OCCASIONAL PAPER No. 2

“Safe Injecting FacilitiesTheir justification and viability in the Victorian setting”

The views expressed in this paper do not reflect current or proposed VictorianGovernment policy, and they do not necessarily reflect the final position of theVictorian Parliamentary Drugs and Crime Prevention Committee.

Drugs and Crime Prevention CommitteePARLIAMENT OF VICTORIA

Drugs and Crime Prevention Committee

MEMBERS

The Honourable Andrew R. Brideson, MLC, Chairman

Gary J. Rowe, MLA, Deputy Chairman

Andre Haermeyer, MLA

Don Kilgour, MLA

Hurtle Lupton, MLA ( from September 1997)

The Honourable Jean McLean, MLC

Edward J. Micallef, MLA

The Honourable Dr John W. G. Ross, MLC

Jan T.C. Wilson, MLA

Terms of Reference

The Parliamentary Crime Prevention Committee shall inquire into, consider andreport to the Parliament on the implementation of the Government’s DrugReform Strategy, and in particular to: -

1. Monitor the implementation, and evaluate the effectiveness, of thecomprehensive drug reform strategy announced in response to the report of thePremier’s Drug Advisory Council in the document Turning the Tide.

2. Investigate and evaluate national and international experience in thedrug area. This will include undertaking an evaluation of differing approaches tothe drug problem in other states, particularly South Australia and the A.C.T., andinternational jurisdictions.

3. Monitor and evaluate two research projects which will be commissionedby the Government. The first will further investigate any linkage betweenmarijuana use and the onset of schizophrenia and other mental illness. Thesecond will investigate the effects of marijuana use on driving and supportexpanded work on the development and commissioning of a roadside testingmechanism for marijuana.

A preliminary report focusing on the extent to which implementation ofinitiatives has been achieved will be required to be tabled in the Parliament nolater than December 1997.

A second report providing a clear indication of the extent to which the use andabuse of drugs and the physical, emotional and social harm that results has beenreduced will be required to be tabled in the Parliament no later than June 1999.This report will take into account the results of the research projects consideredby the committee and the evaluation of national and international experience.

The two reports will form the basis for ongoing action, including legislativereform.

Dated 25 June 1996

Responsible Minister:J. G. KennettPremier

Preface

For many years in Victoria, heroin use and the harms associated with that use – particularly

fatal overdoses - have continued to rise. This is despite the fact that Victoria has had a

consistently developing system of harm-minimisation programs and interventions that span the

range of government activity and social domains. This, by no means, is to suggest that these

programs and interventions have had no impact at all. The drug problem in Victoria would

clearly be much worse than it is without them.

What this trend of increasing harms does suggest is that something more needs to be done. It is

not clear, though, that more of the same sorts of interventions and activities will be quite enough.

There is a need to consider different, and perhaps sometimes courageous, options as well. One

such option is the provision of a controlled context or place for street-level heroin users to inject

safely. Safe injecting facilities are intended to target a specific range of drug-related harms, and

experience from overseas suggests that they ought to be given serious consideration.

It is the responsibility of the Victorian Parliamentary Drugs and Crime Prevention Committee

to evaluate the Victorian drug reform strategy “Turning the Tide”, and also to examine the

range of options and interventions that might be brought to bear on reducing drug-related harms

in Victoria. This discussion paper on safe injecting facilities in the Victorian setting is intended

to be part of this process of examination. It is hoped that the arguments and findings presented

in this paper will contribute to public discussion and greater understanding, so that more

informed and justified policy decisions can be made on the issue.

* * * * * * * * * * * * * * * * *

A number of people have made helpful comments on earlier draftsof this document, and their contribution is greatly appreciated. Anyfurther feedback can be directed to the following email address:

maurice.rickard@parliament.vic.gov.au

Contents

Key Findings

1. What are Safe Injecting Facilities

2. The impetus for Safe Injecting Facilities

3. The role of Safe Injecting Facilities in addressing harms

4. Concerns that have been expressed about Safe InjectingFacilities

5. Legal issues relating to Safe Injecting Facilities

6. Models for Safe Injecting Facilities

7. Conclusion

References

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KEY FINDINGS

Safe Injecting Facilities are designed as a specific response to a specificproblem - public street-injecting and the specific harms associatedwith it [eg., public nuisance, high risks associated with hurriedand unsafe injecting, etc.].

Finding One: There are few interventions other than SafeInjecting Facilities that are specifically suited tocomprehensively deal with the range of harms arising frompublic street injecting.

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Safe Injecting Facilities have been operating in Europe for morethan 10 years, and appear to be effective in achieving the goalsthey are designed for.

Finding Two: Safe Injecting Facilities may be effective indealing with the harms of street injecting, (particularlypublic nuisance), but only if they are properly targeted, andsensitively managed in the context of communityconsultation and education.

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Not all purportedly harm-reducing interventions are completelyfree of the potential to create harms themselves. Safe InjectingFacilities appear to have a potential to produce significant harms,including the possibility of a further entrenched local drugmarket and related crime, perceptions of condoned drug use, andentrenching drug injecting as the major route of administration.

Finding Three: There are potential dangers and possibledisadvantages in implementing Safe Injecting Facilities.The extent to which these disadvantages would actuallyarise, and what the true balance of costs and benefits wouldbe in Safe Injecting Facilities (as an ongoing establishedform of intervention) will best be determined through acontrolled trial.

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Finding Four: There are legal factors involved in theimplementation and operation of Safe Injecting Facilities,but they are not unique or insurmountable. The possibilityof implementing Safe Injecting Facilities will depend on afull consideration and resolution of these legal issues.

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Finding Five: There are good reasons for adopting amodel of implementation that incorporates safe injecting asa part or aspect of a primary health-care centre whichaddresses the general health needs of drug users, ratherthan having a facility that is devised for and largelydedicated to safe injecting.

1. What are Safe Injecting Facilities?

As the name suggests, safe injectingfacilities are establishments whosespecific and officially sanctioned purposeis to provide injecting drug users with asafe environment in which to inject theirdrugs. Safe injecting facilities (or SIFs)are to be distinguished from “shootinggalleries”, which are not officiallysanctioned places for injecting, and areoften unsafe. Although SIFs ultimatelyneed to be sanctioned by governments,they can be established, operated andfunded by non-governmentorganisations, or in conjunction withgovernment agencies.

Clients of safe injecting facilities injectdrugs that they have acquiredthemselves. No drugs are administeredor distributed by the facility staff ormanagement. Staff do not help clients toinject, either. The safety of SIFs revolvesprimarily around their capacity to reducethe risk of fatal overdose, as well as therisk of blood-borne viral infectionsassociated with unsafe injectingpractices. This safety is sought through:

� the presence of trained health-carestaff who are available to superviseusers, provide advice and useavailable equipment to resuscitateoverdosing users or call for anambulance promptly;

� the free availability of sterileinjecting equipment, such as needles,syringes, ascorbic acid (in someregions), water, alcohol and dryswabs, and tourniquets (all of whichare collected after use).

SIFs should also play a secondary healthand welfare role for users through

� the provision of education andadvice to users on safe drug use;

� the provision of primary health-careand medical treatment (given thatusers’ general health tends to be

poor, and their access to appropriateprimary health-care is very poor);

� the increased access to andavailability of drug treatment andrehabilitation;

� the increased access to advice andhelp with life-skill problems (eg.,help with completing social securityforms, seeking housing, etc..)

Although there is no one set model forthe operation of SIFs, a facility may havethe following characteristics:1

� located within a larger Centre whichcan include a clinic for primarymedical care, counselling room, andcafeteria;

� the injecting rooms are likely to besterile looking, containing chairs andtables for clients to prepare andinject their drugs, as well as sterileinjecting equipment (needles,syringes, a candle, sterile water andspoons), as well as paper towels,bandaids and rubbish bins;

� Staff will control who enters thefacility, and the number of clientspresent at any one time. Clientsmight have to formally apply to usethe facility;

� There might be a maximum of 6 to10 clients in the injecting room atany one time, where clients stay inthe room to inject for up to 30minutes;

� A staff member will be on duty inthe injecting room at all times (on arotating basis);

1 Based on the operation of well-establishedfacilities in Switzerland as described in NSWJoint Select Committee into Safe InjectingRooms (JSCSIR), 1998.

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� The facility must have clear rules tobe followed by all clients, such as nodealing, no violence and nosmoking, and also possibly, rulesconcerning cleanliness while usingthe facility. Users may be banned fora period of time for breaching therules.

� A doctor may regularly visit theCentre, and the Centre may havedirect phone lines to the police andambulance services;

� If a client overdoses, the staffmember on duty (probably withassistance) will attempt to resuscitatethe client with an airbag, and if theclient’s breathing does not resume

normally after a few minutes, anambulance will be called;

� The opening hours of a facility maybe staggered to maximise thenumber of clients it can cater for;

� The facility managers may maintainongoing consultation with the localcommunity to ensure smoothoperation of the facility.

Across the world, there are five SIFs inFrankfurt, and others in Hamburg,Hannover, Bremen and Bonn inGermany; there are fourteen in Zurich,Berne and Basel in Switzerland; and anumber operate in the Dutch cities ofRotterdam, Arnhem and Maastricht.

2. The Impetus for Safe Injecting Facilities

Consideration of SIFs as an option forVictoria has arisen largely as a result ofthe apparent increase in a range of harmsassociated with injecting drug use (andtrafficking) in public places inmetropolitan Melbourne (most notablyin Fitzroy/Collingwood, St. Kilda,Footscray, Springvale, Box Hill, andparts of the CBD).

Street-level use tends to be aphenomenon involving mostly youngusers, older ones generally having moreopportunity to purchase and use inprivate settings. Street-level use istypified by users making quick, smallpurchases of heroin or cocaine fromknown or newly encountered street-dealers, and then consuming the drugvery soon after, and very close to thepoint of purchase – often in close-bystreets, secluded laneways, or publictoilet facilities.2 The shorter the time

2 In Smith St. Collingwood, for instance,68% of syringes collected from syringe

between buying the heroin and injectingit, the less the likelihood of beingdetected or intercepted by police inpossession of the drug or injectingequipment.The health risks to users commonlyassociated with injecting are increasedsubstantially by street use. Quite clearly,people who inject all of their drug supplyvery quickly increase their risk ofoverdose. One major study of thecircumstances of overdose showed thatnearly all of the overdoses inCabrammatta in Sydney were of usersfrom outside that area who had come into purchase and use near the point ofpurchase (Darke, et. al., 1997). But therisks are high even with non-fataloverdose, particularly if overdose istaken to include anything that counts asmore than an “effective” dose(Fitzgerald, et. al. 1998).

A recent survey of 40 street injectingdrug users in the Melbourne CBD disposal bins are collected from bins inpublic toilets (Fitzgerald, et. al., 1998)

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indicated that half had overdosed in thecity (Don, 1998). Users who overdose inthe sense of being either acutely drugaffected, or else lapsing into and out ofconsciousness, are a danger tothemselves and others, particularly in anopen street context. Losingconsciousness or “dropping off” directlyoutside shops has also been identified byshop-traders as a significant nuisance.If “deals” are shared, as they often arebetween users, injecting equipment isalso likely to be shared in the urgency ofthe moment. Along with this come therisks of transmitting blood-borne virusesand infectious diseases. The survey ofMelbourne CBD street injectors revealedthat nearly half (47%) shared needles andsyringes either because they were sharingwith a partner, or because of cost andlack of availability of needles/syringes,or because of the possibility of policedetection (Don, 1998). That same surveyalso indicated that over three-quarters ofthe CBD users interviewed sharedinjecting equipment other needles andsyringes (ie, spoons, water), and only15% administered their own injecteddoes themselves (Don, 1998).

Apart from the risks and harms to usersthemselves from street use, there are alsoharms for third-parties. Clearly, there is afear on the part of the general public ofneedle-stick injury from discardedsyringes.3 There is also the generalnuisance to consumers and businessoperators of a visibly present illegal drug-market, as well as bodily fluids (blood,vomit) and anti-social behaviour. Onemajor concern for members of thepublic is the appropriation of publictoilet facilities by injecting users.

As well as this there is also theoccurrence of, and fear of, opportunisticproperty and street crime in the locality.In business districts this impacts on

3 The probability of becoming infected witha blood-borne virus following a needle-stickinjury is very low for members of the generalpublic, and there are no known recordedcases of this to date (NDARC, 1999).

business operations and viability. As wellas all this, there is another set ofpotential harms which is too oftenoverlooked - the hazards to police,ambulance workers and paramedics ofemergency attendance at overdoses (withthe risks associated with speeding inemergency vehicles, needle-stickinjuries,4 etc..)

Although public street-level traffickingand use is a recent phenomenon, thereare reasons to think that it will becomemore and more common. It has beensuggested by senior police that one ofthe reasons for this increasing movementof using into the public area from thehome or residential environment is themore sophisticated police surveillancemethods being used in relation totrafficking and use in residential areasand static addresses (Fitzgerald, et. al.,1998).

Another suggested reason is the factthat, while there are undeniable risks,there are nonetheless certain advantagesfor users in purchasing and usingpublicly in consumer zones andshopping malls (Fitzgerald, et. al., 1998).These areas are generally accessible atmost hours for users (who often do notlive in the immediate locality). There isalso the element of anonymity for userswhere they are able to limit theirpersonal contact with dealers. And alsothere is the convenience of being able tochoose between dealers and dealspackaged in a variety of ways (e.g.,balloons and foils which are usuallysmall, easily concealed, andtransportable).

The convenience and anonymity ofpublic use has been encapsulated byFitzgerald, et. al. as reflecting what couldbe thought of as a “take away” ethicamong street users. So, in view of thefact that there are these attractions for a

4 The risk though of contracting HIV fromany one occupational needle-stick injury hasbeen estimated to be 1 in 316. The estimatedrisks are higher for hepatitis C (1 in 11) andhepatitis B (1 in 4) per exposure (Ippolito,et. al. 1994).

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certain group or type of user, it is notunreasonable to think that thephenomenon of street use will continue

to grow, along with the harms and risksthat are connected with it.

3. The Role of Safe Injecting Facilities in Addressing Harms

Street injectors, as described above, notonly experience greater than usual risk ofserious harm, they are typically the mostmarginalised group of users, and are lesslikely to access treatment and otherhealth-care services. The majority ofpeople who have overdosed are thosewho have never been in treatment (NSWJSCSIR, 1998). There are limited ways ofaddressing the increasing occurrence ofpublic street injecting use.

The common initial response to thisinjecting use is sometimes to engage insaturation policing to “clean up thestreets”. Experience shows, though, thatthis measure has limited long-termimpact. As Fitzgerald, et. al., haveobserved, “if drugs cannot be kept outof prisons, they cannot be kept out of acity full of alleyways, nooks andcrannies”.5 Even if users leave initiallyand move somewhere else, they stillcome back. There is also the possibilityof a rebound effect, where users moveback in more heavily (Fitzgerald, 1998).

One could speculate that the reasons forthis rebound effect revolve around theperception among users that thatparticular area has already been “done”by police, and that there will not be asimilar degree of intensive policing in thesame area for a while. And even if usersdon’t come back, they are simply movingtheir activity somewhere else, and thereis no guarantee that their injecting orassociated behaviour will be any lessharm-producing than it was in the firstplace. In fact, the more aggressive thepolicing, the more harm is likely to bedone. As Lisa Maher has observed:

. . . the effects of aggressive street-policing on socially marginalised

5 Fitzgerald, et. al., (1998), p. 118.

groups and particular ethniccommunities can produce bigproblems, including alienation or adistrust of the police or they canconfound those problems wherethey already exist, and with it goesthe potential for serious publicdisorder.6

This is not to say that police activity ofsome sort has no role to play at all inaddressing the various harms arisingfrom street-level dealing and use. It isnot unreasonable to expect that low-level, but nonetheless visible police foot-patrols might act to decrease theopenness of trafficking and use to somedegree, and thereby allay public concernsabout the possibility of opportunisticcrime, and some of the general nuisanceassociated with injecting behaviour.Police should not tolerate open markets.

This police presence, though, is only onemeasure which deals with only onedimension of the problem. It could beargued that the presence of SIFs mightprovide a more reliable response to thevisibility and nuisance of public injecting,and the offensive and criminalbehaviours often associated with it.Clearly, if persistent street users areprovided with a safe and sanctionedplace to go to inject away from thestreet, then the harms arising from streetuse can be expected to decline. Forexample, public drug use in Frankfurtshrunk from 800 individuals in 1991-2 to150 in 1993, and neighbourhoodcomplaints about drug use decreasedsignificantly (Kemmesies, 1995). Drugoverdose deaths in Frankfurt alsodropped sharply.

6 Lisa Maher, 1998, commenting onproblems of policing in Cabramatta.

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It is also often overlooked with streetuse that users themselves, and not justnon-using third-parties, are at risk ofoffensive, unsafe and sometimes criminalbehaviours from other users and non-users. Users, unlike the general publicand business operators, areunderstandably reluctant to seek policeaid when subjected to this behaviour. So,while police presence may be of somebenefit to third-parties, it will have alimited place for users at risk. One of themain reasons that clients cited for usinginjecting rooms in Switzerland was thefact that they provided a secure place toinject (Dolan & Wodak, 1996). Thisgeneral pro-attitude to SIFs among usersis echoed in Melbourne as well, with a1998 survey of 400 injecting drug usersin Melbourne finding that 77% of thoseusers would use a SIF with appropriateequipment rather than injecting inpublic. The remaining 23% indicatedthey had a fear of authorities andpreferred to inject in privacy (Fry, 1998)

This is where safe injecting facilities canalso be seen to have a very pertinent roleto play in addressing a range of otherserious harms of street use. Existingoptions like needle and syringe programshave the capacity to deal with some ofthe risks of injecting drug use in a streetcontext. But again, it is only some of theharms that are targeted, namely HIV andhepatitis C transmission, (serious asthese harms are). And when it comes toHepatitis C, it has been hypothesisedthat the virus can be transmitted throughdrug using paraphernalia other thanneedles and syringes. Safer injectingfacilities can provide each client with awhole complement of sterile injectingparaphernalia. This is particularlyimportant with the possibility over timein Victoria of increasing cocaine use,where users tend to inject at a higher ratethan heroin users. Further to this, usedneedles and syringes will not be carriedby clients to SIFs, unlike needleexchanges.

Also, in contrast to needle exchangeoutlets where clients generally visitbriefly, safe injecting facilities allow for amore prolonged interaction between

health-care staff and clients. Thisinteraction provides the opportunity forusers to access advice from staff, and forstaff to assess the general health andwellbeing of clients. As noted earlier, thiscontact facilitates safer using habits7 (forinstance, use of smaller-gauge 1mlneedles instead of 2ml to minimise veindamage8) provides opportunities toundertake treatment, increases detectionof conditions requiring primary health-care or medical treatment (for instance,abscesses, general infections and poorhealth), and provides opportunities forthe development of increased life-skillsand coping strategies for users. In SIFsin Zurich, Basel and Berne, some clientshave been documented to entertreatment as a result of attending SIFs(Dolan & Wodak).

With the increased accessibility ofeducation, counselling and treatment,there is an increased potential for usersto diminish their use and perhaps toeventually cease it. Evidence gatheredfrom overseas SIF programs inFrankfurt and Rotterdam indicates thatwhen clients are provided with theopportunity to engage in skills programsand community activities, they decreasedtheir drug use (JSCSIR, 1998).9

It has been proposed also that the “life-stabilising” influence of these programsand activities in SIFs could contribute tothe reduction of criminal activity ofclients. Needless to say, resort to crimewill probably always be a consequence ofthe illicit drug black market. But, as theNSW Report on the Establishment or Trial ofSafe Injecting Rooms conjectures “ . . .when an injecting drug user gains morecontrol over his or her life, it is morelikely that will cease or reduce theirinvolvement in petty or opportunistic

7 Clients in Swiss SIFs report themselves toinject more safely (Haemmig, 1996).8 Staff at the Berne SIF successfullyencouraged users to switch to the smallerbore syringes. (Dolan & Wodak, 1996)9 It should be kept in mind that there havebeen very few impact evaluation studiesconducted of overseas SIFs.

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crime”.10 One recent survey study ofclients of the Berne SIF in Switzerlandindicated a self-reported reduction (over5 years) in their reliance on drug dealingas a source of income (Buerki, et. al.,1996).

One of the significant and primarybenefits of safe injecting facilities is theircapacity to respond immediately andeffectively to resuscitate clients whooverdose, and to reduce the incidence ofoverdose in the facilities themselves, aswell as in the community. Participants inthe Melbourne CBD street injectorsurvey stated that they were hesitant toassist in peer overdose incidents on thestreet because of the possibility ofdisease transmission, fear of beingdetected themselves carrying drugs, andbecause of the presence of the generalpublic (Don, 1998). These factors wouldnot be a significant issue in SIFs, wherestaff would immediately assist overdose,and where users could be educated aboutappropriate modes of assistance forstreet overdose, as well as safer injectinghabits.11

There have been no fatal overdoses inany overseas SIF. Overdoses in theFrankfurt community have declinedfrom 147 in 1991 to 26 in 1997, and thishas been attributed to a range of harmreduction programs of which SIFs are akey part (Frankfurt, 1998). A decrease inthe incidence of overdose has obviousbenefits for users. The 1998 NSW JointSelect Committee Investigation into SafeInjecting Rooms cited some estimates ofthe number of overdose deaths thatcould be prevented by SIFs. Oneestimate suggested that an injectingfacility with 600 injections per daywould, in every 100 days, prevent the

10 P. 100, NSW Joint Select CommitteeInvestigation into Safe Injecting Rooms(1998).11 One effective habit which can beencouraged in users through SIFs is to taketheir drugs in two injections, rather than allat once. In this way, some initial idea can begained of the strength and purity of the drugbeing injected.

one death that would otherwise be likelyto occur without a SIF. Another estimateis that a SIF with 120 injections per daywould prevent a death as often as oncein every 7 weeks. Estimates based onoverseas experience suggest theprevention of one death in every fivedays.12

As well as these obvious personalbenefits, there are considerable benefitsto be had to the broader community. Itcould be expected that the occupationalharms to police and emergency workerswho would otherwise attend overdoseswould be averted to some degree. Andthen there are well-known savings to thecommunity resources that would beexpended in dealing with fatal and non-fatal overdoses.

The most obvious are savings toambulance and hospital emergencydepartment resources. It has recentlybeen estimated that ambulances attended205 overdoses in the Fitzroy/Collingwood area between July andOctober, 1998. At an estimated cost of$600 per attendance, the presence of aSIF could have produced a potentialsaving of over $120, 000 in attendancecosts for this period in that small area.13

This amounts to $360, 000 per annumsaved. Considerable savings could alsobe made to hospital casualty andemergency units. As well as this, therewould be significant costs to be saved inconnection with the rehabilitation ofusers who become disabled as a result ofnon-fatal overdose.

Apart from these economic savings inrelation to overdose, there have beenother projected resource benefits in

12 P. 79, NSW Joint Select CommitteeInvestigation into Safe Injecting Rooms(1998). These estimates were presented tothe NSW Committee by Professor JohnKaldor, Deputy Director of the NationalCentre in HIV Epidemiology and ClinicalResearch.

13 The estimate is based on discussions withepidemiologists at Turning Point Epicentre.

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connection with SIFs. Some of these areas follows:

� A reduction in the health-care costsof serious blood-borne viruses. Ithas been estimated that one HIVinfection costs the communityapproximately $100, 000.The directhealth-care costs per person ofHepatitis C infection have beenestimated to be $14,000 perinfection, or $150 million per annumin Australia (Brown & Crofts, 1998).However, it is suggested that aburden of $71 million per year isadded to health-care costs as a resultof new infections in NSW; 14

� A reduction in the costs of SIFclients’ general primary health-care,through earlier detection andtreatment of general health needs;

� A reduction in costs associated withneedle/syringe clean-ups, andgeneral maintenance of using areas.In Swiss cities with SIFs, there arefewer discarded syringes (Haemmig,1996)

The advantages of officially sanctionedSIFs also need to be judged in thecontext of increasing calls from certainsectors of the public for theestablishment of such facilities, includingsome non-government drug serviceagencies which have the resourcecapacity and apparent willingness toestablish them. If there is sufficientwillingness on the part of theseotherwise respectable agencies to act indisobedience of the law and to establisha SIF, then this introduces the possibilityof under-resourcing, poor practice, andeven, perhaps, corruption andcriminality.15 These possibilities can arisein unregulated, under-resourced and

14 These cost estimations were presentedrespectively to the NSW Joint SelectCommittee Investigation into Safe InjectingRooms by Professor John Kaldor, and Mr.Stuart Loveday, Executive Officer, HepatitisC Council.15 These issues have also been broached inWood 1997.

unmonitored facilities. There is somesense, therefore, in having an officiallyregulated or sponsored SIF incircumstances where it is inevitable thatone will be set up anyway, but illegallyand officially unmonitored.

The brief overview above gives anindication of some of the ways in whichthe provision of safe injecting facilitiescould act to decrease some of the harms,risks and nuisances associated withpublic drug use. However, not all druginterventions are completely harm-free,and there is always the possibility thatsafe injecting facilities will themselves actto produce certain harms. Arepresentative discussion of SIFs willneed to encompass not only theiradvantages, but also their drawbacks,and solid conclusions about theirviability will only emerge in the light ofhow these advantages and disadvantagesbalance out against each other. Thefollowing section outlines what havebeen perceived by some to be thepossible disadvantages of safe injectingfacilities. Where appropriate, someresponses are proposed to some of theseconcerns and perceptions.

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4. Concerns that have been expressed about Safe Injecting Facilities

Many of the major concerns that havebeen expressed about safe injectingrooms revolve around the possibility thatthey may not sufficiently remove theproblems of public nuisance they aredesigned to, and might make them, andother harms, worse in certain ways. Forexample, it could be argued that even ifSIFs play a role in removing theoccurrence of injecting from business,consumer and residential areas, clientsleaving SIFs may still constitute a publicnuisance through being intoxicated.

Although this argument might seemplausible, the available evidence suggeststhat this problem may not eventuate allthat readily. In Frankfurt,neighbourhood complaints about druguse dropped as a result of that city’scomprehensive harm-reduction strategy,of which safe injecting rooms are acentral part (Kemmesies, 1995). Thereare also some other significant concernsabout safe injecting facilities. The majorand most forceful of these are listedbelow.

The ‘Honey-pot” hypothesis: It has beenargued that an established, governmentsanctioned safe injecting facility in somearea might act as a strong attraction forusers and traffickers from outside thearea. If this were the case, and thesepeople did frequently enter the area insufficient numbers, the problems thatthe SIF was designed to address wouldnot have been averted at all. Therewould be significant public nuisancecreated, along with many of the otherharms associated with a visible drugmarket. So, the hypothesis is that thepublic nuisance and associated harmsthat would be caused by SIFs attractingoutside users and traffickers, wouldnegate the public nuisance andassociated harms prevented by thoseSIFs, and may even make thoseproblems worse than would have beenwithout SIFs.

Various factors, though, suggest that thishoney-pot effect may not be as strong or

as inevitable or as likely as it mightinitially seem. A number of measures canbe taken to minimise the possibility of ahoney-pot effect. One measure adoptedin overseas SIFs is to regulate who iseligible to enter the facility through asystem of registering clients (who mustbe established local users and must applyfor registration). If this regime ofrestricted access becomes commonknowledge among users, then there isless incentive for outsiders to come intothe vicinity seeking access to the SIF.

It could be replied here, though, that thismight not stop more traffickers cominginto the vicinity, knowing there will be asure market, and other non-client userscoming in seeking a sure deal from thosetraffickers. There might be something inthis suggestion. But, it really needs to beviewed in light of the fact that thespecific localities in which SIFs areintended to operate will already be wellestablished hotspots of public use andtrafficking, which are also already well-known to users as places of opentrafficking and use. This suggests thatany users who would be inclined to visitthe area in order to purchase and/or useare already likely to be doing just that. Itis not clear that the existence of a SIF inthe area would provide any independentincentive for more users to come in thanwould have come anyway.

There are also other measures, some ofwhich have been successfully adoptedoverseas, to actively decrease theincidence of use and trafficking in thevicinity of SIFs, including:

� Maintaining a consistent policepresence around SIF localities toprovide disincentive to traffickers

� Ban or suspend clients who deal orbuy in the vicinity of their SIFs.

� Locate SIFs as discretely as possibleso as not to advertise too widelytheir presence.

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It has been suggested also that it is wiseto establish SIFs around a number ofhotspots of street use in order topreclude any possibility that one localitywill be stigmatised in the eyes of thepublic as an “illicit drug centre”(Micallef, 1998) or targeted by users andtraffickers as the place to go. If theincidence of dealing can be reduced inthe vicinity of SIFs, then it is likely thatthere will be less occasion for drug-related property crime in the local area aswell.

It is also worth noting here, inconnection with the issue of communitydisturbance, some anecdotalobservations recently made by a recentvisitor to a central Berne SIF:

Arriving at Berne railway station weenquired of the Tourist InformationCentre about the location of thesafe injecting facility. In a verymatter of fact manner the assistantpointed us in the right direction. Onlocating the street we then asked apassing elderly nun which was thebuilding. Without batting an eyelidshe directed us to a nearby door.The premises were a cross betweena no frills coffee bar and a medicalclinic.16

From this description, the SIF inquestion had become such a normalisedfeature of the Berne city-scape that itelicited little in the way of any notableresponse, and certainly not anantagonistic one.

Official support for SIFs might convey theattitude that injecting drug use is acceptable, andmight consequently contribute to an increase inintravenous drug use. This perception is acommon one, but it is not clear whatevidence there is to suppose that amessage of acceptability is being sent,and if there is, that this will contribute toincreased use. If SIFs are establisheddiscretely, then adverse messages will beminimised. Also, if the image of SIFs is 16 Tony Trimingham of the TriminghamFoundation, ADCA Update Email List,April 8, 1999.

managed well, a constructive messagecould be produced - perhaps somethingto the effect that SIFs exist because ofthe potential dangers and harms ofinjecting drug use in certain contexts.The message here is a dual one: thatinjecting use in these contexts is aharmful activity, and that the state isresponsible and compassionate in theface of these harms.

It has been suggested by the NSW JointSelect Committee into Safe InjectingRooms that community education wouldbe essential to the establishment of SIFs,as well as ongoing communityinvolvement in their planning andoperation. This would help dispel anyconfusion, for instance, that might arisein connection between standard lawsagainst drug use in the broadercommunity, on the one hand, andexemptions in the context of SIFs, onthe other.

Even if there is no strong reason tothink that SIFs will condone or increaseinjecting drug use in the widercommunity, it has been suggested thatSIFs might act to maintain injecting druguse among people who are establishedusers, and perhaps to further encourageor entrench that use in younger clientswho are not so established, throughmaking it easier for them. With respectto clients with established usage, one ofthe express roles of SIFs is to providethem with opportunities to accesstreatment and rehabilitation, in order toempower them to moderate their use. Ifthe “in-house culture” of SIFs explicitlyreflects this push toward treatment andrehabilitation, then this will help negateany use-prolonging effect that SIFs mayhave.17 With respect to younger, non-established users, the system adopted inZurich SIFs is to register only existingand persistent problematic street userswho are local residents (Dolan &Wodak). The idea there is that youngnew users would not become clients of 17 In the Netherlands, there is a roomprovided in which to smoke heroin, so as notto entrench injecting as the route ofadministration.

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SIFs. A similar scheme of registeringonly established users as clients could beadopted in Victoria. The disadvantagewith this option, however, is that itexcludes just those users who are most atrisk, ie., young new users.

SIFs will not be able to effectively minister totheir intended target group. This lastsuggestion about the intended clientelefor SIFs brings to light some furtherconcerns about just how well SIFs cantarget their clientele, given thecircumstances in which they are intendedto operate. One of the suggestions madeabove to reduce a honey-pot effect is toregister only established local users asSIF clients, the local user requirementbeing intended as a disincentive tooutsiders coming into the vicinity. Thefact is, though, many of the persistentfrequenters of the street injectinghotspots in Melbourne are itinerant andnot necessarily from the local area, andare indeed often homeless (Don, 1998).If these are the target group – the groupwho are at risk through street injecting,and whose presence creates harm in thelocality – then they will be missed if

entry to SIFs is restricted to localresidents.

Other than residence status, it is hard toknow what other solid and consistentevidence of being a “local user” theremight be. Similarly, if the target is userswho have an established history of use,then it is not clear how this can bereliably determined among street userswho are again itinerant, and who are alsothe most marginalised of users whoaccess treatment, primary health-careand other health-care recording serviceslittle. On top of this, most of the street-level users are youth (Fitzgerald, et. al.,1998), and any age restriction forregistration to avoid any possibility thatSIFs might further encourage injectinguse among young users will thereforemiss the target group.

The planning, design andimplementation of SIFs in Victoria willneed to address the issues of exactlywhat clientele group it intends to target,and just what means are available toeffectively capture that target clientele.

5. Legal issues relating to Safe Injecting Facilities

Some of the most difficult issues to betackled with safe injecting facilities arelegal and legislative ones revolvingaround:

1. Criminal Liability: Conflicts with, andexemptions from, existing State lawsprohibiting illicit drug use and aiding andabetting that use.

2. Observance of international treaties.Australia is signatory to (and so boundby) various international treaties thatrequire possession and use of scheduleddrugs to be prohibited by signatorystates.

3. Civil Liability: The possibility of themanagers and sponsors of SIFs being

legally liable for injuries sustained to SIFclients, staff and third-parties.

1. Criminal Liability. The operation ofSIFs would conflict with current lawslargely on two counts: (i) whereindividual clients, by injecting drugs,would be acting in contravention of lawswhich prohibit the possession and use ofscheduled drugs; and (ii) where themanagers or sponsors of SIFs, inproviding facilities specifically designedto facilitate the injecting of prohibiteddrugs, would be acting to aid and abet acrime or acting to incite a crime.

The NSW Committee Investigation intoSafe Injecting Rooms identified threeways (both legislative and non-legislative)in which SIFs could be formally and

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officially mandated by the state. Thestrongest option is to explicitly amendthe existing legislative acts whichprohibit the use and abetting of use ofillicit drugs to provide for the existenceof SIFs. This could be done either bycreating a new part to the Act, or bycreating a new separate Act specificallydevoted to injecting facilities.

The second, slightly weaker, option is tosimply amend and qualify current Actsby providing regulations exempting SIFs(their clients and managers/sponsors)from the operation of those Acts. Thisoption avoids having to go through theentire process of creating new legislationor significantly adding to existinglegislation.

The third option is a non-legislative onewhich relies on the establishment ofadministrative protocol agreementsbetween police and the Director ofPublic Prosecutions. The idea with this isthat even though the activities withinSIFs remain illegal on the books, thepolice force uses its discretionary power(through various means including ChiefCommissioners instructions andoperational protocols) to refrain frompursuing and charging clients andmanagement of SIFs. The Office of theDirector of Public Prosecutions wouldalso use its discretionary powers torefrain from prosecuting in this matter.18

The stronger options of creating, addingto, or amending legislation will providethe most consistency and certainty, andwill have all the force that comes withlegislation. However, from a pragmaticpoint of view, the prospect of bringingabout this sort of legislative reformmight be low, given that it wouldpresumably require a very high degree ofstate-wide community consensus.Legislative measures can also be lessthan flexible when it comes toresponding to changing and unforeseencircumstances, given the lengthy 18 A non-legislative administrative protocoloperates in the case of the current CannabisCautioning and Drug Diversion schemescurrently operating in Victoria.

processes involved in modifyinglegislation. Also, even though it isentirely questionable as to whether theofficial sanctioning of SIFs will send aconfused or wrong message about druguse to the community, it might be arguedthat if there is any danger at all of that, itmight arise most acutely where SIFs arepublicly enshrined in state legislation asacceptable. An administrative protocol,on the other hand, does have moreflexibility when it comes to respondingto any changes in arrangements andallowances that may be needed. And ifthe sending of unintended messages is aconcern, these protocols might be seento hold less chance of that, seeing theydo not publicly institutionalise SIFs.

The major disadvantage of sanctioningSIFs through administrative protocols isthe fact that they are purely at thediscretion of the Police and the Office ofPublic Prosecutions. Although, inpractice, any such protocol would needstate government approval for itsadoption or withdrawal, there is still lessthan the certainty and consistency that isprovided by legislation. [Please refer tofootnote 22 below for further commentson approaches to sanctioning SIFs].

2. Observance of International Treaties.Australia is signatory to a number ofinternational treaty conventions,19 themain thrust of which commit Australiato treating the possession, use andsupply of scheduled drugs as punishableoffences. If the injecting drug use thattakes place in SIFs were to be sanctionedby the state, by whichever of the modesdiscussed above, this might appear toconflict with those conventions.

However, this is not necessarily the case.There are provisions within the 1961Single Convention on Narcotic Drugs20

that allow the possession and use ofscheduled drugs for medical andscientific research purposes, including 19 Namely, the 1961 Single Convention onNarcotic Drugs, and the 1988 ConventionAgainst Illicit Traffic in Narcotic Drugs andPsychotropic Substances.20 Article 2(5)(b)

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controlled clinical trials. This means thatthe possession and use that takes placewithin SIFs could be legitimatelysanctioned by Victoria in the eyes ofinternational treaties if SIFs are designedto operate as medical or scientific clinicaltrials. There is no doubt that if SIFs areto be implemented, then they should beimplemented in the first instance asclinical trials, where rigorous andsystematic monitoring and evaluationtakes place. So, there are quite goodindependent reasons for introducingSIFs in the form of clinical trials.

However, a good clinical trial will alwayshave a determinate time frame, at theend of which it will be completed. Whatthen, though? A good clinical trial willalso be conducted with the express andcentral purpose of determining whetherSIFs are scientifically viable as anongoing public health-care arrangement.But if an ongoing arrangement is nolonger a trial, it can no longer be justifiedunder the relevant provision of theSingle Convention. Moreover, if noongoing SIF arrangement is allowable,this arguably brings into question thewhole point of having SIFs as a genuineclinical trial in the first place.21

What is really needed here is somefurther provision under internationaltreaties which allows SIFs as an ongoingconcern. As it happens, there is such aprovision built into the qualificationsexpressed in Article 2(5)(b) which statesthat possession, use and supply shouldbe prohibited only if the prevailingconditions in the country “render it themost appropriate means of protectingthe public health and welfare”. Thismeans that if SIFs can be shown to bebeneficial to public health and welfare inVictoria, they would be allowable underthis provision.

This suggests that, from the point ofview of international treaties, thesanctioning of safe injecting facilities as 21 Though it could be argued that havingsuch trials might provide further relevantinformation for assessing theappropriateness of the existing legislation.

an ongoing concern might best be donein two stages: firstly, as a clinical trialjustified under the “medical andscientific purposes” clause of Article2(5)(b); and then, if the trial is successful,and SIFs are shown to be viable to theextent that without them public healthand welfare would not be appropriatelyprotected, then SIFs could be justified asan ongoing concern by appeal to thesecond provision in Article 2(5)(b), justnoted above.22,23

3. Civil Liability: Clearly, any facility thatallows, and sets out to oversee, apotentially dangerous activity like heroinor cocaine injecting, will be at risk ofbeing legally liable for damage andinjuries incurred to people as a result ofthe conduct of that activity. It might be,for instance that a client overdoses andsuffers a disability as a result of notbeing revived quickly enough, or that astaff member is assaulted or suffersinjury in the conduct of their duties, orthat an uninvolved third-party is, say, hitby a car driven by a user under theinfluence of a drug recently injected at aSIF. Unless issues can be resolved aboutthe degree to which the management andsponsors of SIFs may be legally liable insuch cases, and the degree to which theycan insure against that risk or otherwiseprotect themselves, SIFs could not beconsidered as a practical option.

It is not clear that SIFs would introduceany particular or peculiar problems inthis area that wouldn’t apply already toother health-care or treatment facilities.With respect to clients, it can be argued 22 It may well be also, that a SIF trial wouldbe best mandated through administrativeprotocol approach, and perhaps legislativelyas an ongoing operation if it is shown to besubstantially and enduringly beneficial topublic health and welfare. From a pragmaticpoint of view also, the existence of asuccessful rigorous SIF trial might help toachieve the sort of community consensusthat is important for legislative changes.23 The fact that SIFs have operated inEurope for some time suggests thatinternational conventions can be interpretedin a way that is compatible with the statesanctioning of these facilities.

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that the management of any suchoperation owes a common law duty ofcare to any client who enters thepremises. This means that SIF managersare legally responsible for reparation inthe case of death or injury to clients onlywhen the managers have not acted with“reasonable care” to avoid or preventthe prospect of the death or injury.24 Ithas also been argued25 that clients enterthe SIF voluntarily to enjoy theperceived benefits of the facilities andcan be taken to have consented to therisks involved (assuming they have beenproperly informed by staff). In this case,clients would only have recourse tolitigation if injured through careless actsof the staff and management of SIFs. Insome states as well, immunity isprovided to the state in respect of deathor injury in relation to the care of(alcoholically) intoxicated people. Thisindemnity could be extended to thoseunder the influence of injectable drugs.The bottom line, though, is that SIFs arespecifically designed to minimise theprospect of death or injury resultingfrom injecting drug use, and so theoccasions on which death or injurymight occur are very minimal. It shouldbe kept in mind also, that no deaths haveoccurred in SIFs in Europe.26

With respect to the civil liability ofmanagement for injuries to the staff ofSIFs, there again do not appear to be anyunique problems. Staff would be eligibleto be protected under whateveroccupational health and safety acts andregulations operate for health-careworkers, and it could be argued thatlitigation would be pursuable only uponneglect of those acts and regulations onthe part of SIF management.

24 Advice given to the ACT Minister ofHealth, Michael Moore, by the ACTGovernment Solicitor’s Office, November23, 1998.25 In advice given to the ACT Minister ofHealth, Michael Moore, by Hunt & HuntLawyers, Canberra ACT, December 7, 1998.26 In Frankfurt, clients had to sign to say theywere over 18 and understood the risks ofinjecting.

Third party liability matters tend to bemore complex because they involveissues of causation, and rely on asufficiently plausible case that there wasa causal connection between theinjecting at the SIF and the subsequentharm to some third-party. In cases wherea causal connection can be establishedbetween injecting at a SIF and asubsequent third-party injury, it may notbe a sufficient defence that the SIF inquestion was just allowing the user to dosomething (ie. inject drugs) more safelythat he or she was going to do anyway. Itdoes seem reasonable though, that SIFmanagement should not be liable forthird-party harms that were notforeseeable or expectable. Difficult as itmay be to establish such things, it is notclear that the civil liability matters thatarise in the case of SIFs will be any morecomplex than those arising in the case ofhotels, or venues where alcohol is soldand consumed, for instance.

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6. Models for Safe Injecting Facilities

There are various views about what thebest model of operation would be for asafe injecting facility. Two of the centralobjectives in providing a safe andsupervised injecting environment are tominimise the health-related risks ofinjecting, and to increase the access ofat-risk injectors to the primary health-care, counselling and rehabilitativeopportunities that they wouldn’totherwise access. The health of clients isa key focus with safe injecting facilities,and it makes sense therefore that suchfacilities should operate in conjunctionwith primary health-care services ofsome sort. The question, though, is howthey should be incorporated.

There are, broadly speaking, twopossibilities. One possibility is to have afacility that is devoted to safe injecting,but which also includes somesupplementary primary health careservices. The other possibility is to makeprovision for safe injecting as just oneaspect or part of a broader health-carecentre or unit, the central purpose ofwhich is to provide a range of primaryhealth care services for injecting drugusers.

Though both of these models ofincorporation equally address theimmediate harms of street-basedinjecting, there are a number for reasonsfor preferring the latter model. The mainreason is its explicit general health-care

emphasis, and the fact that it places safeinjecting in the context of the widerhealth needs of injectors. Safer injecting,important as it clearly is, is merely one ofthe many and diverse health and socialneeds of itinerant, problematic injectors.It seems appropriate, therefore, thatprovision for safe injecting should bemade within a setting that addresses allthese needs, and in so doing, ministers toinjectors as persons.

This holistic approach could serve twopurposes: firstly, it may go some waytoward lessening the sense ofhopelessness and alienation that manyproblematic injectors feel; and secondly,it may increase users’ own adoption ofsafer injecting behaviours throughincreasing their sense of being sociallysupported, less marginalised and moreempowered in their lives. A “primaryhealth-care centre” model of safeinjecting might also lend itself morereadily to users themselves becominginvolved in the running and operation ofthe centre, thereby enhancing a sense ofownership and empowerment on thepart of the target group. A primaryhealth-care centre is also likely to havemore comprehensively trained, qualifiedand on-going health-care staff than amere safe injecting facility. This meansthat there will be staff who can work ondemand reduction and prevention, dealwith overdose problems and also follow-up on people who overdose and recover.

7. Conclusion

The general upshot of all this is thatthere are potentially strong advantages inhaving properly organised and operatedSIFs. There are possible disadvantages,as well, and there are dangers in viewingSIFs as a panacea for all the harms ofstreet-based injecting. One of thedangers is that of ignoring or neglectingsome of the other options that arecurrently available to address suchharms. For example, there are many

ways in which needle and syringeprograms could be improved. Forexample, extending the range of injectingequipment provided, extending thehours of operation, improved fundingfor disposal hotlines/services. Also,there are a range of steps that local andstate governments could take to addressthe issues of the street-basedenvironment of public injecting. Forexample, the design and maintenance of

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public toilets, provision and maintenanceof disposal bins, improved streetlighting, general upkeep andmaintenance of public areas andamenities, and improved communitydiscussion of the issue.

Another danger in viewing SIFs as apanacea is to overlook the possibilitythat even if a SIF may be appropriateand workable in one area where street-based injecting takes place, such facilitiesmay not be appropriate for all suchareas. The nature of the harms of street-based injecting, and indeed, the degree towhich the local community might bereceptive or supportive of the possibility,may well vary from region to region. It iscrucial to maintain a clear sense of thefact that SIFs need to be viewed as a part(albeit a significant part) of a package ofapproaches.

If SIFs are seriously considered as aharm-minimisation option, they need tobe viewed in the light of the limitationsthey might have in their proposedcontext of operation. It is crucial alsothat their operation be governed by aminimum set of standardised operationalguidelines for SIFs which need to bedeveloped in consultation with all thekey stakeholders.27 Similarly, thedecision-making process concerningtheir viability for Victoria and the natureof their implementation should be asinclusive as possible, and take intoaccount the concerns, interests andperspectives of all the key stake-holdersin the community. It is only in thecontext of this broader, informedcommunity deliberation that appropriatedecisions about safe injecting facilitiescan be made.

27 Many of the points in this, and theprevious paragraph were suggested by CraigFry, Research Fellow at Turning PointAlcohol and Drug Centre.

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Brown, K and Crofts, N. 1998 “Health-care Costs of a Continuing Epidemic ofHepatitis C Virus Infection Among Injecting Drug Users Australian and New ZealandJournal of Public Health, 1998; Vol. 22. Pp. 384-388.

Buerki, C., Egger, M. Hammig R., Minder-Nejedly M, and Malinverni, 1996, HIV-RiskBehavior Among Street Intravenous Drug Users Attending a Shooting Room in Berne, Switzerland,1990 and 1995, University Psychiatric Services, Department of Social and PreventiveMedicine and Medical Polyclinic, University of Berne.

Darke, S, Zador, D & Sunjic S, 1997 Toxicological Findings and Circumstances of Heroin-related Deaths in South West Sydney Technical report No. 40, NDARC,.

Dolan, K. & Wodak, A. 1996 Final Report on Injecting Rooms in Switzerland, (unpublishedreport)

Don, Kathy 1998 There Will be No-one There for Me: Injecting Drug Use Harm ReductionTraining Project Project Report to the City of Melbourne.

Fitzgerald, J.L., Broad, S. & Dare, A., 1998 Regulating the Street Heroin Market inFitzroy/Collingwood, VicHealth/University of Melbourne.

Frankfurt, 1998. Integrative Drogenhilfe Annual Report 1997, Frankfurt Germany:Integrative Drogenhilfe an der Fachhochschule Frankfurt am main e. V.

Fry, C., Fox, C. & Rumbold, G. 1999. “Establishing Safe Injecting Rooms in Australia:Attitudes and Opinions of People Who Inject Drugs in Melbourne.” Paper presented atthe 10th International Conference on the Reduction of Drug-related Harm, March 21-25, Geneva,Switzerland.

Haemmig, Robert B. 1996 “Speech on Swiss Experiences with Heroin Dispension,Fixer Rooms and Harm-reduction in Prison”, Conference Overlastenverlichting. TrimbosInstitute, 21 November.

Ippolito, G., De Carli, G., Puro, V. et. al. 1994. “Device-specific Risk of Needle-stickInjury to Health-care Workers” Journal of the American Medical Association, V. 272, pp.607-610.

Joint Select Committee into Safe Injecting Rooms, 1998, Report on the Establishment orTrial of Safe Injecting Rooms. Parliament of NSW

Kemmesies, Uwe E. (1995) “Drug Scene Survey, Frankfurt am Main 1995: The‘Open Drug Scene’ and the Availability of Health Rooms in Frankfurt am Main”,Frankfurt, Germany: Stadt Frankfurt/Dezernat Frauen und Gesundheit,Drugenreferat.

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Micallef, Eddie. 1998 Safe Injecting Facilities: Should Victoria have a SIF Pilot-Trial?Discussion Paper. Drugs and Crime Prevention Committee, Parliament of Victoria.

NDARC (National Drug and Alcohol Research Centre) 1999. “A Review of theLiterature on Needle and Syringe Programs”. Unpublished paper, 9 April, 1999

Trimingham, Tony 1999 ADCA Update Email List, April 8, 1999.

Wood, The Hon. Justice J. R. T., 1997. Royal Commission Into the New South Wales PoliceService. Government of New South Wales.