Submission by Dr Khim Harris (Fresh Start Recovery Programme)
no comment View full submission by Dr Khim Harris
10 Dec 2010
Submission by Macciza
Governance is certainly needed - the Government at all levels needs to take the lead is making Cannabis a non-criminal offence in line with the numerous recommendations for change that it has requested and received in past. The political community needs to engage in productive debate to immediately enact legislation enabling the medical use of marijuana and to remove criminal penalties for the personal cultivation and consumption of Cannabis by adults.
The National Campaign Against Drug Abuse had a policy of 'uniform drug legislation' across the various States and Territories back in 1985. The Federal government needs to take the lead in setting an agenda of reform to bring all States and Territories to remove criminal penalties for personal Cannabis cultivation and consumption by adults.
The Intergovernmental Committee in Drugs should immediately review all the evidence in support of Cannabis law reform and the recommendations therein for legal reform and provide policy advice to the relevant Ministers in line with such recommendations of reform to remove criminal penalties for the personal cultivation and consumption of Cannabis by adults.
The continued support for prohibition by many levels of government is an endorsement of organised crime as it potentiates the very criminal syndicates whose very existence relies on the continuation of prohibition. This is not only an historically proven fact, but is also currently a major reason behind law reforms in many countries that have enacted reforms.
Governance is needed to take the lead and set an agenda of reform - any other course of action is complicity criminal.
View full submission by Macciza
10 Dec 2010
Submission by WANADA (WANADA)
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.
View full submission by WANADA
10 Dec 2010
Submission by Burnet Institute (Burnet Institute)
The NDS strategy should be a big-picture consensus document with a clear indication of where we aim to be 5 years hence. The draft NDS identified 16 relevant but separate sub-strategies at various stages of implementation in Appendix A. However, it does not articulate how these interact with the overarching NDS. As many of these have already or are about to expire, the Drug Policy Modelling Program proposal for a series of workplans to replace the sub-strategies is advocated. Workplans with detailed measurable performance indicators and resource allocations by subject area should report against the overarching objectives of the NDS and still allow sufficient flexibility to accommodate the reality that plans are implemented at state and local level and in a range of settings.
NDS governance arrangements need improvement to ensure key stakeholders (e.g. public, service providers and consumers and experts) remain engaged with implementation. The IGCD needs to achieve a balance between using in-house resources and drawing on external expertise especially in areas such as engaging the alcohol and other drug sector in significant health sector reform processes (e.g. Medicare Locals). The draft strategy hints at approaches for improved governance (e.g. linking AOD to the social inclusion agenda, establishment of working groups for development of research and workforce development strategies) but the public and service users remain unrepresented.
The two National research Centres should broaden their scope to reflect the fact that most of the spending is in law enforcement. There is also a need to make the funding mechanisms for these entities more competitive.
The membership of the national drug research data working group needs to be broadened.
View full submission by Burnet Institute
10 Dec 2010
Submission by Fiona Sharkie (Quit Victoria)
There is no reference to the National Preventive Health Agency and how the strategy will interact with, and/or contribute to, its work. View full submission by Fiona Sharkie
10 Dec 2010
Submission by APSAD (Australasian Professional Society on Alcohol & other Drugs (APSAD))
APSAD supports the continuing partnerships between the many sectors of government, and partnerships between government, community and research organisations.
We are concerned that the closing date of the submissions has been set at 10 December 2010 rather than having been delayed until decisions have been made about the future of the ATOD sector under the forthcoming national health reforms. It could well be that the governance arrangements will be significantly impacted upon by those decisions.
APSAD is disappointed that no changes in the governance structures and processes are found in this draft strategy. Considering that the draft has already been approved by IGCD and MCDS we assume it is unlikely that changes will be made as a result of this submission (not consultation) process. It is clear that the findings and recommendations of the evaluation of the previous phase of the NDS relating to governance have not carried through to the draft strategy. In particular, APSAD is concerned at the continuation of a governance framework which includes little capacity for people and organisations outside of government to have inputs into policy. While there were some difficulties with the system of IGCD expert advisory groups, their abolition has meant that IGCD has no structured way of accessing expertise around the nation that lies outside of government departments. We urge that this be reconsidered.
Furthermore, the IGCD remains the only conduit of advice on policy matters to MCDS. Retaining its membership as restricted to public servants means, as the NDS evaluation pointed out, that it faces significant impediments in taking into account the potential inputs of the non-government and community sectors, along with the expertise of ATOD researchers and practitioners. There is no place for inputs from Indigenous people and organisations. We see this as a lost opportunity to improve the governments of the NDS. View full submission by APSAD
10 Dec 2010
Submission by School Drug Education and Road Aware (SDERA)
No comment 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 document notes that ‘the IGCD will seek to engage sectors beyond health, law enforcement and education.’ On critical issues such as the relationship between drug use and social disadvantage/inclusion there is a compelling argument for expanding the IGCD to formally include representation from relevant sectors/departments.
The strategy document states that stakeholders will be invited to the IGCD to ‘discuss particular issues’ or working groups established to provide input (p 36). This approach will go some way to address disconnection from the policy process expressed by key stakeholders (eg. DPMP Expert Group NDS submission, 2010, p 3). The strategy document still falls short in outlining mechanisms for meaningful, ongoing engagement in the policy process for groups including consumers, Indigenous people, researchers etc. This also applies to the non-government sector where confusion still exists about representation – how? And by whom (ANCD, ADCA, other)? The challenge will be to demonstrate commitment and establish and document the structures and processes necessary to ensure meaningful input.
We would also expect the IGCD to provide or advocate for AOD representation in other critical forums. This is needed to address the sense that AOD ‘is not even at the table’ when many key health and welfare reforms are discussed (DPMP Expert Group NDS submission, 2010, p 3). We welcome reference to this issue and strategies to address it on p 37.
Unlike other sections of the strategy document, actions to improve areas of governance and performance measures are not included. This needs to be addressed given the concern expressed previously about this issue (Siggins Miller, 2009 p 63).
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 multiple problems caused by the misuse of alcohol and other drugs are usually be the most important issues affecting health and wellbeing raised by Aboriginal families and communities. High rates of illegal drugs are a problem in all geographical areas of Aboriginal Australia, from metropolitan to the most remote communities (although the drugs of choice or availability may vary across these areas). The misuse of prescription drugs is also a significant, if more hidden, problem. Aboriginal disadvantage and poor health status will continue unless there are specific actions taken to reduce these impacts. Given this, the strategy should outline particular actions to help Aboriginal communities address these problems.
When the exclusion of Aboriginal interests in documents such as this is pointed out to policy-makers, the usual response suggests that there is often an assumption that these interests are being met in other strategies or by other sections of government. In the area of alcohol and other drugs, this is emphatically not the case. The COAG Indigenous Health National Partnership provides funding for tobacco control, but alcohol and other drugs have been ignored. The National Drug Strategy represents an opportunity to redress the imbalance. It must not be missed.
In the draft strategy, each “objective” has a number of actions listed as dot points. Each objective has relevance for Aboriginal people, so is not unreasonable to suggest that there should be at least one dot point under each objective which specifically addresses the particular need of Aboriginal people.
View full submission by Aboriginal Health Council of South Australia
10 Dec 2010
Submission by Australian Drug Foundation (ADF)
The current system of governance has not served the community well. COAG, despite agreeing that drug misuse issues are a priority, too often puts drug issues on hold and delays decision making.
Currently the future and role of the MCDS is under review. Disbanding the MCDS would greatly compromise the future of the NDS and it implementation. We strongly support the continuation of MCDS.
The need for better community and Non-Government sector representation in the governance of the NDS was a common theme in the consultations. This has not been addressed. The Alcohol and Drug sector is quite unique in that it is the NGO sector which is responsible for the bulk of delivering programs and services.
The governance model put forward identifies the ANCD as providing the non-government voice. While the ANCD is a valuable and proven advisory body it does not (and does not claim to) represent the NGO sector.
The strategy states that the IGCD “ will seek to better engage sectors…. representatives of… and/or non-government organisations will be invited to the IGCD for discussion of particular issues.
We are concerned that this is too ad hoc and a more formal role for the non-government sector needs to be created to ensure a stronger NGO voice in advising on the direction and implementation of the NDS.
The NGO representation must go wider than just the drug and alcohol sector to ensure issues such as housing, welfare, employment and training.
In some instances the document talks about the Health – Law enforcement partnership as being central but in others refers to the Health-Law enforcement - Education partnership as central.
View full submission by Australian Drug Foundation
10 Dec 2010
Submission by Richard Struik (Western Australian Local Government Association)
We support this section, and encourage Local Government consultation, information dissemination and participation where appropriate View full submission by Richard Struik
07 Dec 2010
Submission by Simon Beynon (FREECHOICE Stores - Tobacconist)
We would appreciate being involved in discussions over the approach on tobacco as we are the franchisor of over 180 tobacconists, who derive their income from selling a legal product to persons over the age of 18 and as part of our franchise agreement we make it perfectly clear that all franchisees have a responibility to obide by all federal and state legislation in relation to the sale and display of tobacco products so it is important that we are involved in any discussions that could have a dramitic effect on our franchisees businesses. View full submission by Simon Beynon
07 Dec 2010
Submission by P James (Motivated Individual and Parent)
The ownership of this strategy needs to be clearer, the targets need to be more defined, and the owners need to be seen to be responsible for achieving the targets. View full submission by P James
03 Dec 2010