Vienna NGO Committee on Drugs
Wagramer Strabe 5, P.O. Box 14
Vienna 1400
Austria
Dear Committee Members
Re: The Vienna NGO Committee on Drugs request for comment on V2 23 November 2021 1 ASIA-PACIFIC CIVIL SOCIETY COMMON POSITION ON DRUGS.
Thank you for the opportunity to contribute comment to the ‘Position Paper’, above.
Drug Free Australia would like to bring to your urgent attention the clear objections of drug prevention agencies such as ours to the wording in the 23 recommendations
- General Comment
- In our part of the Asia-Pacific region, that is within Australia, there is little doubt about what the Australian public feels about illicit drug use and New Zealanders would be little different. Every three years our Australian Government conducts household surveys which in 2019 indicated that 99% of Australians do not approve the regular use of heroin, ice and speed with 97% against the use of cocaine, 96% against ecstasy and 80% against cannabis. With these levels of outright disapproval, Australians clearly do not want more drug use, but less.
The underlying assumptions of all statements in the VNGOC document, other than those statements that speak drug prevention, support policies that demonstrably lead to increased drug use. Therefore the document flies in the face of our country’s sentiments about drug use. The same could be said about every other Asian and Pacific country where attitudes to drug use are on all reports similar. The VNGOC document therefore needs to be entirely redrafted to reflect the attitudes of each country’s public, and not the attitudes of politically orientated NGO’s which are out of touch with the public’s own sentiments.
- In our part of the Asia-Pacific region, that is within Australia, there is little doubt about what the Australian public feels about illicit drug use and New Zealanders would be little different. Every three years our Australian Government conducts household surveys which in 2019 indicated that 99% of Australians do not approve the regular use of heroin, ice and speed with 97% against the use of cocaine, 96% against ecstasy and 80% against cannabis. With these levels of outright disapproval, Australians clearly do not want more drug use, but less.
- The paper assumes that there is a strong science supporting the success of harm reduction initiatives. This assumption is clearly wrong. The paper needs to be rewritten around the reality of the drug intervention science, which clearly demonstrates that harm reduction initiatives are not successful. For instance, there is no evidence supporting the effectiveness of needle exchanges, as seen in the world’s most authoritative study on needle program effectiveness – the pro-harm-reduction US NIH Institutes of Medicine 2006 finding that there is inconclusive evidence on their effectiveness against HIV and that multiple studies show they do not reduce transmission of HCV. Likewise with maintenance therapies – the 2009 Cochrane Collaboration review done by harm-reductionist Professor Richard Mattick found no benefit for these programs in reducing overdose deaths or criminality, the very things they had claimed to reduce. If the VNGOC paper wrongly assumes the success of harm reduction initiatives, it clearly must be rewritten to reflect the failure of harm reduction, rather than giving a pretense of success.
- The paper wrongly assumes that there is a societal consensus that drug policy has failed. There is no such consensus, and never has been. Many within the international community believe that increased drug use is because governments have not been sufficiently committed to the enforcement and rehabilitation required by the international Conventions against illicit drug use. Others, more particularly represented in the Position Paper’s statements, see any failure as due to a lack of non-inclusive, drug user orientated policies. These positions are polar opposites, and therefore cannot feed any assumed consensus of any kind. Statements that reflect the false assumption of any consensus about drug policy must be removed.
- The Paper appears to make liberal reference to a multitude of UN documents to support the points made herein. DFA has concerns that the author may be subtly misrepresenting & overstating the extent to which the supporting reference endorses the points made. Some measure of clarity and balance is needed with regard to this.
- Drug use, like drink driving, is a behaviour which is associated with increased risk for both the individual and for those around them. For these reasons, most societies do not permit drug use, in line with international agreement, or such other behaviors.
- Not everyone who engages in any of these behaviours experiences or causes harm. When society is discussing road traffic policy, drink drivers and NGOs who represent their interests, are not invited onto the top table to discuss and agree the societal response to road safety. The assumption of the VNGOC paper is at odds with normal societal practices.
- This common position seeks to capture a consensus among civil society organisations from across the Asia-Pacific region, reflecting the need for health and evidence at the centre of all drug policies, while operating in a manner consistent with human rights. While the VNGOC paper is focused on the inclusion of certain vulnerable groups, including the UN right of children to be free from the harm produced by drug use, the paper does not appear to reflect the rights of a drug user’s partner, their children’s grandparents, siblings, friends, workmates or other road users to be free of the harm caused by drug use, and this non-inclusiveness weakens the force of its statements.
- Challenges
While our legal psychoactive drugs alcohol and tobacco, are larger contributors to morbidity & mortality, the harms arising from dugs use remain substantial (Murray et al, 2020). These harms are experienced primarily by people who use drugs but are also experienced by others, especially the families of people who use drugs. The harms arising from persistent drug use include addiction, mental health problems, physical illnesses and inability to fulfil social roles (caring for family, employment, participation in education). Harms can also arise from short term or episodic use due to acute intoxication, including overdoses, suicidal and aggressive behaviour and road traffic collisions. Growing up in a home with a parent who has an addiction constitutes an adverse childhood experience (ACEs) in itself and is also associated with a range of other ACEs. Children who have many ACEs are much more likely to suffer poor mental and physical health, and to develop addiction themselves.
3. Specific Comment on sections of the VNGOC document:
Re the following statements in the VNGOC document:
(1) Commit to the goals of the UN System Common Position on Drugs (2018)3 and Incarceration (2021)4 within the framework of 2030 Sustainable Development Agenda, with a view to implementing truly balanced, comprehensive, integrated, evidence-based, health led, human rights-consistent, and sustainable responses respecting local cultures to the world drug situation
(7) Need para on human rights violations.
we would warn that, in relation to the inclusion of civil society, that the UN must ensure that there is no capture of civil society organizations by those who are intent on the development of a new legal commercial drug industry. We know from experience in domains of tobacco and alcohol that industry actors frequently use ‘charities’ and NPGs to act as fronts to protect their commercial interests.
Pharmaceutical companies have similarly infiltrated and influenced patient advocacy groups (Rothman 2011). While there is currently only a relatively small legal drugs industry (the cannabis corporations in Canada), it would be naive to think that those who are intent on growth of a new trillion-dollar drugs industry are not currently using similar approaches to infiltrate civil society.
(11) Acknowledge the invaluable expertise of and participatory role that people with drug addiction and people with lived experience of harms arising from drug use, play in shaping successful drug policies and responses to the world drug situation.
This expertise will also ensure that the voices of children whose lives has been adversely impacted by parental drug use are included. The voice of other family members and of non-drug using victims of harm (e.g. those bereaved by a road traffic collision caused by drug intoxicated drivers) should also be represented. Equal opportunity must be provided to voice their rights at all levels.
(14) Recognise that evidence-based prevention of drug use should be part of any comprehensive response to drug use in society, with a focus on all domains of prevention: family, school, community, media, and workplace prevention.
In particular, there should be a focus on young people within prevention efforts to delay initiation into substance use and thus, preventing the harm to the developing teen brain and, therefore, reducing the prevalence of problematic drug use. More particularly, children who grow up in homes affected by parental addiction should receive prompt and adequately resourced social, medical and mental health supports.
In relation to criminal justice responses as reflected in the VNGOC statements:
Imprisonment is an inappropriate criminal justice response to drug use, except, for example, where possession is ‘deemed’ to be for personal use, but, in reality, is part of an organized crime syndicate that uses small, individual ‘drug couriers’ to on-sell their drug products, under the guise, ‘if caught, to claim that it is for personal use only’. We note that Drug Free Australia has always promoted mandatory rehabilitation rather than imprisonment.
We trust that these comments and recommendations will be given serious and robust consideration.
Yours faithfully
Yours faithfully
Major Brian Watters AO
PRESIDENT
Drug Free Australia
Former Vice President, INCB (UN)
4/14 Tuffy Avenue
SANS SOUCI NSW 2219
Herschel Baker
International Liaison Director,
Queensland Director
Drug Free Australia
M: 0412988835
Prevent. Don’t Promote Drug Use