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Pontifications on Poison

Being some ramblings on events associated with poisonous plants.

Sunday 10th November 2013

When I stopped writing daily I said I would use Twitter to flag up items of interest that did not justify a full blog entry. I started to do that, this morning, but realised that the matter concerned needed the benefit of a long and detailed rant.

It started with a Tweet I received from Fatima Hashi directing me to the Impact Assessment published by the UK Home Office on 22nd October ‘Impact Assessment Of New Drug Control Of Khat’.

I've written a lot about khat and you can find a list of the blog entries on the Catha edulis plant page.

Impact assessments are prepared for every proposed policy change. They involve civil servants examining the change and assessing, in detail, what its benefits will be and identifying and estimating the costs, including any unforeseen effects, to determine if the policy is justified overall.

If the impact assessment demonstrates that there are substantial problems likely to arise from implementation, the minister concerned will reconsider or suspend the proposed change and announce that the hard work of civil servants has prevented a bad mistake from being made.


I seem to have slipped into writing fiction for a couple of paragraphs. The purpose of an impact assessment, of course, is to establish the evidential cover for a political decision that is set in stone. There are times when it is impossible for an impact assessment to polish a particular turd of bad policy and, in those cases, governments find reasons not to conduct the assessment at all. There has, for example, never been a full impact assessment of the workings of the Misuse of Drugs Act 1971.

As always when I write one of these pieces I’m going to have to try and find the balance between making my case and keeping the whole piece to a readable length.

We start with some subtle preconditioning of the mind of the reader.

Under ‘Summary: Intervention and Options’ the first paragraph heading says ‘What is the problem under consideration? Why is government intervention necessary?’ Straightaway, we are expected to buy the concept that there is a problem to be dealt with. If there is a problem then, clearly, ‘SOMETHING MUST BE DONE’.

The paragraph itself begins ‘Following consultation with the Advisory Council on the Misuse of Drugs (ACMD)…’ That’s alright then. ‘We’ve all had a good consult and here’s what’s been agreed’. That line should read ‘Against the advice of many of the country’s leading experts on drug science who took every factor (apart from political dogma and personal ambition) into account…’

The one page summary ends with this statement;

‘I have read the Impact Assessment and I am satisfied that (a) it represents a fair and reasonable view of the expected costs, benefits and impact of the policy, and (b) that the benefits justify the costs.’

That is ‘Signed by the responsible Minister: James Brokenshire’ on the 25th October 2013.

The Wikipedia list of Home Office Ministers shows James Brokenshire as responsible for;

‘Crime and security. Counter-terrorism, Olympic security, exclusion orders, departmental science, including counter-terrorism science and technology, extradition, mutual legal assistance’

And Norman Baker, who was appointed on 7th October, as responsible for;

‘Crime prevention and anti-social behaviour reduction. Crime reduction policy, drugs and alcohol policy (emphasis added), use of DNA and reform of DNA database, Licensing Act and powers of police and local authorities, public order, use of powers of surveillance by local authorities, violent crime, CCTV, acquisitive and business crime, oversight of the Forensic Science Service’

I could be reading too much into the fact that Baker, who is known to have more liberal views on drug policy, wasn’t asked to sign this assessment. It is true that, before 7th October, Brokenshire had the drugs responsibility so maybe the civil servants who wrote the impact assessment simply picked up a pre-signed blank and used that.

The assessment gives three options with Option 1 being ‘No change’ but page 2 begins with a summary of Option 2. Surely it is a gross oversimplification to suggest that choosing ‘No change’ results in no changes because existing trends will unfold?

I shouldn’t be completely cynical about the Impact Assessment because in the summaries of both Option 2 & 3 it does say;

‘Evidence from other countries which have controlled khat suggests that levels of demand may not reduce immediately after the ban comes into effect.’

It does not, however, define how long ‘immediately’ lasts nor what happens after it ends.

By page 4, we’re into the detail of the ‘Evidence Base’ beginning with a summary of khat and the khat trade. The introduction to khat contains this sentence;

‘Dried khat does not appear to be as popular, but can retain its stimulant properties for several years.’

The paragraph concerned begins ‘Khat is a plant’. Unless great care is taken with preservation there is no plant that has ANY properties (or any physical existence) after several years so that is a stupid thing to write regardless of the fact that all studies show that the actual stimulant effects last only a few days.

The notion that khat has a shelf-life is essential to the case for classification because the claim is that the UK will become a hub for re-export if action isn’t taken.

Paragraph 5 of the ‘Background’ is headed ‘ACMD reviews of khat’. It attempts to justify the third review, ordered in 2010, after the 1998 and 2005 reviews found no need for change.

‘In late 2010, in light of persistent concerns amongst UK communities and the international community…’

If those concerns were only ‘persistent’ then the response to them should have been to refer to the 2005 report and say the balanced decision taken on the basis of that report was still valid. There is no suggestion that these concerns were growing or new and, elsewhere, the Impact Assessment accepts the ACMD’s finding that khat use is in decline.

That sentence finishes with a real corker;

‘[Concerns] about the health and societal harms associated with khat use and the khat trade’

That’s not concerns about the possibility of harms. It is saying that the government decided there were enough harms to justify classification and started the process aimed at giving evidential cover to a dogmatic decision.

Then there is the fudge at the heart of this matter.

‘…the ACMD acknowledged the limitations of the evidence base concerning the social and physical harms associated with khat use’

The government has taken the lack of evidence of harms to mean that there are harms but they haven’t been discovered in spite of the ACMD making three attempts in fifteen years to find them.

Section D ‘Options’ mentions Option 1 but contains a blatant lie;

‘Option 1: Do nothing- no change, consistent with the ACMD’s advice.’

‘Do nothing’ is not consistent with the ACMD’s advice. The ACMD acknowledged that a small minority of users become dependent (whether physically or psychologically) and said that more support should be offered to those users and their families. Criminalising those problem users makes it much more difficult to offer them support. The impact assessment wants readers to believe that the ACMD recommended no action of any sort because that says that the government is the only one interested in ‘doing something’.

1,200 words in and I was beginning to think I’d have to end this before getting to the real Lulu. Section E Appraisal (Costs and Benefits) gets into the detail and begins with an estimate of the retail value of khat.

‘Estimated £63.8 million per annum (2011/12). This is based on data suggesting 2.6 tonnes is imported each year[1] and an estimated street value of a 5.5kg box of £120[2], uprated to 2011/12 prices.’

2.6 tonnes?

The [1] reference is to the literature review undertaken as a prelude to the ACMD study. On page 10 it says that;

‘…the total volume of consignments imported per week into UK was 57.7 tonnes…’

Normally, I wouldn’t pick on someone for making a simple error even one that should have been easily spotted (2.6 tonnes is only 473 boxes of 5.5kg each with a total value of £57k). But, this is a document that supports a change in policy that will destroy individuals, families and communities. A policy that hands fundamentalists a win by demonstrating that the British government doesn’t care about the immigrant communities involved in the khat trade.

Such a slapdash approach simply confirms that this is just a case of going through the motions to try and justify the actions of a government that prefers sanction to support.

My final point, though we’re only on page 10 of 22, concerns where this document enters the world of the surreal. In paragraphs 26 & 28, the impact assessment says that because there is no evidence of medical or social harms from khat it is not possible to include any benefits resulting from the change in classification in those areas.

And my final, final point is that the ‘see paragraph 35’ in paragraph 41 is rubbish. Paragraph 35 has nothing to do with the nature of khat. Further proof, if any were needed, that no-one has bothered to read this document before releasing it suggesting that everyone knows it is a sham.

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