APPENDIX 10
Memorandum from the Advisory Council on
the Misuse of Drugs (ACMD)
1. INTRODUCTION
1.1 The Advisory Council on the Misuse of
Drugs (the Council) was established, as a non-departmental public
body, by the Misuse of Drugs Act 1971 (the Act). Its current membership
is shown in Annex A.
1.2 The Council's terms of reference are
set out in the Act as follows:
"It shall be the duty of the Advisory Council
to keep under review the situation in the United Kingdom with
respect to drugs which are being or appear to them likely to be
misused and of which the misuse is having or appears to them capable
of having harmful effects sufficient to constitute a social problem,
and to give to any one or more of the Ministers, where either
Council consider it expedient to do so or they are consulted by
the Minister or Ministers in question, advice on measures (whether
or not involving alteration of the law) which in the opinion of
the Council ought to be taken for preventing the misuse of such
drugs or dealing with social problems connected with their misuse,
and in particular on measures which in the opinion of the Council,
ought to be taken.
(a) for restricting the availability
of such drugs or supervising the arrangements for their supply;
(b) for enabling persons afffected by
the misuse of such drugs to obain proper advice, and for securing
the provision of proper facilities and services for the treatment,
rehabilitation and aftercare of such persons;
(c) for promoting co-operation between
the various professional and community services which in the opinion
of the Council have a part to play in dealing with social problems
connected with the misuse of drugs;
(d) for educating the public (and in
particular the young) in the dangers of misusing such drugs and
for giving publicity to those dangers; and
(e) for promoting research into, or
otherwise obtaining information about, any matter which in the
opinion of the Council is of relevance for the purpose of preventing
the misuse of such drugs or dealing with any social problem connected
with their misuse."
1.3 A further duty is placed on the Council
in the Act to consider any matter relating to drug dependence,
or the misuse of drugs, which may be referred to it by anyone
of the Secretaries of State (as defined in the Act). The Home
Secretary is, moreover, obliged to consult the Advisory Council
before making any amendment to the Regulations to the Misuse of
Drugs Act 1971.
1.4 The Council ordinarily meets, in full
session, twice each year but it has powers to meet more frequently
if necessary. Much of the detailed work of the Council is carried
out by its Technical Committee and its Prevention Working Group.
Ad hoc working groups, with limited life-spans, are also
established from time to time to undertake detailed examinations
of specific issues. Over the past 18 months, for example, the
Council has had a specific working party to examine the implications
of the reports of the Shipman Inquiry. The committees and working
groups report to the Council since that is the body responsible
for formally advising the Home Secretary.
2. THE WORK
OF THE
COUNCIL
2.1 The Council fulfills its responsibilities
in various ways:
2.1.1 The Council advises on whether substances
should be controlled under the Act and, if so, into which Class
and Schedule they should most appropriately be placed. The initial
scrutiny of the available evidence is normally undertaken by the
Technical Committee. The Technical Committee's membership is drawn
from Council as well as others—co-opted members—with
particular expertise. The Technical Committee's members are appointed
by the Council, and the Committee reports to Council. Membership
of the Technical Committee is shown at Annex B.
2.1.2 The Council advises on arrangements
for the safe custody, prescribing and disposal of medicinal substances
controlled under the Act.
2.1.3 The Council reviews arrangements for
reducing the harmful effects of controlled drugs amongst those
who continue to use them; and advises on appropriate harm reduction
measures.
2.1.4 The Council undertakes major reviews,
through its Prevention Working Group, of problem areas relating
to substance misuse. While much of this work relates to harm reduction
(secondary and tertiary prevention), it also encompasses primary
prevention. Its latest Inquiry report was Hidden Harm: Responding
to the needs of children of problem drug users.
2.1.5 The Council published its Reports,
in previous years exclusively in hard copy and more recently,
on its webpages at www.drugs.gov.uk Since 1977, the Council has
published 27 reports.
3. CLASSIFICATION
AND SCHEDULING
OF SUBSTANCES
UNDER THE
ACT
3.1 Substances controlled under the Act
are placed, on the basis of their harmfulness to individuals and
society, into one of three classes:
Class A (most harmful) includes
cocaine, diamorphine (Heroin), 3,4-methylenedioxyme- thamphetamine
(Ecstasy) and lysergic acid diethylamide (LSD).
Class B (an intermediate category)
includes amphetamines, barbiturates and codeine.
Class C (less harmful) includes
cannabis, benzodiazepines, anabolic steroids and gamma-hydroxy
butyrate.
3.2 This system of classification of drugs,
under the Act, is related to determining the penalties for their
possession and supply. The current maximum penalties are as follows:
Class A drugs: For possession—seven
years imprisonment and/or a fine; for supply—life imprisonment
and/or fine.
Class B drugs: For possession—five
years imprisonment and/or a fine; for supply—14 years imprisonment
and/or fine.
Class C drugs: For possession—two
years imprisonment and/or a fine; for supply—14 years imprisonment
and/or fine.
3.3 The Misuse of Drugs Regulations 2001
(Statutory Instrument 2001/3998) defines the categories of people
authorised to supply and possess drugs controlled under the Act.
In these Regulations, drugs are categorised under five schedules:
Schedule 1 includes substances
such as lysergic acid diethylamide and cannabis that are not available
for medical purposes. Possession and supply are prohibited without
specific Home Office approval.
Schedule 2 includes prescription
drugs such as morphine and diamorphine that, because of their
harmfulness, are subject to special requirements relating to their
safe custody, prescription, and the need to maintain registers
relating to their acquisition and use.
Schedule 3 includes barbiturates
and are subject to special prescription, though not safe custody,
requirements.
Schedule 4 includes benzodiazepines
and are subject to neither special prescribing arrangements, nor
to safe custody requirements.
Schedule 5 includes preparations
that, because of their low strength, are exempt from most of the
controlled drug requirements.
4. THE COUNCIL'S
GENERAL APPROACH
TO THE
CONTROL, CLASSIFICATION
AND SCHEDULING
OF DRUGS
4.1 The Council and its Technical Committee
consider evidence, from a variety of sources, about substances
that are—or might potentially be—controlled under
the Act. Sources of intelligence include information from:
— formal surveys undertaken for, or
on behalf of, Government including the British Crime Survey, the
Forensic Science Service statistics, general population surveys,
school surveys as well as international/European surveys such
as European School Survey Project on Alcohol and other drugs (ESPAD);
— the law enforcement agencies;
— voluntary sector organisations with
concerns and responsibilities, for those who misuse drugs;
— published and unpublished scientific
literature; and
— submissions from special interest
groups and the general public.
4.2 Substances considered by the Council
and its Technical Committee over the past three years include:
— benzodiazepines (as a class);
4.3 When considering whether a substance
should be brought under the scope of the Act (ie be designated
as a controlled drug) the Council's advice is based on three domains
of harmfulness:
— Physical and mental health;
— Dependence-producing potential; and
4.3.1 Consideration of the harmfulness of
a substance to physical and mental health covers three areas.
The acute harmfulness of a substance refers to its propensity
to produce harm during the hours (or sometimes days) after administration.
Examples include respiratory arrest after excessive doses of barbiturates,
or acute psychosis with amphetamine. Chronic harms are those which
persist after short-term exposure or which develop as a consequence
of repeated use. Cannabis-induced relapse, in individuals with
schizophrenia, is an example of the former; whilst the carcinogenic
effect of anabolic steroids is a feature of the latter. Substances
that are given by intravenous injection pose special hazards because
of needle-sharing by consumers. This is particularly the case
for the transmisssion of blood borne infections (such human immunodeficiency
virus and hepatitis C virus).
4.3.2 Drug dependence is a complex phenomenon
whose nature differs from substance to substance. It is related
to the duration and amount used, as well as to characteristics
of the user. It is also related to the pleasure that use of the
substance gives. Dependence is generally associated with an increasing
reliance on the drug, with psychological craving when consumption
is reduced or stopped, and sometimes (though not invariably) with
the development of physical withdrawal symptoms.
4.3.3 Social harms include the potential
damage to others when individuals are under the influence of the
substance; other adverse consequences such as acquisitive crime
to finance continued access to the substance. Costs falling on
the National Health Service, to treat the consequences of the
physical and psychological harms (including dependence), are also
considered.
4.4 Much of the evidence about a substance's
physical and psychological harmfulness can be found in the relevant
chemical, pharmacological, clinical and epidemiological literature.
In assessing harmfulness the Council generally undertakes, or
commissions, a review of the published and (wherever possible)
unpublished literature. Valuable information can also be obtained
from information about seizures made by law enforcement officers.
4.4.1 The pharmacological, clinical and
epidemiological literature is of particular value in assessing
the physical harmfulness of a substance.
4.4.2 Reliable evidence about the dependence-producing
potential of a substance can sometimes be obtained from these
same sources; but there can be serious omissions. The prevalence
of dependency on individual controlled substances in the UK, for
example, has been notoriously difficult to establish.
4.4.3 Evidence about social harms is often
the weakest data-set because of the inherent problems in gathering
relevant information. In particular, evidence about the quality
and potency of material used by consumers, their pattern of consumption,
and the social consequences of their use, are all too often absent.
In some instances the Council has commissioned primary research
into areas of particular significance. In other cases the Council
has had to relay on anecdotal evidence provided by individual
Council members or others with expertise in the particular field.
The Council does, however, gain invaluable information form studies
carried out by organisations such as the British Crime Survey,
the Forensic Science Service, and the National Criminal Intelligence
Service.
4.5 As with other national advisory bodies,
the Council ultimately has to make informed judgements based on
the available evidence and the collective experience and expertise
of its members.
4.6 The Council's advice to ministers is
conveyed as either:
— a formal report with a covering letter
from the chairman;
— a letter from the chairman; or
— a submission to ministers, from the
Council's secretary.
In some instances, the Council's chairman may
request a meeting with ministers, or ministers may request a meeting
with the chairman, to discuss the Council's advice. During the
tenure of office of the current chairman of the Council (ie since
1998), no request for a meeting with ministers has been declined.
4.7 On occasions, meetings are also held
between the Chairman and the Director of the Home Office Drugs
Strategy.
5. SPECIFIC SUBSTANCES
5.1 We understand that the Committee seeks
information about the Council's consideration of cocaine, cannabis,
magic mushrooms and amphetamines. As indicated in paragraph 4.2,
the Council has not discussed cocaine but has advised on the other
three substances.
Cannabis
5.2 Cannabis produces its effects on the
brain through interactions between most active psychoactive ingredient,
9-tetrahydrocannabinol
(THC), and specific proteins on the surface of cells known as
cannabinoid receptors. Other psychoactive components in cannabis
preparations, especially cannabidiol, interact with other receptors
in the brain.
5.3 Cannabis products were categorised as
class B substances in 1971 (apart from cannabis oil, which was
classified in Class A). Athough reviewed periodically, between
1971 and 2002, no change in legal status was made.
5.4 The Council was asked to advise on the
appropriate classification of cannabis, in October 2001, by the
then Home Secretary (Rt Hon David Blunkett MP). The Council presented
its report—The classification of cannabis under the Misuse
of Drugs Act 1971—(available at www.drugs.gov.uk/drugs-laws/acmd),
in March 2002, and advised that all cannabis products should be
reclassified as class C. The necessary legislative changes came
into force in January 2004.
5.5 The current Home Secretary asked the
Council, in March 2005, to review the classification of cannabis
in the light of recent evidence about its possible adverse effects
on mental health. He also asked the Council to advise on the extent
to which the potency of cannabis products, as used by consumers,
had increased over the past few years. The chronology of the development
of the Council's consideration of this issue is in Annex C; and
the Council's final report—Further consideration of the
classification of cannabis under the Misuse of Drugs Act 1971—
which was sent to the Home Secretary in December 2005, can be
found at www.drugs.gov.uk/drugs-laws/acmd
5.6 The Home Secretary announced his decision
to accept the Council's recommendations, in full, on 19 January
2006. The Council's report was published on the same day.
Amphetamines
5.7 Amphetamine and its derivatives are
known, pharmacologically as the phenylethylamines. The phenylethylamines
include:
— methylamphetamine (metamphetamine);
5.7.1 The substituted amphetamines include:
— methylenedioxyamphetamine (MDA);
and
— 3,4-methylenedioxymethamphetamine
(MDMA, Ecstasy).
5.8 Whilst the phenylethylamines have common
pharmacological properties, there also are differences in both
their qualitative and quantitative effects. These may be due to
(apparently) small changes in their chemical structure or their
chemical form (eg as base or salt). The phenylethylamines also
exist as optical isomers which, despite their chemical similarities,
differ in their pharmacological actions and potencies.
5.9 Amphetamines and subsituted amphetamines
are controlled under Misuse of Drugs Act 1971. Amphetamine and
methylamphetamine are class B substances. The substituted amphetamines
(MDA and MDMA) are class A substances.
5.10 Following a visit to the US, in late
2003, the Permanent Secretary for Crime, Policing, Counter-Terrorism
and Delivery at the Home Offfice asked the Council to undertake
a detailed assessment of the harms posed by methylamphetamine;
and to recommend measures that might need to be taken to prevent
its misuse in the UK. Although there was at that time little evidence
of such misuse in Britain, the Permanent Secretary was concerned
that the widespread problems associated with its misuse in the
US might spread to the UK.
5.11 The details of the preparation of the
Council's report on methylamphetamine are described in Annex D;
and the report itself can be found at www.drugs.gov.uk/drugs-laws/acmd
Magic mushrooms
5.12 Magic mushrooms contain, as naturally-occuring
substances, psilocin and psilocybin. These compounds, like lysergic
acid diethylamide, have hallucinogenic properties and are particularly
harmful to those with mental illnesses.
5.13 Under the Act products containing psilocin
or an ester of psilocin are controlled as class A substances.
However, the wording of the legislation (as well as its legal
interpretaion in the Courts) suggested that magic mushrooms were
only controlled (under the provisions of the Act if supplied in
the form of a product. This included those that had been dried,
or treated, prior to sale but excluded magic mushrooms sold as
"fresh".
5.14 In March 2004 the Technical Committee
heard that, over recent years, there had been a substantial increase
in the number of retail outlets selling "fresh" magic
mushrooms. In fact HM Customs and Excise estimated the importation
of 8,000-16,000 kgs during 2004.
5.15 In December 2004, the ACMD received
a letter from the Home Office notifying them of the Government's
intention to initiate a change in the law that would clarify the
legal position regarding magic mushrooms. The letter sought feedback
from the ACMD, which was generally supportive and the Council
agreed that clarification of the law would be helpful.
5.16 The Government introduced this change
in law by way of the Drugs Act 2005. Associated regulations were
required to exclude some individuals from the offences under the
Misuse of Drugs Act 1971. In May 2005 the Council endorsed a draft
Regulation that would provide these exemptions in the law. The
Council's opinion was communicated to officials in the Home Office,
in a letter from the chairman, in June 2005. The Regulation came
into force in July 2005.
January 2006
Annex A
MEMBERSHIP OF THE ADVISORY COUNCIL ON THE
MISUSE OF DRUGS AS AT JANUARY 2006
Professor Sir Michael Rawlins (chairman)
Chairman, National Institute of Health and Clinical
Excellence and Professor of Clinical Pharmacology, University
of Newcastle upon Tyne.
Dr Dima Abdulrahim.
Research Briefings Manager
National Treatment Agency
Lord Victor Adebowale
Chief Executive, Turning Point.
Mr Martin Barnes
Chief Executive, DrugScope.
Dr Margaret Birtwistle
Specialist General Practitioner, Senior Tutor—Education
and Training Unit, St George's Hospital and Forensic Medical Examiner.
Reverend Martin Blakeborough
Director, Kaleidoscope Drugs Project, Kingston upon
Thames.
Dr Cecilia Bottomley
Specialist Registrar in Obstetrics and Gynaecology,
London.
Ms Carmel Clancy
Principal Lecturer in Mental Health and Addictions,
Middlesex University.
Professor Ilana Crome
Professor of Addiction Psychiatry, Keele University
Medical School, Harplands Hospital.
Ms Robyn Doran
Registered Mental Health Nurse and Service Director,
Substance Misuse, Central and North-West London Mental Health
Trust.
Ms Dianne Draper
Public Health Policy Support Officer, Government
Office for Yorkshire and Humberside.
Mr Robert Eschle JP
Local Councillor and Magistrate, Kent.
Ms Vivienne Evans
Chief Executive, ADFAM.
Professor C Robin Ganellin FRS
Emeritus Professor of Medicinal Chemistry, University
College London.
Dr Clare Gerada
General Practitioner, London and Primary Care Lead
for Drug Misuse, Royal College of General Practitioners.
Mr Patrick Hargreaves
Drugs and Alcohol Advisor, Durham County Council
Education Department.
Mr Paul Hayes
Chief Executive, National Treatment Agency.
Mr Andrew Hayman
Assistant Commissioner of the Metropolitan Police,
and Chair of the Association of Chief Police Officers Drugs Committee.
Mr Russell Hayton
Clinical Nurse Specialist and Clinical and Services
Governance Manager, Plymouth Drug and Alcohol Action Team.
Ms Caroline Healy JP
Director, ChildLine and Magistrate, London.
Dr Matthew Hickman
Deputy Director, Centre for Research on Drugs and
Health Behaviour, Senior Lecturer in Public Health, Bristol University.
Mr Alan Hunter
Director, Law Regulatory & Intellectual Property
and Secretary to the Association of British Pharmaceutical Industry.
Professor Leslie Iversen FRS
Professor of Pharmacology, Oxford University.
His Honour Judge Thomas Joseph
Resident Judge, Croydon Crown Court.
Professor Michael Lewis
Professor of Oral Medicine, Cardiff University.
Dr John Marsden
Research Psychologist, Institute of Psychiatry, London.
Mr Peter Martin
Former Chief Executive, Addaction.
Mrs Samantha Mortimer
Head of Personal, Social and Health Education and
Citizenship, St Paul's Catholic High School, Manchester.
Professor David Nutt
Professor of Psychopharmacology, Bristol University.
Dr Richard Pates
Consultant Clinical Psychologist and Clinical Director,
Community Addiction Unit, Cardiff.
Mr Trevor Pearce
Acting Director General, National Crime Squad.
Mr Howard Roberts
Deputy Chief Constable, Nottinghamshire Police.
Mrs Kay Roberts
Pharmacist, Glasgow
Dr Mary Rowlands
Consultant Psychiatrist in Substance Misuse, Exeter.
Dr Polly Taylor
Veterinary Surgeon, Cambridgeshire.
Ms Monique Tomlinson
Freelance Consultant in Substance Misuse, London.
Mr Arthur Wing
Assistant Chief Officer, Sussex Probation Area.
Annex B
MEMBERSHIP OF THE COUNCIL'S TECHNICAL COMMITTEE
AS AT JANUARY 2006
Professor David Nutt FMedSci
(Chairman)
ACMD member
Mr Martin Barnes
ACMD Member
Professor Geoff Phillips
Advisor to the Home Office
Dr Clare Gerada
ACMD Member
Dr Noel Gill
Public Health Laboratory Service
Professor CR Ganellin FRS
ACMD Member
Alan Hunter
ACMD Member
Dr S L H Thomas
Reader in Clinical Pharmacology, University of Newcastle
upon Tyne
National Poisons Information Service (Newcastle Regional
Drugs and Therapeutics Centre)
Dr Les King
Advisor to the Home Office
Former Head of Drugs Intelligence Unit (Forensic
Science Service)
Kay Roberts
ACMD member
Dr Polly Taylor
ACMD member
Dr Dima Abdulrahim
ACMD member
Dr Margaret Birtwistle
ACMD member
Robert Eschle
ACMD member
Dr Tom Gilhooly
General Practitioner
Professor Leslie Iversen FRS
ACMD member
Matthew Hickman
ACMD member
Baroness Ilora Finlay
Professor of Palliative Medicine, Cardiff
Annex C
CHRONOLOGY OF EVENTS LEADING TO THE ACMD's
2005 REPORT ON CANNABIS:
"FURTHER CONSIDERATION OF THE CLASSIFICATION
OF CANNABIS UNDER THE MISUSE OF DRUGS ACT 1971"
(1) Following the publication of the Council's
2002 report on cannabis the issue remained a standing item on
the agendas of both the Council and its Technical Committee.
(2) At its meeting in October 2004 the Technical
Committee invited Dr Stanley Zammit—who had undertaken further
analysis of the Swedish conscripts of 1969 historical cohort study—to
attend and to provide an overview of the relationship between
cannabis use and psychotic illness.
(3) In March 2005, the Home Secretary wrote
to the chairman of the Council, seeking advice on recent evidence
(published since its 2002 report) about the effects of cannabis
on mental health. He also asked the Council for advice on the
alleged increase in potency of cannabis products currently available.
(4) At its meeting in May 2005, the Council
agreed to a process by which it would review the available evidence
and appointed a Steering Group (comprising the chairman of the
Council, the chairman of the Technical Committee, Professor Leslie
Iversen, Mrs Kay Roberts, Dr Matthew Hickman, Dr John Macleod
and Dr Leslie King) to undertake the detailed planning on its
behalf.
(5) The Steering Group, through the secretariat,
commissioned the preparation of additional information:
— Forensic Science Service: An Update
on Cannabis Potency;
— Dr Matthew Hickman: Cannabis and
schizophrenia: model projections and impact of the rise in cannabis
on historical and future trends in schizophrenia (England and
Wales);
— Home Office: FRANK statistics;
— National Poisons Information Service:
Enquiries relating to suspected cannabis toxicity;
— British Crime Survey: (Then) unpublished
data on cannabis use (2004-05).
(6) With the assistance of the Council's
secretariat, the Steering Group also undertook the identification
and retrieval of the relevant published literature on the effects
of cannabis on mental health, and the potency of THC in cannabis
products.
(7) The Steering Group invited the submission
of evidence from interested parties. These included specific requests
to individuals in the UK, and overseas, who were known to have
expertise in the area; as well as arrangements to consider unsolicited
submissions (including those made directly to the Home Secretary)
from both special interest groups and the general public.
(8) The Steering Group invited, on behalf
of the Council, selected outside experts and representatives of
voluntary organisations to present their data or views at a special
meeting of the Council convened on 23 September 2005. Those invited
to give oral evidence are identified in the Council's final report
(at Annex 3 of that report).
(9) The Steering Group also asked five additional
experts (in psychiatry, epiemiology and statistics) to attend
the special meeting of the Council and to act as additional scientific
advisors. These individuals are identified in Annex 2 of the Council's
report.
(10) All relevant written material submitted
to the Council, including submissions and letters from the special
interest groups and general public, was included in a 500+ page
pack of papers and sent to Council members, and to the five expert
advisors, well in advance of the special Council meeting in September
2005.
(11) The day after the special open meeting
of the Council, a closed session was held to consider the evdience
and draw provisional conclusions. Those attending this session
were limited to the Council members, the five additional expert
advisors, a limited number of relevant officials and the secretariat.
(12) The Steering Group took responsibility
for drawing up the draft report which was considered by the Technical
Committee, and the full Couincil, at their meetings on 3 and 24
November (respectively). The final report was sent to the Home
Secretary in December with a covering letter from the Council's
chairman.
Annex D
CHRONOLOGY OF EVENTS LEADING TO THE ACMD
2005 REPORT ON METHYLAMPHETAMINE
(1) Following the receipt of the Permanent
Secretary's request the Technical Committee undertook a preliminary
examination of the global misuse of methylamphetamine at its meeting
on 11 March 2004. This was informed by a presentation from Dr
John Marsden and Dr Mike Farrell (Institute of Psychiatry, London).
The Committee recommended to Council that, despite the lack of
evidence of widespread misuse in the UK, a detailed assessment
should be undertaken.
(2) At its meeting on 1 April 2004, the
presentation by Drs Marsden and Farrell was repeated to the full
Council who decided to establish a Working Group, under the immmediate
jurisdiction of the Technical Committee, to investgate the matter
further and to draft a report for Council.
(3) The Working Group met on three occasions
between April and September 2004. The evidence base constructed
by the Working Group was as follows:
— a review of the relevant scientific
literature;
— additional (unpublished) reports
provided by:
— National Criminal Intelligence Service:
Misuse of Pharmaceutical Products in the Illicit production
of Methylamphetamine;
— Forensic Science Service: Chemistry,
Seizure Statistics<Analysis,
Synthetic Routes and History of Illicit Manufacture in the UK
and USA.
— Professor Charles Marsden: Pharmacology
of methylamphetamine;
— Dr Val Curran: Literature Review of
Methylamphetamine;
— Mr Ronald Geer: Experience of Methylamphetamine
Misuse in the US;
— Professor Robin Murray: Drug induced
psychoses;
— Dr Judy Miles: Treament Issues.
(4) The Working Group's draft report was
considered by the Technical Committee in October 2004, and by
the Council, in November 2004. At the request of the Council the
Working Group was asked to undertake additional work. The Working
Group met on one further occasion and its final report was considered
by Council in April 2005. After amendments, the report was sent
to the Home Secretary who accepted the Council's advice in full.
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