Regarding the first question on off-label usage, Health Canada and other regulatory bodies—not Health Canada alone—leave practitioners in the lurch, because we have a system in which the manufacturer asks for the drug to go to market for particular uses, the so-called indications, for which evidence has to be produced. And when evidence is available, the drug goes to market for that use in that general population—let's say adults—but if the same drug is useful for other purposes, and research has been done on it by universities or medical groups and has been published in the literature, and it is well accepted that the drug has a bona fide other use, that is not then reflected in the approval of use by Health Canada. So this forces doctors to use drugs in an off-label fashion, with the result that the industry can always say, oh well, it was used for a non-approved use. It gives them an out; it reduces their liability. But in fact it's a very dangerous process that forces doctors to use drugs for indications where there isn't any official authority saying yes, this is how the drug should be used.
I'm a pediatrician, as well as a clinical pharmacologist, with extensive regulatory experience in years past. I am now working part-time in the emergency department at CHEO, the Children's Hospital of Eastern Ontario in Ottawa. We see patients day in and day out, and we are using drugs that do not have a pediatric indication but are used worldwide and accepted as appropriate for use in those indications.
So this whole notion of off-label is very misleading in that it allows the drug companies to get off the hook by saying, oh, it was an unapproved use. And it leaves doctors and patients with no federal body having said yes, this is appropriate.