Submission by Families and Friends for Drug Law Reform (Families and Friends for Drug Law Reform)
Full comments on submission will be sent in Word format via email to firstname.lastname@example.org View full submission by Families and Friends for Drug Law Reform
10 Dec 2010
Submission by Dr Khim Harris (Fresh Start Recovery Programme)
Overall, we believe that the 2010-2015 Strategy needs to have a more recovery-focussed approach to treating addictions, much like the new UK Drug Strategy, launched by the British Government on 8 December 2010.
View full submission by Dr Khim Harris
10 Dec 2010
Submission by Macciza
This submission will deal primarily with the plant Cannabis, its current illegality and the consequences of it's cultivation and consumption by adults. In this context it proposes a total harm minimisation approach whereby all criminal penalties are removed. It applauds the efforts being taken to reduce the many associated harms from alcohol use and abuse.
If I were to be blunt I would have to say that with regards to Cannabis, the National Drug Strategy has failed in both it's stated aims and in its operational implementation. It has rejected numerous substantiative recommendations for change of legislation to allow Cannabis use by adults and instead continued a policy of prohibition which by definition creates the very 'problems' which we now seek to solve.
It fails in its stated aim of minimising harm for personal cannabis cultivation by continuing to pursue an overall policy of prohibition thereby criminalising behaviour which is simultaneously defined as a health issue. In fact it has increased the penalties for the preferred method of home cultivation in a number of States, allowing organised syndicates to charge more for their commodity and imposing greater penalties on continuing personal cultivators.
It fails in its implementation of harm minimising because it does nothing to reduce the major harm associated with Cannabis; apprehension, criminal prosecution, possible conviction and penalties including incarceration. It also fails to recognise and allow the medicinal use of Cannabis, as a herbal alternative to current licit prescription drugs, nor as a prescribed prepared commercial product such as Sativex. Our endogenous Cannabinoid system is an area of promising research in the treatment of numerous diverse ailments and yet the use of therapeutic Cannabis is compromised by an archaic social control law.
It fails in its operational aims because the principle of prohibition of popular activities is fundamentally flawed. As with the case of Alcohol prohibition, continued Cannabis prohibition creates a marginally restricted 'black' market; and as with Alcohol prohibition, the only solution is to legalise, regulate and tax the product in a legitimate m View full submission by Macciza
10 Dec 2010
Submission by WANADA (WANADA)
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
• 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
View full submission by WANADA
10 Dec 2010
Submission by Jan Warren (South Australian Department of Education and Children's Services)
DECS strongly supports:
- the continuing overarching approach of harm minimisation, the three pillars of supply, demand, and harm reduction; commitment to building workforce capacity , evidence-based and informed practice etc. etc.
- the critical partnership approach across sectors, levels, jurisdictions.
- emphasis on describing costs and harms of drug use, particularly to children, families, communities
- use of data relating to need for lowering the age of uptake; need for early intervention.
- emphasis on schools and communities as significant settings for preventative interventions.
- recognition of risks around transition points and the secondary years of schooling;
- recognition of adolescent needs re coping mechanisms etc and the implicit role of schools in helping to address these issues.
It is noted that the sub strategy: National School Drug Education Strategy has been removed from the previous list of sub-strategies 2004-2009. It is assumed that this is an outcome of the allocation of funding to states and territories under the National Education Agreement, and that it is planned to integrate school-based action in other strategies under the NDS.
It may be helpful to explain this in the introduction, as the NDS framework so strongly emphasises issues relating to children, young people and families; the need for more socially included and resilient individuals, families and communities; the value of networks; promotion of safe and healthy lifestyles; childcare and schools as settings for “points of life” transition and potential agents of change for parents and communities; as settings for preventative intervention; and the “central” health-education-law enforcement partnership; and where performance indicators relate to age of initiation and prevalence data.
View full submission by Jan Warren
10 Dec 2010
Submission by Burnet Institute (Burnet Institute)
The manner in which the introductory material is framed suggests satisfaction with earlier strategies and an ongoing commitment to incremental change. The strategy would be strengthened by an explicit statement that this is indeed the preferred approach or by providing further clarification on the overall direction if this is not the case.
If Australia wishes to remain a leader in responding to drug related harms then the strategy should include clear articulation of past successes to build on, persistent gaps/challenges and a commitment to innovative responses to address these. The attempt to better integrate illegal drugs and other drug (e.g. prescription drugs alcohol and tobacco) use is a positive development and may lead to better capacity to maximise policy research and learning across different drug types (e.g. tobacco policy is relatively advanced and may provide insights for other drugs.
A more accurate description of how responses are operationalised and the tensions associated with health/law enforcement interactions in actual settings may increase potential for genuine partnerships than the current formulation that does not reflect these issues of competing tensions and prioirities adequately. With respect to this issue, there is no mention of corruption and how this impacts on performance of the strategy especially in relation to law enforcement.
View full submission by Burnet Institute
10 Dec 2010
Submission by Fiona Sharkie (Quit Victoria)
On page 14, first paragraph, suggested addition: "The internet poses both challenges and opportunities for the National Drug Strategy. It is an efficient channel for information on illegal drug manufacture and use and the promotion of tobacco products." View full submission by Fiona Sharkie
10 Dec 2010
Submission by APSAD (Australasian Professional Society on Alcohol & other Drugs (APSAD))
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. View full submission by APSAD
10 Dec 2010
Submission by School Drug Education and Road Aware (SDERA)
The introductory section provides a sound overview of the historical context, the current philosophy concerning strategies to address harms from drug use and ther future intent of the NDS. School Drug Education and Road Aware (SDERA) is particularly concerned with AOD issues related to young people and specifically in the school setting. SDERA is the WA state government's primary drug education strategy for young people and supports government and non government schools implement best practice drug education programs. In terms of "...building safe and healthy communities..." SDERA considers the school community to be an important setting for prevention education and early intervention. Through the auspices of the National School Drug Education Strategy (NSDES) that was a component of the 2004-9 NDS there was significant achievement in promoting best practice prevention drug education and increasing the capacity of the school workforce to engage in early intervention. While the introductory comments in the NDS 2010-15 draft document draws attention to young people's drug use, school education and prevention it does not provide a sense of a coherrent sub strategy to address drug use by young people in the school setting. The school setting is consistently recognised by practitioners and researchers as a key location for prevention efforts and evidence based prevention is consistently recognised as a worhty and cost effective component of drug strategy. In contract the NSDES provided a focal point for addressing current and emerging issues facing young people that included state/territory collaboration in the appropriate and sensitive implementation of harm minimisation in the school setting.To this end SDERA supports the continued use of harm minimsation, using the 3 "pillars" of demand, supply and harm reduction, as a framework for addressing the harms associated with drug use.
SDERA further supports the focus on alcohol and cannabis use as key drug use issues to address in the youth area while keeping the downward pressure on tobacco use. While a focus on risk factors and vulnerable groups helps formaulate strategy protective factors should also be considered View full submission by School Drug Education and Road Aware
10 Dec 2010
Submission by Trevor King (DPMP Deputy Director) (UNSW: Drug Policy Modelling Program)
Compared to earlier drafts of the strategy document and the previous strategy, this is a clearer, much improved version. It is sufficiently broad to sustain Australia until 2015 and builds on the solid foundations provided by the earlier strategies.
The emphasis on safe and healthy communities in the mission statement is welcome. Specific reference to the range of drugs covered by the strategy sets the scene for a more integrated NDS and contributes to shared, cross-substance policy responses.
The explanation of terms used in this strategy (p 5) could be more comprehensive. The glossary in the previous strategy was much better.
The section on harms from drug misuse (p 6) should use a more consistent format and language across different drug types. Health and social harms can be attributed to each of the drugs or drug categories mentioned and could be addressed in that order for each. In terms of language, illegal drugs are described as having “dangerous health impacts” and inhalants “can cause brain damage and death” whereas for legal substances the language is less emotive.
The term ‘balance’ as it applies to the 3 pillars is contentious given the obvious funding imbalance between pillars. It requires definition or at least a brief statement acknowledging the complexities associated with the concept (p7).
The diagram of the NDS on p 7 does not enhance the clarity of the NDS text description on p 8. Inclusion in its current format should be reconsidered.
The NDS sub-strategies are briefly mentioned on p 8 but there is no detail about how they currently relate to the NDS Strategy document or what if anything may change in the future.
The emphasis on “age and stage of life”, “disadvantaged populations” and “settings” is a welcome addition to the strategy. Some evidence/rationale justifying focus on the chosen settings (p 10) is necessary. The use of the term “communities” in this section also requires some explanation.
Extending the NDS partnerships beyond health, law enforcement and education (p 10)is welcome. Specific details on what departments/sectors will be involved and how this will be achieved need to be included in the governance section. View full submission by Trevor King (DPMP Deputy Director)
10 Dec 2010
Submission by Aboriginal Health Council of South Australia (Aboriginal Health Council of South Australia)
The Draft National Drug Strategy 2010-2015: A framework for action on alcohol, tobacco, illegal and other drugs provides a comprehensive framework for future actions in reducing the impact of drugs in Australian society. There is a glaring omission however: the particular needs of the Aboriginal and Torres Strait Islander population.
Maggie Brady, in her book “Indigenous Australia and Alcohol Policy: Meeting difference with indifference” published in 2004, noted that national policy-makers had become increasingly uncertain about how they should deal with Aboriginal issues within national strategic documents, and that this uncertainty had led to “a virtual exclusion of Indigenous interests and special needs from mainstream documents with a national focus” (p.42). This draft strategy shows that this problem has not been resolved, but there remains an opportunity in this strategy to overcome what Brady calls the indifference stemming from difference.
There are passing references to the Aboriginal population in the draft document. On page 9, Aboriginal people are included in a list of dot points under the heading “disadvantaged populations” but the brief mention only refers to the high rates of smoking tobacco and risky levels if drinking. There is nothing to suggest that other drugs may be having a disproportionate impact on Aboriginal families and communities. It is worth noting that in all the other listed “disadvantaged populations” (unemployment, homelessness, poverty, family breakdown, regional and remote areas, mental illness, prison, culturally and linguistically diverse, and people with multiple and complex needs) Aboriginal people are disproportionately represented. Yet there is little in the actions further in the document which addresses the particular needs of Aboriginal people.
View full submission by Aboriginal Health Council of South Australia
10 Dec 2010
Submission by Australian Drug Foundation (ADF)
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
View full submission by Australian Drug Foundation
10 Dec 2010
Submission by L Grant (National Council of Women of Tasmania Inc)
Please see submission forwarded by email View full submission by L Grant
09 Dec 2010
Submission by ACSO (ACSO)
Australian Community Support Organisation (ACSO) commends the Ministerial Council on Drug Strategy on the development of the draft National Drug Strategy 2010-2015 and strongly supports the overall direction of the Strategy. In particular ACSO supports the stronger focus on linkages between the drug treatment sector and the wider health/community sectors and the greater recognition of the impact of substance use on families that are key elements of the Strategy. View full submission by ACSO
09 Dec 2010
Submission by Richard Struik (Western Australian Local Government Association)
WALGA supports the background and context. For Local Governments, alcohol and drug misuse contribute to a number of areas where Local Governments build community capacity, including parenting and young children and youth. A study is currently being conducted by the Drug and Alcohol Office into the dollar costs to Local Governments incurred when cleaning litter, vandalised assets and more. Whilst it is difficult to apportion which costs relate directly to Alcohol and Drug misues, estimates would be well in the tens of millions of dollars.
WALGA is pleased to note that support could be offerred to Local Governments and town planners, we are currently partnering with the Drug and Alcohol Office here to work with planners to ensure that they are able to maximise their role in reducing the effects of misuse. We look forward to further news on this particular point. View full submission by Richard Struik
07 Dec 2010
Submission by P James (Motivated Individual and Parent)
This is a well written and realistic strategy for minimising harm from drugs. I hope the following points provide some valuable feedback for the final strategy. View full submission by P James
03 Dec 2010
Submission by Professor John Toumbourou (Deakin University)
I wish to commend the draft National Drug Strategy 2010–2015 as a well considered and valuable policy document. In what follows I make only minor comments.
P. 10 “Some culturally and linguistically diverse (CALD) populations have higher rates of, or are at higher risk of drug misuse”. I recommend altering this sentence as it is misleading. It should make clear that non-Australian birth and non-English language background are typically protective factors associated with lower alcohol and drug use in the Australian population.
P11. Successes of the National Drug Strategy. This section could make clearer that the many positive changes would have been unlikely to occur without coordinated strategic action. Many strategic policies were not initially popular and in some cases such as such as the reductions in tobacco use were opposed by vested interests.
View full submission by Professor John Toumbourou
29 Nov 2010
Submission by Norml Australia (NORML AUSTRALIA)
I must say that the ignorance that you possess in relation to Cannabis and how helpful it is with the sick and needy as PROVEN WORLD WIDE is pathetic.
You people seem to forget, or rather simply do not acknowledge, that some pharma drugs that are LEGAL have severe side effects and are a detriment to anybodies health.
Your statistics are
Causes of deaths in Australia*
Pharmaceuticals 2,831 ( this one was not on your list ) maybe a bit bias on your part, but thats okay we did our own research
Motor Vehicle Accidents 1,731
Illegal Drugs 863
Cannabis 0. (another one that is not on your list)
Yes thats right Cannabis 0, 0 deaths. You cannot overdose on Cannabis. This is a proven scientific fact over and over again.
Your draft is really simple for our organization to understand.
We understand that you, yes you, support organized crime.
You would rather someone who only uses Cannabis for their health problems to go to a underground drug dealer and purchase it.
Drug dealers do not ask for identification and dont really know their product, to them weed is weed. If they dont have any they'll push something else.
Cannabis is not a gateway drug.
Cannabis has not made anyone commit any crime.
Cannabis is not addictive.
Lets face the fact shall we?
The Australian Government, simply knows all the benefits about Medicinal Cannabis but still persists to drive further backwards with blinkers on.
Every PATIENT who uses Cannabis legitimately knows that the only reason that Cannabis is illegal in Australia is because anyone can cultivate this miraculous plant and that the government wont get their cut.
Boohoo. Legalize it and tax it then.
Tobacco, alcohol and pharma drugs kill millions around the globe every year and yet they are legal.
This is a pretty sad state of affairs dont you think?
Let the public have a say and a vote for or against Cannabis. Although I must admit our organization dont want or need you to manage the sale, quality control and distribution of Cannabis.
We would do a far better job for the management and policing of Cannabis if it were legally available medicinally in Australia.
View full submission by Norml Australia
27 Nov 2010
Submission by Stephen
The draft outlines the growing problem of drug and alcohol problems in Australia and therefore highlights the failure of government and indeed the strategy itself over the last decade or so. View full submission by Stephen
22 Nov 2010