Amid numerous findings of neglect, a recent report by Ontario’s Auditor General revealed Doug Ford and his PC government were aware of the risks associated with closing several supervised consumption sites across the province before the decision was made.
The audit of Ontario’s Opioid Strategy, conducted by the Office of the Auditor General of Ontario as part of a larger annual report, confirmed the decision by Premier Ford and Health Minister Sylvia Jones to facilitate the closure of ten supervised consumption sites (SCS) by March and bar future ones from opening under specific conditions “was made without proper planning, impact analysis or public consultations.”
The highly critical report revealed “no formal consultation with key external stakeholders affected by the proposed new model, as well as Public Health Ontario, were conducted prior to the announcement of the new decision,” which was officially passed a day before the audit was released.
These sites — five of which are located in Toronto — have been ordered to close by no later than March 31, after the Province passed legislation that prevents such facilities within 200 metres of schools and childcare centres — despite clear knowledge of their proximity to such buildings which was part of the reporting for their application to operate. The legislation also prohibits any future sites from opening. Outside of Toronto, the other five sites that will be forced to close due to the new restrictions include one each in Ottawa, Kitchener, Thunder Bay, Hamilton and Guelph.
“We found that the Ministry has not performed comprehensive analysis to assess and quantify the impacts on and risks to public health and the health system prior to the finalization of its decision to introduce the new legislation,” the auditor general’s report highlighted.
“Our review of the government’s internal documents noted that the Ministry recognized the potential impacts to the health system of closing the 10 supervised consumption services sites, including: an increased risk of deaths from overdoses and emergency department visits; increased distances of public drug use and the public discarding of drug supplies; and no access within a responsible distance to supervised consumption services for Northern Ontarians going forward as a result of the closure of the only remaining site in Thunder Bay.”
The audit shows the PC decision was made despite direct evidence that indicates safe injection facilities, which provide a controlled environment for people to consume substances in a supervised setting with sterilized equipment and overdose-prevention support, have reversed thousands of drug-related fatalities since their inception. It also found the Province and Ministry of Health had not developed plans to mitigate the risks prior to making the decision, including increased overdoses and “the financial and operational burden on emergency departments.”.
“It speaks to our interest and our motivation to get things done,” Minister Jones recently told reporters, when asked about the lack of consultation or studies completed before making the decision to close several sites. “We have not bypassed due process, what we have done is ensured that we have a path forward and we are consulting with our stakeholders. We are seeing rising rates and we are doing something that we believe will ultimately make a difference to the people of Ontario.”
Her statements contradict several studies that show these sites actually reduce the risk of overdose. Highlighting that “Supervised consumption services at CTS (Consumption and Treatment Services) sites are proven life-saving interventions,” the Auditor General’s report found that between 2022 and 2023, the ten sites that have been ordered to close have successfully prevented fatalities from the over 1,500 overdoses that happened on-site. During that period, none of the over 2,500 opioid-related deaths in Ontario happened at CTS sites and none of the more than 3,600 overdoses reported by CTS sites resulted in death, the report detailed.
The audit identified a number of benefits to CTS sites, including overdose death prevention, providing clean and sterilized tools to prevent the transmission of diseases, and the opportunity for these sites to connect users to addiction treatment options and other services, such as mental health treatment, social supports and primary care.
When asked about the absence of studies backing the PC decision, Jones referred to two separate reviews initiated by the government and conducted on the City of Toronto’s South Riverdale Community Health Centre in 2024, which she said influenced the legislation in an effort to respond to community safety concerns. The reports outlined several community safety concerns around discarded needles, substances and other garbage in the neighbourhoods, with simple measures to mitigate these problems.
But the overall recommendation was to keep existing locations and actually expand them, acknowledging SCS “are a necessary public health service, implemented to save lives and prevent accidental overdose death related to substance use,” adding “Recent evidence demonstrates that these health services make a difference in opioid-related death rates based on proximity to the CTS.”
Addictions and Mental Health Ontario has warned that “Without access to harm reduction and addictions services, Ontarians are more likely to use alone, where they become increasingly susceptible to the often harmful and even fatal effects of an increasingly toxic drug supply.” The organization has instead stressed the best way to protect people from the increasingly toxic drug supply is to expand access to harm reduction services.
Jones’ misleading comments have been heavily criticized by advocates who suggest the Ford government simply does not want to address the ongoing opioid crisis.
Despite Addictions and Mental Health Ontario underlining that “Drug poisoning deaths are preventable deaths,” both opioid-related deaths and emergency department visits have increased by almost 300 percent between 2014 and 2023, with an average of seven deaths per day in Ontario from opioid-related causes in 2023 alone. According to data published by the Public Health Agency of Canada and referenced in the audit, the number of opioid-related deaths in Ontario has gone up by 205 percent since 2016 when the province’s Opioid Strategy was launched, slightly higher than the national increase of 200 percent.
The severity of the crisis has led several Ontario municipalities (including Belleville, Hamilton, Kingston and Niagara) to declare a state of emergency. Jones has denied that her government’s changes will cause further, possibly fatal, harm, and instead has reiterated, “People are not going to die, they are going to get access to treatment.”
Ontario’s Opioid Strategy, introduced by the Liberal government in 2016 prior to the PCs taking office in 2018, was initially driven by the unnecessary dispensing or over-prescribing of opioids. But the focus has since shifted, with an increase in the illegal supply of more potent opioids. With the heightened toxicity of these substances, the Auditor General's report stressed that “having access to sufficient and appropriate treatment and harm-reduction services is essential to combat the opioid crisis.”
The audit also found the Province's Opioid Strategy is outdated and does not adequately address the increased needs and risks of the current crisis, even with the PCs new HART Hubs model (Homelessness and Addiction Recovery Treatment). Since its implementation in 2016, the plan has not been updated to address the rising rates of opioid-related deaths. It identified that, “the outdated Strategy does not address ongoing issues, such as the disproportionate impact of the crisis on specific regions and population groups and emerging risks, including an increase in poly-substance use (that is, using multiple drugs at once, such as opioids with stimulants, and/or benzodiazepines) and the availability of more potent opioids from illegal markets.”
It recommended the provincial government develop a new holistic strategy that includes all best practices targeted at addressing current drivers of the opioid crisis, reducing their harms and preventing addiction and overdose while also developing a clear governance, accountability and leadership structure to inform future work on the Ministry’s response to the crisis. It also recommends implementing performance measures to evaluate progress of work and initiatives under the revised strategy and report annually on the results.
The AG report concluded “that the Ministry does not have effective processes in place to meet the challenging and changing nature of the opioid crisis in Ontario.” It found the Province has not effectively implemented the 2016 strategy or properly provided evidence-based services for people who require opioid-related services “in an equitable, integrated and timely manner.”
More alarmingly, it reported the Province did not provide a thorough, evidence-based business case analysis for its recently proposed Homelessness and Addiction Recovery Treatment (HART) Hubs, to ensure that they are responsive to the needs of the community.
In 2019 the Region of Peel developed its own Opioid Strategy in an effort to respond to the growing death rate. An accompanying needs assessment and feasibility study identified the demand for safe consumption sites to reduce substance related harms that would ultimately prevent overdoses, reduce the risk of transmission of bloodborne illnesses, decrease public drug use and drug litter and provide linkages to care for people who use drugs.
As part of the Region’s response, centered around a four-pillar approach, an interim location for a SCS in Peel was approved to meet the urgent need, with funding from Regional reserves to be provided for up to 24 months or until provincial CTS funding could be secured. Staff said at the time that they would learn from the interim site and scale up to a more permanent model that would rely on sustainable funding from the Province. A spokesperson for the Region told The Pointer earlier this year that Peel Public Health would be conducting a review of the site to “assess effective implementation and achievement of intended outcomes for people who use substances.”
The Region had been working on the launch of two permanent safe consumption sites, one in Brampton and one in Mississauga to address the ongoing overdose crisis. But the PC legislation has upended the Region’s plans. Meanwhile, data from the Region show Peel had 145 opioid-related deaths in 2023 — an increase over the previous year — with 19 in April, the worst month. In 2024, 27 deaths were reported in Peel between January and April (the latest available data), a 53 percent decrease from the 58 deaths reported during the same period in 2023.
Following the PC announcement in August, a regional spokesperson told The Pointer, “We are concerned, but we are waiting for further details.” The site, which opened in Brampton earlier this year is currently being funded by the Region through a federal exemption under the Controlled Drugs and Substances Act.
“We are working to understand what our options are moving forward. We plan to bring a report to Regional Council in 2025 for an update,” a spokesperson told The Pointer on December 18. According to data provided by the spokesperson, Peel’s site had more than 600 visits, including over 170 service users.
“Peel Public Health supports a comprehensive approach to substance use which focuses on substances, including opioids, through prevention, harm reduction, treatment and enforcement strategies. We resumed work on the harm reduction strategy in 2021 with a focus on the supervised consumption site,” the spokesperson said. “We will resume work for the other strategies with partners in 2025” with more information on the updated work to be shared with council this year.
The PCs through their legislation are redirecting funding toward implementing 19 new HART Hubs under a $378 million investment as part of the new strategy. Of the 10 sites ordered to close before March, nine of them currently funded by the Province will be given the option to transition to this new model. Up to an additional 10 HART Hubs will also be selected through a call for proposals.
These Hubs, the PCs previously explained, will add up to 375 supportive housing units, in addition to addiction recovery and treatment beds, however, they will not offer safe supply, supervised drug consumption or needle exchange programs. While they will not be allowed to deliver needle exchange programs, the PCs said needle return or collection services may be considered during the application process. The audit noted the government has not detailed the public health measures or the associated costs or developed a performance measurement plan, targets or timeline to evaluate the effectiveness of the hub model.
It found the transition to the revised model was decided without a needs-based assessment, and that the Ministry “did not conduct formal consultations with all affected external stakeholders,” such as users of the sites being closed and high-risk populations, including Northern communities and Indigenous and younger populations.
While the new model expands on addiction treatment and recovery services, it scales back on the harm reduction services available in Ontario, which the AG report stressed are “essential to combat the opioid crisis.” It points out that unlike CTS sites, “these hubs will not provide some key harm-reduction services, such as supervised consumption or needle exchange, despite the fact that these services have been proven to prevent overdose deaths.”
The audit recommended the PC government complete the following planning work before transitioning to the new HART Hubs.
- work with providers to support CTS users being impacted by any closure of a CTS site and to perform impact, risk and financial analysis;
- engage with all relevant stakeholders;
- develop a performance measurement plan; and
- deploy public health measures in areas where supervised consumption sites are closing
The PCs have agreed with the recommendations laid out in the audit and say they are “committed to working with providers to support clients who may be impacted by the closure” of any of the ten sites.
The government says it will perform "outreach to public health units to update their harm reduction strategies” and that the HART hubs will be subjected to a "third-party evaluation to determine outcomes, lessons learned and areas for improvement."
Sites currently funded under the CTS program that are planning to convert to a HART hub will be required to develop wind-down plans that outline impacts, risks and financial analysis, timelines, communication with existing clients and referrals to other health services.
Toronto’s Kensington Market Overdose Prevention Site, run by The Neighbourhood Group Community Services agency has launched a Charter challenge against the PC legislation, arguing the law strips residents of the right to life, liberty and security of the person, which are protected by Canada’s Charter.
According to the case being made, shutting down safe consumption sites will create dangerous conditions for people, causing a greater risk of harm from overdose and criminal prosecution.
The AG’s audit shows no work was done by the PCs to address these and other possible outcomes of their decision.