Thank you very much, and thank you for the invitation.
I don't have a very extensive presentation, but I have a few comments, nonetheless. I came here more prepared to answer questions.
I'm a medical microbiologist, and I spend a considerable part of my time working in diagnostic microbiology laboratories, so my reading of the bill has been very much coloured by that experience.
I think legislation that clarifies these issues and provides clear regulation and has the tools to enforce them is something that is welcomed overall. However, we ought to be cognizant that this legislation is proposed in the Criminal Code, which has very broad power, and if it is not done right, it's going to cause considerable problems.
It may cause a definite chill in the scientific community, especially in light of recent events in the microbiology community in the United States following the legislation of biosafety and biosecurity they have introduced--I'd be happy to go into the details on that. I think we can agree that it's important to do it right.
Personally, I was very much comforted during the consultation we had with the civil servants and the PHAC and other agencies in which they indicated they very much want to continue their historical approach, which has been one of cooperation and education rather than coercion, but to nonetheless have the tools available in cases where it is necessary. I must say that having seen the proposed changes and the changes in the law that has followed the consultation, I'm very much encouraged in that regard.
It is important to realize that the danger of legislation that is too strict is an inhibition or paralysis of diagnostic microbiology laboratories, which would have important adverse effects on the health of Canadians being treated in the hospital. Not only are many Canadians hospitalized primarily for infections, but infections are one of the most common complications of many of the other therapies we have, be it organ transplantation, cancer treatment, surgery, etc. It is very important for public health, and for the health of Canadians, that the diagnostic microbiology laboratories be able to do their work.
With respect to a few notes that I made on the bill, the clarification that many of the regulations concerning the handling of risk 3 and 4 pathogens, or even risk 2 pathogens, does not apply to natural samples such as a human patient actually infected with the disease or samples that are taken for laboratory testing is very much welcome.
I think there are problems with the schedules that list the organisms. They have been improved throughout the process, but they still contain mistakes and many surprising omissions. Even if they were perfect at this point, it is the nature of the field that this list must be regularly updated because of changes in our knowledge or changes in the objective circumstances. It is important that the schedules be updated easily and that they not be cast in stone.
I don't know all the technicalities of overlap of jurisdiction, but I was also concerned about the licensing issues for diagnostic laboratories. There are already licensing processes at the provincial level that are in place. Speaking as a very busy laboratorian whose resources have been cut over the years, it would be very welcome if these processes could be synchronized so we could do licensing at one time in the year and not spend our time moving from one licensing process to the other.
I think the revised licensing for risk group 2 pathogens has been considerably streamlined, and it's very encouraging in that regard.
There is a lot of concern among all of us about the inspectors. They will apparently carry considerable power, and we are a little concerned about their scientific background and training, and making sure their powers are used judiciously.
From the point of view of diagnostic laboratories, I am concerned about the power inspectors have to make copies of any records. In diagnostic labs many records contain names of patients, what the samples are, and what they have been tested for. You can well imagine that you'd like to keep some micro-organisms more private than others. But whatever is the case, there is very stringent privacy protection legislation that we have to obey in diagnostic laboratories, and it seems to me there's a conflict there.
That's all I have to say for now. I came mostly prepared to entertain questions rather than give an extensive presentation.