Response to the Science and Technology Committee (S&TC)
on the selection of homeopathy for a ‘second evidence check’
Dr Lionel R Milgrom BSc, MSc, PhD, CChem, FRSC, LCH, MARH, MRHom(Homeopath, scientist, writer)

1. Introduction
1.1. The main purpose of this response is not so much to provide an exhaustive
account of the evidence for homeopathy – this will be provided by others – but toquestion what in calling for a ‘second evidence check’, the S&TC means by‘evidence’, and evidence for homeopathy compared to what?
1.2. As Prof Harald Walach (University of Northampton) has pointed out,1 theproblem here revolves around the widely-held assertion, currently circulated by‘sceptics’ (more properly, ‘detractors’: the term ‘sceptic’ should be reserved for those
who have yet to make up their minds) that homeopathy/CAM’s (CAM =complementary and alternative medicine) are not evidence-based, while conventional
medicine by and large is. Prof Walach,1 myself,2, 3 and others,4 have effectively
deconstructed this assertion.
1.3. Further, it is my intention to question the term ‘evidence-based’ and that applying
it to conventional medicine is also difficult. In so doing, I hope to level the ‘evidencebased’ playing field that has been tilted against homeopathy.
1.4. My chief concerns, however, relate to the motivation and objectivity of the S&TC,
given the current campaign that is being waged against homeopathy and other CAM
therapies in the UK by various high profile detractors in the media,2, 3, and certain
organisations.5
1.5. Their explicit intention is to pressurise the NHS and PCTs into terminating theircommitment to fund and provide homeopathy/CAM services.
1.6. This is being perpetrated regardless of the wishes of a large segment of the UK
population who by choice avail themselves of these services, and that a minusculeamount of the NHS budget is currently spent on homeopathy.
1.7. Thus, though perhaps not considered part of its remit, the meaning of the term
‘evidence-based’ is something the S&TC might usefully wish to consider.

2. Evidence-based medicine (EBM)?
2.1. As first formulated, EBM was ‘‘an approach to health care that promotes thecollection, interpretation, and integration of . . . patient-reported, clinician-observed,
and research-derived evidence. The best available evidence, moderated by patient
circumstances and preferences, is applied to improve the quality of clinicaljudgments.’’6-1-

2.2. Thus, the double-blind randomised placebo-controlled trial (DBRCT) was meantoriginally as part of an evidence ‘‘package’’ derived from multiple sources. David
Sackett, one of EBM’s founders, emphasized this in 1992: ‘‘Evidence-based
medicine is not restricted to randomised trials and meta-analyses. It involves tracking
down the best external evidence with which to answer our clinical questions.…If norandomised trial has been carried out for our patient’s predicament, we follow the trail
to the next best external evidence and work from there.’’7
2.3. EBM as currently practiced, now concentrates solely on the ‘‘gold-standard’’
double-blind randomized-controlled trial (DBRCT) and meta-analyses as the only
acceptable scientific evidence for a therapy or procedure.8
2.4. Supposedly, this enables purely objective clinical decisions to be taken: otherforms of evidence Sackett referred to as essential parts of the decision-making
process, have been effectively downgraded or ignored. EBM’s original intentions
therefore, have been subsumed by over-emphasis on medicine’s science to the
exclusion of its art.9, 10
2.5. Complex procedures (where it is virtually impossible to separate the therapy
from the context in which it is delivered e.g., CBT, homeopathy, etc) do not readilylend themselves to the DBRCT - itself, implicitly flawed11-14 - and are seemingly left
out in the cold.
2.6. This much narrower interpretation of EBM has elicited trenchant responses,
even from within conventional medicine,15-17 but in particular for its intolerance oftherapeutic pluralism.4
2.7. The change in EBM’s emphasis equates with rapid increases in our biochemical
understanding of life, health, and disease, combined with globalization of thepharmaceutical industry’s commercial and political reach. From this has arisen adesire to place medicine on a similar intellectual footing as other sciences.
2.8. Its concomitant is a resurgence of logical positivism * as an accessible (mediafriendly) interpretation of science, and ultimately to justification of the globalised
pharmaceutical industry’s attempts to monopolize the health care market.
2.9. Though out-dated18-28 within the physical sciences (especially quantum physics),
logical positivism goes unchallenged, especially in public arenas (e.g., the media andin political debates about science), and still holds sway in biomedicine.
2.10. Logical positivism effectively dominates the discourse of EBM, resulting not
only in a downgrading and/or ignoring of other valid forms of evidence; it now means
the medical research community potentially has saddled funding agencies andtaxpayers with a huge and expensive problem: that of subjecting all medical
procedures and therapies to the DBRCT, so they can be judged fit for clinical use.
*

Logical positivism is a school of philosophy that combines empiricism (the idea that observational evidence is
indispensable for knowledge of the world), with a version of rationalism incorporating mathematical and logicolinguistic constructs and deductions in epistemology. It was the dominant philosophy of science between theFirst World War and the Cold War, and has been criticised by among others, Popper, Ayer, Quine, Kuhn, andPutnam.

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2.11. This will not be easy because ‘‘Of around 2500 treatments covered, 13% arerated as beneficial, 23% likely to be beneficial, 8% as trade off between benefits andharms, 6% unlikely to be beneficial, 4% likely to be ineffective or harmful, and 46%,
the largest proportion, as of unknown effectiveness.…The figures above suggest thatthe research community has a large task ahead and that most decisions about
treatments still rest on the individual judgements of clinicians and patients.’’29
2.12. Therefore, the charge often levelled at homeopathy that it is ‘‘unscientific’’ rings
hollow when compared to this clear lack of evidence for many conventional medical
treatments and procedures.
2.13. Thus, if the challenge against homeopathy raised by EBM is to be at all taken
seriously then, by default, it has to be applied with equal rigour to conventional
therapies, which will mean that roughly half of all procedures, including nearly all
surgical ones, will have to be banned.

3. EBM and conventional medicine
3.1. Such a procedure is set to become a double-edged sword for biomedicine, as
the following example shows. Thus trials of one of the world’s biggest selling drugs
Prozac, recently found it to be no better than placebo.30
3.2. Interestingly, homeopathy/CAM detractors are not campaigning for the removalof Prozac, as they do so vociferously against homeopathy/CAM (even when Prozac
and Prozac-like drugs have been known to induce suicidal tendencies). Fortunately,such scientistic † ‘fundamentalism’2 is not shared by all in medicine.
3.3. Thus, cancer clinician Karol Sikora (60% of whose patients use some form of
CAM as adjuvant therapies) has uncompromisingly castigated the more vociferous
homeopathy/CAM detractors as ‘inexperienced armchair physicians’, while berating
their ‘Stalinist’ attempts to rid the NHS of its CAM services.31
3.4. Sir Michael Rawlins (Chair of NICE and no supporter of homeopathy/CAM) in his
Harveian Oration last year,15 warned: “RCTs, long regarded as the ‘gold standard’ ofevidence, have been put on an undeserved pedestal. Their appearance at the top ofhierarchies of evidence is inappropriate; and hierarchies are illusory tools forassessing evidence. They should be replaced by a diversity of approaches thatinvolve analysing the totality of the evidence base.”
3.5. In this respect, Sir Michael Rawlins simply echoes David Sackett’s much earlier
concern that EBM would turn into an evidence ‘mono-culture’, where the primacy ofan assumed ‘ideal’ scientifically-determined efficacy would subsume other no lessimportant forms of patient and clinician derived evidence.7
3.6. That over a decade later, voices in the nursing profession have been raised
concerning EBM’s intolerance of therapeutic pluralism in healthcare systems,4†Scientism describes the view that natural science is superior to all other interpretations of life, such as
philosophical, religious, mythical, spiritual, or humanistic explanations, and over other fields of inquiry, such as
the social sciences.

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suggests Sackett’s early warning went completely unheeded. This scientistic version
of EBM throws up for itself several alarming contradictions.
3.8. Thus, in a recent German randomised controlled back-pain study, acupuncture‘placebo’ was shown to be nearly twice as effective as the best conventional
medicine has to offer. So, according to the principles of EBM as currently practiced,
conventional medicine is less effective than an acupuncture placebo.19
3.9. The H1N1 swine flu vaccine is being rushed into production and distribution withlittle evidence from trials of its effectiveness or safety in humans,
3.10. One of the most frequently quoted studies (by the sceptical literature and the
media), supposedly demonstrating homeopathy is no better than placebo, is a 2005
Lancet meta-analysis,32 which has been shown by leading researchers to bethoroughly biased,33-36
3.11. In addition, two recent studies have concluded this meta-analysis was also ascientifically seriously flawed piece of work,37, 38 which broke the Lancet’s own strict
guidelines on methodological and publication transparency.39
3.12. The question arises therefore as to why it was ever allowed to appear in suchan eminent journal as the Lancet in the first place. This leads onto the whole thorny
issue of abuse of science in medical and pharmacological research,40 reported
recently in the magazine Prospect.41
3.13. In 2008, the journal Nature, stated that “in the US around 1000 incidents ofsuspected fabrication, falsification, and plagiarism go unreported every year”.42 In theUK, the Committee on Publication Ethics estimates that there are about 50 cases per
year of serious fraud in biomedical research, and that academia has been trying tocover up this abuse of science.
3.14. The Prospect article concludes, ‘We may have to wait for fresh scandals before
anyone acts. Until then, patients will remain in real danger of taking expensive drugs
whose risk of harm or inability to cure, have been fraudulently suppressed.’ And thereis clear evidence of harm perpetrated by conventional medical practice.
3.15. The House of Commons Public Accounts Committee concluded that in 2006
alone, at least 2.68 million people in Britain were harmed by conventional medical
interventions: a staggering 4.5% of the UK population.43 In the US, the situation iseven worse.44
3.16. When no such evidence of fraud or large-scale danger of homeopathy inclinical practice have been reported, one wonders why so much energy is expended
trying to demonise homeopathy/CAMs and those who practice them, as ‘unproven,unscientific, deadly and dangerous’.

-4-4. Evidence for homeopathy
4.1. There are many scientific trials and meta-analyses providing evidence that theeffects of homeopathy are more than a placebo response. These are summarised on
the Faculty of Homeopathy website.45
4.2. If the more inclusive Rawlins and Sackett definitions of evidence are utilised
however, then it is clear that there is growing evidence from clinical observation
studies46, 47 for the positive health benefits of homeopathy, and its costeffectiveness.48-50
4.3. There is also mounting basic science evidence that homeopathically prepared
solutions may very well differ from those that are simply diluted, suggesting theoperation of a ‘water-memory’ effect that surely deserves further exploration.51-54
4.4. In addition, laboratory studies suggest that even very high homeopathic dilutions(beyond Avogadro’s number) may exert biological effects, though even high quality
studies have yet to achieve consistency in experimental methodology.55-58
4.5. Some intriguing results which have just been published demonstrate that
extremely low doses of cytokines achieve relief from the symptoms of allergic asthma
induced in experimental mice, but only when the cytokines have been serially diluted
and violently agitated in the homeopathic manner.59

5. An aside: is the ‘Memory of Water’ (MoW) possible?
5.1. As someone who originally came into homeopathy with over 30 years
experience in chemistry (BSc, MSc, PhD, CChem, FRSC), MoW as a possible
mechanism for how homeopathic remedies might produce effects (even when theoriginal substance has been diluted out of existence), has produced in me feelings
ranging from outrage to intrigue.
5.2. Consequently, I can sympathise with those for whom MoW 60 seems tocontravene ‘common sense’ and fundamental scientific principles, such as the Laws
of Thermodynamics.
5.3. The problem with understanding MoW is the prevalence of so-called ‘common
sense’, which ultimately is only an indication of a particular paradigm’s power overpeoples’ imaginations. New experiences, repeated often enough make prevailingparadigms redundant.61
5.4. Not so long ago, the idea that the world was flat was ‘common sense.’ So, one’s
experience and common sense are just as likely to be shaped by one’s beliefs, as
the other way around, and are not fundamental.
5.5. MoW describes the apparent ability of bulk water to be “imprinted” with the“signature” of a substance once dissolved, but now diluted and violently agitated outof existence. The agitation is absolutely necessary, as mere dilution on its own does
not reproduce this phenomenon. The term was first coined by Prof Jacques-5-

Benveniste, and in his controversial Nature paper, he clearly distinguishes between
mere dilution and dilution plus agitation.62, 63
5.6. In chemical terms, MoW might be considered a supra-molecular phenomenon
involving trillions of water molecules. Thus, it is an emergent dynamic property ofbulk liquid water (i.e., the whole is more than the sum of its individual molecularparts) and, as such, defies simple explanation in terms of conventional chemical
ideas of static bonding and additive behaviour of individual water molecules.
5.7. Certainly, water molecules’ ability to dynamically switch hydrogen bonding toeach other is of crucial importance here, as are other weak intermolecularinteractions (e.g., van de Waals forces). Prof Martin Chaplin gives a fulsome accountof this behaviour on his website.64
5.8. The point is, the principles of equilibrium thermodynamics that one learns at
school and university cannot explain this behaviour, because it involves so-called
critical or instability points very far from chemical equilibrium. It is a type of behaviour
first described by Prof Ilya Prigogine’s Nobel Prize-winning work on thethermodynamics of non-equilibrium chemical reactions very close to chaos, such as
those that necessarily occur in all living organisms.65
5.9. One plausible hypothesis is that such instability points act as local dynamic
attractors of the system. These necessarily exist in such microscopic form, it requires
a novel quantum description that predicts effects at the macroscopic level, withconsequences not dissimilar to those of superconductors and super-fluids in lowtemperature physics. The model is applicable to several systems of complementary
medicine, including homeopathy.66
5.10. This means that it is quite possible for the physical and chemical properties of asolution to depend on its dilution history: in other words, for it to have a ‘memory’ ofwhat has been diluted in it. A series of interesting experiments indicating thispossibility, was reported recently using solutions of different substances at various(non-homeopathic) dilutions.67
5.11. Sixteen years after Benveniste’s controversial work, a successful version of his
experiments was performed involving a multi-centre European trial over 5 years, infive separate laboratories.56
5.12. In a completely different area, Rey obtained thermoluminescence data from
homeopathically prepared ultrahigh dilutions of lithium and sodium chloride, whichwere reproducibly different from pure water diluted with itself.51 This suggests that the
dynamically-altering pattern of hydrogen bonds described in 5.7., might survive
removal of the original material.
5.13. The field of materials science has demonstrated that it is changes to thestructure of water rather than its composition that fundamentally affects its
properties.68 In this regard, water can adopt a range of dynamic structures whichhave been used to account for its many well-known anomalies as a liquid.64-6-5.14. There is also compelling thermodynamic evidence that extremely diluted
solutions prepared in the homeopathic manner, by sequential dilution and violent
agitation, are measurably and reproducibly different from similar solutions that have
simply been diluted.53
5.15. Dr Cyril Smith in the UK has for over 30 years researched how living things
make use of electro-magnetic fields and frequencies, and their connection with
MoW.695.15. All the above experimental work supports a theoretical mechanism for MoW
first put forward by Italian physicists Profs Del Guidice and Preparata over 20 years
ago,70 that the homeopathic process of serial dilution and violent agitation triggers
formation of dynamic ‘structures’ in water that can survive removal of all traces of theoriginal dissolved substance.
5.16. Contrary to what some homeopathy/CAM detractors think therefore, MoW is
not only possible, it does NOT contravene known scientific laws and principles.

6. Conclusions
6.1. The charge often levelled at homeopathy by is detractors, that it is ‘‘unscientific’’even “deadly” does not withstand close scrutiny when compared to the clear lack ofevidence for many conventional medical treatments and procedures, including someof the latest vaccines, and the clear evidence of harm through side-effects of someconventional interventions.
6.2. With its increasing reliance solely on the results of randomised-controlled trials,
Evidence-based Medicine as currently understood and practiced is no longer areliable or cost-effective ‘tool’ for investigating the efficacy or safety of many
conventional medical procedures, let alone homeopathy/CAMs.
6.3. There is clear evidence of bias and dependence on flawed science by someassessing and reporting the supposed lack of efficacy of homeopathy, while at thesame time, abuse of science and its cover-up are unfortunately not rare occurrencesin medical and pharmaceutical research.
6.4. From RCTs, meta-analyses, clinical observational studies, and basic science
experiments, there exists a steadily growing evidence base for homeopathy, theefficacy of some of its remedies, and their possible mode of action. Work is also
beginning to elaborate homeopathy’s cost-effectiveness6.5. Finally, I would bring to the S&TC’s attention this quote from Professor Martin
Ryder of Colorado University on the dangers of scientism encroaching into public
policy “….Policy can be informed by science, and the best policies take into accountthe best available scientific reasoning. Law makers are prudent to keep an ear open
to science while resisting the rhetoric of the science industry in formulating policy. It
is the role of science to serve the primary interests of the polity. But government in afree society is not obliged to serve the interests of science…. positivism and-7-

scientism move in where the discourse of science lacks self-reflection and where thespokesmen of science exempt themselves from public scrutiny.”71
6.6. In conclusion, I would hope therefore that the S&TC considers the substantive
points I have made, in regard to the growing evidence for this more than 200-year-old
therapy, regardless of the accompanying bias and abuse I have itemised above. For
without that, it will be doubtful in my view, whether the STC will be able to achieve an
objective assessment of the evidence for homeopathy.
(2960 words: excluding references and footnotes. Declaration of interests; none).
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