Harm reduction must Prefers Option 2 as it meets the stated Utensils are ubiquitous. People who remain central. Harm objectives. Also most appropriate given support cannot obtain a properly prevention is a for cannabis law reform and pending review of manufactured utensil can and will – element of MoDA penalties. improvise, which increases harm. – harm reduction, and Support sub-options except: restriction on public Define utensils by intention of use at should not be confused places; infringement notices; wholly point of sale. Current definitions and with use prevention. unconvinced of a need for licensing why would prohibited features are useless, and – Proportionality needs to alcohol consumption paraphernalia vendors encourage discretionary be maintained. need licensing? enforcement. Feature-based definitions tend to outlaw harm While ease of Can see sense of Option 1 provided reduction innovations (eg, or ‘insert implementation and is understood as a shift towards ‘enhancement’ metal gauze’ feature supposedly cost effectiveness are greater harm reduction and proportionality, and helps define a cannabis pipe, but important and linked, in greater clarity of utensil definition: this feature exists to stop smokers our current policy they remove all arbitrary reference to forms of from inhaling burning embers/hot seem to reflect an ‘... utensils and names they are called ash). Vaporisers are so closely approach more aligned any operating guidance should deprioritise aligned with harm reduction they with a on “War Drugs” enforcement should be exempt. philosophy, where the reduce penalties to the absolute minimum focus on use reduction politically-achievable level. appears to override costs to individuals or overall expenditure’. 20 On behalf of New Zealand Needle Exchange Programme Prioritise harm Support Option 2. It is more compassionate, in Recommends the inclusion of: reduction; as a first line with the NDP. It also addresses online butterflies; wheel filters; sterile principle should be purchasing, which is an increasingly popular water; tourniquets; steri-cups; nothing that hinders way to buy utensils. catheters. harm reduction. Recommends disposal of used New Zealand has been equipment be included in a world leader in regulations. At the moment the NEx needle exchange is unable to update its collection services. processes in line with new technologies. Proportionality is critical. Penalties for possession of utensils should not be higher than for drug possession. 21 On behalf of The Hempstore Aotearoa Ltd
Harm reduction must remain central. Harm prevention is a element of harm reduction, and should not be confused with use prevention. Proportionality needs to be maintained. While ease of implementation and cost effectiveness are important and linked, in our current policy they ‘... seem to reflect an approach more aligned with a “War on Drugs” philosophy, where the focus on use reduction appears to override costs to individuals or overall expenditure’. Prefers Option 2 as it meets the stated objectives. Also most appropriate given support for cannabis law reform and pending review of MoDA penalties. Support sub-options except: restriction on public places; infringement notices; wholly unconvinced of a need for licensing – why would alcohol consumption paraphernalia vendors need licensing? Can see sense of Option 1 provided ‘enhancement’ is understood as a shift towards greater harm reduction and proportionality, and greater clarity of utensil definition: remove all arbitrary reference to forms of utensils and names they are called any operating guidance should deprioritise enforcement reduce penalties to the absolute minimum politically-achievable level. Utensils are ubiquitous. People who cannot obtain a properly manufactured utensil can – and will – improvise, which increases harm. Define utensils by intention of use at point of sale. Current definitions and prohibited features are useless, and encourage discretionary enforcement. Feature-based definitions tend to outlaw harm reduction innovations (eg, ‘insert or metal gauze’ feature supposedly helps define a cannabis pipe, but this feature exists to stop smokers from inhaling burning embers/hot ash). Vaporisers are so closely aligned with harm reduction they should be exempt. 20 On behalf of New Zealand Needle Exchange Programme Prioritise harm reduction; as a first principle should be nothing that hinders harm reduction. New Zealand has been a world leader in needle exchange services. Proportionality is critical. Penalties for possession of utensils should not be higher than for drug possession. Support Option 2. It is more compassionate, in line with the NDP. It also addresses online purchasing, which is an increasingly popular way to buy utensils. Recommends the inclusion of: butterflies; wheel filters; sterile water; tourniquets; steri-cups; catheters. Recommends disposal of used equipment be included in regulations. At the moment the NEx is unable to update its collection processes in line with new technologies. 21 On behalf of The Hempstore Aotearoa Ltd
summary-submissions-review-drug-utensils-regulations-discussion-document-jan17.docx