Diabetes Research Information - Facts for Treatment

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1 Public Health Policy European Union Diabetes Focus Public Consultation Diabetes, Hypoglycaemia, Insurance Diabetes Research Information - Facts for Treatment DIRECT-TO-PATIENT INFORMATION TOOL ON DIABETES is a good foundation tool to facilitate the practising of quality standards and meet the educational requirements of patients, carers, the medical profession, and participation in society to facilitate clear understanding by patients, healthcare professionals, family members, work colleagues, leisure pursuits, driving and road users, insurance requirements and quality of life. The draft document requires to be defined between Type 1 Diabetes and Type 2 Diabetes and Type 1 and Type 2 Diabetes should be addressed separately for clarity in the document. The principles are well accepted but the draft document does not meet the principles and requires greater specificity and lacks detail. For example - It omits to mention Inhaled Insulin in Type 1 Diabetes. 2.4 Complications should be sectioned after Symptoms, Diagnosis, and Treatment and the most feared complication of diabetes hypoglycaemia requires further explanation. It does not address where to go to obtain treatment which may vary in different EU countries depending on whether patient is Type 1 or Type 2 eg hospital, clinic, GP surgery, pharmacist. The document has the potential to be made available to healthcare professionals and patients throughout the EU to provide a basic understanding of the chronic health disorder of diabetes and if made available in all EU languages has the ability to assist the patient if travelling in another EU country and the healthcare professional to understand each other especially in health emergency situations eg hypoglycaemic attack, lost insulin in another country, or need for surgery of a diabetic patient after an accident. Diabetic hypoglycaemic attack often leading to violent convulsions and seizure by accidental insulin overdose or lack of information and educational needs of the patient and carer not informed by the medical profession or healthcare professional requires more detailed description in the document. Diabetes and diabetic hypoglycaemia are serious chronic health disorders requiring medical treatment as recognised and accepted by patients, carers, the NHS, health providers, the medical profession, diabetic charities, and the Law Society. If a Type 1 diabetic patient suffers a diabetic hypoglycaemic attack when driving and is unable to pull off the road fast enough leading to a car crash then the driver s motor insurance policy if correctly worded should provide cover for accidental damage to vehicles, objects and personal injuries to passengers and persons. A serious problem of diabetic discrimination has been identified in the UK in the description of 'diabetes' and 'hypoglycaemia' as 'nonsense' by a St Albans insurance broker insured by Norwich Union plc and Ace Global Ltd and 'acute diabetic hypoglycaemia with convulsions and seizure' being described to the police and solicitors and when under oath as 'domestic violence' by the insurance broker and also described by an ex St Albans G P to solicitors and the High Court as 'domestic violence' leading to

2 exposure to unjustified and unreasonable financial loss and 13 years estrangement of a father from his only daughter following the child witnessing a diabetic hypoglycaemic attack at home when aged 11 in An alleged conspiracy to cover up medical negligence by the insurance broker and G P has been identified and following investigation, and on the recommendation of Serious Crime, Hertfordshire Constabulary, has been referred to the General Medical Council in Manchester to resolve. Insurers Norwich Union plc and Ace Global along with St Albans Accountants Mercer and Hole, courts and solicitors have been misled with falsified evidence in an alleged conspiracy to cover up medical negligence and prevent payment of a justifiable insurance claim to the diabetic father and his only child following the diabetic hypoglycaemic attack in February The accountant has been reported to the Institute of Chartered Accountants (ICA) Milton Keynes for misconduct and receiving attention. The insurers are suggesting that a diabetic patient who suffers an acute hypoglycaemic attack with violent convulsions and seizure is not insured himself or herself with normal home contents and legal insurance for injury to himself or herself or third parties but have suggested the uninsured diabetic patient should be liable for the losses incurred by the insurers Norwich Union plc and Ace Global Ltd for the losses incurred in the cover up. If a diabetic patient suffers a hypoglycaemic attack caused by negligence and over which he or she had no control and found themselves in a state of temporary mental impairment with hypoglycaemia then that patient can in no way be held responsible for costs incurred by other third parties in effecting a cover up when the matter stems from an original acute diabetic hypoglycaemic attack, in this case in Referral to the General Medical Council and Institute of Chartered Accountants has led to debate of the matter as part of the Public Consultation in that such 'descriptions of diabetes and hypoglycaemia as described herein allegedly amount to gross professional negligence and misconduct in public office' by a General Practitioner, an Insurance Broker and an Accountant. This issue typifies the education problem and sad public perception in the UK associated with the management of the chronic health disorder of diabetes hereby informed to the Public Health Pharmaceutical Forum Secretariat at the European Commission for address as part of the undergoing consultation which ends on 4 May 2007 for possible inclusion in the context of an information package for diabetes to be delivered throughout the EU. Diabetic Hypoglycaemia A Feared Complication of Insulin Treatement Violence in NHS Hospitals, especially A and E Departments, is a serious problem which has led to an enormous cost to the NHS as featured on BBC Panorama, 26 February A patient suffering from drunkenness is one issue as the patient self inflicted the drunkenness leading to aggressive behaviour. The patient with diabetes who stabbed the nurse with a needle when the nurse was attempting to give the diabetic hypoglycaemic patient a glucogen injection is a different matter. A diabetic patient places his/her trust in the NHS / NHS consultant / GP to prescribe the correct insulin best suited to treat the chronic health disorder of diabetes. Many patients are immunogenic to certain types of insulin and are sometimes prescribed the wrong insulin and wrong dose by the medical profession which can lead to tragedy.

3 The diabetic patient referred to in the programme was in the A and E department because he was experiencing a violent acute hypoglycaemic attack with convulsions and seizure as described by the nurse who was interviewed but may not have been aware of issues concerning diabetic insulin treatments which have been covered up for many years. Such a hypoglycaemic attack is also a chronic health disorder requiring paramedic assistance with injection of glucogen by a paramedic, or treatment with glucose tablets and sweet drink to stabilise the hypoglycaemic state and get the patient back to normoglycaemia. On the balance of probability the patient on the programme was probably prescribed the wrong insulin and possibly an overdose of the wrong insulin by prescribing physicians, or he may have just recently had his insulin switched to a different brand possibly a different human insulin or an analogue insulin. This was not investigated by the programme. It is unlikely that the patient and his carer were properly trained by NHS staff on how to handle an acute hypoglycaemic attack at home. The symptoms of hypoglycaemia differ between treatment with human and analogue insulin compared to natural animal insulin. Patients treated with human and analogue insulin are much more likely to become violent and aggressive when in a state of acute hypoglycaemia and suffer convulsions and seizure whereas a patient treated with animal insulin will suffer more gentle symptoms of hypoglycaemia with the symptoms being recognised by the patient or carer to enable administration of glucose at home or by ambulatory paramedics. Many patients have been switched from animal insulin, first invented by Banting, Best and Macleod, in 1921 / 22, to human or analogue insulin and many patients have been denied a choice of insulin best suited to their individual requirements namely animal, human, or analogue. Patients and their carers are often not informed of how to manage hypoglycaemic attacks. Our organisation receives many phone inquiries every week from patients and carers experiencing problems with hypoglycaemia, especially night time hypoglycaemia, and most of them have not been informed by NHS staff prescribing insulin on what to do. I suffered marriage breakdown in 1994, subsequent divorce, the loss of contact with my only daughter for 13 years and exposure to costs by the negligence of doctors from who along with an insurance broker it is alleged have conspired to cover up serious medical negligence by lies and false allegations. This tragedy was brought about following my suffering a life threatening diabetic hypoglycaemic attack on February 1994 caused by negligence and failure to have me transferred to hospital by ambulance the effect on my daughter which left her traumatised and emotionally damaged when aged 11 and not Gillick competent as described by a judge in December A conspiracy to cover up the medical negligence of three St Albans general practitioners assisted by a St Albans insurance broker has led to 13 years estrangement and exposure to massive costs in effecting a cover up. After 9 hours of discussion in October 2006 with Professional Standards, Hertfordshire Constabulary, used as a learning experience in diabetes for the police, the matter was referred to Serious Crime, Hertfordshire Constabulary, who advised in February 2007: I have now had the opportunity to consider the issues which you have raised, in particular the allegations levelled against Mr W and Dr A that they have conspired to cover up medical negligence. (names withheld) and goes on I feel the allegations you make would more appropriately be dealt with by the British General Medical Council to whom the matter has been referred and who have requested more evidence now being collated.

4 Symptoms and treatment of hypoglycaemia are described on the NHS Direct website, on our website at Diabetes Research Information Facts for Treatment, and on diabetic charity websites. In the local police constable in Bricket Wood provided advice concerning insulin treatment and medical negligence following his experience in the Metropolitan Police regarding drug investigations of negligent doctors in Harley Street, London. He advised that in order to prove the negligence (civil or criminal) of doctors who incorrectly prescribed insulin if one could obtain clinical information on the first patients to be injected with human insulin and identify if side effects took place with these patients treated with injections of human insulin, including hypoglycaemia and aggression, this would go a long way in confirming to a court the negligence of these doctors. In January 2007 previous clinical references published in The Lancet were discovered: Biosynthetic Human Insulin in the Treatment of Diabetes A Double blind Crossover Trial in Established Diabetic Patients published The Lancet 14 August 1982 This published paper confirms that the first patients treated with human insulin in a trial commencing in 1981 experienced hypoglycaemia and 3 patients withdrew from the trial due to: 1) experience of severe hypoglycaemia requiring transfer to hospital and switched to porcine insulin 2) experience of hypoglycaemia, recovery with oral glucose 3) experience of irritability and frequent hypoglycaemia Warning Symptoms of Hypoglycaemia During Treatment with Human and Porcine Insulin in Diabetes Mellitus published The Lancet 13 May 1989 Hypoglycaemic symptoms of unrest, confusion and aggressiveness in treatment with human insulin reported. These papers were published in the Lancet, a well recognised medical journal read by most GP s, 11.5 years and 5 years before the hypoglycaemic attack I suffered with violent convulsions and seizure on February 1994 when treated with human insulin. The General Practitioner doctors whom I was under (and those at Watford General Hospital) must have been aware of the effects and symptoms associated with hypoglycaemia in treatment with human insulin in 1994 but were negligent and failed to act and inform of side effects to patients and carers. By failing to advise of potential side effects of human insulin the prescription of human insulin by prescribing doctors was prescribed it is alleged contrary to the Misuse of Drugs Regulations 1985 and in breach of the Misuse of Drugs Act 1971 leading to my suffering serious injury in the period and subsequently by way of conspiracy to cover up negligence and cause further injury by the offenders. Recent observations and recommendations of Hertfordshire Constabulary have been helpful and their letter has been forwarded to the General Medical Council along with other supporting information to enable the GMC to take action. Referral to the GMC does raise constitutional questions which have been referred to

5 the Lord Chancellor s Department as to where responsibilities lie and subsequently to the Department of Health and to the Prime Minister for clarification. Solicitors experienced in civil law and medical negligence have been very sympathetic and consider it disgraceful the way I have been treated by exposure to threats and bullying, suffering of loss and breach of trust to implement a cover up of medical negligence for 13 years. I am not the only diabetic victim in the UK and I am aware of other patients who have been falsely accused of wrongdoing without proper investigation. As the victim of this identified alleged conspiracy to cover up medical negligence I consider it totally unreasonable that myself and members of my family and ex-family should be expected to reimburse the offenders costs who have conspired against me for 13 years, who have lied in skeleton arguments, who have lied to the police and when under oath to cover up medical negligence. The public question which now requires to be answered is: Could hypoglycaemia caused by incorrectly prescribed human insulin and probably the wrong insulin have been responsible for the misbehaviour, illness, and actions of some diabetic patients? With my educational qualifications, professional experience and personal experience since 1972 I believe I am suitably trained and qualified to answer this question as: I am in no doubt that hypoglycaemia caused by incorrectly prescribed human insulin, and probably the wrong insulin in the form of human insulin and analogue insulin (a derivative of human insulin), has been responsible for the misbehaviour, illness, and actions (sometimes violent) of diabetic patients and in some instances unexplained premature death in certain diabetic patients so treated. I categorically state that in my experience the loss of warning signs of hypoglycaemia was caused by treatment with human insulin and these warning signs returned within 2 weeks of my switching back to animal insulin from 28 May Education and understanding moves forward. I remain concerned that by the negligence of the General Practitioner (who in 1994 described acute hypoglycaemia as domestic violence ) and the insurance broker who has described diabetes and hypoglycaemia as nonsense and hypoglycaemia as domestic violence concerning the hypoglycaemic attack witnessed by a child on February 1994 when aged 11 may have been experienced by her as a horror description which has left her mentally scarred for life, unable to trust her father and other men and could not bear to be alone with her father ever again. I have been sentenced to a life sentence of estrangement from my only beloved daughter caused by the negligence of the General Practitioner and insurance broker and am expected to pay the offenders costs in effecting a cover up. That is unreasonable and unfair justice and is impossible to uphold in law due to insurance cover for diabetic hypoglycaemia complications issues. Solution I take the view that my estranged daughter requires immediate counselling support (which she was denied in 1994 by alleged conspiracy) to be arranged by the NHS to overcome this tragedy so as to facilitate a

6 reunification with her father. I take the view that the NHS Trust Partnership who incorrectly counselled her in 1994 following referral by the General Practitioner on the condition her medical notes be kept secret forever when she was denied up to 10 NHS counselling sessions so as to cover up the negligence and the counselling became abusive of the child as admitted in affidavits are the correct organisation to arrange for this counselling and should be held responsible for reuniting me with my estranged daughter. The discovery of evidence published in the Lancet in 1982 and 1989 is conclusive proof of the negligence of the doctors who incorrectly prescribed a 20% overdose the wrong insulin for 7 years and raises serious questions as identified in observations placed with Hertfordshire Constabulary concerning the counselling of my daughter by the NHS Trust when represented in a previous damages claim 1999 by covering up negligent conduct of doctors. Solicitors advised several years ago that in the event I was eventually proved right that legal costs incurred by the NHS Trust paid for by myself would require to be refunded by the Trust especially as some of these costs go back to 1994 and the court order stated in 1994 that costs were not enforceable without leave of the court. I have asked that I be reimbursed the legal costs incurred by the NHS Trust and that this cost should be reclaimed from the insurers of the negligent general practitioner, the Medical Protection Society, and the insurer of the insurance broker, Norwich Union plc. who along with Ace Global Markets Ltd have paid out 37,882, and appear not to be seeking to recover these costs, which they will not be able to in any event, and I take the view that all costs I have incurred and legal costs incurred by my ex-wife should be reimbursed from the insurers of the insurance broker, Norwich Union plc. I have received very helpful support from Diabetes UK and the IDDT (Insulin Dependent Diabetes Trust). Both charities along with several consultant diabetes specialists have agreed that since summer 1994 when my insulin was switched back to animal insulin that I should be reunited with my daughter. Both charities are aware of similar problems with insulin treatment of diabetic patients over the years. A deliberate conspiracy has been engineered to cover up negligence and prevent contact with my estranged daughter and was referred for police investigation with identification of conspiracy to cover up medical negligence now referred on their recommendation to the General Medical Council. I have suffered ill health, stress, and retinopathy damage which when treated was not allowed to recover leading to deterioration in eyesight amounting to injury caused by stress to which I have been subjected by alleged professional misconduct in public office initiated against me by instructions issued by the St Albans insurance broker to solicitors Mills and Reeve in Norwich & Birmingham when representing Norwich Union plc and instructions issued to solicitors Wedlake Saint by the St Albans accountant at Mercer and Hole. The incorrect description of diabetic hypoglycaemia, a chronic health disorder requiring immediate carer or emergency medical attention, as domestic violence and along with lies to solicitors, to the police, and in court the description when under oath of diabetes and hypoglycaemia as nonsense is clearly very serious diabetic discrimination by alleged conspiracy to cover up medical negligence. Derek Beatty, BSc. DipM (Healthcare Consultant) 24 April 2007 DRI-FT Division of Aston Clinton Scientific Ltd 2 Garnett Drive, Bricket Wood, St Albans, AL2 3QN, UK Tel: (0044) Fax: (0044) e mail:

7 Observations from viewers published on BBC Panorama Website from 1 March 2007 Dean Morton, Wellingborough, Northamptonshire Having watched the programme I feel that one of the incidents used was a little miss-leading. I have a sister who has been insulin dependant since the age of 7(she is now 44). I have seen my sister aged 15 throw my father across a room with 1 arm whilst me and my mother were trying to hold her down and trying to get her to take a glucose solution to try and bring her out of a Diabetic Hypo. When she was in hospital having my nephew, she went into a hypo due to the pregnancy it took a number of staff to hold her down and inject a glucose solution to bring her round. She doesn't remember what happened although she appeared fully conscious. I am not condoning any sort of violence, but in some cases there is a medical reason for the violence which the patient has no concept or control. If the medical condition is known, like diabetes and the patient appears to be in a hypo then the appropriate number of staff should be on hand to assist. I do not know if the patient was in or had been in a hypo as this was not stated in the programme but it should be made clear that just because someone has diabetes does not automatically make them a violent person. A Bishop, Northampton, Northants I am somewhat concerned that you began a program focussed on A & E showing a nurse discussing a "diabetic" patient who was violent. This man was not convicted of the assault and strong medical evidence historical and specific to this case dictates that the volatility in the patients behaviour was as a result of starvation of glucose to his brain when hypoglycaemia enters a phase where the brain function is significantly impaired. This nurse has shown herself both on your program (and radio 4) to be dismissive and ignorant to medical fact. Why did she train as a nurse? Your program has gone on to discuss substance fuelled attacks on staff why again are these attacks grouped with an assault which occurred as a result of an impairment caused by a diagnosed medical condition. Is this nurse therefore disputing the evidence of the expert witnesses of which there were 2 in this mans case when it in my opinion wrongly entered the criminal justice system. I have had diabetes for 29 years and between the ages of 4 and 13 required physical restraint by my parents during hypoglycaemic episodes. "Amy" cannot expect justice out of a conviction related to Diabetes - a disability as defined by the DDA. This woman has infuriated me. I work in the public sector in the community protecting the most vulnerable in society (children) and am regularly assaulted during my working day - I work alone - I am provided with a mobile phone - I have no back up - I have no security- I have no colleagues - NHS staff need to seriously reflect on their dealing of the issues raised in your program and radio 4. DOES Nurse Amy want to see ZERO TOLERANCE for diabetics who are violent as a result of brain impairment? M, Cranleigh, Surrey As a diabetic I know that when you have a hypoglycaemic attack your behaviour can turn violent. I have unfortunately hurt nursing staff and it has never ever been my intention to do so and I never remember clearly doing so. The most vivid memory is a nurse telling me that I didn't like tea. I asked how do you know? She replied because you spat it out at me... Well as a diabetic It has been ingrained not to have sugary drinks (and as a coffee only drinker at the time) I was given sweet tea. Well as all your behaviour changes I apparently spat it at her. Jennie, Arundel, West Sussex I myself am a diabetic. Whilst I realise that some diabetics when hypoglycaemic or hyperglycaemic do sometimes do things that are out of the ordinary, I disagree with the way diabetic in your program was portrayed. I do not agree with the decision that the case where the nurse lost the use of her finger did not go to trial. I believe it should have, but for the program to simply say the case wasn't pursued due to the man being diabetic was remiss and misleading. When I have ever had a low or high blood sugar level I have never come even close to thinking about harming anyone else. I believe the situation should have been explained further and in a much clearer way. Michaela Hughes, Coatbridge, UK I was shocked to see that the first case reported on tonight's Panorama was a case of violence from a diabetic patient. My son is a diabetic, and we were warned that one of the symptoms of low blood sugar was the patient becoming violent. As traumatic as the attack on the nurse was, the patient, being a diabetic who had collapsed due to a low blood sugar (or "hypo"), should not be blamed for his actions, not being in control of his actions at the time. I'm afraid after a start like this, I have lost all respect for the reporter or the programme. This case should not have been used. I dread to think what may happen to my son when he is older and has the misfortune to suffer a hypo in public. Will he be labelled a violent thug as well?!

8 Bibliography and References Insulin Human Insulin A Decade of Experience and Future Developments Diabetes Care Dec 1993 Report to BDA Low Task Force on Letters about change over to Human Insulin 1992 Human Insulin Advice Forest & Evans 1992 Hypoglycaemia Unawareness in Diabetics Transferred from Beef / Porcine Insulin to Human Insulin - A. Teuscher; W D Berger, The Lancet August Human insulin and unawareness of hypoglycaemia: need for a large randomised trial Egger, Smith, Teuscher, BMJ August 1992 The Diabetes Handbook - Day, BDA 1986 DCCT Diabetes Control and Complications Trial 1993 Bellagio Report 1996 Hypoglycaemia in insulin requiring diabetes A patient and carer perspective IDDT 1997 Human and Animal Insulins Compared BDA Report 2000 Changing to Human Insulin BDA Balance 1993 Cochrane Review Human insulin versus animal insulin in people with diabetes mellitus Richter, Neises 2002 Cochrane Review - Short acting insulin analogues versus regular human insulin in patients with diabetes mellitus. Siebenhofer A, Plank J, Berghold A, Narath M, Gfrerer R, Pieber T. Biosynthetic Human Insulin in the Treatment of Diabetes A Double blind Crossover Trial in Established Diabetic Patients - The Lancet 14 August ) experience of severe hypoglycaemia requiring transfer to hospital and switched to porcine insulin 2) experience of hypoglycaemia, recovery with oral glucose 3) experience of irritability and frequent hypoglycaemia Warning Symptoms of Hypoglycaemia During Treatment with Human and Porcine Insulin in Diabetes Mellitus - The Lancet 13 May 1989 Hypoglycaemic symptoms of unrest, confusion and aggressiveness in treatment with human insulin reported. Diabetes and Cognitive Function The Evidence So Far BDA 1996 A Diabetic Complication Dawson 1994 (unpublished) Hypoglycaemia Real and Unreal Lawful and Unlawful the 1994 Banting Lecture V Marks 1995 Diabetes in the UK BDA 1996 St Vincent Joint Task Force for Diabetes BDA 1995 Scottish Diabetes Framework 2002 Diabetes Dialogue 2005 Diabetes State of the Nations 2005 Diabetic Books The Discovery of Insulin Michael Bliss 1982 Consumers Guide to Prescription Medicines Cooper & Gerlis 2003 edition Diabetes A New Guide Hillson1992 (1995 edition) Diabetes at Your Fingertips Sonkson, Fox, Judd1985 (1995 edition) Living with Diabetes Gomez1995 Practical Diabetes Levy 1999 Hypertension in Diabetes Feher1994 edition Insulin Dependent Diabetes Day 1986 Hypothyroidism/ Hypopituitarism Hypothyroidism Expert Report Shalet 2000 Coping with Thyroid Problems Gomez 1995 edition Assessment and Management of Thyroid Dysfunction Godden & Volpe 1975 Pituitary Disease Fact File The Pituitary Foundation Congenital Adrenal Hyperplasia Cape 2000 PTSD Post Traumatic Stress Disorder The Invisible Injury Kinchin 2001 edition Stress Reactions Turnbull 2005 PTSD Reactions Turnbull 2005 Journals MIMS- various issues since 1994 BNF British National Formulary various issues since 1994

9 Balance BDA Diabetes UK 1994 IDDT Newsletter Law European Human Rights Law Starmer 1999 (2000ed) The Legal Aspects of Child Health Dimond Prescription for Murder Dr Harold Fredrick Shipman Whittle & Ritchie 2000 The World s Worst Medical Mistakes Fido1996 Regina v Quick, Regina v Paddison (C of A 1973) R v Majewski H of L 1975/76 Mental Health Act 1983 Misuse of Drugs Regulations 1985 & Misuse of Drugs Act 1971 Headford v Bristol and District Health Authority - C of A 1994 (Disability 24 years) Vernon v Bosley QBD 1995 (psychiatric shock injury) Liability for Psychiatric Illness Law Commission 1988 R249 Goorkani v Tayside Health Board C of S Scotland 1990 Childrens Act 1989 Grandparents and Childrens Act 1989 Donoghue v Stevenson AC (Duty of Care) Caparo Industries plc v Dickman WCR (Duty of Care) Offences against the person 1861 Cunningham v North Manchester HA C of A 1994 Home Office v Dorset Yacht Co Ltd H of L 1970 Access to Health Records Act 1990 Children and Young Persons Act 1933 Chiild Abduction Act 1984 S b,a Perverting Justice Law Year Book 2000 Striking out abuse of process fraud on part of litigant presenting evidencefair trial no longer possible Turpen v Microsoft Corp Harassment Protection from Harassment Act 1997 Excluded that it was pursued for the purpose of detecting crime, preventing crime. Learning curve for Hertfordshire Constabulary to detect crime and prevent crime of patients incorrectly treated with human insulin

10 This paper represents the views of its author on the subject. These views have not been adopted or in any way approved by the Commission and should not be relied upon as a statement of the Commission's or Health & Consumer Protection DG's views. The European Commission does not guarantee the accuracy of the data included in this paper, nor does it accept responsibility for any use made thereof.

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