The Word-based submission to the CAM discussion document which was sent out in our (NZCSICOP) name is now available for you to read at http://skeptics.org.nz/cam
My apologies for not being able to circulate this prior to sub-mission, but we only just finished the proof-read five minutes before submissions closed, with the much appreciated help of researchers world-wide (Stephen Barrett of Quackwatch has even sent his own submission in with a line-by-line critique of the proposals!).
I’ve tried to be as hardline as possible in those areas which are not negotiable. And I’ve tried to provide some grounds for cooperative, rational development in those areas where CAM may prove its utility, rather than rejecting it out of hand.
I hope that for the most part I have the mix about right, and that you consider it a reasonably representative view of our organisation.
Exhaustedly,
Vicki Hyde
The list below, taken from the submission’s introduction, covers the general recommendations it makes; each point is covered in detail in the remainder of the document.
Problems of Basic Focus
- The basic question is whether CAM can help, not how;
- Ministerial Advisory Committee on Complementary and Alternative Health (MACCAH) definition of CAM is too broad;
- Better definitional analysis of CAM is required;
- Categorisation and prioritisation necessary for evaluation, research and application;
- Broader representation on MACCAH needs to be addressed for credibility of policy recommendations.
Regulation
- Need to recognise public demand for regulation;
- Does training imply competency? Disclosure and liability responsibilities must be enforced;
- Regulations required against disproven and unsafe practices and products;
- Need to ensure that apparent safeguards arising from regulation are not misleading to consumers;
- Costs should be borne predominantly by CAM industry with independent monitoring;
- Regulations need to recognise range of risks;
- Lower standards for CAM harm its own credibility and should not be accepted;
- Self-regulation is inadequate and inappropriate;
- Issues of public accountability and enforcement have to be addressed;
- Failure to regulate products leads to public harm;
- Clear, consistent product regulation is vital and achievable;
- Recommended response to ensure safety and efficacy.
Consumer Information Needs
- Informed choice should be a primary requirement and must include totality of available evidence;
- MOH database needs to be balanced, neutral to achieve credibility;
- Vested sources can be inaccurate, misleading and potentially dangerous;
- Publication bias has to be recognised and assessment provided.
Research, Evidence and Efficacy
- Identify practices, products outside the scope of research;
- CAM is big business and should contribute to research;
- Credible research programmes can provide useful information;
- Public research programmes need to prioritise promising approaches over questionable ones;
- Public funding should be based on results and capped at appropriate levels;
- All research programmes need to be robust and defensible;
- Binding negotiated research protocols required;
- Negative results need to be acknowledged, accepted and publicised;
- Anecdotal evidence should be treated as an indicator for research, not a research result.
Integration
- First, do no harm; second, do some good;
- Education and training required: acknowledged where limited or conflicting;
- Evidence of safety and efficacy vital prior to integration;
- Integration efforts require monitoring and evaluation as current examples are inadequate;
- Ethical standards necessary regarding declaration of commercial interests;
- Cost-benefit analysis required prior to integration.
