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: S.Allsop@curtin.edu.au 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: 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. 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 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 and the CCI ARC Centre of Excellence for Creative Industries and Innovation. Australian Institute of Health and Welfare (2008). 2007 National Drug Strategy Household Survey: first results. . Drug Statistics Series number 20.Cat. no. PHE 98. Canberra, AIHW. Begg, S., T. Vos, et al. (2007). The Burden of Disease and Injury in Australia 2003. Canberra, Australian Institute of Health and Welfare. Collins, D. J. and H. M. Lapsley (2008). The costs of tobacco, alcohol and illicit drug abuse to Australian society in 2004/05. N. D. S. M. S. N. 64. Canberra, Australian Government Department of Health and Ageing. Lenton, S. and M. Phillips (1997). "Mobilizing public support for providing needles to drug injectors: a pilot advocacy intervention." International Journal of Drug Policy 8(2): 101-110. Loxley, W., J. W. Toumbouro, et al. (2004). The Prevention of Substance Use, Risk and Harm in Australia: A Review of the Evidence. Canberra, Australian Government Department of Health and Ageing. Siggins, I. and M.-E. Miller (2009). Evaluation and Monitoring of the National Drug Strategy 2004-2009: Final Report. Brisbane, Siggins Miller. Volume 1: Findings and recommendations. The Australian Institute for Primary Care (2007). National Drug Research Centres of Excellence Evaluation: Final Report. Melbourne, The Australian Institute for Primary Care (AIPC), La Trobe University. Gray D, Stearne A, Wilson M, Doyle MF. Indigenous-specific Alcohol and Other Drug Interventions: Continuities, Changes and Areas of Greatest Need. ANCD Research Paper 20. Canberra. Australian National Council on Drugs, Canberra. [In Press]