Dear Ms Dewangree,

Consultation letter MLX 288

I am responding briefly to the Agency’s proposal to remove restrictions that now prohibit the advertising of certain OTC medicinal products to the general public. We see no merit in these proposals and oppose them. We will outline the reasons that apply specifically to the advertising of OTC preparations for ‘psychiatric diseases’. Please let us know if you require further information on any point, but we are reluctant to spend time elaborating our objections as we regard this consultation as a pro-forma process, if not as rather cynical:

There are several hundred ‘psychiatric diseases’ and several thousand symptoms that may be associated with them. The proposal makes no distinction between them, gives no specific illustration of any benefits that might be expected from removal of current restrictions; fails to discuss the possibility that the advertising of OTC medicines for such conditions might discourage especially vulnerable patients from seeking professional help; and makes no reference to the health hazards of medicalisation.

It is inappropriate to rely on arguments for the removal of restrictions on OTC advertising proposed by "The European High Level Group." This was an ad hoc advisory body, four of its thirteen members representing pharmaceutical industry interests, that was set up essentially, "to explore ways of improving industry competitiveness in Europe" and. For the MCA to suggest that OTC product advertising would help fulfill consumers’ requirement for "good quality objective information" is laughable.

For reasons explained in the attached letter to Mr Alder, consumers have little or no basis for trusting the Medicines Control Agency to adequately protect their interests in matters relating to advertising standards and control. The letter to Mr Alter should be regarded as an integral part of our response; both parts of our reply may be made freely available after the closing date for this consultation.

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