Illicit Tablet Information and

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Premier’s Drug Prevention Council

A Feasibility Study for an

Illicit Tablet Information and

Monitoring Service

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A Feasibility Study for an Illicit Tablet Information and Monitoring Service

Prepared for the Premier’s Drug Prevention Council September 2009

Author

J Hales. Health Outcomes International. Suite 1, 51 Stephen Terrace, St Peters SA 5069 (PO Box 1038, Kent Town SA 5071)

Ph 08 8363 3699 Fax 08 8363 9011 ABN 80 081 950 692

This document should be cited as:

J Hales. A Feasibility Study for an Illicit Tablet Information and Monitoring Service.

Report to the Premier’s Drug Prevention Council Victoria; Health Outcomes International, Melbourne, September 2009. Design and art by Caridi Design Pty Ltd

Research Note

This report describes findings of research that was conducted in 2007-2008. Further information about illicit tablet information systems may have been produced since that time. Identified costs would also be expected to have increased.

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FeASIbIlITy STudy For An IllIcIT TAbleT InForMATIon & MonITorIng ServIce

Executive Summary . . . 3

1 Introduction . . . 11

1.1 Background . . . .11

1.2 Project Objective . . . .11

1.3 Scope . . . .11

2 Findings from the Literature . . . 13

2.1 Introduction . . . .13

2.2 Rationale for Illicit Tablet Information and Monitoring . . . .13

2.3 Web-based Drug Information . . . .15

2.4 Drug Monitoring Systems in New Zealand and Australia . . . .16

2.5 Early Warning Systems . . . .18

2.6 Tablet Information Services . . . .19

2.7 Tablet Testing . . . .20

3 Stakeholder Interviews . . . . 33

3.2 Summary of Findings . . . .33

4 Implementation Issues and conclusions . . . 43

4.2 Accessing Illicit Tablets . . . .43

4.3 Testing Illicit Tablets . . . .46

4.4 Presenting Information in an ITIMS . . . .49

Endnotes . . . . 55

Glossary . . . 56

Appendices . . . . 57

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Background

The Victorian Department of Human Services, on behalf of the (former1_{) Premier’s Drug Prevention Council}

(PDPC) commissioned a study to ascertain the feasibility of developing and implementing an Illicit Tablet Information and Monitoring Service (ITIMS) in Victoria.

An ITIMS seeks to provide information about illicit tablets that enables individuals to be more informed of the content of the tablets that they may contemplate using; to identify the health and social risks associated with illicit drug use; to measure progress against strategies to offset drug use and to seek treatment, support and referral information. In addition, an ITIMS may assist in identifying emergent trends in drug use and in providing awareness of the presence of illicit drugs in specific regions, thus making it a useful resource for legislators, law enforcement personnel, health care providers, drug services and researchers. An ITIMS in Victoria would focus on tablets that are “illicitly manufactured, distributed and sold/consumed, as well as tablets legally manufactured, but are illicitly obtained, distributed and sold/consumed.”2_Health

Outcomes International was appointed to undertake the study.

Project Objective and Scope

The project objective is to:

n Identify the major potential users of an ITIMS and determine their collective and respective information

needs.

n Develop and appraise a range of options (system models) for an ITIMS, which meets the collective and

respective needs of the major potential information users.

n Assess the feasibility, output costs, and risks of developing and implementing the range of options

identified and propose recommendations as to the most preferable option/s.

The methodology used in this study comprised a scan of the available literature on the use and experience of a range of information systems internationally, together with a series of face-to-face and telephone interviews with nominated stakeholders in Victoria. Further, implementation issues were explored and recommendations made, in particular regarding accessing illicit tablets, testing of illicit tablets and presenting information in an ITIMS. This report presents the project’s consolidated findings.

Findings from the Literature

The literature was reviewed for existing web-based drug information, drug monitoring systems, early warning systems, tablet information services and tablet testing models in Australia and overseas.

A number of reasons to support the provision of an illicit tablet information and monitoring service were presented in the literature, including:

n The provision of information enables individuals to be properly informed of the content of the tablets

that they may contemplate using.

ExECuTIvE SummAry

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n Identification of the health and social risks associated with illicit drug use.

n Measurement of progress against strategies to offset drug use and to seek treatment, support and

referral information.

n Assistance in identifying emergent trends in drug use and in providing awareness of the presence of

illicit drugs in specific regions, thus making them a useful resource for legislators, law enforcement personnel, health care providers, drug services and researchers.

Data provided by an ITIMS must be widely disseminated and frequently updated if it is to be of practical value. However, the implementation of an ITIMS requires consideration of the type and amount of information that is to be provided, to whom, and via which medium or media. Consequently, the implementation of an ITIMS must identify the potential end users of the service and consider their specific needs. An ITIMS could thus be targeted at the needs of emergency services, law enforcement agencies and other key stakeholders in the drug and alcohol sector. Education and prevention information targeted at users and potential users may also be one of the objectives of a tablet information service. There are essentially three types of information that an ITIMS might collect and disseminate. These are:

n Information relevant to the identification of substances. n Information relating to the use of specific illicit substances.

n Information on the health and other consequences of using specific illicit substances.

It is particularly important that such information be scientifically valid, objective and is based on appropriate testing procedures.

Tablet testing methods identified in the literature include for example:

n Tablet identification (i.e. visual comparison of tablets with details of formerly analysed tablets, such

as size, shape, colour logos or other physical markers).

n Colour reaction tests (e.g. the Marquis test). This can identify the presence of ecstasy substances

such as MDMA, MDA, MDE, but cannot determine how much of the identified substance is present in the tablet. These tests are not capable of detecting a number of potentially dangerous chemicals that may be substituted for ecstasy.

n Chromatography involves the separation of a drug compound into its separate chemical components,

thus permitting the identification of individual substances in complex chemical mixtures. It is a relatively fast technique, taking as little as fifteen minutes, possesses high-level reliability and produces quantitative and qualitative results that can be used immediately in on-site testing locations.

n Mass spectrometry involves the conversion of a drug or drug metabolite into charged particles

and the mass-to-charge ratios of the particles generated create a pattern that provides a positive identification of the drug.

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n Immunological tests are based on the reaction of a specific antibody to a substance. Commercially

available immunotest systems for urine drug tests are commonly employed in Europe for this form of testing. Immunology cannot be used directly for tablet testing, but is used to identify substances consumed after the fact.

n Capillary electrophoresis describes a family of techniques that can be employed to separate a variety

of compounds. These analyses, all driven by an electric field, are performed in narrow tubes and can result in the rapid separation of many hundreds of different chemicals.

Chromatography is the most widely accepted and available testing method.

The cost of tablet testing reported in the literature varied and there was no relevant information from Australia.

Drug users have been identified as a potential source that would provide for the widest and most timely coverage of tablets on the market. In a number of countries, tablet testing at known sites and occasions (e.g. raves) is used as a point of data collection about illicit tablets, as well as providing immediate feedback to users on the tablets being tested at the time. Consequently, there is an inherent link between the timeliness and coverage of an illicit tablet information service and the use of tablet testing as the main source of the data. However, there are a number of factors relating to tablet testing that would need to be considered in the context of its role in informing an ITIMS:

n The evidence about the influence of tablet testing on the behaviour of users is equivocal, and comes

from overseas. Some research indicates that tablet testing raises the profile of the safety issues surrounding illicit tablets and provides a mechanism by which service providers can interact with drug users. This research did not show that tablet testing leads to an increase in tablet use, nor did it demonstrate dramatic behaviour changes towards safer tablet use that were associated with tablet testing. Other research has found that tablet testing would have little effect, or possibly an adverse effect, on the safer use of illicit tablets.

n Current legislation in Victoria would see any person bringing a tablet to be tested as guilty of

possession, and by handing a tablet to a tester as committing the offence of supply. The same offences apply to the tester by receiving the tablet for testing, and then handing it back.

n A decision on the implementation of illicit tablet testing could also take into account the capacity to

benefit. In this regard, data from the National Coronial Information System showed that from 2001-2004, there were 112 ecstasy-related deaths in Australia, of which 51 (46%) had ecstasy as the primary contributor; 16 (14%) had ecstasy as the secondary contributor, and 45 (40%) had ecstasy as the tertiary contributor. Importantly, in the large majority of cases where adverse outcomes have been experienced, ecstasy was rarely the only drug used, and other external factors such as the ambient temperature of the environment, the level of physical activity and the extent of fluid re-hydration after ecstasy use were also contributing factors. None of these would be affected by the provision of on-site tablet testing.

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There are a number of legal and ethical issues associated with testing illicit tablets in public venues. A critical issue concerns what users should be told after testing. It is important that no information that could be construed as encouraging the consumption of illicit substances or that implies even the relative “safety” of any detected substances be made.

It has also been suggested in the literature that tablet testing projects provide indirect benefits such as opportunities to access populations that are otherwise difficult to contact and to raise their interest in harm prevention and reduction. Harm reduction may be achieved if tablet testing provides opportunities to transmit “safer-use” messages relating to issues such as acute, short-term and long-term health hazards, addiction, legal risks and drug driving.

Stakeholder Interviews

The consultations undertaken for this study involved face-to-face and telephone interviews with a range of stakeholders in Victoria, and revealed widespread agreement that they, their clients and other stakeholders currently have unmet information needs regarding the illicit tablets available and their characteristics. In general, these concerns relate to an absence of timely and reliable information regarding chemical content and tablet appearance, for instance shape, colour, logos and any other distinguishing features. However, there was some variability in the needs expressed in regard to the nature and timeliness of the information required and its use, largely reflective of the various roles and interests of the parties interviewed.

The most common required content of an ITIMS identified across stakeholder groups included:

n Alert warnings about tablets that have been found to be dangerous due to contaminants or

adulterants.

n Information on tablet content, including both active and passive constituents. In this regard,

legislative requirements call for constant definitions to be applied for three to four years.

n Tablet description, including street names, appearance, colour size, shape, logos and any other differentiating

characteristics. This may include photographs, but they would need to be of suitable quality.

n Information on how different drugs may affect behaviour, as well as risks associated with potential

negative effects.

n Locations where the tablets were sourced in order to ensure that localised data are available, including

rural locations.

General information on harm minimisation and where to access additional services.

Views were mixed as to whether the concentration of tablets’ contents should be included in an ITIMS. Consumer representatives generally considered that concentration of constituents should be included, but recognised that this information should be presented carefully in order not to infer increased effects. Other stakeholders were generally opposed to constituent concentration being presented.

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Views regarding access to the information contained on an ITIMS varied considerably, and were divided fairly equally between the following perspectives:

n Access to all the information contained on an ITIMS should be universal in order to maximise

its influence and to inform the decisions of drug users. This view was held by advocacy bodies representing drug users and some other stakeholders.

n The information on the ITIMS should be partitioned such that different groups would have access to

different elements of the information. This approach would involve establishing a “public” component of the ITIMS and a “private” component that would require a password to access.

n The general public (including drug users) should not have any access to the ITIMS; access should

be restricted to organisations and their representatives in such areas as health, research, police and policy makers. This view was based on a concern about potential misuse by users and dealers, as well as the legal and health implications of suggesting that any particular substance or tablet might be less hazardous than another.

The currency of the information contained on an ITIMS was regarded as particularly important by drug users and health professionals who might access the system for safety reasons. The illicit tablet market was seen as being highly dynamic and changeable, with new tablets appearing, and disappearing on a frequent basis. Consequently the need to keep abreast of these changes was seen as underpinning the value of the information contained in an ITIMS for these groups. For other stakeholder groups, the issue of timeliness was generally less pressing.

The source of the information has clear implications for the timeliness of the data presented on an ITIMS. Police and Customs seizures were seen as being useful, but potentially limited in terms of their timeliness, coverage, and delays in presentation of results. However, views on this issue varied between stakeholder groups. Information gathered at hospitals, particularly emergency departments, was also seen as being useful, but also of limited coverage and uncertain timeliness.

Additional potential data sources identified for an ITIMS include the analysis of tablets placed in amnesty bins or discarded at raves etc., and the use of covert tablet purchases by Police for the purpose of analysis. Both such approaches are likely to require legislative or regulatory changes.

Perhaps the most controversial source identified was on-site tablet testing at sites where drugs are being used. It was recognised by most of those consulted that this source could potentially provide the widest and most timely coverage of tablets on the market. The issues associated with tablet testing embodied in using drug users as the source of information for the ITIMS were widely recognised, and reflect those reported in the literature review. Opinions were divided as to the merits of this approach.

Views also diverged in regard to management of an ITIMS. The majority of stakeholders considered that an ITIMS system should not be under the management of Police or the judicial system. The general consensus was that both the philosophy underpinning an ITIMS (as a harm minimisation initiative) and the acceptability of the system to a wide range of its users indicated that its management should fall

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under the general umbrella of the health sector. However, the establishment and ongoing operation of an ITIMS was widely recognised as requiring a collaborative effort and communication processes across a range of government and non-government agencies.

The application of an ITIMS in rural areas was regarded as being important in two respects. Firstly, access to a web-based ITIMS was seen as potentially providing rural drug users with improved access to information about the tablets on the market and their effects. The second aspect related to the need to collect tablets from rural areas to ensure that the information contained in the ITIMS was relevant to these locations. It was suggested that, if tablet testing from drug users is to be adopted, that it be extended to rural areas on a regular cycle, in addition to any other information gathered through other sources.

Implementation Issues and Conclusions

This section considers issues relating to the implementation of an ITIMS in Victoria, having regard to the findings from the literature and the views of stakeholders presented previously. Further, it presents recommendations for key implementation processes.

The establishment of an ITIMS may be feasible within the current legislative and policy environments, and using existing infrastructure and processes to maximise efficiency and reduce costs.

There are also a number of challenges that would impact on implementation, with the key processes involved in establishing and operating an ITIMS being identified as accessing illicit tablets for testing, testing tablets and presenting information in an ITIMS.

The use of the tablets seized by Police and Customs is the recommended approach, as it will provide a more readily implementable, less costly and less controversial approach than other alternatives. Implementation of this approach would require further discussions with Police to ascertain the most appropriate processes to expedite the provision of tablets for testing, and any ramifications this may have on other Police operations (such as tablet storage, evidence handling, prosecution processes). The coverage and currency of the tablets collected under this approach would require monitoring to assess its appropriateness.

Chromatography is the most widely accepted and available testing method that meets the technical quality and timing requirements of users of an ITIMS, and is the recommended approach. This technology is currently used in the Forensic Services Department of Victoria Police, which may have capacity to expand its services to meet the timeline needs of users of an ITIMS. Further, the Department meets the legislative and safety requirements for handling and testing illicit substances. Costs of the Forensic Services Department expanding its capacity to test an additional 100 tablets per week with a four-hour turnaround are approximately $140,000-$160,000 per annum, or $30 per tablet.

A web-based application is regarded as the most accessible and effective mechanism for hosting an ITIMS. A specification for the design of the ITIMS was prepared as a guide to its structure, content and functionality. Hosting ITIMS on an existing website with a similar subject matter and synergy of content would be the recommended approach. This approach would provide for ITIMS to be located within a broader suite of relevant information, place it in an environment and location that users are more likely to

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find, and reinforce the harm minimisation message.

An important factor to be considered is the cost of implementing an ITIMS, particularly in regard to expanding the capacity of the Forensic Services Department to meet the timing requirements of ITIMS and the design, development and maintenance of the ITIMS Website.

An important factor to be considered is the cost of implementing the ITIMS, particularly in regard to expanding the capacity of the Forensic Services Department to meet the timing requirements of ITIMS and the design, development and maintenance of the ITIMS Website.

Overall, initial establishment costs are estimated at $10,000 for website design and development, with annual operating costs of approximately $150,000 – $200,000.

If the decision is made to proceed with the implementation of an ITIMS, further discussions will need to be held with:

n DHS, Victoria Police and the Forensic Services Department in Victoria Police about the content and

accessibility of the ITIMS.

n Police regarding processes for the forwarding of seized tablets to the laboratory, and the procedures

required to maintain the chain of evidence and access to test results for evidentiary purposes.

n Forensic Services Department in Victoria Police for their requirements to expand testing capacity to

the level required.

n A third party web-site provider to assess willingness to host the ITIMS (or alternatively implement an

open tender process for this purpose).

n A web-site developer to design and develop the ITIMS (or alternatively implement an open tender

process for this purpose).

Further consideration also needs to be given to managing a number of issues, risks and barriers to the establishment of an ITIMS, including:

n balancing diverse community views associated with an ITIMS being regarded as promoting or supporting

the use of illicit drugs.

n ensuring that the methods used for collecting tablets for testing comply with the law. n Ensuring safety with regard to the the range of substances tested for and reported on.

n achieving the right balance with pre- and post-test messaging in terms of drug users interpreting the

information provided as implying that some tablets are “safe”.

n preventing drug dealers using ITIMS to legitimate and promote their drugs.

n balancing the costs associated with the collection and testing of tablets which may outweigh the benefits

to be derived.

n ensuring timely information contained in ITIMS given the changing pace of the illicit tablet environment

means information could become outdated very quickly.

These issues may not be insurmountable, but require consideration and planning, together with careful management and promotion of the ITIMS to ensure that each issue is catered for.

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1.1 Background

The Victorian Department of Human Services, on behalf of the Premier’s Drug Prevention Council (PDPC) commissioned a study to ascertain the feasibility of developing and implementing an Illicit Tablet Information and Monitoring Service (ITIMS) in Victoria. It intended that an ITIMS would focus on tablets that are “illicitly manufactured, distributed and sold/consumed, as well as tablets legally manufactured, but are illicitly obtained, distributed and sold/consumed.” Health Outcomes International was appointed to undertake the study.

1.2 Project Objective

The project objective was to:

n Identify the major potential users of an ITIMS and determine their collective and respective

information needs.

n Develop and appraise a range of options (system models) for an ITIMS, which meets the

collective and respective needs of the major potential information users.

n Assess the feasibility, output costs, and risks of developing and implementing the range of

options identified and propose recommendations as to the most preferable option/s.

1.3 Scope

The project focuses on the feasibility of the development and implementation of an ITIMS. The users of an ITIMS are likely to include, but are not limited to, health workers, law enforcement, researchers, policy makers and program planners, and users of illicit tablets.

There were three key stages planned for the project, each with related tasks:

Stage 1 – Survey and analyse the needs of potential users of an ITImS . This includes:

n Review the local and international research literature relating to drug information and

monitoring services, particularly that pertaining to illicit tablets. This should include a review of any existing models and the social and health risks surrounding these.

n Identify and review existing activities, drug monitoring, research and surveillance underway

by Government (including health and law enforcement) and non-government groups within Victoria and nationally that constitute part or whole of an illicit tablet information and monitoring service.

n Identify the major potential users of an ITIMS.

n Undertake initial, individual consultations with representatives of the identified information

users to determine their respective needs, including:

• the purpose/s for which they would use ITIMS information;

INTrOduCTION

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• the type (such as tablet content, drug effects, health warnings and referral information) and format of ITIMS information they would use/not use; and,

• the preferred timing and method of receiving/accessing ITIMS information and the risks involved in not achieving the preferred timing and method.

n Analyse the findings of the consultations and literature review to form a needs assessment

and a specification of the essential and non-essential requirements for an ITIMS and any risks surrounding these.

n Compile a summary of the findings and analysis of the first stage into a brief report.

Stage 2 – develop and analyse a range of ITImS options:

n Develop a range of options (system models) for an ITIMS which:

• provides accurate and timely information which addresses the collective and respective needs of the major potential information users identified;

• are within the existing legal and policy parameters of Government;

• takes into account the existing drug information, monitoring and research activities within Victoria and nationally that could constitute part or whole of an ITIMS;

• balances the health and safety interests of the general public and illicit tablet users with the output costs and risks associated with a tablet information and monitoring service.

n Devise a clear criterion for assessing the feasibility, output costs and social and health risks of

developing and implementing the range of options identified and for selecting one or more options as the most preferable option/s.

n Assess the range of options identified and propose recommendations as to the most preferable

option/s.

n Develop and facilitate a consultation workshop with a representative sample of all identified

users to present the options and draft recommendations and seek their feedback.

n Compile a summary of the findings and analysis of the second stage into a brief report.

Stage 3 – Present Final report and recommendations:

n Compile the findings of the stages 1 and 2 and final recommendations into a Final Report for

presentation to the PDPC and the government.

n Present the main issues, findings and final recommendations in the Final Report to the

government.

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2.1 Introduction

The purpose of this section is to present the findings of a review of the literature on illicit drug information, monitoring programs currently available in Australia and internationally, and operational systems of testing the chemical content of tablets. The objective is to summarise the range and nature of extant illicit tablet monitoring and information services, to describe their operations, and to identify issues of relevance for the establishment and operation of an ITIMS in Victoria.

There are numerous drug information and monitoring services located in Australia and overseas that are readily accessible via the internet. These services, individually or in combination, appear to address some of the objectives of the proposed ITIMS. In addition, the (former4_{) Drugs Policy and}

Services Branch completed a scoping study of such services in Victoria which mapped the illicit tablet data collection, analysis and information dissemination systems in Victoria. These resources are referenced in the current review, with the objective of identifying the range of currently available services that at least partially address the requirements of Victorian stakeholders.

It should be noted that, despite the numerous examples of drug information and monitoring services that exist internationally, no research was found about the effects of these services on drug use or drug taking behaviours, nor whether they were cost-effective.

The following presents a rationale for illicit tablet information and monitoring, followed by findings on web-based drug information, drug monitoring systems in New Zealand and Australia, early warning systems, tablet information services, and tablet testing.

2.2 Rationale for Illicit Tablet Information and Monitoring

The literature provides a number of reasons to support the provision of an illicit tablet information and monitoring service. Services that provide information in relation to illicit tablets enable individuals:

n To be more informed of the content of the tablets that they may contemplate using. n To identify the health and social risks associated with illicit drug use.

n To measure progress against strategies to offset drug use and to seek treatment, support and

referral information.

In addition, tablet information services may assist in identifying emergent trends in drug use and in providing awareness of the presence of illicit drugs in specific regions, thus making them a useful resource for legislators, law enforcement personnel, health care providers, drug services and researchers.

The data provided by tablet monitoring systems must be widely disseminated if they are to be of practical value. However, the implementation of a tablet information service requires consideration of the type and amount of information that is to be provided, to whom, and via which medium

FINdINGS FrOm ThE LITErATurE

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or media. Consideration must also be given to the rationale for the provision of specific types of information to specific target audiences. For instance, information provided to users may differ in format, content, focus and degree of scientific sophistication from that provided to drug support services, researchers and policy makers. A tablet information service should also collect data from a wide range of sources if it is to offer comprehensive and timely information. It should draw on disparate sources such as users, workers in the field, police, the judicial system, and clinical data from hospitals, clinics and laboratories.

The implementation of an illicit tablet information service should identify all potential end users of the service and consider their specific needs. A tablet information service could thus be targeted at the needs of emergency services, law enforcement agencies and other key stakeholders in the drug and alcohol sector. Education and prevention information targeted at users and potential users may also be one of the objectives of a tablet information service.

There are essentially three types of information that a tablet information service might collect and disseminate. These are:

n Information relevant to the identification of substances. n Information relating to the use of specific illicit substances.

n Information on the health and other consequences of using specific illicit substances.5

Identification information should include details of the physical appearance of illicit substances, in this instance tablets, their street names and their chemical properties. Details such as shape, colour, weight, logos and other distinguishing characteristics should be provided. Information designed to assist with drug identification may also include details of substitute substances that are being marketed under common names, such as the range of chemical compounds that are passed off as ecstasy. Information relating to the use of illicit substances in tablet form should also profile the identified user group, the settings in which the drugs are likely to be used, and details of the range of observed effects on behaviour, mental processing and social functioning.

A key issue for such an information system is the purity of the chemical substances found in illicit tablets, and the attendant issue of the substitution of one chemical compound for another, creating a situation in which users have no means of knowing precisely which drug they are ingesting. For instance, deaths associated with the substitution of paramethoxyamphetamine (PMA), a powerful stimulant, for MDMA or “real” ecstasy, have been reported in Australia, Europe, the UK and the US.6

Drugs commonly substituted for ecstasy include PCP, DOB, ketamine, speed, cocaine, atropine, 4-MTA and a wide range of prescription and over-the-counter medications. The first three of these, in contrast to ecstasy’s mild empathy and mood-elevating effects, can impair motor control and produce intense hallucinations. Many of the fake or adulterated substances presented as ecstasy can thus be far more dangerous and have severe and unanticipated psychological consequences for users.7_{For this reason,}

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Where possible, the known health risks and other consequences associated with substance use should be detailed, although data on long-term effects will of necessity not be available for new illicit substances as they appear on the market. Tablet information services could also provide details to emergency service workers, police and users of potential risks such as seizures, drug induced psychosis or death associated with specific tablets or with substances which may be substituted for the expected content of those tablets.

A more comprehensive model for describing new drugs as they emerge onto the drug market is provided by the formal risk assessment reports produced in Europe in response to newly identified synthetic drugs. These reports include the chemical analysis and description of the substance, including details of precursor chemicals and manufacturing processes; descriptions of the format and appearance of the substance; discussion of individual health risks including the acute, clinical and psychological effects and the potential for dependency; an analysis of the public health risks such as the availability and quality of the substance, user knowledge and perceptions of the substance, patterns and prevalence of use, the characteristics and behaviours of users, indicators of health consequences and context of use; discussion of the social risks including sociological aspects, social consequences, consequences for the social behaviour of users, other social consequences and criminological aspects; and a review of the legal consequences of prohibition, including a discussion of the substance’s current legal status and the possible consequences of prohibition. The reports end with conclusions and recommendations.8

Whilst this reporting model may be too comprehensive for a tablet information service to implement, elements of it could nevertheless be employed to inform the development of such a service.

2.3 Web-based Drug Information

Numerous websites provide information about illicit and other dugs with a sample of sites reviewed below. These have been selected to provide a broadly representative cross-section of the different types of websites that present such information. It should be noted that the statements contained in the description of the various sites are largely those expressed on the sites themselves, rather than those of the research team, except where otherwise identified.

For ease of presentation, the sites have been grouped into the following categories (note that some sites could be included in more than one category, but for ease of presentation, have been listed only once)

n Drug monitoring systems, which contain information about drug use and associated trends in

different countries.

n Early warning systems that detect and identify new substances as soon as they come onto the

drug market.

n Tablet monitoring systems that provide specific information about different tablets and other

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2.4 Drug Monitoring Systems in New Zealand and Australia

New Zealand

Arrestee Drug Abuse Monitoring (NZ-ADAM)

NZ-ADAM is a project which seeks to measure drug use among those people who have been detained in police cells. NZ-ADAM is the equivalent of Australia’s DUMA study – see below. Data from NZ-ADAM are used to examine issues such as the relationship between drugs and crime, to monitor patterns of drug use over time, and help assess the need for drug treatment amongst the offender population.

NZ-ADAM’s quarterly and annual reports provide details of the characteristics of detainees at each site, including self-reported drug use. In addition to tracking changes in local drug markets, NZ-ADAM collects information on key strategic issues.

Illicit Drug Monitoring System (IDMS)

A recent initiative of the New Zealand government is IDMS, a research program carried out annually to better understand trends in illicit drug use and associated harms. IDMS is modelled on similar types of drug surveillance and monitoring systems that operate overseas, which offer early warning of shifts in the markets for different drugs. IDMS results are built up from interviews with people who regularly use illicit drugs, as well as individuals with particular expertise or insight into drug related trends. The results of these interviews are compared with other indicators of drug use, such as seizure patterns, hospital data and information from drug treatment services. IDMS consists of three modules based on the type of frequent illicit drug user interviewed: (i) the Methamphetamine Module, which interviews frequent methamphetamine users; (ii) the Hallucinogen Module, which interviews frequent ecstasy (MDMA) and LSD users; and (iii) the Cannabis Module, which interviews frequent cannabis users. Each module of the IDMS draws on three types of data: interviews with frequent drug users; interviews with key experts who have regular contact with drug users through their work; and the collation and examination of secondary data sources on drug trends. The combined information from these three sources is used to identify emerging trends in drug use and drug related harm.9

Australia

Illicit tablet monitoring and/or information are currently provided in Australia by a range of research and government organisations. Government-funded information resources currently available on illicit drugs include the:

n Ecstasy and Related Drugs Reporting System (EDRS). n Illicit Drug Data Report (IDDR).

n National Illicit Drug Indicators Project (NIDIP). n Drug Use Monitoring in Australia (DUMA).

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Much of the information provided by these programs is sourced via annual data collection activities. Brief reviews of each of the programs are provided below.

Ecstasy and Related Drugs Reporting System (EDRS)

EDRS is a national study funded by the Australian Government Department of Health and Ageing and coordinated by the National Drug and Alcohol Research Centre to monitor the ecstasy and related drugs (ERDs) markets in Australia. ERDs cover a range of drugs including ecstasy, methamphetamine, cocaine, GHB and ketamine.

EDRS employs a methodology similar to that used by the Illicit Drug Reporting System . Regular ecstasy users are interviewed on patterns of ERDs use, the current availability, price and purity of ERDs and perceived drug-related health issues associated with ERDs use. A semi-structured survey of experts in the field (e.g. party promoters, treatment providers, law enforcement personnel) is also conducted and indicator data, such as purity of drug seizures and overdose rates, are analysed. Data from these sources are examined together to identify convergent trends in the use of ERDs and in drug markets.10

The Illicit Drug Data Report (IDDR)

The IDDR, produced annually by the Australian Crime Commission, delivers information on law enforcement activity for the previous financial year. Specifically, the report provides statistics about drug arrests, seizures and detection by Australia’s law enforcement agencies.11_{The data contained in}

the reports provide law enforcement, decision-makers, National Illicit Drug Strategy stakeholders and research bodies with a national overview of the illicit drug situation in Australia.12_{The reports}

are potentially of relevance to tablet information and monitoring by providing trend data with respect to the amounts of illicit substances detected by law enforcement agencies across the country and by providing profiles of the state and territory drug markets. However, currency may be a limitation of this information source as the reports are not released until some time after the data collection period.

National Illicit Drug Indicators Project (NIDIP)

The purpose of NIDIP is to improve the understanding of, and systematically track changes in, heroin and psychostimulant use and related harms using comprehensive, timely and reliable information. The project disseminates information on heroin and psychostimulant use and related harms and informs agencies and policymakers in assessing the need for, and outcomes of, policy and other interventions.

Data indicators are collected across five broad themes: prevalence of drug use, drug-related morbidity, treatment, mortality and crime. Information from NIDIP is made available via several modalities including regular bulletins, journal articles and web-based bulletins and links, thus providing an accessible picture of trends in drug use and harms over time.

A number of issues have been identified in the collection and presentation of data in the NIDIP, including lack of geographic specificity, lack of national datasets for some types of data, and time

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lags in reporting some types of data. To circumvent these problems, jurisdictional data have been recommended for monitoring.13

Drug Use Monitoring in Australia (DUMA)

DUMA is a project which seeks to measure drug use among people who have been recently apprehended by police. Data from DUMA are used to examine issues such as the relationship between drugs, property and violent crime, to monitor patterns of drug use over time, and to help assess the need for drug treatment amongst the offender population. Data collected through DUMA sites provide a research and evaluation tool for local analysts, policymakers and practitioners.14_{DUMA’s Annual Reports include an overview of the characteristics of detainees}

at each site, including self-reported drug use.15_{Whilst the DUMA reports focus on a specific}

population, they may provide a source of information for the proposed ITIMS.

2.5 Early Warning Systems

Early warning systems are employed to detect and identify new substances as soon as they come onto the drug market, by collecting, exchanging, centralising and validating information obtained from a range of sources.16_{Their main objective is to prevent the spread of negative consequences,}

through rapid responses and preventative action with respect to new drug threats. Thus early warning systems are considered to be a critical component of drug monitoring strategies. This has been recognised by the European Union, which has undertaken considerable work in developing and implementing an Early Information Function (EIF) for Emerging Drug Phenomena (EDP). The central function of this multi-jurisdictional project is to develop systems that can quickly identify, assess and categorise EDPs in order to facilitate the production of relevant information and its rapid dissemination to target audiences, including consumers, policy makers and workers in the field.17

Early Information Function (EIF) for Emerging Drug Phenomena (EDP)

The European early warning system operates under a five-step operational model that was developed to structure the data collection, analysis and reporting processes. It comprises data collection, identification of EDPs, assessment of their likely impact, dissemination of information and follow-up/feedback obtained from those involved in the data collection. In addition, a three-tier information structure focusing on users, substances and settings underpins the data collection and describes the key areas of inquiry.18

The EIF collects data from drug users, low-threshold facilities, health services, criminal justice settings, recreational night-life and other settings via a range of methods including observation, questionnaires, interviews, focus groups and population surveys.19_{This comprehensive approach}

to data collection facilitates the acquisition of information that can be cross-referenced against a number of sources to confirm its validity and reliability. The EIF incorporates a standardised assessment process, during which an identified EDP is assessed in terms of its diffusion potential,

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health, social and economic consequences. The assessment provides information regarding the prevalence of the EDP and the range and magnitude of potential consequences. Decisions can thus be made regarding the immediacy and seriousness of the EDP and policy responses formulated on the basis of evidence. The process of disseminating the results considers the purpose of the dissemination strategy, the appropriate audience(s) and the dissemination media, with the overall aim of early intervention to reduce the impact of the potentially harmful EDP.20

The Drug Abuse Early Warning Network (DAWN)

DAWN is a public health surveillance system that operates in a number of cities across the US. Collecting data via hundreds of hospitals, it monitors drug-related visits to emergency departments and drug-related deaths investigated by medical examiners and coroners. The range of drug-related data collected is comprehensive, including the use of illegal drugs, prescription and over-the-counter medications, dietary supplements, non-pharmaceutical inhalants, and alcohol alone and in combination with other drugs. DAWN’s purpose is to measure drug-related morbidity and mortality and to monitor patterns of drug-related hospital cases, identify sentinel events, and increase drug awareness in hospitals.21

The Illicit Drug Reporting System (IDRS)

IDRS is Australia’s main national illicit drug monitoring system and acts as an early warning system for emerging trends in illicit drug markets. It is funded by the Australian Government Department of Health and Ageing and the National Drug Law Enforcement Research Fund. IDRS data collection is conducted each year in every state and territory by participating research institutions, and is coordinated by the National Drug and Alcohol Research Centre. The IDRS monitors the price, purity, availability and patterns of use associated with the main illicit drugs. The IDRS triangulates data obtained from three sources:

n A quantitative survey of injecting drug users, who act as a sentinel group for the detection of

emerging trends in illicit drug use.

n A qualitative survey of key experts who work in the field of illicit drugs.

n A synthesis of extant indicator data sources, such as Customs data, seizure purity data, arrest

data and so on.22

2.6 Tablet Information Services

A wide range of tablet information is available via the internet. Whilst many tablet information websites are government-funded, others are provided by users or other stakeholder groups relying on volunteers, donations or other non-government sources of income such as the proceeds from the sale of drug testing kits. Many of these websites allow community members to use forums to share (“post”) information detailing their experiences with illicit drugs. Information presented includes the content of the drug (this can be identified through drug testing kits), regions where

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illicit drugs are being sold, and the “positive” and “negative” effects of drug consumption. Some sites also have access to literature on various illicit drugs, and links to health, treatment and support websites. Most of these sites aim to equip the community with knowledge on illicit drugs, thereby seeking to promote a harm minimisation approach to illicit drug use.

Europe

Bluelight

Bluelight (www.bluelight.ru) is an international internet message board that seeks to educate the public about responsible drug use (with a focus on MDMA) by promoting free discussion. It advocates harm reduction and is funded by private donations and maintained by a team of volunteers. It does not condone or condemn the use of illegal drugs. Bluelight seeks to educate the public about drugs by summarising whatever information is known about a subject, and to deliver accurate information in a readily understood manner that emphasises safety. There is also an aim to eliminate misinformation, whether it exaggerates or understates the danger, and the organisers suggest that if facts are unavailable, honest anecdotal stories can provide useful information.23

Bluelight’s goal is to find the middle ground between the fairly inaccessible published literature and the misinformation that often exists in street level drug culture. It claims that the consumption of new or exotic recreational drugs can start years before any scientific/medical studies can be attempted. Bluelight contains a mixture of facts and anecdotal information, and suggests a certain level of scepticism be adopted when viewing the answers and opinions of others. The website also links to www.pillreport.com which provides reports by individuals on their experience of different tablets, both positive and negative, including a physical description of the tablet.

The United States

Tablet information and monitoring services in the United States are numerous and even a limited web search identifies many relevant web portals. A number of relevant sites are reviewed below.

The Partnership for a Drug Free America

The Partnership for a Drug Free America (www.drugfree.org) is a non-profit coalition of communication, health, medical and educational professionals working to reduce illicit drug use and help people live healthy, drug-free lives.24_{The Partnership’s website offers a broad range of}

resources targeted at parents and teenagers, that includes information on many common drugs, users’ stories, memorials to individuals who have died as a result of drug abuse and video clips of ex-users describing their experiences with a range of licit and illicit substances.25_{The website includes}

a “Drugs Guide” page with information about a range of drugs.

DanceSafe

DanceSafe (www.dancesafe.org) is a non-profit harm reduction organisation promoting health and safety within the North American rave and nightclub community, with local chapters in the USA and Canada. A coalition of independent, youth-based harm reduction organisations, it is supported

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entirely through donations from individuals.26_{Volunteers are trained to be health educators and}

drug abuse prevention counselors within their own communities, utilising the principles and methods of harm reduction and popular education.27

DanceSafe has three tablet testing programs: a laboratory analysis program, an on-site tablet testing program at raves and dance clubs, and a testing kit distribution program.

The Laboratory Pill Analysis Program monitors the US ecstasy market and provides general public information on the contents of ecstasy tablets. This seeks to help ecstasy users avoid ingesting tablets that contain more dangerous substances, and to educate researchers, health care professionals, treatment providers and policy makers on the variety of drugs people are being exposed to, who are taking what they think is MDMA.

n The laboratory is licensed by the Drug Enforcement Administration (DEA) to handle

anonymously-sent controlled substances. It provides this service for a fee of $US100 per analysis and performs qualitative testing only. The United States DEA currently forbids quantitative anonymous testing. The laboratory is only allowed to identify the ingredients in tablets, but not their concentrations. Tablets with more than one active ingredient have their ingredients listed in order of relative amount, with the dominant ingredient listed first. All tests are performed using gas chromatography (GCMS). The laboratory is able to identify the presence of MDMA, MDA, MDE, MBDB, MDOH, PCP, amphetamine, methamphetamine, ketamine, 2-CB, DOB, 4-MTA, caffeine, ephedrine, dextromethorphan (DXM) and many other known drugs.

n On-site tablet testing is offered to ecstasy users at raves, nightclubs and other public events

where ecstasy is used socially. Users who are unsure of the authenticity of a tablet they possess can bring it to a booth where trained harm reduction volunteers will test it for using a reliable, liquid reagent. All DanceSafe volunteers are trained to follow strict harm reduction protocols for responsible tablet testing. These protocols have become international standards and are used in a number of other countries.

n The drug testing kit distribution service offers five different kits, ranging in price from $US25 to

$50 for use in self-testing of tablets.

In the reviewers’ opinion, this website provides one of the most comprehensive information sources found, and includes a section on how they have set up tablet-testing programs and how to replicate their approach.

Erowid

Erowid (www.erowid.org) is a member-supported organisation providing access to reliable, non-judgmental information about psychoactive chemicals and plants and related issues. It works with academic, medical and experiential experts to develop and publish new resources, as well as to improve and increase access to already existing resources. The organisation claims to strive to ensure that these resources are maintained and preserved as an historical record for the future. Erowid.org

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is an online library of information about psychoactive plants, chemicals, and related topics. The site is a cross between a library and a journal, archiving older historical documents and information as well as publishing new articles. The Erowid website contains more than 30,000 documents related to psychoactive substances including images, research summaries and abstracts, media articles, experience reports, information on chemistry, dosage, effects, health and drug testing.28

Australia

A number of government and non-government websites in Australia provide drug information services. Some of these are reviewed below.

National Illicit Tablet Database (NITD)

In Australia, the National Illicit Tablet Database (NITD) contains standardised information about the size, colour, and shape of tablets seized by police. The database is maintained by the Victoria Forensic Science Centre and contains high quality photographs of these tablets. The database is a source of information for law enforcement agencies, forensic scientists, and other key agencies throughout Australia. The database is accessible only by authorised personnel via the National Institute of Forensic Science website. The database does not currently contain information about the content of the tablets seized by police.29

The Australian Drug Foundation

The Australian Drug Foundation (ADF) is a non-government, not for profit organisation, and was established in 1959 as the Alcoholism Foundation of Victoria. The core purposes of the ADF are to prevent drug problems and reduce drug-related harms, and to help people remain safe if, when and while they use drugs. ADF has a specific website called the DrugInfo Clearinghouse (www. druginfo.adf.org.au) which provides easy access to information about alcohol and other drugs, and drug prevention. Professionals and members of the general community can use the service as their first port of call for information from local, national and international sources.

DrugInfo Clearinghouse offers a range of services, including free information products, a special library, a telephone and email information service, a website, and email alert services for people interested in drug prevention. Anyone with an interest in drug and alcohol issues can browse the library. Library membership is free to Victorians who work in the health, education, welfare, community, youth, justice and related sectors, and to postgraduate students.

ADF’s drug prevention resources are updated regularly and sent out to DrugInfo Clearinghouse members free of charge. Every three months a range of new resources is published, focusing on a particular drug prevention strategy or issue.

In the reviewers’ opinion, this website appears to have the potential to act as a suitable site for an ITIMS, and is consistent with the general philosophy, format and content of an ITIMS. Further discussions would need to be held with the ADF to ascertain their interest in this concept.

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The National Drugs Campaign

As part of the National Drugs Campaign, the Department of Health and Ageing operates a comprehensive website titled “Information about drugs” (see http://www.drugs.health.gov.au/ internet/drugs/publishing.nsf/

Content/Information-about-drugs) and “Where’s Your Head At”, a youth-oriented website that provides information on a range of drugs. (see http://www.drugs.health.gov.au/internet/drugs/ publishing.nsf/Content/youth-home).

Enlighten

The Enlighten website (www.enlighten.org.au) is operated by Enlighten Harm Reduction, a non-profit volunteer organisation based in Melbourne. The stated aim of the organisation is “to promote harm reduction, specifically techniques concerning the drug MDMA or ‘ecstasy’”.30_{A central part of their}

strategy is the promotion of tablet testing, using both chemical reagents and portable laboratory systems. The site also provides a link to another site (www.pillreports.com), a global database of “Ecstasy” tablets based on both subjective user reports and scientific analysis.

Ravesafe

The Ravesafe website (www.ravesafeqld.com) provides “information and support to promote health, safety and enjoyment for punters at music events, raves, parties and nightclubs”.31_{It offers information}

on a range of illicit drugs, including amphetamines, ecstasy (MDMA), GHB (gamma-hydroxybutyrate), ketamine, LSD (d-lysergic acid diethylamide), nitrites and PMA (para-methoxyamphetamine). The site offers detailed descriptions of each substance, including appearance and physical properties, street names, how they are used and their effects, known adulterations and substitutions employed by manufacturers, and the negative consequences of use.32

Comment

Some websites that provide photographs (though generally of poor quality) and information about ecstasy tablets include tablets that were tested up to two years previously and may therefore be out of date. Perhaps the major drawback of this approach is that it does not facilitate contact between ecstasy users and health and welfare professionals, which would encourage more broad-based harm reduction behaviours.

Some of these sites are potentials for an ITIMS, however some of them have not been updated for some time and therefore would not fit with the expectations of a current content information source. With the exception of the NITD, the sites are easy to access and can be found easily, and with their existing profile could act as a suitable host for an ITIMS.

On the other hand, databases such as the NITD are similar to the model adopted in the Netherlands. In that country, the results from laboratory testing are placed into a pictorial ‘determination table’. The table consists of tablets that have been tested in the past eight weeks. Tablets with identical characteristics need to be tested three times before they are described as coming from the same

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batch. The determination table is available to workers who interact with ecstasy users, but not to the public. This methodology ensures that illicit drug producers cannot produce counterfeit tablets that have the same appearance as tablets determined by the tablet testing process to be low risk.

2.7 Tablet Testing

Underpinning the currency of the information contained in any tablet information system is the source of that information and the capacity to collect, test and present the required data in a timely manner. In this context, the testing methods used and the sources of the tablets tested become particularly important.

Tablet testing programs typically bring together multidisciplinary teams of experts that may include chemists, social workers, youth workers and psychologists. Testing can allow researchers to detect, track and monitor emerging drug trends and changing patterns of drug supply and consumption and can provide demographic information about drug consumers and others involved in the drug market.33_{Drug testing can take a number of forms, including laboratory analysis, on-site testing}

conducted at events where drug taking is prevalent, such as raves and dance clubs, and via testing kits supplied to users.

Testing Methods

Tablet identification, colour reaction tests (e.g. the Marquis test), liquid or gas chromatography, mass-spectroscopy, immunological tests and capillary electrophoresis are common methods employed in determining the chemical content of illicit substances. Different testing methods can require from 5% of the tablet to the whole tablet to be subjected to testing, making some testing methods more suitable than others, depending on the circumstances under which testing is conducted. A brief description of each testing method is provided below:34

n Tablet identification involves a visual comparison of tablets presented for testing with details

of formerly analysed tablets, such as size, shape, colour logos or other physical markers. Tablet identification is fast and cheap but offers poor reliability.

n Colour reaction tests (e.g. the Marquis test) can identify the presence of ecstasy and

ecstasy-like substances (MDMA, MDA, MDE) but cannot determine how much of the identified substance is present in the tablet. These tests can also identify the presence of some non-ecstasy substances and the absence of non-ecstasy but are not capable of detecting a number of potentially dangerous chemicals that may be substituted for ecstasy.

n Chromatography involves the separation of a drug compound into its separate chemical

components, thus permitting the identification of individual substances in complex chemical mixtures. It is a relatively fast technique, taking as little as fifteen minutes, possesses high-level reliability and produces quantitative and qualitative results that can be used immediately in on-site testing locations.

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n Mass spectrometry involves the conversion of a drug or drug metabolite into charged particles

and the mass-to-charge ratios of the particles generated create a pattern that provides a positive identification of the drug.

n Immunological tests are based on the reaction of a specific antibody to a substance.

Commercially available immunotest systems for urine drug tests are commonly employed in Europe for this form of testing. Immunology cannot be used directly for tablet testing but is used to identify substances consumed after the fact.

n Capillary electrophoresis describes a family of techniques that can be employed to separate a

variety of compounds. These analyses, all driven by an electric field, are performed in narrow tubes and can result in the rapid separation of many hundreds of different chemicals.

Of the various tests available, chromatography is widely regarded as being the most effective and appropriate method to this application.

On-Site Tablet Testing

On-site testing is typically conducted at venues where drugs are in circulation. These include festivals, dance clubs, car parks outside discotheques and rave parties, although testing is generally confined to “legal” rave parties where this distinction is made. Trained testers generally take small samples of the tablets presented for testing and apply a reagent capable of confirming the presence of the supposed drug, such as ecstasy. The reagent does not respond to other substances which may have been substituted. Testing is often conducted with the support of local law enforcement agencies who recognise the value of harm minimisation and who provide an amnesty for users who have their tablets tested. This type of response from police is comparable to the manner in which needle exchange programs, treatment facilities, hospital emergency departments and other drug use response facilities are dealt with.35

A number of legal and ethical issues are associated with testing tablets in public venues. A critical issue concerns what users should be told after testing. It is important that no information that could be construed as encouraging the consumption of illicit substances or that implies even the relative “safety” of any detected substances be made. Responsible harm reduction strategies reinforce the message that the ingestion of any illicit substance constitutes a health risk and that death or serious injury may result. It is also important from a legal perspective that the anonymity of those who present drugs for testing be maintained.36

The costs of tablet testing may be high. Recent (2004) cost data published in the US indicate that laboratory testing costs $US110 per tablet, not including any costs associated with the collection of samples at venues, project management, data entry or the dissemination of results to local communities.37_{Effective and reliable tablet testing also requires investment in high quality}

analytical tools that can easily be transported to testing and intervention sites.38_{In some cases, such}

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whilst other tablet testing organisations charge consumers a co-payment, such as the $120 per test charged by the US EcstasyData.org. This fee was previously $30, but the website reports that the “EcstasyData testing project has run out of money. The project has been temporarily discontinued while we seek additional funding. No new tablets are being accepted for testing (unless the entire lab fee of $120/tablet is covered by the submitter.” 40

Dissemination of Test Results

Policies regarding the dissemination of test results vary. Some testing services provide the results only to the individual consumers who have requested the test; some post all test results on notice boards at the testing venue and/or on an internet website; some release specific details of identified dangerous tablets only at the testing venue; and others record and report aggregate results only via scientific (prevalence) studies.

A review of tablet testing and information services in Europe identified four types of information policies that are employed. These are useful to consider within the Australian context and are presented below:

n Information is provided only to the individual who presents a tablet for testing (this is relevant

only to tablet testing services).

n Information is provided to potential consumers only in the case of “especially dangerous”

tablets.

n Some information is provided to potential consumers in cases where the “expected” substances

are detected and all information is provided in the case of “especially dangerous” tablets.

n All information is made available to all potential consumers.41

Stationary Tablet testing

Stationary tablet testing is conducted within a laboratory, often located within the offices of drug monitoring services. Consumers may make contact by presenting in person at the service or by submitting tablets for analysis by post. In Europe, services report tablet testing for up to 2,000 clients per month and identifying approximately 10 tablet types in that period. Results are made available to consumers on the same day or with a waiting period of up to eight days.42

Tablet Testing in the European Union

Tablet testing is conducted in a number of Western European countries, some since the early 1990s, and in a range of legal contexts. For legal reasons, most services in Europe have in place strict policies stating that testers may not touch or handle the drugs presented for testing at any time, and that all tablets must be returned to consumers after a sample has been taken but prior to any testing being carried out. Some tablet testing services, such as Hamburg’s DROBS, require users to conduct the test themselves, thus completely avoiding the need for staff to touch tablets. Data reported from across Europe suggest that those requesting tablet testing are generally males, who represent