Australian Drug Foundation submission to the
the consultation on
“Australia’s national drug strategy – beyond 2009”
28 February 2010
About the Australian Drug Foundation (ADF)
The ADF is a charitable, not–for-profit, independent organisation, founded in 1959 as the Alcoholism Foundation. The mission of the ADF is to work together to prevent alcohol and other drug harm in communities. The ADF works within a philosophy of harm minimisation. The ADF programs and services are organised under the three main areas of Policy, Innovation and Sector Development, and Community Development. The ADF operates across Australia and has strong international links.
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Summary
The ADF welcomes and supports the development of the next phase of the National Drug Strategy.
The ADF makes the following comments and recommendations:
To be more effective and relevant the NDS should more clearly link to and give direction to implementation processes.
The philosophy of harm minimisation should be retained but confusion around the term needs to be addressed. Greater emphasis should be placed on the fact that it encompasses and supports prevention and non-drug use.
A prevention agenda is urgently required, with an accompanying strategy and action plans. Adequate, long term funding of community based prevention programs is required.
The NDS must consider the broad policy context in which it is located. The National Competition Policy is of increasing importance to alcohol policy.
A commitment to cross-sectorial partnerships is essential if the NDS is to be effective. However, the ADF urges caution in partnering with the alcohol industry.
It is important that the NDS be developed in a way that will allow due consideration of different ways to manage, regulate and/or legislate for illicit drugs.
The expertise, knowledge and community access available through the NGO sector should be much better utilised.There is a need for more effective consultation processes and more transparent reporting.
A NDS Aboriginal and Torres Strait Islander Complementary Action Plan should be developed. Adequately resourcing the Indigenous AOD sector and equipping the mainstream AOD sector to address the needs of Indigenous peoples is crucial.
The generalist health workforce requires a stronger understanding of prevention, of what works and encouragement to deliver prevention programs and services.
The cyclical funding of school based drug prevention must be replaced with consistent, long term funding if the possible benefits of school education are to be realised.
The creative and innovative use of technology holds huge potential. More research and evaluation is needed to provide guidance on best practice.
The ADF welcomes the linking of the NDS with the social inclusion agenda and the acknowledgement that addressing social disadvantage is integral to preventing alcohol and other drug problems.
The ADF supports the concept of setting performance measures and targets. A national indicator and measures framework is required.
General comments
The Australian Drug Foundation welcomes this opportunity to make comment in response to the consultation paper “Australia’s National Drug Strategy Beyond 2009”. The ADF supports the development of the next phase of the National Drug Strategy (NDS) and looks forward to participating in further consultations.
As the main focus of the ADF’s work is prevention, the majority of this submission will centre on prevention and related issues.
The ADF is a member of the Alcohol Policy Coalition (APC) which is also making a submission to this consultation. While this submission covers some alcohol relevant issues, we refer the MCDS to the APC’s submission which covers alcohol related issues in more detail.
Some general issues
The role of the NDS
It is essential to have a national, coordinated policy to guide and inform the policies, strategies and activities undertaken by both government and non-government sectors working to address drug issues in the community. As the evaluation[1] of the NDS observes the NDS policy framework ‘has successfully informed the development and implementation of drug policies and strategies at across government and the public, private and non-government sectors’. It has provided a broad policy consensus within which there is flexibility for the development of a range of policies and strategies for specific needs.
However, being broad and non-prescriptive, it provides little detail and direction on implementation. While it is not the role of a strategy document to spell out specific implementation plans, there is a need for the NDS to more clearly link to, and give direction to, implementation processes.
This could be better achieved by linking the various sub-strategies (as identified in the Consultation Paper) more consistently so that they have complementary and consistent time-frames, share supportive objectives where possible and identify shared targets. Detailed action plans are required for all the sub-strategies to ensure implementation and inform evaluation.
Harm minimisation
A consistent feature of Australian Drug Strategy has been the commitment to harm minimisation as a central principle. It has been shown to effectively accommodate the three approaches of demand reduction, supply reduction and harm reduction and facilitates the working together of diverse sectors such as education, law enforcement, and health. Harm Minimisation has recognition and currency both here and abroad.
The ADF agrees there is confusion around the meaning of the term. The confusion is due to the near interchange ability of ‘harm minimisation’ and ‘harm reduction’. The meaning of ‘harm minimisation’ is not transparent and it needs interpretation which means it does not communicate clearly. Understandably then, it has little purchase among the general community.
The ADF agrees that the national drug strategy could place greater emphasis on prevention, with more attention devoted to reducing the prevalence and incidence of drug use, while seeking to not marginalise people who do use drugs. Under the policy of harm minimisation the distinction between the three levels of prevention (primary, secondary, tertiary) has been lost to some degree. Harm minimisation may have been interpreted as privileging secondary and tertiary prevention at the expense of primary prevention.
Opposition to ‘harm minimisation’ may stem from the impression that the policy awards legitimacy to drug use per se and that the main concern is whether a drug is used as safely as possible. That is not the view represented in the national drug strategy and to that degree the term harm minimisation may not be a fair description of the policy.
However the term ‘harm minimisation’ should not be abandoned unless there is a suitable term to replace it. Any new term introduced runs the same risk of being misinterpreted and misused. The term ‘harm prevention’ might be more expressive of the general impulse behind the national strategy as long as it is defined carefully to emphasise that some drug use (licit, illicit, medical) is an inevitable aspect of modern human life.
If a new term is selected the national policy should place special emphasis on the fact that it encompasses and supports prevention and non-drug use.
Prevention
The ADF supports the emphasis on prevention articulated in the consultation paper, and the recognition that prevention efforts must be appropriate to the target groups and harms being addressed.
The ADF subscribes to the understanding of prevention as given in the 2004 comprehensive review of prevention[2] “Prevention … encompasses measures that prevent or delay the onset of drug use, protect the healthy development of children and youth, and reduce harm associated with drug supply and use”.
We concur with the finding of the NDS evaluation[3] that prevention is ‘missing in action’ within the NDS, even though it is listed as a priority. More research and evidence is needed on what works in prevention in various contexts and across target groups. A prevention agenda is urgently required, with an accompanying strategy and action plans.
The ADF believes that a major limiting factor for prevention is the amount of resources allocated within the NDS. Not only must prevention research and programs be funded, they must be funded adequately and for the long-term. The ADF applies a community development approach which recognises that community engagement and involvement is essential for the reduction of drug problems. Long-term commitment and resourcing is required to identify models of community development programs which can engage all sectors including parents and families; education, workplaces, sports and recreation, local government and more. Such programs need to be evidence based; subject to trialling and evaluation; and funded adequately over a long period of time. The availability of quality, community based programs offers the means to provide tailored responses to specific sub-groups and at-risk groups on a sustainable basis.
Give the complexity and inter related nature of the sectors and factors concerned with drug prevention, it is difficult to ascertain how much is actually spent on drug prevention. Work by the Drug Policy Modelling Project[4] calculated that of a $1.3 billion spend on proactive strategies in 2002-03, 23% was spent on prevention while 55% was spent on enforcement. Due to the methodology used and assumptions made in the calculation of expenditure on prevention, especially in regard to school based drug education, the ADF contends that that this is an overly generous assessment of the proportion spent on prevention.
Prevention is good investment. A 2009 cost benefit analysis[5] showed a return of $18 for every dollar spent on drug prevention programs. The ADF is pleased to see that the NDS will take account of the Preventative Health Strategy and the work of the Preventative Health Agency. We refer to the submission from the Alcohol Policy Coalition where issues specific to the Preventative Health Taskforce Report is discussed.
Broader Policy Context
The National Drug Strategy must consider the broad policy context in which it is located. Given the complex and far reaching nature of drug use and its contributing causes there are many sectors which must be integrated. As well as the ones traditionally identified (e.g. health, law enforcement, education) and the more recently recognised areas (e.g. mental health, social inclusion) there are other areas such as human rights; employment and workplace; community strengthening and renewal. The entities and sectors involved with finance and economic development issues such as Treasury and the Productivity Commission also have great relevance. Many of their initiatives and proposals are based on economics but must also take into account the social and health outcomes of their recommendations.
One policy framework of particular relevance is the National Competition Policy (NCP). Within the AOD field the NCP is widely believed to prevent governments from taking action to place limits on the regulation of alcohol as, under the Trade Practices Act, it would constitute anti-competitive practice. However that view is disputed by Marsden Jacobs Associates[6] who observe that there is not a necessary conflict between National Competition Policy and regulation. They argue increased competition is not always in the public interest as it may exacerbate alcohol-related problems and alcohol is one product that deserves regulation even if it reduces competition on occasions. They also point out that many regulatory measures of regulation have a negligible effect on competition because they do not discriminate between sellers of liquor and are acceptable under the Act.
The ADF believes that the profound negative effects of alcohol consumption on individual lives and on the social and economic fabric of Australian society justify some limitation on competition. Governments can apply for exemptions for particular measures under the Act and policymakers should be reminded that the strictures of competition policy need not be applied to alcohol without careful consideration and that in many instances alcohol should be exempted from national competition policy as it possible under the Act.
It is important that the NDS addresses the National Competition Policy issue so policymakers and the sector have an accurate understanding of how and when it might be relevant.
Partnerships
The ADF is committed to and depends upon building strong, working partnerships with all levels of government, non government, community and other stakeholders. A commitment to cross-sectorial partnerships is essential if the NDS is to be effective.
However, the ADF urges caution in government partnering with the alcohol industry, because the industry exists to expand the alcohol market rather than reduce drinking problems. The industry has shown an inability to reconcile the conflict between the aims and there is no reason to expect them to be reconciled.[7] It has been the ADF’s experience, most notably through the recent alcopop taxation campaign, that alcohol industry efforts will be driven by their commercial interests over the evidence available on what is best for the community. It is therefore important to ensure that the progress and direction of the NDS cannot be subverted or obstructed by industry interests.
Emerging Thinking on Drug Strategy
The Australian approach to drug strategy, with harm minimisation as its central tenet, is rightly admired around the world. Australia is a signatory to the various UN drug control frameworks and participates at an international level in drug policy debate. There are growing calls to rethink the ways that illicit drugs are controlled and regulated[8][9] , taking into consideration the growing cost (economic and human) of enforcement of drug strategy.
The ADF believes that it is important that the NDS be developed in a way that will allow due consideration, and where indicated trialling and testing, of different ways to manage, regulate and/or legislate for illicit drugs.
Specific responses to key consultation questions
Cross Sectoral Approaches
- How can structures and processes under the National Drug Strategy more effectively engage with sectors outside health, law enforcement and education?
The non-government sector plays an integral role in the implementation of the NDS and so the involvement and engagement of the NGO sector is essential. As an NGO, it has been the ADF’s experience that the expertise, knowledge and community access available through the NGOs could be much better utilised.
The processes for consultation are often too restrictive. Consultation documents are often written for government audiences and have short consultation periods, reducing the opportunity for sector or community input. The NGO sector should be involved at the early development phase so that strategy documents better reflect their views in the development.
It is often presumed that the state government will canvas and submit the views of the NGOs in their state. As an NGO based in Victoria but with a national focus and programs, the ADF has found this is not an efficient or effective way for us to contribute.
The Drug Policy Modelling Program has undertaken a review[10] of the co-ordination of Australia, evaluating the NDS strategy against the principles of good governance. The Review finds that good governance principles are recognised as important by those involved in coordinating the NDS, and that compliance to good governance principles is improving over time. However there were significant differences between sectors as to application of the principles. The principles of participation, transparency responsiveness; and equity and inclusiveness are of particular concern to the ADF.
The DPMP report[11] confirmed the findings of the NDS evaluation[12] that the Australian National Council on Drugs (ANCD) has facilitated improved coordination with the NGO and community sectors.
The ADF believes it is far more efficient and effective for the ADF to submit its views directly to government and policy makers rather than rely on the limited opportunities provided by peak bodies. The ADF’s experience is confirmed by a recent study that reported the relevance of peak bodies to NGOs in the AOD sector is unclear as both small and large NGOs do not believe the peak bodies in the AOD field necessarily represent their interests.[13]
- Which sectors will be particularly important for the National Drug Strategy to engage with?
The work of the ADF crosses a wide range of sectors, the members of which are important stakeholders in the drug prevention arena, but who have not traditionally been directly engaged with in the development and implementation of drug strategy. These include
parents and families,
community groups,
the community sporting sector,
local government.
- Could the Intergovernmental Committee on Drugs (IGCD) and the Ministerial Council on Drugs Strategy (MCDS) more effectively access expert advice and if so, how?
The DPMP Review[14] criticises the IGCD for its lack of transparency, accountability and responsiveness and participation. The issue of the IGCD restricting its contact to only those they specifically seek expert input was highlighted.