安樂死和輔助死亡的比率正在飆升。但它們在哪裡合法?

What is the difference between euthanasia, assisted dying and assisted suicide?

The main difference between euthanasia and assisted suicide is who performs the final fatal act.

Euthanasia refers to active steps taken to end someone's life in order to stop their suffering, with the "final act" being performed by someone other than the individual, such as a doctor. If the person concerned makes a request, it is considered "voluntary euthanasia."

Assisted suicide is helping someone take their own life at their request—in other words, the ultimate act is the person's responsibility. Assisted dying can refer to euthanasia (usually voluntary) and assisted suicide. However, some campaign groups use it only to refer to assisted suicide in terminally ill patients.

"One of the dilemmas we face in these ongoing debates is how people use various phrases." Most, but not all, jurisdictions that allow some form of euthanasia or assisted suicide require the involvement of a medical professional.

Many countries, including the Netherlands and France, allow hospice sedation, where people can request to be kept deeply sedated until death, but this sedation is not euthanasia.

Which countries allow euthanasia?

The Netherlands and Switzerland are the most well-known, and Belgium is probably considered the most liberal, but several other jurisdictions allow some form of euthanasia or assisted suicide. That said, what is allowed varies significantly.

In the Netherlands, both euthanasia and assisted suicide are legal if the patient suffers intolerable pain and there is no hope of improvement. Anyone over the age of 12 can make a request, but if a child is under 16, parental consent is required. There are many checks and balances, including that doctors must consult with at least one other independent doctor to determine whether a patient meets the necessary criteria for a condition.

Belgium, Luxembourg, Canada and Colombia also allow euthanasia and assisted suicide, although there are differences - for example, in Colombia only terminally ill patients can request it, while Belgium has no age limit for children (although they must be terminally ill).

Assisted suicide is more widespread than euthanasia. Places where people can choose to end their lives this way include Switzerland and a number of U.S. states, including California, Colorado, Hawaii, New Jersey, Oregon, Washington, Vermont and the District of Columbia. A law allowing assisted suicide came into effect last month in the Australian state of Victoria.

Likewise, the specific circumstances under which assisted suicide is permitted vary, with some jurisdictions—Oregon and Vermont—allowing it only in cases of terminal illness. For some places, it is allowed not because the law has been passed, but because the law does not prohibit it. In Switzerland, for example, assisted suicide is a crime if it is motivated by selfish motives. The result is nonprofit growth.

How is the situation in the UK?

Both euthanasia and assisted suicide are illegal. Euthanasia can lead to murder charges, and assisted suicide can lead to up to 14 years in prison.

Despite this, anonymous surveys show that euthanasia does occur in the UK, but is very rare. A study published in 2009, using responses from more than 3,700 medical professionals, showed that 0.2% of deaths involved voluntary euthanasia and 0.3% involved euthanasia that was not explicitly requested by the patient - no assisted suicide was recorded.

It is generally not illegal to treat a patient to relieve suffering that may indirectly shorten their life, but this is not euthanasia. In the UK it is already legal for patients to refuse treatment, even if it may shorten their life, and doctors can withdraw medical care in certain circumstances, such as when the patient is in a vegetative state and unable to recover (sometimes controversially known as passive euthanasia) .

Royal precedent for euthanasia

Euthanasia is illegal in the UK - but in 1936 it seems that at least one patient's doctor decided to actively end his suffering: King George V.

The king's health had been deteriorating, and by early 1936 it was clear that his life was coming to an end - and on 20 January his chief physician, Lord Dawson, announced that his death was imminent. The king died shortly before midnight.

But decades later, when Dawson’s biographer Francis Watson revealed Dawson’s personal notes, it was discovered that the ending was orchestrated: Dawson admitted to injecting King with a lethal mixture of morphine and cocaine to hasten his death.

"Hours of waiting for the mechanical end, when all real life has departed, only exhausts the onlookers and leaves them so nervous that they cannot console themselves with thought, communication, or prayer. So I decided to decide on the ending. ” he wrote.

However, he added that his actions meant news of the king's death might be reported in The Times' morning edition.

How many people undergo euthanasia or assisted suicide ?

Total figures from around the world are difficult to reconcile. Figures from Switzerland show that the number of people receiving assisted suicide in the country increased from 187 in 2003 to 965 in 2015.

According to data from the Regional Euthanasia Review Board (RTE) in 2017, there were 6,585 cases of voluntary euthanasia or assisted suicide in the Netherlands, accounting for 4.4% of the total deaths. About 96% of cases involved euthanasia and less than 4% involved assisted suicide, with the largest proportion involving cancer patients.

There are several reasons why euthanasia is more common than assisted suicide in the Netherlands. Doctors may believe that by performing the surgery themselves, they have better control over the dose and duration of surgery.

Patients are often in advanced stages of the disease, and when choosing assisted suicide, drinking the lethal drink they must take is actually difficult or even impossible. It is a very bitter drink and it takes quite a lot of effort to finish it. There may also be an element of viewing this act as a medical procedure and therefore preferring a doctor to do the work.

Even if they could, the vast majority of people would not end their lives by euthanasia. Even in jurisdictions that allow euthanasia, there are far more instances of forgoing life-sustaining treatment.

Is there any suicide tourism?

In some places, yes. Although suicide tourism is not officially banned in the Netherlands, doctors must work with patients to determine that they meet certain criteria. If a doctor euthanizes a patient he does not know, the regional board is likely to object.

However, people do travel to Switzerland to seek assisted suicide. According to Dignitas statistics, 221 people traveled to the country for this purpose in 2018, 87 of whom were from Germany, 31 from France and 24 from the United Kingdom.

What is the public’s view on euthanasia and assisted suicide?

It depends in part on the question you ask. A recent poll by the National MDMD Center for Social Research found that 93% of Britons either support or would not rule out physician-assisted suicide when terminally ill.

The British Social Attitudes Survey, published in 2017, sheds light on people's views on voluntary euthanasia, showing that there is widespread support for doctors to end the lives of terminally ill patients (78%), but less support for voluntary euthanasia than for close relatives who do this work (39%) . It also shows that enthusiastic support for voluntary euthanasia is lower if the person has a non-terminal illness or is dependent on relatives for all needs but is not terminally ill or is in pain.

What does the doctor think?

Euthanasia and assisted suicide are controversial among doctors. Some believe support for such ideas violates the promise to do no harm. Others said some people might choose not to end their lives if they realized they could receive good end-of-life care.

Some health professionals are familiar with the care of end-of-life patients and the role of palliative care, so they may feel that assisted dying is not always necessary.

But some doctors have expressed support - at least in special cases such as terminal illness - saying it can be a humane act and that individuals should be allowed to decide for themselves when to die. After years of opposition to euthanasia, the Royal College of Physicians this year changed its position and remained neutral on the issue in a poll of 7,000 British hospital doctors, with 43.4% opposed to allowing euthanasia and 31.6% support. The Royal College of General Practitioners recently announced that it would start consulting its members.

In the Netherlands, a survey of nearly 1,500 doctors published in 2015 found that more than 90% of general practitioners and 87% of geriatric care doctors supported the Netherlands' liberal approach to euthanasia and assisted suicide. This may be because the law was written with input from the medical community.

All standards and practice of euthanasia depend largely on how doctors think it should be carried out, and for a typical patient suffering from terminal cancer and severe unbearable pain, few doctors in the Netherlands believe that harm to the patient is at risk.

Are these laws successful?

It depends on how you look at it. Support for the Dutch law apparently remains high, but some say there are signs of a "slippery slope" to the approach being applied too broadly.

Dutch law was designed with conditions such as advanced cancer in mind, but while cancer patients still make up the majority of requests, the proportion of requests related to other illnesses is growing. Of course, both doctors and patients are gradually becoming more aware of what these requirements are, and they can apply to other categories as well.

This sparked controversy. A 2017 RTE report documented concerns among Dutch psychiatrists and doctors about euthanasia for patients with mental illness and advanced dementia. The 2015 survey found that of nearly 1,500 responses, 31% of GPs and 25% of aged care doctors were willing to provide assisted dying for patients with advanced dementia, compared with 37% for patients with psychiatric problems. and 43%.

However, other jurisdictions, including Oregon, have shown that expanded use is not inevitable. The fact that the Dutch economy is in decline should give everyone reason to pause. We should think correctly from the outset about what we consider to be defensible in principle and whether we will – and we should – police the border.

There have also been allegations of malfeasance. In 2018, the Netherlands and Belgium reported the first cases of doctors being investigated for possible legal violations, and three other investigations involving euthanasia of psychiatric patients are ongoing in the Netherlands.

There are now more contested cases, so the likelihood that standards will not be met and prosecutors deem it necessary to initiate criminal proceedings is now greater than before.

Do you have any other questions?

Disability groups worry that as euthanasia and assisted suicide become more common, it could put pressure on those with non-terminal illnesses to end their lives. But doctors in the Netherlands are careful when processing requests to ensure patients meet strict requirements and reject those who don't.

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