Alzheimer Europe has submitted a response to the Steering committee for human rights in the fields of biomedicine and health (CDBIO) of the Council of Europe, following its consultation on a Draft Recommendation on respect for autonomy in mental healthcare. The Recommendation aims to provide common principles to promote a human rights-based approach in mental healthcare, safeguarding the rights and self-determination of persons with mental health problems. Alzheimer Europe welcomed the opportunity to comment on these recommendations and raised concerns with the approach taken, specifically, the broadness of the recommendations and the separate Explanatory Memorandum (EM), which was not included as part of the consultation.
We expressed concern that the recommendations were not accessible as the need to refer to footnotes/the EM, may deter people from using them. Alternatively, we noted that if applied without reference to these additional documents, the Articles may not be applied in the way intended by the CDBIO. As such, we strongly urged the CDBIO to revise the Articles so that there is greater detail and specificity for each Article, without the need to refer to an EM or another document.
Alzheimer Europe also noted the difficulty in providing feedback on the Articles and the document as a whole, as many of the Articles are dependent on the clarification or further detail which is anticipated to be in the EM. These details were crucial to the understanding of both the intention behind, and the application of, the Articles, in relation to policy and practice. As such, we urged the CDBIO to put the EM out for consultation, so that stakeholders have the opportunity to comment on both documents. Alzheimer Europe’s full response is available at:
