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...