3. Australia's alcohol and other drugs policy and research
   1. This chapter analyses the policy framework that shapes Australia’s response to alcohol and other drugs (AOD). Central to this discussion is the widespread call to establish a national governing body for the AOD sector, along with debate pertaining to the current funding landscape. The chapter also examines Australia’s AOD-related data collections and explores strategies to enhance the nation’s capacity to gather and utilise this critical information.
   2. While the evidence outlined in this chapter focuses on health-based approaches to AOD use, input from the criminal justice system and law enforcement agencies is vital in forming a comprehensive understanding of the key issues. Further evidence from these areas will be required to develop an effective policy response.

Alcohol and other drugs policy landscape

3.3In Australia, responsibility for AOD is shared by all levels of government, and across both health and law enforcement agencies. In its submission, the Department of Health and Aged Care stated that over time AOD policies have tended to emphasise health more than law enforcement response. According to the Department, the fact that a health-led policy approach has gained dominance across the world represents a recognition that substance dependence is primarily a health and social issue, rather than a criminal justice or moral issue.[1]

3.4The Australian Government uses a range of instruments to guide the national AOD response, including:

• The National Drug Strategy 2017-2026
• Statutory and delegated regulation covering the labelling standards, importation, exportation, manufacture, production and cultivation of controlled substances
• Restrictions on alcohol advertising
• Guidelines covering alcohol consumption
• Funding for prevention and treatment services
• Funding for relevant research and evaluation.[2]
  5. The National Drug Strategy is Australia’s framework for addressing the adverse impacts of AOD use. Set around a 10-year framework covering the period from 2017 to 2026, the Strategy aims to reduce the harmful effects of alcohol, tobacco and other drugs. There are several sub-strategies and national frameworks under this document, which focus on specific issues and cover different time periods:
• National Aboriginal and Torres Strait Islander People Drug Strategy 2014-2019
• National Alcohol and Other Drug Workforce Development Strategy 2015-2018
• National Alcohol Strategy 2019-2028
• National Fetal Alcohol Spectrum Disorder (FASD) Strategic Action Plan 2018-2028
• National Ice Action Strategy 2015
• National Tobacco Strategy 2023-2030
• National Framework for Alcohol, Tobacco and Other Drug Treatment 2019-2029
• National Quality Framework.[3]
  6. The shift towards a harm minimisation approach in drug policy occurred in Australia in response to the HIV/AIDS epidemic in the 1980s. The current National Drug Strategy reflects the health-led approach; it acknowledges a wide range of health, social, and economic harms resulting from AOD use, and emphasises the need for a coordinated response to reduce these harms.[4]
  7. The approach to harm minimisation within the Strategy is structured around three pillars: demand reduction (preventing the uptake or delaying the onset of use of alcohol, tobacco and other drugs), supply reduction (preventing or reducing the supply of illegal drugs, and controlling the availability of legal drugs), and harm reduction (reducing the adverse health, social and economic consequences of AOD use). The Strategy further identifies three priority areas for implementation:
• priority actions (such as, for example, enhanced access to treatment and development of AOD research and data)
• priority populations (with 7 at-risk population cohorts identified)
• priority substances (methamphetamine, alcohol, tobacco, cannabis, non-medical use of pharmaceutical, opioids, and new psychoactive substances).[5]
  8. The Strategy exists in parallel with other policy instruments. In particular, it aligns with the National Preventative Health Strategy 2021-2030, which includes four targets for reducing AOD related harm:
• at least a 10 per cent reduction in harmful alcohol consumption by Australians (≥14 years) by 2025, and at least a 15 per cent reduction by 2030
• less than 10 per cent of young people (14–17-year-olds) are consuming alcohol by 2030
• less than 10 per cent of pregnant women aged 14-49 are consuming alcohol whilst pregnant by 2030
• at least a 15 per cent decrease in the prevalence of recent illicit drug use (≥14 years) by 2030.[6]
  9. Some states and territories also have their own AOD strategies. These documents broadly align with the Natural Drug Strategy, seeking to achieve harm minimisation through demand, supply and harm reduction:
• ACT Drug Strategy Action Plan 2022-2026
• The Queensland Alcohol and Other Drugs Plan 2022-2027
• South Australian Alcohol and Other Drug Strategy 2024-2030
• Reform Agenda for the AOD Sector in Tasmania and the Tasmanian Drug Strategy 2024-2029.[7]
  10. In the Northern Territory, the response to reducing AOD harms is guided by several national strategies, including the National Drug Strategy 2017-2026, its sub-strategies, and the National Pharmaceutical Drug Misuse Framework 2012-2015. The Northern Territory also has a strategy focused specifically on fetal alcohol spectrum disorder, entitled Addressing Fetal Alcohol Spectrum Disorder (FASD) in the Northern Territory 2018-2024.
  11. The Western Australian government is currently developing a new Mental Health and Alcohol and Other Drug Strategy 2025-2030 and Outcomes Measurement Framework, which will replace the Western Australian Alcohol and Drug Interagency Strategy 2018-2022. In July 2024, the Western Australian Government also established a new Office of Alcohol and Other Drugs.[8]
  12. While New South Wales does not currently have a state-level strategy (the most recent one expired in 2010), during the NSW Drug Summit held in late 2024, the AOD sector called for the development of a state-level AOD instrument.[9] Meanwhile, in Victoria, the Victoria Police Drug Strategy 2020-2025 and a Statewide Action Plan aimed at reducing drug related harms both frame the AOD response.
  13. Multiple witnesses drew the Committee’s attention to the complexity of the AOD policy landscape (which includes a multiplicity of strategies with varied timeframes) and argued that the absence of national coordination presents a major impediment to the sector’s effective functioning.[10]
  14. A national level governing body for the AOD sector was originally established as part of the National Ice Action Strategy in 2015. Indeed, the Council of Australian Governments (COAG) established the Ministerial Drug and Alcohol Forum (MDAF) at the time, which was responsible for the oversight, development, implementation and monitoring of Australia’s national drug policy frameworks and reported directly to COAG. MDAF was removed in 2020, when COAG was replaced by National Cabinet. Since then, there has been no formal oversight over the implementation or coordination of AOD strategies across jurisdictions.[11]
  15. There are at present certain mechanisms that allow AOD-related matters to be addressed at a ministerial level, although these tend to be ad hoc in nature, and are not focused on AOD use alone. Mr Ben Mudaliar, Assistant Secretary, Alcohol and Other Drugs Branch at the Department of Health and Aged Care, explained:

The Health Ministers Meeting and the Health Chief Executives Forum, which sits underneath it, do provide a mechanism for ministers and for jurisdictions to come together. And there are opportunities, through things like the Health Ministers Meeting, for them to invite ministerial colleagues from other sectors. I suppose the issue is that they have a broad spectrum of issues that they need to attend to. We have seen health ministers deal with things like opioid dependence issues and the kinds of policy reforms we need in that space.[12]

3.16In its submission, Alcohol, Tobacco and other Drugs Council Tasmania identified the lack of coordination and communication between and from the Commonwealth and state governments as a major challenge for the AOD sector.[13] The Australian Alcohol and Other Drugs Council (AADC), the Alcohol and Drug Foundation (ADF) and the National Centre for Education and Training on Addiction (NCETA) each highlighted that this situation inhibited a dialogue between the AOD sector, different tiers of government, funding and commissioning bodies, and other relevant stakeholders. Furthermore, the abolition of the MDAF deprived the sector of the ability to act proactively in response to new issues such as, for example, vaping, the online sale and delivery of alcohol, emerging contaminants in the drug supply, or responses to opioid dependence treatment.[14]

3.17AADC added that, in the absence of a national governance structure, there is a lack of monitoring of current strategies, sub-strategies and frameworks that guide AOD work.[15] As a result, there had been no mid-point review of either the National Drug Strategy 2017-2026 or the National Alcohol Strategy 2019-2028, while the National Aboriginal and Torres Strait Islander People’s Drug Strategy and National Alcohol and Other Drug Workforce Development Strategies both lapsed without a review of outcomes.[16]

3.18The Matilda Centre for Research in Mental Health and Substance Use at the University of Sydney (the Matilda Centre) drew attention to the fact that the lack of national oversight had a direct impact on the implementation of standards for AOD services. In 2018, the Australian Government introduced the National Quality Framework for Drug and Alcohol Treatment Service (NQF), which was intended to have an implementation period from 2019 to 2022 under MDAF guidance. Since the disbandment of MDAF, however, ownership of the NQF has not been transferred to any other national body.[17]

3.19In its submission, the Queensland Network of Alcohol and Other Drug Agencies (QNADA) expressed concern about the lack of NQF monitoring and implementation, noting that:

While the majority of the funded AOD service sector provides evidence-based, safe, high-quality care, stigma around substance use and the root causes of substance use problems means anyone can establish a residential service and make untested claims about their approach.[18]

3.20While there are high levels of compliance among funded providers in the public and non-government sector, QNADA submitted that ‘the status of providers not receiving government funding is more difficult to establish, as there is no mechanism requiring them to be licenced to provide treatment’.[19] The Matilda Centre highlighted that findings from two recent inquiries into Victorian and Western Australian private AOD sectors ‘both advocated for consistent, nation-wide regulation to protect clients from poor treatment outcomes and abuse’.[20]

3.21The Committee also heard evidence that the complexity of AOD cases necessitated cross-sector collaboration. Such collaboration would see closer engagement between mental health, disability, housing, employment and education sector in AOD service provision. A national governance body has been recommended as an optimal forum for coordinating these different areas.[21]

3.22A national governing structure was also identified as a channel through which individuals with living or lived experience of AOD use could be better heard. Throughout the inquiry, witnesses repeatedly drew attention to the importance of this cohort in the design of policies and the delivery of services. In its submission, the Foundation for Alcohol Research and Education (FARE), stated that there is a need for a national network of AOD lived experience advisory groups, to ensure that policy and programs reflected people’s experiences, and that these should comprise diverse communities with lived experience of harm, such as domestic and family violence, mental health disorders, FASD and chronic disease. As FARE explained:

A focus on data alone can sometimes obscure the real-life pain, suffering and trauma experienced by people harmed by alcohol, as well as the far-reaching ripple effects on the health and wellbeing of their families and loved ones. Engaging people with lived and living experience as active partners in co-design and co-production ensures policies are informed by people who are most affected by them.[22]

A health-led policy response

3.23Evidence gathered during this inquiry points to a growing recognition that social, economic and environmental conditions are key contributors to AOD use. The Committee also heard that legal and criminal sanctions are ineffective and costly responses.[23] According to the Youth Support and Advocacy Service (YSAS) and the AADC, government policy approaches that reduce criminal sanctions for some drug offences (personal drug possession and use), and strengthen AOD prevention, treatment and rehabilitation measures have been demonstrated as most effective.[24]

3.24Throughout the inquiry, witnesses highlighted the fact that a shift in response to the possession and use of illegal drugs from the justice to health sector is taking place across the world. The Global Commission on Drug Policy, for example, has advocated for the decriminalisation of drugs for individual use for more than a decade.[25] In addition, several United Nations agencies, such as the Joint United Nations Programme on HIV/AIDS, the World Health Organization, the United Nations Development Programme, and the Office of the United Nations High Commissioner for Human Rights have all expressed the view that the possession of drugs for personal use should be decriminalised.[26]

3.25Notably, several countries have already undertaken drug policy reform of this nature, redeploying resources previously dedicated to policing and criminal justice into drug treatment. Portugal and Canada were most frequently cited as exemplars of this approach during the inquiry.[27] Dr Jeremy Hayllar, Clinical Director at Metro North Mental Health Alcohol and Drug Service, Queensland Health, for example, shared his view of the Portuguese model:

I went to Portugal in 2018 with the mental health commissioner, and it was really interesting. They took a very bold step in 2001 to change the whole approach. They weren't trying to avoid the big criminals at the top, who were doing all the dealing and supplying. It was mainly the street dealers that were no longer going to be taken into custody, locked up and tried, et cetera. They had dissuasion commissions around the country where people would attend for a session, and that was it. They might have a small fine. The worry was that this might encourage people to use more substances. It has not done so at all. Compared with countries nearby—Spain and other European countries—there has really been no significant increase in substances. Whereas, the rate of overdoses, which was the chief driver for this change, has dropped precipitously. I think by most standards it has been very, very effective.[28]

3.26The Department of Health and Aged Care noted that Australia’s approach to drug policy can be considered progressive in the international context.[29] Professor Kate Seear and her colleagues from the Australian Research Centre in Sex, Health and Society at La Trobe University further explained that in 2021, Australia ranked fifth out of 30 countries in the Global Drug Policy Index, behind Norway, New Zealand, Portugal and the United Kingdom.[30]

3.27The Australian Research Centre in Sex, Health and Society noted that the Global Drug Policy Index, a project of the Harm Reduction Consortium that gathers a range of civil society and community organisations, scored each country out of 100 on a range of different measures, and also provided an overall score out of 100. Australia’s overall score was 65/100, and although Australia did well on some measures, it scored poorly on others, including equity of impact of criminal justice responses (25/100), imprisonment for non-violent drug offences (25/100), decriminalisation (33/100), equity of access to harm reduction (33/100).[31]

3.28This result echoes evidence from several witnesses who, while viewing Australia’s drug policy positively, argued that there was a need for a more decisive shift away from the law enforcement and toward a health-led response to AOD harm.[32] In its submission, QNADA called for a reframing of Australia’s current drug policies to a narrative that emphasised drug use harm as health issues and acknowledged that dependent, problematic illicit drug use is a minority experience.[33]

3.29Echoing the findings of the Global Drug Policy Index, QNADA submitted that drug legislation and policy tend to have disproportionate and compounding impacts for lower socio-economic and marginalised populations. In a 2020 survey that QNADA undertook together with the Queensland Injectors Voice for Advocacy and Action (QuIVAA) and the Queensland Aboriginal and Islander Health Council’s Substance Misuse Council (QAIHC/QISMC), many participants cited police harassment and other legal consequences associated with AOD use (court, probation, parole, child safety and imprisonment) as the primary areas of concern.[34]

3.30The Committee acknowledges the important role of law enforcement in drug related harm reduction. In its submission, Australian Federal Police (AFP) noted that the agency prioritised offshore detections, disruption and deterrence to stop illicit drugs at their source of origin or transit points. In 2023-24, the AFP seized 34 tonnes of illicit drugs and precursors, resulting in an estimated $12.5 billion in harm avoidance. The agency also assistant in the seizure of 36.5 tonnes of illicit drugs by overseas police.[35]

3.31The AFP also focuses on disrupting transnational, serious and organised crime figures, who are responsible for importing high volumes of illicit drugs. The AFP submitted that, in 2019-20 Australia’s cocaine consumption increased by 38 per cent. Between July 2020 and December 2022, however, AFP seized approximately 12.5 tonnes of cocaine (more than double the annualised average consumption of approximately 5 tonnes). These actions may have contributed to Australia’s cocaine consumption decreasing 40 per cent (2.29 tonnes) from 2019-20 to 2021-22 and falling to historic lows in 2022.[36]

3.32While the supply reduction is undoubtedly an important aspect of the national AOD response, multiple witnesses expressed concern that Australia’s response to illicit drugs is disproportionately weighted toward law enforcement. Entities such as QNADA, YSAS, and AADC claimed there was an imbalance in Australia’s response reflected in funding across the three pillars of harm minimisation within the National Drug Strategy, being the demand reduction (prevention and treatment), supply reduction (law enforcement), and harm reduction (initiatives such as, for example, needle and syringe programs).[37]

3.33In 2024, the Drug Policy Modelling Program within the UNSW Social Policy Research Centre published its analysis of Australian ‘drug budget’ for the financial year 2021/22 across four policy domains: prevention, treatment, harm reduction, and law enforcement. Of the total $5.45 billion (0.63 per cent of government expenditure), law enforcement received 64.3 per cent, treatment 27.4 per cent, prevention 6.7 per cent, with harm reduction allocated 1.6 per cent.[38]

3.34AADC expressed concern that while multiple AOD related inquiries since 2018 have identified a need for more balance across the three pillars of the National Drug Strategy, ‘law enforcement, criminalisation and supply reduction actions lead Australia’s response to AOD use and harms’.[39] Funding for law enforcement interventions, AADC reiterated, outweighed health responses by a factor of almost 2:1.[40]

3.35AADC further submitted that ‘despite the emphasis on law enforcement and supply reduction as the primary means to respond to illicit drug use in Australia, these efforts do relatively little to reduce the availability and use of illicit substances in the absence of a corresponding investment in demand reduction measures’.[41] According to a study undertaken by the UNSW National Drug and Alcohol Research Centre, 18per cent of Australians aged 14 and over have used an illicit substance in the past 12 months, and 43 per cent have used an illicit substance at some point in their lives, with the majority of illicit drug types being rated as ‘easy’ or ‘very easy’ to obtain.[42]

3.36For AADC, an over-emphasis on law enforcement and supply reduction under a framework of drug criminalisation comes at significant cost to community health and wellbeing. Drug criminalisation tends to incentivise the supply of more potent substances of unknown quality, increasing the risk of fatal and non-fatal overdoes, driving an increase in the transmission of blood borne viruses, encouraging risky consumption practices through fear of police and other means of detection, and creating barriers to AOD treatment, employment, and social inclusion.[43]

3.37Meanwhile, multiple witnesses emphasised the value of investing in a health-led response. Drawing on Australian Institute of Criminology data, the Australian Alcohol and Drugs Council claimed that for every $1 invested in AOD treatment, $5.40 is returned in benefit to the community—but for every $1 invested in harm reduction programs, $27 is returned in community benefit.[44]

Service delivery and funding

3.38At the Commonwealth level, AOD treatment programs are funded primarily through

• direct funding from the Department of Health and Aged Care
• direct funding from the National Indigenous Australians Agency under strategies such as the Indigenous Advancement Strategy
• commissioning via the 31 Primary Health Networks across the country
• other time-limited supplementary budget measures, such as the Drug and Alcohol Treatment Services Maintenance (DATSM) program, Wage Cost Indices (WCI) and Community Sector Organisation (CSO) payments.[45]
  39. Most AOD treatment in Australia is provided through the specialist AOD system and the generalist health service system. The specialist AOD system provides withdrawal, psycho-social therapies, residential rehabilitation, and pharmacotherapy maintenance, among other treatment types. The generalist service system provides a similar set of treatments, with GPs providing pharmacotherapy maintenance and brief interventions; clinical psychologist providing psycho-social therapy (counselling); general hospitals provide withdrawal services; and welfare services that can also provide psycho-social therapy.[46]
  40. Since 2015, the Australian Government has commissioned Primary Health Networks (PHNs) to provide funding for locally based AOD treatment services in line with community need. PHNs are independent organisations that are funded to coordinate primary health care in their designated region.[47] PHNs are allocated operational and flexible general grant funding (which could be used for AOD treatment services); they also receive additional flexible funding for AOD services through the Australian Government’s Drug and Alcohol Program.[48]
  41. As such, PHNs are responsible for most specialist AOD treatment planning and commissioning. They work in consultation with state and territory government regional health services, jurisdictional and national drug and alcohol peak bodies and relevant stakeholders, including Local Hospital Networks (LHNs), Aboriginal Community Controlled Health Organisations (ACCHOs) and other service providers.[49] More than $400 million in funding for the AOD sector has been commissioned through PHNs since their establishment, making them a major funder of AOD services.[50]
  42. In its submission, the Victorian-Tasmanian Primary Health Networks Alliance explained that PHN commissioned services focus on community codesign, equity, and cost-effective care models that align with the needs of specific populations. In metro Victoria, for example, PHN commissioned programs include initiatives such as Rainbow Recovery that are designed for LGBTIQA+ communities by offering peer-led, culturally appropriate AOD services for this population; Bendigo District Aboriginal Cooperative was commissioned to pilot Therapeutic Day Rehabilitation programs that allow individuals to access intensive alcohol and other drug treatment while remaining within their communities.[51]
  43. Multiple witnesses emphasised that the complexity of funding arrangements hinders the work of the AOD sector. AADC, for example, illustrated some shortcomings of the current funding system by noting that:

… a single service may be funded for different activities through multiple funding streams at the Commonwealth level – each requiring its own application, management, reporting and reconciliation – as well as potentially a range of different State and Territory funding streams.[52]

3.44Similarly, Mr Geoffrey Davey, Chief Executive Officer of the Queensland Injectors Health Network (QuIHN) said:

QuIHN relies on 18 different contracts to run its programs. That creates a patchwork of funds, which actually raises a number of administrative and financial risks; it creates a house of cards. Also, we navigate multiple recording and compliance requirements, with numerous funding applications and extensions of contracts that have varying timelines.[53]

3.45The absence of national governance adds an additional layer of complexity to the task of achieving integrated planning and prioritisation of funding allocation, with the AADC further noting: ‘The result is for example different agencies prioritising funding for the same location, while completely missing or under-funding other locations’.[54]

3.46The Committee also heard about inconsistencies in the application of indexation on Commonwealth funding contracts. In some instances where indexation has been applied, the rates were significantly below those applied by state and territory governments, which resulted in a significant reduction in funding in real terms.[55] Supplementary budget measures have been introduced to address some of these issues, but as the Committee understands the situation, while these payments were necessary for addressing current funding shortfalls, they have not been rolled into core sector funding.[56] To address this problem, the Glen Group, an Aboriginal Community Controlled Organisation that operates rehabilitation centres in NSW, recommended embedding indexation in funding agreements.[57]

3.47The short-term nature of many commissioning contracts in the sector has been identified as a major driver of funding instability. AADC noted that the Commonwealth makes use of grant making processes, which are often three years or less in length. As consequence, the sector was hindered by:

A commissioning environment that requires frequent recommissioning due to short contract lengths, necessitating services to re-direct their resources, and late contract executions and other delays that often result in services whose main source of funding is through the Australian Government, being required to cover funding gaps. In addition, for regional, rural and remote services, funding and commissioning processes frequently do not account for the higher cost of service provision outside of metropolitan areas. These factors contribute to an overall picture of funding instability and insecurity, leading to challenges in workforce retention, and resulting in services working around – rather than in partnership with – funding bodies to deliver outcomes.[58]

3.48QNADA reiterate this point, and informed the Committee that:

… less than one fifth of NGO AOD providers across Australia have some portion of their funding as recurrent. Despite relaying on community-based NGOs to provide 71 percent of all treatment episodes nationwide, the funding and purchasing arrangements for these services serve to increase organisational instability and vulnerability.[59]

3.49QNADA further noted that the Commonwealth’s ‘stop-start funding arrangements and last-minute contract renewals impact the ability of services to develop and maintain a skilled and available workforce …’[60]

3.50AADC insisted that contracting and commissioning issues were ‘frequently most acutely felt through PHN commissioning processes’, and explained that:

Delays in the Australian Government confirming ongoing funding for the PHN program create flow-on contract execution delays for commissioned AOD services. In addition, budget measures such as CSO, WCI and DATSM are not automatically applied to PHN funding contracts and where they are, the level of discretion individual PHNs have in applying these budget measures creates additional instability and insecurity within the AOD sector.[61]

3.51In its submission, the Victorian-Tasmanian Primary Health Networks Alliance suggested that ‘the iterative nature of the PHN commissioning cycle provides regular opportunities for planning the delivery of services in line with community needs, in a way that is cognisant of and promotes linkages and integration between providers’.[62]

3.52In order to address funding instability in the sector, the AADC explained that some state and territory governments have progressively adopted longer contract lengths, which provided a level of security and stability within respective jurisdictions. The South Australian Government, for example, uses 3+3+3 year contract lengths, providing up to nine years security where key performance indicators are met. The Australian Capital Territory Government has introduced 7+3 year contract lengths in its latest recommendation process.[63]

AOD research and data

3.53The study of AOD-related issues in Australia is concentrated around five major research hubs, funded by the Commonwealth Government:

• National Centre for Education and Training on Addiction, Flinders University (NCETA)
• National Drug and Alcohol Research Centre, UNSW Sydney (NDARC)
• National Centre for Youth Substance Use Research, The University of Queensland (NCYSUR)
• National Drug Research Institute, Curtin University (NDRI)
• National Centre for Clinical Research on Emerging Drugs (NCCRED).[64]
  54. Other notable research hubs include, for example, the Centre for Drug Use, Alcohol and Addictive Behaviour Research (CEDAAR), the Monash Addiction Research Centre (MARC), the Matilda Centre for Research in Mental Health and Substance Use (the Matilda Centre), and the NSW Drug and Alcohol Clinical Research and Improvement Network (DACRIN).
  55. AOD research sector receives government funding through Medical Research Future Fund (MRFF) and grants awarded by the National Health and Medical Research Council (NHMRC). According to the Department of Health and Aged Care, between 2015 and 2024, the MRFF has invested $48.17 million in 30 grants with a focus on AOD use research. During the same period, NHMRC has expended $229.1 million towards research relevant to AOD addiction. In May 2024, the Government announced up to $20 million in MRFF funding for AOD focused projects, with application outcomes for these grants expected to be announced in July 2025.[65]
  56. In its submission, the Matilda Centre highlighted the need for the establishment of national research strategies in the field of AOD. The importance of national research strategies has been recognised by the health sector more broadly and the mental health specifically through the National Health and Medical Research Strategy, which is currently under development, and the inaugural National Mental Health Research Strategy (2022). No equivalent strategy, however, has been developed for the AOD field. According to the Centre, a national AOD research strategy has the potential to help identify evidence gaps, reduce the duplication of efforts across NHMRC, MRFF and other funded AOD research, build the AOD research workforce, and ultimately strengthen Australia’s response to AOD harms.[66]
  57. The Matilda Centre further emphasised support for collaboration with people who had personal experience with addiction, as well as for Aboriginal and Torres Strait Islander communities, as being vital for addressing AOD harm in Australia.[67] These forms of collaboration and research co-design processes have been raised through the inquiry as important areas of focus and development for the sector.
  58. The Institute for Urban Indigenous Health submitted that Aboriginal and Torres Strait Islander-led research and evaluation of AOD services must be recognised as a separate, dedicated stream of research and evaluation component of the AOD system.[68] Such an approach would recognise that AOD has a disproportionate effect on Indigenous communities. According to the Institute, more Aboriginal Australians die due to drug and alcohol-related causes than any other disease group, including suicide and cardiovascular illnesses. Among young Aboriginal people aged 15 to 24, alcohol is the number one contributor to the burden of disease.[69]
  59. In reflecting on the close relationship between trauma and AOD use, the research sector also emphasised the need for the development of culturally specific understanding of trauma for priority groups, and research and evaluation of trauma-informed approaches to AOD treatment. Such an approach would help to better situate AOD related problems and trauma in the context of related social issues of gender and family violence, racism, sexual discrimination, criminalisation, poverty, and homelessness.[70]
  60. Through the course of the inquiry, the efficacy of new AOD treatments was cited as a priority area for further research.[71] Equally, the study of chronic liver problems was noted as being vital to addressing alcohol-related liver disease. According to Dr Paul Clark, Professor of Medicine at the University of Queensland and Director of the Alcohol and Drug Assessment Unit at Princess Alexandra Hospital, liver disease is ‘the most common medical problem and occupies the biggest burden of disease and cost from alcohol in our community’.[72]
  61. The Committee also heard evidence on how AOD research has been translated into clinical practice. In its submission, the Department of Health and Aged Care underlined the critical role that research and research translation have in informing a quick response to new and emerging issues in the AOD sector. As an example, the Department cited work related to the identification of new psychoactive substances in order to inform government responses. These substances are constantly evolving, expanding and diversifying, and their toxicity is often difficult to quantify:

Also referred to as ‘emerging drugs’ there are increasing fears about these substances, particularly considering recent overdose deaths where other drugs have been adulterated with nitazenes, a particularly potent category of synthetic opioids.[73]

3.62Commenting on the capacity to respond to rapidly evolving drug markets, NCCRED drew the Committee’s attention to the importance of ‘futures focussed foresight’ approaches to support preparedness. Research that informs such an approach involves a study of social, economic and ecological shifts that influence drug markets and drug use in several ways such as, for example, how the development of encrypted technologies has impacted drug manufacturing and supply.[74]

3.63Other entities also emphasised the need for more agile and responsive research and research translation approaches in the AOD domain. NCYSUR noted that more investment focus needed to be placed on hybrid implementation trials:

Even when an intervention is found to be effective, it can take up to 17 years for evidence to change practice. Hybrid effectiveness implementation trials, which blend the design components of clinical effectiveness and implementation research and are conducted in real-world settings, increase the speed of knowledge creation and its translation into clinical practice and policy.[75]

3.64In raising the issue of research translation, the Committee also heard from witnesses about the need for stronger support for health service research.[76] Reconnexion, a support service for benzodiazepine withdrawal, noted that at the beginning of 2024, the United Kingdom’s Maudsley Hospital, well known for its psychiatric prescribing guidelines, released de-prescribing guidelines for antidepressants and benzodiazepines. According to Reconnexion, these are the most comprehensive guidelines to date; while previous guidelines were general, this was the first time a medical authority has laid out the clear guidelines for how to de-prescribe.[77] This document, however, is complex and requires translation for general use by medical professionals.[78]

3.65Reconnexion subsequently launched a research project involving a cohort of general practitioners around Australia, along with the author of the Maudsley guidelines, working on translating the de-prescribing guidelines into practice. Developing this type of AOD translational research, Reconnexion noted, was vital for ensuring that most up-to-date strategies are implemented across the sector. As Dr Erin Oldenhof, Reconnexion Benzodiazepine Withdrawal Counsellor and Research and Innovation Lead, told the Committee:

You've got academics and researchers with great ideas and doing wonderful research, but it stays there and it doesn't move into the world. And it doesn't often work with the services to inform the design and development. So they have the evidence but then they realise, 'Oh, that doesn't work for the service trying to provide it.' This is that missing piece.[79]

3.66Throughout the inquiry, the importance of using high-quality data collections to inform AOD research and policy response was repeatedly impressed upon the Committee. The Australian Government funds the collection of national data on AOD, with many of these collections administered by the Australian Institute of Health and Welfare (AIHW).[80]

3.67The AIHW manages two main AOD data collections on behalf of all state and territory governments: the Alcohol and Other Drug Treatment Services National Minimum Data Set (AODTS NMDS) and the National Opioid Pharmacotherapy Statistics Annual Data collection. The first captures information about publicly funded AOD treatment services—including agencies, clients, and treatment received—and covers the period from 2000. The second collection gathers information on clients who access opioid pharmacotherapy, prescribers of opioid pharmacotherapy, and dosing point sites where clients receive pharmacotherapy since 2004.[81]

3.68The AIHW also manages the National Drug Strategy Household Survey on behalf of the Commonwealth government. This survey captures information on alcohol, tobacco and illicit drug use among the general population in Australia, including people’s attitudes and perceptions relating to AOD use.[82] Conducted every two to three years since 1985, the collection includes information on AOD related impacts, such as:

• treatment seeking
• high risk drug use
• risky alcohol consumption
• experiences of overdose
• drink spiking
• risky activities undertaken while under the influence of alcohol and other drugs
• injuries sustained while under the influence of alcohol or other drugs
• harms experienced from someone under the influence of alcohol or other drugs.[83]
  69. Numerous other data collections assist in analysing the AOD impacts and harms. These include, for example, the Department of Health and Aged Care Pharmaceutical Benefits Scheme and Medicare Benefits Scheme data collections, as well as data from the Australian Secondary Students Alcohol and Drug survey. The Australian Criminal Intelligence Commission’s National Wastewater Drug Monitoring Program also provides an important source of data in this context.[84]
  70. In its submission, AIHW noted that data pertaining to such things as ambulance services, patients admitted across public and private hospitals, the health status of people in Australia’s prisons, pregnancy and childbirth, access to homelessness services, and burden of disease database all provide different information points that help to build the picture of the use and impact of AOD.[85]
  71. Up-to-date data is critical for monitoring new and emerging issues. The National Drug and Alcohol Research Centre (NDRAC) coordinates the Drug Trends Program, which serves to inform policy response through the early identification of emerging problems in substance use in the country. The program uses a range of data sources, including the Illicit Drug Reporting System (IDRS) and the Ecstasy and Related Drugs Reporting System (EDRS) drug monitoring projects, which collect data among people from metropolitan regions who regularly use stimulant drugs and who regularly inject drugs.[86]
  72. In its submission, the Department of Health and Aged Care underscored the critical value of these monitoring systems:

These projects aim to identify emerging trends of local and national concern in illicit drugs and related drug markets. Both projects seek to monitor the price, purity, availability, and patterns of use of specific illicit drugs including heroin, cocaine, ecstasy, cannabis, methamphetamine, ketamine, GHB (gamma hydroxybutyrate), MDMA (Methylenedioxyamphetamine) and LSD (lysergic acid diethylamide).[87]

3.73The Emerging Drugs Network of Australia (EDNA), a national toxico-surveillance system, has also been identified as an invaluable data source. EDNA draws its data from patients presenting to the emergency departments (EDs) after using illicit drugs. It is a collaborative national network of emergency physicians, toxicologists, forensic laboratories and public health authorities. The key benefit of EDNA is the capacity to provide timely laboratory-confirmed toxicology data on emerging drug-related threats in the community, which acts as an early warning system. EDNA has made Australia’s first contribution of national ED data on novel psychoactive substances to the United Nations Office on Drugs and Crime Global SMART Forensics program. It has strengthened Australia’s contribution to global surveillance networks. Concerns have been raised, however, that funding for EDNA, which comes from the NHMRC, may cease in 2025-26.[88]

3.74NCCRED submitted that Australia had a strong history of monitoring illicit drug trends over time, and since 2020 also a better capacity to detect concerns relating to novel psychoactive substances and drug potency in real time. NCCRED emphasised, however, that there is presently no national system to collate and analyse events-based data in real time:

There is a range of data sources that if analysed and triangulated in a timely fashion could facilitate real time access to data points such as substance related harms and treatment episodes. The establishment of such a data source may support improved public health decision making.[89]

3.75The AIHW similarly noted a number of AOD data gaps, highlighting that ‘the available data on harms are more limited than data on consumptions, particularly at the national level’.[90] This includes information on:

• targeted treatment programs for groups with specific needs
• treatment outcomes (to understand the most effective treatments)
• AOD workforce data (similar to the AIHW’s existing National Mental Health Service Planning Framework)
• AOD expenditure data
• data on demand for AOD services (such as, for example, wait times)
• data from the broader AOD service sector (such as the private treatment services).[91]
  76. There is currently no coherent, national evidence base containing data on AOD use and harms in the context of inter-related psychosocial factors that may increase the risk of harm. AIHW noted that it was well established that drug use often co-occurred with psychosocial factors including mental health conditions, family, domestic and sexual violence (FDSV), socioeconomic disadvantage, chronic health conditions, experiences of homelessness, and self-harm. While AIHW data holdings provide coverage of many of these topics, there is limited data available at the national level that allow for the examination of these factors in combination.[92]
  77. The AIHW is currently undertaking several linkage programs to address these gaps, such as National Health Data Hub, Child Wellbeing Data Asset, and NACS linked dataset, a bespoke data linkage project including data on all-cause mortality among people who have accessed specialised AOD treatment and or specialist homelessness services.[93]
  78. Witnesses made several recommendations for the strengthening of current data collections, in particular the AODTS NMDS. NCYSUR noted, for example, that the set lacks information on the safety, quality, and more specific details of the treatment delivered:

… only information on the main physical setting (e.g., residential treatment facility, outreach setting) and broad type of treatment delivered (e.g., withdrawal management, counselling, rehabilitation, pharmacotherapy), is collected.

We recommend the development of NMDS items to collect information on the specific subtype/s of treatments being delivered during withdrawal management, counselling, rehabilitation and pharmacotherapy treatment in AOD services to ensure they are safe and evidence based.[94]

3.79The NCYSUR submission further highlighted that there had been no measures for the quality outcomes or effectiveness of treatment:

Despite nearly two decades of calls to collect person reported outcome measures (PROMs) in Australia, there has been limited success to date, as AOD service providers lack the time, infrastructure and staffing to collect and utilise this valuable data.[95]

3.80In response, NCYSUR developed QuikFix, an evidence-based PROM system designed specifically for AOD treatment services which focuses on outcomes that matter to clients. The routine collection of PROM is seen as vital for approving AOD treatment service in Australia.[96]

3.81Multiple witnesses emphasised the need for better data to help measure the effectiveness of different programs. Mr Adam Miller, Chief Communications Officer at Windana, told the Committee that a significant shift is needed to support the implementation of effective and equitable policy responses:

… and part of this shift can be driven by the data the federal government mandates service providers like us to collect and a shift from outputs to outcomes—for example, from capturing whether someone was referred to a housing agency to capturing whether their housing security has improved.

To do this, data collection at all levels needs to include a meaningful focus on the social determinants of health. It's often said that, if it's not written down, it didn't happen. Take a quick look at the data that service providers are mandated to collect in the alcohol, tobacco and other drug services database and you'll see that what we're being asked to capture primarily relates to demographic data and outputs—how many sessions, who ran the sessions and so forth. There is little if anything about outcomes—about what a person needs to be able to meet their recovery goals. This is what matters, yet it's not captured in federal government mandated data fields.[97]

3.82Mr Joseph Coyte, Executive Director at Ngaimpe Aboriginal Corporation (The Glen Group) similarly emphasised the importance of collecting data that would enable the objective measurement of achieved outcomes:

I'd love to really understand who's funding what and what outcomes on the ground we are achieving as a society. That's what we're trying to do. For instance, in New South Wales recently, there was a half-billion-dollar investment after the ice inquiry. Now, we've got to make sure we monitor that to actually see what outcomes were achieved on the ground. It's not about who you funded so you can tick your box and say, 'We gave that person that money and this person this money.' I don't think anyone cares, as long as the outcome on the ground is worth a half-a-billion-dollar improvement to the state of New South Wales.[98]

3.83In other to enhance current AOD data collections, the Australasian College for Emergency Medicine (ACEM) urged Australian governments to require reporting on alcohol and drug related presentations to ED and use this to inform prevalence. ACEM noted that current coding systems has not sufficiently evolved to capture the complex nature of AOD presentations. The organisation noted that, for example, the New South Wales Special Commission of Inquiry into the Drug ‘Ice’ found that systematic data collection under-reports methamphetamine ED presentations by 40per cent.[99]

3.84The Australian Medical Association (AMA) added that: ‘Accurate, timely and comprehensive indicators and monitoring of alcohol and other use, and substance-related harms, must be uniformly collected across the states and territories as a matter of urgency’.[100] In acknowledging the vital work conducted by AIHW, AMA also recommended additional measures that should be taken to strengthen Australia’s AOD data:

Alcohol sales data should be collected so the sales volumes of each beverage and outlet type can be determined at a local level to facilitate evaluation of community initiatives to reduce alcohol-related harms. Data should be collected on foetal alcohol spectrum disorder, both in the general population and in high-risk groups.[101]

3.85NDRI reiterated that accurate measures of alcohol consumption are lacking within Australia. Only five states and territories currently collect some level of data from alcohol wholesalers, and of these only the Northern Territory has made this data publicly available since 2018.[102]

3.86NDRI recommended that Australia should consider moving to a Point-of-Sale approach to monitoring alcohol-related harm, which would see retail sales data be collected by government. Such data would inform government of the price alcohol is being sold for, the time of day these sales are made, and the quantity of alcohol that is purchased at any one time. The NDRI submitted: ‘This information can be used to inform effective and targeted alcohol prevention programs in areas with elevated levels of alcohol-related harm’.[103]

3.87In reflecting on current data collections, the National Indigenous Australians Agency (NIAA) emphasised that improving the AOD evidence base was essential to achieving better outcomes for First Nations People. Furthermore, the NIAA highlighted the importance of data for self-determination, and noted that data practitioners should have greater awareness and acceptant of the principles of Indigenous Data Sovereignty. This involves First Nations people leading discussion on matters that affect them, including the ‘conceptualisation, prioritisation, design, collection, management, and use of data and research to inform policy and programs’.[104]

Committee comments

3.88The Committee recognises that the AOD governance framework has grown increasingly complex, underscoring the critical need for renewed national leadership to strengthen coordination and oversight in this area. In developing the next National Drug Strategy, robust research and data collection remain fundamental for properly understanding sector needs and crafting effective policies. Our research institutions continue to make vital contributions, and their capacity to translate new knowledge into clinical practice is an essential part of Australia’s ability to provide a meaningful response to AOD harms.

Footnotes

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

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

[3]Department of Health and Aged Care (2017), National Drug Strategy 2017-2026, p. 38; Department of Health and Aged Care, Submission 157, pp.27-30.

[4]Youth Support and Advocacy Service (YSAS), Submission 32, n.p.

[5]Department of Health and Aged Care (2017), National Drug Strategy 2017-2026, pp. 1-2.

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

[7]For the Tasmanian context, see The Department of Health, Tasmanian Government, Submission 200, n.p.

[8]Government of Western Australia, Mental Health Commission, Mental Health and Alcohol and Other Drugs Strategy 2025-2030 and Outcome Measurement Framework; Government of Western Australia, Mental Health Commission (12 March 2024), “Office of Alcohol and Other Drugs to be established”.

[9]Sam Nichols and Joseph Hathaway-Wilson (4 December 2024), ‘NSW drug summit an opportunity for new government strategy to address risks of drug harm, experts say’, ABC News.

[10]See, for example, Alcohol, Tobacco and other Drugs Council Tasmania, Submission 22; The Matilda Centre for Research in Mental Health and Substance Use, The University of Sydney (the Matilda Centre), Submission 24; Australian Alcohol and other Drugs Council (AADC), Submission 45; The Salvation Army, Submission 68; Alcohol and Drug Foundation (ADF), Submission 77.

[11]Department of Health and Aged Care (2017), National Drug Strategy 2017-2026, pp. 35-37; ADF, Submission 77, pp. 14-15.

[12]Mr Ben Mudaliar, Assistant Secretary, Alcohol and Other Drugs Branch, Department of Health and Aged Care, Proof Committee Hansard, Canberra, 7 February 2025, pp. 29-30.

[13]Alcohol, Tobacco and other Drugs Council Tasmania, Submission 22, p. 7.

[14]AADC, Submission 45, p. 11; ADF, Submission 77, p.16; National Centre for Education and Training on Addiction (NCETA), Submission 43, p. 2.

[15]AADC, Submission 45, pp. 11-13.

[16]AADC, Submission 45, p. 11.

[17]The Matilda Centre, Submission 24, p. 6.

[18]Queensland Network of Alcohol and Other Drug Agencies (QNADA), Submission 75, p. 10.

[19]QNADA, Submission 75, p. 10.

[20]The Matilda Centre, Submission 24, p. 6.

[21]AADC, Submission 45, p. 18; Foundation for Alcohol Research and Education (FARE), Submission 87, p. 16.

[22]FARE, Submission 87, p. 11.

[23]AADC, Submission 45, pp. 8-9.

[24]YSAS, Submission 32, n.p.; AADC, Submission 45, p. 9; see also Drug Free Australia, Submission 176, pp. 5-6.

[25]The Global Commission on Drug Policy (2014), Taking Control: Pathways to Drug Policies that Work.

[26]YSAS, Submission 32, n.p.

[27]YSAS, Submission 32; Youth Empowered Towards Independence, Submission 51; ADF, Submission 77; LGBTIQ+ Health, Submission 189.

[28]Dr Jeremy Hayllar, Clinical Director, Metro North Mental Health Alcohol and Drug Service, Queensland Health, Committee Hansard, Brisbane, 30 October 2024, p. 35.

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

[30]Professor Kate Seear, Submission 33, p. 14; The Global Drug Policy Index, Ranking.

[31]Professor Seear, Submission 33, p. 14.

[32]ADF, Submission 77.

[33]QNADA, Submission 75, p. 15; Australian Institute of Health and Welfare (2023), National Study of Mental Health and Wellbeing, cited in AADC, Submission 45, p. 3.

[34]QNADA, Submission 75, pp. 16-17.

[35]Australian Federal Police (AFP), Submission 89, n.p.

[36]AFP, Submission 89, n.p.

[37]Alcohol, Tobacco and Other Drug Council Tasmania, Submission 22; YSAS, Submission 32; QNADA, Submission 75.

[38]Drug Policy Modelling Program (DPMP), Social Policy Research Centre, UNSW, Submission 17, p. 2.

[39]AADC, Submission 45, p. 3.

[40]AADC, Submission 45, p. 3.

[41]AADC, Submission 45, p. 8.

[42]AADC, Submission 45, pp. 8-9.

[43]AADC, Submission 45, p. 9.

[44]AADC, Submission 45, p. 3.

[45]AADC, Submission 45, p. 13.

[46]Alison Ritter, Lynda Berends, Jenny Chalmers, Phil Hull, Kari Lancaster and Maria Gomez, Drug Policy Modelling Program, National Drug and Alcohol Research Centre, University of New South Wales, Sydney (2014), New Horizons: the review of alcohol and other drug treatment services in Australia final report, p.24

[47]Victorian and Tasmanian Primary Health Networks Alliance, Submission 41, p. 3.

[48]Department of Health (2014), Primary Health Networks, Grant Programme Guidelines; Australian Institute of Health and Welfare (AIHW) (2014), Alcohol and other drug treatment service in Australia annual report.

[49]Department of Health (2014), Primary Health Networks, Grant Programme Guidelines; AIHW (2014), Alcohol and other drug treatment service in Australia annual report.

[50]AADC, Submission 45, p. 16.

[51]Victorian-Tasmanian Primary Health Network Alliance, Submission 41, pp. 5-6.

[52]AADC, Submission 45, p. 13.

[53]Mr Geoffrey Davey, Chief Executive Officer, Queensland Injectors Health Network, Committee Hansard, Brisbane, 30 October 2024, p. 9.

[54]AADC, Submission 45, p. 14.

[55]AADC, Submission 45, p. 4.

[56]AADC, Submission 45, p. 16.

[57]Ngaimpe Aboriginal Corporation (The Glen Group), Submission 118, n.p.

[58]AADC, Submission 45, p. 4.

[59]QNADA, Submission 75, p. 12.

[60]QNADA, Submission 75, p. 12.

[61]AADC, Submission 45, p. 16.

[62]Victorian-Tasmanian Primary Health Networks Alliance, Submission 41, p. 5.

[63]AADC, Submission 45, p. 16.

[64]Department of Health and Aged Care, Submission 157, p. 33.

[65]Department of Health and Aged Care, Submission 157, p. 33.

[66]The Matilda Centre, Submission 24, p. 9.

[67]The Matilda Centre, Submission 24, p. 11.

[68]Institute for Urban Indigenous Health, Submission 155, p. 20.

[69]The Matilda Centre, Submission 24, p. 11.

[70]Professor Carla Treloar, Submission 31, p. 2.

[71]National Centre for Clinical Research on Emerging Drugs (NCCRED), Submission 171, pp. 13-14.

[72]Dr Paul Clark, Director, Alcohol and Drug Assessment Unit, Princess Alexandra Hospital, Brisbane, Proof Committee Hansard, Canberra, 7 February 2025, p. 23.

[73]Department of Health and Aged Care, Submission 157, p. 33; See also Odyssey Victoria, Submission 136.

[74]NCCRED, Submission 171, p. 11.

[75]The Australian National Centre for Youth Substance Use Research (NCYSUR), Submission 120, pp. 7-8.

[76]Reconnexion, Committee Hansard, Melbourne, 28 October 2024, pages 26-34; Odyssey Victoria, Submission 136, p. 3.

[77]Dr Erin Oldenhof, Benzodiazepine Withdrawal Counsellor and Research and Innovation Lead, Reconnexion, Committee Hansard, Melbourne, 28 October 2024, pp. 28-30.

[78]Dr Oldenhof, Reconnexion, Committee Hansard, Melbourne, 28 October 2024, pp. 28-30.

[79]Dr Oldenhof, Reconnexion, Committee Hansard, Melbourne, 28 October 2024, p. 30.

[80]Department of Health and Aged Care, Submission 157, p. 33.

[81]Australian Institute of Health and Welfare (AIHW), Submission 142, Attachment 1, p. 1.

[82]AIHW, Submission 142, Attachment 1, p. 1.

[83]AIHW, Submission 142, Attachment 1, p. 3.

[84]Department of Health and Aged Care, Submission 157, p. 34.

[85]AIHW, Submission 142, Attachment 1, p. 1.

[86]Department of Health and Aged Care, Submission 157, p. 32.

[87]Department of Health and Aged Care, Submission 157, p. 32.

[88]Australasian College of Emergency Medicine (ACEM), Submission 95, pp. 3-4.

[89]NCCRED, Submission 171, p. 10-11.

[90]AIHW, Submission 142, p. 2.

[91]AIHW, Submission 142, pp. 3-4.

[92]AIHW, Submission 142, p. 4.

[93]AIHW, Submission 142, p. 5.

[94]NCYSUR, Submission 120, p. 8.

[95]NCYSUR, Submission 120, p. 8.

[96]NCYSUR, Submission 120, p. 9.

[97]Mr Adam Miller, Chief Communications Officer, Windana, Committee Hansard, Melbourne, 29 October 2024, p. 29.

[98]Mr Joseph Coyte, Executive Director, Ngaimpe Aboriginal Corporation (The Glen Group), Committee Hansard, Canberra, 7 Novembre 2024, p. 5.

[99]ACEM, Submission 95, p. 7.

[100]Australian Medical Association (AMA), Submission 80, p. 13

[101]AMA, Submission 80, p. 13.

[102]National Drug Research Institute (NDRI), Submission 141, n.p.

[103]NDRI, Submission 141, n.p.

[104]National Indigenous Australians Agency, Submission 140, p. 15.