The letter of complaint being sent to the GCC has been posted on ZENOs blog
with a list of 524 chiropractors, their registration number and their websites. For fifteen years I tried to get chiropractors to work together and now chiropractic sceptics seem to be demonstrating how effective co-operation is over competition.
The complaint is addressed to the GCC Registrar Margaret Coats who thought it would be a good idea
to use the Advertising Standards against chiropractors back in 2002 , presumably to protect GCC “experts” from criticism. What the complainant does not realise is that the GCC office does not have the money to investigate all these complaints.
They may just brush them under the carpet as they did with a complaint in 2002. In a Freedom of Information request they told me it had been investigated not expecting me to be elected onto council ,only to find Greg Price had brushed the complaint under the carpet. You see the GCC is capable of all sorts of shenanigans when it suits their purpose. Margaret Coats et al would like to purge a sizeable number of chiropractors from the register, but she needs their registration fees to keep her in the style she has become accustomed to.
Chief Executive & Registrar
General Chiropractic Council
Complaints against various chiropractors
I understand the General Chiropractic Council (GCC) is the statutory body charged with regulating all chiropractors in the UK under the Chiropractors Act 1994.
I note that the GCC has three main duties1:
· To protect the public by establishing and operating a scheme of statutory regulation for chiropractors, similar to the arrangements that cover other health professionals
· To set the standards of chiropractic education, conduct and practice
· To ensure the development of the profession of chiropractic, using a model of continuous improvement in practice
I understand from this that it is your role as statutory regulator to ensure that all chiropractors work within the GCC’s Code of Practice and Standards of Proficiency2 (CoP). I understand that the CoP ‘are binding requirements on chiropractors, which are developed and published by the GCC under specific provisions of the Act’3.
In light of the above, please treat this as a formal complaint against the chiropractors detailed in the attached list.
I believe they are all members of the British Chiropractic Association (BCA). I also understand most of them are in the statutory GCC register and I have given their registration number where available. However, as indicated in the list, I have not been able to locate 15 of them in the GCC register, although they appear to be in the BCA’s register and they may be practicing as chiropractors. It may be that they are registered under a different name, but please confirm you will investigate these cases.
1 http://www.gcc-uk.org/page.cfm?page_id=7, retrieved 07 June 2009
2 http://www.gcc-uk.org/files/link_file/COPSOP_Dec05_WEB(with_glossary)07Jan09.pdf, retrieved 21 May
My complaints are in three parts:
1. On the websites of the clinics where these chiropractors appear to be working, claims are made about medical conditions that I do not believe can be substantiated to the required standard.
Paragraph C1.6 of the CoP states that any information published by chiropractors or on their behalf, must be ‘consistent with the law and the guidance issued by the Advertising
Standards Authority’ (ASA).
I understand that relevant ASA guidance includes:
· The British Code of Advertising, Sales Promotion and Direct Marketing (CAP)4 · AdviceOnline: Therapies: Chiropractic· Health Beauty and Slimming Marketing That Refers to Medical Conditions6
I note in particular that paragraph 50.1 of the ASA’s CAP states:
Medical and scientific claims made about beauty and health-related products should be backed by evidence … Substantiation will be assessed by the ASA on the basis of the available scientific knowledge.
Additionally, reference 6 states:
Marketers should hold robust evidence for all claims.
I note reference 5 states:
To date, the only serious medical condition to which CAP and the ASA accept chiropractors may refer is migraine (not headaches).
I further note that the same guidance continues:
But CAP has accepted in the past that chiropractors may claim to help: aches and pains, arthritic pain, backache, back pain, circulatory problems, cramp,
digestion problems, joint pains, lumbago, muscle spasms, neuralgia,fibromyalgia, inability to relax, rheumatic pain, rheumatism, minor sports injuries and tension (see General List in the Help Note on Health, Beauty and Slimming Marketing Communications that Refers to Medical Conditions).Practitioners claiming to treat such conditions would be expected to hold evidence.
This implies that such claims may not be in contravention of the ASA’s guidance if a chiropractor making those claims holds evidence of the efficacy of chiropractic for those conditions. However, CAP paragraph 50.1 simultaneously applies; any such evidence being evaluated ‘on the basis of the available scientific knowledge’.
4 http://www.asa.org.uk/NR/rdonlyres/AE1CB9D7-0981-4792-8FF1-C27A39DA917E/0/CAPCode.pdf, retrieved 21 May 2009
5 http://www.asa.org.uk/cap/advice_online/advice_online_database/Show+Entry.htm?advice_online_id=487,retrieved 21 May 2009
Some practitioners believe chiropractic helps the short-term treatment of acute low-back pain (not sciatica) and headaches. To date, we have not seen
evidence that the therapy can help but the evidence we have seen so far on its efficacy is scant and our position could change.
I also note various ASA adjudications that inform their guidance, including Optimum Health Centres, 19 December 2007 and BritChiro Clinics Ltd, 28 May 2008.
Some of the claims made for the conditions I have listed are direct claims that chiropractic can be beneficial or ‘cure’ that condition. Some other claims are made are less definitive or direct: ‘chiropractic can help with…’, ‘we have seen improvements with…’, ‘patients come to us with…’ or similar words and phrases. However, these websites encourage the public to seek out chiropractic as a remedy to medical conditions and in the context of the complete
website, a member of the public—particularly the vulnerable—would be led to believe that chiropractic can influence and improve or cure these conditions. I therefore believe that the general public will not appreciate the subtlety of these indirect claims and that these claims will mislead just as much as if they were direct claims.
I believe that some or all of the claims (whether specified by the ASA or not) made by those on the attached list are not capable of being substantiated to the ASA’s standard and therefore should not be claimed by any chiropractor under the GCC CoP.
2. Some of the registered chiropractors (as indicated on the attached list) represent themselves using the title ‘Dr’, use the word ‘Doctor’ where it is not clearly associated with ‘Chiropractic’ or make other representations that will lead members of the public to believe they are registered medical practitioners, particularly in the context of websites that make medical claims and are intended to lead visitors to believe that the chiropractic can diagnose and treat a large number of medical conditions, some of which are serious medical conditions. I believe this contravenes paragraph C1.8 of your CoP, the ASA’s guidance in AdviceOnline:
Use of the Term "Dr"7 and various ASA adjudications including Wigan Family Chiropractic Clinic, 25 February 2009.
3. I note that many of the chiropractors listed also appear to be contravening various other aspects of the CoP. For example, many chiropractors frequently encourage potential patients to become reliant on chiropractic by telling them they must continue to receive chiropractic treatment to keep their spine—and hence themselves—in good health. I believe this contravenes paragraph C1.3 of the CoP. Other chiropractors use language that will dissuade or delay some people from seeking proper medical attention for serious medical conditions.
I believe that the public are currently not being protected and indeed may be exposed to harm by the claims being made by GCC registered chiropractors and I understand that it is the responsibility of the GCC to ensure that this situation is remedied and controls put in place to
ensure the public are fully protected in future. Although I am making complaints against those I have listed, I believe other registered
chiropractors may also be in similar contravention of your CoP.
In view of the scale and seriousness of these complaints, please deal with this as a matter of urgency.Please acknowledge receipt of these complaints and please keep me fully informed of your progress in dealing with them.