DOES NEW ZEALAND CANNABIS POLICY NEED DUTCH COURAGE?

INTRODUCTION

In a recent issue of the Social Policy Journal of New Zealand, Sally Abel and Sally Casswell backgrounded the development of cannabis policy in New Zealand, identified options for modifying the current prohibitionist approach, and speculated on the likelihood of future cannabis law reform (Abel and Casswell 1998). They detected a number of tensions, particularly the perceived impact of neo-liberalism in supporting moves to increase availability of the licit drug alcohol, commenting: "It is possible that the alcohol industry has considerable influence over how it positions itself in the market vis-a-vis other drugs, such as cannabis" (p.80). The researchers also pointed to a lack of strong community support, and a lack of political will to engage in cannabis law reform, as supporting the status quo. Were this constellation of factors to change, however, Abel and Casswell argued, economic incentives to cultivate and distribute cannabis should be reduced, which suggests to them a need to consider a more liberal policy than the "prohibition with civil penalties" models that are being pursued in Australia.

The Netherlands is typically cited as having the most liberal cannabis policy of any country in the world, making it a lightning rod for enthusiastic praise or damning criticism, depending on the commentator's ideological starting point. As some observers have remarked, however, "a closer examination suggests that the actual Dutch policies are considerably more nuanced and the results more ambiguous than is generally understood" (MacCoun and Reuter 1997: 48). This paper describes and analyses the Dutch approach to cannabis, in order to better contextualise any future debate about adopting or adapting a Dutch style "decriminalisation" model in New Zealand. It draws upon field research and key informant interviews in Amsterdam, Rotterdam, Utrecht and The Hague, which were conducted in November and December 1998. The paper concludes by discussing the relevance of the Dutch model to New Zealand.

THE DUTCH APPROACH TO CANNABIS CONTROL

The Dutch approach to cannabis has often been associated with the words "pragmatism", "tolerance" and "normalisation". At a recent international symposium on regulating cannabis, however, one Dutch researcher encouraged participants to "conceive it as a mixture of benign neglect and haphazard punishment" (Jansen 1998). Variously portrayed as an enlightened system of regulated tolerance or a doomed experiment in calculated indifference, the so-called "Dutch model" has been in place for over twenty years. In that time, its core features have remained basically unchanged (for overviews, see van de Wijngaart 1988, 1990, 1991, Reuter 1988, Engelsman 1989, Leuw 1991, Leuw and Marshall 1994; refer also to the helpful bibliography on cannabis regulation that is provided by Nadelmann et al. 1999).

What is "the Dutch Model"?

In many respects, Dutch drug policy is indistinguishable from those of other countries. As a party to the three major United Nations drug control conventions, the Netherlands has taken steps to control illicit drug trafficking and to create penal offences under its domestic law for unauthorised possession of illicit drugs. Specifically in relation to cannabis, there is strict enforcement of the law relating to drug traffickers and people who possess and/or attempt to grow large amounts of cannabis for commercial supply. During the ten-year period between 1986 and 1995, for example, Dutch interdiction efforts accounted for an average of 30 per cent of all cannabis seized by European Union (EU) countries, reaching a peak of 46 per cent of all EU seizures - a staggering 332 tonnes of cannabis - during 1995 (EMCDDA 1997: 35).

The distinctive aspects of Dutch drug policy are based upon its differentiation of drug-related risks. This approach followed the recommendations of a Working Group on Narcotics Drugs - the Baan Committee - whose 1972 report concluded that policies should be based on the relative risk involved in drug use, noting the inherent harmfulness of the drug itself, but also taking into account the social background of the user, the circumstances in which the use occurs, and the motivations for and expectations of using the drug. The Baan Committee's review of the medical, pharmacological and socio-psychological data on different types of drug use, which were then ranked according to a risk scale, formed the basis of revisions to the Dutch Opium Act in 1976. The new Act distinguished between "drugs which present an unacceptable risk" ("hard drugs" such as heroin, cocaine, LSD, amphetamines and cannabis oil) and hemp products (the "soft drugs" hashish and marijuana), with less severe penalties for offences involving soft drugs. The Act also sought to distinguish between drug users and drug traffickers, with stricter penalties for offences where drugs were possessed for commercial purposes than for offences involving drug possession for personal use.

One of the most important goals of this differentiation was to try and separate the market for hard drugs from the market for soft drugs, so that people who wish to buy soft drugs are not forced into the illicit world of the black market where hard drugs are sold, thus lessening the risk of drug use "graduation" (see Leuw 1994). Also behind this bifurcation policy was a belief in the criminal law's inability to deter drug use (Reuter 1987). Pessimism about the law's prospects of deterring drug use was balanced by cautious optimism about the possibility of integrating drug users within Dutch society, and reaching them with prevention and treatment initiatives. As the Baan Committee's report stated (1972: 68, 66): "[While] a penal law approach to drug users is inadequate ... socially integrated use of drugs may be possible ... This does not mean that no risks are involved, but that those risks could be acceptable".

The lever which allows Dutch authorities to pursue this stated aim of social integration is the expediency principle which exists in the Dutch penal code, combined with the central role of the Public Prosecutor within the Dutch criminal justice process (which van Dijk [1983] colourfully terms the "spider in the web"). The expediency principle allows the Public Prosecutor to refrain from prosecuting certain types of offences if judged to be in the public interest. Consequently, the actual mechanics of "the Dutch model" are not found in the Opium Act itself, but in policy guidelines for the investigation and prosecution of Opium Act offences that are issued by the Office of Public Prosecutors. These guidelines, the most recent of which were issued in October 1996 (College van Procureurs-Generaal 1996), effectively bridge the gap between "law-on-the-books" and "law-in-action" which is such a striking feature of the Dutch model (Silvis 1994). The guidelines provide a practical synthesis of the legal provisions of the Opium Act and the normative provisions of the government's drug policy, as spelt out in its 1995 White Paper, Drugs Policy in the Netherlands: Continuity and Change (Ministry of Foreign Affairs et al. 1995; for useful summaries of this document, see Cramer 1997, Trimbos Institute 1997; for a critical view, refer to Maris 1996a, 1996b). The net effect is unlikely to fully satisfy either legal positivists or legal realists, but it does offer a benchmark for national consistency in the application of police and prosecutorial discretion vis-a-vis cannabis offences.

Investigation and Prosecution of Drug Offences

Broadly speaking, Dutch criminal justice, penal and policing policy have been designed, as far as possible, to avoid social exclusion and stigmatisation of drug users, and to encourage instead their social integration and normalisation (e.g. Downes 1982, 1988). One of the practical implications of this design has been the deliberate development of "free zones" where open trade in and use of drugs is allowed to occur without police intervention, provided that such drug-related activities do not cause a public nuisance. (Of course, equivalent free zones are known to exist in a number of countries, especially in large cities like Hamburg, however not all are officially sanctioned and many simply develop by default and are then tolerated by authorities.) This is a radically different role than is usually attributed to law enforcement interventions in a culture where "tough on drugs" rhetoric predominates. However, it fits with the ideology of the Dutch liberal state, the founder of which, J.R. Thorbecke, once announced: "we wish a police force that is seen as little as possible and about which as little as possible is said" (quoted in Punch 1983: 14).

One of the "prices" to be paid for accepting such free zones is the visibility of an open drug-using scene in parts of downtown Amsterdam and some other Dutch cities. According to a key Ministry of Justice official:

    Normally, people using drugs are left undisturbed by patrolling policemen.
    The policing of the retail (street) market in the Amsterdam free zone is
    somewhat less tolerant. If the policemen on patrol bump into a street
    dealer of hard drugs involved in transactions they will probably arrest
    him. On the other hand, if they spot, some 50 yards ahead, a typical
    volatile gathering of junkies where drug transactions can easily be
    expected to take place, foot patrolling policemen will usually not
    increase their pace. The crowd will respond to the approaching law,
    however, by calmly dispersing in different directions, away from the
    policemen. (Leuw 1995: 43)

In cases where the police decide to investigate and prosecute people for cannabis offences, a penalty tariff is set out in the detailed guidelines issued by the Office of Public Prosecutors (see Table 1).

Table 1 Dutch Prosecution Guidelines for Penalties Involving Cannabis Offences

Amount of cannabis   Penalty imposed

Possession/Supply

< 5 gms              Confiscation by police; no charges brought
5 gms to 30 gms      Fine of NLG $50 to NLG $150
30 gms to 100 gms    Fine of NLG $5 to NLG $10 per gm (with an
                      option of settling out of Court)
1 kg to 5 kgs        Fine of NLG $5,000 to NLG $10,000 and/or 2
                      weeks imprisonment per kg
5 kgs to 25 kgs      3 to 6 months imprisonment plus maximum NLG
                      $25,000 fine
25 kgs to 100 kgs    6 to 12 months imprisonment plus maximum NLG
                      $25,000 fine
> 100 kgs            1 to 2 years imprisonment plus maximum NLG
                      $25,000 fine

Cultivation

< 5 plants           Confiscation by police; no charges brought
5 to 10 plants       Fine of NLG $50 per plant
10 to 100 plants     Fine of NLG $125 and/or half a day imprisonment
                      per plant
100 to 1000 plants   2 to 6 months imprisonment plus maximum NLG
                      $25,000 fine
> 1000 plants        6 months to 2 years imprisonment plus maximum
                      NLG $25,000 fine

(Source: College van Procureurs-Generaal 1996: Appendix B).

Penalties are subject to a number of multiplier factors. For example, if a person repeats the same offence within five years, the Public Prosecutor is instructed to demand a penalty 25 per cent higher, providing that the maximum has not already been reached. Similarly, where cannabis is sold to a person belonging to a vulnerable group (such as a minor or a person with a mental illness), the Public Prosecutor is instructed to demand a higher penalty of at least NLG $750. Higher penalties are also demanded in cases involving a commercial operation or where there are signs that the offender has been trading for a long period of time.

HASH COFFEE SHOPS

Perhaps the most (in)famous feature of the Dutch model is the tolerance of hash coffee shops. The term "coffee shop" is convenient shorthand to describe cafe-like establishments where cannabis is lawfully sold.

National policy on coffee shops is once again set out in the 1996 Office of Public Prosecutors guidelines. The guidelines stipulate that criminal proceedings will not normally be instituted against coffee shop owners provided that the following five criteria are met: no posters or advertising; no hard drugs on the premises; no public nuisance (such as road traffic congestion outside the venue, excessive noise, litter or loitering); no sales or admission to young people (under 18); and no sales larger than needed for personal consumption (defined as more than 5 grams per transaction per person). The guidelines also prohibit coffee shops from keeping more than 500 grams of cannabis products on the premises as stock-in-trade.

Local policy on coffee shops is a matter for municipal authorities, on the basis of a tripartite consultation exercise between the local mayor (burgemeester), local Public Prosecutor and local Chief of Police. Some municipalities have used this power to ban any coffee shops from opening in their communities, or to prevent them from opening in certain locations - such as opposite schools or psychiatric facilities. A recent trend has been towards issuing special operating licenses for coffee shops which can be tailored with covenants that apply to each location - such as "no parking in front of the entrance", or "closing time at 10:30 pm each night". For instance, new municipal guidelines promulgated in Rotterdam during 1997 now make it compulsory for coffee shop owners to apply for special one-year licenses covering their operations. These licenses set special conditions over and above the national guidelines, like banning the sale of alcohol products to discourage polydrug use (Blom and Khan 1999: 217-219).

How Many Coffee Shops are There?

From only a handful at the start of 1980, coffee shops in the Netherlands proliferated dramatically. According to police estimates, the number of coffee shops rose to between 1200 and 1500 in 1991 (Trimbos Institute 1997). Using location game theory, Jansen (1991) offers an interesting analysis of the geography of hash coffee shops in Amsterdam during this period. Whereas the first coffee shops were typically situated in unattractive buildings in backstreets, newer outlets were established near the Central Train Station and foot-traffic routes used by tourists, as well as clusters forming in prominent entertainment centres like Rembrantplein, Leidseplein and Nieuwmarkt.

Concern about the level of nuisance associated with some coffee shops, and a sense that allowing too many outlets would create perverse incentives for coffee shop owners to turn to illicit means to generate market share, particularly in Amsterdam, led to a clampdown on the number of coffee shops during the mid-1990s. Current Ministry of Justice estimates place the number of coffee shops at between 1000 and 1100, with a further reduction planned to bring the number down to around 800 nationally (Mulder 1998).

How do Coffee Shops Work in Practice?

Hash coffee shop opening hours vary according to establishment and local licensing conditions, although typically outlets will open from 10 am to midnight, Monday to Sunday. The cannabis offered for sale is either locally-grown Nederwiet or imported varieties from countries such as Morocco or Turkey. It is estimated that Dutch cannabis makes up about half of total coffee shop sales (Ministry of Foreign Affairs et al. 1995), and a number of coffee shop customers spoken to indicated a preference for "homegrown".

The cannabis itself can be purchased in raw form up to the maximum allowance of 5 grams per transaction, although it is more often sold in pre-packaged amounts worth NLG $10 or $25, roughly equivalent to 1 or 2.5 grams of plant material (Jansen 1991). Single, pre-rolled "joints" can also be bought in most coffee shops, although these tend to be more designed for foreign tourists than for Dutch nationals. Most transactions take place at a separate space within the venue, not unlike a ticket booth, where the customer makes a product selection from a glass case of different types of marijuana, hashish or Nederwiet. Prices are normally listed on a separate menu. As an illicit drug, cannabis itself is not subject to taxation, however the income generated by coffee shop sales is taxed by the state in the normal way.

While coffee shops are permitted to sell cannabis at the front door, they are still prohibited from being supplied with cannabis at the back door. This so-called "back door problem" complicates life for coffee shop owners, who regularly need to run the gauntlet of possible prosecution in order to keep their premises stocked with cannabis product. The Dutch government has suggested that the way to reconcile this problem is that coffee shops should be supplied with homegrown cannabis (under the Opium Act policy guidelines, people may grow a small number of plants without prosecution). In practice, most coffee shop proprietors source larger amounts of cannabis product from trusted "commercial" suppliers.

Fairly typical are the experiences of Rashida Khellaf, owner of the Coffeeshop 't Ballonnetje in Amsterdam (Khellaf 1998). Approximately 80 per cent of her profits come from the retailing of cannabis products, with the remaining 20 per cent coming from the sale of food and beverages. A 100 per cent mark-up on cannabis products is standard. Because of the legal risks involved, Rashida does not purchase more than 1 to 2 kgs of cannabis product at any one time, and these stockpiles are kept at various locations around the city (friends' houses, storage facilities, etc.) so as not to breach the threshold of 500 grams which is allowed to be kept on the premises at any one time. Rashida has four or five regular suppliers, and has never been followed by undercover police to discover their identity. During her seven years as a coffee shop owner, Rashida reports few public nuisance problems involving her cafe indeed, a first-time visitor to her coffee shop may be surprised to see that it is located less than 100 meters from a primary school. Police surveillance of the premises is minimal, usually a glance in the window during routine foot patrols, nor has the shop been subject to a random search. Twice-yearly inspections are conducted by the local authority to check for compliance with storage requirements and advertising restrictions, but controlled purchase operations are not used to test whether cannabis is being offered for sale to underage patrons.

Who Goes to Coffee Shops?

The customers who visit coffee shops appear to represent a fairly broad cross-section of Dutch society. In a non-randomised study of regular coffee shop visitors reported by Maalste (1997), the large majority of her sample (n = 167) were men (84%), ranging between 15 and 50 years old, although half were under 23. Most were ethnic Dutch (86%). Interestingly, over a quarter of the sample group had a university or professional education, and the most commonly reported occupation of the respondents was student (44%). A third of the sample were employed (31%) while an eighth of the sample were unemployed (13%).

The coffee shops away from the popular pedestrian routes favoured by tourists will usually have a regular client base. Coffee shop managers who were spoken to indicated that most Dutch people who purchase cannabis do not stay in the outlets to "smoke up", but rather take it away for use at home or at friends' houses. It was commented that the policy of allowing a maximum purchase of 5 grams is helpful in this regard, because people tend to buy only what they need, knowing that they can always purchase more if they want to. This was compared with buying in bulk in an illicit environment (because of economies of scale and wanting to avoid the risk of legal consequences from numerous, small, repeat purchases) and therefore having more on hand to smoke to the point of intoxication, if this is what customers chose to do.

A comparison was also drawn by some coffee shop managers with the consumption patterns of many foreign tourists, who typically sit in coffee shops and smoke with the intention of becoming intoxicated. There was a suggestion that foreigners are more accustomed to smoking cannabis to become "stoned", rather than what was seen as the Dutch characteristic of smoking cannabis for primarily social reasons. (Note, however, this may simply be an expression of attribution biases that often bedevil drug policy studies: see Hadorn 1996.) In any event, the limit of 5 grams per transaction is quite sizeable, when one considers that few users report consuming more than 10 grams per month (refer to Cohen and Sas 1997).

The Normalisation of Coffee Shops

Coffee shops designed to attract tourists, for instance around Amsterdam Central Station, often have painted windows, garish neon signs and seem to be appealing to the Rastafarian image of a "dope house". Such outlets are not representative of what the majority of coffee shops look like. Away from such heavily touristed areas, coffee shops are more integrated into their local neighbourhoods and usually blend in.

In addition to the movement of coffee shops from back streets and "red light" districts to more open public retail spaces, a striking feature of the coffee shops visited is the extent to which the trade in cannabis is normalised within the cafes. Hash coffee shops are not the imaginings of popular prejudice: dimly lit, smoke-filled affairs populated with glassy-eyed patrons who sit blankly listening to psychedelic or reggae music. Far from it, there is little which distinguishes most coffee shops to any other cafe or bar, save for the tell-tale green cannabis leaf license form which will be placed discreetly in the venue's window or door.

Almost all of the dozen coffee shops visited during the study tour were energetic places filled with conversation, diverse music (ranging from drum 'n bass to jazz), and diverse customers (young and old, male and female, Dutch and foreigners). In some coffee shops, patrons played chess or draughts, read newspapers, played pinball, or simply chatted. In other words, the sort of things you might expect to see in any cafe, but with one key difference: at a designated place in each venue, legal commerce in an illicit drug was openly taking place. For anyone who has lived all their life in a country which practices legal intolerance of such drug use, seeing it take place so matter-of-factly can be profoundly disconcerting.

This normalisation of hash coffee shops within Dutch society extends to the legitimacy of the position of the coffee shop owner. Initially there were indications that many of the hash coffee shops set up during the 1980s were being operated by former street-level drug dealers (see Jansen 1991). Over time, as less reputable businesses were shut down, and the Dutch policy of regulated tolerance has bedded in, the role of coffee shop proprietor has turned from being something to be sheepishly admitted into one increasingly viewed as little different from any other small business owner. For the last five years, in fact, Dutch coffee shop owners have had their own nationwide representative body, the Union of Cannabis Retailers, which collectively advocates on their behalf in central government and municipal policy forums.

For example, one of the most pressing issues which the Union is currently working on is the discrimination that coffee shop owners say they face from banks involved in United States financial markets, which refuse to handle the proceeds of their drug-related businesses for fear of breaching anti-money-laundering legislation. The Union has appealed to the Dutch Finance Minister to impose a value-added tax on cannabis products, thereby bringing their businesses wholly within the formal taxation system, and in turn hopefully forcing banks to let them operate ordinary business accounts. As one coffee shop owner recently lamented, without a trace of irony, "now we are walking with all our money to the post office, that's the only bank who will work with us, and everybody has to transport his money over the street, and obviously there are a lot of criminals who can see when and where, so it's actually very dangerous" (Silver 1998). This anecdote illustrates the extent to which Dutch coffee shops owners have been redefined from criminals themselves, albeit officially tolerated ones, into legitimate members of the petit bourgeoisie.

IS THE DUTCH MODEL SUCCESSFUL?

Is the Dutch model a success? Inevitably, this depends upon blow one chooses to measure success. In terms of its own stated objectives, most analysts agree that the Dutch policy has been broadly successful. (For even-handed syntheses of the research evidence, see Korf 1995, Zimmer and Morgan 1997:49-56.)

To recap, Dutch cannabis policy aims to: separate the soft drug and hard drug markets, so as to minimise the risk of "graduation" between the two; prevent drug users being stigmatised and excluded from society; and not punish drug users, but integrate them into society and help them when they experience problems.

In relation to the bifurcation of the markets for (and cultures of) soft and hard drug use, the best evidence comes from population-based surveys conducted in Amsterdam over a ten-year period (see Cohen 1998).

Cohen and Sas (1997a) found that, of people aged 12 and over who have lifetime experience with cannabis, only 22 per cent will try cocaine -- the second most popular illicit drug in Amsterdam -- at least once in their lives. Put another way, over three-quarters of "ever cannabis users" will never try cocaine. While this may still seem high, Cohen and Sas (1997b) point out that most cocaine use is typically floating and experimental: only two per cent of lifetime cannabis users will become once-a-month cocaine users; moreover, experimentation with heroin amongst lifetime cannabis users is almost completely unheard of.

Using the metric of harm minimisation, there is other good evidence to suggest that the soft and hard drug markets are effectively segregated in the Netherlands, with a consequent reduction in drug-related harm. For instance, Dutch rates of opioid dependence and heroin overdose deaths have remained some of the lowest in the EU during the period of the de facto decriminalisation of cannabis, while at the same time the average age of heroin addicts has slowly risen, indicating an ageing addict population (EMCDDA 1999). Narrowly measured in terms of presentations to drug treatment agencies for cannabis-related problems, the Medical Consultation Bureau for Alcohol and Drug Problems reports that only three per cent of its total client intake present with cannabis abuse or dependence problems, as compared with around ten per cent of clients who require treatment for gambling disorders (Leuw 1995: 47). This is consistent with the findings by Cohen and Sas (1997a) that the norm for cannabis users was a tendency towards low use or abstinence over a drug-taking "career". From an average age of first cannabis use of 20 years, and during an average ten years of cannabis use, 65 per cent of respondents reported becoming either abstinent or using less than 2.5 grams of cannabis per month. In other words, their cannabis use became self-limited.

Similar success is evident in relation to the stated goal of non-punishment of drug users, with hoped-for payoffs in terms of social integration of drug users within Dutch society. According to Cohen (1997b), cannabis use has almost become "normalised" in Dutch cities in the sense that it is more or less culturally accepted, and certainly no longer taboo. More formally, large numbers of Dutch people are not being prosecuted for minor cannabis offences, are not incurring criminal records, and are thus not suffering the socio-economic impacts associated with criminal records or contact with the Court system. Costly police and Court time is not taken up with such proceedings either, and is therefore available for other priorities.

In 1995, for example, a total of 4,228 people were convicted of a drug offence under the Opium Act 1976 (Trimbos Institute 1998). A mere 706 cases involving soft drugs were taken to trial before Dutch Magistrates. A further 1,305 cases involving soft drugs were settled by Public Prosecutors without the need for formal Court proceedings (Trimbos Institute 1997a). When expressed relative to a total Dutch population of nearly 16 million people, these are quite remarkable statistics. By way of comparison, in New Zealand during the same period, with a population of 3.6 million people, 12,225 cannabis offences were resolved by prosecution, resulting in 5,389 sentences for either possession/use of cannabis (2,927) or cannabis dealing (2,462) (see New Zealand Parliamentary Debates, 23 July 1998:68-70).

Criticisms of the Dutch Model

While the discussion above should suffice to discount the "stepping stone" arguments that have been voiced against Dutch cannabis policy, it is worthwhile to briefly address two other criticisms that are commonly advanced. These are versions of the well known "floodgates" and "slippery slope" arguments.

The "floodgates" argument holds that liberalisation of Dutch policy on coffee shops has led to increasing prevalence of cannabis use in the general population and, most worryingly of all, amongst young people. Prevalence figures have increased for both groups during the 1990s, mirroring increases across the EU (EMCDDA 1999) and in many other countries, which suggests that wider influences are at play. It would certainly be a leap of faith to attribute this trend within the Netherlands solely or primarily to the coffee shop policy. Comparative studies reveal that cannabis is no more difficult to obtain in, say, the United States than it is in the Netherlands. For example, a 1996 survey found that almost half (42%) of the American teenagers surveyed find marijuana easier to buy than beer or cigarettes (CASA 1996). The key difference is the formal openness with which cannabis is made available -- not the fact of availability itself.

The impact of Dutch policy on cannabis use rates is moot. Reinarman (1997: 145) concludes that the "existing evidence suggests that either there is no relationship between drug policy and drug consumption or that the Dutch policy actually holds down cannabis use by removing the allure of forbidden fruit". Cohen (1997b: 88) argues for the former view: "we should be prepared to accept the notion that drug control policy in the Netherlands is of limited influence on drug use prevalence". Ultimately, as Lee (1996: 8) notes, "As far as the consequences of Dutch policy on cannabis use are concerned, the jury is still out".

This ambivalence of Dutch policy-outcome linkages can also be read into the impressive Dutch cannabis seizure levels that were cited earlier. (Between 1986 and 1995, Dutch interdiction efforts accounted for an average of 30 per cent of all cannabis seized by EU countries.) It may be that these high seizure levels are the result of Dutch law enforcement officers being able to focus on large-scale drug trafficking rather than small-time users and growers. The Netherlands is a major trading centre within Europe, which might be expected to result in drug traffickers attempting to move proportionately more cannabis through the country. Or it may be that the state-sanctioned "regular" demand for cannabis through coffee shops creates a market opportunity to supply that demand, encouraging commercial cannabis growers to cultivate large indoor crops, and hence yield bigger seizures when they are detected. According to Jansen (1998), there is a "green avalanche" in Holland, not only in relation to exporting cannabis to effectively borderless countries in the EU, but exporting the means of production for cannabis cultivation such as lamps, hydroponics technology, seeds and fertiliser. The validity of this claim is unclear, but it again illustrates how ambiguous even apparently "positive" indicators of the success of Dutch drug policy can be.

Turning to "slippery slope" arguments against the Dutch model, these proceed that liberalising laws relating to soft drugs like cannabis will lead, inexorably, to liberalisation of laws relating to harder drugs. Such slippery slope arguments often surface when morally contested social policy change is suggested (see, generally, Shauer 1985, Williams 1985, van der Burg 1991, Freedman 1992). In the case of decriminalising cannabis, the concern is that it will not be possible to resist calls to progressively loosen the enforcement regime for all drugs, thus leading to the permissive society nightmare of a narco-etat.

This type of argument can only be considered persuasive if it makes sense at a logical or empirical level. At a logical level, there are at least two obvious flaws in using slippery slope arguments against changing the law enforcement regime around cannabis. Such arguments must first provide evidence that it is the change in legal status or law enforcement praxis which creates the slippery slope to begin with, as some sort of necessary and sufficient condition for any liberalisation of hard drug laws. It is possible to think of a number of other factors -- popular social movements, new research findings, advocacy by experts, etc. -- that might instead create the incline towards such liberalisation. Secondly, slippery slope arguments must be able to show that the slope is more slippery in jurisdictions that have liberalised their approaches than those that have not. Again, it is at least conceivable that removing the "anomaly" value of cannabis from the dichotomy between illegal and legal (but nonetheless harmful) drugs, might actually serve to strengthen the legitimacy of the division, and thus make future liberalisation of hard drug laws less likely. Overall, the published literature pays scant attention to such logical "proofs" of causation and comparability.

At an empirical level, also, the available evidence is that Dutch opposition to loosening the enforcement of hard drug laws has remained stable over time. While the possession of single doses (defined as less than 0.5 grams) of heroin, cocaine and synthetic drugs are not routinely prosecuted under the policy guidelines issued by the Office of Public Prosecutors, possession of "commercial" quantities and selling hard drugs continue to be strictly policed. There has been no official movement towards allowing hard drugs to be sold through existing coffee shops, or to allow the development of a parallel infrastructure of outlets where hard drugs can be purchased. While some Dutch addiction specialists have begun to question whether hard drugs should be "legalised" in the same way as soft drugs have (e.g. Garretsen et al. 1996), the Dutch Government firmly ruled this out in a recent White Paper (Ministry of Foreign Affairs et al. 1995).

Per contra slippery slope arguments, there are a range of factors which constrain further development of drug policy in the Netherlands, such as its responsibilities under the Schengen Agreement to harmonise Dutch drug laws with the Benelux nations and other EU countries (see Dorn et al. 1996, Dorn 1998, Lemmens and Garretsen 1998). Given its international treaty obligations, its position as a major trade centre within the region, its contiguous borders with several countries and the increasing mobility of people in the EU, the Dutch government recognises that any debate about formally legalising cannabis must be pursued in a European framework (Ministry of Foreign Affairs et al. 1995).

As admitted privately by some senior Dutch officials, there is also a sense in which the Netherlands has spent too long in a reactive mode, having to defend the central tenets of its drug policy to both domestic and international audiences. A great deal of energy has been spent fighting against forces that would have the Dutch roll back their liberal model, notably French President Jacques Chirac and, more recently, the United States Drug Czar, General Barry McCaffrey. This may have contributed to a lack of policy innovation in recent years, as important bureaucratic resources have been tied up in efforts to "hold the line", instead of mobilising networks to push forward the boundaries of new harmminimisation initiatives.

It is also possible that its twenty-year tradition of "leading the world in drug policy" has led to complacency, or arrogance even, which assumes that the current Dutch approach represents best practice in every area of drug-related effort. This may be one reason for what appears to be the Dutch failure to keep up with certain cutting-edge developments in other countries, such as the assessment and management of people with co-existing substance use and mental health disorders (see Beeltje et al. 1998; compare Todd et al. 1999). The development of addiction services as an autonomous specialty in the Dutch health sector has meant that the linkages with mental health services do not appear to have been fully explored. Neither is the Netherlands immune from the problem of innovation within the drug treatment field being hampered by professional rivalries between different centres (e.g. Rotterdam versus Amsterdam), which in turn can lead to a reluctance to share experiences or work together on joint projects.

Overall, analyses of the prospects for formal legalisation of drug use in the Netherlands have identified the marginal utility of such a move in the current environment, and predict that any policy shift is some way off. Notably, van Dijk (1998) has attempted to tabulate the pros and cons of present Dutch policy versus a legalisation scenario. Intriguingly, the unweighted aggregate scores only slightly favour legalisation (see Table 2):

Table 2 Pros and Cons of Current Dutch Drug Policy Versus a Legalisation Scenario

Measure                                Current drug policy

Prevalence of drug addicts             low (+)
Drug-related disease/mortality rate    low (+)
Prevalence of cannabis use             no effect? (o)
Drug-related crime                     no effect (o)
Organised crime                        high (-)
Nuisance                               high (-)
International relations                negative effect (-)
Costs of health care                   high (-)
Costs of law enforcement               low (+)
Tax income on coffee shops             unknown (+)

TOTAL                                  ++++/oo/----

Measure                                Legalisation

Prevalence of drug addicts             higher (-)
Drug-related disease/mortality rate    lower (+)
Prevalence of cannabis use             no effect (o)
Drug-related crime                     lower (+)
Organised crime                        lower (+)
Nuisance                               "magnet effect" (-)
International relations                negative effect (-)
Costs of health care                   no effect (o)
Costs of law enforcement               lower (+)
Tax income on coffee shops             higher (+)

TOTAL                                  +++++/oo/---

(Source: adapted from van Dijk 1998: Tables V and VI)

HOW RELEVANT IS THE DUTCH MODEL TO NEW ZEALAND?

The Dutch model is not perfect; indeed, it contains inherent tensions such as the "backdoor problem" which are difficult to rationalise away. It is often the case that in attempting to solve one problem, policymakers create new problems, or resuscitate old problems that become expressed in new ways. Dutch officials are quick to point out that no country can claim its drug policy is completely successful:

   We continue to find new problems and try to tackle these to the best of our
   ability. But when we look at the results of our policy and compare them
   with those of other countries, we can say that we have succeeded in
   managing the drugs problem reasonably well. We have done so by approaching
   the drugs problem from the Dutch angle and in a way understood by the Dutch
   population. (Keizer 1996: 3)

This quotation introduces the importance of seeing Dutch drug policy in its specific context. According to the former Head of the Drugs Branch at the Dutch Ministry of Health, Welfare and Cultural Affairs: "Dutch measures for controlling drug problems can only be understood in the context of history and culture combined with the policy of social security based on solidarity" (Engelsman 1989:211). He continues: "Dutch people favour a policy of encirclement, adaptation and integration.... Drug legislation remains supplementary to the (informal) social control which has for centuries been established on traditionally tight family structures conforming with a Calvinistic life-style" (p.212). This resonates with the observation reported earlier about the social unacceptability of smoking cannabis to the point of intoxication -- a behaviour seen as more characteristic of foreign tourists -- which may be a reflection of the Calvinist influences in Dutch society. As Dutch researchers have reported, public displays of cannabis use, such as walking down a street smoking a "spliff", are frowned upon by the majority of Dutch people: "this is indicative of the control system of internal rules that operates in the Netherlands, where the consumption of cannabis is regulated by social norms rather than explicit rules" (Boekhout van Solinge 1998).

It is unclear whether the same is true of New Zealand society, or what social norms around cannabis use would develop if New Zealand adopted or adapted a Dutch-style "decriminalisation" model.

There are important differences between the political economies of cannabis use in New Zealand and the Netherlands, and the political cultures that influence the way in which policy makers respond to the issue. For example, allowing market saturation of coffee shops to occur without recourse to the "visible hand" of central control, then stepping into the soft drug market as a quasi-regulator, leaves the Dutch government open to charges of operating a "trial and error" approach to cannabis. As one Dutch commentator wryly notes: "If you're looking for a system of muddling through, then you look for the history of hash coffee shops in the Netherlands" (Font 1998). While such a "hands off" approach may be consistent with Dutch values about the minimal state and, some would argue, is also broadly consistent with the ascendancy of neo-liberal ideas in New Zealand (see Abel and Casswell 1998), there is reason to doubt that such a "science of muddling through" on cannabis would be acceptable to New Zealand policy makers or publics.

As hinted at here, an even more important difference in political cultures (and constitutional arrangements) between the two countries, which would cause difficulties transferring the Dutch model, is the degree to which responsibility is devolved for law enforcement policy-making. Not only is there no equivalent "expediency principle" in New Zealand law, but the broad parameters of policy on the enforcement of cannabis laws is set by Police National Headquarters, rather than, say, by individual District Commanders. This offers a sharp contrast to the Dutch policing model, with its degree of sensitisation to the preferences of local communities, including the way cannabis offences are policed (Tjepkema 1984, Janin 1991). In the Netherlands, day-to-day policing policy has been the product of regular triangular consultations between the local mayor (burgemeester), the Public Prosecutor and Chief of Police. The Dutch Police Act 1993 makes this triangular consultation a statutory requirement (see Wintle 1996). Animated by the principle of decentralisation, codifying local consultation in this way is widely expected to encourage an even greater degree of community input into policing policy (Jones 1995). It is a key component of the Dutch model, and one that cannot be readily replicated in New Zealand at present.

Nonetheless, discretion in the application of cannabis laws is exercised at the level of the individual police officer in New Zealand, and there may even be unofficial enforcement policies at a local level. This is not the place to attempt a detailed examination of cannabis law enforcement in New Zealand or the likely trajectory of New Zealand cannabis policy. That task is taken up elsewhere (Webb 1999). But there is certainly much to be added to Abel and Casswell's (1998) assessment, based on the published version of the National Drug Policy (Ministry of Health 1998), work by Parliamentary select committees (Health Committee 1998, Justice and Law Reform Committee 1998), and recent indications that the current Government may consider decriminalisation of cannabis.

Present indications suggest that New Zealand may be moving towards a version of the cannabis expiation notice (CEN) scheme(1), which operates in South Australia. This is despite worrying evidence of net widening and concerns over the automatic prosecution of CEN defaulters, which suggest that the South Australian model may not be the optimal approach (see, further, Lenton et al. 1999). Nevertheless, the usual caveats about the politics of illicit drug policy should apply. The failure to achieve decriminalisation in jurisdictions like Canada, even after government promises to overhaul prohibitionist drug statutes in favour of new harm-reduction legislation (see Fischer 1997), should be instructive in this regard. Indeed, the annals of history are littered with examples of why prohibition has been described as "the political path of least resistance" (Hall 1997: 1114). But then, as Dorn (1998: 11) does well to remind us: "Drug policy is never purely about drugs; it is like water, running through channels and topography carved out by larger forces".

CONCLUSION

In reviewing the policy and practice of cannabis control in the Netherlands, this paper has called for caution in relying too heavily upon "the Dutch model" on either side of the evolving cannabis policy debate in New Zealand. It has been argued that the specific cultural, historical and political landscape which gave rise to and now sustains this approach to the soft drug market, does not allow the Dutch model to be used as a template which can be unproblematically transferred to a New Zealand setting. Just because a policy is seen to work in instrumental and value terms in one particular place at one particular time does not guarantee that it can be transplanted to another place at another point in time.

In many ways, the Dutch approach to cannabis policy is most useful in a New Zealand context for the voyeuristic opportunity it gives domestic policy makers to anticipate and examine issues which have emerged during the last two decades, since the shift in Dutch law and practice on cannabis offences. As the renowned French anthropologist Claude Levi-Strauss once remarked, "Obviously for moral and practical reasons, we cannot experiment with human societies; and even if we had the power to do so, it would take too much time. All we can do ... is go throughout the world in order to see ready-made experiments" (Levi-Strauss 1979: 18). In the case of Dutch cannabis policy, with its nuances and its somewhat equivocal outcomes, what the New Zealand drug policy analyst will see from this ready-made experiment of de facto decriminalisation depends very much on what he or she is looking to see. It is precisely this lack of unequivocal findings that allows "the Dutch model" to be freighted with either positive or negative meaning. Where policy sciences cannot provide simple answers, politics often will.

(1) Here, infringement notices -- rather like those for under-age drinking under the Sale of Liquor Act -- are issued for minor cannabis offences, and are "expiated" if the associated fine is paid within a certain time.

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Michael Webb Research Policy Department London School of Economics