From David Love:
(ref: http://forums.whyweprotest.net/threads/ ... cian.91830 )

Scanned & now OCR'd, two pages from the "Intervention Report" dated 17th June 2011, plus the cover page.

These are the pages that David can release and which regard the use of Niacin.


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COURTESY TRANSLATION

Regional Service Quality and Complaints Commissioner Office

Our Reference: 2010-00237

CONFIDENTIAL 1

INTERVENTION REPORT

Name of the Resource: Narconon Rehabilitation Center


Person in charge of the case: Mr. Denis Grenier
Regional service quality and complaints commissioner
06-17-2011

1 NOTICE: A Person Receiving this document regarding the complaint record of a user is required to respect the confidentiality of its content as provided in the Act Respecting Health Services and Social Services.


Agence de la santé et des services sociaux
de la Mauricie et du Centre-du-Québec

Page 1 of 8

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Narconon Rehabilitation Center 2010-00237

The complaint brought to our attention raises several issues related to the chosen approach by the center and the safety of users.

> Use of niacin and medical monitoring

On this subject, it should be noted that it is not up to the regional service quality and complaint commissioner to assess the quality of the medical intevention in the complaint investigation. In Quebec, it is the responsibility of the Collège des médecins. However, Narconon makes sure that every user who signs up with them consults a doctor to ensure they are able to follow the program. The documents provided also indicate that any subsequent medical treatment, prescriptions, analysis or other requests is the responsibility of the user. Although, if necessary. Narconon will assist them in obtaining appointments with doctors, dentists or other healthcare providers, and arrange for transportation (fees and transportation costs are the responsibility of the user)3.

As part of the complaint investigation, we read a document written in 2010 by the Institut national de santé publique du Québec entitled Energy Drinks: Risks Related to Consumption and Public Health Prospects. Chapter 5 of this document deals with health effects of the various energy drink components. Section 5.1.7 of this chapter focuses on the B-complex vitamins, especially niacin.

It states that "Niacin is the B-complex vitamin for which the potential for toxicity is greater. Therefore, depending on the person's age and condition, the recommended daily dose may vary between 2 and 35 mg (whereas Narconon's program suggests a daily dose of up to 5000 mg).

Thus, "Some effects are observed starling with a dose of 30 mg daily. In fact, regular ingestion of a high dose of niacin (30 to 1000 mg) in the form of supplements or food fortification may cause flushing, i.e., sudden redness in the face, neck and chest, accompanied by itching, tingling and a burning sensation. Hepatotoxicity, intestinal disturbances, decrease in glucose tolerance, decrease in excretion of uric acid, hypotension, drowsiness, tachycardia, arrhythmia, dizziness and headaches are reported in intoxication cases. However, in moderate doses and for limited periods, niacin is a vitamin with low toxicity. Moreover, no adverse effects were associated with the consumption of niacin naturally present in food."

In our opinion, we are confronted to diametrically opposed information and perceptions regarding the use of niacin. While information provided by Narconon presents niacin as a contributor to detoxification, the document written by the Institut national de sante publique states the dangers of toxicity associated with it. This contradiction raises important questions, especially regarding the users health and safety. For example, if, as suggested in the public health document, niacin presents risks of toxicity, is absorption of high doses a risk to users health and safety? If so, what should the medical monitoring be? Faced with such different interpretations, what is the center's or physician's obligation in regards with information to be given to the user on the risks and possible consequences of treatment?


3 Narconon Trois-Rivières Admission et entente de services -
consentement du candidat (document on admission and service agreement — user's consent),
may 2006, page 2. Op. cit., page 42.

Agence de la santé et des services sociaux
de la Mauricie et du Centre-du-Québec

Page 5 of 8

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Narconon Rehabilitation Center 2010-00237


As previously mentioned, this issue could be addressed to the Collège des médecins du Québec. However, we believe that the situation will be clarified as part of the certification process of the center. This issue is addressed below.

> Approach recognition

In order for the center to be certified, they must have an approach that has already been recognized, as stated in Article 6 of the certification manual: "Activities regarding drug, alcohol or pathological gambling addiction must be part of an intervention program based on a known approach."

In this regard, the Centre Dollard-Cormier — Institut universitaire sur les dependences has written a document (recognized by the ministère de la Santé et des Services sociaux) on the accepted practices in the treatment of young people and adults struggling with addiction. This document is a guide for people in charge of rehabilitation centers to validate their approach.

The certification process put forward by the Government of Quebec provides the following steps:

• An evaluation team from the Conseil québécois d'agrément (CQA) visits the center and makes sure that they comply to conditions in order to obtain their compliance certificate;

• The evaluation team from the CQA delivers the compliance audit report to an experts committee. This committee must make sure that the evaluation process was done in respect with established standards, validate the analysis produced by the evaluation team, and make a recommendation for the issuance of the certification to the CQA, the correctives measures and required delays as well as the follow-up recommended;

• The CQA must deliver the committee's recommendation to the Agence de la sante et des services sociaux of the region where the center is located;

• Once it receives the report, the Agence de la sante et des services sociaux must analyze the recommendation made before taking the decision to issue the compliance certificate or not.

The description of the process allows us to understand the responsibilities of those who must rule on the validity of the approach advocated by a drug, alcohol or pathological gambling addiction rehabilitation center. First of all, the experts committee has to decide if the center is in compliance with the certification conditions, including the validity of the approach, and then has to make a recommendation to the Agence de Is santé et des services sociaux. Then, the Agence has to analyze the recommendation made.

In conclusion on that matter, it is not up to the regional service quality and complaints commissioner to decide on the validity of the approach advocated by Narconon. It is up to the different people involved in the certification process. However, considering the remaining questions regarding the use of niacin following our analysis, it appears important to us that these matters are carefully reviewed by the deciding people as part of the certification process.

Agence de la santé et des services sociaux
de la Mauricie et du Centre-du-Québec

Page 6 of 8

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