For the first time in almost a decade, MPs are to vote on giving terminally ill adults in England and Wales the right to assisted death. Although this is something that is illegal in most countries, over 300 million people now live in countries that have legalized assisted dying.

Canada, Australia, New Zealand, Spain and Austria have all introduced assisted dying legislation in the past decade, some allowing assisted dying for people who are not terminally ill.

The proposed bill in England and Wales comes with safeguards supporters say would make it the strictest set of rules in the world, including requiring patients to have the approval of a High Court judge. Critics, on the other hand, say changing the law would be a dangerous step that would put vulnerable people at risk. They argue that the focus should be on improving poor access to palliative care.

Ahead of Friday’s vote, we’re taking a look at assisted dying laws in North America, Europe and Australia.

Across the US, assisted death – which some critics prefer to call assisted suicide – is legal in 10 states as well as Washington DC. In 1997, Oregon was one of the first places in the world to offer help to die to some patients, and so has more than 25 years of experience. This has become the model on which other US assisted dying laws have been built.

in oregon, Assisted dying is open to terminally ill peopleMentally competent adults are expected to die within six months – and must be signed off by two doctors. since 19974,274 people have received prescriptions for lethal doses of the drug – with 2,847 (67%) deaths.

Two thirds of patients in the state Who had sought help to die from cancer last year. About one in 10 had a neurological condition and about the same proportion had heart disease. Of the 367 patients who took a fatal dose of the drug in the past year, the vast majority (91.6%) said Loss of autonomy was a major concernWhile others quoted:

• Loss of dignity – 234 patients (63.8%)
• Loss of control over bodily functions – 171 (46.6%)
• Worry about being a burden on family and friends – 159 (43.3%)
• Inadequate pain control – 126 (34.3%)
• Financial implications of treatment – ​​30 (8.2%)

In Oregon, like other US states that allow assisted dying, lethal medication must be self-administered – the same is proposed in England and Wales. Of those who are given a lethal dose, about one in three do not make it any further.

Oregon is critical of supporters of assisted dying in England and Wales because they say it has been limited to terminally ill adults since its introduction. However, opponents say some rules have been relaxed. The residency requirement has been removed, meaning it is open to people from out of state. The number of assisted deaths has also increased significantly over the years.

Canada is the country most often cited by opponents of assisted dying as an example of the so-called “slippery slope” – a place where assisted dying has been expanded since it was first introduced to more people. Has been made available. Medical assistance in dying (MAID) Launched in 2016, initially only for terminally ill people.

This was revised in 2021 and extended to people experiencing “unbearable suffering” from irreversible illness or disability. It’s still going to be available to people with mental illness Despite delays, in three years,

Critics say the more sweeping the law is made, the more disabled and vulnerable people will be put at risk. The number of people using MAID has also increased dramatically. Four out of 100 deaths in Canada are now medically assistedThat compares to about one in 100 in Oregon.

Kim Leadbeater, the MP who proposed the assisted dying bill in Westminster, says the Canadian system is not the one being debated for England and Wales, where eligibility would be limited only to the terminally ill.

Voluntary assisted dying has been legalized in most parts of Australia over the past few years. While in New Zealand, patients would be terminally ill and expected to die within six months. This has been extended to 12 months for people with neurodegenerative conditions in eligible parts of Australia.

In both countries, patients can self-administer the lethal drug. But it can also be given by a doctor or nurse, usually through intravenous injection.