Drug Abuse

1 J Doward, ‘Students warned of lethal risks from “legal highs”’, Observer, 20 Sep 2009, www.guardian.co.uk/society/2009/sep/20/legal-highs-lethal-risk (accessed 24 Mar 2011); Mixmag Drugs Survey 2010, Feb 2010.

2 R Gray, ‘Forty new legal highs made in China are being sold in Britain, Telegraph, 15 Jan 2011, www.telegraph.co.uk/journalists/richard-gray/8247808/Forty-new-legal-highs-made-in-China-arebeing-sold-in-Britain.html (accessed 24 Mar 2011).

3 EMCDDA, The State of the Drugs Problem in Europe: Annual Report 2010, Luxembourg: European Monitoring Centre for Drugs and Drug Addiction, 2010.

4 Home Office, ‘Controlled drugs list (updated October 2010),www.homeoffice.gov.uk/publications/drugs/drug-licences/controlled-drugs-list (accessed 24 Mar 2011).

5 P Reuter, Options for Regulating New Psychoactive Drugs: A review of recent experiences and an analytic framework, London: UK Drug Policy Commission, 2011.

6 NZLC, Controlling and Regulating Drugs, Wellington: New Zealand Law Commission, 2010, chapter 8.

7 ‘Mephedrone: meet the UK’s favourite new drug’, Mixmag, 12 Jan 2010.

8 Mixmag Drugs Survey 2010, Feb 2010; F Measham et al, ‘Tweaking, bombing dabbing and stockpiling: the emergence of mephedrone and the perversity of prohibition’, Drugs and Alcohol Today 10, no 1, Mar 2010; T Bates, ‘Britain battles with a dangerous “legal high”’, www.aolnews.com/2010/01/30/britainbattles-with-a-dangerous-legal-high/ (accessed 24 Mar 2011).

9 It is noteworthy that while the review was under way officials had already been using a general control on imports power, as far as we are aware for the first time in such circumstances, to seek to restrict and control supplies into the country.

10 Doward, ‘Students warned of lethal risks from “legal highs”’; ‘Mephedrone: meet the UK’s favourite new drug’.

11 V Wheeler, ‘NRG-1 is 25p a hit and will kill many more than meow’, Sun, 31 Mar 2010, www.thesun.co.uk/sol/homepage/news/2914372/NRG-1-is-25p-a-hit-and-will-kill-many-more-thanmeow.html (accessed 24 Mar 2011); R Porter, ‘‘‘Legal high” bath
salts Ivory Wave kill bride’, Daily Mail, 28 Aug 2010, www.dailymail.co.uk/news/article-1306877/Legal-high-bath-salts-Ivory-Wave-kill-bride.html (accessed 24 Mar 2011).

12 Measham et al, ‘Tweaking, bombing dabbing and stockpiling’; Bates, ‘Britain battles with a dangerous “legal high”’.

13 D Campbell, ‘Grasping the nettle: five strategies for a pressing problem’, Guardian, 11 Mar 2009, www.guardian.co.uk/world/2009/mar/11/prohibition-law-un-drugs-strategies (accessed 24Mar 2011); Bates, ‘Britain battles with a dangerous “legal high”’.

14 S. Bird, ‘Banned drug may have saved lives, not cost them’, Straight Statistics, 22 Nov 2010, www.straightstatistics.org/article/banned-drug-may-have-saved-lives-not-cost-them(accessed April 2011).

15 P Reuter and A Stevens, An Analysis of UK Drug Policy, London: UK Drug Policy Commission, 2007.

16 J Hoare and D Moon (eds), Drug Misuse Declared: Findings from the 2009/10 British Crime Survey, Home Office, 2010.

17 R Runciman (chair), Drugs and the Law: Report of the Independent Inquiry into the Misuse of Drugs Act 1971, London: Police Foundation, 2000.

18 Home Office, ‘Controlled drugs list (updated October 2010).

19 EMCDDA, The State of the Drugs Problem in Europe: Annual Report 2010.

20 Gray, ‘Forty new legal highs made in China are being sold in Britain’.

21 Prison Reform Trust, Bromley Briefings Prison Factfile, July 2010.

22 UKDPC, Reducing Drug Use, Reducing Reoffending, London: UK Drug Policy Commission, 2008.

23 T Feiling, The Candy Machine: How cocaine took over the world, London: Penguin, 2009; Transform, After the War on Drugs: Blueprint for regulation, Bristol: Transform Drug Policy Foundation, 2009.

24 N Dorn and A Jamieson, Room for Manoeuvre, London: DrugScope, 2000.

25 Runciman, Drugs and the Law; House of Commons Science and Technology Committee, Drugs Classification: making a hash of it?, HC 1031, London: The Stationery Office, 2006; House of Commons Home Affairs Committee, The Government’s Drugs Policy: Is it working?, Cm 5573, Norwich: HMSO, 2002.

26 This review will be published separately in its entirety by the UKDPC.

27 J Chapman, ‘Lessons from a pluralist approach to a wicked policy issue’, Integral Review 6, no 1, Mar 2010, 236, www.integralreview.org/current_issue/politics-issue_index.asp (accessed Nov 123 2010); J Chapman, System Failure, 2nd ed, London: Demos 2004;
J Chapman, C Edwards and S Hampson, Connecting the Dots, London: Demos 2009.

28 Ken Arnold, foreword to M Jay, High Society: Mind-altering Drugs in History and Culture, London: Wellcome Institute, 2010, www.wellcomecollection.org/whats-on/exhibitions/highsociety/the-book.aspx (accessed 28 Mar 2011).

29 J Wynne-Jones, ‘Stone Age man took drugs, says scientist’,Telegraph, 19 Oct 2008, www.telegraph.co.uk/news/newstopics/howaboutthat/3225729/Stone-Age-man-took-drugs-sayscientists.html (accessed 24 Mar 2011).

30 W Sneader, Drug Discovery: A history, Chichester: John Wiley, 2005; Y Zheng, The Social Life of Opium in China, Cambridge: Cambridge University Press, 2005.

31 ‘Too much of the hard stuff: what alcohol costs the NHS’, NHS Confederation Briefing, issue 193, Jan 2010, www.nhsconfed.org/Publications/Documents/Briefing_193_Alcohol_costs_the_NHS.pdf (accessed 24 Mar 2011).

32 Ibid.

33 ASH, ‘Facts at a glance: smoking statistics’, Action on Smoking and Health, Jan 2011, www.ash.org.uk/archived-pages/facts-at-aglance (accessed 24 Mar 2011).

34 D Nutt, L King and L Philips, ‘Drug harms in the UK: a multicriteria decision analysis’, Lancet 376, 2010, 1558–65.

35 T Babor et al, Drug Policy and the Public Good, Oxford: OUP; 2010.

36 UNODC, World Drug Report 2010, New York: UN Office on Drugs and Crime, 2010

37 Ibid.

38 Ecstasy used to be primarily manufactured in Europe, mainly because this is where the primary market for such drugs was. However, its production quickly spread to North America (Canada) and Asia. There are now indications it is manufactured in Latin American countries such as Argentina, Belize, Brazil, Guatemala and Mexico, and even in West Africa (UNODC, World Drug Report 2010).

39 UNODC, World Drug Report 2010.

40 Ibid.

41 Piperazines are a group of substances with similar chemical composition that are manufactured synthetically. The use of piperazines in ‘party pills’ began in New Zealand, and increasingly in Europe after 2004. Piperazines are not included in the UN 1971 Convention on Psychotropic Substances, though have been recommended for critical review by the World Health Organization. According to the EMCDDA, BZP (1-Benzylpiperazine) is a central nervous system stimulant with around 10 per cent of the potency of d-amphetamine. mCPP
(1-(3-chlorophenyl) is another piperazine, which has become even more widespread than BZP. In 2009 it was estimated that up to 50 per cent of ecstasy pills contained mCPP. mCPP could not be subject to controls initially because of its role in manufacturing anti-depressant medicines. TFMPP (1-(3-trifluoromethyl-phenyl)piperazine) is the third most commonly found piperazine, often found in conjunction with BZP. For more information see EMCDDA, ‘BZP and other piperazines’, www.emcdda.europa.eu/publications/drugprofiles/bzp (accessed 24 Mar 2011).

42 According to the UNODC’s, World Drug Report 2010, there are, presently, no national or international controls for piperazines, although some have been referred to the WHO which may lead to international control measures.

43 EMCDDA, ‘BZP and other piperazines’.

44 Reuter, Options for Regulating New Psychoactive Drugs.

45 EMCDDA, The State of the Drugs Problem in Europe: Annual Report

46 Reuter, Options for Regulating New Psychoactive Drugs.

47 EMCDDA, Polydrug use: patterns and responses, Luxembourg: European Monitoring Centre for Drugs and Drug Addiction, 2009.

48 K McElrath and C O’Neill, ‘Experiences with mephedrone preand post-legislative controls: perceptions of safety and sources of supply’, International Journal of Drug Policy, 2011.

49 New Zealand Law Commission, Controlling and Regulating Drugs, Wellington: New Zealand Law Commission, 2009.

50 J Sheridan et al, ‘Legal piperazine-containing party pills: a new trend in substance abuse’, Drug and Alcohol Review 26, 2007.

51 N Freye, Pharmacology and Abuse of Cocaine, Amphetamines, Ecstasy and Related Designer Drugs: A comprehensive review on their mode of action, treatment of abuse and intoxication, New York: Springer, 2009 (cited in Reuter, Options for Regulating New Psychoactive Drugs).

52 Information in the DAWN system is collected from a sample of hospital emergency departments on drug-related admissions. See Reuter, Options for Regulating New Psychoactive Drugs.

53 S Byrd, ‘Officials: “bath salts” are growing drug problem’, Washington Post, 23 Jan 2011.

54 D Frosch, ‘Government bans five chemicals used in marijuana stand-ins’, New York Times, 1 Mar 2011.

55 PI Dargan, S Albert and DM Wood, ‘Mephedrone use and associated adverse effects in school and college/university students before the UK legislation change’, QJM 103, 2010.

56 See for example: R Newcombe, The Use of Mephedrone (M-Cat,meow) in Middlesborough, Manchester: Lifeline Publications, 2009; Measham et al, ‘Tweaking, bombing dabbing and stockpiling’; McElrath and O’Neill, ‘Experiences with mephedrone pre- and post-legislative controls’.

57 EMCDDA, The State of the Drugs Problem in Europe.

58 Measham et al, ‘Tweaking, bombing dabbing and stockpiling’.

59 Europol and EMCDDA, Europol–EMCDDA Joint Report on a New Psychoactive Substance: 4-methylmethcathinone (mephedrone), 2010, www.emcdda.europa.eu/.../att_33263_EN_Final%20Joint%20Report%20mCPP.pdf (accessed 24 Mar 2011).

60 Ibid.

61 Mixmag Drugs Survey 2010, Feb 2010.

62 EMCDDA, The State of the Drugs Problem in Europe.

63 Measham et al, ‘Tweaking, bombing dabbing and stockpiling’.

64 Ibid.

65 SD Brandt et al, ‘The confusing case of NRG-1’, British Medical Journal 341, 2010.

66 ACMD, Consideration of the Naphthylpyrovalerone Analogues and Related Compounds, London: Advisory Council on the Misuse of Drugs, 2010.

67 Reuter, Options for Regulating New Psychoactive Drugs. For a description of triple uptake inhibitors see: ‘Triple reuptake inhibitors will inherit the depression market’, Outsourcing-Pharma.com, 8 Jul 2005, www.outsourcing-pharma.com/Preclinical-Research/Triple-reuptake-inhibitors-will-inheritdepression-market (accessed 8 Apr 2011).

68 McElrath and O’Neill, ‘Experiences with mephedrone pre- and post-legislative controls’.

69 Mixmag Drugs Survey 2011.

70 Reuter and Stevens, An Analysis of UK Drug Policy.

71 S Abrams, ‘Soma, the Wootton Report and cannabis law reform in Britain during the 1960s and 1970s’, in EMCDDA, A Cannabis Reader: Global issues and local experiences, Luxembourg: European Monitoring Centre for Drugs and Drugs Addiction, 2008.

72 Cabinet Office, Strategy Unit Drugs Report, London: Cabinet Office, 2003.

73 Hoare and Moon, Drug Misuse Declared.

74 Home Office, Review of the UK’s Drugs Classification System – A public consultation, London: Home Office, Crime and Drug Strategy Directorate, 2006. This is a draft of a consultation paper, which was not approved for publication in 2006. The draft is being released under freedom of information legislation.

75 UNODC, Making Drug Control ‘Fit for Purpose’: Building on the UNGASS decade, report by the executive director of the United Nations Office on Drugs and Crime, 2008, www.unodc.org/documents/commissions/CND-Session51/CND-UNGASSCRPs/ECN72008CRP17.pdf (accessed 25 Mar 2011).

76 Advisory Council on the Misuse of Drugs. Drug misuse and the environment. Home Office, London, 1998.

77 A Austin, ‘White privilege and illicit drugs’, Huffington Post, 4 Jan 2011, www.huffingtonpost.com/algernon-austin/white-privilegeand-illic_b_804130.html (accessed 24 Mar 2011).

78 A Stevens, Drugs, Crime and Public Health: The Political Economy of Drug Policy, Abingdon: Routledge, 2007.

79 See Police Reform and Social Responsibility Bill, written evidence to be reported to the house, 17 Feb 2011, www.publications.parliament.uk/pa/cm201011/cmpublic/policereform/110217/pm/110217s01.htm (accessed 24 Mar 2011).

80 Obtained from of-americans-now-say-they-support-marijuana-legalization/ (accessed Feb 2011).

81 British Social Attitudes socio-demographic cross-tabulations on whether cannabis should be legalised, results from 1983 to 2007, www.britsocat.com/Body.aspx?control=BritsocatMarginals&AddSuperMap=LBLEGCAN&JumpCrossMarginals=yes (accessed
April 2011).

82 EMCDDA, Illicit Drug Use in the EU: Legislative approaches, Luxembourg: European Monitoring Centre for Drugs and Drug Addiction, 2005.

83 M Szalavitz, ‘Drugs in Portugal: did decriminalization work’, Time, 26 Apr 2009, www.time.com/time/health/article/0,8599,1893946,00.html (accessed 24 Mar 2011).

84 A Stevens, ‘Britain’s drug policy will not improve until we are bold enough to experiment’, Observer, 5 Sep 2010, www.guardian.co.uk/world/2010/sep/05/portugal-uk-drugsdecriminalisation (accessed 24 Mar 2011).

85 G Greenwald, Drug Decriminalisation in Portugal, Washington: Cato Institute, Apr 2009, www.cato.org/pub_display.php?pub_id=10080 (accessed 24 Mar 2011).

86 CE Hughes and A Stevens, ‘What can we learn from the Portuguese decriminalisation of illicit drugs?’, British Journal of Criminology 50, 2010, 999–1022.

87 J Flatley et al (eds) Crime in England & Wales 2009/10, London: Home Office, 2010, p 15.

88 ProCon.org, ‘15 legal medical marijuana states and DC: laws, fees, and possession limits’, procon.org/view.resource.php?resourceID=000881 (accessed 24 Mar 2011).

89 K Johnson, ‘Where Marijuana is a point of pride’, New York Times, 7 Nov 2010.

90 M Shear, ‘Pat Robertson questions prison for pot conviction’, The Caucus: the politics and government blog of The Times, New York Times, 23 Dec 2010.

91 See for example R Carroll and P Harris, ‘War on drugs: why the US and Latin America could be ready to end a fruitless 40-year struggle’, Observer, 8 Aug 2010, www.guardian.co.uk/world/2010/aug/08/drugs-legalise-mexico-california (accessed 24 Mar2011).

92 BBC News, ‘Argentina rules on marijuana use’, 26 Aug 2009 (accessed 24 Mar 2011).

93 S Gibbs, ‘Mexico eases drug possession law’, BBC News, 21 Aug2009, (24 Mar 2011).

94 S Jenkins, ‘The war on drugs is immoral idiocy: we need the courage of Argentina’, Guardian, 3 Sep 2009.

95 Carroll and Harris, ‘War on drugs’.

96 D Barrett, ‘Is the decriminalisation of possession of controlled substances for personal use consistent with international law?’, International Centre on Human Rights and Drug Policy and the International Harm Reduction Association, Feb 2011, www.ihra.net/files/2011/02/12/IHRA_and_ICHRDP_Amicus.p df (accessed 24 Mar 2011).

97 Expert interview, 3 Aug 2010; D Nutt et al, ‘Development of a rational scale to assess the harm of drugs of potential misuse’, Lancet 369, 24 Mar 2007.

98 Nutt, King and Philips, ‘Drug harms in the UK’.

99 Drinkaware, ‘Why let good times go bad?’, www.drinksinitiatives.eu/files/313/why-let-the-good-times-gobad-report-final.pdf (accessed 24 Mar 2011).

100 ASH, ‘Facts at a glance: tobacco economics’, Action on Smoking and Health, Jan 2011, www.ash.org.uk/archived-pages/facts-at-aglance (accessed 24 Mar 2011).

101 Ibid.

102 J Melkle, ‘Shops to be banned from displaying tobacco products’, Guardian, 9 Mar 2011.

103 EMCDDA, The State of the Drugs Problem in Europe.

104 HM Government, Drug Strategy 2010, Reducing Demand, Restricting Supply, Building Recovery: Supporting people to live a drug free life, London: Home Office, 2010.

105 A Kay, ‘The agony of ecstasy: reconsidering the punitive approach to United States drug policy’, Fordham Urban Law Journal 29, 2002, 2163–66.

106 Reuter, Options for Regulating New Psychoactive Drugs.

107 M Szalavitz, ‘Outlawing “legal highs”: can emergency bans hinder drug development?’, Time, 2011/02/23/outlawing-legal-highs-can-emergency-bans-hinderdrug-development/ (accessed 24 Mar 2011).

108 ECMDDA, Risk Assessment Report of a New Psychoactive Substance:4-methylmethcathinone (mephedrone), Luxembourg: European Monitoring Centre for Drugs and Drug Addiction, 2010.

109 EMCDDA, The State of the Drugs Problem in Europe, Annual report 2009, Luxembourg: European Monitoring Centre for Drugs and Drug Addiction, 2009.

110 BZP is prohibited in a number of EU member states, including the UK, and in Australia and the USA. The USA took action first with an emergency scheduling in 2000 in response to three deaths that had been identified as involving the simultaneous use of BZP and MDMA. For literature on BZP in New Zealand see P Gee et al, ‘Toxic effects of BZP-based herbal party pills in humans: prospective study in Christchurch, New Zealand’, New Zealand Medical Journal 118, 2005; C Wilkins et al, ‘Legal party pill use in New Zealand: prevalence of use, availability, health harms and “gateway effects” of benzylpiperazine (BZP) and trifluorophenylmethylpiperazine (TFMPP)’, Auckland: Massey University Centre for Social and Health Outcomes Research and Evaluation, 2006; J Sheridan et al, ‘Legal piperazine-containing party pills: a new trend in substance abuse’, Drug and Alcohol Review 26, 2007.

111 J Sheridan and R Butler, ‘“They’re legal so they’re safe, right?” What did the legal status of BZP-party pills mean to young people in New Zealand?’, International Journal of Drug Policy 21, 2010.

112 Reuter, Options for Regulating New Psychoactive Drugs.

113 The Committee membership includes both medical and law enforcement personnel. The tone of the Committee reports is very much that of a medical or public health document, with careful attention to peer-reviewed studies and an emphasis on evidence.

114 NZLC, Controlling and Regulating Drugs, chapter 8.

115 The text of the bill can be found at www.oireachtas.ie/viewdoc.asp?fn=/documents/bills28/bills/2010/3410/document1.htm (accessed April 2011)

116 Szalavitz, ‘Outlawing “legal highs”: can emergency bans hinder drug development?’.

117 Reuter, Options for Regulating New Psychoactive Drugs.

118 Europa, ‘The precautionary principle’, legislation_summaries/consumers/consumer_safety/l32042_en.htm (accessed 24 Mar 2011).

119 NZLC, Controlling and Regulating Drugs, p 145.

120 Reuter, Options for Regulating New Psychoactive Drugs.

121 UKDPC, Drugs and Diversity: Disabled People, London: UK Drug Policy Commission, 2010.

122 Examples include the chief constables of Humberside – see M Townsend, ‘Cuts prompt police to call for debate on drugs and redirect resources’, Guardian, 18 Sep 2010, www.guardian.co.uk/society/2010/sep/18/police-chief-decriminalise-cannabis Sept 2010 (accessed 24 Mar 2011); of North Wales – see J Brown and D Langton, ‘Legalise all drugs: chief constable demands end to “immoral laws”’, Independent, 15 Oct 2007, www.independent.co.uk/news/uk/politics/legalise-all-drugschief- constable-demands-end-to-immoral-laws-396884.html (accessed 24 Mar 2011); and of South Yorkshire – see A Eckford,

‘Top road cop calls for change in drug law’, Auto Trader, 4 Jan 2007, www.autotrader.co.uk/EDITORIAL/CARS/news/ AUTOTRADER/33396.html (accessed 24 Mar 2011).

123 Sir Ian Gilmour, the retiring president of the Royal College of Physicians, called for the legalisation of heroin and cocaine. See S Borland, ‘Legalise heroin and cocaine to cut crime and improve health, top doctor says’, Daily Mail, 17 Aug 2010, www.dailymail.co.uk/news/article-1303590/Prof-Ian-Gilmore-Legalise-heroin-cocaine-cut-crime-improvehealth.html#ixzz16lDsmF61 (accessed 23 Feb 2011).

124 BBC News, ‘Ex-minister Bob Ainsworth: make drugs legally available’, 16 Dec 2010, www.bbc.co.uk/news/uk-12005824 (accessed Feb 2011).

125 Babor et al, Drug Policy and the Public Good.

126 For an extended discussion of what constitutes a ‘wicked issue’ see Chapman, Edwards and Hampson, Connecting the Dots.

127 P Checkland and J Scholes, Soft Systems Methodology in Action, Chichester: Wiley & Sons, 1999.

128 Data from the Department of Health show that the use of drugs declined from about 30 per cent to 22 per cent between 2001 and 2009; see figure 2.1 at www.ic.nhs.uk/webfiles/publications/Health per cent20and per cent20Lifestyles/sdd2009/SDD_ 2009_Report.pdf (accessed 23 Feb 2011).

129 High Society, an exhibition in London from November 2010 to the end of February 2011. Details including the book and events at Wellcome Collection, ‘High society’, www.wellcomecollection.org/whats-on/exhibitions/highsociety.aspx (accessed 24 Mar 2011).

130 RR Griffiths et al, ‘Mystical-type experiences occasioned by psilocybin mediate the attribution of personal meaning and spiritual significance 14 months later’, Journal of Psychopharmacology, 1 Jul 2008.

131 Our Drugs War was first shown on Channel 4 on 2 Aug 2010. See www.channel4.com/programmes/our-drugs-war/episodeguide/series-1/episode-1 (accessed 28 Nov 2010).

132 As illustrated by the papers by David Nutt in Lancet; see Nutt, King and Phillips, ‘Drug harms in the UK’.

133 Babor et al, Drug Policy and the Public Good.

134 The issue of obtaining better information about emerging NPAS was discussed in both workshops. Some of the more innovative ideas arose in the second workshop but are incorporated here for clarity.

135 Runciman, Drugs and the Law.

136 This is optimistic since the street price of cannabis, ecstasy, amphetamines, heroin and cocaine has steadily declined over the last 40 years, implying that supply is more than meeting demand.

137 C Lloyd, ‘Cannabis’ in C Lloyd and N McKeganey, Drugs Research: An overview of evidence and questions for policy, York: Joseph Rowntree Foundation, 2010.

138 This advice was to avoid immediately criminalising the users who had purchased supplies while the compounds were legally available on the internet.

139 ACMD submission to the Government’s Drug Strategy Consultation, 8 Oct 2010, www.homeoffice.gov.uk/publications/drugs/acmd1/acmd-response-drug-strategy-2010?view=Binary (accessed 24 Mar 2011).

140 H Ghodse et al, ‘Trends in UK Deaths Associated with Abuse of Volatile Substances 1971–2008, Volatile Substance Abuse (VSA) Mortality Project, London: International Centre for Drug Policy, St George’s University of London, 2010, www.sgul.ac.uk/research/projects/icdp/pdf/1vsa-annual-report-2010-finalversioncorrigenda.pdf (accessed 8 Apr 2011).

141 UKDPC, ‘Commission calls for a new category for drug control– “category X”’, press release, 19 Mar 2010, www.ukdpc.org.uk/resources/Category_X_Media_STATEMENT_final.pdf(accessed 24 Mar 2011).

142 RSA, Drugs – Facing Facts, London: Royal Society of Arts, 2007.

143 Ibid.

144 L King, Forensic Chemistry of Substance Misuse: A guide to drug control, London: Royal Society of Chemistry, 2009.

145 Babor et al, Drug Policy and the Public Good.

146 HM Government, Drug Strategy 2010.

147 See www.talktofrank.com/ (accessed 26 Mar 2011).

148 Reuter, Options for Regulating New Psychoactive Drugs.

149 H Eichler et al, ‘Balancing early market access to new drugs with the need for benefit/risk data: a mounting dilemma’, Nature Reviews Drug Discovery 7, 2008.

150 Reuter, Options for Regulating New Psychoactive Drugs.

151 Ibid.

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