National Drug Strategy
National Drug Strategy

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10 Dec 2010

Submission by WANADA (WANADA)

Introduction and Mission

WANADA supports mission of the NDS- “reducing” rather than “minimising” drug related harms would be more continuously measurable

Intro & throughout NDS “misuse” implies a punitive response is needed for individuals & does not support health focus. When applied to pharmaceuticals unintended dependence (patients following prescription requirements) is not represented by misuse. Preferred terminology is drug use problems

Harms dot 2 - 4 areas covered under drinking: short-term heavy; long-term heavy; during pregnancy; & during childhood. This level of refinement is not covered under the other drug categories & would be welcomed. The opening sentence on alcohol indicates the paragraph relates to “excessive consumption” not consumption per se. Either the order of the four areas needs to be modified or separate dot points for the first & last 2 areas is needed

WANADA congratulates maintenance of harm minimisation/3 pillars approach. The visual representation & order of the 3 pillars suggest priority - the information does not speak to the inequity of funds to each pillar, cost efficiency/return on investment, equitable government commitment

disadvantaged dot 4– useful to have mental illness defined vs compromised mental health/wellbeing

Challenges:

• Ensuring services can meet demand re both capacity & range of available options including the unmet need from people in corrections. Also requires forecasting re regional population growth

• Meaningful consumer participation in service development, as well as service consumer representation at systemic policy development & planning & with consumers that have a focus on drugs in addition to IDU

• In relation to quality frameworks for treatment services– need to incorporate evidence as well as demonstrated continuous quality improvement & strategies for improving access to people who otherwise may not be accessing sector services

• Discrimination & social stigma for consumers - also impacting on service access including for family members

The Pillars: Supply Reduction

WANADA supports the focus under supply reduction on importers, suppliers, manufacturers and organised crime, & not individual drug users. WANADA also supports the evident links across the 3 pillars.

Objective 1 on illegal drug supply reduction speaks of raising awareness of the harms and consequences arising from problematic drug use. However, the unintended consequences of, for example interrupting the supply of one drug and creating a demand for another, are not discussed.

While the included actions are not intended to be comprehensive:

• Actions/strategies that proactively reduce black market demand, such as supporting/researching replacement pharmacotherapies (eg for ATS) or less harmful alternatives to the legal market (eg non-smoking nicotine) could be included – with a clear agenda of undermining suppliers and reducing criminality of individuals

• Actions/strategies to identify and minimise corruption is a further key area to maintain community confidence in supply reduction initiatives that is not included

Objective 2 on supply of legal substances, again misuse of pharmaceuticals is referred to with no recognition of unintended dependence from sanctioned use or pain management. Also the information in this section and following actions do not mention alcohol availability, the need to reduce outlet density & hours (referred to in harm reduction) and sly grogging. There is also inadequate action/strategy for reducing under aged drinking when it is acknowledged that supply of alcohol to young people is via family and friends (also confusingly in harm reduction)

Two actions within this section could be strengthened – dot point 5 “further foster relationships with industry…” does not provide clear direction for effective change; and dot point 10 “research, investigate and gather information …” does not indicate the purpose of the research etc, i.e. to inform policy & action

Additional actions could include: Commitment from government demonstrated through ban on alcohol industry donations to political parties; support for community driven action particularly in Aboriginal communities; cost benefit analysis for introduction of volumetric taxation of alcohol

The Pillars: Demand Reduction

Acknowledge no strategy alone can prevent/reduce demand for drugs & meet the diverse needs- across sector collaboration & cooperation needed. There is a need to ensure prevention reduction treatment & support approaches are effective

1 prevention- cost efficiency sound rationale for boosting prevention initiatives- actions highlight prevention is everyone’s business. Gap in actions to determine &/or ensure effectiveness of prevention strategies

2 reducing misuse- definition of brief intervention (5–30 minute one-off session provided by generalist services, GPs, police, family etc) inadequately describes BI provided by specialist AOD services, including expectations of BI in diversion initiatives. Information on access to treatment services for dependent people to reduce drug use is vague and is a misfit in this section when further sections discuss treatment support & harm reduction

Increasing access to culturally sensitive services welcomed - recommend reference to cultural security- sensitivity applied and evident in practice. These efforts need to be enhanced not just sustained

Current diversion initiatives focus on illicit drugs - would welcome inclusion of alcohol

Welcome development/implementation of quality frameworks for treatment services - WANADA and ATCA are developing industry specific accreditation standards to support CQI of culturally secure treatment services & TCs respectively. These need to be considered in the national process

Reference to justice system needs to relate to people involved in both prison & community justice

3 recovery- requires defining- encouragingly linked to strength based/empowerment holistic & individually tailored treatment models. Reference to consumer participation & social isolation (& an action dedicated to addressing stigma) supported

Evident coordination expectations between primary health & AOD specialist services indicated in the actions (4 and 5) requires significant negotiation/raises a number of issues – response limits

Identifying an action to improve relationships between funders and providers is applauded

4 social inclusion - applaud recognition of links between healthy communities & AOD demand reduction

The Pillars: Harm reduction

The sections within harm reduction would logically flow better if they were reversed – i.e. harm to individual, families, communities (compared with the reverse order presented).

A number of examples of harm reduction are presented with one significant exclusion intoxication maintenance/sobering up services

Objective 1 on reducing harm to community, there is inadequate information on the impact of alcohol and other drug use within regional, rural and remote communities, where this can be significant and all encompassing.

Action point 6 refers to awareness in the community and workforce of clandestine laboratories, and yet misses the impact of working under the influence of alcohol and other drugs.

Action point 7 refers to working with industry (presumably the alcohol and pharmaceutical industries) and provides only one example of mixing alcohol with energy drinks. Improved awareness of mixing legal substances with other legal and/or illegal substances is needed for the public and those in the industries.

Objective 2 on reducing harm to families – WANADA welcomes this and the above focus within the NDS. Reference to FASD and the ‘particular issues’ for Indigenous communities is not backed up with examples, and without this expansion implies FASD does not impact on all communities/pregnant women who consume alcohol. Action point 5 related to preventing “misuse” of alcohol and other drugs during pregnancy surely needs to be preventing “use”

Objective 3 on reducing harm to individuals appropriately covers a range of initiatives.

Workforce

It is encouraging that the range of workforce planning and development (including training with identified core competencies, organisational development including accreditation, and systemic capacity building across sector) is identified – even as an identified challenge. WANADA would welcome an action plan linking workforce planning and development across the 3 pillars. Ensuring suitable funds support workforce planning and development would be the obvious next step to support this approach.

Evidence base and Performance measures

WANADA welcomes the commitment to evidence demonstrated in the NDS, including support for ongoing evaluation of approaches. Support for ongoing evaluation of all funded services would inform continuous quality improvement and further generate an evidence base for both new initiatives and practice wisdom.

Governance

It is encouraging that the governance of the NDS incorporates the views of the non-government service sector, both through calling on representative participation at the IGCD when appropriate and through the ANCD. WANADA has confidence from past experience that the ANCD actively seeks and clarifies a range of perspectives, ensuring their representation is equitable and based on broad consultation that takes into consideration jurisdictional differences in context including geographic and population differences, legislation, policy and service capacity. WANADA would like assurance that this model is applied to any representation called upon to inform decision making.

WANADA would recommend the inclusion of both consumer and carer/family representation, with consideration of the diversity of perspectives.

Other comments

P/Measure 1: Disruption of illegal drug supply It is appreciated that measures across the 3 pillars are not distinct however it would be useful to include a measure for the disruption of supply of legal drugs and not just focus on illegal drug supply. A possible measure could, for example be determined on an average reduction of alcohol outlet density (in terms of actions to reduce availability), or reduction of alcohol use reported by under aged young people (in terms of supply by family and friends resulting from actions/strategies taken)

While the measures of disrupted production and supply of illegal drugs presented offer one approach it is never clear what percentage of production and supply this represents. Additional measures of availability and price could provide a better indicator of the success of supply and production disruption/reduction

P/Measure 2: Indicators of drug use WANADA supports the now long standing measures of prevalence of use and age of uptake. Examination of this data for population sub-groups (youth, jurisdictions, regional rural remote/metropolitan, Indigenous, gender etc) and qualitative contextualisation and patterns of drug use are supported

WANADA is encouraged by the intended review of the National Minimum Data Set. It is hoped that the data set can be enhanced to include measures that support effectiveness and continuous quality improvement – i.e. outcome and impact measures

P/Measure 3: Harms associated with drug misuse A key measure that is missing from this section is drug related deaths and drug related crime. In relation to these and all of the measures in this section at least WANADA would like to see the performance measures with desired targets that indicate a percentage reduction that would represent action and strategy success

General: The structure of the NDS is sound, and the linked approaches comprehensive. NDS partially addresses relationship between disadvantaged populations & AOD use- gap addressing relationship between inequality re poor societal outcomes contributed to by AOD use ie a focus on effecting strong community not just individual resilience

WANADA welcomes any request for clarification/further info

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