cured by pills that contain no medicine? Is this dangerous nonsense what the RPSGB really believes?
More unreliable advice
While waiting for the train to Cardiff on April 16th (to give a seminar at the Welsh School of Pharmacy), I amused myself by dropping into the Boots store on Paddington station.
| DC I’ve seen your advertisements for CoQ10. Can you tell me more? Will they really make me more energetic?
Boots: Yes they will, but you may have to take them for several weeks. DC. Several weeks? Boots: yes the effect develops only slowly Peers at the label and reads it out to me DC I see. Can you tell me whether there have been any trials that show it works? Boots. I don’t know. I’d have to ask. But there must be or they wouldn’t be allowed to sell it. DC. Actually there are no trials, you know Boots. Really? I didn’t think that was allowed. But people have told me that they feel better after taking it. DC You are a pharmacist? Boots. Yes |
Sadly, this abysmal performance is only too typical in my experience, Try it yourself.
The malaria question
After it was revealed that pharmacists were recommending, or tolerating recommendations, of homeopathic treatment of malaria, the RPSGB did, at last. speak out. It was this episode that caused Quackometer to write his now famous piece on ‘The gentle art of homeopathic killing‘ (it shot to fame when the Society of Homeopaths tried to take legal action to ban it) Recommending pills that contain no medicine for the treatment or prevention or treatment of malaria is dangerous. If it is not criminal it ought to be [watch the Neals Yard video]. .
The RPSGB says it is investigating the role of pharmacists in the Newsnight sting (see the follow-up here). That was in July 2006, but they are stlll unwilling to say if any action will be taken. Anyone want to bet that it will be swept under the carpet?
The statement issued by the RPSGB, 5 months after the malaria sting is just about the only example that I can find of them speaking out against dangerous and fraudulent homeopathic practices. Even in this case, it is pretty mild and restricted narrowly to malaria prevention.
The RPSGB and the Quacktioner Royal
The RPSGB submitted a response to the ‘consultation’ held by the Prince’s Foundation for Integrated Health, about their Complementary Healthcare; a guide for patients.
| Response by the Royal Pharmaceutical Society of Great Britain Dr John Clements, Science Secretary “We believe that more emphasis should be given to the need for members of the public who are purchasing products (as opposed to services) to ask for advice about the product. Pharmacists are trained as experts on medicines and the public, when making purchases in pharmacies, would expect to seek advice from pharmacists” |
So plenty of puffery for the role of pharmacists. But there is not a word of criticism about the many barmy treatments that are included in the “Guide for Patients”. Not just homeopathy and herbalism, but also Craniosacral therapy, Laying on of Hands, chiropractic, Reiki, Shiatsu –every form of barminess under the sun drew no comment from the RPS.
I can’t see how a response like this is consistent with the RPS’s own code of ethics.
A recent president of the RPSGB was a homeopath
| Christine Glover provides perhaps the most dramatic reason of all for thinking thst, despite all the fine words, the RPSGB cares little for evidence and truth The NHS Blogdoctor published “Letter from an angry pharmacist”. |  |
Mrs Glover was president of the RPSGB from 1999 to 2001, vice-president in 1997-98, and a member of the RPSGB Council until May 2005. She is not just a member, but a Fellow. (Oddly, her own web site says President from 1998 – 2001.)
So it is relevant to ask how the RPSGB’s own ex-president obeys their code of ethics. Here are some examples on how Ms Glover helps to assist the safe and effective use of medicines. . Much of her own web site seems to have vanished (I wonder why) so I’ll have to quote the “Letter from an angry pharmacist”., as revealed by NHS Blogdoctor,
“What has Christine got to offer?
- “We offer a wide range of Homeopathic remedies (over 3000 different remedies and potencies) as well as Bach flower remedies, Vitamins, Supplements, some herbal products and Essential Oils.”
- Jetlag Tablets highly recommended in ‘Wanderlust’ travel magazine. Suitable for all ages.
- Wind Remedy useful for wind particularly in babies. In can be supplied in powder form for very small babies. Granules or as liquid potency.
- Udder Care 100ml £80.00 One capful in sprayer filled with water. Two jets to be squirted on inner vulva twice daily for up to 4 days until clots reduced. Discard remainder. Same dose for high cell-counting cows detected.
Udder Care? Oh! I forgot to say, “Glover’s Integrated Healthcare” does cows as well as people. Dr Crippen would not suggest to a woman with sore breasts that she sprayed something on her inner vulva. But women are women and cows are cows and Dr Crippen is not an expert on bovine anatomy and physiology. But, were he a farmer, he would need some persuasion to spend £80.00 on 100 mls of a liquid to squirt on a cow’s vulva. Sorry, inner vulva.”
Nothing shows more clearly that the RPSGB will tolerate almost any quackery than the fact that they think Glover is an appropriate person to be president. Every item on the quotation above seems to me to be in flagrant breach of the RPSGB’s Code of Ethics. Just like the Society of Homeopaths, the code seems to be there merely for show, at least in the case of advice about junk medicine..
A greater role for pharmacists?
This problem has become more important now that the government proposes to give pharmacists a greater role in prescribing. Needless to say the RPSGB is gloating about their proposed new role. Other people are much less sure it is anything but a money–saving gimmick and crypto-privatisation.
I have known pharmacists who have a detailed knowledge of the actions of drugs, and I have met many more who haven’t. The main objection, though, is that pharmacists have a direct financial interest in their prescribing. Conflicts of interest are already rife in medicine, and we can’t afford them.
Conclusion
The Royal Pharmaceutical Society is desperately evasive about a matter that is central to their very existence, giving good advice to patients about which medicines work and which don’t. Pharmacists should be in the front line in education of the public, about medicines, the ‘scientist on the High Street’. Some of them are, but their professional organisation is letting them down badly.
Until such time as the RPSGB decides to take notice of evidence, and clears up some of the things described here, it is hard to see how they can earn the respect of pharmacists, or of anyone else.
Follow-up
Stavros Isaiadis’ blog, Burning Mind, has done a good piece on “More on Quack Medicine in High Street Shops“.
The Chemist and Druggist reports that the RPSGB is worried about the marketing of placebo pills (‘obecalp’ -geddit?). It does seem very odd that the RPSGB should condemn honest placebos, but be so very tolerant about dishonest placebos. You couldn’t make it up.
A complaint to the RPSGB is rejected
Just to see what happened, I made a complaint to thr RPSGB about branches of their own Code of Ethics at Boots in Hexham and in Evesham. Both of them supported Homeopathy Awareness Week These events had been publicised in those particularly unpleasent local ‘newspapers’ that carry paid advertising disguised as editorial material. In this case it was the Evesham Journal and the Hexham Courant.
Guess what? The RPSGB replied thus
“Your complaint has been reviewed bt Mrs Jill Williams and Mr David Slater who are both Regional Lead Inspectors. Having carried out a review they have concluded that support of homeopathic awareness week does not constitute a breach of the Society’s Code of Ethics or Professional Standards.”
In case you have forgotten, the Professional Standards say
2.1 procedures for sales of OTC medicines enable intervention and professional advice to be given whenever this can assist the safe and effective use of medicines.
The RPSGB has some very quaint ideas on how to interpret their own code of ethics
Boots the Chemists have proved themselves dishonest before, over their promotion of homeopathy and of B Vitamins “for vitality”
In a press release dated 12 March 2008, they have hit a new low in ethical standards
| Boots help boost the nation’s energy levels in just one week “Health and beauty expert Boots has launched an exclusive energising vitamin supplement that helps boost depleted energy levels and maintain vitality. It is the first time that this exclusive form of CoQ10 has been made available on the high street.” ” . . .supplementation can help to supply higher levels of CoQ10 than are available in the diet. Boots Energy Super Strength CoQ10 containing natural Kaneka CoQ10 is a way of boosting energy levels that can help people who lack energy to see results in a week” |
You decide.
Last year there was an equally misleading press release about CoQ10 from Solgar/Boots Herbal. That one was headed “Need More Energy – Solgar’s Nutri Nano™ Uses Nanotechnology to Deliver Unprecedented Bioavailability of CoQ10”. Not only is the word ‘energy’ misused but notice that the trendy term ‘nanotechnology’ is worked in for extra sciencey effect. It turns out that all this means is that the preparation contains micelles. So nothing new there either. Micelles have been known for almost 100 years.
In contrast, the Boots online store is noticeably more restrained. Could that be because the Advertising Standards People can’t touch press releases, just as they can’t control what Boots Expert Team tell you face to face in the shop?
Boots PR contact is given as: Carrie Eames, PR Manager, Boots The Chemists, D90W WG14, Thane Road, Nottingham NG90 1BS. I’m not sure how Ms Eames sleeps at night. Perhaps you should write to her and let her know what you think.
You might point out to her Boots (anti) Social Corporate (ir)Responsibility Page. It says
| “So it’s part of our heritage to treat our customers fairly and act with integrity in everything we do, rather than seizing on the quickest and easiest way to turn a profit.” |
CoQ10 and “energy”
Coenzyme Q10 (also known as ubiquinone) is a relatively small molecule. It cooperates with cytochrome enzymes (big proteins) to synthesize a molecule called ATP. This is a chemical form of energy that can be used to do work, such as making a muscle fibre contract.
The word “energy ” here is used in the sense that a physicist would use it. It is measured in joules or in calories. The meaning of the word ‘energy‘ is described nicely in the Wikipedia entry. For example, when an electric current passes through a resistor (like a kettle) the electrical energy is converted to heat energy, and the energy used is potential difference (volts) X current (amps) X time. In other words energy is power (in watts) times time. So another unit for energy is kilowatt-hours (one kilowatt-hour is about 3.6 megajoules).
Energy in this sense has nothing whatsoever to do with the everyday use of ‘energy’ to indicate your vitality, or how lively you feel.
Furthermore there is not the slightest empirical reason to think that CoQ10 makes you feel more lively. None. The press release cites a sciencey-sounding reference (Ernster L, Dallner G. Biochemical, physiological and medical aspects of ubiquinone function. Biochim Biophys Acta. 1995 May 24;1271(1):195-204.). But this paper is just a review of the biochemistry, nothing whatsoever to do with feeling good.
CoQ10 and the supplement business
There is nothing new in this big push by Boots. CoQ10 has been a staple of supplement business for a long time now. All sorts of medical claims have been made for it. Everything from migraine, to Parkinson’s disease to cancer has been raised as possible benefits of the magic drug, oops, I mean ‘supplement’. This is quite improper of course, since it is being sold as a food not as a medicine, but it is standard practice among supplement hucksters, and so far they have been allowed to get away with it.
What’s interesting though is that until Boots PR machine swung into action, one thing that hadn’t been claimed much is that it made you feel more lively. That’s one they just invented.
CoQ10 and the press
It’s standard technique to get free advertising by hoping that journalists will dash off an article on the basis of a press release, with the hope that they will be in too much hurry to check the spin. Too often it works.
The Daily Mail has big coverage of the press release, under the title “Can a 60p pill from the chemist really add years to your life?“. This was written by Anna Hodgekiss and it’s not bad. It starts with a nice note of scepticism
“Forget vitamins C, E or even B12. The real wonder supplement is Coenzyme Q10 or CoQ10. That’s what Boots would have you believe, anyway. ”
“So should we all be taking this supplement?Not according to David Colquhoun, professor of pharmacology at University College London, who says Boots’ claims are “deliberately misleading customers”.
“Yes, CoQ10 helps the body convert glucose into energy, but it’s not the psychological get-up-and-go energy you feel day to day.
“The type of energy it does produce powers our muscles and cells – physical energy. They have confused the two here to promote a product that I’m not convinced would make any difference to how you actually feel at all.”
The article goes on
Among the other sceptics is Scott Marsden, a senior dietician at The London Clinic.
“There haven’t been enough trials to warrant us all taking CoQ10,” he says.
“It sounds boring, but if you are healthy and eating a balanced diet, you will get all the nutrients you need and shouldn’t have to take supplements.
“Not only could you be spending money unnecessarily, you could also be putting your health at risk. Buy some wholesome food instead.” “
Dr Clare Gerada, vice chairman of the Royal College of General Practitioners, is more forthright.
“While there is some evidence to suggest CoQ10 supplements may help patients with heart failure or severe respiratory disorders, more work is needed,” she says.
“This is just another example of normal health being medicalised, and it’s an issue that worries me.
“The human body is an amazing machine, and we have never been in better health. The fact that more people are living well into their 80s and 90s is proof.
“People need to stop looking for a wonder pill in their quest to live for ever.”
But guess who comes out fighting for Boots? None other than my old friend Dr Ann Walker. Little wonder then that my Nutriprofile result recommended a co Q10 supplement, because she is involved in that too.
Ann Walker’s colleague on the Nutriprofile project, Dr Sarah Brewer comments on CoQ10 on the Healthspan site, thus.
“As CoQ10 is vital for energy production in muscle cells, lack of CoQ10 is linked with lack of energy, physical fatigues, muscle aches and pains . . .”
It seems that she also can’t distinguish between energy in joules and energy as vitality,
Female First and Marie Claire also carry a story “Boots Sell ‘Life Extending’ Pill”
“A new pill that claims to add years to our lives is due to hit shelves in Boots stores this week but scientists say the drug is misleading.”
“Despite these claims Professor David Colquhoun told Marie Clare that he believes the drug is ‘deliberately misleading customers’: “Yes, CoQ10 helps the body convert glucose into energy, but it’s not the psychological get-up-and-go energy you feel day to day,” he said.”
(Funny, I never consciously spoke to Marie Claire but the quotation is OK.)
The Times, in contrast, carries an appalling column by their Dr Thomas Stuttaford, “A natural solution to tiredness“. There isn’t even a question mark in the title, and the content is totally uncritical. Private Eye has nicknamed the author ‘Dr Thomas Utterfraud’. How very cruel.
See also, excellent articles on CoQ10 by Ben Goldacre in the Guardian, and at badscience.net, and at Holfordwatch and Dr Aust’s Spleen
Aha Boots have repeated their mendacious claims in newspaper advertisements
This appeared in the Guardian on 18 March, and I’m told it was in the Mail too.
The small print says
“The new Boots Energy supplement contains Kaneka Q10 to help boost your energy levels throughout the day”
Here is what I just sent to the Advertising Standard Authority, or email new.complaints@asa.org.uk . Why not have a go yourself?
| “The words “boost your energy levels” and “still lacking energy” constitute a (presumably deliberate) confusion beteen ‘energy’ measured in joules and the everyday use of the word ‘energy’ to mean vitality. The former usage would be justified in viewof the role of Coenzyme Q10 in ATP production. There is neither theoretical justification nor any empirical evidence that CoQ10 helps your vitality or ‘energy’ in the latter sense.” |
A full size graphic to attach to your complaint can be downloaded here.
