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From the letters page DDN July/August 2019

Welcome dialogue

Molly Cochrane raises some challenging questions around legalisation and regulation in her letter ‘Awkward Facts’ (DDN, June, page 17). Coming up with models for the legal regulation of risky drugs is certainly difficult. My colleagues and I at Transform Drug Policy Foundation have worked for over two decades to try and meet this challenge in a series of detailed publications that outline a range of possible options.

Steve Rolles, senior policy analyst, Transform Drug Policy Foundation
Steve Rolles, senior policy analyst, Transform Drug Policy Foundation

In considering how regulation might work, Molly rightly notes the delicate balance that would need to be struck between keeping prices high, and restricting availability, to dissuade use, and keeping prices low enough, and availability high enough, to dis-incentivise a parallel illegal trade. These are challenges facing both tobacco and alcohol policy and there is no perfect answer. Neither, however, is it beyond resolution: fiscal policy is based precisely on establishing taxation thresholds that achieve precisely this balance for a range of goods.

Transform advocate for optimal legal drug regulation models that minimise social and health harms. In our view, legal regulation – for all its challenges – would achieve this far more effectively than prohibition, whose failures are evident all around us. But that is not to say the regulation of currently legal drugs, such as alcohol, is perfect. Far from it. Indeed, it is entirely consistent to call for better regulation of legal drugs (such alcohol MUP and plain packaging for cigarettes – both of which we support) as well as effective regulation of currently illegal drugs. The destination of optimal regulation is the same, even if the starting point is different.

Finally, Molly cites the case of mephedrone. The unregulated legal NPS market (before the PSA 2016) was nothing like the strictly regulated model we advocate. Furthermore, mephedrone’s emergence was not just because of its legal status (although that was, no doubt, a factor) but significantly due to an MDMA shortage following the ‘successful’ interdiction of almost the entire global supply of a key precursor in 2008. A new illegal MDMA production method was discovered in 2010 – coincidentally when mephedrone was banned in the UK – and by 2011-12 high purity MDMA pills and powder returned to the market. Following this, MDMA’s user base, many of whom were previously displaced to mephedrone, largely returned, both in the UK and elsewhere, even where mephedrone remained legal.

Problems such as those identified by Ms Cochrane are difficult, but they become less awkward when, rather than ignoring or simplifying, we look at them more closely. I and Transform welcome the kinds of challenges that Molly raises in her letter and we look forward to further dialogue to help put in place measures that afford the highest level of protection to consumers using the best regulatory tools we have available.

Steve Rolles, senior policy analyst, Transform Drug Policy Foundation

Counselling credentials

It was a disappointing surprise to read the article on FDAP (DDN, June, page 10), which inaccurately stated that FDAP is the only professional registration body for drug and alcohol workers. This is incorrect. There is also IC&RC UK and Europe, a body that certifies drug and alcohol counsellors in the UK and has done so for over 20 years. It is a UK branch of the worldwide IC&RC 50,000-strong credentialing body and members may apply for reciprocity throughout the world.

We can be contacted at: IC&RC UK, 33 Thurloe Place, South Kensington, London SW7 2H or at

IC&RC UK and Europe Board members

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