HEAL Committee Meeting

STANDING COMMITTEE ON HEALTH

COMITÉ PERMANENT DE LA SANTÉ

EVIDENCE

[Recorded by Electronic Apparatus]

Tuesday, February 10, 1998

• 0910

[English]

The Chair (Ms. Beth Phinney (Hamilton Mountain, Lib.)): I call the meeting to order.

This is the 15th meeting of the Standing Committee on Health. We're doing a study of natural health products.

I'd like to introduce the witnesses. I think I'll just introduce the groups and then they can introduce themselves.

We have the Committee for Preserving the Integrity of Chinese Herbology and Traditional Chinese Medicine. Dr. Wu, are you the head of that little delegation?

Dr. Joseph Wen-Teng Wu (President, Committee for Preserving the Integrity of Chinese Herbology and Traditional Chinese Medicine): Yes.

The Chair: I'll ask you to introduce the other two when I'm finished here.

Then from the company Personal Health and Nutrition we have Paul Hogarth, and from the Canadian Pharmacists Association we have Dr. Poston and Ms. Willems.

We'll just do the order that we have on our printed-up agenda here, so I'll ask Dr. Wu to start.

Would you introduce your two other panellists?

Dr. Joseph Wen-Teng Wu: Thank you for giving me this opportunity to appear before the Standing Committee on Health. I hope this will help all Canadians concerned with the issue.

Let me introduce Dr. Henry Lu. He's my colleague, and we've worked in the PTCM for many years. He's the principal of the International College of Traditional Chinese Medicine, the oldest one in B.C. Also, he's the director of my association.

Dr. Bill Chan has two professions, one as an MD, a western doctor, and the other in Chinese medicine as well. So it's pretty good to have those differences on this issue. He's a member of the PTCM and also president of Treasure Box Products Inc.

Thank you so much.

There is a growing number of Canadians who benefit from traditional Chinese medicine and use it regularly as an alternative form of health care. Due to inappropriate regulatory policy right now for TCM, as I have analysed in my report paper, Health Canada's traditional herbal medicine guidelines undermine traditional Chinese medicine by ignoring its philosophy, theory, application, and culture.

Canadians using TCM for health care have difficulty assessing TCM products in Canada. The traditional herbal medicine guidelines employ inherently biased pharmaceutical standards that ignore TCM paradigms and practices, making it virtually impossible for TCM products to pass such criteria. These guidelines have now threatened Canadians who want freedom in their choice of health care through TCM and TCM herbal products.

I wish to point out that TCM has existed in Canada for a century. In addition, the growing TCM sector provides economic and employment benefits that should not be ignored. According to a recent CTV Angus Reid Group poll, publicly released on September 8, 1997, 70% of Canadians feel the provincial health care plans should cover the cost of alternative medicines and practices. In addition, 66% of Canadians feel the government should be advocating the use of alternative medicines in order to potentially reduce the cost of the already overburdened health care system.

Furthermore, China, Taiwan, Hong Kong, Japan, and some of the states in the United States have already recognized the validity and efficacy of Chinese medicine and their formulas and products.

• 0915

In conclusion, I sincerely request the Standing Committee on Health to take the following actions to ensure the legal recognition and availability of TCM and TCM products to the Canadian consumer public and to make it possible for coverage by provincial health care plans.

One, recognize and accept the claims of the Chinese pharmacopoeia, such as in but not limited to appendix 1. Appendix 1 has the ancient pharmacopoeia. Appendix 1 also has the official pharmacopoeia from the People's Republic of China's Ministry of Health.

Second, recognize and accept the claims, ingredients, and modifications thereof of traditional Chinese herbal formulas from traditional texts and references, such as in but not limited to appendix 2. In appendix 2 I have incorporated about 49 old texts and references from famous doctors in Chinese medical history. That's just for reference, but there are some more.

I'm happy to answer any questions, and my colleagues are as well.

Thank you so much.

The Chair: Thank you very much. It's kind of you to keep your remarks so brief.

Paul.

Mr. Paul Hogarth (Owner and Founder, Personal Health and Nutrition): I'll be speaking a little more informally today, because my information got packed in the wrong case and I brought the wrong one, so I'll have to wing it the best I can.

My name's Paul Hogarth. I'm more of an independent as far as health care goes in the natural sector. I'm a bestselling author in Canada and the U.S. and I'm an international lecturer throughout the world now, speaking about nutrition and its benefits for human beings and how we should be able to use it.

What I find in the world today, especially in westernized civilization, is that more and more people are turning towards natural products to help themselves with sickness and diseases. I firmly believe that the way it's going right now, people having free access, should remain the way it is. I don't feel that people should step in and think they can change it and make it better.

In regard to policies being put on the table, I find that when I go around and talk to people, it's not the people themselves who are concerned about natural products and their benefits or harms per se; it's the larger industries who are out to regulate and make more profits on a growing business and growing trend.

Personally, as I talk to people, I am appalled that people with decision-making power would believe we want more regulation in regard to our natural health care products and supplementations, because sections 4 and 5 of the Food and Drugs Act specifically state safety procedures and protocols for unnatural supplementations.

I just firmly believe and would like to get the point across that if a person smokes, for example, and you talk to them and try to tell them to quit, they can say, “If I want to kill myself, it's my own free choice. I can smoke. It's my choice. If I want to go to the store and buy it, it's up to me.” If a person wants to make themselves healthy with vitamin supplements and herbal supplements, we're now going to be told, “No, you can't just go pick it up and do it. You have to go to your doctor, your naturopath, or your homeopath and have it prescribed to you. You don't have the right to make yourself healthy, but you can kill yourself.”

I'd just like to get the point across that the regulations in place are already good enough for the safety of Canadians, and any further regulations are only going to harm Canadians as far as their health goes, because they'll no longer have free access. The current policies I see going through are not going to allow free access. Free access is walking into your health store.

There are 2,000 health stores in Canada right now, which will be affected severely. There are close to 100,000 people who have their own companies through network marketing who are going to be affected severely through the regulations. I hope they are prevented.

I thank you for your time and am willing to answer any questions you have.

The Chair: Thank you, Mr. Hogarth.

Now, who's going to start for the Pharmacists Association?

Dr. Jeff W. Poston (Director, Research and Practice Development, Canadian Pharmacists Association): Thank you, Madam Chair.

My name's Jeff Poston. I'm director of research and practice development for the Canadian Pharmacists Association. I welcome this opportunity to present today, together with my colleague, Noëlle-Dominique Willems, who's director of government and public affairs.

• 0920

The Canadian Pharmacists Association represents more than 9,000 pharmacists in all areas of practice in Canada. We'd like to submit the following comments to the committee as it embarks on this important study of herbal and homeopathic products.

The regulation of herbal and homeopathic products has always concerned community pharmacists, more so recently because more and more pharmacists are being asked by their patients to explain the value of these products.

Some stakeholders who will appear in front of you will allege that pharmacists are trying to increase their market share by integrating herbal products into the wide array of health products they already provide. Yet data from the Canada Health Monitor Survey, which is a survey of more than 2,000 Canadian consumers, indicate that already 65% of consumers purchase their complementary medicines in a pharmacy. So there's little for pharmacists to personally gain by advocating for stronger regulations.

However, as front-line health care professionals, pharmacists are extremely interested in providing safe, optimal drug therapy. And since herbal remedies are being used more and more, they need to be considered as a part of the continuum of pharmaceutical care. Pharmacists need to know the pharmacological properties and effective uses of common herbal products. They need to be able to recognize the potential for any drug interactions or allergic reactions and be assured of the quality of the products they provide.

We therefore recommend that herbal products be treated as self-medication products and be considered as an integral part of the products covered under the drugs section of the Food and Drugs Act.

We further recommend that herbal remedies be submitted to the principles of drug schedule harmonization, as defined in the final report of the National Drug Scheduling Advisory Committee of August 1997, which determines the conditions under which drugs in different schedules must be sold.

With respect to meeting the costs of this regulation, we recommend that the framework developed by the Therapeutic Products Directorate for cost recovery should apply across the board to all manufacturers of herbal and homeopathic products in Canada.

We commend the federal government on the convening of the advisory committee on herbal products, chaired by Dr. Frank Chandler, and we support the principles on which they proceeded to do their work.

We believe, however, that it's not necessary to add a third category to the Food and Drugs Act. Herbal products can and should be accommodated in a framework that takes into account the dosage form of the products and whether or not they make health claims. The three-level risk grid can also assist in the classification of those products.

We do agree with this committee that a system of simple notification should be set up for some of those products with low-level risk, particularly for those products where standards and traditional references already exist.

In our presentation today, we want to focus on three traditional areas of concern with respect to therapeutic products: safety, efficacy, and quality. I'd like to address the safety issues first.

Herbal products, like all forms of self-treatment, present a potential risk to human health. Self-medication may delay a patient from seeking professional advice. In the Canadian health care system, people who do not receive appropriate treatment from the onset may eventually cost more to the system. It's therefore important that clear and complete information about complementary treatments be available to people who choose to self-medicate with these products.

Many aspects of the safety of herbal products need to be assessed by the government when proceeding with the regulation of these products—for example, the acute and chronic toxicity of various dosage forms and the impact on patients of long-term use. Therefore we recommend that, where possible, herbal products are subjected to the same safety standards as those used for other therapeutic products.

While a number of herbal products have traditional, established uses, it's important that consumer safety is additionally protected by appropriate labelling. Therefore, we recommend that clear warnings should appear on products to deal with issues such as excessive ingestion, hypersensitivity reactions, the potential for phototoxic reactions, side effects, and potential interactions with other foods and medications.

• 0925

With respect to the documented information available on drug interactions with conventional medicines, this is somewhat limited for herbal products, and there's a need to identify herbal ingredients that may potentially interfere with specific categories of conventional drugs based on known phytochemical and pharmacological properties of certain herbs and documented side effects.

We therefore recommend that Health Canada should encourage research on the interactions of herbal products with conventional medicines and broadly disseminate such information to health care professionals and consumers.

We also have concerns with respect to the reporting of adverse drug reactions. There are no mechanisms in Canada for reporting adverse effects from self-medication products or herbal products, unless the effects are so severe that the patient has to go to a health professional or a hospital.

We recommend that the government should investigate the establishment of a reporting process for adverse drug reactions whereby a consumer could file a report on untoward events that may indicate reactions or side effects to self-medication products.

Moving on to consider efficacy, claims of efficacy have led to the increased use of herbal products and have contributed to the current need to review herbal products. As with other remedies being assessed in Canada, there is a move toward evidence-based decision-making. We believe that herbal products should be subjected to the same rules as those required for other therapeutic products, particularly if they are to be considered for inclusion on publicly funded drug benefit lists.

Documented clinical data does not exist for most herbal products. However, there is no reason why some traditional products should not be available for minor conditions provided they are consistent with traditional uses, that based on known pharmacological and toxicological data their use appears rational, the products are of suitable quality and safety, and the appropriate warnings and contraindications appear on the label. However, significant therapeutic claims should not be made for these products unless they are evidence based.

We recommend therefore that therapeutic claims of efficacy for herbal products should be substantiated by available clinical data. We further recommend that Health Canada consider the regulation and monitoring of the types of claims and advertising made by herbal product manufacturers. We recommend that all herbal and homeopathic product advertising be pre-cleared by the agency that also monitors the advertising of non-prescription medication, and we recommend that Health Canada addresses the issue of promotion by association through appropriate regulations.

With respect to quality, we feel that herbal remedies present unique problems that arise because of the nature of herbal ingredients, which are usually a complex mixture of plant constituents that may vary greatly, depending on environmental and genetic factors, as well as the source or part of the plant from which the ingredients are obtained. The control of raw materials is essential to ensure that standardized, quality herbal product is being consistently manufactured.

Finally, we have a few words about the role of the federal government. As more people try complementary medicines, the natural health products community is opposed to strong federal intervention in this field. It's important, however, to reaffirm the important role the federal government plays in ensuring the safety of Canadians in many domains: foods, drugs, consumer goods, and transportation. No legitimate reason exists to forgo this important role where herbal and homeopathic products are concerned.

The success of regulations under Canada's Food and Drugs Act to ensure the safety and efficacy of pharmaceutical preparations should not lull us into a false sense of security. We enjoy safe and effective drugs and consumer goods because the Government of Canada has had the foresight to adopt a regulatory framework that makes it so.

We agree that as much as possible, consumers must continue to be able to choose the types of products they wish to choose, but there is an onus on government to ensure that the products from which they make their selection are safe.

• 0930

We therefore recommend that herbal products be submitted to the same standards in manufacturing as other products deemed fit for consumption in Canada. Thank you very much.

The Chairman: Thank you.

Mr. Hill.

Mr. Grant Hill (Macleod, Ref.): Thank you.

Thank you for your presentations. I wonder if I could direct my initial comments to treatment with Chinese medicines.

You're the first group that has actually come here and suggested that we expand medicare to include your area of expertise. Do you mean we should cover the actual products or the practitioners under medicare?

Dr. Joseph Wen-Teng Wu: You should cover both.

Mr. Grant Hill: Do you have any indication of what that would cost?

Dr. Joseph Wen-Teng Wu: I don't have the precise information but I can get it from Taiwan. In Taiwan right now, the national health care system covers the practice of Chinese medicine. It also has a list of herbal products that are paid for by the medical service plan. I can take a trip and to get the precise information for you.

Mr. Grant Hill: It would be handy for the committee to have that information and know which products are covered. You could just provide that to the clerk and give an approximation of what the cost would be for Canada.

Dr. Joseph Wen-Teng Wu: Yes. I will do this homework for the committee.

I'll try to arrange a symposium between TPP and the Taiwan ministry of health, which is in charge of Chinese medicine. In fact, Canada has more of a positive and active response to this approach but on the other side it's still in the process.

I will try to make the symposium possible and get the information we need.

Mr. Grant Hill: Okay.

Dr. Henry Lu (Committee for Preserving the Integrity of Chinese Herbology and Traditional Chinese Medicine): You asked how much extra it would cost, but the question should be how much of a reduction will there be in the costs. If I'm sick, I go to the hospital and it might cost the government $10,000. If I go to a Chinese doctor it may cost only $500.

Mr. Grant Hill: You'll never get sick—your point. Okay. That's fair.

We would also like the cost-benefit analysis, if you can provide that. It's tough, but I know that's the claim.

To the Canadian Pharmacists Association, we hear quite commonly that the big pharmaceutical companies would capture this market if the goal posts were raised so high that the small manufacturers could not meet the standards.

We also hear—and I think it's accurate—that a lot of pharmaceutical preparations are much more toxic than some of the natural products. We hear the data that aspirin kills 1,400 people here in Canada per year, and that's accurate according to my research.

Why would you then need the goal posts to be the same for products that are relatively less harmful? Since there can be harm, why would you have the goal posts the same height for less toxic products?

Dr. Jeff Poston: I think there's good evidence that shows herbal products can be just as toxic as some traditional preparations or pharmaceuticals.

Mr. Grant Hill: Could you provide us with data on morbidity and mortality—mortality data in particular?

Dr. Jeff Poston: What you have is a series of reports in the published literature. For example, in Belgium recently 70 people were hospitalized with renal failure, required renal dialysis, and went on to kidney transplants as a result of an error in labelling of different herbal products. There's evidence of hepatic toxicity—liver damage—in patients who have used herbal teas.

There's a considerable body of literature that illustrates toxicity and the potential for toxicity with traditional herbal products. They've had traditional uses and have been used for many years, but there hasn't been the system of science to gather information relating to toxicity and evaluation as there has been with our more usual pharmaceutical preparations.

Mr. Grant Hill: I would request once again that you provide just a bibliography of some of that data so we could review it—

Dr. Jeff Poston: Yes, certainly.

Mr. Grant Hill: —and particularly information on serious side effects such as you have suggested, and mortality. We often hear there has not been a single death from natural health products. Refute that, if you can. I think that would help.

Dr. Jeff Poston: Yes.

• 0935

The Chair: Please make sure you send the information to the clerk of the committee.

Dr. Joseph Wen-Teng Wu: May I say something about this issue? I have been dealing with this issue with TPP for four years. For instance, in 1995 as a policy issue they put out their list of restricted herbs. Six of them are very commonly used in Chinese herbal formulas. So I asked TPP why they listed these commonly used herbs, and they said there were toxins. For instance, for paeonia they say there is a toxin in the branch and in the leaves. But we don't use the leaves; we don't use the branch. We use the root, and there is no toxin in the root.

Also, we have to go through standard processes. I— [Editor's Note: Inaudible]— these people when they use Chinese herbs. They may take a branch and process it right away. They use it right away in a powder or as a substrate and so on, without standard process for Chinese herbology. You are going to use Chinese herbs when? You use it according to Chinese medicine and Chinese herbology. You're going to get into trouble and blame it on us, and that's unfair.

Thank you.

Mr. Grant Hill: Thank you.

The Chair: Thank you. Madame Picard.

[Translation]

Ms. Pauline Picard (Drummond, BQ): Dr. William Chan, when you were introduced along with your qualifications, was I correct in understanding that you are a member of the College of Physicians of Canada and that you are also a licensed practitioner of Chinese medicine? Is this correct?

[English]

Dr. William Chan (Committee for Preserving the Integrity of Chinese Herbology and Traditional Chinese Medicine): Yes. I've been trained in western medicine, and also I've had training in Chinese medicine. For the last two years, I've basically concentrated more on the industry or the business part of things. But I received my medical degree in Canada.

[Translation]

Ms. Pauline Picard: I would like you to explain to me how you manage to reconcile Chinese medicine and conventional medicine. For example, do you use chemical products of proven efficacy?

[English]

Dr. William Chan: Well, I must say that I pretty well grew up in Canada, and if you'd asked me about Chinese medicine eight or ten years ago I, along with some other people, would have said it was quackery. So it has been a really big turn for me to learn about Chinese medicine, to accept it. I was trained purely on the western model, with the allopathic medicines and running ICUs, etc.

When I got into family practice I realized there were a lot of things that you just can't do, and we weren't trained for, and that there is a lot more to health and healing. So as I talked to people— What happened was that some of my patients ended up seeing a Chinese doctor, and I looked into the different alternate health systems. I don't need to tell anyone how popular that is.

The reason I picked traditional Chinese medicine is that I think it's one of the most powerful systems of health, not just in the treatment modalities. Everyone has heard of acupuncture, but it's not just acupuncture, it's herbology, food cures, exercise, Chinese massage too, now—everything.

But it's not even that. The whole model of Chinese medicine is powerful because it actually gives someone a chance of looking at a person and, based on their list of symptoms—which I could never have tied together in western medicine—getting an explanation of why the person is not well. Unless you have an approach to someone's problem, you can't really fix it.

Everyone accepts that there is a big traditional aspect to it—there are thousands of years of history, so there must be something to it. But there is a lot of mystique about Chinese medicine. As I learn Chinese medicine, I think there are actually a lot of similarities between eastern and western medicine. We're just climbing up different sides of the mountain. I think the time will come when a lot more information will be shared.

I couldn't not accept the benefits of it. Even though it's a whole different language, I found there were a lot of similarities. As far as using the medical model to help someone's health goes, I think I accepted it that way, even if it wasn't the same double-blind studies for everything. I saw the effects of it.

• 0940

If you go farther and say, well, how about all these western drugs versus the natural products, I don't think anyone here will say that there isn't some need to provide the safety and to address the efficacy. Obviously safety is number one. Efficacy and quality—I don't think anyone would disagree that we need these types of considerations. At the same time, I don't think it's right to just make it all not available because we don't understand it or we don't have the same type of information. Anyway, I don't have any problems using it, because I can sort of see it from both sides, and it has advantages and disadvantages.

Just one last example. If you take a Chinese herb, dong quai, there are a lot of health risks along with it that the people are recommending should be applied to it. All I say is that sometimes there are a lot of benefits to the western way of thinking, where there is a lot of high research and processing extraction, and as soon as we can identify a fraction of the plant and find the active ingredient we can now start using it.

But sometimes it's actually the reverse. By doing that, by applying the allopathic model to some of these natural remedies, you lose a lot of the good qualities. You'd never have problems eating dong quai root from the ground and having the benefits from it. As soon as you start extracting it and applying some of the western requirements for the information and the efficacy and the proof, you actually isolate the toxicity as well. So there are a lot of considerations, though I'm sure we don't have time for it.

The Chair: Would you like to respond just briefly?

[Translation]

Ms. Noëlle-Dominique Willems (Director, Government and Public Affairs, Canadian Pharmacists Association): This is a very interesting question, Ms. Picard. In fact, under the model that is being developed in Australia, university students can decide to study both medicines at the same time, namely, traditional Chinese medicine and what is called "conventional" medicine in the West. An increasing number of physicians are practising both types of medicine at the same time, saying that they are complementary.

[English]

The Chair: Thank you.

Mr. Myers.

Mr. Lynn Myers (Waterloo—Wellington, Lib.): Thank you, Madam Chair.

I wanted to ask Mr. Hogarth, with respect to consumers, do you have a handle on the profile of who's using natural health products, and in what proportions and what kinds?

Mr. Paul Hogarth: Basically right now I've found that in general it is more of the elderly people. They're the ones starting to look more towards it because they're the one starting to get sick, of course. But overall, there really is no one type of person. There is young, there is old, there is overweight, there is underweight—there is a whole variety of people. It's just that more and more people are learning the benefits of the natural health care system, and they tend to use it more.

Mr. Lynn Myers: Have there been any studies with respect to, for example, what combinations are used of the various categories of natural health products?

Mr. Paul Hogarth: Oh, I'm sure there has been a wide study already. I can get information, if you'd like, on that.

Basically the point I like to get across when it comes to people and the use of products is that people like to have the access to choose what they want to use.

Again we get back to the safety issue, where we cited a question in Belgium of 70 people becoming sick because of labelling. The Food and Drugs Act—we already have labelling sections in there specifically stating that we can't falsely label something or we're going to be in trouble for it. The guidelines are already set in place as far as safety goes, and people know that, so they're starting to use more and more products.

Again, talk about how they don't expect to profit in regard to regulating more heavily in a drug category because they already sell 65% of the products. Well, when tryptophan was removed from the market it was costing $14 for a bottle in the health store, and when it became regulated it was costing $114 through a doctor's prescription. It's simply an amino acid that you find in foods.

As far as profits go, we can begin to see that once you look at more and more regulations and more and more things with more and more expenses involved— The people who are looking into using the products don't want to see a cost increase. The safety is already set in place. The guidelines are already in place, so while they're using them and expanding their knowledge through reading and getting more information on the products through seeing more traditional doctors versus westernised doctors, they're experiencing the results as far as their health goes, and they know the benefits. If they got regulated further than what they are now as far as all these safety issues we're being told about are concerned, people would lose the access completely and they wouldn't be happy. I know that for sure.

Mr. Lynn Myers: I think there was a response here, Madam Chair, as well.

• 0945

Dr. Jeff Poston: On the question of who's using complementary medicines, I think, as we've referred to earlier, you are seeing a shift towards the younger population, the better off and the better educated. The people who can, if you like, afford to seek alternatives seem to be one area where there is significant uptake, particularly of the vitamins and nutritional supplements.

One of the points we obviously have to wrestle with in this area is the separation of foods, functional foods and drugs, and what sorts of guidelines there are, and how you differentiate between those categories. I think you've seen that the advisory committee has begun to grapple with that issue and is certainly making some important progress in that area.

The Chair: Mr. Myers.

Mr. Lynn Myers: Just a supplementary. I want to hear from Mr. Hogarth.

Mr. Paul Hogarth: If I could expand on what you're talking about, when it comes to regulating these products that go from food and food supplementaries to drugs, my concern as a consumer is where the line gets drawn on food and food supplementaries.

If we're talking just about traditional Chinese medicine here, as far as herbs are concerned, they are a food. We simply go out and buy basil and thyme. They are herbs and they are a food we use. And we buy cayenne pepper and so on.

Where does it stop as far as food supplements go? Does it go all the way through vitamins and minerals and amino acids? I've seen a part of a list where it includes mineral and spring waters that have extra minerals in them as far as safety goes. Once you regulate a mineral, if it's in the water, where does it stop?

Do we regulate juices, apple juices that you juice yourself? Once you take apple juice, you've increased the sugar level going inside your body. Do we regulate sugars because they stimulate the body? The Food and Drugs Act states that once food has a stimulant effect on the body it should be classified as a drug.

Do we regulate milk because it has a claim such as “Milk does a body good”? You go to a doctor and he says you have to drink milk because it will make your bones strong. Well, that's the health claim. How far do we go?

The current Food and Drugs Act actually states that once a product has a health claim put behind it or a stimulant effect on the body, it must be classified as a drug.

My concern comes when we talk about safety, safety, safety. Where are the lines being drawn as far as the safety issue goes?

They keep expressing people's safety. Well, I don't see people complaining about the products. I don't see people complaining as far as the safety goes. They're asking to be allowed to have free access.

I once again see companies and large pharmaceutical interests coming in and trying to regulate a market in which they're saying they're not going to profit. Well, if they're not going to profit in it, they're not going to get involved in the business.

Again, as far as safety goes, you have to keep showing the information that shows— As Dr. Hill put it, where's the mortality, where's the morbidity when it comes to these products? We again say that we haven't found a death led from these natural products, yet you've 1,400 just from aspirin, and the list goes on.

We know we consume too much dairy; it's high saturated fats that cause heart disease, which is the number one killer in Canada. Fifty thousand people die in Canada yearly from cigarette smoke, and so many thousands die from second-hand smoke.

Again, we're talking about safety, safety, safety. I think we should be looking at the big things first and looking at these small ones later.

There is no safety issue; it's simply a monetary issue.

Mr. Lynn Myers: Thank you very much.

The Chair: The next person I have on my list is Ms. Caplan.

Ms. Elinor Caplan (Thornhill, Lib.): I think you've actually portrayed very well for us what the issue and the concerns are. I want to question on what people want, which I heard mentioned. I think I'd prefer to start with what people expect, whether they walk into a drugstore or they walk into a natural products store or a health food store. As a consumer, my expectation is that, whether I'm walking into a grocery store or a drugstore or a health food store, the products on the shelf are safe and of good quality.

Does anyone want to answer that? Is that a reasonable expectation? Do you think that's what people expect?

Mr. Paul Hogarth: I firmly believe that what's set in place right now is working. If your local health store is where you want to go for products to support that store, we should get more products in and do that. If 65% are going to pharmacies to buy the product, they should be allowed to do that also. If they buy through network marketing, they should do the same thing. Again it's a free-access issue.

If the government simply enforces sections 4 and 5 of the Food and Drugs Act, the safety issue is taken out of account. There can be no false claims made on the labelling. The food and products will be manufactured, processed and handled properly, in accordance with the guidelines already set in place. If they're simply enforced, people will just expect when they walk in to get that product— If a friend has told them, hey, this is going to help you with your high blood sugar, they will take it, and if they have said, hey, it's going to help you with your cholesterol, they will take it.

• 0950

You will recall we can't say any more that “an apple a day will keep the doctor away”. We can't say these things any more. We're talking about false claims and all these different things we're supposed to regulate.

Again, where does the line get drawn? People expect the products to work. They use them, and if they don't, they stop.

Ms. Elinor Caplan: So you think people expect the products to work. I didn't say that. I said I think what they expect is safety and quality and they have an open mind to see whether or not it's going to work for them. All right?

Mr. Paul Hogarth: Yes.

Dr. Jeff Poston: I think the perspective of our members on that is— Actually, you see it played out in pharmacies across the country day by day. I think there is a lot of concern about safety and quality.

One of the strategies you see in the absence of any regulation and in the absence of a great deal of necessary information, one of the strategies our members are following, is they are actually stocking a few limited lines of products from reputable manufacturers who have an established track record in the area. That's one of the practical things that happen at the store level: they are going to stock products from a line of reputable manufacturers.

I think there is concern then about the amount of information available for the consumer when the consumer is self-selecting off the shelf, with limited information. That's one of the reasons why we see the need for better consumer labelling of content as being particularly important.

Ms. Elinor Caplan: What I've heard is that there is general agreement from everyone; that it doesn't matter where it's sold, that it's the issue of making sure consumer expectations of safety and quality are met, and that the issue comes down to labelling claims and really, as I would put it, the basket of how harmful, how risky, how toxic it is, and whether that can be dealt with by warnings or whether we actually are then on that slope of how much you regulate those things which are risky.

Do you want to comment on that?

Mr. Paul Hogarth: What you're stating is correct. That's basically the issue, the safety factor. But if someone comes down and finds they are allergic to peanut oil or peanuts, they simply stop taking peanuts. Do we regulate peanuts because, say, 10,000 people are allergic?

Ms. Elinor Caplan: Or do you label them?

Mr. Paul Hogarth: Or do you label them and say “this may cause an allergic reaction”? Do we label every single food product and say “this may cause people allergic to oranges—” and so on? The list keeps going on. How far do we go?

We simply should have an understanding that human beings at one point or another just ate foods, maybe picked some herbs and did stuff, back in the old days, and took care of themselves. How far are we to regulate human beings' choice in taking care of themselves? We do have a responsibility to take care of ourselves and our families. I believe we have the knowledge and education to do that.

Ms. Elinor Caplan: Paul, if we're drawing the line on the basis of risk of harm, is the place where it's very risky, very harmful, the place where we should draw the line, or is it at low risk? You tell me. Do we all agree that if it's not harmful and it's not risky we have no problem?

Mr. Paul Hogarth: To some extent, yes. If people take aspirin because it helps their headache but it kills 1,400 people per year in Canada alone, how risky is that? Sure, there might be a widespread amount of people taking it, but 95% of Canadians do take vitamin and mineral supplements in some form or another at some time in their lives. So the risk factor comes in again with people who will profit in saying we have to get more and more safety, but where is the safety in 1,400 people dying every single year?

When you find a safety issue, if you say yes, it's killing 1,400 people per year, what do we do with the product? Do we allow it still to be sold, or do we simply put a label on it saying “this can kill you”? That's really where the issue comes down. People should know, yes, it can't kill me, or it can't harm me—

The Chair: Does anybody else want to comment?

Dr. Jeff Poston: On the issue of risk, first of all, the work of the National Drug Scheduling Advisory Committee is to develop that sort of framework of risk cascade which Health Canada has worked on, to look at matching the level of control and the regulations to the level of risk. I think that concept needs to be applied to herbal products, and criteria need to be defined for low risk.

For me, where the line gets drawn in the sand is when you start to make a therapeutic claim. When you have somebody who is sick seeking this product as a remedy, that's where you go a little beyond just a safety issue and a quality issue and where efficacy comes in. The great concern there is that you're going to have somebody who needs effective professional advice and treatment and isn't going to get into the system, so there are going to be unnecessary delays in treatment. I think that's the concern.

• 0955

The Chair: Ms. Wasylycia-Leis.

Ms. Judy Wasylycia-Leis (Winnipeg North Centre, NDP): First of all I apologize for being late, and I hope my question is redundant. I'd be interested in hearing from each witness or each organization represented here today what their official or unofficial position is in response to the draft regulatory framework for national health products as tabled with this committee on February 3, 1998 by the advisory panel on natural health products?

The Chair: Dr. Wu.

Dr. Joseph Wen-Teng Wu: Generally speaking, the presentation from the advisory panel has addressed some of the concerns from the stakeholders, which is good, because there is a consensus that regulations have to change.

We do have to change, but how to change is the task of the advisory panel, which represents the concerns and interests of the stakeholders, and of the standing committee, which represents the concerns and interests of the general public, because the general public votes MPs in. So that we can take care of this issue for the general public, we should work together.

Again, the one policy that really hurts Chinese medicine is that traditional herbal medicine guidelines don't recognize any ingredients other than those of botanical origin. Also— [Editor's Note: Inaudible]— they only use the allopathic and pharmaceutical concepts, which is a bit unfair to culture-based medicine.

I sent my report to the panel in August 1997, and I believe I also sent it to the standing committee last year before Christmas. I have a point-by-point analysis and I hope you will go through it.

But the policy items only— [Editor's Note: Inaudible]— that CHM guidelines need to be updated because some of the ingredients may not be of botanical origin. But that is not enough. It doesn't touch the creams. And the creams in the culture-based medicine have their own powers and different concepts. That's ancient science. It would take decades of research work to explain why this concept thoroughly works.

We have to work together as Canadians now and for the future generations. But just because you haven't done this work you cannot deny it. It has existed in Chinese history for 5,000 years and for centuries in Canada and North America. We don't have many problems. You can go to the poison centre to check for any reports regarding the use of Chinese herbal medicine and find very little.

Again, I appreciate the report from the panel but it's not enough yet. More work needs to be done. And we'll continue to work on it together with the standing committee.

The Chair: Dr. Poston.

Dr. Jeff Poston: We certainly have supported the framework in principle. We have some concerns about it. One thing we think is particularly useful is the idea of looking at the dosage form and the grid of “Is it a dosage form or not?”, “Is there a health claim or not?”, and “Is there a useful framework within which to start to think about this?”

I think the concept of notification to a standard is helpful, particularly for low-risk products. I believe we need quite a bit more work done with respect to criteria for grading risk of these products.

• 1000

I think we have some concerns as to whether there actually needs to be a third category under the Food and Drugs Act. That's an issue that needs further debate. The way we see it, in the time the panel's been working they've made some good progress, and they have a basic framework we can work with, but there certainly are issues around definition of risk, around what standards are notified to, and other issues like these that obviously need further work.

The Chair: Thank you very much. Mr. Vellacott.

Mr. Maurice Vellacott (Wanuskewin, Ref.): I have a question for Dr. Poston, and I'd like a response from Dr. Chan as well.

Dr. Poston, you seem most inclined toward high levels of processing—extraction to the nth degree, I guess we might say. I have a question in terms of then some of the trace elements that might be rather necessary to the efficacy of some product.

I would go back to a very simple example from the change in folks' cooking habits and so on. My mother used to boil carrots with lots of water until they were pretty soft and all the nutrients were in the water, and maybe none left in the carrots, and so on. My wife handles it a whole lot differently. So we've changed in terms of some our habits.

Would you say we need to get down to very precise dosages for those trace elements and so on? I'm afraid we're losing something in the effectiveness by high levels of processing, while wanting to balance the issue of knowing what the quality is, and the dosage.

I'd like a response from you, and then Dr. Chan.

Dr. Jeff Poston: I think there are a number of parts, but on the efficacy side of it, what you want to do is certainly get an idea as to what are the active ingredients and the active constituents and to ensure that active constituents are present in appropriate quantities in terms of their effects. I think there is emerging knowledge with respect to the pharmacology of herbal products, how they work, and what their effect is on the body.

With respect to the trace elements, I tend to have concern the other way. There are a number of trace heavy metals present in herbal products. They grow in natural surroundings that contain heavy metals that are toxic. So one of the things you see in the standard literature, for example, calls for the need for limit tests on heavy metal contaminants of herbal products. That's particularly important where you have people with chronic, long-term use.

I think what we get to is the need to actually define active constituents and to have some criteria for quality, both in terms of ensuring that the appropriate part of the plant is used—I think the example our colleagues in Chinese medicine brought forward is a good example of where we've seen problems in the past—and the active constituent and the content of the ingredients—

Mr. Maurice Vellacott: So if something is in a fairly minute, or a very trace element, amount, you would tend to discount it unless it registers “on the radar screen” of an active ingredient?

Dr. Jeff Poston: One of the difficulties you have is actually identifying the role of what the trace elements are in some herbal products, or the identification. There are a mixture of constituents.

I think where individual trace elements and heavy metals are concerned, the absolute bottom line is that you have limit tests with respect to toxicity, because if they have a positive effect, then that's clearly beneficial. What you have to give a priority to is protecting from toxicity.

Mr. Maurice Vellacott: So unless you can isolate it to that degree, it's almost guilty until proven innocent.

Dr. Jeff Poston: Yes. I think the stuff that's toxic, people are beginning to get an understanding of, but it is also an area where clearly there needs to be more research. There is a body of knowledge out there. Phytochemistry and phytopharmacology have been around for many years. Fairly well-established university departments are doing active work in the area.

Mr. Maurice Vellacott: Super. Thank you.

Dr. Chan.

Dr. William Chan: There's a lot we don't know. I'm sure that eating a carrot, as you say, or broccoli is different from eating it in a pill. What we've done is to always try to pick what are the benefits, and to find the active ingredient in this particular food that gives you this health benefit. Then we start the process of processing it, what makes it okay, and we identify it. We know a little bit more about it, we can handle it, we know how to treat it, we know how to evaluate the health risk.

• 1005

I don't think any of us here will disagree that safety is going to be number one, and no matter what herb from what country—Chinese herbs are no different from any other herb anywhere else. If you look in a book that explains both Chinese and western medicine, say you take an herb that's for flu, you look up that herb and it will explain in the western side that it's been found to be good for cough and sore throat. On the Chinese side it'll say it releases the exterior and expels wind. You don't have an idea what that means, but it's the same herb. There's nothing really different about it.

So we're looking at these things, and there's a lot that we don't know and there are different ways we explain the benefits. Just because we've picked certain benefits and gone down the road, then it becomes whether that is a way to assess the safety and efficacy. And does it then become more marketing tools for people saying my product is better because the extraction is better, it's more concentrated?

So I agree with you that I have problems with this road as being the only way to go and that we are losing a lot, from what you're saying.

The Chair: Can Dr. Lu add a comment?

Dr. Henry Lu: I'm surprised that— we are talking about herbal products here, and so many honourable people are asking pharmacists about herbal products. Why? We are experts, and no one asked me. So I'm curious about this. Who knows herbs, particularly Chinese herbs, better than me here? I'm not bragging about this. I come all the way here to make one important point, namely that Chinese herbs are no risk, really no risk.

I can explain how I know. How do I know? I have 30 years of practice behind me. I run a school of Chinese medicine, the largest in Canada, and I have run it for 12 years. I have investigated hundreds and hundreds of pages of documents, Chinese documents, about the toxicity of Chinese herbs, and I have come to the conclusion that there isn't toxicity. Many people worry about toxicity because of ignorance. They wonder why. Why? What is there? I haven't seen in my clinical practice, in my school, in my clinic, any case of toxicity.

You talk about toxicity because the herb contains some chemical element that by itself is toxic. So you come to the conclusion that this herb is toxic just because it contains some element that is toxic. But we import a system of medicine from China, a system containing theory, containing many experiences, and we bring it here and we totally ignore the system. We focus on the herbs. And because we don't know the system we conclude the herbs are toxic. And this just doesn't make sense to me.

That's all I have to say.

The Chair: All right. Thank you.

Mr. Volpe.

Ms. Noëlle-Dominique Willems: Could I just—

The Chair: All right. Okay, take Mr. Volpe's time if he has agreed.

Ms. Noëlle-Dominique Willems: I'm sorry, Mr. Volpe.

Mr. Lu, they ask pharmacists because at least 75% of pharmaceuticals now are based on molecules that are derived from herbs and were done that way so that you can have safety and security in the manufacturing of those products.

The Chair: Because I let you speak, I end up with somebody who asked a long time ago. Mr. Hogarth.

Mr. Paul Hogarth: I won't take a full minute.

You look at toxicity again. We should be looking more towards safety of foods versus toxicity of herbs and everything else. Did you know that DDT was banned as a pesticide on spraying foods, yet it's still sprayed in Mexico where your bananas and certain products are imported? So you're getting DDT back into the country.

There are other issues as far as safety is concerned, and real safety. As far as the products go—you say you boil the carrots and things come out—it boils down again to where does the line get drawn in regard to products. Everybody's talking herbs, and we all picture traditional Chinese medicine herbs as some concoction they've put together. They're talking vitamin A, vitamin C, vitamin E, vitamin and mineral supplements, also. This is the line that scares the hell out of me. I'm sorry to say that, but it really does.

• 1010

They keep quoting herbs, and some people want a drug category and some people want a third category. They're a food. We should be talking vitamin A and vitamin C, because we understand them more; they come from foods. We understand more about that, and these are the things they want to regulate also. That's where the concern of toxicity should be. Yes, we've found that if we take too much vitamin A in an unnatural form, it can be toxic. If you take too much vitamin A by juicing your own carrots in a natural form it's not toxic. It might turn your skin slightly orange from the beta carotene but it's not toxic. It's natural; your body will expel what's too much. The toxic body comes more so through the growth of the food.

The Chair: Mr. Volpe, it's your turn.

Mr. Joseph Volpe (Eglinton—Lawrence, Lib.): Maybe I'll get Dr. Wu to intervene in the few minutes I have left.

I wanted to ask whether this toxic risk is associated with either advice or information that's written, and I guess maybe there's a sense that they're both the same. I'm trying to think my way through on a practical basis.

You know, we have a couple of doctors on this committee, and typically what would happen is that I would go to a doctor and I'd say, “I have this problem. Do you know what the cause of it is, and then will you tell me how I can resolve this, first the symptoms and second the cause?” And the doctor writes something down that only he and a pharmacist can read. I go to the pharmacy, I hand this to somebody at a “prescription in” booth, and then I go to the “prescription out” booth and I'm given a bottle of something.

A couple of years ago the system intervened with additional information, giving me a sheet describing what was actually there. But to all intents and purposes the process is not terribly different.

The consumer—that's me—has enormous faith in the doctor over there who gave me an indication that this will solve my problem. I don't know what the toxicity is, I haven't got a clue what the correct dosage is, except what my doctor tells me, and he says either take it with food or without food.

So now the risk element in the pharmacology associated with my treatment is completely vested in the doctor's advice. I can't say, with due respect, it's in the pharmacist because I don't think I've ever seen a pharmacist where I go. But the pharmacist is now beginning to intercede and he or she is now beginning to make himself or herself more visible and says this is garbage and this is not garbage. But it was actually a grosser word that my pharmacist, whom I just met, told me about some stuff that's on the shelf.

The stuff that's on the shelf has a list of ingredients and it says not to exceed such and such. And Seldane comes to mind, Sudafed comes to mind. Sudafed's okay, except that if you play hockey and you want to go to the Olympics it's not good. But it's okay to give to my daughter. I don't understand this any more.

So I'm wondering what definition I should give to risk. Is it the provider of the information, the advice that's associated with training that convinces me to consume a product, or is it the fact that it has some words scribbled on a package that sits on a pharmacist's shelf on my side of the counter?

Dr. Jeff Poston: First of all, you've had 40-odd years of regulation of safety, that is, controlled risk, that has been done for you as a consumer by the Government of Canada through regulations. If you go back to late 1800s, for example, when there wasn't the science and the monitoring, control and regulation of risk that there is today, you could have been quite vulnerable to what your physician might have prescribed and what you may have got from your pharmacy, because you had products and you didn't have the science that there is now that is put into products that leads to regulation.

Mr. Joseph Volpe: May I please interrupt you for a second. I'm not a consumer of Chinese medicine, not yet, with due respect. But if there's about 40 to 50 years of government regulation on our side— and I'm one of those people who have believed blindly in our own medical practices and our techniques. They tell me they have 3,000 or 4,000 years of the same kind of— I wouldn't say science-based, but at least observation. It certainly is part of science: observation, analysis, criticism, recording, re-analysis, re-experimentation, and so on. Surely that must count for something.

• 1015

Dr. Jeff Poston: To finish the answer about the role of advice and information in controlling risk, what you have in comparing the two systems is—I think Dr. Chan talked about it—a system. Within western medicine there is a system, and part of that system is advice and information as a basis. There is regulation that restricts the product to being prescription only. There are standards of practice in the professions. You should be getting advice and information from your pharmacist. If you are not, you should change your pharmacist.

Mr. Joseph Volpe: But the government regulations are a function of the practice the public has accepted; it's not the other way around. Or am I confused?

Dr. Jeff Poston: You have two aspects. You have regulation of the products, which has come through government, but you also have regulation of the professions through the licensing bodies in medicine and in pharmacy. They are setting standards of practice in the provision of advice and information.

A lot of it then comes to—

Mr. Joseph Volpe: We trust that particular body to protect the public, but that body is really beyond the regulator's authority to regulate, isn't it?

Dr. Jeff Poston: Self-regulation of the professions is the model you've had since about the mid-1800s.

The Chair: I'm going to intercede here and ask a question.

I think I have this right. Mr. Hogarth argues that natural health products should be regulated as food or food supplements and appropriate information should be put on the labels. Dr. Wu agrees with the recommendation of the advisory panel to create a third category and develop specific regulations for natural health products. The Canadian Pharmacists Association contends that natural health products should be considered as drugs and regulated as such.

How can we come to some kind of conclusion? Where can we draw the line between food and drug products? Do any of you have a comment to make?

Dr. Wu.

Dr. Joseph Wen-Teng Wu: Yes, a question first, then I'm going to expand a bit about this active ingredient concept in homeopathy. A philosophy of science is involved. I'm going to expand a little on my observation.

It's not a matter of a yes or no answer, east or west. There are no absolute things in this universe. You have to come to some compromise.

The existence of natural health products, including Chinese herbs, is a fact. So food doesn't cover the issue 100%, drugs don't cover the issue 100%. There is a continuum between the two.

We had a long discussion, an argument, within our panel. We spent six months, through regular meetings, telephone, fax, Internet. We had a lot of arguments, but eventually came to a consensus conclusion. It's a continuum between the two. You have to have a compromise.

This task is not finished yet. Our advisory panel will continue to work on it after this process. They will give you more reasonable and acceptable solutions.

This is very important to me too, because the philosophy decides what you're going to do in the policy and guidelines.

Often in talking about scientific processes, pharmacy, you say they subtract out the chemical ingredients and components from the natural herbs, so there is no difference. There is a difference. Why? Because in natural herbs, besides the major active components, there are minor active components. If we isolate just the major active components for testing, especially on animals—it's not a human body; they are different—that doesn't represent a naturally grown herb that is created in nature. We call it God, but it is the Mother of the universe. The different natures and properties—you have to be careful in this concept.

• 1020

Second, from nature God put these material types of active ingredient, minor and major together, into natural herbs. There is a creative concept in science. When scientists isolate major active components, they miss minor ones. Also, they miss the creative consciousness.

So what I try to say is this. You isolate the active ingredient from natural herbs, fine, but you use it according to pharmacology, making it another drug. But the natural herbs have different properties and natures now. The active ingredient you have isolated has different properties and a different nature. This is the problem with Chinese medicine and the regulatory bodies.

I've no argument with the TPP for this concept. I believe it is true.

Second, talking about the combinations, when we prescribe Chinese herbs in combination, we prescribe according to Chinese herbology. I have my report analyse this. In this process they balance each other. You see, Chinese medicine, also a culture-based medicine, is playing a game of balance, of harmony. If there is a small toxicity, those who pass it eliminate it. They balance each other. There is no more in the combination.

So this is a different power and a different policy. You should not use the pharmaceutical model to judge Chinese medicine, natural herb products. They have entirely different aspects.

We got into contamination in a manufacturing facility. It Taiwan they have practised the system for at least 16 years. In order to comply with this germ-free system, all of the manufacturing facilities have to be in stainless steel, which is very expensive, under high pressure and high temperature. The metal doesn't melt into the herb product. But if in an underdeveloped country they don't have that kind of market or expensive facility or technology, it might happen.

But it doesn't mean Chinese medicine is not true. It doesn't mean a Chinese herbal product is toxic. That's a wrong thing. You have to distinguish between these two.

The Chair: Dr. Chan, did you want to add something?

Dr. William Chan: No, I'll let—

The Chair: I would like the other two to respond very quickly.

Dr. William Chan: I'll let them respond first.

Dr. Henry Lu: If you want to learn the Chinese language, you learn from the Chinese—right? If you want to know about Chinese herbs, you ask the Chinese doctors, not western pharmacists or western doctors. So that's my comment.

The Chair: Yes. We got that point forth.

Dr. Hogarth, did you want to answer my question?

Dr. Paul Hogarth: The question was basically: I'm for foods, leaving it the way it is, the third category, and drugs; where do we decide which it is?

Again, if you're the advisory panel, the Standing Committee on Health, the question is what is your basic function, what is your mandate? If your mandate is to protect the consumers, then you should be talking to the consumers more than you should be talking to professionals. I don't have “Dr.” in front of my name. The current system and the current regulations in place are already safe enough for us consumers.

As far as the drug category goes, again we're talking about where the emphasis came from. The emphasis came from business pushing changes in the current system for higher profits. There is no doubt of this whatsoever.

The current system and safety regulations and the Food and Drugs Act are already in place and they are safe enough for us. Simply, if you want to do anything, enforce them harder. But leave them alone. We should not get into an issue of drawing a line for what is food and what is not food. If it's grown in the ground, it is food. I'm sorry, I'm a vegetarian; if it runs or crawls or swims or flies it's also food to some people. Where do we draw the line? I don't think that's up to us, as a professional body or an advisory body, to decide. I think people should be allowed the choice to consume foods in the way they want to.

• 1025

If you take hawthorn berries in the wild and consume them today, you can be charged with consuming an illegal drug. If you give them to your wife, you can be charged with drug trafficking. That doesn't make sense; it's simply a food. But according to regulations, that is what would happen to us. It has just gone too far and we should leave it alone.

Thank you.

The Chair: Dr. Poston.

Dr. Jeff Poston: I'd just like to answer your question as to where you draw the line. I think the advisory committee has made progress in that. I think it does boil down to whether it is presented in a dosage form or not and whether there is a health claim made or not. I think that can be a basic framework that you can begin to address the issue through.

The advisory committee has a very broad spectrum of representatives on it. I think they're a body that you can certainly seek direction from, and hopefully as they carry on with their work and get further input, I think there will be appropriate leadership from that group.

The Chair: Right. We have three people who want to ask questions and we have about four minutes.

Mr. Maurice Vellacott: We have a bridge in mind between these two camps.

Dr. William Chan: To answer your question—I'll just keep it to less than thirty seconds again—I don't think that as a general issue there is really a line we can draw between food and drugs. It doesn't matter what culture. In Chinese cooking, the reason you cook crab with spring onions is to balance it off. There are properties to food, like herbs, and drugs come from herbs, etc. So there's really no line you can draw.

But in this whole playing field, I think everyone is saying we realize the difficulties that exist but that in general the majority of the natural products are safe, so let's make it available. Having said that, we must have some system of evaluating it, and if we do make health claims we are moving into an area of therapeutics. So we are forced into having categories of evaluation, and I think we are moving in that direction.

We need to have a category to address it, not because of what Paul has said about not being able to draw the line, but somehow we have to assess it. Within that category, we're asking that Chinese medicine be yet another category because we haven't yet understood all the different principles and we can't evaluate it. But at the same time, we'd like to be on that same playing field. Don't restrict us from using it because we don't anything about it, because we don't know the medical system and how the terminology goes.

Let's start somewhere and look at safety first, because we are not going to look at the efficacy very well. The quality, of course, we can address. And even though we're scared of the cost recovery, licensing, establishing licences, etc., we don't disagree with that. It's looking at the safety issues, and perhaps there will be experts available to assist in identifying what we call toxic herbs that may need to be addressed, either through labelling or through a list where it has to be handled through a practitioner, or whatever. But I think we're moving in the right direction.

The Chair: Thank you. Dr. Hill, do you have a short question? We'll do a short one for the three of you.

Mr. Grant Hill: I've had my kick at the cat, so if there are others who have not, I'd be willing to cede.

The Chair: Okay. Ms. Carroll, a short question please.

Ms. Aileen Carroll (Barrie—Simcoe—Bradford, Lib.): It's a long one, but I'm going to jump in anyway.

Dr. Lu, I appreciate what you said and I hear you when you speak from a great experience base. And if it hasn't been processed through the traditional western norms of science, I do think it still has great merit and value.

Where I have difficulty for the route down which we are proceeding is this. I see, and I'm speaking quickly, an opening up on the part of western medicine toward traditional Chinese remedies, towards herbal remedies, and seeing them in a growing way as complementary rather than an either/or proposition. This, I think, is growth and we are experiencing that.

I listened carefully to the advice you gave. Where would you suggest this committee go when they consider situations where they hear evidence about the use of a traditional herb, where the user also is using a pharmaceutical product and has run into a serious reaction? I have had people come forward with instances of that, probably because they know I'm on this committee.

I will tell of one very quickly, where a person was using a pharmaceutical product that is unknown to me and on his own initiative began to use St. John's wort and had a very dire consequence. How do we put in place something that is going to cope with cross-usage?

Dr. Henry Lu: That probably would arise from that person using western drugs. I have been practising for many years, I have gone through old documents, and I haven't come across a single instance. When people have died from consuming Chinese herbs it was due to ignorance. They consumed large quantities. That is where our approach to Chinese medicine is based on misunderstanding, based on ignorance.

• 1030

For example, now we are talking natural herbs, talking about Chinese herbs, and we are asking a pharmacist. I have deep respect for him, but this is the wrong approach. We should ask the experts for their opinion on the use of Chinese medicine, based on their experience, their contacts with students and others. In other words, we need someone or some group of people who have expertise in this area.

Actually, my school has a four-year program. I can spend hours and hours explaining what happened and what I think, but I don't have the time and you don't have the time. You don't have the patience. So I will mention just one point.

Ms. Aileen Carroll: Thank you.

I can look to you, Dr. Poston, as my pharmacist, who has all the products I'm using and says to me I've now got into difficulty because I can't use A and B together. What I'm asking is how we can cope with the two different fields coming together.

Mr. Hogarth, you were going to jump in there.

Mr. Paul Hogarth: I have a quick question. If the panel here were to decide right now on an answer to the question— if you were to try to help yourself today to avoid heart disease and cancer from saturated fats and stuff like that, would you consume more meats and dairy products or would you consume more fruits and vegetables? Which do you think?

Again, you've just made an actual claim, a side claim, that fruits and vegetables are going to help prevent these diseases. You're stepping into a framework here that is really getting dangerous, when you say human beings have a choice on their own. Again, we're saying that once it has made a claim, it's therapeutical, it's pharmaceutical, it's a drug. Where do we get off saying only doctors who took school longer than I did can claim that this product helps you with your health? That alone is already a fault with the Food and Drugs Act.

I do have something I will send to the committee this week to expand on that.

The Chair: Good. Thank you.

Dr. Poston.

Dr. Jeff Poston: First of all, you could address some of it through appropriate labelling, but it all becomes a question of how you assess risk and how you control access. Then something we've been doing a great deal of work on with the profession is actually getting information out there about drug interactions. But as I mentioned, there's a need for more systematic study.

One comment I have to make is that you have to start to put this in the framework of evidence-based medicine, risk assessment, and population health. You have something like the National Forum on Health, which is proposing major reform of the health care system based on the concept of population health. I think you have to take a population perspective, a pharma-epidemiological perspective, of risks associated with drug utilization.

You find a western physician who has never seen an antibiotic rash, and he's damned difficult to convince that antibiotics cause rashes. You find a western physician who has prescribed an antibiotic that has caused a fatal rash in a child, and it's extremely difficult to get that physician to prescribe that antibiotic for anybody ever again. Physicians are conditioned, and their responses and perspectives are conditioned, by experience. I think you have to balance that practice experience with the population health perspective of an epidemiological assessment of risk, because that's the framework that's really being used as the basis of modern health care systems.

The Chair: Ms. Caplan.

Ms. Elinor Caplan: I have one very short question on which I would really like a yes or a no from those on the panel. Do they think foods that make a health claim, or a natural product that makes a therapeutic claim, should have to provide evidence of their claim?

Dr. Joseph Wen-Teng Wu: The evidence—

The Chair: She wants a yes or no, she says.

• 1035

Dr. Joseph Wen-Teng Wu: Yes, but there's a condition. The evidence is more than the western allopathic, pharmaceutical model or the traditional Chinese model. You need both.

Ms. Elinor Caplan: Okay, I agree. I just said evidence; I didn't say which model. Just yes or no.

The Chair: Mr. Hogarth.

Mr. Paul Hogarth: I hate to say no, but I will with a condition. Again, if you take it and it doesn't work, you won't keep using it.

Dr. Jeff Poston: Yes, particularly if it's in a dosage form.

The Chair: Thank you.

Thank you very much to our witnesses. If you have any other comments, please mail them to the clerk as soon as you can, because the committee won't go on forever. Also, I'd like the clerk or Dr. Wu to make sure all of us sitting on the committee have the material that was sent before Christmas.

We'll take a five-minute break.

• 1036

• 1050

The Chair: I call to order the second part of this meeting.

From the Ontario Homeopathic Association we have Lynda Shannon, and from the Fédération des professionnelles et professionnels salarié(e)s et des cadres du Québec, Claudine Larocque.

We'll start in the order that's on the agenda. We'll also ask you to keep your comments relatively short. The things you have to say will come out anyway with the questioning from the members, and they all want time to be able to ask questions.

Ms. Shannon, perhaps you can start.

Ms. Lynda Shannon (President, Ontario Homeopathic Association): Actually, Doug Smith is going to make our presentation this morning.

The Chair: Okay. Mr. Smith, would you introduce yourself and tell us a little bit about your background?

Mr. Doug Smith (Member, Board of Directors, Ontario Homeopathic Association): Yes. I'm one of the members of one of the boards of directors of the Ontario Homeopathic Association. In the distant past, my primary affiliation was with a university as an anthropologist, but I've since moved into the homeopathic field.

I appreciate this opportunity to address the committee. Thank you, Madam Chairman, for listening to our comments.

Since we have only so much time to deal with the complex issues at hand, I won't say too much about the association itself. You may wish to know more about that during questioning.

I think it's quite important to identify the fundamentally distinct nature of the homeopathic healing system so that when regulation is contemplated, our own concerns can be specifically addressed.

I wish to read from this document a section that details what we understand by homeopathy. I hope it's clear enough for you, but I also expect it will engender a fair amount of questioning as well.

In our view, homeopathy is a system of medicine that employs a wide range of remedies, from the crude dose to those in potency, in order to correct disturbances on the mental, emotional and physical levels.

The extent to which a remedy is attenuated is known as its “potency”. Potency is conveyed by a numerical expression. The higher the number, the more dilute the preparation. Thus, a remedy in a potency of 3C will have one part of the original substance mixed with one million parts of a medicinally neutral material, such as lactose or hydroethanol.

Homeopaths—in Ontario, at least; there may be some question in Quebec—would regard a 3C remedy as a very low potency indeed, one that verges, in fact, on the biochemical level. Today, most homeopaths in Canada prefer to make use of remedies in potencies of 30C or higher, because these seem to be more effective in eradicating deeply seated pathologies.

Now, 30C means the remedy has been diluted through 30 separate steps. At each step, one part of the previous attenuation is mixed with 99 parts of inert matrix. At the end of this long process, a 30C potency will consist of one part medicinal substance or agent in ratio to a matrix expressed as the digit 1 followed by 60 zeros. So this is quite an astronomical sum.

In fact, ratios on an order of that magnitude are hard to imagine. We would have to try to picture a single grain of sand nestled somewhere on a long expansive beach to understand a ratio like that.

With higher potencies, on the order of 1M, one thousand, or 10M, we would have to imagine a single drop of water merging with the ocean itself. It's this kind of ratio we're speaking of.

In practical terms, where ratios of this sort are concerned it is highly probable that any particular homeopathic dose will contain even one atom of the original agent. This is what homeopaths mean by their famous phrase, “the infinitesimal dose”.

Without knowing in detail how homeopathic medicines are made, many people naturally wonder how something so attenuated could possibly have any effect on the human organism, but the crucial thing to bear in mind here is that the medicinal substance is not just passively mixed in with its matrix. Rather, at each step in the attenuation process, the preparation is either vigorously shaken if the matrix is in liquid form or else finely ground if the matrix is powdered. It is this method of repeated shaking or grinding that lends homeopathic preparations their unique properties. That's a crucial point.

• 1055

Homeopaths believe that medicines prepared in this way can be extremely effective in stimulating processes of self-healing. But in ultra-high dilution, these medicines certainly do not address themselves to the material body as such. Instead they seem to influence the vital force that animates the organism, giving it life and pulsation. Most homeopaths would accept that the vital force is more or less identical with the “chi” energy of traditional Chinese medicine. This is actually an energy configuration torn free by vigorous attenuations that is responsible for the homeopathic effect.

In its potentized form, a medicine no longer acts as the original substance once did. In fact, a sort of reversal takes place whereby the potentized remedy can actually alleviate such pathologies as may be caused by the original substance. For example, a case of stomach poisoning might be successfully treated with arsenic in high potency, or a headache might be nicely resolved with nux vomica, which is known to produce the very same condition in its crude form. These strange reversals, observed by practitioners generation after generation, form the basis of homeopathic therapeutics. The underlying law governing such phenomena is summed up in the Latin adage similia similibus curantur, which means “like cures like”.

Since the time when the first potencies were clinically tested, around 1800, homeopaths have explored the therapeutic effects of more than 2,500 substances drawn from the mineral, plant, and animal kingdoms. Some of these substances are simply inert in their crude form, while others may be highly toxic or else have medicinal properties that are not recognizable when taken up through a series of vigorous dilutions.

For the student of homeopathy, it is a daunting prospect to become familiar with the vast materia medica, which homeopaths have accumulated down through the years. Even with the availability of computer programs, there is no easy way to learn this material. Furthermore, homeopaths employ a distinct and rather complex procedure for determining the correct remedy in each case. This procedure is holistic in the sense that homeopathic prescribing depends on matching remedy profiles with detailed syptomatologies so that the “like cures like” mechanism will take effect.

Homeopaths do not in fact make use of disease classifications as such, another very important point. They recognize, in other words, that two individuals suffering from the same so-called “disease” may require quite different remedies due to the fact that their symptoms vary in small but significant ways.

As if this were not enough, homeopaths also have to recognize that a remedy, even if correctly prescribed, may not be effective if the potency is either too low or too high. To develop skill in prescribing the correct potency, let alone the correct remedy, requires specialized training along with extensive clinical experience.

The positions that the OHA is taking with regard to regulation of homeopathy apply both to the federal and provincial levels. We'll try to keep our remarks pertinent to the federal level since that's the aegis of this committee.

In Canada a number of homeopathic remedies, such as nux vomica, arsenic, and ignatia, have been proscribed on account of the known toxicity of their crude substrates. The Ontario Homeopathic Association again wishes to emphasize that homeopathic remedies in ultra-high dilution present no danger to the public in the toxicological sense. They do not have a direct biochemical effect on the organism. Therefore this schedule of proscribed remedies should be rescinded as soon as possible, in our view.

Nevertheless there's a distinct hazard involved in prescribing remedies in high potencies on an uninformed or haphazard basis. While these remedies are not toxic in the biochemical sense, they can cause intense aggravations if inappropriately prescribed. The mechanism here seems to involve an over-stimulation of the vital force, which is experienced as extreme discomfort or dysfunction for the person who's going through it.

Apart from this well-attested risk, homeopathic practitioners are also concerned that a high-potency remedy, if mis-prescribed, can so distort a patient's symptom picture or symptomatology that future homeopathic prescribing is made very difficult, if not impossible in some cases. So you can lose a patient or a patient can become unavailable to you downstream where a high-potency remedy doesn't work or has a prolonged aggravation.

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For the above reasons, the Ontario Homeopathic Association is apprehensive about the fact that high-potency remedies are currently available on an over-the-counter basis in many pharmacies across Canada. Our association maintains that high-potency remedies should be furnished on a prescription basis only. In other words, only qualified homeopaths should be permitted to prescribe and administer these higher potencies.

Also sold over the counter are various remedy complexes consisting of two or more medicinal agents in low potency, which would be in the area of 3C or 6C. Such remedies are intended to treat acute self-limiting disease episodes. In our view, this class of remedies does not present a significant risk to the public, but neither do we regard them as homeopathic remedies in the strict sense. Perhaps you'd like to pursue that issue in questioning period.

Prescribed as they are on a more routine if not scatter-gun basis, these remedies may not be particularly effective, but again, at least they are not harmful toxicologically. Nevertheless, in our view, to thrust them before the public does nothing to raise awareness about homeopathy in Canada. Therefore, the Ontario Homeopathic Association does wish to express its concern regarding any publicity or advertising effort that would promote low-potency compounds as a substitute for professional care.

In the previous century many homeopaths prepared potencies rights in their own office labs. Today this is rarely if ever the case. Contemporary homeopaths have come to rely upon national and international homeopathic pharmacies to supply their needs. These mass-produced remedies, labelled and sealed at the factory site, are not subsequently altered by the practitioner. The OHA is satisfied that the current manufacturers of homeopathic medicine are meeting the highest standards in terms of quality assurance; that is to say, they have good manufacturing practices.

However, due to the increased demand for homeopathic remedies, other manufacturers will likely enter the marketplace in the near future. Because their reputability has not yet been established, it would seem reasonable for a committee of homeopathic pharmacists to oversee the production standards of such companies, at least during their set-up period.

At this point we're making eight recommendations to the committee. Some are in a provisional state and depend on previous recommendations being implemented, so if there is some vagueness in our remarks I think it's necessary at this point. There is much exploration yet to be done.

We first wish to make the point—and this is categorical—that homeopathic medicines are neither foodstuffs nor drugs. They constitute a separate and distinct category in themselves, which should be acknowledged in law.

The second point is also a categorical one. The current proscription on certain homeopathic remedies should be immediately lifted. Instead, homeopathic medicine should be regulated so as to ensure that qualified homeopathic practitioners have full access to the complete range of remedies itemized in the materia medica.

Thirdly, we would like to see a permanent standing panel of qualified homeopathic practitioners struck in order to determine, among other things, the degree of risk of high-potency homeopathic medicines. Here our language must be provisional, because there is not yet a complete consensus within the field as to the degree of risk. We would have to elect appropriate persons from the various homeopathic bodies and professional organizations across Canada—and indeed internationally—to convene in order to hopefully come to some consensus on this matter. It would be premature to authorize any one person or any one body to determine that at this point.

We also think that the first task of such a committee would be to create a new regulatory framework to administer homeopathic substances in Canada at large. By means of this framework the standing committee could also be empowered to monitor homeopathic remedies with regard to their production, packaging, promotion and distribution. This covers both the aspect of safety and the aspect of misrepresentation.

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In our view it's imperative that this new regulatory body and none other assume the burden of proof of harm. There's a tradition as to what constitutes harm within homeopathy and means of discerning it. We regard homeopaths as alone being qualified in the first instance to assess a remedy as to that issue.

Our seventh recommendation is that the new regulatory panel should proceed in such a manner that homeopathic remedies are made affordable to the general public. This is a guideline in light of the fact that excessive regulation, labelling and DIN standards could drive the prices of the remedies beyond what people are prepared to pay, and the history of homeopathy has been such that it's always been an affordable remedy, always been an affordable therapeutics available to the people at large. We wouldn't wish to see that changed.

Our eighth recommendation concerns the wider range of health care products altogether, for within our practice as homeopathic physicians we will make use of vitamin supplements and herbal and botanical preparations. The OHA's position, therefore, with respect to the use and regulations of these products conforms entirely with the recommendations presented before this committee by the Canadian Coalition for Health Freedom on the third of February of this year.

So perhaps those brief remarks will offer something by which we can carry on a discussion. Thank you very much.

The Chair: Thank you, Mr. Smith.

Now, if we could have Madame Larocque.

[Translation]

Ms. Claudine Larocque (Secretary General, Fédération des professionnelles et professionnels salarié(e)s et des cadres du Québec—CSN): Good morning. First of all I would like to say that this is the first time that the Fédération des professionnels has participated in hearings at the national level. Therefore, I will use this opportunity to give you an idea of the type of activity that we carry out and who we are. In short, I would like to show you that we are representatives of everything that is happening in alternative medicine in Quebec, since we represent the acupuncturists, homeopaths, naturopaths and osteopaths.

I know that some of you speak French. I have some notes. Subsequently, we will certainly send you a brief.

Personally, I am a homeopath. I have been president of the Syndicat professionnel des homéopathes du Québec since 1993. I have also been the secretary general of the Fédération des professionnelles et professionnels salarié(e)s et des cadres du Québec since 1995. In October 1996, I became president of the Federal Bureau of Alternative Medecines. I have been one of the founding vice-presidents of the Conseil des approches alternatives et complémentaires de santé since 1995, and, since 1997, a member of the executive committee of the Réseau québécois d'action pour la santé des femmes.

I will briefly introduce you to the CNTU and its affiliated federations. In Quebec, the Confederation of National Trade Unions represents over 225,000 workers who are members of nine federations. More than 125,000 of our members are employed in the health and social services sector. They belong to the Fédération de la santé et des services sociaux.

The CNTU is the second largest labour federation in Quebec, and has distinguished itself by its social vision and its involvement in all the major social issues and in all sectors of activity, mainly: metallurgy, pulp and paper, communications, social affairs, trade and education from daycares to universities.

More specifically, I would like to refer to the Fédération des professionnels. For more than 30 years, the Fédération des professionnels has represented over 6000 professionals, more than half of whom work in the health and social services sector. We represent occupational therapists, physiotherapists, psychologists, social workers, legal aid lawyers, etc.

In 1988, the acupuncturists were the first alternative health professionals to join the federation. In 1989, the homeopaths joined the ranks. The naturopaths participated in our proceedings for the first time in 1995, and, in 1996, the osteopaths also joined us. We represent approximately 800 professionals in alternative medicine.

• 1110

All of our members are trained to the equivalent of a bachelor's degree, are subject to by-laws and regulations, subscribe to a code of ethics, and meet rigorous training standards. The training lasts four years. Consumers are protected by a conciliation committee that handles complaints from the public and is supported by the CNTU legal services.

As for the Federation's participation in health matters: the FPPSCQ has assumed an active role in all of Quebec's major social issues: parliamentary committees, tabling of briefs, consultation. We were really the only Quebec federation to be consulted in conjunction with the reform of the Office des professions, conducted by Mr. Robert Diamant.

At the federal level, we were consulted by the Bureau of alternative medicine concerning two issues: good manufacturing practices and the claims of homeopathic remedies.

In July 1996, the CNTU participated in the creation of the Ordre des acupuncteurs et acupunctrices du Québec.

We work in close co-operation with international organizations who contribute to the recognition of alternative medicine, including the Lannoye report on regulation of all alternative medicines for the European Parliament. Finally, in November we participated in the development of a five-year plan Prince Charles presented for the creation of what he calls integrated medicine. It is known that the Royal Family relies almost exclusively on homeopathy. Hence, Prince Charles is a great supporter of the complementarity of the different approaches. We believe that this is the path to follow.

Therefore, we could provide you with this information and these documents and those produced by our European collaborators.

The Federation views itself as an excellent representative of Quebec that will be helpful to this committee. We are consulted by the various agencies and departments of the Quebec government in sectors such as health and social services, education, legal aid, the independent professions and alternative medicine.

The Federation supports the main objectives of Health Canada. It is obvious that our objectives are quite specific and rather similar to yours, for example, improving training standards in education, protecting the public in respect to professionals and remedies, and ensuring that the public has access to the best possible natural remedies, promoting high standards of practice among our professionals of alternative medicine and supporting the development of alternative therapies at the international level.

In homeopathy, seven of our members have participated in international conferences in Australia, England, Costa Rica, Romania, the United States, France, Belgium, England, etc.

We are officially requesting that you introduce general regulations that will ensure that practitioners of alternative medicine can, first, provide the best possible quality natural medications through measures such as good manufacturing practices and, second, that alternative medicine professionals may have access to all the natural remedies in the various recognized international pharmacopoeia. For example, in the area of naturopathy, we know that individual amino acids such as lysine or cystine are not available. The only way for a Quebec naturopath to get a supply of these is to obtain them from the United States.

As for the Chinese pharmacopoeia, there are various remedies that are effective for treating asthma and other conditions but that are banned in Canada because of toxicity factors. I believe that the experts who were here explained this to you at length.

As for homeopathy, various schedules of the current Canadian regulations list a number of remedies that are available in most other countries, and we ask you to remove the ban on homeopathic remedies such as components using arsenic, mercury, strychnine, etc.

We would also like to begin a joint examination of the definition of "prescribing practitioners", since only one Canadian province has amended its legislation on the practice of alternative medicine, namely Ontario.

It would be unfortunate for everyone—the public, practitioners and government authorities—if the regulations were so restrictive that they led to a black market for natural remedies.

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You may ask me some questions on this, and I will tell you that we would regret this, but that it is something that could happen, because we need all the remedies available in the pharmacopoeia in order to treat our patients effectively.

In closing, I would like to request a hearing for the various groups and associations in order to provide information for the committee on the specific needs of the following disciplines: acupuncture and traditional Chinese medicine, homeopathy and naturopathy.

On behalf of the executives of the following unions, the Syndicat professionnel des acupuncteurs et acupunctrices du Québec, the Syndicat professionnel des homéopathes du Québec and the Association des diplômés en naturopathie du Québec, I would like to ask that representatives of each of these unions be allowed to enrich the Parliamentary Committee with their expertise. In this way, we will ensure that Health Canada establishes regulations on natural remedies that will protect the public and enable alternative medicine professionals to practice their profession properly with all the remedies set out in the various pharmacopoeia.

If the unions would appear before your committee, they would have an opportunity to submit their briefs and their recommendations.

Thank you for considering my request. I hope this is the beginning of a long working relationship, which, I am sure, will be mutually rewarding.

The Chair: Thank you, Ms. Larocque.

[English]

Would you tell these groups that they can apply to come if they have not already done so? They should just write to the clerk. They should do it fairly quickly.

Ms. Claudine Larocque: We will.

The Chair: We will be hearing from all of these different groups if we haven't already.

Mr. Elley.

Mr. Reed Elley (Nanaimo—Cowichan, Ref.): Once again, thank you for sharing your time and your expertise in this area with us.

I'm sure you will understand me when I say that after hearing many people talk about what we believe is the same thing, those of us on this committee sometimes get a little confused as to whether we really are talking about the same thing. There are two questions I'd like to ask about Mr. Smith's comments.

We've heard about the development of a third category. Are those involved in homeopathic medicine talking about a fourth category? That's one question.

Second, you talked about the current proscription on certain homeopathic remedies. You believe it should be immediately lifted. We've heard from a number of witnesses who have said they cannot get the list of proscribed natural remedies from the drug protection branch. Are you talking about the same thing when you talk about this?

Mr. Doug Smith: The second question can be answered fairly quickly. There is a list of proscribed homeopathic remedies. I saw it quite recently, and I believe it's updated. The last update I saw was January 1998. It is available.

Mr. Reed Elley: Really? We'd love to see that.

Mr. Doug Smith: We may have a copy.

Ms. Claudine Larocque: I have it.

Mr. Doug Smith: Very good.

Mr. Reed Elley: Is this different from this list that we've been trying to get from Health Canada?

Mr. Doug Smith: It's the same, but there are different schedules depending on the nature of the substance involved. There's a specific schedule for homeopathic remedies. It rhymes them off alphabetically beginning with arsenic and ending with strychnine.

Ms. Claudine Larocque: Yes. “Forbidden substances”—dated March 21, 1997, mercury, strychnine, chloroform, cocaine, morphine, opium, aurum, cortisone, digitalis, kali bromatum, lithium. This is mainly our pharmacopoeia.

Mr. Doug Smith: We understand that for an agent at the border it would be a bit like waving a flag in front of a bull to be importing opium, cannabis and arsenic. This is pretty inflammatory stuff and we don't expect that the border officers are necessarily aware of the fact that these things are attenuated in the level of one to the sixtieth zero. Thus, as we say, there's no original trace of the substance present in these preparations. They are energy bodies. They are energy medicines. The word may be provocative for some, but it's something we must use. Otherwise, the nature of the homeopathic effect is inexplicable, there being no atomic presence left.

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The first issue that could be easily remedied would be to lift this proscription in that the materials that are coming in are not material substances.

The Chair: Excuse me for a second.

[Translation]

Ms. Larocque, would you like to give a copy of that to the clerk?

Ms. Claudine Larocque: Certainly.

[English]

Mr. Doug Smith: That's the easier-disposed-of question. We would recognize that any regulatory agency would be faced with an increasing task were further categories of drugs to proliferate, but we do take the position that homeopathic remedies are unique. There's no other form of medicine prepared in this way. Because they are unique, I think they have to be approached in a distinctly different regulatory framework.

We're prepared, of course, to discuss details in this regard, but from our point of view it really is necessary to regard homeopathic remedies as somewhat different from health substances or health medicinal substances altogether, natural health substances.

While we may argue that they fall in the general category, it's also true that we use toxic materials as a substrate, as a point of departure, to prepare our remedies. To maintain that a snake venom, for instance, is a natural substance, or arsenic or uranium nitrate are natural substances, is a moot point. It's not something we wish to pursue. What we do claim is the preparations we make have not been altered chemically or biochemically. They are altered through a physical process that we call sucussion, or trituration. They're natural only in that sense.

Mr. Reed Elley: To get right down to the bare bones here, you are advocating a fourth category.

Mr. Doug Smith: Well, let's call it the third category and let the other ones have the fourth.

Voices: Oh, oh.

Mr. Reed Elley: You are advocating another category.

Mr. Doug Smith: Indeed.

Mr. Reed Elley: All right. Thank you.

The Chair: Madame Picard.

[Translation]

Ms. Pauline Picard: I would like to welcome the three of you. I should say at the outset that I believe in alternative medicine and I use natural products. I would like to know what you think about this comment made by the Association of Canadian Pharmacists:

It is true, of course, that homeopathy uses medicinal plants, but in such weak, non-therapeutic doses that often there is not a single molecule of the drug left. According to homeopathists, once these drugs are diluted, they are extremely effective and remain effective even once the active ingredient has disappeared. This runs counter to conventional pharmacological principles whereby, to some extent, there is a response dose. In other words, the larger the amount of drug, the greater the response. Most health care professionals think that homeopathy is a "pathological science" that relies solely on the placebo effect.

What is your response to that?

Ms. Claude Larocque: Should I try?

Ms. Pauline Picard: Yes, or both of you or all three of you.

Ms. Claudine Larocque: First of all, I must say that this is a question of vision and culture. Nevertheless, I find it difficult to understand why— homeopathy has existed for 201 years. It was developed by Samuel Hahnemann.

So homeopathy has been practised for 201 years. At the present time, homeopathy is practised in 45 countries, by both doctors and homeopaths. The remedies found in our pharmacopoeia are part of the official pharmacopoeia of these 45 countries. I am thinking of places such as France, Belgium, Germany, Sweden, England, Australia, Costa Rica, the Bahamas, Romania, Moldavia and the United States.

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Some scientists deny not only the homeopathic effect, but also the fact that it exists. At the very least, I think that someone interested in science should not necessarily deny a phenomenon he or she does not understand.

I believe that four French researchers studied the theory of highly diluted substances for 20 years. Last year they published the results of their work, and when they went to give their first lecture, a pharmacist and a doctor passed out because the explanations they were hearing ran so counter to their idea of therapeutic effects. I don't think it can be said that homeopathy has a placebo effect, when we see the therapeutic effect confirmed everyday in our offices. These results are measurable and have been measured.

If you wish, I could provide you with the evidence submitted by the doctors at the London Homeopathic Hospital, because in England there are hospitals that provide mainly homeopathic treatments. I have trouble believing that the government authorities in England would be involved in some sort of conspiracy to treat their patients with nothing other than the placebo effect. This research exists, and the effectiveness of homeopathy has been demonstrated. Nevertheless, there is the paradox of homeopathy: namely, that we cannot really explain how it works.

However, I would say that the fact that at the moment science does not have the tools required to prove that something works does not mean that the process in question does not work. I have trouble imagining how the French Minister of Health would allow half of the population to be treated using nothing other than the placebo effect for decades and decades. This would be very difficult to understand, at the very least.

[English]

Mr. Doug Smith: I'd have a few things to add to my colleague's remarks.

The Chair: Fine. Go ahead.

Mr. Doug Smith: There is a whole branch of homeopathy involved with veterinarian science. There is considerable success being registered by veterinarians through the use of homeopathic remedies. It's very hard to see how a cow or a dog or a cat can operate according to the placebo effect.

Children also take homeopathic remedies and there can be some placebo effect in this situation. These remedies are successful in instances where you have idiocy or brain damage or circumstances where the child is inattentive—ADHD, for instance—to the environment or the immediate circumstances or the nuances of emotional or psychic rapport that can go on with the doctor and which constitutes part of the placebo effect.

As my colleague mentions, there is research being carried out most professionally in France with regard to degranulation effects brought about through in vitro experiments with homeopathic remedies in which it's been shown indubitably that there is an acceleration of a biochemical process in the presence of these remedies.

There is virtually a stack of material, which is altogether more than suggestive, showing that even in in vitro there is a demonstrable effect taking place. I think we're right at the verge of some breakthroughs in this regard of science being able to finally document through the use of instrumentation that there is something going on.

Interferometers, interference grids and so forth are pointing to a shadow world where the homeopathic effect can be discerned as an effect of something else. We can see through interference patterns that there is something going on, there are different levels of electrical potential.

It's very important to stress that these phenomena are a by-product of the homeopathic effect and do not represent the effect in themselves. It's all too easy for persons who are perhaps marginalized with regard to the conventional scientific enterprise to jump upon the first positive finding and say “There's the homeopathic effect”.

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I think we have to be cautious and not become reductionist in that regard, such that we're not going to quickly conclude that the homeopathic effect is merely electricity or merely an interference pattern. It actually has to do something with the vital force. By maintaining that perspective, we are inviting scientists to begin to think in larger terms than simply to regard the physical organism as a biochemical soup—that there is an animating principle that's involved there. Our medicines are addressed precisely to that.

The Chair: Okay. Thank you.

Ms. Caplan.

Ms. Elinor Caplan: The questions I have relate to the fact that we're hearing a lot of different names of practitioners—homeopaths, naturopaths, herbalists, Chinese medicine practitioners. I can only speak from the Ontario context, but in the legislation in Ontario, which is a self-regulating environment, the decision has been made to include naturopathy, but they have not yet received their own legislation. There has not been a decision to include any of the others in a self-regulating environment. The decision was made—and I know it well—because the view was that they weren't doing anything harmful.

Having said that, in the context of the cascading risk of harm, I'm curious about your list of products in the context of whether you think evidence should be produced if a claim is made. And in a society where we have a self-regulating environment, how do you think that evidence should be provided to protect the public from harm?

Mr. Doug Smith: We don't have a final answer to this question, but the initial distinction we are hoping will be made has to do with dividing the field of homeopathic medicines into high and low potencies. Obviously there's a sliding scale, but in practical terms the remedies are made on the basis of certain standard potencies. So one could establish a threshold. It would remain arbitrary, but it's not entirely arbitrary.

Ms. Elinor Caplan: A threshold on the basis of harm or toxicity or what?

Mr. Doug Smith: The level of potency, the reason being that you can—

Ms. Elinor Caplan: The level of potency—could you explain what that means?

Mr. Doug Smith: Well, the remedies are based on the principle that less is more. So the more the remedy is attenuated—and this is the aspect that the pharmacists found pathological about our approach—through sucussion at each point— It's not just mixed passively. There's quite a violent process involved. I've done it myself, and I can attest to the amount of energy that's thrust into the remedy as it's potentized up through the stages. This can be done 30 times, 200 times, 1,000 times, and the more it's done, the more potent the remedy becomes.

Ms. Elinor Caplan: Stronger.

Mr. Doug Smith: Stronger.

Ms. Elinor Caplan: But you may have some remedies that, no matter how strong they are, are not harmful.

Mr. Doug Smith: We rather doubt that.

Ms. Elinor Caplan: Okay.

Mr. Doug Smith: The point of departure could be something so simple as a seashell or hydrogen. It could also be a toxic substance such as a snake venom or arsenic or coffee. But the changes that are wrought in the material or the medicine as it's potentized make all of those substances somewhat risky to use in very high potency. The way we would see it is that they affect the vital force. The more high the potency, the deeper the effect is on the vital force.

Ms. Elinor Caplan: Do I have time for another question?

What we've heard is that there are foods and there are drugs, and then there's something else. Would you agree with that?

Mr. Doug Smith: Yes.

Ms. Elinor Caplan: That something else could be herbs or homeopathic products or natural health products. There's a whole range of products that people want to try because they either make a claim or, used in a certain way, may have a benefit to the individual. The challenge for this committee is to figure out whether there is an alternative way, a different process, for ensuring the safety and quality of the product, particularly if they are low-risk products, to ensure that people can have access to them without imposing the kind of rigour we put on pharmaceutical products.

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Maybe what we're talking about here is the need for a different process. Would you want to comment on that?

[Translation]

Ms. Claudine Larocque: In order to answer your question, I would like to add that we are talking about doses and measurements that can be weighed, both in the case of drugs and food.

Because of the law of the minimum dose in homeopathy, most of the time, there is not even a single atom of the original substance. Thus I fail to see how we could regulate these small remedies or these products, when we cannot actually measure their effect. Homeopathic remedies are not at all toxic, except, according to Avogadro's Law, beginning at the 9th hydrogen-ion concentration.

To draw a rather simple analogy, I would say that Health Canada allows a greater concentration of mercury in the fish you eat every day than is contained in 10, 20 or 30 tubes of mercuries. I think homeopathic remedies should be in a separate category.

[English]

Ms. Elinor Caplan: This is my last question. Do you believe that if a product makes a claim, it should have to prove its claim?

Ms. Claudine Larocque: Yes.

Mr. Doug Smith: May I respond to the previous question as well as in connection also with what you asked just at this point.

There's an issue around taking remedies of high and low potency. There is also an issue around taking remedies over a long period of time on a regular basis. Both processes involve risk. They should be overseen by a qualified homeopath.

In the second instance, I've known situations where amateurs or uninformed people have recommended to somebody that they should take a remedy that's used loosely to deal with depression. They say you should just keep taking this remedy until your sad feelings go away.

A qualified homeopath would know that if you keep taking the same homeopathic remedy, you're going to engraft on the vital force of the person the very problem they're trying to eradicate. I know several people who are now almost unshakeably depressed as a result of a misprescribing of homeopathic remedies.

If they take those remedies once, twice, or three times, that would be okay. The bad advice was for them to take that for three or four months or until the problem went away. The problem deepened, became more grave and ensconced, or engrafted, in our terms, so they doubled the dose.

This is the situation that causes us the greatest concern. We feel that in some way the public either has to be informed or the medicines have to be controlled in some fashion to prevent that from happening.

Ms. Elinor Caplan: What is your association doing to inform the public against these incompetent practitioners?

Mr. Doug Smith: We're rather militant about it. There are other associations in Canada that play tennis with the net down. Our perspective is that we, in Ontario at least, have to return to the same standards that were authorized in the original bill in the 1860s. There has to be a considerable amount of training in the area so that once you come out at the end of a long period, you are feeling comfortable about calling yourself a doctor. It's like that.

Ms. Elinor Caplan: You can't legally call yourself a doctor in Ontario.

Mr. Doug Smith: Not at this point. That's a situation we're working on in Ontario. It's a very slow process.

Of course, we wouldn't break the law, but there's an inner feeling as well of becoming competent to work with this form of medicine. It's not arrived at overnight.

Ms. Elinor Caplan: Do you publicize the names of those you have concerns about?

Mr. Doug Smith: No, we don't.

The Chair: There are only certain questions we want to know the answer to.

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Mr. Doug Smith: The second question with regard to advertising risk is a difficult one for us to deal with, because again we're not working with standard disease classifications. To alert the public as to what the risk of a remedy is would be to go through the kind of long-winded explanation that I've offered you here just now in terms of repeated dosages posing a risk.

The best we could do in our view is to make high potencies available only to qualified practitioners, and, for the foreseeable future, allow low potencies to be available on the market in light of the fact that there's always been a popular or folkish aspect to homeopathy. These low potencies are known and used by people who have a passing acquaintance with the field and have developed some effectiveness in working with self-limiting acute episodes. They know what to do for their headaches, fevers and diarrhea, they're quite accurate about that and they're prepared to work.

Many European, South American and East Indian people have this kind of household familiarity with homeopathy and we wouldn't wish to interfere with their practices. They ordinarily would not use high potencies.

The Chair: Thank you. I only allowed Mrs. Caplan to continue because I had no one else on the list.

May I ask a question here? Could you tell us what your training is, how many years it lasts, and who teaches you, etc.? And if you are a self-regulating body, could you tell us how you regulate your industry? Anyone who wants to can answer.

Madame Larocque.

[Translation]

Ms. Claudine Larocque: In Quebec the Syndicat professionnel des homéopathes du Québec knows that there is a legal vacuum at the moment. That means that under the Charter of Rights and Freedoms, Quebeckers are entitled to homeopathic care. Under Quebec law, homeopaths are charged with practising medicine illegally, and doctors are charged with non-scientific practice of medicine. So legally, even though Quebeckers are entitled to receive homeopathic care, no one in the province can provide this care. Consequently, the union representing homeopaths thinks that in order to protect the public—

[English]

The Chair: Excuse me, Madame Larocque, could you answer my question about your training?

Ms. Claudine Larocque: I was getting to it.

The Chair: Good.

[Translation]

Ms. Claudine Larocque: We think that protection of the public depends on training. There are 1500 hours of homeopathic training, spread out over four years. It is the equivalent of a B.A.

Our members must obey our by-laws and regulations, a code of ethics, and training standards. In addition, we have a conciliation committee that handles public complaints in co-operation with lawyers from the CNTU.

We conduct information campaigns regularly. Our last campaign was held in August, when Homeopathy Week was established in Quebec. All our members went to provide information sessions in the CLSCs and clinics, and held open houses to invite consumers to come in to hear free talks on homeopathy.

In order to ensure the public is protected, we have requested professional incorporation with the Quebec Office des professions. The matter is still under study.

We have also publicly denounced the incompetence of professional health care workers who offer homeopathic services. We believe they are direct threats to the public. Let me explain what I mean. All physicians, pharmacists and nurses who are members of their professional associations in Quebec, together with dentists and veterinarians, all these people who have direct contact with patients, take 45 hours of training with a homeopathic laboratory, 75 hours if they are lucky—and they claim to be homeopaths.

In my opinion, while these people may be excellent doctors, they are incompetent homeopaths. They are prescribing homeopathic remedies, exactly as in the example given by Mr. Smith earlier, and decide that homeopathy does not work.

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Let me give you an example of the way I see the situation. I am a homeopath, and if I were to take a St. John's Ambulance course tomorrow, could I claim to be a doctor? That is exactly the type of thing I am talking about. We are very active with the government to try to get recognition for homeopathy and to create all the necessary regulations so that we have access to better training. We want to improve our practice in order to better protect the public.

[English]

The Chair: Mr. Smith, did you want to add anything?

Mr. Doug Smith: I would wish Ms. Shannon to do that.

The Chair: Ms. Shannon.

Ms. Lynda Shannon: At the last page of your handout we have included a list of our standards, standards that the OHA does accept. If you look at criterion two on the very back page, we insist on 750 hours in homeopathy, taught of course by fully qualified homeopathic people, plus we have 1,100 hours that are required in clinical externship. And, of course, everybody understands that this means seeing patients in a supervised setting. Also, there are many medical science courses. Under criterion one on the previous page, you can see the actual numbers that are required, and these must be taught at the university level. Basically, these are the only standards we will accept in the OHA and this is how we protect the public from risk of harm.

The Chair: And for the self-regulation is there any follow-up? Or if you know somebody does something wrong or anything, is there any kicking people out of the association?

Ms. Lynda Shannon: Yes, there is. At the moment it's slipped my mind what the committee is called, but there is a committee in the association that deals specifically with complaints of our professional members, and we are very careful that any complaints are very carefully fielded.

The Chair: And can you disqualify somebody, remove them from the field?

Ms. Lynda Shannon: We can remove them from our association, which to our understanding has the highest standards, at least in Ontario. And at the moment that's the strongest policing we can do, because of course we're not a regulated profession as yet in Ontario.

The Chair: So somebody could continue to practise even though they were using unacceptable—

Ms. Lynda Shannon: Unfortunately, yes, they could.

The Chair: Madam Wasylycia-Leis.

Ms. Judy Wasylycia-Leis: Thank you.

I have several questions. I'll try to do them all at once and see which ones you feel comfortable answering.

The first is further to the line of questioning by Elinor Caplan, and tell me if I'm wrong in terms of my understanding. But my assumption is that practitioners in the field of homeopathy would want to see homeopathy considered as a school of medicine, not as simply a line of products, and in fact your long-term goal would be to seek recognition of homeopathy as a legitimate medicine, as legitimate as established medicine in this country. In fact you would like to see it included in the whole health delivery system, in the insurance system and so on, but that the short-term goal would be at least to have legitimacy of homeopathic remedies through this review of the regulatory framework. That's the first question or statement I'd like you to comment on.

The second has to do with, Doug, your comment that in fact if there was to be a third category, or fourth, whatever, at this point in time there's not a particular national body in the country to draw on for representation. So my assumption is that at present there is not a national association of homeopathy but that there are a number of provincial associations.

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Related to that point is that I'm very familiar and have had close association with the Manitoba Association of Homeopathy and have had long discussions with Dr. Leelamma Neilsen. I am familiar with their whole effort in Manitoba to establish an institute and a training school, an educational facility. They have also made a request to appear before the committee.

Can we assume that there is unity in thought on this whole area, that you have a common message, or should we in fact be hearing from other associations, like the Manitoba Association of Homeopathy, either to support what you're saying or to get other viewpoints?

My third question is related to your recommendations around the lifting of the current proscription on certain homeopathic remedies. How is it that one can now go to a drugstore anywhere and pick up a homeopathic remedy? I actually picked one up because it said “Good for fatigue”. I felt that this would be a magic cure-all. It's natural; it's by Homeocan.

I was surprised. I think it's very recent that this has happened—to see this range of products available in a drugstore. How is it that this is happening? Is it because of the moratorium that these products are now available, or are they getting around a regulation that we don't know about?

You said that you believe manufacturers are offering quality assurance, but you also said you think any homeopathic remedy should be delivered from a practitioner's office or a clinic.

Mr. Doug Smith: I disagree with that. The low-potency remedies, single, are—

Ms. Judy Wasylycia-Leis: Those are my three questions. Go ahead.

Mr. Doug Smith: I'd like to start with the last one, because that's the one that irritates me the most—not the question, but the situation that's taking place. It's rather like bad money driving out good.

The homeopathic system is rather subtle and it addresses itself to a level of the human being that's not identified by the universities or mainstream paradigms. Therefore it's easily corrupted and distorted by these kinds of commercial appeals.

Any practising homeopath would never say that their remedies are good for such a thing as insomnia. They work with very complex patterns of symptoms, amongst which might be insomnia, but insomnia is not something you can prescribe for as a homeopath. It's left to other forms of medicine to take on that issue.

We work with very differentiated symptom patterns, and it's often tremendously informative or educational for our patients to understand that we're not grabbing on to disease classifications but working with a far finer grid of manifestation.

This kind of thing is what we tried to address in our brief. It causes confusion. It's almost a form of misrepresentation. It certainly is not a way in which a homeopath goes about prescribing, and therefore, in terms of the actual therapeutic encounter, these are not homeopathic remedies, because they're not being applied to the level of phenomenon that homeopathy works with.

I know that homeopaths would make the case that this is a case of misrepresentation. That stuff could be sold as a means of curing insomnia—fine, that's a folk remedy. But to call it a homeopathic remedy at the same time is misrepresenting, because this is not the way homeopaths work. They do not prescribe for insomnia.

So something has to go there. Either you get rid of the insomnia or you get rid of the homeopathy. You can't have both.

If you encounter a homeopath who is prepared to pop a pill into you simply became you have insomnia, then that is not a homeopath. That is somebody who is pretending to be a homeopath, and that would carry us back to one of your earlier questions, as to what a non-self-regulating profession can do about such things.

We can certainly circulate information. We can gossip, as professionals are apt to do, about incompetence and nincompoops and pretenders and impostors. In no case did I use the word “quack”, but somebody who would take it upon themselves to treat a broad-gauge condition with this form of medicine is presuming too much, certainly. We can work through informal means to deal with that, but at the moment we lack a legal lever by which we could identify to a government body the fact that somebody was practising homeopathy without a licence.

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The Chair: Would anybody else like to answer that?

Ms. Judy Wasylycia-Leis: What about the other questions? My question was about who else we should be talking to or whether all the associations are of one mind.

The Chair: Answer quickly, please.

Mr. Doug Smith: I think we can both offer something on that because we come from very different perspectives, both provincially and culturally. I've been most satisfied by the level of communication that's achieved at conferences and congresses rather than the level of liaison that currently exists amongst the provincial organizations.

We've been struggling so much to get our own shop together and to go through a process of regulation which is only intelligible at the provincial level that the matter of interlinking with the other organizations, while it's very important, is not the highest priority. We only have so much time, and the issue of regulation within our own provinces is paramount at this point. Once we get that, then a whole category of abuse that we've identified here can be dealt with on the spot or very quickly.

To answer your question directly, I think it would be wise to canvass all the provincial organizations. You may find uniformity of judgment, and we would love to hear about it.

[Translation]

Ms. Claudine Larocque: I think it would be very interesting if homeopaths from different provinces could talk to each other more often. I agree completely with what my colleague from Ontario was saying about our self-regulation and our battles to try to obtain professional recognition at the provincial level.

However, I should perhaps mention that in the last two years, the union representing homeopaths in Quebec has been a member of the International Council for Classical Homeopathy. This is the most demanding and strict international association regarding homeopathic training. We have taken part in a number of meetings, in Germany, for example, and we write to each other regularly. The objective is to establish worldwide training standards to ensure some consistency in homeopathic care. We have already established contact with the North American Society of Homeopaths, NASH, and with our counterparts in Ontario and Quebec. We have already begun discussing issues of substance.

You will agree that our initial task is huge. We are seeking recognition of homeopathy as a different medical approach and recognition of our specific pharmacopoeia—the French, the German or the American pharmacopoeia. We realize that we are attacking a cultural, legal and professional empire. Even though the regulations in each province demand a great deal of energy of us, I think it is desirable that the issue of homeopathy be discussed in Canada. We support most of the demands and share the vision of our counterparts in Ontario on the subject of homeopathy. I think this could be a very interesting Canada-wide discussion.

[English]

The Chair: We've reached our time limit, but I have one question I'd like to ask you. Health Canada has indicated to the committee that they may invoke sections C.01.036, C.01.038 and C.01.040 of the regulations to permit use of prohibited substances in the manufacturing of homeopathic preparations. Would you agree with these modifications and should the Food and Drug Act and its regulations be amended in other ways?

Mr. Doug Smith: I'm not aware of these sections of the act, so I can't answer directly to that. I can only reiterate what we said at the beginning: we wish to see the proscription list lifted.

The Chair: Thank you. I'll call the meeting closed now and speak to you about it afterwards.

Mr. Doug Smith: Thank you. This has been wonderful.

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Ms. Elinor Caplan: Madam Chair, I asked if I could be recognized before you adjourned the meeting, because I would like an opportunity at some point. I know we're scheduled with representation of witnesses, but what we've been hearing from witnesses over and over again is that we don't get a chance to hear from people directly.

The Chair: Ms. Caplan, do you want them to stay or can they go?

Ms. Elinor Caplan: It's up to them. They're welcome to stay or not. I'm not addressing this directly to them.

I am concerned that we're not hearing directly from consumers. The only way we're going to be able to do that is if the committee takes the time in March to visit some of the places across this country that will give people a chance to come and address us. We had originally scheduled some time on the committee, and I'm asking you to set some time—not to interfere with delegations; I don't want to do that. But I would like us to have some time when we can discuss that issue, because it was the wish of the majority of the committee to travel.

The more I hear from witnesses, the more I believe it is important for us to leave Ottawa and go out and listen to people who use these services, use these products. We haven't had a chance to have that discussion at committee, of even some ideas and proposals, so I'm asking if you will schedule some time for the committee to have that debate.

The Chair: Certainly.

[Translation]

Ms. Claudine Larocque: I would like to tell committee members that the Quebec Department of Social Services has done some surveys. They show that 85 per cent of the Quebec population favours recognition of alternative medicines, that 49 per cent of the population consults alternative therapists, and that the majority—namely 47 per cent, turns to alternative medicine because they are totally dissatisfied with the way they were treated by conventional medicine.

I could send you copies of these surveys if you think they might give this to you. They could give you a better idea of what people think about alternative medicine and what they demand of it.

[English]

Ms. Elinor Caplan: We've been enormously frustrated in trying to hear people directly, so if you would like to table anything, just send it to the clerk and they'll circulate it amongst the committee members. That would be very helpful.

The Chair: Thank you very much.

The meeting is adjourned.