The Context for the APPG’s survey on prescribed drug dependence

by Julia Evans on November 30, 2018

A related text:

I suggest you also read The Psychopharmacology of Everyday Life | by Jamieson Webster | NYR Daily | The New York Review of Books  : Available here

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Content

Introduction

About the APPG

The Survey

Areas of criticism

A critique of the APPG’s position as established in this survey

1)  that ‘clients’ who are also unique human beings, can be divided into labelled groups, ‘those who are dependant on prescription drugs’.

2) that the talking therapies can be labelled as a branch of medical practice

3) that dependence on drugs can be separated from dependence functioning within each unique individual’s structure

4) that a systematic procedure can be drawn up for imposition on each unique individual subject by a Government-authorised practitioner (so registered with BACP, UKCP or BPS) using a body of knowledge which is imposed over and above the practitioner’s experience to support a withdrawal from dependence process.

5) No account is taken of the unholy alliance between the Government (NICE clinical guidance, etc), Medical Practitioners, and drug companies.

6) the research method used – a survey – has inbuilt flaws and is unsafe for building any kind of practice on.

A way forward

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Introduction

The context for the APPG’s survey on drug dependence.

I have been invited to take part in the All Party Parliamentary Group on Prescribed Drug Dependence (http://prescribeddrug.org)’s survey on prescribed drug dependence. I chose not to fill in the survey as it makes many assumptions with which I do not agree. The results of this survey will be made to fit in this false framework.

About the APPG

All-Party Parliamentary groups are informal groups of Members of both Houses with a common interest in particular issues.  The views they express are those of the group and they have not been approved by either the House of Commons or the House of Lords or its committees.  So this APPG has Members[i]from both Houses and includes representative of the BACP (https://www.bacp.co.uk), BPS (https://www.bps.org.uk) and UKCP (https://www.psychotherapy.org.uk) & officers. The National User Survivor Network (NSUN – https://www.nsun.org.uk) has also been invited to join the Group to ensure that the client/service user voice is represented.

APPG’s aims:

The All-Party Parliamentary Group for Prescribed Drug Dependence (APPG for PDD) is a cross-party parliamentary group dedicated to persuading government, government departments and relevant public and medical bodies to reduce the individual and social harms associated with the injudicious and over use of prescribed psychoactive medications (e.g. antidepressants. benzodiazepines, antipsychotics, stimulants and painkillers).

More detail on its mission and aims can be found here (http://prescribeddrug.org )

The group is currently pursuing two main goals:

  • To influence government to provide a dedicated 24 helpline and associated 
services to support people dependent on prescription drugs.
  • To create and deploy guidance materials for talking therapists to support them 
working with issues of prescribed drug dependence

Note : it is to the second of these goals that the project relates & my remarks. I entirely agree with their first aim.

The Survey

The APPG’s Project Briefing Note on ‘Guidance for psychological therapists’ is available here

or here

The survey is available here

& its introduction, downloaded on 24thNovember 2018, is:

Experiences of working with clients taking prescribed psychiatric drugs

About you and the context of your work:

Accredited or registered members of BACP, UKCP and the BPS Divisions of Counselling and Clinical Psychology are invited to complete this short survey about their current experiences of working with clients taking prescribed psychiatric drugs.
Over 7 million adults in England were prescribed an antidepressant last year (16% of the adult population), and the average number of annual prescriptions has doubled since the mid-2000s, as has the average amount of time people spend on antidepressants. Today’s therapist is therefore likely to be operating in an entirely new climate from the one in which they trained, where most of their clients have either taken, are taking, or are withdrawing from psychiatric drugs.
This survey is designed to assess the needs of therapists when working with this growing client group.

 

Areas of criticism

My position on this:

This survey has a number of inbuilt distortions:

1) that ‘clients’ who are also unique human beings, can be divided into labelled groups.

2) that the talking therapies can be labelled as a branch of medical practice

3) that dependence on drugs can be separated from dependence functioning within each unique individual’s structure & that clients being dependent on drugs makes our clinic radically different.

4) that a systematic procedure can be drawn up for imposition on each unique individual subject by a Government-authorised practitioner (so registered with BACP, UKCP or BPS) using a body of knowledge which is imposed over and above the practitioner’s experience to support a withdrawal from dependence process.

5) No account is taken of the unholy alliance between the Government (NICE clinical guidance, etc), Medical Practitioners, and drug companies. Why are these drugs being given in such quantities? The evidence is that the complaint returns when the fog of the drug is removed.

6) the research method used – a survey – has inbuilt flaws and is unsafe for building any kind of practice on.

 

A critique of the APPG’s position as established in this survey

1)  that ‘clients’ who are also unique human beings, can be divided into labelled groups, ‘those who are dependant on prescription drugs’.

From Psychoanalysis and the Post-DSM Crisis : 2014 : Éric Laurent[ii]

about reminding us that everyone is a little ill, offbeat, out of step, and eccentric with respect to any category that seeks to centre the subject. It is this ex – sistence that needs to be highlighted in any discourse.

This is how each subject manages to accommodate the fundamental failing of his “mentality”, in Lacan’s sense.

People speak about illness. At the same time people say that there isn’t any, that there isn’t any mental illness, for example. They are quite right to say so, in the sense that this would be a nosological entity, as one used to say in the past. Mental illness is on no account a given entity. It’s rather the case that mentality has flaws.

So this project asserts that there is a discrete entity ‘those dependant on prescription drugs’ which has its own unique traits separate from those who come up to Government standard well-being and (mental) health (see Health & Professions Order 2001) or have other dependencies, such as coffee or alcohol or chocolate.

This isolates this group as different and probably substandard. This position is the basis for racism, those with a disability, and so on.

Laurent (2014 op.cit.p3)

… that the difficulty psychoanalysis meets when it comes to inspiring stable classifications is not linked to some contingent impotence or harmful bias. Rather, it is consubstantial with its discourse. It is an impossibility that is logically inscribed from the outset. In his low-key manner, he (Allen Francis) says the following of this epistemological problem:

The psychoanalytical model tended to be all-inclusive, but there was one notable exception – there is no real place in it for normal. […] No one is ever completely normal for Freud; everyone is neurotic.[iii]

This is what Lacan radicalised with his “Everybody is mad, i.e. everyone is delusional.[iv]

So the practitioner either works from a position of mastery of knowledge, ministering to subjects who can be classified into groupings of complaint or they work from a position of equality where everybody is mad. This is an ethical decision.

2) that the talking therapies can be labelled as a branch of medical practice

BACP, BPS & UKCP are all defining the talking therapies as a profession. They do it because there is money to be made out of promising to protect ‘wellbeing and (mental) health’ (HPO 2001 op.cit.) They also provide registered and stamped as safe practitioners to the Government-regulated market in the provision of Mental Health treatments (as per NICE clinical guidelines). So in seeking professional status, to be alongside those trained in medicine, they ape the medical paradigm. They claim that symptoms can be bundled up into bundles that the practitioner, being a superior human being, can then play God and decide with which label the subject can be stamped. Are they manic-depressive, depressed, or what? Once the label is in place, it is easy-peasy – you just follow the clinical guidelines and the practitioner will produce a Government-standard human being. (This is usually measured by whether they have a job or draw on benefits.) So the BACP, BPS & UKCP are all committed to making this systematised way of working take precedence and to being seen as the equivalent of ‘scientific’ medicine. It is possible to practice outside this medically-based system and be a member of BACP, BPS or UKCP. However, it is difficult as the medical model is very far from clinical practice in the talking therapies.

P4 of Laurent 2014 op. cit. : Nevertheless, the DSM-IV did not prevent the outbreak of a downwards spiral that has seen an increase in the diagnoses handed out by psychiatrists and GPs, resulting in what he calls an “inflated bubble”: over-diagnosis and over-medication.

P4 of Laurent 2014 op. cit. : … According to Frances (op. cit.), the role of Big Pharma in over-medication and the promotion of the medicalisation of life has been pivotal. To this he adds the weight of the parents’ associations who want to have access to the appropriate services for their children, access which is only granted once a diagnosis has been set, coupled with the role of consumer associations who are always seeking to accumulate more members.

Of course, once you have a stake in being a solid professional body, then it is not just the seeking to accumulate members that is a worry, you can be bought :

P4 of Laurent 2014 : … points the finger at conflicts of interest and collusion between the expert psychiatrists of the DSM and Big Pharma, favouring competitive advantage in academia for some experts who seek to further their domain of interest at the expense of others.

So this is where NICE clinical guidelines and the Government-standard clinical practice in which BACP, UKCP & BPS are enmeshed, leads, to busy GPs on factory performance bonuses, getting rid of patients with prescriptions. To being paid against evaluation criteria as laid down by the Government, so getting the three ‘professional’ organisations to behave uniformly, as the medical profession, and they become targets as they represent a huge market, 70,000+ psychological therapists in the UK.I used to work alongside GPs & Psychiatrists but no longer – they would be acting against what is required of them, if they make a referral to me or many other colleagues who work outside this standardisation.

Before leaving the topic of why the talking therapies should not be considered as an extension of medical practice, may I state I am not against registration. I am registered here. What I am drawing your attention to is this professionalised registration which apes medical practices within the Government’s regulation put in place to (falsely) ‘protect wellbeing & (mental) health’ against those who are called by the Government, charlatans and worse.

 3) that dependence on drugs can be separated from dependence functioning within each unique individual’s structure

This separation is again copying the medical model where you have specialists in eyes, bones, heart and so on. The body of symptoms can be divided.  This cannot be done in psycho-practice as

Laurent 2014 p5 : Nevertheless, beyond laying the blame on Big Pharma, Frances perceives a phenomenon of civilization that constitutes the all-pervasive foundation of this slippery slope and which cannot be solved by a regulating decree from a welfare bureaucracy:

Our world is homogenizing – we have increasingly less tolerance for individual difference or eccentricity and instead tend to medicalize it into illnessFrances p82 op. cit.

Frances observes that this tendency towards the normalisation of behaviours does not mean that we are sicker than we were before, but it remains to be seen why this taste, this choice forced in the direction of medicalisation, would be the only possible way out?

Laurent 2014 p6 : The main emphasis would be placed on those techniques that would ensure “inter-rater reliability”, in other words, the fact of zero possible variation across the description of observed phenomena. The DSM’s “a-theoretical” classification was to prove to be increasingly based on a theory of statistics. Clinical questions per se were soon to be swallowed up by questions that basically belonged to the field of statistical technique.

The logical form chosen by the DSM is that of a formal tree that classifies mental illnesses in keeping with a “botanical” model of genera, species and subspecies, that

was first presented by Linnaeus in his Systema Naturae and later adopted by Darwin.

So to this question, there are 3 fields to consider : a) the inappropriate use of drugs for conditions without confirmed body correlates. b) the comparison of behaviour to a standard of normal-ness and the movement towards everyone being made ‘normal’. c) the belief that prescriptive drug dependence can be treated in isolation as if it is a cataract on the eye or a broken leg.

And the APPG’s statistic that 60% of subjects will be dependent on prescription drugs, is based on a statistical projection. So this is a clinic driven by the medical model’s classification system and statistical projections.

4) that a systematic procedure can be drawn up for imposition on each unique individual subject by a Government-authorised practitioner (so registered with BACP, UKCP or BPS) using a body of knowledge which is imposed over and above the practitioner’s experience to support a withdrawal from dependence process.

There are two assumptions here :

– that a complete body of knowledge exists which can be written down and then learnt &

– that the process used to enforce a withdrawing from drugs can be homogenised, then mandated for each practitioner to use.

Thus registrants with BACP, BPS & UKCP can become sole providers of the mandated techniques to deliver the nation from prescribed drug dependence.

I have drawn out 3 distinct ways of practicing in ‘Psychotherapy is imposed:  Psycho-analysis© works: Psychoanalysis operates’: 15thDecember 2010 : by Julia Evans : See here. I will try to remember to attach this. It is possible to operate effectively as a practitioner from any of the 3 positions & under any of the labels. There will be results from each encounter.

This APPG project assumes, together with BACP, BPS, & UKCP, that all talking therapies are given from the first position. There exists a standardised knowledge which can be imposed in exactly the same manner on each individual subject. Further it assumes that despite the difference in experience of the practitioner, that the standardised treatment will have the same effect whosoever is administering it.

I suggest it is not possible to mandate treatments from a central point. I give you two examples :

– Dr Shipman fulfilled all his CPD requirements and ticked all the boxes for his up-to-date knowledge, and yet he was left to murder over 50 people. Tony Blair invented HPO 2001in order to stop a recurrence. This is an example of ‘Hard cases make bad law’  The phrase means that an extreme case is apoor basis for a general law that would cover a wider range of less extreme cases– not that anyone cares. Everyone proceeds as if HPO 2001 is the fig leaf which will cover criminal acts.

– Also the NHS Consultant Psychiatrist, Zholia Alemi, as reported in the Guardian[v]. It took a newspaper investigation to find out she is unqualified and presumably a charlatan. Or is she? She practised for 22 years and no-one complained. None of the systems for protecting the public against charlatans & Dr Shipman lookalikes worked.

Is it possible to produce even guidelines for treatment of those dependant on prescription drugs? Well, of course, it is possible. Will this sort out the problem – well no! It is applying a sticking plaster over issues of dependency within the individual’s structure & it is assuming responsibility for something the Government, Big Pharma & medical practitioners have created.

 

5) No account is taken of the unholy alliance between the Government (NICE clinical guidance, etc), Medical Practitioners, and drug companies.

Why are these drugs being given in such quantities? The evidence is that the complaint returns when the fog caused by the drug is removed.

Two quotes:

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From Psychoanalysis and the Post-DSM Crisis : 2014 : Éric Laurent. Op. cit.

According to Frances, the role of Big Pharma in over-medication and the promotion of the medicalisation of life has been pivotal. …. Frances sometimes compares the role of Big Pharma to a sort of mechanistic Marxism, which is undoubtedly too direct: “Sixty billion dollars a year will go a long way to sell products and buy politicians”.

….

The overly descriptive character of the clinical categories … are being referred to a continuum with those organic processes that are expected to be objectifiable at some future date, in keeping with the model of dementia processes that will evolve for upwards of fifteen years before finding an observable clinical translation. Instead of categories that can lead to belief in false distinctions, the researchers prefer a model that privileges continuity. The flipside of the “medicalisation of everyday life” process is precisely the recognition that “psychiatric patients are merely people who are a little less ‘normal’ that the rest”.

The extension of the clinic of addictions vouches for this.

So Big Pharma are driving the process of giving pills out like Smarties so each subject becomes Government-standard normal. This project accepts this as established fact and does not attempt to change the behaviour of the medics who sign off the prescriptions, but put registrants of BACP, BPS & UKCP in to sort out those who are not normal enough for the Government.

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Professor Kendall explains that not only are drugs over-prescribed but that they do nothing. When you stop taking them all the original symptoms recur.

Avoid drug treatment for children and young people with moderate ADHD : 15th August 2013 : National Institute for Clinical Excellence (NICE) : see here : Downloaded on 28th November 2018

Professor Tim Kendall, consultant psychiatrist and member of the group that developed NICE’s clinical guideline on ADHD, spoke to BBC Radio 4’s Today programme about the rise in prescriptions.

When asked whether the whether there were any long-term risks among people who take methylphenidate drugs, he said: “In children, without doubt. If you take Ritalin for a year, it’s likely to reduce your growth by about three-quarters of an inch.

“I think there’s also increasing evidence that it precipitates self-harming behaviour in children, and in the long-term we have absolutely no evidence that the use of Ritalin reduces the long-term problems associated with ADHD.”

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Further, the drug companies know that drugs do nothing, within the clinic known as ‘Mental Health’.

From Laurent 2014 op. cit. :Big Pharma has let it be known, in equal doses of threat and reality, that research into the new generation of psychotropic drugs has been suspended, indeed to all intents and purposes abandoned, because they are too costly and too risky to develop, regardless of the hopes that had been pinned on the glutamate chain. See Friedman, R., “A dry pipeline for psychiatric drugs”, in The New York Times, 19 August 2013.

&

From Health: no room for gloom by Clive Cookson and Andrew Jack : Financial Times : 14th  June 2010& Challenges to Government’s principles used to define the care of mental ill-health by Julia Evans on 15th July 2010 or here

 Several of the largest drugmakers have recently decided to curb or cease research in the field, reducing the funding and expertise available to find better treatments ………………..   The withdrawal reflects growing financial pressures on the industry to cut spending on high-risk low-profit areas such as mental health, where there are few new scientific leads in the laboratory and many cheap generic drugs are coming on to the market

Evaluation fails the test….. drugs have weak “endpoints”.  It is not possible to measure success.

From article

In February Andrew Witty, chief executive of GlaxoSmithKline, said his company would stop work on antidepressants, bringing an end to research……. GSK denied that its decision was related to the public criticism, regulatory scrutiny and litigation over suicidal feelings and other alleged side-effects generated by Seroxat in recent years…… Rather, Mr Witty said there were more promising and productive areas of research…, while antidepressants were “among the most expensive, high-risk” drugs to develop, with weak “endpoints” that made it difficult to measure likely success until late in the development process. AstraZeneca took a similar view a few weeks later, winding down its discovery work on depression and other mental disorders as it pared back in-house research spending.

AND mental disorders in human subjects are difficult to identify.

Extract from article

At the heart of the problem is the difficulty in first identifying appropriate patients to take part in clinical trials and then proving that they do better on the new drug candidate than on placebo (dummy pills). “That is the number one reason why we as an industry are moving away from an area that has an incredible burden of disease,” says Frank Yocca, AstraZeneca’s head of discovery for central nervous system drugs. Clinical trials are particularly hard to organise for antidepressants because, for a start, medical definitions of depression and its severity are not as clear-cut as for most other diseases. In addition, reliable “bio markers”, objective measurements of disease progress such as brain scans or blood tests, are unavailable.

Everyone, whether on drug or placebo, seems to get better.  AND surprise, surprise, interaction with another human being supports the cure or is essential to the cure.

Then there is the large – and mysteriously growing – placebo effect, which makes it hard to demonstrate statistically that patients taking the active drug are doing better than those on dummy pills. Psychiatrists have long recognised that patients with depression and other mood disorders are susceptible to the suggestion that they will get better. But it is not clear why placebo power should have increased, as analysis of clinical trials over the past 30 years shows it has.

“It would be like invoking magic to suggest that people are becoming more suggestible,” says John Geddes, professor of psychiatry at Oxford University. “The change is more likely to be an artefact of the way patients are recruited to clinical trials.”

Everyone, whether on drug or placebo, seems to get better – “which is catastrophic if you are trying to discover how effective the drug is”, says Prof Geddes, who chaired the depression and anxiety part of the UK Medical Research Council’s recent mental health research review. “Everyone in the field knows that this happens.” So researchers are discussing ways to reduce the problem – for example, dropping placebo-controlled trials and comparing new drugs with the best existing treatments.

Health: no room for gloom by Clive Cookson and Andrew Jack  Financial Times  14 June 2010

So why are we giving drugs to those in difficulties when we know they do not work?

6) the research method used – a survey – has inbuilt flaws and is unsafe for building any kind of practice on.

In my brief review of this survey, I have found 6 or more postulates which are being tested, for instance, do the original symptoms return when withdrawing from prescribed drug dependence, is there any need for the therapist to be in contact with the medics, Is it necessary for a therapist to have an up-to-date knowledge of the pharmacology involved, is prescribed drug dependence any different from other forms of dependence, is it possible to become an ‘expert’ in withdrawal from prescribed drugs?

There also seems to be no null hypothesis being tested and the medical model, via NICE clinical guidelines, is automatically accepted. So are surveys the best way of finding information on this topic?

– a comment on introducing a methodological evaluation which is false, based in the use of statistics which prove.

Quote from Jean-Claud Maleval[vi][1](see below): Human activities have always been spontaneously evaluated, both by those who do the activities and those who use them. What is new in our time resides in the introduction of a methodical evaluation that claims to incarnate an absolute, which is false. It is important to repeat that evaluation carries with it a pernicious ideology, because it is extremely costly from a material and human point of view, because it disorganises what it claims to optimise, because, contrary to its pretension, it is never totally reliable, because it fetishises the numerical figure, thus giving a simplistic version of the human factor, because it harms the social bond, because it erases the political act on which it is founded. Why is it being advocated in spite of everything? Because it presents the enormous political advantage of covertly insuring that those who accept it adhere to the liberal logic of the market economy.

Quoted from:  Why is the Ideology of Evaluation Pernicious?by Jean-Claude Maleval on 14thApril 2010 : See here

A quote from Professor Philip Green’s letter to the Guardian on the results of a NHS digital survey : 25th November 2018 : See here

Young people are being prescribed dangerous antidepressants

  • The results of the NHS digital survey into the mental health of children and young people (More than a fifth of girls aged 17-19 attempt self-harm or suicide, 23 November) are certainly alarming but it is doubtful they can be accurately presented as the “latest evidence of the growing epidemic of mental ill health in young people”. In five- to 15-year-olds (the only age group covered in all three surveys) there was a slight increase over time in the prevalence of mental disorders, from 9.7% in 1999 to 10.1% in 2004 to 11.2% in 2017; hardly a dramatic rise. The figures relating to emotional disorder and self-harm in 17- to 19-year-olds cannot be said to represent a rise as this age group was not investigated in previous surveys.

Not mentioned in your report is the fact that the study shows other disorder types, especially antisocial behaviour and hyperactivity, have been largely stable since 1999. In addition, the rate of autism spectrum disorder was stable between 2004 and 2017, providing no support for the commonly held view that rates of this disorder are rising. The figures presented in this authoritative study are sufficiently worrying to amply justify calls for more specialist services, but talk of an epidemic is exaggerated.
Professor Philip GrahamLondon

So surveys have to be checked out by other means, or they are conclusions in a vacuum.

A way forward?

From Laurent : 2014 : p. cit.

The extension of the clinic of addictions vouches for this.

First of all, we have to privilege, in the field of psychopathology, the critique of the effects of abandonment produced by these clinical approaches that foreclose the subject. This approach is evident in the project of reviving a perfect classification that would be able to describe the subject exhaustively on the basis of psychopathology. Next, we need to be attentive to the effects of subverting the categories, the drugs, and all the instruments of the clinical field, by means of “off-label uses” (a term of which I am rather fond). More than wanting at any price to propose a new classification based on the subject and to redo a systematically updated clinic of the subject, psychoanalysis has to remain attentive to the subject’s subversion that follows any classification like its shadow, in keeping with the way that the classification is lived. Subjects who come to see psychoanalysts effectively come along, in a certain number of cases, brandishing labels, living with them and finding their bearings in them by using them to organise their experience. On the basis of the subversive uses that the subjects make of the classifications, and the way that each of them live with the labelling they have received, the psychoanalyst will try to discern how this anchors the subject’s history as a whole and gives order to it. Lastly, we have to call subjects back to the singularity of their desire, their fantasy, and their symptom, through the specific power of the psychoanalytic discourse. This is a discourse that underlines the dimension of the subject that lies outside the box, with its fundamental subversion of the categories, and an aspect that necessarily lies wide of the norm. This is where the psychoanalytic project of calling each subject back to the singularity of his delusion, in Lacan’s terms, meets Allen Frances’s project, which at first sight seeks the opposite because it is all about “saving normal”. Contrary to this, we seek to put paid to the different forms of prestige, and radically so. Luckily, what Frances calls “saving normal” is actually about reminding us that everyone is a little ill, offbeat, out of step, and eccentric with respect to any category that seeks to centre the subject. It is this ex- sistence that needs to be highlighted in any discourse.

So this treatment by remote prescribed systems and ‘professional’ practitioners who are stamped by BPC, BACP & UKCP as being safe and being able to produce a predicted result, resemble factory processes. As there is no place for the unique subjectivity of either practitioner or recipient, then alienation or abandonment occurs. This state produces many symptoms such as dependence which is a way for the subject to assert their uniqueness from an objectified position. In this survey, BPC, BACP & UKCP all leap into this field of abandonment and pretend to be professional working scientifically. Rather the treatment should release these subjects from their bondage and encourage them to act from within what they have been given. Individual practitioners within all the talking therapy disciplines, do put this in place but they do not register in the Government’s standard clinic for eliminating conditions known as Mental Health Issues.

 

Julia Evans

Practicing Lacanian Psychoanalyst, Earl’s Court, London

 

Footnotes

[1]See  All-Party Parliamentary Group for Prescribed Drug Dependence

Officers

Chairman: Sir Oliver Letwin MP (Con), Co-chair: Paul Flynn MP (Lab), Co-chair: Norman Lamb MP (LibDem), Co-chair: Luciana Berger MP (Lab), Co-chair: Baroness Masham of Ilton, Co-chair: Earl of Sandwich

Representatives from the British Association for Counselling and Psychotherapy (BACP), the British Psychological Society (BPS) and the UK Council for Psychotherapy (UKCP) – which collectively represent 70,000+ psychological therapists in the UK – have joined APPG representatives in forming a Steering Group committed to creating and deploying such guidance. The National User Survivor Network (NSUN) has also been invited to joined the Steering Group to ensure that the client / service user voice is represented.

[ii]I recommend this text as essential reading to this project. Seehere  for availability & details.

[iii] Frances, A., Saving Normal: An Insider’s Revolt Against Out-of-Control Psychiatric Diagnosis, DSM-5, Big Pharma, and the Medicalization of Ordinary Life, William Morrow, 2013.

[iv]See Transfert à Saint Denis? : Lacan pour Vincennes ! : Il y a quatre discours. : 22nd October 1978 : Jacques Lacan : See here for the exact quote.

[v]From Fake psychiatrist case puts thousands of doctors under scrutiny by Patrick Greenfield, Monday 19th November 2018, The Guardian, here

The records of up to 3,000 doctors are being reviewed after it emerged that a woman worked as a NHS consultant psychiatrist for 22 years with fake qualifications before she was convicted of trying to defraud a patient.

Zholia Alemi, 56, was jailed for five years last month for faking an 87-year-old patient’s will as part of an attempt to inherit her £1.3m estate after they met at a dementia clinic in Workington, Cumbria in 2016.

Following the trial, an investigation by the Cumbrian newspaper News and Star revealed Alemi had been working in the UK for more than two decades with forged qualifications from the University of Auckland.

The convicted fraudster had failed the first year of medical school in New Zealand in 1992, but subsequently managed to register as a doctor with the General Medical Council (GMC) with a forged degree certificate, forged primary medical qualification and a fake letter of recommendation from her most recent job in Pakistan, under a visa scheme that has since been discontinued.

[vi]See Why is the Ideology of Evaluation Pernicious?by Jean-Claude Maleval on 14thApril 2010 : See here. Originally presented on 14th April 2010. Published in Psychoanalytic Notebooks, journal of the London Society of the New Lacanian School, issue 21 2010.

Other texts

Opposing the Counsellors and Psychotherapists (Regulation) and Conversion Therapy Bill by Julia Evans 23rd August 2018 or here

Psychoanalysis and the Post-DSM Crisis : 2014 : Éric Laurent or here

Politics, ethics, regulation and the talking therapies : current positions emerging from Parliamentary debate by Julia Evans on 20th November 2013 or here

Psychotherapy is imposed:  Psycho-analysis© works: Psychoanalysis operates’: 15th December 2010 : by Julia Evans : See here

Challenges to Government’s principles used to define the care of mental ill-health by Julia Evans on 15th July 2010 or here

Why is the Ideology of Evaluation Pernicious? by Jean-Claude Maleval on 14th April 2010 : See here

Use of power here

Ethics here

Definitions of humanness here  & here

Responses to the UK Government action here

UK Government & Government action here

Lacanian Transmission : here

Of the clinic here

Texts on ‘The Symbolic Order in the XXIst Century’ here

Some Lacanian History : here

Topology : here

By Éric Laurent here

By Jean-Claude Maleval here

By Sigmund Freud here

Notes on texts by Sigmund Freud : here

By Jacques Lacan here

Notes on texts by Jacques Lacan here