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Producing alcohol and other drugs as a policy

‘problem’: A critical analysis of South Africa’s
‘National Drug Master Plan’ (2013–2017)

Article in International Journal of Drug Policy · December 2015

DOI: 10.1016/j.drugpo.2015.12.013

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Accepted Manuscript

Title: Producing alcohol and other drugs as a policy

‘problem’: A critical analysis of South Africa’s ‘National
Drug Master Plan’ (2013–2017)

Author: Kiran Pienaar Michael Savic

PII: S0955-3959(15)00366-7
DOI: http://dx.doi.org/doi:10.1016/j.drugpo.2015.12.013
Reference: DRUPOL 1684

To appear in: International Journal of Drug Policy

Received date: 24-7-2015

Revised date: 9-12-2015
Accepted date: 10-12-2015

Please cite this article as: Pienaar, K., and Savic, M.,Producing alcohol and
other drugs as a policy ‘problem’: A critical analysis of South Africa’s ‘National
Drug Master Plan’ (2013ndash2017), International Journal of Drug Policy (2015),
http://dx.doi.org/10.1016/j.drugpo.2015.12.013

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*Highlights (for review)

Producing alcohol and other drugs as a policy ‘problem’: A critical analysis of South
Africa’s ‘National Drug Master Plan’ (2013–2017)

Highlights

 We examine how South Africa’s current AOD policy produces the ‘problem of

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AODs’.

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 The policy constitutes AODs as a unified, global ‘problem’ on which consensus

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exists.

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 The policy displays a tendency towards inflating the ‘problem’ of AOD use.

 All AOD use is depicted as harmful, which works to legitimise punitive policy

responses.
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Page 1 of 30
*Manuscript

Producing alcohol and other drugs as a policy ‘problem’: A critical analysis of South

Africa’s ‘National Drug Master Plan’ (2013–2017)

Kiran Pienaara*, Michael Savicbc

a
National Drug Research Institute (NDRI), Melbourne Office, Curtin University, 19–35

t
ip
Gertrude St, Fitzroy, VIC, 3065.

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b
Turning Point, Eastern Health, 54–62 Gertrude St, Fitzroy, Victoria, 3065, Australia

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c
Eastern Health Clinical School, Monash University, Level 2, 5 Arnold Street,
Box Hill, Victoria, 3128, Australia.

*Corresponding author at: National Drug Research Institute (NDRI), Melbourne Office,
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Curtin University, Suite 6, 19–35 Gertrude St, Fiztroy, Victoria, 3065, Australia. Tel.: +61 3
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9079 2204. Email address: kiran.pienaar@curtin.edu.au
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Page 2 of 30
Abstract

The strong symbolic value of illicit drug use makes it a contested issue, which attracts mixed

public opinion, intense media attention and close political scrutiny. This means that the

formulation of plausible, authoritative policies governing illicit drugs must navigate fraught

political terrain. In a country like South Africa with its long unique history of institutionalised

t
ip
oppression of the black majority, the issues confronting drug policy are particularly complex

and the need for carefully formulated policy responses especially urgent. Yet despite this, the

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area of drug policy development in South Africa has received little scholarly attention to date.

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This paper explores the complexities of policymaking in the South African context by

drawing on feminist scholar Carol Bacchi’s poststructuralist approach to policy analysis,

an
which focusses on how policy helps to produce the problems it purports to solve. Taking as

its empirical focus, South Africa’s current drug policy, the third National Drug Master Plan
M
(NDMP), 2013–2017, the paper analyses how the policy constitutes the ‘problem of alcohol
ed

and other drugs’ (AODs). We identify three central policy proposals through which specific

problematisations emerge: 1) The proposal that drug use is a global issue requiring a
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coordinated policy response, 2) appeals to evidence-based policy proposals and 3) the

proposal that AOD ‘use’ and ‘abuse’ be treated interchangeably. We suggest that these
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proposals reveal a tendency towards inflating the ‘problem of AODs’ and thus work to justify
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punitive policy measures. In an effort to explore the implications of particular

problematisations for effecting social change, we clarify the ways in which the policy may

work to undermine the interests of those it seeks to aid by reinforcing stigma and

marginalisation.

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Page 3 of 30
Keywords: AOD policy, poststructuralist policy analysis, South Africa, problematisation,

policy development

Introduction

Given the controversy surrounding illicit drug use, the formulation of effective, credible

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policies governing such use must navigate complex political terrain. Policies are seen as

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needing to address public concern about illicit drug use as well as demonstrating a capacity to

remedy the problems presumed to follow from drug use (Fraser & Moore, 2011). At the same

us
time, the strong symbolic value of illicit drug use means it draws mixed opinion (Ritter,

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2011) and policies can sometimes attract criticism for their tendency to pathologise people

who use drugs, and stigmatise already marginalised communities (Buchanan & Young,
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2000). In a country like South Africa with its unique history of social exclusion and political

disenfranchisement of the black majority, the issues confronting policymakers are especially
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challenging and the need for carefully formulated policy responses are particularly pressing.

In an effort to explore the complexities of policymaking in the South African context, we

pt

draw on feminist scholar Carol Bacchi’s poststructuralist approach to policy analysis, which
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offers tools for analysing the ways in which ‘problems’ are constituted within policies. Rather

than accepting policy definitions of social problems, Bacchi’s ‘What’s the Problem
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Represented to be?’ (WPR) approach invites consideration of how particular issues are

represented as ‘problems’ in policy. Doing so requires scrutiny of what counts as a ‘problem’

and the implications of particular problematisations for how governing takes place. This

approach has been productively used to examine a variety of alcohol and other drug (AOD)

policy issues (see e.g. Fraser & Moore, 2011; Lancaster & Ritter, 2014), and laws in the

Australian context (Seear & Fraser, 2014; Lancaster, Seear & Treloar, in press). It has also

been applied in a cross-national comparison of recovery discourse in two Australian and

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Page 4 of 30
British AOD policy reports (Lancaster, Duke & Ritter, 2015). Despite these important

scholarly contributions to understanding the complexities of AOD policymaking in Western

policy contexts, a critical analysis of AOD policy development in the South African context

has yet to be undertaken. Alongside Bacchi’s WPR approach, we draw on an analysis of

rhetoric and an assessment of the objectives of South Africa’s current AOD policy.

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Drug policy in South Africa has historically been dominated by prohibitionist and supply

reduction approaches aimed at achieving a drug free society (Otu, 2011; Parry & Myers,

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2011). However, in the lead-up to the development of the third National Drug Master Plan

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2013–2017 (NDMP) – South Africa’s key national policy document – commentators called

for a more nuanced harm reduction approach (Parry & Myers, 2011; Van Niekerk, 2011).
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Given these two different visions for AOD policy and the fairly recent adoption of the current

NDMP, a critical analysis of South Africa’s AOD policy is both timely and important.
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Following Bacchi’s observation that policies are active in producing the problems they claim

to address, we explore how the ‘problem of AODs’ has been articulated in South Africa’s
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third NDMP, and with what potential effects for those governed by it. In doing so, we
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identify the discursive strategies used to render AODs (especially illicit drugs) a particular

kind of ‘problem’, and clarify how this problematisation authorises certain measures as
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legitimate. As we do not have access to empirical data on the implementation of the NDMP,

we do not seek to evaluate how the policy is being applied in practice, nor whether it is an
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effective means of governance. And while we make some tentative observations on the

implications of this policy for those it targets, a thoroughgoing assessment of how specific

policy practices affect the individuals and communities concerned requires further research.

Nonetheless the arguments we develop are likely to be of interest both within and beyond the

South African policy context in that they raise questions about the potential of policy to

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Page 5 of 30
undermine the interests of those it seeks to aid – in this case people who use AODs – by

reinforcing stigma and marginalisation.

Background

Historically, drug policy in South Africa has been characterised by a prohibitionist and

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punitive stance, which has been institutionalised via South Africa’s international agreements

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and domestic laws and policies (Van Niekerk, 2011; Parry & Myers, 2011; Otu, 2011; Myers,

Louw & Fakier, 2008; Padayachee 2001). South Africa is a signatory to the United Nations

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(UN) Single Convention on Narcotic Drugs, 1961 (Van Niekerk, 2011) and the UN

Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988
an
(Fellingham, Dhai, Guidozzi & Gardner, 2012), both of which aim to prohibit production and
M
supply of narcotic drugs. Upholding these international commitments while also being

attentive to local needs has proved challenging, with prohibitionist treaties often seemingly
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winning out (Padayachee, 2001). The means by which South Africa translated its

international commitment to prohibition into domestic law was through the Drugs and Drug
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Trafficking Act 1992 (ZA). Primarily concerned with supply reduction through law
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enforcement measures, the Act prohibited the use, possession, sale and manufacture of ‘any

dependence-producing substance’ (Drug and Drug Trafficking Act 1992, p. 6). Notably, the
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dependence-producing substances listed did not include alcohol or tobacco, nor did the Act

recognise that people could use drugs without becoming dependent. Indeed, the idea that

drugs are dangerous to society underpinned the Act, and legitimised the design of a policy

underpinned by the vision of a drug free society (Parry & Myers, 2011; Fellingham et al.,

2012). The focus on drug dependence is also evident in the Prevention of and Treatment of

Drug Dependency Act, 1992 (ZA), which sought to establish treatment and prevention

programmes for drug dependence.

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Page 6 of 30
It is important to contextualise South African drug policy at the time against the backdrop of

the racial segregation that occurred during apartheid. Under apartheid, people of colour were

systematically excluded from opportunities available to white South Africans, and were

forced to live in poor conditions in remote areas or townships on the urban fringe (Peltzer,

t
Ramlagan, Johnson & Phaswana-Mafuya, 2010). While the apartheid regime established

ip
health and social services for whites, public services for the black majority were scant by

cr
comparison, the one exception being police and law enforcement resources, which were

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deployed primarily to maintain control over black South Africans (Peltzer et al., 2010). In

relation to South Africa’s drug policy under apartheid, it has been suggested that the
an
apartheid regime may even have ‘deliberately promoted drugs among the black and coloured

communities as a strategy to fight back mounting oppositions to apartheid policy’ (Otu, 2012,
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p. 381).
ed

Since South Africa’s transition to a non-racial democracy in 1994, impetus has grown to

address social ‘problems’, including those associated with AOD use, through a social welfare
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approach (Geyer & Lombard, 2014). This is partially evident in the first National Drug
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Master Plan (NDMP), 1999–2004 (Department of Welfare, 1999), which emphasised the

need not only to reduce supply, but also demand for AODs (Geyer & Lombard, 2014). The
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second NDMP, 2006–2011 (DSD, 2006) and the Prevention of and Treatment for Substance

Abuse Act, 2008 (ZA), which supersedes the Prevention of and Treatment of Drug

Dependency Act, 1992 (ZA), also underscored the need to reduce demand for AODs and

address AOD-related harms alongside supply reduction (Otu, 2011). Despite the apparent

shift to a more multi-faceted policy approach, scholars have observed that the second NDMP

retains the rhetoric of cultivating a ‘drug free society’ through law enforcement supply

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Page 7 of 30
reduction measures (Parry & Myers, 2011). Otu (2011) notes that law enforcement activities

have increased despite the inclusion of harm reduction strategies in the second NDMP,

arguing that ‘South Africa has seen soaring numbers of drug offences arrests, trials,

convictions and incarceration’ (p. 386). Moreover, as he points out, the majority of people in

South Africa facing charges of drug offences are people of colour, leading him to argue that

t
South Africa’s drug policy has further entrenched apartheid-era racial inequalities.

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While it has been claimed that the ‘war on drugs’ rhetoric resonates with both the public and

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political parties (Otu, 2011), commentators have levelled a number of criticisms at the second

NDMP. Like the Drugs and Drug Trafficking Act 1992 (ZA), it treats all AOD use as
an
intrinsically harmful irrespective of drug type and individual patterns of use, prompting calls

for a more nuanced policy approach (Parry & Myers, 2011; Van Niekerk, 2011). Often
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drawing on international examples, scholars have argued that criminalisation is neither

evidence-based nor effective, stigmatises people who use drugs, neglects appropriate
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treatment responses, can result in corruption and vigilantism, and overburdens the criminal

justice system (see Otu, 2011; Van Niekerk, 2011; Parry & Myers, 2011; Padayachee 2001).
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Extending this critique, Myers et al. (2008) have commented on the absence of clear
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recommendations for AOD policy action in South Africa, alongside a lack of leadership and

accountability to implement policy effectively.

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The formulation of the third, and current, NDMP 2013–2017 presented an opportunity for the

identified shortcomings of the previous policy to be addressed, although it is unclear to what

extent they have informed the current policy. In 2011, the Central Drug Authority (CDA) and

the Department of Social Development (DSD) held the second Biennial Anti-Substance

Abuse Summit to finalise its review of the second NDMP and to guide the development of

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Page 8 of 30
the third NDMP 2013–2017. In total 670 delegates attended the summit (DSD, 2011)

including the president and eight cabinet members (Parry & Myers, 2011). Among the

activities conducted in the lead-up to the summit were a national rapid participatory

assessment, a door-to-door community anti-substance abuse campaign, and provincial

summits (DSD, 2013). Although the third NDMP (henceforth referred to as the NDMP)

t
states that community member input on the policy was widely sought, it is not clear whether

ip
consumer representatives or peer-support networks were consulted and if so, the extent to

cr
which their input informed the policy design. The NDMP retains the same key strategies of

us
previous iterations, including supply reduction, demand reduction and a ‘localised version’ of

harm reduction (DSD, 2013, p. 4). The document recognises that ‘harm reduction’ in the
an
South African context is more closely aligned with ‘harm prevention’ given that ‘harm

reduction practices appear to condone drug use’ (DSD, 2013, p. 68). The concern not to be
M
seen to ‘condone drug use’ is in keeping with the prohibitionist approach of past iterations of

the NDMP. Indeed, the underlying vision of a ‘drug free society’ is retained in the NDMP
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albeit rephrased in terms of a ‘society free of substance abuse’ (DSD, 2013, p. 3).
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Although a number of scholars have commented on South Africa’s AOD policy, to our
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knowledge very few policy analyses, and limited empirical research has been conducted on

the NDMP. Of the few available empirical studies is a quantitative content analysis of the
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second NDMP by Geyer and Lombard (2014), which aimed to ‘determine objectively

whether indicators of social development are covered in the manifest content of the NDMP’

(p. 334). The researchers developed a checklist of ‘quantifiable’ indicators, and used statistics

to identify which indicators received the most attention in the second NDMP (p. 334). They

found that mention of supply reduction strategies was much more common than harm

reduction strategies, and relatedly that references to human rights in the second NDMP were

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Page 9 of 30
limited. While this is a useful contribution in an otherwise scarce AOD policy analysis

landscape, it has some limitations. It assumes that policy can be examined objectively

through quantifying the occurrence of particular policy concepts that are identified as being

of interest a priori. For instance, if the policy frequently mentions ‘supply reduction’, then

according to this approach, it is said to have a supply reduction focus even though the

t
meaning of ‘supply reduction’ and the way it constitutes the ‘problem of drugs’ may differ

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across the policy. Indeed, such approaches to policy analysis tend to leave unexamined the

cr
contextually specific meanings of key policy concepts, the broader discourses on which they

us
rely, and perhaps most importantly for our purposes, how policy helps to constitute AODs as

a particular kind of social ‘problem’. In skipping over these issues such approaches treat
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national AOD policies as if they are ‘inconsequential, rhetorical documents’ (Lancaster &

Ritter, 2014 p. 81) that simply respond to pre-existing ‘problems’. However, as Lancaster and
M
Ritter (2014, p. 81) note, ‘this belies the subtlety with which such documents generate

discourse and produce (and re-produce) policy issues’. If we view policy as active in
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producing the ‘problems’ it claims merely to address, then a key aim of critical policy

analysis is to make these problematisations and their effects visible with a view to disrupting
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counterproductive and/or stigmatising policy formulations.

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Method: A poststructuralist approach to policy analysis

To track the processes by which South Africa’s AOD policy produces the ‘problem of

AODs’, we draw on Australian feminist scholar Carol Bacchi’s poststructuralist approach to

policy analysis, alongside a study of rhetoric and an assessment of intentions. Bacchi’s

approach, called ‘What’s the Problem Represented to be?’ (WPR), examines meaning-

making in policy design and identifies the taken-for-granted assumptions at work in policy.

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Page 10 of 30
Central to the WPR method is the concept of ‘problematisation’, which Bacchi uses to

advance two key objectives: 1. Denaturalise the commonsensical assumptions lodged in

policy about the nature of social ‘problems’; 2. Provoke close questioning of specific policy

proposals to identify how they formulate certain issues as ‘problems’ and illuminate their

presuppositions and effects (Bacchi, 2012). Crucially, in pursuing these objectives, Bacchi

t
challenges the premise that policy is capable of solving pre-existing problems, and instead

ip
considers how policy delineates and creates a ‘problem’ to be solved. As she puts it,

cr
‘“problems” are endogenous – created within – rather than exogeneous – existing outside –

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the policy-making process’ (Bacchi, 2009, p. x, original emphasis).

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In a departure from conventional approches to policy analysis with their emphasis on

‘problem-solving’, WPR shifts the focus of policy analysis to ‘problem-questioning’ (Bacchi,

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2009, p. xvii). This shift requires policy analysts to direct their attention to the ways in which

policy implies certain conceptions of problems that in turn shape how the purported problems
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are addressed and how the people involved are treated. Attending to the generative role of
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policy in producing social problems is an important task in the AOD policy arena where the

idea of ‘drug problems’ is so naturalised as to appear commonsensical (Lancaster, Duke &

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Ritter, 2015). If we are to disrupt the assumption that problems necessarily follow from AOD

use, and expose the counterproductive effects of some AOD policies and laws, then we need
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to denaturalise the very concept of ‘drug problems’ that underpins much AOD policy.

Bacchi’s approach offers tools for pursuing precisely this mode of critical analysis in that it

seeks to illuminate the deep-seated assumptions that buttress problem representations, and

traces how these representations lodge within particular policy interventions.

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Bacchi elaborates a strategy comprising six questions for analysing the kinds of taken-for-

granted assumptions shaping policy (2009, p. 2):

1. What is the problem represented to be in a specific policy?

2. What presuppositions […] or assumptions […] underlie the representation of this

problem?

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3. How has this representation of the problem come about?

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4. What is left unproblematic in the problem representation? […]

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5. What effects are produced by this representation of the problem?

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6. How/where has this representation of the problem been produced, disseminated and

defended? How could it be questioned, disrupted and replaced?

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While all these questions could be usefully applied to South Africa’s AOD policy, in this

article we address questions 1, 2, and briefly 5. In doing so, the analysis pays close attention
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to three key policy proposals underpinning the NDMP, their underlying assumptions and how
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they problematise AODs: 1) The representation of AOD use as a global issue requiring

coordinated interventions to address it; 2) Appeals to evidence and the pursuit of evidence-
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based policy proposals; 3) The policy proposal that AOD ‘use’ and ‘abuse’ be treated

interchangeably. We see these proposals as playing a significant role in the policy’s

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construction of the ‘problem of AODs’. Our argument is two-fold. First, we argue that these
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proposals reveal a tendency towards inflating what the policy construes as the ‘drug

problem’. And second, we draw attention to the policy’s rather problematic treatment of

evidence, arguing that despite calls for evidence-based policy interventions, the NDMP relies

on very limited research (and in some cases, no research) and evinces a worrisome tendency

to ignore the available evidence when advancing particular proposals for change.

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The NDMP and the ‘world drug problem’

We begin by addressing an issue that aligns with the first question of the WPR approach:

‘How are AODs constituted as a policy ‘problem’ in the NDMP?’ The introduction to the

policy opens with the following statement, which serves to delineate the ‘problem’

warranting a policy response:

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As part of the global community, South Africa is entangled in the world drug

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problem. The term ‘world drug problem’ or ‘drug problem’ relates primarily to the

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global demand for illicit drugs. However, in South Africa the concept is expanded to

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the demand for all types of dependence-forming substances (i.e. alcohol and other

substances such as various types of prescription and over-the-counter medication or

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illicit substances/drugs such as cannabis, cocaine and heroin), and is referred to as the

‘substance abuse problem’ (Department of Social Services (DSD hereafter), 2013, p.

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20).

Lodged in this statement is the policy proposal that ‘all types of dependence-forming
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substances’ be treated as problematic in that they contribute to the ‘substance abuse problem’.

A number of issues are collapsed in this opening proposal. The demand for ‘all types of
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dependence-forming substances’ is connected to ‘the substance abuse problem’, implying a

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linear causal progression between demand for AODs, supply of them, AOD use and abuse.

This is one of over fifty examples in the document where the policy collapses ‘use’ and
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‘abuse’ – a point we discuss in detail later. It is also worth noting that the demand for drugs

identified above as a crucial dimension of ‘the world drug problem’ is in part an effect of

prohibitionist policies themselves and the legal measures taken to control and regulate both

licit and illicit drug use (Van Niekerk, 2011). Thus, the problem as formulated here is

produced through, rather than preceding, AOD policy and law: were certain drugs not

prohibited, and the use of other so-called ‘dependence-forming substances’ not regulated,

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Page 13 of 30
they would not be difficult to access and demand for them would likely be viewed as

unremarkable, rather than problematic. But this construction of the problem as one of demand

serves an important political goal. It affords the illusion that policymakers have mastery over

the ‘problem’ and can govern it through the systematic reduction of individual demand for

AODs and the regulation of their supply. Not surprisingly then, the strategies of demand and

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supply reduction are central to the NDMP’s approach and are authorised as ‘commonly

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recognised strategies’ for addressing the ‘problem’, such as it is understood to be (DSD,

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2013, p. 4). We are not suggesting here that policymakers actively, or even consciously,

us
attempt to demonstrate mastery of the presumed problem through specific policy measures

but rather that this is an effect of particular problematisations. According to the NDMP’s
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formulation, ‘the drug problem’ is a global one in need of concerted global and local efforts

to ‘combat’ it. A specific policy proposal is embedded in this formulation, namely that the
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use of (illicit) drugs is a global issue requiring coordinated interventions to address it. The

specificities of the issues identified as ‘the drug problem’ are elided here in favour of
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presenting the problem as unified, homogeneous and, importantly for our purposes, pre-

existing particular policy interventions. More fundamentally, the status of drugs as a problem
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per se is treated as beyond dispute.

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The policy’s opening reference to the ‘world drug problem’ paves the way for the authorising

claim that almost immediately follows it: ‘These policies and practices are formulated in

response to the relevant United Nations conventions and the conventions of other relevant

international bodies’ (DSD, 2013, p. 20). Later the document observes the need to realign

South Africa’s policy approach with the ‘changing strategies of the United Nations Office on

Drugs and Crime (UNODC) and the World Health Organization (WHO)’ (p. 27). These

references to international organisations seen as possessing expertise in the specific area of

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Page 14 of 30
policy development play an auspicing role (Bacchi, 2009). They legitimate the policy

contents and proposals for change. In this case, they also create the impression of a global

consensus on the nature of the ‘drug problem’ and the strategies proposed to address it. Yet

given the controversy surrounding illicit drug use, and the mixed opinion and intense media

attention it generates (Fraser & Moore, 2011), the notion of a global consensus and a unified

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strategy on drugs, both licit and illicit, is very far-removed from the heterogeneity and

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variability that characterises policy approaches to drugs around the world. Indeed the very

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shifts in the UNODC’s and WHO’s AOD policy approach (from an emphasis on supply

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reduction toward a focus on primary prevention), reiterate the unstable and changing nature

of AOD policy and practice, even amongst international organisations that are associated
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with the idea of a global consensus. In the NDMP’s references to international organisations,

such as UNODC and the WHO, we begin to see the crucial role of evidence and expert
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opinion in the formulation of the ‘drug problem’ in the policy. The treatment of evidence is

the second noteworthy feature of the NDMP that we examine as appeals to evidence are used
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to support the policy proposals and recommendations.

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Appeals to evidence and the pursuit of evidence-based policy proposals

In the foreword to the NDMP, the Minister of Social Development stresses: ‘The impact of
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alcohol and substance abuse continues to ravage families, communities and society […] The

emotional and psychological impacts on families and the high levels of crime and other social

ills have left many communities under siege by the scale of alcohol and drug abuse’ (DSD,

2013, p. 2). She continues by proposing the delivery of ‘evidence-based strategies’: ‘the

revised plan focuses more on the delivery of evidence based strategies that are designed to

meet the defined needs of communities (DSD, 2013, p. 3). While these bold assertions about

the scale of the ‘problem’ and the pursuit of evidence-based policy proposals appear

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Page 15 of 30
uncontroversial, a closer look at the policy reveals they are more contentious than a cursory

reading would suggest. Consider for example this observation about research knowledge on

AOD use in South Africa:

As in the case of alcohol use, accurate, comprehensive and up-to-date data on the

nature, extent and consequences of the use of drugs […] in South Africa are not

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available. No comprehensive national population study on these issues has been done

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over the past more or less two decades. Indeed, the paucity of data on especially the

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use of illicit drugs and the non-medical use of over-the-counter and prescription

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medication complicates the identification of patterns of use and in particular trends

over time in this regard (DSD, 2013, p. 40).

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How can the ‘impact of AOD abuse’ have ‘ravaged families, communities and societies’ and

‘left many communities under siege’ if, by the policy’s own admission, there are no available
M
data documenting the ‘nature, extent and consequences’ of AOD use in South Africa? Indeed

if we look at the policy as a whole, an even more complex, equivocal picture of the ‘drug
ed

problem’ emerges than is evident in the stark contrast between these two formulations.

Across the text, AOD use in South Africa is variously described as a ‘siege’ (p. 2)
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‘continu[ing] to ravage families and communities’ (p. 2), a ‘scourge’ (p. 4, 21, 22), ‘(fairly)
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common’ (p. 40), ‘generally a male rather than a female phenomenon (p. 41), requiring

‘extensive research’ (p. 132) and ‘[in] need of comprehensive research’ (p. 137). While the
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first three of these formulations constitute the scale of the ‘problem’ as severe through the use

of negatively freighted ‘crisis’ metaphors, the last four enact it in rather more cautious terms:

as moderately prevalent, gendered and, importantly as inconclusive and necessitating

extensive investigation. These contradictory formulations point to the difficult terrain that

policymakers must navigate. On the one hand, they need to establish the authority and

credibility of policy measures through, amongst other things, appeals to evidence (Lancaster,

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Page 16 of 30
2014). But where the evidence is thin (or in this case non-existent), policymakers still need to

establish the legitimacy of particular proposals by presenting the policy ‘problem’ as

indisputable and in need of a concerted response (Moore & Fraser, 2015). One could argue

that the representation of the problem as a ‘crisis’ serves the latter aim: it works to endorse

stronger statements about its severity than are warranted by the available research.

t
ip
The issue of evidence also comes up in a later section titled ‘Predictive analysis of substance

abuse patterns and trends in South Africa and implications for policy’ (DSD, 2013, p. 136).

cr
Here the authors again acknowledge the limited evidence on the ‘drug problem’: ‘In South

us
Africa there is very little concrete, accurate and detailed evidence of the drug problem and its

effect on populations, hence the mentioned need for comprehensive research on the subject.
an
If this need is satisfied, it would become possible to identify problems more scientifically and

devise appropriate policy responses.’ (DSD, 2013, pp. 136–7). Implicit here is the assumption
M
that evidence is grounded in science (‘identify problems more scientifically’) and thus
ed

evidence-based policy responses are justified as ‘appropriate’ because of their scientific

backing. Evidence is presumed to have intrinsic value and is constituted as a superior form of
pt

knowledge guiding policymaking (Lancaster, 2014). Absent from this account is any

acknowledgement that evidence is the outcome of competing interests and is always

ce

contested as it is based on the privileging of certain perspectives and the silencing of others
Ac

(Colebatch, 2010). Such an acknowledgment challenges a key presupposition of the NDMP,

namely that evidence is objective and inherently valid.

The NDMP’s acknowledgement of the paucity of local AOD research is consistent with

observations that there is a lack of funding for such research in South Africa, which has been

attributed to the government’s competing funding priorities such as housing, education and

healthcare (Peltzer et al., 2010). One might expect that where limited research is available

16
Page 17 of 30
and a lack of clarity persists, policymakers might be more circumspect in their

pronouncements and the policy solutions they propose. Instead, in the absence of conclusive

knowledge, the NDMP advocates a ‘[p]redictive analysis of substance abuse patterns and

trends in South Africa [...] that could help predict the potential policy, practice, protocol and

legislative implications […] for […d]rugs in use, drug use patterns and related bio-psycho-

t
social harm’ (DSD, 2013, pp. 136–7). Implicit in this proposal is the assumption that such an

ip
analysis would provide a neutral and effective means for ‘predict[ing] potential policy’

cr
(DSD, 2013, p. 137). However, by implying a direct causal relationship between AOD use of

us
any kind and ‘bio-psycho-social harm’, it undermines its implied claim to neutrality (DSD,

2013, p. 137). In other words, while the policy is obliged to admit that little is known about
an
the ‘drug problem and its effect on populations’, it still treats the causal link between AOD

use and bio-psycho-social harm as incontrovertible. AOD use is constituted here as both
M
inherently harmful and poorly understood.
ed

A related feature that bolsters the appeals to evidence in the NDMP is the discussion of ‘gaps

in drug-related information in South Africa’ (DSD, 2013, p. 132). This expression suggests
pt

that the field is sufficiently developed that only gaps remain, when in fact, and as already

noted, the policy repeatedly concedes the dearth of knowledge on AOD use in South Africa.
ce

We argue that the use of the term ‘gaps’ minimises the extent of what is unknown about the
Ac

purported AOD problem and instead enacts the state of knowledge as almost complete, rather

than thin and rudimentary. Crucially, what is not known is vital to the policy

recommendations made. For example, the strategy for dealing with ‘substance abuse’ that is

accorded the highest priority in the NDMP is ‘better parenting’ (DSD, 2013, p. 45) , but the

policy then goes on to note that this strategy only has ‘some effect in reducing onset [of AOD

use]’ and has ‘some positive findings’ to support it (DSD, 2013, p. 56, emphasis added).

Importantly, from the perspective of a WPR analysis, the strategy of better parenting renders

17
Page 18 of 30
parents responsible for producing ‘sober’ citizens. Like the modes of governmentality that

Nikolas Rose identifies in his 1999 analysis of political power, this policy proposal operates

as a form of micro-government: it seeks to manage the conduct of individuals by intervening

at the level of the family unit to prevent ‘substance abuse’ in future generations.

In other cases where policy draws on AOD research, it does so in ways that are confusing and

t
ip
suggest a lack of congruence between the findings of existing research and the NDMP’s

recommendations. This is perhaps most clearly evident in a section titled ‘Effective drug

cr
policy options’. Here nine ‘conclusions’ on options for drug policy proposals are presented as

us
a ‘guide for policymakers’ and the work of Babor et al. (2010) on evidence-based policy is

cited to authorise these conclusions (DSD, 2013, p. 55). Apparently intended to demonstrate
an
that the policy is guided by ‘some [research-based] consensus’ on ‘effective drug policy

options’ these options do not actually find their way into the policy measures (DSD, 2013, p.
M
55). For instance, the NDMP reports that ‘[p]revention programmes have a modest impact
ed

[…] the value of which is appraised differently by different stakeholders.’ (DSD, 2013, p. 59,

original emphasis). Yet despite this finding, the NDMP emphasises prevention as the ‘most
pt

important leg of [its] programme’ (DSD, 2013, p. 3). It would appear from this and other

examples that specific research findings on effective AOD policy proposals have little
ce

bearing on the policy measures proposed. Indeed, these ‘effective policy options’ sit
Ac

uncomfortably alongside definitive policy recommendations that do not take them into

account and instead tend to inflate the ‘problem’, make bold claims about its causation and

emphasise the dire consequences AOD use poses to the public.

18
Page 19 of 30
The conflation of AOD ‘use’ and ‘abuse’

Consistent with the tendency observed above to slip indiscriminately between AOD ‘use’ and

‘abuse’, the NDMP proposes treating the terms ‘drug’, ‘substance (of abuse)’ and

‘dependence-forming substance’ as interchangeable terms: ‘For convenience the terms

‘drug’, ‘substance’ (of abuse), ‘dependence-forming substance’ and ‘alcohol and other drugs’

t
(AOD) are considered interchangeable in the NDMP’ (DSD, 2013, p. 28). This policy

ip
proposal constructs drugs as inherently harmful, which problematises all drugs regardless of

cr
how they are used. In so doing, it ignores the established body of sociological and

us
anthropological research documenting that many people take drugs without ‘abusing’ them

and/or without becoming drug dependent (see for example, Aldridge, Measham & Williams,
an
2011; Pennay & Moore, 2010). Corroborating the findings of this research, the UNODC 2014

World Drug Report estimates that of all those who use illicit drugs, only 10–12% develop
M
‘drug dependence’ or ‘problematic drug use’ (UNODC, 2014). We argue that the UNODC

findings point to the importance of distinguishing between ‘drug use’ and ‘abuse’. Implicit in
ed

this distinction is an acknowledgment that drugs are not inherently harmful. Thus, retaining

this distinction makes it possible to query the all-too-familiar characterisation of drug use as
pt

problematic. Interestingly, as noted above, UNODC is one of the organisations to which the
ce

policy defers, observing the need to align its approach with that of UNODC (and other

international organisations). Yet the policy displays a startling amnesia of this earlier stated
Ac

need when it comes to retaining the key distinction between use and abuse.

However, the conflation of AOD use and abuse is in keeping with the policy’s treatment of

AOD harm causation: it endorses the policy message that any AOD consumption, regardless

of pattern of use, inevitably leads to a range of serious harms. To illustrate this understanding

of AOD harm causation, consider the statements made by the Minister of Social

19
Page 20 of 30
Development in the foreword to the policy: ‘The use of alcohol and illicit drugs impact

negatively on the users, their families and communities. Alcohol and drugs damage the health

of users and are linked to rises in non-communicable diseases […] Users are also […] at risk

of long-term unemployment due to school dropout […] The social costs for users are

exacerbated due to being ostracised from families and their communities. In acute cases users

t
are at risk of premature deaths due [to] ill health, […] violent crime and suicide.’ (DSD,

ip
2013, p. 2). Implicit in these statements are three presuppositions. Firstly, AOD use in and of

cr
itself, has negative impacts. Secondly, these can be distinguished from the impact of other

us
individual, social and institutional factors. Thirdly, these impacts extend beyond the

individual taking AOD to the families and communities of which s/he is a part. This
an
representation of the ‘problem’ renders the individual responsible for a number of deleterious

effects presumed to follow from AOD use, including violent crime, unemployment and even
M
‘premature death’ (DSD, 2013, p. 2). Importantly, because of the NDMP’s consistent

conflation of ‘use’ and ‘abuse’, these negative effects are ascribed to AOD consumption on
ed

any scale or at any frequency. This serves to problematise all AOD use, collapsing it into a

single undifferentiated category called the ‘drug problem’. This move exaggerates the risks
pt

and harms of AODs and inflates the scale of the ‘problem’ (in the process expanding the
ce

category of ‘abuse’ to annex all patterns of AOD consumption). Furthermore, the policy

emphasis on harm narrowly circumscribes the ways that AOD use can be thought about,
Ac

foreclosing any consideration of the pleasures and therapeutic benefits that certain patterns of

AOD use can afford (Duff, 2004).

Given the extensive sociological and anthropological literature documenting AOD use as a

widespread social practice, what discursive effects might be produced by characterising it as

intrinsically problematic? Firstly, this representation of the ‘problem’ allows policymakers to

20
Page 21 of 30
render the arguably unremarkable phenomenon of AOD use a unified ‘problem’, which can

then be tackled with familiar strategies to generate predictable effects. This view of social

problems works to preserve the credibility of public policy as capable of achieving specified

outcomes, and it therefore has considerable political value. Secondly, when AOD use is

understood to be a marker of other ‘social ills’ such as crime, poverty and unemployment, the

t
specificity of each of these so-called ills is displaced from view (valentine & Fraser, 2008),

ip
allowing policy to oversimplify AODs as the cause of harm and overdetermine responses to

cr
this presumed harm. Importantly, the implied strong causal link between AOD use of any

us
kind and a range of serious harms underpins tough policy measures to address such use

(Fraser & Moore, 2015).

an
Problematising all AOD use also allows policymakers to ascribe intractable social issues to
M
individual AOD consumption: instead of focussing on unemployment, incidence of disease,

social marginalisation and violent crime as issues in their own right, it is simpler (and perhaps
ed

more politically acceptable) to treat these issues as arising from AOD use alone. This

tendency manifests in the NDMP’s list of proposed interventions for addressing ‘the drug
pt

problem’:
ce

[The policy recommends] a combination of environmental and individual oriented factors

[…] to combat substance abuse. These factors are, in order of priority:

Ac

 Better parenting […]

 Recreation […]

 Tavern closure […]

 Law enforcement […]

 Spiritual care […]

 [R]educing the availability of dependence-forming substances [...]

21
Page 22 of 30
  Rehabilitation or provision of access to […] detoxification, rehabilitation, aftercare

and re-integration with society for those suffering from substance abuse/dependence;

 [T]he ability to persuade community members to become involved in the process of

dealing with substance abuse;

 Healthy mind or the ability to resist the temptation to abuse substances […]

t
 Employment or lack thereof; and

ip
 Poverty or the lack of adequate means of support. (DSD, 2013, pp. 45-6, original

cr
emphasis).

us
Striking in this list is the low priority accorded to social-structural issues, such as

unemployment and poverty. With the exception of tavern closure and some law enforcement
an
efforts, these interventions target the individual and to a lesser extent, their family and

community. The effect of this focus on individual interventions is to place the burden of
M
AOD-related harm, and thus the onus to address ‘the drug problem’ largely on the individual,

diverting policy and resources away from broader structural issues that contribute to the
ed

‘problem’, such as it is understood to be. As Nancy Campbell (1999, p. 903) astutely

observes in the context of US illicit drug policy, ‘individualist policies effectively shift blame
pt

to individuals for the cumulative effects of policy decisions, social change and structural
ce

phenomenona’. We argue that these structural phenomena, and the thorny social issues

associated with them, merit attention in their own right, rather than being treated as inevitable
Ac

sequelae of AOD use.

While we suggest that all the measures above warrant careful scrutiny, we restrict ourselves

here to examining the measure of ‘rehabilitation’, specifically its goal of ‘re-integrat[ing]

with society those suffering from substance abuse/dependence’ (DSD, 2013, p. 45). In the

NMDP the cumulative effect of ‘substance abuse’, and the variety of social ills presumed to

22
Page 23 of 30
follow from it, is understood to pose a threat to ‘social cohesion’ and community stability

(DSD, 2013, p. 21). Because of the causal links drawn elsewhere in the document between

AOD use and crime, violence, the spread of disease, unemployment, poverty and a variety of

other social issues, people who use AODs are implicitly constituted as responsible for these

social issues. Re-integrating these marginalised ‘others’ into the community thus becomes the

t
solution, as part of a broader goal of ‘rehabilitation’ (DSD, 2013, p. 25). Implicit in the

ip
concept of ‘re-integration’ is a belief that people who use AODs (especially illicit drugs) exist

cr
on the margins of society, or at worst, are excluded entirely. The policy intervention thus

us
comprises a set of regulatory mechanisms for bringing the individual back into line with

established social norms, restoring their relationship to society. In other words, the aim of re-
an
integration is to achieve sameness and social conformity (Moore, Fraser, Tӧrrӧnen &

Tinghӧg, 2015).
M
Importantly, because AOD use is understood to be the problem – that which makes certain

people unacceptably different – the means by which they can once more become
ed

indistinguishable members of society is to renounce AODs. This solution leaves little place
pt

for harm reduction and its acknowledgement that, for a variety of reasons, people continue to

drink and take drugs and therefore public health interventions are more effectively directed at
ce

minimising AOD-related harm, rather than reducing or preventing use per se (Ritter &

Cameron, 2006). Moreover, by depicting people who take AODs as socially excluded and
Ac

requiring that they ‘rehabilitate’ and ‘re-integrate’ into society, the policy risks reinforcing

their marginalisation especially when they cannot or do not wish to renounce AOD use. We

are not suggesting here that policymakers make these causal links and assumptions

intentionally, or even consciously, but rather that this is one of the effects of policy

formulations that locate the cause of the ‘problem’ in individual drug-using subjects. Indeed,

as Bacchi (2007) notes, the conceptual logics and assumptions that lodge within policy are

23
Page 24 of 30
deep-seated and thus require careful scrutiny for their capacity to marginalise, stigmatise or

simply undermine the interests of those policy seeks to aid.

Conclusion

In this article, we have conducted a critical, poststructuralist analysis of South Africa’s

t
ip
current AOD policy, identifying the ways in which it constitutes the ‘problem of AODs’.

cr
While on the surface the NMDP contains elements that appear to be aligned with a more

nuanced harm reduction approach to AOD policy in South Africa, a closer inspection reveals

us
a continuation of previous punitive approaches, which we argue could serve to further

an
marginalise and stigmatise those intended to benefit from the policy, namely people who use

AODs. We also drew attention to two related and concerning trends in the policy’s
M
formulation of ‘the drug problem’: 1. The tendency toward problem inflation, which works to

endorse stronger statements about the severity of the ‘problem’ than are warranted by the
ed

available research; 2. The treatment of evidence in the policy: despite calls for evidence-

based policy interventions, the NDMP relies on very limited research and tends to ignore the
pt

available evidence when advancing particular policy solutions. Of course, we acknowledge

ce

that in the absence of a robust local AOD research sector and given the dearth of knowledge

about AOD use in South Africa, the representation of the ‘drug problem’ as a major, global
Ac

issue allows policymakers to default to ‘evidence’ generated and/or promulgated by global

centres of ‘expertise’, which serve to authorise particular policy measures as both legitimate

and credible. However, this reliance on international research knowledge moves

understandings of AOD-related issues further away from the local context in which the policy

operates. It seems to us that this approach elides the specificities of the issues that have come

to be gathered under the umbrella of ‘the drug problem’, and risks generating policy

measures that are inappropriate or, at worst ineffective, in the South African context. The

24
Page 25 of 30
development of a strong national AOD research base that can guide policy in South Africa is

therefore crucial.

In closing, and by way of suggesting how potentially damaging policy formulations might be

disrupted, we wish to draw attention to the language used to refer to affected individuals in

t
ip
the NDMP. Rarely are they referred to as people who use drugs, a phrase that has become so

widely used and accepted in the AOD sector as to merit its own acronym, PWUD. In most

cr
cases, they are depicted entirely in terms of their AOD use and reduced to the status of ‘users’

us
(DSD, 2013, pp. 51, 56–8, 60), ‘addicts’ (p. 2), ‘abusers’ (pp. 4, 28–30,137), and

‘dependents’ (pp. 29–30, 64, 137). These representations produce people who use AODs as
an
the ‘problem’, as pathological subjects in need of treatment. In so doing, they stigmatise

those seen as responsible for the problem and place the focus of policy interventions on these
M
individuals. The ways in which PWUDs figure in the policy leads us to return to an issue we

touched on earlier of whether consumer representatives were consulted in its formulation.

ed

Although the NDMP notes that ‘experts on substance abuse’ guided the policy development
pt

and will contribute to its review after five years, it is unclear whether these experts included

consumer representatives (DSD, 2013, p. 25). If not, there is a risk that the proposed
ce

measures will fail to address their needs and, as we have suggested, may even work to

undermine them. With this in mind, we underscore the need for policy to be informed by the
Ac

lived experiences of AOD consumers in South Africa, and relatedly for policymakers to

consider to what extent people’s experiences align with, or depart from, the problematisations

articulated in the NDMP. Building a research base in South Africa that illuminates the

diversity of people’s experiences with AOD use is, we suggest, critical to the development of

nuanced, empirically informed AOD policy. So too is involving those directly affected in the

policymaking process since ultimately it is their needs that should direct policy.

25
Page 26 of 30
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