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Un-Controlled Quackery all over the Country.

An Update
By,

Dr.Abdul.Ghafoor Shoro

PMA Anti Quackery Sub. Committee Karachi.
Quackery.
• How Should It Be Defined?
• Quackery can be broadly defined as "anything involving
over promotion in the field of health.“
• A quack is an untrained person who pretends to be a
physician and who dispenses medical advice and they
claim to be properly qualified doctors.
• The FDA defines health fraud as “The promotion, for
profit, of a medical remedy known to be false or
unproven”.
STATISTICS
According to PMDC REGISTERED doctors UP TO 27th September, 2012
TOTAL NUMBER OF DOCTORS / DENTAL SURGEONS (G.P's with basic degree only)
Province

M.B.B.S.
Male
Female

Punjab/
28456
Federal Area
Sindh
28260
K.P.K
10110
Balochistan.
2351
A.J.K.
1394
Foreign
2460
Nationals

Total

73031

Total

B.D.S.
Male
Female

Total

24030

52486

1970

2632

4602

25208
4712
1485
954
800

53468
14822
3836
2348
3260

1473
850
172
127
317

2642
869
118
95
107

4115
1719
290
222
424

4909

6463
RDP

11372

57189
RMP

130220

L.S.M.F. (Licentiate of State Medical Faculty)
Male
Female Total
511
284
52
44
3
98

992

54

565

22
2
11
1
8

306
54
55
4
106

98
LSMF/LDS

1090

TOTAL=130220+11372+1090= 142682
•
•
•
•
•

TOTAL LSMF
TOTAL RMPs (Basic & Specialists)
TOTAL RDPs (Basic & Specialists)
GRAND TOTAL=
GRAND TOTAL=

158075
RMP

=(130220+27855)
=(11372+913)
+12285
+1090
+RDP
+LSMF

=1090
=158075
=12285
=171450
Current Situation.
•
•
•
•

According PMDC anti quackery committee:
600000 Quacks in Pakistan .
1/3rd in Sindh.
70000 -80000 in Karachi.

• TOTAL NUMBER OF DOCTORS/DENTAL SURGEONS
REGISTERED Up to 27th September, 2012 .

• Doctors
=
• GRAND TOTAL=

158075
RMP

+12285
+RDP

+1090 =171450
+LSMF Total

(L.S.M.F stands for Licentiate of State Medical Faculty)
Types of quacks
1.Dispensers.
• These are the commonest and most dangerous type
of quacks in our country.
• They may or may not have a technician's diploma.
They usually have served for a while with a doctor
to assist him in his clinic usually for 3 tasks.
1. Giving injections and I/V fluids to patients.
2. Giving medicines to the patients on doctor's
prescriptions
3. Carrying out minor dressings and stitching.
2.LHV’S /LHW’s .
• There are so many Maternity homes and Clinics run by LHV’S and
LHW’s in rural areas and Peripheral areas of cities.
• They claim as a qualified lady doctors.
• Lady Health Visitors(LHV’s):
• Job Description. They are responsible for preventive and curative
care with a focus on Family Planning (FP).
• Assist the clients to make their decisions based on their family
planning needs after providing thorough counseling.
• Lady Health Workers. (LHW’s) are working under the National
Program for Family Planning and Primary Health Care. It was
launched in Pakistan in 1994.
• Education . Mostly 8th Class education • Job Description. Visiting the homes of her community - registering
pregnant women for antenatal care, health education and basic
preventive services for family planning, maternal and child health,
improving nutrition, basic hygiene ,sanitation and immunization.
3.Street Doctors Or Hakeems.
• This is another category of quacks in our
community ,Street Doctors Or Hakeems.(Gali
Mohalay ka Doctor)
• These are usually found in every house and if not
then at least in every street.
• They have never received any formal health
education but they seem to know every thing about
every illness including Cancer, HIV ,AIDS, Hepatitis,
and Diabetes etc.
4.Aamils and Jinnati babas.
• This is a totally unique category of practitioners in our
culture. These derive their roots from the ancient evil
arts of magic and related categories. Some of them put
a veil of Islamic face on their malpractices.
• They usually exploit the psychiatric illnesses of the
category usually encountered in young girls from lower
or middle class of our society.
• These People also treat infertile couples with a promise
of giving them off springs at certain high costs.
5.Sex Experts.
• Last but not the least this is another commonly
encountered category of quacks. We can witness a
very strong advertising campaign by these experts
throughout our country by various methods.
• Unfortunately our print media is also used at times
by these quacks to get their advertisements across
to the public.
• Usually they resort to wall chalking, banners, sign
boards, brochures and wall posts in addition to
hired agents who are utilized to spread the success
stories of their miraculous cures.
Why does quackery 'work' for some people

?

•

Quackery thrives on susceptibility. We are all susceptible at certain times in our lives. Anxiety and fear can be
so strong that reason gives way to false hope or an unsuspecting person may simply be enticed by catchy
advertising and convincing personal testimonials.

•

The two main reasons why a quack product might seem to "work" are:

•

A placebo effect — Placebos have no active ingredients. They may work on the power of suggestion. Scientists
speculate that a person's confidence in a certain treatment may activate chemical impulses in the brain that
diminish symptoms. It is estimated that 10% to 20% of persons are very responsive to placebo treatments.

•

A self-limiting illness — Diseases vary in their duration and intensity. Arthritis, for instance, can be a life-long
problem whose symptoms may improve for periods of time. If you happen to be using a quack treatment when
pain subsides, it's natural to think that the "wonder cure" really helps. Colds are another example of a self
limiting illness that gets better whether or not a person seeks treatment.

•

So there are two arguments in favor of letting quacks run their businesses:

1.
2.

They earn their bread and butter through this profession.
It is all about freedom. Every one is entitled to adopt whatever profession he wants.

•

Can we really afford to let them play havoc with the health and lives of our ignorant people?

•

Is there any comparison between a doctor who enters the profession after a tough competition then
learns his skill under close supervision of experts of field for many years and at immense expenses?

•

And a quack who has highly dubious knowledge about therapeutics and does not possess any valid
qualification?
The Hazards of their Practice.
• They are an important source of spread of needle
borne diseases especially viral hepatitis and HIV.
• The frequently use latest antibiotics injudiciously
and are responsible for development of resistance
against such life saving medicines.
• They frequently endanger the lives of patients
because of inappropriate use of medicines about
whose pharmacological properties they know the
least.
• Due to their vested interests and poor knowledge
they frequently spread misinformation regarding
health, disease and health systems.
Who is responsible?
Quacks.
Who deals with treatment practices in spite of the awareness of their
ignorance of proper knowledge.

Government and its Institutions .
Due to its apathy towards the social problems of our nation and its lack of
will to set the health care system right.

General public.
Due to its ignorance of modern medical knowledge and lack of effort to seek
the right professionals.

Doctors and their organizations.
Due to their passive role in the current jumble. It is their responsibility as well
to shout it loud and clear to government and masses that there must be no
place for quackery in our country.
Who is responsible?
 Pharmaceutical Companies.
Pharma: co’s. Representatives visit the Quacks and offer different
packages for prescription of their Medicine.
 Media.
Print Media as well as Electronic media(not All) are promoting the
quackery through different documentaries and ads. There are lots of
ads for fake doctors and quacks and even programs about them.
Pakistan's press and electronic media should stop illegal health
related ads, which led the people towards quacks.

 National and International NGO’S.
Due to their vested interest they recruit Quacks for their different
Health related Projects to save money.
NEW LAW AGAINST QUACKERY
Law amendment 2012
ISLAMABAD, MONDAY, AUGUST 13, 2012
PART I Law amend mended
Acts, Ordinances, President's Orders and Regulations

NATIONAL ASSEMBLY SECRETARIAT
Islamabad, the 13th August, 20/2
THE GAZETTE OF PAKISTAN"EXTRA. AUGUST 13, 2012

31. Amendment of section 28, Ordinance XXXII of 1962.In the Said Ordinance, for section 28 the following shall be substituted, namely:-'
"28. Penalty for fraudulent representation or registration.- Whoever falsely pretends to be registered under this Ordinance as a medical
Practitioner or dentist and uses with his name or title any words or letters representing that he is so registered with the Councilor uses the word
"doctor" without legal basis, irrespective of whether any person is actually deceived by such pretence or representation or not, shall, On
conviction before a Magistrate of the first class, be punishable with fine which may extend to one hundred thousand rupees or with
imprisonment for a term which may extend to six months or with both.
Any person found aiding and abetting him shall also be prosecuted and punished.".
32. Insertion of new sections 28A and 28B, Ordinance XXXII of 1962.- In the said Ordinance, after section 28, substituted as aforesaid, the
following new sections shall be inserted, namely:-

"28A. Penalty of practicing without registration.(I) No person, other than a registered medical or dental practitioner, shall practice medicine
. or dentistry.
(2) Any person who acts in contravention of the provisions of sub-section
(I) shall be punishable with imprisonment for a term which may extend to two years but shall not be less than six months or with fine
which may extend to two hundred thousand rupees but shall not be less than one hundred thousand rupees or with both.
28B. Cognizance of offences.(I) No court shall take cognizance of any offence or matter under this Ordinance except upon
complaint in, writing made by the authorized officer of the Council.
(2) Notwithstanding anything contained in the Code of Criminal Procedure, 1898 (Act of 1898), it shall be lawful for any Magistrate of the first
class to pass any sentence authorized by this Ordinance even if such sentence exceeds his powers under Section 32 of the said Code.".
Role of PM&DC.
PMDC registers bogus doctors.


After getting the bogus registration certificates, now these half-baked doctors are
doing government service and running their own clinics. Some of them are said to
have left Pakistan to get jobs abroad in the light of these bogus registration
certificates issued to them with the help of PMDC.



These candidates after failing to pass the PMDC test are said to have paid millions of
rupees to the top guns of PMDC .



Pakistan ambassador to Bishkek Tanveer A Khaskheli had written to the then president
of PMDC Prof Dr Hasnain that Kyrgyz State Medical college Academy and Osh university
had informed him that documents submitted by the Pakistanis students to get PMDC
registration were bogus and fake.

A report By Rauf Klasra. Published in Pak Tribune on 06-04-2010
The Senate Standing Committee on Health was informed on Wednesday that the
Pakistan Medical and Dental Council (PMDC) registered more than 40 doctors last
year without any formal testing.

• “The council registered these doctors without fulfilling the basic
criteria of clearing a registration examination,” Senator Zahid Khan.
• Majority of the 48 medical practitioners whose degrees have been
declared fake are serving in government-run health facilities and the
council has recommended strict action against them, said an official
of PMDC.
• The chairperson also constituted a sub-committee to look into the
matters of PMDC and suggest recommendations to streamline the
council.
Published in The Express Tribune, April 14th, 2011.
Pakistan: Fake doctors have PMDC
registration certificates
•

President PMDC Dr Asim .Hussain confirmed that he knew that at
least 30 such students were given fake registration certificates by
PMDC.
• FIA unearthed the following doctors whose files were missing from
the official record.
• The names of the doctors are Dr Shafif Ahmed, Dr Jehangir Khan, Dr
Said Wali, Dr Syed Salauddin, Dr Syed Naseemudin, Dr Ikram ullah,
Dr Sakhi Jan, Dr Rehmanullah, Dr Abrar ullah and Dr Malik Asad.
The News dated 04/06/2010
What is Needed ?
 Quackery is a society-wide public health problem it should be clearly defined .
 Laws should be implemented against unauthorized health care.
 Through our actions, we need to convey that the exploitation of sufferers should not be
tolerated by our society.
 To cope with it adequately, a more scientific approach is required.
 As with any other public health problem, an epidemiologic strategy is needed to develop
information on causal agents (which people become quacks and why) and environmental
aspects that favor or discourage the proliferation of quackery.
 Vital statistics are needed on the morbidity, mortality, incidence and prevalence of quackery.
Presently, we have only isolated case reports. These are enough to indicate that great harm
is being done, but don't tell us how many people are being harmed.
 There is need of a system be developed for reporting quackery cases, this would enable us to
keep track of what is being promoted, where the "hot spots" are, and what legal and
educational efforts are needed for an effective response.
Cont: What is Needed ?
 Health professionals have a duty to take action when the public is being abused in an area in
which they have special knowledge. The failure to take concerted action against quackery
sends an unprofessional message.

 Quackery and unauthorized health care giving should be penalized under law.
 A doubting attitude like “this may work” at official level must now be stopped forthwith.
 Only scientifically proven methods must be allowed to practice.
 We should not condone the "victim-blaming" ideology which says that if people are too
dumb to spot quackery on their own, they are probably too dumb to be worth saving.
 Nor should we condone the attitude of law enforcement officials who feel that quackery is
"merely" a form of white collar crime" that takes money from its victims.
Thank You
For your

Patience

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Quacks in action in Pakistan

  • 1. Un-Controlled Quackery all over the Country. An Update By, Dr.Abdul.Ghafoor Shoro PMA Anti Quackery Sub. Committee Karachi.
  • 2. Quackery. • How Should It Be Defined? • Quackery can be broadly defined as "anything involving over promotion in the field of health.“ • A quack is an untrained person who pretends to be a physician and who dispenses medical advice and they claim to be properly qualified doctors. • The FDA defines health fraud as “The promotion, for profit, of a medical remedy known to be false or unproven”.
  • 3. STATISTICS According to PMDC REGISTERED doctors UP TO 27th September, 2012 TOTAL NUMBER OF DOCTORS / DENTAL SURGEONS (G.P's with basic degree only) Province M.B.B.S. Male Female Punjab/ 28456 Federal Area Sindh 28260 K.P.K 10110 Balochistan. 2351 A.J.K. 1394 Foreign 2460 Nationals Total 73031 Total B.D.S. Male Female Total 24030 52486 1970 2632 4602 25208 4712 1485 954 800 53468 14822 3836 2348 3260 1473 850 172 127 317 2642 869 118 95 107 4115 1719 290 222 424 4909 6463 RDP 11372 57189 RMP 130220 L.S.M.F. (Licentiate of State Medical Faculty) Male Female Total 511 284 52 44 3 98 992 54 565 22 2 11 1 8 306 54 55 4 106 98 LSMF/LDS 1090 TOTAL=130220+11372+1090= 142682 • • • • • TOTAL LSMF TOTAL RMPs (Basic & Specialists) TOTAL RDPs (Basic & Specialists) GRAND TOTAL= GRAND TOTAL= 158075 RMP =(130220+27855) =(11372+913) +12285 +1090 +RDP +LSMF =1090 =158075 =12285 =171450
  • 4. Current Situation. • • • • According PMDC anti quackery committee: 600000 Quacks in Pakistan . 1/3rd in Sindh. 70000 -80000 in Karachi. • TOTAL NUMBER OF DOCTORS/DENTAL SURGEONS REGISTERED Up to 27th September, 2012 . • Doctors = • GRAND TOTAL= 158075 RMP +12285 +RDP +1090 =171450 +LSMF Total (L.S.M.F stands for Licentiate of State Medical Faculty)
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  • 7. Types of quacks 1.Dispensers. • These are the commonest and most dangerous type of quacks in our country. • They may or may not have a technician's diploma. They usually have served for a while with a doctor to assist him in his clinic usually for 3 tasks. 1. Giving injections and I/V fluids to patients. 2. Giving medicines to the patients on doctor's prescriptions 3. Carrying out minor dressings and stitching.
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  • 9. 2.LHV’S /LHW’s . • There are so many Maternity homes and Clinics run by LHV’S and LHW’s in rural areas and Peripheral areas of cities. • They claim as a qualified lady doctors. • Lady Health Visitors(LHV’s): • Job Description. They are responsible for preventive and curative care with a focus on Family Planning (FP). • Assist the clients to make their decisions based on their family planning needs after providing thorough counseling. • Lady Health Workers. (LHW’s) are working under the National Program for Family Planning and Primary Health Care. It was launched in Pakistan in 1994. • Education . Mostly 8th Class education • Job Description. Visiting the homes of her community - registering pregnant women for antenatal care, health education and basic preventive services for family planning, maternal and child health, improving nutrition, basic hygiene ,sanitation and immunization.
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  • 11. 3.Street Doctors Or Hakeems. • This is another category of quacks in our community ,Street Doctors Or Hakeems.(Gali Mohalay ka Doctor) • These are usually found in every house and if not then at least in every street. • They have never received any formal health education but they seem to know every thing about every illness including Cancer, HIV ,AIDS, Hepatitis, and Diabetes etc.
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  • 13. 4.Aamils and Jinnati babas. • This is a totally unique category of practitioners in our culture. These derive their roots from the ancient evil arts of magic and related categories. Some of them put a veil of Islamic face on their malpractices. • They usually exploit the psychiatric illnesses of the category usually encountered in young girls from lower or middle class of our society. • These People also treat infertile couples with a promise of giving them off springs at certain high costs.
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  • 15. 5.Sex Experts. • Last but not the least this is another commonly encountered category of quacks. We can witness a very strong advertising campaign by these experts throughout our country by various methods. • Unfortunately our print media is also used at times by these quacks to get their advertisements across to the public. • Usually they resort to wall chalking, banners, sign boards, brochures and wall posts in addition to hired agents who are utilized to spread the success stories of their miraculous cures.
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  • 19. Why does quackery 'work' for some people ? • Quackery thrives on susceptibility. We are all susceptible at certain times in our lives. Anxiety and fear can be so strong that reason gives way to false hope or an unsuspecting person may simply be enticed by catchy advertising and convincing personal testimonials. • The two main reasons why a quack product might seem to "work" are: • A placebo effect — Placebos have no active ingredients. They may work on the power of suggestion. Scientists speculate that a person's confidence in a certain treatment may activate chemical impulses in the brain that diminish symptoms. It is estimated that 10% to 20% of persons are very responsive to placebo treatments. • A self-limiting illness — Diseases vary in their duration and intensity. Arthritis, for instance, can be a life-long problem whose symptoms may improve for periods of time. If you happen to be using a quack treatment when pain subsides, it's natural to think that the "wonder cure" really helps. Colds are another example of a self limiting illness that gets better whether or not a person seeks treatment. • So there are two arguments in favor of letting quacks run their businesses: 1. 2. They earn their bread and butter through this profession. It is all about freedom. Every one is entitled to adopt whatever profession he wants. • Can we really afford to let them play havoc with the health and lives of our ignorant people? • Is there any comparison between a doctor who enters the profession after a tough competition then learns his skill under close supervision of experts of field for many years and at immense expenses? • And a quack who has highly dubious knowledge about therapeutics and does not possess any valid qualification?
  • 20. The Hazards of their Practice. • They are an important source of spread of needle borne diseases especially viral hepatitis and HIV. • The frequently use latest antibiotics injudiciously and are responsible for development of resistance against such life saving medicines. • They frequently endanger the lives of patients because of inappropriate use of medicines about whose pharmacological properties they know the least. • Due to their vested interests and poor knowledge they frequently spread misinformation regarding health, disease and health systems.
  • 21. Who is responsible? Quacks. Who deals with treatment practices in spite of the awareness of their ignorance of proper knowledge. Government and its Institutions . Due to its apathy towards the social problems of our nation and its lack of will to set the health care system right. General public. Due to its ignorance of modern medical knowledge and lack of effort to seek the right professionals. Doctors and their organizations. Due to their passive role in the current jumble. It is their responsibility as well to shout it loud and clear to government and masses that there must be no place for quackery in our country.
  • 22. Who is responsible?  Pharmaceutical Companies. Pharma: co’s. Representatives visit the Quacks and offer different packages for prescription of their Medicine.  Media. Print Media as well as Electronic media(not All) are promoting the quackery through different documentaries and ads. There are lots of ads for fake doctors and quacks and even programs about them. Pakistan's press and electronic media should stop illegal health related ads, which led the people towards quacks.  National and International NGO’S. Due to their vested interest they recruit Quacks for their different Health related Projects to save money.
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  • 25. NEW LAW AGAINST QUACKERY
  • 26. Law amendment 2012 ISLAMABAD, MONDAY, AUGUST 13, 2012 PART I Law amend mended Acts, Ordinances, President's Orders and Regulations NATIONAL ASSEMBLY SECRETARIAT Islamabad, the 13th August, 20/2 THE GAZETTE OF PAKISTAN"EXTRA. AUGUST 13, 2012 31. Amendment of section 28, Ordinance XXXII of 1962.In the Said Ordinance, for section 28 the following shall be substituted, namely:-' "28. Penalty for fraudulent representation or registration.- Whoever falsely pretends to be registered under this Ordinance as a medical Practitioner or dentist and uses with his name or title any words or letters representing that he is so registered with the Councilor uses the word "doctor" without legal basis, irrespective of whether any person is actually deceived by such pretence or representation or not, shall, On conviction before a Magistrate of the first class, be punishable with fine which may extend to one hundred thousand rupees or with imprisonment for a term which may extend to six months or with both. Any person found aiding and abetting him shall also be prosecuted and punished.". 32. Insertion of new sections 28A and 28B, Ordinance XXXII of 1962.- In the said Ordinance, after section 28, substituted as aforesaid, the following new sections shall be inserted, namely:- "28A. Penalty of practicing without registration.(I) No person, other than a registered medical or dental practitioner, shall practice medicine . or dentistry. (2) Any person who acts in contravention of the provisions of sub-section (I) shall be punishable with imprisonment for a term which may extend to two years but shall not be less than six months or with fine which may extend to two hundred thousand rupees but shall not be less than one hundred thousand rupees or with both. 28B. Cognizance of offences.(I) No court shall take cognizance of any offence or matter under this Ordinance except upon complaint in, writing made by the authorized officer of the Council. (2) Notwithstanding anything contained in the Code of Criminal Procedure, 1898 (Act of 1898), it shall be lawful for any Magistrate of the first class to pass any sentence authorized by this Ordinance even if such sentence exceeds his powers under Section 32 of the said Code.".
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  • 28. Role of PM&DC. PMDC registers bogus doctors.  After getting the bogus registration certificates, now these half-baked doctors are doing government service and running their own clinics. Some of them are said to have left Pakistan to get jobs abroad in the light of these bogus registration certificates issued to them with the help of PMDC.  These candidates after failing to pass the PMDC test are said to have paid millions of rupees to the top guns of PMDC .  Pakistan ambassador to Bishkek Tanveer A Khaskheli had written to the then president of PMDC Prof Dr Hasnain that Kyrgyz State Medical college Academy and Osh university had informed him that documents submitted by the Pakistanis students to get PMDC registration were bogus and fake. A report By Rauf Klasra. Published in Pak Tribune on 06-04-2010
  • 29. The Senate Standing Committee on Health was informed on Wednesday that the Pakistan Medical and Dental Council (PMDC) registered more than 40 doctors last year without any formal testing. • “The council registered these doctors without fulfilling the basic criteria of clearing a registration examination,” Senator Zahid Khan. • Majority of the 48 medical practitioners whose degrees have been declared fake are serving in government-run health facilities and the council has recommended strict action against them, said an official of PMDC. • The chairperson also constituted a sub-committee to look into the matters of PMDC and suggest recommendations to streamline the council. Published in The Express Tribune, April 14th, 2011.
  • 30. Pakistan: Fake doctors have PMDC registration certificates • President PMDC Dr Asim .Hussain confirmed that he knew that at least 30 such students were given fake registration certificates by PMDC. • FIA unearthed the following doctors whose files were missing from the official record. • The names of the doctors are Dr Shafif Ahmed, Dr Jehangir Khan, Dr Said Wali, Dr Syed Salauddin, Dr Syed Naseemudin, Dr Ikram ullah, Dr Sakhi Jan, Dr Rehmanullah, Dr Abrar ullah and Dr Malik Asad. The News dated 04/06/2010
  • 31. What is Needed ?  Quackery is a society-wide public health problem it should be clearly defined .  Laws should be implemented against unauthorized health care.  Through our actions, we need to convey that the exploitation of sufferers should not be tolerated by our society.  To cope with it adequately, a more scientific approach is required.  As with any other public health problem, an epidemiologic strategy is needed to develop information on causal agents (which people become quacks and why) and environmental aspects that favor or discourage the proliferation of quackery.  Vital statistics are needed on the morbidity, mortality, incidence and prevalence of quackery. Presently, we have only isolated case reports. These are enough to indicate that great harm is being done, but don't tell us how many people are being harmed.  There is need of a system be developed for reporting quackery cases, this would enable us to keep track of what is being promoted, where the "hot spots" are, and what legal and educational efforts are needed for an effective response.
  • 32. Cont: What is Needed ?  Health professionals have a duty to take action when the public is being abused in an area in which they have special knowledge. The failure to take concerted action against quackery sends an unprofessional message.  Quackery and unauthorized health care giving should be penalized under law.  A doubting attitude like “this may work” at official level must now be stopped forthwith.  Only scientifically proven methods must be allowed to practice.  We should not condone the "victim-blaming" ideology which says that if people are too dumb to spot quackery on their own, they are probably too dumb to be worth saving.  Nor should we condone the attitude of law enforcement officials who feel that quackery is "merely" a form of white collar crime" that takes money from its victims.
  • 33.