Submission by Dr Khim Harris (Fresh Start Recovery Programme)
no comment View full submission by Dr Khim Harris
10 Dec 2010
Submission by Macciza
The Supply Reduction policies and objectives are not particularly appropriate to the decriminalised cultivation and consumption of Cannabis by adults. Rather than prohibiting and placing Cannabis in an uncontrolled market, Cannabis cultivation should be encouraged in a regulated market ensuring strain purity and quality.
Many of the arguments presented in this section are questionable once one accepts that Prohibition itself is the major problem. They are often based on moralistic, illogical 'a priori' assumptions that fail basic analysis ie- all 'illegal' drug consumption is 'misuse'. Additionally the arguments you use for legal drugs apply equally to personal Cannabis consumption by adults. For example, rephrased from the National Draft Strategy:
For personal Cannabis consumption by adults , both government and non-government authorities need to collaborate in regulating access to these drugs based on community norms and standards, and the health and other harms arising from inappropriate access. For cannabis, this means that cannabis licensing, planning authorities, licensed venues and retailers need to be involved – as do parents in reducing the supply of cannabis to minors. Additionally, the involvement of retailers is essential. For pharmaceutical cannabis, doctors and pharmacists need to be consulted and involved in supply improvement strategies to increase pharmaceutical use.
Objective two demonstrates further failures of logical insight:
Supply reduction for alcohol, tobacco, pharmaceutical and other legal drugs involves activities targeted toward the regulation of legitimate supply and the detection and interruption of illegal markets.
Obviously it is far easier to exercise true 'regulation' upon a legitimate market. We can only seek to 'detect and interrupt' illegal markets; by definition is there is no effective control of product purity, quality or quantity in a 'Black Market', and age restrictions etc simply are not applied.
Supply reduction policies have no place in the decision of an adult to grow Cannabis for personal consumption. Adults should be encouraged to cultivate Cannabis for personal consumption as an alternative to purchasing i View full submission by Macciza
10 Dec 2010
Submission by WANADA (WANADA)
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 View full submission by WANADA
10 Dec 2010
Submission by Jan Warren (South Australian Department of Education and Children's Services)
DECS strongly supports parental and family education re supply of alcohol to minors: as agents of change in communities, schools can play a role by engaging parents through their children's drug education programs to raise awareness about issues and approaches to prevention and intervention. View full submission by Jan Warren
10 Dec 2010
Submission by Burnet Institute (Burnet Institute)
Even though the strategy refers to ‘balance’ it still reflects an over-investment in supply reduction strategies. Commitment to this approach persists despite the absence of research evidence in support of effectiveness; community based policing is an exception here and provides an example of why commitment to trialling new approaches and commitment to gathering evidence of effectiveness is essential.
There needs to be an explicit acknowledgement that evidence in the area of supply reduction is lacking, a commitment to developing new and innovative approaches, development of performance indicators, not activity indices, and programming in response to what the evidence demonstrates works.
View full submission by Burnet Institute
10 Dec 2010
Submission by Fiona Sharkie (Quit Victoria)
No specific comments (adequately notes the need to curtail illicit tobacco). View full submission by Fiona Sharkie
10 Dec 2010
Submission by APSAD (Australasian Professional Society on Alcohol & other Drugs (APSAD))
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. View full submission by APSAD
10 Dec 2010
Submission by School Drug Education and Road Aware (SDERA)
SDERA supports the drive to curb the supply of lllegal drugs and emphatically supports the control and management of the supply of legal drugs to young people, specifically alcohol. While regulatory, enforcement and workforce development (training of hospitality staff) measures should be strenghtened to limit supply of alcohol to young people the vexing issue remains the secondary supply of alcohol to young people by parents. This has surfaced as an issue of some siginficance in the data of the last 2 ASSAD surveys 2005,2008. SDERA supports the strengthening of strategies to empower family communication around alcohol and drug use. SDERA supports the consderation of regulatory mechanisms to emphasis duty of care by adults at functions where young people have access to alcohol. 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)
The strategy outlines a range of supply reduction actions relating to illegal drugs that have been in place over previous strategies (Objective one, p 16). Given the substantial cost of these activities and the proportion of resources allocated to this pillar of the NDS, far greater emphasis needs to be placed on evaluating the effectiveness of the strategies. Therefore the actions relating to research in this area detailed on p 17 are welcome.
Paragraph 4 in this section (p 15) refers to the role of government and non-government authorities in regulating access to certain drugs based on “community norms and standards and health and other harms arising from inappropriate access”. It is equally important that government provides leadership designed to influence these norms, when the evidence suggests that a shift is required.
View full submission by Trevor King (DPMP Deputy Director)
10 Dec 2010
Submission by Australian Drug Foundation (ADF)
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.
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 Richard Struik (Western Australian Local Government Association)
We support this section. View full submission by Richard Struik
07 Dec 2010
Submission by Simon Beynon (FREECHOICE Stores - Tobacconist)
A key approach by the government is to introduce plain packaging on all Tobacco products, this approach only opens the door to a massive in crease in counterfiet tobacco products and therefore pushes the sale of tobacco products underground. Anyone person who is prepared to sell counterfiet cigarettes certainly will not worry about the age of the person they are selling it to. This just places an extra burden on the honest retailer who is ensuring they follow the rules of the land. From our understanding Counterfiet cigarettes account for around 10% of sales cost the government $100's millions every year. The government needs to concentrate on education and not make rash decisions that will cost both the tax payer and honest hard working retailers large amounts of money.
As we have expressed on numerous occasions to both state and federal governement, licences should be introduced to enable the sale of tobacco products, similar to what is currently in place for alcohol, by doing this you will significantly increase the controls you have over the sale of tobacco products and be have a stronger understanding of how many business's are selling tobacco products. View full submission by Simon Beynon
07 Dec 2010
Submission by P James (Motivated Individual and Parent)
For legal prescription drugs, the implementation of a Real Time Reporting system will aid in reducing the supply of drugs through intervention. Ideally this intervention needs to be at the point of prescription by GP’s. The value of such systems is currently being proven in Tasmania Department of Health and Human Services, who have successfully developed and deployed a Real Time Reporting solution with a local business partner. View full submission by P James
03 Dec 2010
Submission by Christina Naylor (Drug Awareness NSW)
There must be zero tolerance of illegal drugs.
Hours and venues for the sale of alcohol must be reduced - closing time not 3.00 a.m, but 10.00 p.m. at the latest.Thesale of useful commodities is much more restricted than this.
Warning labels must be put on all alcoholic beverages.
Plain packaging for cigarettes should be continued. View full submission by Christina Naylor
29 Nov 2010