Dear Sirs,

I feel unable to respond to your consultation on ‘patient information’ on the point-by-point basis proposed. But I do wish to register the strongest objections to your plans, not least for the reasons explained in the statement you have received from the consortium of eleven European organisations, led by ISDB, MiEF, HAI and AIM, also in papers from the Picker Institute and others.

From a health perspective, the proposal to expose people to more and more disease awareness messages from pharmaceutical companies seems destitute. It is especially unacceptable that DG Enterprise & Industry should be trying to legalise direct-to-consumer promotion of prescription drugs, yet again by dressing it up as a proposal to liberate consumers with better drug information.

The Commission’s proposals stand for principles that, after 30 years of professional engagement in this field, I have learned to abhor. An abbreviated Curriculum Vitae is attached at Appendix Two.

As a prescription for health, this consultation exercise seems essentially cynical. The main objective of DG Enterprise and Industry (DGEI) is to promote European trade and economic development. That is a legitimate interest in its own right, but it presents grotesque conflicts of interest when it comes to shaping health policy – and these proposals exemplify them. DGEI greatly over-estimates the support they deserve, no doubt partly in the expectation of strong backing from the industry-funded patient groups that it has traditionally promoted and preferred.

The consultation document lacks any coherent health impact assessment. Its proposals further blur the distinction between high and low quality information, and take no account of the health impact of the far greater quantities of partial information to which people will now be exposed. That is a crucial omission.

Professional judgment underpins my fear that the longer-term impact of these proposals will be to damage health and beckon Pharmageddon. See Appendix One. It is of great concern that the European Commission should so vigorously and uncritically promote the cause of an industry whose behaviour is routinely seductive, deceptive, manipulative and grasping, and whose output of useful new drugs is low and in decline.

The activities of the leading pharmaceutical companies – all deeply engaged with DGEI - mainly distract from the health problems we face. Medicinal drugs are of course sometimes extremely valuable – but can only ever be a small part of the effective solutions we need. Real health grows from the roots up, not from cabals down.

Europeans need to take personal responsibility for their own health, and to understand how much it depends on the health of local and global community. DG Enterprise & Industry completely fails to appreciate that you paralyse the healthy human response, once people come to believe that their genes, body chemistry, and social and cosmetic camouflage are key to developing health and well-being. These proposals take absurdly for granted the benefits of technological and medical intervention

People can never take responsibility for health if bombarded with disease awareness propositions - relentless reminders of their vulnerability, with the promise of drug solutions always to hand. This drive to medicalisation not only makes people feel resourceless and ill; it also threatens the very existence of national health services, by creating unsustainable demand.

What do these proposals have to offer in terms of promoting clear and general understanding of the real benefits, risks and harms that come from pharmaceutical interventions? Possibly one step forward; probably three or more steps back.

Health is basically to do with eating sensibility and sufficiently, taking enough exercise, avoiding toxic exposures, and social security and justice. Disease awareness propaganda diminishes these imperatives and makes the situation worse. Medicines have their place, but it is folly to promote them as if they were the bedrock of health development and the key to maintaining good enough levels of personal confidence, social equilibrium and mental and physical health.

These dismal and potentially dangerous proposals from DG Enterprise seem to me a portent of the health chaos that the European leadership on medicines might first precipitate and then hopelessly fail to contain.

I would be happy to further explain and justify these observations, if required.

Yours faithfully

Charles Medawar
Executive Director
Social Audit Ltd
P O Box 111
London NW1 8XG

Charles Medawar
3 April 2008


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