Thank you very much, Chair.
Once again, I find it fascinating that for the benefit of Canadians out there watching, it is important to understand why a wrecking motion, as we call it colloquially here in the Ottawa bubble, cannot be allowed to continue forward.
Is this a Conservative-proposed bill? Yes, it is a Conservative-proposed bill, absolutely. In the original format that was proposed, it was to say that a natural health product cannot be considered a therapeutic product.
What we have seen from Mr. Julian is that clearly he wants natural health products to be considered therapeutic products, which is in direct contravention of the drafter of the bill.
As we look at some of the products that will be affected by this, we see that we had a great testimony from a practitioner of Chinese medicine named Pierre Chen, who was here at the last meeting. He has a school in Mississauga where he teaches traditional Chinese medicine. He is also a Harvard graduate. His father has been a practitioner of traditional Chinese medicine for decades and provides care to thousands of individuals in the Mississauga area.
Maybe Mr. Julian hasn't taken the time to actually visit businesses that will be directly impacted by this bill. What I heard when I took the time to go visit Mr. Chen is that for the vast majority of his products, even if the definition of therapeutic product were applied to natural health products, it might not make that much of a change to the overall cost of the actual natural health products because they were frequently used and prescribed by traditional Chinese medicine practitioners.
What he did make clear, though, was that a smaller fraction of substances would be significantly impacted because they were not prescribed or used often. The cost of these would go from approximately $30 to $50 for a large-sized supply to $1,500 for a large-sized supply. That would mean that for those folks who have the opportunity to use those products, it would certainly have a significantly negative effect on their ability to pay for those products.
As that difficulty continued and the labelling requirements also were then applied to natural health products, what we also know is that the labelling requirements would become unnecessarily burdensome. Indeed, I liken it to when I went to visit a distribution centre for McKesson, which is one of the largest medication distributors in Canada. I had an opportunity to visit their facility as well.
You clearly see that when these bottles of medication are picked and these large, floppy, accordion-style plastic-laden labels are stuck to the side of a bottle by glue, two things will happen.
First of all, the accordion-style label will “unaccordion” itself. That's perhaps not a word, but it's descriptive of what will happen. It unravels, becomes floppy and will gum up the machines because a bottle of product with a label with a long floppy tail of plastic hanging off of it is not designed to be picked up.
The other very negative thing that will happen is that when it has unravelled, it will come off the bottle. Not only then do you have a large floppy tail with glue on it flopping around inside machinery, but then you have the glue there as well. Of course, that will, in the vernacular, gum up the system and everything then comes to a crashing halt.
These large, accordion-style plastic labels start to have this downward effect when you require companies to put this labelling on.
I think the other sad thing is that inside the natural health product industry, there is an obvious ability to begin to use novel ways of labelling, such as QR codes.
QR codes, especially in an industry that has a very low likelihood of harm.... I'll come to the products that are mainly prescribed and used by individuals in Canada soon, but when you have an industry that has a low degree of harm, it's an obvious move to move away from printed labels with tiny, tiny print. I know that certainly as I reach a certain age, it becomes more difficult to read that tiny print. It would make only good sense to ask if this industry would be interested in trialing those low-risk medications with QR codes. What would that enable?
Now, there will be people out there who will argue that not everybody has a phone to scan a QR code. I understand that; however, that being said, this is an opportunity to begin to trial QR codes in unique, low-risk environments that would allow those who have the technological ability to scan a QR code to begin to ask about transitioning prescription products to a QR code as an ultimate goal?
Now, again, as many of you know, the Compendium of Pharmaceuticals and Specialties, the CPS, is a large dictionary-like tome with tiny print that lists all the known side effects of prescription medications, not just those that are common or that those are serious. Generally speaking, the CPS is not available to the general public but is often accessed by health care professionals. Wouldn't it be interesting to be able to take that amount of information, add it to a QR code and allow people to access it so they could be better informed? I would suggest that a better-informed populace is able to make even better decisions on behalf of themselves and their family members to say what is going to suit their needs.
I think the other huge benefit with QR codes, as we are a varied nation with varied backgrounds, cultural practices and languages, is that QR codes would be not only easy to update with respect to the information that is available to the consumer, to the patient, but also with respect to the language in which it is presented. We did hear, whether it's true or not, from the ISMP group that reading labels presented a challenge to people, and that this was one of the reasons for a potential adverse event.
I don't know, because I don't have that information. It would appear that ISMP doesn't want to provide it until Mr. Julian has attempted to gut Bill C-368.
Once we receive that information, we will be able to clarify whether it's a language disability or an inability to read English, for instance, or perhaps French. I don't know, because I don't have that data, but that would be interesting to know.
Again, if we had the data to make our decisions upon, it would be interesting to know if a new and unique solution on a trial basis was able to take not only English but any language and provide it to folks who had the ability to access it, such that practitioners who sold natural health products had that ability to say, “Hey, you know what? I understand that English is not your first language, but if you were able to scan a QR code or find a family member who is able to scan this for you, you could read the indications, the potential side effects, whether they are serious or whether they are minor but frequent, and you could then access those in your native language.”
I believe that it would be an incredibly unique and useful situation to be able to look at it and, again, I will say that it's an incredibly low-risk segment of the market for Canadians to be able to say that this is what they would like to see on a moving forward basis.
Why do we say it's low risk? We believe it's low risk because even though the data is scant, the data that we have been able to receive in the low-risk environment is related to comparisons with other difficult environments, such as prescription drugs.
What we could understand from the fairly recent data is that every single year, approximately 13,000 seniors are admitted to hospital because of prescription drugs. Does that mean that we should tighten up the regulations around prescription drugs? That's not what I'm saying here, but what we need is a significant context with respect to natural health products so that we can understand the safety that is associated with natural health products, and we do understand that 13,000 seniors alone—and as we all know, the definition by Health Canada with this particular study is age 65 and older—have been hospitalized due to the side effects of the prescription medications they are taking.
When we hear this number thrown about of 700 individuals who may have had an adverse effect attributable to a natural health product, without the context it's impossible to know whether this is a serious adverse event or whether it is simply a problem—and again I'll go back to what I heard them say—with reading the label and they got the product that they didn't want and they couldn't get a refund on it. That's certainly not serious, and I'm not convinced that it's an adverse event that is related to a natural health product.
That is why it's incredibly important to have the data that we will not have to be able to complete the study on Bill C-368. It's to say that there's no reason for Mr. Julian to want to have his NDP-1 amendment, which then moves natural health products back into the realm of being a therapeutic product. That is what presents the difficulties here. I think that for Canadians to have that ability to choose what they want is an incredibly important part of society here in Canada.
Whether or not I understand traditional Chinese medicine or somebody else doesn't understand it, that's okay. I don't need to understand it. What I do need to understand is whether it is a sector of the Canadian economy and Canadian health care that people choose to improve or maintain their own health, and whether it is safe. Because of the numbers—even the numbers that we've heard thrown around and the report that Deloitte was able to do on behalf of the natural health product industry—I believe that this is a very safe sector of the health care industry.
One of the things that we did here, Chair, as well, is related to vitamin D and vitamin D overdose. Again, without the substantiation of that particular case, I find it difficult to believe. Why do I find it difficult to believe? It's difficult to believe because many folks would take vitamin D in the dose of a 1,000 international units a day, and that happens very commonly. However, when you look at the science of vitamin D and exposure to sun, if you're out in the sun.... Again, this is not me giving advice to get you out in the sun, but I note, as an important indicator of not having data with respect to this bill, that when you are out there in the sun on a great sunny summer day, you could achieve a level dose of 25,000 international units of vitamin D just from the sun alone on a one-day basis.
Again, we heard Minister Holland here making an egregious claim, without substantiation, that there was an overdose on vitamin D. Minister Holland is not a health care professional. Does he know if it was vitamin D from vitamin C or vitamin B1 or B12? I would suggest to you that he probably does not know that.
Not having the data to substantiate this egregious claim—which was unsubstantiated and unwarranted and cast a shadow and a pall over an entire industry—I think directly points to the need to have data to understand the implications of changing any legislation with respect to natural health products.
We can look at vitamin B12. A long time ago, when I started to practise medicine in Truro, Nova Scotia, we often injected people with vitamin B12 on a weekly basis. What we now know is that if folks who have a B12 deficiency take enough of it orally, by mouth, they don't need to come every week for a vitamin B12 injection. This is if you're B12-deficient.
As we began testing folks for a B12 deficiency, we also realized that many of them were having supraphysiological doses of B12. Getting B12 at the frequency with which it was originally administered was not a requirement.
There are many different vitamins that we know are very safe. When you look at the fat-soluble vitamins, for instance, like vitamins A, D, E and K, that is one particular—