Risk Assessment of Magic Mushrooms
Risk Assessment of Magic Mushrooms
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Risk assessment of psilocin and psilocybin mushrooms (mushrooms) 2007
Co‐ordination Point for Assessment and Monitoring of New Drugs
CAM
Bilthoven, June 2007
Accountability
This report reflects the risk assessment process concerning magic mushrooms. The risk assessment was carried out by
the Committee for Risk Assessment on New Drugs. The risk assessment process was carried out by the New Drugs Risk
Assessment Committee. The process was coordinated by the New Drugs Assessment and Monitoring Coordination Point
(CAM), which provides the secretariat for this Committee. The CAM is part of the National Institute for Public Health and
the Environment (RIVM).
Coordination point for Assessment and Monitoring of New Drugs p/a
National Institute for Public Health and the Environment
BMT, Box 50
P.O. Box 1
3720 BA Bilthoven
Content
1
1 Management summary ........................................................................................................... 2
1.1 Executive summary ................................................................................................... 4
2 Risk estimation ........................................................................................................................ 6
2.1 Risks to the health of the individual ................................................................................ 6
2.2 Risks to public health ....................................................................................................... 7
2.3 Risks to public order and safety ..................................................................................... 10
2.4 Risks related to criminal involvement ........................................................................... 11
2.5 Qualitative and quantitative enumeration of scores .................................................... 11
3 Conclusions and recommendation .................................................................................. 14
3.1 Conclusions on the procedure .................................................................................. 14
3.2 Conclusions on magic mushrooms ........................................................................... 14
3.3 Placing on the risk scale ............................................................................................ 15
3.4 Consequences of measures ............................................................................................ 15
3.5 Recommendation ...................................................................................................... 16
Annex 1 Information report .................................................................................................. 18
Summary .............................................................................................................................. 18
Summary .............................................................................................................................. 18
Accountability ...................................................................................................................... 19
INDIVIDUAL HEALTH EFFECTS ....................................................................................................... 19
PUBLIC HEALTH ......................................................................................................................... 22
PUBLIC ORDER AND SAFETY ......................................................................................................... 30
CRIMINAL INVOLVEMENT ............................................................................................................ 31
Annex 2 Description of the risk estimation process ............................................................. 40
1 Composition of the risk assessment committee .......................................................... 40
2 Risk estimation procedures ........................................................................................... 41
3 Risk assessment criteria ................................................................................................ 42
4 Riscos estimation score table ........................................................................................ 44
Annex 3 Chronology risk assessment procedure magic mushrooms ..................................... 45
Appendix 4 Terms and abbreviations ................................................................................... 46
1 Management summary
The use of hallucinogenic mushrooms (mushrooms) poses such a low risk to individual health
and to society that banning them is too heavy a burden in relation to the nuisance and damage
caused by their current use. This is apparent from a risk assessment carried out by the
Coordination Centre for Assessment and Monitoring of New Drugs (CAM) at the request of the
Ministry of Health, Welfare and Sport.
2
The CAM has performed a risk assessment for mushrooms, mushrooms containing the active
substances psilocin and psilocybin according to established procedures. The CAM was assisted
in this task by the Committee on the Risk Assessment of New Drugs. The risk assessment shows
the following:
There is no physical or mental dependence. Acute toxicity is largely limited to possible panic
and anxiety attacks, which can only have incidental fatal consequences. In the case of chronic
toxicity, at most the occurrence of flashbacks can be mentioned. On balance, therefore, there
is no risk to individual health when using magic mushrooms. For only one of the criteria in this
risk category, acute toxicity, the risk was estimated to be low. Although there are no scientific
research data, the use of magic mushrooms in combination with other psychoactive
substances, including alcohol, does appear to pose an additional risk.
Mushrooms have been easier to obtain since 2000 as the number of points of sale (including
the Internet) has increased. There are also more varieties available. There is little adequate
user information available. The content of psychoactive substances in the mushrooms varies,
making the quality of the product unpredictable. The quality awareness of those who sell the
product is largely lacking. The extent of use, the vulnerability of the user and the number of
reports of incidents is limited. The extent of use by tourists has increased considerably since
2000, partly due to a significant growth in tourism. In contrast to Dutch users, ill‐prepared
tourists in Amsterdam in particular are seen as a vulnerable group. Some serious incidents have
been reported about this group in recent years. In general, however, the risk to public health
is estimated to be low.
Mushrooms reduce the user's responsiveness (e.g. driving ability), but there is no lowering of
the user's threshold of violence. Because the use usually takes place at home and in the wild,
there is no nuisance for civilians. The risk of disturbance to public order is therefore estimated
to be low. In contrast to the general population, tourists use the mushrooms in hotels and in
public spaces. This gives more cause for nuisance.
There is no evidence of organised crime involvement. Some individuals from the smartshop
circuit have links to cannabis growers. Legally grown fresh mushrooms may serve as a raw
material for the illegal trade and export of dried mushrooms and products in which they are
processed. There is therefore a low risk of criminal involvement.
In 2000 the CAM issued recommendations to set quality requirements for mushrooms (e.g.
standardisation, purity, labelling) and the trade in mushrooms (e.g. responsible information).
The aim was to promote the limited availability of mushrooms. These recommendations have
hardly been realized in recent years.
The Committee points out that the vast majority of use is without problems. Compared with
other drugs for which the CAM carried out risk assessments (MBDB, MTA, PMMA, ketamine
3
and GHB), the mushrooms scored relatively low on the risk scale. The weighted risk estimate
in 2007 does not differ from that in the year 2000. As a result, the Committee does not consider
a substantial revision of the mushroom policy to be necessary. Prohibiting hallucinogenic
mushrooms, also for satisfied users, seems to be a disproportionate burden compared to the
nuisance and damage caused by the existing use. Enforcement of such a ban would entail costs.
There is also a chance that alternative substances will be used that can cause more damage to
public health and that may be more attractive from a criminal point of view, causing more
nuisance. The Committee estimates the highest risk for use by persons unfamiliar with the
effects of the use and for those who take the product in an environment unfamiliar to them,
such as foreign tourists. The most important risks identified by the committee are the varying
composition and quality of the products, oversized packaging units, poor information and easy
availability of the mushrooms.
The committee advises developing high‐quality information material for users, including
material for foreign tourists in their mother tongue. Points of sale and tourist information
points should provide this information material. The committee believes that the most profit
can be made from this. The lack of good quality sales information seems to be more often the
case in retail outlets other than smartshops.
Further conditional regulation of the trade in mushrooms should be considered, if necessary
by amending the Commodities Act. To prevent inadvertent overdose it is recommended to
reduce the dose to a maximum of 10‐15 grams of fresh mushrooms per package.
1.1 Executive summary
The use of hallucinogenic mushrooms (paddo's) poses such a low risk for the health of the
individual and for society that prohibiting their use would appear to be a disproportionately
grave measure in relation to the nuisance and damage caused by their current use. This is the
conclusion reached by the Co‐ordination Centre for Assessment and Monitoring of new drugs
(CAM) in an assessment commissioned by the the Dutch Ministry of Health, Welfare and Sport
(VWS).
The CAM performed this risk assessment according to established procedures with the support
of the Committee for risk assessment of new drugs for the mushrooms containing the active
substances, psilocin and psilocybin, the so‐called ‘magic mushrooms’ (paddo’s).
Physical or psychological dependence has not been reported, and acute toxicity is mainly
confined to possible attacks of panic or anxiety, which only seldom have fatal consequences.
With regard to chronic toxicity, only the occurrence of flashbacks can be mentioned. Thus, on
balance, the use of magic mushrooms is not considered to pose a risk to an individual’s health.
For only one of the criteria in this risk category, namely, acute toxicity, was a small risk
estimated. Although scientific data are not available, the use of magic mushrooms in
2
combination with other psychoactive products, including alcohol, appears to constitute an
additional risk.
The increase in the number of sales outlets (including internet) has made magic mushrooms
more easily available since the year 2000; the number of available species has also increased.
There is hardly any adequate user information available. The quality of the product is
unpredictable due to the variation in concentration of the psychoactive substances in the magic
mushrooms, while those selling the product have little awareness of the quality. The
prevalence of use, the vulnerability of the user and the number of reports of accidents is
limited. The prevalence of use by tourists has increased considerably since the year 2000, partly
due to a substantial growth of tourism. Contrary to the Dutch users, poorly prepared tourists,
especially those in Amsterdam, are considered a vulnerable group; several serious accidents
have been reported within this group the last few years. In general, the risk for public health is
considered to be small.
Magic mushrooms reduce the user’s ability to react (e.g. decrease in driving skills), but do not
reduce the user’s threshold of violence. As use usually takes place at home or in the
countryside, there is no public nuisance. Therefore, the risk of disturbing the public order is
considered to be small. Contrary to the general population, tourists use magic mushrooms in
hotels and public places, which may cause more public nuisance.
Involvement of organized crime has not been reported. Some individuals from the smartshop
scene have ties with cannabis growers. Legally grown fresh magic mushrooms may serve as
raw material for the illegal trade and export of dried mushrooms or products containing
processed mushrooms. Therefore, the risk for criminal involvement is considered to be small.
Both the recommendation of the Committee from the year 2000 to impose requirements on
the quality of magic mushrooms (standardization, purity and labeling) and the trade in magic
mushrooms (including a sound information supply that are conducive to a limited availability
of magic mushrooms) have barely been put into practice the past few years.
The committee points out that most of the magic mushroom use occurs without problems.
Compared to other substances for which CAM has performed a risk assessment (i.e. MBDB,
MTA, PMMA, ketamine and GHB), magic mushrooms score relatively low on the risk scale. As
the weighted risk assessment in 2007 does not deviate from the assessment in 2000, the
committee does not consider a fundamental revision of magic mushroom policy to be
warranted. Prohibiting hallucinogenic mushrooms (for the satisfied consumer too) would
appear to be a disproportionate grave measure in relation to the nuisance and damage caused
by their current use. Enforcement of such a ban also requires financial resources. Alternative
substances could be used, causing more damage to public health and being possibly more
attractive from a criminal perspective, leading to more public nuisance. The committee
5
considers the risks highest for those unfamiliar with the effects of use (foreign tourists) and
those using magic mushrooms in an unfamiliar environment. The most important risks noted
by the committee are the varying composition and quality of the products, the sales containers,
which are too large, the poor consumer information and the readily availability of the magic
mushrooms.
According to the committee, most can be gained by the development of highquality standard
consumer information ( including material for foreign tourists in their native language); this
information should be made available in sales outlets and tourist information depots/centres.
The lack of high‐quality standard consumer information appears to be more common in sales
outlets other than smartshops. Further conditional regulation of the trade in magic mushrooms
should be considered if required by modification of food and consumer goods legislation. To
prevent unintended overdoses, the dose should be reduced to a maximum of 1015 grams of
fresh magic mushrooms per sales container.
2 Risk estimation
Below, for each criterion (numbered), the arguments and comments that emerged during the
discussion are briefly presented and the average of the scores of the members of the risk
assessment committee is indicated.
2.1 Risks to the health of the individual
1) The magnitude of the risk of physical dependence
Physical dependence does not occur when using magic mushrooms.
none (1.0) low possible large mighty
2) The magnitude of the risk of mental dependence
It depends on what definition is used for mental dependence. If mental dependence is
synonymous with "addiction," there is no risk. However, there are users who like the
experience so much that they like to use magic mushrooms again. Since this does not lead to
reduced social or psychological functioning, it is not seen as a risk.
none (1.4) low possible large mighty
3) The magnitude of the risk of acute toxicity
2
There are regular incidents requiring medical assistance (first aid, hospital admissions) which
are mainly due to the occurrence of anxiety and panic attacks. However, the somatic effects
(changes in blood pressure, heart rate, etc.) are not so pronounced. The setting plays a major
role here: it is important that it is used in a quiet, safe environment. Inexperienced tourists in
a foreign country for them use all kinds of psychoactive substances in a short period of time.
The occurrence of anxiety and panic attacks can therefore not always be attributed solely to
the use of magic mushrooms. The incidents reported by the Municipal Health Service (GGD) in
Amsterdam have more to do with the manner and situation of use and are not related to a
changed toxicity of the mushrooms.
no low (2.4) possible large mighty
4) Magnitude of risk of chronic toxicity
Mushrooms are mainly used experimentally, long‐term use is rare. There are examples from
other cultures where people have used mushrooms regularly throughout their lives, without
any symptoms of chronic toxicity. However, there are also users who experience flashbacks
after single use for several weeks to months after use. There is insufficient data available on
mutagenicity and teratogenicity to draw any conclusion, but it is not consistent with the logic
that magic mushrooms possess these properties. As with some other psychoactive drugs, the
use of magic mushrooms by psychologically unstable people can be a trigger for mental
derangement.
1. none (1.9) 2. small 3. possible 4. large 5. very large
2.2 Risks to public health
5) The degree of risk with regard to size and frequency of use and any increase in use
Mushrooms are used less than XTC, which in itself is significantly less than the use of cannabis.
From a national point of view the use is low. The ever use among the general population of 12
years and older had increased in 2001 (2.6%) compared to 1997 (1.6%). The use is somewhat
higher among young people and highest among special populations (outgoers, foreigners,
truancy youngsters). Research in Amsterdam shows that the use among young pub and club
visitors has decreased in recent years. Most of the use mainly concerns experimental
behaviour, one stops after a number of times, which is shown by the remarkably low
prevalence for the last month of use compared to ever use. Many users indicate that they do
not find the use/effect a pleasant experience, they become unsociable (anti‐social), it is
absolutely incomparable with the empathic effect of XTC and it is therefore unsuitable to use
at parties.
7
Young foreign tourists can be seen as a separate group, especially in Amsterdam. Many of these
tourists experiment with drugs during their visit, including mushrooms. Because new cohorts
of tourists continuously visit our country, the volume of use of this group is relatively large. The
influx of (young) tourists to Amsterdam has risen sharply in recent years, which may explain
the increase in the number of mushroom‐related incidents.
no low (2.6) possible large mighty
6) The degree of risk due to the vulnerability of the user
This is a young age group, which often uses other means as well. The smartshop industry
indicates that it advises young people under the age of 18 not to use magic mushrooms.
Psychologically unstable people also run a slightly higher risk (see 4). Tourists are a relatively
vulnerable group as they often do not use the magic mushrooms in a familiar quiet
environment, but for example in a busy hotel room without the presence of sober, non‐users
for guidance or in the public space in the city. The common combined use of other drugs or
alcohol, and the fact that all kinds of drugs are often used in a short period of time, also makes
them extra vulnerable.
no low possible (3.0) large mighty
7) The degree of risk due to lack of adequate usage information
The extent to which smartshop owners or sellers themselves are adequately informed varies
from large to not at all. Moreover, providing information sometimes seems subordinate to
achieving turnover. This is even more important in tourist shops. Compared to 2000, there
seems to be a little more information available, but this still varies greatly from point of sale to
point of sale. Also, the information still falls short in the sense that more emphasis is placed on
the desired than on the undesirable effects.
The information is usually provided in Dutch and English. No information is available for tourists
who do not speak these languages.
no low (2.9) possible large mighty
8) The degree of risk related to the availability of the product in question
The sale of mushrooms is not limited to the smartshops, also in growshops, headshops, tourist
shops and through the Internet mushrooms are available. The exact number of points of sale
in the country is not known, and in addition the number of points of sale varies greatly per
2
region. There are relatively many outlets in Amsterdam and the border areas. In those areas,
and because of the role of the Internet, the hallucinogenic mushrooms are easily available. It
is estimated that sales of mushrooms account for approximately 30‐50% of the turnover of
smartshops.
no low possible (3.5) large mighty
9) The degree of risk due to unreliable product quality
The levels of psychoactive substances vary from species to species and range from 1% to 3.5%.
Within different batches of the same species sometimes twice as much active substance can
be present. In most cases there is no standardization of this natural product. Because the
mushrooms are also offered in a unit (trays) intended for use by two persons, there is a chance
that this quantity will be used by one person at once. The mushrooms can also be contaminated
with, for example, fungi and mites. Due to the variation in concentration of active substances
in the mushrooms and the quantities in which the mushrooms are offered for sale, the dose
taken per administration can vary greatly. The intensity of the experience is dose‐related. This
also applies to possible feelings of anxiety if a mushroom trip turns out wrong. The collection
in the wild gives a certain risk of substitution with poisonous species.
no low possible (3.0) large mighty
10) The degree of risk due to unreliability of the method of distribution and points of sale and
traders
Some smartshop owners are known to have connections with the "synthetic drug
environment". A number of smartshop owners are not willing to indicate who the suppliers of
the magic mushrooms are. Throughout the industry, quality awareness is not very important,
barring some exceptions. This certainly applies to tourist shops etc. where mushrooms are also
sold.
no low (2.6) possible large mighty
11) The degree of risk measured by the nature and extent of incident reports
From a national perspective, there has been no increase in reports of intoxications with
mushrooms containing psilocybin (National Poisoning Information Centre; NVIC). In
Amsterdam, there has been a striking increase in the number of calls made to the Central
Ambulance Dispatch Centre in connection with a mushroom‐related incident (from 55 in 2004
9
to 128 in 2006). This mainly involved foreign tourists (92%). (See also point 5). Such figures are
not available for other cities or regions, but enquiries from GGDs in the other three major cities
gave no indication of fatal incidents in those cities. Medical assistance was mainly needed
because of the occurrence of anxiety and panic attacks (see also point 3).
no low (2.6) possible large mighty
2.3 Risks to public order and safety
12) The degree of risk in terms of frequency and severity of possible nuisance to citizens
around sales and use
The points of sale of magic mushrooms do not cause any nuisance and the use generally takes
place at home or in the wild. The perception of users is "inward", at the most if a panic attack
occurs, they may appeal to or harass citizens. Contrary to the use by the general population,
foreign tourists in Amsterdam usually use the magic mushrooms in hotels and in public spaces,
which means that the risk of disturbance to public order by this group has to be estimated
higher.
none (1.6) low possible large mighty
13) The degree of risk because the use leads to a lowering of the threshold of violence in the
user
Only in case of anxiety and panic attacks can users react aggressively if, for example, they are
addressed by the competent authority. However, the number of fear and panic reactions is
relatively low (see point 11).
none (1.4) low possible large mighty
14) The degree of risk because the use of the product influences the ability to react
Hallucinogenic drugs can impair responsiveness, cause behavioural changes and effects on
perception, leading to dangerous situations in psychomotor skills, particularly when it comes
to driving and operating equipment. Sleepiness may also occur.
The inherent risk is no different now than it was in 2000. However, experience shows that users
are apparently aware of this risk and do not expose themselves and others to danger by, for
example, driving under the influence of magic mushrooms. In the past two years, the
Netherlands Forensic Institute (NFI) found only four psilocybin positive samples in the blood of
2
4636 people who died under suspicious circumstances, including traffic victims. Because this
aspect was taken more into account by the Committee in this risk estimation (compared to the
risk estimation in 2000), this criterion now scores lower than in 2000.
no low (2.9) possible large mighty
2.4 Risks related to criminal involvement
15) The degree of risk through involvement of (organised) crime in production and trafficking
There is no evidence of organised crime involvement. A number of individuals from the
smartshop industry have links with cannabis growers. There is a regular violation of the Opium
Act in connection with the export of dried mushrooms, including to France, Belgium and
Luxembourg. Frequent mail packages and letters containing mushrooms to be sent abroad are
also intercepted. It is often impossible to determine whether these are fresh or dried
mushrooms. In one case, it has been established that dried mushrooms were processed in
chocolate on a large scale, in a professional manner, for export to a large number of countries
all over the world.
no low (2.1) possible large mighty
16) The degree of risk through involvement of (organised) crime in the production and trade
of raw materials
See point 15. In this case, it is difficult to distinguish between raw material and finished product.
Legally grown (fresh) mushrooms can be used as raw material for the illegal trade and export
of dried mushrooms and products containing them.
none (1.9) low possible large mighty
2.5 Qualitative and quantitative enumeration of scores
The results of the scores in 2000 and 2007 for each risk category are shown graphically and in
a table below.
11
Total scores
10
9
8
7
6
5
4
3
2
1
0
I II III IV Total
2000 1,78 2,95 2,53 2,06 9, 3
2
2007 1,66 2,89 1,98 2,00 8, 53
category
The numbers above represent the average of the scores per category. The table below shows
in words how the numerical scores are evaluated textually. It is emphasized that the numerical
scores are an aid in risk estimation. The (qualitative) arguments used in the risk estimation are
paramount in determining the final verbal valuation. As a guideline, a score of 1 to 2 is assigned
a valuation of no risk, 2 to 3 a low risk, 3 to 4 a possible risk, 4 to 5 a high risk and a score of 5
a very high risk.
Category risk Score Appreciation
Total score 8.5
The main numerical difference between the risk estimate in 2000 and the current risk estimate
is the difference in risk of public order disruption. This is mainly due to a difference in the
estimate of the risk related to the effects on responsiveness. Although the responsiveness is
strongly influenced, the user seems to recognise this and will therefore try to avoid the risk.
For the rest, the risks are estimated in numbers and on average per category not larger or
smaller than in 2000.
The results of the scores in 2000 and 2007 for each criterion are shown graphically and in a
table below.
2
The Committee has assessed the risks as presented here for the general population in the
Netherlands. The population of foreign tourists in Amsterdam forms a separate group. If the
risks for this group were scored separately, they would be higher. Especially criteria 5 (size and
frequency of use), 6 (vulnerability of the user), 7 (lack of adequate user information) and 11
(the nature and size of incident reports) would be criteria for which the Committee would
estimate the risks for foreign tourists higher.
13
3 Conclusions and recommendation
3.1 Conclusions on the procedure
The risk assessment for mushrooms containing psilocin and psilocybin is the sixth according to
the established procedure and criteria of the CAM. It is the second time that the CAM assesses
the risks of magic mushrooms. A reasonable amount of information on mushrooms was already
available in 2000. Since the previous assessment, hardly any new information on magic
mushrooms has become available. The risk estimation is partly based on an information report
compiled by the CAM (see Appendix 1).
3.2 Conclusions on magic mushrooms
1. There is no physical or mental dependence. Acute toxicity is largely limited to possible panic
and anxiety attacks, which can only have incidental fatal consequences. In the case of
chronic toxicity, at most the occurrence of flashbacks can be mentioned. On balance,
therefore, there is no risk to individual health when using magic mushrooms. For only one
of the criteria in this risk category, acute toxicity, the risk was estimated to be low. Although
there are no scientific research data, the use of magic mushrooms in combination with
other psychoactive substances, including alcohol, does appear to pose an additional risk.
2. Mushrooms have been easier to obtain since 2000 as the number of points of sale
(including the Internet) has increased. There are also more varieties available. There is little
adequate user information available. The content of psychoactive substances in the
mushrooms varies, making the quality of the product unpredictable. The quality awareness
of those who sell the product is largely lacking. The extent of use, the vulnerability of the
user and the number of reports of incidents is limited. The extent of use by tourists has
increased considerably since 2000, partly due to a significant growth in tourism. In contrast
to Dutch users, ill‐prepared tourists in Amsterdam in particular are seen as a vulnerable
group. Some serious incidents have been reported about this group in recent years. In
general, however, the risk to public health is estimated to be low.
3. Mushrooms reduce the user's responsiveness (e.g. driving ability), but there is no lowering
of the user's threshold of violence. Because the use usually takes place at home and in the
wild, there is no nuisance for civilians. The risk of disturbance to public order is therefore
estimated to be low. In contrast to the general population, tourists use the mushrooms in
hotels and in public spaces. This gives more cause for nuisance.
4. There is no evidence of organised crime involvement. Some individuals from the smartshop
circuit have links to cannabis growers. Legally grown fresh mushrooms may serve as a raw
material for the illegal trade and export of dried mushrooms and products in which they
are processed. There is therefore a low risk of criminal involvement.
2
5. In 2000 the CAM issued recommendations to set quality requirements for mushrooms (e.g.
standardisation, purity, labelling) and the trade in mushrooms (e.g. responsible
information). The aim was to promote the limited availability of mushrooms. These
recommendations have hardly been realized in recent years.
3.3 Placing on the risk scale
Health of the Public Health Public Total
Resource individual Order Crime Recommendation
score
ketamine low low low no 8,8 monitoring
product and
mushrooms
no low low low 9,3 trade quality
(2000) requirements
production and
PMMA possible possible low possible 11,8 trade measures
production and
4‐MTA possible possible possible possible 11,8 trade measures
product and
mushrooms trade quality
no low low low 8,5 requirements;
(2007)
prevention
Compared with other drugs for which the CAM has carried out risk estimates (MBDB, MTA,
PMMA, ketamine and GHB), the magic mushrooms score relatively low on the risk scale (see
table above). The weighted risk estimation for magic mushrooms carried out in 2007 does not
deviate significantly from that reported in 2000.
3.4 Consequences of measures
The risk assessment committee briefly discussed the consequences of possible measures. The
discussion focused mainly on the pros and cons of a total ban versus regulation with regard to
the quality of the product and the trade in it.
15
It was argued in the discussion that in the event of a ban, smartshops would lose about one
third to half of their turnover. This could result in them looking for other ‐ possibly more risky
‐ products to fill this gap. Risks are seen in the illegal appearance of stronger hallucinogens, but
also in the appearance of hallucinogens in the form of tablets or pills. As a result, the nature of
the product will not be directly apparent from the form of the product, which may result in
unintended use (e.g. use under the assumption of consuming an XTC tablet). If the user is
unable to obtain mushrooms in the smartshop, he could decide to pick mushrooms in nature,
with a risk of substitution with poisonous species. However, the search in nature is only
expected to a limited extent, as the mushrooms in the Netherlands are not very common and
therefore hard to find for a layman. Users could also switch to other products, which might be
more risky.
A ban would eliminate the visibility of use and the possibility of providing good product
information. Enforcement of a ban on mushrooms would entail significant costs and it is
questionable whether these outweigh the benefits to be gained.
Because the cultivation of mushrooms in the Netherlands is legal, there is the possibility that
they are used as raw material for the illegal trade and export of dried mushrooms or products
in which they are processed. A total ban would remove this possibility. Also, a ban would
greatly reduce the availability of mushrooms for tourists, so it can be expected that the number
of mushroom related incidents in Amsterdam in particular will decrease.
When mushrooms are not banned but measures are taken to achieve further product
regulation, mushrooms will remain available as a relatively harmless alternative to heavier
hallucinogens, there is the possibility to provide good product information and the use of magic
mushrooms will be monitored. However, when trying to achieve product regulation within the
current regime, this requires an adjustment of the regulations. For effective enforcement by
VWA it is necessary to include specific rules for the sale and commendation of magic
mushrooms in the Commodities Act. The success of more information and product regulation
is difficult to estimate. The question is whether foreign tourists are easily accessible and
receptive to information and whether they will follow recommendations on the product
information. Foreign tourists will still use the mushrooms in unsuitable locations.
The average starting age for magic mushroom use is 22.3 years and the ever use in the age
group 16‐19 years was about 3% in 2001, compared to 12% for the age group 20‐24 years.
Introducing an age limit of 18 years would therefore have little effect on the overall level of
use. On the other hand, it has been suggested that under‐age users may be more likely to take
ill‐considered use.
3.5 Recommendation
The Committee points out that the vast majority of use is without problems. Compared with
other drugs for which the CAM carried out risk assessments (MBDB, MTA, PMMA, ketamine
and GHB), the mushrooms scored relatively low on the risk scale. The weighted risk estimate
2
in 2007 does not differ from that in the year 2000. As a result, the Committee does not consider
a substantial revision of the mushroom policy to be necessary. Prohibiting hallucinogenic magic
mushrooms, also for satisfied users, seems to be a disproportionate burden compared to the
nuisance and damage caused by the existing use. Enforcement of such a ban would entail costs.
There is also a chance that alternative substances will be used that can cause more damage to
public health and that may be more attractive from a criminal point of view, causing more
nuisance. The Committee estimates the highest risk for use by persons unfamiliar with the
effects of the use and for those who take the product in an environment unfamiliar to them,
such as foreign tourists. The most important risks identified by the committee are the varying
composition and quality of the products, oversized packaging units, poor information and easy
availability of the mushrooms.
The committee advises developing high‐quality information material for users, including
material for foreign tourists in their mother tongue. Points of sale and tourist information
points should provide this information material. The committee believes that the most profit
can be made from this. The lack of good quality sales information seems to be more often the
case in retail outlets other than smartshops.
Further conditional regulation of the trade in mushrooms should be considered, if necessary
by amending the Commodities Act. To prevent inadvertent overdose it is recommended to
reduce the dose to a maximum of 10‐15 grams of fresh mushrooms per package.
Further procedure
The CAM presents the risk assessment report with its conclusions and recommendation to the
Minister of Health, Welfare and Sport. The policy board advises the Minister on the measures
to be taken in response to the CAM report.
17
Annex 1 Information report
INFORMATION REPORT MUSHROOMS (MUSHROOMS)
An 'update' of the literature since 2000
Summary
The 'Information Report Mushrooms (Mushrooms) 2007' gives no indication that the 'state of
the art', opinion and consideration of mushrooms have changed substantially since 2000. Since
2000, little new data have appeared in the scientific (and grey) literature on physical or mental
addiction, acute and chronic toxicity, public health risks, and criminal aspects related to
mushroom consumption.
The prevalence of mushroom use in the Dutch population is still decreasing, given the decrease
in 'last year prevalence' among young visitors to pubs in Amsterdam from 6.3% in 2000 to 2.9%
in 2005.
Although previously recognised, two issues appear to be of increasing importance:
1. Combined use of mushrooms and alcohol (or other drugs; poly‐drug use);
2. the 'setting' in which the mushrooms are used.
The 2007 report of the Amsterdam Municipal Health Service (GGD) and the EMCDDA review
article suggest that the fatal outcome of mushroom consumption could be related to prior or
concomitant alcohol consumption. For two years, the Amsterdam Municipal Health Service
provided ambulance support in approximately 70 cases.
related incidents. In 63 cases, foreign tourists (92%) were involved. It is clear that in absolute
terms, the number of medical support to tourists is very high compared to Dutch mushroom
users. However, given the many hundreds of thousands of young tourists who visit Amsterdam
annually and use magic mushrooms, this number is not alarming. The fact that less support is
given to Dutch users seems to underline the importance of a quiet 'setting' for mushroom users
(e.g. users should not consume mushrooms on the street and crowded hotel rooms, and should
avoid confusing noise and light within the 'setting' of use). Different interest groups
recommend, among other things, to better inform users with 'flyers' and leaflets, which warn
users in different languages not to combine mushrooms with alcohol consumption, to ensure
a quiet 'setting' and to use them under the supervision of someone who has not used them.
Summary
The “CAM risk assessment magic mushrooms (paddo’s). Information report 2007” shows no
evidence that the state of the art of, and opinions and views on magic mushrooms have largely
changed since the year 2000. Few new data have appeared in scientific (and gray) literature
about physical or mental dependence, acute and chronic toxicity, risk for public health and
criminal aspects related to the consumption of magic mushrooms.
2
The prevalence of magic mushroom use in the Dutch population is still declining, considering
its decrease in last year prevalence amongst young visitors to cafés in Amsterdam from 6.3%
in 2000 to 2.9% in 2005.
Though previously acknowledged before, two issues appear to be of increasing importance:
1. combinatory use of mushrooms and alcohol (or other drugs; poly‐drug use);
2. the setting in which the magic mushrooms are consumed.
The 2007 report of the Amsterdam Municipal Health Service (GGD) and the review of EMCDDA
suggest that the fatal outcome of magic mushroom consumption may be related to prior or
simultaneous use of alcohol. Over two years GGD gave assistance and ambulance support in
about 70 magic mushroom related incidents. In 63 of those foreign tourists (92%) were
involved. Obviously, the absolute number of medical supports given to tourists is much higher
as compared to those given to Dutch paddo users. However, considering the several hundreds
of thousands of young tourists which visit Amsterdam yearly and use paddo’s, this number of
supports is not alarming. That less support seems to be given to Dutch users, highlights the
importance of a quiet setting for magic mushrooms use (i.e. users should not use on street
corners, crowded hotel rooms, and should avoid confusing noisy and bright lighted settings).
Various stakeholders advocate amongst others to inform the consumers better by flyers and
leaflets which warn the consumer in different languages not to combine magic mushrooms use
with alcohol consumption, to take care of a quiet setting, and to have surveillance by a non‐
user.
Accountability
The Information Report used by the CAM in the last risk assessment of mushrooms dates back
to February 2000 and was mainly based on the basic report "Psychoactive Mushroom & Plant
Products. Toxicology and clinical effects" by JA Bosch, EJM Pennings and FA de Wolff, 1997
(Bosch et al., 1997).
The Information Report from 2000 (CAM, 2000) has been revised with regard to new scientific
data, experiences and opinions that have appeared in the Netherlands and abroad over the
last seven years. This report serves as a basis document for the second assessment of magic
mushrooms by CAM in June 2007. The most efficient way to 'update' the previous basic
document from 2000 was to use the recent thematic report of the European Monitoring Center
for Drugs and Drug Addiction, Hallucinogenic mushrooms: an emerging trend case study from
2006 (EMCDDA, 2006) as a basis. Thus, the current report contains selected relevant parts of
this document. The update was completed with literature found in the Medline database 2000‐
2007 by means of literature searches. The search terms used were: 'magic mushrooms', 'LSD',
'psilocybin', 'psilocin', 'suicide', and 'alcohol'. As in the previous assessment, the current basic
document only deals with mushrooms containing psilocybin and/or psilocin.
INDIVIDUAL HEALTH EFFECTS
19
1, 2. Physical and mental addiction
No new data on physical and mental addiction due to the use of magic mushrooms were
published. Both forms of addiction do not occur and no 'kick off' symptoms have been
observed.
3. Acute toxicity
The duration of a 'trip' is usually 2 to 6 hours and is accompanied by residual effects (e.g.
difficulty sleeping), which last another 2‐6 hours. Subjective effects include: a mildly relaxed
feeling (similar to cannabis), dizziness, uncontrolled laughter, energetic, happy and euphoric,
altered visual perception (colours appear brighter, moving surfaces, waves), delusions, altered
perception of events, images and faces, and real hallucinations. The sensory disturbances can
be linked to restlessness, poor coordination, anxiety, reduced sense of time and distance, a
feeling of irreality or even depersonalization. These effects are referred to by users as 'bad
trips' and they can lead to panic reactions and a psychosis‐like state. A report on the internet
from April 2006 (Shroomery, 2007) refers to literature reports on severe acute effects of
mushroom extracts after intravenous administration.
In general, the physiological side effects are not significant and are accompanied by drowsiness,
dizziness, a feeling of weakness, muscle pain, tremors, abdominal pain and pupil dilation
(mydriasis). A British magazine aimed at the dance club audience conducted a survey among
users of hallucinogenic mushrooms in 2005. It was found that more than 25 percent had
suffered from nausea or vomiting in the last year (Mixmag, 2005). Increased heart rate is often
observed in Psilocybe mushroom intoxications. Mild to significant increase in respiratory rate,
accelerated heart rate (tachycardia at 10 beats per minute), and a systolic and diastolic increase
in blood pressure (+25, and +10 mm Hg, respectively) were observed at an oral dose of 0.2
mg/kg psilocybin (Gouzoulis‐Mayfrank et al., 1999), confirming previous findings after 8‐12
mg/kg oral psilocybin (Quetin, 1960). In general, body temperature remains normal, although
clear physical symptoms such as severe abdominal pain, persistent vomiting, diarrhoea were
observed. The tendency for a temporary increase in blood pressure is mainly a risk factor for
users who are heart patients, especially those with (untreated) hypertension (Hasler et al.,
2004).
Clinical research from the '50s and '60s ignored the powerful effects of 'set' and 'setting' on
psilocybin effects. Subsequent studies, which paid more attention to preparation and
interpersonal support during drug use (and effects), found fewer psychological side effects,
such as panic reactions and paranoid episodes, and more often reported positive experiences
during the use of magic mushrooms (Leary et al., 1963; Metzner et al., 1965). However, a recent
study by Griffiths et al. (Griffiths et al., 2006) reported that 22% (8 out of 36) of the volunteers
given 30 mg psilocybin per 70 kg orally had had a period of significant anxiety/dysphoria during
the total session. In some cases, this included thoughts of paranoia that were transient. These
symptoms thus occurred despite the fact that there was a gathering and pre‐sessions with
supervisors that lasted 8 hours (when psilocybin was administered in the first session) to 24
hours (when psilocybin was administered in the third session) of contact time. Of the carefully
2
selected volunteers, who were treated with the high dosage of 30 mg/70 kg, 31% had
significant anxiety experiences and 17% had transient paranoia. In addition, the study was
conducted in a comfortable setting under good supervision. With insufficient supervision, such
effects can escalate into panic attacks and dangerous behaviour.
A few days to a week after the ingestion of mushrooms the hallucinations can occur again. This
is called a 'flashback' effect (Benjamin, 1979). A very carefully conducted critical review of 20
quantitative studies of Hallucinogen Persisting Perception Disorder (Flashbacks) or 'HPPD'
(Halpern and Pope, 2003) from 2003 concluded that current knowledge about this is very
limited. HPPD appears to exist, is rare, but can persist for months or even years after
hallucinogens have been used. The syndrome was usually reported after LSD use and less so
after the administration of LSD in a research or treatment setting or in other hallucinogens
(magic mushrooms) (Halpern and Pope, 2003). The majority of reported flashbacks involved
multi‐drug users or psychiatric patients.
4. Chronic toxicity
Genotoxicity, reproductive toxicity and hormonal effects
Although no systematic studies have been carried out, there is as yet no evidence of chronic
toxicity. No data are available to draw any conclusion on the teratogenic damage of magic
mushrooms. No genotoxicity was found in the mouse micronucleus test (psilocybin 4‐16
mg/kg) (Van Went, 1978) and no irreversible organ damage by psilocybin was reported (CAM,
2000). Human plasma levels of TSH, ACTH, prolactin and cortisol were elevated during the
maximum effect of psilocybin (315 µg/kg orally), but returned to normal within 5 hours. On
liver function tests ASAT and GGT, only minimal effects of psilocybin were observed (Hasler et
al., 2004).
Psychosis and other psychiatric illnesses
Selective serotonin reuptake inhibitors are known to be effective in the treatment of obsessive‐
compulsive syndrome (OCD). Recently, Moreno et al. (Moreno et al., 2006) reported a
beneficial effect of psilocybin (four doses; 100 to 300 µg/kg orally) in a small sample (N=9) of
OCD patients. Their results showed a dose‐dependent (23‐100 percent) decrease in the
measures for OCD. No major side effects were observed. Vollenweider et al. recently reported
a series of studies on acute subjective, psychological and perceptual effects of psilocybin
(Carter et al., 2005; Hasler et al., 2004; Vollenweider et al., 1998). Psilocybin induced a model
of psychoses mimicking certain aspects of acute and early stages of schizophrenia (Gouzoulis‐
Mayfrank et al., 1998); (Vollenweider et al., 1998; Vollenweider and Geyer, 2001).
These reports did not establish a causal relationship between psilocybin and psychiatric
disorders. However, the possible role of hallucinogens in the elicitation and exacerbation of
existing psychosis, other psychiatric disorders and ongoing visual perceptual disturbances
needs to be further determined (Abraham et al., 1996; Halpern and Pope, 1999). There may be
a similarity here with the use of cannabis that is thought to provoke psychosis in sensitive
individuals (van Amsterdam and van de Brink, 2004). The use of drugs by psychiatric patients
21
and persons with a genetic predisposition for psychiatric disorders, i.e. persons with psychiatric
disorders in the family, is not recommended at all.
PUBLIC HEALTH
5. Prevalence of use / increase in use (inter)nationally
Estimates of the prevalence of hallucinogenic mushroom use in the EU are significantly lower
than for cannabis. The prevalence for 'ever use' of mushrooms is estimated in some countries
to be as high as for ecstasy among 15‐ to 16‐year‐old schoolchildren. Surveys in 12 EU Member
States indicate that among 15‐ to 24‐year‐olds, 'ever use' of hallucinogenic mushrooms ranges
from less than 1% to 8%. In the Netherlands in 2003, the 'ever use' of hallucinogenic
mushrooms among 15/16 year old pupils was 5% (Hibell et al., 2003). Another EMCDDA study
(EMQ 2000‐2003) reported an 'ever use' prevalence of mushroom use in the Netherlands in
2001 among 15‐24 year olds of 8%; a last year prevalence of 2%, and a last month prevalence
of 0.3%.
Hive and Nabben (Hive and Nabben, 2007) reported a decreasing trend in mushroom use,
suggesting that the consumption of magic mushrooms is mainly initiated because the individual
simply wants to experiment. Ever use' by young adolescents aged 14‐16 years decreased from
5% in 1997 to 3% in 2002. The figure of 3% 'ever use' of magic mushrooms was confirmed in
2004 (Monshouwer et al., 2004). In somewhat older adolescents the use decreased from 11%
to 6% in the same period. Other data among young pub‐goers show a similar trend: decrease
of the use of magic mushrooms in the last year from 6.3% in 2002.
2000 to 2.9% in 2005.
6. Vulnerability, age, experience in use, knowledge and 'setting' of users
The effects (intended effects and side effects) of mushrooms depend on the dosage, the
individual reaction to and sensitivity to psilocybin, previous experience, and the setting in
which the drugs are used. Furthermore, within the same person, subjective effects vary greatly
depending on the time of use (Jacob and Fehr, 1987; O'Brien, 1996; Pechnick and Ungerleider,
2005). The acute toxicity of psilocybin is estimated to be low, so that fatal intoxications related
to the consumption of hallucinogenic mushrooms rarely occur. Combined use of mushrooms
with other psychoactive substances, including alcohol, is contraindicated because it increases
the risk of harmful effects and 'bad trips' (Satora et al., 2005). Many of the reported incidents
(see below) involved combined use. In this context, it is noteworthy that it has been popular
among young users in Slovakia for 20 years to combine herbal drugs, including Psilocybe, with
alcohol (the authors did not provide any further information).
Although there are no numbers about how many users have experienced a 'bad trip', it is these
users who are likely to contact emergency services. In such cases, users are usually extremely
anxious, extremely excited, confused and disoriented. Furthermore, they have impaired
judgment and are less able to concentrate. In severe cases, acute psychoses can occur,
including bizarre and frightening images, severe paranoia and total loss of sense of reality that
2
can lead to accidents, self‐injury and suicide (attempts). A 'bad trip' is usually followed by
flaccidity, sadness, depression, paranoid interpretations etc., which can last for days, weeks or
even months. Some of these symptoms are probably associated with the use of other drugs.
Delayed and chronic psychoses may be triggered by hallucinogenic mushrooms; in certain
individuals, use may bring out underlying psychoses or personality disorders. Flashbacks may
also occur although less frequently than after taking LSD. These episodes are generally
perceptual changes or pseudohallucinations.
Documented serious and fatal incidents
1. A British magazine aimed at the dance club audience conducted a survey among users
of hallucinogenic mushrooms in 2005. It was found that almost a quarter of the
hallucinogenic mushroom users had experienced a panic attack in the last year
(Mixmag, 2005).
2. A case in March 2004 in Manchester, United Kingdom, where a 31‐year‐old man died
from a fall from the window of a flat after consuming 'Hawaiian' psilocybin‐containing
mushrooms combined with alcohol (Manchester Evening News, 28.05.2005). An
autopsy report confirmed that the mushrooms had contributed along with alcohol: the
amount of alcohol consumed was 2 ½ times the limit that applies to participation in
traffic (in the United Kingdom this limit is 0.8 per mille).
3. In 2005, a 33‐year‐old man died in the Irish town of Dun Laoghaire after falling off the
4th floor after consuming hallucinogenic mushrooms (Irish Independent, 02.03.2006).
Prior to the mushroom use he had drunk beer with his friends.
4. A mushroom‐induced fatal case was reported by Asselborn et al. (Asselborn et al.,
1999). After a trip to the Netherlands, a young French girl had eaten a handful of
psilocybe mushrooms together with a non‐alcoholic drink. Soon afterwards she died
after trying to 'fly' out the window of her room on the 2nd floor. The victim was not
known to the investigative authorities as a chronic drug addict. The autopsy showed
that the trauma incurred was the cause of death, while post‐mortem toxicological
analysis showed that the trauma was the cause of death.
indicated the consumption of psilocybin and cannabis. The concentrations of psilocin
were 0.06 mg/l in cardio blood and 0.22 mg/l in femoral venous blood. In addition, the
following cannabinoids were found in her blood: THC (0.03 mg/l), 11‐OH‐THC (0.008
mg/l) and THC‐COOH (0.09 mg/l).
5. Fatal case in Amsterdam 2007 (IGZ, 2007). After a 17‐year‐old French girl had jumped
off a building in Amsterdam, the body was only examined and on that basis the corpse
was released. Neither an autopsy (no suspicion of a crime) nor a toxicological
examination was carried out. There was only a rumour ('people say that') of mushroom
use, but this was never confirmed by autopsy. It should be noted that ‐ despite warnings
to use magic mushrooms in a quiet, relaxed environment in the presence of an
acquaintance ‐ this girl apparently used 'it' in a hotel boat and then ran away in panic.
This suggests no quiet surroundings and no surveillance. Moreover, the (co‐)use of
23
alcohol and poly‐drug use cannot be excluded. Police sources indicate that the girl had
family relational problems, which are circumstances under which the use of
hallucinogens in general is strongly discouraged.
6. A toxicologically unconfirmed fatal case, which should be attributed to the use of a
large quantity of mushrooms, concerns the death of a 27‐year‐old Frenchman
(Gonmori and Yoshioka, 2002). On the other hand, the authors indicate hypothermia
in winter (which is a typical alcohol‐related cause of death) as the cause of death.
7. In 2004, a case of suicide was reported in the Czech Republic in which the presence of
'hallucinogenic mushrooms' was confirmed by autopsy (EMCDDA, 2006).
The following fatal mushroom‐related cases in the Amsterdam area are mentioned in the 2007
report of the GGD (Buster and van Brussel, 2007):
8. In 2002, a 24‐year‐old Frenchman died after he jumped out the window of his hotel
room during a toadstool psychosis.
9. In a similar case, in 2002, a 23‐year‐old American, who was aggressive and disinhibited
after consuming magic mushrooms, jumped out of the window of his hotel room.
10. Less well documented is a case of a person who, under the influence of magic
mushrooms and wine, got into the water and later drowned.
11. A barely further documented case in 2005, when someone probably died as a result of
combined use of magic mushrooms, cocaine and heroin.
Interaction of magic mushrooms with other drugs.
A possible mechanism of the interaction of magic mushrooms with alcohol is the inhibition of
the enzyme MAO (monoamine oxidase). Both psilocin and psilocybin are compounds with a
structure derived from dimethyltryptamine (DMT). Normally, such DMT compounds are
converted by the enzyme MAO, which catalyzes the oxidative deamination of biogenic amines
making them biologically inactive. However, the conversion of DMT compounds is inhibited by
MAO inhibitors. Alcohol consumption can lead in vivo to the formation of an indirect
endogenous MAO inhibitor, namely acetaldehyde. Acetaldehyde, the primary metabolite of
ethanol, reacts in vivo with endogenous biogenic amines, producing the MAO inhibitors
tetrahydroisoquinolines (TIQs) and ß‐carbolines (tryptolines). In this way alcohol can reinforce
the mushroom‐induced 'trip' (and its side effects!). Although cocoa also contains MAO‐
inhibitors, their quantity in plain chocolate is clinically irrelevant.
Tobacco use is also associated with lower levels of MAO in the brain and peripheral organs
(long‐term effects; recovery after smoking cessation) (Fowler et al., 1996; van Amsterdam et
al., 2006). Smokers may therefore experience more desirable and undesirable effects of magic
mushrooms than non‐smokers. Finally, pharmacodynamic interaction between alcohol and
magic mushrooms cannot be excluded.
Barrett et al. (Barrett et al., 2000) found that alcohol had little effect on the subjective
mushroom effects: of the 15 drug users, 2, 1 and 12 persons reported a reduced, increased and
no change in the psilocybin (mushroom) response by simultaneous alcohol consumption,
2
respectively. On the other hand, mushroom use was found to suppress certain subjective
effects of alcohol (especially the sedative effects) (Barrettt et al., 2000). With simultaneous
mushroom consumption the effects of alcohol were reduced, amplified and experienced
without change by 9, 1 and 5 persons, respectively. In LSD users the interactions were more
pronounced. Of the drug users, 13 reported a complete blockade of the subjective alcohol
effects, while 2 reported a reduced response rate. On the other hand, simultaneous alcohol
consumption did not influence the subjective effects of LSD in any of the users (Barrettt et al.,
2000). This reduction in the effects of alcohol often has the effect that individuals drink more
than normal without recognizing the normal symptoms of alcohol intoxication. In some cases
mushrooms are deliberately used to continue 'partying', but most use mushrooms because of
the 'psychedelic experience'. Alcohol and mushrooms affect both brain areas involved in
behavioural regulation and both may have additive or synergistic effects leading to behavioural
disinhibition. However, this phenomenon has not yet been properly researched.
Although alcohol has not been proven to increase negative experiences from mushroom use,
there are reports that this combination is associated in a small proportion of users with very
unpleasant subjective effects and panic reactions. In most cases, however, the combination is
apparently fairly well tolerated. Currently, very little information is available to predict which
users are most at risk of experiencing severe adverse effects. In short, although mushrooms
are associated with 'bath‐trips', it is not at all clear to what extent alcohol contributes to this.
Nevertheless, alcohol should at least be considered here as a complicating factor and it is
prudent not to use alcohol at the same time as mushrooms (Barrett, 2007).
7. Availability of adequate user information, presence and quality of product leaflets,
misleading information, appearance of the product
In the Netherlands, many smartshop dealers issue warnings. For example, images with Dutch
and English texts warn people under the age of 18 not to use the product. They also warn not
to use mushrooms when pregnant, on medication, suffering from mental illness, driving a car
or operating machinery. The texts also warn against using the product in combination with
alcohol. In addition, the telephone number of a UK Drug Help line is on the label, suggesting
that the information is also directed to UK customers.
The quality and quantity of information provided by the trader varies (CAM, 2000). As a rule,
the labels do not provide information on the maximum shelf life, the nature of possible side
effects and the quantity (concentration) of the active substances (psilocybin and psilocin).
In a snapshot of 21 online shops visited in January 2006, the majority did not warn against the
use of hallucinogenic mushrooms if drugs were used and/or the undesirable combination with
alcohol or other drugs such as stimulants. Only 1 in 3 advises against the use of hallucinogenic
mushrooms if the user suffers from depression or psychosis. About half of the sites provide
information on dosage and contain information on safe use (e.g. consume on an empty
stomach, drink during the trip and consume in a quiet and safe environment). The street(s), a
busy hotel room, the presence of loud music or bright light are or do not provide a quiet
'setting'. Most sites provide information about desired effects, but few inform on how to
25
increase the desired effects. The vast majority do not give information about possible negative
side effects. Only a minority of sites explicitly mention that nausea and dizziness can occur
during use. Although this snapshot is not representative for all online shops, it indicates that
the information from these traders distorts the spectrum of effects and that the amount of
information varies enormously.
In response to the 2007 GGD report (Buster and van Brussel, 2007), in April/May 2007, after
consultation with stakeholders, the Drugs Advisory Office advised to produce a flyer ‐analogical
to the 'flyers' on cannabis distributed in coffee shops‐ with advice on the safe use of
mushrooms. In addition, the Drugs Advisory Agency advised (1) to organise a national course
on "Responsible mushroom and other psychoactive drug sales" for smartshop traffickers, and
(2) to consider whether a 'policy' could be defined to reduce the number of smartshops in
Amsterdam.
The VLOS (Vereniging Landelijk Overleg Smartshops) will investigate how cooperation with
local health services (the GGD‐en) can be improved. Possibly VLOS (1) will open its website to
serve its members with product information and (2) disseminate certain information about the
risks of mushroom use by tourists (VLOS, 2007).
8. Product Availability
ESPAD school surveys in 2003 reported that 4% to 28% of 15‐ to 16‐year‐old schoolchildren
believe that hallucinogenic mushrooms are 'very easy' or 'quite easy' to obtain. Less than 10%
of students in Cyprus, Finland, Greece, Hungary, Latvia, Lithuania, Romania and Turkey
reported easy access to hallucinogenic mushrooms and more than 20% of students in the Czech
Republic, Ireland, Italy, Poland and the United Kingdom. Kingdom reported easy access. The
levels of observed availability reflect the estimates of prevalence, although they are higher.
Despite the absence of legal penalties to control supply, only 16% of students in the
Netherlands reported easy access to hallucinogenic mushrooms.
The mushroom market is in full swing. For example, following the recent ban of psilocybin and
psilocin containing mushrooms in the United Kingdom. Kingdom a growing interest of traders
has been aroused in legal types of hallucinogenic mushrooms, like Amanita muscaria ('fly
agaric') (Black Poppy, 2006).
KLPD data: Amsterdam has about 35 smart shops (some souvenir shops also sell magic
mushrooms), Arnhem: 2‐3, Bergen op Zoom: 3, Roozendaal: 3, The Hague: 5 (KLPD, 2007). On
the website [Link] 112 Dutch smartshops can be found, of which 26 are
located in Amsterdam. Presumably the number of smartshops is much higher than this site
indicates, namely about 200.
9. Reliability of the product (chemical purity, production process, toxicity of by‐products,
place of production)
Mushrooms have a great variety of potency; their potency depends on the species or variety,
origin, growing conditions and harvest date. In general, the most potent species (e.g. Psilocybe
semilanceata) contain up to 1% g/g psilocybin (10 mg psilocybin per 1 g of dried mushrooms),
2
although higher concentrations than 1% g/g have also been reported for other species (e.g.
Psilocybe azure scens, Psilocybe bohemica). Psilocybe cubensis (known as common psilocybe)
may contain up to 0.6% psilocybin and psilocin.
Hallucinogenic effects are induced by a dose of about 410 mg psilocybin (Beck et al., 1998),
which is equivalent to 50‐300 µg/kg body weight (Hasler et al., 2004). Thus, the minimum
weight of mushrooms needed to obtain the desired effect is about 1 gram of dried or 10 grams
of fresh mushrooms.
According to the English site Erowid the recommended dose of mushrooms is between 1 and
5 grams of dried mushrooms, while the dose for fresh mushrooms is 10x higher (10‐50 grams)
(Erowid, 2006). However, according to Erowid, these dosages should be used with caution as
the concentration of active substances can vary. Moreover, the mushrooms may contain more
than one active ingredient. On the other hand, repeated use can cause rapid tolerance for both
physiological and psychological effects. It should be noted that finding an optimal dose in case
of oral intake is not always easy, because after consumption it always takes some time before
the desired effect occurs.
Some mushrooms may contain significant amounts of phenylethylamine (up to 150 µg/g wet
weight in Psilocybe semilanceata) (Beck et al., 1998). Phenylethylamine is a sympathomimetic
amine similar in chemical structure to amphetamine. Phenylethylamine in the magic
mushroom may therefore be responsible for cardiovascular effects (tachycardia) and other
adverse reactions, such as dizziness and anxiety. Phenylethylamine is unlikely to be used as a
drug. The variation in the concentration of phenylethylamine in mushrooms is much higher
than that of psilocybin, which explains why the mentioned side effects occur so rarely. Finally,
it is worth mentioning that the psychoactive substances psilocin and psilocybin appear to be
more stable in the dried than in the fresh mushrooms; after 4 weeks of storage of fresh
mushrooms, VWA was only able to detect very small amounts of both components (VWA,
2007).
10. Reliability of distribution, sales and traders
Users buy their magic mushrooms at smart shops or via the internet. According to a 2001 study
among a representative group of Dutch youth, who had used mushrooms in the last year, 64%
had bought the mushrooms in smartshops (Abraham et al., 2002).
It is estimated that in the Netherlands there are currently (2007) about 200 addresses
(including smartshops, excluding internet addresses) where magic mushrooms are for sale (the
exact number is not known). The smartshops legally sell mainly natural products, including
mushrooms. However, mushrooms are also sold in some coffee shops and some souvenir
shops. In some regions 'mushrooms' deliver hallucinogenic mushrooms to the home (Riper and
de Kort, 1999). Some 'head shops' (shops selling drug paraphernalia such as pipes) and 'grow
shops' (shops offering material for growing marijuana at home) also sell hallucinogenic
mushrooms.
According to the CAM report from 2000 (CAM, 2000) the turnover of mushrooms in smartshops
is estimated at 50%. Although figures on the turnover of smart shops are missing, the estimate
27
in 2007 is still 30‐50% depending on the type of smartshop. In Dutch headshops or smartshops
the different Psilocybe cubensis varieties are sold the most, especially the Psilocybe mexicana,
which does not grow wild in Europe.
11. Nature and frequency of incidents, reported by First Aid posts of hospitals and national
poisoning information centres The number of reports of people seeking help or medical
assistance due to mushroom use ‐ compared to other drugs ‐ is very low. Toxicology
Information Centers in Slovakia reported that the number of intoxications with all plant‐based
drugs increased five times between 2001 and 2002. The number of mushroom poisonings (not
further specified) was 4.3% of the total number of reports (Kresanek et al., 2005). In Poland, a
toxicology centre reported five psilocybin/psilocin intoxications (2 in 2003 and 3 in 2004).
A data overview from the Swedish poisoning information centre for 15 years (1980‐1995)
contained only 25 cases of patients with intoxication by psilocybe‐containing mushrooms (Beck
1998). In addition to the usual symptoms, there were the following: anxiety (10 patients);
excitement (4 patients); redness (3 patients); dizziness and vomiting (3 patients), and
'flashbacks' (2 patients). A more recent report from the Swedish Poisons Information Center
reported that in the last five years the number of cases remained relatively low and stable at
around 30 to 40 per year. However, the coverage and capacity of reporting bodies and case
definitions vary widely across the EU, making it difficult to interpret the findings or draw firm
conclusions (EMCDDA reporting form; Detecting, tracking and understanding emerging trends
from 2005).
The Dutch NVIC (Dutch Poisoning Information Centre) reported that the number of requests
for information on magic mushrooms is approximately 60 per year and was stable over the
years 2001 to 2006 (NVIC, 2007).
In the period 2004‐2006, the Dutch NFI (Netherlands Forensic Institute) investigated whether
psilocybin was present in the urine of persons who had died under suspicious circumstances,
died unnaturally, were involved in traffic accidents where drugs were involved, and in criminal
cases where persons had been drugged. Psilocybin (observed in urine) was probably involved
in only 4 out of a total of 4636 cases investigated (NFI, 2007).
The database of the Trimbos Institute "Death due to hallucinogens 1996‐2005", which is based
on data from Statistics Netherlands (Centraal Bureau voor de Statistiek), indicated that there
were only two cases of hallucinogen‐related causes of death in the year 2005 (no case in the
other years). Mortality due to hallucinogens falls within the EMCDDA definition, but there is no
special code (classification) referring to psilocybin or psilocin. The above evaluation of 2 cases
refers to the code that refers to all hallucinogens, including LSD. CBS reports are unclear
whether the mortality due to "other and unspecified psychodysleptics" includes the additional
fatal cases of hallucinogen‐related causes of death, but this is likely to be the case. Thus, there
are probably a few more mushroom‐related causes of death that have been reported (van Laar,
2007).
Apart from the recent Amsterdam GGD report, the Health Care Inspectorate received no signals
about incidents involving psilocin or mushrooms containing psilocybin in the past five years
2
(IGZ, 2007). The GGD report mainly concerns mushroom‐using tourists and to a much lesser
extent regular Dutch mushroom users. The remarkable thing about these signals is that despite
the report of mushroom use, this use has never been confirmed by toxicological research. Also,
the concomitant use of other psycho‐active drugs is never routinely investigated in such cases.
One may therefore wonder (1) whether the users, who were transported by ambulance to the
hospital, were telling the truth about what they had used, and (2) whether the cause of their
problems may be interpreted as being caused by the mushrooms (or other drugs) and not by
their behaviour. With regard to point 2, one should also think of the importance of 'Drug, set
and setting'.
Mushroom poisoning is very common in Poland, especially in summer and autumn, and is
associated with the traditional search and preparation of wild mushrooms. In autumn 2004,
four intoxications following the consumption of Psilocybe mushrooms were reported by the
Department of Clinical Toxicology in Krakow (Satora et al., 2005).
One of the conclusions of the Amsterdam GGD registration (Buster and van Brussel, 2007) was
that alcohol use is much more problematic (2100 times assistance from an ambulance) than
mushroom use (70 times). The high number of ambulance assistance is mainly due to the high
number of foreign tourists (based on incomplete registration, 92% of mushroom 'victims' of
foreign origin), who mainly came from the United Kingdom and Italy (30% and 13% of the total
number of 'victims', respectively). Most mushroom related incidents took place during the
summer. In contrast to the incidents related to cocaine, heroin and XTC, the mushroom related
incidents were relatively harmless: treatment in intensive care took place for the first group in
11‐20% of the cases, and for the paddo group in 1.5% (2 out of 148) of the cases. More
importantly, the combined use of mushrooms with alcohol or cannabis was most likely the
main cause of the incidents (however, no exact data are available in these cases). Finally, the
mushroom incidents took place mainly (95%) in the public domain (street, pubs, hotels),
whereas 30% to 40% of the incidents related to cocaine, heroin, XTC and alcohol took place in
the private domain.
Comments on the GGD report
Approximately 350,000 inhabitants of Amsterdam are 40 years of age or younger. The
assumption that magic mushrooms are mainly used by people in this age group plus the 'last
year' prevalence of mushroom use by the Amsterdam population in 2001 of 2.2% (Abraham et
al., 2002) imply that more than 7,700 inhabitants of Amsterdam have ever used magic
mushrooms in the past year (15,000 in 2 years).
Using cheap flight options, many young tourists now visit Amsterdam; in 2006, the number of
tourists visiting Amsterdam had risen to about 1.5 million. In the two years that the Municipal
Health Service carried out the study, an estimated two million young tourists visited
Amsterdam. If one assumes that ten percent of them actually used or tried magic mushrooms
(this figure of 10% is no more than an estimate; after all, no data are known about this), then
the estimated number of mushroom‐using tourists in these two research years is 200,000.
29
Nevertheless, only 63 out of 200,000 foreign mushroom users were assisted by the GGD
(0.03%).
In comparison, seven Amsterdammers (8% of the 70 incidents related to mushroom use)
needed support from the GGD ambulance staff (Buster and van Brussel, 2007), which suggests
that only 0.05% (7 of 15.000) of the Amsterdam mushroom users experienced problems when
using magic mushrooms. However, the conclusions drawn here should be treated with great
caution, because:
1. It cannot be excluded that the mushroom users living in Amsterdam used other ways
of medical help (family doctor, first aid, helplines) when they were confronted with
problems during the use of magic mushrooms. Unfortunately, there are no figures
available (at the Amsterdam Municipal Health Service or other agencies) about these
forms of medical help.
2. The frequency of mushroom use by the Dutch group was probably higher than 1x per
year, which implies that the number of times this group used magic mushrooms is much
higher than 15.000 times. Therefore, the above calculation of the GG&D support is
probably much lower than 0.05%.
3. The numbers of Dutch mushroom users and mushroom‐using tourists are estimated
numbers, which is a weak basis for these conclusions.
This indicates once again the importance of a quiet 'setting' to use mushrooms, i.e. no street
(corner), no busy hotel room, no loud music, no bright light. Various stakeholders recommend,
among other things, to better inform consumers with 'flyers' and brochures that warn in
different languages not to use mushrooms together with alcohol and to ensure a quiet setting.
At the request of the Ministry of Health, Welfare and Sport, the Municipalities of Rotterdam,
Utrecht and The Hague replied that they had received no reports of fatal accidents related to
mushroom use in the past five years (Ministry of Health, Welfare and Sport, 2007).
According to the Adviesburo Drugs, the harmful health effects of magic mushrooms do not
need to be reconsidered, because in recent years ‐ apart from tourists ‐ there have been no
signs that Dutch users have appealed to health care because of magic mushroom use.
PUBLIC ORDER AND SAFETY
12. Nature and frequency of nuisances to citizens related to the use and sale of the drug
In 2005 and 2006 respectively, forensic physicians in Amsterdam registered 30 and 36
detentions at police stations that were related to mushroom intoxication. The main reasons
for confinement were public nuisance (71%) and violation of traffic rules (27%). By way of
comparison, the number of inclusions for alcohol abuse was 1846 (Buster and van Brussel,
2007). The National Criminal Intelligence Service (NCID) contacted several municipalities in
2000, but found no evidence of public nuisance related to the use of hallucinogenic mushrooms
or as a result of the sale of these products.
2
13. Does use of the drug lower the threshold of violence in the user?
In theory, a user can behave recklessly during a paddo trip.
Panic attacks during a 'bad trip' can provoke aggressive behaviour.
14. Does the drug affect the ability to react (driving a car, operating machinery)?
Psilocybin (100‐250 µg/kg orally) affects time and space perception. Furthermore, psilocybin
impairs the sense of synchronisation and rhythm and lowers working memory and subjective
consciousness (Hasler et al., 2004). All these effects negatively influence the ability to drive cars
and operate machines (Wittmann et al., 2007). Indeed, LSD use was one of the risk factors (like
alcohol abuse) to get involved in a traffic accident. In 24% of the cases of 'drink‐driving',
marijuana and/or LSD was also used (Morrison et al., 2002).
CRIMINAL INVOLVEMENT
15. Is (organised) crime involved in the production and trafficking of the drug?
When a Dutch risk analysis was carried out in 2000, a number of smartshop owners were
suspected of having links with the synthetic drugs 'mafia' and were not prepared to name the
mushroom suppliers (CAM, 2000). In 2004, seizures of hallucinogenic mushrooms were
reported by police or customs in the Czech Republic, Estonia, Germany, Greece, Hungary,
Lithuania, the Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia and Sweden (EMCDDA
reporting forms; Detecting, tracking and understanding emerging trends, 2005). Estonia
reported the confiscation of 14 postal consignments of psilocybin mushrooms, their spores or
their mycelium (EMCDDA, national report Estonia, 2005). Reported trends of seizures of
hallucinogenic mushrooms varied. Data from Swedish and German customs showed an
increase in 2004, while Norway reported a decrease. The largest seizures were reported by
Poland, where police found 11.5 kg of hallucinogenic mushrooms in 2004.
After hallucinogenic mushrooms were classified as a Class A drug in the United Kingdom,
seizures were also registered by the investigative authorities. One report concerned the seizure
in Glasgow in 2005 of hallucinogenic mushrooms worth £6,000
([Link] 20.07.2005). In Cyprus, hallucinogenic
mushrooms were seized for the first time in 2006. These had apparently been purchased from
a Dutch trader (national focal point, Cyprus).
There is very little data available on drug law violations. In the Czech Republic, the National
Police Drugs Team reported a total of nine offences related to magic mushrooms in 2003 and
2004. In Greece, 37 and 20 offences related to hallucinogenic mushrooms were recorded in
2003 and 2004 respectively (reporting form Detecting, tracking and understanding emerging
trends, Czech Republic, Greece, 2005).
In the United Kingdom the recent legal measures against hallucinogenic mushrooms appear to
be followed by an increased interest of traders in selling alternative, legal types of
hallucinogenic mushrooms, such as Amanita muscaria ('Fly agaric'). The active chemical
31
components in Amanita muscaria are known to have a high toxicity and some closely related
Amanita species are highly toxic and can cause fatal poisoning. The use of these species
therefore entails a high health risk, which calls for additional legal and preventive measures.
The 'briefing' of the National Police Services Agency (Korps Landelijke Politiediensten) and
National Network Drugsexpertise (NND) from 2007 (KLPD, 2007) does not indicate any
involvement of organised crime in the trade in and cultivation of mushrooms. Most of the
offences that attracted the attention of the investigative services were related to the export of
dried mushrooms. According to the Dutch Opium Act such an export is prohibited. An
important case concerned the professional production and sale of mushrooms processed in
chocolate bars in order to export these products worldwide. For the rest, there is no relation
between mushroom growers or the mushroom trade and criminals; hardly any violations of
the legislation on mushrooms were found (two violations in a 'shop' by selling dried (?)
mushrooms; the shop was temporarily closed); in one region there were some seizures (the
result of the NFI analysis is not yet known). Through courier services, the police regularly
received parcels (number not declared) with foreign destinations that turned out to be
undeliverable. These parcels contain dried mushrooms. The police have no information on the
number and locations (and quantities produced) of mushroom growers. The police at the
Belgian border (Hazeldonk) encounter very regularly (frequency was not reported) exports of
dried mushrooms to France, Belgium and Luxembourg, all of which are confiscated.
Customs at Schiphol Airport occasionally confiscates small quantities of mushrooms (order of
magnitude: a few kilos). In June 2006 a considerable catch was made. A Dutch company has
been exporting fresh mushrooms to a large number of countries all over the world for the past
year. In May 2006 a shipment from this company with destination Turkey was checked and this
shipment turned out to contain 160 grams of dried mushrooms (described as "Cubensis
Mexicana Kilo"). Because the analysis indicated "psilocin", the shipment was seized. In the
consignor's warehouses, customs found and confiscated a further 150 kilograms of dried
mushrooms, bags of ground mushrooms, hundreds of kilograms of chocolate containing
psilocybin, and machines for making chocolates. A total of 6,992 grams of mushrooms were
found in 333 postal consignments with destinations such as France (84%), Spain (6%), Germany
(5%) and the United Kingdom (2%). The liaison of the 'Zollkriminalamt Deutschland' (ZKA;
German customs) reported that in the years 2006‐2007 only one large mushroom shipment of
27 kg was confiscated in Germany. This shipment was transported by order of a Dutchman by
two Danish citizens from Amsterdam to Denmark (KLPD, 2007). Finally, it should be noted that
the investigation and prosecution in the Netherlands is not really a priority and therefore fewer
cases are known, because if you do not look at them you will not see it.
16. Is (organised) crime involved in the production and trade of raw materials?
The police at the Belgian border (Hazeldonk) observe that there is trade in 'nursery boxes'
from the Netherlands to the southern countries (their purchase is not prohibited in the
Netherlands) (KLPD, 2007).
2
In the Netherlands the production of fresh mushrooms (growing mushrooms) is not illegal,
while the processing (drying) of mushrooms is illegal. However, it is conceivable that certain
individuals will abuse the legal cultivation and show criminal behavior by drying these
mushrooms and then exporting them.
Overige informatie: huidige legale status van paddenstoelen
In Nederland, zijn psilocine en psilocybine illegaal omdat zij volgens het Verdrag van de
Verenigde Naties over Psychotrope stoffen uit 1971 op lijst I van de Opiumwet zijn geplaatst.
Paddenstoelen zijn echter als zodanig niet opgenomen, omdat ze in de VN Verdrag niet
genoemd worden. Na consultatie van Wetenschappelijk Comité en de juridische afdeling stelde
het secretariaat van de International Narcotics Control Board (INCB), de instelling van de
Verenigde Naties die toeziet op de bestrijding van productie, vervoer en handel van verboden
drugs, dat planten (natuurlijk materiaal) die psilocine en psilocybine bevatten, thans niet onder
de Conventie on Psychotropic Substances van 1971 vallen. Dientengevolge staan preparaten
van deze planten ook niet onder internationale controle zijn daarom geen onderwerp in enig
artikel van het VN Verdrag uit 1971 (IGZ, 2007). Niettemin wordt sinds een uitspraak van de
Hoge Raad het drogen van paddenstoelen als een bewerking beschouwd. Aldus zijn in
Nederland gedroogde paddenstoelen gedefinieerd als een preparaat dat psilocybine bevat.
Dergelijke preparaten worden in wettelijke zin gezien als een actieve stof; verse paddo’s
worden niet gecontroleerd door wetgeving.
In Europa worden de internationale verdragen over paddenstoelen op verschillende wijze
geïnterpreteerd (EMCDDA, 2007; zie Tabel 1). In sommige landen, worden hallucinogene
paddenstoelen specifiek als een te controleren substantie in de wet genoemd en wordt de
verkoop of bezit van paddo’s uitdrukkelijk verboden. Sommige landen behandelen de
paddenstoelen als de te controleren substantie die bestaat uit psilocine of psilocybine, terwijl
andere landen meer in de geest van de wet handelen; zij verbieden het kweken, het bezit en
de verkoop van paddo’s slechts als misbruik in het geding is. Hun voorwaarden zijn dan ook
beschouwelijk: verse paddenstoelen dienen niet als illegaal te worden beschouwd, maar
bewerkte of gedroogde paddenstoelen wél. De interpretatie van de term “bewerkt” of
“behandeld” kan nog een complexe aangelegenheid zijn voor de rechters. Weer anderen
gebruiken in de wettekst een allesomvattend begrip, die geen uitzondering toelaat, zoals
“cultivering van enige plant teneinde een psychoactieve substantie te produceren”). Een aantal
landen tenslotte hebben een vage wetgeving, omdat er domweg zo weinig paddozaken bij het
gerechtshof dienen.
Tabel 1. Overzicht van de paddowetgeving in Europese lidstaten.
33
Belgium Specifically prohibited by the Specifically prohibited by Specifically prohibited (as is
criminal law of 24 the Royal Decree of offer for sale) by the
February 1921 22/1/1998 Royal Decree of
22/1/1998
2
Cyprus Prohibited by Law 29/77 Treated as psilocin and Treated as psilocin and
which prohibits the psilocybinprohibited by psilocybin‐prohibited by
cultivation of any plant or Law Law 29/77
product from which such 29/77
substances (class A controlled
substances) may be
extracted.
substances.
35
Slovenia Treated as psilocin Treated as psilocin Treated as psilocin
2
Norway Prohibited according to the Prohibited according to Prohibited according to the
Regulation regarding the Regulation regarding Regulation regarding
Narcotics etc. Narcotics etc. Narcotics etc.
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Bijlage 2 Beschrijving van het risicoschattingsproces
1 Samenstelling risicoschattingscommissie
hr. drs. W. Best, Inspectie voor de Gezondheidszorg (IGZ) 1,2,3) hr. A.J.J. de Bruin,
Korps Landelijke Politiediensten: Unit Zuid‐Nederland
(Synthetische Drugs) 1,2,3) hr. drs. G.H.A. van Brussel,
GG&GD Amsterdam 1,2,3)
mw. mr. E. van Duijnhoven, Ministerie van Justitie: Openbaar Ministerie 1) hr. A. Elissen,
Nationaal Netwerk Drugsexpertise (NND) 1)
mw. mr. J.H. de Jager, Ministerie van Volksgezondheid, Welzijn en Sport: Directie
Voeding, Gezondheidsbescherming en Preventie; tevens voorzitter 1,2) hr. dr. D.J.
Korf, Universiteit van Amsterdam: Criminologisch Instituut Bonger 1) mw. dr. M.W. van
Laar, Trimbosinstituut, Focal Point 1,2,3)
hr. ir. M. Martena, Ministerie van Landbouw, Natuur en Voedselkwaliteit: Voedsel en
Warenautoriteit (VWA) 1,2,3)
mw. mr. M.H.J. van de Mortel, Ministerie van Justitie, Landelijk Parket. 1) hr. dr. R.J.M.
Niesink, Trimbosinstituut, Drugs Informatie en Monitoring Systeem
(DIMS) 1,2,3) hr. dr.
E.J.M. Pennings 1)
mw. dr. A.J. Poortman‐van der Meer, Ministerie van Justitie: Nederlands
Forensisch Instituut (NFI) 1) mw. mr. J. de Quartel, Ministerie van Justitie,
Directie Rechtshandhaving en
2
Criminaliteitsbestrijding 1)
mw. drs. I. de Vries, Rijksinstituut voor
Volksgezondheid en Milieu: Nationaal
Vergiftigingen Informatie Centrum (NVIC) 1,2,3) mw. drs. W.M. de Zwart,
Ministerie van Volksgezondheid, Welzijn en Sport:
Directie Voeding, Gezondheidsbescherming en Preventie 2,4) hr. drs. T. Nabben,
Universiteit van Amsterdam: Criminologisch Instituut Bonger 2,3,4)
hr. mr. J.L. Luijs, Ministerie van Justitie, Directie Rechtshandhaving en
Criminaliteitsbestrijding 2,4)
mw. drs A. van Riel, Rijksinstituut voor
Volksgezondheid en Milieu: Nationaal
Vergiftigingen Informatie Centrum (NVIC) 1,2) dr. L.A.G.J.M. van Aerts, Rijks
Instituut voor Volksgezondheid en Milieu, tevens secretaris 1,2)
dr. J.G.C. van Amsterdam, Rijks Instituut voor Volksgezondheid en Milieu, tevens
secretaris 2,4)
1)
Lid 2)
Aanwezig tijdens vergadering op 7 juni 2007
Deelname aan scoring van de risico’s 4)
3)
Plaatsvervangend lid
2 Procedures voor risicoschatting
Er zijn drie procedures, die slechts in snelheid verschillen:
A. Een zeer snelle procedure, (fast assessment) voor situaties die een acuut
volksgezondheidsrisico geven (bv. atropine). Binnen 24 uur dient deze procedure te zijn
afgerond.
B. Een redelijk snelle procedure, (moderate assessment) voor situaties waarin het
volksgezondheidsgevaar niet acuut, maar wel op korte termijn aanwezig is. Een redelijke
termijn lijkt 12 dagen te zijn.
C. Een procedure op aanvraag, waarbij geen sprake is van een strikte beperking in
tijdstermijn (preventive assessment). Deze procedure kan enkele maanden duren.
De stappen in de drie procedures zijn gelijk:
1. De melding van een (vermoedelijke) nieuwe drug of de aanvraag tot een risicoschatting
komt binnen bij het coördinatiepunt via het netwerk. Via Europol of het Focal Point
(Trimbos) kunnen meldingen van andere Lidstaten binnenkomen.
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2. Het coördinatiepunt legt aan het dagelijks bestuur voor of een procedure wordt opgestart.
Zo ja, dan verzamelt het coördinatiepunt informatie over de nieuwe drug via haar
netwerk. Op basis van de binnengekomen informatie wordt een informatierapport
opgesteld. Het informatierapport wordt aan alle leden van de commissie of aan een
selectie hiervan verstuurd. (4 dagen)
3. Op basis van deze informatie voeren de leden individueel een risicoschatting uit via het
scoreformulier met de vastgestelde criteria. Indien de procedure dit toelaat, wordt de
uitkomst gezamenlijk besproken. (2 dagen)
4. De ingevulde risicoschattingsformulieren worden verzameld en geëvalueerd door het
coördinatiepunt. Op basis hiervan stelt het coördinatiepunt een risicoschattingsrapport op
met conclusies en aanbevelingen. (4 dagen) 5. Dit rapport wordt indien mogelijk
voorgelegd aan de leden ter commentaar en aan het dagelijks bestuur ter goedkeuring (2
dagen).
6. Het risicoschattingsrapport wordt aan de Minister van VWS voorgelegd via de
Directeur Voeding, Gezondheidsbescherming en Preventie (VGP) van het Ministerie van
VWS.
7. De procedure wordt geëvalueerd (facultatief).
3 Risicoschattingscriteria
I. Gezondheid individu:
1. Mate van het risico van lichamelijke afhankelijkheid
2. Mate van het risico van geestelijke afhankelijkheid
3. Mate van het risico van acute toxiciteit (afgezien van het door de gebruiker beoogde effect)
frequentie en ernst klachten/ gebruik andere stoffen/ doseringen en variaties daarvan/
gebruikelijke wijze van innemen/frequentie gebruik/ effecten die consument zelf niet kan
waarnemen, maar wel gedrag beïnvloeden.
4. Mate van het risico van chronische toxiciteit (zie 3)
II. Volksgezondheid:
5. Mate van risico met betrekking tot omvang en frequentie van (toename van) het gebruik
(inter)nationaal
6. Mate van risico door kwetsbaarheid van gebruiker
leeftijd/ervaring/kennis/omstandigheden
7. Mate van risico door het niet beschikbaar zijn van adequate gebruikersinformatie
aanwezigheid en kwaliteit bijsluiter/ misleidende informatie/ uiterlijk product
8. Mate van risico met betrekking tot de beschikbaarheid van het product 9. Mate van risico
vanwege het niet betrouwbaar zijn van de kwaliteit van het product
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productiemethode/zuiverheid/toxiciteit bijproducten/ plaats productie
10. Mate van risico vanwege het niet betrouwbaar zijn van de distributiewijze,
verkooppunten en handelaren
11. Mate van risico afgemeten aan de aard en omvang van meldingen van incidenten
eerste hulp ziekenhuizen/EHBO/NVIC
III. Openbare orde en veiligheid:
12. Mate van risico met betrekking tot overlast (frequentie en ernst) voor burgers rond
gebruik en verkoop
13. Mate van risico in relatie tot het feit dat de stof tot verlaging van de geweldsdrempel bij
gebruiker leidt
14. Mate van risico vanwege beïnvloeding van het reactievermogen (rijvaardigheid, bedienen
apparatuur) van de gebruiker
IV. Criminele betrokkenheid:
15. Mate van risico met betrekking tot eventuele betrokkenheid van
(georganiseerde) criminaliteit bij productie en handel
16. Mate van risico met betrekking tot eventuele betrokkenheid (georganiseerde) criminaliteit
bij productie en handel grondstof
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4 Riscoschatting scoretabel
Naam invuller: Naam stof:
2
(13) Verlaging geweldsdrempel no low aanwezig large mighty
Bijlage 3 Chronologie risicoschattingsprocedure paddo’s
Op 11 april 2007 diende de beleidsdirectie VGP van het Ministerie van VWS een verzoek in om
een risicoschattingsprocedure voor paddo’s op te starten.
Op 16 april 2007 werd door het CAM om informatie gevraagd aan de leden van de Commissie
Risicobeoordeling nieuwe drugs en op 29 mei 2007 werd het informatierapport (de
verzamelde, geanalyseerde en samengevatte informatie) naar alle leden van de
risicoschattingscommissie verstuurd met het verzoek een individuele risicoschatting uit te
voeren.
Op 7 juni 2007 kwam de risicoschattingscommissie bijeen voor het uitvoeren van de
gezamenlijke risicoschatting.
Op 11 juni 2007 is het conceptrapport ter commentaar toegestuurd aan de leden van de
risicoschattingscommissie.
Op 19 juni 2007 heeft het CAM het eindrapport aan het dagelijks bestuur voorgelegd en op
22 juni 2007 is het rapport door het dagelijks bestuur goedgekeurd.
In totaal heeft de procedure 2½ maand in beslag genomen.
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Bijlage 4 Begrippen en afkortingen
1 Begrippen
Criminaliteit: Indien de wet bewust overtreden wordt en dit de gebruikelijke wijze van
inkomstenverwerving is.
Euforie: Verhoogd gevoel van welzijn en ongefundeerd optimisme
Empathie: Het vermogen zich in te leven in de gevoelens van anderen
Gewenning: Verworven tolerantie
Georganiseerde criminaliteit: Groepsgewijs, in netwerken of andere verbanden. Er moet sprake
zijn van gebruik van geweld om positie te verdedigen etc.
Risicoschatting (risk assessment): Een (wetenschappelijke) evaluatie van de waarschijnlijkheid
van optreden van bekende of potentiële nadelige gevolgen (zowel kwantitatief als kwalitatief)
voor de (volks)gezondheid, de openbare orde en de maatschappij.
Risico (risk): Een schatting van de waarschijnlijkheid waarmee en de mate waarin een nadelig
gevolg voor (volks)gezondheid, openbare orde of de maatschappij kan optreden.
Hallucinatie: Zintuiglijke waarneming zonder de daarbij behorende zintuiglijke input
Illusie: Onjuiste interpretatie van zintuiglijke input
Mutageen: Mutaties (in het DNA) bevorderend of teweegbrengend
Overlast: Een ongewenste maatschappelijke situatie, veroorzaakt door o.a.
verwervingscriminaliteit, agressie en (straat)geweld, afwijkend gedrag en verstoring
openbare orde
Teratogeen: Misvormingen (in de ongeboren vrucht) bevorderend of teweegbrengend
Tolerantie: Geringe gevoeligheid voor de farmacologische werking van een stof Verslaving:
Afhankelijkheid welke zich uit in ontrekkingsverschijnselen bij onthouding. Lichamelijk: bv.
sidderingen, rillingen, roodheid van gezicht en hals, stoornissen van het gevoel(svermogen).
Geestelijk: bv. onrust, agitatie, angst, depressie, hallucinaties.
2
2 Afkortingen
11‐OH‐THC 11‐hydroxy‐ ∆9‐tetrahydrocannibinol
ACTH Adrenocorticotroof hormoon
ASAT Aspartaataminotransferase
CAM Co‐ordination Point for Assessment and Monitoring of New Drugs
DMT Dimethyltryptamine
EMCDDA European Monitoring Center for Drugs and Drug Addiction
ESPAD European School Survey Project on Alcohol and Other Drugs
GGD Geneeskundige en Gezondheidsdienst
GGT Gamma‐glutamyltransferase
GHB Gamma‐hydroxyboterzuur
HPPD Hallucinogen Persisting Perception Disorder
KLPD Koninklijke Landelijke Politie Diensten
LSD Lysergsäure‐diäthylamid
MAO Monoamineoxidase
MBDB 1‐(1,3‐benzodioxol‐5‐yl)‐2‐(methylamino)butaan
MDMA 3,4‐methyleendioxymethamfetamine
MTA 4‐methylthioamfetamine
NFI Nederlands Forensich Instituut
NVIC Nationaal Vergiftigingen Informatie Centrum
OCD Obsessief Compulsieve Stoornis
PMMA para‐methoxymethamfetamine
RIVM Rijksinstituut voor Volksgezondheid en Milieu
THC ∆9‐tetrahydrocannibinol
THC‐COOH ∆9‐tetrahydrocannibinolcarbonzuur
TSH Thyroid Stimulerend Hormoon
VLOS Vereniging Landelijk Overleg Smartshops (branchevereniging)
VN Verenigde Naties
VWA Voedsel en Waren Autoriteit
WOG Wet op de geneesmiddelenvoorziening
XTC Ecstasy (gewoonlijk MDMA‐bevattende preparaten)
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