How assisted dying has spread across the world and how laws differ

On November 27, 2024, in London, pedestrians passed by posters that promoted the Assisted Dying bill at Westminster Underground station. This bill is significant because, for the first time in nearly a decade, Members of Parliament (MPs) will vote on whether to allow terminally ill adults in England and Wales the right to choose assisted death. While assisted dying remains illegal in many countries, over 300 million people now reside in nations that have legalized it. Since 2015, countries such as Canada, Australia, New Zealand, Spain, and Austria have enacted laws regarding assisted dying, with some even permitting assisted death for individuals who are not terminally ill. The proposed legislation in England and Wales includes safeguards that supporters argue will create the strictest regulations in the world, requiring patients to obtain approval from a High Court judge. However, critics contend that changing the law could pose a dangerous risk to vulnerable individuals, asserting that the focus should instead be on improving access to palliative care. As the vote approaches, it is essential to examine assisted dying laws in North America, Europe, and Australasia. In the United States, assisted dying, which some critics prefer to label as assisted suicide, is legal in ten states and Washington D. C. Oregon was one of the first regions to offer assistance in dying, having introduced the law in 1997, and it has accumulated over 25 years of experience. Oregon's model has influenced the development of assisted dying laws in other states. In Oregon, mentally competent adults who are expected to die within six months can request assistance, but they must be approved by two doctors. Since the law's inception, 4,274 individuals have received prescriptions for lethal medication, with 2,847 (67%) of those resulting in deaths. Most of the individuals who sought assistance last year were diagnosed with cancer, while others had neurological conditions or heart disease. Among the 367 patients who took the lethal medication last year, the majority (91. 6%) cited loss of dignity as a reason for their choice, while others mentioned concerns about being a burden to family and friends, loss of bodily control, inadequate pain management, and financial implications of treatment. In Oregon, as in other U. S. states that permit assisted dying, the lethal medication must be self-administered, which is also proposed in England and Wales. Interestingly, about one in three individuals prescribed a lethal dose do not proceed with it. Supporters of assisted dying in England and Wales often reference Oregon as a model, emphasizing that it has remained limited to terminally ill adults since its introduction. However, opponents argue that some regulations have been relaxed, including the removal of a residency requirement, allowing individuals from outside the state to access the law. The number of assisted deaths in Oregon has also increased significantly over the years. In Canada, the assisted dying law was first introduced in 2016, initially limited to terminally ill individuals. However, in 2021, the law was amended to include those experiencing unbearable suffering from irreversible illnesses or disabilities. There are plans to extend this law to individuals with mental health issues as well. Critics argue that as the law expands, more disabled and vulnerable individuals may be at risk. The number of people utilizing Medical Assistance in Dying (MAID) has grown dramatically, in contrast to Oregon, where only about one in 100 individuals choose this option. Kim Leadbeater, the MP who proposed the assisted dying bill in Westminster, asserts that the Canadian system is not what is being debated for England and Wales, where eligibility would be restricted to terminally ill individuals. In Europe, six countries have legalized some form of assisted dying: Switzerland, the Netherlands, Belgium, Luxembourg, Spain, and Austria. In these countries, unlike the proposals in England and Wales, assistance in dying is not limited to terminally ill individuals. Switzerland was the first country to establish a 'right to die' when it legalized assisted suicide in 1942. It is one of the few nations that allows foreigners to access assistance through organizations like Dignitas in Zurich. In the past two decades, the number of people utilizing this option has increased significantly, including 40 individuals last year. The lethal medication must be self-administered. The Netherlands and Belgium both legalized assisted dying over 20 years ago for patients experiencing unbearable suffering from incurable illnesses, including mental health issues. These countries have also extended the option to children, making them the only European nations to do so. Both countries permit euthanasia, or physician-assisted dying. Most recently, Spain and Austria have legalized assisted dying for both terminal illness and intolerable suffering. In Austria, the drugs must be self-administered, while in Spain, a medical professional can administer them. Despite the differences, it is evident that eligibility for assisted dying is much broader across Europe than what is being proposed in the British Isles. In Scotland, Members of the Scottish Parliament (MSPs) are set to debate a similar bill that would allow terminally ill adult patients to choose to die if they have 12 months or less to live. This legislation is expected to receive Royal Assent next year, and the first assisted death in Scotland could occur in 2027. There is a residency requirement of five years for this bill. In Australia and New Zealand, voluntary assisted dying has become legal in most parts. In New Zealand, patients must be terminally ill and expected to die within six months, while in eligible areas of Australia, this period can be extended to 12 months for those with neurodegenerative conditions. In both countries, patients can self-administer the lethal medication, but it can also be administered by a doctor or nurse, usually through an intravenous injection. This topic continues to be a significant point of discussion and debate in many regions.