RT Hon Andrew Lansley MP Jim Dobbin MP
Department of Health House of Commons
Richmond House London SW1A OAA
79 Whitehall 8 November 2011
London SW1A 2NS
Dear Andrew,
I am writing in reply to your letter of the 8 August 2011 in which you replied to my complaint of 11 July 2011 concerning the National Addiction Centre review of the literature on addiction to prescribed medication and the conflict of interest of the author Professor Strang.
In your letter you say that Dr Kylie Reed was the principal author because her name is listed first on the title page. However this is not the case according to page 93 of the review (link provided)
Professor John Strang and Dr Kylie Reed conceived the original scope of the work, and secured funding for the review.
Dr Kylie Reed coordinated the review under Professor Strang’s overall direction.
1. In my first letter I brought to your attention that when Professor Strang tendered for commissioning of the review contract he had an undeclared financial relationship with Genus Pharmaceuticals who manufacture the benzodiazepine tranquillisers lorazepam lormetazepam and oxazepam which are part of the subject matter of the review. Professor Strang also did not declare these interests in the review when it was published. The declaration of interest subsequently attached to the online copy of the review is not a proper declaration because it does not make explicit that Professor Strang has these conflicts of interest.
Since my first letter it has come to light that Professor Strang has numerous other undeclared conflicts of interest.
2. Genus pharmaceuticals is a wholly owned subsidiary of Clonmel Healthcare; Clonmel manufacture the benzodiazepine tranquilliser diazepam and the Z drugs Zopiclone and Zolpidem. All of these drugs are part of the subject matter of the literature review. Professor Strang did not declare these conflicts of interest when tendering for the contract, he did not declare them when the review was first published and they are still not properly declared in the updated online copy.
3. Professor Strang has a financial relationship with Napp Pharmaceuticals, Reckitt Benckiser and and Clonmel Healthcare all of whom manufacture codeine containing over the counter products which were also part of the subject matter of the review. These conflicts of interest were not declared by Professor Strang at tendering, publication and are still not properly declared in the updated online copy.
4. Professor Strang obtained £984,000 from the Medical Research Council for the funding of prison trials of the drug Naloxone, named the “N-Alive Trials”. The Naloxone used in the trials is manufactured by Martindale/Cardinal Pharma, (according to a Parliamentary Question by Eric Ollerenshaw MP, (link provided)). Professor Strang has a financial relationship with Martindale/Cardinal (according to his declaration on p.93 of the literature review). Therefore, Professor Strang has a significant conflict of interest and did not declare this conflict of interest in his funding application to the Medical Research Council (according to the answer to question 4 of an FOI request by Kathy Gyngell of the Centre for Policy Studies, (attachment provided)).
5. Professor Strang co-signed a letter on jointly headed Ministry of Justice and Department of Health notepaper, (attachment provided). The letter instructs Prison Governors and Primary Care Trusts to conduct trials of Naloxone. Professor Strang describes himself as “Principal Investigator” and does not disclose his conflict of interest, that he has a financial relationship with Martindale/Cardinal.
The purpose of declaring of conflicts of interest is to mitigate the possibility of the biased and corruption they may generate. The review of the literature on prescribed medication is highly selective and bias as far as tranquillisers are concerned. Most notably Professor Ashton’s voluminous work on tranquillisers and tranquilliser withdrawal is virtually ignored. The literature on the tranquilliser post withdrawal syndrome and long term and permanent tranquilliser damage are under reported. Literature and data on tranquilliser related deaths and “benzo-babies” is not reviewed and the evidence of benzodiazepine related brain damage is dismissed.
Eric Ollerenshaw: To ask the Secretary of State for Health what interests were declared by each author of the recently published National Addiction Centre report on addiction to prescribed medicine. [64022] (link provided)
Anne Milton: All academic research is bound by strict codes of conduct such as the Research Councils UK policy and code of conduct on the governance of good research conduct and the UK Research Integrity Office code of conduct for research.
The National Addictions Centre is part of Kings College London and as such is bound by the college’s commitment to maintaining the highest possible standards of integrity and probity in the conduct of academic research. This includes a specific requirement for all possible conflicts of interest to be declared within any tender for externally commissioned work.
The authors of the report published by the National Addiction Centre declared no conflicts of interest in their tender for the work commissioned by the Department. (Hansard 5 July)
Professor Strang was obligated to declare by the Research Council UK’s policy and code of conduct, the UK Research Integrity Office’s code of conduct, the “specific requirement” mentioned above of King’s College and his professional ethics as a doctor. Professor Strang’s behaviour in the examples given above must call into question the validity of the scientific evidence that Professor Strang has submitted to the Department of Health to support the drug policy advice he has provided.
The policy outcomes of Professor Strang’s advice on drug addiction are enormous expenditures on drug maintenance systems, pharmaceutical drugs and drug paraphernalia. Drug treatment budgets have been diverted away from any form of withdrawal, detoxification, rehab or abstinence. Professor Strang’s advice has often relied upon scientific evidence he himself has created in various research projects. In the light of the behaviour outlined above I believe Professor Strang’s research is not a reliable evidence base for national drug policies.
My suggestions are as follows:
1. The Department of Health should investigate Professor Strang’s activities with particular attention to financial arrangements.
2. There should be a reassessment of drug policies adopted as a result of Professor Strang’s advice, particularly the opiate maintenance systems and the naloxone trials, with a view to providing abstinence based withdrawal services.
3. The National Addiction Centre review of literature on addiction to prescribed medication should be declared invalid by the Department of Health.
4. Until the above issues are resolved, Professor Strang should stand down as an adviser and no further funding should be provided to him by the Department.
5. The Department of Health’s standard procurement policy, which was applied to the commissioning of the literature review, contains no code of practice for dealing with conflicts of interest and no requirement for them to be declared. I suggest the procurement policy should be appropriately amended.
Yours sincerely
Jim Dobbin MP
Chair All Party Group on Involuntary Tranquilliser Addiction
c.c
Anne Milton MP
Rt. Hon Andy Burnham MP
Eric Ollerenshaw MP
Debbie Abrahams MP
Kelvin Hopkins MP
Jeremy Corbyn MP
Melanie Davis Camden Mind
Barry Haslam
Professor Heather Ashton
Deirdre Boyd, Editor Addiction Today
Kathy Gyngell, Centre for Policy Studies
Earl Sandwich
Earl Howe
Lord Mancroft
Professor Strang
Link to NAC Review:
http://www.kcl.ac.uk/iop/depts/addictions/research/drugs/benzodiazepinesz-drugsandcodeineproducts.aspx
Link to Parliamentary Questions about naloxone:
http://www.publications.parliament.uk/pa/cm201011/cmhansrd/cm111017/text/111017w0008.htm#11101857001341
Link to Parliamentary Questions about declarations of interest:
http://www.publications.parliament.uk/pa/cm201011/cmhansrd/cm110705/text/110705w0004.htm#110705101000050
Medical Research Council Freedom of Information request N-ALIVE pilot study:
http://www.appgita.com/wp-content/uploads/2011/11/MRC-FOI-request-N-ALIVE-pilot-study.pdf
Ministry of Justice / Department of Health headed letter signed by Professor Strang:
http://www.appgita.com/wp-content/uploads/2011/11/MoJ-Headed-letter-from-Prof-Strang.pdf