Letter from Jim Dobbin MP to Equality and Human Rights Commission (22 August 2010)

House of Commons Portcullis

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

Equality and Human Rights Commission                                       Jim Dobbin MP
Corporate Communications Officer                                                House of Commons
3rd Floor Lancaster House                                                               Westminister
67 Newhall Street                                                                            London SW1A OAA
Birmingham
B3 1NA                                                                                            22nd August 2010

Dear Sir,

I am making a formal complaint under the EHRC complaints procedure with regard to the lack of action on the submission made from my office on 20th July 2009 on the subject of Involuntary Tranquilliser Addiction. The submission complained that the UK government, particularly the Department of Health and the Department of Work and Pensions, has systematically discriminated against involuntary tranquilliser addicts for many years on the basis of their illness and disability.

The Commission’s response has been to await the outcome of the Department of Health’s review of policy on addiction to prescribed drugs in the belief or hope that the issues raised in my submission will be addressed. A close examination of the terms of reference, composition and process of the review shows that is unlikely to be the case.

The review’s terms of reference do not fully cover the subject matter of the submission.The original submission identified the following five forms of discrimination. Additionally a sixth complaint has arisen from the conduct of the department’s review.

  1. Exclusion from appropriate medical treatment by the Department of Health.
  2. Failure to treat or recognise the tranquilliser post-withdrawal syndrome by the Department of Health.
  3. Non-recognition of the illness of Involuntary Tranquilliser Addiction or post-withdrawal syndrome in processing benefit claims. (Department of Work and Pensions)
  4. Failure to provide back to work support or rehabilitation for tranquilliser addicts and ex-addicts, particularly in the arrangements introduced under the Welfare Reform Bill. (DWP)
  5. Failure to collect statistics on ITA by all departments.

The current terms of reference for the policy review were given in an answer in the House of Lords by Lord Howe on June 24 2010 on behalf of the DoH to a written Parliamentary Question by Lord Sandwich. The terms of reference are:

  1. a literature review on published evidence.
  2. an audit of primary care trust prescribing records to assess the scale of over    prescribing.
  3. an audit of addiction clinicians to map the assistance that is available to help people withdraw from prescription and over the counter medicines.

The terms of reference of the review do not address parts 2, 3 and 4 of the complaint and there is no review at all of by the DWP. It is uncertain whether the terms of reference address parts 1 and 5 because of the lack of specification.

6. The sixth additional complaint is that the process of the DoH review itself is discriminatory:
a) The review is being conducted in secrecy. Patients, addicts, ex-addicts, withdrawal    charities, the APPG and Professor Ashton received token visits and have since been excluded from the process. All requests for information and offers of assistance have been refused.
b) The review has been delegated to the following three organisations, from the patient point of view they are all inappropriate for this review:
Firstly, the Department of Health’s Drug Misuse Team which has for many years stigmatised prescribed tranquilliser addicts as “drug misusers” responsible for their own addiction.
Secondly, the MHRA which is the UK drug licensing and regulatory body responsible for the weak and unenforced prescribing guidelines for tranquillisers. The MHRA has defended tranquillisers and their manufacturers over many decades.
Thirdly, the “literature review” item is delegated to Professor Strang and the National Addiction Centre. Professor Strang designed the methadone drug treatment system delivered by the National Treatment Agency in the UK, in which heroin addicts are prescribed a pharmaceutical substitute and no withdrawal treatment is provided. The methadone system has many similarities with the state sponsored tranquilliser maintenance system which also contains no withdrawal option. Professor Strang is a psychiatrist, a member of a profession predisposed to look for disorders of the mind rather than drug toxicity problems. Addictive personality theories and other drug misuse concepts are not appropriate in the treatment of involuntary tranquilliser addiction. The NAC has no expertise in treating ITA and psychiatrists as a profession have routinely misprescibed tranquillisers and ignored prescribing guidelines.
In my opinion there are insufficient grounds to justify the EHRC’s belief that the issues raised in my complaint to the EHRC will be remedied by the Department of Health review.

The review was announced on 20 July 2009 and scheduled to report in December 2009. The reports completion date has been regularly altered and the current target date is December 2010 with policy discussions to continue into 2011. Campaigners have questioned whether any serious work has been done at all.

It is hard to see the relevance of a literature review and item 2, the prescribing audit, could be downloaded from GPs’ computers within a few days. A reply to a Freedom of Information request by the Head of the FOI Team at the DoH disclosed on13th August 2009 with respect to the three items listed by the terms of reference:

“……work on the first is not yet complete and the second two items has only just commenced in the last two weeks.”

Taking into account all the circumstances given above I do not agree with the Commission’s decision to “wait and see”. Tranquilliser addiction originated from corporate greed and is sustained by poor regulation, negligent prescribing and the absence of withdrawal services combined with systematic discrimination against large numbers of patients by government departments. The organisations which we believe to be at fault have been given control of the DoH’s review to the exclusion of patients. I therefore call upon the EHRC to now begin an urgent investigation into my complaint of government discrimination against Involuntary Tranquilliser Addicts.

I have attached a copy of the submission of July 2009 which includes a copy of the Disability Regulations 1996, a copy of Lord Sandwich’s PQ and answer and a copy of the FOI response from the DoH. Please contact my office for any clarification or other supporting documents. The APPGITA website is at www.appgita.com/

Yours Sincerely

Jim Dobbin MP

Chair, All Party Parliamentary Group on Involuntary Tranquilliser Addiction.

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