Memorandum submitted by Michael Behan
(PI 64)
INTRODUCTION
Ativan is a highly addictive and dangerous benzodiazepine
drug. The more inaccurate and defective are the warnings issued
with such a drug then the more dangerous that drug becomes.
The purpose of this submission is to draw the
attention of the Health Select Committee to the benzodiazepine
scandal and to its architects the pharmaceutical manufacturers
John Wyeth and Hoffman La-Roche (Roche Products). These manufacturers
introduced a successful mass benzo addiction trap into this country.
The trap was based on the provision of inadequate and defective
drug safety warnings to the public and prescribers.
Those defective warnings remained in place until
1988 by which time a benzodiazepine addict population had been
created.
The benzodiazepine addiction problem and the
commercial success of the drugs has continued ever since. A stream
of unwary patients is initiated into drug addiction by trusted
doctors. Meanwhile, the Government has tinkered in the face of
an enormous problem, and is misled by a flawed system of advisers,
experts and regulators.
My perception is that of a sufferer of a benzodiazepine
drug injury. My experience and the theme of this submission is
that the pharmaceutical manufacturers have introduced and openly
operated a psychotropic drug scandal with impunity.
They are confident that their influence is so
strong that they possess a complete defensive shield—in
the legal system, in the regulatory system and the Government
Departments and can never be held accountable for their actions.
Application of the Terms of Reference
The first section of the submission, parts 1
and 2, address "the provision of drug information and promotion".
The second section, parts 3 and 4, address "regulatory
review of drug safety and efficacy".
I am willing to give oral evidence.
My name is Michael Behan and I took the benzodiazepine
Ativan from 1981-87 on prescription from my GP in the belief that
it was a medicine.
Upon discovering that Ativan was a drug, I withdrew
to a zero dose over six months. I suffered side-effects whilst
ingesting Ativan and severe withdrawal symptoms during the tapering
period. Many of these symptoms have persisted ever since, particularly
neurological and muscular-skeletal symptoms, and I now believe
that they represent permanent damage.
I was a litigant in the benzodiazepine litigation
against the benzodiazepine manufacturers John Wyeth (Ativan) and
Roche Products (Valium, Librium, Mogadon). I became a litigant-in-person
in the High Court and the Court of Appeal. I subsequently petitioned
the House of Lords and the ECHR. In connection with this I privately
researched all aspects of the benzodiazepine for three years in
The British Library, the Royal Pharmaceutical Library and the
WHO and UN Libraries. I contributed to the Panorama special "The
Tranquilliser Trap". I am assisting solicitors in Ireland
in their Ativan litigation and acted as a researcher for the continuing
Scottish Mogadon case against Roche Products. I was a founder
and a Director of the charity "Beat the Benzos".
In these phases, as involuntary benzodiazepine
addict, litigant, researcher and campaigner, I have encountered
the pharmaceutical industry in several different ways. I have
divided these experiences into four parts and draw my own conclusions.
1. Litigation
The domination of the legal process by the pharmaceutical
companies.
2. Research
The drug companies own documents show the UK
benzodiazepine scandal to be the intended outcome of the manufacturers—mass
addiction.
3. Regulation
The processing and issuing of the Benzodiazepine
Drug Licence by the CSM/MCA is suspect.
4. Government
Control of psychotropic drugs has been infiltrated
by regulators, advisers and self-styled experts who promote the
agenda, the ideas and the products of drug manufacture to the
detriment of public health.
SECTION ONE
THE PROVISION
OF DRUG
INFORMATION AND
PROMOTION
Benzodiazepines
The Problem
Benzodiazepines are highly addictive. Ativan
is one of the most addictive drugs known to man, a three year
withdrawal (tapering of dose to zero) from the prescribed dose
may be necessary, 12 months withdrawal is common. Benzodiazepine
addiction is a physical addiction. The nervous system becomes
reliant on the benzodiazepine chemicals, which replace natural
chemicals in the nervous system. If the benzo chemicals are removed
or reduced the nervous system cannot operate properly. The natural
chemicals may regenerate slowly or not at all. Furthermore, benzodiazepines
are poisonous. They insidiously poison the body and its organs.
While the dangers of benzodiazepines are enormous,
their efficacy is limited. They do not cure anything. Benzodiazepines
can only suppress the symptoms of anxiety and only for a short
period. The Data Sheet recommendation is for a prescribing period
of 2-4 weeks in total.
As the efficacy of benzodiazepines decrease,
addiction can already be setting in. Also, paradoxical reactions
can start to appear, the drug produces the conditions it attempts
to treat such as anxiety, insomnia and anger. These are the first
stages of the Tranquilliser Trap.
The current number of benzo addicts in the UK
is estimated at one and a half million although no official figures
exist. Many more people are ingesting benzos and are on their
way to addiction. Many other ex-addicts have withdrawn but remain
damaged. There is no treatment for benzo damage. Post-benzo sufferers
are often left to struggle alone, stigmatised and excluded by
the Health Service that made them ill.
1. Benzo Litigation
Benzo victims are often told by Government letter
writers at the Home Office, Department of Health, MHRA, etc to
seek compensation through the courts for any injury they have
suffered. In fact, this is an impossibility. The pharmaceutical
companies dominate the courts and the legal process with their
power and money.
I was a litigant in the benzo litigation against
the manufacturers John Wyeth and Brother and Roche Products. The
litigation ran from 1986 to 1996 with a peak of 17,000 complaints.
The plaintiffs alleged that the manufacturers were negligent in
failing to give adequate warnings of the dangers associated with
their products. The manufacturer delayed and complicated the proceedings
to the point that the Legal Aid Board could no longer meet the
expense of the litigation. Each side spent more than £35
million yet not one minute of court time was spent on the merits
of the case; the time and the money was spent on technical motions
and procedural wranglings. Under pressure from the defendants
the LAB withdrew funding from the litigation.
The defendants then successfully applied to
the court for a strike out on the basis that the Plaintiffs would
be unable to continue without funding and legal representation.
The Legal Aid Board was disbanded in the wake of the benzo litigation
and re-constituted as the Legal Services Commission with a new
set of regulations designed to exclude the possibility of any
similar litigation occurring again.
The failure of the benzo litigation gave the
pharmaceutical companies the green light. They had demonstrated
they could not be brought to trial and that the evidence against
them would not see the light of day. In reality, the consumer
has no protection in law against pharmaceutical companies or rogue
drugs.
Powerful commercial corporations should not
be immune to liability. Such potential liability acts as an incitement
to developers of new products to ensure that their product is
safe, this is a valuable counterbalance to the temptation to make
fast profits.
Recommendation
My recommendation here is a no fault drug compensation
scheme for sufferers of drug injuries.
Secondly, the Government should set up an independent
prosecuting authority to take on the pharmaceutical companies
when necessary. It is unrealistic to expect a firm of solicitors
to be able to take on the might of a multi-national. When convicted
the pharmaceutical companies should pay proportionate fines in
order to provide a deterrent.
2. Documents
The benzodiazepine manufacturers have pretended
that the litigation collapsed because the drugs were safe and
the case was weak.
In fact, the evidence of negligence against
the manufacturers was overwhelming and their defence was a fraud
that never had to be tested. The benzodiazepine scandal is the
outcome of a deliberate strategy by the manufacturers. Mass benzodiazepine
addiction is not something that just happened, it was the intended
result of a world-wide benzo strategy devised by Wyeth and Roche.
Wyeth and Roche released co-ordinated information
on benzo's in each country according to the strength and vigilance
of the regulatory authorities in that country. Ativan first appeared
in the UK in 1972 with warnings well below the level of information
in the possession of Wyeth. The minimal warnings and the exaggerated
indications for Ativan increased prescribing and therefore sales
and profits for Ativan. The addictiveness of Ativan works a ratchet
effect. Any unwary patient who is prescribed Ativan for a month
or more can become an addict for decades and thus a steady customer
for Wyeth drugs.
Wyeth deliberately issued defective information
on Ativan in their UK Data Sheets. This defectiveness can be shown
by collating and cross-referencing Wyeth's own documents:
(ii) worldwide Wyeth Benzo Data Sheets;
(iii) Wyeth benzo adverts in USA medical
journals;
(iv) information provided by Thomas Harry,
Wyeth Medical Director and Whistleblower.
(i) Ativan Clinical Trials
The Wyeth Ativan Clinical Trials were poor quality
and short term; none provide reliable evidence that Ativan is
safe, several of the Ativan trials report what were to become
the classic Ativan problems.
The earliest Ativan trial sponsored by Wyeth
was conducted in a US prison in 1970 and is by HW Elliot (1).
This was a one-tablet only, one day trial. Subjects are reported
with:
EEG modification to alpha rhythms;
"minimal" changes in cardiovascular
reflexes;
being unable to repond to their spoken names;
instantly falling asleep;
post treatment depression of CO2 response;
unable to complete a test because of fear;
EEG—loss of alpha rhythm, burst of spindles;
and
Cross-referencing this trial with the 1974 UK
Ativan Data Sheet (2) shows Wyeth withheld vital safety information
from the Data Sheet. Omissions from a Data Sheet are a simple
but effective way of sabotaging the mechanism for drug safety
put in place by the 1968 Medicine Act.
De Buck 1972 trial "Clinical Experience
with Lorazepam" (3) is also Wyeth sponsored. This trial reported
epileptic seizures in two patients (of 30) when withdrawing from
Ativan after three weeks ingestion. Epileptic seizures are an
extreme withdrawal symptom and were clear warnings of the highly
addictive nature of Ativan.
The appropriate warning for a specific Adverse
Drug Reaction (epileptic seizure) that the De Buck trial should
generate does not appear in the UK Ativan Data Sheet. Neither
does an appropriate high level addiction warning.
The deeper question consequently arises—did
Wyeth provide the CMS/MCA with all available safety information
when they applied for an Ativan Product Licence? My answer is
most definitely not but, as long as Wyeth's Ativan Drug Licence
Application remains secret, Wyeth will deny any wrong doing. A
DLA application is the country's most secret document, and it
remains secret in perpetuity.
These discrepancies—between the trial
results and the Data Sheets—are not administrative details
or secretarial problems. The withheld trial results correspond
closely to the injuries suffered ever since by unwary ingesters
of Ativan.
The discrepancies are at the heart of a multi-million
pound drug swindle perpetrated in the UK by Wyeth. It is a swindle
that has condemned 1000's in the UK to the misery of Ativan addiction
and the slow incurable poisoning of their bodies organs and nervous
systems.
Up until now Wyeth have escaped responsibility
by hiding behind the shield of a supposedly all powerful "right"
to commercial confidentiality.
Recommendation (during enquiry)
I strongly recommend that the Health Select
Committee root out the truth by subpoena of the DLA for Ativan,
in particular the Summary Basis of Approval (SBA) which is the
section dealing with safety as opposed to commercial information.
(ii) Wyeth's Benzodiazepine Adverts
Oxazepam (Serax), Wyeth's first benzo, was launched
in the USA in 1965. All benzodiazepines are analogues of one another.
This means they are not just similar to one another but closely
similar. Any warning or information provided for Oxazepam (Serax)
is applicable to Ativan. Particularly when Ativan is 20 times
the strength of Oxazepam (Serax).
Oxazepam (Serax) prescribing information (FDA
approved) is provided in a Wyeth advert in Psychosomatics September
1965 (4), one of a series of advertisements that appeared in USA
Medical Journals. The nightmare list of side-effects associated
with this low-strength earlier product can be compared with the
innocuous warnings (CSM/MCA approved!) provided by the UK Ativan
Data Sheet nine years later in 1974.
Similarly, when Ativan itself was launched in
the USA in 1978 it was done so under a different higher-level
set of warnings (JAMA 1978) (5).
Ativan is described in the USA as a potent and
dangerous compound. Ativan is described in the UK as clean, mild
and efficient. US consumers and prescribers have proper addiction
warnings, pregnancy and lactation warnings, liver function warnings,
etc. Generally, it can take 10 or 15 years for safety warnings
to travel from the USA to the UK Data Sheet.
(iii) Wyeth's Ativan Data Sheets
The origin of drug information in the UK is
the Data Sheet. It is a legal document required by the Medicine
Act 1968. Wyeth consistently issue a lower level of information
on Ativan in the UK Data Sheet, lower than the information provided
in the equivalent year Data Sheet for Ativan in the USA, Canada
or Australia. I have provided copies of 1978 Ativan Data Sheets
(6) for the Committee to examine—and I have complete Ativan
Data Sheets collection for those countries.
Recommendation (during enquiry)
Senior Directors of John Wyeth should be summoned
before the HSC to explain these safety information discrepancies
and to take responsibility for the results of these discrepancies.
Recommendation (during enquiry)
Unpublished clinical trials for Oxazepam (Serax)
and Ativan should be subpoenaed from John Wyeth.
(iv) Whistleblower Statements
During the benzodiazepine litigation, two ex-Wyeth
Medical Directors made detailed and incriminating statements against
their former employers. They are Dipak Malhotra and Thomas Harry
(7) who was responsible for the development of Ativan. Thomas
Harry states clearly and consistently that Wyeth were fully aware
of the problems with Ativan and that for commercial reasons they
did not warn doctors or patients.
These statements were taken by my former solicitor
Graham Ross. So far this document has been swept under the carpet
and ignored by Government and regulators.
Recommendation (during enquiry)
That Graham Ross (8) and the original Thomas
Harry statements and authentication be subpoenaed by the HSC.
3. The Ativan Licence
My submission is that Wyeth did not tell the
truth when they made their Ativan Licence Application.
Furthermore, the licensing procedure that was
applied to the benzodiazepines, and in particular to Ativan, was
not the vigorous assessment procedure that has been claimed by
the CSM/MCA. Far from it.
Most of the benzodiazepines—Valium, Librium,
Mogadon—were on the market before the Medicine Act of 1968.
These drugs were issued "Licences of Right". The Licences
of Right were a registration procedure and involved no assessment
of safety or efficacy. Assessment was deferred to a future review
by the CRM. Significantly, those reviews did not occur until 1983/84.
By then the damage was done, the huge benzo addict population
had been created and still exists to this day.
The first application for a full Benzo Product
Licence was for Ativan in 1972. The relevant safety requirement
was that the drug should be no less safe than other drugs indicated
for the same condition (ie, the existing benzos). This was not
an objective standard, it was a comparative standard and it was
a comparison to Roche's benzodiazepine products that had not yet
been assessed for safety themselves. As Ativan had secured a full
Product Licence it was not even subject to the future CRM review.
Can it be said that Ativan was ever fully assessed for safety
by the licensing authority?
The senior members of the licensing authority
have what has been quaintly described as a conflict of interest—they
receive large amounts of money from the drug companies they regulate.
In 1996-97, for example, 10 members of the CSM/MCA declared financial
links with John Wyeth and Brother.
Wyeth is a subsidiary of American Home Products.
In the 1970's the USA Securities Exchange Commission offered US
corporations an amnesty from prosecution in return for disclosure
of corrupt payments. American Home products (9) declared from
1971-75 corrupt payments of $3.4 million in 41 different countries
by their subsidiaries and divisions.
AHP's auditors, Arthur Andersen, submitted form
8K in 1975:
"These payments were intended to further
business with government agencies or to obtain action on necessary
government clearances". (Item 13).
"Non-commission type payments were made
in a number of countries to foreign government employees primarily
in connection with the granting of required government approvals".
(P4).
Recommendation (during enquiry)
That Wyeth and the MHRA should be questioned
on all aspects of the Ativan Licence application, its truthfulness
and the process applied. That Wyeth be questioned on involvement
in corrupt payments in the UK.
Recommendations (for actions)
That the MHRA be disbanded. That it should be
replaced with an independent body. That clinical trials should
be supervised by an independent body. That there should be no
retainers from the pharmaceutical industry to regulators. There
should be significant lay membership and an end to secrecy.
Wyeth have plenty of form when it comes to avoiding
regulatory control and manipulating information on safety and
efficacy. Dr Rheinstein of the FDA in the United States wrote
a regulatory letter to Wyeth-Ayerst in 1989 telling them they
had an "intolerable record of compliance with the law"
(on drug promotion). (10).
Wyeth-Ayerst had "in case after case .
. . disseminated promotional materials that are clearly false
and misleading" indicating a "general and wilful disregard
for legal and regulatory limitations upon drug promotion".
Dr Rheinstein told Wyeth-Ayerst that a 1989
advert for the heart drug Cordarone was "clearly intended
to minimise the hazards of the drug and emphasise the drugs efficacy".
Dr Rheinstein's Office of Drug Standards issued
18 notices of violation to Wyeth-Ayerst concerning drug advertising
and labelling in 1988-89.
In 1999, AHP had to pay $4.85 billion compensation
in the "Fen-Phen" litigation to 5.8 million ex-users
who suffered heart-valve damage. The drug was marketed through
Wyeth-Ayerst, it was linked to serious lung disease and leaky
heart valves. Wyeth-Ayerst were found to have concealed this information.
Settlements included medical care and monitoring for the victims,
paid for by the manufacturers. (11)
Also in 1999, Wyeth Laboratories were convicted
by the Supreme Court of New Jersey of failing to warn adequately
of side-effects associated with the contraceptive device Norplant.
4. Government Control of Psychotropic Drugs
In 1997, the campaign group "Beat the Benzos"
was formed by Barry Haslam, Phil Woolas MP, myself and others.
We hoped that if we brought the benzo problem to the attention
of the Government that appropriate action would be taken across
the various government departments. There has been no action.
In my opinion the strength and influence of pharmaceutical companies
extends into Government.
Ministers come to the complex subject matter
of psychotropic drugs as lay people and move on regularly, this
produces an over-reliance on advisers who are presumed by Government
to be unbiased. There is no balance or brake on these advisers.
The Government takes advice on the psychotropic drug problem from
people who help to sustain the problem, namely the psychiatric
profession, specialised prescribers of drugs. The psychiatric
profession has both feet firmly in the camp of the manufacturer
with whom they share the common desire to extend the use of psychotropic
drugs.
The advisers on psychotropic drugs claim possession
of "The Science" and that thereby Ministers can believe
that their policies are underwritten by science. "The Science"
they possess is actually information emerging from the pharmaceutical
companies and the clinical trial system—also known as "The
Evidence". The psychiatrists claim the exclusive ability
to understand and interpret this information and they insist that
it is true. What anyone else says, for example the patient or
ex-patient, is excluded as "anecdotal evidence" as opposed
to their "scientific evidence". The government experts
define their own expertise. They create a monopoly for their own
extreme viewpoint. The policy outcome is a non-policy of minimum
regulation and inaction, the ideal environment for drug addiction
to take root and spread.
In our case the "Beat the Benzos"
group attended a meeting in April 2003 with the Home Office Minister
Bob Ainsworth MP. We asked Bob Ainsworth to consider re-scheduling
and re-classifying benzodiazepines and he invited us to prepare
a submission (12) to the Home Office Advisory Council on the Misuse
of Drugs (ACMD), which we did. The submission was referred to
the Technical Committee of the ACMD which is chaired by Professor
David Nutt, a key Government adviser and regulator. The ACMD was
set up by and derives its power from the Misuse of Drugs Act 1971.
The Act states (Section 2) that class and schedule are to be determined
by the drugs level of misuse and the harmful effects to the public
thereby caused.
We submitted that on any relevant criteria benzodiazepines
are one of the most harmful of drugs and are wrongly classified
and scheduled. Example of criteria that are used in the submission
are:
(a) the number of benzo related deaths;
(b) the number of people affected 1.5 million+;
(c) the magnitude of addiction;
(d) the duration of addiction;
(e) the social cost of benzo addiction; and
(f) the suffering of addicts and its immorality.
It emerged that in fact the original scheduling
(1986) and classifying of the benzos was not based on a risk assessment.
The concern in 1986 was to conform with international legal obligations
created by a UN Convention.
The ACMD has not so far carried out, in fact,
a risk or safety assessment of the benzos. We received a refusal
letter from the Home Office in April 2004.(13). The ACMD do not
respond to any of the evidence arguments or suggestions put forward
in the submission. The ACMD make an assertion that re-classifying
and/or re-scheduling benzodiazepines would be likely to be ineffective
in curtailing their misuse but gave no reason.
Professor Nutt has financial links with John
Wyeth. In the 2001 CSM Declaration of Interest, Nutt declares
an "Honoria" and a non-personal grant from benzo manufacturers
John Wyeth. He did not declare that interest in his dealings with
us.
Professor Nutt chaired a recent CSM/MCA/MHRA
review on SSRI's which found them to be safe. He was later revealed
by the Guardian to have financial links to Glaxo Smith Kline,
as had two out of three of the other members of the review committee.
Professor Nutt sets out his own position on
benzodiazepines in his paper "The Psychopharmacology of Anxiety".
(14). Professor Nutt recommends prescribing practices that directly
contradict:
1. CSM advice and addiction warning.
2. Data sheet addiction warning.
3. The Department of Health stated position.
Professor Nutt advocates treatment for 6-10
weeks, six months, one to two years and life-long use—"some
patients appear to require maintenance benzodiazepines".
In this medical paper, Nutt also takes the trouble
to present the manufacturers account of the litigation. Nutt wrongly
claims that "it was decided by the presiding judge that the
case for benzodiazepine dependence causing real damage has not
been made".
At the original meeting with Bob Ainsworth and
in a letter dated 11 July 2003 from the ACMD, it was indicated
to us that our submission would be assessed by a point scoring
system that would measure levels of harm. Professor Nutt did not
apply that system. I have requested the minutes of the ACMD Technical
Committee meeting of 2 October 2003 but have been refused for
"reasons of confidentiality".
The processing of our ACMD submission on benzos
followed the pattern of benzo drug regulation set by the CSM/MCA.
The case against drugging is not addressed, it is ignored and
avoided by bureaucratic manoeuvering. There is extreme secrecy
and no engagement between the regulator and consumer. The complete
absence of a safety assessment is revealed. Power and control
is concentrated in the hands of Professor Nutt, an all powerful
benzo-enthusiast who claims expertise and is in the pay of the
manufacturers.
Recommendation for enquiry
To examine Professor Nutt. That the scheduling
and classification of benzos be properly assessed by an independent
and open process.
Beat the Benzos final attempt to change the
benzodiazepine status quo was a meeting with Health Minister Rosie
Winterton in 2003. We outlined our concerns and suggested solutions.
Rosie Winterton asked for more information and told her advisers
she had not been kept informed or had been wrongly informed of
the situation. However, the arrangement was unexpectedly ended
in January 2004 when we received a letter that shut the door in
our face and re-affirmed Department of Health policy. That policy
is:
(a) To exclude any consideration of benzo
damaged people for aftercare by setting the parameter "the
main focus is to prevent addiction in the first place".
(b) To provide no research into and no treatment
for benzodiazepine injuries.
(c) To ignore the problem, there is no quantification,
no figures, no statistics.
(d) To claim withdrawal facilities are available
when they are not.
(e) To blame over-prescribing on GP's and
psychiatrists as if these employees are nothing to do with the
Department of Health. The Department of Health makes no effort
to enforce benzo prescribing guidelines. As long as guidelines
are not enforced prescribers will continue to over-prescribe in
dosage, in time and by polypharmacy.
(f) To pretend the benzo problem is a mental
health problem—it is not, it is a problem of physical drug
addiction and drug toxicology.
Chief spokesperson and letter writer for the
Department of Health, and this policy, for the last several years
has been Dr Anna Higgit who styles herself as Senior Policy Adviser
on benzodiazepines. It is a policy of denial and inaction which
provides the perfect environment for psychotropic drug addiction
to flourish.
The pharmaceutical industry have created the
benzodiazepine problem and have left it in the lap of the Department
of Health. The Department of Health will not tackle the problem
because:
(a) The Department of Health has been compromised
by years of denial and cover-up.
(b) Tackling the benzo problem involves confronting
the pharmaceutical industry which they will not do.
(c) The apparent cost of tackling the benzo
problem appears massive—benzo withdrawal facilities, medical
treatment and compensation payments—but is not massive when
calculated against the social cost of benzo-addiction.
Melanie Johnson MP, Minister of Health has registered
a financial contribution of £20,000 from Hoffman La-Roche.
(15).
Recommendations for Action
1. Establishment of benzo withdrawal facilities
nationwide including clinics, self-help groups and a help line.
2. Prescribing guidelines to be enforced.
3. Compensation for benzodiazepine injuries
with no-fault compensation scheme.
4. Prosecution of negligent manufacturers
by a government agency.
5. Medical research into benzo injuries
and after-care for victims—alternative, non-drug treatment.
6. An independent and open licensing procedure.
7. Education of the medical profession on
psychotropic drugs.
8. New government experts, adviser and regulations.
REFERENCES
| 1 | "Central Nervous System and Cardiovascular Effects of Lorazepam in Man". HW Elliot, Clinical Pharmacology and Therapeutics 1971.
|
| 2 | UK Ativan Data Sheet 1974.
|
| 3 | "Clinical Experience with Lorazepam . . ." R De Buck. Current Med Res and Opinion 1973.
|
| 4 | Serax Advert Psychosomatic Sept 1965.
|
| 5 | Ativan Advert Journal of the American Medical Association 1978 v 240.
|
| 6 | Ativan Data Sheet. USA 1978. Australia 1978.
|
| 7 | Whistleblower Testimony Thomas Harry.
|
| 8 | Letter Graham Ross to Neil Fearn.
|
| 9 | Amnesty Disclosure on Corrupt Payments by AHP to SEC.
|
| 10 | SCRIP World Pharmaceutical News 1990.
|
| 11 | Fen-Phen Litigation from Internet.
|
| 12 | ACMD Submission 2003. |
| 13 | Home Office Refusal 2004.
|
| 14 | The Psychopharmacology of Anxiety. Professor Nutt.
|
| 15 | Private Eye. |
Michael Behan
Beat the Benzos
30 August 2004
| |
| 
