Hard News by Russell Brown

I'd be worried about teratogenic effects without animal testing -- which seems to have been the initial sticking point for the 'rodents only, ie, not rabbits' version of Psychoactive Substances animal testing.

One difference between medicinal and recreational drugs is that we might be willing to tolerate a lot more false-positive rejections from in vitro tests for recreational drugs, and get fewer false-negative safety problems. That is, it's not a disaster if huge swathes of THC analogues gets turned down by a computer, but it would be a pity if that happened to a new class of diabetes treatments.

The other question is what level of human trials (with what level of monitoring of users) get done before approval. Something like the Parkinson's disease from that synthetic opioid back in the 1980s might well not get caught in animal testing, but under protocols for medicinal drugs it would probably get caught in Phase I clinical testing and be a tragedy rather than a catastrophe.

Thanks for getting clarification here that controlled drugs such as cannabis might be part of a PSA-like law, rather than the PSA itself, which is currently fatally flawed (in part due to themselves!). The major issue for me is that the PSA takes a medicines approach which is not warranted (as the substances are not trying to cure a disease or treat a condition), and especially for natural plants and herbs. It's one thing to demand pharmaceutical-level tests for novel chemicals - and of course Jessamine and Medsafe would insist on this, it's what they do - but there are other approaches for plant-based drugs that could treat safety issues more like foods or, duh, herbs. The Natural Health and Supplementary Products Bill comes to mind.

That is, it’s not a disaster if huge swathes of THC analogues gets turned down by a computer, but it would be a pity if that happened to a new class of diabetes treatments.

Good point. I'd been trying to form a thought around that, and that's it.

The other question is what level of human trials (with what level of monitoring of users) get done before approval.

Which would be extremely relevant for something new, but could you use existing evidence for, say, cannabis or MDMA?

- There is no middle ground between the government jailing people for selling or using a substance, and the government asserting a substance to be "safe".

- The PSA explicitly excluded all proscribed substances (except analogues) from ever being approved. This removed from consideration a range of substances that have already been through the medical testing process.

- The continuation of prohibition results in numerous harms itself because drug use is not prevented, but drug users are forced by definition into criminality.

I'd suggest, since a perfect, neat approach appears impossible, taking a pragmatic approach.

+ remove criminal penalties for all personal possession

+ remove jail as a sentence for any drug offence

+ make the unlawful sale or manufacture of drugs a regulatory rather than police issue, to be dealt with by local authorities and resourced according to the wishes of their communities

+ make the possession of drugs for testing purposes specifically legal, and make it a mitigating factor (smaller fine) if somebody selling drugs has had them tested and accurately labelled

could you use existing evidence for, say, cannabis or MDMA?

I’d say so. I mean, if MDMA were legalised I’m sure there’d be lots of interest in research on the more subtle or longer-term health effects, but we must know about as much about short-term safety risks as we would from a Phase II human study.

Another interesting question is whether the Greens would ever be willing to compromise on zebrafish. These are used a lot in biological and biochemical research as a step between cell cultures and mice -- partly because they're transparent when young, but also because they're small, cheap, and about as cuddly as whitebait.

On the one hand, they're obviously animals. Vertebrates, even. On the other hand, there's much less social disapproval of being cruel to fish than to small furry animals. Think of catch-and-release fishing, for example.

why would the standard of safety for a drug you expect people to take be different depending on their reasons for taking it?

I'm going to break with tradition and not explain why. I weighed up the cons and found that there were only cons. It felt like something was missing, but ....

Seriously, I wonder who goes into a course of chemotherapy without once consulting their reasons for taking it.

There’s a huge difference between “a drug you expect people to take” = a drug that people will choose to take regardless of what you think, and “a drug you expect people to take” = a drug that you are recommending a patient should take. “You” (ultimately the government) have a very different level of responsibility in those two cases, so why should the standard of evidence for safety have to be the same?

whether the Greens would ever be willing to compromise on zebrafish.

Here was me starting with the question "Do The Greens/the law understand that people are animals". Viz, does the law clearly explain that only testing on non-human animals is prohibited? It's obvious, but that doesn't mean it's in the law.

Or worse, is the actual problem that it doesn't and thus the Psychodrugs bill says "you have to test, but you can't"?

My expectation is that many of the basic tests for toxicity and so on will have already been done by recreational users. Much as we know that auto-erotic asphyxiation can be fatal, we know that using cannibis is rarely immediately fatal and overdosing is hard (and we know that the same is less true of ethanol). Demanding that those tests be repeated in a lab setting seems pointless to me, even if consenting volunteer lab animals are used.

It also amuses me that the entire point of many medical drugs is to kill animals. Demanding "no animal testing" removes the ability to find new anti-parisiticals, for example (bedbugs and scabies are increasingly drug-resistant). Tapeworms, anyone?

It also amuses me that the entire point of many medical drugs is to kill animals.

Good point.