ATODA Submission to the ACT Budget Consultation 2011 – 2012 Excerpt Attachment B: Needle and Syringe Program Trial in the Alexander Maconochie Centre B1. Proposal To prevent and reduce the transmission of blood-borne viruses (e.g. HIV/AIDS, hepatitis C and B), improve the safety of staff, and improve the health of prisoners by conducting a trial, which includes a feasibility study, of a needle and syringe program (NSP) in the Alexander Maconochie Centre (AMC). B2. Background and Rationale Over 80% of all newly acquired hepatitis C infections in Australia and the vast majority in most Western countries are associated with injecting (illicit) drug use.i Sharing injecting equipment is the primary manner in which blood-borne viruses (e.g. HIV/AIDS, hepatitis C and B) are spread in this population. NSPs are one of the major components of Australia’s approach to reducing the spread to blood-borne viral infections among injecting drug users. Each case of hepatitis C infection, a blood-borne virus, costs the Australian community and health services between $798 and $18,835 per year.ii NSPs in the ACT have been cost-effective at preventing the spread of blood-borne viruses, including hepatitis C.iii However, the substantial savings from NSPs in the community are being eroded by transmission of hepatitis C among a confined and identifiable population (i.e. prisoners). The 2007 Australian prison entrants blood-borne virus survey found that 35% of 740 consecutive prison entrants were HCV antibody positive, compared with 0.2% in the general Australian population.iv Prisoners have high rates of hepatitis C upon entry into prison.v For most, this has resulted from unsafe injecting practices. Injecting drug use occurs in Australian prisonsvi and continued injecting behaviours and the sharing of injecting equipment causes the transmission of hepatitis C among prisoners who continue to inject in prisonvii. NSPs reduce the rate of transmission of hepatitis C and other blood-borne viruses in this population.viii Prison staff safety is essential. The risk of punishment for possessing injecting equipment means that prisoners attempt to hide used syringes which places staff at risk of needle-stick injuries and contracting blood-borne viruses.ix The prohibition of injecting equipment also means that prisoners who do inject are at a greatly elevated risk of negative health outcomes. Syringes are often used many times, increasing the likelihood of blood-borne virus transmission among prisoners, and making a substantial contribution to the spread of blood-borne viruses throughout the ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 1 community. The very fact that substantial numbers of prisoners continue to inject in prison demonstrates that appropriate treatment and support is not reaching many prisoners who need it most.x This population should be targeted for interventions which reduce the risk of bloodborne virus infection. Prisoners who may contract hepatitis C in prison are generally released into the community within a relatively short period of time; such prisoners become a substantial contributor to the spread of hepatitis C in the ACT community. The overwhelming evidence indicates that incorporating NSPs into prisons is safe and effective in reducing the risk of blood-borne virus transmission among prisoners, staff and the community.xi B3. Aim and Objectives The primary aim is to reduce and prevent the transmission of blood-borne viruses and enhance the safety of staff through trialing an NSP that will make sterile injecting equipment available to prisoners. The objectives include: 1. To reduce blood-borne virus transmissions among prisoners, and as a consequence, the wider ACT community; 2. To improve the safety of staff by reducing the risk of needle-stick injuries and the contraction of blood-borne viral infections; 3. To improve prisoners’ engagement with health services to improve the rates of appropriate alcohol, tobacco and other drug (ATOD) treatment among substance misusing prisoners; 4. To reduce the social and economic costs of blood-borne viruses on prisoners, prison health services, community health services, and the general community; 5. To enhance the AMC’s human rights compliance; and, 6. To reduce the exposure of the ACT Government to litigation for failing to exercise its duty of care towards prisoners. The trial will determine the feasibility of introducing and operating an NSP in the AMC and will evaluate its outcomes. B4. Priority populations B4.1 Prisoners who inject drugs More than half of Australia’s prison entrants have a history of injecting drug usexii and nearly one-third test positive for the hepatitis C antibody.xiii Many of these prisoners will continue to inject in prison.xiv Data from NSW has found that 43% of females and 24% of males had injected drugs whilst in prison. Of those, 72% of females and 67% of males had reused the needle and syringe after someone else.xv Because the AMC is a relatively new facility, there is limited publicly available data on rates of blood-borne viral infections, injecting drug use, or the sharing of injecting equipment among inmates. However, and despite substantial efforts on the part of AMC staff; drugs and injecting equipment have been found in the AMC. The Chief Minister has said: “I would accept, on the information that is available and on the knowledge that we have, illicit substances are still finding their way into Alexander Maconochie despite ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 2 our best efforts and there is access through whatever illegal means to contraband within AMC.”xvi Injecting drug use occurs in the AMC. Consequently, prisoners are almost certainly sharing injecting equipment. There has already been one documented case of a prisoner contracting hepatitis C during their imprisonment at the AMC. The Minister for Health has confirmed that a detainee contracted hepatitis C while in the AMC, less than one year after its opening.xvii The first ACT Inmate Health Survey has been conducted (report yet to be released); and the Burnet Institute, commissioned by the ACT Government, is currently reporting on an Evaluation of Drug Policies and Services within the AMC. These reports will provide further information as to the current situation. B4.2 Aboriginal and Torres Strait Islander Injecting Drug Users The over-representation of Aboriginal and Torres Strait Islander people in Australia’s prisons is partly due to the high rates of alcohol and other drug misuse in these communities. Consequently, injecting drug use in prison may be major contributor to growing rates of hepatitis C infection among this population. xviii Aboriginal and Torres Strait Islander prisoners are more likely to have hepatitis C before entering prison than other prisoners and are also more likely to inject drugs in prison than other prisoners.xix Consequently, preventing the transmission of bloodborne viral infections in prisons may have a substantial impact upon improving the health of Aboriginal and Torres Strait Islander people. B5. Evidence of Effectiveness and Safety The arguments for introducing a NSP into the AMC are many and widely accepted by international and domestic bodies, health professionals, and the ACT Government. The overwhelming evidence indicates that incorporating NSPs into prisons is safe and effective in reducing the risk of blood-borne virus transmission among prisoners, staff and the community.xx Prison NSPs are cost-effective, safe, and endorsed by international and domestic bodies. They have been introduced in 12 countries, where they have been the subject of extensive evaluation. The results demonstrate that prison NSPs can: Reduce rates of needle stick injuries among corrections staff and reduce the likelihood of contracting a blood-borne virus among those who do sustain a needle-stick injury; Reduce the rate of blood-borne viral transmission among prisoners who inject drugs in prisons; and, Improve the uptake of appropriate treatment among people who inject drugs in prisons. xxi,xxii,xxiii,xxiv,xxv The ACT Minister for Health has stated: “From a health point of view, it is a no-brainer; you have a Needle and Syringe Program in the jail as soon as you can.”xxvi Prison staff’s attitudes to NSPs in prisons have been generally positive once they have been implemented. In a 2004 review of NSPs in European countries, the World Health Organization found that not a single case of syringes being used as weapons ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 3 by inmates had been reported.xxvii In Australia, there has been only one reported case, in 1990, in which a prison officer was assaulted with a syringe. However this occurred when there were no NSP facilities available in the prison. Evaluations of Needle and Syringe Programs in overseas prisons have shown that they do not increase drug consumption or injecting and they effectively reduce needle sharing.xxviii Additionally, there have been no documented cases of adverse events from NSPs in prisons anywhere in the world, making NSPs in prisons a safe health intervention. B6. Safety guarding the community from blood-borne virus infection The National Drug and Alcohol Research Centre’s technical report 112 reviewing international research and program development for prison-based syringe exchange programs concludes the following:xxix “The rationale for establishing syringe exchange programs in prisons is even stronger than in communities. This rationale is accepted by an impressive number of prestigious bodies… Because of the rapid turnover of inmate populations, spread of blood borne viral infections among prisoners cannot be considered to remain for long within the confines of correctional facilities. There is increasing evidence that experience of incarceration is a strong predictor of HIV and hepatitis C infection.” The authors elaborate: “The failure to reduce the risk of hepatitis C and other blood borne viral infection transmission in prisons severely undermines the work being conducted in the community with injecting drug users.” B7. Improve the uptake of ATOD health services by prisoners Prison drug treatments are effective in reducing substance misuse and their associate risk behaviours.xxx However, for these treatments to be effective, prisoners in need must first access these services. Alcohol, tobacco and other drug (ATOD) assessments of prisoners cannot guarantee that prisoners with ATOD issues are identified and appropriately treated.xxxi Additionally, the risk of punishment for engaging in drug use in prison, or possessing injecting equipment, ensures that some prisoners will intentionally avoid contact with needed AOD treatment services. Consequently, there is a need to promote engagement with health services among prisoners with problematic AOD issues. NSPs in the community are a primary point of contact between injecting drug users and AOD treatment services. This can also be the case in custodial settings,xxxii so long as this effort does not act as a barrier to prisoners accessing the NSP. B8. Enhancing the Human Rights Compliance of the AMC Developing a human rights culture in the ACT is a progressive process which builds upon the Territory’s previous success. The AMC is a unique opportunity to develop a truly human rights compliant prison. Currently, prisoners are not afforded the same standard of healthcare made available to them in the general community. Dr Helen Watchirs, ACT Human Rights Commissioner, suggests: “To deny protection against disease transmission in such a high-prevalence and closed population in prison may be viewed as inhumane.” xxxiii The ACT Human Rights Commission conducted two audits of the operation of the ACT’s corrections facilities in 2006 and 2007. One of the Commission’s recommendations was for a trial of an NSP, which was based on a prisoner's right to ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 4 life, which includes protection from infectious diseases, as well as the right to the highest attainable standard of health.xxxivxxxv B9. Support for a NSP in the AMC A range of international bodies with responsibility for developing an international response to drugs and blood-borne virus transmission have indicated strong support for prison NSPs as one of many methods to reduce the spread of hepatitis and HIV/AIDS in prisons. These include the United National Office on Drugs and Crime,xxxvi the World Health Organization, and the Joint United Nations Programme on HIV/AIDS.xxxvii The Australian National Council on Drugs (ANCD), the primary advisory council to the Australian Government, appointed by the Prime Minister, has recommended: “That each jurisdictional department responsible for the management of prisons and juvenile detention centres, in consultation with staff, health authorities and relevant community-based organisations, develop occupationally safe and culturally appropriate policies, protocols and procedures regarding the introduction of trial needle and syringe programs within at least one of its prisons and juvenile detention centres.”xxxviii The National Hepatitis C Strategy 2010-2013 states: “In view of the well documented return on investment and effectiveness of Australian community-based needle and syringe program, combined with the international evidence demonstrating the effectiveness of prison needle and syringe programs it is appropriate throughout the life of this strategy for State and Territory governments to identify opportunities for trialing the intervention in Australian custodial settings.” xxxix The ACT Human Rights Commission has recommended that: "[a] pilot program for a needle and syringe exchange with provision for safe disposal of needles should be developed for the Alexander Maconochie Centre…" xl The ACT Chief Minister’s and the ACT Minister for Health’s comments, quoted above, further strengthen this support. Adding to that, the Attorney General has stated, "What we want to do is stop the spread of disease that comes from sharing needles.”xli The ACT Greens have called for the establishment of an NSP, developed a discussion paper and a consultation summary.xlii Anex, an national leader in public health, has also recently released a paper supporting NSPs in prisons.xliii B10. Policy Context Trialing a NSP in the AMC is: Consistent with the principles of the ACT Adult Corrections Health Services Plan 2007 – 2010; Consistent with initiatives being undertaken through the Alexander Maconochie Centre including the evaluation of drug polices and services; A recommendation from the ACT Human Rights Commission’s Human Rights Audit on the Operation of Correctional Facilities under Corrections Legislation; and the ACT Legislative Assembly’s Standing Committee on Health report 2003; ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 5 B11. Consistent with and progresses Actions 19, 20, 29, 30, 57 from the ACT Alcohol, Tobacco and Other Drug Strategy 2010 – 2014; Consistent with and progresses Action 26 from the A New Way: The ACT Aboriginal and Torres Strait Islander Health and Family Wellbeing Plan 2006 – 2011; and the recommendations from the Winnunga Nimmityjah Aboriginal Health Service report You do the Crime, You do the Time; xliv Part of a broader NSP program which is supported by the National Drugs Strategy, the National HIV/AIDS Strategy and the National Hepatitis C Strategy as part of a harm minimisation framework that is based on the three pillars of supply reduction, demand reduction and harm reduction. Issues for Consideration B11.1 Addressing the concerns of some staff Corrections Officers, their representatives, and ACT Corrective Services have concerns over the introduction of a trial NSP into the AMC. Their concerns to date have focused on issues of occupational health and safety (OH&S) for staff - the risk of needle-stick injuries and injecting equipment being used as weapons. The evidence states that: “International experience has shown that regulated prison NSPs do contribute to institutional safety, and that they do not result in syringes being used as weapons. The introduction of prison-regulated and controlled NSPs would be consistent with efforts to comply with OHS principles, as well as the approved standards for corrections in Australia.”xlv The ACT Minister for Health has said: “From a corrections staff point of view—I have said this in these forums a number of times—it is more complex than that. Corrections staff have mixed and strongly held views around the commencement of a Needle and Syringe Program. It would be a brave new step. We would be the first jail in the country to head this way—not the first jail in the world but the first jail in the country.”xlvi Appropriate education and training to staff complemented by appropriate amendment to OH&S policies and practices will need to form part of a trial NSP. However, to maximise the potential benefits of a trial NSP, it will be necessary to have the support of staff. ATODA believes that engagement by staff with the issues, evidence, and experiences of colleagues from prisons in which NSPs have been introduced will help to facilitate a change in mindset from one of opposition to one of engagement. Opportunities for key staff and representatives to investigate, first hand, the experiences of overseas prisons in which NSPs have been introduced should be considered. Additionally, all staff at the AMC would benefit from hearing the experiences of colleagues from overseas about the introduction of a NSP in their prison. Extensive consultation with staff will need to be undertaken before, during, and after the introduction of a NSP. Incorporating staff into the implementation and evaluation process may help to develop a sense among staff of ownership over the trial. B11.2 Legislative Issuesxlvii ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 6 New legislation would need to be enacted by the ACT Legislative Assembly to allow a trial of the NSP to be implemented. There is nothing unusual about this. For example the ACT Public Health Act 1997 includes Part 3A: ‘Supply of Syringes’, authorising the Chief Health Officer to approve designated people to supply syringes for purposes of ‘preventing the spread of disease’ (s. 66C) (McDonald 1989) and this approval could be extended to people working in correctional centres. Most, if not all Australian States and Territories, have removed the offence of possession of syringes for the purpose of self-administration of an illegal drug as a public health measure (Norberry 1997). In 2004, the Legislative Assembly passed the Drugs of Dependence (Syringe Vending Machines) Amendment Act to authorise a trial of syringe vending machines in Canberra. These are all examples of legislative changes made to facilitate access to sterile injecting equipment as a public health measure. Acts and/or regulations covering the operation of the Alexander Maconochie Centre (such as the Corrections Management Act) could also be amended to remove any barriers to the NSP, such as current offences relating to the possession and use of syringes. Other existing offences related to drugs would remain in force, including possession, cultivation, manufacture and supply. This mirrors the position in the Canberra community, where all these behaviours are criminal offences that coincide with an extensive community-based NSP without substantial conflict. B12. Design and Evaluation While it is premature to draw attention to any preferred model, the particular approach used in implementing a prison NSP should be sensitive to context, taking into account the local needs and opportunities of the AMC – including allowing sufficient time for program development and for trust building amongst stakeholders. The approach taken will depend, in part, on the objectives of the program and how health staff interact with the drug-using inmates. Overall, however, across the more than 50 prison NSPs currently operating, some for over a decade, five broad models have been described (Stöver & Nelles 2003). They are: 1. 2. 3. 4. 5. Syringe dispensing machines; Hand-to-hand provision of injecting equipment by corrections health staff; Hand-to-hand provision by the staff of external drug sector agencies; Distribution by peer leaders/educators; and, Various combinations of these.xlviii The trial would include a feasibility study, which would determine the strengths and limitations to the models available and determine the best way forward given the complex context of the AMC. The program will include a comprehensive evaluation, which will contribute to the evidence base both within the ACT, nationally and internationally. B13. Funding Estimates Preliminary estimates are that the implementation of the trial would cost $200,000. This would include: 1. Feasibility research including detailed consultation with all the key stakeholders; 2. Trial implementation; and, 3. Trial evaluation. ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 7 The recurrent costs of an NSP in the AMC would be significantly less. Due to the national interest of the initiative, additional funding may be able to be identified to contribute to the costs of the trial. i Awofeso N. (2009) Updating the hepatitis C infection risk reduction hierarchy in prison settings. Australasian Journal of Correctional Staff Development. Volume 4, No 1-4 ii Return on Investment 2: DoHA (2009) available online at: http://www.nchecr.unsw.edu.au/NCHECRweb.nsf/resources/Reports/$file/RO-2ReportLQ.pdf iii National Centre in HIV Epidemiology and Clinical Research (2009) Return on investment 2: evaluating the cost-effectiveness of needle and syringe programs in Australia, National Centre in HIV Epidemiology and Clinical Research, The University of New South Wales, Sydney. iv Butler T, Papanastisiou C. (2008) National prison entrants’ blood borne virus and risk behaviour survey report 2004 & 2007. NDRI, Curtin University and NCHECR, University of New South Wales. v Butler T, Milner L (2003) The 2001 New South Wales Inmate Health Survey, Corrections Health Service, Sydney. vi Butler T, Milner L (2003) The 2001 New South Wales Inmate Health Survey, Corrections Health Service, Sydney. vii Dolan K, Teutsch S, Scheuer N, Levy M, Rawlinson W, Kaldor J, Lloyd A, Haber P. (2010) Incidence and risk for acute hepatitis C infection during imprisonment in Australia. European Journal of Epidemiology 25(2): pp. 143-148. viii Dolan K, Larney S, Jacka B, Rawlinson W. (2009) Presence of hepatitis C virus in syringes confiscated in prisons in Australia. Journal of Gastroenterology and Hepatology 24(10); pp. 1655-1657. ix Ryan J, Voon D, Kirwan A, Levy M, Sutton. (2010) Prisons, needles and OHS. Journal of Health Safety and Environment. 2010;26(1): pp. 63-72. x Butler T, Milner, L (2003) The 2001 New South Wales Inmate Health Survey, Corrections Health Service, Sydney. xi Lines R, Jürgens R, Betteridge G, Stöver H, Laticevschi D, Nelles, J (2006) Prison needle exchange: lessons from a comprehensive review of international evidence and experience, 2nd edn, Canadian HIV/AIDS Legal Network, Montréal, Québec. xii Australian Institute of Health & Welfare (2010) The health of Australia's prisoners 2009, AIHW cat. no. PHE 123, Australian Institute of Health & Welfare, Canberra. xiii NPEBBV_RBS 2007 xiv Loxley W, Carruthers S, Bevan J. (1995) In the same vein: First report of the Australian study of HIV and injecting drug use. Perth: Curtin University of Technology. Cited in Mogg D, Levy, M (2007) Moving beyond non-engagement on regulated needle-syringe exchange programs in Australian prisons. Harm Reduction Journal. 2009; 6: p. 7. xv Butler T, Milner L. (2003) The 2001 New South Wales Inmate Health Survey. Sydney. Cited in Mogg D, Levy, M (2007) Moving beyond non-engagement on regulated needle-syringe exchange programs in Australian prisons. Harm Reduction Journal. 2009; 6: p. 7. xvi The Canberra Times (16 September 2010) p. 1 xvii Legislative Assembly for the ACT (18 May 2010) Select Committee on Estimates 2010 – 2011, Canberra. Available online at: http://www.hansard.act.gov.au/hansard/2009/comms/estimates16.pdf xviii National Indigenous Drug and Alcohol Committee (2009) Bridges and Barriers: Addressing Indigenous Incarceration and Health. Canberra: Australian National Council on Drugs. xix Australian Institute of Health & Welfare (2010) The health of Australia's prisoners 2009, AIHW cat. no. PHE 123, Australian Institute of Health & Welfare, Canberra. xx Lines R et al. (2005) Taking action to reduce injecting drug-related harms in prisons: The evidence of effectiveness of prison needle exchange in six countries. International Journal of Prisoner Health 1(1): pp. 49-64. xxi Dolan K, Rutter S, Wodak, A.D. (2003) Prison-based syringe exchange programmes: a review of international research and development, Addiction, vol. 98, no. 2, pp. 153-8. xxii Lines R, Jürgens R, Betteridge G, Stöver H, Laticevschi D, Nelles, J (2004) Prison needle exchange: lessons from a comprehensive review of international evidence and experience, Canadian HIV/AIDS Legal Network, Montréal, Québec. xxiii Niveau, G (2005) Prevention of infectious disease transmission in correctional settings: A review, Public Health. xxiv Stöver H, Nelles J (2003) Ten years of experience with needle and syringe exchange programmes in European prisons, International Journal of Drug Policy, vol. 14, no. 5-6, pp. 437-44. xxv Rutter S, Dolan K, Wodak A, Heilpern H (2001) Prison-based syringe exchange programs: a review of international research and program development, NDARC technical report no. 112, National Drug & Alcohol Research Centre, Sydney, NSW. xxvi Legislative Assembly for the ACT (18 May 2010) Select Committee on Estimates 2010 – 2011, Canberra. Available online at: http://www.hansard.act.gov.au/hansard/2009/comms/estimates16.pdf ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 8 xxvii Lines R, Jürgens R, Betteridge G, Stöver H, Laticevschi D, Nelles, J (2004) Prison needle exchange: lessons from a comprehensive review of international evidence and experience, Canadian HIV/AIDS Legal Network, Montréal, Québec. xxviii I. van Beek (2004) In the Eye of the Needle: Diary of a Medically Supervised Injecting Centre. xxix Rutter S, Dolan K, Wodak A, Heilpern, H (2001) Prison-based syringe exchange programs: a review of international research and program development, NDARC technical report no. 112, National Drug & Alcohol Research Centre, Sydney, NSW. xxx Hall W, Lucke, J (2010) Legally coerced treatment for drug using offenders: ethical and policy issues, Crime and Justice Bulletin no. 144, NSW Bureau of Crime Statistics and Research, Sydney. xxxi Butler T, Milner L (2003) The 2001 New South Wales Inmate Health Survey, Corrections Health Service, Sydney. xxxii Lines R, Jürgens R, Betteridge G, Stöver H (2005) Taking action to reduce injecting drug-related harms in prisons: the evidence of effectiveness of prison needle exchange in six countries, International Journal of Prisoner Health, vol. 1, no. 1, pp. 49-64. xxxiii Speech by Dr Helen Watchirs (5 September 2009) Human Rights for Prisoners – the ACT Experience, ACT Human Rights & Discrimination Commissioner. NSW State Library, Sydney. Available online at: http://www.hrc.act.gov.au/content.php/content.view/id/194. xxxiv ACT Human Rights Commission (2007) Human Rights Audit on the Operation of Correctional Facilities under Corrections Legislation. Canberra. xxxv Mogg D, Levy, M (2007) Moving beyond non-engagement on regulated needle-syringe exchange programs in Australian prisons. Harm Reduction Journal. 2009; 6: p. 7. xxxvi United Nations Office on Drugs and Crime (2008) HIV and AIDS in places of detention: a toolkit for policymakers, programme managers, prison officers and health care providers in prison settings, United Nations Office on Drugs and Crime, Vienna. xxxvii World Health Organization, United Nations Office on Drugs and Crime & Joint United Nations Programme on HIV/AIDS (2007) Interventions to address HIV in prisons: needle and syringe programmes and decontamination strategies, World Health Organization, Geneva. xxxviii Australian National Council on Drugs (2002) Needle and syringe programs. ANCD Position Paper. ANCD, Canberra. Available online at: http://www.ancd.org.au/images/PDF/Positionpapers/pp_needle_syringe.pdf xxxix Department of Health & Ageing (2010) Third National Hepatitis C Strategy: 2010-2013, Australian Government Department of Health & Ageing, Canberra. xl ACT Human Rights Commission (2007) Human Rights Audit on the Operation of Correctional Facilities under Corrections Legislation. Canberra. xli Mogg D, Levy M (2007) Moving beyond non-engagement on regulated needle-syringe exchange programs in Australian prisons. Harm Reduction Journal. 2009; 6: p. 7. xlii For further details see: http://act.greens.org.au/issues-2 xliii Anex (2010) With conviction: the case for controlled needle and syringe programs in Australian prisons. Available online at: http://www.anex.org.au/downloads/HMPC%20Paper%20on%20NSP%20in%20Prison%20%20October%202010.pdf xliv Poroch N (2007) You do the crime, you do the time: Best practice model of holistic health services delivery for Aboriginal and Torres Strait Islander inmates in the ACT prison. Winnunga Nimmityjah Aboriginal Health Service, Narrabundah, ACT. xlv Ryan J, Voon D, Kirwan A, Levy M, Sutton. (2010) Prisons, needles and OHS. Journal of Health Safety and Environment. 2010;26(1): pp. 63-72. xlvi Legislative Assembly for the ACT (18 May 2010) Select Committee on Estimates 2010 – 2011, Canberra. Available online at: http://www.hansard.act.gov.au/hansard/2009/comms/estimates16.pdf xlvii This section is an excerpt from McDonald, D. (2005) The Proposed Needle and Syringe Program at the Alexander Maconochie Centre, Canberra’s New Prison – An information paper on the evidence underlying the proposal. Canberra. xlviii This section is an excerpt from McDonald, D. (2005) The Proposed Needle and Syringe Program at the Alexander Maconochie Centre, Canberra’s New Prison – An information paper on the evidence underlying the proposal. Canberra. ATODA Submission to the ACT Budget Consultation 2011 – 2012 December 2010 9