Howard Jeffers

oper] | 16 [Ss

Imperial College
London

Toxicology Unit S——2==~~~
Imperial College London

Charing Cross Campus

St Dunstan’s Road

London W6 8RP-

Tel; 020 8846 7107 Fax: 020 8846 7110

S.paterson@i

bimperial.ac.uk
www.imperial.ac.uk/medicine/toxicology

Dr S Paterson BSc MSc PhD
Head of Toxicology Unit
Consultant Forensic Toxicologist

Re: Response to Report to Prevent Future Deaths concerning Nature Barr (also
known as Howard Jeffers) (deceased)

Tox Ref: 0354/16

Qualifications and experience

I have a BSc degree in Physiology & Biochemistry, an MSc degree in Forensic Science and a PhD
degree in Pharmacology. I am Head of the Toxicology Unit at Imperial College London, a position I
have held since 1994. I have over 30 years’ experience of analysing samples from Coroners’ post-
mortem cases and interpreting the results.

Ireceived a Report to Prevent Future Deaths concerning Nature Barr (also known as Howard Jeffers)
Jrom R Brittan, Assistant Coroner for Inner London North dated 15 May 2017.

Coroner’s concerns

Evidence was heard stating that the analysis of NPSs is difficult owing to frequent changes in their
components and structure. The concern was that Mr Barr may have used NPSs during his admission
to hospital which may have caused or contributed to his death. However, this could not be
substantiated in the available evidence.

The concern is that there is a risk that future deaths may occur unless NPS can be more accurately
analysed and detected by toxicological testing.

The concern is that at the inquest in to Mr Barr there was no specific evidence adduced which
reassured that steps are being taken to address the risk of death from NPSs.

NPSs

The major classes of NPS available for purchase on the streets or via the internet include B-
phenethylamines, cathinones and piperazines, which were the first NPSs to make an appearance in
the early 2000s. “Spice” or synthetic cannabinoids started to appear around the same time and the
first one was identified in 2008. Within the last year another group of compounds have started to
appear, synthetic fentanyls.

For each of these classes of NPSs a starter compound has been identified, phenylethylamine (CsHi1N)
for phenylethylamines, cathinone (CoH1;NO) for cathinones, piperazine (C4H1oN2) for piperazines,
tetrahydrocannaibinol (C2)H3002) for synthetic cannabinoids and fentanyl (C22H2gN20) for synthetic
fentanyls. These starter compounds are then structurally modified eg a hydroxyl group is removed, a

Instrumentation for Analysis
Many of the NPS can be detected in Post-mortem blood if advanced technology is used. The

Potency of NPSs
Some of these compounds are extremely potent, for example one fentanyl! analogue is estimated to
have 10,000 times th ine. This makes the analysis technically very challenging and

The NPSs available on the market are continually changing. Once one has been identified and
Possibly a standard becomes available then the Suppliers of these Compounds tweak the structure of
the compound and Produce a new modified compound.

Interpretation

No pharmacological testing, clinical trials etc. have been performed on the novel compounds
available for sale on the street/internet. Even if the NPS is identified it is difficult to predict the
pharmacological effects the drug will have. Also even if a standard is available and the concentration
measured interpretation is not Possible because no reference ranges for these drugs are available.

onclusion ; ;
heal of NPSs is limited and challenging because of the number of compounds available, their

potency, lack of funding, lack of standards and lack of pharmacological data. Therefore no action is
proposed

Se Vateoso~ ; 22™4 June 2017

Dr Sue Paterson ; ;
Consultant Forensic Toxicologist

7th  July 2017 

REGULATION  28:  REPORT  TO  PREVENT  FUTURE  DEATHS  arising  from  the  investigation  into  the 
death of Nature Barr (also known as Howard Jeffers): response by the Psychopharmacology, Drug 
Misuse and Novel Psychoactive Substances Research Unit, University of Hertfordshire.  

Dear Dr Brittain, 

Thank you for your Regulation 28 Report to prevent future deaths, dated 15th May 2017, bringing to 
my  attention  the  Coroner’s  concerns  arising  from  the  inquest  into  the  death  of  Nature  Barr.  The 
members of the Psychopharmacology, Drug Misuse and Novel Psychoactive Substance Research Unit 
at the University of Hertfordshire have given careful consideration to the concerns outlined. I set out 
the actions we have taken and plan to take in response to the concerns below. 

(1)  “…  [the]  risk  that  future  deaths  may  occur  unless  NPS  can  be  more  accurately  analysed  and 

detected by toxicological testing.” 

Novel  Psychoactive  Substances  (NPS)  is  the  scientific  name  of  mind-altering  substances  also 
misleadingly  known  as  “legal  highs”.  The  phenomenon  of  NPS  began,  among  a  small  group  of 
individuals, about a decade ago but in the last few years it has grown exponentially and represent 
now a major treat in terms of public health. 

There is a growing evidence of negative effects secondary to the use of NPS. This evidence was at 
first anecdotal (e.g. media coverage), but recently the scientific community has focused its interest 
on NPS and therefore there is now a growing number of scientific studies and related publications. 
The  Psychopharmacology,  Drug  Misuse  and  Novel  Psychoactive  Substances  Research  Unit  at  the 
University of Hertfordshire is actively engaged in research to facilitate the accurate identification of 
NPS from “seized” samples, and to provide clinicians with updated guidelines to help them better 
manage  patients  presenting  with  toxicities  associated  with  abuse  of  NPS.  The  head  of  the  unit, 
Professor Fabrizio Schifano, is a full member of the Advisory Council on the Misuse of Drugs (ACMD). 
Both he and another member of the unit, Mr John Corkery, are members of the ACMD's Technical 
and NPS Committees. In addition, Prof. Schifano has recently been appointed chair of the ACMD's 
new committee on Performance and Image-Enhancing Drugs. 

Overall, unprecedented knowledge has been provided by our research group on the epidemiological, 
psychopathological  and  overdose  issues  related  to  the  misuse  of  NPS.  To  this  respect,  Professor 
Schifano has been the Principal Investigator of 6 consecutive EU Commission-funded, multi-centre 
(i.e. 12 EU countries), Novel Psychoactive Substance-based, research  

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 programmes  (since  2002).  These  have  included  the  following:  ‘Psychonaut  2002’  (2002-2004); 
‘Psychonaut  Web  Mapping  system’  (2008-2009);  ‘EU-ReDNet/Recreational  Drug  Network’  (2010-
2012); EU-MADNESS (2014-2016); and EPS/NPS (2015-2016) projects. In particular, the University of 
Hertfordshire  and  St  George's  University  of  London  co-led  the  EU-funded  EU-MADNESS  project 
“EUropean-wide,  Monitoring,  Analysis  and  knowledge  Dissemination  on  Novel/Emerging 
pSychoactiveS”. The  objective  was  to  develop  integrated  monitoring  and  profiling  of  Novel 
Psychoactive  Substances  (NPS)  in  Europe  in  order  to  prevent  health  harms  and  update  relevant 
professionals.  The  project  aimed:  to  monitor,  test,  profile,  and  feed  back  into  education  and 
prevention  knowledge  relating  to  the  types  of  NPS  emerging,  their  associated  characteristics  and 
potential harms. 

Specific actions taken to address the concern: Very little is known of the effect of NPS in individuals 
with mental health conditions. Our University of Hertfordshire (UH)-based NPS Unit has started to 
collect data on the effect of the NPS in individuals admitted in the Highgate Mental Health Centre.  

This particular project is being carried out in collaboration with two Highgate Mental Health Centre 
psychiatrists who have also enrolled for a PhD with our University (supervisor: Dr Ornella Corazza). 
The  aim  of  their  study  is  to  gather  new  information  on  the  effect  of  the  NPS  among  vulnerable 
individuals,  but  also  to  develop  evidence-based  policies  that  will  help  to  control  and  reduce  the 
damage caused by these compounds.   

In 1997 whilst working at the Home Office, John Corkery helped to set up the National Programme 
on Substance Abuse Deaths (NPSAD), which is based at St George's University of London. He also 
served on the Council's reconvened Drug-Related Deaths Working Group, having worked as a Home 
Office Official on the original Working Group in 1999-2000. Professor Fabrizio Schifano joined the 
NPSAD in 2000. Although their formal association with NPSAD has ended, they both continue to work 
together on research projects and publish together. 

Our  efforts  are  also  focused  to  improve  in-field  methods  of  NPS  identification  in  products  using 
analytical approaches (led by Dr Jacqueline Stair).  The main approach we are currently researching 
in handheld Raman spectroscopy which allows the identification of key molecular scaffolds via the 
scattering of light. This tool is to enable the quick identification of NPS at borders, from seizures, or 
from individuals. Due to the > 650 NPS that exists, Raman spectroscopy can differentiate between 
closely related NPS analogues which can vastly reduce the number of substances sent to forensic labs 
for full analytical testing, which can be costly and time-consuming. A particular challenge is that NPS 
products are often available as complicated mixtures of NPS, adulterants, and cutting agents. To this 
end, we are focused on examining sophisticated mixture algorithms for their effectiveness of NPS 
identification in product mixtures often found with ‘street’ samples. As only a sample of suspected 
products can usually be send for full analytical testing/ NPS subsequently identified, this technology 
can improve presumptive analysis throughput for identification of more NPS products arriving in the 
EU and UK. The idea is to greatly reduce the NPS making it to the UK market for human consumption 
via improved identification. 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 As  an  extension  of  this  work,  Dr  Amira  Guirguis  recently  completed  a  PhD  (supervised  by  Dr 
Jacqueline  Stair,  Dr  Stewart  Kirton  and  Dr  Suzanne  Fergus)  on  the  ‘identification  of  NPS  using 
spectroscopic  and  chemometric  approaches’.  Her  work  examined  the  issues  surrounding  the 
appropriate  selection  of  analytical  conditions  and  instrumentation  for  the  detection  of  NPS;  a 
scientifically-robust  approach  to  construct  compound  libraries  that  have  relevance  to  ‘in-field’ 
analysis  and  data  analytical  science  that  examined  approaches  that  can  be  employed  to  develop 
accurate NPS identification algorithms from spectroscopic information for use by non-experts. This 
work aimed at providing advice and support in the following areas: General education on NPS for 
pharmacists, common cutting agents and adulterants in NPS samples, what they are, how to identify 
and classify them, health harms posed by NPS and harm reduction techniques. Additionally, research 
was carried out with respect to education on the strengths and limitations of in-field techniques used 
for the identification of NPS, education on using handheld Raman techniques in the field and advice 
on improving the signals obtained and hence increasing the chances of detecting NPS. The technical 
aspects of these studies to aid accurate identification of NPS in “street” samples included: 

  Strategies to reduce fluorescence and enhance signal to noise in field Raman measurements. 
  Approaches  to  validate  and  use  spectral  libraries  that  can  identify  and  categorise  chemical 

species present in complex mixtures of poorly-defined provenance. 

  Signal processing  approaches  that  can  be  employed to  introduce  greater  discrimination  for 
adulterants  that  often  contribute  to  the  noise  in  Raman  spectra,  which  pose  a  barrier  to 
identification of unknown constituents in typical mixtures. 

  Development of chemometric approaches to build a spectral library that provides appropriate 

 

cover of the entire chemical space underlying known NPS. 
Incorporation  of  common  adulterants  and  cutting  agents  into  high  resolution  spectral 
databases  in  order  to  develop  categorisation  approaches  using  an  expanded  ‘importable’ 
library and subsequent attempts to deploy that strategy for hand-held device, remote analysis. 

Dr Guirguis is also leading on potential collaborations with the Royal Pharmaceutical Society (RPS), 
consultant  psychiatrists,  addiction  specialists,  general  community  pharmacists,  mental  health 
pharmacists and mental health nurses in the UK to assess the baseline knowledge on NPS and the 
design of education and training courses on NPS targeting healthcare professionals. Future work over 
the next year will include collaborations with French psychiatrists and addiction specialists to design 
a tool that clinicians can use for the efficient identification of NPS. She is also leading on a two-fold 
study: 1) to train and educate police officers on the use of handheld Raman instruments which could 
be employed on road-sides as well as in prisons for the identification of solid samples confiscated 
from prisoners and 2) to train and educate police officers and healthcare professionals who work in 
prisons on NPS and their categorization, which may potentially enhance the management of NPS use 
and assist in treatment decision-making. Her work is currently exploring developing undergraduate 
pharmacy curricula on NPS, which can be piloted nationally. 

3 

 
 
 
 
 
 
 
 
 
 
 
 In order to compliment and extend the work carried out to systematically classify existing NPS, Dr 
Stewart Kirton, Dr Jacqueline Stair and Dr Suzanne Fergus are leading research into predicting the 
next generation of chemical scaffolds that could be exploited by those who synthesize and distribute 
NPS.  One  PhD  student  (Michelle  Botha)  has  used  computers  to  identify  a  series  of  commercially 
available  compounds  that  have  the  potential  to  bind  to  the  CB1  receptor,  but  crucially  are 
significantly different with respect to their chemical structures from any of the identified synthetic 
cannabinoids. Currently, biological testing is underway to establish if the activity predicted in silico is 
apparent  in  vitro/in  vivo.  Where  biological  activity  exists,  the  spectral  properties  of  the  active 
compounds will be fed into the computational models that have previously been described. For the 
first time, this  will provide  a technology  capable  of  identifying  and  classifying  molecular  scaffolds 
prior to them appearing on the market. Funding will be sought to extend the scope of this research 
into other classes of NPS beyond that of the synthetic cannabinoids. 

We  hope  that  our  response  demonstrates  the  actions  that  are  being  taken  here  in  the 
Psychopharmacology,  Drug  Misuse  and  Novel  Psychoactive  Substances  Research  Unit  at  the 
University of Hertfordshire to address the concerns around the real and significant dangers posed by 
the  abuse  of  NPS.  As  you  can  see  our  approaches  to  tackling  the  problem  are  multi-faceted  and 
extend from physical science and informatics, through medicinal chemistry and biological evaluation 
to clinical guidance and epidemiology. However, it is important to be clear that at this time we have 
no plans to develop techniques for the identification of NPS and their metabolites from biological 
matrices (e.g. blood and urine). The expertise of the members of the group does not extend to this 
type of biological analysis, and we feel others are better placed to address this issue. 

Yours Sincerely, 

Stewart Kirton PhD, CChem, FRSC, SFHEA 
Head of Pharmaceutical Chemistry 
Psychopharmacology, Drug Misuse and Novel Psychoactive Substances Research Unit 
University of Hertfordshire 

4

Dr R. Brittain 
HM Assistant Coroner 
Inner London North 
St Pancras Coroner's Court 
Camley Street 
London N1C4PP 

Malvern Hills Science Park 
Geraldine Road 
Malvern 
Worcestershire 
WR14 3SZ 
Tel:  01684 585282  

 www.alereforensics.com 
E-mail: simon.elliott@alere.com 

RE: Regulation 28 in relation to BARR 

Dear Dr Brittain, 

24th May 2017 

I  am  writing  in  response  to  the  Regulation  28  Report  to  prevent  future  deaths  received  on 
15th  May  2017.  I  understand  that  Mr  BARR  (aka  JEFFERS)  died  on  23rd  February  2016 
having  been  behaving  bizarrely  the  previous  day.  He  was  found  collapsed  and  in  cardiac 
arrest  at  5:36  pm  on  23rd  February  and  was pronounced  dead  at  6:46  pm.  It  is  understood 
that on searching the ward a substance labelled as “Kronic” was found which was reported to 
contain 
the  synthetic  cannabinoid  5F-CUMYL-PINACA.  Toxicological  analysis  was 
undertaken  (including  specific  analysis  for  this  substance)  and  according  to  the  toxicology 
report  of  Imperial  College  London,  only  modafinil  and  olanzapine  were  detected  (no  5F-
CUMYL-PINACA or other drugs within the range of screening performed). 
At  the  inquest  on  5th  May  2017,  the  Court  heard  evidence  that  the  nature  of  NPS  (New 
Psychoactive  Substances)  is  such  that  analysis  of  these  compounds  is  difficult  owing  to 
frequent changes in their components and structure. There was a concern that the deceased 
may have used NPS during his admission to hospital which may have caused or contributed 
to death but this could not be substantiated by the available evidence. You were concerned 
that there was no specific evidence adduced which assured you that steps are being taken to 
address the risk that future deaths may occur unless NPS can be more accurately analysed 
and detected by toxicological testing. 

Whilst we were not directly involved in the case, I welcome the Coroner contacting me and 
also identifying us as a prominent toxicology provider. I believe I may be able to assist HM 
Coroner with the issues involved and the concerns. In order to do this, I will address the case 
of Mr BARR specifically as well as the wider issue of NPS and toxicology. 

The death of Mr BARR (aka JEFFERS) 

The  toxicology  report  indicates  that  screening  for  drugs  in  blood  was  performed  utilising  a 
“general  screening”  approach  which  is  appropriate,  although  the  database  upon  which 
detection/identification  is  based  on  may  be  limited  as  although  “new  psychoactive 
substances”  was  cited,  the  actual  NPS  included  was  not  stated.  Nevertheless,  the  key 
feature of this case was the seizure and analysis of the suspected drug product used “Kronic 
Black Label”. This is especially important nowadays in NPS testing as often they may only be 
unlabelled  white  powders,  tablets,  liquids,  herbal  plant  material  or  branded  products,  the 
latter having no consistent relation to the brand and the contents.  

FORM Letter 0034.05  

22.08.2016 | SE LGM 

Forensics Ltd, company no. 06167670. VAT registered no. 926 4130 39. 
Also trading as Alere Forensics (Previously ROAR Forensics). 
Additional office: Windsor House, Ackhurst Business Park, Chorley PR7 1NY 

 
 
 
        
 
 
 
 
 
 
 
 
 
 
 Subsequent  analysis  of  the  “Kronic”  product  identified  5F-CUMYL-PINACA  which  is  a 
synthetic  cannabinoid first  seen  in the  UK  in  late  2014. It  appears  analysis  of the  blood for 
this  compound  as  well  as  3  other  synthetic  cannabinoids  detected  no  compounds.  It  is 
unclear if this analysis was performed by Imperial College or not but as stated in the report, 
there are hundreds of potential compounds so it is unclear why only 3 additional substances 
were  analysed  for.  Nevertheless,  focusing  on  the  suspected  drug  in  question  was  entirely 
appropriate.  The  reason  for  its  apparent  absence  in  the  blood  could  be  due  to  it  being 
present  at  a  concentration  below  the  limit  of  detection  (thought  to  be  0.25  ng/mL  for  the 
additional  3  and  not  sure  if  this  also  applied  to  5F-CUMYL-PINACA).  As  there  are  no 
published concentrations in post-mortem blood for 5F-CUMYL-PINACA it is not known if this 
limit  of  detection  was  sufficient  or  not  but on the  whole such  a  limit should  suffice.  Another 
reason  is  that  the  substance  may  have  metabolised  and  been  eliminated  from  the  blood 
during the time elapsed between using the substance and death. In this case this may have 
been  many  hours  and  although  no  specific  data  exist  for  the  expected  time  window  of 
detection,  current 
rapid  metabolism/elimination  of  synthetic 
cannabinoids so it is possible that disappearance from the blood may have occurred. A third 
reason may be that synthetic cannabinoids are known to be unstable, although 5F-CUMYL-
PINACA does not possess the chemical components found in current synthetic cannabinoids 
that are  highly  prone to instability  in blood.  A final  reason for  its  apparent  absence  may  be 
that  Mr  BARR  had  not  used  the  product  or  had  used  a  different  product  (if  at  all)  recently 
prior to death. I am not aware if these scenarios were discussed during the inquest. 

information  suggests 

If  it  assists  HM  Coroner,  our  approach  would  have  also  been  to  undertake  a  general  drug 
screen but in both blood and urine which would have included a significant number of known 
(over 1000) and unknown compounds - including many NPS. A list is available if required. In 
such  a  case,  along  with  analysis  of  the  “Kronic”  product,  we  would  have  also  applied 
advanced  techniques  to  analyse  for  latent  drug  metabolites  in  the  urine  especially  for 
synthetic cannabinoids as due to their purported rapid metabolism/elimination, they are often 
present as metabolites only. Regardless we would have described the various scenarios that 
may have occurred and provided extended interpretation in the report. This is no criticism of 
the  approach  by  Imperial  College  but  merely  provides  HM  Coroner  with  some  form  of 
comparative approach to inform my next point. 

New Psychoactive Substances 

Clearly the inquest heard evidence of the challenging nature of NPS and their analysis. This 
is due to a number of things but is largely in part due to the changing chemistries, sometimes 
potent  nature  leading  to  very  low  concentrations,  lack  of  reference  material  to  enable  “pro-
active”  method  optimisation  and  potential  instability  of  such  substances  in  biological  fluid  – 
especially  post-mortem  samples.  This  is  not  helped  by  the  variable  analytical  methods 
employed  by  toxicology  organisations  as  there  is  no  one  “gold  standard”  technique  or 
instrument  as  a  multi-technique  approach  is  the  best  option  and  this  requires  time  and 
investment,  that  is  not  possible  for  all  or  many  organisations  or  palatable  in  the  current 
climate of lower costs and quicker turnaround time for analysis. So you raise an appropriate 
concern  in  that  how  is  this  being  addressed  by  the  toxicological  community.  The  short 
answer is that it is but also it isn’t or has not been sufficient across the board. You will have 
seen  in  this  single  case,  a  slightly  different  approach  outlined  by  two  long-standing  and 
experienced organisations, therefore concern is warranted if this is extrapolated to the wider 
laboratory marketplace. 

FORM Letter 0034.05  

22.08.2016 | SE LGM 

Forensics Ltd, company no. 06167670. VAT registered no. 926 4130 39. 
Also trading as Alere Forensics (Previously ROAR Forensics). 
Additional office: Windsor House, Ackhurst Business Park, Chorley PR7 1NY 

 
 
 
 
 
 
 
 
 The  toxicology  community  is  aware  of  the  challenges  and  problems  involved  in  NPS  and 
there  is  a  concerted  effort  to  first  ensure  they  are  aware  of  the  various  drugs  of  concern, 
whether  this  is  through  awareness  of  the  scientific  literature  and/or  attendance  at  scientific 
meetings (both national and international) where NPS are invariably discussed, not least at 
the  UK  &  Ireland  Association  of  Forensic  Toxicologists  (UKIAFT)  where  Dr  Paterson  and 
these  meetings  (especially 
myself  are  Chair  and  Vice-Chair,  respectively.  Within 
internationally) analytical methodologies are presented and published but of course it is the 
duty  of  the  toxicologists  and  organisations  to  assess  whether  they  have  the  necessary 
opportunity to replicate such work.  

For our organisation in particular, we regularly attend and present at such meetings as well 
publishing  on the topic of  NPS  (see  list  of  publications on our  website)  and importantly  are 
also  actively  engaged  in  the  UK  and  European  Early Warning  Systems  for  NPS.  I  am  also 
personally  a  Member  of the  Expert  Committee for  Drugs  and  Drug Dependence (ECDD)  at 
the  World  Health  Organisation  that  prioritises  NPS  for  assessment  for  international  drug 
control  as  well  as  working  directly  with  the  United  Nations  Office  on  Drugs  and  Crime 
(UNODC)  that  monitor  the  situation  worldwide.  This  has  resulted  from  my  many  years 
involvement in the investigation and identification of NPS (sometimes for the first time in the 
UK,  Europe  and  the  world)  which  has  resulted  from  a  significant  time  investment  and 
determined  effort  in  such  investigations  on  the  back  of  clinical  and  post-mortem  toxicology 
casework.  We  also  work  with  Liverpool  John  Moore’s  University  to  obtain  synthesised  or 
characterised reference material of NPS that are newly on the market or have yet to become 
fully  commercialised.  This  is  subsequently  coupled  with  publications  to  allow  other 
laboratories to detect and identify such substances. This particular approach has been very 
successful  in  many  cases  on  behalf  of  HM  Coroners  and  the  Police,  with  us  being  able  to 
pre-emptively  identify  NPS  that  have  had  a  positive  impact  on  the  investigation;  including 
cause  of  death  and  driving  under  the  influence  in  particular.  We  also  provide  training  for 
stakeholders (HM Coroners, Coroners’ Officers, Pathologists and APTs) in relation to current 
drugs  and  toxicology.  Even  for  ourselves  there  are  still  challenges  such  as  ensuring 
methodologies  are  kept  up-to-date  and  potential  substance  instability  is  researched  and 
understood;  to  this  end  we  regularly  accommodate  university  MSc  studentships  (including 
King’s College London and the University of Birmingham) for short-term projects to do this. 

In conclusion, I hope some of these comments address some of your entirely valid concerns 
but  there  is  also  a  recognition  that  it  requires  investment  and  effort  of  all  parties,  not  least 
toxicology  providers,  to  move  forward  with  this.  Despite  variations  in  legislation,  NPS 
continue to be a challenge to all those concerned and you rightly highlight that improvements 
should  be  made  to  prevent  future  deaths.  If  it  assists,  I  would  be  happy  to  discuss  any  of 
these  aspects  with  yourself  and  HM  Senior  Coroner  further,  as  well  as  providing  any 
analytical support for the District. 

Yours sincerely 

Dr Simon Elliott PhD, BSc, MRSC, MCSFS, CSci, ERT 

(Consultant Forensic Toxicologist, Managing Director) 

FORM Letter 0034.05  

22.08.2016 | SE LGM 

Forensics Ltd, company no. 06167670. VAT registered no. 926 4130 39. 
Also trading as Alere Forensics (Previously ROAR Forensics). 
Additional office: Windsor House, Ackhurst Business Park, Chorley PR7 1NY