Another new miracle skin product suddenly appears on our retail shelves. Another uncritical product promotion gets a run on the ACA. There’s nothing new there, but this time ACA may have gone too far, by claiming that the product is TGA approved.
Sorry about all the acronyms in the opening splash. Just in case you’re not keeping up:
ACA = Channel Nine’s A Current Affair (It’s on between the news and Two and a Half Men.)
TGA = Therapeutic Goods Administration (Our thin line of government defense against medical quackery.)
I think we need to come up with a snappy name or acronym for that period of time between the introduction of a new miracle health product to our retail shelves, and the eventual release of data from clinical trials showing a distinct lack of the miraculous.
How about … marketer’s dreamtime? Pre-clinical flog time? Ignorance-is-bliss time? Trust-me-I’m-a-caring-kind-of-person-so-buy-this” time? What name should apply? I welcome your suggestions in the comments.
Is there a fruit or vegetable that hasn’t, at some stage, had some health giving benefit attributed to it? Did you know carrots can improve your eyesight? And alfalfa cures the pox? (Note to self: must improve research skills.)
Do the marketers of skin and health products really have our best interests at heart by bringing new products out so quickly?
Now it’s the turn of the pawpaw to be turned into a skin care product. The full weight of professional marketing is currently behind it, as seen on ACA, on Friday the 11th of March 2011. The segment can be viewed here.
Can you believe they made the Pythonesque claim of treating baldness? *head-desk*
So is there anything to this pawpaw skin cream? We must ask (based on past experience of similar products, and the all-too-obvious lack of science behind it): just what is the probability that it will work as claimed?
The TV segment on ACA included most of the red flags you’d expect from a dodgy here-today-gone-tomorrow product: testimonials, expert qualifications (i.e. “this all needs to be tested”, “it’s still early days”), the naturalistic fallacy and the obligatory backyard battler who turns out to be the product developer.
The segment (presumably for “balance”) includes a “a skeptic turned believer” (loud groan).
A quick note to ACA’s producers … if someone rates anecdotal evidence as more significant than scientific evidence, then you can’t call them a skeptic of any kind.
However let’s skip to the final moments of the segment, where ACA stated:
… and the Optiderma products have been approved by the Therapeutic Goods Administration.
[Listen below: nine seconds of audio from the ACA show.]
I assume when ACA uses the word approve they simply mean that the TGA has let the manufacturer (Optiderma) put an Aust L label on their packaging. But this is NOT an endorsement of the product.
Aust L simply means:
- The product is a listed product. It’s made the cut for things which can be sold in a pharmacy.
- The manufacturers say the product is harmless.
- The TGA are prepared to take the manufacturer’s word for this, but can’t be bothered doing any testing of their own.
This puts Optiderma products in the same group as sunscreens and many vitamin, mineral, herbal and homoeopathic products. Had the TGA actually tested the product and found that it worked, then Optiderma would be entitled to display the more stringently-applied label Aust R. This is the label given to validated prescription items and over-the counter products such as analgesics, cough and cold remedies and antiseptic creams.
The TGA’s explanation of the difference between Aust L and Aust R is here.
Over the years there have been many complaints to the TGA that the Aust L & R scheme is confusing to consumers of health products, but let’s leave that discussion for another time. It’s a whole, big, other can of worms.
What’s important is that the Aust L label identifies the product as one where the TGA does not check efficacy.
Dr Ken Harvey of Latrobe University’s School of Public Health found that the following Optiderma products have been permitted by the TGA to show Aust L on the label.
- 175847 Optiderma Activated Healing Gel
- 175848 Optiderma Burn Spray
- 175849 Optiderma Eczema Cream
So what’s wrong with ACA claiming that Optiderma products are TGA approved?
Unscrupulous promoters look for trust to gain market share, and the TGA’s Aust L label is often exploited to imply government approval. In 2007 the law was changed to try and stamp out this practice.
Section 4(6)(b) of the Therapeutic Goods Advertising Code 2007 states:
Advertisements must not contain or imply endorsement by: (i) any government agency;
With just a little internet searching it’s not difficult to establish that the TGA are actually trying to enforce this law. (See this page on the TGA website and this 2008 TGA complaints panel decision.)
One problem remains: can the ACA segment be classified as an advertisement? I’ll leave that one for readers to decide, although I would point out that advertisements generally don’t contain critical assessment. And in that regard the pawpaw skin cream segment on ACA certainly qualifies.
So how does the selection and editing process work at ACA? I’m sure there are a huge number of organisations (charitable, educational, scientific and otherwise) who would like to be able to present material on ACA. Why do we get another dodgy skin cream with testimonials and no science?
Perhaps I’m being too hard on ACA. Perhaps the throwaway line about TGA approval was just that.
Unfortunately, ACA have misconstrued a TGA listing as an endorsement before. Their report on the FatBlaster pill earlier this year ended as follows.
….and Reducta has been approved by the Therapeutic Goods Administration as a listed medicine.
[Listen below: five seconds of audio from the end of the ACA FatBlaster segment]
Where’s my magnifying glass? I think there may be some kind of pattern here.
Once again I’m hugely indebted to Dr Ken Harvey, whose tireless research made this post possible. Thanks also to someone who doesn’t want to be named. There’s nothing conspiratorial about it. They’re just shy. You know who you are.