BILL ANALYSIS                                                                                                                                                                                                    






                                 SENATE HEALTH
                               COMMITTEE ANALYSIS
                        Senator Elaine K. Alquist, Chair


          BILL NO:       AB 1858                                      
          A
          AUTHOR:        Blumenfield                                  
          B
          AMENDED:       June 10, 2010
          HEARING DATE:  June 30, 2010                                
          1
          CONSULTANT:                                                 
          8
          Orr                                                          
                     5
                                                                       
                     8                                        
                                  FOR VOTE ONLY

                                    SUBJECT
                                         
               Hypodermic needles and syringes: exchange services


                                     SUMMARY  

          This bill allows the California Department of Public Health  
          (CDPH) to authorize entities to provide hypodermic needle  
          and syringe exchange programs in any location where the  
          department determines conditions exist for the rapid spread  
          of deadly or disabling disease spread through the sharing  
          of unclean hypodermic needles and syringes.

                             CHANGES TO EXISTING LAW  

          Existing law:
          Requires that no person shall possess a hypodermic needle  
          or syringe except when acquired in accordance with  
          specified provisions of law.

          Authorizes a clean needle and syringe exchange program in  
          any city, county, or city and county upon action by the  
          county board of supervisors and the local health officer or  
          health commission as applicable, or action of the city  
          council, mayor and local health officer as applicable. The  
                                                         Continued---



          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          2


          

          programs shall be authorized using recommendations from the  
          United States Secretary of Health and Human Services,  
          subject to availability of funding, and shall be offered as  
          part of a comprehensive network of services.

          Allows local governments, public health officials, and law  
          enforcement agencies the opportunity to comment on clean  
          needle and syringe exchange programs on an annual basis to  
          address potential adverse impacts to the public.  

          Requires health officers of jurisdictions that participate  
          in clean needle and syringe exchange programs to annually  
          report the status of those programs and at an open meeting  
          of the board of supervisors or city council. 

          Allows counties to authorize pharmacists to furnish or sell  
          10 or fewer hypodermic needles or syringes to persons 18  
          years of age or older, for the period commencing January 1,  
          2005 and ending December 31, 2010, if the pharmacy is  
          registered for the Disease Prevention Demonstration Project  
          (DPDP) and if the pharmacy complies with other specified  
          provisions. 

          Stipulates that no public entity, its agents, or employees  
          will be subject to criminal prosecution for the  
          distribution of hypodermic needles or syringes to  
          participants in clean needle and syringe exchange projects  
          authorized by law.

          Finds and declares that needle exchange programs have been  
          shown to serve as a bridge to treatment and recovery from  
          drug abuse, curtail the spread of HIV infection through the  
          IDU population, and do not increase drug use.

          Establishes the DPDP as a collaboration between pharmacies  
          and local and state health officials, for the purpose of  
          evaluating the long-term desirability of allowing licensed  
          pharmacists to furnish or sell nonprescription hypodermic  
          needles or syringes to prevent the spread of blood-borne  
          pathogens, including HIV and hepatitis C. 
          
          As part of the DPDP, requires participating pharmacies to  
          register with their local health department, and certify  
          that they will provide written or verbal information on  
          drug treatment, testing services, and safe sharps disposal  




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          3


          

          practices at the point of sale.

          Allows a pharmacist or physician to furnish hypodermic  
          needles or syringes for human use without a prescription or  
          permit if the person is known to the furnisher and the  
          furnisher has been previously provided with a prescription  
          or proof of legitimate medical need.

          This bill:
          Authorizes CDPH to allow entities to apply for  
          authorization to provide hypodermic needles and syringe  
          exchange services in any location where the department  
          determines that conditions exist for the rapid spread of  
          HIV, viral hepatitis, or any other potentially deadly or  
          disabling infectious disease, spread through the sharing of  
          unclean hypodermic needles and syringes. 

          The department or other authorizing city and county,  
          county, or city with or without a health department must  
          authorize the needle or syringe exchange services in  
          consultation with CDPH, as recommended by the US Public  
          Health Service and consistent with state and federal  
          standards. The entity must have sufficient staff and  
          capacity to provide such services. The provision of  
          services is subject to the availability of funding. 

          Allows participants in the newly authorized syringe  
          exchange programs to lawfully possess 10 or fewer  
          hypodermic needles or syringes, if acquired from an  
          authorized source, until December 31, 2010. 

          Requires CDPH to establish and maintain the addresses and  
          contact information of programs providing services pursuant  
          to this section on its website.

          Provides that staff and volunteers participating in  
          exchange projects authorized by the state shall not be  
          subject to criminal prosecution for violation of any law  
          related to the possession, furnishing, or transfer of  
          hypodermic needles in an exchange project. 

          Changes the frequency with which local governments, public  
          health officials, law enforcement agencies, and the public  
          may comment on clean needle and syringe exchange programs  
          from once per year to once every two years. Also changes  




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          4


          

          the requirement for local health officials to report to the  
          board of supervisors or city council on the status of such  
          programs from once per year to once every two years.   
          Requires CDPH to provide biennial reports to local health  
          officers in jurisdictions where CDPH has authorized needle  
          exchange services.

          Replaces a reference to recommendations by the US Secretary  
          of Health and Human Services, with the US Public Health  
          Service.

                                  FISCAL IMPACT  

          According to the Assembly Appropriations Committee  
          analysis, AB 1858 would result in  Annual General Fund  
          costs to CDPH of $30,000 to $40,000 in 2011 through 2013 to  
          comply with requirements of this bill. 
             Ongoing, likely absorbable costs for CDPH to continue  
             oversight of needle exchange projects after 2013. 
             Unknown, but potentially significant savings to the  
             extent this bill reduces medical costs associated with  
             infectious diseases such as HIV and hepatitis.

                            BACKGROUND AND DISCUSSION
                                         
          According to the author, this bill would allow CDPH to  
          authorize community clinics or other health agencies to  
          provide syringe exchange services in any location where the  
          department determines that the conditions exist for the  
          rapid spread of HIV, viral hepatitis, or any other  
          potentially deadly or disabling infection that is spread  
          through the sharing of used syringes. This bill will  
          authorize CDPH to approve syringe exchange programs (SEPs)  
          without inhibiting the ability of local governments to  
          regulate SEPs within their jurisdiction. The author claims  
          that most counties in California do not have safe, legal  
          access to sterile syringes, even in areas with high rates  
          of HIV and hepatitis.  The provision of sterile syringes  
          through exchange programs is considered a vital component  
          of a comprehensive HIV and hepatitis control strategy, and  
          is endorsed by every major state, national, and  
          international health and medical association, including the  
          US Centers for Disease Control and Prevention, U.S. Public  
          Health Service, National Institutes of Health, and the  
          World Health Organization, among others. 




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          5


          


          The author notes that this bill does not appropriate funds  
          for syringe exchanges, nor does it mandate the state to  
          fund new or existing syringe exchanges. The author claims  
          that a sterile syringe costs approximately $.10. Most SEPs  
          in California operate on very modest budgets, primarily  
          funded by private donors and foundations. As President  
          Obama recently signed legislation lifting the ban on the  
          use of federal funds for syringe exchange, AB 1858 creates  
          the statutory conditions to make the best use of federal  
          HIV prevention dollars that may become available in the  
          future. 
          
          Clean needle and syringe exchange programs (SEPs)
          Clean needle exchange programs make sterile needles  
          available to injection drug users (IDUs), in order to  
          mitigate the transmission of bloodborne diseases such as  
          HIV and HCV. SEPs provide a safe and accessible method for  
          IDUs to exchange used syringes for sterile ones.  Often,  
          SEPs also provide other public health services, such as HIV  
          testing, risk-reduction education, and referrals for  
          substance-abuse treatment. For some California residents, a  
          SEP is the only accessible provider of medical or social  
          services.  

          SEPs have been shown to be effective in reducing the  
          sharing of syringes and the transmission of blood-borne  
          infections among drug users, without increasing drug use.   
          SEPs can help lower the number of contaminated syringes  
          circulating in communities by decreasing syringe scarcity,  
          and in the case of an accidental needlestick, can lower the  
          likelihood of a needle being contaminated with a  
          potentially deadly disease. Since the implementation of  
          these programs in the late 1980s, new HIV infections among  
          IDUs have declined overall by 80 percent. One study  
          published in 2001 found that the mean HIV prevalence rate  
          among IDUs in metropolitan areas that banned  
          over-the-counter sales or purchases of needles and syringes  
          was twice as high as the mean HIV prevalence rate in metro  
          areas that allow over-the-counter sales (13.8 percent vs.  
          6.7 percent respectively). 

          According to the Center for Health Improvement, there were  
          41 authorized SEPs in California as of March 2009.  Cities  
          and counties are enabled to authorize a clean needle and  




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          6


          

          syringe exchange project as part of a comprehensive network  
          of services. Local government, local public health  
          officials, law enforcement personnel, and the public are  
          supposed to be given the opportunity to provide comments on  
          the clean needle and syringe exchange programs annually.  
          The local health officers are required to annually report  
          to the boards of supervisors or city councils, and to  
          include a detailed report on the status of local clean  
          needle and syringe exchange programs including, but not  
          limited to, relevant statistics on blood-borne infections  
          associated with needle-sharing activities and the use of  
          public funds for these programs. According to CDPH/OA,  
          seventeen county boards of supervisors and four city  
          councils have authorized SEPs, and several other counties  
          and cities are currently considering them.
          
          Funding for syringe exchange
          On December 16, 2009, President Obama signed the  
          Consolidated Appropriations Act of
          2010, which lifts the 1989 ban on the use of federal funds  
          for syringe exchange programs (SEPs). According to CDPH  
          Office of AIDS (CDPH/OA), CDPH considers syringe exchange  
          to be "unquestionably vital in the struggle to reduce the  
          spread of HIV, HCV and other bloodborne infections among  
          injection drug users, their partners, and their children."  
          Over the past four years, CDPH has awarded over 3.5 million  
          dollars in state General Funds to authorized syringe  
          exchange programs across the state to provide syringe  
          exchange, HIV and HCV testing, counseling and referral to  
          needed services. Recent cuts in state General Funds for HIV  
          prevention have resulted in elimination of all state  
          funding of SEPs; HIV prevention in the state is now solely  
          funded by federal dollars, which had precluded the funding  
          of SEPs. The lifting of the federal ban will mean that CDC  
          funds for FY 2010-2011 and future fiscal year funds can be  
          used to support SEPs when they are awarded. The Division of  
          HIV/AIDS Prevention (DHAP) of the Centers for Disease  
          Control and Prevention (CDC), is developing policy guidance  
          for grantees around the use of federal funds for SEPs; when  
          the guidance is provided to CDPH/OA, they will provide the  
          information to grantees in order to allow local health  
          jurisdictions the flexibility to use these funds to support  
          syringe exchange programs where they are authorized.

          Pharmacy sale of syringes




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          7


          

          Until the 2004 signing of SB 1159 (Vasconcellos), which  
          started the Disease Prevention Demonstration Project,  
          California was one of only five states that required a  
          prescription in order to purchase a syringe. In the early  
          80s, insulin and allergy syringes could be bought in any  
          drugstore without a prescription. In spite of the available  
          supply, some drug users chose to reuse and share needles,  
          and are believed to be partly responsible for the early  
          spread of the AIDS epidemic. In the 90s, some states began  
          requiring needles to be stored behind the pharmacy counter  
          and began requiring a prescription, in hopes of cutting  
          down on illegal drug use by making syringes more scarce.  
          Many states abandoned that policy once a correlation was  
          noted between syringe scarcity and increased infectious  
          disease rates in IDUs. 

          To address and prevent the spread of blood-borne infectious  
          diseases among IDUs in California, the DPDP was established  
          to allow the sale of up to 10 hypodermic needles or  
          syringes without a prescription at pharmacies. In order to  
          participate in the DPDP, pharmacies must register with  
          their local health department and provide a contact name  
          and related information. They must also certify that they  
          will provide written or verbal counseling at the time of  
          furnishing or selling needles or syringes. Additionally,  
          pharmacies must properly store needles and syringes so that  
          they are only available to authorized personnel, provide  
          on-site safe disposal of needles and syringes, or furnish  
          or sell mail-back state or federal standard personal sharps  
          disposal containers. In the absence of local authorization  
          of a DPDP or a SEP, the sale and possession of syringes  
          without a prescription remains illegal in California.

          Needlestick injuries 
          Access to sterile syringes can affect the occupational  
          health and safety of peace officers and waste management  
          employees because they are at risk of accidental  
          needlestick injuries from improperly disposed needles. A  
          recent study found that 29.7 percent of San Diego Police  
          Officers surveyed had suffered a needlestick injury on  
          duty, usually during a pat-down or search incident to  
          arrest. A study of police officers in Rhode Island found  
          that nearly 30 percent had been stuck by a syringe at one  
          point in their career, with over 27 percent experiencing 2  
          or more needle stick injuries. Research has shown that  




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          8


          

          accidental needlesticks to police officers have decreased  
          significantly following the implementation of SEPs.  For  
          instance, studies in Connecticut and Massachusetts found  
          that needlestick injuries to officers were reduced 66  
          percent after syringe deregulation. 

          Related bills
          SB 1029 (Yee) would allow individuals to obtain, and  
          pharmacists and physicians to distribute up to 30 syringes  
          or needles for personal use without a prescription from a  
          pharmacy until December 31, 2018. Repeals the Disease  
          Prevention Demonstration Project (DPDP), thereby removing a  
          requirement for local governments to first authorize  
          participation in the DPDP prior to a pharmacy's  
          registration in the program. Pending in the Assembly.

          AB 1701 (Chesbro) removes the sunset date for cities and  
          counties to authorize pharmacists to furnish or sell 10 or  
          fewer hypodermic needles or syringes to persons 18 years of  
          age or older, and removes the sunset date for persons 18  
          years of age or older to be allowed to possess 10 or fewer  
          needles or syringes if acquired through an authorized  
          source, thereby extending these authorizations  
          indefinitely. Pending hearing in the Senate Health  
          Committee.
          
          Prior legislation
          AB 110 (Laird), Chapter 707, Statutes of 2007, permits a  
          public entity that receives General Fund (GF) money for  
          human immunodeficiency virus (HIV) prevention and education  
          from the Department of Public Health (DPH) to use that  
          money to support clean needle and syringe exchange projects  
          (NEPs), as specified. 

          SB 1305 (Figueroa), Chapter 64, Statutes of 2006, prohibits  
          a person from knowingly placing home-generated sharps waste  
          in the commercial and residential solid waste collection  
          containers after September 1, 2008. 
          
          AB 1597 (Laird) of 2005 and AB 2076 (Laird) of 2006,  
          contained provisions substantially similar to AB 110.  
          Governor Schwarzenegger vetoed AB 1597, stating   
          "authorizing the use of state funds to purchase syringes,  
          without appropriate local controls, including mechanisms  
          for input from local law enforcement, and protections   




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          9


          

          against the use of state funds to supplant private or local  
          resources is not prudent."  AB 2076 was held on the  
          Assembly Floor.
          
          AB 547 (Berg and Richman), Chapter 692, Statutes of 2005,  
          authorized clean SEPs in any city and county, county, or  
          city upon the action of a county board of supervisors and  
          the local health officer or health commission of that  
          county; the city council, the mayor, and the local health  
          officer of a city with a health department; or, the city  
          council and the mayor of a city without a health  
          department.
          
          SB 1159 (Vasconcellos), Chapter 608, Statutes of 2004,  
          authorizes the Disease Prevention Demonstration Project  
          (DPDP) to evaluate the long-term desirability of allowing  
          licensed pharmacies to sell or furnish nonprescription  
          hypodermic needles or syringes to prevent the spread of  
          blood-borne pathogens. Authorizes a licensed pharmacist,  
          until December 31, 2010 and subject to authorization by a  
          county or city, to sell or furnish 10 or fewer hypodermic  
          needles or syringes to a person for human use without a  
          prescription if the pharmacy is registered in the DPDP with  
          a local health department. 

          SB 774 (Vasconcellos) of 2003 was almost identical to SB  
          1159; however the hypodermic needle and syringe limit was  
          higher, permitting a maximum of 30. Vetoed.

          SB 1785 (Vasconcellos) of 2002 was nearly identical to SB  
          744; however the bill included an additional provision that  
          would have mandated criminal penalties for discarding or  
          disposing of hypodermic needles or syringes on a  
          playground, public beach, public park, or the grounds of an  
          elementary school, vocational, junior high, or high school.  
           Vetoed

          AB 1292 (Aroner) of 2001 would have authorized pharmacists  
          in a licensed pharmacy to furnish or sell at retail  
          hypodermic needles or syringes for human use without a       
              prescription.  This bill was substantively similar to  
          SB 1785 and SB 744. The author chose not to move the bill  
          forward.
          
          AB 136 (Mazzoni), Chapter 762, Statutes of 1999, exempts   




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          10


          

          from criminal prosecution public entities and their agents  
          and employees who distribute hypodermic needles or syringes  
          to participants in clean needle and syringe exchange  
          projects authorized by the public entity pursuant to a  
          declaration of a local emergency due to the existence of a  
          critical local public health crisis.
          
          Arguments in support
          The Health Officers Association of California claims that  
          by allowing CDPH to establish vital disease-prevention  
          programs in high-risk areas, this bill will protect public  
          health without sacrificing public safety.  This bill will  
          permit the state to empower clinics, health service  
          organizations, community-based organizations, and other  
          entities to establish needle exchange programs. Such  
          programs are a proven way to minimize the burden of  
          HIV/AIDS and hepatitis among injection drug users and those  
          who come into contact with them. 

          Planned Parenthood Affiliates of California (PPAC) claims  
          that while cities and counties currently have the ability  
          to authorize a syringe exchange program, some of the  
          counties with the highest rates of AIDS infections do not  
          presently have exchange programs. PPAC states that data  
          collected by CDPH shows that 19 percent of new AIDS cases,  
          and over 5,000 new hepatitis C infections per year are  
          linked to shared needles. Once infected, an individual can  
          pass the disease to sexual partners, children, and others  
          in the community. They believe that allowing access to  
          clean syringes will help reduce new infections among  
          injection drug users and the rest of the community. 

          AIDS Project Los Angeles believes expanding access to  
          syringe exchange programs statewide will reduce costs to  
          taxpayers. They claim that more than 600,000 Californians  
          are living with hepatitis C and their health care costs are  
          expected to rise over the next decade. Syringe exchanges  
          deliver cost-effective results and money-saving benefits.  
          Preventing disease before it spreads is sound fiscal  
          policy, particularly in light of our current recession and  
          budget cuts. 

          The Solid Waste Association of North America is supportive  
          of the intent of this legislation, but believes that  
          organizations that are allowed to distribute needles and  




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          11
         

          

          syringes should also be required to take back the waste and  
          provide safe methods to transport the products. They  
          believe an amendment to address safe sharps disposal would  
          assist local governments in creating safer environments for  
          their constituents, including those using the needles.  

          Arguments in opposition
          The League of California Cities recognizes the intent of  
          this legislation, but opposes this bill because they claim  
          it overrides local authority and allows health service  
          organizations and clinics to operate outside city or county  
          government's discretion. They believe that authorizing CDPH  
          to declare an area in need of a needle exchange program and  
          permit the clinics and community-based organizations to  
          operate them without the approval of the city blatantly  
          undermines the authority and autonomy of that city. In  
          addition, to be fully successful, a needle exchange program  
          needs to have companion programs such as drug treatment and  
          rehabilitation. Without local support, they believe AB 1858  
          will not  address the root of the problem.  

                                 PRIOR ACTIONS

           Assembly Health Committee                 11-5
          Assembly Appropriations         12-5
          Assembly Floor             44-29

                                     COMMENTS

           1.  For vote only.  This bill was heard at the June 23,  
          2010 Senate Health Committee hearing, where it failed  
          passage. It was granted reconsideration by the Committee.   
          Therefore, this bill is set for vote only.
          
          2. Related bills. On April 14, 2010 this committee heard a  
          similar measure, SB 1029 (Yee), which sought to authorize  
          broad access to syringes in participating pharmacies  
          statewide by removing the existing requirement for local  
          authorization and increasing the number of syringes a  
          person can lawfully possess from an authorized source from  
          10 to 30.  SB 1029 was amended in committee to include a  
          sunset date of December 31, 2018 and to require pharmacists  
          to provide specified written information or verbal  
          counseling at the time of furnishing needles.





          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          12


          

          This committee will also hear an additional similar  
          measure, AB 1701 (Chesbro) which removes sunset dates to  
          allow pharmacy access to syringes indefinitely, but  
          continues the existing local authorization requirement and  
          keeps the number of allowable syringes capped at 10.  

          The key difference between AB 1858 and both SB 1029 and AB  
          1701 is that AB 1585 deals with allowing new entities to  
          create needle exchange programs in various locations at the  
          discretion of the state public health department. SB 1029  
          and AB 1701 deal solely with allowing access to syringes  
          and needles through pharmacies. 

          3. Local authority. AB 1858 allows CDPH to determine where  
          to provide authorization for needle and syringe exchange  
          programs for the purpose of addressing a public health  
          problem, and circumvents the existing local control over  
          the authorization of such programs. Given the concern about  
          bypassing local authority and that this change in policy  
          would allow additional unknown entities to engage in needle  
          and syringe exchanges, should this bill also apply a sunset  
          provision to this expansion of CDPH's authority? 

          Also, under the existing authorization of SEPs, there is an  
          opportunity for notice and comments when local governments  
          take the authorizing action. Should this bill be amended to  
          allow for a similar opportunity for public comment prior to  
          the initiation of a new SEP in jurisdictions authorized by  
          CDPH?
          
          4. Eligible entities. The bill does not define which  
          entities will be eligible to apply to CDPH to operate SEPs.  
          The bill also does not specify or reference which specific  
          state and federal standards these entities will have to  
          meet in order to be eligible to apply. The author may wish  
          to provide further clarification. 

          5. Technical amendments. 
          Section 2 of this bill seeks to amend HSC 121349.1 by  
          adding a provision that "Program participants shall be  
          allowed to possess syringes consistent with (HSC) Section  
          11364." The referenced provision in HSC Section 11364 that  
          allows the possession of 10 or fewer hypodermic needles or  
          syringes if acquired from an authorized source is scheduled  
          to sunset as of December 31, 2010. Staff suggests technical  




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          13


          

          amendments to address this. Since the other pending syringe  
          exchange bills maintain the sunset in HSC 11364, the author  
          may wish to consider double-jointing amendments.

          6. Author's amendments. At the bill's first hearing on June  
          23, the author agreed to take the following amendments at  
          the committee's suggestion:
             1.   Allow for an opportunity for public comment prior  
               to the initiation of a new SEP in jurisdictions  
               authorized by CDPH.
             2.   Describe which entities will be eligible to apply  
               to CDPH to operate SEPs.
             3.   Specify or reference which standards these entities  
               will have to meet in order to be eligible to apply. 
             4.   Technical amendments referenced in Comment 5.
          The author did not agree to accept the suggestion in  
          Comment 3 above to apply a sunset provision to this  
          expansion of CDPH's authority. 

           
                                    POSITIONS  
                                        
          Support:   AIDS Project Los Angeles
                     American Civil Liberties Union
                 Asian Pacific AIDS Intervention Team
                 California Association of Alcohol and Drug Program  
          Executives, Inc.
                 California Hepatitis Alliance (CalHEP)
                 California Medical Association
                 Community Health Empowerment/Exchange Works
                 County Alcohol and Drug Program Administrators  
          Association of California
                 Drug Policy Alliance
                 Friends Committee on Legislation of California
                 Harm Reduction Coalition
                 HIV Education and Prevention Project of Alameda  
          County
                 Homeless Health Care Los Angeles
                 Planned Parenthood Affiliates of California
                 Health Officers Association of California
                 Solid Waste Association of North America (if  
          amended)

          Oppose:  California Narcotic Officers' Association
                 League of California Cities




          STAFF ANALYSIS OF ASSEMBLY BILL 1858 (Blumenfield)    Page  
          14


          


                                   -- END --