Health Committee on March 5th, 2009

[The Chair, Conservative, Joy Smith]

Welcome to our committee once again. We're so delighted to have you here.

Ladies and gentlemen, we have before us Dr. Peter Singer from the McLaughlin-Rotman Centre for Global Health. Welcome.

From Laval University, we have Dr. Marc Ouellette.

From McGill University, we have Dr. Greg Matlashewski. Welcome.

What we're going to do is ask each of you to give us your 10-minute presentation, and then we'll go into round one of the questions from the committee.

We'll start with Dr. Singer, please.

[Dr. Peter Singer, Director and Professor of Medicine, University Health Network and University of Toronto, McLaughlin-Rotman Centre for Global Health]

Thank you very much, and good afternoon. My name is Peter Singer. I'm a professor of medicine at the McLaughlin-Rotman Centre for Global Health at the University Health Network and University of Toronto. I'm speaking as an individual.

I became involved in biosecurity in 2003 when I joined the committee of the U.S. National Academy of Sciences, which released a report on globalization biosecurity and the future of the life sciences. I've been a member of the biological threat reduction project of the Center for Strategic and International Security in Washington. I'm currently an advisor to the UN Secretary General's office on the Secretary General's biotechnology initiative.

In January 2009 I wrote an editorial in The Globe and Mail entitled “Is Canada ready for bioterrorism?” In short, my answer was that I'm not sure. In contrast to at least five independent committees that studied that question in the U.S., there's been no comprehensive independent assessment of that question in Canada to my knowledge.

Bill C-11, the Human Pathogens and Toxins Act, does make us more secure, which is why I support this legislation. In these remarks I wish to make two points related to the act, leading to specific recommendations.

First, the act will succeed in making us more secure only if it's implemented in close partnership with the scientists whom it regulates. I want to pick up from some of your discussions on Tuesday, when you delved into this area.

Secondly, the act is only a part of the web of protection needed to make Canada more secure and prepared for bioterrorism, especially when it comes to next-generation threats.

In making these points I think it's very helpful to emphasize how different biosecurity is from nuclear security. Nuclear security has a single choke point, namely the control of highly enriched uranium and plutonium. Nuclear security is achieved by keeping secret the means of producing these weapons-grade materials. The technologies are capital intensive, require state support, and if you control the highly enriched uranium and plutonium, you get nuclear security.

Not so with biosecurity. Pathogens are ubiquitous, knowledge is freely disseminated, technology is not capital intensive. Non-state actors, therefore, are a key issue. In short, the cooperation of scientists and a web of protection is needed to gain true biosecurity.

I want to elaborate on those points.

The first point has to do with implementation in close partnership with scientists. The act must be implemented in close partnership with scientists. As you discussed previously, the social well-being and economic prosperity of Canada will depend on scientific discovery. Imagine if a regulatory regime got in the way of Banting and Best's discovery of insulin, or the commercial production of insulin in bacteria, the insulin that's used by all of Canada's patients with diabetes.

I think the proposed act does strike a reasonable balance between scientific openness and the mitigation of risk, but this calculus will play out initially in the regulations, and it will need constant attention and rebalancing that can be done only through ongoing dialogue with the scientific community.

Because biosecurity does not equal pathogen security, what this act does do is really raise the barriers to those who would seek to misuse pathogens. It lowers the background noise of what's happening in laboratories so the signal of aberrant activity can stand out better. But we also need the help of the thousands of scientists in those laboratories, very few of whom, if any, intend to misuse human pathogens, to make sure that 99.99% constitute a network of vigilance to bring that signal to the attention of authorities. Because biosecurity is achieved by winning the scientists' hearts and minds, not through legislative compulsion but by fostering a scientific culture of awareness and responsibility, it's extremely important to have them on side.

I've reached out to a university, a provincial health prevention agency, and an industry association to ascertain whether they feel they've been consulted in the process of developing this legislation. I was pleased to hear a generally favourable response, but the important question, which was raised in your committee on Tuesday, is how to ensure that dialogue continues. This leads me to my first recommendation, which is that the committee recommend the creation of an external advisory group to the minister consisting of representatives of universities, provincial public health agencies, private industry, and others--possibly CIHR--to ensure that the regulations and the subsequent implementation of the act beyond that two years of regulation work proceed with the input and the support of the scientists they regulate.

I think I emphasized in these comments why that's needed even more with respect to an act around pathogen security than it would be with respect to many other acts in terms of implementation.

The second area and the second point I want to make is about the web of protection and next-generation threats. Biosecurity has several moving parts, which all need to work well, and they need to work together. There are the military aspects of biodefence, regulated by the biological weapons convention, and in the non-military area, there's law enforcement intelligence and national security, where there probably is a need for better interaction between those communities and non-governmental communities than there currently is. There's the public health response, which is really the final common pathway of defence. Unfortunately, we had a dress rehearsal with SARS, but for that reason, I think it's likely we're reasonably well prepared in the public health domain. There are the pathogen security and laboratory biosecurity and biosafety issues, the focus of this bill. We need that; that's why I support it. See remarks about implementation above.

But the one piece that hasn't really been attended to, and the one I'd like to focus on, is the idea of next-generation threats. This is about how life sciences can create new and far more serious threats, and I'd like to discuss it and suggest a way to deal with that.

Tomorrow's threats are not going to be the pathogens and toxins in the schedules of this act. A key recommendation of the report of the U.S. National Academy, which I was on, was to adopt a broader perspective of the threat spectrum. We highlighted how terrorists could use techniques like DNA shuffling or synthetic biology to design bacteria resistant to antibiotics. A procedure called RNA interference could be used to switch off genes that protect us from cancer. Systems biology could identify ways to disrupt the body's immune system, making us vulnerable to infection or to wipe out memory. Nanotechnology could figure out better ways to deliver bioweapons, which is actually the Holy Grail of bioterrorism. There's a whole spectrum of next-generation threats, not necessarily only pathogen-related, that need a focus.

At the same time, our committee recommended we maintain, to the maximum extent possible, free exchange of information in the life sciences, because the bioterrorists win without launching a single attack if we choke off these future advancements. Open science is also important to the development of countermeasures. This balance means making sure universities and companies promote a common culture of awareness, a shared sense of responsibility to prevent misuse within the community of their scientists—another recommendation of our National Academy committee. This is done using codes of ethics, teaching role modelling—also not a particular focus of the biosecurity agenda in Canada yet.

An earlier National Academy committee issued a 2004 report entitled Biotechnology Research in an Age of Terrorism, identifying, for instance, experiments of concern, like showing how to render vaccines ineffective, or turning non-pathogens—which aren't anywhere on your schedules—into pathogens. We need to make sure medical journals and granting agencies are sensitive to these matters and have processes for dealing with them.

Also, these threats change extremely quickly with the progress of science, so that our National Academy committee recommended creating by statute an independent science and technology advisory group to the intelligence community. To my knowledge, there is no group in Canada attending to these next-generation threats in a comprehensive, systematic way, the way I've seen in the communities in the United States, or attending to how the working parts that I mentioned form a web of protection together and how those various communities work together. If there's one thing I've learned, how those pieces work together is at least as important as the individual pieces, not just the coordination within government, which you talked about on Tuesday, which is also important, but the relationship between the government communities and the non-government communities in the universities, the private sector, etc.

In my Globe and Mail piece, I proposed that the federal government request an assessment of the question of whether Canada is ready for bioterrorism from the Council of Canadian Academies, working with the Canadian Academy of Health Sciences and the Canadian Academy of Engineering—the top academics in the country. These national academies of scientists were created, and in the case of the Council of Canadian Academies, funded to conduct just such an assessment. The mandate of such a study, which could complement the pathogen security focus in this act, would be to evaluate whether Canada is prepared for bioterrorism, with an emphasis on next-generation threats and the overall web of protection about how these pieces move together.

I won't go through in detail the specific questions that such a mandate might include, but I could do that in the discussion period.

To take a couple of examples, what is the nature of the threat, including the next-generation threats? How well do the pieces work together to form a web of protection? Do we have the capacity in Canada, outside of the government, to engage in these biosecurity issues? Is the public adequately involved in biosecurity issues? It's questions like those.

In closing, I would like to propose my second recommendation, which is that the committee recommend to the minister that PHAC request from the Council of Canadian Academies, working with the Canadian Academy of Health Sciences and the Canadian Academy of Engineering, a study to evaluate whether Canada is prepared for bioterrorism, with special emphasis on these next-generation threats and the web of protection--how the various pieces and communities work together. That is really what leads to biosecurity, not just the control of the pathogens.

It's a good act, but we don't want to have a false sense of security around the act. We want to look at biosecurity, generally.

I want to thank you very much for your attention. It's been my honour to address you, and I look forward to your comments and questions.

[The Chair, Conservative, Joy Smith]

Thank you, Dr. Singer, for a very interesting presentation.

Dr. Ouellette, would you present to the committee as well now?

[Prof. Marc Ouellette, Professor, Laval University]

Very good; thank you.

My name is Marc Ouellette and I work at the Infectious Diseases Research Centre at Laval University. I hold a Canada Research Chair in resistance to anti-microbial agents, which my colleague has just talked about. We can treat micro-organisms, whether they be viruses, parasites or bacteria, but they are all becoming resistant to anti-microbial agents, and that is one of my specialities.

One of the reasons why I am pleased to be here today—my thanks to the committee—is that I was the academic representative who contributed to the drafting of guidelines for biosafety. This is the archetype document that researchers in Canadian universities must abide by when they import or export human pathogens. I know the topic quite well. We were consulted extensively when the document was being drawn up.

Each university in Canada has a biosafety committee. Having the approval of those biosafety committees is an indispensable condition for obtaining research funds. I am on the Université Laval's committee. I will come back to that later. But I am going to speak today as an individual and especially as a frequent importer and exporter of Risk Group 2 pathogens.

I am on page 2 of the document you have before you.

I would like to acknowledge the people who invited me here. It has actually been quite enlightening to read Bill C-11, and even more enlightening to read the transcript of the debate that the MPs had about Bill C-11. I was quite amazed. The quality of the interventions was wonderful. There was a very good understanding of what was going on, and that was very useful for me.

We were informed by PHAC but we were never consulted by PHAC, whereas when this was written we were consulted and then the writing happened. Bill C-11 arrived from almost nowhere, and we were fairly surprised. The research community, as a whole, was actually very surprised by the predecessor, Bill C-54. We were caught by Bill C-54, but now I am quite happy to see that there is consultation. Now I am here at the Standing Committee on Health in the House of Commons to discuss biosecurity and I thank you.

The first message I want to convey is that biosecurity matters, at least within all of the universities in Canada. I'll give you a few examples. First of all, there are three national agencies that fund research. There is CIHR, NSERC, and SSHRC, which is for social sciences and doesn't work that much with micro-organisms--the only one is probably a virus they have in their computers, but the bill is not directed at that.

When we write a proposal for NSERC and CIHR, we have to pick a box about the biocontainment of the organism we have. We say yes, it's level 2, level 3, or level 4. Level 1 is actually the usual, and I'll come back to that, but level 2, let's say, is frequent. By good luck we get the grant. It is a 20% success rate, so we're not always a winner, but when we get it, we now have to get the institutional okay. Every university has its own committee looking at the grant and saying if it is level 2 or level 3, and only then, when you have the okay of the committee, can you get the funds. There is already a structure in place to look at that.

Now you have the money. Now you can start doing some work. So you want to import pathogens that you don't have in your lab. The first thing you have to do is work on a permit from the Public Health Agency, PHAC. This is what we have to fill out to get the okay from the Public Health Agency of Canada. I can provide this to the committee in both languages. Almost every human pathogen is also a pathogen of animals, and CFIA is also interested in that, so we also have to file for a permit from CFIA. This is the permit, and this is the extra paper we have to write. This is the real paper because French and English are on the same form.

Once we have that, it's often a dialogue. They will say, we are missing that piece of information, we are missing this protocol. What I'm saying is you cannot just get a pathogen like this. You have to go through paperwork to be able to do that, and once you have it, then you get your organisms. But now the people who work with this organism need training. The students, the personnel, have to be trained to be able to work with this, and it is the institution that is also responsible for that.

The message I want to convey is that the importation and manipulation of human pathogens is already under competent administrative scrutiny. Now, of course, we're all in favour of increasing the strategy to increase public health, for sure--nobody can be against that--but it is to find the best strategy to be able to have a dialogue, and with that I totally agree, between the legislators, the civil servants, the national agencies, and the people who are doing that on a day-to-day basis.

On the third page there are some comments.

One of the problems with this document, Bill C-11, which, incidentally, is very well done, is that Level 1 micro-organisms are not even mentioned. Level 1 are those that pose no threat to humans, except in huge quantities, but the quantity of micro-organisms is another factor. E. coli, for example, is one of those Level 1 micro-organisms. Everyone has heard of Escherichia coli. In the list, it appears as a Level 2 pathogen, but the biology laboratories in Canada that work with E. coli, who take pieces of a gene and put them somewhere else, are all working with non-pathogenic E. coli.

So, we must be very careful because, with E. coli, or any of the micro-organisms shown here, there are kinds that are pathogens and kinds that are not. It would complicate research enormously if there were no distinction between pathogenic forms of E. coli and the other forms.

Believe me, I sit on a number of committees, and everyone in Canada is worried and wondering if the things we have done for years and years are going to become a problem eventually.

One of the unique features of the bill is that there are Level 2, Level 3 and Level 4 pathogens. The bill makes no distinction between them, but the risks for the community from Level 2 are virtually nil. Level 2 organisms must not be considered in the same way as Levels 3 and 4. So, as to security clearance, I feel that those working with Level 2 pathogens should not be required to have a security check.

All university laboratories are Level 2. Professors' offices are laboratories. So how would students wanting to see their professors go about it if they had to have a security check first? These are things we have to think seriously about.

Six pages of this document deal with the role of the inspector, a position that does not presently exist. This individual (or more than one) will have a lot of power. We will need to see how we can limit that power to prevent an abuse of power, to prevent the person going on a power trip and end up hurting...

[The Chair, Conservative, Joy Smith]

Dr. Ouellette, I don't want to interrupt you, but I just want to remind you that you only have one minute left.

[Prof. Marc Ouellette]

Very good. Thank you so much.

I'll go to page 4 now, the end of the document. The schedules can be fairly confusing in terms of level 2, level 3. As I said, E. coli often has to be a level 1 pathogen, not a level 2. We often manipulate these bugs. Once we have different bugs, will we have to report them as new pathogens or not? If we put a plasmid in them, is that a new parasite, a new bacteria?

In the bill, the clinical microbiology is not discussed that much. How will clinical microbiology deal with these rules, with these regulations, or with this law?

In conclusion, because now I only have 30 seconds, first, thank you for the bill. I think it's very timely and it's nice to have discussions, but please listen to the users, because we are the ones who will either benefit from it or suffer from it.

Thank you so much for your attention.

[The Chair, Conservative, Joy Smith]

Thank you very much for that, Doctor.

Now we will go to Dr. Matlashewski. Did I do better this time on the pronunciation?

Thank you.

[Prof. Greg Matlashewski, Professor, Department of Microbiology and Immunology, McGill University]

Yes, that's fine.

First of all, I'd like to thank the committee for allowing me this opportunity to give some feedback on the bill. What I'm really going to be talking about is what's written in the bill here and my interpretation of it.

Just to give you a bit of background, I'm the chairman of the department of microbiology at McGill University. I teach microbiology and immunology, but more important for this committee, I also do research, and I practise microbiology and immunology. My research has contributed to over 90 publications. I also sit on advisory committees for the Canadian Institutes of Health Research; the National Institutes of Health, in the United States; the FDA, the Food and Drug Administration, in the United States; the World Health Organization, in Geneva; the United Nations; and Médecins Sans Frontières.

I have sat on these committees to deal with infectious diseases and microbiology over the years, and I continue to sit. So I feel competent in addressing the people here concerning this bill.

Like the Public Health Agency of Canada and the people on this committee, my concern is for health and the protection of people from infectious diseases. Because of that, I am largely in agreement with this bill, but there are some modifications that have to be made before it is passed. So I am only going to focus on that aspect and give you my reasons for that. I'm not being overly negative. I just want to focus on what needs to be changed.

The best thing to do to change this bill is to remove level 2 pathogens from this bill. They should not be linked. This is the same point Marc just made. Level 2 pathogens should not be linked with level 3 and level 4 pathogens.

Let me explain. Level 2 pathogens generally pose a low risk to public health. They are unlikely to cause serious disease, and the risk of spread is low. Completely different are level 3 and level 4 pathogens, which pose a high risk and are likely to cause serious disease. The risk of spread for level 4 pathogens is high. Therefore, the way you work with these pathogens is very different.

With level 2 pathogens, you work one way. You work with a biological safety cabinet, in which air can't get in or out, and you work with your hands like this. With level 3 and level 4 pathogens, you need a completely different infrastructure, which is a multi-million-dollar infrastructure, with a completely different negative pressure room and so forth.

So to work with these pathogens, you have to work under very different conditions. Therefore, the administrative and security levels also have to be different. This bill links them together. The administrative and security issues link level 2 and level 3 and level 4 together. That cannot work. You have to separate them just the way you separate working with these pathogens. You can't have them linked together. If you link them together, the consequences are enormous for this country.

For example, from a scientific point of view, a lot of research on level 3 and level 4 pathogens, the most dangerous pathogens, is actually performed using level 2 pathogens as a model system. For example, mycobacterium tuberculosis, which is passed through aerosol, is a pathogen that gets into the lungs, survives in the lungs, and causes tuberculosis. It's a fatal infection. Mycobacterium smegmatis is a very similar organism. It looks the same under the microscope. It has the same genes, or virtually the same. It has the same biochemical pathway. But it has evolved slightly differently to survive only in the soil, and there's very low risk of it infecting people. It is a level 2 pathogen because of its low risk of infecting people.

Drugs that kill mycobacterium smegmatis will also kill mycobacterium tuberculosis, so working with a level 2 pathogen reduces the risk and, as important, reduces the cost as well. So if this bill is passed the way it's written, it will link level 2 and level 3 together in an administrative way, and you'll lose that advantage. Working with the level 2 and level 3 pathogens will become equally administratively difficult and you will lose that ability, that advantage, of working on a level 2 pathogen.

That's a very important point to take away. Marc gave a very good overview of the administrative point of view, so I won't go into that. I'll just give one example. If I had a sample of mycobacterium smegmatis--a very safe organism to work with in a laboratory--and I gave it to my colleague next door, I couldn't do that with this bill. I would have to get a permit from Ottawa first, which would take an enormous amount of time.

I'm not sure if I understood correctly, but according to this bill, if I did do it, I would be criminally responsible and could be fined $250,000 and put in jail for three months. And that has really scared my colleagues across the country. My colleagues across the country have been calling me and asking me to clarify whether in fact this is what is true within the bill.

Another point is that Canada has to be able to compete globally on a scientific level. Something very good that's occurring in Montreal is that Merck Pharmaceuticals, which is one of the major pharmaceutical companies in the world, has recently developed a very good vaccine against the human papilloma virus.

They're relocating their research in infectious disease from the United States to the facility in Montreal. This will be a multi-million-dollar research facility. They will have to be supported by Canadian science in microbiology and immunology. We will have to be able to train students and graduate students to be able to support a facility like this. I've spoken to them already, and they want to be able to work with McGill University, the University of Laval, and the University of Montreal, because they want that academic interaction.

The way Bill C-11 is written it will slow our ability to conduct this research and our ability to interact with companies like Merck. If Merck can't survive in Montreal because of the effect this bill could have on research in Canada, other companies may not come in. I think it will really hurt us economically as well as scientifically if our ability to interact scientifically is impaired.

Marc brought up the important point that we have to be able to teach our students. We have 350 undergraduate students in microbiology and immunology at McGill. We teach them how to use level 2 pathogens. The way this bill is written we couldn't teach them any longer. We would no longer be able to train the students because they wouldn't have the proper security clearance. That has to be changed within the bill.

Another point is that in Canada, most professors' offices are in the laboratory. If I give a lecture in the morning, a student could not come to ask me a question in my office because the office is in the laboratory and the student wouldn't have the proper clearance. That's a problem with the bill.

We have visiting scientists coming into McGill University every week, and we like to talk science with them. They would not be allowed in my laboratory. We couldn't actually get into the lab and discuss results there the way the bill is now.

I'd like to finish by saying something that I think is quite important that I'm quite passionate about. Doing research in Canada has been wonderful. The Canadian Institutes of Health is as good an institution as there is anywhere in the world. They funded my research on Leishmania for over 15 or 20 years.

Leishmania is a level 2 pathogen. It's transmitted by sand flies, so it can't cause disease in Canada, but it does cause disease in the developing world, particularly in Peru, where it causes a severe form of leprosy. With the support of the Canadian Institutes of Health Research we've developed new treatments for this infection. We've taken it from the laboratory and we're now doing clinical trials in Peru. We're able to actually treat people before they get that form of leprosy. This is supported by the World Health Organization and Médecins Sans Frontières. It's because of the wonderful research environment we've had in this country that we can actually do this kind of research.

I can honestly say that if Bill C-11 had been passed the way it's written here to include pathogen level 2 organisms, we would not have been able to make that progress. We would not have been able to make those contributions and compete on an international level.

I think there are many positive things about this bill, but the thing that worries the Canadian scientific group is that linking level 2 pathogens with level 3 and level 4 pathogens is a mistake. It can be easily rectified by just removing level 2 pathogens and focusing on level 3 and level 4 pathogens. This should focus only on level 3 and level 4 pathogens. That's the message I'd like to put across today.

Thank you very much for your patience in listening to me.

[The Chair, Conservative, Joy Smith]

I have to thank you for your presentations today. They've been very thoughtful and insightful. We're quite looking forward to having the opportunity to ask questions.

Ms. Duncan, can you start?

[Kirsty Duncan, Liberal, Etobicoke North, ON]

Thank you, gentlemen.

You gave very interesting presentations. I appreciate the biosafety level 2 to level 4 perspective, and that the legislation is there to protect both Canadians and those working in the lab.

I have a number of questions. How does this legislation compare to WHO recommendations, and how does it compares to the U.S. and the U.K. in terms of the different classifications? Are we separating level 2 from level 3?

[Prof. Greg Matlashewski]

I could give my perspective on that.

The way Bill C-11 addresses level 2 pathogens in this bill in Canada is not what happens in the United States. They do not have those kinds of restrictions in the United States on level 2 pathogens. They do on levels 3 and 4. This bill is right on level 3 and 4, but it's not right on level 2.

In the United States there is a much freer exchange of reagents without having to get a federal permit first. There is not the security. I can walk into any laboratory in the United States and speak with a scientist there. They cannot do that to me. If a scientist comes from the United States to my lab, they can't come into my lab. So there is a difference. And it's the same thing in the U.K. and it's the same thing in Europe as well.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

That's what I wanted to know. Thank you.

What changes would you like to see? You've mentioned the level 2 separation. We work with students. What's the training...not just the laboratory work but the ethics around training students to work with level 2, if we're going to separate them, which they are currently?

[Prof. Marc Ouellette]

Every graduate student and every undergraduate student also—I don't know about all universities, but at least I know what's going on at our university—has to follow ethics courses on the conduct of research, not specifically on the pathogens, but this is included in the larger framework of compulsory courses on ethics of research. When they come into the lab, they have to pass training on biosecurity. It's not 10 years of training, but they do have to have all the know-how and how to deal with micro-organisms. They have to be trained to be able to work in the lab when they are there and have a contract and will stay there for a number of weeks.

And the second part of your question was?

[Kirsty Duncan, Liberal, Etobicoke North, ON]

No, that's okay.

Dr. Singer.

[Dr. Peter Singer]

On the ethics, in my former life I used to run a bioethics centre, and one National Academy committee's recommendation had to do with this culture of responsibility. Let me just tell you a story.

A guy called George Church is one of the world's pre-eminent producers of bits of DNA, and some next-generation threats are associated with some of those life sciences procedures. He's an excellent role model for his students. He talks about the ethical issues of biosecurity. He actually keeps track of all his students and what happens afterwards. So a lot of work can be done, I think more in the informal curriculum and role modelling, even more so than in the formal curriculum. That work, yes, around pathogens, but also around life sciences, folds very much into next-generation threats.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

That's where I was going with that.

[Dr. Peter Singer]

You won't be able to deal with it in this bill. That's why my second recommendation about the broader look on life sciences, next-generation threats, and the whole pieces of the puzzle, including the ethical aspects, which don't do well through legislation, or even regulation.... That's an unaddressed piece in Canada that would make us more biosecure.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

It's the additional web, that's true.

Is there anything from the toxins list that you think might be missing, or are there any changes you would like to see in this schedule? Be very specific.

[Prof. Greg Matlashewski]

I think everybody will see things they would like to change, but one of them is mycobacterium bovis. BCG is a level 3 pathogen. In fact, one-third of the world has been injected with this as a vaccine against tuberculosis, TB, so I'm not sure it should be a level 3 pathogen if it's already being injected into people as a potential vaccine.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

Are there any others? For example, ricin doesn't seem to....

[Prof. Marc Ouellette]

E. coli. There has to be a way of putting escherichia coli.... There are some level 2 pathogens, but several strains of E. coli are also level 1, and this is what is going on. Every lab in Canada and every lab in industry works with E. coli that is non-pathogenic to humans. So this is a big worry in the community.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

And what about toxins?

[Prof. Marc Ouellette]

Toxins are less special. But are there guidelines for toxins? My biosecurity officer at my university commented that there no real guidelines for the use of toxins.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

That's what I was going to ask Dr. Singer.

[Dr. Peter Singer]

I was going to say that those lists, especially the level 3 and level 4 lists.... Again I'm not a microbiologist, but they look pretty reasonable to me; they look comparable to the select agent rule. But the one thing I want to emphasize is that a good molecular biologist can turn a level zero pathogen or non-pathogen into—I'm only exaggerating a little here—a level 3 or level 4 pathogen in a little bit of time, or certainly can increase pathogenicity. That's the nature of the threat that you can't address in a piece of legislation like this. It's a crucial element of biosecurity.

I've made a recommendation about how we can really move forward on that through the Council of Canadian Academies studying it and making recommendations, which may actually be outside a legislative framework.