The Editorial Executive Committee welcomes letters, which should be less than 250 words. Before a decision to publish is made, letters which refer to a published article may be sent to the author for a response. Any letter may be sent to an expert for comment. When letters are published, they are usually accompanied in the same issue by their responses or comments. The Committee screens out discourteous, inaccurate or libellous statements. The letters are sub-edited before publication. Authors are required to declare any conflicts of interest. The Committee's decision on publication is final.


Letter to the Editor

Editor, – The comment in comment in Australian Prescriber (2007;30:91) (2007;30:91) draws unhelpful and misleading parallels between complementary medicines today and 'dangerous and useless medicines' available 100 years ago.

The author is right to point to the establishment of the Therapeutic Goods Administration (TGA) as an important landmark for the regulation of pharmaceuticals and complementary medicines. The Complementary Healthcare Council (CHC) fully supports a regulatory process that safeguards consumer interests. However, to suggest that complementary medicines as therapeutic goods are somehow compromised by false or misleading advertising or that barriers exist to understanding them because sponsors hide behind 'commercial-in-confidence' is inaccurate.

All advertisements for therapeutic goods are subject to the Therapeutic Goods, Trade Practices and other relevant laws. The Therapeutic Goods Advertising Code, which applies to advertisements directed to consumers and where sanctions apply for breaches, requires material to be truthful, balanced, not contain misleading or exaggerated claims, and all descriptions, claims and comparisons must be able to be substantiated.

With regard to 'commercial-in-confidence', it is hard to see how concerns regarding transparency would not equally apply to pharmaceutical companies. Companies responsible for marketing products are obliged to make available all evidence regarding claims in relation to their products, should they be asked to do so by the TGA.

What does concern the CHC, is the outdated attitudes demonstrated towards complementary medicines, despite repeated and compelling evidence demonstrating their health benefits. Let's imagine for one moment the implication for pregnant women globally, if folate supplementation in preventing neural tube defects had not become accepted mainstream practice.

Tony Lewis
Executive Director
Complementary Healthcare Council


Author's comments

Dr JS Dowden, the author of the comment, responds:

There is Level 1 evidence to support the use of folate supplements by women planning pregnancy. It is doubtful that such strong evidence exists for many complementary products. Given the plethora of complementary medicines it is unlikely that the TGA has the resources to assess the evidence for many of these products. Evidence of a product's safety and efficacy should not be 'commercial-in-confidence' irrespective of whether it is a prescription or a non-prescription drug.

Despite the somewhat confusing regulatory system, there are plenty of complaints about the advertising of complementary medicines.1 The usual sanction for an unacceptable advertisement seems to be a request for the advertisement to be withdrawn, but it is unclear how effectively this is enforced.2

Octavius Beale was concerned about the outrageous claims being made by medicines manufacturers in the early 20th century.3 The number of justified complaints in 2007 suggests that there is still a problem.1


Tony Lewis

Executive Director, Complementary Healthcare Council, Canberra

John S Dowden

Editor, Australian Prescriber