Submission by Dr Khim Harris (Fresh Start Recovery Programme)
On page 21, the Draft Strategy mentions “A range of appropriate, specialised services should be available to anyone with a drug problem, irrespective of personal history, complex circumstances or socioeconomic status.” In the actions below, the report mentions only to “sustain efforts to increase access to, and links between, a greater range of treatment and other support services.”
We believe that emphases should be placed on the use of antagonist pharmacotherapies in the role of helping those individuals that are seeking a method of cessation of drug addiction. Currently this is only available to individuals living in Australia if they are prepared to travel to Western Australia.
View full submission by Dr Khim Harris
10 Dec 2010
Submission by Macciza
Demand reduction has no place in the informed decision of an adult to cultivate and consume Cannabis in moderation.
Again from your own publication, "The demand for drugs can also be affected by their availability and affordability; which can, depending on the drug, be influenced through supply control, regulation and taxation." The best method of supply control is through regulation and taxation of a legitimate market. Prohibition policies have negligible effect on demand and legalisation does not lead to an increase in demand.
Whilst we are talking about demand reduction, we are not aspiring to drug use elimination; drug use is an accepted part of our society - we are an intoxicated society. Inherent in this argument is a certain allowance of legitimate drug use, as opposed to the all too often used term of drug misuse with regards to any Cannabis consumption. Just as many people enjoy a relaxing alcoholic beverage in the evening, there are many people who simply choose to consume Cannabis instead.
Criminalisation of Cannabis users marginalises them from society and disconnects them from the broader community, the very opposite of the stated aims of inclusivity and connection. The continued criminality of cannabis is a policy of social exclusion. It discriminates against socially disadvantaged groups who are over-represented in the statistics and is not based upon any principal of harm minimisation.
The objectives of this section are either reduced, reversed or irrelevant if Cannabis consumption by adults is legally permissible, in line with the numerous official recommendations and overwhelming community opinion supporting such change. Cannabis cultivators and consumers come from all walks of life across every echelon of society. They are productive members of our society who are indistinguishable from the general populace by any criterion other than their choice to consume Cannabis. Their criminalisation is as selective as discrimination based on race, culture or sexual orientation.
View full submission by Macciza
10 Dec 2010
Submission by WANADA (WANADA)
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 View full submission by WANADA
10 Dec 2010
Submission by Jan Warren (South Australian Department of Education and Children's Services)
DECS acknowledges that a robust partnership approach is critical to achieving outcomes of the NDS. However schools and teachers (rather than other agencies) must remain central to the carriage of school drug education e.g. there is strong agreement in the research that for drug education programs to be effective they need to be based on the needs of, and be relevant to, the students who will participate in them. Providing students, particularly in secondary education, with opportunities to assert their needs within program development and delivery is important for the determination of appropriate content and learning strategies. Teachers are best placed to do this, and to respond sensitively to the individual needs of young people and families around these issues.
Informing, consulting and supporting families as part of the school’s drug education process is likely to lead to better outcomes. A number of reviews on effective drug education programs recommend the inclusion of a parental component.
A continuing emphasis on the role schools play in building resilience by promoting protective factors for wellbeing such as connection to schooling; engaging curriculum; success and achievement; positive relationships; and to address risk factors such as bullying; peer rejection; school failure; ineffective behaviour management etc. could be made explicit.
View full submission by Jan Warren
10 Dec 2010
Submission by Burnet Institute (Burnet Institute)
There needs to be increased commitment to collecting evidence for program effectiveness in the suite of demand reduction activities. The NDS refers to social marketing campaigns which have limited evidence for effectiveness outside of the tobacco programs (see Wakefield et al, Lancet, 2010). At a minimum, further research on developing effective social marketing strategies for other drugs should be undertaken before significant investments are made in programs using this approach. The section on participation needs to indicate that the evidence of effective programs in this area is very weak, and therefore further work is needed.
The strategy should allow for the development of consistent national structures for providing some of the mainstay treatments such as pharmacotherapy as a mechanism of demand reduction. This is especially important in relation to the costs of pharmacotherapy treatment which vary dramatically across the country.
The role of taxation as a supply or demand reduction tool with respect to alcohol is not represented in the strategy. View full submission by Burnet Institute
10 Dec 2010
Submission by Fiona Sharkie (Quit Victoria)
People with drug dependence have very high smoking prevalence rates (between 51-91%) and often die from illnesses caused by tobacco. However, tobacco cessation is often ignored by treatment services. Reviews of tobacco cessation literature indicate that smoking cessation during substance abuse treatment does not impair drug treatment outcomes and can in fact enhance outcome success. As such, it should be noted that drug treatment services should be giving much more attention to addressing nicotine dependence among clients. View full submission by Fiona Sharkie
10 Dec 2010
Submission by APSAD (Australasian Professional Society on Alcohol & other Drugs (APSAD))
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. View full submission by APSAD
10 Dec 2010
Submission by School Drug Education and Road Aware (SDERA)
SDERA supports the provision of school drug education as a key component of prevention education based approaches to demand reduction. The school setting has long been recognised as a focal point for prevention education. SDERA supports the notion that "Settings based approaches will be a key feature of the National Drug Strategy 2010-15>" SDERA supports the implementation of school drug education that complies with the "Principles for School Drug Education" (DEST 2004) and recognises that drug education should be:
- comprehensive in nature
- delivered by classroom teachers
- developmentally appropriate
- tailored to the local community context
- based on the best available evidence.
Schools are in a unique position to be able to connect with young people and their parents/carers and, given the resources, can not only provide prevention education but provide support for families and, in partnership with external agencies, referral avenues should early intervention be required. Furthermore, as part of broader student wellbeing philosophy, schools can focus on building protective factors such as resilience skills and contribute to socially inclusive communities through the adoption of of a health promotion schools approach. 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)
Objective two on page 20 & 21 focuses on reducing drug misuse largely through treatment. The first paragraph on page 21 should be strengthened by the inclusion of a statement to the effect that treatment should be evidence based or innovative/promising where the evidence base is weak. These words could also be incorporated in the first action regarding the development of nationally agreed principles for treatment services (p 23).
A key consideration is the delivery of treatment by competent specialist and generalist workforces (an issue considered in the workforce section of the strategy). The actions listed on page 23 will all contribute to improved treatment, however of fundamental concern is the issue of difficulty recruiting and retaining skilled staff due to inadequate service funding. This needs to be acknowledged in the strategy.
The lack of specific reference to substitution therapies in the strategy is very concerning. Efficacy as an intervention for opioid dependence has been well established and we know that potential unmet demand for treatment may be as high as 50% in the opioid-dependent injecting drug using population. There are many actions that require Commonwealth leadership to address issues such as national program consistency, client affordability and accessibility.
In previous NDS strategies there was a commitment to develop and implement a national prevention agenda. This is an important issue that requires a comprehensive strategy and significant investment. Actions listed on p 20 are welcome, but need to be located within a comprehensive strategy.
The section on social inclusion and resiliency (p 24) requires an action about the need for research to explore, understand and evaluate better ways of achieving community resiliency and social inclusion.
View full submission by Trevor King (DPMP Deputy Director)
10 Dec 2010
Submission by Australian Drug Foundation (ADF)
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.
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)
ACSO supports the general direction of all the proposed objectives and associated actions under the demand reduction pillar. As an organisation specialising in providing services to people within, and transiting from, the criminal justice system ACSO also commends the actions related to addressing the substance use needs of people involved with the criminal justice system. ACSO provides various transitional programs for offenders to assist with reintegration back into the community in an endeavour to improve client’s self-efficacy and to prevent reoffending.
Some points for consideration include:
Under the final action under Objective 2 (p. 22), we suggest to add developing opportunities within the criminal justice system and through the interface with the broader community. While provision of effective drug treatment services to people involved in the criminal justice system through imprisonment or community orders is crucial, this needs to be followed-up by sufficient transitional support as a person moves from the criminal justice system.
Similarly, under the final action under Objective 3 (p. 23) ACSO suggests consideration to include the criminal justice support sector as another crucial sector requiring linkage and coordination with other sectors.
Under Objective 4, ACSO strongly supports the third action (p. 24) relating to taking a preventative approach to high risk life transition points such as moving from prison.
Smooth transition from prison-based settings to the community are required for achieving positive outcomes for clients particularly when considering the increasing complexity of multiple issues such as substance use, homelessness, unemployment and mental health. This transitional phase is equally crucial in rebuilding relationships with families, partners and the community.
View full submission by ACSO
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)
Education is the answer, do not make a product taboo as this only makes the young ones want it more. Everyone knows the health risks of tobacco products as it is constantly taught at school, what makes it appealing to many minors is the fact that they should not be having it. This philosophy applies to all drugs both legal and illegal. View full submission by Simon Beynon
07 Dec 2010
Submission by Christina Naylor (Drug Awareness NSW)
Legal drinking age should be no earlier than 21.
heavy penalties should apply for supplying alcohol to minors.
Advertising of alcohol must be banned.
TV programs must be monitored to exclude gratuitous
advertising/glamorising of alcohol,tobacco or other drugs. View full submission by Christina Naylor
29 Nov 2010