Submission on Proposed Regulation under the Restricting Public Consumption of Illegal Substances Act, 2025

Canadian Drug Policy Coalition/ Doalition canadienne des politiques sur les drogues

On February 28, 2026, the Canadian Drug Policy Coalition (CDPC) submitted comments opposing a proposed regulation under the Restricting Public Consumption of Illegal Substances Act, 2025 (RPCISA) that would extend authorities to transit special constables. We reiterate our serious concerns that the Act and proposed regulation will increase the risk of death, serious injury, psychological harm, and discrimination, particularly for people who are unhoused, living in poverty, and Indigenous people.

The submission highlights that expanding enforcement in transit spaces will further incentivize lone and isolated drug use due to fear of criminalization, including harassment, displacement, fines, and imprisonment — behaviour that directly contradicts public health guidance and increases the risk of drug toxicity injury and death. We also raise alarm about public statements suggesting the need for additional tools such as tasers, noting documented risks associated with their use. The submission outlines the disproportionate harms to Indigenous people, the high public costs of criminalization compared to housing and health-based services, and the risk of psychological harm to health and social service workers, transit workers, and bystanders. CDPC urges the Ministry to withdraw the proposed regulation and repeal the Act.