Mr. Mark Kennedy:

I am the head of day services at Merchants Quay Ireland. We have been providing low-threshold accessible services to drug users in the country since 1989. We provide supports to those who are chaotic drug users on the streets and many others all the way through to those who are in need of rehabilitation, detoxification and drug-free aftercare and employment.

The services at Merchants Quay Ireland provide a range of supports, including assistance with food, medical issues, drug treatment, accommodation, psychiatric, justice and welfare issues. In 2015 Merchants Quay Ireland provided services to approximately 7,500 individuals, up to 3,000 of whom were injecting drug users. A significant proportion of the intravenous drug users accessing our needle exchanges are homeless street injectors. Sadly, Merchants Quay Ireland has been operating on the front line in respect of over 5,000 drug deaths in Ireland in the past ten years. Ireland has one of the highest drug mortality rates in the EU.

Merchants Quay Ireland is keen to highlight several points in consideration of the misuse of drugs (supervised injecting facilities) Bill 2016. The central theme of the national drugs rehabilitation implementation committee case management protocols is the importance of a continuum of care from harm reduction through to recovery. While there is consensus that more resources are needed in areas such as methadone maintenance and residential recovery, the medically supervised injecting centre represents an evidence-based element of the continuum of care that does not currently exist in Ireland.

The latest research from the Centre for Global Health at Trinity College highlights the importance of understanding the needs of all stakeholders in an injecting centre, including drug users, the community, treatment services and justice. To this end, the proposed legislation represents an opportunity to address the limitations of Irish drug service provision. For example, to operate in line with the current Misuse of Drugs Act, services such as Merchants Quay Ireland have to exclude people based on the fact that they have sought a safe place within our services to inject drugs. These are precisely the people who most need our support. As a result, the only option available to such people is to inject in alleyways on the streets of Dublin, where the likelihood of overdose and death is far higher.

Homeless and drug services such as the Ana Liffey Drug Project, the Simon Community and Merchant's Quay Ireland operate in line with the quality in alcohol and drug services organisational standards, which are currently being aligned to the national standards for safer and better health care. Such services have strong working relationships with hospitals, community GPs, gardaí, community groups and drug treatment providers. These relationships are critical to the operation of pilot injecting centre sites.

When injecting centres are being provided, it is important to learn from the evidence and experience of the earliest injecting centres in cities such as Sydney and Vancouver. We should also take account of the latest evidence from the European Monitoring Centre for Drugs and Drug Addiction on how injecting centres are evolving to include not just injecting facilities but also a full range of immediately accessible practical on-site supports to address the complexity of needs associated with street injectors, including medical, accommodation and psychological needs and basic needs such as food and clothing. The legislation should, therefore, support the development of existing specialised service provision to injecting drug users. It should maximise the ability of the existing network of services, which are highly skilled in working with injecting drug users across the county, to reduce harms, develop working relationships and provide treatment options on the basis of need. Many Irish homeless services in large urban areas that are working with street-based injecting drug users now provide needle exchange and nursing supports. If the pilot sites are located within these services, this will empower such services to intervene and save lives. Such an approach would also engage synergies with existing services, thereby eliminating the need to reinvent the wheel and, in so doing, ensure cost-effectiveness.

The most recent evidence on implementing injecting centres indicates efficacy in reaching injecting drug users and in reducing health risks, public injecting, mortality and injecting harms. Injecting centres are most effective when they are integrated into a wider public policy framework as part of a network of services; when they are based on consensus, support and active co-operation among local key actors; and when they are seen as highly targeted services that aim to reduce problems of health and social harm involving high-risk drug use populations and to address needs that other responses have failed to meet. It is important to admit that, realistically, injecting centres in isolation are not going to eliminate drug deaths, street injecting and the spread of blood-borne viruses. An injecting centre would form part of a solution by operating at the harm-reduction end of the continuum of care. It is critical for the legislation to take advantage of the evidence-based operational and budgetary synergies that may be gained from locating injecting centre pilot sites inside existing services in urban areas with a high prevalence of injecting drug use. This should not be limited to Dublin. The ability to operate the licensed injecting centre model represents a natural addition to existing low-threshold harm-reduction services. In line with the case management protocols of the national drugs rehabilitation implementation committee, the injecting centres can operate as part of an inter-agency multidisciplinary response to high-risk drug use, with that response being provided in a caring ethos as part of a care plan which the client plays an active role in developing.