On July 10, the Toronto Board of Health will review a report from the City’s Medical Officer of Health Dr. David McKeown that, if adopted, could help secure the health and safety of thousands of vulnerable intravenous drug users in Toronto. Released on June 21, the Staff Report recommends that the Board of Health work with the Ontario government to create a supervised injection service (SIS) in Toronto that would operate as a provincially-funded pilot project. Using peer-reviewed research, the Report demonstrates that the use of supervised injection sites has resulted in a decreased number of drug overdoses, a decrease in HIV and Hepatitis C infections, an increase in users entering addiction and treatment programs, and a neutral impact on the level of crime in the area where the SIS is located.
While the benefits of creating an SIS in Toronto are statistically evident, the reality of creating one is frustratingly opaque. Under the current system, an SIS like Vancouver’s Insite must receive an exemption from the Federal Minister of Health in order to operate under the Controlled Drugs and Substances Act (CDSA). Insite has had a vulnerable existence since its creation in 2003. While it received a pass in 2006 and 2007, the federal government rejected their request for an exemption in 2008, forcing Insite to take the decision to the Supreme Court of Canada. In 2011, the Court unanimously decided to force the Minister of Health to grant Insite an exemption, and outlined criteria that must be considered for future decisions.
In response, the federal government set their sights on fighting the development of future supervised injection services. On June 6, Federal Health Minister Leona Aglukkaq introduced Bill C-65 The Respect for Communities Act, which would amend the CDSA to include a lengthy and complicated process for SIS exemption. Bill C-65 includes a whopping 26 requirements that must be submitted, including letters of support from the provincial health minister, minister of public safety, local police force, and municipal government; extended consultations with physicians and nurses associations and a “broad range” of community organizations; police and resume checks for all staff at the site dating back 10 years; and information on overdoses, rates of infection, and consumption of illicit substances both among drug users and the municipality as a whole, as well as additional public safety and crime data.
As Dr. McKeown notes in the Staff Report, the likelihood that an SIS would have the ability or necessary funding to access all the required information and perform each of the consultations is preposterous. Moreover, an SIS is highly unlikely to receive letters of support from every single stakeholder listed, and many of the requirements are intentionally vague; the Bill doesn’t specify, for example, which community groups need to be consulted. The most troubling requirement in Bill C-65 is the final one, which allows the Minister to demand “any other information that the Minister considers relevant to the consideration of the application” before allowing an exemption.
Based on the absurd demands outlined in Bill C-65, the Staff Report recommends that the Toronto Board of Health oppose the legislation and request a more realistic exemption process. Supervised injection services are often dismissed as too controversial, yet they have received endorsement from a broad range of supporters, including the Canadian Medical Association, the Canadian Nurses Association, the Public Health Physicians of Canada, the Registered Nurses Association of Ontario, and the Urban Public Health Network.
Toronto needs to take action on the issue of intravenous drug use. 2013 data from a Dalla Lana School of Public Health study shows that 61% of surveyed intravenous drug users in Toronto tested positive for Hepatitis C, with 6% testing positive for HIV. In another Toronto study 29% of intravenous drug users experienced an overdose within a six month period. Studies of Insite have shown that since its inception, fatal overdoses in Vancouver have dropped by 35%, and that Insite clients are 70% less likely to share needles than drug users who do not use an SIS.
In addition to the clear benefits for intravenous drug users, supervised injection services means lower costs for provinces, municipalities, and communities. A decrease in the spread of infectious diseases and drug overdoses results in lower hospital and medical costs. Decreased public use of drugs means less money spent on policing and public safety. Increased interaction between drug users and medical professionals at an SIS results in more preventative health care (which is significantly cheaper than emergency care), and the increase in the number of users voluntarily undergoing drug treatment resulting from SIS use leads to avoided future health and crime costs. The net health care savings of Insite alone are estimated at $18 million, revealing a benefit-cost ratio of 5 to 1.
The existing data on the 90-plus supervised injection services around the world clearly demonstrate their widespread benefits. By refusing to acknowledge the significant data and support for supervised injection services, the federal government is doing the public a significant disservice. This embrace of outdated war-on-drugs ideology and prioritization of a moral agenda over the health and safety of citizens is bound to have tragic consequences. Hopefully the Toronto Board of Public Health will be brave enough to follow Dr. McKeown’s Report and stand up for the creation of an SIS in Toronto.