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H O U S E   OF   C O M M O N S

APPGITA - All Party Parliamentary Group for
Involuntary Tranquilliser Addiction

House of Commons, London SW1A 0AA

Letter from Jim Dobbin MP to Steve Taylor,
National Treatment Agency,
September 5, 2012

September 5, 2012

Steve Taylor
National Treatment Agency
6th Floor Skipton House
80 London Road
London Road
SE1 6LH

Dear Mr Taylor,

I am writing to provide you with my comments on the final draft of the Roundtable consensus statement. These comments will be circulated to other members of the Roundtable.

  1. In my opinion Roundtable members have not been provided with full information on the arrangements to which they have been asked to sign. The reality of the new policy is contained within the Joint Strategic Needs Assessment (JSNA) published by the National Treatment Agency which provides guidance on drug treatment services for local authorities and on their funding. The JSNA instructs local authorities to commission "integrated services" meaning services which treat both illegal drug users and patients dependent upon prescribed medication only, including involuntary tranquilliser addicts who do not use other drugs.

    The NTA, the local authorities and the drug misuse service providers do not have the necessary experience or expertise in the job they are about to take on, the treatment of addiction to prescribed medication including prescribed tranquilliser addiction. The NTA specialises in illegal drug use and has not generally withdrawn those clients; they have been maintained on prescribed pharmaceutical substitutes such as methadone.

    When NTA service providers have treated prescribed tranquilliser addicts they have often ignorantly subjected patients to dangerous abrupt withdrawal regimes. Bill Cash's constituent Barbara Bell has been left disabled by this treatment. The APPGITA has recommended withdrawal services should be provided by creating a network of clinics based on the existing charitable support groups such as the Bristol Tranquilliser Project and CITA. Instead the JSNA arrangements will have the opposite effect and remove funding from these organisations, which do not provide an integrated service.

    CITA, Council for Information on Tranquillisers and Antidepressants, was founded by Pam Armstrong in 1987 and is in the process of having its funding removed under JSNA regulations. CITA pioneered a successful system of providing specially trained personnel to work within GP surgeries advising on withdrawal protocols for patients addicted to tranquillisers and antidepressants. CITA has withdrawn thousands of addicted clients from prescribed tranquillisers and antidepressants in Lancashire and throughout the UK. CITA provides staff training courses, a national helpline and is famous worldwide for its good work and the safe and successful treatment it provides.

    The consensus statement does not make it clear to Roundtable members what it is they are being asked to sign up to. By signing the statement Roundtable members unwittingly approve the closure of CITA and other such organisations and endorse the introduction of the yet to be explained "integrated services".

  2. There is no action plan contained within the consensus statement and no ring-fenced budget created for prescribed medication. The Roundtable members do not know if they are signing up to drug maintenance treatment, dose reduction or drug free outcomes as practiced by the existing tranquilliser withdrawal charities.

    Professor Ashton has already made clear in her previous letter to Roundtable attendees that it is a misconception to believe that addiction to over the counter drugs and to prescribed tranquillisers and antidepressants can be treated together successfully. They are entirely different populations requiring different actions and different management. It is an even bigger misconception and mistake to believe the two populations can be successfully lumped together with a third group, the drug misusers.

  3. The Department of Health, the NTA and the consensus statement have remained silent on the question of SSRI, tricyclic and other antidepressant medication. There are an estimated 3 million plus long-term SSRI users alone and prescription numbers are increasing. Are these patients considered to be addicted, dependent or neither? Has the Roundtable discussed whether antidepressants fall within the scope of the consensus statement?

  4. Existing prescribing guidelines in the British National Formulary, Electronic Medicines Compendium and the 1988 CSM letter restrict tranquilliser use to 2-4 weeks with no exceptions. These guidelines were compiled by qualified scientific and medical experts and were introduced in recognition of the addictive properties of benzodiazepine and z drug tranquillisers.

    Paragraph 5 of the consensus statement recommends that prescribers can henceforth breach those guidelines in non-specified "exceptional circumstances", determined by the practitioner. A main cause of tranquilliser addiction is bad prescribing by practitioners who become authorised by this statement to continue and extend misprescribing. Paragraph 5 of the consensus statement will legitimise long-term and life-long misprescribing and provide legal protection for doctors who do this.

  5. The draft consensus statement suggests that misprescribing will be reduced by referrals to alternative treatments for example:

    "Non-pharmacological options that can be used as alternatives or adjuncts to pharmacological treatment could include...lifestyle advice, psychological and social therapies and support (paragraph 11).

    In practice these treatments have long waiting lists and are not readily available. APPGITA has recommended that the way to reduce the misprescribing of tranquillisers is by enforcement of the existing prescribing guidelines.

  6. The consensus statement refers all prescribing issues back into the hands of the doctors but these are the people who misprescribed in the first place and were a main cause of the present 1.5 million long-term users of prescribed tranquillisers.

    "regular review by practitioners with suitable expertise and understanding of the risks ... interventions for anxiety, depression and pain conditions."(paragraph 5) "patients and requires suitable expert support." (Paragraph 6).

    Student doctors receive little or no training in pharmacology, their knowledge of drugs and prescribing are informed by promotional literature from pharmaceutical companies and the habits of other doctors. The tranquilliser expertise that the consensus assumes for the medical profession does not exist. A large number of doctors do not understand these powerful drugs, do not understand how to withdraw patients and do not observe the prescribing guidelines.

CONSENSUS

Consensus decision making is a group decision making process. I have copied two examples of the requirements for a consensus process from a list provided by Wikipedia.

As a decision-making process, consensus decision-making aims to be:

Egalitarian: All members of a consensus decision-making body should be afforded, as much as possible, equal input into the process. All members have the opportunity to present, and amend proposals.

Inclusive: As many stakeholders as possible should be involved in the consensus decision-making process.

The Department of Health Roundtable process did not meet these requirements. It was not an inclusive process because the following stakeholders were excluded from the group:

  1. Patients' representatives: No expert recovered patient was invited to the group.

  2. Professor Heather Ashton is a recognised expert on benzodiazepines and benzodiazepine withdrawal. She was not invited to the Roundtable despite requests from Roundtable members.

  3. APPGITA. The All Party Parliamentary on Involuntary Tranquilliser Addiction was formed by Members of Parliament in response to complaints from constituents about the effects of tranquillisers and the lack of services. An All Party Parliamentary Group is a legitimate part of the policy making process yet APPGITA was specifically excluded despite requests from Roundtable members.

  4. Pharmaceutical manufacturers are stakeholders; they continue to profit from addiction to prescribed drugs and exercise no self-restraint. Manufacturers could have been held to account at the Roundtable and asked to help and fund a clean up operation.

The Roundtable decision process is not egalitarian as members do not have equal status; the service users attending do not have a vote in the decision making process.

The Roundtable's composition, agenda and statement content have been determined by a controlling group of Departmental officials. The statement cannot therefore be regarded as a consensus statement and can be more properly described as a statement of an imposed hierarchical decision.

The consensus statement is to be used in an attempt to confer legitimacy for yet unspecified arrangements.

The Roundtable does not have one medically or scientifically qualified expert on tranquillisers or antidepressants. Similarly the NTA does not have any qualified expert on the subject for which they have been given responsibility. The NTA do not have any expertise or experience in prescribed medication withdrawal, neither do their service providers who specialise in methadone maintenance programmes. Perversely, the NTA through the JSNA is dismantling the withdrawal expertise that does exist by removing the funding of the stand alone tranquilliser / anti-depressant charities, the first to feel the impact being CITA.

The APPGITA can only see this as an unpredictable and badly advised experiment with the health of patients. Roundtable members should take into account they have been asked to sign within seven days without a meeting or discussion and that no further meetings of the Roundtable are scheduled.

I ask Roundtable members to think carefully before they sign as to whether the group has the necessary expertise, whether they are fully informed and of the possibility of unforeseen consequences for patients from the consensus statement.

Yours sincerely,

Jim Dobbin MP
Chair, All Party Parliamentary Group on Involuntary Tranquilliser Addiction

Endorsed by Professor Heather Ashton

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