GHB Letter

Assemblyman Robert M. Hertzberg
Chairman, Committee on Public Safety
State of California
Sacramento, California
Fax: 916-327-6830

Subject; AB-6

Dear Assemblyman Hertzberg,

I have just become aware fo the contents of AB-6, and wish to voice my stong opposition to it.

I am a physician licensed to practice in California where I grew up and where most of my family still reside (mother, two brothers, and sister). I was appointed to the U.S. Military Academy at West Point (graduated, 1967) by Congressman John J. McFall (Manteca), and spent six years in the infantry (Ranger Battalion Advisor in Vietnam, 1970-1972) prior to attending medical school. After medical school, I served as an Army Flight Surgeon and Diving Medical Officer for 7 years, and was the flight surgeon for the Delta Force from 1982-1985. I was in private practice in Los Angeles from 1985-1990, until joining the Navy and serving in Pensacola as the Senior Flight Surgeon for the Naval Aviation Schools Command, from which I recently retired in the grade of Commander. I am now in private practice here in Pensacola.

I have recommended the use of gamma-hydroxy-butyrate (GHB) to many of my patients of all ages (particularly the elderly) for many years. AB-6 would criminalize this use, to the detriment of the health and well-being of my patients. GHB has many clinical uses, for which there are no substitutes which are so safe, non-toxic, non-habit-forming, and so effective.

GHB is a naturally-occuring substance, present in every cell in the body. It is both a precursor to and a metabolite of gamma amino butyric acid (GABA), a neurotransmitter amino acid currently available for sale in any health food store. GHB is a food supplement in accordance with the definition of food supplement as defined in the Federal Food and Drug Act.

I am a Federal court-approved expert witness on the safety and toxicity of food supplements—with particular emphasis on GHB. As stated, I have had broad personal experience with GHB on my patients. In addition, I have extensively reviewed the published clinical and toxicological literature on the subject, and have had access to and carefully evaluated the Investigational New Drug Applications (INDs) that have been submitted to the FDA (over 3,000 pages of data).

In the reams of FDA INDs that I reviewed, in which the use of GHB was evaluated for more than 15 clinical conditions, I found repeatedly words to the effect that GHB was an extremely safe, non-toxic, non-habit forming natural substance with a variety of beneficial uses. This is in Accordance with my findings in my patients. Normal use in the INDs called for 6-8 grams of GHB to be taken each night, with several studies reporting doses as high as 30 grams per day, taken for months on end, withoug adverse effects. One paper reported a subject who "accidentally" took 15 tablespoons fo GHB (approximatley 75 grams—nearly a whole bottle!), and awoke 24 hours later feeling somewhat sedated with a headache. Finally, one researcher referred to GHB as the anti-anxiety agent of choice for potentially suicidal patients, because of its lack of toxicity.

I have investegated each of the purported "GHB-related deaths" that have been reported in the media—including discussions with the medical examiners—and found these reports to be scientifically and medically unsupportable. In every case, I found that there were other factors or other substances that were the proximate cause of death. Significantly, there was usually a DEA or FDA agent guiding the medical examiner in the preparation of his report. I spoke with the Chief Medical Examiner of San Francisco County—who designed the most widely-used laboratory test for body tissue and fluid levels of GHB—who told me that he had never seen a death that could be attributed to any toxic effects of GHB.

I believe the data support the fact that GHB is an extremely safe substance, and that there is no justification for its criminalization.

I would welcome the opportunity to testify before your committee regarding any legislation concerning GHB.

Yours truly,

Ward Dean, M.D.