Select Committee on Home Affairs Memoranda


Submitted by Action on Hepatitis C


  In the late 1980s British drug policy was led by an individual and public health approach to contain the spread of HIV. The reduction of harm through needle exchange and other measures took precedence in development plans1. Although this effectively contained HIV transmission via injecting drug use, the UK now has a much larger epidemic of another blood borne virus, hepatitis C (HCV) with huge anticipated costs. Yet current UK drug policy sidelines this. Issues of control and criminal justice are promoted to the detriment of individual and public health. Our current policy will increase drug-related deaths and other harm to individuals and society. It should be replaced by one where harm reduction is central to our approach.

The following are examples of recent/anticipated national drug policy changes and omissions which will increase drug-related deaths:


New UK criminal justice initiatives will increase drug-related deaths from hepatitis C.

  Prisons are multipliers of blood borne viruses. Many people become infected with hepatitis C while in prison through the sharing of injecting equipment with other prisoners and will later die of their infection. Harsh UK drug laws with high custodial sentencing are out of step with other European countries and will increase drug related deaths in the UK.

  Recent changes in UK legislation have worsened the risk of BBV infection in prison and drug-related deaths:

    (a)  There is widespread anecdotal evidence of a switch from cannabis to heroin use in UK prisons since the introduction of mandatory drug testing. Unlike cannabis heroin is commonly injected, increasing the risk of BBV transmission and drug-related death.

    (b)  Abstinence Orders are expected to increase the number of drug users in prison when those sentenced fail to maintain abstinence, because dependent drug use is a relapsing disorder. Studies in France, Italy and Australia show that 54-64 per cent of IDUs in prison are already infected with HCV. The total numbers of HCV infected prisoners will increase with a heightened risk of infection of other prison inmates.

    (c)  As investigation and treatment of hepatitis C is almost impossible to obtain in prison, overall circulating virus levels remain high with an increased risk of HCV transmission, and anticipated future high morbidity and mortality.

The treatment of injecting drug users who have chronic hepatitis C

  British drug policy and national policy on BBV infection are intimately related through drug-related deaths. Deaths from hepatitis C can be prevented by treatment. Although current IDUs with HIV can access treatment, UK guidelines 2,3,4 on the treatment of hepatitis C exclude current IDUs. This is a major concern because drug users form the greatest number of those who are infected with HCV. It ignores the human right to life and will considerably increase the morbidity and mortality of drug users.

  This exclusion on the grounds of presumed future lack of compliance and presumed high reinfection rates is ill-founded as shown by two articles in the medical press in July 2001. The first by seven authors from the University of California in San Francisco (UCSF)5 lays out all the evidence why drug users should not be denied treatment for HCV. The second is a paper in Hepatology from a group in Germany6 showing that current IDUs can be treated successfully for HCV.

Supervised Consumption

  Current clinical guidelines recommend that almost all new patients should have supervised consumption of their prescribed drugs for at least three months, subject to compliance. Supervised consumption has a small role but should not be universally applied. The management of drug users should be sensitive to individual health care needs.

  In rural areas most supervised consumption occurs at community pharmacies where drug users can be seen swallowing the green liquid by their neighbours. The BMA believes this to be unethical7. It will also deter drug users from accessing treatment for other reasons, such as distance to travel in rural areas, potential loss of employment, etc. This deterrence to help-seeking will increase overdose deaths, increase deaths from BBVs both in drug users and the general population, and increase crime.

Proposed licensing of doctors treating drug users

  An almost identical proposal to license doctors was rejected in 1984 because it would deter GPs from treating drug users. Senior doctors in the drug field have recently stated the current proposals on licensing will also deter GPs from treating drug users8,9,10, and that clinical governance is a better way of ensuring good quality care9,10. Specialist drug services are small, but there are 36,000 UK GPs. Even a small percentage of GPs pulling out will have a major impact. We anticipate that specialist drug services, already stretched beyond capacity, will become overwhelmed with drug users seeking help they cannot obtain from their GP or elsewhere, and waiting lists for treatment (already up to six months in places) will grow progressively longer.

  It is well established that treatment reduced drug-related deaths, drug-related crime and injecting risk behaviour leading to blood borne virus (BBV) transmission. Failure to access treatment will result in:

    —  more overdose deaths and a rise in blood borne virus infection rates. We already have a national disaster from the hepatitis C epidemic. This will worsen with more delayed deaths from liver failure and cancer of the liver.

    —  more crimes on the streets perpetrated by those unable to access treatment.


  The absence of an alcohol treatment strategy and the exclusion of alcohol from advice and funding within current drug strategy will increase drug-related deaths. Alcohol use increases the risk of death from liver failure and cancer of the liver of the estimated 400,000 people in the UK who have been infected with HCV (in 80 per cent the virus has been transmitted through shared injecting drug use).

  Prison needle exchange has been shown to work in Europe and should be piloted in the UK.

  Harm reduction should be central to UK drug policy, as it is in Australia, where policy makers ensure that potentially harmful new polices are not enacted and harmful policy omissions are corrected.

September 2001


  1.  Report of the Advisory Council on the Misuse of Drugs. (1988) AIDS and Drug Misuse Part 1. London: HMSO.

  2.  Report of the National Institute for Clinical Excellence (2000). Guidance on the Use of Ribavirin and Interferon Alpha for Hepatitis C.

  3.  British Society of Gastroenterology (2001) Clinical Guidelines on the management of hepatitis C.

  4.  EASL International Consensus Conference on Hepatitis C. Consensus Statement. (1999) Journal of Hepatology, 30, pp.956-961.

  5.  Edlin, B.R., Seal, K.H., Lorvick, J., et al (2001) Is it Justifiable to Withold Treatment for Hepatitis C from Illicit Drug Users? New England Journal of Medicine, Vol 345, No 3, pp.211-214.

  6.  Backmund, M., Meyer, K., Von Zielonka, M., & Eichenlaub, D. (2001) Treatment of hepatitis C infection in injecting drug users. Hepatology, 34, (1), pp.188-193.

  7.  Personal communication to Dr Waller from Anne Somerville, ethical adviser BMA. (2000).

  8.  Beaumont, B., Carnwath, T., Clee, W., Ford, C., Gabbay, M., Robertson, R., Rumball, D., Waller, T. (2000) Licensing doctors counters the national strategy, Druglink, 15 (6) p.25

  9.  Beaumont, B., Carnwath, T., Clee, W., Ford, C., Gabbay, M., Robertson, R., Rumball, D., Waller, T. (2001) Alternatives to licensing doctors, Druglink, 16 (1), p.9.

  10.  Gabbay, M.B., Carnwath, T., Ford, C., & Zador, D.A. (2001) reducing deaths among drug misusers, British Medical Journal, 322, pp.749-750.

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Prepared 20 December 2001