Ontario has released its rules for groups applying to join the new Consumption and Treatment Services (CTS) program — its version of the former overdose prevention and supervised consumption site frameworks — and its biggest city officially thinks they’re flawed.
The Toronto Board of Health is urging the program’s architects to go back to the drawing board and find ways to make it more accessible to organizations hoping to offer spaces where people can use drugs under the supervision of trained staff.
The guidelines, released by the Ministry of Health and Long-Term Care on Nov. 1, introduce restrictions and requirements that didn’t exist under Ontario’s previous frameworks.
Ontario’s new CTS framework also doesn’t mention the existence of a service similar to the former overdose prevention sites — lower-barrier, more-flexible and less-regulated pop-up sites.
The new program caps the number of CTS sites allowed across Ontario at 21 and says sites should not exist within 600 metres from each other. In Toronto’s downtown core alone, several sites exist within a short distance of each other and could be forced to close if rule is enforced.
The guidelines also require all sites to offer foot baths, which are important for maintaining hygiene among intravenous drug users and people who are homeless. However they don’t specify whether the baths will need to feature permanent infrastructure or if they can be improvised, which could pose a challenge to sites that can only offer rudimentary foot baths.
The new model also requires organizations hoping to open a site, as well as those already running a site, to undergo the federal Supervised Consumption Site exemption process and a new, more rigorous provincial Consumption and Treatment Services application.
Following the release of these guidelines, Toronto’s board of health passed a motion to meet with the province to discuss concerns around, and amendments to, what it called “restrictive” rules.
The motion was originally tabled by Joe Cressy, a city councillor and head of the board of health.
In a letter to the board, Cressy praised the provincial government for acknowledging the role of harm reduction services like supervised injection sites, but cautioned against making the framework too restrictive to organizations trying to respond to a crisis.
“We continue to be in the midst of an overdose crisis that represents the worst public health crisis our city, and indeed our country, has seen in decades,” he said, citing data that shows the number of people who died from opioid overdoses in Toronto in 2017 increased by 121 per cent from 2015.
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“The situation remains urgent, and we need to do everything possible to save lives…While the acknowledgement of the role of harm reduction services was critical, there are concerns with the restrictive nature of the new Consumption and Treatment Service guidelines.”
As well as requesting a meeting with the province, the board also asked Ontario to maintain funding for all of Toronto’s current sites.
‘This strategy will absolutely cost lives’
While the Toronto Overdose Prevention Society initially praised the province’s decision in October to maintain an overdose prevention framework in Ontario, it took a more direct approach in responding to the guidelines released in November.
“The Ford government claims to be about reducing red tape and bureaucracy. However…they are now attempting to use unnecessarily complicated and overly bureaucratic processes to thwart the ongoing operation of effective, life-saving services,” a media release by the society reads.
“This strategy will absolutely cost lives across this province.”
Sarah Ovens, a spokesperson for the society, told Yahoo Canada repeated attempts by the society and other overdose prevention organizations to discuss the guidelines with the province have yielded little information.
“The organizations that are having to go through this process have been in touch with their contacts at the ministry and have been trying to get answers about some of the specifics,” she said.
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“They haven’t been hearing much. I know they’re feeling like they’re not getting great answers to their questions and that they have concerns that have yet to be addressed.”
While the group doesn’t run any overdose prevention sites, it works with organizations across Ontario who do. It coordinates the sharing of resources, engages with governments, guides organizations through application processes and advocates for the continued existence of supervised injection sites.
Ovens, who previously advocated for supervised consumption sites under the Harper government, said the provincial government’s approach to regulating the sites amounts to a regulatory purge, much like the last federal government’s approach.
“[The Harper government’s] framework as so difficult and so onerous that it was almost as if they were trying to ban those sites,” Ovens said.
“The Liberals came in and recognized that the former Harper-era process was far too onerous and difficult, so they streamlined that process and got rid of the more cumbersome aspects of it. And some of those things have now been added back in by what the [Ford government] has put forward.”
Impacts on cities big and small
As a result of the 21-site cap introduced by the new framework, Ovens said organizations that lack the resources to complete the new application process as quickly as other groups — for example, those in small communities with high overdose death rates — could be left without a single site.
“It’s just precluding them from being able to do anything for who knows how long,” she said.
And she said in densely populated cities like Toronto, the limit of one site per 600 metres will exacerbate the lines and overcrowding at sites and limit organizations’ ability to gear services toward different groups of people, like Indigenous patients.
“In the downtown east area of Toronto that’s an example of a place where right now we have five sites quite close together,” she said. “But there’s four sites specifically which are within 300 or 400 metres from each other.”
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The Regent Park Community Health Centres, Street Health and Moss Park sites, for example, are within 350 and 550 metres of one another.
“If they interpret these rules to the letter of how they’re written, a number of sites in Toronto are going to not be able to keep operating,” she said.
“And the thing is, those sites all have line ups right now, they have people waiting to use those services.”
The government’s rationale
On Oct. 22, the Ministry of Health and Long-Term Care said tougher requirements for ongoing monitoring and reporting and a more comprehensive enforcement and audit protocol are necessary to “help review performance, provide measurable outcomes and ensure compliance.”
In its review of Ontario’s Supervised Consumption Services and Overdose Prevention Sites, the ministry said it believed tighter restrictions on the number and locations of sites in Ontario were necessary to “address public concerns that have been raised about them,” particularly “in terms of crime increase, drug trafficking or public disorder (such as vandalism and discarded syringes) or their effects on the quality of life for local residents.”
With the CTS guidelines facing criticism from the Toronto Board of Health and the Toronto Overdose Prevention Society, Ministry spokesman David Jensen defended the approval process as being informed by an “extensive evidence-based review.”
“Approval under the new CTS model is based on need, proximity to other sites and services, community support, ongoing community consultation, integration with primary care, treatment and other health services,” Jensen told Yahoo Canada.
“These parameters are entirely consistent with expert input and feedback.”