The description of the standards is good but rarely gets past the general idea. The CCSA standards should emulate the CAMH guidelines on mental health (http://www.camh.net/About_CAMH/Health_Promotion/Community_Health_Promotion/Best_Practice_MHYouth/index.html#guidelines). The CAMH guidelines make a general point but then point to and link with evaluated programs that implement that principle. We have tried to do the same in our listing of evaluated, existing programs in our toolbox (http://shtoolbox-substanceabuse.wetpaint.com/). In that toolbox we have listed over 100 programs that have been evaluated, identified or developed by credible organizations. I realize that CCSA is also creating a database of local programs as part of this project but unless those programs are conveniently linked as suggested, then you force the reader to go looking and perhaps use the wrong search words or not bother.

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These 18 statementsneed to be applied at all levels in the school system, and health system. Take a look at Michael Fullan's work on tri-level change and then apply it to this set of standards.

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All the stuff about school climate and connectedness has been said before. The school dropout literature has been around for years. Most ministries have issued student conduct policies and done dropout prevention programs for years. The drugs people don't need to repeat all that.

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The descriptions of the standards are all fine but way too general for any use by schools. For example, the Effective Behavior Support program is used by a lot of schools to deal with trobled students. Educators don't need to be told the school climate and connectedness are important. What they need are proven example programs that they can adapt and implement. The CASH web site has a lot of good programs. It should be integrated with the standards.

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(Comment: This sentence shows the real philosophy of this document, the poor souls who work in schools are responsible for preventing substance abuse. It is not parents, not the police, not the community...just teachers)

"While support and advice may be drawn from different sectors, it is ultimately staff and students who will bring positive change to the school community. Viewed this way, the best results occur when schools not only refer to research on good practices but also take the time to reflect on and interpret how these apply to their situation."

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The approach to the workbook section is quite muddled. Almost all of the suggested processes are well beyond the time available to local schools to do self-evaluation. Indeed the questions are more suited to a local school board, working with a health authority, when they are implementing a program like that in the Vancouver School Board.

I suggest CCSA consider choosing one of these three routes to clear up this confusion between what is possible at the school vs the local SH and HA level.

One. CCSA could revise the content to aim it clearly at a local inter-agency level. The questions would need to be changed to reflect that level (The SH program in England has an excellent tool that could be adapted.

Two. CCSA can change the approach and copy other self-assessment programs used by PREVNET on school safety, UNB on school climate and Waterloo on tobacco, physical activity and nutrition. In these other examples, the university researchers help the school collect data, analyze it and formulate a plan of action. The university researchers engage grad students in the process and get to publish articles, so they provide free expertise.

Three. The approach is broadened to an overall health approach. The ASCD self-assessment tool could be used to assess program capacity. The PHAC Voices & Choices program could be used to survey students. Both of these instruments are on-line, have been tested for reliability and can provide comparative reports to schools on a confidential basis. The incentive for schools to participate would be far greater because it would cover all aspects of health, rather than just drugs, thereby reducing potential stigma for the school and broadening interest.

These three alternatives would offer a far better and more attractive option to schools The existing school assessments have had some success or the inter-agency assessment would be more manageable for staff at that level.

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The notion that a "caring school" as described in Standard 12 in the CCSA can alleviate addiction problems is alluring but may be problematic. It may be a weak cornerstone for the CCSA standards.

This desire to find a new way to connect students more firmly to their schools has been pursued by school dropout prevention experts for years and is currently now part of the mental health movement as well. However, the "safe & caring schools" movement is very cautious about placing too many eggs in this basket. Researchers in PREVNET have questioned this social climate approach (Smith, J. D. , Schneider, B. H., Smith, P. K., & Ananiadou, K. (2004). The effectiveness of whole-school antibullying programs: A synthesis of evaluation research. School Psychology Review, 33 , 548-561). As well, recent research in mental health (Herman et al, 2008, )is suggesting depression in Grade Seven students can be predicted as early as Grade One, when students first begin to experience academic problems in school. A recent study done in France(Didier et al, in press) correlated and weighted the factors that affect student perceptions of the social climate in their schools. Teacher behaviours accounted for 7% of the variation and school type/organization affected 1%. The vast majority of the influence on student perceptions was due to social determinants that are structural in nature and embedded in the social roles played by schools. Also, the early results a somewhat disappointing but very credible study of the "good and healthy school" in Germany (Paulus et al, in press) is showing null effect on student or parent perceptions of the school climate (but is having an effect on teacher perceptions)

Connecting troubled students more with their schools may be better achieved through different interventions than simply whole school climate approaches.(eg mentoring, peer helper, counselling, tareget after school programs..

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Given that education is provinically mandated it is not clear why national standards have been developed as many health departments already have existing substance abuse prevention initiatives, some already connected to schools and school boards that may be functioning well already.

These guidelines are quite elaborate and require extensive and intensive planning, even if implemented through a team. Schools already are limited by time contraints even with their own educational objectives and this "resource" is another time consuming exercise.

There are a lot of valuable insights and recommendations in this document, that may be able to be adopted into municipal and possibly school programs already in existence, but it is difficult to see these this guidelines being adopted in their complete form given the limitations and restrictions already mentioned.

Finally, many schools have wellness initiatives that may or may not be comprehensive but that fulfil many requirement for prevention on a number of mental and physical health related issues. Other schools that may not have specific initiatives may still have an abundance of activities ranging from sports and clubs to skill and asset building that could also be
considered health promotion activities. Why reinvent health promotion for
substance use with specific guidelines when schools have already done a good job offering some practical tool and activities already?

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Section D which explains the comprehensive approach (Standards 12-16) includes four types of "initiatives". These include a positive school climate (established by school policies and student-teacher relationships), classroom instruction, targeted activities (established by the school) within a comprehensive continuum and relevant policies. While these four things are good, they fail to capture the standard understanding of comprehensive approaches, coordinated SH programs and whole school strategies used in most statements and definitions of school health promotion. (References to health services (early identification, referral, preventive, treatment coordinated with IEP's for individual students, reintegration etc) and physical environment (safe places in schools, lighting, security measures etc).
The essential part of a comprehensive, coordinated or whole school approach is that there are multiple, coordinated interventions delivered by several agencies within or in cooperation with the school. The CCSA standards document should list all of the possible interventions clearly and then describe how they can be developed, implemented and coordinated. The current draft contains only a partial list.

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This is so focussed on drugs it could be broadened...although maybe you are attempting to only address those issues...

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Despite its claims to the contrary, the document places almost the entire burden of prevention on educators, indeed, it places that burden on the front line of educators, those who work in local schools. I went through the document with this in mind and found over 70 references to "schools, over 25 references to "teachers/staff", over 10 references to school administrators. However, I found only 4 references to community agencies. I found no references whatsoever about public health nurses, no references whatsoever to addictions agency workers, no references whatsoever to social workers, no references to police officers, no references to health authorities, no references to municipalities, no references to addictions or mental health agencies and clinic policies/procedures/practices .

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