National Drug Strategy
National Drug Strategy

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SubmissionDate

Submission by Dr Khim Harris (Fresh Start Recovery Programme)



We would like to ask why is it that in the Draft there is not a measure of the reduction of individuals being prescribed government funded opiates. For example, there are currently some 43,445 people in Australia receiving pharmacotherapy treatment, with 30,000 of them receiving methadone (source: National Opioid Pharmacotherapy Statistics Annual Data collection: 2009 report). Whilst this helps in reducing the prevalence of people using an illegal drug (opiate), there is no performance measure to record the number of people ceasing their drug use. This should be the priority of any government in its drug strategy to help people to move from a situation of drug abuse to a drug free lifestyle in the shortest period possible. If there is no measure to reduce the no. of individuals on these programs, then there is no pressure or incentive in helping people to become opiate free. W



A recent paper published in the British Medical Journal reported that “exposure to opiate substitution treatment was inversely related to the chances of achieving long-term cessation”. For patients who did not start opiate substitution treatment, the median duration of injecting was five years – with almost 30% ceasing within a year – compared with 20 years for those with more than five years’ exposure to treatment (Kimber et al, 2010). As most patients on methadone maintenance are still likely to inject illegal opiates, albeit at a much reduced level pre methadone, they are likely to inject illegal opiates over a greatly increased period and are less likely to gain abstinence from opiate addiction. Is it not in the best interest of everyone involved, to provide alternative pharmacotherapies that help the individual to attain abstinence from all opiates and the risks associated with opiate use?



We wish to propose that a better measure of the success of the drug strategy is to measure the number of individuals who achieve a drug free lifestyle from both illegal and legal substances. This would then focus all those involved in implementing the drug strategy to work towards helping people wanting to become drug free. View full submission by Dr Khim Harris

20101210195513

10 Dec 2010

Submission by Macciza

If we are to use approaches that have been proven to be effective, then surely prohibition, as was experienced with alcohol, is a proven failure and alternatives should be sought. Would we have 'won the war' against alcohol by now, if it had remained illegal? If tobacco were criminalised to the point that Cannabis is, would that reduce attendant harms or create even greater problems socially? Considering you have not 'won' much against organised drug crime in more than 50 years of prohibition, let alone as a result of the renewed efforts over this past 25 years; can anyone serious believe that wewill achieve much in the next 25 years following the same path of prohibition and 'guns and robbers'.



There already exist a huge body of generated evidence on Cannabis - particularly regarding reform of laws against its personal cultivation and consumption. The real question is 'why are these recommendations for legal acceptable use are always ignored' ? The complete rejection or subsequent 'de novo' re-evaluation of any recommendations to reform laws to allow personal adult cultivation and consumption of Cannabis is an unfortunate indictment of the corruption of the political process. Law is not an absolute, particularly in a rapidly changing society. Law reform should be seen as a process rather than a destination, and should also overcome party politics and personal prejudices.



The National Drug Strategy has continued to perpetuate myth and hysteria regarding Cannabis cultivation and use, and directly supports powerful criminal syndicates through continued criminalisation of a popular recreational activity. Its selective rejection of any recommendations for liberalisation of current laws reinforces an already too powerful black market.



Performance measure may be analysed in many different ways to support many different viewpoints. It is time the National Drug Strategy realises and reflects the fact that increasing Cannabis arrest and increasing Cannabis seizures are a sign of policies failings and not of laws succeeding.



The Performance Measures to date reveal an approach which is unworkable, unachievable, unsustainable and unaffordable. Arrests and seizures repr View full submission by Macciza

20101210203456

10 Dec 2010

Submission by WANADA (WANADA)

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. View full submission by WANADA

20101210173901

10 Dec 2010

Submission by Jan Warren (South Australian Department of Education and Children's Services)

To date the Principles for School Drug Education (2004) have well informed approaches taken by education, health and law enforcement in the provision drug education to school-age young people. Strengthening of this evidence base is welcomed. View full submission by Jan Warren

20101210170121

10 Dec 2010

Submission by Burnet Institute (Burnet Institute)

Ongoing commitment to evidence informed programming is admirable but the strategy must also embody the same principles for data quality and use. For example, the strategy refers to data from 1998 data (NDS p11 re illicit drugs) which is an outlier due to survey errors and cannot be compared with later data to provide an accurate description of trends (2001 survey data is the earliest available comparison).

A minimum standard for program evidence must be consistent across the three pillars of harm minimisation. This is usually done well for drug treatment and other health indicators but should be replicated across all areas. In particular, a shift from activity indicators to valid and reliable performance indicators focussing the harms in the area of demand reduction and supply reduction (interruption) need to be identified. The number/volume of seizures alone cannot be a measure of success and using prevalence data to attribute success to supply and demand reduction programs is tenuous. Issues of this type arise with respect to law enforcement and many other previously funded programs.

There should be scope within the strategy to revisit activities within the suite of responses where the evidence has improved/changed to ensure effective responses are not excluded from consideration e.g. Sydney MSIC

View full submission by Burnet Institute

20101210153557

10 Dec 2010

Submission by Fiona Sharkie (Quit Victoria)

Page 31, last paragraph, suggested amendment: "Other academic institutions contribute to the evidence base with support from the NHMRC, ARC, universities and state and territory governments. View full submission by Fiona Sharkie

20101210164951

10 Dec 2010

Submission by J.B. Withnall, Prof S.B.Hill, Dr S. Bourgeois (University of Western Sydney)

Contact: Janice Withnall, University of Western Sydney



Page 1 of this document is submitted in the Harm Reduction section. Below is Evidence Base information, with a three page table in the Other Comment section.



Australian systematic research and data collection and analysis needs to include commitment to midlife women with AUDs so evidence-based and evidence-informed practice can be developed and trialled.



G. Initiating linkage of midlife-oriented, transdisciplinary AUDs recovery research AND practitioner - researcher partnerships is required

H. Expanding knowledge translation and dissemination for improved midlife recovery care AND contemporary evidence-informed integrated health and welfare services to support women to sustain abstinent recovery is necessary.



There are more than 450,000 midlife women in Australia who are high-risk drinkers, for which a homogeneous healthcare process is inadequate:

I. there is reverse discrimination (with the number of middle-class women with AUDs rising at a greater rate, than working class women abusing and dependent on alcohol)

II. high midlife self-stigma limits revealing alcohol problems to health professionals

III. and, misdiagnosis or ‘preferable diagnosis’ is common e.g., PMT, anxiety and depression, menopause-related and PTSD.



Our RWR study has identified a midlife women priority area and what works for midlife women requiring AUDs care: particularly developing socioemotional wellbeing; women-oriented chronic illness monitoring; enabling women’s non-drinking self-identity to develop within a recovery support network; and easy access to respite to stop or limit relapse.



Recovery care, development and support for midlife abstinence objectives (abstinence is on the continuum of harm reduction) are necessary and supported by 2008-2010 research. Progress towards women maintaining and sustaining long-term abstinent recovery will require robust service integration. This is cost effective when emergency services and acute care is reduced by early and proactive intervention. Importantly, women in midlife recovery are role models and can assist in the prevention of increasing alcohol consumption.

Abstract available View full submission by J.B. Withnall, Prof S.B.Hill, Dr S. Bourgeois

20101210155747

10 Dec 2010

Submission by J.B. Withnall, Prof S.B.Hill, Dr S. Bourgeois (University of Western Sydney)

Contact: Janice Withnall, University of Western Sydney



Page 1 of this document is submitted in the Harm Reduction section. Below is Evidence Base information, with a three page table in the Other Comment section.



Australian systematic research and data collection and analysis needs to include commitment to midlife women with AUDs so evidence-based and evidence-informed practice can be developed and trialled.



G. Initiating linkage of midlife-oriented, transdisciplinary AUDs recovery research AND practitioner - researcher partnerships is required

H. Expanding knowledge translation and dissemination for improved midlife recovery care AND contemporary evidence-informed integrated health and welfare services to support women to sustain abstinent recovery is necessary.



There are more than 450,000 midlife women in Australia who are high-risk drinkers, for which a homogeneous healthcare process is inadequate:

I. there is reverse discrimination (with the number of middle-class women with AUDs rising at a greater rate, than working class women abusing and dependent on alcohol)

II. high midlife self-stigma limits revealing alcohol problems to health professionals

III. and, misdiagnosis or ‘preferable diagnosis’ is common e.g., PMT, anxiety and depression, menopause-related and PTSD.



Our RWR study has identified a midlife women priority area and what works for midlife women requiring AUDs care: particularly developing socioemotional wellbeing; women-oriented chronic illness monitoring; enabling women’s non-drinking self-identity to develop within a recovery support network; and easy access to respite to stop or limit relapse.



Recovery care, development and support for midlife abstinence objectives (abstinence is on the continuum of harm reduction) are necessary and supported by 2008-2010 research. Progress towards women maintaining and sustaining long-term abstinent recovery will require robust service integration. This is cost effective when emergency services and acute care is reduced by early and proactive intervention. Importantly, women in midlife recovery are role models and can assist in the prevention of increasing alcohol consumption.

Abstract available View full submission by J.B. Withnall, Prof S.B.Hill, Dr S. Bourgeois

20101210155747

10 Dec 2010

Submission by APSAD (Australasian Professional Society on Alcohol & other Drugs (APSAD))

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. View full submission by APSAD

20101210150450

10 Dec 2010

Submission by School Drug Education and Road Aware (SDERA)

"The Principles for School Drug Education" (DEST 2004) have provided and evidence base for the development, implementation and evaluation of school drug education programs for a number of years. It would be timely, should further investment be accorded to school drug education, that these principles be revised and fine tuned according to the evidence that has emerged in the years subsequent to 2004. Consequently a more current and relavent performance framework could be developed around the successful delivery of school based drug education programs. SDERA supports the extension and refining of the evidence base upon which the performance of NDS is judeged. View full submission by School Drug Education and Road Aware

20101210150017

10 Dec 2010

Submission by Trevor King (DPMP Deputy Director) (UNSW: Drug Policy Modelling Program)

The commitment to evidence is important but it is equally important that the rhetoric is accompanied by effective measurable strategies.



The development of the National Drug Research and Data Strategy by a working group of experts is a good starting point for identifying research priorities. As outlined in the previous DPMP Expert Group NDS submission (2010), the end product needs to be ‘a directions document rather than an undifferentiated list of research topics’ (p 7). It will be necessary to draw on broad and multidisciplinary expertise to ensure good advice on research, testing and validation of new interventions, dissemination and translation into policies and programs.



The title of the strategy implies consideration of data systems. This was only briefly mentioned on page 33. It is critically important and was raised in the NDS Evaluation (Siggins Miller 2009). One of the dot points on page 32 should make specific reference to enhancing data collection systems.



The section on performance measures (p 33) notes that they are intended “to provide a broad indication of progress against the 3 pillars” of the NDS. Inclusion of these headline performance measures is a welcome improvement on the previous strategy. This is consistent with a high-level, broad, consensus document.



To strengthen the performance measurement section, the task of finalising indicators and measures should be the responsibility of the expert group developing the National Drug Research and Data Strategy.



The inclusion of objectives and actions in the strategy document serve to signal areas of focus for the NDS. But this level of detail also raises questions about the relationship between the NDS strategy document and the sub-strategies. The NDS strategy document needs to be supported by flexible sub-strategies or action plans written by experts and other stakeholders. It is at this level that specific goals, actions, resource allocations and performance measures (outputs and outcomes) could be outlined. This would complement the NDS strategy and increase the level of accountability.



View full submission by Trevor King (DPMP Deputy Director)

20101210121352

10 Dec 2010

Submission by Aboriginal Health Council of South Australia (Aboriginal Health Council of South Australia)

The actions to deal with supply reduction, demand reduction and harm reduction in Aboriginal communities should involve Aboriginal organizations. The Assessing Cost-Effectiveness in Prevention (ACE-Prevention) Study recently published by the University of Queensland estimated that prevention activities to improve the health of Aboriginal people are up to fifty percent more effective if delivered by Aboriginal community-controlled health services, compared to services delivered by mainstream organizations. View full submission by Aboriginal Health Council of South Australia

20101210110155

10 Dec 2010

Submission by Australian Drug Foundation (ADF)

We support the commitment to evidence based and evidence informed practice and the development of a National Drug Research and Data Strategy.



Effective evaluation of all actions and initiatives must be a core element of the strategy. We note that this is articulated as an action under only some of the objectives.



This commitment needs backing by adequate funding to support quality research and evaluation of programs over a reasonable length of time; as opposed to short –term funding with inadequate or non-existent evaluation budgets.



A valuable data source missing is Alcohol Sales Data. Currently only collected in Queensland, NT and WA, it can inform key alcohol policy developments and evaluations. The NPH Strategy recommended the national collection of this important data.



As well as identification of performance measures, there is a need to set targets against which to assess the progress of the NDS, such as has been set by the NPH Strategy for alcohol.



Other measures which should be included:

• Return on investment

• Effectiveness of treatment outcomes

• Prevention outcomes

• Rates of use of pharmaceuticals

• Changes in culture and attitudes

• Prevalence and extent of advertising, sponsorship and other promotions





PM1: Disruption of illegal supply

Focusing on offence type of measures (arrests, seizures, detections) will not give a true or useful reflection of the progress of the Drug Strategy.



More accurate measures would be intelligence related to the ease of availability and the price variations of various drugs.



PM 2. Indicators of Drug use



The Illicit Drug Reporting System should be included as a data source.

The measures identified will provide data on lifetime use, recent use and age of initiation.



PM 3: Harms associated with drug use.



Additional measures

• Costs associated with law enforcement, imprisonment

• Rate of individuals receiving correctional sentences due to drug offences

• Number of people who share or reuse needles.



View full submission by Australian Drug Foundation

20101210101433

10 Dec 2010

Submission by Richard Struik (Western Australian Local Government Association)

We support this section. View full submission by Richard Struik

20101207183550

07 Dec 2010

Submission by P James (Motivated Individual and Parent)

I agree that policy and strategy must be evidence based and would like to see more specific reference to this in the Strategy. How is this evidence collected and analysed? Who is responsible for setting and measuring performance against targets? How will this evidence be conveyed to the stakeholders and community? View full submission by P James

20101203170817

03 Dec 2010

Page currency, Latest update: 23 September, 2009