This afternoon, the Advertising Standards Authority released their decision to uphold an interesting complaint regarding advertisements for a couple of cleaning products on a website. Here is the ASA’s description of how the products were described on the website:
The Wendyl’s website (http://wendyls.co.nz/) for “100% natural cleaning and beauty products” advertised their products as having “all their ingredients listed and contain no fillers, chemicals or synthetics.”
The webpage for Wendyl’s Oxygen Bleach 1KG (sodium Percarbonate) stated, in part:
This is powdered hydrogen peroxide which is a greener alternative to chlorine bleach because it breaks down to oxygen and water in the environment.
The webpage for Wendyl-San oxygen soaker 1KG stated, in part:
I’ve spent years testing this oxygen soaker and stain remover and I’m so glad to have something which is so free of chemicals and additives. Secret ingredient is sodium percarbonate, a powdered hydrogen peroxide bleach which breaks down in the environment to oxygen and water…
The advertiser uses words such as “100% natural”, and “contains no fillers, chemicals, or synthetics”.
However, the product in question is sodium percarbonate, which is not a naturally occurring product. The main active ingredient, hydrogen peroxide, is also not a naturally occurring product and it is not stable in nature.
Both are synthetic chemicals.
After hearing from the advertiser as well, the Advertising Standards Complaints Board sided with the complainant. Here is a summary from the headnote of their decision:
The Complaints Board said it accepted the Advertiser’s view that “sodium percarbonate is a much safer and more environmnetally friendly alternative to chlorine bleach” but not that it was “chemical free” and “100% natural.” The Complaints Board said the advertisement was likely to mislead consumers into thinking the products were “100% natural” and “chemical free” when they actually contained naturally occurring chemicals, in breach of Principle 2 of the Code for Environmental Claims and had not been prepared with a due sense of social responsibility to consumers in breach of Principle 1 of the Code for Environmental Claims.
Accordingly, the Complaints Board ruled to Uphold the complaint.
The most interesting part of this complaint is, I think, who the advertiser is. As well as selling cleaning and beauty products online, Wendyl Nissen writes a weekly column for the New Zealand Herald called “Wendyl Wants To Know“. The Herald describes the column as:
Each week, Wendyl Nissen takes a packaged food item and decodes what the label tells you about its contents.
Have a look for yourself, but from the columns of hers that I’ve read it seems the main argument is typically along the lines of “natural is good, chemicals are bad”. So I find it very ironic that she’s now had a complaint upheld against her for misleadingly claiming that a product she sells is “100% natural” and “chemical free”.
For a counterexample to the attitude of “natural is good, chemicals are bad”, you need look no further than the “recipes” section of her website. There, she has some pet recipes which she makes available for free including one for De-Flea Powder for Cat Biscuits and another for Doggy De-Flea Treats. In both recipes, she claims the active ingredients are yeast and garlic:
The theory behind this powder is that fleas hate the taste of yeast and garlic so will hop off and look elsewhere.
Elsewhere on her website, she recommends that if you:
Put a garlic clove in your pet’s water you can help deter pests such as mites and fleas.
Although it certainly is natural, garlic is also toxic to cats and dogs, especially for cats. I couldn’t find any warnings about this on Wendyl Nissen’s website.
The lessons to be learned? Natural isn’t always good, and don’t take advertisers’ word for it when they claim something is “100% natural” or “chemical free”. As always, ask for evidence.
In New Zealand, we are lucky enough to have an industry code of ethics for pharmacists, published by the Pharmacy Council of New Zealand, which holds pharmacists to high ethical standards. This code of ethics is the Safe Effective Pharmacy Practice Code of Ethics. One of the most important parts of this code of ethics is section 6.9, which states:
[PHARMACISTS] MUST:… Only purchase, supply or promote any medicine, complementary therapy, herbal remedy or other healthcare product where there is no reason to doubt its quality or safety and when there is credible evidence of efficacy.
Pharmacy Council’s Safe Effective Pharmacy Practice Code of Ethics Section 6.9
The Pharmacy Council of New Zealand isn’t a voluntary member organisation like the Pharmacy Guild or the Pharmaceutical Society. Instead the council is established as part of the Health Practitioners Competence Assurance Act 2003. Their roles are set out in this act and include:
- Registering pharmacists
- Reviewing and maintaining the competence of pharmacists
- Setting standards of clinical competence, cultural competence, and ethical conduct for pharmacists
Which means that the Safe Effective Pharmacy Practice Code of Ethics is not a voluntary code of ethics. It is published by the body whose legal duty it is to set the standards of ethical conduct for pharmacists. Yet all over New Zealand, many pharmacists ignore it.
Walk into any New Zealand pharmacy. Chances are that you will find a section where they advertise and sell a range of homeopathic products. To anyone familiar with the evidence for homeopathy, it will come as no surprise when I tell you that there is no credible evidence of efficacy for any homeopathic product. Therefore, it seems to me, New Zealand pharmacists have an ethical obligation not to promote or sell them.
Yesterday, the Australian National Health and Medical Research Council (NHMRC) issued their final statement on homeopathy, following an incredibly extensive and rigorous review of the literature. They looked at over 1,800 scientific papers, and found that 225 met their criteria for methodological rigour, sample size, and placebo control. Their main finding was:
there are no health conditions for which there is reliable evidence that homeopathy is effective.
As I said, this conclusion does not come as a surprise. This research is the latest in a long line of reviews of the evidence for homeopathy that drew essentially the same finding:
A 2002 systematic review of systematic reviews of homeopathy published in the British Journal of Clinical Pharmacology concluded that:
the hypothesis that any given homeopathic remedy leads to clinical effects that are relevantly different from placebo or superior to other control interventions for any medical condition, is not supported by evidence from systematic reviews. Until more compelling results are available, homeopathy cannot be viewed as an evidence-based form of therapy.
A 2010 systematic review of systematic reviews of homeopathy published in the Medical Journal of Australia concluded:
The findings of currently available Cochrane reviews of studies of homeopathy do not show that homeopathic medicines have effects beyond placebo.
A 2010 report from the UK House of Commons concluded:
homeopathy is a placebo treatment.
In 2013, the NHMRC published a report based on their research that found:
There is a paucity of good-quality studies of sufficient size that examine the effectiveness of homeopathy as a treatment for any clinical condition in humans. The available evidence is not compelling and fails to demonstrate that homeopathy is an effective treatment for any of the reported clinical conditions in humans.
I could go on, but I hope by now you get the idea.
New Zealand pharmacists need to respond to the NHMRC’s research. And if they mean to practice responsibly and ethically, that response should be to immediately stop all promotion and sale of homeopathic products. The ethical standard to which they should be held is clear, and it is not consistent with promoting or supplying homeopathic products.
Last year, I complained to the Advertising Standards Authority under the auspices of the Society for Science Based Healthcare about a homeopathic product for preventing jet lag (No-Jet-Lag) that was advertised in Parnell Pharmacy. The pharmacy responded by removing the advertisement, and agreeing to stop selling the product if it was found that the claims were not supported by credible evidence, and my complaint was upheld. Unsurprisingly, my complaint was upheld when the ASA decided claims such as “it really works” were not supported by credible evidence. However, despite Parnell Pharmacy’s example, many New Zealand pharmacies still sell this exact product.
The NHMRC’s report represents the same finding, but on a larger scale. New Zealand pharmacists who promote and sell homeopathic products should follow the responsible example of Parnell Pharmacy, and remove homeopathic products from their shelves.
Recently I’ve run across a couple of New Zealand companies that sell therapeutic products – one a weight loss pill, the other a jet lag drink – that seem to put marketing first and let science take the back seat. This is by no means new behaviour, but I want to use them as examples to illustrate this widespread problem and suggest what can be done to combat it.
Before promoting a therapeutic product, you should first have good reason to believe that it works. This, I hope, is common sense, but it’s also enshrined in the Fair Trading Act and the Therapeutic Products Advertising Code as they prohibit unsubstantiated claims. This means you have to test the product, and do so rigorously. Rigorous clinical trials are expensive to undertake though, so they’re quite a prohibitive first step.
Instead of jumping straight into the deep end, a useful first step can be to undertake a smaller and less rigorous (and therefore less expensive) experiment. In order to answer the question of whether or not a product actually works you need to conduct a more rigorous trial. There’s a great cost involved in doing this, but if the results of a preliminary trial are optimistic then you have reason to expect a more rigorous trial might give similar results, so the expense might be worth it. You may even be able to get some funding to help with a more rigorous trial on the basis that the preliminary results were positive.
This is what Tuatara Natural Products has been doing with their weight loss pill “Satisfax”. They have completed a low quality preliminary trial on their product, which has been colloquially dubbed the “Fat Mates” trial. Although I don’t believe it has yet been published in a journal at the time I’m writing this article, it was registered retrospectively in the Australian New Zealand Clinical Trials Registry: Effect of the dietary supplement Satisfax (Registered Trademark) on weight loss in overweight volunteers. Some information on the data in the trial can be found on their website as part of an analysis by Dr Chris Frampton: Analysis of Satisfax® Clinical trial
As you can see on the trial registration page, this was an uncontrolled trial on overweight adults. The original plan was to recruit 100 volunteers with the hope that at least 60 will complete the trial. I have to say I’m a bit confused about how many people were in the trial, as apparently the recruitment was increased to 200 applicants after applications opened (a change that has not been reflected in the trial’s registration) yet apparently about 400 people applied. One article claims there were 200 participants, a later media release from Tuatara Natural Products seems to imply 100 were recruited, and the analysis of the trial says there were only 81 participants. Either way, 81 participants completed the full 8 weeks, and 52 of them took the recommended dose for the whole duration of the trial.
If there were 19 or 119 participants who didn’t complete the trial, the statistical analysis seems to ignore them with no justification given. This is unusual – a 19% drop out rate is significant and shouldn’t be swept under the rug. A lot of the time Tuatara also seems to ignore the 29 participants who didn’t drop out but also didn’t take the full dose for the whole duration.
The Science Media Centre posted the responses of 2 experts, Associate Professor Andrew Jull and Professor Thomas Lumley, to a press release from Tuatara Natural Products in February. It’s a good analysis of some of the weaknesses with the study, and I recommend you read it: Kiwi diet pill claims – experts respond
This trial was uncontrolled, and therefore also unblinded and unrandomised. As Professor Lumley explains, this is a problem if you want to draw strong conclusions from its results. It is of low methodological quality, but that’s okay. There is no problem with doing less rigorous trials first if they’re done in order to determine if more rigorous trials are necessary. Dr Glenn Vile, Chief Technical Officer of Tuatara Natural Products and the principal investigator for this study, wrote the following in a comment on a post on the “Fat Mates” trial by Dr John Pickering:
The Fat Mates trial was designed by clinical trial specialists to generate information about the Satisfax® capsules that would help Tuatara Natural Products plan a larger and longer double blind, cross over, placebo controlled trial.
We will use this information to proceed with the next clinical trial, but in the meantime we were so excited the weight loss achieved by most of our Fat Mates was much greater than the placebo effect seen in other weight loss clinical trials that we decided to launch the product so that anybody who is overweight can try Satisfax® for themselves.
I think the first part of what I’ve quoted above describes exactly what Tuatara Natural Products should be doing. They’ve conducted their low quality trial, and intend to use its results to proceed with a larger, longer, and more rigorous clinical trial. This is the right way to proceed – they now have an indication that their product might be effective, so they should do the research to find out.
The problem is that that’s not all they’re doing. After performing only a small low-quality trial, they’ve released their product for sale online and have been making a lot of noise about it. In my opinion, they’ve been significantly overstepping the results of their clinical trial. For example, in his comment Dr Vile also said:
our initial trial has shown [Satisfax] to be extremely effective in some overweight people.
Dr Glenn Vile
In their media release on the 20th of February, they reported the average weight lost only by the 52 participants who took the full dose to completion (rounded up from 2.9 kg to “close to 3kg”) but not the average weight lost by all participants. They then reported in bold that the top 26 participants lost more weight, and the top two participants lost even more weight than that!
This cherry picking of the best results appears to have been part of Tuatara Natural Products’ marketing strategy for at least a few months now. In January, Stuff published an article on the trial highlighting the single person who lost the most while participating in it: Blenheim ‘fat mate’ loses 13.5kg in 8 weeks.
That article particularly highlights the person who lost the most weight out of all those in the trial, at 13.5 kg (confusingly, the maximum weight loss reported in the analysis of the trial’s results is 13.3 kg). However, she was one of only 2 participants who lost over 10 kg, and on average the 52 participants who took the recommended dose for the full eight weeks lost 2.9 kg. Losing 13.5 kg is very far from a representative example. I’m not surprised that they didn’t choose instead to focus on the participant who gained 1.2 kg despite taking the recommended dose for the whole duration, but that is actually much closer to the mean change in weight.
The article is, for all intents and purposes, one big testimonial in favour of Satisfax. It was an article, not an advertisement, which is important because in New Zealand it’s illegal to publish any medical advertisement that:
directly or by implication claims, indicates, or suggests that a medicine of the description, or a medical device of the kind, or the method of treatment, advertised… has beneficially affected the health of a particular person or class of persons, whether named or unnamed, and whether real or fictitious, referred to in the advertisement
This effectively bans all health testimonials from advertisements. I think this is a good part of the law, as testimonials can be both very convincing and completely misleading; a quack’s dream. Banning them should force businesses to instead focus on the results of research on their products, but this hasn’t stopped Tuatara Natural Products from getting stories written about the most extreme testimonials they could find from people who have lost weight at the same time as they were taking Satisfax.
More recently, Tuatara Natural Products has put out a press release multiple times (at least on the 20th of February and again on the 4th of March) that I think rather oversteps the results of their small preliminary trial:
A NEW ZEALAND SOLUTION TO A GLOBAL PROBLEM A little pill is providing an exciting answer to one of the worlds greatest and fastest growing problems: Obesity.A NEW ZEALAND SOLUTION TO A GLOBAL PROBLEM
A little pill is providing an exciting answer to one of the world’s greatest and fastest growing problems: Obesity.
I simply don’t think they are at all justified in saying that their new product is “providing an exciting answer to… Obesity”. They are putting marketing ahead of science, and that’s not okay.
Another company that seems to put marketing before research is 1Above. They make a drink which they claim can help you recover faster from jet lag, and have recently been in the news for signing a sponsorship deal with the fantastically successful golfer Lydia Ko.
At the end of that article about their sponsorship deal the reporter, Richard Meadows, made some comments regarding the science behind jet lag relief products and asked some good questions of 1Above’s CEO, Stephen Smith (emphasis mine):
[1Above’s] product contains a mixture of vitamins B and C, electrolytes, and Pycnogenol, a pine bark extract.
The efficacy of flight drinks to combat the effects of jetlag is unproven.
Late last year pharmacists were warned after the Advertising Standards Authority upheld a complaint against an ad saying a homeopathic anti-jet lag pill really worked.
[1Above CEO Stephen] Smith said 1Above would not be doing clinical trials, which were highly expensive and not necessary.
“What we tend to use is testimonials from people who have used the product and swear by it.”
Smith said the key ingredient, Pycnogenol, had itself had been tested in dozens of trials, including its effects on reducing jetlag.
Yes, you read that correctly. The CEO of 1Above literally said that they won’t be doing clinical trials because they are “not necessary” and that they use testimonials instead.
As I said before, using testimonials to promote a therapeutic product, like a drink to help you recover faster from jet lag, can be both very convincing and completely misleading. There’s a reason why testimonials implying health benefits are illegal in New Zealand, and I hope that 1Above’s marketing will not violate this regulation.
Not all testimonials are prohibited, of course. It’s entirely acceptably to provide a testimonial from someone who thinks their drink tastes great, or that they provide great service. Basically anything for which a single person’s experience can provide a useful insight. Therapeutic effects, almost without exception, do not fall into this category, which is a big part of why we need to do clinical trials in the first place. If they quote someone in saying that their product helped them recover faster from jet lag, they may be in danger of breaching the Medicines Act.
For example, I’d expect they probably shouldn’t use a testimonial that says this:
On their website, 1Above currently does refer to research on one of the ingredients in their product, “pycnogenol”. Professor Lumley recently wrote a post about this on his other blog, Biased and Inefficient, regarding these studies and how they are used by 1Above: Clinically Proven Ingredients
I recently contacted 1Above to ask about some discrepancies I found between the abstract of the study they cited for showing pycnogenol reduced the duration of jet lag and their description of it on their website:
I was interested to see the claim your company made that Pycnogenol® has been shown to support circulation and reduce the length and severity of jet lag.
I have found the study “Jet-lag: prevention with Pycnogenol. Preliminary report: evaluation in healthy individuals and in hypertensive patients” that is mentioned on your website as the source for this claim, but I am only able to access the abstract of this preliminary report. Unfortunately, as far as I can tell, the study protocol didn’t involve blinding of participants or researchers.
The participants in the study took 50 mg Pycnogenol 3 times per day, but I haven’t been able to find out how much is contained in your products. Is this information available anywhere on your website? I notice the study also says the participants took this regimen for 7 days, starting 2 days prior to departure. Is this comparable with how your product is intended to be used?
I also noticed some differences between the description of the study and its results between the abstract and your website, I would be grateful if you could explain to me the source of these differences.
The abstract states the control group took, on average, 39.3 hours to recover and the experimental group took, on average, 18.2 hours to recover. However your website reports these as 40 and 17 hours respectively.
Also, your website states that the study involved 133 passengers (it’s not clear from the description on your website if they all took Pycnogenol or if some of them were in the control group) who reported the time it took them to recover from jetlag. However, the study’s abstract states that in the first experiment, which is the only one that involved the reporting of the time taken to recover from jetlag, only involved 68 participants – 30 in the control group and 38 in the experimental group.
I would be grateful if you could explain these differences to me, and if you could send me any other relevant scientific information that supports this claim.
To their credit, since receiving my message they did update their website to fix the discrepancies in the reported number of participants and times taken to recover from jet lag, and their CEO replied to thank me for pointing these discrepancies out.
However, they didn’t respond to my other questions about the amount of pycnogenol in their products or the study involving the participants taking pycnogenol for 7 consecutive days, starting 2 days before their flight, which is inconsistent with how 1Above recommends their products be used.
This is just one more company basing their marketing on preliminary trials instead of using them as the basis for research that could actually answer the question of whether or not a product is useful. Worse than Tuatara Natural Products, they even go so far as to consider clinical trials “not necessary” and apparently intend to rely on testimonials instead. It would be much more appropriate for them to spend some of their $2.4 million annualised income on researching their product rather than paying for a sporting celebrity to endorse them.
I try to make my rants constructive, so I want to end this article with the question “What can we do about this?”. If you have any suggestions, I’d love to hear them in the comments section.
I think the most important thing that anyone can do to address this problem is to ask for evidence. If you see a claim made about a product that you think you might buy, then get in touch with the company selling it to let them know you’re considering buying it and to ask for evidence. If they don’t have a good enough answer, then let them know that’s why you won’t be buying their product. If they give you evidence to back up their claim, then great!
Asking for evidence doesn’t have to be a big deal, involving a formal letter or anything like that. When you see a weight loss product advertised on a one day deal site, a copper bracelet that apparently offers pain relief advertised on a store counter, or a jet lag cure promoted on Twitter, make your first response be to politely ask for evidence.
This isn’t a problem that’s going away any time soon. As consumers, we deserve to be able to make informed decisions about the products we buy, and when companies put marketing before research it becomes harder to make these informed choices. But if we work together then we can encourage companies like Tuatara Natural Products and 1Above to improve their behaviour and attitudes toward marketing and research.
Let’s turn “what’s the evidence?” into a frequently asked question for all companies that sell therapeutic products.
Phil Plait, who writes the wonderful Bad Astronomy blog over on Slate, noticed something interesting in a recent episode of The Simpsons:
To the untrained eye, nothing about this cartoon image is likely to seem unusual. But if you spend a lot of time looking at the sky, and you have the additional context that this scene occurred in the evening, then the Moon is actually quite revealing.
(For those of you thinking “it’s just a cartoon, don’t expect it to be accurate”, I realise that. But if you decide to treat it as though it must be accurate then it can be interesting to think about so bear with me.)
To understand why that is and how we know, we have to have a think about how we look at the Moon.
The Moon orbits the Earth in a plane that’s pretty well aligned with the plane of the solar system. This means if you drawn a line in the sky tracing the path of the Moon, you’ll also find the Sun and the planets roughly on that line. This is why we experience solar and lunar eclipses, which happen when the Sun and Moon are lined up particularly well with the Earth. Because the line is where eclipses happen, it’s called the ecliptic by astronomers.
Earth’s axis is tilted by 23.5° relative to this plane, but if you’re not too close to the equator (for example, if you’re in New Zealand or the USA) then you can say that if you projected the equator into the sky it would be in roughly the same position as the ecliptic. If you’re in the southern hemisphere, that means it’s to the north, and if you’re in the northern hemisphere, it’s to your south.
So, if you’re looking at the Moon from New Zealand, you must be looking roughly to the north. If you’re looking at it from the USA, you must be looking roughly to the south. This also means the Sun and Moon, moving east to west across the sky as the Earth spins, appear to move right to left from the southern hemisphere and left to right from the northern hemisphere.
When we look at the Moon, we’re seeing the same thing no matter where we are on Earth except for one thing: which way is “down”. The “bottom” of the Moon in the part that’s closest to the horizon. If you travel to the other hemisphere, and you’re familiar enough with the Moon, you may notice that it appears upside down. That’s because the direction of “down” has swapped – from roughly north to roughly south (or vice versa if you’ve travelled from north to south). If you want to see what the Moon looks like from the other half of the world, you have to bend over backwards (or lie on the ground). This is also why the Moon will appear to have rotated if you compare it when it’s rising to when it’s setting.
One more thing: the Moon orbits us in the same direction as we’re spinning, which means it moves across the sky slightly slower than the Sun. Each day, the Moon rises roughly 50 minutes later than the day before, so that over its 28 day cycle of phases this sums to 24 hours.
Now, getting back to that image from the Simpsons episode. That scene was apparently in the evening, and the Moon is low on the horizon. That means the Moon must either be about to set or have just risen. If it had just risen after sunset, then it was recently full (because a full moon rises at sunset and the moon rises later each day), which means its phase would be a waning gibbous. Waning refers to the fact that it is on its way from being full to being new, and a gibbous is the shape made by a circle with a crescent cut out from it.
In the picture, the Moon is obviously a crescent, so it can’t have just risen. If it’s just about to set after sunset, then is must just have been a new moon (because a new moon sets at sunset and the moon rises later each day), which means its phase would be a waxing crescent. Waxing refers to the fact that it is on its way from being new to being full, and the crescent refers to its curved shape.
Another thing we know about the Moon is that its lit side always faces the Sun. For example, the lit side of a full moon points right back at us, because from its perspective the Sun shines on it from behind us. If the Sun has just set, and the Moon is just about to set as well, then the lit side of the Moon must be facing the Sun. As the Sun sets in the west, this means the lit side of the Moon should also be facing west if it is a waxing crescent.
In the picture from the Simpsons, which we’ve established should be a waxing crescent, the lit side of the Moon is facing to the left. But remember, if you look at the Moon from the northern hemisphere you must be looking to your south, so west should be on your right. So if the waxing crescent moon is lit on its left, then you must be looking north to see it, which means you’re in the southern hemisphere.
Unfortunately, a lot of pop culture doesn’t get the Moon and its phases right. I know it’s such a tiny thing, and typically when they don’t get it quite right I can’t say I mind too much (although I often can’t help but notice), but I really love it when they put in that extra bit of effort to get it correct.
Almost all video games with day/night cycles where you can see the sky have the Moon orbit in 24 hours. Some of them include phases, although technically if your Moon always rises at sunset then it should always be full. I can forgive video games fairly easily though, I’m probably the only person who cares and I understand it could take significant development time to get proper lunar phases in. The only example I can think of that gets it right is Kerbal Space Program, where accurate celestial mechanics is an important part of the game.
Some books have issues with the Moon as well. Last year I was reading the book Ship of Theseus, and one scene describes the protagonist seeing the crescent moon rise as it gets dark. But crescent moons never rise as the Sun sets, light simply doesn’t work that way.
Movies often have trouble with it as well. The worst offender I’ve seen is the final scene from the movie Cloud Atlas:
Remembering that the lit side of a moon points towards its sun, and this applies even with multiple moons, that image implies some very strange things about the nature of light.
I’d love to see more media put more effort into getting this right. I know that one author who paid particular attention to this detail was J.R.R. Tolkien, who tried hard to get the phases of the Moon consistent with his dates when writing The Lord of the Rings and apparently did a pretty good job of it too.
My favourite example of well-documented in-depth world building doesn’t involve the Moon but I’d like to share it here anyway. My brother Jeremy (who’s currently working as a concept artist at Weta Workshop, a job he got soon after leaving Uni) worked on creating a deep and internally consistent fictional history to earn his masters degree in 2013. He ended up creating a fake National Geographic article from 1932 recounting the reporter’s visit to the settlement of Elkwood. The article only scratched the surface of all the thought he put into the work, if you want to see what he came up with you can read both the article and his exegesis explaining his research methods here: Creating Elkwood: building an alternate history
When fictional worlds are deep and internally consistent they become that much more enriched. If you know of any that have represented lunar cycles particularly well (or particularly poorly) let me know in the comments.
Biosecurity is a big issue for New Zealand. Being a group of islands fairly isolated from all other landmasses and having quite a unique native ecosystem (many native birds with no native mammalian predators and few native land mammals), we have a lot to lose from introduced species. There are also biological threats to industry that we have to try really hard to keep out of the country, such as Queensland fruit fly. There’s good reason why the Ministry for Primary Industries (MPI, formerly MAF) reacted so strongly when one of these flies was found in Whangarei in April 2014. If enough of these flies made it into New Zealand to self perpetuate, they could cause massive damage to New Zealand’s $5 billion horticulture industry.
In order to kill off any biosecurity risks, including disease-causing organisms and foodborne pests, various treatments (also known as “phytosanitary actions” when used on plant products) can be used when importing products into New Zealand. Different products that can be imported each have an Import Health Standard (IHS) that documents the process of importing them.
For fruit and vegetables being imported, they need to come with a phytosanitary certificate from their country of origin, to say that either they have been inspected by someone from MPI and they couldn’t find any pests, they come from a certified pest free area, or they have been treated to kill any pests. A sample of the products is also inspected by MPI when arriving in New Zealand, and if any pests are found then the products will have to be treated if they are to enter New Zealand.
The treatment used depends on a few things, such as what pest was found that they’re trying to kill. For example, assuming I’m interpreting the IHS correctly, if Thrips palmi is found in a shipment of capsicum from Australia it would be fumigated with methyl bromide at 32 g/m3 for 2 hours. Whereas if Conogethes punctiferalis were found, then the capsicum would be irradiated with a minimum dose of 250 Gy (Grays; 1 Gray is equivalent to 1 Joule of energy absorbed per kg of food).
The previous paragraph is incorrect. Those treatments are the ones that should appear on the phytosanitary certificate, having been performed in the country of origin. The treatments done if a pest is found when they arrive in New Zealand are determined in the Approved Biosecurity Treatments Standard. So for fresh fruit and vegetables (page 37), if insects except for fruit flies (not slugs and spiders) are found then they have to be fumigated with methyl bromide at a particular rate and temperature for a particular duration (presumably depending on the pest and the produce). Looking at this standard, it seems human food doesn’t get irradiated if pests are found when it arrives in New Zealand. According to MPI’s list of treatment providers (direct PDF download), there is only one facility in New Zealand able to provide food irradiation, which is in Wellington.
Methyl bromide is an insecticide, and it’s also recognised as an ozone-depleting substance. Because of this, its use is tightly controlled. It’s only allowed to be used for a few specific purposes, one of which is quarantine, and New Zealand has to provide statistical data to the Ozone Secretariat on the annual amount of methyl bromide that we use. It’s nasty stuff – even skin contact with high enough concentration of the gas can cause severe blistering – but after being used to fumigate food it apparently dissipates fairly rapidly. There are some objects that MPI won’t fumigate with methyl bromide for various reasons, which are described in their info sheet I linked to above.
Irradiation is quite different. Using either Cobalt 60, x-rays, or an electron beam food is blasted with a specific amount of ionising radiation. Cobalt 60 is a radioactive source of this radiation, but as it emits gamma rays instead of neutrons it doesn’t make anything else around it radioactive. Both x-rays and electron beams are created by non-radioactive sources and can be switched on and off.
When food is irradiated, the process kills any organisms that are living in the food, including disease-causing organisms and pests. The food does not become radioactive, instead it will just be slightly warmed from the energy it absorbs. Also, the radiation will trigger some chemical changes, but these occur only in amounts comparable to heat treatments. In this way it’s quite similar to the process of pasteurisation used to make milk safe to drink.
In 2010, following an extensive literature search, the European Food Safety Authority (EFSA) published their Scientific Opinion on the Chemical Safety of Irradiation of Food. They found that the new evidence published since their previous decision in 2003 wasn’t enough to change their opinion that “there is not an immediate cause for concern” regarding the safety of irradiated food.
The strongest negative evidence they found seemed to be a case in which cats ate a diet consisting largely or entirely of highly irradiated (25.7 to 53.6 kGy, i.e. 100 to 200 times as much as in the capsicum example from earlier) cat food and subsequently suffered from leukoencephalomyelopathy (LEM). This evidence doesn’t necessarily have any relevance to humans though; in another report dogs ate the same pet food and didn’t exhibit LEM. Also, as the incident was only linked to one specific lot of one specific brand of pet food it’s unclear if irradiation was the culprit at all.
Even though irradiated food appears to be entirely safe to eat and not significantly different from food that hasn’t been irradiated, it is currently compulsory to label irradiated food in New Zealand under the Australia New Zealand Food Standards Code Standard 1.5.3.
MPI’s Food Smart website has an informative page on food irradiation. It’s quite clear on several important points (you can read their full answers on the page):
Does irradiation change food?
At the approved doses, changes to the nutritional value of the food caused by irradiation are insignificant and do not pose any public health and safety concerns.
Some treated foods may taste slightly different, just as pasteurized milk tastes slightly different from unpasteurized milk. There are no other significant changes to these foods.
Does irradiation make food radioactive?
Is it safe to eat irradiated food?
Yes. Irradiation of food does not make the food unsafe to eat.
The World Health Organisation, the Food and Drug Administration in the US and the American Medical Association all agree that irradiated food products are safe to eat.
The FDA’s page on food irradition has an informative “Debunking Irradiation Myths” inset:
Irradiation does not make foods radioactive, compromise nutritional quality, or noticeably change the taste, texture, or appearance of food. In fact, any changes made by irradiation are so minimal that it is not easy to tell if a food has been irradiated.
It also states that:
FDA has evaluated the safety of irradiated food for more than thirty years and has found the process to be safe. The World Health Organization (WHO), the Centers for Disease Control and Prevention (CDC) and the U.S. Department of Agriculture (USDA) have also endorsed the safety of irradiated food.
Earlier this week, the Herald published an article by Sue Kedgley on irradiated food. In my opinion that article is a load of unscientific scaremongering. Here are a few excerpts that appear clearly intended to be more emotive than informative:
But irradiated food is anything but fresh. It’s been exposed to radiation doses that are between three and 15 million times the strength of x-rays. The Brisbane radiation facility uses Cobalt 60 to irradiate food, a radioactive material that is manufactured in Canadian nuclear reactors, and shipped to Australia in special unbreakable steel canisters.
I visited the Brisbane irradiation facility in 2004. Boxes of food travel by conveyor belt into an irradiation “chamber”. The irradiation process breaks down the molecular structure of food; destroys vitamins in food, and creates free radicals and other “radiolytic compounds” that have never been found in nature, and whose effect on human health is not known.
Also of concern is the fact that in 2008 the Australian Government was forced to ban irradiated cat food after more than 80 cats died or became seriously ill after eating irradiated cat food.
This begs the question – if cats can die, or become ill from eating irradiated cat food, what could be the cumulative effect on humans of eating significant quantities of irradiated food? There’s no benefit to New Zealand consumers, and only risks to our growers, from imported irradiated produce.
Her comment that irradiation “breaks down the molecular structure of food [and] destroys vitamins in food” is quite at odds with the evidence that the nutritional content of irradiated foods are not changed significantly. This statement is entirely blown out of proportion, it’s like describing a papercut as having “ripped my flesh apart”.
She also doesn’t mention any of the details regarding the cat food incident, such as that their diet consisted largely or wholly of food irradiated 100-200 times as much as human food generally is, that the same food seemed to have no negative effects when eaten by dogs, or that the incident was only linked to one specific lot of one brand of cat food. How it relates to humans consuming irradiated food, if it has any implications on that at all, is not clear but her reaction is just scaremongering.
Her article appears to have been prompted by a couple of changes to the regulations that are being considered:
FSANZ is currently assessing Application A1092 seeking permission to irradiate twelve specific fruits and vegetables. A call for submissions on our assessment is expected to be released in the second half of 2014.
FSANZ plans to start work on recommendation 34 (that the requirement for mandatory labelling of irradiated food be reviewed) later this year.
Here’s a link to Application A1092. That page specifies the 12 fruits and vegetables involved as apple, apricot, cherry, nectarine, peach, plum, honeydew, rockmelon, strawberry, table grape, zucchini, and scallopini (squash).
Ms Kedgley describes these potential changes as:
the Government is about to approve the importation of irradiated apples, peaches, apricots and nine other fruit and vegetables from fruit fly-infested Queensland.
If they succeed, retailers will be able to sneak irradiated produce into the food chain, and it will be sold, unlabelled, as if it was “fresh”.
Surely consumers have a right to know whether the apples they are buying are fresh, or have been imported from Queensland and exposed to high doses of radiation to sterilise them and kill off potential fruit fly lava?
Looking at the IHS for fresh fruit and vegetables (direct PDF download), you can see that honeydew, rockmelon, strawberry, grape, zucchini, and scallopini are already included, they just aren’t yet allowed to be treated via irradiation. As far as I can tell the others – apple, apricot, cherry, nectarine, peach, and plum – can’t currently be imported from Australia.
Given that the entire function of irradiating food is to kill unwanted organisms such as Queensland fruit fly larva, I think it seems disingenuous of Ms Kedgley to repeatedly refer to it as though allowing these products in will bring Queensland fruit fly to New Zealand. The reason why we can’t currently import these products is because of that fly, but allowing them to be treated by irradiation would let us safely import them.
On the issue of labelling, this seems to be a very similar issue to compulsory labelling of genetically modified foods and foods containing genetically modified ingredients (this is currently mostly compulsory in New Zealand). In that case, as with food irradiation, opposition generally seems to be driven by idealogical issues with the technology used or misinformed beliefs that it’s somehow unsafe, even though it’s entirely safe. It’s effectively a lose/lose situation – if labelling isn’t mandatory then “What are they trying to hide?” but if it is mandatory then “They wouldn’t have to put it on the label if it wasn’t bad for you”.
If you want to oppose the addition of those 6 new fruits to the list of foods that can be imported from Australia on the basis of supporting New Zealand farmers then okay, that’s a different argument altogether that has nothing to do with irradiation. There doesn’t seem to be much reason to oppose this on grounds that irradiated food may be unsafe to eat though.
Foods are not allowed to be irradiated unless they have been through a pre-market safety assessment process conducted by FSANZ
Given that irradiated food doesn’t appear to be unsafe, is there really any reason to keep labelling of irradiated food compulsory? If anything, isn’t compulsory labelling most likely to make people think that means it’s bad or unsafe when it isn’t? If it’s all about allowing consumers to make informed decisions, that would be rather counterproductive.
I’m lucky enough to know someone who’s a food scientist. Claire Suen has an MSc in Food Science from the University of Auckland, and I contacted her to ask for her thoughts on the process of food irradiation. Here are some of the things she had to say in response to some of the common arguments opposing food irradiation:
[Irradiation] changes the nature of food: carcinogenic, loss of nutrients etc.
So does cooking, burning toast, deep frying, etc. Irradiation causes minute changes to the food and some loss of nutrients such as vitamins, but these have all been thoroughly researched and the results are readily available. In short, no significant changes to the food have been found.
Regarding the lost of nutrients, I usually point out to people that this is negligible considering the nature of the food.
FSANZ have published some comprehensive risk assessment reports in the past, and using the latest report on tomato as an example:
Nevertheless, even assuming an upper estimate of vitamin A and C loss of 15% following irradiation from all fresh tomatoes, capsicums and tropical fruits (with existing irradiation permissions), estimated mean dietary intakes of these vitamins would decrease by 2% or less and remain above Estimated Average Requirements following irradiation at doses up to 1 kGy, with dietary intake typically derived from a wide range of foods.
The impact of cooking and storage time on nutrients in food is far more severe than the effects of irradiation.
Here’s a link to that FSANZ report on Irradiation of Tomatoes & Capsicums (direct DOC download)
There are better alternatives
Irradiated food saves cost for the manufacturers/importers/supermarkets because it eliminates otherwise costly alternatives.
Methyl bromide for example, is not 100% effective against insect eggs and larva, particularly if they are buried inside the fruit or seed. Storage pest such as beetles and weevils are extremely difficult to control and often need a combination of methods such as heat treatment, and fumigation. For herbs and spices, irradiation can be used to control pathogens such as salmonella and E. coli. No other method is as effective. But because consumers in NZ are against it, we have to use methods such as steam sterilisation and heat treatment, which impacts on the flavour and quality of the product. Consumers sometimes do not understand the amount of work MPI and the importers have to do to make sure foreign organisms do not get in the country. All it will take is a slack importer, a missed check, or an incomplete fumigation. What of the products that have to be destroyed due to microorganism contamination, or spoilage? If they had been irradiated, this wastage wouldn’t happen.
We don’t need irradiation since we can just buy local products
Unfortunately NZ is a small country and we have limited produce. I’m not saying we can’t get by without EVER importing anything, but, it seems to me that these people don’t realise just what the consequences are. Sure, we don’t have to import apples, or nectarines, but what about the tropical fruits not grown locally? Or spices? Let’s not eat fresh mango again, or curries, since pepper used to be worth its weight in gold because it’s not grown in Europe. We can’t get away from importing and by not using irradiation, NZ business have to use more costly, and less effective alternatives, which means all these cost are passed ultimately onto the consumers. I understand people’s concern that this will hurt local producers, but that is a question of economy and has nothing to do with the safety of irradiated food.
Now coming to the question of labelling
Unfortunately, it’s a no-win situation. If we label then consumers will think something is wrong with it, if we don’t label it’s as if we are hiding something. There is simply no way to beat that logic. In my opinion, if we don’t label products which have been heat treated, or fumigated, then we shouldn’t need to label for irradiation. But because consumer backlash is so strong, I wouldn’t want to give haters a chance to play the “Ah ha you are hiding something” or “give me my freedom of choice” card.
I say let’s put irradiated fruits on the shelves and label it as such so I can chose to buy it because it will be cheaper and better!
I think that last point says it all really. As a food scientist, Claire is quite familiar with the topic of food irradiation, and she would choose to preferentially buy irradiated food because she understands the process to be safe, effective, and not detrimental to the food.
I’ve written a couple of times in the past about ACC and Acupuncture:
To summarise, in 2014 a couple of Official Information Act (OIA) requests to ACC uncovered information about how much they had spent on acupuncture treatments over the past decade, as well as a more detailed breakdown of how much was spent on acupuncture used for different categories of injury (the detailed breakdown also included data for 2013/2014).
Information released in parliament in 2004 also revealed how much money ACC spent on acupuncture in the decade from 1994-2004, as well as projections on how much they expected to spend on acupuncture from 2004-2009.
As you can see from the chart below, their projections turned out to be rather inaccurate, and ACC spending on acupuncture has been absolutely booming:
In August, I submitted my own OIA request asking for:
copies of or links to all literature reviews regarding the effectiveness of acupuncture for any condition undertaken by ACC
I was told that:
There are only two ACC literature reviews on the efficacy of acupuncture.
- Pragmatic Evidence Based Review: The efficacy of acupuncture in the management of musculoskeletal pain (2011)
- Brief Report: Effectiveness of acupuncture in selected mental health conditions (2014)
It was with this information that I wrote my previous two posts on this topic. Here are the important parts of those reviews’ conclusions:
The evidence for the effectiveness of acupuncture is most convincing for the treatment of chronic neck and shoulder pain. In terms of other injuries, the evidence is either inconclusive or insufficient.
There is limited good quality evidence to conclusively determine acupuncture’s efficacy in treatment of mental health conditions such as Major Depressive Disorder, Dysthymia, Anxiety Disorder, Borderline Personality Disorder and Post Traumatic Stress Disorder.
When I went to write on this topic again last year during “Acupuncture Awareness Week”, I found two more ACC literature reviews on the efficacy of acupuncture (as well as other treatments) on the ACC website:
- Managing Soft Tissue Ankle Injuries (2002)
- Traumatic Brain Injury: Diagnosis, Acute Management and Rehabilitation (2006)
On the topic of acupuncture, these reviews concluded that:
The evidence is either weak or absent for:
current evidence does not support the use of acupuncture to treat people with [Traumatic Brain Injury].
Feeling rather frustrated that ACC’s response to my earlier request (which arrived less than 2 weeks before last year’s September election) was apparently false, I sent a more specific followup:
I would like to reiterate my request to be provided with copies of or links to all literature reviews regarding the effectiveness of acupuncture for any condition undertaken by ACC. For the sake of clarity, I would like to be explicit that this includes both reviews that looked at several treatment options including acupuncture, and reviews that were commissioned by ACC as well as those directly undertaken by ACC.
I hope anyone reading this would agree that this followup should absolutely not have been necessary, and all the information I was requesting here should have been provided in ACC’s response to my original request before they’d be breaking the law.
However, when ACC finally acknowledged my request over a week after having received it, they maintained that “the information provided to [me] on 3 September 2014 was complete” and that this was therefore a new, separate OIA request. Because of the break over summer, this gave them until the 20th of January to respond to my request.
At 4 o’clock in the afternoon on the 20th of January, I heard back from ACC with an answer that essentially felt like “find the information yourself, it’s online”. Instead of providing me with copies of or links to any reviews, they told me the name of one review commissioned by ACC and that it could be found online, and provided me with 2 links to pages on their website that listed all of their reviews.
Interestingly, although I don’t believe the 2011 review has been released except in response to an OIA request, it was not mentioned in ACC’s response and they told me that:
ACC does not hold any other information that has not been published.
Having taken some time to go through all the reviews found on the pages I was linked to in order to find all those which mention acupuncture, I came up with the following list. As well as a link to the review and its title and date where I could find one, I am quoting the relevant conclusions below.
Brief Report: Effectiveness of acupuncture in
selected mental health conditions (2014)
There is limited good quality evidence to conclusively determine acupuncture’s efficacy in treatment of mental health conditions such as Major Depressive Disorder, Dysthymia, Anxiety Disorder, Borderline Personality Disorder and Post Traumatic Stress Disorder.
Considered Judgement Form: Effectiveness of acupuncture in selected mental health conditions (2014)
There is limited and heterogeneous evidence of effectiveness of acupuncture in depression… The evidence base [for anxiety] is small and varies greatly in terms of methodological rigour and comparability and the published literature is limited to very few good quality RCTs… There is limited evidence about the effectiveness of acupuncture in PTSD
Distal Upper Limb: Guidelines for Management of Some Common Musculoskeletal Disorders
Unknown effectiveness (conflicting evidence of efficacy or absence of evidence; methodological concerns with research/insufficient data to date):… Acupuncture
While acupuncture and ginkgo biloba have respectively been demonstrated in two small, separate randomised clinical trials to provide statistically significant effects on the frequency of RP attacks, use of these therapies is not recommended in these guidelines, on account of the absence of any further followup studies investigating these interventions.
New Zealand Acute Low Back Pain Guide (2004; apparently superceded by more recent evidence but this appears to be ACC’s latest guide on this topic?)
Evidence of no improvement in clinical outcomes… Acupuncture
Traumatic Brain Injury: Diagnosis, Acute Management and Rehabilitation (2006)
Evidence on the use of acupuncture for post-TBI symptoms is scarce and inconsistent. Therefore, current evidence does not support the use of acupuncture to treat people with TBI.
The Diagnosis and Management of Soft Tissue Knee Injuries: Internal Derangements (2003)
No recommendations can be made about the use of acupuncture, chiropractic, osteopathy or other complementary therapies for the treatment of soft tissue knee injuries due to a lack of good quality evidence.
The Diagnosis and Management of Soft Tissue Shoulder Injuries and Related Disorders (2004)
There is some evidence that exercise and acupuncture, compared with exercise alone, may lead to better outcomes.
Effectiveness of acupuncture for the treatment and rehabilitation of accident-related muskuloskeletal disorders: A systematic review of the literature (2002; Undertaken by New Zealand Health Technology Assessment)
Given the very small number of eligible RCTs identified, and their heterogeneity, it is not possible for this review to reach any strong conclusions about the effectiveness of acupuncture for the treatment and rehabilitation of musculoskeletal injuries.
Pragmatic Evidence Based Review: The efficacy of acupuncture in the management of musculoskeletal pain (2011)
The evidence for the effectiveness of acupuncture is most convincing for the treatment of chronic neck and shoulder pain. In terms of other injuries, the evidence is either inconclusive or insufficient.
Although they have told me so incorrectly in the past, I have ACC’s word that these are all the ACC literature reviews that evaluate acupuncture. As you can see, they are inconclusive or negative for all but a few specific conditions: Frozen shoulder, chronic neck pain, chronic shoulder pain.
In 2014 ACC spent $30,000 on acupuncture to treat burns, $59,000 on acupuncture for concussion and brain injury, and $591,000 on acupuncture for fracture and dislocation. They apparently spent $22,592,000 on acupuncture for soft tissue injuries, but I find it highly unlikely that all of this money was used to treat frozen shoulder, chronic neck pain, and chronic shoulder pain.
ACC’s expenditure on acupuncture shows no sign of slowing. It grew 17% from 2011/12 to 2012/13, then a further 17% from 2012/13 to 2013/14, leaving the expenditure for 2013/14 at over $24,000,000. It’s certainly not a large part of ACC’s total expenditure, but it’s no small sum of money.
ACC is publicly funded. Publicly funded healthcare should be based on rigorous evidence. ACC does not appear to have evidence that would allow them to conclude that acupuncture is an effective treatment for any more than these conditions. It is well past time for ACC to re-evaluate their expenditure on acupuncture. It should only be funded when used to treat conditions in a way that is supported by rigorous evidence, and that is certainly not the case currently.
I will end this post the same way as I have ended my previous posts on this topic, with my recommendations for how ACC should deal with this issue:
I think ACC needs to review its funding scheme for acupuncture. I think their approach to this should start with reviewing their Acupuncture Treatment Profiles document, ensuring that the only treatments contained within it are those supported by rigorous evidence, and purging pseudoscientific claims from it. If they find they need to undertake further reviews of the evidence for the use of acupuncture for particular indications, then they should do that before approving funding for it.
I think ACC should then only agree to pay for acupuncture treatments that are aligned with their Treatment Profiles document, which they should commit to reviewing at regular intervals to keep it in line with the latest evidence (I’m not sure what time interval would be most appropriate, and I understand that there is a cost involved in that work).
I’m not sure, but it’s possible some changes to legislation may be required before this becomes a reality, but if that’s the case those changes should happen. A government body should not be bound by law to fund healthcare that is not supported by evidence.
There’s one last thing I’d also like to see, although I really feel like this is a long shot. I think ACC should take an active role in discouraging healthcare practice based on the “pre-scientific notions” described in their 2011 review. I think they should do this by distancing themselves from those acupuncturists who promote it and who base their practice on it, by refusing to grant them status as registered ACC practitioners if they are found to rely on it.
Ever since I was a child, I’ve spent my summers at Oakura Bay. It’s a really lovely beach on the east coast of New Zealand, about 3 hours’ drive north of Auckland. My father’s family has been coming here since he was a child, and for the past 16 years we’ve been lucky enough to have a fantastic bach here.
One of my favourite things at this bay is the fantastic rocks. Near our end of the beach, there is a rocky peninsula accessible only at low tide, and it’s an absolute treasure trove.
Last night I had a really interesting conversation about the stuff I found there with fellow Sciblogger Victoria Metcalf, prompted by one of her tweets about what she and her daughter had found around a similar set of rocks:
One thing I’ve got in the habit of doing in my trips to the rocks is collecting any paua shells I found. In order to carry them more easily, I’d stack them together to hold in one hand, and I ended up quite enjoying how that looked so developed a habit of it. Here are some stacks I’ve collected that we keep on a windowsill back at our bach:
I’ve noticed, in doing this, that some paua shells are more curved than others, which makes them very difficult to stack:
I’m really glad I mentioned this, as now I finally understand why that is:
After being encouraged by this chat we had last night, today I took my phone with me to the rocks so I could share what one of these trips is like, and perhaps find answers to a few more questions I had. Unfortunately my phone died near the end, but I’m quite happy with how much I managed to capture.
If you missed it on Twitter, here are the tweets from my trip. Unfortunately it seems Twitter compressed some of the photos a little too aggressively, so I’m afraid in some case it might be tough to see some of the things I’m trying to point out.
If you see I’ve called anything by the wrong name or if you have anything more to add, please let me know in the comments:
Oops, by “thung” I meant to say “thing”
“thus” should be “this”
I meant to say “damp” instead of “damn” here
If I were paying more attention last night, I might have remembered that Victoria had mentioned that these creatures are called chitons:
“are’of” should be “area of”