If you are a member of the British public and you want to complain about something a pharmaceutical company has done, said or written, you effectively have one option. That option is to write to the pharmaceutical industry administered PMCPA (Prescription Medicines Code of Practice Authority). The PMCPA would argue that it is independent of the pharmaceutical industry but it is entirely funded by the industry whose trade body, the ABPI, also:
- appoints the Chair of the PMCPA Appeal Board (operationally probably the most important and influential person in the PMCPA);
- appoints the CEO of the PMCPA (the other big operational voice in the PMCPA) – the CEO then reports to the Board of the ABPI;
- appoints the other members of the PMCPA Appeal Board (including a number of places reserved specifically for employees of pharmaceutical companies);
- has final sign-off on the constitution of the PMCPA, including any proposed changes.
The PMCPA’s claim that it is independent of the ABPI must therefore be taken with a large pinch of salt. The interests of the pharmaceutical industry would appear to be very much in the driving seat.
This PMCPA complaints system is called ‘self-regulation’. It represents a valuable privilege endowed by our government and it is one which the UK pharmaceutical industry defends vigorously.
Until recently there was no ‘statute of limitations’ relating to how much time had passed since any alleged misconduct occurred or potentially dodgy material was produced. If you were concerned about it, you could complain to the PMCPA and it would deal with your complaint.
However, the PMCPA has just announced a number of proposed changes to its constitution and procedures, one of which is that in future it will refuse to process any complaints which relate to pharmaceutical company activities or materials which are more than two years old, or just six months if they involve social media.
The PMCPA first floated this idea as a pilot project starting on June 1st 2025 with little information or data to either justify this decision or explain how the success, or otherwise, of the ‘pilot’ would be measured. When the scheme originally launched it was intended to be a brief temporary trial expiring on December 31st 2025. However, this ‘pilot’ was then extended twice. First it was extended until June 30th 2026 with yet another extension announced on June 29th 2026. But on August 3rd 2026 the PMCPA then announced, again with little supporting information or data, its intention to make this ‘pilot’ restriction a permanent feature of its complaints procedure.
The proposal now threatens to create a de facto historical immunity for poor conduct by pharmaceutical companies in the UK. It must be resisted. I myself have sent a letter to the PMCPA, setting out in great detail my opposition to this proposal. I would urge other members of the British public to do likewise (although I do appreciate that you may not wish to go into quite so much detail as I have). Alternatively you can contribute to the public consultation using the PMCPA’s own online form.
The proposed introduction of the fixed time limits is listed there as the first of the proposed changes. You can also read about, and comment on, the other proposed changes if you wish, but please at least register your opinion on the time-limit proposal. The consultation period ends on September 21st 2026, so there is not long left to get your comments in.
Dr Alan Black is a retired pharmaceutical physician, having worked in and for the pharmaceutical industry for around 30 years. Prior to that he spent a number of years in laboratory and clinical medicine.
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They’ll be giving themselves pardons soon if they’re closing down the opportunity to hold Big PHarma to account!
Just completed the survey, looks a bit sinister to me!
is there a link to easily “register our opinion on the time-limit proposal”
Thank you Dr Black. I’ve responded to the survey.
I just completed the said form. Is it possible that your gov’t is attempting to shut down free speech? We now know the mRNA Covid vaxxes are and were unsafe and ineffective, and that childhood vaxxes are causing autism, gut issues and other types of chronic illnesses in children. Is this proposal suggesting we the public will not have the right to comment, discuss our concerns about big pharma products that harm? Looks like your freedom of speech rights are being crushed, one step at a time little Britain.
Thanks for this interesting article. The author is eminently better qualified than I am on this subject, but self-regulation seems inherently problematic to me especially when the industry’s products are supposed to regulated by governments who seem not to want to do that job properly. The result seems to be that we have a section of the population who happily consume pharma products because surely if they have been approved by the government they must be safe and effective, and a smaller section who distrust pretty much everything the pharma industry does. I don’t know what the answer is.
But why would anyone want to complain? They’re only trying to make us healthier… aren’t they?
Made Malcolm Kendrick’s “ Doctoring Data “ is a very interesting read.
*Made*? I’m sure that I typed, “ Dr “.