HomeMy WebLinkAbout2023-08-17; Comment Letter to California Department of Public Health regarding Vista Community Clinic's Application for Authorization of a Syringe Services Program (Districts - All); Barberio, GaryTo the members of the:
CITY COUNCIL
Date~l1\'l3CA V CC /
CM _ ACM v'DCM (3 ) V
August 17, 2023
Co un cil Me morandum
{cityof
.Carlsbad
Memo ID# 2023089
To: Honorable Mayor Blackburn and Members of the City Council
From: Gary Barberio, Deputy City Manager, Community Services
Mandy Mills, Housing & Homeless S~s Director
Via: Geoff Patnoe, Acting City Manager~
Re: Comment Letter to the Ca lifornia Department of Public Hea lth Regarding Vista
Community Clinic's Application for Authorization of a Syringe Services Program
(Districts -All)
This memorandum provides the City Council with additional information related to a proposed
syringe services program within the City of Vista.
On August 15, 2023, t he City Manager provided a comment letter to the CA Department of
Public Health (CDPH), provided as Attachment A.
Attachment: A. Comment letter to the CDPH, dated August 14, 2023
B. Council Memorandum, dated July 20, 2023
cc: Scott Chadwick, City Manager
Cindie McMahon, City Attorney
Community Services Branch
Housing & Homeless Services Department
1200 Carlsbad Village Drive I Carlsbad, CA 92008 I 442-339-2810 t
August 14, 2023
Marjorie l<atz
CA Department of Public Health
Office of AIDS -Harm Reduction Unit
PO Box 997377
MS 0500 -
Sacramento, CA 95899-7377
Dear Ms. Katz,
Attachment A
(_ City of
Carlsbad
Thank you for the opportunity to provide feedback regarding Vista Community Clinic's (VCC)
application for authorization of a syringe services program (SSP}. We understand from a public
health perspective that these types of programs aim to prevent infectious disease outbreaks,
increase entrance into drug treatment programs and facilitate safe disposal of used syringes. Our
Chief of Police previously responded with comments in accordance with Health and Safety Code
Section 121349. This separate response was prepared to provide constructive input from the City
of Carlsbad regarding potential community impacts and concerns should VCC be authorized to
implement a SSP in our city. It includes additional feedback from law enforcement, first
responders, parks and recreation, homeless services,. and environmental sustainability. If a
program like this is enacted, we request the following features to help mitigate t he negative
consequences to our community.
Foster Relationships with a Variety of Stakeholders
While we appreciate the comprehensive, community-engaged health and wellness services VCC
provides, VCC has not reached out to the City of Carlsbad staff to work together despite
proposing to provide mobile SSP services in our city. To establish positive relationships with
.;:ommunity partners and other stakeholders, VCC should:
• Open lines of communication with the communities in which they desire to operate, and
work to incorporate constructive feedback into programmatic activities.
9 Proactively seek routine feedback to determine any negative community impacts that
need mitigating. This can help improve community relations, stakeholder support, and
overall community health. The application only calls for passive feedback via a response
option on their website.
o Include clean up after mobile events as a core component of the program. This was not
mentioned in the application.
o Work collaboratively, not independently. The success of any program could benefit from
leveraging services provided by other community partners.
City Manager's Office
1200 Carlsbad Village Drive I Carlsbad, CA 92008 I 442-339-2820 t
Marjorie Katz
August 14, 2023
Page 2
• Coordinate with the city and community service providers to provide a pathway to ensure
that SSP clients are connected to housing and treatment options.
• Participate in city-facilitated case conferencing meetings with community partners
addressing homelessness within the city. These meetings provide an opportunity for care
coordination of mutual clients as well as opportunities for service referrals.
• Create a Good Neighbor agreement to allow for the concerns of community partners and
other stakeholders to be incorporated into a plan wit h ongoing feedback and
cooperation.
Consult on Locations
VCC's application states mobile services will be provided in four cities in north San Diego County
in various locations three days per week. Their application states t hat VCC staff will identify
appropriate times and locations of services, including homeless encampments, parks, and social
service locations to garner the greatest need for these services. Unfortunately, this approach
only takes into consideration the best outreach to attract people who use drugs and does not
take into consideration the safet y of the general public in those spaces or surrounding uses.
The city has taken great measures to ensure the safety of all community members and will not
put that in jeopardy. A mobile exchange program in city parks and other public spaces is
unacceptable for the safety of the general public. Carlsbad's Homeless Outreach Team, Fire
Department, Homeless Services staff and contracted social workers have the ·necessary
awareness of who would benefit from VCC's mobile service and could work toward identifying a
suitable accessible location for the service and provide referrals as appropriate.
Provide Necessary Hea lth Services
VCC proposes to provide harm reduction services, including distribution of safer injection kits
and disposal, fentanyl education and test strip distribution, naloxone education and
distribut ion, safer sex supplies, hygiene kits, and wound care supplies. The application is
unclear about what health services will be directly provided or available through linkage and
referral because the checklist and narrative contain conflicting statement s. There is evidence
that people who inject drugs who work with a nurse at an SSP are more likely to access primary
care, which increases access to medication-assisted treatment {MAT). To most effectively
address public health needs, health services should be directly provided rather than available
through referral.
• The provision of HIV and hepatitis screening, Hepatitis A and B vaccinations, sexually
transmitted infection screening and substance use t reatment should all be provided
directly to address health concerns oft he participants and others.
G We understand participants can receive referrals to case management and support
services; mental health and behavioral treatment; housing services; low threshold
medication-assist ed treatment (MAT), and recovery support services; and other social
Marjorie Katz
AugL,Jst 14, 2023
Page 3
support services. While beneficial, leveraging with existing services in the community
could more comprehensively meet public health needs.
Compromise Needle Program Design
If a program is approved to operate in our city without our assent, we recommend
modifications regarding the distribution of needles. While we understand public health
practitioners recommend elements of program design to best reach people who use drugs, any
program must be balanced with the safety of the general public.
• The application proposes a needs-based distribution model. Although sharps disposal
kits are provided, we have concerns with proper disposal using t his model and instead
request an exchange program. The program design does not have to cap availability, but
must ensure proper disposal of all needles.
• We are a beach community with a number of canyons and trails bordered by sensitive
wetlands and other habitat. We have serious concerns about what ends up in our
environment. VCC could offer to accompany the city on encampment clean ups to
provide proper sharps disposal.
G The application does not identify the type of syringe to be distributed, but we anticipate
they are high quality, non retractable syringes to encourage those who use injectable
drugs to utilize the service. However, this type of syringe is more dangerous when
disposed of improperly. Distributing single use, retractable syringes may reduce the
chance of accidental needlesticks for the general public, litter abatement crews and first
responders.
We understand there are competing factors in this complex issue and appreciate the
opportunity to share the City of Carlsbad's comments related to this proposed program. While
we val t he critical services provided by VCC, we request that any services provided in our city
be re o sive and complimentary to our existing approaches.
City Manager
cc: Michelle Sevilla, Vista Community Clinic
Cindie McMahon, City Attorney
Mickey Williams, Chief of Police
Michael Calderwood, Fire Chief
Kyle Lancaster, Director of Parks & Recreation
Mandy Mills, Director of Housing & Homeless Services
James Wood, Environmental Sustainability Director
To the members ofthe:
CITY COUNCl'7,
Date\12~123 cAX cc. { /
CM~ V DCM(3)~ --
July 20, 2023
Council Memorandum
To:
From:
Honorable Mayor t cl b rn and Members of the City Council
Mickey Williams, qh~~ t li~e
Scott Chadwick, C~g~ Via:
Attachment B
{city of
Carlsbad
Memo ID# 2023075
Re: Vista Community Clinic Application for Syringe Services Program (Districts -All)
This memorandum provides City Council with information related to a proposed syringe
services program within the City of Vista and the Police Chief's response to a request for input.
Background
On July 19, 2023, Chief Williams was advised that the Vista Community Clinic (VCC) has applied
to the California Department of Public Health, Office of AIDS (CDPH/OA) for authorization of a
syringe services program.
Discussion
In accordance with requirements in Health and Safety Code section 121349, CDPH sent an email
seeking consultation with the local health officer of San Diego and law enforcement officials in
the proposed service areas, including Carlsbad. CDPH requested input from Chief Williams
pertaining to the authorization application.
Under the proposed syringe services program, VCC will provide harm reduction services to the
underserved areas of the north regions of San Diego County. These services will include
distribution of safer injection kits and disposal, fentanyl education and test strip distribution,
naloxone education and distribution, safer sex supplies, hygiene kits, and wound care supplies.
Mobile services will be provided in north San Diego County in various locations in the cities of
Carlsbad, Oceanside, Vista, and San Marcos, Monday from 9 a.m. to 3 p.m., Wednesday from
7 to 9 a.m. and from 1 to 5 p.m., and Friday from 1 to 6 p.m.
The application is attached for your review. The OA has initiated a 45-day public comment
period through a posting on the CDPH/OA website. Public comment closes on
September 1, 2023.
Fiscal Impact
There is no anticipated direct fiscal impact to the City of Carlsbad.
Relevant Legislative Platform Position Statements
The following position statements are found in the city's legislative platform, and help inform
the comments provided by Police Chief Williams, below:
Police Department
2560 Orion Way I Carlsbad, CA 92010 I 442-339-2100 t
Council Memo -Vista Community Clinic Application for Syringe Services Program (Districts -All)
July 20, 2023
Page 2
Guiding Principles
Ill. Protect Quality of Life -The city supports state legislation and funding that preserve the
safety, security, cultural resources and well-being of our residents, workers, businesses and
visitors. The city opposes efforts that would negatively impact the infrastructure, public health
and safety, community development, equitable community services, cultural integrity and
environmental programs and other city efforts to maintain and enhance the quality of life in
Carlsbad.
Healthy Cities
(a) Support legislation that recognizes and prevents adverse impacts affecting public health and
the welfare of all residents, visitors and workers, and especially the young.
Police Chief Williams' Response
On July 19, 2023, Police Chief Williams provided the following response to Marjorie Katz from
t he CDPH/OA, Harm Reduction Unit.
Hello Marjorie,
Thank you for the email and opportunity to respond with a comment.
I would like it noted that I have substantial concerns with the provision of safer injection kits
within North County and specifically within the City of Carlsbad. I firmly believe that assisting in
the administration and ingestion of highly addictive and harmful substances is
counterproductive to the health, safety, and we/I-being of our community.
I also have concerns regarding the distribution of fentanyl test strips. The handling, testing and
ingestion of illegal narcotics to include fentanyl or suspected fentanyl is exceptionally dangerous
and in my opinion is harmful to the health, safety, and well-being of our community.
With respect to the disposal of safer injection kits, or the provision of fentanyl education,
naloxone education and distribution, safer sex supplies (provided only to adults, 18 years of age
or older), hygiene kits, and wound care supplies, I have no objection.
If you would like any additional information, please let me know.
Respectfully,
Mickey Williams
Police Chief
Carlsbad Police Department
2560 Orion Way
Carlsbad, CA 92010
0 : 442.339.2130
www.carlsbadca.gov/police
cc: Geoff Pat noe, Assistant City Manager
Cindie McMahon, City Attorney