Katherine Pettus and Sunil Kumar Aggarwal

Lead Author: Katherine Pettus
Additional Author: Sunil Kumar Aggarwal
Organization: The author is an independent contractor
Country: USA

Abstract

This proposal focuses on expanding accessibility and affordability of medicines essential to the management of severe pain, mental health, and substance use disorders. It recognises their dual status as traditional medicines, which confers additional rights and protections afforded to country-level and local health systems in which they are utilised. States parties have disregarded these protections under their national drug control systems, contributing to crisis-level shortages and/or unavailability of essential controlled pharmaceutical medicines, especially in low and LMIC countries.

Unavailability undermines the human right to health, as well as the guarantees of respecting traditional and nonconventional medicine compounds and health practices. In support of the proposal, reference is made to the central treaty governing "narcotic" drugs as a schema which has granted the pharmaceutical industry monopolistic patent rights to traditional plants and their derivatives and the inability of this schema to withstand intellectual property rights claims scrutiny under existing global trade agreements which require due respect for "prior use" and traditional medical knowledge claims. Given this, the proposal envisages duly licensable local and sovereign in-country production of opium, cannabis, and relevant traditional medicine plants to address under-and untreated population needs in pain relief, palliative care, substance use disorders, mental health care, and other medical and preventive health services with a combination of modern medical scientific community knowledge and practices with traditional medical knowledge.

Submission

Proposal: To encourage UN member states, especially where consumption of controlled medicines for pain, palliative care, mental health and dependence disorders, is low to inadequate according to the International Narcotics Control Board, to wholly produce, manufacture, and regulate these substances for medical and scientific use in their domestic and regional markets, having due regard for constitutional constraints and limitations as well as traditional medicine practices.

IMPACT ON POLICY COHERENCE: The contribution reduces the incoherence in rules between international human rights and trade law, and public health objectives. It addresses the specific aspects of the right to health, and to controlled medicines for palliation and the treatment of pain, substance use, and mental health disorders. Furthermore, it protects and preserves traditional medicine, respects indigenous rights, and enhances the rights of specific demographic groups, within the framework of the Sustainable Development Goals.

IMPACT ON PUBLIC HEALTH: 
The expected results will allow sovereign states to regulate their own medical and scientific access to biotic substances that the pharmaceutical industry has held under state-backed monopoly since the early 20th century, for the commercial preparation of essential medicines controlled under the schedules of the UN drug conventions. Mandatory import and export licenses required by the conventions and in themselves associated with low consumption of controlled medicines, will be moot and unnecessary if countries grow their own, retrieve, preserve, and utilise traditional knowledge, and develop national pharmaceutical industries under compulsory licensing exceptions. The proposal should incentivise the preservation of rich cultural traditions, allow national pharmaceutical companies to become more involved in the market, and reduce the prices of medicines on the WHO Model list, where these have been distorted by non-market mechanisms introduced by non-rational implementation of drug control conventions.


ADVANCING HUMAN RIGHTS: Increasing rational access to controlled medicines allows countries to fulfil their obligation to provide treatment for substance use and mental health disorders as well as to provide pain relief and palliative care for children, adults, and older persons.[1] Human rights experts have reiterated these obligations, which are laid out in multiple sources, including the cornerstone Declaration of Human Rights and the International Covenant on Economic, Social, and Cultural Rights, General Comment 14, and opinio juris.


IMPLEMENTATION: The political, financial and institutional work needed to bring the contribution to its expected results would be considerable, although the groundwork has been laid at the Commission on Narcotic Drugs, the World Health Organisation, the Human Rights Council, the UNGA, the World Trade Organisation, The International Labor Organisation, global civil society, and in the academic and scientific literature. Supporting educational work and training of health professionals by including palliative care, treatment of pain, mental health disorders, and substance use disorders into health curricula, will advance public health outcomes and support achievement of the Sustainable Development Goals.

I. Relevant Facts:
1. Approximately one billion persons have no access to modern health care,[2] 5.5 billion people live in countries with little or no access to controlled medications.[3] Availability of essential medicines in the Low and LMIC is estimated at 60% of need, and essential controlled medicines at less than 20%, with these figures varying greatly between countries, and within countries and regions.[4] This lack of access to medicines is a primary cause of avoidable suffering and death around the world. It also impinges on productivity and economic growth.
2. The Preamble to the Single Convention on Narcotic Drugs makes clear that its overall aim is to advance the “health and welfare of mankind” and explicitly recognizes that “the medical use of narcotic drugs continues to be indispensable for the relief of pain and suffering and that adequate provision must be made to ensure the availability of narcotic drugs for such purposes…”[5] The operational paragraphs of the Convention itself, however, focus heavily on drug control, do not state that countries have an obligation to ensure the adequate availability of controlled medicines, or offer any guidance on what States must undertake to achieve this goal. For example, the Convention sets out reasonable minimum regulatory requirements for the prescribing of controlled medicines at national levels but explicitly allows Member States to impose stricter rules if they deem that necessary. The Convention does not require that such rules be proportionate and avoid interfering needlessly with the availability of controlled medicines.
3. In the absence of specific operational paragraphs guiding states parties in the rational provision of “narcotic drugs [sic] for medical and scientific purposes” the placement of medicines the WHO has designated as “essential” (i.e., morphine in all preparations) in the schedules of the international drug conventions, amounts to the imposition of a de facto trade rule or patent that impedes rational access to those medicines, including to biotic germplasm starting materials, and creates multiple negative public health externalities, including a health workforce untrained in their appropriate use.
4. The UNGASS preparatory process has revealed that a plurality of states, supported by well established civil society organisations, in addition to the academic and scientific communities, want to explore textual “flexibilities” in conventions, and take a public health, and person-centered, rather than criminal justice approach to the “World Drug Problem.”
5. Traditional medicine must be protected beyond intellectual property aspects. The vast quantities of knowledge and wisdom that have been accumulated by traditional and indigenous populations over millennia should be respected, revived, and preserved for future generations. There must be respect for medicinal plants and the communities which cultivate them.[6]
6. Global ageing of populations and the increasing burden of noncommunicable and communicable diseases on all ages and demographic groups, are increasing pressure on UN member states to provide palliative care services for children, adults, and older persons. Such provision will not be possible, especially in low and middle income member states, without national production of traditional medicinal plants, and the participation and support of pharmaceutical industries in provision of controlled medicines.
7. The international drug control treaties, combined with human rights and trade law, provide an enabling normative and technical matrix to support UN member states who wish to do so, to cultivate and manufacture the plants used to make traditional medicines for pain relief, palliative care, and other “medical and scientific purposes.”

Discussion:
1. States’ obligations under international human rights law to ensure equitable access to safe, effective, quality and affordable essential medicines, is complicated by the fact that few responsible authorities are aware of the enabling provisions of the Single Convention on Narcotic Drugs, and have enforced unduly strict supply control measures in conformity with the ideological climate of the “war on drugs.”
2. Although states parties are obliged to limit their licit use of plants and preparations listed in the schedules of the drug control conventions to “medical and scientific purposes,” authoritative and accessible legal interpretation of this “exception” is entirely absent from opinio juris.
3. Under customary, non-expert interpretations, signatories to the treaties are mandated to ensure that persons (natural or artificial) wishing to cultivate, manufacture, or distribute plants or their preparations “for medical and/or scientific purposes,” must obtain special licenses issued by the competent authorities in member states, including import and export licenses where indicated for commercial purposes. Moreover, the International Narcotics Control Board strictly monitors global production, consumption, and distribution of biotic materials and commercial preparations listed in the schedules of the conventions, particularly the Single Convention on Narcotic Drugs.
4. Although cost is a factor affecting access to both controlled and uncontrolled medications, the often unduly restrictive regulations hindering access to those that are controlled (ostensibly to prevent diversion and abuse),[7] reinforce low demand for such medicines. In small markets,[8] pharmaceutical companies either leave or raise the prices of what are often low profit medications, to cover their costs, if produced at all.

II. Legal support for proposal:
1. The Single Convention allows for traditional use, and all “medical and scientific use.”[9]
A. “The term ‘medical purposes’ does not necessarily have the same meaning at all times and under all circumstances. Its interpretation must depend on the stage [type and development] of medical science in the particular time [and place] in question; and not only modern medicine, sometimes referred to as ‘western medicine,’ but also systems of indigenous medicine such as those which exist in China, India and Pakistan, may be taken into account in this connection.”[10] Also taken into account should be geographic patterns of immigration, globalization, and cultural exchange that have brought elements of traditional medicine systems from their origins to other countries where they are intercalated in local medical usage.
B. The Single Convention allows countries to interpret the treaty according to their own “constitutional, legal and administrative systems” (Art.35). Any party that incorporates the right to health or relevant key elements in its constitution would be entitled to take whatever measures were necessary to ensure that its citizens had adequate access to pain relief and palliative care.
2. Parties to the WHO Constitution recognise the right to traditional medicine[11].
3. Right to [the highest attainable standard of] health is supported, at minimum, by the following:
A. Universal Declaration of Human Rights, 1948, (Art.25);
B. International Covenant on Economic, Social and Cultural Rights,1966, (Art.12), General Comment No. 14 of the Committee of the Economic, Social and Cultural Rights, 2000;
C. Convention on the Rights of Child, 1989,
D. African Charter of Human Rights and the Peoples, 1981,
E. Protocol in the American Covenant on Human Rights dedicated to the economic, social and cultural rights,1988,
F. European Social Charter, 1961, and its additional protocols, etc.
G. Mandates of several intergovernmental agencies entrust stakeholders with the responsibilities of realizing the right to health: WHO, UNFPA, UNDP, AU, EU, OAS (Protocol on Rights of Older Persons)
H. Sustainable Development Goals, Goal 3.
4. Under the right to health, states have the obligation:
A. To arrange sufficient installations, resources, services, and functional programs for public health and health care. Many states are failing to fulfill these obligations. By contrast, nonconventional medicines (NCMs) and practitioners are often, or could easily be, readily available in these states, mostly without state investment, due to the health sector’s ability to source widespread existent local resources. For example, in Ghana and Swaziland there are between 10,000- 25,000 patients per modern medical doctor versus 100-200 patients per traditional practitioner.[12]
B. To make health installations, resources, services, and public health and health care programs accessible to all citizens without discrimination. This right to health obligation implies physical, economic, and cultural dimensions of accessibility. Affordability is often an obstacle to accessible formal health services. Yet NCMs often have low costs.
C. To make health care and public health infrastructure, resources, services, and programs readily acceptable to all users in terms of satisfaction with medical ethics and cultural sensitivity.
D. To adopt appropriate legislative, administrative, budgetary, judicial, promotional and other measures to fully realize the right to health, including an “obligation to refrain from prohibiting or impeding traditional preventive care, healing practices and medicines”[13]. Entitlement of right to health includes access to essential medicines[14].

Discussion:
1. The 1961 ratification of the Single Convention on Narcotic Drugs can be read as a multilateral patent grant by the international community to member states with pharmaceutical industries to cultivate, manufacture and market so-called “narcotic” substances derived from commonwealth plants that grow wild all over the planet.
2. The stakes of this interpretation are political: the received global narrative is that narcotic plants and substances are controlled under international law because addiction is “evil” and narcotic substances are harmful when “abused.” This narrative justifies strict national and international regulatory and law enforcement policies to control “illicit” cultivation, manufacture, distribution, and consumption of plants having narcotic properties and the substances derived therefrom. Health information distributed to the public based on such a narrative, insofar as it would only highlight harms of such plants and substances and not therapeutic benefits, would contravene states’ legal obligations to respect the right to health by not engaging in “deliberate withholding or misrepresentation of information vital to health protection or treatment”[15].
3. By embedding all these measures in a normatively “anti-drug” framework, defining any unsupervised (by INCB) production and use as “illegal” or “illicit,” the Single Convention effectively granted to the pharmaceutical industry as it existed in the mid-twentieth century, exclusive legal rights to the world’s biotic commons for industrial purposes and also usurped many traditional, folk, and commons medical and cultural uses of these biota.
4. Ratification amounted to “patenting” the global biotic commons of narcotic plants because viable pharmaceutical industries only existed in the US, Western Europe, the Soviet Union and the UK at that time.
5. There was, and with the exception of India and Brazil, still is, no viable pharmaceutical industry in the global south. There was also a body of traditional medicine that utilised the now outlawed plants and compounds derived therefrom. The de facto patent imposed by the Single Convention de jure trumped those indigenous and traditional intellectual property rights and seed sovereignties.
6. Their traditional sources of “narcotic” medicine having been outlawed, states parties of the drug conventions without pharmaceutical industries are wholly dependent on external pharmaceutical companies for medicines both controlled and “essential” under international law.
7. The view from the intellectual property lens offers some solutions though: if states parties to the WTO accept the argument that the Single Convention amounts to a patent achieved by means of a multilateral treaty, a global intellectual property rights takeover, they may be persuaded to adopt more pro-active strategies utilising the evolving normative framework of international trade mechanisms. These include the Doha Agreements and compulsory licensing.
8. International narcotics control via law enforcement, because it is a different body of international law, amounts to a form of subsidy and state protectionism for the pharmaceutical companies, who then claim free trade privileges that trump indigenous medicine. Countries should be able to claim, for example, intellectual property rights (IPR) in traditional knowledge of opioids and cannabinoids under GATT, thus helping foster local systems for production of cannabis and opium for medicinal purposes in these countries, specifically by utilising traditional knowledge and integrating into health systems.[16]
9. Retrieving, curating, and respecting traditional medicinal and cultural uses, and supporting subsistence farmers of these crops, will introduce a narrative of respect and healing to counter the pre-21st century monolithic narrative of “evil” and “addiction” described above.

III. Implementation of proposal:
1. Governments whose competent authorities report “low to inadequate consumption of medical opioids”[17] can begin by acknowledging the WHO, INCB, and Human Rights Council reports stating that lack of palliative care and under-treatment of pain is a public health and human rights issue in their countries.[18]
2. Supported by national and international government and civil society experts, planners can conduct system-wide needs assessments detailing human and natural resource gaps, regulatory barriers, and educational deficits needed to implement the plan.
3. Matching available evidence regarding the epidemiology of pain-causing conditions such as cancer, AIDS, trauma, maternal child health, etc., against human resources and capacity, will yield baseline policy planning data, and support the development of necessary implementation collaborations. Conducting such needs assessment can be particularly challenging in countries lacking complete demographic data or comprehensive disease registries.[19]
4. Countries that have performed basic needs assessment and multi-level planning processes with affected communities, civil society, and the academic community, can begin to cultivate cannabis and opium poppies for traditional and modern medical and scientific uses.
5. Development assistance should not be predicated on prior eradication of these crops designated by governments for medical and scientific use.
6. Integrated sustainable development should be the guiding principle for crop producing communities. Such development should promote and protect the livelihoods of small scale farmers and rural workers, and should guarantee access to and control over land and common goods.[20]

Discussion:
1. The goal of sustainable development of state health sectors, for affordability and accessibility, must invariably involve maximal usage of locally sourced and renewable resources at the grounds-level, as it is less costly, less perpetually reliant on wholly external inputs, and fosters local sustainability.
2. Countries reliant on importation or having inadequate domestic production of traditional cannabinoid-based and opioid-based preparations and isolates due to restrictions of the Single Convention framework for these plants, can develop local health sector medical and public health systems in which locally cultivated opium and cannabis is internally and adequately sourced for pain relief, palliative care, and other medical and mental health care purposes.
3. Allowing the utilisation of traditional medicinal knowledge regarding controlled medicines would respect, protect, and fulfill the right to health.
4. Prior knowledge and use claims related to traditional medical knowledge and use of opium and cannabis are strong and well-substantiated, traceable to ancient times in many countries that now experience severe shortages and inaccessibility of medicinal preparations derived from these plants. Much of this ancient and early modern knowledge and use has spread globally with human migration and cultural exchange, and much of it prior to the adoption of the Single Convention treaty’s cannabis and opium patent-granting monopoly scheme. For example, to protect it from international biopiracy, India’s traditional knowledge digital library identifies the useful parts of cannabis as being constitutive of the formulation of “bhang”, therapeutically “known for a 1000 years”. Cited as documentation of “prior art” is the 87th section of vol.II of the Al-Aaanoon-fil-Tibb (“Canon of Medicine”), the 11th century Arabic language book written by Abu Ali Ibn Sina, known to medieval Europe scholars as Avicenna[21]. Such well-documented claims would invalidate, under trade agreements, any 20th/21st century commercial or monopoly patenting rights or claims to these plants and establish their open source and holding in commons, and allow for locally licensable use.
5. Rational and expedient health system development and planning for under-treated and untreated populations involving allocation, provisioning, production, stocking, and use of opium and cannabis-based preparations and isolates in implementation of preventive health, rehabilitative, and medical care programs, including pain and palliative care, mental health care, and disease-modifying therapy, will be greatly assisted by utilisation of local workforces, materials, and sustainable resource inputs and guided by traditional and modern scientific community knowledge and practices.

Bibliography and Refereces

REFERENCES

[1] Resolution WHA67.19: Strengthening of palliative care as a component of comprehensive care throughout the life course.
[2] WHO, “Inequalities are killing people on grand scale, reports WHO’s commission,” WHO Press Release, August 28, 2008.
[3] INCB Supplement 2015, Ensuring Adequate Access for Medical and Scientific Purposes.
[4] Bazargani, Yaser T., et al. "Essential medicines are more available than other medicines around the globe." PloS one 9.2 (2014): e87576; MDG Chapter 8e, “Access to Affordable Essential Medicines”;
Global Atlas of Palliative Care at the End of Life.
[5] Preamble, 1961 Single Convention on Narcotic Drugs.
[6] Rodríguez, Emilio La Rosa. 2016. "Ethics and Traditional Medicine."; Alma-Ata Declaration 1978; See WHO, “Background of WHO Congress on Traditional Medicine”, 2008, attended by over 70 member states.
[7] Vranken et al. 2014, “Legal Barriers in Accessing Opioid Medicines: Results of the ATOME Quick Scan of National Legislation of Eastern European Countries”; Husain et al. 2014, “Do national drug control laws ensure the availability of opioids for medical and scientific purposes?”; Cleary et al. 2013, “Formulary availability and regulatory barriers to accessibility of opioids for cancer pain in Africa: A report from the Global Opioid Policy Initiative (GOPI).”
[8] De Lima, Liliana 2015, "Palliative care and pain treatment in the global health agenda"; De Lima, Liliana, et al 2014, "Cross-Sectional Pilot Study to Monitor the Availability, Dispensed Prices, and Affordability of Opioids Around the Globe."
[9] See Thoumi, F 2016. Re-examining the ‘Medical and Scientific’ Basis for Interpreting the Drug Treaties: Does The ‘Regime’ Have Any Clothes? in “After the Drug Wars: report of the LSE Expert Group on the Economics of Drug Policy”.
[10] United Nations, ‘Commentary on the Single Convention on Narcotic Drugs, 1961’, p.111. Thoumi 2016: LSE Report: “without clearly defining the terms ‘medical’ and ‘scientific’ in the conventions, it is logically impossible to claim that there is a unique way to interpret them.”
[11] As defined by the World Health Organization, traditional medicine is “the sum total of the knowledge, skills, and practices based on the theories, beliefs, and experiences indigenous to different cultures, whether explicable or not, used in the maintenance of health as well as in the prevention, diagnosis, improvement or treatment of physical and mental illness.”
[12] Mpinga, Emmanuel Kabengele, et al 2013. "Traditional/alternative medicines and the right to health: key elements for a convention on global health." p.50.
[13] General Comment No. 14. 2000. On the right to the highest attainable standard of health
[14] WHO 2008, The Right to Health Factsheet.
[15] Op. cit. 13.
[16] Mashelkar et al. 2001, “Intellectual property rights and the Third World.”
[17] See Op. Cit. 3 and WHO 2012, “Access to Controlled Medications Programme Component: Developing WHO Clinical Guidelines on Pain Treatment”.
[18] Study on the impact of the world drug problem on the enjoyment of human rights, UN doc. A/HRC/30/65, 4 September 2015.
[19] De Lima, Liliana et al. 2013, "Global framework for noncommunicable diseases: how can we monitor palliative care?"; Akol, Angela et al. 2009, “Demographic data for development decisionmaking: Case studies from Ethiopia and Uganda.”
[20] See “The Heemskerk Declaration: Final declaration of the Global Forum of Producers of Prohibited Plants” January 21, 2016.
[21] Government of India, “Bhang” in Traditional Knowledge Digital Library. Accessed 2/28/2016. http://www.tkdl.res.in/tkdl/LangDefault/Formulation/Demo_Docs/BC/unani/highlight.asp?a=/tkdl/langdefault/formulation/demo_docs/bc/unani/ah1-104.asp&b=cannabis&c=F&stypePrint=GLOBAL-SIMPLE-SEARCH?str=Global


BIBLIOGRAPHY

Akol, Angela et al. “Demographic data for development decisionmaking: Case studies from Ethiopia and Uganda.” Population Reference Bureau Assessment Team. April 2009. Available online: http://www.prb.org/pdf09/demographicdatadecisionmaking.pdf.

Bazargani YT, Ewen M, de Boer A, Leufkens HGM, Mantel-Teeuwisse AK. Essential Medicines Are More Available than Other Medicines around the Globe. 2014 PLoS ONE 9(2): e87576. doi:10.1371/journal.pone.0087576. Available online: http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0087576.

Cleary J, Powell RA, Munene G et al. Formulary availability and regulatory barriers to accessibility of opioids for cancer pain in Africa: A report from the Global Opioid Policy Initiative (GOPI). Ann Oncol 2013;24(Suppl 11):xi14-xi23.

Connor S, Sepulveda C. Global Atlas of Palliative Care at the End-of-Life. Worldwide Palliative Care Alliance, 2014. Available online: http://www.who.int/nmh/Global_Atlas_of_Palliative_Care.pdf.

De Lima, Liliana. "Palliative care and pain treatment in the global health agenda." Pain 156 (2015): S115-S118.

De Lima, Liliana et al. "Cross-Sectional Pilot Study to Monitor the Availability, Dispensed Prices, and Affordability of Opioids Around the Globe." Journal of pain and symptom management 48.4 (2014): 649-659.

De Lima, Liliana et al. “Global framework for noncommunicable diseases: how can we monitor palliative care?” Journal of palliative medicine 16.3 (2013): 226-229.

Declaration of Alma-Ata. International Conference on Primary Health Care, Alma-Ata, USSR, 6–12 September 1978. Available online: http://www1.paho.org/English/DD/PIN/alma-ata_declaration.htm.

General Comment No. 14. 2000. On the right to the highest attainable standard of health (Article 12 of the International Covenant on Economic, Social, and Cultural Rights); Committee on Economic, Social, and Cultural Rights; UN doc.E/C.12/2000/4, 4 July 2000. Available online: http://www.nesri.org/resources/general-comment-no-14-the-right-to-the-highest-attainable-standard-of-health-un-committee-on-economic-social-and.

Government of India. “Bhang”. Traditional Knowledge Digital Library. Collaborative Project of Council of Scientific & Industrial Research (CSIR) and Department of Ayurveda, Yoga & Naturopathy, Unani, Siddha and Homeopathy (AYUSH). Accessed Feb 28, 2016. Available online: http://www.tkdl.res.in/tkdl/LangDefault/Formulation/Demo_Docs/BC/unani/highlight.asp?a=/tkdl/langdefault/formulation/demo_docs/bc/unani/ah1-104.asp&b=cannabis&c=F&stypePrint=GLOBAL-SIMPLE-SEARCH?str=Global

Husain, S. Asra, Marty Skemp Brown, and Martha A. Maurer. "Do national drug control laws ensure the availability of opioids for medical and scientific purposes?" Bulletin of the World Health Organization 92.2 (2014): 108-116.

INCB. Report of the International Narcotics Control Board on the Availability of Internationally Controlled Drugs: Ensuring Adequate Access for Medical and Scientific Purposes. International Narcotics Control Board. E/INCB/2010/1/Supp.1. January 2011. Vienna: UN. Available online: https://www.incb.org/documents/Publications/AnnualReports/AR2010/Supplement-AR10_availability_English.pdf.

Mashelkar, R. A., General, D., & Bhawan, A. 2001. Intellectual property rights and the Third World. Current Science, 81(8), 955-965. Available online: http://repository.ias.ac.in/63031/1/30_pub.pdf.

Mpinga, Emmanuel Kabengele et al. "Traditional/alternative medicines and the right to health: key elements for a convention on global health." Health Hum Rights 15 (2013): 44-57. Available online: http://wrap.warwick.ac.uk/55305/1/WRAP_Mpinga-FINAL.pdf.

Rodríguez, Emilio La Rosa. "Ethics and Traditional Medicine." Global Bioethics: The Impact of the UNESCO International Bioethics Committee. Springer International Publishing, 2016. pp.79-83.

“The Heemskerk Declaration: Final declaration of the Global Forum of Producers of Prohibited Plants.” Global Forum of Producers of Prohibited Plants (GFPPP). January 21, 2016. Available online: http://growersforum.org/index.php/2016/01/25/the-heemskerk-declaration/.

Thoumi, F. “Re-examining the ‘Medical and Scientific’ Basis for Interpreting the Drug Treaties: Does The ‘Regime’ Have Any Clothes?” in After the Drug Wars: Report of the LSE Expert Group on the Economics of Drug Policy, February 2016. Available online: http://www.lse.ac.uk/IDEAS/publications/reports/pdf/LSE-IDEAS-After-the-Drug-Wars.pdf

UN. "Commentary on the Single Convention on Narcotic Drugs, 1961." New York (1973). Available online: https://www.unodc.org/documents/treaties/organized_crime/Drug%20Convention/Commentary_on_the_single_convention_1961.pdf.

UN. Single Convention on Narcotic Drugs, as amended by the Protocol amending the Single Convention on Narcotic Drugs, 1961. Signed in Geneva on 25 March 1972. (1972 [1961]). Available online: https://www.unodc.org/unodc/en/treaties/single-convention.html.

UN. “Study on the impact of the world drug problem on the enjoyment of human rights” Report of the United Nations High Commissioner for Human Rights, UN doc. A/HRC/30/65, 4 September 2015. Available online: https://dl.dropboxusercontent.com/u/64663568/library/Study-impact-of-the-world-drug-problem-on-human-rights.pdf.

Vranken, Marjolein JM, et al. "Legal Barriers in Accessing Opioid Medicines: Results of the ATOME Quick Scan of National Legislation of Eastern European Countries." Journal of pain and symptom management 48.6 (2014): 1135-1144.

WHO. “Background of WHO Congress on Traditional Medicine.” WHO Congress on Traditional Medicine, 7-9 November 2008, Beijing, China. Available online: http://www.who.int/medicines/areas/traditional/congress/congress_background_info/en/.

WHO. Briefing Note. “Access to Controlled Medications Programme Component: Developing WHO Clinical Guidelines on Pain Treatment.” April 2012. Available online: http://www.who.int/medicines/areas/quality_safety/ACMP_BrNote_PainGLs_EN_Apr2012.pdf

WHO. “Inequalities are killing people on grand scale, reports WHO’s commission,” WHO Press Release (August 28, 2008). Available online: http://www.who.int/mediacentre/news/releases/2008/pr29/en/index.html.

WHO. Millennium Development Goal, access to affordable essential medicine. Chapter 8e, 2003. Available online: http://www.who.int/medicine/mdg/MDG08ChapterEMedsEn.pdf.

WHO. Strengthening of palliative care as a component of comprehensive care throughout the life course. Resolution WHA67.19. 2014. Geneva: WHO. Available online: http://apps.who.int/gb/ebwha/pdf_files/WHA67/A67_R19-en.pdf.

WHO. The Right to Health Fact Sheet No. 31. 2008. Geneva: WHO. Available online: http://www.ohchr.org/Documents/Publications/Factsheet31.pdf.

WHO. Traditional Medicine: Definitions. 2016. Available online: http://www.who.int/medicines/areas/traditional/definitions/en/.