With due respect to the authors Martyn Lloyd Jones and Professor Paul Komesaroff (C/T, Evidence backs need for pill testing trials, Jan 10, p19) I disagree with the statement " It has taken until now for pill testing techniques to be developed to a level where they can identify the constituents in analysed samples with sufficient precision, reliability and speed".

As long ago as October 9, 2017 in this paper ( 'Oversold' pill testing not a magic bullet : toxicologist, p 2) senior toxicologist Dr Andrew Leibie of Safework Laboratories told us that infrared spectroscopy equipment will tell you nothing about the dose – a key consideration in determining toxicity and that with backyard/uncontrolled pill or tablet manufacture it is not at all uncommon to find more than 90% of the total drug in any given pill in less than half of the volume, i.e. the active ingredient distribution is highly variable. So, the only way to determine the exact contents of any pill to save young lives is to test its entire mass. This would mean crushing and grinding a pill to powder form in your instrument.

The unreliability of pill testing equipment is further underlined in the Canberra Times letter 'Deadly concept' of Jan 8 2019 where the pill testing advocate Gino Vumbaca of Pill Testing Australia is reported inter alia as saying "The testing capabilities are so  limited that revellers would be required to sign a death waiver, which includes a warning that tests cannot accurately determine drug purity levels or give any indication of safety".

Recently, Dr Leibie deepened the unreliability of infra-red pill testing technology saying that new designer drugs known as 'bath salts' were comparatively harder to trace and "They're much more dangerous, they're much more toxic than our more traditional drugs like ecstasy, and they're very cheap." (Daily Telegraph, Shining a light on limits of pill tests, Jan 11, p3). The stage has been reached where pill testing and music festivals are in a life and death scenario and the possibility of them being shut down in NSW is under active consideration (Daily Telegraph, Death dance hit list, Jan 15, p 1). ". In my view governments must not approve any more youth festivals until promoters sign a legally binding PILL TESTING EQUIPMENT Drug Watch Internationalng document accepting duty of care responsibilities, and we have gold standard testing equipment certified by the national toxicology body.

Colliss Parrett

Drug Watch International

24/43 Blackall Street

Barton A.C.T. 2600




Gino Vumbaca


Harm Reduction Australia

PO Box 7363


14 January 2019

Dear Gino

As you are no doubt aware, Drug Free Australia has been very concerned about the national pill testing push which has been chiefly led by your organization, Harm Reduction Australia. Our concerns pivot on the fact that MDMA, which is a most sought-after substance at music festivals, has been the substance responsible for many deaths within Australia, moreso than impurities in party pills or other illicit drugs in the pill which are unknown to the user.

We will be asking every politician in Australia to totally reject any further discussion on Harm Reduction Australia’s pill testing push until such time as your organisation has demonstrated from available Australian Coroners’ reports that

  1. it is NOT the substance MDMA, or MDMA in a polydrug use context, which is chiefly responsible for the many Australian deaths


  1. that most of the deaths are alternately from MDMA consumed in amounts beyond what is considered normal for recreational use

We have previously made our view known to Australian politicians, a view which has been backed by strong evidence from the medical literature. We have asserted that MDMA is the sole drug responsible for many of the deaths but has also contributed via combined drug toxicity to many others. We have cited an Australian study of 82 deaths over a five year period (2001-2005)

<https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.ncbi.nlm.nih.gov%2Fpubmed%2F19604654&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=gR3oDEXId72QQxsRsJF0Cz%2FeM0KyxqezrKv1%2BV%2FJEdY%3D&amp;reserved=0> https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.ncbi.nlm.nih.gov%2Fpubmed%2F19604654&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=gR3oDEXId72QQxsRsJF0Cz%2FeM0KyxqezrKv1%2BV%2FJEdY%3D&amp;reserved=0 where MDMA was the sole drug responsible for 23% of the deaths, while taken with other licit and illicit drugs for another 59%, totaling 82% of the 82 deaths. This appears to be the only journal study available on Australian party pill deaths, but from media reports on Coroners’ findings on later festival deaths we have only seen support for this same picture.

We have also alerted Australian politicians to the fact that most MDMA deaths are not overdoses. As Dancesafe, an American harm reduction group has persuasively outlined:

Overdosing means taking a higher than appropriate dose of a medicine or a drug. In other words, it simply means taking too much or taking a “dose” that is “over” the proper therapeutic or recreational amount. The association of the word “overdose” with “drug-related death” is primarily reflective of heroin and opiate-related deaths, where the majority of fatalities may, in fact, result of overdosing. However, MDMA-related deaths are rarely the result of an overdose, and calling them overdoses is dangerous and negligent. It sends the message that “you will be okay as long as you don’t take too much,” which is simply not true. In the vast majority of cases of MDMA-related deaths, where no other drugs were found in the person’s bloodstream, the deceased had taken a dose within the normal range for appropriate therapeutic or recreational use. https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdancesafe.org%2Fmdma-related-deaths-stop-calling-them-overdoses%2F&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=%2Bby1aJh7sRAJS%2Fka5Fiss%2BhMbiRzOVcHpeaS2mZpfT0%3D&amp;reserved=0

The Drug Policy Alliance, with whom we have thought you would likely be ideologically aligned, assert the same https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.drugpolicy.org%2Fsites%2Fdefault%2Ffiles%2FDPA_Fact_Sheet_MDMA.PDF&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=oH5%2BuQCGq7pfei8fTktIcAbAodoC%2BkgnEnw%2FVSsEItU%3D&amp;reserved=0, stating that most deaths are not overdoses. Also on this same issue we point to evidence in the medical literature, such as the British Journal of Anaesthesia https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Facademic.oup.com%2Fbja%2Farticle%2F96%2F6%2F678%2F326917&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=HYe%2FEXRB340nT7091buFiAqCmKOEZRXuXE73gU6HpvI%3D&amp;reserved=0 which records that:

Typically, after oral ingestion (75–150 mg), desired effects begin within 1 h and last 4–6 h.68 Blood levels in asymptomatic users and those with serious side-effects are often similar, suggesting that adverse reactions are likely to relate to the circumstances in which the drug is taken, and that there may also be an idiosyncratic component.28 A number of fatalities have been reported with blood levels of 0.1–2.1 mg litre−1.31 However, a case of a deliberate overdose of MDMA in which the blood level reached 4.3 mg litre−1 with no more than mild sinus tachycardia and a degree of somnolence has been reported.54 Another analytically documented overdose resulted in a plasma MDMA of 7.72 mg litre−1, the highest recorded in a surviving patient, with just a ‘hangover’, tachycardia and hypertension.31 The highest level reported in association with multi-organ failure in a subsequent survivor was 7 mg litre−1.6

Some observations regarding MDMA deaths are that many are from taking a single pill, and can be described as more akin to an idiosyncratic individual allergic reaction to MDMA, making first-time ecstasy use more akin to playing Russian roulette https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fonlinelibrary.wiley.com%2Fdoi%2Fepdf%2F10.1111%2Fj.1365-2044.1993.tb06813.x&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=wmEISM1cflUHxZ4XvkVHIHczOiTIvCQlPgXpYWpQq%2BU%3D&amp;reserved=0. A group of friends can all ingest the same amount but only one might die https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.theguardian.com%2Fsociety%2F2017%2Fjul%2F22%2Ffriends-out-ecstasy-deaths-highest-level-pills&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=hqRWZEMmOnTQZJf5IkRB3q6CaIhlBdRLdmNnXpD5Si0%3D&amp;reserved=0. This was precisely the case with Anna Wood, who took the same amount as her five friends, but only she died. Tony Wood will confirm this on 0404 407 477.

We understand that it may seem somewhat confronting that Drug Free Australia is putting the onus of proof onto Harm Reduction Australia concerning the notion that party pill deaths are not mostly from using MDMA or are alternately from MDMA ‘overdoses’.

However our reasoning is as follows . . .

  1. Harm Reduction Australia asserts that pill testing is needed because impurities or unknown drugs in the pills cause deaths (which is rarely the case in Australia)
  1. Harm Reduction Australia also asserts that pill testing is needed because of unknown MDMA purity in party pills, suggesting that deaths are often from MDMA overdose (which is rarely the case in Australia)
  1. The implicit conclusion from these first two pieces of misinformation is that pure MDMA is safe if ingested in normal recreational quantities (which is against all evidence)
  1. Drug Free Australia further contends that unless HRA clearly and openly publicises that most Australian deaths are tied to MDMA itself, it is responsible for the current spurious sense of security surrounding tested MDMA[GC1] <>   .

Drug Free Australia cannot think of a more sure way to widen demand for a dangerous substance via an entirely false sense of security for festival attendees, which will only cause an accelerated escalation in deaths.

This letter is also to inform you that we are currently alerting every State/Territory/Federal politician in Australia, as well as Australian media players to the contents of this letter, as well as our call for Harm Reduction Australia to put evidence behind your assertions before anything further is politically considered within Australia concerning pill testing.

We would like to see your organisation publish a list of names of all those deceased after taking party pills where the fatal impurity or other illicit drug in the pills was nominated by the Coroner. For those found by the Coroner to have overdosed (Drug Free Australia does at least know of one WA Coroner’s report that nominated overdose in recent years) a list containing the name of the deceased and the report’s estimate of the amount of MDMA ingested.

I might just mention that Drug Free Australia does recognise, and has previously informed Australian politicians accordingly, that three deaths in Melbourne in January 2017 from party pills were due to the drugs 4-FA and 25C-NBOMe being found in purported ecstasy pills, but that these drugs would not be identified by current pill testing equipment. https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.vice.com%2Fen_au%2Farticle%2F3dp5pk%2Fleaked-police-memo-reveals-what-was-in-melbournes-deadly-batch-of-mdma&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=FPAqI78AzR9PEXfZjuZxmDP6A4pLUmnM5jCIfYXwWr8%3D&amp;reserved=0

Drug Free Australia also asserts that most GHB overdoses are by users who know they are taking GHB, as was the case in Melbourne, for example, in February 2017. https://eur02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.abc.net.au%2Fnews%2F2017-02-19%2Felectric-parade-festival-more-than-20-overdose-hospital%2F8283828&amp;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=ALvWSqTBPSu29jz4Q9jNHFtluQ%2BOM8d0coLnwXIpJbQ%3D&amp;reserved=0.

Drug Free Australia invites your response.

Yours faithfully

Major Brian Watters AO

President, Drug Free Australia

Chairman, Prime Minister’s Australian National Council on Drugs (ANCD) 1998-2005 Australia’s representative to the United Nations International Narcotics Control Board (INCB) 2004-2012

Subject: Could medical cannabis be the new THALIDOMIDE?

It has come to Drug Free Australia attention that some contacts overseas are unable to access this data on the Drug Free Australian link.  It is very important that this evidence is clearly available for all to read.  Please find additional links.

Could medical cannabis be the new THALIDOMIDE? Fears of a crisis as doctors consider doling marijuana-based medicines out to pregnant mothers despite evidence the drug can damage fetuses.


GUY ADAMS FOR THE DAILY MAIL PUBLISHED: 10:31 AEDT, 24 November 2018 | UPDATED: 12:36 AEDT, 24 November 2018


The British Medical Journal (BMJ) recently published an article arguing that the widespread use of medical cannabis could eventually lead to a public health crisis bearing comparison with the thalidomide disaster.

William McBride: alerted the world to the dangers of thalidomide in fetal development

Ned Stafford

BMJ 2018; 362: k3415 (Published 06 Aug 2018)

...thalidomide during pregnancy.1 He concluded his letter by asking: Have any of your readers seen similar abnormalities in babies delivered of women who have taken this drug during pregnancy?The letter, thought to be the first published suggestion from a doctor of teratogenicity of thalidomide in humans ~~~


Kind Regards

Herschel Baker
International Liaison Director,
Drug Free Australia 

PO Box 379
Seaford, SA 5169

Don't Promote Drug Use.

This email address is being protected from spambots. You need JavaScript enabled to view it.

BRIEF for Australians

Our Vision: To support and educate young people, their families and communities to prevent the damage caused by drugs


Why test pills when it is the ecstasy that kills?

The accelerating number of Australian deaths from ecstasy are, according to the medical literature, mostly NOT from overdosing on MDMA, nor, according to coroners’ reports, are they due to impurities in party pills but rather from individual reactions to MDMA.

While drug legalisation/decriminalisation activists attempt to build the myth that normal amounts of MDMA are not life-threatening, just the opposite is the truth.  According to our own Australian coroners’ reports our ecstasy deaths are mostly not due to unknown impurities but due to MDMA either by itself or in combination with other drugs https://www.ncbi.nlm.nih.gov/pubmed/19604654.  Nor is there a medical literature which supports frequent deaths due to ‘overdosing’ on MDMA.  This fact is even recognised by the Soros-funded drug legalisation organisation, the Drug Policy Alliance https://www.drugpolicy.org/sites/default/files/DPA_Fact_Sheet_MDMA.PDF and other drug legalisation activist organisations overseas https://dancesafe.org/mdma-related-deaths-stop-calling-them-overdoses/.  It begs the question of why Australian activists are seeking to promote a myth that their own overseas allies do not. 

Medical literature http://bja.oxfordjournals.org/content/96/6/678.full (see paragraph before Figure 1) records ecstasy users boasting MDMA blood levels more than 70 times the lowest levels associated with ecstasy deaths, and 4 times higher than the higher levels more typically found in ecstasy deaths.  Even a Four Corners program http://www.abc.net.au/4corners/stories/2016/02/15/4404734.htm which advocated for pill testing told of one user celebrating his 22nd birthday by taking 22 ecstasy tablets.  Many deaths are from taking a single pill, and can be described as more akin to an idiosyncratic individual allergic reaction to MDMA, making first-time ecstasy use more akin to playing Russian roulette https://onlinelibrary.wiley.com/doi/epdf/10.1111/j.1365-2044.1993.tb06813.x.  A group of friends can all ingest the same amount but only one might die https://www.theguardian.com/society/2017/jul/22/friends-out-ecstasy-deaths-highest-level-pills.  This was precisely the case with Anna Wood, who took the same amount as her friends, but only she died.   

Whether a tablet is 5% or 60% MDMA is much less important than what other drugs are being taken with it and what idiosyncratic physiological reaction an individual user will have to it.  Rather than pill testing machines at the doors of RAVE concerts, heart and DNA testing machines might be more relevant, but even then, medicos are not entirely sure of all they should be physiologically testing for.  If pill testing is pursued with government auspice the inevitable result will be more people willing to use the substance on the false assumption that they are now safe.  With an increased population of users there will inevitably be more deaths.

According to the 2016 National Drug Strategy Household Survey of around 25,000 Australians, most Australians (97%) do not approve the regular use of ecstasy. 

Drug Free Australia believes that the link below shows an informed political response to calls for pill testing.


Gary Christian­­­­­


Drug Free Australia

0422 163 141

Also contact: Tony Wood  0404 407 477

Note: Three deaths in Melbourne in January 2017 were due to other drugs 4-FA and 25C-NBOMe in ecstasy pills, but Victorian Police said that normal pill testing would not have helped.  https://www.vice.com/en_au/article/3dp5pk/leaked-police-memo-reveals-what-was-in-melbournes-deadly-batch-of-mdma

Our Vision: To support and educate young people, their families and communities to prevent the damage caused by drugs


Removing Federal Restrictions on Cannabis? Australians Want Less Drugs, Not More

Almost all Australians, according to the 2016 National Drug Strategy Household Survey of 25,000 Australians,  do NOT give approval to the use of the illicit drugs heroin (99%), cocaine (98%), speed/ice (99%), ecstasy (97%) and cannabis (86%).[i]  It is safe to conclude from these statistics that Australians do not want increasing drug use, but less drug use.

Cannabis legalisation in the United States has increased drug use as well as social harms. 

Colorado and Washington legalised cannabis in 2013.  Comparing the two year average 2013/14[ii] with the pre-legalisation 2011/12, Colorado’s cannabis use was as follows:

Adult use increased by 63% in the first year after legalisation against increases of 21% nationally.  In 2013/14 Colorado adults ranked #1 for cannabis use in the United States, up from #7 in 2011/12 and from #8 in 2005/6.

College-age use (ages 8-25) rose by 17% against increases of 2% nationally, within the first year of legalised cannabis use. In 2013/14 Colorado college-age students ranked #1 for cannabis use in the United States, up from #3 in 2011/12 and from #8 in 2005/6.

Adolescent use rose by 20% against decreases in other states of 4%, despite use of cannabis being illegal for all under the age of 21.  In 2013/14 Colorado youth ranked #1 for cannabis use in the United States, up from #4 in 2011/12 and from #14 in 2005/6. In school year 2015/2016, 62 percent of all drug expulsions and suspensions were for marijuana violations.

Other social harms were:

Road fatalities related to cannabis use rose by 62% by 2015, from 71 to 115 persons since 2013 when recreational cannabis use was legalised.[iii]

Hospitalisations likely related to cannabis increased 32% in the two year average (2013-14) since Colorado legalised recreational marijuana compared to the two-year average prior to legalisation (2011-2012).[iv]

Governor Hickenlooper last year introduced House Bill 1220 and 1221 to address the 380% rise in arrests for black market grows between 2014 and 2016.[v],[vi]

Cannabis legalisation has led to more drugs, not less drugs.  Adult cannabis users in a state with medical cannabis laws in 2010 already stood at around 400,000.[vii]  Under legalisation that had increased by an additional 200,000 by 2015.  That is 200,000 more opened to increased risks of psychosis, depression, suicide, drugged driving, altered brain function and death from pulmonary and cardio-vascular conditions.[viii]

Gary Christian


Drug Free Australia


[i] See Table 9.7 https://www.aihw.gov.au/reports/illicit-use-of-drugs/2016-ndshs-detailed/data#page2

[ii] https://www.samhsa.gov/data/sites/default/files/NSDUHsaeShortTermCHG2015/NSDUHsaeShortTermCHG2015.htm  see also “2011-2012 National Survey on Drug Use and Health: Model-Based Prevalence Estimates (50 States and the District of Columbia)” and graphs of stats at https://www.sheriffs.org/sites/default/files/2016%20FINAL%20Legalization%20of%20Marijuana%20in%20Colorado%20The%20Impact.pdf

[iii] https://www.sheriffs.org/sites/default/files/2016%20FINAL%20Legalization%20of%20Marijuana%20in%20Colorado%20The%20Impact.pdf

P 16

[iv] https://www.sheriffs.org/sites/default/files/2016%20FINAL%20Legalization%20of%20Marijuana%20in%20Colorado%20The%20Impact.pdf

P 78

[v] http://gazette.com/collateral-impact-the-unintended-consequences-of-the-legalisation-of-pot/article/1621232

[vi] http://gazette.com/editorial-pass-bills-to-curb-black-market-marijuana-in-colorado/article/1598339

[vii] Calculated from 8.86% of Colorado’s population in 2010 vs 12.45% of its increased population in 2014

[viii] https://drugfree.org.au/images/13Books-FP/pdf/DFA_CannabisPaper.pdf

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