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)

<;data=02%7C01%7C%7C6b410e4cfe4c45ee6b9508d67ad2c2ad%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636831442965479206&amp;sdata=gR3oDEXId72QQxsRsJF0Cz%2FeM0KyxqezrKv1%2BV%2FJEdY%3D&amp;reserved=0>;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.;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;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;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;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;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.;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.;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

Drug Free Australia Newsletter Signup

Would you like to be informed about the work of Drug Free Australia?

You can join our Mailing List and receive our Newsletter by completing the details below.

Remember, this is an opt-in list.

You will receive an email requesting confirmation. This is to protect you from being added to this list against your wishes.

You can also Un-Subscribe at any time by using the 'unsubscribe' link in the emails you will receive from us.

Please wait