I prefer not to use the word “threat”, because none of the companies, none of our members, have ever viewed this as a threat. Rather, it's a reflection of the reality of the situation.
I can comment quantitatively. I have an advantage that you don't and that no one on this committee does. You're looking at lagging indicators in the reports that come out with data that's a couple of years old. I get to talk with these companies on a daily basis. While I can't name companies—I can name one, but I'll save that for my third comment—I can tell you that at least six planned drug launches by our member companies have been delayed, including drugs for rare diseases, because of the uncertainty around PMPRB. We know that only 15 of 54 drugs that have been approved by the U.S. FDA have even been submitted to Health Canada for approval. I have a list of 39 drugs, and not just on rare diseases—they include cancer, Parkinson's and HIV—that have not been submitted to Health Canada for approval specifically because of the uncertainty around PMPRB. This is not for other reasons.
That's quantitatively; I gave you a few numbers there.
Qualitatively, Life Sciences Ontario did a survey of companies and executives just a couple of months ago: 35% say they've already delayed bringing new treatments to Canada; 96% anticipate that these new rules will drive decisions to delay or not bring new treatments to Canada; and 90% say that the reform will reduce research, clinical trials and innovation.
My last point, if you want a very specific example, is the letter that was submitted to this committee by a member company, Medicago. It states very clearly that as a Canadian company—we've all heard about Medicago, and are so proud to have a homegrown company—when it comes to the launch, it may not be here in Canada. It's because of PMPRB.