Home Affairs Committee - Drugs: Breaking the CycleWritten evidence submitted by London Drug and Alcohol Policy Forum (DP135)

Background

1. The London Drug and Alcohol Policy Forum (LDAPF) was established in 1991 as the result of concerns raised by Directors of Social Services, other key agencies and the Police that there was a lack of co-ordination and sharing of best practice in response to developing drug problems. It is core funded by the City of London Corporation as part of its commitment to the wellbeing of the capital and the nation.

2. LDAPF works with all agencies (police, customs, health, local authorities, local drug partnerships) with an interest in reducing the harm illicit drugs do to communities. It organises seminars and conferences aimed at improving communication and awareness around drug issues as well as producing a range of materials including literature for parents, a toolkit for employers on responding to alcohol and drug problems, anti-drug driving campaigns, advice on responding to drug related overdoses and guidance aimed at those working in the night time economy. The successful drug amnesty bin scheme currently run in co-operation with the City of London Police is a further example of the activities in which the Forum is involved. In addition it supports a number of pan-London practitioner networks (eg those responsible for co-ordination and delivery of drug policy at a borough level).

3. The Forum supports a number of pan-London practitioner networks (eg those responsible for co-ordination and delivery of drug policy at a borough level). As such the LDAPF enjoys a unique viewpoint across the breadth of drug policy and its responses are informed by experts and experience at a regional and borough based level.

4. The LDAPF welcomes the decision of the Home Affairs Committee to perform a comprehensive review of drugs policy and the effectiveness of the 2010 UK Drug strategy. Given the impact of drug related problems on individuals, communities and society as a whole, plus the resources directed to tackle these, it is important that their effectiveness and appropriateness are considered regularly.

5. The paragraphs below respond to the specific points raised by the Committee in their call for evidence.

The extent to which the Government’s 2010 drug strategy is a “fiscally responsible policy with strategies grounded in science, health, security and human rights” in line with the recent recommendation by the Global Commission on Drug Policy

6. There are many aspects of the Global Commission on Drug Policy report and recommendations that the Forum would support, for example the essential importance of harm reduction and a range of evidence based treatments and the benefits of working with communities. We also welcome their call for increased debate on this subject area. In terms of the specific point of the extent the 2010 drug strategy is “fiscally responsible” it is difficult to judge. Some aspects of the strategy are better evidenced than others1 but with changes in health delivery, the moves towards increased localism and budget reductions, it is difficult to determine exactly how much is spent across the board on tackling drug issues.

7. The Forum does have concerns that while the overall goals of the 2010 strategy are generally supported, there is a lack of central support and leadership. During a period of massive transition there is clear benefit in existing evidence and best practice being promoted or at least readily available from central government or other reputable agencies. There is concern that learning and experience developed over the last 20 years is being lost or forgotten. The loss of experienced staff from government departments, local authorities and other agencies has seriously reduced the corporate memory. The provision of advice and information should not be considered as being excessive central interference, micro-management or antipathetic to the spirit of localism. To the contrary, it should help local areas, communities, schools etc develop the most appropriate responses to the challenges they face. The LDAPF is fully supportive of the principles of localism and recognises that local areas are uniquely well placed to respond to local problems.

8. The 2010 strategy, as with its predecessors, underlines the importance of education and information. However, it remains the case that little investment or focus is dedicated to this area and there are real concerns that gains achieved over many years are in danger of being lost. The Forum welcomes the recent decision to delay the end of funding for the Drug Education Forum, but the fact remains this is an area which is underdeveloped and under supported as was noted by the Home Affairs Committee in its 2002 report.

The criteria used by the Government to measure the efficacy of its drug policies.

9. The 2010 strategy includes a commitment to an annual review but, if this has been produced, it does not seem to have been widely publicised. While specific information remains available about treatment numbers, completion and aspects of the criminal justice system there is scope for developing a more sophisticated and broader basket of measures to gauge the efficacy of current policies. The Forum has specific concerns over the measurement of drug related deaths. Changes in the process have been made, but it remains unclear what the future system will be. The two projects based at St. Georges University of London (Volatile Substance Abuse mortality project and National Programme on Substance Abuse Deaths) are now defunct and have not been replaced. Mortality is a key indicator used to evaluate the hazard caused by new psychoactive substances, the so called “legal highs”. This information is likely to be vital to support the new risk assessments required by the Advisory Council on the Misuse of Drugs (ACMD) to service the temporary class drug orders. Anecdotally, there is some evidence of a spike in deaths amongst older drug and alcohol users who have been or remain in contact with services.

The independence and quality of expert advice which is being given to the government

10. The ACMD has many highly qualified and well regarded individuals amongst its membership. However, it does not have the resources to commission or undertake research and a great deal is asked of some of its members in terms of time and resources they dedicate to its work. The Forum strongly believes that a modest investment in developing an enhanced network of experts with a research budget would provide an important resource for all those engaged in responding to drug issues. The National Institute of Drug Abuse in the United States provides an impressive model of bringing science, information and resources together for the benefit of a range of audiences.

Whether drug-related policing and expenditure is likely to decrease in line with police budgets and what impact this may have

11. Committee members will be aware of the UK Drug Policy Commission’s report, Drug Enforcement in an Age of Austerity.2 The conclusions of this report match LDAPF’s experience. Drug related work is often seen as an additional feature of enforcement work and is seen as being a relatively easy cut to make. This is particularly true with police involvement with partnerships and communities. There is the sense by the police, and indeed by other agencies, that they need to concentrate on core business, while drugs work is often seen as being a fringe activity. This trend has the potential to impact seriously on local areas’ ability to co-ordinate work around drugs as police support is often essential.

12. The concentration on Class A drugs and disrupting the link between drugs and acquisitive crime has resulted in almost complete neglect of significant problems such as anabolic steroids, “legal highs” such as the synthetic cannabinoid receptor agonists and GHB/GBL.

13. However, the seizure and confiscation of assets linked to drug trafficking is strongly supported. Illicit trafficking is cash dependent and removal of assets is seen as genuine deterrent. The Forum would welcome increased efforts to use some of these funds in areas which suffer most from drug dealing and drug related crime. This is an area which is considerably under-developed and where community co-operation and engagement could be improved. Rates of seizure and confiscation could also be improved by refining the process or through the greater use of the civil recovery powers.

The cost effectiveness of different policies to reduce drug usage

14. This is an area of limited research and evidence. While treatment interventions often have a clear evidence base in terms of individuals reducing or stopping drug use, there is little evidence to suggest that policing activity alone does so. Policing activity is, however, valued by communities where drug dealing or drug related crime causes problems and many people enter treatment via the criminal justice system. More research is required on what policies are effective, but the dissemination and support for these is also important. In terms of young people and general prevalence of drug use, there is evidence showing an overall reduction in use but little examination as to the factors that have influenced this. It is unclear to what extent the reduction in the use of traditional drugs (amphetamine, cocaine, cannabis) has been replaced by new compounds (mephedrone, synthetic cannabinoids, ketamine) and perhaps alcohol.

15. Policies that take a stronger account of the factors faced by individuals and consider these in a holistic fashion with a range of responses (e.g mental health, housing, training, employment etc) are likely to be more cost effective than those that only deal with one issue in isolation.

The extent to which public health considerations should play a leading role in developing drugs policy

16. Public health is the key component of a good drugs policy. It should be borne in mind that the UK has achieved considerable public health gains over the decades in relation to drug related disease. The actions of Governments since the mid-1980s have seen the UK have one of the lowest levels in the world of HIV related to injecting drug use. Likewise significant gains have been achieved in halting the increase in, and then reducing, drug related deaths. The success in reducing deaths linked to the use of Volatile Substance Abuse is of particular note. However, there is a sense that the focus has moved away from measures such as these, especially in relation to blood borne viruses and there has not been adequate attention and focus on Hepatitis C in terms of seeking to prevent its spread, testing and treatment. This is already a major health issue and is likely to remain so for some years regardless of emerging new treatments and the potential of a vaccine.

17. There is also a need to ensure that public health approaches which focus on whole or large population models do not let service commissioners and providers lose sight of the individual and their particular needs. Thereby tackling a range of behaviours that becomes a major focus in the life of an individual, in addition to harm (self, family, friends, society) and social exclusion (stigma). Fundamentally it is important to ensure that decision and policymakers recognise that public health approaches are not in competition with other actions (eg enforcement) but in fact can complement and contribute to better outcomes for communities and individuals.

The relationship between drug and alcohol abuse

18. The 2010 strategy marked a further stage in the bringing together of responses to drug and alcohol abuse. At a service and treatment level, the inter connection is well acknowledged and understood, nearly all local partnerships are now addressing both substances. However, while it is positive to note that it is converging at a national level policy, more remains to be done. There is an implicit risk that the merging of budgets and removal of ring fences from certain drug budgets could see the greater demands (in terms of numbers) from alcohol treatment lead to a sharp reduction in drug treatment capacity. This is an issue that needs to be addressed by building on the work that has been done by the National Treatment Agency and others to make a clear case of the value of drug treatment to communities and individuals. There is also a need to consider approaches that don’t promote the consumption of alcohol at home or other, non-regulated, environments compared to licensed premises.

The comparative harm and cost of legal and illegal drugs

19. This is an area where there has been considerable work though results are often contradictory. What is clear, in terms of harms and costs is that the use of alcohol far exceeds other substances, whether that is measured in terms of deaths, illness, cost to the economy (absence from work etc) or violence. It is also evident that certain illegal drugs, especially heroin and crack cocaine, are often linked to high levels of acquisitive crime. The gradual coming together of more coherent policy responses to alcohol and drug use, and the significant recent increases in the use of so called legal highs, is beginning to make the differentiation of harms between illegal or legal substances increasingly irrelevant. Indeed the situation is complicated by the unknown scale of abuse of prescription only drugs available via the internet. The Forum would support more work being undertaken on determining the range of harms that these substances cause to individuals, communities and also those countries and regions involved in production, manufacture and trafficking routes. The extent of use and harm caused by drugs such as illegally imported benzodiazepines, anabolic steroids and cogitative enhancers is largely unknown.

The impact of the transfer of functions of the National Treatment Agency for Substance Misuse to Public Health England and how this will affect the provision of treatment

20. At this stage of the process it is too early to say. The National Treatment Agency has helped ensure a standard of access and quality across England. Whether the value of drug treatment is fully understood by all those who will now be involved in the commissioning and delivery of this treatment remains to be seen. The LDAPF has concerns that in many areas responses to drugs will be seen as a relatively peripheral issue, this coupled with pressure on budgets could have a highly detrimental impact especially in those areas with a less visible problem. The recent fact sheets from the Department of Health on the future of public health provide a strong foundation on which to build in terms of promoting understanding of new functions and responsibilities.

The availability of “legal highs” and the challenges associated with adapting the legal framework to deal with new substances

21. Legal highs have been available for many years, for example magic mushrooms could be described as such prior to the changes in legislation resulting from the 2005 Drugs Act (which incidentally left some psycho-active mushrooms outside the law). However, the rise of mephedrone use during 2009 and the subsequent marketing of various stimulants as legal highs (regardless of whether they are actually legal) and synthetic cannabinoids has raised fundamental challenges that both the legal framework and enforcement system has struggled to respond to effectively. Initial research was lacking in terms of being able to identify new and emerging substances, though recent steps such as the Forensic Early Warning System introduced by the Home Office go some way to remedying this. Likewise temporary banning orders provide enforcement agencies with a locus to act, though not necessarily the expertise or equipment to do so. Though the scale of the problem may be exaggerated by the media (with the exception of mephedrone none have become what could be described as mainstream drugs) it is a challenge that is unlikely to disappear and evidence from the USA and within Europe suggests that while action on specific suppliers or websites can be effective, legislation alone is of limited impact. This then is an additional reason for a systematic and well informed debate on what legislation can achieve and to what effect. The relevance of the Misuse of Drugs Act needs to be accessed and effective systems of control need to be considered. Enforcement of the Medicines Act needs to be strengthened to control better the inappropriate online sale of medicinal products and lifestyle drugs such as injectable tanning agents.

The links between drugs, organised crime and terrorism

22. This is an area where the LDAPF has limited direct experience, though clearly organised crime is involved in all aspects of drugs be that cocaine and heroin importation, the illicit production or supply of alcohol or indeed in the sale of legal highs. Where high profits are to be made in an illegal or quasi-illegal manner it is natural to assume organised crime, or even those with a terrorist connection, will get involved. It seems certain that whatever changes or reforms to legislation are considered there will remain a need for efficient enforcement and we repeat the point that cash and assets are the best way of tackling these groups.

Whether the UK is supporting its global partners effectively and what changes may occur with the introduction of the national crime agency

23. This is an area where the LDAPF has limited direct experience, though clearly organised crime is involved in all aspects of drugs be that cocaine and heroin importation, the illicit production or supply of alcohol or indeed in the sale of legal highs. Where high profits are to be made in an illegal or quasi-illegal manner it is natural to assume organised crime, or even those with a terrorist connection, will get involved. It seems certain that whatever changes or reforms to legislation are considered there will remain a need for efficient enforcement and we repeat the point that cash and assets are the best way of tackling these groups. The UK regularly reports more new substances to European Monitoring Centre for Drugs and Drug Addiction (EMCDDA) than other European countries, although this may be compromised by the closure of the Forensic Science Service and the dislocation occurring within forensic science in the UK.

Whether detailed consideration ought to be given to alternative ways of tackling the drugs dilemma, as recommended by the Select Committee in 2002 (The Government’s Drugs Policy: Is It Working?, HC 318, 2001–02) and the Justice Committee’s 2010 Report on justice reinvestment (Cutting crime: the case for justice reinvestment, HC 94, 2009–10)

24. The Forum welcomes informed debate on tackling drugs. It is a critically important subject and one that effects the lives directly or indirectly of almost everyone in the UK. There is a need to engage not only expert opinion but also that of a wide range of communities and also to accept that legislation while important is not the main factor in reducing problems and harms. It is the initiatives and policies delivered which have the impact. Individuals and communities do not understand, nor care greatly, about the intricacies of the Misuse of Drugs Act, the classes and schedules of substances or the machinations of the Advisory Council on the Misuse of Drugs. They do, however, want to have good information, know what to say to their children, understand what happens in schools, that the police and other agencies will intervene when crime or anti-social behaviour threatens them or their community and that if someone has a problem there is a place to get effective help. The Forum strongly believes that more debate, more consideration and a willingness to explore new approaches to tackle a changing environment are key to successful policy delivery. Particularly we believe that more attention should be paid to drug abuse by very young children using drugs such as tobacco, poppers, volatile substances and alcohol.

January 2012

1 although some areas are under researched this does not mean they should be neglected but rather that more research and testing of approaches is required

2 Drug enforcement in an age of austerity: Key findings from a survey of police forces in England, Helen Beck, UK Drug Policy Commission, October 2011.

Prepared 8th December 2012