Dear Minister Elliott:
We write to you as organizations concerned about the health and welfare of some of the most vulnerable Ontarians, in response to the October 22 announcement that your government plans to replace supervised consumption sites (SCS) and low-barrier overdose prevention sites (OPS) with “Consumption and Treatment Services.”1
While we welcome the stated commitment to maintain existing SCS and OPS in Ontario, we are deeply concerned that your government’s new approach to supervised consumption services is creating more barriers instead of facilitating the rapid-scale up of a diversity of much-needed supervised consumption services across the province. This is especially troubling in the context of the public health crisis in which we now find ourselves.
In particular, we are concerned by the decision to impose one “Consumption and Treatment Services” model on service providers and essentially terminate low-threshold, flexible OPS. These life-saving services are part of a continuum of service models that should be made available to all people who use drugs who need them, including the most marginalized. Thousands of overdoses have been reversed using this model, and no deaths recorded at these sites.
As you know, OPS were created in response to the urgent need for rapid roll-out of these vital services. A specific legal regime under a federal class exemption issued to Ontario was put in place to allow for their rapid implementation in response to the current crisis. The requirement for both OPS and SCS, including already authorized ones, to undergo a new application process for funding is sapping concerted efforts from the federal and provincial governments to respond to the overdose crisis. Not only does the new application process replicate the onerous federal exemption process for SCS (such as requiring applicants to engage in ongoing community consultations), it will also impose additional requirements including requiring applicants to provide treatment and rehabilitation services and to conduct seemingly more extensive data reporting, monitoring and evaluations — all without dedicating additional funding to allow organizations to adequately comply. Moreover, the requirement for service providers to provide treatment and rehabilitation services is not in line with harm reduction values of meeting people where they are.
At the same time, the arbitrary decision to cap the number of sites at 21 without any justification means people who do not reside near existing or impending sites will be denied access to life-saving care, at a time when overdose deaths in Ontario are at an all-time high, with more than three people dying every day in 2017.2 Denying funding to new sites will undoubtedly mean more preventable overdose deaths and new HIV, hepatitis C and other infections.
We agree that there are inadequate drug treatment, mental health services and supportive housing options available for people who use drugs, and providing greater support for these services is laudable. But this should not come at the expense of life-saving supervised consumption services, including low-threshold services that are varied, responsive and meet the needs of their communities. We urge you to reconsider the decision to create new hurdles for service providers to receive funding to provide supervised consumption services and to limit the number of sites to 21. We call on you to work with people who use drugs, community organizations and other health service providers to ensure greater, equitable access to SCS and OPS for the people of Ontario. Lives are at stake.
Richard Elliott, Executive Director, Canadian HIV/AIDS Legal Network
Ryan Peck, Executive Director, HIV & AIDS Legal Clinic Ontario
Dr. F. Gigi Osler, President, Canadian Medical Association
Michael Villeneuve, Chief Executive Officer, Canadian Nurses Association
Ian Culbert, Executive Director, Canadian Public Health Association
Sarah Ovens, Coordinator, Toronto Overdose Prevention Society
Cc. The Honourable Doug Ford, Premier of Ontario
1 Ministry of Health and Long-Term Care News Release: Ontario Government Connecting People with Addictions to Treatment and Rehabilitation, October 22, 2018, online: https://news.ontario.ca/mohltc/en/2018/10/ontario-government-connecting-people-with-addictions-to-treatment-and-rehabilitation.html.
2 Public Health Ontario, “Opioid-related morbidity and mortality in Ontario” (May 23, 2018), online: https://www.publichealthontario.ca/en/dataandanalytics/pages/opioid.aspx#/trends.
Dear Premier Ford and Minister Elliott:
We write to you as organizations concerned about the health and welfare of some of the most vulnerable Ontarians, following reports that your government plans to undertake an unnecessary review of the evidence on supervised consumption sites (SCS),1 and the even more troubling announcement that you are imposing a moratorium on the approval of new overdose prevention sites (OPS).2
All the available evidence, including substantial peer-reviewed scientific literature, demonstrates conclusively that these health services save lives and promote the health of people who use drugs. This includes opening doors to treatment. Rather than conduct an unnecessary review and delay expansion of these services, the Ontario government should work with community organizations and health providers to rapidly scale up these services. Delays mean more preventable overdose deaths and new infections of HIV, hepatitis C and other illnesses that could be averted.
Multiple reviews of the evidence have already been done, and have established that SCS and OPS:
provide a needed health service, reducing overdose deaths and the sharing of drug-injection equipment (and the associated risk of transmission of blood-borne infections);
increase access to addiction treatment and other necessary health services; and
benefit public order by reducing public injecting.3
As you know, Canada is experiencing a large-scale opioid overdose crisis. In Ontario alone, overdose deaths related to opioids increased by 45 per cent in 2017, with more than three people dying every day during that year.4 The opioid overdose epidemic has been called “the worst drug safety crisis in Canadian history.”5 HIV, hepatitis C and other infections, as well as overdose deaths, are preventable if the right measures are taken. These include increasing voluntary access to treatment for problematic drug use (where Ontario must do better), and also simultaneously scaling up evidence-based harm reduction services such as SCS and OPS.
We urge you to heed the recommendations of experts in public health, front-line clinicians, harm reduction staff, and people with lived experience of drug use. Rather than impeding access to life-saving health services, we urge you to work with community organizations and other health services providers to ensure greater, equitable access to SCS and OPS for the people of Ontario.
Aboriginal Legal Services
ACAS—Asian Community AIDS Services
Action Canada for Sexual Health and Rights
Addiction Services of Thames Valley
Addictions and Mental Health Ontario
Africans in Partnership Against AIDS
AIDS Coalition of Nova Scotia
AIDS Committee of North Bay and Area
AIDS Committee of Toronto
AIDS Committee of Windsor
AIDS Committee of York Region
AIDS Vancouver Island
Alliance for Healthier Communities
Atlantic Interdisciplinary Research Network on Hepatitis C and HIV
Black Coalition for AIDS Prevention
Breakaway Addiction Services
Butterfly (Asian and Migrant Sex Workers Support Network)
Canadian Aboriginal AIDS Network
Canadian AIDS Society
Canadian Association of Community Health Centres
Canadian HIV/AIDS Legal Network
Canadian Medical Association
Canadian Mental Health Association—Thunder Bay Branch
Canadian Nurses Association
Canadian Positive People Network
Canadian Public Health Association
Canadian Research Initiative on Substance Misuse—Prairie Node
Canadian Students for Sensible Drug Policy
Canadian Treatment Action Council
Centre for Addiction and Mental Health (CAMH)
Centre for Social Innovation
Centre on Drug Policy Evaluation
Chinese and Southeast Asian Legal Clinic
Community Legal Assistance Sarnia
Community Legal Services of Ottawa / Services juridiques communautaires d’Ottawa
Community YWCA Muskoka
Courage Co-Lab Inc.
Dr. Peter AIDS Foundation
Elgin-Oxford Legal Clinic
Four Counties Addiction Services Team
Gerstein Crisis Centre
Guelph Community Health Centre
Haliburton, Kawartha, Pine Ridge Drug Strategy
Halifax Area Network of Drug Using People (HANDUP)
Harm Reduction Nurses Association
Health Providers Against Poverty
HIV & AIDS Legal Clinic Ontario
HIV/AIDS Regional Services
HIV/AIDS Resources and Community Health
Houselink Community Homes
Housing Action Now!
Huron Perth Community Legal Clinic
Income Security Advocacy Centre (ISAC)
Injured Workers Community Legal Clinic
Inner City Health and Wellness Program
Interagency Coalition on AIDS and Development (ICAD)
Kensington-Bellwoods Community Legal Services
Lake Country Community Legal Clinic
Lakeside HOPE House
Lanark County Interval House
Legal Clinic of Guelph and Wellington County
Maggie’s Toronto Sexwork Action Project
Mission Services of Hamilton Inc.
Mississauga Community Legal Services
MODIFY: Drug Insight From Youth
Moms Stop the Harm
mumsDU - moms united and mandated to saving the lives of Drug Users
Native Youth Sexual Health Network
Neighbourhood Legal Services London & Middlesex
Nipissing Community Legal Clinic
OHIP for All
Ontario AIDS Network (OAN)
Ontario Nurses’ Association
Ontario Positive Asians (OPA+)
Overdose Prevention Ottawa
Parkdale Activity Recreation Centre
Parkdale Community Legal Services
Parkdale Queen West Community Health Centre
PHS Community Services Society
Planned Parenthood Toronto
Racial Health Equity Network
Reelout Arts Project
Regent Park Community Health Centre
Regional HIV/AIDS Connection
Registered Nurses’ Association of Ontario (RNAO)
Rideauwood Addiction and Family Services
Sandy Hill Community Health Centre
South Riverdale Community Health Centre
Stonegate Community Health Centre
Students for Sensible Drug Policy, Ryerson Chapter
Superior North Emergency Medical Service
Syme Woolner Neighbourhood and Family Centre
Tanner Steffler Foundation
The AIDS Committee of Cambridge, Kitchener, Waterloo and Area
The Children’s Aid Society of the District of Thunder Bay
The Interfaith Coalition to Fight Homelessness
The Mental Health Consumer Survivor Project for Simcoe County
Thunder Bay Catholic District School Board
Thunder Bay Drug Strategy
Timmins-Temiskaming Community Legal Clinic
Toronto Overdose Prevention Society
Toronto People With AIDS Foundation
Waterloo Region Community Legal Services
WellFort Community Health Services
West Neighbourhood House
West Toronto Community Legal Services
Women & HIV/AIDS Initiative, Ontario
YWCA Niagara Region
1 F. Merali, “PCs ‘playing politics with people’s lives’ on injection sites, drug policy expert warns,” CBC News, August 4, 2018. Available at: www.cbc.ca/news/canada/toronto/supervised-injection-sites-waiting-1.4771143.
2 K. Bueckert, “Ontario puts new overdose prevention sites approvals on hold,” CBC News, August 11, 2018. Available at: www.cbc.ca/news/canada/kitchener-waterloo/ontario-overdose-prevention-sites-approval-hold-1.4782132.
3 E.g., M. Kennedy, M. Karamouzian & T. Kerr. “Public Health and Public Order Outcomes Associated with Supervised Drug Consumption Facilities: A Systematic Review,” Current HIV/AIDS Reports, 2017; 14(5): 161-183, doi: 10.1007/s11904-017-0363-y. Available at: www.salledeconsommation.fr/_media/public-health-and-public-order-outcomes-associated-with-supervised-drug-consumption-facilities-a-systematic-review.pdf.
4 Public Health Ontario, “Opioid-related morbidity and mortality in Ontario,” May 23, 2018. Available at: www.publichealthontario.ca/en/dataandanalytics/pages/opioid.aspx#/trends.
5 Municipal Drug Strategy Coordinators’ Network of Ontario, “Opioid Epidemic: Call for Urgent Action That Can Save Lives Now,” December 9, 2015.