making drug policy together: reflections on evidence, engagement and participation

Accepted Manuscript

Title: Making drug policy together: Reflections on evidence,engagement and participation

Author: Marcus Roberts

PII: S0955-3959(14)00090-5DOI: http://dx.doi.org/doi:10.1016/j.drugpo.2014.04.014Reference: DRUPOL 1374

To appear in: International Journal of Drug Policy

Received date: 17-10-2013Revised date: 28-3-2014Accepted date: 20-4-2014

Please cite this article as: Roberts, M.,Making drug policy together: Reflections onevidence, engagement and participation, International Journal of Drug Policy (2014),http://dx.doi.org/10.1016/j.drugpo.2014.04.014

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Making drug policy together:

Reflections on evidence, engagement and participation Dr Marcus Roberts, Director of Policy, DrugScope

Corresponding author:

Marcus Roberts

DrugScope, Asra House, 1 Long Lane, London SE1 4PG

E-mail: [email protected]

Tel: 020 7234 9733

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Reflections on evidence, engagement and politics

Key words: consultation, engagement, evidence, evidence-base, politics

Abstract

This commentary considers the relationship between evidence, engagement and

participation in drug policy governance. It argues that the use of various forms of

evidence (for example, statistical data and service user narratives) is critical for

meaningful stakeholder engagement and public participation in drug policy, as well

as effective policy design and implementation. The respective roles of these different

kinds of evidence in consultation processes need to be better understood. It

discusses the limits of evidence, which it suggests is rarely conclusive or decisive for

drug policy. This is partly because of the incompleteness of most research agendas

and the lack of consensus among researchers, but also because issues in drug

policy are inherently contestable, involving considerations that lie outside the

competency of drug policy specialist as such. In particular, this is because they

involve normative and evaluative issues that are properly political (for example,

about the relative weight to be accorded to different kinds of harm and benefit). It

concludes by supporting calls for a more nuanced undertstanding of the relationship

between evidence, engagement and politics than is implicit in the term ‘evidence

based policy’. It also argues that we should view the inherent contestability of drug

policy not as something that can or should be resolved by ‘objective’ evidence, but

as a source of vitality and creativity in policy development and evaluation.

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Reflections on evidence, engagement and participation

The report How to make drug policy better (UKDPC 2012a) identifies a number of

governance issues, including ‘better use of evidence’, ‘accountability and scrutiny’

and ‘stakeholder engagement’. So, how do they fit together?

In my UKDPC essay on ‘Consultation processes and good governance’ (Roberts M,

2012) I raised this question with reference to the role of public consultation and

engagement processes in drug policy governance. On the one hand, consultation is

intended to inform policy by helping to provide the evidence-base for policy

development. On the other, it provides an opportunity for representation of the views

and experiences of a range of individuals and organisations who are interested in

and/or affected by drug policy. I linked this to a distinction between two principles of

public engagement. First, a principle of fairness or inclusiveness in the distribution of

opportunities for participation. Second, a principle of competence or robustness in

determining the value of different contributions, requiring qualitative distinctions

between the views of participants (or, more accurately, of the experience, evidence

and/or argument that support them).

I am now less sure that this is necessarily a helpful way to describe the issues, and

would like to indicate how some of the apparent tensions might be creatively

managed in the interests of good policy governance. For simplicity’s sake, this could

be described as a discussion of the relationship between ‘evidence’, ‘engagement’

and ‘participation’, and as a challenge to a particular view of how this relationship

should work: that the purpose of public consultation and engagement is to provide

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the evidence-base to determine policy at the political level. By contrast, I will sketch

out the lineaments of an argument for what might be described as ‘evidence

informed pluralism’ with a strong emphasis on the need for on-going and iterative

policy processes (and – although I don’t discuss it here – for engagement

mechanisms that nurture and support discussion, learning and recalibration of policy

in the light of the lessons from implementation).

The nature of evidence

Three initial observations about evidence and drug policy.

First, a particularly high premium appears to be placed on evidence-based policy in

fields like drug policy and criminal justice, and this is partly because drug policy is

believed to be particularly susceptible to misinformation and to emotional responses.

For example, the UK Drug Policy Commission’s A Fresh Approach to Drugs

observes that ‘the debate about how we address the challenges of mind-altering

drugs is polarised and with an added emotional and moral aspect that is not seen in

most other policy areas’ (UKDPC, 2012b, p. 8). This is compounded by the

stigmatisation of individuals, families and communities affected by drug problems,

which is fed by commonly held but often false or exaggerated beliefs. As the UK

Drug Policy Commission report How to make drug policy better observes this is also

a consideration in the design of consultation processes as ‘people with drug

problems are a highly stigmatised and marginalised group and they may be excluded

or “drowned out”’ (UKDPC 2012a p. 39).

Second, different forms of evidence will be relevant to different kinds and stages of

drug policy development and implementation, and these involve different forms of

competency and expertise. For example, evidence from analyical toxology or

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neuropsychopharmacology is different in kind to economic analysis of the cost-

benefit ratio of a policy initiative or to a qualitative analysis of its impact within a local

community. There is a particularly fraught question about how research evidence

derived (for example) from clinical trials and research studies is balanced with

‘narrative evidence’ from service users. This is particularly pertinent given the

importance of narrative in service-user led recovery movements in mental health and

substance misuse that have challenged dominant treatment models even where

these are believed to be well-supported by medical and clinical evidence-bases. Nick

Tilley highlights the potential for ‘the discourse of user empowerment’ to collide ‘with

the other key driver of contemporary health and social policy – evidence-based

policy’ (Tilley N, cited in Cook 2002, pp. 526-7). In a similar vein, Mark Monaghan

writes that ‘devolving … decision(s) to experts … could be seen as an abrogation of

the principles of democracy and a step along the way to technocratic decision-

making’, with the risk – citing Weingert – that politics is ‘replaced by scientifically

rationalised administration’ (Monaghan M 2012, p. 54).

Third, one of the least likely things you’ll hear from a specialist researcher is that the

evidence for something is complete, unambiguous and points to a single policy

conclusion. In other words, the call for evidence-based policy is at least as often a

plea to be mindful of what we don’t know as to build on what we do. A related issue

is the need to reconcile the interest in evidence-based approaches to drug policy

issues with calls for innovation (particularly in drug treatment provision). A particular

issue for analysis of the likely impact of policy is the problem of unanticipated and

unintended consequences, which the philosopher Karl Popper (1902-1994)

described as ‘the characteristic problem of the social sciences’. Put crudely, one

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thing we know about policy is that it will tend to produce consequences that were not

predicted by evidence available at the point of implementation.

The role and limits of evidence

There are issues in drug policy that are (in a more or less broad sense) ‘scientific’ or

‘technocratic’ and ought therefore to be entrusted to the relevant expert

communities. These include the chemical compositions of psycho-active substances;

their physiological and psychological effects, including potential risks; the

relationship between clinical interventions (such as needle exchange, substitute

prescribing or psycho-social interventions) and treatment outcomes (such as

retention in services, transmission of blood borne viruses like HIV and hepatitis or

levels of offending); and analysis of the cost-benefit of policy approaches (for

example, in the UK it has been calculated that every £1 invested in drug treatment

saves £2.50 in subsequent costs arising from a failure to intervene).

While these kinds of evidence can frame and inform policy development, they will

rarely be decisive; policy conclusions can seldom (if ever) be rationally derived from

an uncontested evidence-base.

For a start, and as highlighted above, there is rarely consensus in research and

specialist communities. For example, the relationship between drug dependence and

crime – critical for cost-benefit calculations - is an area of controversy amongst social

scientists. Mark Monaghan writes that ‘one of the true stumbling blocks to the

realisation of evidence-based policy is that the “evidence” is rarely definitive. Indeed,

one of the paradoxes of research in any given area is that the more heavily

something is researched, the less there is convergence on points of agreement’

(Monaghan M 2012, p. 53). Evidence about the composition, effects and risks of

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particular drugs may appear less susceptible to controversy, but often the evidence

here is provisional and contestable about causal relationships and longer-term

effects (for example, on cannabis and mental health), and increasingly policy is

addressing an explosion in new psychoactive substances about which there is little

or no scientific evidence. Policy makers are having to address issues about risk in

(and, indeed, because of) the absence of reliable evidence.

There is an historical case to be made that a particular emphasis on ‘evidence based

policy’ emerged in the 1990s in the UK partly as a reaction by what might loosely be

described as the progressive left to a political environment that was inhospitable to

its values. On this view, the political ideology could be stripped out of policy making

and replaced with ‘objective scientific evidence’ demonstating ‘what actually works’

and persuading any rational person to accept the preferred policy solution, and

which it was believed would fortuitously support progressive policy on issues like

crime and punishment and drug policy. There is much to commend this approach: in

the UK it is widely accepted that it drove and legitimised an unprecedented

expansion in the availability of drug treatment provision. But, in reality, it is

impossible to cleanse policy debates of values, even where these can be concealed

more or less successfully for a while. The repressed has a habit of returning.

In the UK, for example, a group of scientists led by Professor David Nutt (currently

Edmond J Safra chair in neuropsychopharmacology at Imperial College London)

published an influential article in The Lancet called ‘Drug harms in the UK: a multi-

criterion decision analysis’, which ranked alcohol as the most harmful drug, followed

by heroin, and with ecstasy and LSD among the least harmful (Nutt D et al 2010).

This research was widely heralded for taking a scientific approach to the emotive

issue of drug harm, and so it did to a significant extent; however, it was also heavily

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reliant on subjective evaluations. In addition, it considered 16 forms of harm,

including drug-related mortality, drug dependence, crime and social cohesion. There

is no scientific way of weighing these various harms using a single objective

standard of commensuration, as its authors acknowledged.

The same sort of issue arises with the campaign currently being led by the pro-

reform group Transform in the UK for the development of ‘an objective mechanism

for assessing the relative merits of different policy approaches, by developing a

genuinely evidence-based Impact Assessment of Drug Policy that compares the

impact of alternative policies on human development, human security and human

rights’ (Transform website, 10 October 2013). There will be an extraordinarily wide

range of harms and benefits that will need to be balanced against each other. Nor

will harms or benefits be distributed equally between individuals or communities,

requiring a balancing of different and potentially competing interests. It’s also very

complicated. The Beckley Foundation report A regulated cannabis market in England

and Wales – Towards a cost-benefit analysis [emphasis added] looked at ‘seventeen

distinct sources of social cost or benefit’, concluding that ‘at present there is so much

uncertainty about some of the important issues involved in the introduction of a

licensed and regulated cannabis market that a clear conclusion is not possible’

(Bryan M, Del Bono E and Pudney S 2013, p. iv). This study considered a single

drug in a single jurisdiction, these uncertainties would be considerably magnified for

any attempt at a global impact assessment.

To take another example, New Zealand’s Psychoactive Substances Act 2013 has

been heralded as ‘a pragmatic and evidence-based approach to recreational drug

use’ (Wood J and McCullough C, 2013). This law regulates the production and sale

of new psychoactive substances by placing the onus of proof on manufacturers to

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demonstrate that they are ‘low risk’ before they can be legally sold, with each

product required to go through a clinical testing process. But what is ‘low risk’ (and,

incidentally, how will this process identify longer term risks)? As Mike Power has

observed ‘all drugs, it could be argued, have a toxic effect: that’s the point. This is a

key issue for the NZ legislation: set the harm threshold too low, and it’s prohibition

redux. Too high and dangerous substances can be sold legally’ (Powers M, 2013).

Setting a benchmark for the ‘low risk’ threshold is critical for the implementation of

this ‘evidence-based approach’. This is not a scientific issue but a normative - and

properly political - issue.

In conclusion, drug policy issues share many of the characteristics of so-called

‘wicked problems’. Kane and Bishop note that these issues are ‘frieghted with

diverse and sometimes incompatible opinions and interests’, such that ‘consensus

among them may in the end prove impossible’ (Kane J and Bishop P 2002, p. 89).

Mark Monaghan observes that ‘wicked problems’ arise in ‘areas of policy that defy

neat solutions as there is little agreement on the nature of the problem in the first

instance’ (Monaghan M 2012 p. 50). Consider, for example, two recent discussions

of the role of Opiate Substitution Treatment (OST) in the UK. A study commissioned

by the Department of Health concluded that among the benefts of OST are that it

‘prevents people dropping out of treatment’ (National Treatment Agency 2012, p.

24); by contrast a report by the Conservative supporting thinktank the Centre for

Social Justice decries ‘a fatalistic drug treatment system which [has] trapped many

thousands of addicts in state-sponsored dependency’ (Centre for Social Justice

2013, p. 5). These are very different assessments in terms of their tone and

conclusions, but how far is this a disagreement about objective evidence and how

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much does it reflect a lack of ‘agreement on the nature of the problem in the first

instance’?

Evidence, engagement and participation

As Dee Cook observes, ‘consultation, participation and empowerment are

processes which are problematic and challenging for researchers, practitioners and

policy makers alike … developing appropriate tools and recognising that consultation

is a process not an event are essential starting points’ (Cook D 2002, p. 530). Such

engagement processes can occur at a number of stages in a policy process

including initial scoping of options, policy design, implementation and evaluation.

They may serve a range of purposes including gathering evidence, listening to

community concerns, reconciling interest groups, involving service users, evaluating

policy options and assessing the impact of policy implementation. They may include

a range of engagement processes including formal written consultation exercises,

face-to-face meetings between lobby groups and decision-makers, consultative

events with stakeholders, advisory groups, commissioned research and relatively

new and innovative approaches such as deliberative polls and citizens juries. These

can all involve a range of interlocuters including think tanks, representative and

campaigning bodies, researchers and statisticians, service commissioners, service

providers, service users, families, community groups, residents affected by a

particular issue or policy and the public as a whole.

Different approaches to consultation will be appropriate to different issues and at

different stages. An engagement process to consider options for drug law reform will

require a different approach to clinical assessment of a medical intervention or

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consultation on configuration and delivery of a local drug treatment system. Different

kinds of competence, knowledge and experience will be relevant to different kinds

and stages of consultation. For example, only those with certain kinds of expertise

are qualified to contribute meaningfully to a cost-benefit assessment or a clinical

assessment. In this sense, a ‘principle of inclusiveness’ is not necessarily in conflict

with a ‘principle of competence’. Fairness may require that everyone affected by a

policy is included in the scope of engagement processes, but because this is about

engaging each on the basis of their particular expertise or experience there is no

necessary tension with competence. It is not necessary or desirable for every stage

or aspect of a consultation process to be inclusive. For example, an expert on

toxicology or pharmacology should not expect to be consulted on community impact

of a drug service nor a community leader on the pharmacological properties of a

certain drug.

Considering drug policy as a whole, competency should not be conceived in binary

terms but in terms of the particular competencies that different contributors bring to

different stages and aspects of the process in virtue of their knowledge and

experience. The professor or politician will defer to the drug worker or service user

where their views and experiences are most pertinent, and vice versa – everyone is

committed to listening as well as talking. Thus Nick Tilley observes that evidence in

the narrow sense is critical to inform policy formation and implementation, but that an

'evidence-led agenda' promises 'too strong a role for evidence' (cited in Cook D 2002

pp. 526-7). As a corrective to an overly technocratic approach, he emphasises the

importance of theorising based on experience of contexts, mechanisms and

outcomes, as distinguished from generalisable evidence from Randomised

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Controlled Trials. The focus should be on achieving 'an improved grasp on what

worked, how and with whom within the process' (ibid).

As previously noted there is a particular issue about the balance between research

evidence and the narrative testimony of service users and others directly affected by

drug policies. It may be useful to distinguish between, on the one hand, anecdotal

evidence in which – for example - a research conclusion is dismissed or rejected on

the basis of a single counter-example from personal experience (the Uncle who

smoked 60 a day and lived to be 100) and, on the other hand, narrative evidence

where experience is described on a person’s own terms to provide a finely textured

and personally and emotionally engaged account of their experience.

Research is selective in its scope and relevant experience will escape the

searchlight it throws on an issue at a particular time and driven by a particular

agenda. For example, research on a treatment intervention will screen out a lot of

other things that are going on in a person’s life which may be critical for them (for

example, the impact of a positive relationship, an activity or loss of work or housing).

Consider, at extreme ends of a continuum, the contrast between a first person

narrative and the bare statistical datum that X has been ‘retained in treatment’ for six

months. Research will operate at various points across this spectrum, and

sophisicated research will account for a wide range of factors like relationships and

employment, but it will not (and is not intended to) extend to the totality of an

individual’s experience and its particular meaning and significance for that person

(unless perhaps in the form of narrative testimony within a qualitative process).

Narrative evidence can push research and policy outside of its current frameworks

and ‘comfort zones’ and provides a catalyst for fresh thinking. The issues about

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balancing research evidence with first person testimonies are not straightforward.

There are challenges in designing engagement processes that enable service users

to contribute on their own terms, while giving due weight to other evidence. Dee

Cook observes 'that while government does indeed "talk the talk" on consultation, it

has yet to persuade many that it will "walk the walk". If the objects of social policy -

service users, the poor, powerless and disaffected - were to find their voice, the talk

itself may become unpalatable’ (Cook D 2002, p. 529).

A further issue is what might be described as ‘competency drift’. There has been a

tendency for drug policy experts to presume special competency (often implicitly)

with respect to matters that are normative or political issues. These are not issues in

drug policy, but they are critical for drug policy. Drug policy specialists as such have

no unique competence to pronounce on the value that should be accorded to

different kinds of harms and benefits in assessing policy options; the allocation of

scarce resources between priorities (for example, drug treatment and social care); or

the levels of risk to which governments expose citizens or markets pass to

consumers. It is with respect to such questions that there is potential to develop

mechanisms for informed public and community debate such as deliberative polling

and citizens juries. Participants are not policy specialists: their role is not to provide

evidence or expertise to inform decision-makers, but to engage in deliberative

processes where they reflect on evidence and make policy or practice

recommendations.

There are wider issues about the relationship between stakeholder consultation and

policy and political processes, particularly in democratic systems, which go back to

Monaghan’s point about the risks of ‘technocratic decision-making’. In ‘Consultation

and Contest’, John Kane and Patrick Bishop highlight the dangers of ‘talk[ing] up

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consultation as a democratic device’, which they argue is inconsistent with the

principles of representative democracy for which ‘a policy is legitimate if it has been

made by the appropriate authority after due consideration of the various interests

and opinions that exist amongst the public’ (Kane J and Bishop P 2002, p. 89). They

conclude that ‘a representative government should never (save in a referenda) allow

citizens to believe that their input in policy questions will be determinant of final

decisions’ (ibid). Helena Catt and Michael Murphy note that ‘consultation, by

definition, is not decision-making’, but a process that can inform it; it is therefore

important to distinguish between ‘the range of situations where the government gives

a voice in making decisions while on the other side are all the instances where the

group is involved in advising or providing information for the decision makers’ (Catt H

and Murphy M 2003, p. 415).

Conclusion

The purpose of this commentary has been to highlight the complex relationships

between evidence, engagement and participation and the 'wicked' nature of drug

policy issues. It has moved freely between different levels and kinds of policy

development, from drug law reform to service development at local level, further

complicating the picture. It is beyond its scope to propose solutions in terms of

specific mechanisms for drug policy governance, but I hope it has helped to raise

some relevant questions and considerations.

Firstly, there is the question of how to balance issues of competence with principles

of inclusivity in drug policy development. Everyone must have some form of

'competency' in order to have a legitimate claim to inclusion in consultations, but the

basis and nature of those competences will be varied. This is an important

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consideration in the design of participatory mechanisms. It also helps to address

concerns about 'technocratic decision making', because it means that even if

governance and participatory processes were designed with a focus on 'expertise'

they should tend to inclusivity if they have worked with an appropriately broad

understanding of relevant forms of expertise (for example, drug service users as

'experts by experience'). In addition, pluralistic and inclusive approaches will tend to

produce more robust forums for the interrogation of research claims and policy

proposals, so long as these forums are framed by principles of reciprocity and

respect for the diverse competences and points of view of different interlocutors.

Second, there is a related issue about the role of specialist competences (including

scientific expertise) in democratic processes, which is not specific to drug policy, but

applies across the policy spectrum. It has been suggested that meaningful and

empowering democratic decision-making requires that all participants are equipped

with the tools to make informed choices about key policy issues, including to predict

as far as possible the probable consequences and impact of different decisions that

they could make (as well as understanding the risks and uncertainties). Without this

political choice is meaningless. It follows that genuinely inclusive and participatory

drug policy processes will not be meaningful without adequate investment in

research, in information and education, and in the effective dissemination of

knowledge. This raises issues about the responsibilities of public figures and the

media to ensure they are not legitimising false or misleading perceptions and

information. Again, the general principles of inclusiveness/democracy and

competence/expertise are not in conflict on inspection but, on the contrary, are

interdependent. In practical terms, consultative mechanisms such as citizens juries

could provide an effective model for this kind of political decision-making.

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Third, it has been suggested that a threat to effective pluralistic approaches to drug

policy development - and the cultures and relationships that sustain them - is

'competency drift'. On the one hand, this occurs when political exigencies influence

the interpretation or presentation of evidence, which may not be conscious or

deliberate. On the other hand, it occurs when drug policy expertise is regarded as

providing a privileged basis for pronouncing on issues to which it may not be directly

relevant, including aspects of some of the most critical and contested issues within

drug policy - for example, pertaining to law reform and investment in drug services

given competing priorities. Once again, this suggests that there is no inherent conflict

between a commitment to evidence based policy and respect for the role of

representative government in making ultimate decisions about policy issues, so long

as issues of respective competencies are respected, negotiated and managed.

Finally, the scope of evidence to determine policy and it's implementation is critical

but also limited. This is not only because evidence is incomplete and often

contested by the relevant expert and professional communities, but also because

drug policy inevitably involves normative considerations that are not resolvable by

'evidence'. We should therefore reject models of evidence informed policy

development which assume that the gradual accumulation of more evidence will

necessarily provide a fully rational basis for resolving policy disagreements or point

us unambiguously to a particular policy solution. It would be a useful project to make

explicit the values implicit in drug policy positions and their relationship to matters of

evidence and to consider how we would create space for rational debate of these

underlying ideas, drawing on disciplines like moral philosophy and political

psychology. It is likely, however, that many of these issues would turn out to be

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general moral and political questions and not drug policy specific - for example,

about individual liberty or the role of markets or the responsibility to reduce harms.

Evidence, then, should be at the core of drug policy development and governance,

and is indispensible for meaningful participatory and democratic processes, but it will

also tend to be partial, provisional, contested, incomplete and open to revision – and

many of the key issues for drug policy are not in principle amenable to purely

evidential solutions because they have a normative aspect. There is often an implicit

assumption that rational governance processes should produce a reasoned

consensus on a policy solution (and residual opposition will reflect lack of

acquaintance with evidence or a failure of rationality). But many of the key issues in

drug policy are inherently contestable. While evidence will rule out a range of options

and shape many others it will rarely point unambiguously to one solution or approach

– there is much that is provisional and contestable. This is something we might

perhaps learn to embrace. John Stuart Mill (1806-73) observes that where an

opinion ‘is not fully, frequently and fearlessly discussed, it will be held as a dead

dogma, not a living truth’ (J S Mill, On Liberty). Policy consensus can be followed by

ossification, as an idea loses its vitality and radical force and is reduced to jargonese

and subject to formulaic or bureaucratised forms of implementation.

More prosaically, engagment and consultation processes need to be on-going and

open-ended because the evidence-base changes and develops as new research

becomes available, old evidence is reviewed and reinterpreted, and different stages

are reached in policy design, development, implementation and review – the wider

environment in which policy is developed and implemented changes too of course

(for example, the financial context, political climate or policy in closely related areas

like welfare or housing).

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One final point, effective stakeholder engagement and the development of

participatory processes is likely to be a resource-intensive business for both

consultors and consultees – there are significant opportunity costs in diverting

resources away from other activities, including providing services or developing

research projects. What is the cost-benefit of good governance – and is it worth the

candle at a time when resources are being squeezed in many jurisdictions? Part of

the answer is that unless sufficient investment of time and resource is made to

ensure consultation and participatory processes are genuinely meaningful with

demonstrable impact on decision making there will be a tendency for key voices and

constituencies to disengage from these processes, undermining the pluralism upon

which the sort of approach that has been outlined here depends.

References

Bryan M, Del Bono E and Pudney S (2013), A regulated cannabis market in England and Wales –

Towards a cost-benefit analysis, Essex: Institute for Social and Economic Research and Oxford:

Beckley Foundation.

Catt H & Murphy M (2003), ‘What voice for the people? Categorising methods of public consultation’,

Australian Journal of Political Science 38:3

Centre for Social Justice (2013), No quick fix- Exposing the depth of Britain’s drug and alcohol

problem, London: CSJ.

Cook D (2002), ‘Consultation, for a Change? Engaging Users and Communities in the Policy

Process’, Social Policy and Administration 36:5

Kane J & Bishop P (2002), ‘Consultation and Contest: The Danger of Mixing Modes’, Australian

Journal of Public Administration 61:1

Monaghan M (2012), ‘Cannabis classification and drug policy governance’, in UK Drug Policy

Commission (2012), Essays on the governance of drug policy, London: UKDPC.

Mill J S (1859), On Liberty, Cosimo: New York

National Treatment Agency (2012), Medications in recovery – Re-orientating drug dependence

treatment (The Strang Report), London: NTA.

of 19

Accep

ted

Man

uscr

ipt

19

Nutt D et al (2010), ‘Drug harms in the UK: a multi-criterion decision analysis’, The Lancet, 376, 6

November 2010.

Popper K (1957), The poverty of historicism, London: Routledge).

Powers, M (2013), ‘Artificial paradise?’, DrugLink, Vol 28, Issue 5, September/October 2013.

Roberts, M (2012), ‘Consultation processes and good goverance: from “unproductive process” to “real

engagement” in UK Drug Policy Commission (2012), Essays on the governance of drug policy.

Shepherd G, Boardman J and Slade M (2008), Making Recovery a Reality, Sainsbury Centre for

Mental Health.

Tilley, N. (2001) ‘Evaluation and evidence-led crime reduction policy’. In R. Matthews and J. Pitts

(eds), Crime, Disorder and Community Safety, London: Routledge.

Transform Website ‘Time for an Impact Assessment of Drug Policy’ on 10 October 2013 at

www.tdpf.org.uk/Impactassessmentlead.htm

UK Drug Policy Commission (2012a), How to make drug policy better: key findings from UKDPC

reseach into drug policy governance, UKDPC: London.

UK Drug Policy Commission (2012b), A fresh approach to drugs, UKDPC: London.

Weingart, P. (1999) 'Scientific expertise and political accountability: paradoxes of science in politics',

Science and Public Policy, 26 (3) 151-61.

Wood J and McCullough C (2013), ‘Psychoactive Substances Act’, Matters of Substance, August

2013.

making drug policy together: reflections on evidence, engagement and participation

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