Dear Sirs,

I am writing to enquire about the possibilities and appropriate procedures for making a complaint about a registered medical practitioner, in circumstances which do not appear to be covered by the guidance given on the GMC website. I should be grateful for your advice about how to proceed, in the light of the following possibly complicating factors:

1. The complaint I seek to bring does not directly relate to standards of treatment or practice by the individual concerned. I am not a patient of the doctor in question, nor do I have reason to believe that he lacks qualities that would call into question his fitness to practice medicine in a clinical setting. My concern is about the conduct of medically qualified individuals in an institutional/organisational setting.

2. The subject of this prospective complaint is a well qualified physician who acted as the principal spokesperson for the manufacturers (his employers) of a widely prescribed antidepressant drug. I would wish to allege that, in that capacity, and on several occasions, he offered inappropriately reassuring advice about the safety profile (benefit-to-harm ratio) of that drug, in programmes broadcast on television (Panorama: BBC-TV), distributed worldwide. I would wish to allege [a] that his statements were (by omission and/or commission) inaccurate, misleading and possibly reckless; [b] that the statements he made did not reflect the evidence to which he had unique access, whether or not he availed himself of those data. (It is relevant to note here that some submissions to the UK drug regulatory authorities were made in his name); and [c] that substantial harm very probably resulted from his failure either to critically assess the evidence available to him, and/or to his presumption that there was no cause for concern.

In short, and in the light of the evidence that has since become publicly available, this man’s statements on television leave the impression that he conceived his primary duty of care to be to his employers, rather than to the many people (including health professionals) likely to have trusted his judgment as a doctor, and to have been influenced by the reassurances he gave. (Panorama has broadcast four programmes on this subject and this man was interviewed for the first two, but made appearances in all four). I believe that, in the UK, the audience for each of these programmes has been over 3.5 million viewers).

3. My status as a prospective complainant is untypical. The complaint I would wish to bring would and should be in my name - but in my professional capacity as a medicines policy analyst and reporter, with a particular interest in the marketing and effects of this (and related) medicinal products. Therefore it would also seem most appropriate to bring forward any complaint under the letterhead of the organisation (Social Audit Ltd) which employs me in this capacity.

By way of background information, I am enclosing a copy of the review posted to the Social Audit website of the Panorama programme broadcast on 29 January: www.socialaudit.org.uk now gets >750,000 visits/year. I understand this review is to also be posted to bmj.com

I would welcome your advice on how best to proceed. Thank you for your attention; I look forward to hearing from you.

Yours faithfully

Charles Medawar
Director

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