Department of Health's consultation Choosing Health? - PALAD response

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1. Impact of organisations on health of individuals (Question 7)

1.1 Roles and responsibilities of individuals and organisations - basic principles:

1.1.1 Establishing basic principles is essential to ensure consistency. Policies must be consistent both with each other and with common-sense. Otherwise they risk not being accepted by individuals and compliance will be low.

1.1.2 All activities have multiple causes and multiple consequences. No single cause can be blamed for any single consequence. Causes and consequences may be ranked in terms of importance and association.

1.1.3 The consequences of activities may be beneficial, neutral or harmful; they may take effect in the short-term and/or the long-term; they may effect only the actor or they may effect others.

1.1.4 All activities involve uncertainty including the risk of causing harmful consequences. Even the act of breathing risks infection from air-borne disease.

1.1.5 Common-sense dictates that individuals and organisations have a right to risk self-harm but not to risk harming others. They also have a responsibility to themselves to minimise the risk of self-harm and a responsibility to others to minimise the risks they impose upon them. In both cases the risk of harm should be reduced to an acceptable level.

1.1.6 Current drugs policies contradict health policies, Government modernisation principles and common-sense. "Drugs are harmful and will remain illegal" is not a rational policy.

1.2 Government:

1.2.1 Self-harm is a health issue, harm to others is a crime. The primary responsibilities of Government are to use legislation to prevent individuals and organisations from imposing unacceptable risks of harm on others and to target education at voluntary risks, encouraging individual and organisational responsibility through informed choice. The Strategy Unit’s report Risk: Improving government’s capability to handle risk and uncertainty says "Governments will not normally intervene where individuals take risks voluntarily and where they alone are affected" [1]. The Wanless report Securing Good Health for the Whole Population [2] says "the right of the individual to choose their own lifestyle must be balanced against any adverse impacts those choices have on the quality of life of others", that "individuals are, and must remain, primarily responsible for decisions about their and their children’s personal health and lifestyle. Individuals must be free to make their own choices about their own lifestyles" and "if government or other bodies do intervene, it is essential that social welfare is improved and that personal freedoms are respected". Arguing for an educational approach and warning against the inappropriate use of legislation the Wanless report says "Influencing and, over time, changing social attitudes to health and lifestyles is likely to be much more effective in the long run than a punitive approach that does not also aim for a change in attitude. Laws and regulations not accompanied by public support incur high enforcement costs, and could jeopardise the development of a consensus for future public health measures". Describing the limits to Government intervention the report says "In general, if the freedom to be curtailed or limited is a significant one and valued highly by the individual, the state would need strong reasons to impose its will over the individual on public health grounds. Usually, there should at least be a strong consensus, preferably public but certainly professional, that the public health measure is necessary to prevent harm to others".

1.2.2 Self-harm does impose a social cost in terms of health treatment. Government may tax the trade relating to activities that risk self-harm to cover this cost. Taxation of alcohol and tobacco covers the cost of all required drug-related services.

1.2.3 Government must clearly define the boundary between self-harm and harm to others and so between the interventions of education and legislation. This requires objective scientific evidence.

1.2.4 Government must also take into account pre-existing social and individual attitudes to risk when determining acceptable levels of risk. These subjective attitudes to risk may bias risk perception but since they act as ingrained habits they are resistant to change. Government and scientific experts may themselves also suffer from such biased risk perception habits.

1.2.5 Familiarity biases risk perception. The risks from traditional drug use (alcohol, tobacco and caffeine) have been underestimated and the risks from non-traditional drugs have been proportionately over-estimated. The Government’s drug education website, Talk to Frank, 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]. The United Nations’ definition of ‘drugs’ also warns against 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. 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" [4].

1.2.6 A major challenge is to encourage risk perception consistent with scientific evidence. This is a problem faced by Government, all organisations and all individuals. Government has a responsibility to correct faulty risk perception through evidence-based education.

1.2.7 The Better Regulation Task Force’s five Principles of Good Regulation [5] state that regulations should be accountable, transparent, consistent with each other, targeted at the problem and proportionate to risk.

  • Accountability: I have been unable to establish who is responsible for the decision to exclude traditional drugs from being considered under the Misuse of Drugs Act 1971. The Advisory Council on the Misuse of Drugs (ACMD) has a statutory duty to advise Government about the risks of all harmful drug use and to provide proportionate regulatory advice [6]. It would seem that the ACMD fail to provide regulatory advice concerning the traditional drugs to comply with the wishes of the Home Office. The ACMD Secretariat has told me "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]. Home Office drugs minister Caroline Flint has told me "alcohol, tobacco and caffeine will not be considered by the ACMD for control" [8]. The Government’s influence on the ACMD’s independent scientific advice distorts the ACMD’s regulatory advice resulting in the exclusion of traditional drugs from control under the Act - drugs which 90% of voters consume and whose trade brings Government 20 billion a year (see Appendix 1, my consultation response to the Committee on Standards in Public Life).
  • Transparency: Government should make it clear that some non-traditional drugs have been made illegal to comply with United Nations’ Conventions and not because they have been proven to be more harmful than the traditional drugs, alcohol, tobacco and caffeine.
  • Consistency: Traditional and non-traditional drug regulations are not consistent in terms of targeting and proportionality. The Home Affairs Select Committee Third Report The Government’s Drugs Policy: Is it Working? says that drug misuse "is a continuum perhaps artificially divided into legal and illegal activity" [9].
  • Targeting: Traditional drug regulations do not yet fully target harmful use. Education is targeted at the risk of self-harm and legislation is increasingly being targeted at harm to others. For individuals legislation includes: drink-driving, fire risk on public transport, anti-social behaviour, and soon smoking in enclosed public places. (For legislation affecting alcohol and tobacco businesses, see 1.3.3 below). Non-traditional drug regulations are not targeted only at harmful use, the problem, but all use. This denial of equal opportunity and informed choice for non-traditional drug consumers, traders and producers results in ever-decreasing compliance and ever-increasing enforcement costs. This is not sustainable.
  • Proportionality: Traditional drug regulations are not proportionate to risk. The risks of these traditional drugs have been under-estimated due to risk perception biased by familiarity. Tobacco, a drug that warns it kills, is permitted to be sold in food outlets everywhere, often alongside sweets for children. The World Health Organisation says "Tobacco products are the only products which kill when used as intended, up to one-half of users. Yet, in many respects and in many countries, the product itself is virtually unregulated" [10]. As a result traditional drugs are too available. Non-traditional drug regulations are also not proportionate to risk. The risks of these drugs have been overestimated often resulting in punishments that cause more harm than the drug use, trade or production in question. The Government’s Updated Drug Strategy 2002 recognises the importance of proportionality 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" [11]. However Government uses ‘drugs’ to mean only illegal drugs in this context. The law seriously misleads legal drug users into believing legal drugs are safer than illegal drugs while for illegal drug users it confirms their view that Government’s message is not "open, honest and credible". Increasing non-compliance has lead to massive growth of the unregulated black market, a growth prohibition has failed to stem. As a result non-traditional drugs have now become as available as traditional drugs.

1.2.8 Drug-taking is an adult activity like sex and products and services should only be available from licensed premises dedicated to that adult activity, with no access to young people (e.g. tobacconists, off-licenses, pubs). This represents the optimum restriction of availability for an integrated drugs strategy including both traditional and non-traditional drugs, a balance point to aim for.

1.2.9 The Government’s modernisation program will eventually lead to integrated, evidence-based drug regulations. Drug regulation trends of the last few decades show convergence upon the targeting of legislation against harm to others only. This is a foreseeable risk to current drug regulations. The Strategy Unit’s Personal Responsibility and Changing Behaviour says about the "over-arching logic: helping people help themselves" that "policy must at once empower and give choices, but at the same time policy should set the default to be in the best interests of individuals and the wider public interest. To be effective, this twin approach needs to be built around a sense of partnership between state and individual. …in health, governments do not ban unhealthy foods or smoking, but seek to refashion the behavioural pressures towards healthier choices" [12]. Prohibition of non-traditional drugs undermines this "over-aching logic" and "could jeopardise the development of a consensus for future public health measures".

1.3 Industry:

1.3.1 Businesses have a right to pursue activities that risk harm only to themselves. However they have a responsibility to others not to impose unacceptable risks upon them. Government has a responsibility to target legislation at businesses that fail to reduce these imposed risks to an acceptable level.

1.3.2 Government has a responsibility to target education at businesses that risk harming themselves through poor management.

1.3.3 Businesses involved in production and trade of substances for consumption (food & drugs) may impose unacceptable risks on others in many ways. Legislation regulating production includes laws requiring ingredients lists, health warnings and adequate quantity and quality control throughout production, distribution and the consumption period (e.g. ‘sell by’ & ‘best before’ dates). Legislation regulating trade includes advertising and sales restrictions of products that may cause significant harm.

1.3.4 A common risk assessment framework is required for all substances produced and supplied by organisations and consumed by individuals.

1.3.5 It is not clear what influence the traditional drug industry has in shaping policy toward competing non-traditional drug industries. A World Health Organisation Committee "found that the tobacco industry regarded the World Health Organization as one of their leading enemies, and that the industry had a planned strategy to "contain, neutralise, reorient" WHO's tobacco control initiatives" [13]. The Department of Health’s Dangerousness of Drugs says "a powerful lobby, the alcohol industry, has an obvious interest in minimising the number of deaths that are attributed to alcohol. This political pressure acts only to confound what is already a complex question of aetiology" [14].

1.4 Voluntary and community organisations:

1.4.1 Alongside health warnings on products could be contact details for an umbrella organisation concerned with that product. Such an umbrella organisation would include all organisations concerned with that product. For tobacco this would include ASH (‘anti’), Forest (‘pro’) and the NHS (treatment).

1.4.2 This would provide an important single link between consumer, organisations and Government. Consumers could find out further information and advice about rights, responsibilities and risk. The umbrella organisation may then be able to co-ordinate public involvement in Government policy-making aiding the co-production of policy.

1.4.3 Ultimately a significant proportion of policy-making might be devolved to these umbrella organisations which would then attempt to resolve conflicting views, taking this burden from Government.

1.5 Public sector:

1.5.1 Currently the public sector provides inconsistent information, advice, treatment and enforcement for drugs because drugs policy is not integrated.

1.5.2 The most fundamental symptom of this is the inconsistent provision of the most basic information: what is a drug? The Department of Education and Skills correctly uses the word to mean all drugs [15], in accordance with the United Nations’ definition and the word’s use in the Misuse of Drugs Act 1971. The Department of Health usually uses ‘substance’ to refer to all drugs (but not food) and ‘drugs’ to refer to illegal drugs only though sometimes ‘drugs’ is used in the correct sense to mean all drugs. The consultation briefing on Drug Misuse is an example, particularly when it says "the most effective way of reducing the harm drugs cause is to persuade all potential users not to use drugs". The Home Office uses ‘drugs’ to mean only illegal drugs, contradicting the use of the word in the Misuse of Drugs Act 1971.

1.5.3 Advice, treatment and enforcement for legal and illegal drugs are similarly inconsistent.

1.5.4 Accurate and consistent use of the word ‘drugs’ must be established across the public sector.

1.6 Encouraging healthy choices, discouraging unhealthy choices:

1.6.1 The consultation document points out that "between 15,000 and 22,000 deaths each year are associated with alcohol misuse". Alcohol also causes a large proportion of violent crime and anti-social behaviour due to its inherent properties of reducing inhibitions and increasing risk-taking. However alcohol is used by 90% of the adult population to aid relaxation and socialisation. The only other commonly used intoxicant is cannabis. Evidence suggests that cannabis is a considerably healthier alternative to alcohol in terms of both harm to the consumer and harm to others. Appendix 2 compares the risks of these drugs, summarising the evidence presented in the Department of Health’s Dangerousness of Drugs and the ACMD’s The Classification of Cannabis under the Misuse of Drugs Act 1971. The ACMD’s report states that "the high use of cannabis is not associated with major health problems for the individual or society" [16]. Much of the existing harm from cannabis use is not caused by the inherent properties of the drug but by the method of administration, smoking. The development of medicinal inhalers will allow a safer extract to be used by a safer method. When cannabis becomes legally available those who consume alcohol excessively should be targeted to switch to cannabis.

1.6.2 This is an example where ingrained attitudes that bias risk perception dominate the scientific evidence of risk throughout all levels of society. Individuals are denied a healthier alternative and businesses are prevented from competing with established drug industries; both are denied informed choice and equal opportunity instead being socially excluded and threatened with punishment. This creates and maintains health inequalities and an unhealthy social environment for drug consumption.

1.6.3 We support the recommendations and ideas for changing behaviour (both Government’s and individuals’ behaviour) in the two most recent reports stressing the need to encourage individual responsibility through informed choice and to reduce health inequalities:

  • The Wanless report Securing Good Health for the Whole Population.
  • The Strategy Unit’s Individual Responsibility and Changing Behaviour – the state of knowledge and its implications for public policy.

1.6.4 The Department of Health’s Dangerousness of Drugs remains the best account of drug dangers. It should provide the basis for proportionate regulations complying with BRTF’s Principles of Good Regulation. Prohibition is an unhealthy choice of intervention.

 

2. Creating and maintaining a healthy environment (Question 8)

2.1 Children are taught correctly at school that tobacco is a drug. Millions of children witness a parent consuming this drug every hour of their waking life. They witness their role models ignoring the drug education warning on the packet and suffer the effects of passive smoking as a result. When these children go to buy sweets they see this drug that warns it kills sold openly alongside their sweets. This is not a healthy environment for children to develop in.

2.2 Society accepts, in principle, that drugs may be used non-medicinally to alter mood. Ninety per cent of adults take the stimulant drug caffeine and the intoxicant drug alcohol. Society denies its acceptance of this drug use by believing that these substances are not really drugs, that they are, somehow, not the same as illegal drugs. It is this social norm that undermines rational analysis, Government policy and individual behaviour.

2.3 The Department of Health’s Dangerousness of Drugs lists many factors in the social environment that effect the harmful use of drugs including family values, peer values, public values and Government values. These inherent values emerge from experience, familiarity with risk, rather than any cost-benefit assessment based on objective evidence.

2.4 Risk perception appears to be severely distorted 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" [17]. The Department of Health’s Communication about risks to public health says "risks are generally more worrying if perceived … to arise from an unfamiliar or novel source" [18]. This is also reflected in common speech with the phrases "familiarity breeds contempt" and "better the devil you know".

2.5 The discrimination between legal and illegal drugs discriminates between traditional and non-traditional drugs rather than between safer and more harmful drugs. This biased risk perception over-estimates non-traditional drug risks and under-estimates traditional drug risks. This leads to proportionately biased regulations - the attempted over-regulation of non-traditional drugs (prohibition) and under-regulation of traditional drugs.

2.6 The risk perception 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 unfamiliar non-traditional is more harmful than the familiar 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.

2.7 Social and individual norms that bias risk assessment in favour of the familiar and against the unfamiliar may be a common factor in many cases of individual attitudes and organisational culture resistant to change. This may lie at the heart of habit, dependence and addiction, whether to substances, beliefs and ideologies or Government interventions.

 

3. Helping people deal with stress (Question 9)

3.1 The harmful use of substances, food and non-medicinal drugs, is the largest source of lifestyle health problems. Harmful substance use is often a response to stress. Some individuals may find that consumption reduces stress. This negative feedback reduces their primary cause of substance use and so may lead to a re-balancing of the individual’s state. However if stress is chronic and this response to stress continues then dependence is likely. Dependence leads to long-term consumption and all the health risks and stress that entails. This positive feedback increases the causes of consumption. The benefits of drug use must be properly considered and the boundary between reasonably safe use and harmful use clearly defined.

3.2 Dieters show the same relapse rate as those attempting to break their dependency on drugs. The Strategy Unit’s Addictive Behaviours – a review of research says "what are the main harmful addictions? Smoking, illicit drug use, and drinking, but possibly also over-eating leading to obesity?" [19]. An integrated systems strategy is required for cross-cutting issues such as substance consumption especially in light of their common non-linear effects due to feedback.

3.3 The prohibition of only non-traditional drugs remains a barrier to joined-up policy. The word ‘substance’ can not be used to identify cross-cutting substance use issues since the word is currently used to mean only ‘legal and illegal drugs’.

3.4 Prohibition also presents a barrier to healthier choices for individuals. Cannabis has been shown to be a far safer relaxant drug than alcohol, especially for those likely to use drugs excessively, young people. The stresses of adolescence should not be disregarded. Young people are naturally high risk-takers and the consumption of alcohol, a drug that increases risk-taking, has particular dangers for this group.

3.5 Exercise not only benefits physical health but also mental health. In the long-term, research into the effects of exercise on mood may provide the basis of educating people toward a healthier alternative method of satisfying their need for a sense of control over their mood.

 

4. Working together to support healthy choices (Question 10)

4.1 Substance consumption, trade and production are cross-cutting issues that require an integrated approach in line with the principles of Government modernisation.

4.2 Caffeine is regulated through the Food Standards Agency with scientific advice from the Committee on Toxicity of Chemicals in Food. Alcohol is regulated through the Department for Culture, Media and Sport with scientific advice from the Alcohol Education & Research Council. Tobacco is regulated by the Department of Health with scientific advice from the Scientific Committee on Tobacco and Health. Illegal drugs are regulated by the Home Office with scientific advice from the Advisory Council on the Misuse of Drugs.

4.3 All these substances are in fact drugs and should be regulated through the Misuse of Drugs Act 1971. The ACMD has a statutory duty under this Act to advise Government about all harmful drugs and to provide regulatory advice. There is no exclusion of traditional drugs, caffeine, alcohol and tobacco, from the Act.

4.4 The ACMD should integrate all information and regulatory advice about non-medicinal drugs and evolve toward a model like the Food Standards Agency – a Drugs Standards Agency. The ACMD should seek expertise from the Better Regulation Task Force to ensure the accountability, transparency, consistency, targeting and proportionality of their regulatory advice.

4.5 Only once Government’s drugs policies comply with BRTF’s principles of good regulation can we expect individuals responsible for regulating their own behaviour to adopt similar evidence-based regulatory policies.

4.6 The continuing prohibition of non-traditional drugs contradicts the principle of working together and undermines healthy choices.

 

5. Evidence base (Question 11)

5.1 The consultation briefing on Drug Misuse says "the most effective way of reducing the harm drugs cause is to persuade all potential users not to use drugs". Evidence suggests that illegal drug use has steadily increased under prohibition in contrast to the decrease in tobacco use following education targeted at self-harm and legislation targeted at harm to others (e.g. health warnings). The Department of Health’s Dangerousness of Drugs says "Cannabis availability: widely available across the UK and internationally - no clear evidence of both police or custom interventions on supply" [20]. The Home Affairs Select Committee Third Report Government’s Drugs Policy: Is it working? says "HM Customs and Excise told the Committee: "There is no sign at the moment that the overall attack on supply side is reducing availability or increasing the price"."[21]

5.2 The consultation briefings on alcohol and tobacco show how interventions other than prohibition are used for tackling harmful drug use, interventions that do not contradict all other Government policies.

5.3 The risks of legalisation of non-traditional drugs (risks of both positive and negative consequences) have not been assessed in accordance with policy review guidelines. Beneficial consequences have been under-estimated and harmful consequences over-estimated. Assessment of beneficial consequences fails to consider any benefits of reasonably safe use or the possibility that individuals may switch from more harmful drugs to safer drugs like cannabis. Beliefs about harmful consequences remain untested, particularly that increased use must lead to increased harm. Car use has increased 25-fold since 1922 but car harm has been halved. Regulatory improvements offset the risk of increased harm: improvements to the environment (road or market place), the object’s design (vehicle or drug quality/quantity) and the education of the user (driver training or drug user education).

5.4 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 [22]. This suggests that the risk of death from tobacco use is 3 times greater than the risk of death from illegal drug use, evidence that traditional and non-traditional drug regulations are not proportionate to risk.

5.5 We strongly support the Government’s evidence-based approach to improving risk assessment, risk management, regulations and policy-making using cost-benefit analysis of options followed by a cost-effectiveness evaluation. (e.g. Strategy Unit’s Risk: Improving government’s capability to handle risk uncertainty; Better Regulation Task Force: Principles of Good Regulation & Imaginative thinking for better regulation; Centre for Management and Policy Studies: Better Policy Making).

 

6. Disseminating information (Question 12)

6.1 A fundamental failure at present is the lack of involvement by non-traditional drug consumers, traders and producers in risk assessment, management and communication.

6.2 Risk communication is very thoroughly covered by the UK Resilience’s Communicating Risk and the Department of Health’s Communicating about risks to public health.

6.3 We hope the Department of Health will have access to the Strategy Unit’s recent report on illegal drug regulations, currently not permitted to be publicly available.

 

7. Ensuring change happens (Question 13)

7.1 Individuals, alone or as part of organisations, will only change their behaviour when they really understand the benefit. Knowledge is not enough. Basic principles that accord with natural common-sense are essential. Research into common-sense may be required.

7.2 We fully support the Government’s modernisation program and believe that implementation will be effective once the program is integrated within itself and with common-sense. Within Government, organisations and individuals the problems of dependency on traditional habits cannot be over-estimated. As the title of the Strategy Unit’s Individual Responsibility and Changing Behaviour – the state of knowledge and its implications for public policy suggests, no-one really knows how to encourage behaviour change. There is universal agreement that unhealthy behaviour cannot be changed by force yet teenagers grow up seeing the Government still attempting to do so in the face of all the evidence. The Government’s ‘King Canute’ behaviour undermines young peoples’ respect for health advice, authority, law, Government and an inclusive society.

 

  

Appendix 1: Response to Committee on Standards in Public Life consultation

Appendix 2: Comparison of cannabis, alcohol and tobacco harm by Department of Health and the ACMD.

 

 References:

  1. The Strategy Unit: Risk: Improving government’s capability to handle risk and uncertainty, paragraph 2.6.
  2. Derek Wanless: Securing Good Health for the Whole Population, paragraphs 7.59.5; 7.3; 7.4; 7.29; 8.43.
  3. The Government’s drug education website: Talk to Frank, alcohol webpage.
  4. The United Nations: A Participatory Handbook for Youth Drug Abuse Prevention Programmes - Chap 2, page 1.
  5. The Better Regulation Task Force: Principles of Good Regulation.
  6. Home Office webpage: Advisory Council on the Misuse of Drugs’ statutory remit.
  7. The Advisory Council on the Misuse of Drugs Secretariat, personal correspondence.
  8. Home Office drugs minister Caroline Flint, personal correspondence, last sentence.
  9. The Home Affairs Select Committee Third Report: The Government’s Drugs Policy: Is it Working?, introduction, paragraph 10.
  10. The World Health Organisation webpage: tobacco unregulated.
  11. The Government: Updated Drug Strategy 2002, page 22, Reclassification of Cannabis.
  12. The Strategy Unit: Personal Responsibility and Changing Behaviour, paragraph 3.5.
  13. The World Health Organisation webpage: tobacco industry’s interference with health policy.
  14. The Department of Health: Dangerousness of Drugs, page 8, paragraph 2.
  15. The Department of Education and Skills: Drugs: Guidance for Schools, 1.3 Terminology.
  16. The Advisory Council on the Misuse of Drugs: The Classification of Cannabis under the Misuse of Drugs Act 1971, paragraph 5.1.
  17. The Parliamentary Office of Science and Technology: Safety in Numbers, page 2.
  18. The Department of Health: Communication about risks to public health.
  19. The Strategy Unit: Addictive Behaviours – a review of research, paragraph 2.
  20. See Ref 14: The Department of Health: Dangerousness of Drugs, page 32, Cannabis Availability.
  21. See Ref 9: The Home Affairs Select Committee Third Report Government’s Drugs Policy: Is it working?., paragraph 18.
  22. World Health Organisation webpage: The Global Burden.