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Greater Harlem Coalition Logo

October 18, 2023

STRIVING FOR A HARLEM WHERE ALL PEOPLE CAN THRIVE

POST FACTO GUIDELINES ISSUED

Overdose Prevention Centers Now Have Operational Guidance From The Department of Health

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In 2021 New York City opened the nation's first two Overdose Prevention Centers (OPC) - sites where addicts can safely consume their drug of choice under medical supervision. One opened in East Harlem and the other is located in Washington Heights.



Because both sites operate illegally, there had been no federal or state regulations to guide these OPC's with best practices and safest operations. Into this void, the New York City Department of Health and Mental Hygiene or DoHMH (NYC's Health Department) recently released guidelines for current and future injection sites. These guidelines suggest program eligibility, equipment, space, staffing, training, services, community engagement, safety, funding, data management and reporting.

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Eligibility: Organizations wishing to open a consumption center must be registered with New York State Department of Health (NYSDOH) as a syringe exchange program. 

  • This provision will likely insure that OPC's are located in low-income communities of color where syringe exchange locations are currently densely located. 
  • The DoHMH provided no guidelines as to how close centers can be to schools.  In the Harlem location drug dealers sit on portable chairs across from a pre-school where they signal runners who carry the drugs, and those who take money.

Equipment: Participants bring the drugs they intend to use into the centers.  Based on their preferred mode of administration, the program will provide each user with the appropriate equipment, i.e. syringe, pipe, tourniquet etc. Sharps containers, emergency response equipment and personal protective gear will also be immediately available.



Space: There needs to be sufficient space for registration and screening, it should be regulated so each overdose specialist staff member oversees no more than four participants at one time, and in cleanly lit and mirrored locations. There needs to be space for overdose response, secure entrances and exits so staff can control flow of participants and an area where staff can monitor post-consumption. 

  • Time tables for observations aren't specified.  
  • Overdoses can occur 1-3 hours after the drug is taken and about 1 in 8 overdoses happen immediately after consumption.

Staff: A Responsible Person in Charge (RPIC) must be present at all times as well as overdose specialists and a medical lead. A counselor for crisis support and referrals to mental health care and social services will be present.



Training: The program should submit a list of required trainings, knowledge, experience and competencies to the NYC Health Department for review. Overdose Prevention Centers should participate in NYC Health Department supported evaluations of their services on a range of health and community safety outcomes. Staff providing OPC services need to demonstrate competence in responding to overdoses of varying complexity.

Services: Overdose Prevention Centers should provide on-site services that meet basic needs (including food and hygiene), health, mental health and substance use disorder treatments. As needed, the program should connect participants to health care and social services at other organizations and conduct outreach and community engagement in the neighborhoods where they operate.



Community Engagement: The program should develop and maintain relationships with residents, elected officials and local community organizations prior to opening and throughout the time of operation. There should be a direct point-of-contact manager for community concerns and concerns should be addressed in a timely manner. Syringe litter cleanup and disposal implementation is be maintained and OPC should routinely submit a community engagement plan to the NYC Health Department for review.

  • Notably the two OnPoint OPC's were opened surreptitiously with little to no community warning or engagement



Safety and Security: Safety applies to all staff, participants and local residents. The program will have a clear code of conduct and ensure participants understand and agree to the terms. Violations of the code should have firmly defined consequences. As much as possible, access to services should be preserved. 

  • It is unclear whether or not this applies to the sidewalk and block in front of the OPC's or only inside the facility



Funding: Staff time spent overseeing supervised consumption must be privately funded. Employee’s time should be documented in writing and signed by employee and supervisor and be submitted no less than once a month. Actual time must reflect the time spent on specific activities. Documentation must be audit-ready and produced upon request.



Data Management and Reporting: Electronic reports that include outcome metrics as well as demographic information will routinely be submitted to the NYC Health Department. Reports to the New York Health Department are to be evaluated as to the OPC impact on individual and community health and public safety.



Note that these are currently suggested guidelines meant to encourage compliance from existing and future OPC.



The Overdose Prevention Centers, like most if not all of Harlem's many addiction related programs, deny responsibility for participant behavior outside their facilities. 



OVERDOSE ADVISORY 

Issued by NYC's Health Commissioner

In response to the record number of drug overdose deaths in New York City (the latest data is of overdose deaths in 2022) a new Public Health Advisory has been issued by the Commissioner of New York City Department of Health and Mental Hygiene, Dr. Ashwin Vasan (pictured below).

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The Advisory puts New Yorkers on notice that they:

  1. Should learn the signs of an overdose, call 911 and administer naloxone (Narcan.) if it's available.
  2. Should be trained and equipped with naloxone (Narcan).
  3. Should speak knowledgeably with family and friends about substance use to combat stigma.
  4. Should not let loved ones use drugs alone.
  5. Health care providers should screen patients for substance use and give support if found.
  6. New Yorkers should not bring illicit drugs into their homes, if there are drugs inside they should be kept away from others especially children.
  7. Drug users are encouraged to use prevention centers, syringe programs, treatment options.

In 2022 there were 3,026 overdose deaths, an increase of 330 fatalities (12%) over the prior year, 2021.  For five consecutive years fentanyl has been present in 80% of drug overdoses. Xylazine (also called tranq) and other adulterants are being added to the drug supply and are increasing health risks.



A Mental Health Plan called Care, Community, Action focuses on overdose prevention as its primary objective. This plan has a declared goal of reducing overdose deaths by 15% by 2025.

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