10 Dec 2010
Submission by Australian Drug Foundation (ADF)
Introduction and Mission
The ADF supports the development of the NDS as an important tool to guide the efforts of all those involved in minimising the drug and alcohol harms, including the non-government sector.
We welcome the:
• retention of harm minimisation as central;
• stronger focus on social determinants of drug related harm and the need for social inclusion strategies;
• inclusion of family as a specific target group which is heavily impacted and has a significant role to play.
• identification of communication technology, including the internet, as a significant area to address;
• consideration of populations, age/stage of life and settings is valuable. ‘Partnerships’ should form part of the underpinning ‘Supporting Approaches’.
Problems and omissions
• Inconsistent linking between issues identified and discussed and the objectives and suggested actions.
• Sport, as an important influencer of Australian culture and a setting where alcohol is consumed at very high levels, should be included in relevant settings, both at community and elite level.
• Reference to consumer participation and strategies to ensure the views and experiences of substance users, service users, and the wider community are needed.
• Cultural change: need to challenge unsupportive cultural norms and beliefs e.g. the social acceptance and expectation of intoxication; discrimination against people who use drugs
• Challenges: those identified are not all addressed under the 3 pillars and actions. e.g. older cannabis users; poly drug use
The number and type of sub-strategies should be reduced, with those remaining developed ‘in synch’ with the NDS timelines.
An ATSI Complementary Action plan should be developed to support and complement the NDS
Other national strategies of relevance include
• National Competition Policy
• Australia’s Tax Policy (Henry review)
• Closing the Gap
• Housing Policy
• Social Inclusion Agenda
• National Preventative Health Strategy
The Pillars: Supply Reduction
Efforts to reduce supply and limit availability must take into account any unintended consequences.
The need to engage the community re support for supply reduction is recognised but this is not reflected in the range of actions listed, except for the supply of alcohol to minors.
The biggest proportion of resources is accounted for by illegal drug supply reduction efforts. While building on and expanding supply reduction efforts, more equitable funding of demand reduction and harm reduction efforts is needed.
If supply controls efforts are to be increased then a corresponding increase in diversion programs and treatment services will be needed.
There is significant evidence available on which to base supply control policy and strategies around alcohol, as identified by the National Preventative Health Strategy. It’s recommendations focused on liquor control regulations, developing and implementing best practice nationally consistent approaches to policing and enforcement of liquor control laws, (outlet opening times, outlet density etc). The Commonwealth Government committed to pursuing these recommendations with states and territories through COAG and MCDS.
We urge that the development of a nationally consistent approach to the irresponsible secondary supply of alcohol to minors be included (also recommended by the NHPT). Legislation has already been introduced in three Australian jurisdictions.
Responsible Service of Alcohol training: nationally consistent and accredited RSA training is needed to allow people transfer interstate and to build a pool of trained people. This has been on the national agenda for some time with no progress. Training programs also need to include "distance education" to enable remote areas to have trained staff.
Review of the National Competition Policy by the Productivity Commission regarding alcohol is critical. Limitations set by the NCP are consistently cited as a barrier to implementing policy and regulatory changes around alcohol supply.
The role of Local Government to manage supply issues in their communities must be supported and expanded.
The Pillars: Demand Reduction
More acknowledgment of the value and role of prevention
“Prevention of drug misuse is more cost effective….
Alcohol intoxication as a ‘cultural norm’ must be addressed in preventing the uptake of drugs.
Despite schools being listed as a key setting, the role of school based drug education receives little attention. There is good evidence on what constitutes effective school based drug education but the education sector needs support to implement it. More direction and support on this is required and should be linked to the development of the National Curriculum. The tertiary education sector needs to be included.
Social marketing, to be successful, must be part of a comprehensive, integrated approach of structural, regulatory and legislative changes along with community development initiatives: as evidenced in the anti-tobacco campaign which included action on labelling, promotion, and supply controls.
• Exposure: include Sponsorship in the action on limiting or preventing exposure to advertising and promotion.
• Media: Amend to “Implement strategies to….”
• Preventative Health Taskforce: We urge that the recommendations of the PHT be adopted.
• The proposed action on labelling of alcohol products should be cited here.
More emphasis is needed on early intervention and diversion programs
Brief interventions …. Replace this with “A range of innovative intervention measures can…. “as not all interventions come under that descriptor.
Barriers to access to treatment services must be minimised, including geographical and cultural.
• 2nd dot point: amend to: “Increase access to a greater range of culturally sensitive services”.
Objective 4 social inclusion
• Whole of community efforts: involve communities in planning and design of initiatives.
• “Support.. participation of at-risk…” must go further than sport, recreation and culture pursuits, to include education, housing, adequate housing and health, and other meaningful occupation.
The Pillars: Harm reduction
Objective 1: Amend to “Reduce harms to community health and safety”
• Make local communities… must include local communities in the partnership process, for example communities are excluded from liquor licensing decision making processes
• Investigate nationally… on alcohol outlet density and trading hours - We strongly support this action and commend the findings of the PHT which has already investigated these.
• Work with industry and consider regulation…. from emerging substances….for examples….energy drinks ”
When working with the alcohol industry, important to clarify which sector of the industry (producers, retailers, hospitality) as they have different motivations from each other and to the health lobby. The recognition that regulation may be needed is important as self–regulation by the industry has failed in most instances
Objective 2. Reduce Harm to families
The inclusion of families as a specific group who experience harm due to others alcohol and drug use is welcomed.
• Develop initiatives to reduce …. Need to include legislative options along with community education and information campaigns, as already exists in 3 jurisdictions.
• Consider introducing health warning labels…. Replace ‘Consider ‘ with ‘Introduce and trial …..
Objective 3. Reduce harm to individuals
Need a commitment and openness to trial new harm reduction strategies which already have a robust evidence base; e.g. heroin maintenance; supervised injecting facilities; decriminalisation of personal use of illicit drugs. It is important that the NDS provides the opportunity and support for such research to be undertaken when indicated by evidence .
• Use of Internet reword to
Develop and implement internet-based approaches to target hard to reach individuals and those who do not necessarily identify as needing treatment…
• Continue and expand evidence based illicit drug diversion programs….
• Add “Provide access to NSPs within prisons
Attracting and retaining staff in the alcohol and other drug treatment sector is the major challenge. This is exacerbated in more remote and less prosperous areas.
Evidence base and Performance measures
We support the commitment to evidence based and evidence informed practice and the development of a National Drug Research and Data Strategy.
Effective evaluation of all actions and initiatives must be a core element of the strategy. We note that this is articulated as an action under only some of the objectives.
This commitment needs backing by adequate funding to support quality research and evaluation of programs over a reasonable length of time; as opposed to short –term funding with inadequate or non-existent evaluation budgets.
A valuable data source missing is Alcohol Sales Data. Currently only collected in Queensland, NT and WA, it can inform key alcohol policy developments and evaluations. The NPH Strategy recommended the national collection of this important data.
As well as identification of performance measures, there is a need to set targets against which to assess the progress of the NDS, such as has been set by the NPH Strategy for alcohol.
Other measures which should be included:
• Return on investment
• Effectiveness of treatment outcomes
• Prevention outcomes
• Rates of use of pharmaceuticals
• Changes in culture and attitudes
• Prevalence and extent of advertising, sponsorship and other promotions
PM1: Disruption of illegal supply
Focusing on offence type of measures (arrests, seizures, detections) will not give a true or useful reflection of the progress of the Drug Strategy.
More accurate measures would be intelligence related to the ease of availability and the price variations of various drugs.
PM 2. Indicators of Drug use
The Illicit Drug Reporting System should be included as a data source.
The measures identified will provide data on lifetime use, recent use and age of initiation.
PM 3: Harms associated with drug use.
• Costs associated with law enforcement, imprisonment
• Rate of individuals receiving correctional sentences due to drug offences
• Number of people who share or reuse needles.
The current system of governance has not served the community well. COAG, despite agreeing that drug misuse issues are a priority, too often puts drug issues on hold and delays decision making.
Currently the future and role of the MCDS is under review. Disbanding the MCDS would greatly compromise the future of the NDS and it implementation. We strongly support the continuation of MCDS.
The need for better community and Non-Government sector representation in the governance of the NDS was a common theme in the consultations. This has not been addressed. The Alcohol and Drug sector is quite unique in that it is the NGO sector which is responsible for the bulk of delivering programs and services.
The governance model put forward identifies the ANCD as providing the non-government voice. While the ANCD is a valuable and proven advisory body it does not (and does not claim to) represent the NGO sector.
The strategy states that the IGCD “ will seek to better engage sectors…. representatives of… and/or non-government organisations will be invited to the IGCD for discussion of particular issues.
We are concerned that this is too ad hoc and a more formal role for the non-government sector needs to be created to ensure a stronger NGO voice in advising on the direction and implementation of the NDS.
The NGO representation must go wider than just the drug and alcohol sector to ensure issues such as housing, welfare, employment and training.
In some instances the document talks about the Health – Law enforcement partnership as being central but in others refers to the Health-Law enforcement - Education partnership as central.
Having become involved in the consultation process a year ago, the ADF is disappointed that such an important document is being subjected to a rushed final consultation process, and final drafting stage.
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