NHS Ayrshire and Arran: Register of Interests for staff – “discussions are ongoing”

Sent: 20 February 2015 14:01
Subject: NHS A&A response to – FOI – Compliance with HDL (2003) 62 – our ref 528/2014

Dear Dr Gordon,
Again, please accept my apologies for any inconvenience caused by the delay in responding to your enquiry. Leave commitments of the specialised staff tasked with responding to your request and other events outwith our control have lead to the delay in responding to your request timeously.

Our response in 2013 stated that the organisation was working on compiling a register of interests and register of gifts/hospitality to encompass all staff which would also include payments from pharmaceutical companies.  At the time of your request we already had a ‘declaration of interests’ register for the Area and Drugs Therapeutics Committee to ensure any conflict of interests were registered for decision making around drugs. We had advised at the time of your request that the ‘the Area and Drugs Therapeutics Committee’ were hoping to publish this register in the future. Please see our full 2013 response below:

Discussions are ongoing to create a register to encompass the whole organisation in line with the guidance – A Common Understanding 2012 working together for patients -guidance on joint working between NHSScotland and the Pharmaceutical Industry.

The attached ‘declaration of interests’ register relates to the Area and Drugs Therapeutics Committee, its sub groups and anyone submitting a guideline. We are in the process of updating our Model Publication Scheme to include this register which will be published on our public website.

Since sending our response a decision has been taken not to publish this register.  Please accept my apologies for not fulfilling the assurance to publish the Area and Drugs Therapeutics Committee ‘declaration of interests’ register. However, this was superseded by the register of interest for all staff and the requirement under the Public Services Reform (Scotland) Act 2010.

Section C ‘Standards of Business Conduct’ within the Code of Corporate Governance paragraph. 3.3 states “Where there is an interest, hospitality or relevant outside employment is declared to a manager, they must record that declaration in the employee’s personal file together with any instructions issued to the member of staff in relation to the declaration. This information must also be provided to the Corporate Business Manager to be recorded as part of the Board’s declaration of interests and gifts.”  This register is held by the Corporate Business Manager who is responsible for keeping and maintaining it.  From November 2014 Section C is also included within any contractual paper work for new employees to the organisation. The Chief Executive has also circulated communication to ask employees to ensure they are notifying their line manager and the Corporate Business Manager of any declarations.

We are not at present planning to publish this on our website. As, under part three of the Public Services Reform (Scotland) Act 2010 (the Act), we have a duty to provide information on hospitality and entertainment. This includes any gifts, meals, parties, reception, tickets for or invitations to public, sporting, cultural or other events or other similar benefits accorded by a public body to its own members, employees or third parties for whatever reason. A threshold of £25 for “one off” gifts or benefits has been set as reasonable for this purpose, provided that the gifts or benefits in question are not regular or recurring. If a different threshold is adopted it should be set out in the statement of expenditure.

This information is routinely published as a requirement of the Act as soon as reasonably practical after the year-end. Please follow the link http://www.nhsaaa.net/publications/public-services-reform-(scotland)-act-2010.aspx. Or go to our website, http://www.nhsaaa.net/ click on the ‘publications’ button and select ‘a’ and scroll down to ‘Accounts/financial information.

I trust this response is helpful. However, under the Freedom of Information (Scotland) Act 2002 if you are dissatisfied with our response you are entitled to request a review. A request for a review must be made in writing to Mrs Jillian Neilson, Head of Information Governance, NHS Ayrshire & Arran, 14 Lister Street, University Hospital Crosshouse, Kilmarnock, KA2 0BB or email InformationGovernance@aapct.scot.nhs.uk, no later than 40 working days from 23 February 2015. You must provide your name, an address for correspondence, details of your original request and say why you want a review. If our decision is unchanged following a review and you remain dissatisfied with this, you then have the right to make a formal appeal to the Scottish Information Commissioner.

Please do not hesitate to contact me should you require any further advice or assistance.

Kind regards,

Freedom of Information Officer
Communications dept
28a Lister Street
University Hospital Crosshouse

Email: foi@aaaht.scot.nhs.uk


Previous blog posts on Ayrshire & Arran Register of Interests:



Sponsored medical education: another Scottish NHS Board

Those who have followed my posts on Hole Ousia will know that I have petitioned the Scottish Parliament for a Sunshine Act. As an NHS doctor working in Scotland I was recently invited to this educational meeting. I thought it might be useful to use this as an example of the current situation for continuing medical education as I have encountered it in Scotland.

Passmore, 26-2-2015, NHS Lothian

Although this flyer does not make clear, this educational meeting is sponsored by the Pharmaceutical industry. Professor Peter Passmore has been described as a “key opinion leader” in medical education both in the UK and internationally.

This list of declarations for Professor Peter Passmore is from 2008 as given to the Journal of the Royal College of Physicians in Edinburgh.


I do my best to avoid sponsored medical education but I do try to attend meetings organised by the Royal College of Psychiatrists. For the Autumn 2011 Faculty Meeting I had suggested to the organisers that we might debate “early diagnosis of dementia” . I offered to take one side of the argument. However the organisers chose instead to invite Professor Peter Passmore.

Aware of Professor Passmore’s extensive promotion of drugs I chose not to go.Nov-2011-Forth-Valley-Educa

At this time, 2011, Scottish psychiatrists were invited to a number of educational meetings where Professor Passmore was widely promoting Memantine (EBIXA).

Just recently, the Scottish Parliament have recommended that a Register of lobbying of parliamentarians should be established. The following is an example from 2011:


In 2013, Professor Passmore was promoting SOUVENAID, a nutritional supplement for “early Alzheimer’s disease”:


By being paid to give educational meetings for CPD approved conferences and meetings Professor Passmore is by no means departing from accepted practice.


Whilst I was doing my research on NHS “hospitality registers” I wrote to Professor Passmore asking where he recorded his financial interests? I got this reply from NUTRICIA:


The Association of the British Pharmaceutical Industry (ABPI) are currently introducing a register of payments to individual doctors: “The central platform”. Doctors can choose to opt-out from disclosing any payments received from industry.

My interest is in transparency about such financial conflicts of interest and in particular public transparency. This is why I have petitioned the Scottish Government for a Sunshine Act:


Returning to the start of this post and the invitation to attend this latest sponsored medical education, I wrote to the organisers and had this reply from the Associate Director of Medical Education:

“All of our clinical association meetings are sponsored, if they were not we simply would not be able to provide these educational meetings as we have no budget for either the catering or the travel expenses of our speakers. We have moved away from sponsorship of teaching at foundation level, but for these hospital wide meetings, at which we are keen to attract speakers from out with Lothian, this is not possible at present.”


Those who follow my blog posts may recall that since Alexander McCall Smith’s recommendation to me of “A Pattern Landscape” I have been exploring patterns. Here I am reminded of NHS Forth Valley who are another NHS Board in Scotland who have no money to support medical education.

I am one of many scientists who has concerns that continuing medical education in Scotland is being funded by vested interests.





Royal College of Psychiatrists and conflicts of interest

The Chief Executive of the General Medical Council (GMC) recently confirmed, in response to a recent BMJ article, that it “takes very seriously the issue of conflicts of interest”:start-with-GMC

We know that in the course of a year, in the United Kingdom:40 million

Currently, it is almost impossible to find out anything other than the overall figure.

NHS registers of interest are not functioning. Yet doctors are asked to sign this at annual Appraisal:Probity-statement-SOAR-ApprAll Appraisals are then scrutinised by senior NHS managers to be “signed off”:

The BMJ make this charge:failure of regulation

However should we be asking if our Royal Colleges are also failing?

For several years I have written to the Royal College of Psychiatrists about conflicts of interest. This post is based on the latest correspondence which was prompted by the recent announcement of this International Conference:


The Co-chairs give this welcome note:welcome-by-co-chairs

It is almost certain that a significant proportion of the £40 million goes to: KOLs2

The Conference organisers have made it clear of the “exhibition opportunities” provided at this event:exhibition-opportunities

What is less clear is whether the speakers or those involved in workshops or seminars have any conflicts of interest.

This is why I have written to:Board-RCPsych

My most recent letter to the above, copied to the Chief Executive of the GMC, asks for transparency ahead of the Conference in this important area:Craddock-letter







“A probity issue and may lead to a failure to revalidate”

Here is a submission to the BMJ by S. Musheer Hussain, Consultant & Hon Professor of Otolaryngology, Ninewells Hospital & University of Dundee Medical School:
Here is relevant communication with NHS Tayside on a register of interests

“A public register of UK doctors’ financial interests is long overdue”

Below is my latest submission to the BMJ:

Fiona Godlee, Editor of the BMJ, has concluded that: “The profession must take the lead to protect patients and maintain public trust. The GMC should act, and a public register of UK doctors’ financial interests is long overdue.”(1)75854084_Godlee_62719j


In response, Niall Dickson, Chief Executive of the GMC, has stated that: “Our guidance is comprehensive and clear in respect of the responsibilities of individual doctors and we have taken appropriate action against individual doctors in the past where there has been evidence that our guidance has been breached”. (2)A3DD946F-9966-E522-E48690C05D7C7B5F

I have petitioned the Scottish Government for a Sunshine Act regarding health professionals’ financial conflicts of interest. (3) This was considered most recently at the meeting of the Petitions Committee on 27th January. The evidence accumulated so far demonstrates that existing Scottish Government guidance, in place since 2003, has never been followed in NHS Scotland. FOI response from the GMC confirms that no doctor has been formally investigated in Scotland for breaching guidance on financial interests. (4)


Niall Dickson has stated on behalf of the GMC that “Parliament has not given us powers”. It would seem that Fiona Godlee has correctly identified what needs to be done, and it is clear that governments will need to act.

(1) Godlee, F. Medical corruption in the UK. 29 Jan 2015 http://www.bmj.com/content/350/bmj.h506

(2) Dickson, N. The GMC responds to the special report in the BMJ on regulating doctors’ financial and commercial interests; 29 Jan 2015 http://www.bmj.com/content/350/bmj.h396/rr

(3) Gordon, P.J. PE01493: A Sunshine Act for Scotland  http://www.scottish.parliament.uk/GettingInvolved/Petitions/sunshineact

(4) General Medical Council response to Dr Peter J Gordon. F13/5915/EH; dated14 Jan 2014

A Sunshine Act for Scotland

I cannot promise sunshine (who can) but here is a pattern that appears in the daylight of my today.

Hole Ousia found new direction after Alexander McCall Smith recommended “A Pattern Landscape”


This post is based on the recent considerations (27th January 2015) by the Petitions Committee on my petition for a  “Sunshine Act”

Kenny Macaskill, MSP gave this response to my petition:

Kenny MacAskill & Jackson Carlaw: A Sunshine Act for Scotland from omphalos on Vimeo.

Kenny Macaskill states to the Petitions Committee: “we have got to give them some opportunity” [Scottish Government]  … “I don’t think that can be done quickly as it is quite complex”. HDL-62

HDL (2003) 62 was issued 13 years ago. It was addressed to every NHS chief executive in Scotland.

Kenny MacAskill states that “it does seem to me [for there to be] a willingness to look into this”

Evidence reveals that such “willingness” has been largely ignored by NHS Boards since HDL (2003) 62 was issued more than a decade ago.

Jackson Carlaw, MSP: “can I say how I am delighted to agree with Mr MacAskill”

Appreciating this evidence, John Wilson, MSP, gave this “note of discordance” to the Committee:

A Sunshine Act: John Wilson, MSP from omphalos on Vimeo.

20th January 2015: “Despite numerous reminders, no response has been received from the Scottish Government. In light of this and concerns raised in your correspondence with the Committee’s clerking team, it is advisable for you to direct your concerns directly to the Public Petitions Committee by way of a short written submission that will be published online and circulated for the Committee’s meeting on 27 January 2015″

I sent this reply three days later. I could not do any more.

The basis of my petition, it occurs to me, may risk being lost in procedure:

Prescribed Harm from omphalos on Vimeo.

HDL (2003) 62 made it clear who was accountable. Alex Neil, former Cabinet Minister (17 May 2014) “asked officials to urgently investigate why some NHS boards have not put in place registers as covered by the 2003 circular. Alex Neil believes the guidance is clear that this action should have been taken, and we are looking for clarification on why some boards have not acted.”

My investigations have demonstrated that this financial basis to “medical education” is largely hidden in NHS Scotland. This despite General Medical Council guidance.

Accountability is passed like a parcel.




Consideration of Petition PE1493 by the Scottish Government

The Petitions Committee is meeting today, 27th January 2015, to give further consideration of my petition for a Sunshine Act for Scotland.

This reply from the Scottish Government was received just a few hours ago so I have not had time to properly consider it. However I thought it may be helpful to post it alongside other material on transparency. Scot Gov 25-1-15 pg1 Scot Gov 25-1-15 pg2

This British Medical Journal post of last year is what first came to my mind on reading the Scottish Government’s reply of Sunday 25th January 2015:


NHS Boards are not following existing guidance

The Petitions Committee of the Scottish Parliament are to meet on Tuesday 27th January 2015 to give further consideration of my petition for a Sunshine Act, PE1493. I lodged this petition in September 2013. What follows below is the full transcript of a letter of update to the Committee:

Friday, 23rd January 2015

To: Sigrid Robinson
Assistant Clerk
Public Petitions Committee
The Scottish Parliament

Dear Ms Robinson
Scottish Parliament Public Petition PE1493 on a Sunshine Act for Scotland

Thank you for informing me that my petition is to be considered by the Public Petitions Committee at its meeting on Tuesday 27th January 2015.

You suggested that I might like to make a short written submission for the meeting of the Committee informing me that this would be published online with the other evidence that the Committee have gathered for Petition PE1493.

Before I offer a brief summary, a year on almost to the day from my last written submission, I would like once again to thank the Committee, and supporting staff, for continuing to explore how the people of Scotland might benefit from a Sunshine Act.

I understand from your communication of the 20th January 2015 that the Committee, “despite numerous reminders,” has received no response from the Scottish Government. I am disappointed to hear this, particularly as the summary produced by the Scottish Government, in their letter of 17 April 2014, would appear to demonstrate wide failings in NHS Scotland’s Compliance with HDL (2003) 62. Given these failings, in December 2014 I contacted all 14 regional NHS Boards for further clarification and in the hope of progress. I have so far had reply from only 2 NHS Boards.

NHS Forth Valley and NHS Tayside now have a central register of interests for all staff. Both have now made these registers publicly accessible.

NHS Forth Valley: the current register includes the names of only 7 staff and all the other entries are by designation only. NHS Forth Valley’s register is therefore not complete in that it does not consistently identify individual staff. The Director of Education for NHS Forth Valley, confirmed last year in writing that he was “not aware” of HDL (2003) 62. The Director of Education also confirmed that Forth Valley’s “learning Centre” has no budget that pays for educational meetings”.

NHS Tayside: is the only other Health Board to reply to my recent request for an update and provided the public link to their Register. The register begins in 2011 and records 16 entries, and each without any identifying name. Ms McLeay, Chief Executive, stated in her reply of the 30th December 2014 “I agree that this public record of sponsorship is not complete and accurate at this point”.

NHS Lothian: I have had no reply to my recent communication on HDL (2003) 62. The situation as recorded in FOI reply from NHS Lothian dated 6th May 2013 stated: “There are no other [apart from Board members] centrally held registers available within NHS Lothian and any such register would not necessarily identify payments to staff”.

NHS Greater Glasgow: I have had no reply to my recent communication on HDL (2003) 62. Following my original FOI request (before I lodged this petition in September 2013) NHS Greater Glasgow attached a register that covered 5 years and had entries for 27 separate employees. NHS greater Glasgow is the largest health board in the United Kingdom, serving 1.2 million people and employing 38,000 staff. This NHS Greater Glasgow register for “all staff” is not available to the public.

NHS Ayrshire and Arran: have promised to reply to my recent communication on HDL (2003) 62 stating that “turnaround times are proving challenging”.  NHS Ayrshire and Arran stated in June 2013 “discussions are ongoing to create a register to encompass the whole organisation … we are in the process of updating our Model Publication Scheme to include this register which will be published on our public website.” I can today find no such register (other than for Board Members only) for NHS Ayrshire and Arran.

NHS Lanarkshire: I have had no reply to my recent communication on HDL (2003) 62. However previously (15th May 2014) Dr Iain Wallace, the Medical Director for NHS Lanarkshire, wrote to me stating: “I can advise that it is not the intention of NHS Lanarkshire to publish a register of interests for all staff”.

NHS Grampian: I have had no reply to my recent communication on HDL (2003) 62. However in relation to my original FOI request, I was informed in July 2013: “…no such register is maintained and therefore a copy is unable to be provided to you….In all of the circumstances therefore, NHS Grampian is unable to provide a register to meet your requirements.”

From the 6 other regional NHS Boards I have had no reply to my recent communication on HDL (2003) 62. I have not made further contact with the 7 special NHS Boards since my original FOI request. My understanding however is that HDL (2003) 62 applies equally to the special boards.

To remind the Committee, here is the relevant section of HDL(2003) 62:


On the 17th May 2014 the Herald reported: “The Health Secretary has asked officials to urgently investigate why some NHS boards have not put in place registers as covered by the 2003 circular. Alex Neil believes the guidance is clear that this action should have been taken, and we are looking for clarification on why some boards have not acted.”


  1. HDL (2003) 62 was issued 12th December 2003. It is more than a decade old. It asked Chief Executives to “establish a register of interest for all NHS employees and Primary Care Contractors.”
  1. The Scottish Government summary of the 17th April 2014 demonstrated widespread failure to comply with HDL(2003) 62. The updated evidence I have managed to gain indicates reasons to be more rather than less concerned.
  1. I have found no evidence, in any register of any sort, of declarations from “Primary Care Contractors”.

The Committee may recall that before I had submitted oral evidence for the petition the Association of the British Pharmaceutical Industry (ABPI) submitted a letter to the Committee. The ABPI plan to develop what they term a “Central Platform”: from the 1st July 2016 the intention is to collect and record data of individual payments to healthcare practitioners and record these on an open database. It is important to note that healthcare practitioners will be able to opt-out if they do not wish payments to be disclosed.

The General Medical Council (GMC), in reply to the Petition Committee confirmed that a “compulsory register would require legislative change.” This week the GMC sent this reminder to medical practitioners:

GMC Jan 2015 CoI

Despite reminders, NHS Boards are not following existing guidance. This strategy has failed for more than ten years. The disappointingly slow response of the Scottish Government to communication from the Committee only highlights the failure of the current approach. This strengthens my view that a new law would be a better way of focusing minds on a matter that may be having a significant impact on Scotland’s health. I would remind the Committee that I was first prompted to look into this when considering the widespread, off-label over-prescription of antipsychotic medications for Scotland’s elderly people. My experience was that the Pharmaceutical Industry financially supported the “education” of healthcare practitioners in this approach.

I hope this update is of some assistance to the Committee ahead of the 27th January 2015.  I wish to say that I am very grateful to the Committee members, and supporting staff, for all your help.

Yours sincerely,
Dr Peter J. Gordon

Full correspondence on NHS Registers of Interest can be followed here


The above post is by Chrys Muirhead. It can be accessed here. I have also re-posted it below:

Sunshine Act for Scotland Petition Goes Before Parliament a 3rd Time

January 23, 2015

In Scotland petitions are a direct way for people to raise national issues with their Parliament, a request for action.  Dr Peter J Gordon, consultant psychiatrist, first lodged a petition on the Scottish Parliament website, PE01493: A Sunshine Act for Scotland, 29 September 2013:

“Calling on the Scottish Parliament to urge the Scottish Government to introduce a Sunshine Act for Scotland, creating a searchable record of all payments (including payments in kind) to NHS Scotland healthcare workers from Industry and Commerce.”

Peter J Gordon is a man of many parts: a qualified doctor and landscape architect, husband and father, a family man whose interests include philosophy, sociology, ethics, evidence-based medicine, neuroscience, horticulture, sculpture, poetry, local history,  photography and film-making.  He writes on Hole Ousia (whole being) and has 269 films, at the latest count, on Omphalos.

spshotsunshineactpetOn 12 November 2013 the Public Petitions Committee at parliament took evidence from Dr Gordon in respect of his Sunshine Act for Scotland petition.  (See video, 25 minutes in)  Here is part of my comment on the video, now disabled but on my Google+ profile:

“The points about the marketing potential of education versus scientific objectivity demonstrate the need for regulation of drug industry payments, or in kind rewards, made to or received by health care professionals.  To hear the figure of £40million gifted by drug companies to UK health workers and about £4million of that going to Scottish workers is quite astonishing.”

— Herald Scotland article 13 November 2013: ‘Doctor calls for drug payments register‘.

In addition to petitioning Scottish Parliament, Dr Gordon has been diligently raising Freedom of Information requests in respect of Registers of Interests in every Scottish health board area.  Scottish Government brought out a directive, NHS Circular HDL (2003) 62, instructing health boards to set up Registers of Interest so that staff could declare payments from pharmaceutical companies.  For the sake of transparency.  The health boards have not been complying with this government call to action.

Herald Scotland article 17 May 2014: ‘Urgent review as nearly half of health boards ignore pharma disclosure rule‘ and quote “The Health Secretary has asked officials to urgently investigate why some NHS boards have not put in place registers as covered by the 2003 circular. Alex Neil believes the guidance is clear that this action should have been taken, and we are looking for clarification on why some boards have not acted.”

HeraldEditorial18may14On 18 May 2014 the Herald Scotland Editor gave his support for the Sunshine Act petition and greater transparency, saying “Simply hoping that NHS Boards enforce existing guidance is a strategy that has failed for more than ten years.  A new law would be a better way of focusing minds on this important matter.”

Nearly a year to the day after Dr Gordon gave his evidence, on 11 November 2014, his Sunshine Act petition was considered by the Public Petitions Committee at its meeting in the Robert Burns Room of Scottish Parliament.  I was there to hear the proceedings, punctuated by a Remembrance Day commemoration in the Garden Lobby of parliament at 11am, and then at around 12 noon the topic came up.  It took two minutes mention of contacting Scottish Government to ask about the NHS Circular HDL (2003) 62 (Registers of Interest) progress.  My thoughts?  Swingball.  Pass the buck.  See blog post I wrote following the meeting.

On Monday this week a notification arrived to say that Dr Peter Gordon’s petition will be considered, again, by the Public Petitions Committee on 27 January 2015 in the Robert Burns Room of Scottish Parliament.  Meeting starts at 10am and the agenda item containing the Sunshine Act should start at around 11.15am, subject to change.  I have booked a ticket and plan to observe the proceedings from the Public Gallery.  Live broadcasts can be viewed at this link.  Videos after the event here plus links to business papers and reports.

I am hoping this time around in the Rabbie Burns room for more than 2 minutes worth of talk and no direct action.  A Sunshine Act for Scotland makes sense economically and ethically.  Doctors in their drug prescribing should be free from conflicts of interests.  The pharmaceutical industry is primarily a money making concern.  Patients deserve to know that their medical treatment is for them and not for profit.

“While Europe’s eye is fix’d on mighty things,
The fate of Empires and the fall of Kings;
While quacks of State must each produce his plan,
And even children lisp the Rights of Man;
Amid this mighty fuss just let me mention,
The Rights of Woman merit some attention.”

— Robert Burns, The Rights of Woman, 1792




Marketing opportunities: “Psychiatry at the forefront of science”

This week I noticed the programme for the 2015 Royal College of Psychiatrists International Congress “Psychiatry at the Forefront of Science”:CropperCapture[1]

The programme covers a broad range of topics and the 3 ½ days of the conference includes: academics, physicians, psychiatrists, patients, service users, family members, carers, psychologists, social scientists, policy makers and journalists. This pluralism is welcome.

The co-chairs in their welcome note say:

“With a projected attendance of over 2,000 delegates from more than 50 different countries, The International Congress of the Royal College of Psychiatrists is one of the biggest events in the annual mental health conference calendar.”

This Congress is eligible for a total of 21 CPD / CME points

In the “marketing opportunities” section of the Congress, the Royal College of Psychiatrists state that “this major international event reflects the College’s high standards in education, training and research…” The college confirms that “this is the biggest meeting of psychiatrists in the UK” and thatour 2014 event attracted 2,500 delegates”. They continue “the event includes a large exhibition area where delegates will meet for morning, lunch and afternoon breaks, providing an excellent opportunity for exhibitors to meet and talk to the delegates.

Such “marketing opportunities” are not new. Before the 2014 congress, I wrote to the Royal College of Psychiatry expressing my concern about the combination of marketing and education. The College replied by stating that they did not share my concerns.

Here is one of a range of options for the 2015 Congress:Untitled-12

This year, the Association of the British Pharmaceutical Industry (ABPI) are introducing a Register for payments to individual doctors from the Pharmaceutical Industry. We know that in 2012, £40 million was paid to doctors by the pharmaceutical industry. This may well include some of the doctors speaking this year.


UK doctors have to demonstrate that they have acquired sufficient CPD/CME points  for annual appraisal. Doctors also have to declare that they have followed the requirements of the GMC “Good Medical Practice” regarding probity, including any potential conflicts of interest.

The 2015 ABPI database of payments to doctors will be open access. It is thus a welcome effort to increase transparency. Unfortunately however doctors can opt-out of being on the register. This means that we may not have any record if any of the doctors speaking at the congress have previously received any payments from the pharmaceutical industry.

Last year, at another Royal College of Psychiatry conference, I was one of the speakers. Well in advance of the conference I suggested to the College organisers, and to fellow speakers, that we might declare any interests which we may have in the programme. As it turned out, I was the only one to do so.


At this conference of last year, one of the speakers showed a slide of his extensive declarations of interest.


I mention this speaker as I note that he is involved in several education events at the 2015 International Congress.

If I have one hope in writing this blog it is that the Royal College of Psychiatrists might ensure that declarations of every individual involved in any educational aspect of this 2015 International Congress are recorded and kept on archive. I am of the view that such declarations should also be shared with the public. This could easily be done through a permanent link from the College website. This database could also share the full payments from all industries that have taken up  the “marketing opportunities” offered by the Royal College of Psychiatry.

This would indeed be a solid foundation to “Psychiatry at the Forefront of Science”

“Doing damage in delirium the hazards of antipsychotic treatment in elderly people”

This paper was published in the Lancet in late last year. It is a two page article that is worth reading in full. All screenshots below are from this paper:001

The authors commented that002

The authors were of the view that003

Scottish Government figures confirm that prescribing of antipsychotics is rising in our elderly. It thus seems important to consider why this may be. The authors continue:004

There is always the risk in times of austerity, and when staffing levels are not ideal, that:005

The authors state:006

The promotion of off-label use of antipsychotic medication was instrumental in my petition to the Scottish parliament for a Sunshine Act:007

The authors continue:


But what does the evidence have to say? The authors state:009

The authors continue:011

The authors ask:012

The authors conclude with Dr William Osler:013

I am also of the view that there is a risk that “brief screening tools” may result in “pathways” being followed that, despite good intentions, lead to greater prescribing of antipsychotics in our elderly. I am aware that currently “brief screening tools” are being promoted in Scottish NHS hospitals.

I wish to conclude with one recent example of many: an elderly woman, with terminal cancer returned to her GP after a recent period in hospital. She asked her GP “But why am I on this anti-schizophrenic drug?”