2. Management
of Codes of Conduct:
The Code of
Practise for Scientific Committees [10]:
2.1 ACMD’s
remit and objectivity:
Paragraph 11:
"It is the Government’s responsibility
to ensure that a committee’s remit is clear,
and it is the committee’s responsibility to
raise concerns if they believe there are
ambiguities. As a general principle any required
clarification of a committee’s role should
take place before a committee begins its
work".
Under the MDA the ACMD has a statutory duty
"to keep under review the situation in the
United Kingdom with respect to drugs which are
being or appear to them likely to be misused and
of which the misuse is having or appears to them
capable of having harmful effects sufficient to
constitute a social problem"[1]. Their duty
includes the provision of "advice on
measures (whether or not involving alteration of
the law) which in the opinion of the Council
ought to be taken for preventing the misuse of
such drugs or dealing with social problems
connected with their misuse" [1].
As noted above (1.2) the ACMD do not provide
adequate risk analysis or any proportionate
regulatory advice to Government about the harmful
use of the traditional drugs alcohol, tobacco and
caffeine.
It is scientific fact that these traditional
substances are drugs. The following definitions
support this view. The United Nations definition
of ‘drugs’ suggests that familiarity
may make this fact difficult to appreciate.
- United
Nations:
"What are drugs? A very basic
question but one that needs to be
clarified. For, if we start thinking of
drugs as just the substances that cause
problems or are abused by people we know,
then we are likely to ignore other
substances that, for one reason or
another, are not thought of as drugs by
our immediate communities. A psychoactive
substance is any substance people take to
change either the way they feel, think,
or behave. This description covers
alcohol and tobacco as well as other
natural and manufactured drugs" [5].
- Home Office
guidance: "In the interests of
encouraging rational debate and combating
knee-jerk prejudice, we need to continue
referring to alcohol, tobacco and
caffeine as drugs" [6].
- Department
for Education and Skills, Drugs:
Guidance for Schools:
" The definition of a drug given by
the United Nations Office on Drugs and
Crime is: ‘a substance people take
to change the way they feel, think or
behave’. The term ‘drugs’
and ‘drug education’, unless
otherwise stated, is used throughout this
document to refer to all drugs: all
illegal drugs (those controlled under the
Misuse of Drugs Act 1971), all legal
drugs, including alcohol, tobacco"
[4].
- Advisory
Council on the Misuse of Drugs
Secretariat: "it can be argued that
the ACMD has a remit to consider alcohol,
tobacco and caffeine" [7].
The Home Office
Risk Framework gives no suggestion that a
distinction should be made between traditional
and non-traditional dangerous drugs. It lists
among its aims: "to deliver the
Department’s policies and responsibilities
fairly, effectively and efficiently" and
"to reduce the availability and abuse of
dangerous drugs" [11].
There is no obvious reason why the ACMD has
failed to provide regulatory advice about the
harmful use of traditional drugs. The ACMD has
not provided any explanation for the omission of
this advice.
2.2 Openness and
Transparency:
Para. 46.
"Committees should operate from a
presumption of openness. The proceedings of the
committee should be as open as is compatible with
the requirements of confidentiality. The
committee should maintain high levels of
transparency during routine business".
Para. 68. "Committees should abide by the
principles contained in the Code of Practice
on Access to Government Information".
The Code of Practise on Access to Government
Information says "the target for
response to simple requests for information is 20
working days".
Para. 85. "In order to help provide a full
appreciation of its advice and decisions, the
committee should, where appropriate, facilitate
public access to documents or information that
have contributed to the formulation of its
advice. This would enable third parties to better
understand the conclusions reached and decisions
taken".
Para. 91. "Committees should develop a
policy for the communication of their work to the
public and other interested parties and for
receiving feedback".
- On 22
January 2003 I wrote to Chris Saint, ACMD
secretary, asking "Is there anything
preventing the ACMD from considering the
dangerousness of tobacco or
alcohol?". I have had no reply.
- On 22 June
2003 I wrote again to Mr Saint [12]
saying "We are very concerned that
the ACMD's recent report Hidden Harm
- Responding to the needs of children
of problem drug users [13] is
seriously misleading due to a very simple
error. The word 'drug' in this report is
used to mean 'controlled drug' only but
there is no mention of this unusual and
inaccurate definition. The report aims to
assess the number of children in the UK
effected by parental problem drug use and
concludes that "there are between
200,000 and 300,000 children in England
and Wales where one or both parents have
serious drug problems" and that
"Problem drug use in the UK is
characterised by the use of multiple
drugs, often by injection". These
statements are untrue. They are only true
in reference to the use of controlled
drugs and do not include the two drugs
that cause the greatest harm, alcohol and
tobacco. The report does admit that legal
drugs cause significantly more harm than
controlled drugs in one paragraph of this
92 page report but then says "it was
decided that it was beyond the scope of
the Inquiry to do justice to these two
major topics" [13]. Instead the
report does no justice to these two major
topics, omitting their statistics in the
summary without comment. It continues:
"Our main focus is therefore on
problem drug use, with the impact of
alcohol or tobacco being considered as
additional factors". Again this
wrongly implies that alcohol and tobacco
are not drugs. This report about parental
drug use harmful to children aims to
establish "the size and seriousness
of the problem" yet omits the two
greatest causes, alcohol and tobacco, and
so provides a distorted view of the
problem. Anyone reading the front cover
or summary would have no clue that
parental use of legal drugs causes far
more harm to children than use of
controlled drugs - a vital piece of
information".
Paul Flynn MP wrote to the Home Office in
support of these serious concerns. Again
neither of us have had a reply.
- On 24th
January 2004 I received a letter from
Saleah Ahmed of the ACMD Secretariat in
response to my letter of 5th
December to Caroline Flint at the Home
Office. Ms Ahmed’s letter explained
that there is no definition of
‘drugs’ in the MDA, that legal
drugs could fall under the ACMD’s
remit but, though independent, the ACMD
do take account of the wishes of
Government when giving their advice [7].
I replied on 29th January 2004
asking "I’m trying to find out
details about how the ACMD define the
word ‘drugs’, how they
therefore determine the scope of their
remit and what role Government plays in
these decisions. Are there any documents
relating to these questions that you
could send me?" By April 5th
I had not received a reply.
2.3 Independence
and objectivity:
Para. 76.
"A committee’s advice should be in
writing, and should be seen as independent of
government".
A Home Office press release describes the ACMD as
"an independent expert committee that
advises the Government on drug
classifications" [14].
The letter of 24th January 2004 from
Saleah Ahmed of the ACMD Secretariat said
"Albeit independent, the ACMD as an advisory
body has to be aware of the Government’s
position, which has not given any intention to
consider the control of alcohol, tobacco and
caffeine" [7].
Caroline Flint, Home Office drugs minister, has
written to me suggesting that the Home Office
imposes limitations on the ACMD’s
independence. She said "alcohol, tobacco and
caffeine will not be considered by the ACMD for
control" [8].
The MDA does allow the Government to ignore the
advice of the ACMD when determining which drugs
should be controlled under section 2 of the MDA
so there seems little justification for limiting
the ACMD’s statutory remit.
3.
Enforcement of Codes of Conduct and
Organisational Culture:
3.1 The Home
Office is responsible for good governance of
their public bodies but misleading replies from
them leave me with little faith in their
organisational culture and ability to tackle
enforcement of the ACMD’s Code of Practise.
3.2 The
consultation document says organisational culture
"concerns the basic assumptions and beliefs
that are learned, shared, and often taken for
granted in an organisation" (Consultation
document 2.13).
3.2.1
Assumptions and beliefs that discriminate between
familiar and unfamiliar risks, minimising the
former and maximising the latter, underlie the
problematic organisational culture of the Home
Office and ACMD. This biased risk assessment
leads to proportionately biased regulations - the
over-regulation of non-traditional drugs
(prohibition) and under-regulation of traditional
drugs. The United Nations’ definition of
‘drugs’ warns of the risk of focusing
only on non-traditional drugs and ignoring
traditional ones. It says "if we start
thinking of drugs as just the substances that
cause problems or are abused by people we know,
then we are likely to ignore other substances
that, for one reason or another, are not thought
of as drugs by our immediate communities"
[5]. It goes on to note that alcohol and tobacco
are psychoactive drugs. The Government’s
drug education website also warns of this bias
saying "alcohol can play a major part in
many people's social lives. That's why it's easy
to forget that it's actually a very powerful
drug" [3]. There is considerable evidence
that risk perception is effected by familiarity.
The Parliamentary Office of Science and
Technology leaflet Safety in Numbers
describes factors affecting risk perception
saying "Familiarity – People appear to
be more willing to accept risks that are familiar
rather than new risks" [15]. This is also
reflected in common speech by phrases such as
"familiarity breeds contempt" and
"better the devil you know".
3.2.2 The Home
Office has confirmed that Government drug
policies and drug laws do not discriminate
between dangerous and less dangerous drugs as is
often implied but instead discriminate between
non-traditional and traditional drugs. Adult
consumers of dangerous drugs have a right to make
informed choices and the prohibition of dangerous
drugs is not practical and would increase crime -
but these policies only apply to traditional
drugs.
- Bob
Ainsworth’s letter said tobacco
"smoking is the greatest single
cause of preventable illness and
premature death in the UK, and is
responsible for around 120,000 deaths
every year. However because the habit has
a four hundred-year history of social
acceptance in the Western world, the
Government cannot simply ban it. The
Government believes that adults are
entitled to make an informed choice and
therefore ensures that full information
on the dangers of tobacco are freely
available" [16].
- Caroline
Flint’s letter said "owing to
the wide use of these substances over a
long period of history in modern society
and the general social acceptance that
has resulted, it [prohibition] is not a
realistic or practical option. To
criminalise the supply and use of
alcohol, tobacco and caffeine would
inevitably result in widespread
smuggling, law breaking and other
associated criminal activity" [8].
3.2.3 My
conclusion is that the organisational culture
described is unjustly discriminatory. It shares
the same fundamental characteristic as sex, race
and disability discrimination. Unjust
discrimination seems to be founded on prejudice
by the traditional majority against
non-traditional minorities. The pre-judgement
made is that the non-traditional is more harmful
than the traditional. Non-traditional minorities
are then over-regulated (either consciously or
unconsciously), denied equal opportunity, instead
being socially excluded. The traditional majority
benefits from under-regulation as regulations are
focused on the minorities. The discrimination is
justified on the basis of harm with no acceptance
that the discrimination is actually merely
between the traditional and non-traditional. This
may be a common factor in many cases of
organisational culture resistant to change (e.g.
resistance to Code of Conduct implementation).
3.3 The
consultation document also notes "the
persuasive power of organisational culture to
deflect attention from standards issues"
(Consultation document 2.14).
3.3.1 I asked
the Home Office what is the definition of
‘drugs’ in the MDA 1971 and why are the
drugs alcohol and tobacco not included in the
MDA. Replies were inaccurate and misleading.
- Bob
Ainsworth’s reply of 21 January 2003
stated "the ‘drugs of
misuse’ controlled under the 1971
Act are determined under United Nations
Conventions" [16]. This is not
accurate as confirmed by Caroline
Flint’s letter. She said "the
UK is also free to act independently
outside of this international legal
framework and the ACMD can advise the
Government on drugs that it feels require
control under the MDA 1971" [8].
- On 27th
November 2003 Caroline Flint replied to
my letter of 23rd October. She
said "The Misuse of Drugs Act 1971
(MDA 1971) refers to only controlled
drugs, that is to say any
‘substances or product for the time
being specified in Part I, II or III of
schedule 2 of this Act’. As Alcohol,
caffeine and tobacco are not controlled
drugs, they do not fall under the remit
of the MDA 1971". This is not
accurate since section 1 of the MDA
refers to all harmful drugs, not only
controlled drugs. She also said that
"alcohol, caffeine and tobacco do
fall under the UN’s definition of
drugs" but concluded "The ACMD
is an independent non-departmental public
body established under the MDA 1971 for
the purpose of advising the Government on
drug related issues. It therefore does
not have an obligation to provide advice
to the Government on how to tackle harm
brought on by misuse of alcohol, tobacco
or caffeine" [8].
3.3.2 Again
these replies show the confusion of
‘drugs’ with ‘controlled
drugs’ and the contradictory and misleading
statements that follow such confusion. These
statements, and the attitudes underlying them,
seem to deflect attention from the issues of
objectivity, openness and accountability.
3.4 Independent
scrutiny:
On 12th March 2003 I e-mailed the
Parliamentary Ombudsman asking "Can you
investigate complaints against the Advisory
Council on the Misuse of Drugs? If not, who
can?". I received a reply from Rachael
Hodson on 17th March saying that the
Parliamentary Ombudsman has no power to
investigate the ACMD and that she was
"unaware of any other body with whom you
could pursue your complaint".
No independent scrutiny of the ACMD seems
possible.
4.
Proportionality: "enforcement regimes should
be proportionate to risk" [Better Regulation
Task Force]
4.1
Proportionality of Code implementation and
enforcement to size of public bodies:
Proportionality should not only be based upon the
current size and resources of a public body as
these factors themselves may be determined by
problematic organisational culture.
Proportionality should more directly take into
account the risk of that public body providing
inadequate advice, perhaps through lack of
resources, and the consequent risks to policy
making from such inadequate advice.
4.2 The risk to
policy making from the ACMD’s inappropriate
drug risk and regulatory advice:
4.2.1 The Better
Regulation Task Force’s Principles of Good
Regulation mentions 5 principles:
Accountability, Transparency, Consistency,
Proportionality, Targeting [17].
4.2.2
Accountability: "Regulators must be able to
justify decisions, and be subject to public
scrutiny"
It is not clear who is responsible for the
exclusion of traditional drugs from the MDA.
Section 1 of the MDA suggests the ACMD is the
primary source of scientific drug risk analysis
and proportionate regulatory advice upon which
Government drugs policy is based (2.1 above).
However the independence of their scientific
advice seems to be compromised by unjustified
restrictions imposed by their sponsoring
Department, restrictions that seem to require the
‘independent’ advice to conform to
Government policy (2.3 above).
4.2.3
Transparency: "Regulators should be open,
and keep regulations simple and
user-friendly"
The ACMD have provided no explanation for the
exclusion of traditional drugs from their advice,
nor any explanation why they use the word
‘drugs’ to refer only to controlled
drugs, contradicting the use of the word in the
MDA and implying that the traditional drugs
alcohol and tobacco are not drugs (2.2 above).
4.2.4
Consistency: "Regulators should be
consistent with each other, and work together in
a joined-up way"
The regulatory advice the ACMD provide about
non-traditional drugs is not consistent with
traditional drug regulations. Traditional drug
consumption, trade and production is regulated to
allow taxation to pay for all drug-related
services. Non-traditional drug consumption, trade
and production is prohibited resulting in the
demand being met by the unregulated black market
allowing all drug profits to go to organised
crime. The ACMD’s targeting and
proportionality of legislation to risk is
inconsistent with that of traditional drugs
legislation.
4.2.5 Targeting:
"Regulation should be focused on the
problem, and minimise side effects"
The regulatory advice the ACMD provide about
non-traditional drugs is not targeted at harmful
drug consumption, trade and production. Instead
it targets all non-traditional drug consumption,
trade and production. A side effect is increasing
non-compliance and an increasing black market
which can not be regulated to allow taxation or
to provide consumer protection.
4.2.6
Proportionality: "Regulators should only
intervene when necessary. Remedies should be
appropriate to the risk posed"
"Enforcers should consider an educational,
rather than a punitive approach where
possible"
- The ACMD
have not explained the necessity of
legislating against all use of
non-traditional drugs instead of only
harmful use.
- The ACMD do
not distinguish between two distinct
forms of harm: harm to others and
self-harm. When a risk of harm is imposed
on another, legislation is the
appropriate intervention to protect
citizens. This includes harm caused by
consumers to the public (drink-driving,
alcohol-induced violence, passive smoking
and fire risk), by suppliers to the
public (advertising and supply to minors)
or by producers to consumers (lack of
quality/quantity control or harm
warnings). Self-harm occurs when a person
imposes a risk of harm upon themselves.
The creator of the risk suffers the
consequent harm. It is a health issue and
education is the appropriate
intervention. Government health policy is
to encourage individual responsibility
through informed choice. The Department
of Health's Saving lives: Our
Healthier Nation says "it is the
role of the Government to provide
information about risk. But in most cases
it is for the individual to decide
whether to take the risk. As long as
people are aware of the risk which they
are taking, it is their decision whether
to put themselves at risk" [18]. The
World Health Organisation warns of
inappropriately targeting legislation
against self-harm saying "people
with substance dependence are among the
most marginalized in societies and are in
need of treatment and care. To
incarcerate offenders for drug use and
dependence is not an effective prevention
or treatment strategy" [19].
- The
regulatory advice the ACMD provide about
harmful drug use is not proportionate to
their risk analysis. The ACMD has said
that tobacco "smoking kills about
120,000 people each year, and between
28,000 and 33,000 people die annually as
a result of alcohol" [20] but they
have not advised that alcohol and tobacco
should be classified under the MDA. The
ACMD has said "the high use of
cannabis is not associated with major
health problems for the individual or
society" [21] but they have not
advised that cannabis should be excluded
from the MDA. The ACMD justify the
reclassification of cannabis as a Class C
drug on the basis of proportionality
since cannabis is less harmful than other
Class B drugs yet their evidence suggests
that cannabis is also less harmful than
alcohol and tobacco. Their report The
Classification of Cannabis under the
Misuse of Drugs Act 1971 compares the
specific risks of cannabis use with those
of alcohol and tobacco use, confirming
the view that cannabis appears to be a
safer alternative to these legal drugs
[Appendix & Ref 21]. The Government's
Updated Drugs Strategy 2002
describes the risk to public compliance
of disproportionate drug laws saying
"it is vital that the Government's
message to young people is open, honest
and credible. Drug laws must accurately
reflect the relative harms of different
drugs if they are to persuade young
people in particular of the dangers of
misusing drugs" [22].
4.3 Like the
ACMD the World Health Organisation has a duty to
provide risk analysis and proportionate
regulatory advice in relation to harmful drugs.
WHO cover both traditional and non-traditional
drugs irrespective of their legal status. Their
drug risk analysis shows that tobacco use is 7
times more prevalent than illegal drug use but
causes 22 times as many deaths [23]. This
suggests that the risk of death from tobacco use
is 3 times greater than the risk of death from
illegal drug use. This indicates that traditional
and non-traditional drug regulations are not
proportionate to risk.
4.4 The
ACMD’s failure to refer to traditional drugs
as ‘drugs’ results in the term
‘substance misuse’ being used for
integrated drugs policies (e.g. by the Department
of Health) instead of this term being used more
properly to refer also to excessive or
inappropriate food consumption that risks leading
to obesity. Food is clearly a substance just as
alcohol and tobacco are clearly drugs. Food and
drugs may both be consumed to relieve stress.
Those suffering from excessive stress are most
likely to consume either substance excessively
leading to dependency. Stresses in both cases are
often both internal (psychological) and external
(environmental). Dieters have a similar relapse
rate to traditional and non-traditional drug
users attempting to break their dependency.
Dependency and consequent harmful consumption of
food and drugs should be researched, tackled and
communicated to the public in an integrated way
but the ACMD’s inappropriate terminology
prevents this.
5.
Recommendations:
5.1 Greater
implementation and independent scrutiny of Codes
of Conduct is needed for some public bodies. An
independent Commissioner for Public Conduct,
equivalent to the Commissioner for Public
Appointments, would be appropriate for similar
reasons.
5.2 Code
implementation, enforcement and independent
scrutiny should be proportionate to the risk of
that public body providing inadequate advice,
perhaps through lack of resources, and the
consequent risks to policy making from such
inadequate advice.
5.3 The ACMD
should be reviewed using the ‘Guidance for
reviewing NDPBs’ [24], applicable to small
advisory NDPBs. The review should examine the
ACMD’s statutory remit with respect to the
traditional drugs alcohol, tobacco and caffeine.
It should also examine the consistency of the
ACMD’s regulatory advice with
Government’s modernisation program,
particularly the Better Regulation Task
Force’s Principles of Good Regulation
and ILGRA’s Risk Communication: A Guide
to Regulatory Practise.
Appendix: ACMD - Cannabis harm
compared to alcohol and tobacco harm
Advisory Council
on the Misuse of Drugs - The classification of
cannabis under the Misuse of Drugs Act 1971
[Ref 21]
4.3.5 Unlike
sedative intoxicants such as alcohol, cannabis
does not cause respiratory depression or suppress
the gag reflex even when extremely intoxicated.
4.3.6 Cannabis differs from alcohol, however, in
one major respect: it seems not to increase
risk-taking behaviour. This may explain why it
appears to play a smaller role than alcohol in
road traffic accidents. … cannabis rarely
contributes to violence either to others or to
oneself, whereas alcohol use is a major factor in
deliberate self-harm, domestic accidents and
violence.
4.4.1 In general cannabis users smoke fewer
cigarettes per day than tobacco smokers and most
give up in their 30s, so limiting the long-term
exposure that we now know is the critical factor
in cigarette-induced lung cancer.
4.4.5 It is possible to rank the risks of
dependence of abused drugs with heroin and crack
cocaine the worst and cannabis generally at, or
near, the bottom (and well below nicotine and
alcohol).
4.5.1 Tobacco smoking and alcohol use are
significant causes of harm to the unborn child.
Cannabis may also increase the risk of minor
birth defects and abortion but the effect is
small.
4.5.2 There is some evidence that smoking
cannabis during pregnancy may produce subtle
alterations in neuropsychological performance of
the child that persists into later life. This
effect is similar to that of tobacco smoking and
may be due to the actions of tobacco smoke rather
than to cannabis per se.
4.5.3 Taken together this data suggest that
cannabis use in pregnancy is not safe but that it
is probably no more dangerous to the foetus than
either alcohol or tobacco.
4.6.3 Interestingly, other studies have found
that the use of alcohol and tobacco in early
teens (and especially in pre-adolescents) appears
to be associated with the later use of many drugs
including cannabis.
4.6.4 Despite all these caveats, it is likely
that cannabis use (and that of alcohol or
tobacco) has an effect on later Class A drug use.
4.7.1 Cannabis appears not to make as major a
contribution to road traffic or other accidents
as alcohol.
5.1 The high use
of cannabis is not associated with major health
problems for the individual or society.
5.2 The occasional use of cannabis is only rarely
associated with significant problems in otherwise
healthy individuals. These harmful effects of
cannabis, however, are very substantially less
than those associated with similar use of other
drugs, such as amphetamines, which (like
cannabis) are currently classified as Class B.
5.4 Regular heavy use of cannabis can result in
dependence, but its dependence potential is
substantially less than that of other Class B
drugs such as amphetamines or, indeed, that of
tobacco or alcohol.
5.5 It is not possible to state, with certainty,
whether or not cannabis use predisposes to
dependence on Class A drugs such as heroin or
crack cocaine. Nevertheless the risks (if any)
are small and less than those associated with the
use of tobacco or alcohol.
6.1 Cannabis is
not a harmless substance and its use
unquestionably poses risks both to individual
health and to society.
6.2 Cannabis, however, is less harmful than other
substances (amphetamines, barbiturates,
codeine-like compounds) within Class B of
Schedule 2 to the Misuse of Drugs Act 1971. The
continuing juxtaposition of cannabis with these
more harmful Class B drugs erroneously (and
dangerously) suggests that their harmful effects
are equivalent. This may lead to the belief,
amongst cannabis users, that if they have had no
harmful effects from cannabis then other Class B
substances will be equally safe.
6.3 The Council therefore recommends the
reclassification of all cannabis preparations to
Class C under the Misuse of Drugs Act 1971.
References:
- Home Office
webpage, Advisory Council on the Misuse
of Drugs – statutory remit.
- Home Affairs
Select Committee Third Report The
Government’s Drugs Policy: Is it
Working? – introduction,
paragraph 10.
- Government/Home
Office drug education website, Talk to
Frank.
3.1 "drugs are
illegal".
3.2 nicotine is a
drug.
3.3 alcohol is a drug.
- Department for
Education and Skills, Drugs: Guidance
for schools – 1.3 Terminology
- United Nations, A
Participatory Handbook for Youth Drug
Abuse Prevention Programmes - Chap 2,
page 1.
- Home Office
guidance, Lets Get Real: Communicating
with the public about drugs –
page 40.
- Personal
correspondence from ACMD Secretariat.
- Personal
correspondence from Home Office, Caroline
Flint
- ACMD and Code of
Practise for Scientific Committees.
- Code of
Practise for Scientific Committees.
- Home Office Risk
Framework, Annex B, 2
- Personal
communication to ACMD Secretariat, Chris
Saint
- Advisory Council
on the Misuse of Drugs report Hidden
Harm - Responding to the needs of
children of problem drug users –
Introduction, page 7
- Home Office press
release
- Parliamentary
Office of Science and Technology leaflet Safety
in Numbers, page 2
- Personal
correspondence from Home Office, Bob
Ainsworth.
- Better Regulation
Task Force, Principles of Good Regulation
- The Department of
Health's Saving lives: Our Healthier
Nation, paragraph 3.25
- World Health
Organisation, What do people think
they know about substance dependence?
– page 8.
- Advisory Council
on the Misuse of Drugs report Reducing
Drug Related Deaths – paragraph
1.12
- Advisory Council
on the Misuse of Drugs report The
Classification of Cannabis under the
Misuse of Drugs Act 1971, paragraph
5.1
- The Government's Updated
Drugs Strategy 2002 – page 22,
Reclassification of Cannabis
- World Health
Organisation webpage – The Global
Burden
- Guidance for
reviewing NDPBs