Expressing widespread concerns about the supervised model, including that it will not guarantee detainees' anonymity, the Australian Nursing and Midwifery Federation submission said it was the only valid option to meet the government's policy aim for a program without creating a prison black market for needles.

"The federation has been specifically asked not to comment on the merits or otherwise of a needle and syringe program, but to suggest how an NSP model might operate," it said.

"The only way to ensure that blood-borne viruses' transmission within the Alexander Maconochie Centre can be addressed is the establishment of a supervised injecting room, where the needle and syringe will be used only once and will be disposed of appropriately before the detainee rejoins the prison population."

The federation's ACT secretary Jenny Miragaya, who wrote the submission, lodged mid-November, to the government's working party on the program, said a comprehensive workforce review was also warranted given the increased pressures the record prison population and potential needle program created.

The working party, which is jointly led by Community and Public Sector Union ACT regional secretary Vince McDevitt, was established after the government deferred the controversial needles plan in April due to protracted opposition by prison staff.

Ms Miragaya said no model answered all the problems raised by key stakeholders, but several conditions could make a supervised injecting model safer. These included the detainee being required to remain under supervision for 15 to 30 minutes after taking the drug.

"This is not a decision taken lightly by the federation, who has reiterated its concerns in respect of addressing other modes of blood-borne virus transmission, e.g. tattooing and body piercing, as well as the detection of contraband and other dirty needles and syringes within AMC," she said.

Ms Miragaya said she was unsure how anonymity could be guaranteed when detainees would need to be escorted to the injecting room.

She said her members who remained conscientiously opposed to the establishment of the program on moral or religious grounds would need to be catered for.

Mr McDevitt welcomed the nurses' views and said submissions from about 25 stakeholders the working group had written to were due by the end of the month.

"Over the years there has been various discussions, even a vending machine, and everything in the scale – [from] a free-for-all, special programs or an injecting room, and different models of injecting room," he said.

"It's early days and we're looking forward to constructive submissions."

The Canberra Liberals have criticised the government's call for the program. An ACT Health spokesman said the Justice Health Service had 19 full-time equivalent staff.