The Honourable Carolyn Bennett, M.D., P.C., M.P.
\nMinister of Mental Health and Addictions and Associate Minister of Health<\/p>\n
The Honourable Jean-Yves Duclos
\nMinister of Health<\/p>\n
cc: Hon. Sheila Malcolmson, B.C. Minister of Mental Health and Addictions<\/p>\n
Dear Ministers Bennett and Duclos:<\/p>\n
Re: Proposed cumulative threshold of 4.5 grams in BC<\/p>\n
We write as a coalition of over 20 civil society organizations in Canada, comprising people who use drugs and their families, Indigenous and racialized groups, service providers, legal organizations, research groups, and drug policy advocates. Our mission includes abolishing criminal and other laws, policies, and practices that control, stigmatize, pathologize, and punish people who use drugs.<\/p>\n
We understand Health Canada is considering British Columbia\u2019s request for an exemption from the Controlled Drugs and Substances Act to decriminalize simple possession up to a cumulative threshold quantity of 2.5 grams. As you know, this is far lower than the cumulative threshold of 4.5 grams requested by the province \u2014 already an exceedingly low cumulative threshold for many people who use drugs and near-unanimously rejected by BC\u2019s Core Planning Table on Decriminalization.<\/p>\n
Ministers: there is no legal or evidentiary basis for a cumulative threshold of 2.5 grams. Per the recommendation of our 2021 platform, we urge you to reject this quantity and dispense with threshold quantities altogether.1<\/strong><\/p>\n As we\u2019ve routinely communicated to you, there are significant risks of \u201cnet-widening\u201d in defining a threshold that does not reflect real-world patterns of use. Drug markets will adjust to a low threshold, including via changes to the potency and amounts of drugs held or sold, potentially increasing overdose risk. Other harms resulting from a 2.5 grams threshold may include the incentivization of interactions with the unregulated market as people try to avoid criminalization by frequently purchasing smaller amounts.2 Those who will be most profoundly harmed by a low A 2.5 grams threshold flies in the face of your governments\u2019 commitment to evidence-based drug policy, anti-racism, and reconciliation with Indigenous communities. It sets a dangerous precedent for other municipalities across Canada seeking an exemption. It disregards the recommendations put forward by BC\u2019s Core Planning Table and caters to the unsubstantiated, stigma-based requests of police. We know Health Canada has met with police as part of its decision-making process, while requests from drug user-led groups like the Vancouver Area Network of Drug Users (VANDU) have been ignored entirely.<\/p>\n Decriminalization must be done right.<\/strong> You have a moral, legal, and ethical responsibility to uphold the human rights of people who use drugs; this requires you to centre their expertise. A 2.5 grams threshold will continue to inflict grave harms on our communities and must be abandoned.<\/p>\n We ask that you therefore:<\/p>\n 1) provide us with the rationale and evidence for a 2.5 grams threshold; and <\/p>\n Signed,
\nthreshold will be Black, Indigenous, and other racialized, marginalized, and low-income communities, who are profiled and disproportionately arrested and incarcerated for drug offences.<\/p>\n
\n2) meet with us this month to ensure that the perspectives of people who use drugs are prioritized and the recommendations of the BC Core Planning Table are ultimately adopted.<\/p>\n
\nAvenue B Harm Reduction
\nAVI Health and Community Services
\nBC Association of Aboriginal Friendship Centres
\nBlood Ties Four Directions
\nBritish Columbia Centre on Substance Use
\nBritish Columbia Civil Liberties Association
\nCanadian Association of People who Use Drugs (CAPUD)
\nCanadian Drug Policy Coalition
\nCanadian Students for Sensible Drug Policy
\nCentre on Drug Policy Evaluation
\nDrug Users Advocacy League
\nDrug User Liberation Front
\nENSEMBLE Services Greater-Grand Moncton
\nGilbert Centre
\nHIV Legal Network
\nIndigenous Harm Reduction Network
\nMoms Stop the Harm
\nMultidisciplinary Association for Psychedelic Studies Canada
\nOttawa Inner City Health
\nPivot Legal Society
\nSouth Riverdale Community Health Centre<\/p>\n