HoC Policy Brief Co-Signatory Form; Help Us End the Toxic Drug Crisis
Study: Opioid Epidemic and Toxic Drug Crisis in Canada.


DISCLAIMER: The content on this google form is the shortened version of the policy brief. To see the longer version, please click -------> Working Copy of the Policy Brief and Recommendations to HESA 

Our drug-policy needs progress not regress. Science Shows it's true, Safe Supply is the way through. 

Executive Summary 

Prescribed pharmaceutical programs provide several benefits to people who use drugs. [1] These programs offer a safer alternative to the toxic illicit drug supply and reduce the risk of overdose, overdose death, hospitalization, and other health-related harms [1,2]. Participants in these programs report a decrease in illicit fentanyl use, decreased criminal behaviours, decreased injection frequency, improvements in their social well-being, and improved physical and mental health [1,3]. We are urging the House of Commons to address this crisis through improving the current drug-policies to end the toxic drug crisis in Canada.  The federal government invested millions of dollars into harm reduction efforts and a number of safe supply initiatives (with very limited reach i.e a few hundred out of over 30,000 users in Canada), expecting that the toxic drug crisis will end when the root of the cause has been the prevalence of unpredictable, unregulated supply of illicit substances.

Acknowledgement

We acknowledge that our work is taking place on the unceded and traditional territories of thousands of First Nations, Metis, Inuit, and Indigenous First Peoples. 

Background

  • From January to March 2023, there were 1,904 apparent opioid toxicity deaths in Canada, averaging 21 deaths per day [4].

  • Illicit fentanyl commonly contains a combination of synthetic opioids, benzodiazepines, and adulterants such as tranquilizers in various concentration making the drug supply highly dangerous and unpredictable [4].

  • Most Prescribed alternatives to illicit opioid programs operate in British Columbia, Ontario, and New Brunswick with a growing demand in Alberta and Yukon [5].

  • Eight provinces and territories indicates that almost all (98%) apparent stimulant toxicity deaths so far in 2023 (January-June) were accidental [6]. This means that safety measures that meet the needs of stimulant users, such as prescription stimulants, are needed to prevent accidental deaths. 

  • Out of all accidental apparent opioid toxicity deaths so far in 2023 (January-June), 80% involved opioids that were only non-pharmaceutical underscoring the toxicity of the unregulated drug supply [6].

  • Marginalized populations are disproportionately impacted by this crisis, including those experiencing homelessness, poverty, and mental illness [7].

    Evidence of Prescribed Medications Taken as Prescribed with Minimal Diversion: A recent study on prescribed safer supply demonstrated an 89% reduction in overdose related death when compared to similar people with opioid use disorder but not receiving prescribed safer supply. This large reduction in overdose related death strongly suggests that the prescribed safer supply is being taken by those prescribed or such a significant reduction in overdose related deaths would not be observable. No Increase in Hydromorphone-Involved Overdoses: Data pre- and post-Safer Supply show no increase in hydromorphone-involved overdoses as would be predicted if mass diversion was occuring to the broader community (British Columbia Coroners Service. (2023). Illicit Drug Toxicity Deaths in BC: January 1, 2012 to December 31, 2022. Government of British Columbia. https://www2.gov.bc.ca/assets/gov/birth-adoption-death-marriage-and-div…) This data suggest that hydromorphone prescribed as part of Safer Supply programs is not contributing to the increase in opioid-involved toxicity deaths.  Supply-side reduction strategies only lead to more variation in the supply creating a less predictable and more dangerous illicit drug supply . Laws restricting access to specific classes of compounds (i.e. fentanyls) and their starting materials encourages drug producers to explore an alternative class of compounds (i.e. nitazenes) that utilize different starting materials not monitored by law enforcement. The new class of compounds are then introduced into the illicit drug supply with consumers having no knowledge of the new class of compounds, their potency, or their effects which lead to an increase in overdose as was the case with the introduction of fentanyl into the heroin supply around 2015.

Recommendations

  1. Amend section 56 of the CDSA to include a non-medicalized approach such as Compassion Clubs, defined as;  a cooperative (or “co-op”), as an autonomous and democratic enterprise owned and operated by its members who share its benefits as they work towards mutually set goals.

  2. Invest in meaningful engagement with the People with Lived/Living Experience (PWLLE) in Prescribed Pharmaceutical Treatment programs to optimize implementation and effectiveness.

  3. Standardize procedure for the operation of Indoor Safe-Inhalation Spaces 

  4. Increasing the National capacity for the Individualized Treatment Options: Considering that there are 9% of the Canadian population engaging in problematic use of opioids, which makes up about 350,000 Canadians, the capacity for individualized treatment must at least be able to accommodate 100,000 Canadians. Furthermore, increasing the take home doses to improve treatment retention .

  5. Access to proven treatment methods should be seamlessly integrated at any point of contact in the healthcare system.

  6. Amendment to the Narcotic Control Regulations - C.R.C., c. 1041 (Section 65)  to include Diacetylmorphine; “On receipt of a written order or prescription signed and dated by a practitioner, the person in charge of a hospital may permit a narcotic, including diacetylmorphine (heroin), to be administered to a person under treatment as an in-patient or out-patient of the hospital, or to be sold or provided for the person”. 

  7.  Amendment to Section 24(1) of the Narcotic Control Regulations to allow for safe pharmaceutical supply provision of narcotics including inhalable and injectable diacetylmorphine (heroin) from the licensed dealer to individuals at risk of death from toxic illegal drugs and to the designated Safe Consumption Sites (SCS).

  8. Amendment to the Narcotic Control Regulations - C.R.C., c. 1041 (Section 31) to add a subsection for Diacetylmorphine (Heroin); A pharmacist may sell or provide Diacetylmorphine, including inhalable options,  to the following persons, in addition to the persons referred to in subsection (2).

  9. Increase options in treatment models for Canadians; whether the goal is for abstinence or harm reduction.

  10. Offer pharmaceutical options such as amphetamines, their salts, derivatives, isomers and analogues and salts of derivatives, isomers and analogues.

  11. Enact Recommendations from Health Canada Expert Task Force on Substance Use Immediately: The Expert Task Force unanimously recommended an end to criminal penalties for simple drug possession (decriminalization) and support the creation of a legal framework for the regulation of drugs (legalization) to reduce deaths from the illicit, unregulated drug supply.

  12. Addressing Conflicts of Interest: Require all persons testifying on PATDS and drug policy to declare all potential or perceived financial conflicts of interest. Many opponents of PATDS own, in part or in full, urine drug screening companies, abstinence-based addiction treatment centers, rapid access addiction medicine (RAAM) clinics (i.e. methadone and buprenorphine), pharmacies, etc. that may financially benefit by restricting access to PATDS and a regulated market.

References and Suggested Readings

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