Thank you very much.
I'm Rocco Gerace, and I'm pleased to be here as the chair of the Federation of Medical Regulatory Authorities of Canada.
With me is Louise Marcus, who is the director of professional affairs.
FMRAC is the voice, both nationally and internationally, of the provincial and territorial medical regulatory authorities.
My background is in the practice of emergency medicine and clinical toxicology. I practised for many years using opioids on an acute-care basis, and currently I'm the registrar of the College of Physicians and Surgeons of Ontario.
In describing the problem, we know that opioids are critical in the treatment of pain, whether that's acute pain, chronic pain, or terminal pain. There's no doubt that health professionals are very keen, along with their patients, to ensure that pain is treated. But treatment of pain is fraught with uncertainty, especially when it comes to opioids. The use of opioids ranges from underuse to overuse, and the dosing can be difficult. So we need to create a balance. We have to encourage the judicious use of these agents without creating an atmosphere of fear. There's no doubt that if we approach this too aggressively there will be fear among the prescribers.
We know there is overuse of these drugs in Canada. We are amongst the largest users in the world, second only to the United States. The problem is multifactorial, involving prescribers, dispensers, and, in some cases, the public by way of diversion. Misuse has terrible effects on the individual, sometimes creating addiction, which is occasionally fatal, but I'm sure I don't have to talk about the societal impact of overuse of these agents.
Just to describe what we see in the case of doctors, I'm pleased to say that the majority of doctors prescribe these drugs appropriately. But having said that, we are seeing increasing numbers of reports related to inappropriate prescribing at the regulatory level. These have a number of outcomes. We see some doctors, who want to treat appropriately, who deviate slightly from standards. These doctors really need an educational approach to help them do the job better. Occasionally we see pervasive inappropriate prescribing. The only outcome for these doctors is a regulatory approach, ultimately removing their ability to prescribe these agents. Rarely we see intentional overprescribing for the purposes of diversion. We look at this as criminal behaviour and feel that these individuals should be prosecuted to the full extent of the law. But I think it's important to remember that doctors want to do a good job in prescribing these drugs and in treating their patients' pain.
I'll describe briefly what has been done around the regulatory community. We've provided links to this activity in the material we've circulated.
First of all, at the national level, the regulatory authorities brought together experts to develop standards for opioid use. We have provided this reference. The document has been internationally validated. What these Canadian guidelines do is give evidence-based guidance for the appropriate use of opioids. Flowing from the document have been things like an opioid manager, a tool that helps doctors in the appropriate use of opioids. It also provides the regulators and others with a measure of the standard of care so that when we look at individual doctors prescribing, we know the sorts of outcomes we might have.
The second area is activity in Ontario, which I'm just going to allude to. This was a multi-stakeholder task force to consider what we might do as a community to deal with what we've described as a public health crisis. In this stakeholder consultation, we brought together multiple health professionals, patients, educators, law enforcement officials, and members of the provincial government. I'm just going to highlight a couple of the areas, and we will leave with you a copy of our report.
The recommendations we made are equally valid today. We've suggested that we create a coordinated and accessible system for the treatment of pain and addiction. We do know that in the community there is not adequate access to either treatment of pain or treatment of addiction.
You've heard about the importance of technology. We felt it was important to move forward with greater use of technology so that all providers have real-time access to the drugs their patients are receiving.
Key in our recommendations is the ongoing education of health care providers, individual patients, and the public at large. We feel it is important that all of these stakeholders are aware of the benefits and risks of opioids.
Finally, we felt that there needed to be a mechanism to empower all of the stakeholders to reduce diversion by facilitating an exchange of information, whether it be with regulatory bodies or law enforcement. Certainly, criminal activity has to be stopped.
In closing, I want to say that this is a very complex problem. I'm fond of quoting H.L. Mencken, a journalist in the U.S. from early last century. He said, “For every complex human problem there is a solution which is simple, straightforward and wrong.” This issue of opioid use is complicated. We all have to work together to find solutions that will be applicable across the country.
On behalf of the federation, I appreciate the interest of the committee and the federal government. It's only with the involvement of all of the stakeholders that we're going to come up with meaningful solutions to this difficult problem. I assure you that the medical regulatory community across the country would be pleased to help in any way it can.
Those are my comments. Thank you.