Thank you for having me, dear honourable members, in the context of the House of Commons Standing Committee on Finance's ongoing deliberations on the budget and the COVID-19 pandemic, and on behalf of the Critical Drugs Coalition, which is a non-partisan grassroots coalition of frontline physicians, pharmacists and academics.
I am speaking to provide recommendations for how the federal government can improve the resilience and security of Canada's drug supply chain.
To start off, I'd like to declare that I, along with the coalition, have no conflicts of interest, financial or otherwise. I'm a lecturer with the University of Toronto's department of family and community medicine. I'm also a rural physician. I work in rural and remote settings all across northern Ontario, from remote indigenous communities such as Moose Factory to small but very busy towns such as Kenora, where I am joining you from today.
My interest in drug shortages stems from the beginning of the pandemic when my colleagues and I were actually asked to start rationing and conserving critical anaesthetics, such as ketamine, propofol and fentanyl. These anaesthetics are not just needed to put critically ill patients on ventilators, but also to keep them on them. They're not just needed for COVID-19 patients, but also for other critically ill patients we see in ERs, ICUs and operating rooms. Their shortages have significant downstream consequences.
We are used to working with scarce resources in rural settings, but I was quite surprised to hear from colleagues working in the busier downtown hospitals, where I trained, that they were also experiencing serious shortages of these critical drugs. In fact, at the peak of the shortages in May 2020, only 3% of Canadian pharmacists had received their full shipment of drug orders.
Over the past year we've sought to understand the causes of these drug shortages. The causes do mirror the causes of the other shortages we saw for PPE and for vaccines in terms of production. The fragile global production system mostly based in India and China buckled under the pandemic, and we've had very little domestic capacity to produce injectable critical drugs such as ketamine and propofol, which I mentioned above. In fact, in Canada we only have one plant in Quebec that makes a very limited selection of injectable drugs.
We issued a public open letter to the Prime Minister's Office on August 13, 2020, which was supported and signed by many national bodies such as the Canadian Medical Association, the Canadian Association of Emergency Physicians and the Ontario Medical Association. Our asks were quite clear and included a pan-Canadian list of critical medications that the government commits to ensuring are always in stock, public support for a generic critical drugs manufacturer, and greater transparency and communication around the critical drugs supply.
On April 6, 2021, we heard from Health Canada, and we were happy to see the Minister of Health's announcement of a critical drug reserve, as well as a mention of financial support for domestic biomanufacturing.
However, our concerns still remain on the manufacture of critical drugs. In fact, in the last month I have personally seen the shortage of magnesium sulfate, as have my colleagues. This is a really critical drug used for people with abnormal heart rhythms and pregnant women with pre-eclampsia. Frankly, all these conditions can lead to death if you don't have magnesium sulfate.
Considering that we are having these ongoing shortages, we have three broad recommendations with specific policies we believe are necessary to solve this long-term problem and to maintain supply chain security.
Number one, the critical drug reserve should be maintained after the COVID-19 pandemic for ongoing critical drug supply disruptions. There is no clear definition of a “critical medication”, and at the University of Toronto I and many others have assembled a cross-disciplinary international working group of experts for this very task: to define a critical medicines list. We're pending grant funding. I'm going to put in a shameless plug that this is the sort of research that should be further funded by the government, but I think that's a very important first step.
Number two, we need local production of critical drugs. We've certainly heard lots about PPE and vaccines. A multi-product facility for injectable critical drugs would cost only $50 million to set up. It would be able to make the ketamine and the propofol that I mentioned earlier. There is actually a proposed facility based out of the University of Alberta that could probably supply about 10% of our domestic needs, with spare capacity for future pandemics and disasters. It could also be expanded to make the drug precursors, of which we know we were quite short of in the last year and a half, and that would be another $50 million. For a total of $100 million, we could guarantee sovereignty over our critical drug supply.
Number three, and the last point I'll make, is that we need to think about an overarching industrial policy to incubate and sustain these one-off public-private partnerships in domestic manufacturing. That could take the form of “buy Canadian” provisions to help companies and governments get their money back for investing in these facilities. It could take the form of regulatory harmonization so that we actually align with trusted peers, such as the European Medicines Agency, the U.S. Food and Drug Administration, and so on and so forth. It could even take the shape of a trade and regulatory alliance, such as CANZUK, as proposed by Conservative leader Erin O'Toole.
Regardless, I think there was a lot of really good work done by Health Canada in expediting the approval of imports of critical drugs from other suppliers when they did go short. I think that is something that needs to be encouraged, and we need to make the kind of investment into manufacturing critical drugs that will ensure supply chain security going forward. These investments must be paired with smart industrial policy and ongoing research.
Thank you.