National Drug Strategy Consultation inbox

National Drug Strategy Consultation

MDP 27

GPO Box 9848

Canberra ACT 2601

February 23rd, 2010

Harm Reduction VictoriaSubmission to National Drug Strategy Consultation

About Harm Reduction Victoria Inc.

Harm Reduction Victoria, formerly VIVAIDS Inc, is a membership driven, not-for-profit organisation with a mission to reduce drug related harms accruing to people who use drugs and to the wider community and to promote health. Incorporated in 1987 (as VIVAIDS), the organisation has played a key role in mobilising the IDU (injecting Drug User) community in response to the threat of HIV/AIDS. Since the heyday of the HIV/AIDS epidemic, HRVic has taken on a wider brief of drug user health issues. Through peer education, advocacy, workforce development and community development processes, HRVic addresses issues such as Hepatitis C, Heroin overdose, ATS related harms, the needs of drug users in treatment, drug-related harms in the dance-music scene etc. As the only organisation in Victoria with a mission to represent the needs and perspectives of people who use currently illicit drugs, HRVic provides advice and input on drug-use issues to the community, to government at all levels and to agencies and service providers whose work impacts upon the health and rights of people who use, or have used, illicit drugs. HRVic is an active member of the national network of peer-based drug users’health organisations, with AIVL, the Australian Injecting and Illicit Drug Users League, as our national peak body.

HRVic has sought input to this National Drug Strategy consultation through this submission in our own right, as well as through our participation in the National Drug Modelling Project’s Drug Strategy Roundtable, from which a submission based upon the discussions of the experts present will be tendered. HRVic has also contributed directly to the submission prepared by the Victorian Alcohol and Other Drugs Association (VAADA) and has held discussions on many of the key issues with AIVL, which may be refected in their submission to this consultation.

Summary of Recommendations

  1. HRVic strongly affirms the continued appropriateness of an overarching national strategy, with buy-in from all states and territories, addressing alcohol, tobacco, prescribed and over-the-counter psychoactive medications and illicit drugs.
  2. Harm Reduction Victoria urges policy makers to accept the proposition that the overarching goals and principles for managing currently legal drugs, such as alcohol, and the currently illegal drugs (bearing in mind that tea, coffee, alcohol and tobacco have all been proscribed by governments in their times) must be uniform and consistent.
  3. Harm Reduction Victoria suggests that the choice and development of policy interventions should be based upon the best available evidence of the causes and dynamics of harms arising from problematic use of substances, with the best logic and evidence-base for the overall effectiveness of the interventions. Policy needs to be pragmatic and rational, reflecting the world as it is, rather than utopian and moralistic, and to seek to reduce drug-related harms while respecting the diversity of human behaviours, values and choices and the inherent human rights and dignity of individuals.
  4. HRVIC recommends that the governance structures and processes of the NDS needs to be clarified and strengthened.
  5. The NDS should consist of a high-level document outlining global strategic goals, with a chain-of logic analysis of the key principles and clear exposition of the evidence base underlining the strategic directions and the hierarchy of objectives. This should be supported and executed through lower-level, more specific action plans relating to particular priority issues (areas of drug related harms), in which resourcing, roles and responsibilities and progress evaluation measures are made explicit.
  6. The Commonwealth should not only involve and include the community in its deliberations on drug policy, but needs to work with community representatives and other experts to better inform and engage the broader public on drug policy and the theoretical and evidence-base underpinning it. Some experts describe this as a need to improve the general population’s evidence-literacy in the AOD area.
  7. The NDS should outline its own policy development goals over the period of the strategy and prioritise the areas of research / evidence building needed to inform and guide the development of policy.
  8. The mechanisms of Treasury, including productivity and other economic analysis, should be better used to support whole-of-government effort and to prioritise the place of AOD policy in the overall business of government and within the health, social inclusion and related reform agendas.
  9. Harm Reduction Victoria recommends that the NDS encourages a rigorous research and evaluation effort into the efficacy and cost-effectiveness of our current drug laws and law enforcement activities in achieving benefit to society. Such evaluations must also identify and asses the potential and actual unintended consequences of such supply control and law enforcement approaches. The findings from this research should guide the future development and transformation of AOD policy to meet the needs of the future.
  10. In the interim, it is recommended that the current balance of effort and expenditure be reconfigured, so that harm reduction, education and treatment measures make up the greater part of the funded effort. In the area of supply control, more consideration should be given to developing regulatory mechanisms, rather than the enforcement of criminal sanctions.
  11. As one of the most under-resourced and under-evaluated areas of intervention, it is recommended that the role of harm reductive peer education in working with drug users to address specific areas of drug-related risk and harm should be greatly expanded. This expansion should include provision for the development and evaluation of best-practice models.
  12. Harm Reduction Victoria recommends that the term “Harm Minimisation”, referring to Australia’s Three Pillars AOD policy since 1985, should be replaced with a clearer, up-front declaration of one over-arching principle: Harm Reduction.
  13. Harm Reduction Victoria strongly cautions against the inclusion of any reference to “Prevention” in the title of, or as an overarching principle in any new iteration of National Drug Policy.
  14. HRVic recommends that the NDS maintains and extends the current emphasis on reducing alcohol-related harms in the community. We support the call for more investment in developing evidence-based interventions and approaches for reducing alcohol-related harms and recommend that the lessons learned are applied to the broader area of alcohol and other drugs policy.
  15. HRVic commends the educative and harm reductive approach taken towards tobacco use, but urges greater mindfulness of the dignity and rights of those who have become habituated to the drug. Utilising or allowing stigma and discrimination to play a role in social policy, however worthy the aim, is ultimately harmful to the whole society as well as to the victims of the stigma.
  16. HRVic has similar concerns about the use of taxation and increased pricing to deter smoking. Undoubtedly, this penalises long-term users, many of whom will face very difficult if not impossible challenges to becoming abstinent. As many socially and economically marginalisedsections of the community have higher rates of tobacco dependence, the use of taxation and price to reduce demand many in many respects further entrench poverty and disadvantage. We urge more investigation of other means of reducing smoking rates, such as those employed in California, and for research into the unintended social consequences of increased taxation on tobacco users. We also suggest that subsidised maintenance or substitution therapies should be investigated as a means of sheltering highly dependent people who are economically disadvantaged from the impacts of higher taxes and prices on tobacco.
  17. HRVic recommends that the NDS provide leadership and guidance in the management and reduction of harms from medically prescribed opiates and benzodiazepines. Simply classifying any problematic use as simply “misuse” and relying solely upon regulatory controls and the identification of “problem” consumers and prescribers ignores the iatrogenic origin of such dependence and suggests no solution to the very real problems experienced by those who have become dependent on these medications. Even where problematic use has developed, the patient may still have the original legitimate need for which the drugs were originally prescribed and cannot, with respect to human rights, simply be “cut off”.
  18. HRVic recommends the development of systematic approaches to harms arising from prescribed psychoactive medications, such as the need for increased access to pain and addictions specialists to support both patients and prescribers, improved access to opioid substitution pharmacotherapy, particularly in regional areas and an investigation of the impact of poor pain management on patient welfare and quality of life.
  19. HRVic submits that the discrimination and vilification towards drugs users should be rejected as a tool of social policy and recognised as harmful to its victims and to the community at large. The discrimination experienced by people identified as drug users should be named as one of the principle harms to be addressed through the NDS.
  20. All interventions and instruments of alcohol and other drug policy should be assessed for their potential to inflict or abet discrimination and stigma. Alcohol and other drugs policy should include in its aims the social inclusion and integration of all people affected by alcohol and other drug issues.
  21. HRVic calls for greater integration of NDS and BBV policy, with shared support for and engagement with the affected communities via their user organisations, and greater emphasis on the development and implementation of peer education approaches, with respect to BBVs as well as other drug-related harms
  22. HRVic recommends that the NDS prioritises an evaluation of national treatment services for alcohol and other drug services and explores ways in which national coordination of service improvements can lead to better outcomes for patients and for the community.
  23. HRVic calls upon the NDS to establish priorities and processes for improving access to affordable ORT pharmacotherapy services across Australia and the removal of barriers to equitable standards of care and the social inclusion and participation of pharmacotherapy consumers. In particular, the NDS should work with the PBS and with state and territory health departments to address the issue of fee-related poverty and disadvantage and to ensure that all Australians have reasonable access to services.

Role and Scope of National Drug Strategy

  1. HRVic strongly affirms the continued appropriateness of an overarching national strategy, with buy-in from all states and territories, addressing alcohol, tobacco, prescribed and over-the-counter psychoactive medications and illicit drugs.

While the economic and cultural contexts, regulatory frameworks, patterns of use and the health and social consequences pertaining to the multitude of substances thus covered will vary enormously, the embodiment of a uniform set of overarching principles and policy objectives continues to be of enormous importance. All of these substances are used voluntarily by individuals seeking subjective benefits from their psychoactive properties. All have inherent risks of harms attending their use and all are subject to use in ways that can be deleterious to the health of the consumer, or which might involve risk of harms to others.

While all potential harmful chemical substances need to be managed, in terms of their purity, safe manufacture, use and transport, their availability to the public etc, it is the mood or behaviour modifying properties of the psychoactive chemicalsof common use that necessitate a particular management framework. While we remain short of a consensus agreement on a uniform set of guiding principles for this management framework, which is complicated my historical, cultural and political factors, most would agree that the system of management should be based upon respect for the autonomy of individuals, concern for health and the prevention or reduction of harms to consumers of drugs (including alcohol) where possible and the protection of the rights of others from the harmful sequelae of drug using behaviours.

  1. Harm Reduction Victoria urges policy makers to accept the proposition that the overarching goals and principles for managing currently legal drugs, such as alcohol, and the currently illegal drugs (bearing in mind that tea, coffee, alcohol and tobacco have all been proscribed by governments in their times) must be uniform and consistent.

If we expect to have credibility with the people who use substances, an essential condition if we seek to influence their choices and achieve our aims, we cannot appear to be arbitrary or discriminatory towards them. Aiming to prevent the use of, say, cannabis per se, while being content to simply reduce the problematic use of alcohol is logically inconsistent. An approach which condones the use of a drug of majority choice, however harmfully used, and punishes the use of drugs of minority choice, which may be less harmful, will be seen as cynical and arbitrary and not based upon principle, just, or informed by science. Young people are particularly sensitive to perceived injustice and hypocrisy, so one consequence of our ‘schizophrenic’ approach to drug control is to severely weaken our capacity to speak credibly to young people about the very real and substantial risks and harms associated with the use of all drugs.

A great many policy levers are available for influencing the production, availability, trade and consumption of substances.

  1. Harm Reduction Victoria suggests that the choice and development of policy interventions should be based upon the best available evidence of the causes and dynamics of harms arising from problematic use of substances, with the best logic and evidence-base for the overall effectiveness of the interventions. Policy needs to be pragmatic and rational, reflecting the world as it is, rather than utopian and moralistic, and to seek to reduce drug-related harms while respecting the diversity of human behaviours, values and choices and the inherent human rights and dignity of individuals.

Because the alcohol, tobacco and other drugs (AOD) area is so vast and complex, and because there are so many intersections and cross-overs between AOD issues and other areas of government policy and administration, eg public health and social services, law enforcement, justice (inter alia) the advantages of a coherent drug policy reference-point with currency across all government jurisdictions and the disadvantages of related social policy and services working at cross-purposes are obvious. Perhaps as importantly, the health and social challenges faced by the community from the problematic use of psychoactive substances continue to grow. If significant progress is to be made in reducing harms and enhancing standards of health, a concerted, consistent and robust national effort is required.

Decline in stature of alcohol, tobacco and drugs policy

HRVic has detected a growing perception amongst many of the experts and opinion leaders in the AOD area that the profile and importance of drug policy has fallen in the national consciousness. This may perhaps be reflected in the current Federal Government’s first term reform agenda. The current workplace relations reforms, the education revolution, the social inclusion agenda, hospital and health reform and environmental sustainability agendas proceed at great pace and depth, while drugs policy receives little attention. Given the huge impact of alcohol and other drugs in our economy, our social lives and our health system, together with the enormous remaining challenge of developing more effective and appropriate means of reducing drug-related harms, this lack of commitment towards AOD in the national agenda is regrettable. Without a strong central AOD policy framework to provide consistent and evidence-based approaches, then where alcohol and drug issues arise within other major areas of policies, such as indigenous health, there will be a risk that the AOD policy components will be contradictory or running to divergent agendas.

HRVic suggests that the declining profile of AOD policy in national affairs may be partly due to a lack of role clarity and chain-of-command developing in the governance and execution of NDS over the last decade and a half, together with the lessened sense of crisis over HIV/AIDS,which had impelled robust action in the past. It may also be true that the community as a whole has not been kept engaged or particularly well informed in this area. Certainly, the temptation by politicians to play the “public peril / law and order” card when elections are in the air and to avoid at all times any rational debate or exposition of the evidence-base around drug policy and drug-related harms has not enhanced to the capacity of governments to progress AOD policy in the overall business of government, or to stimulate the nuanced understanding in the community that is required if there is to be any resolute action in the future.