Policy and Political Action

Policy & Political Action

Prescription Drug List: Naloxone File number: 16-100479-342

Dear Members of the Prescription Drug Status Committee,

The Registered Nurses' Association of Ontario (RNAO) is the professional association representing registered nurses, nurse practitioners, and nursing students in all roles and sectors across Ontario. RNAO appreciates this opportunity to provide feedback on the proposal to revise the listing of naloxone on the Prescription Drug List to permit the non-prescription use of naloxone.

RNAO is a strong proponent for harm reduction, based on the public health evidence, clinical experience of our members, and values of respecting human dignity with a commitment to inclusivity, equity, and social justice. RNAO advocates for public policies that support harm reduction at the federal, provincial, and municipal levels, and for the use of clinical best practice guidelines that build capacity in mental health and addictions.
Along with the Canadian Nurses Association and the Association of Registered Nurses of British Columbia, RNAO was granted intervener status in the Supreme Court of Canada case concerning the Insite supervised injection site.

Consistent with the evidence-based recommendations of the World Health Organization, the National Advisory Council on Prescription Drug Misuse, and the Municipal Drug Strategy Coordinators' Network of Ontario, RNAO urges Health Canada to increase access to naloxone to prevent deaths from narcotic overdoses. As Health Canada's own Benefit-Harm-Uncertainty assessment of naloxone found, "the benefit of quickly responding to an overdose far outweighed" minimal risks that pose "no serious harm." Toronto Public Health's peer-based program (Preventing Overdose in Toronto or POINT) has demonstrated that lives can be saved when lay people have education and access to naloxone. Since 2011, the POINT program has provided the community with training and over 2,100 naloxone kits, which have been used in over 370 overdose situations with positive outcomes. RNAO is also aware of a number of other promising initiatives throughout the province to increase access to naloxone. However, a co-ordinated and sustainable approach is needed.

Therefore, to prevent premature deaths from overdose, RNAO urges Health Canada to:

  • remove naloxone from the Prescription Drug List immediately.
  • approve additional naloxone formulations -- such as auto-injectors similar to an Epi-Pen® and intra-nasal devices -- similar to those available in Europe and the United States
  • work with federal and provincial ministries to add naloxone to federal and provincial drug formularies so that this proven lifesaver will be available without cost to people with low incomes.
  • support federal ministries in the creation of Good Samaritan legislation to address fears that hinder calling 911 and/or emergency responders.

    By taking these actions, the federal government will enable further action at the provincial, municipal, and neighbourhood levels to improve health and build stronger communities. To support these efforts, RNAO will continue to advocate at the provincial level for a comprehensive and integrated overdose prevention strategy, informed by the recommendations in the Prescription for Life report.

    Thank you for the opportunity to provide feedback on the need for urgent action to prevent more avoidable deaths by increasing access to naloxone.

    Kind regards,

    Doris Grinspun, RN, MSN, PhD, LLD(hon), O.ONT
    Chief Executive Officer, RNAO

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