Assisted Dying: A Global Perspective
For the first time in nearly a decade, MPs in England and Wales will vote on legalizing assisted dying for terminally ill adults. This comes at a time when over 300 million people worldwide now live in countries with assisted dying laws.
The proposed bill includes strict safeguards, requiring approval from a High Court judge. Supporters argue these would be the world’s most rigorous regulations, while critics warn about potential risks to vulnerable populations.
Global Landscape of Assisted Dying:
United States:
Assisted dying is legal in 10 states and Washington DC, with Oregon pioneering the approach in 1997. Oregon’s model requires:
– Terminally ill, mentally competent adults
– Expected to die within six months
– Approval from two doctors
Since 1997, 4,274 people have received lethal prescriptions, with 2,847 (67%) deaths. Key motivations include:
– Loss of autonomy (91.6%)
– Loss of dignity (63.8%)
– Losing bodily function control (46.6%)
– Concerns about being a burden (43.3%)
Patients must self-administer medication, and approximately one-third never proceed with the prescription.
Canada:
Initially introduced in 2016 for terminally ill patients, Canada’s Medical Assistance in Dying (MAID) has expanded. In 2021, it was extended to those experiencing “unbearable suffering” from irreversible conditions. Critics argue this broadens the law’s scope and potentially endangers vulnerable populations.
Currently, four in 100 deaths in Canada are medically assisted, compared to one in 100 in Oregon.
Europe:
Six European countries have assisted dying laws:
– Switzerland (first to legalize in 1942)
– Netherlands
– Belgium
– Luxembourg
– Spain
– Austria
Unlike the proposed UK legislation, these countries’ laws are not restricted to terminally ill patients. Some, like the Netherlands and Belgium, even allow assisted dying for mental health conditions and have extended eligibility to children.
Australia and New Zealand:
Voluntary assisted dying is now legal across most of Australia and in New Zealand. Requirements typically include:
– Terminal illness
– Expected to die within six months (extended to 12 months for neurodegenerative conditions in some Australian regions)
– Option for self-administration or medical professional administration
The UK proposal differs from these international models by maintaining a narrow focus on terminally ill patients with strict judicial oversight.
Neighboring jurisdictions like the Isle of Man and Jersey are also considering similar legislation, suggesting a potential regional trend towards legalizing assisted dying with careful restrictions.
As the debate continues, the proposed bill represents a significant potential shift in end-of-life care policies in England and Wales.
