January 24, 2023
The Honourable Nicholas Milliken, ECA Minister of Mental Health and Addiction 132 Legislature Building 10800 - 97 Avenue Edmonton, AB T5K 2B6 | - and - | The Honourable Jason Copping Minister of Health Members of Executive Council Executive Branch 423 Legislature Building 10800 - 97 Avenue Edmonton, AB T5K 2B6 |
Dear Minister Milliken and Minister Copping:
We have serious concerns about your Narcotic Transition Services plan.
1. Health care decisions should remain between each person and their health care provider. This plan infringes on the rights of health care providers to prescribe the most appropriate treatment for each person in their care, and on the right of patients to make treatment decisions in consultation with their health care providers. We are extremely concerned that this plan sets a precedent in which the government, not the expertise residing in the regulatory colleges and its members, determines what is and is not appropriate health care.
2. This plan is not based on evidence. The plan states:
“High-potency opioid narcotics include hydromorphone, diacetylmorphine and fentanyl. They do not include buprenorphine, methadone or slow-release oral morphine.”
In Canada, all six of these drugs are classified as narcotics under CDSA Schedule I. There are no clear criteria employed to determine what is and is not labeled a “high potency opioid narcotic” in this plan. Both lists, for example, contain full opioid agonists, plant-based drugs, and synthetic or semi-synthetic drugs. Both lists contain highly potent drugs.
Medications work differently for different people. In order to provide good care, health care providers need access to all formulations of pharmaceutical-grade alternatives that might effectively replace the toxic unregulated drug supply that has led to the deaths of so many Albertans.
Danger caused by the diversion of prescribed medications is often cited as the impetus for this regressive policy change, but there is little evidence for this. Diversion, when it happens, is typically rooted in practices of mutual aid aimed at addressing unmet needs within and among communities of people who use drugs.
3. The plan states that “[n]arcotic transition services involve the use of high-potency opioid narcotics to help people with severe opioid addiction who have not been able to initiate or stabilize on conventional treatment medications.” In other words, this policy explicitly requires people who have not found conventional addiction treatment medications successful, to transition back to those same unsuccessful medications. By leaving people with no legal options that work for them, this policy will drive people back to the toxic unregulated drug supply, thus unnecessarily increasing their risk of overdose and other harms.
4. This plan infringes on the right of all Albertans to equal access to care. The requirement for witnessed dosing at one of a very few licensed Alberta Health Services clinics, likely multiple times every day, makes this life-saving care inaccessible unless someone lives very close to the clinic. Even if someone does live in a city that has a clinic, this requirement would occupy many hours of a person’s day, denying them the freedom to pursue work, school, and recreation. Additionally, limiting this witnessed dosing to oral medications alone restricts people from being able to consume their medications via injection. Medications may have different effects or may not work at all for some people when taken orally.
Imposing such a policy will push people living stable lives back into the toxic unregulated drug supply. People will die because of this policy.
We urge you to rescind this plan immediately.
List of signatories:
Individuals: | Organizations: |
Abhinav Joshi, MD, CCFP (AM) Alana Luft MD CCFP Dr. Alan Chu MD FRCPC Alex Naylor Dr. Alicia Pawluk, CCFP, dip(ISAM) Alison Kyte Amanda Andrew Amanda McClung Amy Leung, RN Andrzej Celinski Angela Adams Angela Welz Attacus Jackson, Peer Support Worker and Outreach Volunteer Azra Panjwani Barbara Fornssler PhD Becky Marval, OT Reg. NS Bev M Knouse Bill Zheng Dr. Bonnie Larson MD Brandi Abele CAPUD Brianna Milley Brooke Bianchi, RN Bryce Koch NP Caitlin Stokvis, MSW, RSW, PhD Student Campion Cottrell-Mcdermott Carissa Pozzi, RN BN Carlee Giffen, RN Carolyn Dressler Catherine Gray MD FRCPC Chelsea Luft, The FentaNIL Project Cheri Jessop Christina DiCecco Claire Bodkin MD CCFP Corey Ranger RN, BN Courtney Amoraal, RN, BScN Cristina Zaganelli NP Cynthia Lu Dalena Dang, Nurse Practitioner Daniel Bingham Danielle Christie, RN Danielle Chuang David Richard Swann MD, FRCP(C) Dawn Berg Dawn Hunt Debbie Cunningham Deborah Watson Dominique Denis-Lalonde BN RN MN Dorene Loughlin Dorothy Schell Douglas Laird Dylan de la Riviere Elaine Hyshka, PhD Elyse Wilson Emily Wagner Emmery Poppleton, B.Sc. Hons Psychology Esther Shpilman Ethan Delparte Ethan Shi Evelyn Violini Fahad Safi Genevieve Eggen, RN MN-NP Student Ginetta Salvalaggio Giselle DeVetten Hannah Zettler-Graca Heather Downes MD, CCFP, FCFP Heather Morris PhD RN Heather Sample Holly Mathias, MA J. Khangura Jack LeMaistre - Program Manager, Victoria SAFER Initiative Dr. Janelle Syring MD, CCFP Jasmine Lo, MD CCFP Jennifer Jackson, PhD RN Jennifer O Jennifer Vanderschaeghe Jenny Peters Jessie Tollestrup Jill Harnum - drug war survivor JoAnn St. John Jodi Cunningham, BSc. Pharm Jolene Mackenzie Karim Alameddine Kate Atkinson Kate Newcombe RN Kelsey Roden, MD, CCFP(AM) Kendall Baker Kim Toombs Kimberly Mitchell and Christopher Fink Kinnon Ross, RN Kira Conroy Kirsten Rea - Registered Nurse, Clinical Nurse Leader La Vonne Rideout Lana Jaster Laurie Gustafson Leah Genge, MD CCFP (AM) Leah Jones, MD, CCFP Linda Fontaine Dr. Lindsay Herriot Lindsay Snyder Lindsey Vold, RN MN PhD(c) Lisa Phillips Lisa Reinbolt, Grieving Mother Lori Bender Lori Hatfield, MSTH Member Lorna Thomas, M.Ed, Co-Founder, MomsStopTheHarm Lynn Malkin Madison Joyce, RN Marianna Balogh - an active drug user’s mother Marliss Taylor Marvin Roberts Maryellen Gibson Marysia Waraksa, Nurse Practitioner Medini Vazé MD CCFP Megan Williamson Melanie Anderson Melanie Crehan Dr. Michael Gniewek MD CCFP Michael Lee NP Mike Jackson Missy McLean, RSW, and Member and Director, Moms Stop the Harm Morgan Magnuson, RN, MPH Naiema Alam Naja Kassir Nancy Henderson RN, MScN Naomi Sirota RPN, BScPN Naomi Watt, Registered Nurse Nathaniel Le Chalifoux Nazlee Maghsoudi Nazret Russon Nick Boyce, Drug Policy Analyst Nicola Gale, BSc, BScPharm, RPh Nicole Gehring, MSc Nicole LaBrie Pamela Arenella, MD Pamela Robertson IBSW RSW Patty Wilson, Nurse Practitioner Petra Schulz Praneetha Mahindan, Nurse Practitioner Rachael Edwards RN Ran Kewel Rebecca Haines-Saah, PhD Rebecca Penn, MPH Rhonda Watt Riley Hammond, RPN Roma Schroter, Community Support Worker Ruth Kelly Ryan Herriot, MD, CCFP, dip(ISAM) Sandy Wright Shae Larson Shanell Twan Shannon Grant, MD CCFP Shaylyn Montgomery MD Shelley Dedio Dr. Sonika Kainth, MD CCFP Stan Houston Dr. Stephanie VandenBerg Sylvana Mastroianni Tanya Hornbuckle Tara Collett- Drug Checking Coordinator, AAWEAR (The Alberta Alliance Who Educate and Advocate Responsibly) Taryn Montgomery, JD, MSW, RSw Thomas Brothers, MD CISAM Tonya Evans Travis Frampton, SOS RN Tyler Paige Veronica Ruschkowski, RN Will Jackson Wol Abiamwol | Alberta Nurses Coalition for Harm Reduction (ANCHR) AVI Health And Community Services Canadian Association of People who Use Drugs Canadian Drug Policy Coalition Canadian Students for Sensible Drug Policy (CSSDP) - Edmonton Chapter Centre on Drug Policy Evaluation EACH+EVERY: Businesses for Harm Reduction The FentaNIL Project Friends of Medicare HAMSMaRT (Hamilton Social Medicine Response Team) Harm Reduction Nurses Association/L’association des infirmiers et infirmières en réduction des méfaits Krasman Centre Medicine Shoppe Pharmacy Moms Stop The Harm National Safer Supply Community of Practice Parkdale Queen West Community Health Center Somerset West Community Health Centre Substance User Network of the Atlantic Region (SUNAR) Toronto Harm Reduction Alliance Vancouver Canadian Students for Sensible Drug Policy Victoria SAFER Initiative |