That's okay. I'm fairly flexible with the title, although I did work hard to get it.
Good afternoon, and thank you, Mr. Chair and members of the committee, for the opportunity to speak with you today.
As you heard, I am Dr. Eileen de Villa, and I am the medical officer of health for the City of Toronto, where I serve the 2.8 million residents of our very fine city.
I should point out that my comments here today represent not just my views, but also the views of Toronto Public Health and the Toronto Board of Health and are restricted to the proposed legislation for non-medical cannabis.
Just to kick off, I'd like to say that we do support the goal of Bill C-45 to provide Canadians with legal access to cannabis and, in doing so, ending the practice of criminalizing people who consume cannabis for non-medical purposes.
As you've heard from presenters thus far, the science on cannabis is indeed still emerging. We do know that it's not a benign substance. We know that it's a psychoactive substance with known harms of use. It's therefore imperative, in my opinion and in that of my organization, that the development of a regulatory framework be guided by public health principles to balance legal access to cannabis with reducing harms of use.
As you've heard already from some of the other witnesses before you today, there is health evidence that shows that smoking cannabis is linked to a number of health conditions, respiratory disorders, including bronchitis and cancer. It's also known to impair memory, attention span, and other cognitive functioning. It impairs psychomotor abilities, including motor coordination and divided attention. These are relevant public health concerns because of their connection to impaired driving in particular.
You've also heard that heavy cannabis use during adolescence has been linked to more serious and long-lasting outcomes such as greater likelihood of developing dependence and impairments in memory and verbal learning. In addition, the risk of dependence increases when use is initiated in adolescence, as rightfully pointed out by Dr. Maté.
As you may know, motor vehicle accidents are the main contributor to Canada's burden of disease and injury when it comes to cannabis. A recent study revealed that many Canadian youth consider cannabis to be less impairing than alcohol; however, as mentioned earlier, the psychoactive effects of cannabis can negatively affect the cognitive and psychomotor skills needed for driving.
In addition to strengthening penalties for impaired driving by amending the Criminal Code as put forward in Bill C-45, preventing canabis-impaired driving will require targeted public education. It's my understanding that the Government of Canada is preparing a public campaign to raise awareness about drug-impaired driving. Toronto Public Health would recommend that the government use evidence-informed messaging targeting youth and young adults in particular and launch this campaign without delay.
Further, I would recommend that the government support municipalities, provinces, and territories with local initiatives to discourage people from driving after consuming cannabis.
In its final recommendations to the government, the task force on cannabis legalization and regulation expressed concerns about the reliability of predicting impairment based on levels of THC, the main psychoactive compound in cannabis detected in samples of bodily fluids. These concerns have also been raised by other organizations, including those in the United States. I would recommend that the government make further investments in research and refinements to technology to better link THC levels with impairment and crash risk for developing evidence-informed standards.
The stated key objective of Bill C-45 to prevent young people from accessing cannabis is central to adopting a public health approach to the legalization of cannabis. We must apply lessons learned from tobacco and alcohol in developing the appropriate policy framework at all orders of government to prevent young people from using cannabis.
As mentioned by my colleague, evidence about tobacco advertising shows that it has an impact on youth smoking and that comprehensive advertising bans are most effective in reducing tobacco use and initiation. Personally, I welcome the requirements in Bill C-45 that maintain existing promotion and marketing rules in place for tobacco, including restrictions on point of sale promotion. We would also like to see these restrictions strengthened to include advertising in such venues as movies, video games, and other media, including online marketing and advertising, which are accessible to youth. Further, additional research on the impact of marketing and promotion is essential for making evidence-informed amendments to regulations and to develop prevention strategies. Federal funding should be targeted to this area.
Furthermore, we know that labelling and packaging are being used for promoting tobacco and tobacco brands. While I appreciate that Bill C-45 prohibits packaging and labelling of cannabis in a way that could be appealing to young people, a key omission in the act is a requirement for the plain packaging of retail cannabis products.
In a recent report, the Smoke-Free Ontario Scientific Advisory Committee identified plain packaging as a highly impactful tool for reducing tobacco use. The requirement for plain and standardized packaging for tobacco is currently being proposed in federal Bill S-5, and we recommend you do likewise for cannabis.
Fundamental to a public health approach for legalizing access to cannabis is regulating retail access. I am pleased with the Province of Ontario's recently announced intent to establish a provincially controlled agency for the retail sale and distribution of non-medical cannabis, separate from that for alcohol. A government-controlled retail and distribution system that is guided by public health objectives and social responsibility will ensure better control of health protective measures for cannabis use. I also urge your government to direct other provinces and territories to establish a retail and distribution system that is guided by public health principles and social responsibility.
I commend the government for not legalizing access to cannabis-based edible products until comprehensive regulations for its production, distribution, and sale have been developed. The experience in the United States cautions us of the challenges posed by edible cannabis products, including accidental consumption by children, overconsumption due to the delay in feeling the psychoactive effects, and in ensuring standardization of the potency of cannabis in edible products.
I would now like to draw your attention to some of the limitations of the existing cannabis research. While there is growing evidence about the health impacts of cannabis, some of the research findings are inconsistent or even contradictory, and causal relationships have not always been established. There is still much that we don't know. Most of the research to date has focused on frequent, chronic use, and the results must be interpreted in that context. More evidence is needed about occasional and moderate use, as this comprises the majority of cannabis use. I therefore urge you to earmark funding for research related to the full range of health impacts of cannabis use, in particular for occasional and moderate consumption.
Evidence-informed public education will be imperative for implementing an effective health-promoting regulatory framework for cannabis. There is an opportunity to promote a culture of moderation and harm reduction for cannabis that may extend to other substance use, especially among young people. The Government of Canada has stated its plan to pass Bill C-45 by July 1, 2018. However, in the meantime, Canadians continue to be arrested for possession of cannabis. Criminalization of cannabis use and possession impacts social determinants of health such as access to employment and housing. Given that cannabis possession will soon be made lawful in Canada, I urge you to immediately decriminalize the possession of non-medical cannabis for personal use.
In closing, I would like to reaffirm that Toronto Public Health supports the stated intent of Bill C-45 and recommends strengthening the health promoting requirements in the bill. I appreciate the complexity of building a regulatory framework for non-medical cannabis. Given that we're still learning about the impacts of cannabis use, the legal framework for cannabis must allow for strengthening health promoting policies while curtailing the influence of profit-driven policies. I look forward to ongoing consultations with the Government of Canada on the evolving policy landscape for this important public health issue.
Thank you for your attention.