Campaign for Supervised Consumption Services

Attention: Provincial Health Minister Terry Lake CEO Regional Health Authority Regional Health Authority Board Chair CC. Federal Health Minister Jane Philpott

Re: Public Health Emergency of Overdose: An Urgent Call to Action

The Province of is in the midst of a growing public health crisis that shows no sign of abating. BC’s rate of overdose deaths has doubled between 2010 and 2015 (rising from 4.4 per 100,000 people to 9.9 in just a few years), leaving 476 people dead in 2015. Furthermore, as the BC Ministry of Health declared in its recent press release of April 14th, 2016: “At the current rate in 2016, without additional steps to combat overdoses, B.C. could see 600 to 800 overdose deaths this year.”

We welcome the recent declaration of a public health emergency related to overdose by of BC and recent action taken by the federal government to increase access to naloxone, supervised injecting sites, and heroin assisted treatment services. These are important steps but many communities in BC are not equipped to address the urgent situation with regard to overdose, and emergency action to implement additional programs, including supervised injection services, is required

476 fatalities is a hard number to come to terms with. Harder still are the more than 10,000 non-fatal overdoses that have occurred in the Province of British Columbia during 2015. Non-fatal overdose often results in severe brain damage as a result of prolonged oxygen deprivation and can thus leave a lasting impact on the survivor, their family, and our health care system. The long-term effects are enormous.

If it were not for the actions of frontline healthcare workers, first responders, and people who use drugs themselves – on whom the impact is also considerable and mounting – the death toll would be far, far greater. On Island alone, the BC Coroners Service is investigating 19 suspected overdose deaths on the South Island and 15 on the Central Island, all of which occurred between December 1st, 2015 and March 1st, 2016. At Victoria’s primary harm reduction service, staff responded to 27 overdose incidents in 2014 and 2015 combined. In the first three months of 2016, the same staff team responded to 21 overdose incidents, nearly the combined total for the previous two years. Not one of these 48 overdoses resulted in death, thanks to the efforts of the well-trained and committed staff of this critical harm reduction service. The community of people who use drugs is the true front-line of overdose prevention, and is the source of the wisdom and knowledge employed by front-line staff. For any public health response to be effective, it must include people who use drugs meaningfully and inclusively. Further, such a response must ensure that potential service users of a supervised consumption service are integral to the functioning of such a site.

Countless studies have shown that supervised injection services (SIS) save lives and connect service users to life-saving health care options. The efficacy of SIS in saving lives is clear, documented and unassailable. In the over 90 SIS around the world there has not been a single fatality, a statistic that strikes at the heart of our current crisis. Additionally, for this crisis to be effectively addressed, we need a comprehensive approach to providing health care for people who use drugs at both the community, residential and acute care levels. We need to enhance access to opioid substitution therapy such as Suboxone and heroin assisted treatments, and other evidence based treatment modalities.

We urge the provincial and federal governments to continue in their commitment to seeing effective evidence based health policies implemented, and work with local health authorities on establishing a set of provincial standards that ensure quality and consistent care for people who use drugs throughout the province of British Columbia. In the context of a public health emergency, Health Authorities must be held to a high standard, and it is clear that access to overdose prevention interventions remain unacceptably low in some health authorities in the province of BC, which constitutes a failure of implementation. As such, it is our hope that the provincial government will set the standard for access to and coverage of essential life-saving overdose interventions to be met by all provincial health authorities, so that all residents of British Columbia can enjoy an equal and consistent standard of care.

Lastly, the Respect for Communities Act (formerly Bill C2 in the last Parliament) is a profound impediment to the swift and effective implementation of SIS in communities that are so desperate for these life-saving health care services. The time, detail, and expense involved in the application process makes it all but impossible for most communities to implement SIS in a timely manner. We agree with the Canadian Medical Association that the bill creates unnecessary burdens and may deter the creation of more SIS in Canada. Accordingly, it is our hope that this bill can be amended or repealed to allow for more timely implementation of supervised injecting services.

To summarize, we the undersigned call for the following measures be taken immediately to address this emerging public health crisis:

1. We call for robust and significant investment on the part of the provincial and federal governments, in the form of sustained core funding and capital infrastructure grants, to facilitate the immediate creation of supervised injection services. Further, we call on regional health authorities to ensure that these monies are allocated towards the implementation of supervised consumption service. 2. We call on the Province of British Columbia to collaborate with regional health authorities to apply for section 56.1 exemptions under the Controlled Drugs and Substances Act for all community-based healthcare services contracted to provide harm reduction services by either the Province of British Columbia, or by a local health authority, to facilitate the immediate creation of supervised injection services throughout the province of British Columbia; and 3. We call on the federal government to do what it can to significantly amend or ideally repeal the Respect for Communities Act, which creates unnecessary and unwarranted barriers for securing exemptions under the CDSA to operate supervised consumption services without risk of prosecution.

As stated by Dr. Perry Kendall, BC Provincial Public Health Officer, in 2011 when commenting on motor vehicle accidents (currently with a reported fatality rate of 6.2 per 100,000 people, as opposed to 9.9 per 100,000 for overdose deaths): “Any preventable death or serious injury is unacceptable.” We wholly agree. We urge all levels of government to act to address this crisis and make available the resources to put in place those services known to save lives and promote community health.

With Respect,