First, let me thank you for giving me the privilege of coming to share with you the concerns of a number of my colleagues and myself with regard to many aspects of Bill C-11.
I am a professor and researcher at the Institut Armand-Frappier. Most of the research and teaching activities at our institution are in virology and microbiology. I am also deputy director of the Centre de recherche sur les interactions hôte-parasite and I hold a Canada Research Chair in infection and immunity. I have more than 25 years' experience in microbiology research.
My interest in Bill C-11comes initially from the classification of micro-organisms in the previous version of this bill, Bill C-54. In it, the parasite that I work with, the Leishmania parasite, was classified in group 3, a glaring error. It mobilized the research community that works with the Leishmania parasite, because of the potentially disastrous consequences that this could have on our research work. Regrettably, there had been no consultation with the researchers involved on the reclassification of this micro-organism, and a number of others. It seems that it was done in quite an arbitrary way. Of course, I cannot make that assumption, but it seemed to be so.
A number of corrections were made to the classification of micro-organisms and toxins in Bill C-11. But problems remain, as Dr. Hynes has indicated. Let me give some examples. Viral strains, such as VSV, are classified at level 3, whereas several strains are modified for the laboratory and used with animal models to understand how they cause infection. Mycobacterium bovis, the BCG vaccine strain, is classified in level 3 in this bill, yet one third to one half of the world's population has received the BCG vaccine. This vaccine is currently used to treat certain cancers, such as bladder cancer. Imagine doctors having to go to a level 3 facility to treat their bladder cancer patients with BCG injections. It would be absolutely ridiculous. Escherichia coli was also mentioned.
I would also like to mention toxins briefly. People seem to be very afraid of toxins. But a toxin called botulinum is used to treat wrinkles and some spasms; the common name is Botox. In humans, it is not really very dangerous. Another interesting thing about bacterial toxins in research is that molecules of microbial origin target molecules in our cells in very specific ways. So these toxins become essential tools in studying how a cell works. In cancer, in neurology and in immunology, for example, toxins are frequently used to block cell functions. If toxins became impossible to obtain, or extremely difficult to keep, a good deal of research in those areas would have to be abandoned, or would become very difficult.
As for basic research, that is, the kind of research in microbiology and the fight against disease that a number of my colleagues do, and I include myself, we know that it is essential if knowledge is to move forward. It allows us to understand the interactions between microbes and their hosts, including humans, the pathogenic processes and the immune responses that humans generate against these micro-organisms. Knowledge like that is essential in order to develop vaccines, treatments, diagnostic tests, and so on.
The current version of this bill can potentially have negative consequences. What consequences can over-restrictive legislation have on microbiology research? It could mean reducing or abandoning research on some micro-organisms because of the administrative complexities and the lack of adequate infrastructure. For example, if a researcher in an institution is working with a level 1 organism that is now classed as level 2, he no longer has the required infrastructure, which is very expensive. Is he going to continue his research? Where is he going to get the money to upgrade his facility? The same happens with pathogens that move from level 2 to level 3.
Costs go up for the research institutions and for the researchers who are funded by the Canadian Institutes for Health Research, for example.
Who is going to pay for the oversight mechanisms, the permit applications, the administration? It is all very well to impose constraints, though they seem excessive to me, but who is going to pay for them so that the research does not suffer? Let us not forget that most research in health and microbiology in Canada is funded by the federal government. If this bill is passed in its present form, there will be less return for each grant dollar.
It was said earlier that research requires the free exchange of information, knowledge and reagents. By “reagent“, I mean exchanging microbial strains, and I am not alone. if the rules are too strict, it can interfere with researchers' ability to exchange and obtain the reagents they need to pursue their research. How are we going to address those questions? The bill does not really make it clear. Ultimately, it is the fight against infectious diseases that may be affected by this bill because of the influence it has on the potential for research in Canada.
I would also like to talk about the negative impacts of overly restrictive legislation on the training of highly qualified people. By that, I mean the students in our universities and colleges. As director of the doctoral program in virology and immunology at my institution, and as a professor who teaches microbial pathogenesis, this concerns me greatly. It is crucial to ensure that the next generation of microbiologists in Canada is properly trained. That is done by having them work with micro-organisms.
These highly qualified people will be needed in order to staff our hospitals. These are the diagnosticians, the people who take samples, and so on. They are in research institutions, private or governmental. They are in biotechnology and pharmaceuticals. In the food industry, they are in quality control departments; we have heard plenty about contamination problems in that industry. People have to be familiar with micro-organisms. So we have to train people so that, for example, they go into government laboratories or into teaching.
In Quebec, we train laboratory technicians at college level. They have to learn how to recognize and work with micro-organisms. A good microbiologist can tell the strain of a microbe by smelling it. He can see the shape of a colony in a Petri dish. If we do not give them the ability to do that, or if it is too difficult to have practical courses in schools, universities and colleges, it is going to be very difficult to train the next generation of microbiologists.
We must make sure that the legislation does not prevent students and trainees from getting into research laboratories, or prevent them from learning by working with micro-organisms. You do not become an auto mechanic without ever rooting around inside an engine or a transmission. It is the same in microbiology. You have to be able to play with these micro-organisms in order to really get to know them.
The greatest dangers from infectious disease that Canadians are exposed to are likely to be in contaminated water and food, which are, in fact, often used to justify this bill. Think of Walkerton, think of the listeria crisis, and so on. You can also go to a restaurant, eat something suspect and get food poisoning, but a bill like this is not going to prevent that. The problems there are negligence, inadequate maintenance, poor practices in hygiene or cooking. Nosocomial infections, the ones you get in hospital, are associated with hygiene problems, as are outbreaks of C. difficile. We tackle epidemics such as flu, SARS and legionellosis with appropriate public health measures that allow us to limit and isolate the outbreaks. Canadians will not become safer overnight, or be in less danger from infectious diseases, because of restrictive legislation.
In my opinion, this bill cannot be used to pretend that it is preventing this kind of everyday hazard. I will end by saying that the vast majority of microbiological research in Canada requires micro-organisms in containment levels 1 and 2.
Because they pose a very low risk and because it is unlikely that they would be used for bioterrorism, micro-organisms in schedule 2 must, in my opinion, be removed from Bill C-11.
Thank you for your attention.