Registed Nurses' Association of Ontario

RNAO's Response on Bill 174: Cannabis, Smoke-Free Ontario and Road Safety Statute Law Amendment Act, 2017

RNAO's Response on Bill 174: Cannabis, Smoke-Free Ontario and Road Safety Statute Law Amendment Act, 2017

RNAO welcomes the opportunity to provide feedback to the Standing Committee on Justice Policy on Bill 174, An Act to enact the Cannabis Act, 2017, the Ontario Cannabis Retail Corporation Act, 2017 and the Smoke-Free Ontario Act, 2017, to repeal two Acts and to make amendments to the Highway Traffic Act respecting alcohol, drugs and other matters. For this submission, RNAO will use the short title of Bill 174, the Cannabis, Smoke-Free Ontario and Road Safety Statute Law Amendment Act, 2017.

RNAO is well positioned to comment on Bill 174 due to expertise developed through our ongoing Tobacco Free RNAO initiative, our Mental Health and Addiction Initiative, RNAO's clinical best practice guidelines program, and membership in the Executive Steering Committee for the Modernization of Smoke-Free Ontario. RNAO's extensive experience supporting excellence in clinical practice, professional development, and public policy, as well as our work with the public and our members to improve health and the health system have created a wealth of pertinent resources that are outlined and accessible in Appendix A.

A public health approach to alcohol, cannabis, tobacco, and other substances

RNAO endorses a public health approach to substances that have psychoactive properties (such as alcohol, cannabis, tobacco, and other substances) based on "the principles of social justice, attention to human rights and equity, evidence-informed policy and practice, and addressing the underlying determinants of health."

Ontario's public policies on alcohol and cannabis are currently being driven primarily by the Ministry of the Attorney General and the Ministry of Finance. In contrast, evidence-informed tobacco policy is being led by the Ministry of Health and Long-Term Care (MOHLTC). RNAO urges the province to move primary responsibility for alcohol and cannabis policy to the MOHLTC so a public health approach can be implemented, as opposed to a focus on commercialization and revenue generation.

RNAO urges the federal and provincial government to move ahead with cannabis legalization with strict legal regulation to decrease health and social harms. At the same time, Ontario has work to do to better align provincial policies with a more coherent and evidence-informed approach to alcohol, tobacco, and cannabis in order improve health and community outcomes. As shown in Figure 1, health and social harms are increased both by prohibition resulting in an unregulated criminal market and commercial promotion with an unregulated legal market.

Summary of RNAO Recommendations

Recommendation 1. RNAO recommends that the Ministry of Health and Long-Term Care be the lead agency to drive optimal public health outcomes through legislation, regulation, and public policies to reduce harm from alcohol, cannabis, tobacco, and other harmful substances in collaboration with other levels of government, ministries, and agencies as needed.

Recommendation 2. RNAO supports legalization of cannabis with strict regulation as the optimal approach to decrease health and social harms.

Recommendation 3. RNAO supports that the minimum age for non-medical cannabis purchase, possession, consumption, and distribution in Ontario be set at 19 years of age.

Recommendation 4. RNAO recommends that public education strategies be developed that are broad-based and informed by evidence from the Lower-Risk Cannabis Use Guidelines.

Recommendation 5. RNAO recommends that the province study and implement evidence-informed prevention/health promotion programs for cannabis use that are non-stigmatizing and include youth and young adults with lived experience in the planning, implementation, and evaluation of initiatives.

Recommendation 6. RNAO recommends creating an exemption for the consumption of cannabis in outdoor designated smoking areas on the properties of multi-unit housing, so long as there is proper signage and the activity occurs a regulated distance away from entrances/exits and outdoor playgrounds.

Recommendation 7. RNAO recommends providing specific regulatory authority for multi-unit housing decision-making bodies to create outdoor designated cannabis smoking areas on their properties.

Recommendation 8. RNAO recommends requiring signage warning of the risks of exposure to second-hand cannabis and tobacco smoke to be posted in the common areas of all multi-unit housing in Ontario.

Recommendation 9. RNAO recommends providing a more seamless and effective approach to enforce the ban on smoking of both cannabis and tobacco in public places and workplaces by enabling tobacco enforcement officers to also enforce the restriction on consumption of non-medical cannabis in public places (in addition to police officers).

Recommendation 10. RNAO recommends establishing requirements for equity training for the criminal justice system, including law enforcement, to ensure fair treatment of racialized and marginalized populations.

Recommendation 11. RNAO welcomes the creation of the Ontario Cannabis Retail Corporation and urges the province to:

  • Prohibit marketing, promotion, sponsorship, and advertising of cannabis. This should include comprehensive regulatory prohibitions to address advertising in movies, video games, and social media that may be directed specifically to youth.
  • Ensure products are sold in plain packaging with clear information about the characteristics of the product (e.g. tetrahydrocannabinol (THC) and cannabidiol content) and warnings about health risks.
  • Curtail higher-risk products such as higher-potency formulations and products designed to appeal to youth; In addition to controlling the potency (THC concentration), ensure quality (no pesticides, mould, and other harmful contaminants) and safety (product traceability, child-proof packages) standards are met.5
  • Limit availability, with caps on retail density and limits on hours of sale.
  • Storefront sales should be conducted from behind the counter (i.e. not off the shelf) by staff trained in challenge-and-refusal protocols who are able to provide information on relative risks of various formulations, products, and modes of delivery.
  • Curb cannabis demand through an effective pricing and tax structure. This includes encouraging use of lower-harm products over higher-harm products and discouraging harmful levels of consumption without increasing demand for contraband products. Revenues generated from taxes can be directed to public education, health promotion, and treatment services.

Recommendation 12: Open additional stand-alone cannabis stores in Northern Ontario by July 2018.

Recommendation 13. RNAO urges the government of Ontario to implement the comprehensive strategy outlined in the Smoke-Free Ontario Modernization: Report of the Executive Steering Committee.

Recommendation 14. RNAO recommends ensuring that the use of heated tobacco products will be prohibited under the Act. Amend 12(1) (1), Prohibitions, as follows:
Smoke, consume or hold lighted or heated tobacco.

Recommendation 15. RNAO recommends broadening the definition of "tobacco product accessory" to include waterpipes/hookahs, cigarette/rolling papers and any other accessory that is prescribed by regulation, and broadening the ban on the display of tobacco product accessories to include all tobacco product accessories, whether or not they are associated with a brand of tobacco product.

Recommendation 16. RNAO supports the zero tolerance approach to prohibiting driving after alcohol and/or drug use for: novice drivers with a graduated license; drivers age 21 years and under; and commercial drivers.

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RNAO's Response on Bill 174674.74 Ko
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