Submission relating to proposals by the Pharmacy Council to alter Clause 6.9 of the code of Ethics

I am Edward Linney a consumer with an active interest in evidence based medicine.

I do not support the intent of clause 6.9b to avoid a requirement of credible evidence of efficacy for complementary therapy or other healthcare products.

Extract from consultation document

Proposed supplementary wording – two distinct parts – clause 6.9

6.9a     “Only supply or promote any medicine or herbal remedy where there is no reason to doubt its quality or safety and when there is credible evidence of efficacy.”


6.9b     “Only supply any complementary therapy or other healthcare product where there is no reason to doubt its quality or safety and when sufficient information about the product can be provided in order for thepurchaser to make an informed choice with regard to the risks and benefits of all the available treatment options.”


The addition of 6.9b explicitly avoids any requirement for there to be credible evidence of efficacy. It moves the roles of evaluation of scientific evidence from the scientists to the consumer. This is bizarre, we all understand that the patient purchasing the homeopathic remedy for example is a believer and is most unlikely to be able to make an informed decision in the complex task of selecting the best products to treat themselves with.

Pharmacies are businesses BUT they are run by scientifically qualified people and they trade on this image. They are the only place where the public can purchase prescribed pharmaceuticals. Pharmacists enjoy a very privileged position in that regard. In my view the public expects you to sell and promote products which are shown in appropriate testing to perform better than a placebo, in short evidence based products.

The National Health and Medical Research Council of Australia ( The Government if you will) published an unqualified opinion in March 2015 after wide public consultation and a meta analysis of many trials that homeopathy is no more effective than placebo in treating humans. It comes as no surprise to me that when the credibility of these products which are actively promoted and sold in all my local pharmacies is vanishing that the Council proposed to avoid the requirement for efficacy in the sale of these to the public by pharmacies.

I believe there is a connection between the growing awareness that homeopathic remedies are placebos and the intention to explicitly avoid efficacy in the code of ethics in relation to their sale in pharmacies. It is a business protection step taken now to ensure that members of the public cannot take pharmacies to task for breaches of their code of ethics.

I submit it is totally unethical for the Council to put in place a provision whereby a scientifically trained seller uses that credibility to then sell known placebos as if they have efficacy. It is a betrayal of the science that trained them and a cynical exploitation of their status as health professionals. I wonder if pharmacists will have a warning label on these products which states they have NO active ingredients and they are no more effective than placebos. Perhaps the Council, if it wishes to see pharmacists selling these products should insist on a step like this, that would be the truth and assist the informed choice you are advocating. It was not so long ago that the pharmacies used to say “the health professional you see most often”, sadly you cannot make this claim today given current practice in selling known placebos.

It is telling that the consultation document suggests not promoting or recommending products which lack efficacy but is unwilling to take the ethical step of including efficacy explicitly in the code. It is simply duplicitous and puts commercial gain ahead of evidence based operations in patient and public outcomes.

The Council should retain the requirement at all times when selling products that claim to assist medical situations that there MUST be credible evidence of efficacy. Not to do so is in breach of the duty of Council to promote good practice and protect the public by being complicit in the public opting for remedies which are placebos and thereby not using genuinely efficacious products that have been proven by proper trials. The patient outcomes are likely worsened if a placebo is used in place of the best treatment.

Pharmacies seek to be taken seriously and want to expand on their offering in the evidence based market by adding things like Wharferin testing for example. They cannot have it both ways they are either just a peddler of anything the public wants or are serious health professionals. Your decisions in this matter will answer that question.

Edward Linney

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