5. Preventing and reducing harm caused by alcohol and other drugs
   1. In examining the submissions received by this Committee, there are a range of issues relating to alcohol and other drug (AOD) that a future Committee might consider. The issues include:

• The regulation, marketing, access to alcohol
• Education about AOD for families and schools
• Public health campaigns
• The stigma associated with accessing AOD services
• The utility of drug checking services
• Supervised injecting centres and needle and exchange programs
• Take home naloxone programs
• Opioid dependence treatment programs
• Diversion initiatives
• AOD screening
• Decriminalisation initiatives, such as those in the ACT

These issues are often highly contested, and it will be important that the Committee receives submissions from a wide range of stakeholders to test evidence on these issues before coming to conclusions, if any.

Addressing the stigma

5.2According to the World Health Organization, alcohol and illicit drug use are among the most stigmatised health conditions globally.[1] Throughout the inquiry, witnesses stressed that stigma is a major barrier to the access of both general health care and AOD services. For individuals experiencing AOD-related harms, stigma associated with substance use impacts not only their health, but extends to all aspects of their lives, such as employment prospects and social connectivity.[2]

5.3Professor Dan Lubman AM, Executive Clinical Director at Turning Point and Director of the Monash Addiction Research Centre emphasised the negative impact of AOD-related stigma:

Everyone knows someone who is struggling with alcohol or drug use, because one in four Australians will. They are our friends, family and colleagues. But roughly half a million people aren't accessing the treatment, care and support they need, with individuals not knowing where to go for help and families not knowing how to support their loved ones. That's largely because addiction is one of the most stigmatised health conditions in the world. People internalise stigma and shame, which causes them to hide their use and delay help seeking.[3]

5.4The Queensland Network of Alcohol and other Drug Agencies (QNADA) further asserted that AOD-related stigma is not exclusive to people who use AOD, but that it also impacts their family members, friends and communities. This situation has a detrimental impact on people directly experiencing AOD-related harm, QNADA explained, as it ’commonly results in a weakened support network, which further impedes their ability to initiate better health outcomes’.[4]

5.5The origin of the stigma associated with the use of illicit drug and alcohol dependence remains a matter of debate. The Alcohol and Drug Foundation (ADF) submitted that this attitude is ‘wrapped up in a complex history that incorporates religious influences, racism, marginalisation, criminalisation, economic pressures, fear, politics and the influence of powerful individual actors in critical times and places’.[5]

5.6ACON further suggested that there is ‘a direct relationship between policy and stigma, with more punitive policy associated with higher level of stigma’.[6] Citing research conducted for the Queensland Mental Health Commission, QNADA said that AOD-related stigma and discrimination often stems from the fact that personal illicit drug use remains a criminal offence.[7]

5.7Witnesses expressed particular concern regarding the stigma that exists in the healthcare system towards people who use drugs. ACON informed the Committee that people who inject drugs report high levels of stigma, particularly in healthcare settings, with two thirds delaying or not attended health appointments to avoid being treated negatively by health workers.[8] According to one survey, 86 per cent of the general public and 56 per cent of healthcare workers self-report their own negative attitudes towards people who inject drugs.[9]

5.8ACON highlighted that AOD-related stigma is further amplified for cohorts that are experiencing additional social pressures or forms of exclusion, ‘such as people with HIV, Aboriginal and Torres Strait Islander People, LGBTQ+ people, sex workers, people who have been incarcerated, people experiencing mental distress, people living with disabilities and people who experience homelessness’.[10] Professor Lubman similarly foregrounded the need to consider the intersectional impact of stigma in efforts to address barriers that might prevent people from seeking help.[11]

5.9Much of the evidence submitted to this inquiry suggests that a lack of knowledge about AOD often drives stigmatised attitudes, and presents a major impediment to cross-sector collaboration in tackling AOD harm. To raise knowledge levels about AOD and create a stronger basis for the integration of services, the National Centre for Education and Training on Addiction (NCETA) has developed resources to enhance the capacity of other sectors to identify and respond to AOD-related harms, such has the Screening and Withdrawal Tools Collection, and the National Alcohol and Drug Knowledgebase.[12]

5.10Throughout the inquiry, the Committee was urged to conder the use of language and its potential to perpetuate stigma and cause harm. The Australian Research Centre in Sex, Health and Society highlighted the need to move away from language that is thought to be stigmatising, such as ‘substance abuse’, ‘substance misuse’, ‘recovery’, ‘addiction’, ‘addict’, and ‘substance use disorder’.[13] Language that was inaccurate or dehumanising, the ADF further argued, is a major contributor to stigmatisation.[14]

5.11The UNSW Drug Policy Modelling Program further explained that the use of the term ‘recovery’ was not consistent with the evidence demonstrating ‘the journey in and out of substance use over a lifetime’.[15] Similarly to chronic medical conditions, AOD treatment is a lifelong commitment to behavioural change, and in many cases also the use of medications, with a majority of people requiring multiple treatment episodes before changing their relationship with substances.[16]

5.12In its submission, the Foundation for Alcohol Research and Education (FARE) recommended the development of government communication guidelines aimed at avoiding the use of stigmatising and blame-apportioning language. Such guidelines, FARE suggested, should build on examples such as Guidelines for communicating about alcohol and other drugs, developed by Mindframe (a national program for safe media reporting about suicide, mental health and AOD) and Language matters, published by the Network of Alcohol and Other Drugs Agencies (NADA).[17]

5.13The Australian Research Centre in Sex, Health and Society pointed out that drugs are routinely depicted as ‘self-evident problems’, ‘generating a range of problems including criminal behaviour, illness, injury and death. The notion that drugs are inherently harmful is both commonplace and taken-for-granted in much policy’.[18] These entrenched views about AOD, the Centre argued, stigmatise people who consume AOD and also obscure the fact that in many cases AOD use does not produce harm.[19]

5.14Law enforcement entities, according to QNADA, can perpetuate stigma and discrimination towards people who use drugs, especially through their engagement with media around illicit drug seizures. An examination of how Australian news media depicted illicit drug stories between 2003 and 2008 revealed that reporting on these matters was heavily biased towards a ‘crime and deviance’ narrative.[20] Reframing of this narrative, witnesses suggested, had a major role to play in reducing the AOD-related stigma, and by extension, increasing readiness of individuals to seek support.

5.15In reflecting on ways to address AOD-related stigma, Windana—which supports people experiencing AOD harms—called for a public health campaign aimed at destigmatising drug consumption. Any such campaign would draw upon experience from previous successful health campaigns, including those designed to destigmatise mental health issues. The organisation further recommended the development of a comprehensive Australian Stigma Reduction Strategy.[21]

Decriminalisation of personal drug use

5.16Responsibility for the oversight, development, implementation and monitoring of Australia’s national illicit drugs policy framework is shared between the Department of Health and Aged Care, Australian Border Force, and the Attorney-General’s Department (AGD). The AGD is responsible for the administration of criminal justice and law enforcement policy, including administering Commonwealth illicit drug use offences under the Commonwealth Criminal Code Act 1995 and Criminal Code Regulation 2019, as well as administering Commonwealth courts and tribunals. States and territories have primary responsibility for laws governing the possession and use of illicit drugs within their jurisdictions. This includes laws relating to decriminalisation or legalisation, and supply, demand and harm reduction.[22]

5.17Throughout the inquiry, the Committee heard substantial evidence pertaining to the extent to which the current legal framework impacts Australia’s ability to effectively address the harmful consequences of AOD use. Multiple witnesses submitted that drug criminalisation had little effect on the availability of illicit substances, and that it could, in fact, elevate the risk of harm related to drug use.[23] According to the Australian Research Centre in Sex, Health and Society:

the law plays a central role in generating, magnifying, exacerbating (and thus ameliorating) AOD-related harms. It does so in several ways, including through laws that criminalise drug use, possession and supply, thus exposing people to criminalisation and stigma, incarceration and social exclusion. In this sense, criminal laws exacerbate social disadvantage and generate other social problems, such has the persistent effects of criminal records on employment, housing, welfare and so on.[24]

5.18ACON submitted that there is growing evidence to support a shifting of focus away from the law enforcement response, ‘especially with regard to communities disproportionately impacted by policing, including LGBTQ+ people, but also First Nations communities and people experiencing complex mental distress’.[25] In its submission, Healthy Cities Illawarra drew attention to the findings of the Johns Hopkins-Lancet Commission on Drug Policy and Health, which concluded that there was no evidence that the threat of imprisonment was an effective deterrent against drug use.[26]

5.19Concerns were expressed in multiple submissions regarding the use of drug detection dogs as part of the law enforcement response. Police dog deployment can be particularly traumatising to certain populations. Students for Sensible Drug Policy further noted that their presence can also trigger ‘panic consumption’—use of greater amount of substance than the person intended in order to avoid detection—which further increases the risk of harm.[27]

5.20According to data from the Australian Criminal Intelligence Commission (ACIC), drug markets are continuing to expand, with law enforcement seizures increasing by 39 per cent over the past 10 years. ADF submitted that relatively few arrests for drug-related offences relate to supply, with ACIC data revealing that of the 140,624 national drug arrests in 2020-21, 87 per cent were for personal use.[28]

5.21Many witnesses expressed strong support for the decriminalisation of personal drug use. ADF explained that:

Decriminalisation of personal drug use refers to the removal of criminal sanctions for individuals in possession or using illicit substances, or in possession of paraphernalia to use illicit substances. Decriminalisation differs from the regulation or legalisation of illicit drugs, as the supply, trafficking, and production of illicit drugs remains criminalised. This provides the person using illicit substances better access to health services, while law enforcement continues to disrupt the supply and production of illicit drugs.[29]

The decriminalisation approach, as ADF further noted, is based upon a recognition that personal drug use inevitably takes place, and that, as such, a health rather than justice response is a more effective and appropriate way to reduce associated harms.[30]

5.22QNADA echoed this point, explaining that:

Across the world, countries which have embarked on reform decriminalising illicit drug use and emphasising health-based responses have witnesses decreased drug-related harms and deaths and declines in costs to law enforcement and criminal justice system, all without a comparable increase in illicit drug use. These benefits are particularly realised where illicit drug decriminalisation occurs with concurrent investment in the health system.[31]

5.23Some states and territories have moved towards the decriminalisation of drugs for personal use. In 2020, the Australian Capital Territory (ACT) introduced legislation to remove criminal penalties for the possession and cultivation of small amounts of cannabis for personal use. A recent review found that in the time that has since elapsed, there has been no significant change in cannabis use prevalence, ambulance or hospital admissions related to cannabis, or in the price and availability of cannabis.[32] In October 2023, the ACT Government decriminalised the personal possession of small amounts of the most commonly used illicit drugs, including amphetamines, cocaine, heroin and some hallucinogens. The reforms did not change laws regarding supply and manufacture of drugs, nor did they alter drug driving laws.[33]

5.24In May 2024, the Police Drug Diversion Program in Queensland, which originally only applied to minor drug offences including cannabis, was expanded to include a wider range of personal use drug possession offences. While the manufacture and supply of drugs remains a criminal offence, people in Queensland found with small amounts of drugs for personal use are given up to three diversion opportunities, including a warning only (for first offences) or referral to a health intervention. The fourth interaction with police would result in a court notice.[34]

5.25Although the decriminalisation of personal drug use is largely the legal responsibility of the states and territories, ADF submitted that leadership from the federal government could aid jurisdictions in designing and implementing evidence-based drug policies. ADF also recommended that the federal government examine and address any conflict between its laws and those of the states and territories, including a current case in which ACT laws clash with the Commonwealth Criminal Code Act 1995, which makes the possession of controlled substances an offence. Equally, a review of the threshold set out in the Commonwealth Criminal Code Act 1995 that delineates personal possession and trafficking was suggested as an initiative that could provide more consistent guidance for states and territories.[35]

5.26In its report Australia’s illicit drug problem: Challenges and opportunities for law enforcement (May 2024), the Parliamentary Joint Committee on Law Enforcement recommended that the Australian Government commission research to better understand the impact of decriminalisation in Australian and international jurisdictions where reforms have been implemented, with an evaluation of the longitudinal impacts on individuals, communities and law enforcement.[36] The Committee recognises that an in-depth investigation of decriminalisation initiatives is a critical step in informing future policy in this area.

Prevention and harm reduction strategies

5.27The goal of prevention and early intervention is to slow and ideally stop progress along a continuum that begins with first or experimental AOD use, and moves to occasional or regular use, before escalating to risky use or dependency.[37] According the Drug Policy Modelling Program at UNSW, responses at both population level and individual level are required along the full continuum; these range from strategies to prevent or delay the commencement of AOD use, preventing the transition to more harmful consumption, and reducing the harms associated with consumption, to the provision of treatment.[38]

5.28The Committee received substantial evidence pertaining to programs and strategies used to prevent or reduce harm associated with AOD use. Focus was placed in particular on:

• Family-focused initiatives
• School-based programs
• Drug checking services
• Supervised injecting centres
• Needle and Syringe Programs
• Take Home Naloxone Program
• Diversion initiatives
• AOD screening.

Family-focused initiatives

5.29In its submission, ADF emphasised that the relationship between young people and their parents plays a critical role in preventing AOD-related harm among young people. Parental monitoring, high quality parent-child relationships, parental support, and parental involvement all act as vital protective factors against harmful substance use.[39]

5.30Beyond positive engagement between parents and children, the South Australian Commissioner for Children and Young People also emphasised the importance of fostering strong relationships between families and their communities as a protective factor.[40] The Commonwealth Department of Education reiterated this point, noting:

Productive partnerships between schools, family, and the community […] provide a strong network of connections that can help protect young people against a range of harms including those associated with drug use, emotional distress and problem behaviours.[41]

5.31In highlighting the role that parental factors in particular play in alcohol use among adolescents, ADF submitted that family-focused initiatives should provide opportunities for parents to enhance their knowledge about alcohol consumption and reduce risky behaviours such as the parental provision of alcohol, favourable parenting attitudes towards alcohol, and parental drinking:

Research shows that when parents give young people alcohol, or let them drink at home, that young person is more likely to start drinking earlier, drink more often, and drink higher quantities of alcohol. That young person will also be at a higher risk for experiencing problems with alcohol both in adolescence, and later in life.[42]

ADF further noted that underage drinking is likely to rise when a parent treats drinking as humorous, or discloses their own negative experiences with alcohol.[43]

5.32DrinkWise—a not-for-profit organisation established in 2005 with funding from alcohol industry producers and the Federal Government—also submitted that parents are critical to encouraging underage abstinence. Throughout its history, the organisation has run a series of campaigns aimed at promoting the importance of parental oversight in this context:

From the first DrinkWise campaign in 2008, Kids Absorb Your Drinking, which saw a dad ask his son to get him a beer from the fridge and the generational cycle repeating – causing many Australian parents to reflect on their own drinking behaviours and role modelling within the home – to the latest It’s okay to say nay campaign [launched in 2022], the success of DrinkWise campaigns has in the ability to resonate with parents.[44]

School-based programs

5.33In its submission, the Department of Education observed that as nearly all children and young people attend school, the school environment makes for ‘an ideal setting for delivering drug and alcohol education, as well as identifying at risk children and young people’.[45] As such, state and territory governments and non-governmental education authorities have adopted a broad range of policies and programs to address the impact of AOD on schools.[46]

5.34The Department of Education emphasised the importance of AOD use prevention messaging for children and young people, noting the significant impact that substance use has on this cohort: ‘In addition to the short-term impacts which can include impaired judgement, memory difficulties and impulsive behaviour, there are significant long-term impacts of ongoing use, which are particularly acute for children and young people’.[47]

5.35Exposure to drugs or alcohol at a young age, which is a crucial phase of brain development, can lead to a lasting impairment in functions such as physical coordination, planning, judgement, decision making, impulse control, learning and memory. Regular drinking, according to Department of Education data, is also linked to an increased risk of developing mental health problems, including anxiety and depression.[48]

5.36The relationship between AOD use among young people and their engagement with the digital environment was raised as a major source of concern within several inquiry submissions.[49] The Department of Education drew attention to research on the link between online advertising and substance use:

As children and young people continue to spend more time online, including to access social media, there are concerns that exposure [to] content positively portraying alcohol and drug use may influence their consumption. Social media consistently exposes teenagers to alcohol and substance-related content including through posts from peers and curated advertising content. Research has suggested that viewing advertising for alcohol can increase intention to drink, likelihood of underage drinking, and levels of alcohol consumed. It has also been shown that adolescents who are exposed to high levels of substance use, including through social media, are more likely to use and develop issues with alcohol, tobacco and cannabis.[50]

5.37As previously noted, recent data on the rates of alcohol use in young people aged 14-24 shows that the consumption has decreased over the past 20 years. At the same time, however, there has been an increase in the use of illicit drugs, including pharmaceutical products. While the use of vapes or e-cigarettes is not the focus of this inquiry, the Committee acknowledges the concern that has been raised by witnesses regarding the use of these products, as younger people are at greater risk of developing nicotine dependence than adults.[51]

5.38In discussing the impact of current school-based education programs on AOD use, the Department of Education explained that the Australian Curriculum (Version 9.0) addresses the health impacts of AOD as part of health and physical education learning. This content is delivered in an age-appropriate way across the years of schooling from Foundation to Year 10, with students progressively learning about safe practice in relation to a range of drugs, from prescription drugs, household poisons, energy drinks, caffeine, to tobacco, alcohol, and other drugs.[52]

5.39The Australian Government also funds a range of other programs that focus on AOD education. The Student Wellbeing Hub, for example, provides information and resources for educators, students, and parents to support students from Foundation to Year 12. The Life Education Australia (Life Ed) is another well-established preventative health and safety education program. Colloquially known as ‘Healthy Harold’ after the giraffe character that features in the program, this initiative supports children aged between three and 13 to make safer and healthier choices throughout their education years, and their lives.[53]

5.40While school-based programs provide a useful avenue for prevention messaging, the National Centre for Youth Substance Use Research (NCYSUR) emphasised that these are ‘often outdated and not informed by current international best practices’.[54] Multiple witnesses asserted that health promotion and education campaigns for young people must be informative, evidence-based, and tailored to reflect the experiences of young people, and avoid being fear-driven.[55] As Dr Adrian Farrugia from La Trobe University explained:

When drug education initiatives do not sufficiently address and value lived experience and local knowledge of consumption, they can contribute to scepticism, including a broader cynicism about all ‘official’ sources of information such as those perceived to be produced by governments.[56]

5.41Dr Farrugia further noted that AOD education must be designed with ethical issues in mind, and in manner than does not perpetuate stigma or negative stereotypes. He recommended a review of drug education programs to ensure that content is free from gender-based stereotypes, and does not place disproportionate focus on consumption by young women, or position young people who consume drugs as morally compromised and shameful.[57]

5.42Students for Sensible Drug Policy Australia similarly recommended that current drug education and harm reduction programs should be reviewed and updated to include culturally relevant and reliable health material, tailored towards multiple platforms, and co-designed with the population they aimed to reach.[58] ADF also called for a review of school-based programs to ensure they reflect the International Standards of Drug Prevention, published by the United Nations Office of Drug and Crime, which provides a guide to best practice for prevention in schools.[59]

5.43NCYSUR further recommended investment in emerging technologies to strengthen the existing health messaging programs. The Centre explains its current work in this field:

… researchers at NCYSUR have begun utilising artificial intelligence (AI) and youth input to cost-effectively and rapidly generate vaping prevention messages which are designed with social media as the focus. Preliminary data from over 600 young people showed that these rapidly generated AI messages are as effective as existing media campaigns which are more costly and time-consuming to create.[60]

Drug checking services

5.44Drug checking (which is also sometimes referred to as pill testing) is a process of examining the chemical content of drugs before their consumption. This service aims to reduce the risk of harm of illegal drugs, which can be highly unpredictable in terms of the substances they contain and their purity.[61]

5.45According to NCYSUR, drug checking services play an important part in reducing the harms associated with drug use. Its submission draws attention to evidence from the European drug checking services, which demonstrated the public health benefits of drug checking, and the additional role these services provide as an early warning system by detecting harmful substances circulating in drug markets.[62]

5.46In Australia, drug checking services have been piloted in Queensland (CheQpoint), and the ACT (CanTEST), with a further service to be established in Victoria 2025. Since its launch in July 2022, CanTEST has analysed more than 2,900 samples, detected 252 novel psychoactive substance and released 20 community notices of dangerous substance detection.[63] Evaluation of the CanTEST pilot, conducted by the Australian National University, revelated that 70 per cent of people who used the service had never previously spoken to a healthcare worker about AOD, and two thirds accepted an AOD or general health intervention after using the service.[64]

5.47Numerous witnesses, including the Alcohol, Tobacco and other Drugs Council (Tasmania), NCYSUR, ACON, ADF, New South Wales Council for Civil Liberties, Healthy Cities Illawarra, and Students for Sensible Drug Policy Australia recommended investment in fixed-site drug checking services as well as mobile drug checking services at events such as music festivals.[65] The Australian Medical Association (AMA) similarly expressed its support for ‘sanctioned, appropriately supervised, and monitored high-quality pill testing trials to minimise the risk to young people and build an evidence base to determine the effectiveness of pill testing in Australia’.[66]

5.48Mr Cameron Francis, Chief Executive Officer of the Loop Australia—a not-for-profit organisation delivering drug checking services in Queensland, New South Wales and Victoria—emphasised that these services also play a critical role by providing an entry point into the healthcare system for at-risk clients:

Harm reduction approaches like drug-checking are able to reach new and different populations that are not currently accessing treatment or engaged in the service system. The majority of clients we see in our drug-checking services are not currently engaged in the system at all. The majority have never spoken to a health professional about alcohol and drug concerns. We are the first people they have ever spoken to about their substance use. From that, we are able to identify a range of hidden populations that are genuinely not connected or not otherwise represented.[67]

5.49Mr Francis also provided an example of how this service functions:

We are also seeing significant numbers of people using drugs like methamphetamine who are not interested in treatment. They are presenting to get their drugs tested because they think the drugs are not working anymore and are saying, 'It must be cut with something.' We are able to show them that is not the case; it is their tolerance that is causing those changes. That opens the door to a discussion regarding treatment. Each week, when we open the service, clients in that category come through who are not seeking treatment. We are able to point out the impacts of their regular methamphetamine use and engage them in treatment conversations.[68]

5.50In addressing a Committee query as to whether drug checking services might have adverse impacts, such as by creating an impression that illegal substances are condoned, Mr Francis said:

We don't give anyone an 'okay'. The common misconception of drug-checking services is that they somehow pass or fail the test. We actually explain to the person what we believe the compound to be in their sample, and we explain the risks of that drug to the person. There is no green light—passing or failing—to the test […]

We don't confiscate drugs from people. We test drugs with people's consent. They provide us those drugs voluntarily. If we encounter a highly-dangerous sample we have a conversation with someone about that. We are very successful at getting people to hand those over for disposal. One of our reports from last month indicated that we got a 100 per cent discard rate in an unexpected result in our client group. That is down to the skill and experience of our staff who are able to have those respectful conversations with people.[69]

Supervised injecting centres

5.51Supervised injecting facilities (also referred to as overdose prevention services) are spaces where people who use drugs can be safely monitored, treated in the event of overdose, and referred to medical and healthcare services. There are presently two medically supervised injecting centres in Australia: Uniting’s Medically Supervised Injecting Centre (MSIC) in Kings Cross, New South Wales, and a centre in North Richmond, Victoria.[70]

5.52International evidence, NCYSUR submitted, revealed that overdose prevention sites tend to be used by middle to older-aged clients. NCYSUR noted that the service needs of young people in this context remain a point of concern, and recommended investment in research and evaluation of youth-focused models of care within overdose prevention sites.[71]

Needle and Syringe Programs

5.53Needle and Syringe Programs (NSPs) are public health programs that provide sterile injecting equipment, both at fixed or mobile sites, with the aim of reducing the transmission of bloodborne viruses.[72] These programs also provide peer support and healthcare information to people who inject drugs. As the Pharmacy Guild of Australia further explained, NSPs:

… may also involve the safe collection and disposal of used syringes via a community pharmacy depot. The use of clean injecting equipment as well as safe disposal of used syringes significantly reduces the health risks to an individual and the burden to a community of blood-borne diseases such as HIV, hepatitis B or C.[73]

5.54Australia has historically been an early adopter of harm reduction measures, including needle and syringe programs.[74] In recent times, multiple countries have extended NSPs to prisons, but Australia is currently behind in the expansion of NSPs. The Australian Research Centre in Sex, Health and Society explained that prison NSPs were an extremely valuable harm reduction service with many potential benefits, including the prevention of AOD-related harms such as hepatitis C transmission. Based on 2020 research data, 37 per cent of all hepatitis C treatments were delivered to people in prison. The reinfection rate within prisons is often high.[75]

5.55As noted in Chapter 4, multiple submissions to this inquiry highlighted the fact that Australia is a signatory of the United Nations Standard Minimum Rules for the Treatment of Prisoners (the Mandela Rules), which state that prisoners ought to have access to the health services available in the country without discrimination on the grounds of their legal situation.[76] Access to NSPs in programs, witnesses highlighted, was a matter of basic human right to healthcare access.

5.56In expressing its support for the program, the Pharmacy Guild of Australia recommended an establishment of a national NSP

to allow for the supply of clean injectable equipment and the safe collection and disposal of needles and syringes through community pharmacies. Any national program should be supported by the State and Territory governments, as people should not be disadvantaged in how they access a NSP based on where they choose to live.[77]

Opioid Dependence Treatment Program

5.57Opioid treatment programs provide treatment to people experiencing opioid dependence. This may include illicit drugs, such as heroin, as well as non-prescribed or prescribed opioids (most commonly opioids prescribed for pain relief). The treatment framework is broad and can include the provision of medication that helps to reduce opioid withdrawal symptoms and control the cravings associated with opioid dependence.

5.58In July 2023, the Pharmaceutical Benefits Scheme (PBS) introduced the National Opioid Dependence Treatment Program (ODT program). The PBS ODT program ensures that patients using the service can access their medicines as a pharmaceutical benefit.[78]

5.59The Pharmacy Guild of Australia noted that ODT treatment has long relied on a small number of high-caseload general practitioners, who are subject ‘to increasing attrition by age and regulatory scrutiny’.[79] In order to address the current shortage, the Guild recommended enhancing access to the PBS ODT program by allowing appropriately trained pharmacists to become ODT prescribes and fully remunerating community pharmacy for these services.[80]

5.60In his submission, Dr Simon Holliday expressed his support for the use of opioids for palliative care as well as active cancer treatment and end-of-life care. He also argued that the PBS should review support for opioid analgesics for chronic noncancer pain, highlighting that in the period between 2013 and 2017, just 16 per cent of Australians were dispensed opioids, almost all for chronic noncancer pain.[81]

5.61Dr Holliday further explained that opioid use over longer periods may lead to addiction and overdose. While they relieve suffering, opioids create ‘psychosocial changes’ and thus their use overlaps between pain management and addiction. The PBS indications, Dr Holliday submitted, require review as they do not presently reflect this complexity. In addition, he recommended that PBS should require the return of unused opioids to avoid their accumulation and potential misuse.[82]

5.62Evidence presented to the inquiry indicated that it is often difficult for clinicians to refuse a request for the initiation of strong pain killers. Dr Holliday explained, however:

Doctors can prevent patients from initiating or maintaining opioids for chronic pain by initiating active self-management strategies. In parallel with this, chronic opioid analgesic patients may require the introduction of therapeutic boundaries as seen in methadone-programmes.[83]

5.63These processes demand substantial amounts of time and emotional energy from the clinician and therefore, it was argued, they need to be supported by the MBS. In addition, Dr Holliday suggested that a brief training should be mandated before doctors could prescribe opioid analgesics, similar to the practice that has been introduced in the United States in response to the opioid epidemic.[84]

5.64The Pharmacy Guild of Australia also expressed its support for a staged supply approach as a valuable strategy in this context:

Staged supply is a clinically indicated, structured pharmacist service where the patient is given the doses of their medicine in periodic instalments that are less than the originally prescribed quantity. It is used for people who may be at risk of self-harm, abuse, or misuse of a particular medicine if they were to be supplied a full or substantial quantity at any one time. This typically means the patient picks up their dose on a daily to weekly basis and allows the pharmacist to monitor and check with the patient to ensure that they are taking their medicine appropriately.[85]

5.65The Guild noted, however, that the Commonwealth program was presently restricted to prescriber initiation, and had a patient cap which meant that each pharmacy was funded to make the program available to a certain number of patients (currently 15 per month). Further expansion of this program, according to the Guild, would significantly contribute to substance use management.[86]

Take Home Naloxone Program

5.66The Take Home Naloxone Program is an initiative that makes naloxone available for free and without a prescription through community and hospital pharmacies, as well as alcohol and drug treatment centres.[87] ADF explained that naloxone is a valuable harm reduction tool that worked by:

blocking opioid drugs, such as heroin and oxycodone, from attaching to opioid receptors in the brain. In can be injected intramuscularly or delivered by intranasal spray. It may be administered by medical professionals, as well as family, friends or bystanders in an emergency where someone is experiencing an overdose. Importantly, there is no evidence that extended use of naloxone can cause harmful physical effects or dependence.[88]

5.67The Pharmacy Guild of Australia emphasised that naloxone is ‘not only suitable for people that use illicit opioids but can also be a life-saver for people using prescription opioids to manage their pain or as part of the ODT program’.[89]

5.68Multiple witnesses explained that the naloxone program has been critical in efforts to prevent fatal overdoses. Students for Sensible Drug Policy warned that in Australia there had been increasing detections of synthetic opioids, particularly nitazenes—a synthetic opioid up to 500 times stronger than heroin. There have been growing reports of harms from the use of these synthetic opioids, including hospitalisation, and at least 17 overdose deaths in Victoria and seven in South Australia. ‘In some cases’, the organisation suggested, ‘people have inadvertently consumed nitazenes contained in drugs sold as something else, such as cocaine or MDMA’.[90] Naloxone can effectively and temporarily reverse nitazene toxicity during overdoses.

5.69In addition to expressing strong support for the Take Home Naloxone Program, witnesses suggested that it might be usefully expanded to further assist efforts to counteract opioid toxicity. Students for Sensible Drug Policy suggested that all first responders, including ‘peer led harm reduction services, and medical services should be appropriately funded to carry naloxone and should undergo nationally recognised training in administering naloxone to respond to an opioid overdose’.[91]

5.70The Pharmacy Guild of Australia reiterated this point, noting:

the Commonwealth must work with the pharmacy and patient sector to promote availability, uptake and access to the take home naloxone program. More must be done at national level to increase uptake of the program by community pharmacies and access to products by people at risk of opioid overdose.[92]

Diversion initiatives

5.71Drug diversion programs provide people who are caught in possession of drugs with an alternative to criminal prosecution. Instead of facing arrest and criminal charges, participants can enter treatment, counselling, or support services to address their drug use. According to NCYSUR:

… police drug diversion programs have been found to be effective in preventing criminal offending and show promising results for improving health outcomes and diminishing social cost as well as costs associated with processing drug-related offences.[93]

5.72In its submission, the Legal Aid Commission of New South Wales (Legal Aid NSW) noted that while it perceived decriminalisation of the possession of prohibited drugs for personal use as preferable, where this is not an option, diversion from the criminal justice system represents a preferred alternative to criminal prosecution.[94] The organisation submitted that in NSW there is currently a number of diversion schemes in place, including the Cannabis Cautioning Scheme and the Early Drug Diversion Initiative. These schemes allow the police to use formal cautions or fines for initial offences, combined with the provision of support services.[95]

5.73Drug courts, which offer offenders the chance to participate in the drug court program, have also been proven effective in reducing reoffending in both the Australian and international contexts.[96] In discussing drug courts, AMA highlighted that it saw:

… a real value in drug courts, which accept referrals from local courts for those who will be charged and imprisoned, who are dependent on prohibited drugs. If a person is accepted into one of the drug court programs, specialised addiction support is given, helping to reduce recidivism in the future.[97]

5.74Legal Aid NSW also commended the use of Work and Development Orders (WDO), which allow people experiencing disadvantage to clear fines through unpaid work, courses or treatment. These orders are available to people who are experiencing harm from drugs, alcohol or volatile substances, and they can engage in treatment as part of a WDO.[98]

5.75Multiple submissions articulated support for the establishment of the Magistrates Early Referral Into Treatment (MERIT) Program.[99] This is a multiagency initiative of the NSW Department of Communities and Justice, the Chief Magistrate’s Office, NSW Health and NSW Police, with support from Legal Aid NSW and Aboriginal Legal Service (NSW/ACT). The program, which commenced in 2000 as a trial at Lismore Local Court, enables eligible defendants to have their matter adjourned to allow them to focus on treating their drug or alcohol problem. Successful engagement with the program (which usually takes 12 weeks) is taken into account in sentence proceedings.[100]

AOD screening

5.76Screening for alcohol and drug use is essential for linking people with treatment.[101] DrHolliday noted, however, that alcohol use disorders, for example, are often not identified by clinicians until at extreme levels, and that as such there is an urgent need for improved screening mechanisms.[102]

5.77AOD screening and brief interventions delivered in primary healthcare can be, according to FARE, effective in AOD harm prevention. In addition, social services can also be effective settings for early identification and referral for people experiencing AOD harm. Efforts to increase the capacity for cross-sector screening for AOD, FARE submitted, is vital step in countering AOD related harm.[103]

5.78The Australian College for Emergency Medicine (ACEM) expressed its support for the recommendation by the World Health Organization that emergency departments be resourced to conduct screening and other brief interventions, as well as referral for treatment programs. As ACEM noted, ‘the routine use of validated, standardised screening tools offers an important mechanism for identifying, reducing and preventing problematic use, abuse, and dependence on alcohol and other drugs’.[104]

5.79Mrs Sophie Harrington, Interim Chief Operating Officer of the National Organisation for Fetal Alcohol Spectrum Disorders, also highlighted that every pregnancy should be screened for prenatal exposure to alcohol. Furthermore, in noting the general increase in alcohol consumption among women of childbearing age combined with the level of unplanned pregnancies, a general screening for FASD in children was recommended. Witnesses also raised the issue of increased alcohol consumption during the COVID pandemic, and emphasised the need for screening children who were born during or after the pandemic.[105]

Alcohol harm reduction

5.80Over the course of the inquiry, the widespread cultural acceptance and normalisation of alcohol use in Australia has been repeatedly raised as a major cause for concern. AMA noted:

Alcohol is viewed as a fabric of Australian culture and not as a drug that has serious health and social implications. Alcohol is a psychotropic drug, and just like cannabis, cocaine and LSD, has an impact on cognition, emotions, and perception.[106]

5.81The Queensland Nurses and Midwives’ Union (QNMU) similarly highlighted that alcohol has become ubiquitous in everyday social interactions across Australia, and present at all major events, including family gatherings, celebrations, sporting events, work parties, and entertainment venues.[107]

5.82In Australia, the National Health and Medical Research Council (NHMRC) is charged with publishing national alcohol guidelines. The NHMRC guidelines suggest that healthy individuals should drink no more than 10 standard drinks in a week, and no more than four standard drinks on any one day.[108] A standard drink contains 10 grams of pure alcohol, which is, on average, the amount of alcohol the human body can process in one hour.[109] In most situations, a standard serving of alcohol is larger than one standard drink: for example, a 375mL can of full-strength beer equates to 1.4 standard drinks, and a 150mL glass of red wine (a typical restaurant serving) equates to 1.6 standard drinks.[110]

5.83Multiple witnesses expressed concern that Australians do not have an adequate understanding of what constitutes low risk alcohol use.[111] Furthermore, NHMRC guidelines mainly apply to healthy Australians. AMA suggested that the NHMRC should develop guidelines that specify what level of consumption presents risk in different contexts: ‘For example, people can have health conditions where any consumption of alcohol can exacerbate symptoms’.[112]

5.84In reflecting on the overall low level of understanding of health risks related to alcohol, ADF noted:

A recent poll conducted by Alcohol Change Australia (ACA) found that knowledge of Australian alcohol guidelines is low; over half of participants are either unsure of lifetime risk guidelines, or overestimate the number of standard drinks to remain at low risk of harm. While knowledge of the relationship between alcohol and liver disease was high (87%), less than half of respondents were aware that alcohol can cause cancer. Only 14% were aware that alcohol can cause breast cancer.[113]

Alcohol regulation

5.85The Australian Government has responsibility for national alcohol labelling standards, and some marketing and advertising, while state and territory governments are responsible for enforcing labelling standards and the specific laws and regulations regarding the sale, supply and consumption of alcohol within their jurisdictions. State and territory oversight also includes licensing requirements for venues and restrictions on where alcohol can be consumed.[114]

Product labelling

5.86To raise awareness of the harmful health impact of alcohol, multiple witnesses suggested the introduction of more comprehensive labels.[115] In its submission, the Department of Health and Aged Care explained that Food Standards Australia New Zealand (FSANZ) was responsible for developing and maintaining the Australia New Zealand Food Standards Code, which includes specific requirements for the labelling of alcoholic beverages. The Department cited research demonstrating that labelling requirements supported the prevention of alcohol related harms, and as such

alcoholic beverages sold in Australia are required to include the following information on their label:

• alcohol content (for beverages containing 0.5% or more alcohol by volume (ABV))

• number of standard drinks (for beverages containing more than 0.5% ABV), and

• a pregnancy warning label (for beverages containing more than 1.15% ABV).[116]

5.87In addition, the Department noted that alcoholic beverages must comply with general food standards within the Australia New Zealand Food Standards Code, such as those relating to approved ingredients and food safety.[117]

5.88While the Australian and New Zealand Governments already mandate pregnancy health warnings on alcohol products, ADF suggested that further health messages are needed ‘to communicate the wide range of other harms caused by alcohol’.[118] In January 2025, the U.S. Surgeon General issued advice on the alcohol and cancer risk, which, among other things, called for clearer health warning labelling on alcoholic beverages.[119]

5.89ADF submitted that Australia’s experience with pregnancy health warnings demonstrated the necessity of mandating labelling requirements, rather than relying on industry-led voluntary schemes:

[T]he current mandated pregnancy warning label was introduced by Food Standards Australia and New Zealand (FSANZ) in 2020, following the use of voluntary labels developed by the alcohol industry since 2011. This voluntary scheme was ineffective and poorly adhered to, with a review in 2013 finding that there was only 38% uptake.[120]

5.90ADF also noted that health warning labels on alcohol products have been implemented in some international jurisdictions, and proven effective in increasing consumer awareness and knowledge of alcohol harm.[121] The organisation thus recommended that the federal government introduce mandatory, standardised health warning labels on alcohol products to help raise awareness of the short- and long-term harms caused by alcohol, explaining that:

… while this policy is enacted through Food Standards Australia and New Zealand (FSANZ), the federal government must take a leadership role in establishing health warning labels to ensure agreement and cooperation across the jurisdictions.[122]

5.91AMA submitted that energy labelling standards be introduced for alcohol products as an appropriate energy intake was major contributing factor to maintaining good health and reducing the risk of chronic disease related to unhealthy body weight.[123] FSANZ is currently examining the introduction of such labels.[124]

5.92Industry entities, however, cautioned against additional labelling. Adding more information, according to Spirits and Cocktails Australia, risked overcrowding, and by extension, reducing the effectiveness of existing regulatory information. Proposals have been made for an introduction of QR codes on alcohol labelling that would complement existing label information as an alternative.[125]

Marketing and advertising

5.93Multiple submissions, including those from the Centre for Alcohol Policy Research at La Trobe University and NCETA, drew the Committee’s attention to the World Health Organization’s three key strategies (refer to as ‘best buys’) in the regulation of alcohol beverages to reduce health harms from drinking:

• restricting exposure to alcohol advertising
• increasing excise taxes on alcohol beverages, and
• restricting the physical availability of retailed alcohol.[126]
  94. In its submission, the Department of Infrastructure, Transport, Regional Development, Communication and the Arts (DITRDCA) explained that the advertising of alcohol is subject to a range of regulatory, co-regulatory and self-regulatory frameworks. Regulatory and co-regulatory frameworks tend to cover the scheduling and placement of advertisements, while the self-regulatory framework governs the content of advertisements.[127]
  95. At the federal level, DITRDCA has primary responsibility for media and advertising regulation for broadcasting and online services. Oversight and regulation of the broadcasting and media industry is the responsibility of the Australian Communications and Media Authority (ACMA). Under the Broadcasting Services Act 1992 (BSA), ACMA is also responsible for the regulatory and co-regulatory advertising frameworks. Advertising in outdoor settings (such as train stations or stadiums) is the responsibility of state and territory governments.[128]
  96. In addition to Commonwealth and state and territory governments, a set of independent third-party entities regulates the content of advertisements:
• The Australian Association of National Advertisers (AANA) Code of Ethics sets the overall standard for social responsibility that is expected of advertisers and marketers
• The Alcohol Beverages Advertising Code Responsible Alcohol Marketing Code (ABAC Code) sets out specific requirements for advertising alcoholic beverages across all traditional forms of media (television, radio, print and outdoor) as well as digital and social media marketing
• Ad Standards, established by AANA in 1998, is responsible for receiving complaints against these codes.[129]
  97. DITRDCA submitted that ‘most content broadcast on television and radio is regulated by co-regulatory codes of practice under BSA’.[130] Codes of practice are developed by industry in consultation with ACMA. Once ACMA is satisfied with a new or revised code, the code is then registered and becomes enforceable. The codes, as DITRDCA explained, do not currently apply to streaming services, as these are excluded under the BSA:

Noting the ACMA’s powers in relation to advertising are limited to the types of services regulated under the BSA, remedial directions and civil penalties cannot be pursued against online services under the ACCTS [Broadcasting Service (Australian Content and Children’s Television) Standards 2020] and industry codes, including subscription video-on-demand services, broadcast video-on-demand services and digital platforms.[131]

5.98In its submission, DITRDCA drew the Committee’s attention to recent proposals for a change in the regulation of free-to-air broadcast networks that could increase the extent to which children are exposed to alcohol advertising. The Commercial Television Industry Code of Practice 2015 (Commercial TV Code) was developed by Free TV Australia—the industry body representing Australia’s commercial free-to-air broadcast networks. The Code presently allows for alcohol advertising between 8.30pm and 5.00am, and between 12pm and 3pm on school days—periods when content is less likely to be viewed by children. The proposed changes to the Code would impact the times during which alcohol advertising is permitted, and potentially result in greater exposure of children to alcohol advertisements.[132] The Department of Health and Aged Care, as well as entities such as FARE, submitted that these changes would expose young people alcohol advertising, which could be harmful.[133]

5.99Multiple witnesses reflected on the link between alcohol consumption and the role of advertising and marketing, with ADF arguing that these practices promote positive attitudes towards alcohol, and are linked to an earlier initiation into and higher levels of drinking.[134]

5.100Much of the evidence presented during the course of the inquiry sought to highlight the shortcomings of the current regulatory framework. FARE noted in its submission that legislative and regulatory instruments (referred to as Liquor Acts and Regulations) across Australia’s states and territories were established decades ago, and expressed the view that many of these instruments are no longer fit for purpose:

We are also now moving into an environment in which existing controls on alcohol availability, which were designed with brick-and-mortar stores in mind, are no longer suitable in a world where every phone is a bottle shop and a billboard. These digital changes are not addressed in our laws, despite the rapid delivery of alcohol via online order being the fastest growing area for expansion in alcohol retail. This, in combination with digital marketing technologies which facilitate targeted, round-the clock advertising, creates a frictionless environment – where a targeted ad can, with one click, result in the rapid delivery of unlimited quantities of alcohol to an individual’s doorstep.[135]

5.101The Committee was concerned to receive evidence pertaining to the targeted promotion of alcohol on social media platforms, and the influence of online marketing on children and young people in particular.[136] The Committee also heard evidence pertaining to targeted marketing to frequent consumers, with evidence suggesting in Australia, 54 per cent of all alcohol is sold to 10percent of people who drink alcohol.[137]

5.102In its submission, Spirits and Cocktails Australia explained that the Alcohol Beverages Advertising Code (ABAC), was founded in 1998 by the alcoholic beverage industry and is overseen by the ABAC Scheme. The Commonwealth, through the Department of Health and Aged Care, is an observer on the ABAC Scheme.[138] The ABAC Scheme applies beyond traditional forms of advertising (television, radio, print and outdoor), encompassing the digital and social media environment.[139]

5.103DITRDCA further outlined the remit of the ABAC Scheme:

The ABAC Code applies to both traditional advertising mediums (television, radio, print and outdoor) and digital advertising, including user-generated content on social media, and provides that advertisements must not depict excessive or rapid alcohol consumption, market the strength of alcohol, or portray abstinence in a negative light. The Code also sets rules around not targeting minors, using imagery or language that is likely to appeal to minors, creating confusion with other products such as soft drinks, and strict rules on using minors in advertising.

The ABAC Code does not consider broader community concerns regarding alcohol advertising (for example, broader concerns in relation to health and safety). However, the regulatory-framework addresses these concerns through the AANA Code.

The ABAC Code places the onus on advertisers to comply with requirements around the advertising of alcohol.[140]

5.104In its submission, the ABAC Scheme explained that the scheme had 100 per cent voluntary compliance by its signatories, which included approximately 562 alcohol producers, distributors and retailers. The ABAC Scheme also drew the Committee’s attention to the National Alcohol Strategy, and in particular its objectives of reducing opportunities for the availability, promotion and pricing contributing to risky alcohol consumption, and minimising the promotion of risky drinking behaviours and other inappropriate marketing, noting that the Scheme is aligned with these aims.[141]

5.105The Department of Health and Aged Care informed the Committee that in July 2002, all Australian governments agreed to an industry and government review of Australia’s regulatory system for alcohol advertising and established the Australian Beverages Advertising Code (ABAC) Committee. The ABAC Committee reviews complaints about alcohol advertisements from members of the public, and its determinations are non-enforceable. The Department stated that self-regulation in this domain did not always produce optimal results, noting that:

… international and domestic evidence demonstrated that industry self-regulation of alcohol marketing is ineffective at reducing the negative impacts of advertising and at protecting vulnerable populations including underage youth.[142]

5.106AMA expressed particular concern about online alcohol advertising and the ‘lack of fit-for-purpose regulation to keep pace with emerging platforms and technologies’.[143] AMA further explained that:

During the COVID-19 pandemic, the marketing and accessibility of alcohol online boomed. Due to the increased use of digital advertising, children are more likely to see alcohol marketing in their day-to-day live than adults. This is due to digital platform use, with the lack of age-restriction regulation allowing easy access to alcohol companies’ social media accounts, websites and points of sale by default. The alcohol industry collects data through loyalty programs, which can be matched with social media data, to generate models that link purchase patterns with time of day, week or month, mood and social events. These algorithms can identify those who consume at a high-volume and disproportionately, because the algorithms work to identify the most susceptible consumers.[144]

5.107In a submission to the Australian Beverages Advertising Code (ABAC) Scheme Limited Responsible Alcohol Marketing Code Review, AMA called for a prohibition of marketing that targeted or appeals to children and young people. It further recommended a prohibition of alcoholic energy drinks and marketing that promoted the consumption of energy drinks in conjunction with alcohol. As part of its recommendations, AMA also sought a limitation of alcohol advertising and sponsorship at sporting events, a reduction of advertising exposure of young people, and the introduction of advertising that outlines the consumption limits recommended by NHMRC.[145]

5.108AMA echoed the view that self-regulation and voluntary codes are not effective in stemming inappropriate and irresponsible promotion of alcohol to younger people.[146] ADF submitted evidence to the same effect, and suggested that the current regulatory framework contains loopholes that allowed children to be ‘exposed to alcohol advertising in avoidable ways’:

As an example, alcohol advertising is banned from live TV during children’s viewing hours with the exception of televised sport. Research has found that in 2012 alone, children and adolescents in Australia received 51 million exposures to alcohol advertising through sport on TV. And whilst alcohol cannot be advertised during children’s viewing hours on live TV, this does not apply to broadcast video on demand (BVOD). This means children watching a show streamed at any time of the day, may be exposed to alcohol advertisements.[147]

Taxation regime

5.109The regulation of alcohol pricing through taxation presents another avenue for reducing alcohol related harm. The current alcohol taxation regime in Australia is composed of two main taxes: the alcohol excise and the wine equalisation tax (WET). The alcohol excise is a volumetric tax levied on producers of beers, spirits, and certain other alcohol products, at different rates, based on their volume of alcohol and other characters. WET is a 29 per cent tax paid by wine and certain other alcohol products made from fruit and vegetables (e.g. traditional ciders) on the value of the product produced.[148]

5.110In its submission, ADF set out the main differences between the two taxes:

• excise paid is generally based on the amount of alcohol contained within the product, whereas the WET is calculated on the monetary value of the product sold
• excise also differs based on characteristics including the product type, its packaging (e.g. keg or bottled), and whether the alcohol is sold for on or off-premises consumption
• excise is adjusted for inflation every six months in line with the consumer price index (CPI), while the WET is set at a consistent rate
• excise is set based on a certain amount per litre of pure alcohol in the product, rather than the volume of the total product itself.[149]
  111. ADF noted that when the price of a certain alcoholic beverage increases, those who drink at the riskiest levels tend to substitute for cheaper alcohol products. Under the current tax system, ADF argued that the availability of cheaper alcohol products under the WET can be seen to enable product substitution for individuals who are price sensitive. The organisation thus recommended that the federal government reform the alcohol taxation system in Australia by removing the WET and placing wine on the excise system. This approach would limit the sale of cheap, high alcohol-volume wine products that contribute to alcohol-related harms, such as cask wine.[150]
  112. Professor Diana Egerton-Warburton from the College for Emergency Medicine similarly stated that ‘our taxation system has been described as illogical’, noting:

I'd particularly like to highlight the wine equalisation tax as an issue which results in wine being able to be sold based upon the wholesale price rather than the amount of the volume of alcohol. So 65 per cent of wine sales are less than $8 for a bottle of wine. That equates to around 24 cents a standard drink for wine.[151]

5.113Professor Egerton-Warburton further highlighted the impact of the current alcohol pricing model:

Quite often—or almost always—in the emergency department, I ask people about their drinking habit, and it's that group of really problematic drinkers who are most affected by that price point. Sometimes when I ask the problem drinker, 'How much do you drink a day?' I get this response quite commonly: 'As much as I can afford to buy.' It's this group that target the really cheap alcohol and where we see a disproportionate amount of harm.[152]

5.114In reflecting on the availability and appeal of low-cost alcohol, Mr Benn Veenker, a lived experience advocate at Turning Point, noted:

There were numerous times when I would go paycheque to paycheque. I would have maybe $20 left in my wallet, and I would choose buying alcohol over food, but it would be a case of, 'I know I can buy a cask of wine for $4, and that's going to serve.' In those last few years of drinking, it was just cask wine, because it was cheap and available and easy to get.[153]

5.115Efforts to reduce alcohol consumption through price control can have certain limitations. Dr Paul Clark, Professor of Medicine at the University of Queensland and Director of the Alcohol and Drug Assessment Unit at Princess Alexandra Hospital, told the Committee that demand for alcohol in people with alcohol dependency is ‘relatively inelastic’:

You can increase the price of alcohol but you do not necessarily change the demand for alcohol in somebody with alcohol dependence. The impact of changing a price to volumetric pricing does not necessarily have the same effect on the part of the community that is not alcohol dependent. Unit pricing has a lot of benefits in moderating the alcohol intake in people with unformed binge pattern drinking, younger people who have more constraints on their expenditure and people who aren't alcohol dependent. It might use price to moderate consumption in a more interactive way, but it may not have the same effect on people who are severely alcohol dependent.[154]

5.116Increasing the price of alcohol can have an unintended impact on those who are alcohol dependent. As Dr Clark noted, people with alcohol dependency may spend greater portion of income on alcohol rather than seeing a reduction in their alcohol intake. There is also the potential for a rise in illegal alcohol production.[155]

Trading hours and outlet density

5.117In addition to pricing, trading hours and outlet density were identified as important factors shaping alcohol availability. While these elements of liquor licencing are controlled by the states and territories, ADF submitted that it was essential for the federal government to show leadership in ensuring a comprehensive, evidence-based approach to regulating alcohol availability.[156]

5.118Multiple witnesses expressed concern regarding the online sale and delivery of alcohol. ADF stated that:

Online sale and delivery facilitate easy access to alcohol late at night, when evidence shows assaults in the home are more likely to occur. This is of particular concern, given that alcohol related assaults increase substantially between 6pm and 3am, with 37 per cent of alcohol fuelled assaults occurring in the home and more than half (57%) of those being family violence.[157]

5.119ADF further drew attention to research indicating that the online sale and delivery of alcohol can increase the risk of harm by bypassing Responsible Service of Alcohol (RSA) processes, age verification, increasing rapid access (as quickly as 30 minutes after ordering), and encouraging extending drinking sessions.[158]

5.120Submission from Multicultural Women Victoria highlighted the impact of this practice:

It is horrifying for a family member to see alcohol being delivered to a heavily intoxicated family member […] It is our understanding that there is currently no obligation for online sales to operate under the same rules as pubs, restaurants and events. There are no links back to the point of sale if violence or injury occurs.[159]

5.121Expressing the view that there is an urgent need to address harms associated with online alcohol delivery, Ms Caterina Giorgi, FARE Chief Executive Officer, reiterated the need for a ban on alcohol delivery between 10pm and 10am, and recommended the introduction of a two-hour safety pause around delivery:

We should have a two-hour safety pause around deliveries, because we know that when people are delivered alcohol rapidly—so within 30 minutes or two hours—about 40 per cent of them say they drink 11 or more standard drinks […] Having a two-hour safety pause would mean that, if people order alcohol, it can be delivered to them two hours later and not sooner, and we know that that will then give people that friction point which will allow them to pause and reconsider. This is what governments need to do—help give people those friction points.[160]

5.122Representatives from the alcoholic beverages industry, however, noted that alcohol is a highly regulated industry, with manufacturers required to hold licences issued by the Australian Taxation Office, and state and territory liquor licences to manufacture and sell alcohol.[161] In response to concerns around the online sale of alcohol, industry representatives drew attention to the industry-developed the Retail Drinks Online Alcohol Sale and Delivery Code of Conduct, which is designed to enhance compliance in the responsible online sale of alcohol. These include self-exclusion requests, mandatory training for delivery drivers, a blanket ban on same day, unattended, alcohol deliveries and preventing alcohol deliveries to designated dry zones.[162] Further regulation, including taxation, could have adverse consequences, such as a proliferation of illegal alcohol.[163]

5.123In their submissions to the inquiry, industry representatives highlighted that the majority of Australians were drinking responsibly and in moderation.[164] Drawing on the AIHW data, Spirits and Cocktails Australia reiterated that alcohol consumption in Australia has declined, and that risky and heavy episodic drinking has reduced, along with overall consumption by young people. The organisation further highlighted that a cultural change was already underway as Australians are choosing to drink less, but higher-quality products.[165]

Public health campaigns

5.124DrinkWise outlined in its submission the initiatives that it had implemented with the aim of reducing alcohol-related harm. These include campaigns aimed at parents regarding the supply of alcohol to children (It’s okay to say nay), as well as initiatives pertaining to alcohol consumption during occasions such as school leavers’ week (Schoolie Survival Tips), or sport and music events. In noting the impact of the COVID-19 pandemic on youth mental health, the organisation highlighted its campaign to encourage young people to avoid relieving stress through alcohol consumption.[166]

5.125During the inquiry, the Committee heard repeated calls for a comprehensive, sustained and targeted public health campaign dedicated to AOD-related harms and the support that is available for those impacted. Professor Dan Lubman AM, Executive Clinical Director at Turning Point and Director of the Monash Addiction Research Centre, told the Committee:

We don't have any community public messaging around alcohol. In my time here over the last two decades, I've never seen a government advertising campaign promoting the idea that this is an actual health issue, that treatment is available and this is how you access treatment. We see that very much in the gambling space. I think one of the things we can say that is positive around gambling at the moment is that there is a very clear message around where to get help. There's no message about where to get help for alcohol and drug problems.[167]

5.126Professor Lubman further emphasised the need to shift the framing of AOD-related issues as a personal responsibility, and articulate AOD use as a health condition:

[T]here are prevailing community myths that alcohol, actually, is around personal responsibility; it's about bad people making bad choices. It's not about the fact that the drug is harmful, and that it can create health issues, and that there are opportunities to get help. We need to change that community perspective. Most people in the community don't believe that, when you have problems with alcohol and drugs, the treatment works. So people don't put up their hand for help, and they only put their hands up for help when things have got so bad that there's no other choice.[168]

5.127The need for a public campaign has been described as particularly urgent in the context of the raise in AOD-related problems triggered by the COVID-19 pandemic. As Professor Lubman noted:

What we saw during COVID was a huge increase in presentations for alcohol intoxications. […] We're inundated at the moment—both our work privately and, obviously, through Turning Point—with referrals for people who are struggling with their alcohol since COVID. And that's largely driven by the fact that it was widely available and actually endorsed as the key coping strategy for COVID. That was something that was commonly talked about, that alcohol is a way that everyone looked forward to knocking off from work at home and drinking. And the industry actually promoted alcohol parties.[169]

5.128Dr Paul Grinzi from the Royal Australian College of General Practitioners similarly told the Committee that he had seen a significant increase in new patients since COVID-19:

COVID lockdown flushed out people who had been drinking and now couldn't hide it because the family were around […] Then the prolonged lockdowns also gave people an opportunity to drink and then continue drinking, and they then found they couldn't stop.[170]

5.129Multiple witnesses pointed to Australia’s experience with tobacco control as an example of successful public health policy that can be applied to alcohol.[171] NCETA explained that ‘tobacco control policy reforms that have been implemented over the past 40 years in Australia have contributed to a 75 per cent reduction in smoking prevalence and significant reduction in disease burden’. Furthermore, ‘Australia has led the world in implementing bold reforms such as plain packaging, accompanied by graphic health warnings, education campaigns, bans on advertising, and increases in tobacco excises’. The lessons learned in this context could be applied to reduce alcohol-related harms.[172]

5.130Dr Clark argued that there is a need to re-frame public health messaging around alcohol dependence following the model used for the ‘stop smoking’ campaigns:

I think the cigarette anti-smoking education has actually moved towards trying to promote not smoking. That's a really important and subtle difference—a move from trying to educate people about the harms of smoking, warning them about what they're doing to their unborn baby and warning them about what they're doing to their lungs, to: 'Hey, this might be you jogging down the street if you don't smoke. You might be able to chase your kids around the park.'

Those sorts of public messages are actually very attractive. They create a positive health image around not drinking, rather than reinforcing a negative health image around drinking. People with alcohol dependency are already quite locked in to negative images about themselves. So those sorts of negative images don't help to break people out of the patterns of behaviour that they're already locked in to. Creating positive health images at a public health level does help people think about what they might like to be, rather than confirming what they're worried about already.[173]

Committee comments

5.131The Committee acknowledges that stigma associated with AOD use is a significant barrier to care. It is clear that tailored public campaigns and enhanced training in AOD-related issues for medical professionals could go a long way toward changing the perception of these issues, both among the general public and within the healthcare sector. The Committee also acknowledges the important impact that different harm reduction strategies have in preventing and responding to AOD use. Over the course of the inquiry, alcohol availability and the impact of alcohol advertising and marketing emerged as a major area of concern, and there is clearly an opportunity to develop a more up-to-date framework for managing exposure to and accessibility of alcohol in the internet age. Any such initiatives need to be coupled with a comprehensive public campaign about the health risks of alcohol consumption, which should be pursued as a priority.

Footnotes

[1]Windana, Submission 50, p. 5.

[2]Windana, Submission 50, p. 5; Queensland Network of Alcohol and Other Drugs (QNADA), Submission 75, p. 19.

[3]Professor Dan Lubman AM, Executive Clinical Director, Turning Point, Eastern Health; Director, Monash Addiction Research Centre, Committee Hansard, Melbourne, 29 October 2024, p. 9.

[4]QNADA, Submission 75, p. 19.

[5]Alcohol and Drug Foundation (ADF), Submission 77, p. 11.

[6]ACON, Submission 30, p. 7.

[7]QNADA, Submission 75, p. 19.

[8]Professor Carla Treloar, Submission 31, p. 1.

[9]ACON, Submission 30, p. 7.

[10]ACON, Submission 30, p. 7; See also Mind Australia, Submission 138, pp.4-5; Windana, Submission 50, p. 5.

[11]Professor Lubman AM, Turning Point, Eastern Health; Monash Addiction Research Centre, Committee Hansard, Melbourne, 29 October 2024, p. 17.

[12]National Centre for Education and Training on Addiction (NCETA), Submission 43, p. 4.

[13]Professor Kate Seear, Submission 33, p. 2.

[14]ADF, Submission 77, p. 11.

[15]Drug Policy Modelling Program, UNSW, Submission 17, p. 2.

[16]Drug Policy Modelling Program, UNSW, Submission 17, p. 2.

[17]Foundation for Alcohol Research and Education (FARE), Submission 87, p. 13.

[18]Professor Seear, Submission 33, pp. 5-6.

[19]Professor Seear, Submission 33, p. 7.

[20]QNADA, Submission 75, p. 16.

[21]Windana, Submission 50, pp. 2; 5-6.

[22]Department of Health and Aged Care, Submission 157, p. 14.

[23]QNADA, Submission 75, p. 19; ACON, Submission 30, p. 8.

[24]Professor Seear, Submission 33, p. 12.

[25]ACON, Submission 30, p. 8.

[26]Healthy Cities Illawarra, Submission 133, p. 2.

[27]Students for Sensible Drug Policy, Submission 59, p. 7; See also ACON, Submission 30, p. 8.

[28]ADF, Submission 77, p. 7.

[29]ADF, Submission 77, p. 29.

[30]ADF, Submission 77, p. 29.

[31]QNADA, Submission 75, p. 19.

[32]ADF, Submission 77, p. 48.

[33]ADF, Submission 77, p. 49.

[34]ADF, Submission 77, p. 49.

[35]ADF, Submission 77, p. 30.

[36]Parliamentary Joint Committee on Law Enforcement (May 2024), Australia’s illicit drug problem: Challenges and opportunities for law enforcement, p. xiii.

[37]ADF, Submission 77, p. 20.

[38]Drug Policy Modelling Program UNSW, Submission 17, p. 2.

[39]ADF, Submission 77, p. 22.

[40]SA Commissioner for Children and Young People, Submission 10, p. 6.

[41]Department of Education, Submission 126, p. 4.

[42]ADF, Submission 77, p. 22.

[43]ADF, Submission 77, pp. 22-23. See also DrinkWise, Submission 194, n.p.

[44]DrinkWise, Submission 192, n.p.

[45]Department of Education, Submission 126, p. 2.

[46]Department of Education, Submission 126, p. 2.

[47]Department of Education, Submission 126, p. 2.

[48]Department of Education, Submission 126, pp. 2-3.

[49]Alcohol and Drug Foundation, Submission 77; Department of Education, Submission 126; Australasian Injury Prevention Network, Submission 151; Heart Foundation, Submission 164; The George Institute, Submission 169.

[50]Department of Education, Submission 126, p. 3.

[51]Department of Education, Submission 126, p. 3; National Centre for Youth Substance Use Research (NCYSUR), Submission 120, pp. 13-14.

[52]Department of Education, Submission 126, p. 5.

[53]Department of Education, Submission 126, pp. 5-6.

[54]NCYSUR, Submission 120, p. 13.

[55]SA Commissioner for Children and Young People, Submission 10, p. 4; Students for Sensible Drug Policy, Submission 59, p. 21.

[56]Dr Adrian Farrugia, Submission 14, p. 5.

[57]Dr Farrugia, Submission 14, p. 2.

[58]Students for Sensible Drug Policy Australia, Submission 59, p. 21.

[59]ADF, Submission 77, pp. 31-32.

[60]NCYSUR, Submission 120, p. 14.

[61]ACT Government, ‘Drug checking.’

[62]NCYSUR, Submission 120, pp. 11-12.

[63]ADF, Submission 77, p. 26.

[64]New South Wales Council for Civil Liberties, Submission 28, pp.4-5.

[65]Alcohol, Tobacco and other Drugs Council (Tasmania), Submission 22; NCYSUR, Submission 120; ACON, Submission 80; ADF, Submission 77; New South Wales Council for Civil Liberties, Submission 28; Healthy Cities Illawarra, Submission 133; Students for Sensible Drug Policy Australia, Submission 59.

[66]Australian Medical Association (AMA), Submission 80, p. 6.

[67]Mr Cameron Francis, Chief Executive Officer, The Loop Australia, Committee Hansard, 30 October 2024, p. 15.

[68]Mr Francis, The Loop Australia, Committee Hansard, 30 October 2024, p. 15.

[69]Mr Francis, The Loop Australia, Committee Hansard, 30 October 2024, pp. 18-19.

[70]New South Wales Council for Civil Liberties, Submission 28, p. 4.

[71]NCYSUR, Submission 120, p. 12.

[72]Professor Seear, Submission 33, p. 18.

[73]The Pharmacy Guild of Australia, Submission 52, p. 6.

[74]Professor Seear, Submission 33, p. 18.

[75]Professor Seear, Submission 33, p. 18.

[76]Professor Seear, Submission 33, p. 18.

[77]The Pharmacy Guild of Australia, Submission 52, p. 7.

[78]The Pharmacy Guild of Australia, Submission 52, p. 4.

[79]The Pharmacy Guild of Australia, Submission 52, p. 4.

[80]The Pharmacy Guild of Australia, Submission 52, p. 4.

[81]Dr Simon Holliday, Submission 9, p. 10.

[82]Dr Holliday, Submission 9, pp. 9-12.

[83]Dr Holliday, Submission 9, p. 11.

[84]Dr Holliday, Submission 9, p. 11.

[85]The Pharmacy Guild of Australia, Submission 52, p. 5.

[86]The Pharmacy Guild of Australia, Submission 52, pp. 5-6.

[87]The Pharmacy Guild of Australia, Submission 52, p. 5.

[88]ADF, Submission 77, p. 27.

[89]The Pharmacy Guild of Australia, Submission 52, p. 5.

[90]Students for Sensible Drug Policy Australia, Submission 59, p. 24.

[91]Students for Sensible Drug Policy Australia, Submission 59, p. 24.

[92]The Pharmacy Guild of Australia, Submission 52, p. 5.

[93]NCYSUR, Submission 120, p. 13.

[94]Legal Aid Commission of New South Wales (Legal Aid NSW), Submission 18, p. 6.

[95]Legal Aid Commission of New South Wales (Legal Aid NSW), Submission 18, pp. 18-20.

[96]Legal Aid Commission of New South Wales (Legal Aid NSW), Submission 18, pp. 19-20.

[97]AMA, Submission 80, p. 8.

[98]Legal Aid Commission of New South Wales (Legal Aid NSW), Submission 18, p. 22.

[99]Community Restorative Centre, Submission 56; Australian Dental and Oral Health Therapists’ Association, Submission 63; NSW Users and AIDS Association (NUAA), Submission 198.

[100]Legal Aid Commission of New South Wales (Legal Aid NSW), Submission 18, pp. 20-21.

[101]Centre for Alcohol Policy Research, La Trobe University, Submission 21, p. 2.

[102]Dr Holliday, Submission 9, p. 9.

[103]FARE, Submission 87, p. 22.

[104]Australian College for Emergency Medicine (ACEM), Submission 95, p. 4.

[105]Mrs Sophie Harrington, Interim Chief Operating Officer, National Organisation for Fetal Alcohol Spectrum Disorders (NOFASD), Proof Committee Hansard, Canberra, 7 February 2025, p. 20. See also Ms Jessica Birch, private capacity, Proof Committee Hansard, Canberra, 7 February 2025, p. 16; Ms Angelene Bruce, private capacity, Proof Committee Hansard, Canberra, 7 February 2025, p. 21.

[106]AMA, Submission 80, p. 2.

[107]Queensland Nurses and Midwives’ Union (QNMU), Submission 34, p. 3; see also FARE, Submission 87, p. 10.

[108]National Health and Medical Research Council (2020), Australian guidelines to reduce health risks from drinking alcohol, p. 2.

[109]Spirits and Cocktails Australia, Submission 113, p. 24.

[110]Spirits and Cocktails Australia, Submission 113, p. 24.

[111]ADF, Submission 77, p. 25; FARE, Submission 87, p. 20; Cancer Council Australia, Submission 110; National Heart Foundation of Australia, Submission 164, p. 7; Alcohol Change Vic., Submission 166, p. 11; DrinkWise, Submission 192, n.p.

[112]AMA, Submission 80, p. 10.

[113]ADF, Submission 77, p. 25.

[114]Department of Health and Aged Care, Submission 157, p. 13.

[115]AMA, Submission 80; FARE, Submission 87; Royal Australian College of General Practitioners (RACGP), Submission 84; ADF, Submission 77; Cancer Council Australia, Submission 110.

[116]Department of Health and Aged Care, Submission 157, p. 16.

[117]Department of Health and Aged Care, Submission 157, p. 16.

[118]ADF, Submission 77, p. 34.

[119]The U.S. Surgeon General’s Advisory (January 2025), Alcohol and Cance Risk, p. 17.

[120]ADF, Submission 77, p. 34.

[121]ADF, Submission 77, p. 44.

[122]ADF, Submission 77, p. 34.

[123]AMA, Submission 80, p. 5.

[124]Food Standards Australia and New Zealand, ‘Energy labelling of alcoholic beverages’.

[125]Spirits and Cocktails Australia, Submission 113, pp. 29-30.

[126]Centre for Alcohol Policy Research, La Trobe University, Submission 7, p. 1; NCETA, Submission 43, p. 5.

[127]Department of Infrastructure, Transport, Regional Development, Communication and the Arts (DITRDCA), Submission 197, p. 3.

[128]DITRDCA, Submission 197, p. 3.

[129]DITRDCA, Submission 197, p. 3.

[130]DITRDCA, Submission 197, p. 4.

[131]DITRDCA, Submission 197, pp. 4-5.

[132]DITRDCA, Submission 197, p. 5.

[133]Ms Caterina Giorgi, Chief Executive Officer, Foundation for Alcohol Research and Education (FARE), Proof Committee Hansard, Canberra, 7 February 2025, p. 6; Mr Ben Mudaliar, Assistant Secretary, Alcohol and Other Drugs Branch, Department of Health and Aged Care, Proof Committee Hansard, Canberra, 7 February 2025, p. 31.

[134]ADF, Submission 77, p. 34.

[135]FARE, Submission 87, p. 17.

[136]ADF, Submission 77, pp. 34-35; Department of Education, Submission 126.

[137]FARE, Submission 87, p. 8; See also Dr Erin Lalor, Chief Executive Officer, Alcohol and Drug Foundation, Committee Hansard, Melbourne, 28 October 2024, p. 8.

[138]DITRDCA, Submission 197, p. 7.

[139]Spirits and Cocktails Australia, Submission 113, p. 15.

[140]DITRDCA, Submission 197, p. 7.

[141]The ABAC Scheme Limited, Submission 139, p. 3.

[142]Department of Health and Aged Care, Submission 157, p. 17.

[143]AMA, Submission 80, p. 12.

[144]AMA, Submission 80, p. 12.

[145]AMA, Submission 80, p. 5.

[146]AMA, Submission 80, p. 5.

[147]ADF, Submission 77, p. 35.

[148]ADF, Submission 77, p. 36.

[149]ADF, Submission 77, p. 36.

[150]ADF, Submission 77, p. 36.

[151]Professor Diana Egerton-Warburton, Representative, Public Health and Disaster Committee, Australasian College for Emergency Medicine (ACEM), Committee Hansard, Melbourne, 29 October 2024, p. 47.

[152]Professor Egerton-Warburton, ACEM, Committee Hansard, Melbourne, 29 October 2024, p. 47.

[153]Mr Benn Veenker, Manager, Lived Experience, Workforce and Advocacy, Turning Point, Eastern Health, Committee Hansard, Melbourne, 29 October 2024, p. 18.

[154]Dr Paul Clark, Director, Alcohol and Drug Assessment Unit, Princess Alexandra Hospital, Brisbane, Proof Committee Hansard, Canberra, 7 February 2025, p. 22.

[155]Dr Clark, Princess Alexandra Hospital, Brisbane, Proof Committee Hansard, Canberra, 7 February 2025, pp. 22-23.

[156]ADF, Submission 77, p. 37.

[157]ADF, Submission 77, p. 37.

[158]ADF, Submission 77, p. 37.

[159]Multicultural Women Victoria, Submission 130, p. 5.

[160]Ms Giorgi, FARE, Proof Committee Hansard, Canberra, 7 February 2025, p. 5.

[161]Spirits and Cocktails Australia, Submission 113, p. 14; Alcohol Beverages Australia, Submission 61, p. 4.

[162]Retail Drinks Australia, Submission 105, n.p; Spirits and Cocktails Australia, Submission 113, p. 16; Alcohol Beverages Australia, Submission 61, p. 10.

[163]Spirits and Cocktails Australia, Submission 113, p. 26; Independent Brewers Association, Submission 117, n.p; Alcohol Beverages Australia, Submission 61, p. 14.

[164]Spirits and Cocktails Australia, Submission 113, p. 3; Alcohol Beverages Australia, Submission 61, n.p.; Brewers Association of Australia, Submission 83, n.p.

[165]Spirits and Cocktails Australia, Submission 113, p. 3; See also Independent Brewers Association, Submission 117, n.p.; Retail Drinks Australia, Submission 105, n.p.

[166]DrinkWise, Submission 192.

[167]Professor Lubman AM, Turning Point, Eastern Health; Monash Addiction Research Centre, Committee Hansard, Melbourne, 29 October 2024, p. 11.

[168]Professor Lubman AM, Turning Point, Eastern Health; Monash Addiction Research Centre, Committee Hansard, Melbourne, 29 October 2024, p. 11.

[169]Professor Lubman AM, Turning Point, Eastern Health; Monash Addiction Research Centre, Committee Hansard, Melbourne, 29 October 2024, p. 11.

[170]Dr Paul Grinzi, Member, RACGP Specific Interest Group, Addiction Medicine, Royal Australian College of General Practitioners, Committee Hansard, Melbourne, 29 October 2024, p. 27.

[171]NCETA, Submission 43; Alcohol Change Australia, Submission 76; Public Health Association Australia, Submission 106.

[172]NCETA, Submission 43, pp. 4-5.

[173]Dr Clark, Princess Alexandra Hospital, Brisbane, Proof Committee Hansard, Canberra, 7 February 2025, p. 23.