Submission to Health Canada on a proposal to control the derivatives and analogues of 4-piperidone and its salts under the Controlled Drugs and Substances Act

CDPC suggests that ongoing scheduling and prohibition of substances under the Controlled Drugs and Substances Act (CDSA) and Precursor Control Regulations (PCR) is having unintended negative effects, and alternative models for regulating all substances should be sought to balance the need to protect the health of Canadians against the negative effects of prohibition. [...] Background On October 28, 2023, Health Canada solicited comments and published a Notice of Intent proposing to amend item 27 of Schedule VI to the CDSA and item 28 of the Schedule to the PCR by expanding the existing listings of the fentanyl precursor 4- piperidone and its salts to include its derivatives and analogues under the CDSA. [...] We suggest that the persistent and growing scheduling of substances and pre-cursors does not achieve the intended outcome of reducing the use of substances and has unintended negative consequences, especially for people who use drugs. [...] Health Canada’s Notice of Intent to control the derivatives and analogues of the fentanyl precursor 4-piperidone and its salts under the CDSA notes: - “Between January 2016 and March 2023, there were a total of 38,514 apparent opioid toxicity deaths in Canada. [...] Recommendations CDCP recommends stopping the endless and harmful cycle of scheduling and prohibition and to follow recommendations and calls found in: - The August 2023 Report of the Office of the United Nations High Commissioner for Human Rights, Human rights challenges in addressing and countering all aspects of the world drug problem (A/HRC/54/53), specifically recommendations: - • (a) Adopt al.