10 Dec 2010
Submission by APSAD (Australasian Professional Society on Alcohol & other Drugs (APSAD))
Introduction and Mission
APSAD fully supports the continuation of the harm minimisation policy underpinning the NDS, with its three pillars approach. That said, the definition of harm reduction will be improved if it reads ‘...strategies and actions that aim primarily to reduce the adverse health, social and economic consequences of the misuse of drugs and of societal responses to drugs and drug users’. This formulation draws attention to the potential for unintended adverse consequences of drug policy and the need for interventions to be designed in such a manner as to minimise the likelihood of this occurring.
One of the pillars is stated as ‘Supply reduction’ but the discussion of this in chapter 2 makes quite clear that it involves both reducing the availability of certain drugs and controlling the availability, without necessarily reducing it, with respect to others. Perhaps this means that the pillar should be characterised as ‘Supply reduction and control’?
We support the approach which emphasises building workforce capacity, using evidence to underpin policy and its implementation, performance measurement and building and maintaining partnerships.
The definition section will be improved if it gives a definition of ‘misuse’ that clarifies the distinction between ‘use’ and ‘misuse’, as confusion arises in policy when these two constructs are conflated.
APSAD supports the approach which emphasises life stages, disadvantaged populations and settings.
The figures relating to the successes of the National Drug Strategy in the area of law enforcement, at the foot of page 11, could well be characterised as ‘cherry picking’, but we understand why such figures are considered appropriate in this type of document.
The introduction to the ‘Pillars’ chapter states ‘The objectives and actions listed under each pillar are not intended to be exhaustive but to provide a rounded explanation of what is involved’. As it is unclear what this means, a redrafting is in order. The redrafting should spell out just what these actions are as the term ‘rounded explanation of what is involved’ does not do the job.
The Pillars: Supply Reduction
Objective 1, ‘Reduce the supply of illegal drugs’, will be strengthened by referring to the availability of these drugs within Australia. Surely a key objective is to reduce their availability, but this goal becomes lost in the language of reducing supply. The problem is that a focus on reducing supply, but not availability, reduces the likelihood of having a key performance indicator that deals with the availability of illegal drugs within Australia.
The types of initiatives illustrated are broadly supported by APSAD.
The Pillars: Demand Reduction
The first sentence on page 19, and the title of Objective 1 on that page, are confusing, stating that demand reduction ‘includes strategies to prevent the uptake of drug use, delayed the first use of drugs...’. This is because ‘uptake’ and ‘first use’ are synonyms.
The types of initiatives illustrated are broadly supported by APSAD.
The Pillars: Harm reduction
Placing emphasis on FASD and the harm reduction initiatives that are available to reduce its prevalence and incidence is supported by APSAD, as well as most of the other potential interventions illustrated in the draft.
We note that the term ‘binge drinking’ is used in the draft. APSAD suggests that this be removed as the term no longer has any agreed-upon meaning and for that reason is not used in leading scientific journals in the ATOD field, nor by NHMRC. A more appropriate term that operationalises the underlying concept is preferred, such as ‘episodic heavy drinking’.
APSAD fully supports legislation and practices that divert problematic drug users out of the criminal justice system into interventions well matched to their needs, but draws attention to the fact that this is mis-characterised in the draft Strategy as ‘harm reduction’. Treatment and education initiatives form part of demand reduction, not harm reduction. The current drafting causes confusion about the meaning of harm reduction. The term is better reserved for interventions that aim to reduce harm among people who continue to use drugs. This has been the definition used in the NDS through many of its previous phases, and is the internationally accepted definition.
APSAD is delighted to see the commitment to developing and hopefully implementing a national ATOD sector workforce development strategy. APSAD stands ready to assist in this important task.
Evidence base and Performance measures
The thrust of this section is supported. APSAD is pleased to see the commitment to developing a National Drug Research and Data Strategy. We are disappointed, however, that the draft says nothing about how this will be funded and how its products will interrelate with processes of policy development. Unfortunately, the NDS has a long history of developing strategies that are largely not implemented as they do not identify who is responsible for implementing them, and the sources of funding to make this possible. We trust that this will not be repeated in the case of the proposed National Drug Research and Data Strategy.
The section on ‘Commitment to evidence’ uses an idiosyncratic definition of ‘evidence-based practice’. Most definitions focus on the use of research evidence rather than simply on ‘approaches which have proven to be effective in the past’. Clearly this is part of evidence-based practice but not the whole of it.
APSAD is pleased to see a return to the commitment, characterised in some of the earlier phases of the NDS but rarely implemented properly, to the development and use of performance measures. In our view, however, it is premature to spell out what these performance measures should be. This is a significant task which should be undertaken as part of developing the National Drug Research and Data Strategy. The performance measures provided do not seem to have been carefully enough thought out as they do little more than reflect the three pillars of the strategy.
APSAD supports the continuing partnerships between the many sectors of government, and partnerships between government, community and research organisations.
We are concerned that the closing date of the submissions has been set at 10 December 2010 rather than having been delayed until decisions have been made about the future of the ATOD sector under the forthcoming national health reforms. It could well be that the governance arrangements will be significantly impacted upon by those decisions.
APSAD is disappointed that no changes in the governance structures and processes are found in this draft strategy. Considering that the draft has already been approved by IGCD and MCDS we assume it is unlikely that changes will be made as a result of this submission (not consultation) process. It is clear that the findings and recommendations of the evaluation of the previous phase of the NDS relating to governance have not carried through to the draft strategy. In particular, APSAD is concerned at the continuation of a governance framework which includes little capacity for people and organisations outside of government to have inputs into policy. While there were some difficulties with the system of IGCD expert advisory groups, their abolition has meant that IGCD has no structured way of accessing expertise around the nation that lies outside of government departments. We urge that this be reconsidered.
Furthermore, the IGCD remains the only conduit of advice on policy matters to MCDS. Retaining its membership as restricted to public servants means, as the NDS evaluation pointed out, that it faces significant impediments in taking into account the potential inputs of the non-government and community sectors, along with the expertise of ATOD researchers and practitioners. There is no place for inputs from Indigenous people and organisations. We see this as a lost opportunity to improve the governments of the NDS.
Overall, APSAD supports the thrust of the consultation draft particularly in so far as it retains many of the strengths of the existing NDS. We regret that opportunities have not been taken to fix problems of the previous phase of the NDS and to innovate in such a way as to improve the quality of policy and its implementation.
APSAD draws attention to the importance of prevention as part of the NDS. Some years ago NDRI was commissioned to document the evidence base for prevention — it was to be used by IGCD to develop a NDS national prevention agenda. It has been a great disappointment to APSAD and the ATOD sector more broadly that this did not occur. APSAD recommends that a section on prevention be included in the new Strategy, and that it include a commitment to developing and implementing, during the life of the next Strategy, a National Prevention Agenda.
Also missing is any discussion of the implications of resource allocation within Australia’s drug sector. We need to move incrementally towards a more rational funding mix. APSAD opposes the current situation in which 45% of governments’ drug expenditures are on illicit drugs but only 5% on tobacco, considering that illicit drugs account for just 16% of the drug-caused burden of injury and disease, and tobacco 65%. This is another example of a missed opportunity to create a more modern, evidence-informed National Drug Strategy that will better serve Australia into the future.
Another major omission is a failure to include any statements about who is responsible for implementing the strategy, using what resource, on what timetable. It could be argued that this is not appropriate in such a high-level strategy and that this matter should be documented elsewhere. That being the case, we would like to see in the new Strategy a commitment to developing an NDS implementation work plan, and making it available to the sector as a whole.
APSAD would also like to see funding for appropriate research under law reform.
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