News

Submission to the Inquiry into Reducing Rates of E-Cigarette Use in Queensland

This submission discusses a range of issues relevant to the Committee’s terms of reference including:

• the importance of understanding the limitations of how data around e-cigarette use (vaping) is currently collated and reported;
• that the overall ‘risks’ of nicotine vaping products are significantly less than those associated with traditional cigarettes and it is important that any perceived risks are balanced against evidence which shows their potential for use as a smoking cessation aid;
• that any approaches in schools and other settings relevant to children and young people which seek to discourage the uptake and use of e-cigarettes should be evidence informed and accord with ‘what works’ in responding to alcohol and other drug use among young people;
• the need for a better understanding of the available research about the risks and harms associated with e-cigarettes, which are largely associated with the currently unregulated market; and
• the overarching need to re-establish a national governance framework for responding to these types of emergent issues in a more coordinated way.

Please click here to read the full submission.

Submission to the Independent Commission of Inquiry into Queensland Policy Service Responses to Domestic and Family Violence

This submission seeks to build on QNADA’s Submission to the Women’s Safety and Justice Taskforce which considered:

• the role that non-government alcohol and other drug treatment and harm reduction services can play in responding to domestic and family violence;
• the ongoing importance of enhancing understanding of the inter-relationship between domestic and family violence and alcohol and other drug use;
• and the stigma and discrimination faced by victims of domestic and family violence who may use substances (particularly illicit drugs).

In considering the Commission’s Terms of Reference and the experiences of the people engaged with our member services who are impacted by domestic and family violence this submission makes a number of observations in relation to:

• the impact of stigma and discrimination on if, how, and when victims may seek assistance from police, particularly where they use illicit drugs;
• the current inability of agencies to safely advocate at an individual, local or systems level where instances of poor service delivery from police may be identified; and
• the evident disconnect between a stated policy intent and how initiatives are implemented operationally across the Queensland Police Service.

Please click here to read the full submission.

Submission on the Corrective Services (Emerging Technologies and Security) and Other Legislation Amendment Bill 2022

QNADA prepared this submission on the Corrective Services (Emerging Technologies and Security) and Other Legislation Amendment Bill 2022 by considering aspects most relevant to our work and our members. Many of our member services support people who have previously been in, or are in, correctional centres or youth detention facilities which provides us with a clear understanding of how any proposed legislative amendments may be implemented or operationalised across Queensland. In the submission we discussed the following points in detail:

• Modernising the emergency response framework
• Criminalising evolving behaviours putting corrective services facilities and youth detention centres at risk and the use of x-ray body scanners and other emerging technologies
• Enhancing information sharing

Please click here to read the full submission.

Submission to the Tobacco and Other Smoking Products Amendment Bill 2023

QNADA recently made a submission to the Tobacco and Other Smoking Products Amendment Bill 2023. We have concerns over an increased regulatory response to further reduce smoking rate in Queensland. We think the provision of evidence-based tobacco prevention and cessation programs as part of routine care across all health and community services and in correctional settings, including within alcohol and other drug treatment and harm reduction services, is more beneficial in helping people to reduce their use.

Please refer to the full submission here.

Submission to the Inspector of Detention Services Bill 2021

QNADA welcomes the opportunity to provide feedback on the Inspector of Detention Services Bill 2021. We commend the intent of the Bill and recognise the important role that the Inspector of Detention Services will have in ensuring accountability and oversight of detention in Queensland with a view to promoting and upholding the humane treatment and conditions of the people detained.

QNADA members provide a diverse range of alcohol and other drug treatment and harm reduction services to people with alcohol and other drug issues in detention facilities. Our feedback is primarily related to the provisions around the interactions between the Inspector of Detention Services and alcohol and other drug treatment and harm reduction services delivered in detention facilities, as well as those delivered to people exiting detention facilities or engaged with community corrections.

Please read the full submission here.

Submission to the Strengthening Community Safety Bill 2023

QNADA’s member services work at the intersection of multiple different systems and provide support to young people and their families who are in contact with, or are at risk of having contact with, the youth justice system. This makes us uniquely positioned to comment on the proposed amendments, which are:

• contradictory to what we know works when responding to youth crime;
• out of step with other Australian jurisdictions; and
• inconsistent with recent commitments by the Queensland Government to reduce demand within the criminal justice system, address the overrepresentation of First Nations people within the youth justice and criminal justice systems and achieve health equity by 2030.

For these reasons, QNADA does not support this Bill, including the supposition that its incompatibility with the Human Rights Act 2019 and international standards is justified ‘to respond to the small cohort of serious repeat young offenders who engage in persistent and serious offending, in particular, offending which occurs while on bail.’ The amendments will have significant implications for all young people on bail and, as with other strategies that aim to increase police presence and enforcement, will only serve to increase the number of young people detected, arrested and incarcerated in Queensland.

Please read the full submission here.

Submission to the Police Powers and Responsibilities and Other Legislation Amendment Bill 2023

QNADA welcomes the opportunity to provide feedback on the Police Powers and Responsibilities and Other Legislation Amendment Bill 2023, and recognises the proposed expansion of the Police Drug Diversion Program (PDDP) as an important step toward reducing the potential for harms associated with AOD use in Queensland. This submission focuses on:

• the significant individual, social and economic harms caused by the criminalisation of people who use drugs;
• shortcomings in the operation of the current PDDP to effectively divert people who use drugs who would otherwise not come to the attention of police away from the criminal justice system;
  the importance of practice change within the Queensland Police Service (QPS) that takes into account the experiences of people who use drugs and their interactions with police, and seeks to address the impact of stigma and discrimination embedded in policing practices;
• issues with the Bill, including with respect to the potential for inequity in the response to children and young people;
• opportunities to learn from the implementation challenges identified with the current approach to improve quality assurance processes and establish a strong, independent monitoring and evaluation framework; and
• other opportunities to further reduce the harms associated with the current policy approach to drug use, including the increasing shift towards decriminalisation across multiple jurisdictions.

Please click here to read the full submission.

Please feel free to watch our appearance at the the public hearing for the Inquiry into Police Powers and Responsibilities and Other Legislation Amendment Bill 2023 here (QNADA appeared from 5:09:45).

Submission to the Queensland Women’s Health Strategy Consultation Paper

QNADA welcomes the opportunity to provide feedback on the Queensland Women’s Health Strategy Consultation Paper. We commend the intent of the development of the Queensland Women’s Health Strategy and recognise the importance of working to achieve gender equality and health equity in Queensland by advancing the rights and interests of women and girls, including those who use alcohol and other drugs (AOD).

While the majority of people who use AOD do not experience problems with their use, a proportion (11-12%) are likely to require specialist treatment. In Australia, women represent approximately 40% of the proportion of people accessing AOD treatment services. They continue to face a range of treatment access barriers due to issues such as:

• continuing treatment and harm reduction supply issues in the face of increasing demand
• fear of legal and social repercussions of service engagement
• employment and family responsibilities
• implications relating to parenting, pregnancy, and childbirth (e.g. potential for child protection involvement resulting reduced willingness to approach services for assistance).

Despite welcome increased investment into the AOD system in recent years, as well as recognition of these barriers, women remain underrepresented in treatment and strategies are required to increase accessibility.

A range of strategies and initiatives have the potential to make it easier for women to access AOD treatment when they need it. These include:

• offering free child care to women accessing AOD treatment
• expanding existing day rehabilitation program options to enable increased treatment availability during school hours
• establishing/funding dedicated programs for women
• expansion of programs that support families to stay together while a parent is undergoing residential rehabilitation (e.g. family units)
• other initiatives to reduce stigma and discrimination of woman who use AOD.

Please click here to read the full submission.

QNADA submission to the Inquiry into Australia’s illicit drug problem: challenges and opportunities for law enforcement

Late last year QNADA developed a submission for the Commonwealth Inquiry into Australia’s illicit drug problem: challenges and opportunities for law enforcement. The submission identified 5 key areas of improvement to the existing Australian approach to illicit drug law enforcement:

1. The removal of criminal penalties for possession (decriminalisation) as a prudent strategy to reduce the investment required over time to process people through the criminal justice system and increase opportunities for people to access treatment when they need it.
2. A review of current approaches across law enforcement, treatment and harm reduction to ensure an appropriate balance across the three pillars of the National Drug Strategy in future investment.
3. Focused awareness-raising and training for police and other law enforcement entities on the impact of stigma and discrimination for people who use drugs.
4. The establishment of a new national governance framework to support effective coordination of the National Drug Strategic Framework, which includes representation from NGO AOD peak bodies.
5. A reinforced and sustained commitment by law enforcement agencies to support the implementation of evidence based harm reduction strategies such as drug checking services, safe injecting facilities, expanded diversion initiatives and improved access to naloxone.

QNADA’s submission to the Inquiry into Australia’s illicit drug problem: challenges and opportunities for law enforcement is available at https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Law_Enforcement/IllicitDrugs/Submissions

QNADA Submission to the Women’s Safety and Justice Taskforce

Response To Discussion Paper 3: Women and girls’ experiences across the criminal justice system

In April 2022 QNADA provided a submission to the third discussion paper of the Women’s Safety and Justice Taskforce – Women and girls experiences across the criminal justice system. The submission focused on specific questions within the discussion paper, and called for:

• responses that focus on addressing the broader social, cultural, and structural determinants of health, and prioritise alternatives to imprisonment – particularly for low-harm drug offences;
• greater clarity around the main drivers of increased drug related imprisonment and recidivism among women and girls, namely increased law enforcement activity by police, rather than any marked change in community behaviour or attitudes;
• meaningful, transparent consideration to be given to decriminalising low-harm drugs in Queensland, in partnership with peaks and other relevant non-government organisations;
• increased investment in, and provision of, alcohol and other drug treatment and harm reduction services for women and children in contact with the criminal justice system across Queensland;
• the expansion of police diversion to all illicit substances, including the removal of the current requirement to admit to an offence prior to accessing diversion, the removal of limits on the number of times a person can access diversion, and reconsideration of the purpose, delivery and type of interventions provided to people diverted from the criminal justice system;
• recognition that, even in the context of increased investment by the Queensland Government, there remains gaps in the treatment system and, although most people who use alcohol and other drugs never require treatment or help, for every dollar invested in treatment and harm reduction there is a seven dollar return^[1];
• people deprived of their liberty for drug related offending to be provided voluntary and evidence-based health services, including harm reduction and drug treatment services, as well as essential medicines, including HIV and Hepatitis C services, at a standard that is equivalent to that in the community in accordance with the International Guidelines on Human Rights and Drug Policy^[2].

The submission also highlights significant and ongoing concerns with the recent introduction of section 229BC of the Criminal Code (Failure to report sexual offending against a child to police) in Queensland. Although the need to ensure adults are appropriately protecting children and young people from sexual abuse is beyond question, the amendments have significant implications for the support provided by non-government AOD services to people who have experienced child sexual abuse. These implications are inherently problematic as:

• a significant proportion of those who access AOD services have complex histories of abuse and trauma (including child sexual abuse), poor experiences with police and other statutory bodies and a general distrust in services (particularly for those who use illicit drugs);
• it is key for victim-survivors to have access to services they trust and can safely to disclose to, and section 229BC inhibits disclosure for those who do not wish to engage with police – this correspondingly impacts treatment outcomes, impedes future service engagement and increases the likelihood of future harm;
• the reality is conviction rates are low and many victim-survivors do not want to engage in often confusing, invasive, lengthy and traumatic criminal justice proceedings;
• although the amendments respond to findings of the Royal Commission into Institutional Responses to Child Sexual Abuse, they are not consistent with the Royal Commission’s findings in relation to the challenges faced by victim-survivors in disclosing such abuse.

The submission calls for urgent review of the provisions, seeking to repeal the amendments or include clear exclusions to ensure Queenslanders who have experienced child sexual abuse can safely disclose that abuse in therapeutic settings and receive effective support for the well-known physical and psychological impacts of trauma.

[1] Alison Ritter et al., “New Horizons: The Review of Alcohol and Other Drug Treatment Services in Australia,” in Final Report (Sydney: University of New South Wales, 2014).

[2] https://www.undp.org/library/international-guidelines-human-rights-and-drug-policy

QNADA’s Submission to the draft National Tobacco Strategy 2022-2030

In March QNADA submitted a response to the call for feedback on the draft National Tobacco Strategy 2022-2030 (the Strategy). The QNADA submission wholly supports the priority areas for the Strategy and commends it for seeking to directly address tobacco industry interference in public health and tobacco control policy. QNADA argues this approach sets an example for other drug policy areas, such as alcohol, where industry influence and involvement continues to stifle good public health policy. QNADA agrees with the Strategy position that government action alone cannot reduce the prevalence of tobacco use, and that a strength of Australia’s tobacco control measures to date has been partnerships between governments, NGOs, health professionals, research groups and community groups. To this end, QNADA identified four areas we believe the strategy should further address. We’ve provided an abridged version of what we included in our submission below.

1. Future proof the strategy by clarifying how all priority areas and actions could be applied to new and emerging nicotine products.

While QNADA recognises the emphasis on preventing and reducing harms from new and emerging products (including e-cigarettes) in priority area 9 of the draft strategy, we believe these issues are relevant across the entire strategy and need to be outlined more widely. As novel nicotine products become more widely used and available, and the evidence around potential harm and therapeutic use continues to evolve, all priority areas and actions of the strategy will become increasingly relevant to novel products. QNADA supports strengthened regulations for new and emerging products, however we do not support legislative approaches that focus on individuals who are using these products as opposed to organisations selling and promoting them.

2. Closely monitor trends related to excise.

Excise increases have been resoundingly successful in reducing smoking prevalence at a population level. However, we note the relatively small gains excise measures have furnished in disadvantaged populations. We suggest that while price increases have been – and may continue to be – an effective mechanism to reduce tobacco use, we may be approaching a threshold, where prohibitive pricing begins pushing vulnerable populations to illicit tobacco in the absence of other nicotine replacements and support. While we acknowledge the ATO’s Tax Gap Analysis findings of a reduced net illicit tobacco market in spite of rising licit tobacco prices, we suggest targeted research be undertaken to quantify the extent of illicit tobacco use amongst disadvantaged groups and to better inform countermeasures to illicit tobacco use.

3. Prioritise support and resourcing for community controlled organisations and ensure meaningful partnerships.

We are pleased to see the strategy acknowledges the social and cultural determinants of health as influencing tobacco use and the broader importance of tobacco cessation efforts to closing the gap. We support the intent to bring culturally safe tobacco cessation interventions to mainstream health services, however resourcing and support for community controlled organisations should be a priority, and the upskilling of mainstream organisations should not be at the expense of community controlled organisations.

4. Appropriately resource organisations to deliver interventions and increase access to NRT

QNADA strongly agrees that evidence-based tobacco prevention and cessation programs should be part of routine care across all health (including AOD treatment and harm reduction services), social care and custodial settings. However, we do not support mandating tobacco interventions as a condition of government funding. In our view this makes little sense in the context of existing governance mechanisms that facilitate good clinical practice. We suggest instead working across systems to ensure that relevant frameworks, strategies, and guidelines address tobacco and other nicotine products where relevant, achievable, and necessary. Further, such an approach risks adding an unnecessary layer of reporting to already underfunded and overburdened services.

QNADA’s Submission to the Inquiry into the opportunities to improve mental health outcomes for Queenslanders

Tom Ogwang

In February QNADA submitted a response to the Mental Health Select Committee Inquiry into the opportunities to improve mental health outcomes for Queenslanders (the Inquiry). The submission addressed the Terms of Reference for the Inquiry in three distinct, but inter-related parts: Services (part A), Policy (part B) and Systems (part C). We’ve provided a very brief overview of highlights from our submission below. If you’d like to read it in full, you can download it here – https://documents.parliament.qld.gov.au/com/MHSC-1B43/IQ-5DEF/submissions/00000048.pdf.

Part A: Services

Developing a shared understanding of when and how the services system should respond to AOD related issues is key to improving AOD responses on the whole. Our shared understanding should recognise that only a small proportion of people who use AOD require treatment, however there are still insufficient specialist services available to meet demand. These challenges are compounded by critical specialist AOD workforce shortages.

Part A highlights that in order for the services system to become better coordinated or ‘integrated’, all systems of care should be informed by both AOD scientific evidence and lived experience in all aspects of program and policy development. In short, policy should be responsive to need and informed by the people it most directly affects. However, people who use drugs have traditionally been marginalised from policy debate and from receiving appropriate care.

Two case studies (Daisy’s Story and Jane’s Story) exemplify how QNADA member services and clients navigate system complexity, and how external system responses impact on client outcomes and opportunities.

Part B: Policy

The absence of a clear whole of government endorsed public AOD plan since 2017 has stifled leadership and prioritisation for AOD system reform outside the health system. It impacts agency understandings of their roles and responsibilities to deliver or support agreed state and national priorities and commitments. This absence means that there is no overarching mechanism drive action across systems such as criminal justice, domestic and family violence, youth justice, child protection, education, and communities.

Part B explores the reforms required to reduce costs and harms associated with criminalising illicit drug use. We note that the approach of criminalisation has proven largely ineffective at significantly reducing the consumption of illicit drugs and has not achieved a sustained reduction in supply. For example, the Queensland Productivity Commission’s makes a compelling economic argument for decriminalisation for low harm drugs within its 2020 Inquiry into Imprisonment and Recidivism and found that:

• Illicit drugs policy has failed to reduce supply or harm and was found to be a key contributor to rising imprisonment rates, with drug offences contributing to 32% of the increase since 2012
• Current illicit drugs policy results in significant unintended harms, through supporting a large criminal market and incentivising the introduction of more harmful drugs
• Evidence suggests legalising lower harm drugs and decriminalising others is unlikely to increase drug use and is likely to provide net benefits to Queensland of at least $2.8 billion by 2025
• Targeted community-level interventions and greater use of diversionary approaches are feasible alternatives to the criminal justice system which are significantly less expensive.

Part C: Systems

For the significant majority of people who use AOD, the risk of harm to both themselves and the community is increased primarily as a result of the social, policy and legislative responses to their use, rather than the substance itself.

Part C discusses opportunities for whole of system collaboration and partnerships across the criminal justice, child protection and youth justice systems. Queensland’s Mental Health, Alcohol and Other Drugs Strategic Plan 2018-23 (Shifting Minds) highlights the importance of collective leadership and responsibility across all policy, funding, program development and service delivery to achieve common outcomes and benefits. There is currently no entity in Queensland who has primary responsibility for, and a dedicated focus on, effectively influencing, driving and coordinating this change within the context of AOD policy and planning.

In early 2021 QNADA launched the self-funded Responsive Systems project to improve cross-agency collaboration and partnerships and support more effective system responses outside the health sector.