Health Committee on Sept. 13th, 2017

[Dr. Eileen de Villa]

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.

[The Chair, Liberal, Bill Casey]

Thank you very much.

Now we're going to go by video conference to Sharon Levy, director of the adolescent substance abuse program, who is speaking to us from New York. Thank you.

[Dr. Sharon Levy, Director, Adolescent Substance Abuse Program, Boston Children's Hospital, As an Individual]

Thank you very much for the opportunity to comment on Bill C-45, an act respecting cannabis and to amend the Controlled Drugs and Substances Act, the Criminal Code and other acts. As a developmental behavioural pediatrician and a researcher in the field of adolescent substance use, I'm concerned about the potential impact of these changes, specifically on the health of children and adolescents.

I've served as the chair of the American Academy of Pediatrics' national committee on substance use and prevention, and I've been the director of the adolescent substance abuse program at Boston Children's Hospital since its inception in 2000. Over the past 17 years, I've evaluated and treated hundreds of teens with substance use disorders, and while many of my comments have already been said in one form or another, I'd like to speak from personal experience.

Cannabis is an addictive drug that's particularly harmful to developing adolescent brains. Teens that consume cannabis have poorer life outcomes on a number of measures. They have more mental health disorders, including depression, anxiety, and psychosis. As a group, they complete less school and are more likely to be unemployed or underemployed than are their peers. These harms are distinctly different from the harms of use of other substances, such as tobacco, alcohol, and opioids, but they're no less serious or consequential.

As the director of an adolescent substance use disorders program serving youth aged 12 to 25, I work regularly with children and young adults who use cannabis. In fact, more than 90% of patients we see in our program have a cannabis use disorder. While almost all of them started their drug use histories with cannabis, few stick to one drug alone. Almost all of our patients in treatment for heroin addiction first used cannabis, and most use it very heavily.

We've treated a number of teen cannabis users who've developed schizophrenia right in front of our eyes, and who will never be able to care for themselves or live independently. We don't know what would have happened to them if they hadn't used cannabis, but the science and the statistics made us wonder if they might have had a different life had it not been for a completely preventable risk factor.

More commonly, we see again and again adolescents whose cannabis use more subtly impedes them. Two patients with similar histories paint a very clear picture of cannabis addiction. Both were good students in high school and were accepted to elite universities, where they began using cannabis heavily and ended up failing out. Both blame their changing academic status on heavy cannabis use. All four of their parents have been devastated. One of the fathers confided about adjusting his own hopes and expectations for his son. A few short years ago, he had envisioned his son becoming a successful professional. Now, he simply hopes he'll be able to function well enough to support himself.

The list goes on and on, with many adolescents that I care for falling short of their own educational goals, being underemployed, and struggling with mental health disorders while their families watch and wonder about their future.

Bill C-45 would prohibit the sale or marketing of cannabis to adolescents and young adults under the age of 18, and legalization is often proposed as a mechanism to reduce youth access by taxing and regulating cannabis, raising the price, eliminating the black market, and making shop owners gatekeepers. This approach has failed with other substances in the past. Marketing restrictions have historically been of limited utility when tested against the potential for substantial profits. While it's illegal for tobacco companies to market cigarettes to children, the familiar story of Joe Camel is a good example of how pernicious advertising can be.

In the U.S., the experience in Colorado, which was one of the first two states to legalize cannabis, is instructive. The number of teen users in Colorado increased by 20% in the two years immediately following legalization, while falling by 4% in the rest of the country. As a developmental pediatrician and also the parent of two teenaged children, I do not find these findings at all surprising. The retail sale of cannabis serves to normalize use. Teens are very responsive to cultural trends. When cannabis use is condoned, teens are more likely to use it. To argue otherwise is simply unreasonable from a developmental perspective.

In the U.S., evolving cannabis policies have resulted in changes to cannabis itself. The concentration of THC, the main active ingredient in cannabis, has increased dramatically over the past three decades, exposing users to higher levels of this drug than ever before. That's one of the reasons the science has been so tricky to pin down, because the product is actually changing. New edible products, including cookies, candies, and sodas have appeared on the market and are sold under the umbrella of marijuana.

Now, this market expansion is to be expected, because creating new and improved products is a tried-and-true technique for boosting sales, constantly inviting new users to try, and old users to add, new products to their repertoire.

Dabbing, a newly popular way of using cannabis, results in extremely high blood levels of THC. Higher THC exposure produces more euphoria and also causes more medical problems. In our clinical practice, kids are coming in with new problems that we rarely saw 10 years ago. Cannabis hyperemesis syndrome, which causes recurrent vomiting, was once rare but is now quite common in our practice. Psychiatric symptoms and complaints have also increased. Many of our patients have heard voices, experienced delusions, or become anxious and paranoid with cannabis use. In a study that our group is currently conducting in our primary care centre, more than 25% of cannabis users report that they've hallucinated while using cannabis, and more than 30% report having been paranoid.

As a pediatrician, I find these numbers terrifying. While there's been limited study of these questions in the past, our clinical experience suggests that these rates are increasing, just as would be expected with ever-increasing drug exposure.

Drawing from my experience as both a researcher and a clinician, I'd like to offer the following suggestions. First off, I recommend delivering clear messages to youth that avoiding cannabis use is best for their health. The American Academy of Pediatrics and the Canadian Paediatric Society both oppose marijuana legalization, and encourage parents, health care providers, teachers, and other adults to give clear and unambiguous guidance to children.

Campaigns that educate the public in an attempt to prevent use or delay initiation could be beneficial. For example, the Truth Initiative campaign that targeted tobacco use was remarkably successful in shifting the public perception of tobacco from glamorous to repulsive. Rates of tobacco use plummeted over the past 20 years with the stigmatization of smoking. Cannabis is well known as a psychoactive substance that's particularly detrimental to developing adolescent brains. Although misconceptions that cannabis is “healthy because it's natural” or “safe because it's legal” have cultural traction, they're false. They require ongoing strong messaging of evidence to the contrary.

Age restrictions are effective at reducing youth substance use. In the U.S., the enactment of the National Minimum Drinking Age Act, which effectively raised the drinking age to 21 in all 50 states, resulted in a 16% reduction in motor vehicle accidents. This was as a direct result of lower alcohol consumption. Canada, which has a lower drinking age, also has the highest rate of problem alcohol use in the Americas. These facts support higher minimum age limits as a good public health strategy.

Innovations to cannabis-based products are public health risks, particularly for adolescents. It may be that addictive substances need completely new policy approaches. Novel regulatory schemes that control or eliminate profits, control prices, and conduct surveillance at both the individual and population level should be considered. This type of approach would be expensive and would require unprecedented collaboration between branches of government and other sectors of society. History and current evidence suggest that simply legalizing cannabis and giving free rein to the industry that it will engender would be to entrust private industry with safeguarding the health of the public, a role that industry is not well designed to handle.

Finally, we need more clinicians trained to treat adolescents with cannabis addiction. This will require financial support. With the legalization of marijuana in Canada, there will be a pressing need for health care providers specialized in youth addictions and treatment of adolescent substance use disorders. I am pleased to report that the first physician to acquire specialized training in pediatric addiction medicine in all of North America is a Canadian. They are currently training at Boston Children's Hospital. Much more support and many more funded training spots and training programs are needed.

Thank you for listening and for the opportunity to address this panel.

[The Chair, Liberal, Bill Casey]

Thank you, Dr. Levy. We're fortunate to have access to your expertise. We'll be asking you questions shortly.

We'll now hear from the Ontario Public Health Association. Michelle Suarly is chair of the cannabis task group and Elena Hasheminejad is a member of the cannabis task group.

Are you going to split the time?

[Michelle Suarly, Chair, Cannabis Task Group, Ontario Public Health Association]

Yes.

[The Chair, Liberal, Bill Casey]

All right. I'll give you a signal when you're five minutes in.

[Michelle Suarly]

We're going to alternate.

Good afternoon, Mr. Chair, and committee members. Thank you for the opportunity to appear before your committee.

My name is Michelle Suarly, and I am representing the Ontario Public Health Association in my capacity as chair of the task group for cannabis. I am pleased to be joined by my colleague, Elena Hasheminejad, who is a member of the task group.

The Ontario Public Health Association, or OPHA, is a non-profit, non-partisan association that brings together those from the public and community health, academic, voluntary, and private sectors who are committed to improving people's health. Many of our members, whether they are public heath nurses like us or from other fields, are working on the front lines to promote and improve public health in their communities.

OPHA has been championing prevention, health promotion, and protection since its creation over 68 years ago. Our mission is to provide leadership on issues affecting the public's health and strengthening the impact of people who are active in public and community health throughout Ontario.

Our task group encourages the federal government to adopt a public health approach to cannabis regulation to allow for more control over the risk factors associated with cannabis-related harms. Based on evidence that the risks of cannabis are higher with early age of initiation and/or high frequency of use, a public health approach would aim to delay the age of initiation of cannabis use, reduce the frequency of use, reduce higher-risk use, reduce problematic use and dependence, expand access to treatment and prevention programs, and ensure early and sustained public education and awareness.

We advocate that the federal government apply the health equity lens and recognize the role played by the social determinants of health, understand those who are most likely to be affected by the legalization of recreational cannabis, and support corresponding strategies to mitigate impacts.

Elena will now highlight OPHA's recommendations.

[Elena Hasheminejad, Member, Cannabis Task Group, Ontario Public Health Association]

Thank you, Michelle.

I'd like to start off by indicating our support for the federal task force on cannabis legalization and regulation's objective to protect young Canadians by keeping marijuana out of the hands of children and youth.

As I'm sure has been shared with you today and throughout this week, Canadian youth have one of the highest reported rates of use among developed countries, which we know is concerning, because research has found that the brain continues to develop until the early twenties.

To protect young Canadians, it's important that we consider some of these prevention measures. Health Canada recognizes that tobacco packages have been powerful promotional vehicles for the tobacco industry and has stated that it is committed to introducing plain packaging, which a lot of my fellow colleagues have also highlighted today.

We recommend that the same regulations be put in place for cannabis products as well. We recommend clear and restrictive requirements for the mitigation of the sale and promotion of products to youth, consideration of unintended exposure, and retail licensing requirements. We recommend that all cannabis and cannabis containing product labels include clearly displayed THC and cannabinol content, evidence-informed health warnings, harm reduction messages, and information on accessing support services.

Although plain and childproof packaging may reduce the risk of unintended exposure through regulation, it would not effectively reduce the risks for edibles. Children may mistake edible products as regular food when these products are not enclosed in their packaging. With that in mind, we recommend that regulations regarding edibles consider the impact of products manufactured that resemble candies, cookies, gummies, and other products typically marketed to children.

Last, given that a significant proportion of cannabis users are young adults, we encourage the federal government to facilitate discussions with all levels of government to ensure that the minimum age is consistent. A consistent minimum age would eliminate cross-border variation, which would limit the effectiveness of minimal legal age regulations in protecting young people.

[Michelle Suarly]

We also want to ensure that Canadians are well informed through sustained, appropriate public health campaigns, and for youth in particular, to ensure that the risks are understood.

As mentioned earlier, the Canadian Centre on Substance Use and Addiction report “Canadian Youth Perceptions on Cannabis” stated, “Overall, youth considered cannabis to be less harmful than alcohol and other substances. ”Youth also felt confused about cannabis laws.

We are concerned that there is not enough public awareness about the harmful effects of cannabis. Further research is needed to continue to understand the impact, be it on brain development, pregnant and breastfeeding women, or other areas. We urge the federal government to engage youth in the creation of health promotion materials and strategies targeted to them.

To ensure that the public is fully aware of the harms associated with cannabis use, we recommend that the government develop and implement an evidence-informed public education campaign ahead of the federal legislation being passed. Both general awareness to promote lower-risk cannabis use guidelines and targeted initiatives to raise awareness of the risks among specific groups, such as adolescents, those who are pregnant, and people with a personal or family history of mental illness, are needed.

It is also crucial that the federal government commit to using a high percentage of revenue gains from the sale of cannabis products as a source of funding for prevention, treatment, harm reduction, and enforcement. Significant funding toward a population approach to mental wellness, stress management, and healthy coping strategies must also be considered.

[Elena Hasheminejad]

In terms of keeping our roads safe, it's important to note that we know that impaired driving is a leading criminal cause of death and injury on our roadways, and cannabinoids are among the most common psychoactive substances found in deceased and injured drivers in Canada.

We agree with the federal government that there is a need to strengthen our impaired driving laws to better understand drug-impaired driving. In addition, we also support the recommendation of the Canadian Association of Chiefs of Police for advanced funding for enhanced officer training and drug recognition technology investments to ensure that there is a clear and reliable system for identifying, testing, and imposing consequences for drug-impaired driving prior to legalization.

In terms of workplace wellness, cannabis use or impairment in the workplace, especially in safety-sensitive positions, can pose a danger to everyone, including the person who's impaired. While substance use in the workplace is not a new issue, employer groups and workplaces would benefit from clear guidance from both the federal and provincial governments regarding measures such as policies and procedures that they can follow through with to address cannabis use in the workplace. In addition, access to programs and services to support employees with dependence or problematic substance use needs to be greatly increased.

[Michelle Suarly]

Lastly, we support research and ongoing data collection, including gathering baseline data to monitor the impact of the new framework.

Our task group emphasizes the need for investing in research and centralized national surveillance systems so that problems could be detected at an early stage, successes are tracked and emphasized, and course corrections can be made. This should be implemented now so that we have baseline data.

We also emphasize the need for a comprehensive policy monitoring and evaluation framework. Moving forward, we recommend further research to investigate maternal cannabis use during pregnancy, impact on birth and childhood outcomes, the impact of cannabis exposure through breastfeeding, the impact of cannabis use on mental health, interactions between cannabis use and pharmaceuticals, testing methods to determine cannabis levels and/or impairment levels, and the health effects of heavy, regular, or occasional cannabis use, just to name a few.

Our recommendation is to enhance current national surveillance systems such as the Canadian community mental health survey and the Canadian tobacco, alcohol, and drugs survey to include additional questions on public opinion on cannabis policy and regulation, awareness of the health effects of cannabis use, and the effects of cannabis use during pregnant or while breastfeeding. This data can help inform the development and changes to health policy, public health programs, and communication campaigns geared towards cannabis use.

[Elena Hasheminejad]

We would like to conclude by thanking you for the opportunity to convey the ideas and recommendations of our members. Further recommendations related to the legalization of the recreational use of cannabis can be found in our position paper, which we've left with you today, titled “The Public Health Implications of the Legalization of Recreational Cannabis”.

Our position paper expands on the recommendations that we've made today, along with other areas of focus such as taxation, age, sales, and access, and we would be happy to speak to these as well.

OPHA believes that Bill C-45 and the recent response from Ontario are steps in the right direction. We believe that, through effective public health-focused policy interventions, a comprehensive, collaborative, and compassionate approach to drug policy can be put in place that the government's commitment to legalize, regulate, and restrict access to cannabis.

We welcome the opportunity to collaborate with the federal government and others to achieve this shared goal and will continue to offer our local, provincial, and national networks our evidence-based information, knowledge, and expertise.

We thank you for your time and consideration today.

[The Chair, Liberal, Bill Casey]

Thank you very much.

Now we'll go to a round of seven-minute questions. We'll start with Ms. Sidhu.

[Sonia Sidhu, Liberal, Brampton South, ON]

Thank you, Chair.

Thank you, all, for your presentations.

A key goal of the legislation is to restrict access of young Canadians to cannabis. In order to shut down the illicit market and keep profits away from criminals, the government has set the federal legal age at 18, but with provinces able to change that.

Mr. Fischer, could you tell us the reasons you believe 18 is the right minimum age for the federal law?

[Dr. Benedikt Fischer]

Eighteen, or 19 as decided in Ontario, is a good political compromise, I'd say. It's a good political compromise because it makes the age limits consistent with alcohol and tobacco regulations. It wouldn't make sense otherwise. It wouldn't make sense to let people drink at age 19 and consume an overall less hazardous substance at a higher age.

At the same time—and I've used this term before—I think there's a certain sense of, if you allow me, political naïveté in the sense that we think we will legalize and regulate and set an age limit, and all of a sudden all the young people below the age of 19 who used cannabis under prohibition, when the age limit was 500 years or 0, will all of a sudden stop using cannabis. We have to be very realistic and aware of that.

The best we can hope for under the age limit of 19 for people under the age of 19 is that we will have trickle-down beneficial effects on that age group that will make their use of cannabis less risky and less harmful through regulated products, safer distribution, etc., combined with more effective, more realistic, and evidence-based prevention. Please, do not fool yourselves that legalization with the strictest and best possible regulation will eliminate cannabis use by the people under age 19. We would all fool ourselves if we thought that. It will not happen. That is the Achilles heel of the current policy and law proposed. Politically it wouldn't be more defensible to lower the age limit. I understand and appreciate that, but we have to put everything in motion to reduce the risks and harms of what will certainly be ongoing cannabis use at the highest levels, relative to other populations, in the age groups below 19.

[Sonia Sidhu, Liberal, Brampton South, ON]

Thank you.

I noticed that you also support the model of the LCBO in Ontario as the distribution system. Why do you feel that is better than private storefront sales?

[Dr. Benedikt Fischer]

I supported all along a publicly controlled, public monopoly distribution system. Whether LCBO stores alone will be the best system, I think is in question. I question that personally.

I advocated for a hybrid model between public, LCBO-based sales and community storefront outlets primarily for the following reason. The success of legalization will, to a large extent, hinge on the what extent to which we can effectively bring current consumers from illegal markets and sources to legal sources, in practice—not on paper or in theory. In other words, if we design a distribution system now that is perfect on paper but is too strictly regulated, too sterile, too aloof from the realities and wishes and preferences, as subjective as these may be, of current users, then they will not go there, but keep buying illegal, hazardous, risky products from illegal markets and sources. Legalization will fail. It will have succeeded maybe in abstract theory, but it will have failed in practice. This is a crucial hinge variable of the success of this, whether we can bring users, all of them or as many as possible, from illegal markets and sources to the legal markets. Therefore, that part of the equation needs to succeed.

At this point, we don't know perfectly how to do that best and well. We have good theoretical ideas. I think some of the ideas are a bit misguided as currently designed, probably being overly restrictive and too sterile, but it remains to be seen. We need to try to see what happens, and if necessary, adjust. That may have to be a little, that may have to be a lot, but we have to bring people into legal distribution systems. If that doesn't happen, if we don't succeed, legalization, to a large extent, as a public health venture, will fail.

[Sonia Sidhu, Liberal, Brampton South, ON]

Thank you.

My next question is for Dr. de Villa.

Thank you for serving 2.8 million Toronto residents. I noticed that you support the idea that cannabis products should be sold in plain packaging. Could you tell us why you favour this model?

[Dr. Eileen de Villa]

As I indicated in my remarks, the idea is to borrow from that we know from other products already out there. There's quite a bit of research with respect to how packaging impacts the uptake in use, by youth in particular. We do know, and I do believe there is good reason to believe, and I think my colleagues to my right also speak about this within their position, that plain packaging not only allows an opportunity for appropriate information to be conveyed, but also minimizes the attractiveness to youth.

As we've heard from all of us across the table here, there are particular concerns around the initiation of cannabis use among youth, particularly heavy use by youth, and its long-term consequences. That's where the evidence is actually most solid, despite the fact that we know that our comprehensive understanding of the health impacts of cannabis is still something that's very much in development.

The notion is to try to minimize or reduce its attractiveness to youth so as to minimize the negative health and social impacts associated with early initiation and heavy use by youth.

[The Chair, Liberal, Bill Casey]

The time's up.

Dr. Carrie.

[Colin Carrie, Conservative, Oshawa, ON]

Thank you very much, Mr. Chair, and thanks to the witnesses. Again, we've had great witnesses here, but so little time to ask them questions. I have so many. Maybe I can start with Dr. Levy.

First of all, thank you very much for participating in this really important committee. As a developmental pediatrician and somebody who's on the ground, I really appreciate your input. I want to ask you a question.

We've had different opinions, but one thing is clear: the younger you start smoking marijuana the higher the chances of becoming addicted. I was wondering what you think of the fact that the legislation will allow 12-year-olds to 17-year-olds to possess up to five grams. My understanding is that could be 10 to 15 joints. Is the federal government sending the wrong message with that?

[Dr. Sharon Levy]

You know, that's an excellent question. I've heard a lot from other committee members about the need to decriminalize marijuana possession, marijuana use, and I think that's very important. What we don't want to do, because we know it's a failure, is to arrest users, arrest those who are in possession of cannabis and send them off to jail or give them criminal records. That doesn't help anybody and it's a waste of effort, it's a waste of time and money, and it also creates bad consequences down the road.

On the other hand, there are ways in which the judicial system can be used as leverage to get people into treatment. For underage users, I think there is a tremendous opportunity not to arrest them or give them a criminal record or throw them in jail, but somehow to use their possession of marijuana to have them evaluated, to have them meet one-on-one with a physician, social worker or other health professional who can really figure out where on the spectrum the youth falls and determine the appropriate next steps, which could be anything from advice and guidance all the way to more formal treatment for cannabis use disorder.

[Colin Carrie, Conservative, Oshawa, ON]

At the previous panel, I asked a similar question of one of the other doctors. What has become obvious is that this legislation really doesn't provide those tools. I don't think anybody wants to see a young person criminalized and have that record follow them, but one of the witnesses did say that there should be a way to allow the issue to be addressed, and we still haven't come up with any answers here. We're hoping, as all of us sit around this table, to make it a better bill. If the government is going down this route, we want to make it the best we can.

There is also a controversy over how dangerous cannabis is to young minds. Again, the former panel said it is more dangerous because of the cumulative effects for young people. We heard Dr. Fischer say this is a less dangerous substance.

I was wondering about your opinion. Is cannabis less dangerous than alcohol for youth, or is it more dangerous? You brought up different things about new disorders, things along those lines. What is your opinion?

[Dr. Sharon Levy]

Each substance has its own profile of consequences and harms. In some way, the question is really comparing apples to oranges.

Cannabis use very clearly cause problems with mental health disorders and problems in functioning. By the way, those are harder to pick up because, typically, monitoring systems are picking up things such as heart disease and lung cancer, the classic problems with smoking. They are not so good at picking up depression or underemployment, so we can miss some of those. That's an important point.

To ask which of those is more harmful is really not such a logical question. I think both of those outcomes are bad. We'd like to avoid all of them. To me, trying to compare the substances doesn't make a whole lot of sense.

[Colin Carrie, Conservative, Oshawa, ON]

I agree. I think both of them are very significant and very serious. Because youth in Canada have this idea that it's just pot and nothing to really worry about, we really have to get ahead of the education. The current government has had two years to get out ahead of this and it's a real lost opportunity.

That's what I want to talk to the OPHA about. You mentioned the importance of things such as data collection. Again, we're trying to make this a better bill. We've had witnesses say that data collection should be ongoing now, and I don't think this bill even addresses it. I don't even see anything moving forward in terms of data collection and helping out the provinces and municipalities on how to do that.

You talked about education. Again, what a lost opportunity it has been. The government has had two years to do that. We had a private organization talk about what they're doing and the government has put forward, I think, $9.5 million over five years for Canada. Colorado put forward $10 million per year for a population of five million people; and the State of Washington, $7 million for seven million people. I wonder if you could really comment on the lack of direction in this bill for data collection and education, and you also meant treatment.