Thank you, Madam Chair, and thank you for the invitation to appear today.
The Canadian Pharmacists Association is the national association that represents individual pharmacists. Our members work in community, hospital, industry, and academia.
We are pleased that the committee has agreed to hold hearings into drug shortages. We suggested to the committee a year ago that such hearings be held and, in fact, the committee had scheduled hearings in March 2011, but the fall of the government and the subsequent election resulted in the cancellation of those hearings.
Although there's been a great deal of attention paid to drug shortages over the past months owing to the Sandoz situation, the fact is that drug shortages have been a serious problem for health practitioners and Canadians for at least two years.
CPhA identified the scope of this problem in a survey of our members that we conducted, and we released the report in December 2010. This work was prompted by reports that we'd been receiving as early as March 2010 about shortages. We've provided copies of this report for your information.
In the survey, you will note that 94% of pharmacists reported not being able to fill at least one prescription in the past week, with the average number of drugs in short supply being 10. At least half an hour per shift was being spent on drug shortages, although we heard reports of many hours per shift being spent addressing some significant problems. Most importantly, 70% of pharmacists reported their patients' health was adversely affected, and over 90% reported that patients had been significantly inconvenienced.
It's important to point out that dealing with shortages consumes a lot of pharmacist and physician time that should be available for direct patient care. It's only the diligent work by front-line health care professionals that's been able to limit the impact of shortages on the population.
Although it is difficult to say whether drug shortages have increased or decreased in scope or duration since that time, the fact remains that drug shortages are a source of serious concern for the Canadian health care system. The events related to the Sandoz shutdown are just the latest manifestation of what has been a major concern for some time.
As an association we've worked with government, industry, other pharmacy groups, and other health practitioners to look at responses and solutions to this problem. In the fall of 2010 we held meetings with industry groups, wholesalers, and other stakeholders to better understand the causes of the problem. That prompted us, later that year, to release our guide to addressing drug shortages to our members as one tool available for pharmacists to deal with shortages when they occur.
There are many aspects of the problem, including causes that we could discuss today—and Dr. O'Rourke has mentioned a number of the causes—but given the time constraints, I'd like to take a few moments to outline a number of the solutions and recommendations that we feel are needed to address not just the Sandoz-related shortages, but the full range of shortages that are plaguing our health care system.
First, we were pleased to see the House of Commons unanimously adopt a motion on March 14 that called for the development of a national strategy to address the long-term issue of drug shortages. We applaud parliamentarians for recognizing this need and would encourage the minister to take the lead on the development of a national strategy.
Second, in response to the Sandoz shutdown, we have welcomed Health Canada's efforts at sourcing alternative supplies and expediting approvals of equivalent or alternative drugs. However, this proactive approach to sourcing supply in the event of a shortage should not be restricted to drugs impacted by Sandoz. This is a role that we believe Health Canada could and should be playing at all times to proactively address shortages. This is the role that the Food and Drug Administration plays in the United States, and we would argue Health Canada could be doing the same.
We would also like to see an increase in effective collaboration between Health Canada and the FDA on drug regulatory aspects related to drug shortages.
Third, governments and large purchasing bodies need to be aware of the risks associated with tendering systems that result in sole-sourcing. Although it is true that sole-sourcing, which is often associated with bulk purchasing, can lead to lower prices, the fact is that when problems are encountered by that sole-source producer, shortages can and will be the result.
Sandoz, which supplies approximately 50% of Canada's injectable pharmaceuticals, is a perfect example.
We understand that HealthPRO announced before this committee last week that they have introduced a new policy whereby they will seek secondary suppliers for hospital drugs when alternative suppliers exist. This is a very welcome development, and one we would encourage other group purchasing organizations and provinces to adopt. However, we wish to point out that in many existing contractual agreements, clauses exist to impose a penalty in the face of failure to supply, yet it is our understanding that these clauses are seldom implemented.
Fourth, in order to ensure that health practitioners and the general public have the most up-to-date information possible, the Canadian Pharmacists Association established in March 2011 a stakeholder working group on drug shortages to develop a voluntary drug shortages reporting system.
Today I'm joined by my colleague Jeff Morrison, who's been the chair of that working group.
An initial version of that reporting system went live in November 2011. Information populating the system is being fed by member companies of Rx&D and the Canadian Generic Pharmaceutical Association. It was announced just last week that this information is now being collated on one centralized website, at www.drugshortages.ca.
The working group is now working on a more robust system that would, we hope, contain therapeutic alternative information and that would allow health practitioners to report directly into the system to validate a shortage. While the industry associations have committed $200,000 towards the establishment of this system, we need to put in place a sustainable funding model to ensure continuity of this reporting system.
Fifth, this is not just a Canadian problem. It is a global problem, and therefore requires global attention. Last fall we were successful in getting the council of the International Pharmaceutical Federation to issue a statement calling for global action on drug shortages.
We strongly recommend that the Minister of Health request that the World Health Organization and the Organisation for Economic Co-operation and Development add this issue to their agendas and immediately look into the global causes and solutions to drug shortages from an international perspective.
Lastly, we need a forum to bring together all stakeholders, particularly manufacturers and regulators, to identify the root causes of drug shortages, provide more information to the discussion, and then, more importantly, identify what solutions can be implemented to alleviate shortages. Reporting on shortages and dealing with them when they occur is all fine and good, but our goal should be nothing less than to prevent any shortage before it can interfere in the care of even one Canadian patient.
In closing, I would like to emphasize that is not only an access to care issue but also a patient safety issue. The uncertainty and inconvenience created through having to manage a lack of supply can result in patients receiving less than optimal treatment and increases the risk of error. Shortages also take up a lot of time on the part of pharmacists and other health care providers, time that would be better spent in treating and caring for our patients.
Thank you, Madam Chair. We'll be happy to take questions