Major Countries Abroad, Ineffective Treatment Withdrawal... Some Allow Assisted Dying for Dignity [What Kind of Death]

④Most Widely Accept Withdrawal of Life-Sustaining Treatment
Assisted Dying Introduced in Some US States and the Netherlands
Without Systems, Only Self-Help Measures Like Suicide or Fasting Available

Major countries overseas allow both passive and active euthanasia, such as the discontinuation of life-sustaining treatment for terminal patients and physician-assisted euthanasia. They broadly recognize the scope of discontinuing life-sustaining treatment based on self-determination, and some have introduced physician-assisted euthanasia systems involving medication administration.

◆Applicable to Terminal and Vegetative State Patients... Court Decision When No Family Exists

According to the comprehensive hospice and life-sustaining treatment plan by the Ministry of Health and Welfare on the 26th, countries such as the UK and some states in Australia do not have physician-assisted euthanasia systems but allow the discontinuation of life-sustaining treatment for terminal, vegetative state, and severe dementia patients. Japan does not permit physician-assisted euthanasia or discontinuation of life-sustaining treatment for vegetative state and severe dementia patients but allows discontinuation of life-sustaining treatment for terminal patients.

These countries aim to ensure that patients can end their lives with dignity and respect without losing their dignity at the end of life. The UK's End of Life Care Strategy defines it as maintaining dignity and respect in a familiar environment and dying without pain together with family and friends. Japan has established measures to improve quality of life by realizing a community-based society where cancer patients and their families can live with dignity while receiving necessary support at their residence.

Decisions to discontinue life-sustaining treatment are possible even when the patient lacks decision-making capacity or has no family. In the UK, under the Mental Capacity Act, the IMCA (Independent Mental Capacity Advocate) service considers the patient's past beliefs and treatment possibilities to determine whether to discontinue life-sustaining treatment in the patient's best interest. In the US, if there is no family to make decisions on behalf of the patient, the court appoints a surrogate decision-maker upon the physician's request. Patients with decision-making capacity can also designate a surrogate through advance directives.

◆Differences in Applicable Subjects and Physician-Assisted Scope by Country

In some US states, the Netherlands, Austria, some Australian states, and Switzerland, the scope of discontinuing life-sustaining treatment ranges from terminal patients to those in vegetative states or with severe dementia. These countries have introduced physician-assisted euthanasia, but there are differences in applicable subjects, revocability, and the scope of physician assistance.

In Oregon, USA, it is possible for patients aged 18 or older who are incurable, expected to die within six months, and terminal, with voluntary consent. A waiting period is required between the patient's request and implementation: 15 days after the initial verbal request and 48 hours after the written request. Revocation is possible at any time, and medication can be prescribed upon patient request, but the physician cannot administer the medication directly.

In the Netherlands, patients aged 12 or older who are incurable and experiencing unbearable suffering must voluntarily consent. The attending physician confirms the patient's condition and carries out the procedure, and there is no provision for medical staff to refuse medication administration. Withdrawal after application is not allowed, and the physician can prescribe and administer medication directly.

In Austria, it applies to patients aged 18 or older with incurable diseases or serious and permanent illnesses who voluntarily request it. Confirmation of the patient's condition by two physicians is required, and physician-assisted euthanasia is carried out according to a death declaration jointly prepared by the patient and medical staff. The law explicitly states that revocation is possible, and physicians can prescribe and administer medication directly.

In New South Wales, Australia, the applicable subjects are terminal adult patients and those with a life expectancy of six months or less (12 months or less for neurodegenerative terminal patients), excluding those with disabilities or dementia. Eligibility is assessed by the attending physician, and medication administration must be approved. Withdrawal is possible at the applicant's will, and physicians are allowed to prescribe and administer medication directly.

Switzerland does not have a specific law permitting physician-assisted euthanasia. Instead, under Article 115 of the Criminal Code, only those who assist another's suicide with selfish motives are punished; assistance without selfish motives is not punishable. Based on this, nonprofit organizations or associations have been established to support people who want physician-assisted euthanasia regardless of nationality.

In countries without physician-assisted euthanasia systems, the only options are self-help measures such as suicide or fasting. Suicide not only causes suffering to the individual but also leaves deep wounds to the family. Fasting involves death within 10 to 14 days without food or water intake, requiring very strong willpower and patience from patients and families, raising concerns that it cannot be a viable alternative.