To: Director-General: Social Development

Attention: Ms Vathiswa Dlangamandla

Per email: VathiswaD@dsd.gov.za

CC: MogotsiK@dsd.gov.za

From: The Evangelical Association of South Africa


  1. The Evangelical Alliance of South Africa welcomes the publication of the draft Policy on the Prevention of and Treatment for Substance Use Disorders. The challenge of substance abuse is one that is harmful in many ways to our society, destroying lives and breaking down families. South Africa is rated as a country that has some of highest rates of substance abuse and it is encouraging that the government is taking these first steps towards a more holistic and evidence based approach.


  1. TEASA is wholly in agreement with the proposals identified on page 25 of the draft policy. The adoption and implementation of these measures would go a long way in dealing with the challenges the country is facing.


  1. The draft policy rightly notes that the work of reducing substance abuse cuts across different levels of government and different departments. TEASA notes however that there is a special role that local municipalities have to place in the regulation of these substances.


  • TEASA proposes that each municipality be legally obligated to develop a liquor trading bylaw and such bylaw to be deposited with ADAC-SA.
  • We also propose that each municipality be obligated to establish a local drug action committee and have a bylaws that are aligned to the proposed new legislation that outlines the functions and responsibilities of a local drug action committees.


  1. TEASA expresses its endorsement of the three primary objectives outlined in the policy framework. The first of these is the Demand Reduction Pillar, focusing on averting the onset of substance abuse or dependency and mitigating the impact of conditions conducive to the use of addictive substances. Implementing measures such as elevating the legal drinking age becomes imperative in combatting the pervasive issue of alcoholism. Timely interventions in high-risk areas, featuring targeted programs for the youth will play a crucial role in reducing demand. Churches, given their historical positioning, emerge as viable entities for executing some of these interventions. We urge the government to actively embrace the services and community engagement that churches can contribute.


  1. The second pillar is the Supply Reduction Pillar, aiming to diminish the availability of both legal and illicit drugs, a responsibility entrusted to law enforcement. It is important for the government to regulate the space through monitoring and controlling licensing for establishments that sell these substances, implementing restrictions on advertising, and setting limitations on the hours of sale. As TEASA we understand the large economic benefits that the alcohol industry has on the economy, however such benefits are vastly overshowed by the negative effects of over drinking and addictions. There will be push back from the industry that supplies as money tends to dictate many conversations. We invite government to be steadfast in the resolutions and consider the overall benefits of reduced supply on society as a whole.


  • In an effort to curb the supply of alcohol, we propose harsher penalties and higher fines for the consumption of alcohol at un-licensed establishments. We propose that criminal sanctions be included as well. It is important that the punitive measures actually work as a deterrent to would be offenders. The consequences of carrying out the illegal activities must be felt by both the consumer and the owner.


  1. Lastly, the Harm Reduction Pillar encompasses the treatment of substance use disorders and associated activities designed to minimize the harm caused by the utilization and abuse of substances within communities. This pillar seeks to alleviate the adverse effects of substance abuse on individuals and communities. Acknowledging substance abuse as a significant challenge, rather than merely a moral failing subject to criminalization, marks a progressive and imperative initial stride towards establishing enduring interventions. Churches, given their historical positioning, emerge as viable entities for executing some of these interventions. We urge the government to actively embrace the services and community engagement that churches can contribute.


  • A key intervention that would go a long way in reduction of the harm that can be caused by enacting mechanisms that ensure that there are compulsory mechanisms placed in the law to report the use of substances by under-age minors.
  • It should become obligatory for parent(s) or guardians to report their under age children to a social workers if there are reasonable grounds to suspect that they are abusing substances.
  • In rural settings that are under traditional leadership it should become obligatory for the parent(s) or guardian to report their under-age minors whom there are grounds to suspect that they are abusing substances to both the tribal authority (traditional leadership) and to a social worker.


  1. The introduction of the Alcohol and Drug Advisory Council Of South Africa (ADACSA) is a timely intervention. TEASA hopes that this will truly be a body that offers timely interventions and properly fulfils its mandate. We trust that at the time of formally convening the council that there will be a very broad sectoral engagement and the voices of all South Africans will be heard, including those of the church.
    • We propose that ADAC-SA be an independent body that is reports to the DSD and the sector, being resourced through the DSD and the Alcohol Harms Reduction Fund.


  1. Whilst the policy is broadly positive and promises to tackle an issue that has held a grip on our society for so long, it is disappointing that no explicit provision has been made for the funding of initiatives that would deal with this issue.
    • TEASA joins in other civil society voices that call for the establishment of an Alcohol Harms Reduction Fund. Such a fund would be used to fund all the necessary interventions highlighted above.


  1. Finally, TEASA would like to note some disappointment with the timing of this policy and call for comments. The policy was published at the end of the year during the festive season, fully aware that the majority of civil society actors and interested parties would be likely unable to make comprehensive submissions in the time allocated. We hope that the relevant government authorities will take into serious considerations the submissions made as well as creating space for further public engagement in the coming months.

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