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Taking care of a loved one with terminal lung cancer is an exercise in both the profound and the mundane. You attend heart-wrenching doctor visits discussing whether a blast of radiation might ease the pain of metastasis to the pelvis or whether we should increase the nebulizer treatments to alleviate her extreme shortness of breath. You shop for small items she needs, each designed to make life just a bit less uncomfortable: dry-mouth mouthwash, socks with no-slip treads on the soles, oatmeal raisin cookies to perk up a sagging appetite.

So it was last week that I found myself with both the profound and the mundane on my to-do list for the day. In the profound column: Meeting with my mother’s “care team” at the skilled nursing facility: nurses, a dietician and social workers in whose hands I must entrust her day-to-day care. On the mundane side: Going by a CVS Pharmacy to pick up some eye drops. Whether due to Tallahassee’s abundance of pollen, or the 24/7 oxygen she must breathe to stay alive, or the side effects of furosemide (the diuretic she must take to relieve fluid buildup), my mother suffers from dry, itchy, red eyes. The Hospice nurse suggested allergy eye drops to relieve these symptoms.

As I searched the CVS aisle, my eyes landed on a line of drops from Similasan, a company unfamiliar to me. Allergy eye drops were among Similasan’s several eye remedy product choices, which were themselves but one brand in a sea of eye drops, including CVS’s store brand, injected into a row of Similasan. Because I was in a hurry to visit my mother prior to meeting with the care team, I almost grabbed the Similasan box and headed to the checkout. But the words “natural ingredients” on the label set off my skeptical antennae. I picked up both the Similasan and CVS brand eye drops to compare.

And right there, printed on both boxes, was a word I knew well, and not for good reasons: “homeopathic.” I was stunned. In my rush, I had almost bought a homeopathic remedy. And I was angry. What if I had not noticed? What if my mother had used the eye drops, which would have given her no relief from the small misery, among many larger ones she suffers daily, of irritated eyes? What of other consumers, who don’t know any better?

I found, on a shelf just below this plethora of homeopathic eye drops, “conventional” allergy eye drops and made my way to the checkout counter, where I told a very nice young man (Albert, according to my receipt) what I thought of CVS selling homeopathic remedies, displaying them right along real eye drops to boot. He was profoundly apologetic and said I could call 1-800-SHOP-CVS to complain if I wished.

So I did. I will say this for CVS: they must put their complaint department employees through their paces in training them to handle irate consumers. The very nice woman (Jessica) on the phone listened politely while I expounded on homeopathic remedies, including the fact that CVS was well aware they don’t work and the confusion caused when they are sold next to “conventional” versions of the same product. I told her of my concern that my mother might have suffered unnecessarily had I purchased the homeopathic eye drops and that I planned to file complaints with the Federal Trade Commission (FTC), the Florida Department of Agriculture and Consumer Services and the Florida Attorney General. She took my name and number in case CVS wanted to “reach out” to me. (They have not.)

What I almost bought

Similasan is a Swiss homeopathic remedy manufacturer. According to the label, Similasan’s allergy eye drops contain,

  • Apis mellifica 6X
  • Euphrasia officinalis (Eyebright) 6X
  • Sabadilla 6X

“Apis mellifica” are honey bees. Yes, honey bees. The other ingredients are plants. [Inactive ingredients: borate buffer, purified water, silver sulfate (preservative), sodium nitrate.]

The meaning of “6X” is not explained. The label says:

Active ingredients are manufactured according to homeopathic principles.

The label also tells consumers:

according to homeopathic principles the active ingredients in this product temporarily relieve minor eye allergy symptoms such as: itching, burning, excessive watering, redness of eyes and lids.

What are these “homeopathic principles?” Similasan’s website tell us:

Similasan products stimulate the body’s natural defenses by utilizing microdilutions of natural active ingredients . . . (originating from minerals, plants or animals) [which] undergo a process of serial dilutions. . . . [A]n ingredient diluted to the level of 6X contains 0.000001% of the active ingredient. This homeopathic mode of action is similar in theory to a conventional allergy or flu shot, yet the natural active ingredients in homeopathic products are much more diluted. . . . Your body’s immune system reacts to the ingredients by triggering the immune system to react to the underlying problem. For example, a microdilution of honey bee will trigger the body to fight symptoms such as burning, stinging and swelling, which are in many cases the symptoms of allergy. . . . In other words, homeopathy encourages the body to maintain proper health by imposing a gentle stimulus, and letting your system do the rest.

“In other words,” pure bunkum. Pseudoscience. Pre-scientific nonsense. Quackery. Fraudulent misrepresentation. Just yesterday, SBM guest blogger Craig D. Pearcey explained why the proposed mechanisms of action for homeopathy are, to use a scientific term, hogwash. [And, no, the proposed mechanism of action is not “similar in theory” to allergy and flu shots.] It’s a topic we’ve covered many times here on SBM.

Given the implausibility of homeopathy itself, it seems superfluous to discuss the ingredients in Similasan’s allergy eye drops. Nevertheless, I could find no evidence that killing and crushing honey bees and diluting them until one bit of bee is left knocking about in one million parts of inert substance is effective for anything other than further decimating their ranks. Their inclusion in homeopathic remedy lore is apparently based on the “like cures like” pseudo-theory:

The very characteristic effects of the sting of the bee furnish unerring indications for its employment in disease. Swelling or puffing up of various parts, EDEMA, red rosy due, stinging pains, soreness, intolerance of heat, and slightest touch, and afternoon worse are some of the general guiding symptoms.

Other indications for use “according to homeopathic principles:”

  • Jealous, fright, rage, vexation, grief
  • Stupor, with sudden sharp cries and startings
  • Awkward; drops things readily
  • Bores head into pillow and screams out
  • Coldness of tip of nose

Euphrasia, or eyebright, is an herb traditionally used for conjunctivitis and other eye inflammation. Natural Medicines Comprehensive Database finds it has “insufficient reliable evidence to rate” for conjunctivitis and “possibly unsafe” for use as an ophthalmic. Of course, when diluted to one part per 1,000,000 “according to homeopathic principles,” the evidence dissipates accordingly.

The sabadilla lily is a poisonous plant formerly used as a pesticide and for lice. The risk of fatality, however, is no bar to homeopaths. According to the National Center for Homeopathy, among sabadilla’s “provers” is none other than the father of homeopathy himself, 18th century physician Samuel Hahnemann. The Center’s poetic description of symptoms indicating one part sabadilla to 1,000,000 parts water is just what the doctor ordered include:

  • As if abdomen were shrunken, were empty.
  • Croaking as of frogs in the abdomen.
  • As if stomach were gnawed.
  • As of a thread or string in throat.
  • As if articulation were suspended.
  • As if tape prevented circulation in chest.
  • As if interior of bones were scraped out with a sharp knife.
  • As if hot breath came out of his mouth and nose.
  • As if everything were in motion.
  • As if the air itself were in tremulous motion.
  • As if he had taken wine.
  • Shaking as if in a severe chill.

CVS’s own brand of homeopathic “irritated eye drops” are not listed on the company’s website. I called CVS and was assured that they had not been discontinued. In fact, the company rep told me there were six bottles in stock at the very CVS where I had my unfortunate encounter with their product. According to the label, CVS’s “irritated eye drops” are “safe and effective” at “relieving redness, watery discharge, burning, grittiness, dryness & stinging.” They contain:

  • Belladonna 6X
  • Euphrasia 6X
  • Helpar sulphuris 12X

Belladonna, a toxic substance, is the same ingredient that caused the FDA to warn against using homeopathic teething remedies. Helpar sulphuris, diluted to 1 part per 1,000,000,000,000, is,

the inner layer of Oyster shells combined with flowers of sulfur and burned.

According to “homeopathic principles,” helper suphuris, among other things,

suits especially scrofulous and lymphatic constitutions who are inclined to have eruptions and glandular swellings. Unhealthy skin. Blondes with sluggish character and weak muscles.

What I’m doing about it

Science Babe generated some bad PR for CVS when she downed a 50-pill bottle of Hyland’s Calms Forte in a social media campaign to get the retail pharmacy giant and other retailers to stop selling worthless homeopathic remedies. CVS shrugged that effort off by essentially saying “everyone’s doing it” and “it’s legal.” (Fortunately, this sort of lame excuse did not prevent CVS from halting cigarette sales a few years ago in a much-lauded decision.)

True to my word, I’ve filed a complaint with the FTC and the Florida Department of Agriculture and Consumers Services against CVS and Similasan. I am in the process of filing a complaint with the Florida Attorney General.

Under federal law, deceptive labeling of OTC drugs is illegal. According to the FTC,

companies must have a reasonable basis for making objective product claims, including claims that a product can treat specific conditions.

The FTC announced just a few months ago that it will hold homeopathic remedy advertising claims to the same standards as similar claims for conventional OTC drugs. (The Society for Science-Based Medicine was pleased to see its comment to the FTC on homeopathic remedy regulation mentioned in the staff report leading to the FTC’s decision.) This means claims of effectiveness, including claims that a product can treat symptoms, must be backed by “competent and reliable scientific evidence,” usually “well-designed human clinical testing.”

The FTC’s enforcement policy states:

For the vast majority of OTC homeopathic drugs, the case for efficacy is based solely on traditional homeopathic theories and there are no valid studies using current scientific methods showing the product’s efficacy. Accordingly, marketing claims that such homeopathic products have a therapeutic effect lack a reasonable basis and are likely misleading in violation of . . . the FTC Act.

If there is no competent and reliable scientific evidence supporting a product’s claims, the FTC won’t automatically consider the labeling deceptive if the company plainly states there is no scientific evidence that the product works and that the claims are based on theories from the 1700s that are not accepted by medical experts.

In my view, neither the Similasan nor CVS brand eye drops meet the FTC’s test and are therefore deceptive. There is no competent and reliable scientific evidence supporting their claims, but consumers aren’t told this. There is no explanation that “homeopathic principles” are bogus. There is no explanation of what “6X” or “12X” means. In my opinion, they are being marketed in violation of federal law.

Under Florida law, the Attorney General can bring a declaratory judgment action against, and seek to enjoin, a company from engaging in unfair and deceptive trade practices and seek a fine of up to $10,000 per violation. Because I did not actually rely on their false claims and purchase the products, I could not bring an individual action for deceptive and unfair trade practices based on state law. That does not prevent me from filing a complaint asking the Attorney General to take action. Under Florida law, interpretations of the FTC Act by the courts and the FTC itself are given great weight. Hence, I anticipate that the FTC’s new policy on homeopathic remedy marketing will be followed by the Attorney General.

I look forward to working with these agencies in pursuing state and federal law claims against Similasan and CVS.

And another thing

CVS and Similasan shouldn’t be scamming consumers with nonsensical remedies. But they had plenty of help stocking the shelves with their worthless products:

Without the support of Congress, the inertia of the FDA, and enthusiasm from certain quarters of the mainstream medical community, homeopathy would be relegated to the backwaters of naturopathic quackery and fringe MDs who practice homeopathy, or illegal even, instead of a multi-billion dollar industry.

I’ll end where I began: my mother has terminal cancer. She is on oxygen 24/7. She breathes with difficulty, sometimes great difficulty. Her body swells with fluid retention. She cannot walk without assistance and, even then, it exhausts her. She is nauseated. She has lost her appetite. And she has dry, red, itchy eyes. There are other discomforts, but I’ll stop there.

We – her family, Hospice, the nursing and other staff, her physicians – are doing all we can to relieve those symptoms, to keep her as comfortable as possible. At this point, it’s all we can do. But CVS and Similasan, and all those who support homeopathy, think it’s perfectly OK to deprive her one small comfort: relieving her troublesome eye symptoms. When I tried to help her, they wanted to scam me by selling me their worthless products, which are craftily displayed right alongside real remedies. They would prefer that we drop crushed honey bees and belladonna in her eyes. Shame on them. Shame on all of you who promote homeopathy.

Posted by Jann Bellamy

Jann J. Bellamy is a Florida attorney and lives in Tallahassee. She is one of the founders and Board members of the Society for Science-Based Medicine (SfSBM) dedicated to providing accurate information about CAM and advocating for state and federal laws that incorporate a science-based standard for all health care practitioners. She tracks state and federal bills that would allow pseudoscience in health care for the SfSBM website.  Her posts are archived here.