Peter Reynolds

The life and times of Peter Reynolds

Posts Tagged ‘BBC

BBC Executive Complaints Unit, Stage 3 Complaint Re: Interview Claiming ‘Cannabis More Harmful Than Heroin’.

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Louisa Philips Kulukundis

CLEAR has submitted a formal complaint to the BBC concerning its broadcast of the interview with Lousia Kulukundis in which she claimed that using heroin was safer than using cannabis.

BBC complaints are outsourced to Capita and are not actually considered by the BBC itself until they reach Stage 3, the ‘Executive Complaints Unit’.

From: Peter Reynolds
Sent: 22 September 2017 17:05
To: ‘ecu@bbc.co.uk’ <ecu@bbc.co.uk>
Subject: Request to review complaint CAS-4563673-ZNGCG0

Dear Sirs,

1. Please review the decision made in respect of this complaint.  The correspondence including complaints and responses at stages 1a and 1b are attached to this email.

2. The complaint concerns an interview with Louisa Kulukundis, a psychotherapist, a member of the British Association of Counselling and Psychotherapy (BACP).  The interview was broadcast as part of ‘Newsbeat Documentary Cannabis:Time for a Change’ which was repeated frequently on the BBC News channel and is available online.  It was also included within the ‘Newsbeat Debate: Cannabis’ also broadcast on the BBC News channel and also available online.

A formal complaint about Ms Kulukundis’ conduct has also been made to the BACP.

During the interview Ms Kulukundis made the statement:

“I would say give me a room full of heroin addicts than skunk addicts. I remember saying to my older son I would prefer you to take heroin than to smoke skunk. There will be generations of kids with severe mental health issues.”

1.The points of complaint raised at 1b that need reconsideration are:

a. In broadcasting these comments which are dangerous, irresponsible and directly contradicted by all scientific and medical evidence, the BBC has acted negligently and endangered the lives of vulnerable, easily-influenced young people at whom this programme was targeted.

b. The relative danger and/or harms of heroin and cannabis cannot be justified as a matter of opinion or of ‘balance’ because they are clearly established scientific fact.

c. It is essential that the BBC should broadcast a correction with equal prominence and repeated as many times as the original programme. The BBC owes a duty of care to its viewers, particularly in the case of programmes for the young.  It must make clear that Ms Kulukundis’ words were incorrect, that heroin is hundreds of times more dangerous than cannabis to both physical and mental health and can lead to death.

Broadcasting this interview breaches the BBC Editorial Guidelines as follows:

a. “…we must give our audiences content made to the highest editorial and ethical standards.  Their trust depends on it.” 1.1

b. “ We must therefore balance our presumption of freedom of expression with our responsibilities…to provide appropriate protection for our audiences from harm.” 1.1

c. “Accuracy  is  not  simply  a  matter  of getting facts right; when necessary, we will weigh relevant facts and information to get at the truth.” 1.2.2

d. “…we  balance  our  right  to broadcast  innovative  and  challenging  content  with  our  responsibility  to  protect the vulnerable from harm…particularly  in  relation  to  the  protection of children.” 1.2.5

e. “We will be rigorous in establishing the truth of the story and well informed when explaining it.” 1.2.6

f. “We will always seek to safeguard the welfare of children and young people…while ensuring their dignity and  their  physical  and  emotional  welfare  is  protected  during  the  making  and broadcast of our output.  Content which might be unsuitable for children will be scheduled appropriately.” 1.2.9

g. “…accuracy  must  be  adequate  and  appropriate  to the  output,  taking  account  of  the  subject  and  nature  of  the  content,  the  likely audience expectation and any signposting that may influence that expectation.” 3.1

h. “Accuracy   is   not   simply   a   matter   of   getting   facts   right… we should check and cross check facts…corroborate claims and allegations made by contributors.” 3.1

i. “The  BBC  must  not  knowingly  and  materially  mislead  its  audiences.    We should  not  distort  known  facts,  present  invented  material  as  fact  or  otherwise undermine our audiences’ trust in our content.” 3.2.3

j. “We should normally acknowledge serious factual errors and correct them quickly, clearly and appropriately.” 3.2.4

k. “ In  all  our  content  we  must  check  and  verify  information,  facts  and documents,  where  required  to  achieve  due accuracy.” 3.4.2

l. “We should not   automatically   assume   that   the   material   is   accurate   and   should   take reasonable  steps,  depending  on  how  it  is  to  be  used  and  if  necessary  to achieve due accuracy, to seek verification.” 3.4.3

m. “We  must  not  knowingly  and  materially  mislead  our  audiences  with  our content.” 3.4.11

n. “We should consider the emotional impact pictures and personal testimony can have on perceptions of risk when not supported by the balance of argument.  If a  contributor’s  view  is  contrary  to  majority  opinion,  the  demands  of  due accuracy and due impartiality may require us to make this clear.” 3.4.21

o. “We should normally acknowledge serious factual errors and correct such mistakes quickly, clearly and appropriately.  Inaccuracy may lead to a complaint of  unfairness.    An  effective  way  of  correcting  a  mistake  is  saying  what  was wrong as well as putting it right.” 3.4.26

p. “When dealing with ‘controversial subjects’…Opinion   should   be   clearly distinguished from fact.” 4.4.7

q. “…when   personal   view   programmes…cover  ‘controversial  subjects’…we should:…retain a respect for factual accuracy.” 4.4.30

r. “The  BBC  must  apply  generally  accepted  standards  so  as  to  provide adequate  protection  for  members  of  the  public  from the  inclusion  of  offensive and harmful material.” 5.2.1

s. “We  must  not  broadcast  material  that  might  seriously  impair  the  physical, mental or moral development of children and young people.” 5.2.2

t. “…deal  with  all  aspects  of  illegal  drug  use…with due accuracy.” 5.4.42

I am happy to provide further information, evidence or detail on any aspect of this complaint.

Yours faithfully,

Peter Reynolds

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Written by Peter Reynolds

September 25, 2017 at 12:22 pm

We Should Encourage Peter Hitchens In His Bombastic Ways.

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Peter Hitchens clearly doesn’t realise what a turn off his rude, boorish behaviour is to 90% of people who watch him on TV. Of course, to the small minority who agree with him, it’s very effective rabble rousing just like an Islamist fanatic or a hard right hatemonger.  That’s exactly how he looks to most people and really we should encourage him to do more of the same.

Peter’s performance on BBC Sunday Morning Live followed a pattern all too-familiar to those who understand his tactics. Through such occasions his tone becomes increasingly strident, he interrupts everyone repeatedly, complains that no one has read his book, throws in a wild and dishonest claim about cannabis and mental health, then goes into full tantrum mode complaining he’s never allowed to finish his point.

He was accompanied today by David Raynes, the retired-in-disgrace, ex-customs officer who is well trained in Hitchens’ techniques. With a career one step up from a security guard, he now holds himself out as some sort of scientific and medical expert and has a ready made reefer madness story to add in while partnering with Hitchens on the interrupting, talking over and hectoring of other guests.

The moderation of the debate by Sean Fletcher was weak, ineffectual and really rather pathetic but I do sympathise.  Hitchens is a Machiavellian, calculated subverter of debate and only the very strongest can handle him.

But it’s clear that nowadays he digs himself deeper and deeper the more hysterical he becomes and the angrier he is, the more the weakness of his arguments is exposed.  Carry on Peter, you’re doing our job for us now.

Written by Peter Reynolds

September 24, 2017 at 9:51 am

Irresponsible, Reckless BBC Broadcasts Dangerous Claim That So-Called ‘Skunk’ is More Harmful Than Heroin.

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Louisa Philips Kulukundis. Psychotherapist at Soul Counselling, counsellor at Steps2Recovery, member of the British Association for Counselling and Psychotherapy.

“I would say give me a room full of heroin addicts than skunk addicts…

I remember saying to my older son I would prefer you to take heroin than to smoke skunk…

There will be generations of kids with severe mental health issues.”

Source: ‘Cannabis: Time for a Change?’ From 28:20

There is huge and justifiable righteous anger about the idiotic words spoken by this woman on the BBC Newsbeat documentary ‘Cannabis: Time for a Change?’

It would be easy to launch into a tirade against Ms Kulukundis but her words and their crass stupidity speak for themselves. I wonder how many kids, listening to her recommendation on the BBC’s ‘yoof’ channel will think ‘Well I’ve smoked weed loads of times with no trouble, now this woman who’s an expert says heroin is safer, maybe I’ll see if I can get hold of some.’

I understand that Ms Kulukundis supports the idea that cannabis with a higher proportion of CBD should be legally available instead of so-called ‘skunk’ which with zero or very little CBD dominates today’s illegal market.  She deserves credit for this and I would be very surprised if she wasn’t already regretting the very serious mistake she has made.

Ms Kulukundis does however subscribe to the falsehood that cannabis is a major cause of mental health problems.  The facts of hospital admissions and GP/community health service treatment prove this is not the case.  While we shouldn’t turn away from protecting those very few people who can be vulnerable, it is about time that the media started reporting accurately instead of the gross distortions and misrepresentation seen recently, particularly from the brazenly dishonest and ‘fake news’ Daily Telegraph.

Far, far more serious and the place where responsibility really lies for this broadcast is with the BBC.  Its negligence in allowing these words to be broadcast is unforgivable and CLEAR is pursuing a complaint.  The BBC’s complaints procedure is of course notorious for its determination to brush aside viewers’ concerns with anodyne responses that mean nothing. Many don’t realise that until you get to stage three you’re not even communicating with the BBC but with Capita to whom it outsources its complaints handling.  We will pursue this complaint until it reaches the BBC Editorial Complaints Unit and if necessary we will appeal it to OFCOM which, with the demise of the BBC Trust, is now the independent regulator.

It is a shame that the BBC has spoiled what is a clear shift in its position on cannabis.  Instead of mindless obedience to the government’s bad science and propaganda it is now recognising that reform is the only rational way forward.  As usual its coverage is dominated by stereotypical caricatures of what it regards as cannabis users.  It still seems incapable of recognising that most of the three million regular cannabis consumers in the UK are not relics of the hippy era but hardworking people with families and ‘ordinary’ lifestyles.  It also allowed its debate programme ‘Newsbeat Debates. Legalising Cannabis’ to be dominated by the ‘Gateway Theory’, an idea comprehensively disproven many times over, which even our prohibitionist government recognises is invalid.  What is the point of debate if it is hijacked by misinformation and not informed by science and evidence?

The BBC should take the initiative in apologising, correcting and broadcasting a full explanatuion of why Ms Kulukundis’ claim is scientifically inaccurate and extremely dangerous. Sadly, it will almost certainly have to be dragged kicking and screaming to provide any meaningful response at all.

 

 

 

Has There Ever Been A Worse UK Government Than This?

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I am a member of the Conservative Party – just.  My annual subscription is due and I feel physically sick at the prospect of doing anything that is supportive of the appalling collection of third and fourth rates that presently sit round the cabinet table.

The Conservative Party has Lost Its Way. We Need To Get Back To Being Tories.

We need to re-focus on our fundamental principles: individual liberty, individual responsibility, small government, free markets, evidence-based policy and a benevolent, responsible, one-nation approach.

Let’s face it, we’ve had a privileged toff, little more than a ponce on the nation, who from his position of wealth found it very easy to impose austerity on people with whom he was totally out-of-touch. Throughout his political career he vacillated and dithered on policy because he has no principles except self-advancement.  Now we have some fake Tory, an authoritarian bureaucrat with big government, nanny state instincts, daughter of a high Anglican priest stuck in some 195os delusion of what Britain is today.

Meanwhile, a socialist activist but a man with integrity, courage and vision has stolen our place.  Jeremy Corbyn provides more leadership in the UK than the entire Conservative cabinet put together.  He was magnificent at Glastonbury, seizing the hearts and minds of not just the young but the young at heart – seizing the future!  Where is the Tory alternative? There is great excitement, belief and enthusiasm for Brexit, 17.4 million people voted for it!  Where is the Conservative spokesperson passionately declaiming this?  The party has been hijacked by Remainers, determined to undermine the referendum result, interested only in the ambitions and concerns of the Westminster Elite.

When I try to talk to my MP, Sir Oliver Letwin, formerly number three in Cameron’s cabinet, although I am talking to someone a few months younger than me, I feel I am talking to my father’s generation – and to someone particularly old-fashioned and out-of-touch.  My local Conservative Party branch, charming though many of the members are, is like an episode of Last of the Summer Wine, as disconnected from the rest of the UK as Cameron is from anyone on less than £250k per annum.  At 59, I’m a youngster.

It’s outrageous really that my party has got itself into such a state with years of weak opposition, popular support for non-socialist policies and, until Corbyn, an absence of effective alternative leadership.  It’s nothing less than disastrous and unless we change now we are doomed.  The membership is old and dying.  If we don’t get a grip within five years we will be gone forever.

A Perfect Storm Of Failure, Corruption And Arrogance.

I’ve been fascinated by and active in politics since the late 1970s. Never in my lifetime have I seen such a combination of mistakes and scandalous cock-ups. Brexit has been sabotaged by dithering and delay – and I’m quite ready to believe this is a calculated deceit.  With the BBC, the bankers and the Twitterati renewing Project Fear on a daily basis, is it any wonder that the going is tough?  Cameron resigned because he said we needed a Leave supporter to take charge but instead we have a Remainer, one of the worst performing government ministers ever.  How, after six years of persistent failure at the Home Office, she became PM is beyond belief but even more incredible is that after her terrible election performance she is still in No. 10.  It is ridiculous!

The failures are all too easy to see but let’s list them to be certain that the huge scale of this crisis is understood.

Brexit – Total failure to plan, perhaps deliberately, best illustrated by the absurd spectacle, just last month, of the Home Office commissioning analysis of the economic and social contributions and costs of EU citizens in Britain.  Surely something that should have been done years ago?  Boris Johnson and Michael Gove have both proved themselves to be lacking in courage and leadership skills.  The bumptious fool Dr Liam Fox, who does seem to stick to his principles on Brexit, shames us by his foreign adventures, recently praising the murdering thug President Duterte of the Philippines as having ‘shared values’ with Britain.

NHS – Persistent deceit from ministers, including the utterly in-credible Jeremy Hunt, about how much money in real terms the health service is receiving.  Scandalous failure to keep multiple promises about mental health having parity with physical health.

Democracy – The UK’s system of government is now a joke compared to other modern democracies.  Our electoral system is primitive.  Conservative and Labour parties conspire to keep the system as it is because it keeps them both in power.  It is obvious that we should be moving towards some form of proportional representation, online voting and a radical shake-up of the House of Lords.  MPs also need to be much more accountable.  The terrible murder of Jo Cox has let too many of them off the hook that the expenses scandal put them on.  Recently they have been whining about the abuse they get online. In general they deserve it for the terrible job they are doing. Also, they get protection from the police for such abuse.  The police are useless when it’s a member of the public under attack.  We need a job description for MPs, rights for constituents and a complaints procedure with teeth.

Social policy – I am ashamed at how Conservative ministers in reality are indistinguishable from the populist caricature of the ‘arrogant, uncaring, effing Tories’.  The Grenfell Tower tragedy encapsulates everything that is wrong with the high-handed view that they take of the people who pay their wages.

Justice – After food, shelter and health what is more important than justice?  The destruction of legal aid is one of the most dreadful developments in my lifetime.  All governments delight in making more and more law but what use is it if it cannot be enforced?  There is no justice if it is not available to everyone.  I am delighted at the Supreme Court’s ruling that makes legal aid available once again for employment tribunals  Without it employment law was literally useless and thousands have been deprived of their rights.  And for his disastrous, destructive, incompetent and thoroughly nasty attitude the man who defines injustice in modern Britain is Chris Grayling.  No other minster has more disgraced our party.  He is unfit to be in government and why he remains anywhere near ministerial office is unbelievable.  No one individual better epitomises the nasty, arrogant, incompetent Tory.

Prisons – There is no greater truth than that in a free society we are defined by how we treat those we send to jail.  This is a terrible condemnation of Britain.  Our prison system is a production line for turning petty criminals into alienated, aggressive, violent repeat offenders.  There is no one who deserves the additional punishments we impose on top of deprivation of liberty.  I would make an exception for Chris Grayling who really should be made to experience a taste of his own medicine.  The Netherlands is closing prisons because it doesn’t send enough people to jail.  We should swallow our pride and copy their system exactly.

Technology – As the nation that has led the world in virtually all new technologies, we are now falling a long way behind.  The government has failed miserably to give enough priority to high speed internet.  We will never catch up now and our children and our businesses are forever disadvantaged.  Progress is hampered in development of new energy sources, transport and infrastructure by bureaucracy, endless bickering between special interest groups and weak strategic management.  The EU has magnified all these problems and prevented progress in GM foods and other technologies that are essential to our future.

Transport – With Chris Grayling at the helm and the farce that is HS2, there is no hope for a sensible transport strategy.  I simply don’t buy the argument that a slightly faster journey time between north and south will do anything to create a better future.  Train fares are ludicrously high.  The conditions commuters are expected to travel under are ridiculous.  The Southern Rail scandal is a microcosm of government incompetence and inaction.  It should have been re-nationalised at least a year ago and there should be massive fines and penalties on those responsible for the chaos, including individuals.  I see no conflict with Conservative principles in re-nationalising the whole network.  The mess that has prevailed since privatisation could not be any worse and compare us with railway networks and service on the continent for a true picture of our national shame and decay.

Environment – Technology and transport converge with environmental policy and this is a difficult, challenging area of policy.  What we need is strong leadership – no, not the empty claims of Mrs May but the real leadership of Mrs Thatcher.  Even the despicable Tony Blair showed more leadership than we have had from any current Conservative politician.  We need to take bold decisions and act on them.  Ecology and controlling pollution must be a real priority but we must not be distracted by the greeny loons and their endless prevarication and delays.  I have no objection to fracking as long as it is strictly regulated and in recent visits to Ireland I have seen how forests of wind turbines do not destroy wonderful countryside and can have their own beauty, just as we now revere Victorian aqueducts and civil engineering.  Most of all though we should racing ahead with tidal power.  As an island it has to be our future and its potential is unlimited.

Northern Ireland – I hope one of the by-products of Brexit will be a united Ireland.  There is no longer a real majority of unionists in the six counties and it only ever existed because of immigrants from Scotland.  The UK’s shameful history in Ireland places a heavy obligation on us.  We are one and the same people and the damage inflicted by the English Parliament on our neighbours must be put right.  We are far closer to the Irish than we are to the French, the Dutch or the Belgians.  As independent nations, with Ulster properly restored, we could be closer than ever and if Ireland wishes to remain in the EU, we should respect that.

Drugs Policy – No policy better demonstrates the incompetence, prejudice, cowardice and corruption of government ministers from all parties. Deaths from drug overdose have reached an all time high. There has been an explosion in highly toxic new psychoactive substances and the Psychoactive Substances Act 2016 has increased harms, deaths, associated crime and potency, exactly as was predicted, warnings the government chose to ignore.  The government has refused to consider or take any expert advice on introducing legal access to medical cannabis, something that virtually all other modern democracies are moving forward on. Its continuing policy on cannabis defies scientific evidence and real-life experience from places where reform has been implemented.  It also supports the criminal market, encourages street dealing, dangerous hidden cannabis farms and the production of poor quality, low-CBD, so-called ‘skunk’ cannabis.

Defence – A catalogue of cock-ups, dullards in charge and weak, indecisive leadership.  In my view we should cancel the renewal of Trident and  spend more on conventional weapons and defence measures which we may actually have to use.  We should retain some battlefield nuclear weapons but invest more in our soldiers and their technology. We should also look after them far better when they leave the service

Foreign Affairs – The UK is the world superpower in ‘soft power’.  Our culture, language, history give us more influence than any other nation and we should be proud to exercise it. We should have the courage to stand for our principles, independently of the USA and Europe.  The £12 billion we give in international aid is far too much when there is real poverty at home but even if we halved the present budget we would still lead the world.  We are responsible for the injustice perpetrated on the Palestinian people when we facilitated the seizure of their land in the 1940s.  We should be standing up to Israel which has become an out-of-control monster.  We created it and we must take responsibility for bringing it to order and helping it to live alongside its neighbours respectfully.  Its conduct is unacceptable and we should be pursuing war crimes prosecutions against Netanyahu and many of his cronies.

Housing – The housing crisis needs a courageous, radical solution, not the pathetic, sticking plaster gimmicks and gestures that is all we have had for 50 years.  Massive investment in social housing would create jobs and boost the economy all round.  We shouldn’t hesitate.  We shouldn’t fear a dramatic fall in house prices caused by massive extra supply. We have to get real and government must stop shirking its responsibility for a strategic role that only it can fill.

Boris is the only one with a brain

I have not yet decided whether I shall renew my membership.  I’m not even sure if there is any future in the UK for me.  Brexit was a great opportunity which has been sabotaged, perhaps fatally.  Britain may well become a tourist destination, fascinating for the way such a small nation led the world for centuries.  We are being led by weak, ineffectual, self-serving, out-of-touch and out-of date politicians.  As the Conservative Party is dying, it is dragging Britain down with it.

More Misguided Expenditure From The Monkeys At The BBC.

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baby-chimp

The BBC can mount a year-long investigation into the trade in baby chimpanzees and drown us all in heartbreaking, sentimental images for days on end.

But when it comes to the hundreds of thousands of people who live in pain, suffering and disability in the UK, in constant fear of a knock at the door because they use medicinal cannabis, the BBC are just stooges and slaves to government misinformation.

The only time the BBC covers the medicinal cannabis issue is when it’s forced to by proceedings in Parliament or when its promoting the work of cannabis oil scammers and rip off artists as it has done on BBC3 recently.

One properly funded documentary, interviewing patients, scientists, doctors and people involved in the genuine campaign could force our government to change its wicked and cruel policy.  That wouldn’t suit the BBC’s paymasters though would it?   They’re the same people as enforce the evil policy in the first place.

Written by Peter Reynolds

February 2, 2017 at 5:05 pm

Theresa May Is Not A Tory, She’s An Authoritarian Bureaucrat.

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LONDON, ENGLAND - JANUARY 17: British Prime Minister Theresa May delivers her keynote speech on Brexit at Lancaster House on January 17, 2017 in London, England. It is widely expected that she will announce that the UK is to leave the single market. (Photo by Kirsty Wigglesworth - WPA Pool /Getty Images)

LONDON, ENGLAND – JANUARY 17: British Prime Minister Theresa May delivers her keynote speech on Brexit at Lancaster House on January 17, 2017.

At the beginning of last week, Tuesday, 17th January, Theresa May finally made clear that leaving the EU means leaving the single market.  It also means leaving the customs union because without doing so it will be impossible to negotiate independent trade agreements.

This has been obvious all along.  Before the referendum, campaigners on both sides were clear. The idea that there was any doubt about it was an invention of the soft-left Blairites at the BBC, eagerly supported by the delusional Tim Farron and his party, now the most illiberal, anti-democratic party in Britain.

I’m unhappy that Ms May didn’t make this clarification a lot sooner but of course she was a Remainer and as David Cameron said, it would be foolish to have a captain to steer the ship in a direction he or she didn’t want to go.

I am generally very unhappy about Ms May’s style of government.  It is secretive, authoritarian, dismissive of public opinion and everything is played very close to her chest and as much behind closed doors as she can get away with.  Her dictatorial, micro-managerial style at the Home Office is continuing in her role as PM and I believe it is unsustainable for the leader of our country. We need far more openness, interest in the people and a desire to inform rather than to conceal.

But the shocker for me was her repudiation of central Conservative philosophy.  She derided the ‘cult of individualism’ as she put it.

DF-SC-85-12090Ms May, the Tory Party is all about the individual.  It is  about individual liberty and individual responsibility.  Individualism is the very essence of why I am a Tory.

Then today the brazen cover up about the Trident missile launch which was kept secret from Parliament, even as it was debating the renewal of our nuclear deterrent. Her secretive, fundamentally dishonest approach was revealed as she dodged Andrew Marr’s questions again and again.  It is obvious that she did know about the incident, chose to keep it secret from both Parliament and the electorate and refused to be honest about it when questioned.

I am , of course, reminded about her attempt to falsify and cover up the International Comparators report on drugs policy which showed clearly that harsher criminal sanctions have no affect at all on drugs use.  This didn’t fit with her prohibitionist prejudice and she wanted it changed to deceive Parliament and the electorate.

I have given Theresa May a more than adequate, even generous, chance to prove herself, particularly given my knowledge of her conduct as Home Secretary.  She was the right compromise candidate at the time but now the Conservative Party needs to get rid of her and appoint someone with leadership ability.  I was impressed with her initial words about inclusiveness and a country that ‘works for everyone’ but I see now that the leopard has not changed its spots.  She is authoritarian, illiberal, secretive, anti-democratic and, most importantly, dishonest.

Theresa May is no Tory and she is not fit to be prime minister.

 

CLEAR’s Submission To The Parliamentary Inquiry Into Medicinal Cannabis

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clear-appg-response-fc

This was the response that CLEAR submitted to the APPG in February 2016.  In March 2016, Roland Gyallay-Pap, then managing director of CLEAR and Peter Reynolds, president, were called to give oral evidence to the Inquiry.

A PDF copy of this document may be downloaded here.

A copy of the Powerpoint presentation delivered by CLEAR at the oral evidence hearing can be downloaded here.

 

Introduction

In June 2015 the All-Party Parliamentary Group for Drug Policy Reform (APPG) published a short report arguing for a rescheduling of cannabis to make it more widely available for medical use. Following the publication of that report there are a number of key questions remaining that it would like to address by means of a Short Inquiry.

CLEAR Cannabis Law Reform has been asked to submit evidence to the Inquiry in answer to these specific questions:

  • Whether switching the medical status of cannabis from schedule 1 to a less restrictive schedule would be beneficial?
  • What do you understand to be the range and extent of unofficial use of cannabis for medical purposes?
  • What has been the impact of the current schedule 1 status on research into the medicinal uses of cannabis?
  • Is there useful evidence emerging from the regulation of cannabis in over 20 US states and elsewhere and what does it tell us about the case for cannabis to be included in the UK pharmacopeia?
  • What would be the implications of licencing cannabis for medicinal use following a change in Schedule?
  • What role could EU regulations play in developing the potential for the medicinal use of cannabis?

We have also added a further response with additional information.

  • Access to prescribed Bedrocan medicinal cannabis is already possible based on careful use of loopholes and errors in existing English law.

 

Whether switching the medical status of cannabis from schedule 1 to a less restrictive schedule would be beneficial?

Yes, we consider that switching cannabis from schedule 1 to a less restrictive schedule would be beneficial, both so that it could be prescribed by doctors as medicine and so that it could more easily be used in research into its use and effects.

Cannabis has been in schedule 1 of the Misuse of Drugs Regulations1 (MoDR) since the Misuse of Drugs Act 19712 (MoDA) came into force.  Drugs in schedule 1 are specified as having no medicinal value.  However, an inquiry by the House of Lords Science and Technology Committee published in 19983 recommended that doctors should be permitted to prescribe cannabis and that it should be moved to schedule 2.  Strangely the government’s response to this recommendation was further to tighten restrictions by the Misuse of Drugs (Designation) Order 20014, which designates cannabis under section 7(4) of MoDA so that it is unlawful for a doctor, dentist, veterinary practitioner or veterinary surgeon, acting in his capacity as such, to prescribe, administer, manufacture, compound or supply” it.

In fact, cannabis has already been re-scheduled into schedule 4 under the international non-proprietary name of nabiximols (Sativex)5.  Although this is specified as being an extract of THC and CBD, it is clear from statements by the manufacturing company, GW Pharmaceuticals, that nabiximols is whole plant cannabis.  Dr Geoffrey Guy, founder and chairman of GW, is on the record:

“Most people in our industry said it was impossible to turn cannabis into a prescription medicine. We had to rewrite the rule book. We have the first approval of a plant extract drug in modern history. It has 420 molecules, whereas every other drug has just one.”6

GW pharmaceuticals has confirmed that this quotation is accurate.7

The MHRA has chosen to issue a marketing authorisation8 for nabiximols (Sativex) by regarding it as only a two molecule medicine.  The marketing authorisation is therefore at best inaccurate, at worst dishonest.

 

What do you understand to be the range and extent of unofficial use of cannabis for medical purposes?

In 2011, CLEAR commissioned independent, expert research from the Independent Drug Monitoring Unit (IDMU).  The report, ‘Taxing the UK Cannabis Market’9, reveals there are three million people using cannabis in the UK regularly (at least once per month).  Since then CLEAR has regularly polled its members and followers and consistently one in three of respondents claim at least some part of their use is for medicinal reasons.  It is reasonable to estimate therefore that there are up to one million people using cannabis for medicinal purposes in the UK.  It is certain that there are hundreds of thousands of medicinal users and previous estimates in the region of 30,000 are far too low.

The most common indications for medicinal use declared by our respondents are chronic pain, fibromyalgia, Crohn’s disease, multiple sclerosis and cancer.

Our interpretation of the responses we have received is that generally cannabis is used as a palliative agent.  Some people find it so effective that they consider it to be a ‘cure’ as long as they keep using it.  Others find it extremely helpful in reducing the amount of toxic and/or dangerous pharmaceutical medicines they are prescribed.  Often the side effects of pharmaceutical medicines are severe and debilitating and cannabis offers a way of minimising these.

CLEAR maintains a Medicinal Users Panel10 which members join in order to gain support in lobbying their MPs and/or attempting to obtain prescribed Bedrocan medicinal cannabis.  The active membership of the panel varies between 20 to 80 people.  Panel members have also been involved in delegations to meet government ministers and other parliamentarians

 

What has been the impact of the current schedule 1 status on research into the medicinal uses of cannabis?

In the UK there is very little research into the medicinal uses of cannabis, except that undertaken by GW Pharmaceuticals11.  There has been some research carried out into single cannabinoids but the evidence is that the therapeutic effects of cannabis depend on the whole plant ‘entourage effect’.

The allopathic, reductionist approach to medicine, which is reflected in the way that the MHRA regulates medicines, is the fundamental, establishment  doctrine that impedes research into cannabis.

Sadly, one of the biggest trials of MS patients, the CUPID study at the University of Plymouth12, intended to look at the many anecdotal reports of benefit, used synthetic THC and consequently the results were disappointing and irrelevant to the claims it sought to test.

It is far easier to obtain funding for research into the harms of cannabis which is undertaken with an almost absurd degree of repetition, most notably by the Institute of Psychiatry at King’s College London (IOPPN).13  It is also worth noting that IOPPN regularly and consistently overstates the results of its research, encouraging the media to report causal effects between cannabis use and mental illness which its research does not support.14

There is a huge stigma around cannabis, largely due to inaccurate, misleading and hysterical press coverage.  For instance, neither of the pre-eminent MS patient groups, the MS Society and the MS Trust, will take a stand in support of patients, despite the fact that many use cannabis. Similarly, despite extraordinary human clinical trial results on Crohn’s disease, none of the Crohn’s patient groups will engage with the campaign.  Mention cannabis and calls are not returned, people are scared by the stigma.  The immediate reaction from all such patient groups is to overlook evidence of benefit and refer to risks to mental health which, in fact, are very low compared to pharmaceutical products.  The press, unchallenged by politicians in its disproportionate attention to these risks, bears a heavy responsibility for this stigma and the lack of research.

Unlike many within the reform movement, CLEAR recognises and values the expertise and achievements of GW Pharmaceuticals.  However, any doctor or scientist that expresses any interest in medicinal cannabis in the UK is immediately retained or contracted by GW. We receive hundreds of reports of doctors, GPs and consultants, who tacitly and sometimes explicitly support their patients’ use of cannabis but it is impossible to find any doctor who is prepared to speak out publicly.  In the few instances where doctors have spoken out on behalf of patients, they have been contacted by Home Office officials and warned. One GP reported that he felt “intimidated”. By contrast, there are tens of thousands of doctors across Europe, Israel and North America who advocate for the use of medicinal cannabis and further research into its applications.

The security and record-keeping requirements for cannabis as a schedule 1 drug15 are wildly disproportionate to the real potential for harm, requiring a high security safe for storage and an audit trail fit for Fort Knox.

In addition the fee for a high THC licence is currently £4700.00 per annum and applications can take more than a year to process. These requirements, delays and corresponding costs severely impede research into medicinal cannabis.

Recently, in response to two government e-petitions, the Home Office issued the following statement:

In 2013 the Home Office undertook a scoping exercise targeted at a cross-section of the scientific community, including the main research bodies, in response to concerns from a limited number of research professionals that Schedule 1 status was generally impeding research into new drugs.

Our analysis of the responses confirmed a high level of interest, both generally and at institution level, in Schedule 1 research. However, the responses did not support the view that Schedule 1 controlled drug status impedes research in this area. While the responses confirmed Home Office licensing costs and requirements form part of a number of issues which influence decisions to undertake research in this area, ethics approval was identified as the key consideration, while the next most important consideration was the availability of funding.”

We consider this response to be disingenuous and misleading.  Cannabis is  a special case.  It is a combination of hundreds of molecules, unlike other schedule 1 drugs, most of which are single molecules.  Also, as is well established in written and archaeological evidence, cannabis has been used effectively for at least 5,000 years as medicine without any evidence of harm.

Furthermore. ethical approval and funding are difficult largely due to the evidence-free scaremongering about cannabis and the consequential stigma, in which the Home Office plays a leading role.  Ethical approval and funding do not seem to be a problem in researching potential harms of cannabis.  Indeed, as noted above, there is a massive amount of such research even though much of it is repetitive and inconclusive.

Until it is recognised that for many years, under successive governments, the Home Office has been systematically misleading and scaremongering about cannabis, it is difficult to see how an evidence-based decision can be reached.  The Home Office regularly makes assertions about cannabis that are completely without evidential support.  There is an established prejudice  and determination to misinform and this must be tackled at root as it amounts to misconduct and corruption.

 

Is there useful evidence emerging from the regulation of cannabis in over 20 US states and elsewhere and what does it tell us about the case for cannabis to be included in the UK pharmacopeia?

There is a vast amount of peer-reviewed, published evidence of the safety and efficacy of cannabis as medicine.  Much of this arises from research carried out in the USA, the Netherlands and Israel, where medicinal cannabis regulation has been in place for many years.

It is a populist myth, promoted by the Home Office, the press, the BBC and the prohibitionist lobby, that there is no evidence supporting the use of cannabis as medicine.

In February 2015, a delegation of medicinal cannabis users from CLEAR met with George Freeman MP, the life sciences minister, at the Department of Health who is largely responsible for medicines regulation. At the conclusion of the meeting, Mr Freeman requested CLEAR to produce a summary of the available evidence.

The result is the paper ‘Medicinal Cannabis:The Evidence’16 (MCTE) which has received international acclaim, so much so that in association with Centro de Investigaciones del Cannabis (CIC), a Colombian non profit association, a Spanish language version has been published.

MCTE was submitted to George Freeman MP in April 2015.  Since then he has repeatedly refused to meet CLEAR again or respond to us directly, even after multiple requests from individual MPs representing CLEAR members. His only responses, received through third parties, fail to address the evidence at all. He simply refers to the legal status of cannabis, the theoretical availability of Sativex and the MHRA process for issuing marketing authorisations in respect of medicines.

This refusal to engage, acknowledge or properly consider the very large amount of evidence that is available is indicative of an inexplicable prejudice within government. Although conspiracy theories abound, it is difficult to understand why ministers adopt this position.

Cannabis was one of the most used medicines in the British pharmacopeia until only about 100 years ago.  It could be restored immediately by a stroke of the Home Secretary’s pen to remove it from schedule 1.  This would immediately make it possible for doctors to prescribe medicinal cannabis from Bedrocan17, the Netherlands government’s exclusive contractor.

Bedrocan cannabis is carefully regulated by the Netherlands government’s Office of Medicinal Cannabis. It is available in five different THC:CBD ratios.  It is already exported to many countries in Europe and the company has established itself in Canada as well.  It is less than a tenth the cost of Sativex for equivalent cannabinoid content and can be consumed either by a medical vapouriser or as an infusion.

No minister in this or any previous government has ever presented a coherent reason for the refusal to allow cannabis to be used as a medicine.  Their only response is to fall back on largely spurious or exaggerated claims about the harms of recreational use.

 

What would be the implications of licencing cannabis for medicinal use following a change in Schedule?

Cannabis would not need to be ‘licenced’ for medicinal use following a change in schedule.  As soon as it removed from schedule 1, doctors would be able to prescribe it and businesses interested to grow, process and develop cannabis medicines would be able to obtain cultivation/possession licences from the Home Office.

Medicines are no longer ‘licenced’ in the UK.  The MHRA grants marketing authorisations. The initial fee, simply for filling in the application form is £103,000.00, thus prohibiting any but the very largest, established businesses from even considering such a venture.  The very term ‘marketing authorisation’ reveals the mindset of medicines regulators which is now more about commercial interests than the evaluation of the safety and efficacy of medicines.

The MHRA does have a regulatory scheme for ‘Traditional Herbal Registration’ (THR) but it only applies if the medicine is used for minor health conditions where medical supervision is not required.”.  An application for a THR for cannabis could not be made while it remains in schedule 1 but, if granted, would not permit its use for many conditions where there is excellent evidence of its efficacy.

The MHRA is locked in an inflexible, unscientific and restrictive process which can only evaluate medicines which are either one or two molecules.  Its process is designed for synthetic, potentially very dangerous molecules and is entirely unsuitable for a plant based medicine such as cannabis.  This is why, as explained above, Sativex has been improperly regulated as containing only two molecules: THC and CBD.

When the Sativex (nabiximols) patent expires, independent analysis of the medicine would certainly demonstrate that it is whole plant cannabis oil.  Presumably alternative and/or generic versions could then be produced.  However, by any standards, for all parties, the regulation and scheduling of Sativex is inaccurate, if not dishonest, and needs revision.

If cannabis is removed from schedule 1, most appropriately to schedule 4 alongside Sativex, in our judgement there will be a large number of businesses applying for cultivation/possession licences for research which will eventually result in applications for marketing authorisations.  In the meantime, it can only be described as cruel and evidence-free not to permit doctors to prescribe Bedrocan, a safe, effective medicine already regulated by another European government.

It is likely that enabling the prescription of Bedrocan would result in substantial savings to the NHS medicines budget.  However, any idea that this could be quantified based on existing evidence is fanciful.  Certainly, compared to existing prescription medicines and Sativex, Bedrocan is very inexpensive, probably less than 10 euros per patient per day.  However, the complexity of calculating which medicines it could replace by individual, partly or wholly and for how long makes the exercise so hypothetical as to be meaningless.

It must be true that once local, UK-based cultivation of medicinal cannabis was permitted, prices would reduce even further.

 

What role could EU regulations play in developing the potential for the medicinal use of cannabis?

Aside from France and Ireland (which is moving rapidly towards drugs policy reform), every other EU country has a more intelligent, compassionate and evidence-based policy towards medicinal cannabis.  Based on existing policy and its record, the UK government would simply refuse to comply with any EU regulation of medicinal cannabis.

Under the Schengen Acquis (of which UK is a signatory, though not to the full Schengen Agreement), if a medicine is prescribed to a resident of a member state, that resident may travel to other member states with up to three month’s supply under the protection of a Schengen certificate.  The effect of this is that a resident of the Netherlands, Belgium, Finland, Germany, Italy, etc. can bring prescribed cannabis, likely Bedrocan, into the UK and use it without restriction.

The crucial test here is residency, so it is not possible for a UK resident to travel to another country, obtain a prescription and then return to the UK legally with cannabis.  Presently, a Schengen certificate for a UK resident has to be issued by the Home Office.  Strangely and in contravention of this explicit provision, Norway (Non EU but a signatory to Schengen) does permit its residents to obtain prescriptions, usually in the Netherlands, and return home with cannabis.

It is also likely that given the hostility towards EU regulation, adding cannabis into that debate would be counterproductive.  It would be used as another stick with which to beat the EU.

 

Access to prescribed Bedrocan medicinal cannabis is already possible based on careful use of loopholes and errors in existing English law.

As some members of the APPG are aware, CLEAR has been involved in trying to obtain legal access to prescribed Bedrocan since 2012. We now have approximately a dozen members who regularly receive private prescriptions from their doctors (both consultants and GPs) and travel to the Netherlands to have them dispensed.

In all instances, these individuals have either declared their medicine at customs and/or have made prior arrangements with the Border Force, producing supporting documentation.

This is possible because of errors and inconsistencies in the MoDA and the MoDR.  All English drugs legislation, including the recent Psychoactive Substances Act 2016, is badly drafted, contradictory and scientifically illiterate.

The principle active ingredients of cannabis are delta-9-THC and cannabidiol (CBD).  Bedrocan products are specified with different ratios of these substances.  While cannabis is classified in schedule 1, so is delta-9-THC but it is also in schedule 2 described as dronabinol, which is the international non-proprietary name (INN) for delta-9-THC.  CBD is not a controlled drug.

Therefore, if a doctor is prepared to write a prescription e.g. dronabinol (Bedrocan 22%) or dronabinol (Bediol 7.5%), three month’s supply of the medicine may be legitimately imported as a schedule 2 drug.

In the past four years only one CLEAR member has been frustrated in this.  He had his medicine seized but he was not prosecuted.  An appeal against the seizure failed.

Clearly, the vital factor in this scheme is a doctor who understands the law and the science and is prepared to write the prescription.

 

References

 

1. Misuse of Drugs Regulations 2001 http://www.legislation.gov.uk/uksi/2001/3998/contents/made
2. Misuse of Drugs Act 1971 http://www.legislation.gov.uk/ukpga/1971/38/contents
3. House of Lords Science and Technology Committee report 1998 http://www.parliament.the-stationery-office.co.uk/pa/ld199798/ldselect/ldsctech/151/15101.htm
4. Misuse of Drugs (Designation) Order 2001 http://www.legislation.gov.uk/uksi/2001/3997/made
5. Nabiximols (Sativex) https://en.wikipedia.org/wiki/Nabiximols
6. Cambridge News, 24th Jan 2012 http://www.cambridge-news.co.uk/Cannabis-company-enjoys-major-growth/story-22509041-detail/story.html
7. Email corres with Marc Rogerson, GW Pharma, 160312. Attached.
8. Sativex (nabiximols) marketing authorisation, MHRA , 2010 http://www.mhra.gov.uk/home/groups/par/documents/websiteresources/con084961.pdf
9. Taxing the UK Cannabis Market, IDMU, 2011 http://clear-uk.org/media/uploads/2011/09/TaxUKCan.pdf
10. CLEAR Medicinal Users Panel http://clear-uk.org/pages/medicinal-panel/
11. GW Pharmaceuticals website http://www.gwpharm.com/
12. CUPID study, University of Plymouth, 2015 http://www.ncbi.nlm.nih.gov/pubmed/25676540
13. Institute of Psychiatry at King’s College London website http://www.kcl.ac.uk/ioppn/index.aspx
14. King’s College Confirms Institute of Psychiatry Misled Media On Cannabis Brain Study. CLEAR, 2015 http://clear-uk.org/kings-college-confirms-institute-of-psychiatry-misled-media-on-cannabis-brain-study/
15. Controlled Drugs (Supervision of management and use) Regulations 2013, Dept of Health https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/214915/15-02-2013-controlled-drugs-regulation-information.pdf
16. Medicinal Cannabis: the Evidence, CLEAR, 2015 http://clear-uk.org/static/media/PDFs/medicinal_cannabis_the_evidence.pdf Attached
17. Bedrocan BV website http://www.bedrocan.nl/