AuthorEuropean Monitoring Centre for Drugs and Drug Addiction (EU body or agency)
TECHNICAL REPORT | Balancing access to opioid substitution treatment with preventing diversion of medications
of misuse of these products, while law enforcement agency data on drugs seizures provide
information on trafficking and diversion at the wholesale and retail levels.
To gain a more accurate understanding of the nature of and relationship between access to
OST and the misuse and diversion of OST medications, current epidemiological tools require
fine tuning, while their limitations must be acknowledged. For example, the source of the OST
medication reported to be misused by clients entering treatment would be useful information to
understand the provenance of the medication. This information would allow an understanding to
be gained of whether the misuse involved legitimately prescribed OST medications or diverted
OST medications. In addition, the duration of the problematic use of OST medications would
provide useful information on the nature of the dependence associated with the misuse of these
In relation to drug-related deaths data, two main pieces of information would clarify the role and
risks of non-prescribed OST medications. First, a clear definition would be needed about the
main cause of death when prescription OST medications are detected in the post mortem
toxicology, and it would need to be determined if the fatality could be attributed solely to the
medication, if the medication was a contributing factor or if it was not implicated. Second,
information on the treatment status of the deceased should be provided. These are important
pieces of information that would clarify whether, when there arementions of OST medications
in reported fatalities (or in emergency room mentions), the clients were in or out of treatme nt at
the moment of death. This information would also clarify whether changes in the number of
mentions of OST medications in opioid-related deaths are associated with growing diversion
and misuse in the country or are a direct function of the number of people who are enrolled in
legitimate OST. As mentioned earlier, as the number of patients in OST increases, so will the
number of deaths in which prescribed OST medications are detected. Linkages between
databases, like in Ireland, namely between the mortality register and the central OST register,
can provide an indication of whether the deceased was prescribed the medication or whether it
originated from diversion.
Improvements in national and European instruments and mechanisms for monitoring the
diversion and misuse of pharmaceutical products, including prescription OST medications, are
therefore paramount for developing effective anti-diversion policies.
6. Conclusion
The consequences of the diversion and misuse of prescription OST medications are a
continuing public health concern and require heightened vigilance in light of the recent opioid
epidemics in the United States. Another important concern presented here is the continued, and
likely increased, involvement of OST medications in drug-related deaths in some countries.
However, there is also a need to maintain focus on the importance of OST as an effective
treatment option. In this context, encouraging the implementation of and adherence to evidence-
based guidance, such as WHO policy guidelines, will contribute to the prevention of diversion
without hindering access for legitimate patients.
It is also important that any policies and responses are in line with international conventions and
treaties emphasising human rights and the right to health in the field of opioid dependence
treatment. The international guiding principles for legislation and regulation of opioid agonist
treatment (Pompidou Group, 2017) highlight that, from a normative point of view, anyone with a
diagnosis of dependence syndrome must have access to treatment based on the latest scientific
and medical knowledge, that obligations for physicians should be limited to what is strictly

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