Item - 2013.HL23.1

Toronto Public Health and 35 community agencies provide harm reduction services, including safer drug use supplies, to people who inject drugs in Toronto.  In 2010, there were 75,000 client visits to these services, and 1.1 million needles were distributed along with other sterile injection supplies.  Injection drug use is associated with important public health issues, including risk behaviours that lead to overdose and the transmission of blood borne diseases such as HIV and hepatitis.  The most recent research for Toronto finds that 61% of people who injected drugs in the six months preceding the study tested positive for hepatitis C, and 6% tested positive for HIV.  

Supervised injection services (SIS) have been implemented in Europe, Australia and Canada to help reduce the harms of injection drug use.  A SIS is a health service that provides a safe and hygienic environment where people can inject pre-obtained drugs under the supervision of trained staff.  Over 90 SISs are operating today.  There is extensive, peer-reviewed research documenting the positive public health and safety outcomes of these services, and wide agreement among health professionals that SISs should be available as part of a comprehensive continuum of health services for people who inject drugs.

In 2005, the Toronto Drug Strategy recommended a needs assessment and feasibility study for supervised consumption services in Toronto.  An independent research study concluded that Toronto would benefit from SISs integrated into health services already serving people who inject drugs.  The study also recommended the service be evaluated to assess individual and community impacts and outcomes.  Toronto Public Health (TPH) supports this model and approach to expand the continuum of health services available for this at-risk population. 

In Canada, SISs must operate with an exemption from Section 56 of the Controlled Drugs and Substances Act (CDSA), granted by the federal Health Minister, or risk Criminal Code sanctions.  InSite, a supervised injection service in Vancouver, was established in 2003, and was granted a CDSA exemption by the federal Minister of Health.  Although InSite received temporary exemptions in 2006 and 2007, the federal government failed to extend InSite's CDSA exemption in 2008.  In response, the operators of InSite initiated a legal challenge.  In September 2011, the Supreme Court of Canada ordered the federal Minister of Health to grant InSite an extended CDSA exemption.  In its decision, the Court also identified evidence that must be considered in making future exemption decisions.  SIS implementation is now being pursued in several cities across Canada.

In June 2013, the federal government introduced Bill C-65, entitled the Respect for Communities Act, which, among other things, outlines a process and the documentation required from groups seeking a CDSA exemption to operate a SIS.  The requirements in the bill are onerous, and there is no indication as to what level of information or support is needed for a successful application.  If the bill is passed as currently drafted, health services seeking to implement supervised injection will have great difficulty meeting the requirements for a CDSA exemption.  It is therefore recommended that the Board of Health make a submission to the federal government to register its opposition to Bill C-65, and to recommend the development of a more feasible CDSA exemption application process, in consultation with relevant provincial, public health, public safety and community stakeholders, including people who use drugs. 

The Toronto Drug Strategy Implementation Panel has developed a comprehensive toolkit to assist with effective implementation of SISs in Toronto.  The toolkit supports a reasonable process that reflects the conditions outlined in the Supreme Court of Canada ruling, and recognizes the importance of community engagement.  It is therefore recommended that the Board of Health urge the provincial government to fund the integration of supervised injection services, on a pilot basis, into existing provincially-funded clinical health services in Toronto, and fund the evaluation of this pilot. 

The Council-approved Toronto Drug Strategy (TDS) provides a comprehensive approach to alcohol and other drug issues based on the integrated components of prevention, harm reduction, treatment and enforcement.  The TDS Implementation Panel is a multi-sectoral leadership group that provides oversight and strategic advice for implementation of the drug strategy's 68 recommendations.