Thank you very much, Madam Chair, for the invitation to appear here.
I have a couple of roles. First of all, I work as an emergency physician in downtown Toronto, and secondly, I teach health policy at York University. Moreover, I've been studying pharmaceutical policy issues for about 30 years now.
With regard to the first role, just yesterday we were discussing drug shortages in the emergency department at the University Health Network. We've had to modify certain practices because of these shortages. I'm well aware of the impact that drug shortages can have on doctors' prescriptions and patient care, which is what we're all concerned about.
I think drug shortages have been on the horizon for a number of years now. We've certainly been aware of them in the emergency department for a few years. It should not come as any surprise that we're now in more of a crisis situation. All it took was a fire to create a crisis.
What we need is proactive planning to avoid any similar situation in the future. Merely approving other generic manufacturers that are able to produce drugs is not really proactive planning. We need to go beyond that, and in that context I have a number of suggestions.
I believe that Health Canada should convene an expert committee to identify off-patent drugs. Most of the products we're concerned about are generics, off-patent, that are supplied by only one or two companies. They are considered critical to medical care. Examples of these critical products might be chemotherapeutic agents, morphine, anesthetic agents, or drugs to treat epilepsy.
Once these critical drugs have been identified, Health Canada should proactively identify possible alternative sources of these products and determine whether the companies making them are prepared to supply Canada in the event of an emergency. Contingency contracts could then be negotiated with interested suppliers.
In the future, any company marketing one of these critical drugs in Canada should be required to give Health Canada a minimum of six months' notice before they stop supplying the product, and Health Canada should maintain a list of these drugs and post it publicly.
One of the conditions for granting a notice of compliance to sell one of these critical drugs in Canada should be a commitment by the company to guarantee the availability of the drug for a minimum of three years. We already go beyond what's required in the Food and Drugs Act when we approve drugs or give them a notice of compliance; we now invoke patent issues, so asking for a commitment to supply the drug doesn't really break any new ground.
Finally, if we do have another crisis similar to the one we have now, we need to avoid any possibility that companies can take advantage of the situation by charging a premium for their products. In that regard, I think the federal government should consider establishing a publicly owned generic drug company to manufacture some of these drugs to ensure that the drugs will not only be available, but will be available at a reasonable price.
Thank you very much for your attention, and I welcome the chance to answer any questions.