Thank you.
Good morning, Mr. Chair and committee members. We thank you for the opportunity to speak to you today on the issue of marijuana for medical purposes. This is a topic of significant importance to FMRAC and its members. As you noted, my name is Trevor Theman and I'm the president-elect of the Federation of Medical Regulatory Authorities of Canada, also known as FMRAC. My day job is that I'm the registrar of the College of Physicians and Surgeons of Alberta.
FMRAC itself provides a national structure for its members, the 13 provincial and territorial medical regulatory authorities, to present and pursue issues of common concern and interest; to share, consider, and develop positions on such matters; and to develop services and benefits for its members.
I'm now going to go directly into our brief on marijuana, and I want to emphasize that our job as medical regulatory authorities is to exercise our authority, which is given to us through provincial and territorial legislation, in the best interests of the public. Our overriding interest is the protection and safety of patients and the quality of care they receive from the physicians we regulate.
So one of our roles is to provide guidance to physicians in their day-to-day practice. So what do we tell practising physicians about marijuana for medical purposes? We've been concerned with the direction that Health Canada has provided with respect to this approval, or permission, or authorization for the use of marijuana for many years—indeed from the beginning, and the beginning goes back over 10 years. At that time our members of FMRAC approved the following policy, and that policy still holds true today. The policy states:
The Federation of Medical Regulatory Authorities of Canada strongly believes that the practice of medicine should be evidence-based, and that physicians should not be asked to prescribe or dispense substances or treatments for which there is little or no evidence of clinical efficacy or safety.
Here's the big challenge: marijuana is a substance for which good scientific evidence about its safety and effectiveness in the treatment of medical conditions is sadly lacking. We're not against the use of marijuana per se; in fact, if appropriate studies had been carried out to demonstrate its effectiveness and safety and to determine proper dosaging, we would view this file very differently. But that's not the case, not even 10 years after we've started down this path.
We note that Minister of Health Ambrose has stated that marijuana is not an approved drug or substance. I don't need to remind this group that there is no drug identification number assigned to marijuana, and you don't pick it up from your pharmacy, and that says it all from our perspective.
So why are we here? We are aware of and certainly we understand, at least to a degree, the drivers for Health Canada's actions, but that does not make the decision that was taken correct. We believe the new federal medical marijuana regulations puts patients and the general public at risk. In our submissions to the draft regulations in February 2013, and again in the summer last year, when the new regulations came into effect, we stated that in our view the new regulations as presented were an abdication by Health Canada in its role in patient safety and public protection. Without clinical evidence of efficacy and safety, we as representatives of the medical regulatory authorities of Canada will continue to oppose the federal government's new medical marijuana regime. To do otherwise would be an abdication of our duty.
We are not aware of any new medical evidence that would warrant a change in our position. Thus the medical and health care communities remain without clear clinical guidance. Without such clear clinical guidance, FMRAC and the medical regulatory authorities will continue to advise physicians, our members, to exercise extreme caution when considering this question of approving marijuana for medical purposes for their patients.
I have repeatedly stated our position. Not only is there minimal evidence to support such a use for marijuana, there is indication that it may be very unsafe for some patients. Of particular concern are patients who are prone to addiction; very young and very old patients, who may be more sensitive to the drug; and those engaged in activities where alertness is a key safety factor. And this whole question of impairment from the use of marijuana, especially in safety-sensitive occupations, has received almost no attention. I think that is a significant oversight.
We are encouraged by Health Canada's commitment to work with an expert advisory committee to improve physician access to comprehensive, accurate, up-to-date information on the use of marijuana, thereby facilitating informed decision-making. This is long overdue. In fact, we may ask why it has taken so long, when the original regulations have been in place for many years.
What is really needed here is clear clinical guidance based on evidence, to advise physicians about the use of marijuana for medical conditions where a benefit is likely to happen. Such a document may also be of use to us, the medical regulators, in the event that a complaint is received regarding the quality of practice of physicians who participate in the program.
I would add that the new regulations diminish the role of the physician while advertising the program as being for medical purposes. While we were also opposed to the previous regulations, at least they required our members to identify and state the condition or symptoms from which the patient was suffering and for which marijuana might be effective. The current regulations remove that requirement and make physicians only a signing authority.
Health Canada would be well advised to recognize that giving physicians more and better information will not reduce the expectations, at times inappropriate, on the part of patients, to have access to marijuana for their medical conditions.
FMRAC and its members are encouraged by recent direction given by the Honourable Minister Rona Ambrose to Health Canada to modify the existing regulations, the intent of which is to require licensed producers to share information about those physicians who provide authorizations with us, the regulators, so it can be reviewed for quality assurance and complaint review processes.
In the interim, many of our members, the provincial regulatory authorities, have put in place mechanisms to allow them to monitor the activities of physicians who are providing approvals for patients to use marijuana.
In general, physicians must be aware of the lack of evidence to support the use of this substance for this purpose, and to inform patients of that. They must document the approval in the context of an established physician-patient relationship, and we belive this is key. That relationship includes making a proper diagnosis, considering all available management options, and ensuring regular follow-up. There's no point in offering any type of prescription or treatment unless one actually checks to see if it has worked. Finally, physicians are to submit information to the medical regulator on this activity.
In closing, on behalf of FMRAC and its members, the thirteen provincial and territory medical regulatory authorities of Canada, I want to extend our appreciation to your committee and the Government of Canada for its interest in this issue. This is about safety for the patient, the population of Canada, and possibly for physicians and other health care providers. As of today, there is insufficient evidence to warrant the use of marijuana for medical purposes, although we remain open and willing to be convinced otherwise.
I appreciate your attention, and I'd be pleased to answer any questions you may have.