Statement on Changes to Ontario’s Policy on Substance Use

On August 20, 2024, Ontario’s Minister of Health, Hon. Sylvia Jones, announced new investments in services along the substance use health continuum. This announcement also introduced new requirements regarding the location of existing Consumption Treatment Services (CTS) and their proximity to schools and daycares, which resulted in the scheduled closure of Path525, the only supervised consumption site in Thunder Bay. Path525 has been a crucial resource, offering harm reduction services for those seeking supervised consumption, as well as access to health and social care.

Noojmawing Sookatagaing Ontario Health Team (OHT), which serves the District and City of Thunder Bay, welcomes the government’s commitment to expanding treatment and recovery services. Thunder Bay has one of the highest opioid-related death rates in the province at a rate of 59.6 per 100,000 people in the first half of 2024 (ODPRN, 2024). With a rate of ~88 opioid toxicities per 100,000 people treated by the Northwest Region EMS in Northwestern Ontario as a whole (ODPRN, 2024), and ~70 opioid related deaths per year since 2018 (Office of the Chief Coroner, 2024), an ongoing commitment to treatment and recovery services is much needed to address the disproportionate impact that drug supply and overdose crisis has in our area. However, we are concerned about the potential impacts of Path525’s closure, which leaves a significant gap in harm reduction services and access to health and social care for community members who rely on these essential supports, and who will not access recovery and treatment.

From May 2019 to October 2024, Path525 offered over 12,000 instances of unique and irreplaceable care to individuals at the site, all while having zero on-site deaths. During that period, Path525 staff were able to treat or reverse 410 overdoses on site without involving EMS and Superior North EMS recorded 3,522 calls relating to opioid overdoses within the city of Thunder Bay alone (Superior North EMS, 2025). Superior North EMS recorded only 66 opioid-related calls to NorWest CHC during this period (Superior North EMS, 2025). From 2022 to 2024 only three overdose cases required transport by EMS to the emergency department. Path525 has also connected 1,892 individuals to primary care after receiving services at the CTS site during the 2022-24 period.

Noojmawing Sookatagaing OHT recognizes that harm reduction is a key component of the essential services that must exist along the substance use health continuum to prevent further harm to our communities. We acknowledge the need to adopt evidence-based and proven interventions, and recognize opioid agonist therapy (Yakovenko et al., 2024; Santo Jr et al., 2021; Larochelle et al., 2018; Pearce et al., 2020), naloxone (Clark et al., 2014; Katzman et al., 2020), supervised consumption sites (Potier et al., 2014; Kennedy et al., 2019; Tsang et al., 2021; Matskiv et al., 2022), and the provision of sterile inhalation and injection supplies as essential services (Platt et al., 2018; Degenhardt et al., 2019).

The Ontario government cites the “safety of children and communities” as a reason for closing any supervised consumption sites within 200m of schools or child-care centres, however, there is no data to support the claim that the proximity of Path525’s regulated programs to Ogden Public School has been a cause for concern in our community. In fact, the data found in the Thunder Bay Police Service’s crime map fails to support the province’s claim that “crime in the vicinity of these sites is significantly higher compared to surrounding neighbourhoods”. Incidents were reported with similar frequency across the city. Furthermore, Odgen Public School supports CTS operations at NorWest Community Health Centres.

Additionally, the Ontario government vows that “if passed, the legislation will also prohibit municipalities from requesting the decriminalization of illegal drugs from the federal government”. Intensifying the criminalization of substances does not deter people from using substances; rather, it reinforces structural inequities and systemic oppression (Scher et al., 2023; Verani & Haines-Saah, 2020).

Improving access to equitable care, promoting care that is centered around and accountable to communities, and advancing Truth and Reconciliation are priorities for the Noojmawing Sookatagaing OHT. To do so, we must actively work to deconstruct systemic oppression. Systemic oppression is embedded in legislation and exists in harmful policies and practices across structures including government and health (Bravement et al., 2022; Canadian Human Rights Commission, 2025).

Oppression also extends beyond systems into institutions and providers on the frontlines. It can manifest consciously or unconsciously, and can lead to hostility, intolerance, poor communication, and indifference (Ramsoondar, Anawati & Cameron, 2023). Such harms, as well as those related to issues across the substance use health continuum – including justice involvement, morbidity, and mortality – disproportionately impact Indigenous, Black, and other visibly racialized communities (Farahmand, Arshed & Bradley, 2020; Public Health Ontario, 2022). When these harms are compounded, individuals are less likely to seek support for substance use and there is a reduction in treatment retention (Hassen et al., 2021).

We are also deeply concerned by the underlying messaging from the province. First, by emphasizing “protection”, the Ontario government is perpetuating the overused trope that people who use substances are dangerous and criminal, rather than people who deserve equitable and accessible care and empathy. Further, by using inflammatory language such as “so-called ‘safer’ supply”, the province is sending a clear message that qualifies substances and the people that use them as ‘bad’. This directly conflicts

with the simultaneous expansion of alcohol sales to corner stores and messages that alcohol use is accepted. In doing so, the province is undermining any commitment to treating all constituents with dignity and respect and breaks its promise to pursue health for all.

As an OHT, we are committed to improving access to care. We will work with local partners to explore alternative solutions that maintain access to harm reduction, treatment, and support services across the district. We are dedicated to advocating for policies that balance public safety with the need for comprehensive healthcare services in Thunder Bay and surrounding areas.

Jennifer Lawrance

Implementation Lead

Noojmawing Sookatagaing Ontario Health Team

Email: JLawrance@nsnorthoht.ca

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