Download Introduction - National Drug Strategy

AUSTRALIA’S NATIONAL DRUG STRATEGY
BEYOND 2009
A SUBMISSION BY THE
NATIONAL DRUG RESEARCH INSTITUTE,
CURTIN UNIVERSITY OF TECHNOLOGY
PERTH, WESTERN AUSTRALIA
Contact Details
Professor Steve Allsop
Director
National Drug Research Institute
P: 08 9266 1600
E: [email protected]
Postal:
National Drug Research Institute
Curtin University of Technology
Health Research Campus
GPO Box U1987
Perth WA 6845
Introduction
As noted in the consultation paper, the National Drug Strategy (NDS) has served
Australia well for more than two decades, and is held in high regard internationally.
As one of the national Centres of Excellence and therefore a key stakeholder, the
National Drug Research Institute welcomes the opportunity to provide meaningful
input into the structure of the post-2010 framework.
In this submission, the Institute briefly addresses key items raised in the ‘Australia’s
National Drug Strategy Beyond 2009’ consultation paper, focusing on each of the
NDS Principles and Emerging issues and New Developments as outlined in the
consultation paper. The points made aim to ensure the 2010-2015 cycle of NDS can
achieve optimum outcomes and engage with and create broader acceptance in the
community for its goals.
National Drug Strategy Principles
A consistent approach
We agree that the harm minimisation approach – as framed in the Australian context
as an overall umbrella principle under which supply reduction, demand reduction and
harm reduction fit – has provided a space where a diverse range of stakeholders can
be brought together and cooperate toward a shared goal.
While there have been criticisms of the terminology and approach, these have been
well weathered. We do not see any reason to change this consistent and proven
framework. It may however be appropriate to enhance communication about harm
minimisation (we accept there is misinterpretation of what harm minimisation
involves) and its positive impact to the community and other key stakeholders.
While there has been a call to find a new terminology other than ‘harm minimisation,’
we believe this is the wrong approach and will imply a step away from the core
principles of previous strategies. We concur with the Siggins Miller review that more
needs to be done to explain and communicate the causes and consequences of
drug-related harm and the ‘three pillars’ approach. To this end, NDRI has published
research showing that the principles of harm reduction programs can be readily
explained to the general public and providing an evidence-based rationale results in
increases in self-reported support for such approaches (Lenton and Phillips 1997).
Similarly this approach is enacted in NDRI’s extensive history of evidence-based
comment in the media on alcohol and other drug (AOD) issues, which we see as a
central role of a research centre of excellence such as our own.
Evaluation Recommendations
The first thing that strikes the Institute is that responses to the recommendations
made by Siggins Miller in its evaluation of the National Drug Strategy 2004-2009 are
not readily identified in the consultation document. As a simple and striking example,
recommendation one is important but it is not clear how the new NDS intends to
incorporate any response to this:
Highlight and further develop a shared public understanding of the
causes and consequences of drug-related harm and the need to
retain the three pillars of supply reduction, demand reduction, and
harm reduction, and consider replacing the term ‘harm minimisation’
with words which better communicate the need for prevention of
drug use and drug-related harm.
This might easily be dealt with by ensuring that there is a communication strategy to
ensure the community is informed about patterns of drug use, related harms and
responses to these harms – and how that is relevant to the three pillars approach.
Consistent Terminology
It is imperative that consistent terminology is used throughout the new NDS to avoid
confusion and conjecture. For example, on page 4 of the consultation paper harm
reduction and harm minimisation seem to be used interchangeably when many
stakeholders, both within the AOD field and outside it, define these terms differently.
In other instances reference is made to drug use, drug related problems and
substance use issues. Consistent terminology should be used and the Institute
suggests that drug use is the most useful term. “Substance use” is commonly used in
the U.S. terminology but does not have common understanding outside the AOD
field.
Furthermore, the discussion about harm minimisation on page 4 should make a
stronger and evidence-based case for this principle, particularly given that there is a
well-founded desire to continue along this path, and, as the paper states, harm
minimisation “continues to be relevant today and is increasingly accepted
internationally as a humane and pragmatic approach”. The Institute suggests that a
brief explanation of supply reduction, demand reduction and harm reduction in this
section would help guide understanding of such terms.
Evidence-based Practice and Policy
We note the statement in the consultation document that ‘policy and practice are,
wherever possible, informed by research evidence…’ We support this principle.
Wherever possible, policy and practice should be evidence-based, and where
evidence is not sufficiently developed, policy and practice should be evidence
informed. It is pertinent to re-affirm that decisions made within an evidence-based
approach necessarily give priority and weight to the best available evidence. In a
practitioner-client context, the burden falls to the practitioner to interpret the evidence
in terms of the unique needs of the individual and to facilitate informed choice by the
individual. We recognise that there are significant gaps in the research evidence and
much research evidence has limited or no direct relevance for significant segments of
the population. To this end, while we must build the evidence base where it is weak
or lacking, we must also ensure that we interpret the evidence in terms of the unique
needs and wants of the individual and/or community. Building research capacity
should also be matched with building the capacity of the workforce to best use that
research, as highlighted elsewhere in the consultation paper.
A Balanced Approach
As an overarching statement ‘policy balance’ has the advantage in that it conveys
that all elements of the drug problem (illicit and licit) and strategy responses (supply
reduction, demand reduction and supply reduction) have been attended to. However,
quantifying where the balance in expenditure and effort should be put is a very
difficult process.
There is some evidence to consider in this regard (e.g. costs of drug use, current
government expenditure, effectiveness of various interventions) however, this
evidence base is incomplete. The ‘balance’ decision may always be a value-based
one in that it depends on the importance placed on each of these elements. While
the net estimated costs of various drug types are important (tobacco and alcohol
versus illicit drugs, for example) this does not in itself inform what should be the
priorities of a limited intervention budget.
As an example, alcohol and tobacco have been estimated to be responsible for 65%
and 19% of the burden of disease in Australia respectively, while all illicit drugs
combined are estimated to be accountable for 16% (Begg, Vos et al. 2007). Yet the
proportion of State, Territory and Federal Government budgets spent on responding
to these drugs have been estimated at 5% for tobacco, 50% for alcohol and 45% for
illicit drugs (Collins and Lapsley 2008).
The response to this question of balance is not as simple as matching the proportion
of budget expenditure to the proportion of harms. A major reason for this is that legal
drugs (tobacco and alcohol) can be subject to powerful and proven statutory and
regulatory measures (price, taxation, restrictions on availability, legal age, etc.) where
the levers of influence for illicit drugs are far less powerful and more costly, simply
because these drugs are not subject to legal regulation.
The evidence is clear that the harm associated with the use of alcohol and tobacco
could be substantially reduced if governments better applied these proven legal and
regulatory strategies for these legal drugs (Loxley, Toumbourou et al. 2004).
With regards to illicit drugs, we note Siggins Miller’s estimation that the total
expenditure for Australian State and Territory Governments is estimated at crime
92%, health 7% and other 1% (Siggins and Miller 2009). We note also that those
members of the public surveyed as part of the 2007 National Drug Strategy
Household Survey on average recommended for illicit drugs that 40% should be
spent on law enforcement, 26% on treatment and 34% on education (Australian
Institute of Health and Welfare 2008). As we have previously said, the balance
question is primarily a value issue and most of the relevant ‘evidence’ is already in.
We note the substantial discrepancy between the estimated 92% of government
monies spent on illicit drug law enforcement and the 40% the Australian public
believe should be spent on these measures. We concur with Siggins Miller in calling
for a re-balance of efforts and investment among supply, demand and harm
reduction strategies across legal and illegal drugs but note that this is largely a
political decision.
We also note a significant imbalance. Co-existing mental health and drug problems
have been noted as a major challenge for mental health, drug specialist, mainstream
health and emergency services. A significant factor in responding to this issue is the
limited resources that are available to effectively respond, especially in the mental
health services, despite welcome increases in investment in recent years. The
significant burden created by co-existing mental health and drug problems, for the
individual, families, the community and services suggest that some attention, and
increased resources, are indicated in this area.
Emphasis on Prevention
The National Drug Research Institute welcomes the additional emphasis on
prevention outlined in the consultation paper, with a particular focus on early
intervention and targeted prevention activities across the life cycle.
However, the Institute believes that it will be important to identify and communicate
key elements of a prevention strategy, such as universal interventions to prevent
risky alcohol use, targeted interventions to address vulnerable and disadvantaged
groups, and brief interventions for adolescents with emerging risky drug use patterns.
The Institute also has some concern about the comment that prevention activities will
“necessarily include targeted and broad based social marketing strategies.” Having
made a plea to base the strategy on evidence, we wonder where is the evidence to
single out social marketing in this way? In many domains, this is where the evidence
for effectiveness is at its weakest. The Institute supports social marketing strategies
as having a supporting role in a broader evidence-based approach that includes
other proven strategies, but questions the singling out of this approach in this
manner. As mentioned earlier, perhaps some unpacking of evidence-based
strategies will help and perhaps there needs to be a statement that a range of
combined and long-term approaches are required. These are issues that the National
Drug Research Institute has focussed on in the past (e.g. Loxley et al 2004, NDRI
2007) and we believe this is a domain where the Institute’s expertise can particularly
make a contribution to the NDS.
Furthermore, the reference to the role that schools can play ignores the evidence for
the importance of early intervention in the pre-school period, particularly for
vulnerable populations. The transition periods in children’s lives – to primary school,
into secondary school and post-school education, training and employment – are
also important. As such, we suggest that the recommendation of the Siggins Miller
evaluation regarding the development and implementation of a national prevention
agenda should be strengthened and include a reference to early intervention.
Emerging Issues and New Developments
The consultation paper’s focus on emerging issues is a prudent and clear-thinking
approach to AOD issues in Australia.
In particular, the Institute strongly supports the inclusion of new technologies as an
area of focus. While we acknowledge that this has implications in terms of law
enforcement as outlined in the discussion paper, we suggest that there should be at
least equal focus on the potential of new technologies to expand prevention and
harm reduction activities, ranging from delivery of interventions and the monitoring of
AOD use patterns to the provision of information to drug consumers and the wider
community.
Key emerging issues that are touched on in the paper but that the Institute believes
require particular focus include:
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The need to focus on Indigenous populations. The evidence indicates that –
despite a range of interventions – there has been little or no decrease in
levels of harmful alcohol and other drug use and that in some communities
problems are probably getting worse.
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New technologies provide new challenges and opportunities – i.e. how they
impact on drug supply, promotion (e.g. of alcohol and tobacco) patterns of
use and provide opportunities for intervention.
The need to focus on populations that do not access treatment services (e.g.
the overwhelming number of people affected by alcohol use; a large
proportion of people who use ecstasy).
The need to invest in better and more timely indicators of patterns of drug use
and harm.
Better engagement of mainstream services in identifying and responding to
AOD related harm, and investing in approaches that coordinate effort across
sectors.
More investment in broad preventive effort (e.g. engaging children in school;
interventions that target vulnerable families and populations).
Investment in evidence-based controls on alcohol availability.
Facilitating the collaboration among sectors that is discussed in the
consultation paper requires investment and resources e.g. contracts and
funding formulae, performance indicators etc.
Cross sectoral approaches
We agree with the sentiments expressed in the Strategy document regarding linking
up the variety of policy priorities and programs that relate to the AOD field. With
regard to the questions about suggested structures and other sectors of
engagement, in addition to those mentioned in the document, we would also add
corrective services and prisoner health and the Australian Taxation Department,
particularly in light of the Henry Taxation Review and the potential implications of
recommendations for alcohol taxation in Australia.
We also note the reference on page 7 of the consultation paper that “The next phase
of the National Drug Strategy will need to take account of the Preventative Health
Strategy” [our emphasis]. This is rather passive and meaningless phrasing. To the
Institute, it seems that work in the area of preventative health is of direct relevance to
the goals and outcomes of the NDS, and vice versa, and rather than taking account
of the Agency’s work, there should be a strong and direct collaboration between the
NDS and the Preventative Health Strategy where their objectives overlap.
We think it is timely to ask the question about IGCD and MCDS and their
engagement with external advice. In our view, while these structures have served the
Australian community well t we believe that their capacity to respond to a changing
drug-using environment can be further enhanced by revising the structures and
mechanisms for expert input. While it is hard to judge from the outside whether the
National Expert Advisory Panel (NEAP) structure is functioning optimally there is a
danger that where experts are invited in on an ‘as needs’ basis that such requests
will be piece-meal and diminish over time. As a consequence, the committees to
which they would have reported become more concerned with process rather than
content. Although there is a risk that external expert advisory groups can become
thorns in the side of government, as per the recent experience with the ACMD in the
U.K., the advantage is that they can provide up-to-date information about new and
emerging trends, issues and potential responses which can invigorate and inform
and stimulate timely consideration.
We believe that there is an opportunity here to facilitate expert input to both MCDS
and IGCD from a breadth of stakeholders both within and outside the AOD sector.
We recommend that an expert working group be established to explore options and
mechanisms and report back to IGCD and MCDS, and the wider AOD community,
within a specific timeframe, such as six months.
One suggestion may be creating an expert advisory group or council including a core
group of stakeholders from the AOD sector along with experts from other related
sectors, including: Aboriginal and Torres Strait Islander services, housing,
employment, social welfare, corrective services, finance and taxation. From within
the AOD field, representatives should be included from each of the National Drug
Research Centres of Excellence (NDRI, NDARC, NCETA) along with drug
researchers from other research centres (e.g. Turning Point), the Alcohol and other
Drugs Council of Australia, the Australian Drug Foundation, the Australian National
Council on Drugs, the Public Health Association and the Chapter of Addiction
Medicine along with law enforcement research bodies, such as the Australian
Institute of Criminology.
The establishment of such an expert advisory body offers real promise to increase
the responsiveness of across-sector collaboration towards reducing Australia’s drugrelated harm. This expert committee should be independent of the liquor industry and
others organisations with vested interests.
Another suggestion is to extend the time allocated to the IGCD meetings to have
regular and substantial input from experts such as researchers from the Centres of
Excellence. While we understand that this does happen occasionally, we believe that
there is far greater scope to utilise the considerable and internationally recognised
expertise in the AOD sector in this country.
Indigenous Australians
In 2003, the Aboriginal and Torres Strait Islander Peoples Complementary Action
Plan 2003–2006 was introduced to supplement the National Drug Strategy. It was
subsequently updated to cover the period 2003–2009.
The Plan was based on extensive consultation with Indigenous Australians and
aimed to address the significantly higher prevalence of harmful use of AOD among
Indigenous people. To achieve this, the Plan had six key result areas:
1. Enhanced capacity of Aboriginal and Torres Strait Islander individuals,
families and communities to address current and future issues in the use of
alcohol, tobacco and other drugs and promote their own health and
wellbeing.
2. Whole-of-government effort and commitment, in collaboration with
community controlled services and other non-government organisations, to
implement, evaluate and continuously improve comprehensive approaches
to reduce drug-related harm among Aboriginal and Torres Strait Islander
peoples.
3. Substantially improved access for Aboriginal and Torres Strait Islander
Peoples to the appropriate range of health and wellbeing services that play
a role in addressing the use of alcohol, tobacco and other drugs.
4. A range of holistic approaches from prevention through to treatment and
continuing care that is locally available and accessible.
5. Workforce initiatives to enhance the capacity of Aboriginal and Torres Strait
Islander community-controlled and mainstream organisations to provide
quality services.
6. Substantial partnerships between Aboriginal and Torres Strait Islander
communities, government and non-government agencies in developing and
managing research, monitoring, evaluation and dissemination of information.
Despite commitment to the Complementary Action Plan by all Australian
Governments – Federal, State and Territory – there has been no significant overall
reduction in the prevalence of harmful AOD use among Indigenous Australians.
Furthermore, research conducted by NDRI on behalf of the National Indigenous Drug
and Alcohol Committee (NIDAC – a committee of the Australian National Council on
Drugs) shows that the extent to which these objectives have been met has been
limited, particularly with regard to key result areas 3, 4 and 5 (Gray et al, In Press).
Given this, there is need for continuing special measures to address harmful AOD
use among Indigenous Australians. If such measures are undertaken within the
framework of a broad National Drug Strategy it is likely that focus upon them will
become secondary to those aimed at the wider Australian community.
Therefore, in response to the question of whether a separate Complementary Action
Plan has value – and consistent with the Australian Government’s commitment to
‘closing the gap’ and with the recommendations of NIDAC – we recommend that a
Complementary Action Plan be retained as part of the next phase of the National
Drug Strategy.
Furthermore, the Institute also recommends that any focus on Indigenous Australians
should also have an emphasis on prevention and early intervention for the 0-5 age
group and families. There is a strong need for rigorous, longitudinal studies of the
impact of such interventions.
Capacity Building
The Institute is pleased that capacity building has been acknowledged as a key area
of the National Drug Strategy. Indeed, building capacity is a specific outcome also
included in our key result areas.
However any emphasis on building capacity needs to have a dual focus, both at an
individual level to build the skills of individuals but also at an organisational level. It
seems that the consultation paper is very focussed on individual skills/capacity. Any
emphasis on building capacity must focus on the need to develop organisational
capacity and mainstream service capacity to respond to AOD issues, not just rely on
developing the skills of individuals.
New technologies and online services (Lumby 2009)
As alluded to in the consultation paper, the increasing pace of technology
development will create particular opportunities and challenges for the community,
drug consumers and the AOD sector during the life of the next NDS.
Over the past decade, Australians who use psychostimulant drugs have increasingly
used the internet to access drug-related information. This behaviour is occurring as
part of a wider trend towards using always-available information to ‘Google’ just
about any topic of interest. NDRI research has shown that drug users have taken the
opportunity to openly and anonymously share drug-related information and make
connections with others with similar histories and interest in drugs. Most instructional
information about drug use available online is aimed at assisting users refine
techniques of use to reduce possible harms.
The public, open nature of many websites that host discussion about illicit drugs
presents both opportunities and challenges. Allowing open discussion risks enabling
information to disseminate freely that may be inaccurate and discussions about drugs
may be seen as glorifying their use or not provide enough cautionary advice. On the
other hand, open discussion also enables balanced information and strong warnings
in an environment where users can ask questions free of the fear of being identified
as a drug user. The public nature of these discussions helps with their monitoring by
health professionals and law enforcement agencies. This same benefit does not
apply to in-person conversations that occur privately.
As noted above, this is an emerging area that provides significant opportunities in the
direct delivery of interventions. Most young Australian drug users now live in a
context where internet use is embedded in their everyday lives. Such access to vast
amounts of drug-related information online changes the landscape of drug policy.
Young adults who are the target of drug prevention campaigns are less likely to
believe warnings about drug use if they are inconsistent with what they can easily
and quickly check online. To gain credibility with drug users, the next phase of the
National Drug Strategy will need to acknowledge the reality of drug use: its benefits
and risks. Doing this while still sending a message that resonates with the rest of the
population will be a formidable task in the present climate fuelled by
misrepresentation of all drug users as ‘addicts’ or ‘junkies’. To this end, engaging
young drug users with realistic messages and shifting public opinion away from
stigmatising drug users should be long-term goals of the National Drug Strategy.
Internet-enabled mobile devices, such as the iPhone, are also changing the context
of availability of drug-related information. The potential to develop applications that
enable access to relevant drug information at the same location that drug use is
occurring should be explored.
A particularly relevant challenge to monitoring and intervening in online drug
discussion will be the introduction of ISP-level filtering proposed by the Federal
Government. The impact of this policy should be monitored as drug users who lose
access to drug information websites may use easily-available tools to set up new
websites that bypass the filter through virtual private networks and secure http sites.
Peer-to-peer traffic will also remain unmonitored. Should drug discussion move to
these domains, it will become more clandestine and, consequently, harder to track
and respond to.
Increased Vulnerability
It is important and pleasing to see this focus included in the consultation paper. The
National Drug Research Institute suggests that there is a significant need for more
investment in interventions that target vulnerable families and populations and to
focus on populations who do not access our treatment services. This will necessarily
involve building collaborations with a broader range of stakeholders, who already
focus on building resilience, such as family and children’s services, education and so
on.
We recommend that the next phase of the NDS include greater exploration of the
costs and benefits impact of interventions, such as education, on the socially
excluded. Such an emphasis could be in line with a project the Institute has
underway, examining the immediate, short and longer-term outcomes for
disadvantaged people from their participation in a community-embedded and socially
supported university education pathway to social inclusion. Based on international
work in this area, the project will collect longitudinal data from the participants in this
and similar pathways to social inclusion. A cost and benefit analysis will examine
program costs and health, justice and other community costs.
Research and Monitoring within the NDS
Research and monitoring are essential in a strategy in which, where possible, policy
and practice are informed by evidence-based practice.
The review of the Research Centres of Excellence conducted in 2007 concluded that
‘the work of RC should continue to be supported’ noting that:
The research centres have made a major contribution to knowledge across
most priorities of the National Drug Strategy. The ongoing investment in RC has
meant substantial benefits in terms of political awareness of drug issues and
the establishment of a body of knowledge along with recognised experts
available for advice at short notice. (The Australian Institute for Primary Care
2007, p. 16)
We contend that a major contributor to the success of the NDS has been the
commitment to capacity building and research, especially the three Research
Centres of Excellence.
In the past dedicated funds were allocated for investigator-driven research in the
AOD field through specific funds (e.g. Drug and Alcohol Research and Education
Advisory Committee) and the Commonwealth AIDS Research Grant scheme. While it
was anticipated that these funds would no longer be needed once the field ‘matured’,
we have seen a steady decline in the relative success of AOD research applications
to competitive research granting bodies such as the National Health and Medical
Research Council as well as the level of funding provided to projects. There may be
several reasons for this. Firstly, the nature of AOD research, particularly research
with hard-to-reach populations such as users of illegal drugs, necessitates the use of
non-random recruitment methods with quasi-experimental designs which are often
judged poorly against other areas of social and medical research with more
mainstream research designs, such as Randomised Controlled Trials. Secondly,
particularly in the area of drug policy, the issues of interest to researchers, policy
makers and other stakeholders often overlap both health and law enforcement areas
and this poses problems for research funding agencies nested within these health
fields (e.g. NHMRC). Furthermore opportunities to do real world policy research are
determined by changes in the domains of government, politics and policy which
seldom meet the timelines and delays required in seeking research funds through
competitive research grant funding cycles.
For these reasons we recommend consideration again be given to establishment of a
dedicated funding source for investigator-driven research. This could be coordinated
under the auspices of one of the existing research grant schemes, such as NHMRC
or the Australian Research Council, or directly under the NDS.
In addition we note that the NHMRC expert reviewer panels, which play a central role
in deciding which research grants should be funded, do not include dedicated panels
for AOD research and representation of AOD research expertise on health and
medical panels is poor. In our experience, the level of understanding and quality of
review given to AOD research proposals by review panels is inconsistent and
arguably of a lesser quality and equity than would be achieved under a more targeted
system which utilised specialised content knowledge of the AOD field. To this end we
suggest that the NDS recommends, auspices and supports the establishment of
multiple AOD reviewer panels (which may incorporate international expertise) within
the NHMRC and ARC structures to provide adequate assessment of policy and
practice-relevant research proposals in the AOD field.
To date the NDS has been relatively well-served by its central monitoring
components of the existing routine data collections, such as the National Drug
Strategy Household Survey and the Australian School Students Alcohol and Drug
(ASSAD) survey. These surveys are important and they inform a substantial amount
of related monitoring work, such as the National Alcohol Indicators Project which
uses drinking prevalence estimates to monitor trends in alcohol-attributable mortality
and morbidity across Australia (e.g. http://ndri.curtin.edu.au/research/naip.cfm). The
National Alcohol Indicators Project has been a central source of information on
alcohol use and related harms for previous National Drug Strategy reports and
countless other publications.) Despite their important place as sources of
fundamental information about AOD use, a number of criticisms of the NDSHS and
ASSAD surveys have been identified, such as: the low response rate of the NDSHS
(consistently less than 50%); the fact that total alcohol consumption derived from the
NDSHS only accounts for a portion of what is known to be consumed from tax,
customs and industry sources; The ASSAD survey’s methodological approach to
self-report alcohol use which does not ask students about their consumption in terms
of standard drinks; and the fact that the ASSAD cannot comment on high risk youth,
such as those who do not attend school. While not wanting to compromise the major
strength of these monitoring systems – which is their consistency over time – we
recommend that the NDS again consider the review of monitoring systems.
While providing timely monitoring of trends in drug use and harms among sentinel
populations of high risk drug users, monitoring systems in the illicit drug field (e.g.
Illicit Drug Reporting System, Ecstasy and related Drugs Reporting System, Drug
Use Monitoring in Australia) contain less explanatory analysis and do not address
drug use by ‘mainstream’ populations of young people. Funding for these important
data collections is not guaranteed and we are in danger of losing the benefit of more
than seven years of accrued annual data trends into the future.
Another important and ongoing survey under threat is the National Prison Entrants'
Bloodborne Virus and Risk Behaviour Survey. This is an annual national survey of
blood borne virus (HIV, HCV, HBV) prevalence and risk behaviours in a consecutive
national sample of prison admissions. The findings, are vital to ongoing efforts to
highlight the importance of this group (prisoners) to the national blood borne virus
picture and to encourage jurisdictions to provide comprehensive treatment services
for hepatitis C in a very important setting for incubation and transmission of HIV and
other blood-borne viruses.
Recommendations
In summary, and particularly in relation to research and monitoring of AOD trends,
NDRI recommends:
o Increased funding to build alcohol monitoring systems in Australia, enhancing the
role of the National Alcohol Indicators Project (NAIP);
o Committed funds to ensure continued monitoring and early warning capability of
monitoring systems such as IDRS and EDRS;
o Funding for a targeted young people and alcohol monitoring system, particularly
given concerns around risky drinking among young people and emerging
evidence regarding the impact of alcohol on developing brains;
o Increased commitment to and investment in evidence-based prevention and early
intervention strategies;
o Retention of and investment in the Complementary Action Plan as part of the
next phase of the National Drug Strategy. This will include investment in building
practice and research capacity among Indigenous communities;
o More funding for Drug Law and Drug Law Enforcement Research, particularly in
the context of the consultation paper’s discussion around an emphasis on
prevention and cross-sectoral approaches;
o Funding for research into policy translation, especially in the context of the stated
desire for evidence-based policy and practice;
o Strategies to ensure Australia’s investment in drug research is maintained;
o Continued commitment to and investment in building collaborative approaches to
alcohol and other drug problems; and
o Enhanced structures and processes for government bodies to draw on the
research expertise across Australia.
Other Specific Issues
Treatment Pathways
While covered to some extent in comments above regarding cross-sectoral
approaches, the Institute strongly supports recommendation five in the Siggins Miller
review regarding better coordination of treatment pathways across sectors:
Recommendation 5: Further integrate treatment services and
pathways across the government, non-government and private
sectors, and encourage increased investment in comprehensive
models of evidence-based interventions, for example by:
1) working collaboratively across sectors to develop referral pathways
and integration of care, through government and non-government
provider co-location, coordinated referral pathways, and shared care
arrangements to meet the clinical and non-clinical needs of clients
2) increasing capacity across State and Territory, non-government,
and private sectors for more collaborative needs-based planning,
funding allocation, performance monitoring, and review processes.
Alcohol estimates
The Institute suggests that statements about alcohol use are carefully framed in the
NDS. The information outlined on page 2 of the consultation paper is based on
estimates that use outdated estimates of alcohol content of wine in Australia. For the
past several years, apparent per capita alcohol consumption across Australia
appears to have remained relatively stable, however, these estimates do not account
for the phenomenon noted elsewhere (i.e. in the U.S.) that the pure alcohol content
of wine has increased substantially in the past decade or so.
Caffeine use
The suggestion on page 4 of the consultation paper that alcohol and tobacco are the
most commonly used drugs ignores caffeine use.
“Right Protective Factors”
The Institute questions the use of the term “right protective factors” in the section on
prevention on page 6. We are confused as to what is meant by “right” protective
factors and suggest the use of an alternative terms and a brief explanation of what is
meant.
Key References

National Drug Research Institute (contributing authors: Chikritzhs, T., Gray, D.,
Lyons, Z. & Saggers, S.) (2007). Restrictions on the sale and supply of alcohol:
Evidence and Outcomes. NDRI Monograph. Perth: National Drug Research Institute,
Curtin University of Technology. ISBN:1740675339
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Lumby, C., Green, L., & Hartley, J. (2009). Untangling the net: The scope of content
caught by mandatory internet filtering. University of NSW, Edith Cowan University
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