Dear Mr Perrott
I am writing in response to your complaints of 10 and 27 January 2011. You
asked for the second complaint to be considered with the first and I am
responding to both in this reply.
In your complaint of 10 January you said the following:
“I wish to submit a formal complaint about the Department of Health.
I have written to the Department regarding involuntary tranquilliser addiction
as an ex-prescription drug addict.
In response to my letters the Department has:
1. Not answered most of my questions.
2. When they have answered they have repeatedly misunderstood the meaning
of some of my questions and answered a different one of their choice.
3. In the last correspondence by email Bilal Ghafoor for the Department stated
that:
‘I note that you have written to the Department previously on a number of
occasions about this issue. The Government’s current position remains as set
out in previous letters. There is currently nothing further that the Department
can add. Unless you raise a new question, any further letters sent to the
Department will be logged but may not receive a reply unless the Government’s
position changes or any new information becomes available.’
This effectively places me in limbo. All my questions were either new questions
or previous ones which had not been answered. By this procedure the
Department avoids answering difficult questions. All the old unanswered ones
are now ruled out of bounds and any new difficult questions may be declared as
old issues and thus ruled out of bounds as well. All this has been done with no
reason or legal authority.”
You subsequently sent a further complaint on the 27 January which raised
issues in relation to Professor Fields comments and the Department’s Review
on addicition to medicine. I hope to address these concerns in my reply also.
You have written to the Department on many occasions in relation to your
concerns about involuntary tranquilliser addiction. I have read all of the
correspondence between yourself and the Department. Many of your letters are
detailed and contain references and excerpts from other sources in support of
your position. As the correspondence has continued it has become more
complex, adding further issues and queries and bringing in further evidence to
back up your opinions. It is clear that you feel very strongly about your concerns
and are determined that something should be done to address the issue of
benzodiazepine addiction.
I am sorry that none of the replies you have received from our Department has
given you any satisfaction in pursuit of your aims. I know that our staff have
done their best to provide you with the most up to date information concerning
the Department’s position on the issue of addiction to tranquillisers and other
medicines.
In response to your specific complaints:
1. Not answered most of my questions.
Having read your letters I feel that it is not always apparent what specific
questions you wish us to address. Some of your correspondence is very
detailed containing statement, opinion and other related wider issues. It has not
always been possible therefore to draft a reply that clearly lays out our answers
in response to your specific questions. However, I do feel that you have been
provided with as much relevant information as the Department holds on the
issues of concern.
2. When they have answered they have repeatedly misunderstood the meaning
of some of my questions and answered a different one of their choice.
Unfortunately, it is not always obvious what your specific questions are and our
staff have attempted to answer your letters as fully as possible. The replies
have been drafted with input from the relevant policy officials and cleared by a
senior official in the Department. Please be assured that there has been no
intention to deliberately misunderstand your questions or provide answers to
ones you did not ask. The Department has tried, through its many responses, to
provide you with assurances that it takes the issues you raise very seriously
and is currently addressing these with a programme of work looking at addiction
to medicine.
3. Your concern that no future correspondence would be answered by the
Department.
You quoted from a letter dated 22 December (ref 571627) which stated that
unless you raised a new question, any further letters from you may not receive
a reply.
This was, by my calculation, the sixteenth letter that the Department had sent to
you in response to your requests on the subject of addiction to
benzodiazepines, dating back to February 2010, excluding the Freedom of
Information (FOI) responses.
The Department did not consider that you had raised any new concerns but had
elaborated on previous ones, and felt that it had done all it could to answer your
previous questions. The Department therefore could find nothing further to add
to earlier replies in response to your concerns. When this situation arises it is
standard procedure for the Department to issue this form of words. Please be
assured that it is not an attempt to cease all correspondence with that individual
and clearly states that if new questions are submitted or new information
becomes available then further replies will be forthcoming from the Department.
Your concern that no future correspondence will be answered by the
Department is therefore not valid. Only if your correspondence falls within the
terms described in our letter of 22 December 2010 will no further responses be
forthcoming, otherwise your correspondence will of course receive a reply.
In response to further issues you raise in your letter of 27 January 2011:
• “Has the Department now rescinded its previous decision not to reply to
my letters?”
You are correct in observing that you were sent a further reply dated 25 January
2011 in response to your email of 29 December 2010 (578466) when an earlier
response (22 December 2010, 571627) stated that you may not receive a
further reply. I have discussed this issue with the member of staff and can
confirm that this was discussed at a senior level in the team. Having reviewed
all of the earlier related correspondence between yourself and the Department
the conclusion was reached that more information could have been supplied to
you in response to your letter of 20 October 2010 (558324). This further
information was then supplied to you.
The Department has not rescinded its previous decision. On this occasion it
was felt that further information could be supplied that would help to further
clarify earlier responses.
• In relation to a statement that Professor Field made during a television
interview concerning the length of time that some patients can become
addicted to benzodiazepines, you asked:
“……if an eminent professor and GP, officially or unofficially, says that patients
can become addicted to benzodiazepines in 3-4 days then why have the
guidelines not been reviewed as a result?”
Firstly, I would re-iterate that Professor Field was not speaking on behalf of the
Department during the television interview you refer to. He was making a
comment based on his personal experiences with prescribing benzodiazepines
and he did not allude to any new evidence-based research within his statement.
The British National Formulary (BNF) is an evidence-based document so his
personal comments alone would not necessarily lead to any review or
amendment in the publication.
In addition, both Professor Field and the BNF are independent of the
Department so it would not have been appropriate for the Department to
comment about his remarks or recommend that a review or amendment be
made concerning the information in the BNF.
The BNF is published independently by the BMJ Group and Pharmaceutical
Press. Their editorial team is responsible for the content of the BNF. Any
questions about the content should be directed to the publisher.
• “Is the Department still maintaining that 3-4 days is consistent with 14-28
days?
The 3-4 days figure is based on the reported personal opinions of Professor
Field, the 14-28 days figure is taken from official evidence based guidance, both
from the Committee on the Review of Medicines (CRM), 1980 and the BNF and
is a position that the Department currently supports. However, it is worth reiterating
that the BNF also advise that “…..benzodiazepine treatment should be
limited to the lowest possible dose for the shortest period of time” which
Professor Field’s comments would appear to support. This gives the strong
message that benzodiazepines should only be prescribed for short-term use.
• You mention two FOI replies that you received concerning the review
which you felt failed to clarify the full extent of work that had been carried
out on the review to date:
“My point was that no work had been carried out on the review from July 2009
until August 2010”.
I have looked at the two FOI responses you quote from and agree that the
second response (538279) dated 13 September 2010 did not pinpoint the
specific inaccuracy that had been in the earlier response (13 August 2010) nor
did it explain exactly what work had been done to date and when. However, the
reply did include an apology for any confusion and for providing inaccurate
information and gave an update regarding the planned programme of work.
I can understand why you consider that this was an insufficient explanation. I
have consulted the relevant policy team and can confirm that the Department
was carrying out work on addiction to medicines during this time which included
the Department undertaking work to identify gaps in the data available on the
subject and to scope the work needed to improve collection of evidence.
Officials then commissioned a comprehensive, expert review of the published
medical evidence on the scale of addiction to medicine and the effects of longterm
dependence to be carried out by the National Addiction Centre (NAC) at
King’s College London.
The policy team also consulted informally with treatment and advice providers
to gauge the availability and nature of treatment services. They met other key
stakeholders such as academics, general practitioners and people with
personal experience of addiction. They also provided support to the team at the
NAC carrying out the literature review by sourcing statistics and specialist
literature. In the light of the meetings with stakeholders, officials worked closely
with the National Treatment Agency (NTA) to plan their systematic survey of
treatment services.
Subsequently the Department has commissioned the NTA to look into the
prevalence of addiction to tranquilisers and the commissioning and governance
of prescribing and the extent of current service provision for those who are
addicted to tranquilisers in addition to the NAC’s literature review.
The NTA and NAC reports will be submitted to Ministers in due course and we
anticipate that they will be published over the next couple of months. Following
publication, we will be engaging widely with interested parties to determine the
future direction of policy and service planning.
I hope you are satisfied with this response and feel that the additional
information has been of help.
If you are not content with this reply, you can ask your MP to contact the
Parliamentary and Health Service Ombudsman, who carries out independent
investigations into complaints about Government Departments. The contact
details are:
The Parliamentary and Health Service Ombudsman
Millbank Tower
Millbank
London SW1P 4QP
Telephone: 0845 015 4033
Email: phso.enquiries@ombudsman.org.uk
Yours sincerely,
Lynwen Paddy
Complaints Manager
Department of Health