HEAL Committee Meeting

STANDING COMMITTEE ON HEALTH

COMITÉ PERMANENT DE LA SANTÉ

EVIDENCE

[Recorded by Electronic Apparatus]

Tuesday, March 17, 1998

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[English]

The Chair (Ms. Beth Phinney (Hamilton Mountain, Lib.)): I call the meeting to order. This is meeting 27 of the Standing Committee on Health. We're doing a study of natural health products.

We have here today Mr. Hassard, an individual homeopath and chiropractor; from the Ontario Federation of Homeopathic Practitioners, Barbara Etcovitch; and from the National Homeopathic Professional Association, or NUPATH, Rudi Verspoor and Patty Smith.

Welcome. If you could keep your remarks not too long, it would then give more time for the members to question you afterwards.

I'll go in the order we have you down here.

Dr. Hassard, would you like to start?

Dr. Murray R. Hassard (Individual Presentation): Hon. members of the House of Commons, ladies and gentlemen, my purpose today is to state the case for government endorsement of alternative health care through supportive funding and supportive policies. In the quest for a new and excellent health care system, this government has the opportunity to reshape the way Canadians think of health care.

A fully complementary health care system operating under the premise that all disciplines of health care—medicine, chiropractic, midwifery, homeopathy, naturopathy, acupuncture, message therapy and so on—have a valid place in the well-being of Canadians is the government's best bet for an efficient, effective, publicly endorsed system.

It is the unmanageable cost of our current health care that is forcing difficult choices by all levels of government and by all Canadians. One of the reasons for this is that we are relying too heavily on an extremely expensive form of health care—conventional medicine.

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While medicine plays an indispensable role on many fronts, such as in the prevention and treatment of infectious diseases, perinatal care and acute care, to name but a few, there are many conditions that fall to our conventional, medical health care system by default, because it is essentially Canada's only publicly funded and endorsed health care choice.

The medical system is the most expensive choice. Many health problems can be prevented and treated through non-conventional health care choices. Ironically the conventional medical system has done its job too well in some aspects: the resources of the system that we rely on for what they do best are being stretched to the limit by the sheer quantity of services they are now obliged to provide, because it has worked everyone else out of the market.

Take, for instance, the example of back pain. In 1993 a comprehensive study of back pain was commissioned by the Government of Ontario for examining the effectiveness and cost-effectiveness in the treatment of low back pain. It concluded that the direct savings to OHIP would be $548 million per year if chiropractors were 100% covered under the provincial health plan. That's the Manga report of 1993. Copies are included.

To date nothing has been done to implement this report.

Despite these services not being covered under provincial health plans, there has been a dramatic increase of 81% in the usage of complementary health care over the past five years. That's an Angus Reid survey of September 1997. I use the term “complementary” because I don't feel any health care system can offer all things to all people. Canadians should have alternatives such as homeopathy, chiropractic, herbal therapy, acupuncture, and massage therapy. These choices, however, are not instead of medicine, but in cooperation with it. If all the barriers to access were removed, there would be substantial savings to health care budgets.

The CTV Angus Reid poll on health care confirmed that 70% of all Canadians were in support of provincial health plans covering natural health care and that 66% of Canadians feel the government should be advocating the use of alternative medicines and practices in order to potentially reduce the cost of the health care system.

Homeopathy is an inexpensive mode of providing health care. The World Health Organization is promoting the use of alternative therapies such as homeopathy, because the cost is so low. The widespread use of homeopathy in India, where it is recognized and supported by the state, is an example of how a country can utilize cost-effective health care on meagre resources. Homeopathy is widespread in Britain, France, Holland, Greece, South Africa, and many other countries. Hospitals in England have homeopaths on staff, which can then offer true choices to patients.

Homeopathy is a form of complementary health care that treats health conditions based on various principles that have been published in The Organon of the Medical Art by Samuel Hahnemann, including vital force, minimum dose, and like treats like.

There is a well-established Materia Medica that lists thousands of plants, minerals, and animals in extreme dilute concentrations. This list was compiled by careful observations of symptoms that were caused by these materials. An example would be onion. I am sure you will agree that an onion has an effect on your eyes and nose. It produces a clear, colourless discharge and eye irritation. This symptom presentation may match that of a person suffering from hay fever. Hay fever may be successfully treated using a dilute remedy made homeopathically from red onion or Allium cepa. With this homeopathic approach, a patient could avoid the more conventional suppression caused by antihistamines and histamine rebound.

Homeopathy effectively provides a full range of care from acute to chronic conditions, short-term to long-term treatments. Literally thousands of conditions can be treated with homeopathic remedies, from colds to injuries, to emotional disorders, to substance abuse.

What Canadians need is increased information on complementary health care and health care choices, and they need to have increased access to these choices. This committee should promote policies that encourage health and wellness choices for Canadians. Amendments to the Food and Drugs Act should have broader interpretations with the formation of a category “supplement” to differentiate it from the categories “food” and “drug”. There needs to be open, honest, and accessible information on labels to allow Canadians to make informed choices.

The private member's bill, Bill C-307, by Mr. Grant Hill, encourages health providers as it allows for honest therapeutic claims to be made, whether or not the substance has been classified as a drug.

This Standing Committee on Health has often focused on the labelling of natural health products. One comment that I would make is that the only true benefit of labelling is when it is done as a vehicle for education. Too often this opportunity is lost. The label appears only to be used to reduce the liability in a law suit and is then ignored by the general population. Canadians need legislation that would be favourable to promote health information. This means there should be no obstacles to truthful health claims on natural health products. Health seminars, public forums, and classes on complementary health care should also be encouraged.

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We also need to find ways of reducing financial obstacles to patients seeking complementary care. In this manner the increased utilization of complementary health care providers, such as homeopaths, chiropractors, naturopaths, accupuncturists, and medical herbalists, could then free hospital resources for those conditions better served by medicine. Increased complementary health care funding would finally make the Canada Health Act the one-tier health care system we aspire it to be.

Canadians need increasing access to safe and effective natural health products. The Health Protection Branch has been removing products that are safe and beneficial from health food store shelves. Canadians need regulations that ensure safe products are not removed without just cause. The private member's Bill C-307 would place the onus on the government to prove that a substance is harmful in a dose form when used as recommended before it is regulated as a drug and removed from health food store shelves.

I would like to take this opportunity to thank the committee for their interest in homeopathy and natural health care and would ask you to consider legislation that encourages freedom of choice in health care choices for Canadians. Thank you.

The Chair: Thank you very much. From the Ontario Federation of Homeopathic Practitioners, Barbara Etcovitch.

Ms. Barbara Etcovitch (Classical Homeopath, Ontario Federation of Homeopathic Practitioners): Thank you.

The Ontario Federation of Homeopathic Practitioners represents a body of highly trained practitioners of classical homeopathy. It is dedicated to upholding the maximum standards of training and practice and to overseeing the ethical conduct of its members. The federation is committed to ensuring that all persons opting to use homeopathy be educated in its principles and philosophy and in the correct and safe use of its homeopathic remedies.

It therefore functions as a watchdog organization and attempts to participate in all issues that affect the profession. Providing input and making recommendations to all levels of government in Canada is an essential part of this process. For example, we were present at the review of naturopathy, the HPRAC hearings. At that time we were called the Ontario Society of Homeopaths but were forced to change our name when we federally incorporated.

My colleague Raymond Edge, who is the director of the Toronto School of Homeopathic Medicine, sends his regrets as he could not be here today. I alone will be speaking on behalf of the federation.

Dear Madam Chair and members of the Standing Committee on Health, homeopathy has a 200-year history of safety and effectiveness in the treatment of acute and chronic disease. No other medical system, natural or otherwise, can boast such a record. In the hands of a skilled practitioner it can be wonderfully beneficial to persons with even the most severe health problems. It is extremely important for the Canadian professional practitioner to have access to the entire pharmacopoeia in a full range of potencies, as is the case in Great Britain, India, etc. The restriction of even one remedy may have dire complications for those requiring a specific medicine. Restriction should be limited to toxic substances, which should be made available in safe dilutions only.

It is the position of the Ontario Federation of Homeopathic Practitioners to support the unhampered availability of homeopathic remedies for the skilled practitioner. However, we ask that the over-the-counter sale of remedies be carefully reviewed. The marketing issues we feel should be considered are claims and directions for use. In addition, the definition of homeotherapy, which has led to much of the misunderstanding of homeopathy by the general consumer, should be considered.

This morning I would like to address these three basic issues: definition of homeotherapy; claims; and directions for use, wherein we feel the problem that is being confronted now lies.

The current definition of homeopathic preparation is a medicinal agent that is manufactured according to a method of production provided for in the relevant homeopathic pharmacopoeia, such as the process of successive dilution and succussion. The original specifications for potentization are presented in Samuel Hahnemann's Organon, which also provides the fundamental principles and philosophy of classical homeopathy. Since Hahnemann's time the use of homeopathic preparations has been modified for utilization by diverse schools, which no longer adhere to the basic principles of classical homeopathy as stipulated in The Organon. These various approaches are today referred to under the banner of homeotherapy. Homeotherapy is seen to encompass all schools of medicinal therapy that use the process of potentization.

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It is from this point the confusion arises, since homeopathic medications are no longer used exclusively in classical homeopathy but are utilized in related schools that have deviated from the basic system. These schools include clinical homeopathy, multi-use or combination-product homeopathy, antihomotoxic therapy, anthroposophical medicine, the biochemistry approaches of Dr. Schussler, and spagyric therapy. No attempt has been made on the part of the producers and marketers of homeopathic remedies to inform the public that there is a distinct difference between these systems. Homeotherapy is being made to appear as a uniform system and the remedies are being marketed accordingly.

Classical homeopathy is based on the law of similars, which matches the total symptom picture of a homeopathic remedy to the total symptom picture of a patient. The therapeutic portrait of a remedy is based upon homeopathic drug provings conducted on healthy human volunteers. In order to ascertain the total symptom picture of a patient, a detailed case history of all physical, emotional, and mental symptoms that reveal a central disturbance is taken and studied. The process is highly detailed and requires a skilled and thoroughly trained practitioner.

With the knowledge that the real causation of the disease originates on a dynamic plane, the plane of the vital force, classical homeopaths understand that the pathological changes are of little importance as they are only expressions of the energetic imbalances. That is, the symptoms are not the illness. The real derangement is invisible, lying behind the visible changes, and homeopathic treatment has to reach the causative level behind the pathology; i.e., it must address the central disturbance.

Lumping all approaches under the label of homeotherapy is inadequate and misleading since:

(1) Not all systems are alike, as previously stated, but are being promoted as such;

(2) Only classical homeopathy is based on provings and the laws as presented in The Organon and thus is the only system representative of Hahnemann's theories; and

(3) Classical homeopathy is concerned with isolating and addressing the central disturbances, while the other approaches concentrate on end results, pathology, etc.

The science of homeopathy is suffering as a result, because it is not being differentiated from other systems, which are not based upon the original principles and philosophy of Samuel Hahnemann. As a result of the lack of differentiation, the public is being misled into believing that all systems are alike and equal.

Suggesting through the lack of information, which would otherwise differentiate them, that all products diluted and succussed, whether single or multiple format, are alike is misleading. The practice can only serve to confuse the public and eventually lead to the disparaging of classical homeopathy.

A recommendation by the Ontario Federation of Homeopathy Practitioners on this point is that a clear distinction be made between a substance that has been merely diluted and succussed without undergoing a proving and a remedy that is truly homeopathic by virtue of the fact that it conforms not only to the process of potentization, as provided for in The Organon, but also to the principles and philosophy presented therein.

The OFHP believes that the solution to this problem lies in changing the terminology used so that only a product that conforms to the manufacturing process outlined in The Organon and to the principles and philosophy of classical homeopathy carries the wording homeopathy, homeopathic, etc. All other medicinal products that do not so conform should not be referred to as homeopathic but carry another label that clearly differentiates them.

Approaching the prescription of a homeopathic remedy from the standpoint of pathology and not the central disturbance is not homeopathy. The marketing approach prevalent today is based on end results and not on the central disturbance, which can only be isolated by a skilled practitioner. Thus, the lay person is being misled into believing that (1) he or she is capable of addressing the acute or chronic problem by superficially matching symptoms; (2) the pathology-based approach is homeopathic; and (3) the process of cure is simple and uncomplicated and does not take into account philosophy or principles.

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Our recommendation is that the consumer be informed through the labelling of remedies and accompanying literature that such remedies should be used only by the prescription of a skilled practitioner and that he or she should refrain from self-diagnosing and self-prescribing remedies under any circumstances.

Along these lines it should be noted that the consumer does not have the general knowledge or understanding of acute and chronic disease and does not therefore necessarily differentiate between the two. The classical homeopath recognizes there is a link between the two and that acute episodes may be signs of deeper chronic imbalances. Accordingly, remedies being marketed for seemingly acute situations may cause complications in chronic disease. The labelling and literature accompanying the remedy should make note of this and explain the link.

The second issue I would like to address today is that of claims.

The subject of claims becomes the next issue. Remedies do not cover any specific complaint. The determination of the prescription is based upon many factors affecting the patient's life and not solely upon the presenting physical complaint. The mental and emotional state, reactions to the environment, weather, food, modalities of symptoms, and miasmatic and personal history are all factors in deciding a remedy.

Taking a single remedy for a specific and isolated physical problem, as is being encouraged through the marketing of remedies at this time, is an incorrect approach. It will, for the most part, not yield results and such practice can confuse and upset cases that eventually will have to be addressed by a skilled practitioner. Thus, any claims made in advertising of homeopathic remedies should be negated.

Claims with respect to repetition pose another problem. The cardinal rule in homeopathy is to stop dosing on improvement; that is, once the action has been effected, the remedy is not repeated. Repetition is a delicate matter, and it is unlikely that the unskilled consumer will adequately be able to judge when it is appropriate to discontinue or repeat. The current instructions carried by the remedy packaging are inadequate. Too frequent repetition of any substance can lead to a proving or to antidoting of a previous dose.

Further, the prescription of several remedies in succession by the unskilled can bring up the problem of remedies that may be inimical or antidotal to one another. Consumers, health store personnel, or amateur homeopaths are not adequately prepared to deal with these issues.

The third issue I would like to address today is that of directions for use.

The current marketing of remedies falls short in this area, as well. Information regarding substances such as menthol, peppermint, camphor, eucalyptus, coffee, etc., which can cause the antidoting of a remedy, is clearly absent. General instructions not to touch remedies with bare hands, to dissolve medicines under the tongue away from meals, to open substances only in clean air, and to store all remedies away from heat, cold, light, electrical currents, and odours are similarly not provided for in labelling.

Our recommendation on this point is that all products be accompanied by full information pamphlets that outline the correct use and storage of homeopathic remedies. Careful consideration should be given to the substances that can interfere with the action of a remedy. The fact that remedies should be taken only under the guidance of a skilled practitioner should be emphasized.

Classical practitioners, rather than manufacturers' representatives, should be consulted for all future revisions in the labelling and marketing of potentized products. Only this can guarantee that a comprehensive, unbiased regulatory structure that ensures the safety and appropriate use of the products and safeguards the system of classical homeopathy will be put in place.

In summation, Canadian professional practitioners should have access to the entire pharmacopoeia in a full range of potencies. Over-the-counter sale of remedies should be reviewed, clarified, and restricted. The definition of a homeopathic medication, solely as a substance that conforms to a process without due consideration to philosophy and principles, is inadequate and misleading. Homeotherapy is too general a term and accordingly the various systems that fall under its umbrella must be clearly differentiated to the public.

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That which does not conform to the process of potentization and to Hahnemann's principles and philosophy should not be referred to as homeopathy. Claims should not be made under any circumstances. Directions for use must be clarified through revised literature. A fully revised regulatory structure should be derived in consultation with classical practitioners.

Thank you.

The Chair: Thank you very much.

Now we have from the National Homeopathic Professional Association, NUPATH, Mr. Rudi Verspoor.

Mr. Rudi Verspoor (President, National Homeopathic Professional Association (NUPATH)): Thank you, Madam Chair. I apologize in advance for not having notified you of bringing along a colleague. I was in Seattle over the weekend and got in just last night.

I would like to thank you and the members of the committee for this opportunity to present our views to you. I will try to confine my remarks to what I understand to be the mandate of your committee, which is dealing with the natural health products, in particular homeopathic products, insofar as they are regulated at the federal level.

I will not address issues related to the practice of homeopathy, which are regulated at the provincial level. I will possibly make some indirect comments, but I will focus my comments on the products themselves.

Let me first introduce my association to you and the members of the committee. We are a Canadian professional association for homeopaths. We were formed in 1994 to promote minimum standards of training and practice for homeopaths, and we have members who come from many diverse backgrounds, both members with conventional medical training who have also specialized in homeopathic medicine and members who have simply specialized in the training of homeopathic medicine.

We have a particular interest in the deliberations of this committee because of our dependence on access to homeopathic products in order to successfully practise. Although the practice of homeopathy is regulated provincially, access to homeopathic products is regulated federally.

As in most things in Canada, we're caught between the two of them. Like Ms. Etcovitch, we too make representations at the provincial level and at the federal level.

I won't go into homeopathy itself, which I think Dr. Hassard has done a wonderful job of explaining, or into its history, but it might be of curious historical interest for the committee to know that homeopathy in Canada goes back to the 1840s and 1850s, when it was brought in by Scottish, English, and German medical practitioners. As a footnote in history, the first medical association in Canada, before it was Canada and Upper Canada, was a homeopathic medical association. It was formed before the Canadian Medical Association. The first president of the Ontario College of Physicians and Surgeons was a homeopath. That's just a historical footnote.

Homeopathy works on the basis of a natural law of cure, and this is derived from observation and grounded in specific provings or testings of medicinal substances on healthy persons, as well as on clinical indications. This is no different from conventional medicine, except, because there are no toxic effects, we do our testing on people rather than on animals.

The substances we use are listed in various pharmacopoeia. These are long lists of substances that have been proved and tested and used generally by homeopathic practitioners. The most common pharmacopoeia, as you probably know, are the United States pharmacopoeia, the French and the German pharmacopoeia. These are the most developed, the most advanced, and the ones that under current law and regulation are referred to.

However, any substance in nature and any substance devised by man has the potential for cure under homeopathic medicine, and the list of homeopathic medicine and remedies is constantly being added to. There's not a finite list of substances, as with any drug.

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However, what is important at this point is that homoeopathic preparations are rather unique in nature. They are medicine, but they are not a drug. They are are entirely non-toxic at preparations above a certain dilution.

Now this non-toxic dilution level, if you look at countries around the world where homoeopathic products are regulated, is usually at the level of what we call a 6x or 3c dilution. This numbering system represents a dilution of roughly one part per million. It's normally considered in countries that use homeopathic medicines; that any substances above that in terms of dilution are non-toxic and safe by nature. They are entirely free of the side effects that are associated with drugs, and therefore in our view should be treated differently.

While it is true that currently there is access to most homeopathic preparations by homeopathic practitioners, we have had problems in the past with regard to access to substances that to us are commonly used and necessary for the practice of our trade. As well, there remain many commonly used and well established homeopathic remedies that we are not allowed to use under current regulations—for a number of reasons, and those reasons relate to the fact that homeopathic remedies are treated as drugs.

I would like to make the following specific points to the committee with respect to the regulation of homeopathic products at the federal level. First of all, homeopathic preparations should not be classified in the same category as what we call allopathic preparations. Allopathic refers to conventional medicine or drugs—synthetic drugs.

Treating homeopathic preparations as drugs has meant restricted access to commonly used homeopathic preparations derived from certain potentially toxic or otherwise prohibited substances. This means that the substance itself may be toxic—arsenic would be a good example—but once it's prepared in a homeopathic form, the substance no longer becomes a drug. When it is diluted beyond a certain point, it enters a different category. On the other hand, homeopathic preparations are also not a food or vitamin supplement. They do not enter into the realm of nutrition and regimen.

Second, in our view a new category should be created for homeopathic preparations under federal law that would recognize the unique nature of such medicines. Homeopathic preparations would generally be considered to be any substance that is diluted above a level of one part per million.

Third, any claims being made by manufacturers for their use—and this is indications-for-use issues—should be restricted to multi-ingredient, low-dilution homeopathic preparations. Such indications for use should be restricted as well to self-limiting conditions, allowing for self-diagnosis and self-treatment. This is relatively similar to what is the case under existing regulations.

Fourth, any substance that is listed in the homeopathic pharmacopoeia of the United States, of France or Germany, or any other homeopathic pharmacopoeia legally recognized in any other country in the world, should be automatically allowed to be produced and sold in Canada.

Fifth, any other substance... You will remember the point I made earlier that we are constantly adding to the list of homeopathic products. In addition to those that are currently listed under any kind of homeopathic pharmacopoeia, any other substance should be allowed to be made into and used as a homeopathic medicine in single-ingredient form above a dilution of what we call 12c.

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A dilution of 12c is just above what is called Avogadro's number. Avogadro's number is the theoretical limit of a solution beyond which there is not a single molecule left of that chemical in the solution, and therefore at least technically speaking there can be absolutely no risk of toxic effect. Above that degree of dilution the onus should be on Health Canada regulators to prove that any risk of allowing the use of that substance outweighs the benefits of such use. So the burden of proof would be on the regulators to forbid the substance, as opposed to being on the person who wishes to use the substance to prove it is safe, because above that level, technically speaking, there can be no risk of toxicity.

Finally, homeopathic practitioners should be allowed to import, for their own use and not for resale, any homeopathic preparation that otherwise would be entitled to be produced and sold in Canada or which is imported in a dilution of 12c or higher. This refers to the dilution limit I mentioned earlier. Our view is that such products would not have to carry a drug identification number.

Madam Chairman, although I recognize that strictly speaking it is not within the mandate of the committee, I would like to draw the committee's attention to the unfairness that currently exists in another federal law, and this relates to the law governing the goods and services tax.

Currently there is a discriminatory treatment if a health service or medical service is provided by a homeopath or other alternative practitioner, as opposed to that same health service being provided by a medical doctor. The current GST law and regulations relating to medical services are based on the old medical licensing system that exists in the provinces. These medical licensing systems effectively give a monopoly to allopathic practice, and in most provinces effectively exclude the practice of alternative medicine.

Members of the committee may be aware of a recent court case in the province of Quebec where a homeopathic practitioner was prosecuted for practising medicine without a licence. This is a direct result of licensing systems at the provincial level.

I don't want to discuss that aspect particularly, but I do want to emphasize the fact that federal law, as far as the GST is concerned, is based on this old licensing system. I practice in Ontario, which on January 1, 1994, introduced a unique law that abolished the old licensing system. There is no such thing in the province of Ontario as a licensed medical practitioner, yet federal law, when it applies the GST, applies it on the basis of a licensed medical practitioner.

However, despite the fact that there is no such thing as a licensed medical practitioner in the province of Ontario, a medical doctor is not required to charge his patients GST. Yet as a homeopathic practitioner, and any other natural health care practitioner in the province of Ontario, I am so required.

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This constitutes a discriminatory tax on alternative medicine. It's bad enough, as Dr. Hassard pointed out, that the provincially funded medicare systems—in Ontario it would be OHIP—currently do not allow and do not cover alternative medicine. In fact, they're even cutting back on allopathic medication and medicine. It's bad enough that people generally have to pay out of their own pockets for alternative practitioners, but to accept a discriminatory tax... If someone comes to me for an ear infection, they have to pay GST, but if they go to an MD to treat the same ear infection, they do not have to pay GST.

I just wanted to draw that to the attention of the committee and to ask the committee, if it's within its powers to do so, to recommend that the government amend the GST laws and regulations so that medical service receives the same tax treatment, and ideally that all health services, for the purposes of the GST law, would be zero-rated. They currently receive an exemption, but this exemption is applied discriminatorily. The exemption has the disadvantage of not allowing practitioners to claim rebates on all the products and other things they use in the practice of medicine. If they were to receive a zero rate, they would be allowed to receive a rebate, which is a much fairer approach to the application of the GST.

Thank you, Madam Chairman. I am prepared to answer any questions the committee might put to me.

The Chair: Thank you.

Mr. Hill.

Mr. Grant Hill (Macleod, Ref.): Thank you, Madam Chair.

Thank you for being here today. When we hear individuals with these presentations, I like to ask whether there is a country that is better than Canada at regulating the area each of you represents. So I would ask each of you that question: could you point to the advantages of a specific jurisdiction that we could look to?

Mr. Rudi Verspoor: Perhaps I can start.

To say whether there is a country that is better than Canada—it depends. If you're talking about the regulation of products, the current situation in Canada is fairly tenable, with one exception, which is the ability to use homeopathic preparations that are otherwise prohibited under the particular schedule of the food and drug laws. I'm referring to such substances as cocaine and opium, for example. These are prohibited substances under other laws and cannot even be released in homeopathic preparation, even though, as I indicated in my comments, at various dilutions above 12c, which is Avogadro's limit, there is chemically no such substance left in the product. So technically speaking—

Mr. Grant Hill: So in your view Canada is as good as anyone else, except in that area.

Mr. Rudi Verspoor: Except for that. The best one would be Britain.

Mr. Grant Hill: Time is tight, so I need to get—

The Chair: Each member gets only five minutes for questions and answers.

Dr. Murray Hassard: There are a number of European countries that have much more openness or integration with homeopathy. In my discussion I alluded to England having homeopaths available in hospitals at the patient's request. In India it's sponsored by the state, which ensures much more widespread access. Holland and many countries throughout Europe are using homeopathy. France is using homeopathy in quite widespread approaches. The legislation does vary from country to country, and I hope Canada could use some of these countries as a model.

Ms. Barbara Etcovitch: I would recommend Great Britain and India—Great Britain for the high quality in production of its remedies, as well as the way in which the remedies are disseminated and made available.

Mr. Grant Hill: The one thing that we hear quite often is that preventive is much better than curative, and that's very evident. In those countries that are more advanced in your field than Canada might be, can you point to evidence that there is in fact an improvement in overall health status?

Ms. Barbara Etcovitch: We know that with the cholera epidemic in Great Britain, for example, which was treated both allopathically and homeopathically, there was far less incidence of death for people who were treated homeopathically. That's documented. That's the only thing that comes to mind at this point.

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Mr. Grant Hill: I'd love to get the documentation on that if you could provide it.

Anyone else?

Mr. Rudi Verspoor: There is a lot of literature about the effectiveness of homeopathy, but if your question was on prevention, there have been studies done in France, for example, that show that—and I think Dr. Hassard referred to this earlier—the overall cost to someone for health care over their life is substantially reduced by using homeopathic medicine as opposed to allopathic medicine.

The difference in homeopathy is that we recognize disease at a much earlier stage than an allopath would recognize it, and therefore in that sense it's much more preventative. We don't wait until pathology or tissue change results before we treat for it and accept it as disease.

So in that sense the prevention aspect is quite high in homeopathic medicine, and the overall savings to people in terms of using drugs later on is much greater. Some studies in France have shown a long-term saving of 20% to 30% over a period of 10 or 15 years.

Dr. Murray Hassard: In the Angus Reid survey on health care for Canadians, done in September, 66% of Canadians felt there would be substantial savings to the health care system if alternative therapies were incorporated in the health care system. So it's not only the research from other countries, it's also the perspective and perception of Canadians.

Mr. Grant Hill: Thank you.

The Chair: Madame Picard.

[Translation]

Ms. Pauline Picard (Drummond, BQ): What are the major research laboratories in Canada? Are there any or do you have to import your medicines from abroad, for instance from Great Britain or from India? How does it work? Do you have scientific experts doing research everyday to develop new medicines?

[English]

Mr. Rudi Verspoor: Essentially, research is conducted by homeopathic pharmaceutical companies similar to that for drugs and allopathic medicine. In Canada there are quite a few homeopathic pharmaceutical companies. Most of them originated in France—Dolisos and Boiron. Some originated in the United States and some in England, which historically have been the main areas of production of homeopathic medicines.

As well, research is conducted—but not in Canada as much—by homeopathic hospitals in France, Germany, the United Kingdom, and the United States. In the United States there is a special office for looking at alternative health. It funds research in alternative health, including in homeopathy. Unfortunately, we do not have that kind of assistance yet from the federal government, but it would be nice to have a similar model established in Canada that would provide funding for research into alternative health care, including homeopathy.

Ms. Pauline Picard: Merci.

The Chair: Mr. Myers.

Mr. Lynn Myers (Waterloo—Wellington, Lib.): Madam Chair, I apologize for being late. I had another commitment.

I was very interested in your brief, Dr. Hassard. I scanned it very quickly. On page 4 I think you say that increased complementary health care funding would finally make the Canada Health Act a one-tier health system. Certainly as we move into the 21st century we're looking for ways to make a viable system in a way that makes sense for Canadians.

Could you expand on what you mean there? I understand you want more accessibility to some of the treatments and such.

Dr. Murray Hassard: In the current health care system, if a patient has a health problem—an ear infection was mentioned earlier—you can take him to your medical doctor and go the medical route, but sometimes it's very costly to the system at large.

But you could also treat an inner ear infection with a homeopathic approach. I can speak from personal experience. My daughter had a fever last night—I have an eight-month-old with me here in Ottawa—and I used the homeopathic remedy belladonna to help her fever. That's a personal approach. I find it very inexpensive to use one pellet of belladonna every half hour to treat an ear infection or fever.

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To compare that with other health models using that same ear infection symptom, you'd probably agree that most medical practitioners in Canada would give antibiotics. If you went to the medical community in Europe, you would not necessarily get antibiotics for an ear infection. There's a totally different approach by the medical community. They would give pain killers for four or five days. They would treat the pain of the ear, not the infection of the ear. Here we strongly promote antibiotics, sometimes to the detriment of the child. Antibiotics can be quite harsh on the bowel floor and there can be subsequent infections.

That's where the cost starts snowballing through our current health care system. The homeopathy approach is very inexpensive when it uses a few small pellets for that particular patient. So it's very inexpensive and the savings would multiply throughout the current health care system.

Mr. Lynn Myers: In your view, this is a way to save the one-tier system. Is that what you're stating today?

Dr. Murray Hassard: I'm saying that for a Canadian at large, if they have a child with an ear infection, they can go to their doctor for free or they can pay a sum to a homeopath to be consulted and get a remedy. It's not equal access for that health care choice.

There are great inequities in the system, although the whole goal of the Canadian health care system should be to help that child with the ear infection to settle down.

Responsible Canadians looking at the health care system should look at economical ways of dealing with that, and homeopathy would be one avenue that could be promoted for that.

Mr. Lynn Myers: Thank you.

I have a quick question for Ms. Etcovitch. I think the first time I ever heard India being held up as a model was from you today. Please explain why you said that.

Ms. Barbara Etcovitch: It has a very old tradition of homeopathic medicine and has superb homeopaths who are changing the face of homeopathic medicine on the continent. Because it is so well-established there and the homoeopathic hospitals are relatively available, and it is the prevalent system of medicine in the country, I mentioned it.

Dr. Murray Hassard: And it is supported by the state in India.

Ms. Barbara Etcovitch: Yes.

Mr. Lynn Myers: Thank you.

Mr. Verspoor, do you want to comment?

Mr. Rudi Verspoor: I want to comment on your question about saving the one-tier system. What we currently have within the medicare system is a monopoly by one form of medicine, but what we really need is competition between the different forms of medicine.

In Ontario, this is what is allowed. Although strictly speaking it's not funded, at least at the level of practice consumers are free to choose. If you had competition within the medicare system, given all the different legitimate alternatives, I think people would quickly use that which was most effective, efficient, and economical, and I can assure you that for most conditions the alternative approach is generally much more efficient, effective, and economical.

We do recognize the value of the allopathic system in extreme emergencies, but applying a system that is designed for extreme emergencies to colds and flus and ear infections and things like that is neither efficient, effective nor economical. So in my view it would have the potential of saving the one-tier system.

Mr. Lynn Myers: Madam Chair, my final point is on Mr. Verspoor's point on the GST. Can we have Revenue Canada and/or the health department—I was interested in this comment about it being a discriminatory tax on alternative medicine.

The Chair: We'll ask them to look into it.

Mr. Lynn Myers: I'd like to get the background on that, either from Revenue and/or Health or the researchers.

The Chair: Okay.

Do you want to add something to that?

Ms. Carolyn Bennett (St. Paul's, Lib.): We'll ask the CMA as well.

Mr. Lynn Myers: I think it's a good point and I would like to explore it.

Mr. Rudi Verspoor: Perhaps I could comment on that, given your comment that you'll ask the CMA.

My understanding was that at the time the GST was introduced, the CMA was given the option of having the GST zero-rated for health services or being exempted from the GST itself. For some reason they chose to be exempted, which has created a number of problems, but it also is discriminatory vis-à-vis the alternative practice thing.

The Chair: Ms. Bennett.

• 1005

Ms. Carolyn Bennett: I'd like to thank you all. I think your presentations have been extremely helpful. We've been inundated with the problems, and we welcome the panels that come with recommendations and solutions. Thank you.

I need to ask what you think the role of government needs to be. Certainly in Ms. Etcovitch's presentation, where the word “restricted” is used...and I guess I need to know what you think the role of government is. We are hearing that homeopathic medicine is clearly not a food. It's been made difficult by characterizing it as a drug. There is a call for this third category.

Last week the ayurvedic medical people were maybe calling for a number of different categories where people who know a lot about it get to do the peer review. Would that be something you would agree to? If there was a third category that was subdivided with people who knew a lot about that area, looking after their own area, is that something you would feel comfortable with?

As well, now that we have homeotherapy at Shoppers Drug Mart, there seems to be... Again, I want to know what you feel in terms of restrictions, because within your own category there may be things that you feel people would be fine with—good labelling to buy over the counter, self-diagnosing and self-prescribing, and other things you would feel more comfortable seeing people use only on the advice of a practitioner.

Ms. Barbara Etcovitch: Part of the problem is the actual word. Homeopathy has to conform to a system of principles and philosophy. Not every product that is diluted and succussed is homeopathy.

So I think that's where we start. The actual word has to be changed so that it reflects the system.

Beyond that, I think it's very important for us to work together to have homeopaths work in conjunction with government to iron out the various problems so that the consumer knows exactly what he or she is getting and knows how to use it properly for whatever products are on the shelves.

In terms of where does government fit in, I think it has to work with the practitioners in order to create a regulatory system of some type.

Dr. Murray Hassard: Your suggestion that was discussed with the ayurvedic practitioners is an excellent one. Mr. Hill's proposal about getting a supplement category is an excellent one, to subdivide, somehow, as you mentioned, into hierarchies where homeopathy could keep an eye on the supplement version, a third subdivision. So you have food, drug, and supplement, for lack of a better word.

Ms. Carolyn Bennett: For natural remedies.

Dr. Murray Hassard: Natural remedies could be subdivided by ayurveda or homeopathy. That would be an excellent way to deal with this dilemma of the missing pigeon-holes for it to fit into.

Mr. Rudi Verspoor: To answer your question on what is the role of government, my position basically is the same as at the level of the profession in the province, that there should be a minimal role for government. That's not to say there should be no role for government. The role for government really is to legislate in the interests of the public, to prevent harm. Clearly, any restrictions that would be placed on homeopathic preparation should have that in mind.

The idea of a third category, or subdivisions within a third category, is certainly acceptable. I disagree with Ms. Etcovitch in the way that what we're talking about here is products, not the practice of homeopathy. No product is in fact homeopathic, strictly speaking, unless it has actually been given on the basis of a homeopathic principle. What we are talking about is products prepared in often homeopathic form, for want of a better term. That means diluted and succussed and potentized, as we call it, in a certain way.

Basically, the role of government should be to prevent harm, and in most homeopathic preparations there is no harm. There should be advice from professionals from the profession with the government in terms of establishing any specific regulations, but certainly within law there should be a third category, at a minimum.

Ms. Carolyn Bennett: Obviously when there is belladonna in something, or strychnine, or arsenic, or the things that obviously in an overdose situation, particularly in kids...we need some protection or some awareness.

• 1010

Mr. Rudi Verspoor: Yes. In most countries—and we agree with this, and this is the way it's currently applied—any dilution below one part per million would be considered not safe, could not be sold over the counter, and often cannot even be given out to practitioners. In France, Germany, the United States, the United Kingdom, those countries, anything above a dilution of one part per million is considered safe, and they're not restricted.

Ms. Barbara Etcovitch: I have to comment on that, because any dilution can cause a proving. If a lay person is repeatedly taking a remedy regardless of dilution, although the lower dilutions have a tendency to be proved more easily, they can result in a proving.

I had somebody walk into my office having taken Thuja 30c every single day for a year. Now, that can result in a proving; it can result in confusion of cases; it can result in suppression.

So the unguided consumer is at risk, and if you want to use the word “harm” in its loosest sense, there is that risk of harm, because we're dealing with a substance that influences deep levels of energy in the body, and it requires follow-up and care. We have to, I think, therefore redefine “risk” and “harm” in terms of the homeopathic remedy.

The Chair: I think we'd better stop now.

Mr. Elley.

Mr. Reed Elley (Nanaimo—Cowichan, Ref.): Thank you, Madam Chair.

A number of presenters who have come before us have suggested that we need a fairly major shift in the way we not only deliver health care services to people, but also in terms of education and preparation for people who are actually in the field.

Mr. Verspoor, you used the term “competition” a few minutes ago. I'm wondering if you'd like to elaborate a little bit further on that, in light of the fact that a number of these folks have used the word “complementary” rather than “competition”, and have gone as far as to talk about integration of conventional medical training with complementary forms of medical training. What would you suggest along that line? Did you really mean competition, or did you mean—well, I'll let you answer the question.

Mr. Rudi Verspoor: Thank you. I don't see any contradiction between the terms “competition” and “integration”. I mean competition between competing medical approaches or philosophies and the treatment of conditions.

Within a practice, and the practice of medicine generally, there can be complementary approaches and there can be integration, so if a medical doctor wishes to use homeopathy or wishes to use ayurvedic medicine or acupuncture, that would be entirely an integration approach.

However, the doctor himself would in effect be allowing within his practice the competition between antibiotics, let's say, and homeopathic medicine. The doctor would decide in which particular circumstance he or she might feel one or the other would be appropriate. But there would be a competition, at least at the level of systems and approaches, and I think that's where the most efficient and effective method would be used.

Currently, or until recently in Ontario, when the Ontario College of Physicians and Surgeons opened the door a little bit to alternative practice, if a doctor chose to treat an ear infection using a homeopathic preparation, for example, he could be brought up before the College of Physicians and Surgeons for malpractice, for having breached the ethics of the profession. This is not competition. This is in effect a monopoly of one particular approach over another.

So I'm talking about competition in terms of the most effective approach. But that's not to say that there can't be integration and complementary approaches by practitioners themselves.

Mr. Reed Elley: At the present time, I may go and consult my GP for a certain health problem, and also of course go and talk to my homeopathic practitioner about the whole situation. Is it unrealistic to think that perhaps 15 or 20 years from now it might be possible for me to go to one person, who has had training from a recognized college in all of these areas, and that the one visit will help me?

• 1015

Mr. Rudi Verspoor: It's not unrealistic. It's something that would be ideal, but it would be very nice to work towards. There's no reason why the different approaches can't work together. There are some differences that would prevent a complete collapsing of everything into one system, of course. Definitely that would be the ideal, though—that your family practitioner would have access to all of these different techniques and be able to decide to some extent which one to use or which one not to use. There's no reason why it couldn't happen.

Mr. Reed Elley: Would anyone else like to comment on that?

Dr. Murray Hassard: Yes, I would. I'm a multi-practitioner practitioner. I am a chiropractor, a homeopath, a homeopathic instructor, and I'm currently studying herbal medicine at Mohawk College. So I'm trying to understand the full spectrum of health.

When a patient comes in the door and says, “I've got a kink in my neck, I would like you to adjust my neck, I want my headache to go away”, sometimes I feel a homeopathic remedy might be appropriate and sometimes I feel an adjustment might correct the mechanical fault. I find that a very difficult challenge amongst those two brethren health care approaches. I couldn't imagine how difficult it would be to be the medical doctor, also trained to adjust, also trained to give out homeopathic remedies, also up on the current drug CPS medical listing and the homeopathic pharmacopoeia. From a personal perspective, that would be quite a challenge and would take a herculean effort.

I think a more workable model would be to have open doors. In a sense the medical community, because it has discouraged alternatives... You've probably followed the court case of Dr. Krop, who's being called up. He's a medical doctor practising homeopathy without a licence, or practising naturopathy without a license. Anyway, he's under a judicial review.

Up until recently the doors have been shut, and I think the medical community has missed an opportunity to be a gatekeeper to the true health care system. Say somebody comes in to see their GP. If your headache is caused by a kink in your neck, a subluxation to your neck that needs mechanical adjustment by chiropractor, I would love to think that your medical physician would send you to a chiropractor down the road, or to a homeopath to treat a headache. But likely as not, up until just recently it wasn't even an option considered.

Certainly a retooling of the whole system would have to take place for your goal to be achieved. That would be wonderful.

Ms. Barbara Etcovitch: May I answer as well?

The Chair: Just a short answer, please.

Ms. Barbara Etcovitch: The differentiation has to be made between seeing the symptoms as the illness, i.e. the headache as the problem, and treating the patient, which is the basis of good, classical homeopathy.

Suppression can be caused by many things. It can be caused by a manipulative therapy in terms of a homeopathic case. It can be caused by a herbal. It can be caused by anything. As a purist of classical homeopathy, I address the person, not the illness.

These systems, which may have a wonderful effect in their own right—and I have no comment on people choosing whatever form of health care they want—can cause a problem in a homeopathic case. That is my only concern. So whether or not these systems can be integrated into one system—I don't see that, as a classical homeopath. Certainly one system will be more effective, or a certain person would be more inclined towards one therapy than another, and that is a choice they must have. But in terms of classical homeopathy, it is seen as a very, very unique and very detailed and very intricate system, and in that respect I see a problem.

Mr. Reed Elley: Thank you.

The Chair: Thank you.

[Translation]

Mr. Drouin.

Mr. Claude Drouin (Beauce, Lib.): My first question is addressed to Ms. Etcovitch.

You were talking about surveillance of marketing. I would like you to elaborate on that. Then I'd like to have everyone's comments on labelling. It seems that labelling is not standard for homeopathic products. Many people are taking these products rather half-hazardly. They get a quick explanation of these products and they carry them away with unbelievable confidence. After a week, you ask them what they're taking and they have no idea, but they say that it's probably good for them.

I'd like you to elaborate on that, please.

• 1020

Ms. Barbara Etcovitch: I would like to reply in English, if possible.

[English]

The Chair: No problem.

Ms. Barbara Etcovitch: It is a problem of marketing. Yes, the labelling is inconsistent, and people do walk away believing they are doing good for themselves. This is a problem.

How do we address this? First, by categorizing the different forms of diluted substances. I think that's very important. Second, by providing additional information on each of the products, and perhaps having in-store consultants or a much stricter form of marketing, a very strictly classified form of marketing.

Whatever it is, I think it is a big problem, and it certainly has to be addressed. The inconsistencies have to be addressed. Some of them are sold right on the counter with very general marketing, and some of them are sold through pharmacists, or pharmacists are available to provide information to the person seeking the homeopathic remedy. The inconsistency is there.

Whatever it is, as it exists now, it's certainly inadequate, but it is the marketing. I think the marketing has to be restricted and curtailed immediately in some respect so that manufacturers do not have free rein in throwing all kinds of products on the market.

The Chair: Does anybody else want to respond to that? Dr. Hassard.

Dr. Murray Hassard: In Bill C-307 Mr. Grant Hill has an excellent amendment to the advertising:

No person shall sell any food or drug

—with I hope the new addition of “or supplement”—

that has been determined to be potentially harmful to human beings, or any cosmetic or device.

The labelling should be permitted if it is truthful and honest and if benefits have been utilized by that remedy. The difficulty is that some homeopathic remedies, such as headache remedies, also might be beneficial in many other treatments. That does confuse the patients. I would like to be able to say this remedy has been proven helpful for people with headaches, or for people with gall bladder problems, or for people with diarrhea. I would like to be able to state that in a truthful, honest way, and that should be encouraged by the government.

The Chair: Mr. Verspoor.

Mr. Rudi Verspoor: The issue of labelling really only arises if someone wants to make a claim. If you are simply producing a homeopathic product as such, and you make no claim for it, then the only labelling you have is the name of the product and the strength or dilution or whatever. The labelling problem arises when you make a claim that this particular product is good for this particular condition.

As was pointed out by Dr. Hassard, with homeopathic preparations the difficulty is that one product may be used across a wide range of conditions. It's very difficult to identify which one. It may be headaches but it may be a whole range of other things.

Homeopathic pharmaceutical companies across the world, including in Canada, commonly provide what they call combination remedies. These are remedies that have a combination of different ingredients in them that are generally recognized as being possibly of some use in particular conditions. They will say this is a combination for headaches, or a combination for stomach acid, or for nausea or whatever.

The current regulations as they exist, in our view, are okay. From a strictly homeopathic practitioner point of view, we don't tend to use those forms of combination remedies. But from a consumer protection point of view, there is no harm, generally speaking, in those products.

Like any product, anything can be abused. If I drink 12 glasses of carrot juice a day, I'll get sick, but you don't want to restrict the use of carrot juice. It is quite clear that you have to depend on a reasonably educated consumer, but I think for most people today, you can depend on that fact. Anything can be abused, in that sense.

From the point of view of the proper role of government, as it's pointed out there, it would be to prevent harm, and there is effectively no harm from these combinations and the way they are regulated under existing regulations. I don't have any particular problem with that.

• 1025

The Chair: Thank you. Mr. Volpe.

Mr. Joseph Volpe (Eglinton—Lawrence, Lib.): I'm sorry I missed the presentation itself.

I want to pick up on something you said, Dr. Hassard, in response to one of my colleagues. I have a couple of questions. If the committee, if the general public, resolves the issue of labelling of products so that we ensure the quality, the consistency, and the integrity of the items themselves, first, is that a sine qua non for you to have your own credibility established?

Let me repeat myself differently. You're prescribing products that currently are—can I be diplomatic?—suspect by virtue of the lack of consistency of quality.

Dr. Murray Hassard: That's not true.

Mr. Joseph Volpe: I mean, this came from your response. You acknowledge that there are some problems with the integrity of the products because—

Ms. Barbara Etcovitch: I can answer that.

Mr. Joseph Volpe: Did I hear you correctly, then?

Ms. Barbara Etcovitch: Yes. Absolutely. There is a tremendous differentiation in the quality of homeopathic products and in the results thereafter.

I have seen dead products on the shelves. I've had patients I've prescribed a particular remedy pick one up, for example, over the counter because it was more convenient. It doesn't work. I know the prescription is right. I give them my higher-quality remedy. It works.

So there is certainly an inconsistency in the production of homeopathic remedies. For example, as classical homeopaths, we have preferred to go to laboratories for our products.

Mr. Joseph Volpe: Don't take my question as an inimical approach. I'm just trying to get at a particular problem.

The panel has suggested, in response to some questions, that products that have ingredients that are not very good for the patient, no matter what the product is, ought to be essentially taken off the shelf or be more rigorously monitored. That's what I've derived from the responses.

Now, if in fact this kind of rigour is applied or imposed to the satisfaction of those who prescribe such products, does it then follow that the prescribers of such products, or the practitioners of therapies that lead to the consumption of such products, acquire a legitimacy equal to any other system?

Ms. Barbara Etcovitch: An interesting question.

Mr. Rudi Verspoor: First, I'd like to make the point that although the system is by no means perfect, and the problems Ms. Etcovitch referred to definitely do exist, there are current standards applied. There are current good manufacturing practices applied to homeopathic pharmaceutical companies that are equal to, or tougher than, those applied to drug production. So the standards are there. Whether they need to be applied more carefully or more consistently is another matter.

To answer your other point, yes, we do depend on the integrity of our products in order to practice our profession. To us, good manufacturing standards and quality control is very important. However, the integrity of the profession has not totally caught up with the quality of the product. It has a lot to do with the legal standing. That is really a provincial matter.

In Ontario, we have equal legal status as homeopathic practitioners to allopathic physicians, but that is not a function of the quality of the product. How effective we are definitely is a function of the quality of the product. So it is important.

Mr. Joseph Volpe: To address the question you raised earlier on about breaking the monopoly of allopaths in the delivery of a medical service system—I was going to use the word “industry”, but I caught myself just in time—you're not looking to this committee to make a recommendation to provincial authorities that homeopaths and naturopaths be brought in under the aegis of the CHA.

• 1030

Mr. Rudi Verspoor: I am not specifically making that request, simply because I understand it's not within the mandate of the committee. However, I would love it if the committee could make a recommendation that the model applied in Ontario, which is unique in Canada, unique in North America, under the Regulated Health Professions Act, be applied in all the provinces such that there would be consistent treatment, under the Canada Health Act, in effect, for alternative practitioners.

In Ontario, the way the law works is that the government says that all forms of medicine are legal, but the government will only regulate—that is, restrict—those forms that represent a significant risk of harm to the public. The only forms of medicine that currently are regulated in Ontario are allopathic professions, which ironically means that the allopathic professions represent a significant risk of harm to their patient, and therefore, in the public interest, need to be regulated.

This is not the case with homeopathic medicine. We do not represent the same risk of harm. However, we have the same legal status to practice in Ontario.

Mr. Joseph Volpe: Let me ask you a question a typical patient/client might ask. What does it mean for me as a patient when I come to a homeopath or someone who is not an allopath and ask for diagnosis and then service? Does it mean I pay you, or does it mean the practitioner is part of the system that pays for the service I require?

Mr. Rudi Verspoor: Certainly, if you ask for a diagnosis, legally I can't give you one, because that is a restricted act under the law in Ontario. Second, yes, you would have to pay for that service unless you had an extended health care plan, which would pay for those services. Some extended health care plans, such as the one in the federal government and the provincial government and various large corporations, do cover—

Mr. Joseph Volpe: Those are private plans.

Mr. Rudi Verspoor: Those are private plans, yes. OHIP does not cover homeopathic services.

Mr. Joseph Volpe: So when we're talking about breaking a monopoly, are we also trying to break that particular...? We are.

Mr. Rudi Verspoor: Yes.

Dr. Murray Hassard: I find that health care savings can certainly justify encouragement of policies that would support alternative therapies. In one of my discussions I alluded to the chiropractic research, where the Government of Ontario commissioned research where they could save...direct cost to OHIP being approximately $548 million per year if chiropractic were included. That's just one of the complementary health care systems that could be integrated in saving health care resources, saving the medical model itself.

Mr. Joseph Volpe: If you can't diagnose—and I'm speaking now as a patient—because it's one of those restricted activities, just what is it you do when I come to you and say I don't feel well?

Mr. Rudi Verspoor: I can't give you what is called an “allopathic diagnosis”. I cannot use the term that is devised by the allopathic system. However, in the homeopathic system...

Mr. Joseph Volpe: But you can examine me.

Mr. Rudi Verspoor: I can examine you, but the homeopathic system of medicine has its own diagnoses, very different from the allopathic system.

What is restricted, then, is the allopathic diagnosis. I can still diagnose and treat homeopathically. That is not restricted.

Mr. Joseph Volpe: You'll do what my GP does. You'll take a look at my tongue, look at my eyes, look in my ears, feel my pulse, and take my temperature. You won't do those things?

Mr. Rudi Verspoor: Generally speaking, in a homeopathic diagnosis you don't need to do those things. You may or may not, depending on your background, but you don't need to do those things.

The homeopathic method of diagnosis is very different from the allopathic one. It does include some elements of it, but there are also many elements that are very different.

Dr. Murray Hassard: As a practitioner, I'm a chiropractor as well as a homeopath. With my one hat, I'm allowed to diagnose, and with my other hat, I'm not allowed to diagnose. I'll tell you how that works.

In Ontario there is the healing arts regulated professions act of 1994. Five professions are legally entitled to diagnose—chiropractors, medical doctors, dentists, veterinarians, and psychiatrists. Those are the five professions that are given the ability to diagnose. These are the health care resources such that you can open the phone book, call them up, get an appointment, and go and see them. You don't need a referral.

• 1035

For example, physiotherapists don't have an ability to diagnose, because they are secondary care. These five types are primary care.

If you came in to see somebody with an inner ear infection—otitis media is the medical designation—a homeopath would sit down, in the first consultation, and take about an hour to find out how long it has been there and to get the patient's description of it. It's not just the ear infection but how long it's been there, the history—what aggravates it; whether it's worse in the morning or the afternoon; any problems associated with balance, which the ear, of course, can influence; how is the vision, the throat, the muscles, the stomach, the bowel movements. This is careful patient assessment, and I don't think your doctor would do that. I don't think a doctor would necessarily spend an hour on that ear infection on that first visit.

So it's a slightly different way. It's interactive with the patient, getting patient history of the total symptom pattern. We call it the “totality of symptoms”, and try to get a complete description.

Once we have all the symptoms matched, if there is a remedy that matches that presentation... For example, for the inflamed throat that accompanies your inner ear problem, the bit of tonsillitis associated with it, then a remedy such as belladonna, which is recommended, might be the one that is more applicable in your case.

The next patient that comes in with an inner ear infection may not get that same remedy, because the symptom pattern might be totally different. So it is taking a look at the individual case assessment, at the totality of symptoms.

The Chair: Do you have another question, Mr. Volpe, or can we move on?

Mr. Joseph Volpe: I will save it for the CMA when they come. I see them ready.

The Chair: Okay.

Thank you very much for coming.

We will take a break now.

• 1037

• 1049

The Chair: I call the meeting back to order. For this part of our meeting, we'll hear from the Canadian Medical Association through Dr. Dirnfeld and Dr. Carter, and from the Chinese Canadian National Council we'll hear from Jonas Ma.

We'll just go in the order we have here, so we'll ask the Canadian Medical Association first—Dr. Dirnfeld.

• 1050

Dr. Victor Dirnfeld (President, Canadian Medical Association): Thank you very much, Chair. Good morning to you all. As president of the Canadian Medical Association and as a practising physician—I do internal medicine as a consultant in my home province of British Columbia—I'm very pleased to appear before this standing committee to present our association's recommendations in respect of a regulatory framework for national health products.

The CMA's mission is to provide leadership for physicians and to promote the highest standards of health and health care for all Canadians.

On behalf of the Canadian Medical Association, I commend the Standing Committee on Health for addressing this important issue. The physicians of Canada are well aware of the increasing use of these products—natural health products—and believe that their regulation is critical to the overall health of Canadians.

Our association recognizes that the use of natural products to promote health has a very long tradition and has contributed empirically to the health of humans over many millennia. There are numerous examples of natural products that have received wide usage, including salicylates for the relief of pain and fever, in the form of willow bark; quinine that was used for malaria; and possibly digitalis. I will entertain questions later about the “possibly” digitalis for heart failure.

The report of a recent survey of the Canada Health Monitor, carried out in June and July of 1997 with a sample of over 25,000 Canadians, noted—and you've heard figures like this before; I've read some of the submissions to you—that 37% of Canadians reported that they were taking at least one complementary remedy other than vitamins. The results also stated that almost 9 out 10 Canadians do want government to require manufacturers to provide information on the active ingredients of each product, the purposes of the product, and in particular its safety and side effects.

Of concern to Canadian physicians is the observation in this survey that 46% of complementary remedy users reported in the Canada Health Monitor do not discuss this use of these remedies with their physician. The potential for problems with interaction and complications—and I had personal experience just recently with this—is very, very significant.

We recognize that many of our patients wish to continue this long tradition and use natural health products in their self-care. They are autonomous, they want choice, and they want to continue or embark on such remedies.

Moreover, our association recognizes that this trend will likely continue in response to increased public information and awareness about health issues and self-care. So many people are on the Internet. So many people go to libraries. So many people read the public media about such items.

While the CMA is not in principle opposed to the use of these products, we wish to work with our patients in promoting their most appropriate use, and of course avoiding inappropriate use and bad outcomes.

It must be recognized, however, that natural health products—and I can give you some very stunning examples—like all drugs and other therapies, can be a two-edged sword, bringing both benefits and risks. Therefore, the CMA proposes that a regulatory framework be developed that will maximize the benefits of these products while minimizing their risks.

To this end, the CMA proposes the development of a regulatory approach based on three pillars, and those are safety, quality, and efficacy—that these agents are safe, that they are pure to the greatest extent possible, and that they work. Such an approach has served the Canadian public well as it's been applied to pharmaceutical products and medical devices and should serve equally well with natural health products.

In addition, the CMA believes that the principle of fairness must be applied to the regulatory process so that natural health products are treated fairly in comparison with other health products.

So the CMA's first recommendation is that a regulatory approach be developed based on risk assessment—and we can speak of that later—and the development of standards for safety, quality, and efficacy.

The same regulatory standards should apply to both natural health products and pharmaceutical health products. These standards should be applied to natural health products regardless of whether a health claim is made for the product.

• 1055

Our second recommendation is that the regulatory system be applied to both pre-marketing regulatory review and post-marketing surveillance.

Our third recommendation is that a series of standards be developed for each natural health product, and they should include at least two aspects: first, manufacturing processes that ensure the purity, the safety, and the quality of the product; and second, that labelling standards include standards for consumer advice, cautions to consumers, claims made for the product, and explanations for the safe use of the product to the consumer.

All labels should advise the consumer to inform their health care provider during any encounter that they are using this product. The consumer should be encouraged to communicate this use, even though it may not seem relevant to the consumer at this time.

The CMA's views about the development of regulatory standards for the labelling of natural health products are consistent with its approach to labelling for non-prescription over-the-counter pharmaceutical products. Consistent with this approach of risk reduction, the Canadian Medical Association's recommendations related to natural health products have the overall objective of ensuring a high degree of public safety.

Our fourth recommendation is that methodological standards be set for the clinical studies used to support health claims made by natural health products. This is imperative so that consumers can be assured that such health claims are valid. It almost goes without saying that it is the responsibility of the proponent of that health claim, the purveyor of that remedy, to provide the scientific evidence in support of the claim.

The CMA believes that the expert advisory committee on natural health products, whose brief we have read, should be given the task of developing these regulatory standards in consultation with interested stakeholders.

The advancement of scientific knowledge about natural health products must be encouraged. The provision of more information to both consumers and health care providers will facilitate the safe and effective use of these products and maximize their health benefits. But all of this must have a foundation in science and evidence, not in tradition, not in the fact that they have been used for hundreds of years. That approach is fraught with danger, and I can elaborate on that subsequently.

Fifth, in order to encourage research that is necessary to advance knowledge, the CMA recommends the government develop innovative methods to grant market exclusivity for new natural health products for a limited period of time to any manufacturer that invests resources in the development of knowledge about the product it markets.

Finally, the CMA believes it is of equal importance that an education process be undertaken in order that both consumers and all health care providers are better informed about natural health products. We take this last recommendation seriously, such that we have established ourselves as a leader in the area of enhancing drug therapy. Recent work by our association includes recommendations favouring consistent information to the patient by physicians and pharmacists using the same database for counselling, and physician and patient access to quality drug information.

As evidence of its commitment to the provision of optimal drug therapy, the Canadian Medical Association has worked closely with groups such as the Canadian Pharmacists Association, and it has recently developed a joint policy statement with this association to further this goal. This joint statement highlights the need for the patient, physician, and pharmacist to work in close collaboration in partnership, each in their area of expertise and competence, to achieve optimal drug therapy. A copy of that position has been appended to our brief to you.

As one of our priority projects, the CMA is presently exploring the development of a drug information database for physicians, other health professionals, and the public, to be made available on the CMA website. We already have in print several editions of a comprehensive manual for lay people and physicians entitled Drugs of Choice. It comprehensively discusses pharmaceutical agents that are now available. Plans for the CMA website database include information about herbal remedies and homeopathics.

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In summary, the CMA believes the present regulatory system of natural health products is inadequate. Regulations and standards must be put into place to ensure that the public has the option of informed decisions on the use of natural health products that are safe, of high quality, and do not carry health benefit claims that are false.

Thank you.

The Chair: Thank you very much.

Mr. Ma.

Mr. Jonas Ma (Executive Director, Chinese Canadian National Council): Thank you, Madam Chair.

Members of the standing committee and ladies and gentlemen, thank you for this opportunity to speak to you about the concern of the Chinese Canadian community as consumers of Chinese herbs and herbal products.

Our council was formed in 1980 to promote the equal rights and full participation of Chinese Canadians. We currently have 30 chapters from coast to coast and we actively participate in the development of public policy that affects our community.

The purpose of my being here today is to bring to you the concerns of our community as consumers of Chinese herbs and herbal products, as the government is looking into how the Chinese herbal industry should be regulated. I would like to start by saying that any health system is ultimately accountable to the people it serves. The Canadian population has become increasingly diverse, with different health beliefs and practices. The system cannot remain monolithic, but must provide consumers the freedom to choose among alternatives.

Our council is a member of the National Supporters of Chinese Herbs and Herbal Products Action Committee, and as a member we are committed to defending our community access to Chinese herbs and herbal products, as well as our rights to an effective health care system that has proven effective for the last 5,000 years. Our rights are threatened under the current biomedically based regulatory system, as a large number of these products will be classified as illegal.

We often hear that regulations are introduced and applied to protect the public's health and consumer's right. However, without a clear understanding of what is being regulated, the application often ends up doing the exact opposite. This seems to be the case with our current regulatory system regarding Chinese herbs and herbal products.

What is traditional Chinese medicine? Let's start by looking at it. Despite the increasing popularity of some practices of traditional Chinese medicines, they are often treated as an appendage to biomedicines by the public health system. Their inherent theories and conceptual frameworks are often ignored or rejected. The whole unique system of concepts and practices of traditional Chinese medicines has not been truly accepted as an alternative to biomedicine. This is where the fundamental problem lies.

Regulating traditional Chinese medicines without understanding and recognizing its uniqueness and the incommensurability of the system is like throwing the baby out with the bath water. It is important that we start with a respect and open-mindedness that this is truly an alternative. After all, traditional Chinese medicine is based on practical experiences accumulated over 5,000 years with proven results and is actively used by one-quarter of the world's population.

In traditional Chinese medicine, health depends not only on the proper functioning of individual body organs and systems, but more importantly on the balance of various integrated systems and the unobstructed circulation of blood and inner vital energy. Illness often results from the imbalance of these systems. Therapeutic interventions focus on restoring the balance and the free flow of vital energy. Chinese herbs and herbal products are used for these therapeutic purposes. However, more often they are used to prevent illness by maintaining the balance of body systems. So in traditional Chinese medicines, herbs or a combination of herbs are prescribed to clear heat, replenish yin, or suppress fire.

These concepts probably sound very strange to those of you who are not familiar with them. They are totally alien to biomedicine, and the therapeutic quality of these herbs will not be demonstrable in a laboratory setting, as required by our present regulatory system based on biomedicine. This is not only impractical, but highly unfair. This is like applying Christian ideologies and norms to judge the behaviour of Buddhists. Because of ideological bias, Buddhists' behaviour will never be understood.

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We talk about public health and safety. Let's look at what is really at stake. Public health and safety are often cited as reasons to regulate the Chinese herbs and herbal products. However, today we have not seen any evidence that herbs and herbal products by themselves pose a danger to public health. Many of the alleged risks are grossly exaggerated. There have been some isolated incidents of misuse or abuse, but these are no different from the misuse or abuse of any substance.

The Chinese Canadian community has used Chinese herbs and herbal products for most of its 135 years of history in Canada. There has never been a public health and safety issue in the community. If there has been, why did the government not look into the problem until now?

What is really at stake for the consumers is whether the Chinese herbal industry will be regulated out of existence and driven underground. This is the case in the U.S., where consumers pay much higher prices and sometimes receive bogus products. We must not let that happen in Canada.

We agree that some standards and regulations need to be set up to deter unscrupulous business practices and protect the interests of the consumers. These standards and regulations, however, must be based on an understanding of and respect for the theories and practices of Chinese traditional medicine.

The Chinese Canadian National Council urges the government to set up a separate regulatory system for traditional Chinese medicine to ensure that the unique traditional Chinese medicine theory and practices are respected and treated as an alternative to biomedicine.

Second, we recommend that staff be trained to become knowledgeable about Chinese traditional medicine.

Third, we recommend that the input of experts on Chinese herbal medicine, such as the Chinese herbal industry, community organizations, and consumer groups, be invited to guide the development of new standards and regulations for the industry.

Fourth, we ask that access to Chinese herbs and the herbal industry not be denied.

Thank you very much.

The Chair: Thank you very much.

Mr. Elley.

Mr. Reed Elley: Thank you, Madam Chair.

I want to thank all of you very much for coming and being part of our study on this whole question.

I am interested in some of the comments that Dr. Dirnfeld has made, and I would like to give him an opportunity to elaborate on some of them. We of course have heard from many people, and sometimes we get some contradictory testimony that we have to sort through.

You, I think, Dr. Dirnfeld, are zeroing in on the whole question of safety as it affects natural health products. You said you had some examples, from your experience and that of your patients, that you would like to share with us about natural health products. I'd like you to comment on it a little further.

Also, on page three of your submission you talk about the establishment of a database, which is being used now by both physicians and pharmacists. I presume this is mostly used for pharmaceuticals. Does it also, however, include information on the use of natural health products and any kind of consequences that might occur when a natural health product is used in conjunction with an antibiotic or any other kind of pharmaceutical? Perhaps you can elaborate on that and give us some of your concerns in this area.

Dr. Victor Dirnfeld: Thank you.

I'd like to answer the second question first. The database, with respect to natural health products, is currently being developed. We're trying electronically to accumulate information based on evidence, on pharmacological data, and on chemical data, so that when there is a particular kind of agent, whether it's echinacea, ephedra, or any of the host of natural remedies, we know what the active ingredients are and what class they fall into in terms of their action in the body. What is their biochemical function or interaction? Do they have some enzymatic activity or blocking activity? Do they affect the autonomic nervous system? These are all well-established, scientifically based, physiologic and pharmacologic concepts and have been demonstrated to be almost absolutes in terms of our understanding of the human body, its function, and the intricacies of its function.

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So to the extent that there is information available based on evidence about these agents and their active ingredients—that's what we're trying to put together so that practitioners, whether they be pharmacists, nurses, physicians, other allied health practitioners or members of the public, can get an understanding and knowledge of what they are ingesting into their bodies or spreading onto their bodies.

In a recent review, only two herbal remedies were found to have been subjected in the international literature—some of it non-English, which was translated for the reviewers. Only two agents were shown by scientific studies to have evidence of active merit. One is St. John's Wort, which has been used for depression, and the other is a concoction of herbal teas that has been used in childhood eczema—skin rashes. It turned out to be effective—it was discovered in England—but like other remedies, when it was looked into, it was discovered to be severely hepatotoxic. It damaged the liver and caused serious injury to the people who used it. Those are the only two natural or herbal remedies in the literature that have been scientifically investigated and demonstrated to be of benefit.

So we would look on a scientific base to be able to explain to consumers and to practitioners what exactly is in these herbal remedies. What are the active potions—senna, casgara, digitalis, and all those things? Put that in the base.

Mr. Reed Elley: Some of the presenters have indicated to us that they think there's a double standard in terms of how stringently Health Canada and the Health Protection Branch want to sort of go after herbal remedies, as opposed to what they say are flagrant abuses within the system about pharmaceuticals. In your experience, have you ever had pharmaceuticals withdrawn that have been shown to produce bad side effects and cause death?

Dr. Victor Dirnfeld: Absolutely, and this is central to what we're talking about. I'll give you several examples in a moment. I agree there should not be double standards. There should be a standard—that's the whole thrust of our thesis. There should not be a separate way of judging natural products or herbal remedies as opposed to pharmaceutical products.

Let me give you some examples of drugs that had to be withdrawn. I had the personal experience in 1961 of giving my wife, who was then pregnant with our eldest, a sedative. At the time I was an intern in St. Boniface Hospital in Winnipeg. As some women in pregnancy do, my wife had difficulty with sleep. A product came onto the market that was shown to be very effective in inducing sleep, but without any hangover effect the next day. It didn't make people fuzzy, so I administered it to wife. I gave it to her on the basis of the then available literature in Canada. To my horror, within a month that drug was shown to have caused severe carcinogenic effects in children, in newborns. They were born without arms and legs. That drug was called thalidomide and the disorder was called phocomelia. That information was available in primate studies in Europe, and there was some emerging information about that in humans in Europe, but it had unfortunately not come across to Canada.

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That drug, as you obviously know, was withdrawn. It is now being reintroduced for people in whom it cannot have that possible effect, and that is in those with advanced cancer—people who are not pregnant—for whom it has a beneficial effect.

As another example, I worked for a long time as the director of the diabetic day service for my hospital for about twenty years. I became aware in the literature about a better drug that was being used for diabetes. That was called Phenphormin DB. As a side effect, it produced lactic acidosis—and Dr. Bennett is familiar with this—and the potential for causing death in diabetics. It was a pill for diabetes.

I stopped using it shortly after I began to read those reports, and I began to speak widely on its being withdrawn from the market. However, it wasn't until the experience of very substantial adverse effects occurred that the drug was withdrawn. I am thankful to say that our threshold, our sensitivity for withdrawing drugs that are shown to produce bad effects, has now increased.

The third quick example is phenacetin, which used to be in the old 222s and APC. It caused damage to the kidneys. Portions of the kidneys were actually sloughed off and excreted in the urine. That drug has also been withdrawn.

Mr. Reed Elley: What about herbal remedies?

The Chair: You're way over.

Mr. Reed Elley: I would like him to comment on herbal remedies, though.

Dr. Victor Dirnfeld: Well, that's the problem. There has been no kind of organized surveillance of herbal remedies. The same rules that we apply to pharmaceuticals have not been applied—both pre-market introduction or post-market surveillance—for herbal remedies.

Mr. Reed Elley: Have you had actual—

The Chair: We're going to stop now, because you're at double the time limit.

[Translation]

Ms. Picard.

Ms. Pauline Picard: Doctor Dirnfeld, there seems to be some contradictions in your brief. You're wondering why consumers don't discuss the natural products they're taking with their physician. I know that many physicians do not believe in natural products and have no experience or expertise in this field because as students, they learned about conventional medicine; and they were not taught how to use natural products.

You're saying:

...regulations must be applied fairly so that natural products be treated equitably as compared to other health products.

I would say that natural products must be treated in laboratories just like the so-called chemical products are treated by pharmaceutical companies.

You seem to believe that these natural products, since they're not treated in a scientific way but rather studied according to principles that have a long history, could have adverse effects on health. I have never heard about anyone dying after having taken natural products.

Have you ever taken natural products? I would like you to state your position clearly. Are you for or against natural products? I know that pharmaceutical companies are presently applying great pressure on physicians. They have a tremendous lobby for selling their products.

Recently, my daughter went to see her physician and she came back with a new kind of anovulatory medicine. He had prescribed it for a year in advance. She does not need to buy any, because she has enough for a year. However, this is a new product with unknown side effects.

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I find that there's some kind of contradiction in your positions.

[English]

Dr. Victor Dirnfeld: I think you raise a number of very important, very significant points, the first of which is why physicians don't prescribe natural products. Do they have an inherent bias against them? Why don't they learn about them in the course of their studies?

My answer is that what physicians do learn about is, as I said, based in science; it's based on the capacity to analyse the active ingredients of any particular agent to determine whether it has a beneficial therapeutic use and what the adverse effects are, what the bad effects of such agents would be, and where, if at all, such agents can be used for the benefit of the patient.

To my knowledge, there does not exist a scientific base of evidence to allow the teaching, the study, the organized approach, as we do for the vast pharmacological therapeutic agents we use, to be applied to natural remedies. The information that exists is anecdotal, it is traditional use, and it hardly addresses the whole issue of the science of pharmacology.

I can give you several examples of that in terms of what we used in medicine. The first would be replacement thyroid treatment. When I first started, we used to use something called desiccated thyroid.

I don't whether you remember it, Dr. Bennett.

It was a thyroid gland taken from a cow, ground up, weighed, and then given to the patient. It was the best we had at the time. They tried to purify it, but it varied from batch to batch and cow to cow. It wasn't very good, but it was the best we had, so we saw swings in how carefully the regulation of the patient occurred.

About 20 years ago we finally got a substrate of it, the same sort of material that came out of our thyroid glands called levothyroxine. We know the exact milligram, we can titrate the dose, and there is reproducibility in the product. That's what we use today.

The second thing we used was called digitalis folia, the leaf of the foxglove plant. Again it was washed, ground up, powdered, and pressed into a capsule, and we gave the patient one grain or two grains or three grains. Again the regulation was varied—there were great swings and valleys—until we extracted a very pharmacologically pure product called dioxin and could measure it.

That's the sort of example of our needing to have scientifically based evidence if we're to use herbal remedies or natural health products and teach practitioners how to use them.

A group of physicians has been impressed by the tradition and the anecdotes and have been experimenting with and using these agents. We don't know how many in society do that. To the extent we can use these agents, we would be open to use them if there were a scientific basis. We have no inherent bias.

I think it's a mistake to characterize this whole issue as against a particular culture, or against a particular tradition. It's not that at all. What it is is good science. That's what we're all about.

With respect, I can't recall the second part of your question, but I think I may have covered it in that answer.

[Translation]

Ms. Pauline Picard: I would like to know if you have already taken vitamin supplements.

[English]

Dr. Victor Dirnfeld: Of vitamins?

Ms. Pauline Picard: Yes.

Dr. Victor Dirnfeld: Not that it's relevant, but I don't. I try to eat the kinds of foods that contain the vitamins and minerals necessary for me. For years I was mocked in my hospital because they talked about Dr. Dirnfeld's diet, which was high in fibre, low in fat. It sometimes tasted like cardboard. But I feel vindicated because that's the standard diet in our hospital, after many years.

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I do prescribe vitamins, particularly in circumstances in which patients can't get the broad kinds of dietary foods that they need or don't have the appetite to ingest. And I have no problem with anybody taking vitamins even if they're eating well. In the doses in which they are formulated, they don't do any harm.

I think you also asked if I have an example. As it turns out, just several weeks ago, a 21-year-old woman came into the emergency room of my hospital and I was asked to see her several days later. She had taken six different preparations of herbal remedies. She was a perfectly healthy, well-functioning young woman who was working in industry and was also a musician. She had no other known use of drugs, and certainly not non-medical drugs. She was psychotic, which means she was out of touch with reality. She was violent, and they had to deal with this poor young woman. Her mother had gone to her apartment and had brought in this paper bag full of these six different agents. I could read to you what they had, but they were natural remedies.

In order to treat her, she had to be given some medication to sedate her. There was no other way around it, but the combination of these neuroleptics led her to develop what's called a neuroleptic malignant syndrome that almost killed her. She had hyperthermia, a huge peak of her temperature to 40° plus, blood pressure that swung very high and low, and she was locked in. And there are other examples of this sort of thing.

[Translation]

Ms. Pauline Picard: This can just as well happen with chemical products. I remember having bought a product off the shelf to help me sleep and it was made by a pharmaceutical company. That product made me very sick. The person you mention took some natural products and mixed everything up. There was a problem right from the start. She could equally well have taken non-natural products.

[English]

The Chair: I don't know if you want to answer that. It would have to be a very short answer of thirty seconds, please.

Dr. Victor Dirnfeld: Right.

I agree with your statement, and that's why we are arguing for labelling and the regulation of natural products, just as are applied to the pharmaceutical products to indicate what you should take, what's in them, and what are the possible complications, risks, and side effects.

The Chair: Thank you very much.

Dr. Bennett.

Ms. Carolyn Bennett: Thank you.

One of the things we keep getting asked here at committee is where the bodies are, what the body count is. They bring us reports of adverse drug reactions this high in terms of aspirin and ibuprofen, but there's nothing for herbal remedies. They're asking what business of ours it is to be prohibiting or restricting things that have been safe for thousands of years. Dr. Buckman has quite often said we could use the whole gross national product to investigate or apply a medical model to these products but still wouldn't actually get to a point at which we could perhaps substantiate all claims to the satisfaction of the Canadian Medical Association.

Dr. Carter and I have had this conversation before. There is a lot that we do in medicine for which there is no... Obstetrics is one thing for which I think there was a dearth of information in terms of what has been traditionally done. It was only with the Cochrane collaboration that we started to actually investigate things just because they've always been done that way. So I don't think we're too perfect even in traditional western medicine.

We've had two things suggested. There are some people who think all natural remedies could be looked after under food and could be dealt with as an industry standard: you have to have safety and you have to have fair labelling. There is another group of people who feel there should be a third category covering natural health products, maybe subdivided under homeopathic, ayurvedic, and traditional Chinese medicine, and those people would have some expertise and could look after their own category.

I guess I want to know if you really would have a problem with something like the Australians have done in labelling. There would be a method whereby you would say a product has been traditionally used for such and such, a method that doesn't say it has been scientifically based. As we all know, people go to their cupboards and use the wrong thing, because they think that thing is given to them for such and such, even in the case of pharmaceuticals.

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If you are saying we can only label things if there's a scientific basis for the claim, I think we set this whole process back hundreds of years, from before 1860 or whenever, when the first college of medicine took over from the homeopaths, and took over in a pretty arbitrary fashion.

So would you tolerate the Australian model where you have a variety of labels? And do you have a view about a third category that looks after natural remedies?

Dr. Victor Dirnfeld: I think we have to do the best we can. I think that at one point in our therapeutic history we advanced from what was then classified in the whole group as snake oil therapy, where claims were made, had been made traditionally, and had been used for a long period of time. Whether or not there were adverse effects really wasn't known until there was such a magnitude of people getting sick from these remedies that there was an outcry and a need to regulate, to look at, and to have surveillance, and that coincided with the approach of the scientific method.

I think the problem we have here is that although these remedies have been used for many years, we don't have a body of evidence, either in terms of whether it's effective or whether it is safe, because we don't have surveillance. That there is no outlying, massive adverse effect, I accept. I agree with you.

I tend to set goals, and I think the Canadian Medical Association has as a vision and as part of its mission the setting of goals, trying to work to an ideal standard. As we have taken our position, we believe there should be a scientific base for the regulation, and caveats notwithstanding, there should at least be complete labelling to indicate possible side effects, complications, and interactions. But you can't have that without adequate investigation of the agents.

Ms. Carolyn Bennett: In your list of things that there's scientific evidence for... I mean, clearly senna leaves and feverfew... I think you should expand the list of stuff that there's actually evidence on.

Secondly, with that patient you described, which is very worrying to me, where do we go to report that, such that it could be substantiated? Do you believe there should be a council or a reporting mechanism whereby the case of a patient such as that would be investigated and those bottles would be analysed to find out if they've been contaminated in some way?

As you know, we had the problem with sleeping buddha, which actually had diazepam or those benzodiazepines contaminating what looked like a herbal remedy. I think that as a government we need to be able to immediately give help to that patient and to ask what on earth made that woman so sick.

Dr. Victor Dirnfeld: I agree, and I think we will report this drug reaction to the Health Protection Branch, the branch we use, here in Ottawa. We will report that, but that sort of reaction to natural products has to have a repository of its own. I also agree with you that there must be standards so that what is said on the label to be in the bottle has to in fact be in the bottle and can't have contaminants, either natural contaminants or others.

With respect to expanding the list, there are two points. Senna is already part of the pharmacopoeia. We know how it works. We know the appropriate dosage and the side effects of using too much. And many other natural remedies have gotten into the pharmacopoeia. With respect to only those two, I'm quoting the same Dr. Buckman you have quoted. In his review, he found only those two natural remedies.

The Chair: Mr. Ma would like to answer, but I'd like to ask you, Doctor, did you answer the question that Ms. Bennett had about whether you approve of a third category or a system such as that?

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Dr. Victor Dirnfeld: Yes, I did so elliptically. My position and the position of the Canadian Medical Association is that we think there should be the same level playing field and a regulatory base applied to natural remedies as is applied to the regular pharmacopoeia, and it should be based on risk management.

In other words, where there is evidence that the risk of the use of a particular agent—for example, garlic; it's a herb. The investigation and the regulation need not be anywhere near as comprehensive as for something like ephedra, which has much greater potential for complication.

The Chair: I have to ask one more question. You're talking about having testing, and so on, and making sure these products are safe, the same way as the products you prescribed. Do you have anything to say about the number of deaths, into the hundreds of thousands in the United States alone, from various drugs and the lack of proof of deaths from natural products?

Dr. Victor Dirnfeld: First of all, I deplore the misuse of pharmaceuticals, the inappropriate use that results in deaths and disability.

For example, non-steroidal anti-inflammatory drugs in the elderly are being misused, and we are desperately teaching physicians at all stages in their life cycle of practice that it is inappropriate to use them under certain circumstances, particularly in the elderly.

In answer then to the part of the question that we have not a large number of people dropping dead from the use of natural remedies, I think that begs a question, because we aren't doing surveillance. We don't know what the incidence of use is, except from some initial surveys, and I think that's the sort of information we need.

The Chair: Ms. Bennett.

Ms. Carolyn Bennett: Take garlic. We're in this trouble because garlic ended up an illegal substance. So you have garlic at the supermarket; you have garlic stuffed into little capsules, or whatever, in what might be this intermediate herbal remedy; and then we could have pharmaceutical companies decide that this garlic-heart disease thing looks pretty possible in terms of proving it and spending money—that's what my concern was—and they do the DINs and this and that and sell it over here as a drug. We would have three different sets of regulations for garlic.

That's where I'm confused. It's the same thing, and the pickle we're in here is because you could end up with two or three different ways of controlling something that's totally safe, based on the money that is available to do all of this fancy testing and backing up of claims. So you could have pharmaceutical companies able to sell garlic in a drug because they can spend the money to do it this way, whereas other people would be accused of false claims because it's only a tincture, or it's a capsule or whatever, over here.

The Chair: Ms. Bennett, could we ask him to answer? It's not your turn now.

Dr. Dirnfeld.

Dr. Victor Dirnfeld: If garlic or any other substance is known to be safe and shown to be effective, then the risk would be very small. The cost of regulation would be, appropriately and parallel, very small. Also, I think the consumer, recognizing that garlic is garlic and the claims, if substantiated, that it's beneficial, would buy the cheapest equally safe product, no matter how it's formulated or who's marketing it.

There are some people who will be convinced that the packaging and the cachet of a drug manufacturer is better than a natural food product.

Ms. Carolyn Bennett: When they get it paid through their drug plan?

Dr. Victor Dirnfeld: Through their drug plan...that's possible. But I think the informed consumer, and that's who we're talking about, will make the appropriate choice.

The Chair: Mr. Ma.

Mr. Jonas Ma: Thank you. I'd like to touch on the three areas that have been discussed earlier in the question period. One is risk, the other is evidence, and the third one is exclusivity.

When we talk about risk and evidence, I think we have to look at what I've described earlier as the biomedical bias in determining what is risk and what is evidence.

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In the traditional Chinese medicines, risk can happen if we take a particular ingredient out of context, out of its formula, out of the way it's intended to be used. So when we subject those herbs to laboratory tests, we can say: this is poisonous; this is dangerous. But when it's used in a prescribed form, it would have a therapeutic quality that is helpful.

I think that's what I referred to earlier, that when we isolate the ingredient, when we look at it in an isolated form and disregard all the concept and philosophy behind the usage of those herbs, it would obviously become a risk. I think, as so many of you have said, sometimes a good thing could become a bad thing if it's misused. Too much carrot juice can be dangerous for you.

About the rights of consumers, what I suggested to you earlier is to invite the participation of consumer groups in the review process, in the regulatory system, so that when there is danger in a particular product, that can be brought to the attention of the regulatory body.

The other thing about evidence is also, I think, related to the way therapeutic qualities of herbs, and Chinese herbs in particular, are used. Again if we isolate it, if don't use it in the way it's intended, obviously it would be hard to prove the usage of this. For example, ginseng is not proven by the lab as effective, but many people already believe that. They're using it, and they see there's a very concrete health benefit they have when they take ginseng. This is a very clear example.

The third point I want to deal with is the question of exclusivity, and I think that's related to testing and what you said earlier about the complex system it has to go through in order to establish those claims. I think if we apply that to traditional Chinese medicine, it will wipe out all the small family run businesses, because they will not be able to afford those fees to get the tests and to get those results and evidence that we require from them. If we establish exclusivity, then obviously they can't sell those products and it would be left to the big drug companies.

The Chair: Thank you.

Ms. Wasylycia-Leis.

Ms. Judy Wasylycia-Leis (Winnipeg North Centre, NDP): I would like to thank the presenters for their contribution today.

I want to ask Dr. Dirnfeld a couple of questions related to the overall theme of the work of this committee and I think the goals we hold in common, which is to find a framework to actually achieve safety, quality, and efficacy in anything that's on the market, and also to acknowledge your recommendation, which I think is critical for the work of this committee, to develop the capacity for adequate scientific surveillance through government to ensure that any product on the market is safe and that what's said to be in the bottle is actually in the bottle.

I want to come back to this issue we've heard time and time again, about integrating alternative medicine with traditional physician practice. We've heard from so many that almost half of Canadians, by survey, use natural health products in one form or another, and I think I'm probably pretty typical of that group of Canadians.

It's through hearsay, through literature, through people recommending whatever. You add to your diet vitamin C and B complex, throw in a bit of B6, make sure you take your calcium, and throw in zinc now and again. When you have a cold coming on, add echinacea. Try evening primrose oil when you're close to menstruation, and so on and so forth.

So I think I'm a typical Canadian. I read about it, hear about it, and add those things to my diet. But I go to my family physician and ask, what do you think of all this? My physician doesn't really know what to say. I don't get an indication one way or the other.

So my question is, regardless of whatever framework we come up with as a committee, we still have this issue to deal with and how you integrate these two areas of medicine. How do you see that happening through the CMA or through education of physicians generally? How can we make sure that we can turn to physicians and get appropriate advice about natural health products?

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Dr. Victor Dirnfeld: The importance of education cannot be emphasized highly enough. Based on good evidence, the information has to be transmitted to providers of health care, physicians, nurses, nutritionists, and others, as well as to consumers of health care. Once we have this foundation of evidence, it is then important that this information be advanced to them at both the earliest stages in their training programs at universities or technical colleges and in continuing education.

There is a genuine thirst and desire for knowledge in this whole area on the part of the health care community. I can speak best for physicians, and I know they look for this information. What they are looking for is authoritative information. They feel very uncomfortable about adopting practices and integrating these things into their practices based on traditional use but without what they are trained to accept and to trust, and that is scientific validation.

With respect to other areas, such as vitamin therapy, where there is a deficiency in knowledge—and there is such a huge body of knowledge that they have to assimilate and integrate—it is difficult. We are working on the wide front of how health professionals can learn best, whether it's no longer didactically from people who give them lectures and is instead through more interactive, seminar-type studies, or whether it's through computer-assisted study.

I agree with you that there are certain deficiencies in knowledge, whether they're in vitamin therapy or in other areas in which we could improve, but this all has to be based on evidence and on solid information that practitioners would be comfortable with and that consumers can also depend on.

Ms. Judy Wasylycia-Leis: For those areas in which we have a considerable body of scientifically based evidence—for example, in the area of vitamin therapy—and even some of the other areas, could one not now argue for a compulsory component in the education system for doctors?

Dr. Victor Dirnfeld: Curriculum development is a very difficult thing. As medical associations across the country, we have asked the deans and faculties that develop the curriculum to include this, this, and this. They drop their hands and say there are only so many hours of teaching time available, this body of knowledge is expanding almost exponentially, and they have to grade on what they can feed the students and teach them. What they are trying most of all is to teach them a method, a discipline of learning, that will be lifelong. As their mentors, what we can try to do is to emphasize the emerging areas, the important areas, and the areas where they may have been some weakness or deficiency in their undergraduate training.

You point out, though, that there are dangers as well with vitamin therapy. For example, if taken in too large a dose, vitamin A can produce liver toxicity—very serious damage to the liver. Vitamin D and calcium can produce calcium deposition in organs. I have seen them destroy kidney function, and I've seen people die of kidney failure. In high doses, vitamin E has a whole host of complications, including thrombophlebitis.

The public has to be aware that many of the therapies that we use, just as do the pharmacotherapeutic agents—I don't care what it is, but you can choose any one—have an adverse effect at a certain point, almost without exception. There are some exceptions, like vitamin B12, for which we seem to be able to get away with large doses. But we have to be aware that there are complications when using too much of a particular agent, including what are considered to be benign vitamins.

Ms. Judy Wasylycia-Leis: Water?

Dr. Victor Dirnfeld: Yes, there's water intoxication. If you take too much, you can have convulsions.

The Chair: Maybe with potatoes, too. We should be careful of what we eat.

You have thirty seconds for a question and an answer, Ms. Wasylycia-Leis.

Ms. Judy Wasylycia-Leis: I just have one last, quick question.

One of the other ideas suggested by presenters over the last few months has been that we actually should expand upon the medicare model, that we should start to include other disciplines such as homeopathy, traditional Chinese medicine, and so on. What is the position of the CMA on expanding the model of medicare to take into account other disciplines?

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Dr. Victor Dirnfeld: And to include, for coverage, their treatments and their medications.

Ms. Judy Wasylycia-Leis: Yes.

Dr. Victor Dirnfeld: We have a big problem with that, because, as we have discussed most intensively in the past several weeks, there is a significant and very marked underfunding in the system as it has evolved over the past three years. Trying to cover these other areas, some of which we question on the basis of science, would do even more damage and would be a greater disservice to the medicare being provided now for our citizens.

When our government speaks of these very important areas such as home care, that should be expanded too, and we agree there must be a seamless transition from acute care in hospitals, decreasing care in hospitals, to more home care, with the support and the financial resources put into that for home care. And national pharmacare—

The Chair: Now can we get back to her question?

Dr. Victor Dirnfeld: So in response to the question, we, the CMA, would not support including these or embracing these under medicare, the reason being the insufficiency of current funding for what needs to be done.

The Chair: Mr. Myers.

Mr. Lynn Myers: Thank you, Madam Chair. I'll try to be brief. I know Mr. Volpe has some questions as well.

I think it's fair, Dr. Dirnfeld, to note that no one argues with the three pillars in terms of safety, quality, and efficacy—and, of course, the fairness inherent in that system. But with respect to your recommendation 4, my ears perked up when you said that products should not be based on tradition and usage. In fact, your words, I think, were that “it's fraught with danger”, and yet some would argue there is a long tradition, history, and usage, and in fact would argue that here is testing and a proven track record and such.

I was wondering about some people saying that perhaps there's an overemphasis on good science, on empirical data and laboratory testing, and that in fact some benefits may not necessarily prove themselves or be demonstrated in a structured laboratory setting. They say that in fact, over usage and time, these things have in fact developed in a way that is appropriate for Canadians. I'd like to hear your response to that and then I'd like to hear Mr. Ma's response, because I think he'll have a very different response from yours.

Dr. Victor Dirnfeld: My point with respect to tradition and use of many years is simply that we have to be much more precise in our study of any particular agent that we are saying either has benefit or has no danger or risk. It doesn't have to be laboratory testing. In fact, it shouldn't be just laboratory testing; it should be clinical testing. It should be applied in a controlled study to people. Then, if it's found to be beneficial with no risk, once it's marketed it should have a post-marketing surveillance. In other words, there should be a follow-up on these agents.

Let me give you an example of a drug that is still in the mainstream of medicine with respect to long use. The name of the drug is digitalis. It's been in use for 200 years. It's a naturally occurring agent that comes from the foxglove plant. For 200 years there was no study as to whether it was safe or effective.

That study was finally done and reported on in March 1996 at the American College of Cardiology meeting in Orlando, Florida. It was a $40-million or $50-million study, international, multi-centre, and it showed that, first of all, digitalis was not only dangerous, but it increased the sudden deaths, the deaths out of hospital, for patients who were on digitalis. So first, it increased the incidence of death, and secondly, it did not decrease the mortality or longevity in people who were given this drug.

Although there are arguments on the interpretation of this study on both sides of the issue, fewer and fewer doctors are using this drug. The editorial by Packer that appeared along with the report in The New England Journal of Medicine in February 1997 predicted that digitalis would probably fall out of use within the next five to ten years.

Mr. Lynn Myers: Madam Chair, I'd like to hear from Mr. Ma.

The Chair: Mr. Ma.

Mr. Jonas Ma: This is what the experience has been with Chinese herbal medicines in the last ten years. They have been subjected to laboratory tests. I agree that we need surveillance and precise labelling, but when the theory and concepts for Chinese medicine are so different from a biomedical model...it was rejected. For example, if this particular herbal remedy is supposed to, as I said earlier, suppress heat, what does that mean? It was rejected. We were not able to put the claims on the label as such. It was given something else.

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I think we support the idea that if we have a regulatory system that allows for the participation of consumers, if there are any side effects or if any problem is associated with the remedy, it can be channelled through that process. I think there's a way for surveillance.

In China itself they are doing a lot of studies on categorizing the herbal remedies that have been traditionally used. Some of that has been rejected, in fact. I think the example that was cited as a potential danger is there, but it's just as much the case with pharmaceuticals or chemically derived drugs that have been put in the market and where we didn't know the problem until later on.

The key thing is that we cannot use a biomedical model to categorize, to define, the therapeutic quality of those herbs. It has to follow the different concept it came from. Maybe we won't have the system, maybe we won't have the resources, to do all that categorizing, but I think we can benefit from research and studies that have been done elsewhere where it's used more commonly. If we disregard it because it doesn't fit into our model, I think we'll basically be wiping out access to that service; those products.

The Chair: Mr. Volpe.

Mr. Joseph Volpe: Thank you very much, Madam Chair.

I have a series of questions, and I'm afraid, Mr. Ma, I may not be asking you some of these questions, but Dr. Dirnfeld might indulge me.

You finished off your last statement with a suggestion that you wouldn't be in favour of including these alternative products and therapies in the general system because there wasn't enough money in the system and you were afraid to dilute the system further. Is this an issue of one lobby group versus another, or are we, and should we, be more interested in what happens with the health of our citizens?

Dr. Victor Dirnfeld: Mr. Volpe, thank you for the question. I'm sorry if I didn't make it clear, but I had included in my response to the questioner that if there was evidence of the efficacy of natural remedies—if there was—then the inclusion would still have to address the concern that there are many other areas that, in our assessment, have a higher priority in need to be funded because of their efficacy, their underfunding, their need.

Mr. Joseph Volpe: Can I ask you, then, if we could just elaborate on the question of efficacy a little more. When it comes to pharmaceuticals, the question of efficacy is usually determined by the designated use of that particular product; the designated use, and the prescribed designated use. Am I correct so far?

Dr. Victor Dirnfeld: Yes.

Mr. Joseph Volpe: Am I also correct in recalling that there's very little—I'm going to use your word—surveillance of use once the prescription has passed from the doctor's hands?

Dr. Victor Dirnfeld: No, that's not correct. I don't think I said that. In fact—

Mr. Joseph Volpe: No, I didn't say you said it. It's an impression I have from other testimony and other places.

In fact, there is very little coordination and very little surveillance. Probably what happens—and I think you more or less would have confirmed this—is there is incomplete usage of the product, abuse of the product, and overuse of the product, pharmaceuticals, in too many instances for this committee to recall. That's a general impression, and it leads to a corruption of the word “efficacy”.

Dr. Victor Dirnfeld: To begin with, if I can go back to the first part of your question, an integral part of marketing is phase four marketing, and that is post-marketing surveillance. Cadres of physicians are involved in this across the country, most frequently in academic centres but not always; sometimes physicians in practice. I've been involved in a number of post-marketing surveillance studies to see and report on in a cohort any adverse outcomes when a drug is used on a broader base other than in a clinical study.

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Mr. Joseph Volpe: Other people who have come before this committee, Dr. Dirnfeld—not this particular committee, but the health committee in the past—have indicated that about 90% of the doctors either don't have a computer or don't computerize and otherwise centralize and coordinate any of the patterns of prescriptions or therapies that they apply to their patients—and I'm talking about conventional practitioners, not alternative or complementary practitioners.

Dr. Victor Dirnfeld: While that may be—and I wouldn't want to dispute the figure—I don't know that it necessarily represents an indictment of the capacity to follow up on a therapy.

Mr. Joseph Volpe: No, don't get me wrong. I'm just trying to follow up on the question of trying to understand what we mean by the word “efficacy”.

Dr. Victor Dirnfeld: Efficacy means that it works for a particular indication, for a claimed indication.

Mr. Joseph Volpe: But it's also backed up by surveillance. I guess you haven't given me an indication that the surveillance is as thorough as I would like, at least.

To illustrate a point, you also gave us an indication of what I would term a horror story about someone who used a complementary product. That shocked you, and I'm glad it did. Without being sarcastic, I'm wondering if there's a correlation between the high cost of malpractice insurance for conventional practitioners and the number of horror stories that emanate from the application of conventional medical practices and pharmaceutical products.

Dr. Victor Dirnfeld: I'm sure the adverse outcomes from pharmaceutical products contribute to malpractice costs, but I don't think they represent a significant or substantive part of malpractice costs. The greatest part—

Mr. Joseph Volpe: Is there a correlation with the number of horror stories emanating from them? You don't think so?

Dr. Victor Dirnfeld: Not that I'm aware of. I think the malpractice costs are centred in a different area. In particular, the malpractice costs are substantial because it is the philosophy of the particular organization, the Canadian Medical Protective Association, not to settle for frivolous claims—as is so often the case in other kinds of insurance schemes—but to base the response on the fact that there either is a claim that can be allowed, or there is not. Where it isn't, there is substantial cost involved in disputing it.

Mr. Joseph Volpe: Let me go to another question. It's one of authoritative information, because that's the basis upon which conventional medicine makes its practices and distributes products. That authoritative information is promoted pre-market by the companies who provide that particular product, and a therapy is developed around the usage of that particular product.

I think you mentioned Dr. Buckman, and you pointed out that he found in his research that there are only two herbal products that actually met the scientific test. I want to ask you two questions on that. First, how many such products have been tested so that we can understand what that number, two, means? Do you want to answer that one first?

Dr. Victor Dirnfeld: There are two answers. The first is that when Dr. Buckman made that statement, he was basing his conclusions on the number of studies he could find, and he was only able to find two. He has no idea how many were tested but were not published. He was only able to find two that were published.

Mr. Joseph Volpe: I'm glad you identified that, because I asked Dr. Buckman about a particular therapy that's currently quite in the know, but he wasn't aware of it.

You also referred to the fact that he gave an indication—and I hope I quote him correctly; if I don't, I apologize, so I'll paraphrase—that some of these products actually make the individual feel better but not necessarily get better. To my mind, that means some of these things have a sort of psychological or psychiatric effect on an individual without having any impact on the body itself.

Dr. Victor Dirnfeld: Absolutely. That's called the placebo effect, and it's very profound.

Mr. Joseph Volpe: Okay, yes, that was his conclusion.

I know he appeared before your annual meeting about two weeks ago, I guess—and I'm sorry, but I just caught a clip on his presentation. When he talked about the scientific method and being better and feeling better, he used a particular example, and I'd like your comment on this.

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His example was that a few years ago—not that long ago—in the field of oncology the application of certain therapies resulted in a death rate of about 15%, but that was considered, in his words, “acceptable”, because we had identified the parameters and therefore our information, to use your word, was “authoritative” because we could find out exactly what it was that was killing these patients.

The operative words are “we know what was killing these patients”. I would have thought that the operative words should have been “we know what was making these people better”. I'm wondering if this is an issue where we should be looking at therapies and products that give us a better handle on what makes our citizens better as opposed to looking at a body, a methodology, that covers the rear ends of those who apply it.

A voice: Hear, hear.

Dr. Victor Dirnfeld: I would have assumed that the corollary was self-evident; that in the investigation of any particular therapy we're looking for, does it make people better and does it help the disease?

In oncology, where, in the vast majority of cases, depending on the kind of cancer you're dealing with, it is inexorably a fatal disease, if you provide a therapy that will reduce mortality by 85% but has along with that a 15% risk of inducing mortality, one would have to weigh—and by “one” I mean the provider of the therapy and the consumer of the therapy—in the most informed way whether one would want to take the risk of the 15% mortality or the potential cure.

Mr. Joseph Volpe: But you see, Dr. Dirnfeld, this is exactly what I heard Mr. Ma and others—maybe the naturopaths and homeopaths before him—say: as long as they advise the patient that the product about to be suggested and the therapy associated with it carry certain risks and some potential benefits, as long as that happens, the patient should then be free to utilize the product and that therapy. That's what I heard them say, and now I'm hearing you say exactly the same thing, except that you have encapsulated that theory and that concept into a system that protects the practitioners and excludes others.

Dr. Victor Dirnfeld: No. What I'm saying is that it is based on evidence, and if alternate providers can adduce the evidence from scientifically valid studies, then we are on a level playing field and we are speaking the same language. The general concept that things have risk and benefit, without the specifics based on clinical studies, laboratory studies, chemical studies, or whatever you want, without that kind of quantitation and evidence, is really pretty meaningless. What are you going to say to a patient? Are you going to say, “You have a choice of accepting treatment X, and by the way, treatment X can help you or harm you”? The informed consumer will say—

Mr. Joseph Volpe: For a doctor, that happens every day.

Dr. Victor Dirnfeld: But an informed consumer would say, “What are the chances that it will be good for me and what are the chances it will be bad?” If it's 5:1 in favour of improving, then the informed consumer is likely to come down on one side rather than the other.

Mr. Joseph Volpe: The key words, then, I guess, Dr. Dirnfeld, are “informed consumer”.

I'm wondering now—and I don't want to sound like I'm harassing you too much, even though my voice has altered a little—if Mr. Ma's clientele... Can I use that term?

Mr. Jonas Ma: Yes.

Mr. Joseph Volpe: We're talking business. If Mr. Ma's clientele is informed about the value and the impact of certain products, perhaps because they've gathered experiential or anecdotal evidence—to use a scientific term—from their families and in their culture, which has spread over, I don't know, generations, why is that a less valid approach than the one you're suggesting?

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I'm beginning to get the impression some of the scientific researchers operate in an environment where they establish methodologies that are protected by associations and it's a bit like what happens around this place. You repeat a rumour once, twice, three times, and it's gospel truth.

Dr. Victor Dirnfeld: Mr. Volpe, the scientific method requires that you have a hypothesis and you subject it rigorously to unbiased assessment. When you reach a conclusion, that conclusion has to be replicated in an independent site, whether it's a laboratory or another hospital or another clinic. When there is evidence at multiple sites that this is in fact what the occurrence is, then that's called evidence and that's called science and we act on it.

On the other hand—

Mr. Joseph Volpe: Dr. Dirnfeld, you're quite right, but it also involves an enormous amount of faith. I'm sorry to cite the same example you cited, because it has a personal involvement, but it's one many of us lived through in the 1960s. It's called thalidomide. A lot of scientific work was done on that. There was a lot of pre-market analysis, post-market analysis. Yet for many people that turned out to be such a tragic use.

I wouldn't have used that example, because I'm a little kinder to the scientific method. But I found it really interesting that a practitioner who is steeped in western conventional medicine would have used that example, because it raises again, in my own mind, the question about where our resources should be spent and how they should be spent and how we arrive at a balanced approach to dealing with the issue that's before this committee.

As a committee member I haven't made up my mind how I'm going to go on this issue, but I said about a week ago that I'm getting more and more skeptical about some of the positions that have been presented here before us. I'm hoping I'm being as critical as we all should be without picking on any one group, but I'm wondering again—and I'll ask you the question I asked the people who appeared before you, whether the issue is one where one group of practitioners are, via the regulations and legislation in place, attempting to move out of the marketplace another group of practitioners, who are applying different practices that may—I underscore that word “may”—be at least as therapeutic in their outcomes as the previous group.

Dr. Victor Dirnfeld: On the thalidomide issue, that was 36 years ago, and we and I personally have learned...and it couldn't have been a better object lesson for, as I say, me as a young scientist 36 years ago, and science and medicine in this country. Since that catastrophe, the post-marketing surveillance and the ability to introduce new drugs have been tightened up remarkably and markedly.

On turf protection, I reject that notion completely. What I am talking about is good science. I'm talking about evidence-based decision making. I'm talking about the safety of the population. I'm talking about a level field on which the same rules have to apply whether the medicine has been in use for 1,000 years or, as in digitalis, 200 years, or it's a new drug. There has to be evidence that it is safe, that it is efficacious—meaning it works—and that it is a quality agent.

Mr. Joseph Volpe: How many drugs has your association been responsible for getting off the market?

Dr. Victor Dirnfeld: That's not our function. The association will present information to the Food Directorate in Canada, and it is the function, as it properly should be, of the Government of Canada and its agencies to do that sort of activity. Where we have evidence, through our members, of adverse outcomes which are significant and which would merit review for the drug, we pass them on, without question.

Mr. Joseph Volpe: How many is that?

Dr. Victor Dirnfeld: I can't give you the number.

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The Chair: Thank you very much.

The meeting is adjourned to the call of the chair.