THE STANDING SENATE COMMITTEE ON SOCIAL AFFAIRS, SCIENCE AND TECHNOLOGY
EVIDENCE
OTTAWA, Wednesday, April 18, 2018
The Standing Senate Committee on Social Affairs, Science and Technology, to which was referred Bill C-45, An Act respecting cannabis and to amend the Controlled Drugs and Substances Act, the Criminal Code and other Acts, met this day at 3:45 p.m., to continue its study of this bill.
Senator Art Eggleton (Chair) in the chair.
[Translation]
The Chair: Welcome to the Standing Senate Committee on Social Affairs, Science and Technology.
[English]
My name is Art Eggleton, senator from Toronto, and I’m chair of the committee. I’ll ask my colleagues to introduce themselves.
Senator Seidman: Judith Seidman, Montreal, Quebec, and deputy chair of the committee.
[Translation]
Senator Poirier: Welcome. Rose-May Poirier from New Brunswick.
[English]
Senator Marshall: Elizabeth Marshall, Newfoundland and Labrador.
[Translation]
Senator Galvez: Rosa Galvez from Quebec.
Senator Mégie: Marie-Françoise Mégie from Quebec.
[English]
Senator Omidvar: Ratna Omidvar, Toronto.
[Translation]
Senator Petitclerc: Chantal Petitclerc from Quebec.
[English]
The Chair: I expect others will be joining us shortly. The Senate is still in session and they are trying to get away.
We are continuing with our examination of Bill C-45, An Act respecting cannabis and to amend the Controlled Drugs and Substances Act, the Criminal Code and other Acts. Today we have witnesses over two panels, which will take us up to 6:15 p.m. This first panel will be from 3:45 p.m. to 4:45 p.m.
I am pleased to welcome two representatives of the Canadian Research Initiative on Substance Misuse, or CRISM, Dr. Benedikt Fischer, Addiction Chair, Professor, Department of Psychiatry, University of Toronto; and Dr. Didier Jutras-Aswad, Principal Scientist,Centre de recherche du Centre hospitalier de l'Université de Montréal; and here as an individual is Michael DeVillaer, Assistant Professor, Peter Boris Centre for Addictions Research, McMaster University.
Welcome to the three of you. For the organization, if the two of you would please split your time. We have about seven minutes, and I know that’s not a long period of time, but you will get a chance to respond to questions and perhaps get some additional points in play as you go.
Benedikt Fischer, Addiction Chair, Professor, Department of Psychiatry, University of Toronto, Canadian Research Initiative on Substance Misuse (CRISM): Honourable senators, good afternoon. It’s a great pleasure to be here with you this afternoon and to share some of our experiences and provide input into this important legislation.
Let me start with the fact that we are, of course, in favour of Bill C-45 and the legalization of non-medical cannabis use and supply. We see this as an option to really improve public health and safety related to cannabis use and avoid most of the adverse consequences related to prohibition as they have unfolded for decades. We have explicitly supported this effort for many years, even before it became a policy initiative.
The devil is in the details, though. This is a Canadian approach and actually will be a major social and policy experiment. It will depend on a lot of details and determinants whether things go well or not. This is really the issue that I want to speak about here today. Concretely, I want to speak quickly to five key points in the legislation, or related to the legislation, that I think still warrant some consideration.
First is the provision of home growing. In my opinion, it’s categorically misguided as part of the supply scheme for cannabis in a public health and a strictly regulated approach. It’s a recipe for people producing cannabis that is unregulated, to expose minors and other vulnerable people who shouldn’t be exposed to cannabis and a recipe for diversion. It doesn’t belong in a public health oriented supply framework for cannabis. The provision should be scrapped.
Second, focus on advertising and marketing. I’m concerned with the fact that this is still handled in a fairly loose way. We know very well from experience with alcohol and tobacco that advertising and marketing, especially how it works in the electronic age, directly or indirectly greatly influences use and harms, especially with vulnerable populations such as young people. The regulations here need to be absolutely tight and waterproof to prevent the kinds of harms and problems we see with alcohol and tobacco. You have one chance to do that, which is at the beginning.
We have a clear recommendation regarding cannabis use and possession by minors. While age limits will be 18 and 19, use levels among people of lower ages — minors — are among the highest in the country in the Canadian population. This will continue. Despite political promises that cannabis use will be eliminated among young people, this will not happen. However, we should keep these young people punishment-free and free of exposure to the criminal justice system to avoid stigmatization and criminalization in this highly vulnerable group. There should be no criminal justice involvement even if cannabis is used or possessed by young people.
Finally, I have a couple of points on the need for a national research agenda. A lot of details about cannabis use and health are changing. We have new products. We have new modes of use. There are a lot of details that we don’t understand well. We need a national research program on cannabis use and health outcomes, as well as on the policy options and the effects of different regulatory regimes as they are unfolding in Canada. I see mainly piecemeal efforts right now from different sides and different angles. There needs to be a well-funded, well-resourced national research program on cannabis as part and parcel of cannabis legalization.
Related to that is that we need an independent monitoring and evaluation strategy of what remains a major social and even well-intentioned major policy experiment. Right now, there are a lot of small bits of evaluation and monitoring being planned by different players and different agencies. I’m worried about the fact whether this will ever come together as a comprehensive evaluation and, in about four or five years’ time, whether this will have actually worked in the interests of public health and safety. We need this comprehensive assessment after sufficient time to determine whether this experiment was positive or negative, and we need to rely on empirical evidence.
This monitoring and evaluation should be comprehensively conducted and resourced by an independent panel or committee of scientists or scholars who are fully independent of government who can determine, after a reasonable monitoring period, whether this worked in Canadians’ health and public safety.
I will leave it at that and hand it over to my colleague, Dr. Jutras-Aswad.
[Translation]
Dr. Didier Jutras-Aswad, Principal Scientist, Centre de recherche du Centre hospitalier, Université de Montréal (CRCHUM), Canadian Research Initiative on Substance Misuse (CRISM): I would like to thank you for your welcome and for giving me the opportunity to talk to you about some issues related to cannabis. I am a researcher both at CRCHUM and at CRISM, an addiction research network in Canada. I am also a psychiatrist who works daily with people with mental health and addictions issues. Like Dr. Fischer, I would also like to point out that, while we are generally in favour of Bill C-45, legalization is not an end in itself. It is the beginning of the work. What I am mainly in favour of is the well-being and health of Canadians. It is our hope that, collectively, we will move away from preconceived ideas to try, in a pragmatic way, to make choices, always in a spirit of public health, in order to minimize the impact of a substance like cannabis on the health of Canadians.
To do so, the approach must be balanced. There needs to be a fair balance that makes the market flexible enough to attract users to a legal market where they can take advantage of the potential benefits of a legitimate market where we can control more of the products. It is also important to regulate this market so as not to reproduce the illicit market where very little consideration for the health of cannabis buyers exists.
One of the aspects I would like to emphasize is that, despite the fact that we could spend a lot of time on this bill — we could spend the next 30 years studying it, in my opinion — it is clear that it contains features that will not be appropriate and that must be adapted to make the legalization of cannabis possible. There must be legislative levers — which are more in your hands — and we must have the data needed to quickly identify problems that may arise in areas that the bill may not have covered, in order to be able to adapt the legislative measures.
In terms of research, there are obvious needs that we are not meeting. We have some knowledge about cannabis and its effects on health, but clearly we are in the fog and in the dark with respect to many of the things that we absolutely need to know about cannabis and its effects on health. We need to better understand the effect of various products on health. We have a lot of data going back to the 1980s and 1990s, but the substance has evolved. For this reason, better data will be needed on different types of cannabis, with different THC levels, for example, and on the health effects of those substances.
I would be remiss if I did not draw your attention to the fact that we have no pharmacological approach to treat people suffering from cannabis addiction. It is unacceptable for this situation to continue. Intensive research efforts must be made to provide our patients with appropriate treatments when they develop a problem associated with the substance.
[English]
Michael R. DeVillaer, Assistant Professor, Peter Boris Centre for Addictions Research, McMaster University, as an individual: Thank you for the opportunity to speak to you this afternoon.
Canadians have received assurances that the cannabis industry will be strictly regulated, like other drug industries, to protect the public’s health. A half-century of international drug policy evidence tells us it is not so simple. Our regulatory bodies often fail at containing the ambitions of these industries. This very committee produced a report in 2015 that informed Canadians of the failure of Health Canada on occasion to effectively regulate the pharmaceutical industry. The same challenge persists with federal and provincial regulation of the tobacco and alcohol industries.
The state of the union is that we have three legal, permissively regulated drug industries, and we have three public health crises. Early indications from the emerging legal cannabis industry suggest that it is on a similar trajectory.
I have time today to give only a couple examples. My written brief to the committee provides reference to a report of mine that provides many more.
The first issue I will address today is cannabis advertising and other product promotion practices.
Bill C-45 includes restrictions on cannabis advertising. The industry is now discussing strategies to “. . . circumvent or navigate these regulations in a creative way.”
For example, they plan to use technology that allows viewing a plain cannabis package through a smartphone lens to reveal hidden features. When clicked, these features will provide access to brand information, such as a video to be viewed on the smartphone. This is exactly what we had hoped to prevent with the legislation.
The cannabis industry has also formally indicated its desire to advertise on websites and social media platforms that include up to 30 per cent underage visitors. That could mean potentially millions of underage Canadians being exposed to cannabis ads.
Clearly, the cannabis industry has not bought into public health protection as an important part of its business model. It will make all possible effort to circumvent restrictions on product promotion. This is why five prominent public health organizations in Canada have recommended not mere restrictions but a complete ban on product promotion. Following the advice of our public health experts, the product promotion restrictions currently in Bill C-45 should be replaced by provisions for a complete ban, with meaningful penalties for attempts at circumvention. I have included specific language in my written submission.
The second issue I will address is contaminated cannabis products. One of the promises of cannabis legalization is that we would have a properly labelled product that was free of the harmful contamination sometimes found in illegal product. After almost two decades, the legalization of medicinal cannabis has not delivered on this promise. Health Canada’s web page on product recalls lists numerous violations including contamination of medicinal cannabis with bacteria, contamination with mould and excessive use of pesticides, including banned pesticides.
Existing medical cannabis regulations provide for licence suspension for using a banned pesticide. Despite several incidents, not one licence suspension has been issued. Consider a company’s decision to, in effect, repeatedly poison their patients, some of whom have compromised immune systems, and then to conceal the evidence from Health Canada inspectors. Senators, if that is not grounds for a licence suspension, what would be?
Bill C-45 must ensure uncontaminated product for consumers. Consumers need to be made aware of the problem on product labels and there must be meaningful consequences for violations. Again, I provide specific wording in my written submission.
I would like to close with a quote from Jonathan Caulkins, an internationally renowned American drug policy researcher, who has this to say about the future of commercial cannabis legalization:
. . . there’s a good chance that people in 25 to 40 years will look back and shake their heads and ask, what were you thinking? Why did you think it was a good idea to create an industry of titans to market this drug?
Thank you again for giving me this time today. I will try to address any questions.
The Chair: Thank you very much. We will now get into questions, and I will start with the deputy chairs, as we usually do.
Senator Petitclerc: My first question will be for you, Mr. Fischer. You have talked a little bit about packaging and more on advertising. I want to hear a little more on your opinion of how strict or how much stricter advertising should be. Mr. DeVillaer talked about a complete ban. Some people talk about maybe a ban for advertising appealing to youth compared to adults. I wanted you to expand a little more on that.
Mr. Fischer: I will be happy to elaborate. I think the only way to go forward with this in a meaningful way is with a categorical ban on advertising and promotion. I think we need to be very conscious of things. If you open papers in Toronto or other places today, you will already find cannabis industry sponsored events, culture. There are a lot of indirect efforts going on in terms of promotion. I don’t think we’ll succeed in making exceptions or saying it should be advertised to adults only. I think it needs to be absolutely categorical and strict so the only thing that’s there is basic product information that consumers need. There probably needs to be a name of a company, but that’s about it, because otherwise it will be a slippery slope. The industry is very creative in sliding and bringing in indirect ways or finding loopholes. The only opportunity to do this is now. Once the genie is out of the bottle, you can’t put it back in.
Senator Petitclerc: I don’t know if anyone else had a comment on that. You’ve been pretty clear, so I think everybody agrees with that.
If we can continue on the plain packaging, we’ve heard the words “plain packaging” many times, but when we compare it to Bill S-5, for tobacco, there is a difference in the definition of “plain packaging.” For example, from what I know, and you can correct me, the names themselves can be very creative. Would you also, in the same kind of spirit, think that we should be very strict and perhaps go for plain packaging the same way as we do with tobacco?
Mr. Fischer: Ideally, yes.
[Translation]
Senator Petitclerc: I will continue with a question to you, Mr. Jutras-Aswad. You mentioned health research. You mentioned legalization, and especially protecting youth, and that certainly catches my attention. We have figures on the efforts that will be made in terms of education and awareness, and on the commitments that have been made in that regard. I am a little less aware of what has been promised in terms of research. Are you sure, under this bill, that you will be able to conduct the research that is essential in order to achieve the objectives of protecting health?
Dr. Jutras-Aswad: Actually, sums of money in the public domain have already been announced. That is not news to you. We are talking about $10 million for the Mental Health Commission of Canada and an organization called the Canadian Centre on Substance Use and Addiction, CCSA. It is for research, but the mandate is not clear as to whether it is purely research or knowledge transfer. That is a concern. It has to be specific. If you want to do research and generate new knowledge, there are processes linked to that. We need to plan a strategy to ensure that we do not cherry-pick, that we are not going to start research that is very fragmented and inconsistent. The Canadian Institutes of Health Research have been meeting to try to plan this. I do not represent that organization and we must give them the chance to express their vision.
At present, there is no clear research strategy. Somewhat in line with what Mr. Fischer was saying, this aspect is crucial right now, and it’s already late. It should have been done yesterday. A multi-level strategy needs to be put in place. We need an organized, planned, predictable and well-funded strategy that will conform to the processes we have in place to ensure quality research. This cannot be done in three minutes on the kitchen table. Quality research must be planned. We must have time to prepare these projects. One of the things that is missing — and it does not question the relevance of prevention — is research and innovation to treat people who have problems associated with cannabis use. A minority of people will become addicted to cannabis, but we have a glaring lack of knowledge about how to react. At this point, we do not know what to do, and we will still not know what to do later if no specific research initiative is started in this area.
[English]
The Chair: Before I go to Senator Seidman, you will notice that the white light is flashing, which means the bells are ringing. That means there is a vote scheduled in the Senate at 4:45. This is a motion on adjournment of debate on Bill S-203, which is the Whales in Captivity Bill.
We have permission to sit while the Senate is sitting, so we can continue if you want, but I suspect there may be whips or facilitators phoning around asking people to show up for the vote, although I’m told the email network is down so I’m not sure they’ll get through. But I’m in your hands. If you feel that we need to adjourn, it means that, at the latest, it would have to be 4:30, which is 15 minutes before this panel is scheduled to end in any event. It does mean I’ll have to tighten up a bit on the time for questions and answers. We’ll have to cut down on preambles if we’re going to get everybody in. Senator Petitclerc had a lot of questions to ask because she cut down on preamble, and that’s a good thing.
I’ll go back to this question of the vote and what we do in a few moments. Think about it.
Senator Seidman: Thank you very much for your presentations.
Senator Petitclerc has addressed my first question, which had to do with advertising and marketing. I think you have been extremely clear in what you’ve told us. You said this is a major social policy experiment, Dr. Fischer, and it depends on the details whether it will go well. You have made those details clear. Given I have a very short time here, I don’t particularly want to get into it, although we have been told that there are serious restrictions of marketing to kids here, and it’s only restrictions on marketing products in a way that evoke glamour or excitement. You have said a complete ban as your professional opinion, and I appreciate that.
Dr. Fischer, another thing you said that was quite vociferous and adamant had to do with growing cannabis in the home. You said it’s at categorical odds with public health principles and ought to be swiftly abandoned. Could you expand on your reasoning that it should be eliminated? What threats does it pose to the health and safety of adults and children, and how does it undermine the government’s rationale that legalization will improve quality and safety?
Mr. Fischer: I’m happy to give you further reasons around that. It is a little bit like if you are trying to keep your house safe and you lock all your front doors and windows but leave the back door open, if you will allow the analogy.
We are trying to do a strictly regulated public health approach to cannabis legalization here, which on many ends is well thought through and well designed. We are strict about who can distribute in terms of retail stores, what products are available and who will have access, but then at the same time, we’re saying, “Well, but if you don’t like those official access mechanisms, you can grow the stuff at home.” It’s four plants according to the law, but who will control it? Will the police go into houses and check?
Second, 15 per cent of the Canadian population are cannabis users and 85 per cent are not. In homes, you will inevitably expose a lot of nonusers or vulnerable people to growing cannabis. You don’t know what people are growing. It’s actually environmentally hazardous to do that. It will not kill people immediately, but it is not good for environmental reasons either. It is a safe recipe for diversion, which we’re also trying to avoid through all these other types of regulations we are trying to do.
There is an old-style romanticism related to cannabis that definitely exists in some populations, but for a strictly regulated public health approach to use and supply, this is categorically misplaced. Romanticism belongs elsewhere. But there is no sense in only then allowing two plants or 80 centimetres instead of 100. In order to make sense, it has to go. It has no place in public-health-oriented legislation of cannabis.
The Chair: To follow up, people have been producing beer or wine in their homes for some time. Do you see any equivalency there? They somehow keep it away from children.
Mr. Fischer: That’s sort of a boutique kind of activity and is way too complicated to happen in a broad-scale kind of approach because it takes quite a lot of resources. People typically do it in their garage and not in their living room or condominium. We would not allow people, for example, to compound medications in their homes. We need to be consistent with the principles here. If we are so strict about purity of cannabis products — who sells and what is sold in the retail stores, and we are focusing on that all that — then we don’t want to let people grow their own stuff in their own homes, the kinds of domestic environments that most people live in. Most people don’t live in a mansion with a few extra rooms where cannabis can be grown. It just doesn’t make sense from a public health point of view.
Senator Seidman: Dr. Jutras-Aswad, I will ask you about something you wrote in 2013:
. . . cannabis is most used by teenagers since it is perceived by many to be of little harm. This perception has led to a growing number of states approving its legalization and increased accessibility. Most of the debates and ensuing policies regarding cannabis were done without consideration of its impact on one of the most vulnerable population, namely teens, or without consideration of scientific data.
You mentioned in your presentation the concern, because there is so little empirical evidence about treatment uses and about overdoses, antidotes and things of that sort. How do you understand, then, Canadian teenagers, and is it the same in Canada as it is in the States and other countries where this has been legalized? Is there a danger we will make the same mistakes here?
Dr. Jutras-Aswad: At this time, we don’t have much data. That’s part of what we need in terms of the perception and the understanding, especially for youth, of legalization and what it means. That’s the kind of data we don’t have.
I would tend to think that’s also why we should be very careful about how we present legalization and how we explain it. We talked about it a few years ago with Prime Minister Trudeau when it was announced. There is a lot of work to explain that and make it clear that we legalize not because cannabis is completely harmless but because it is a better model than not legalizing.
For us here, that might be very clear, but we have to make it loud and clear, and in different ways — not just on TV but also through the Web and all kinds of different strategies — to reach youth so they understand this message very clearly.
Senator Poirier: Thank you, gentlemen, for being here and for the presentations.
My first question is for Dr. Fischer. On the CRISM website, there is a public brochure where it says that using cannabis before the age of 16 increases the likelihood of developing health, education and social problems. I was confused by that comment or that brochure. We’ve heard from so many doctors and experts of the risks under 25. At the same time, we are also hearing that the provinces were given the authority to be able to say what age they wanted. Most are going with 18 or 19. With your brochure sending the message that above 16, the risks are not as present, what type of mixed messaging is this sending to Canadians? Your brochure goes against all the evidence we have heard and even against the legal limits across the country. I was confused about that because of all the different ages.
Mr. Fischer: I’ll happily and respectfully clarify this for you. You are referring to the low-risk cannabis use guidelines we launched and that have been endorsed by major national health organizations in Canada. In that brochure, it certainly does not say that cannabis use above the age of 16 is without harm. We are reporting on the scientific evidence that exists about the correlation between initiation of use and potential harm outcomes. We are reporting on epidemiological studies that most consistently say that use before the age of 16 is associated with harms. That does not imply there are no harms associated with use initiation over the age of 16.
However, I want to make the scientific evidence very clear that, first of all, there is a sliding scale in terms of the association with age of initiation and use, and potential harm outcomes. However, this magic number of 25 that has been tabled by many people is, first, associated mostly with brain imaging studies that detect certain changes in the brain. What real effects really materialize from those changes in the brain in terms of educational, behavioural or other health outcomes is really mostly unclear, first of all. Second of all, we know that, in terms of the harm outcomes, most of the studies that show harm among young users are actually conducted with very frequent and chronic users. A lot of people have jumped to the conclusion that that applies to any kind of cannabis use in certain age groups.
There is a lot more research data that we really need to know and have on the association between age of initiation and actually tangible harm outcomes. I have heard the question a lot that regulation says provincial 18, 19. Shouldn’t it be 25? Again, it is a sliding scale. It depends a lot on how people use, what they use and use patterns. There is no magic age that we can dictate. We can maybe say that above the age of 90 is probably a safe recommendation in terms of avoiding health outcomes, but all of this has to be a compromise, given that we’re not talking about something in a vacuum or that we are starting from zero. The use that is occurring right now is actually really ongoing right now and will continue to happen. I think 18 to 19 is a good, reasonable compromise, and as my colleague said on the prevention side, it’s important to inform young people of the harms and risks associated with cannabis use but also to differentiate what determinants influence higher risk of harm outcomes. At the same time, we need to be clear that, if we’re keeping young people in the context of use in an illegal environment, that the illegality of use among young people will continue to do at least as much harm as the potential health harms of exposure to cannabis.
Senator Poirier: Again, on the same thing as another comment, when you talk about the age of 16, I understand what you are saying. But, at the end of that comment, it says: “Generally, the later in life you begin to use cannabis, the lower the risk of problems.” Because you’re using an age of 16, I’m just wondering what message that is sending out to someone who is 18 or 19. Are we telling them that there is less risk for them at 18 or 19 than there is at 16 just because it is a different number and a very young age? I had concerns.
Mr. Fischer: Again, the number 16 refers to the epidemiological evidence on the correlation between age and harms. The recommendation that’s given is literally, as you read, the later in life you begin to use cannabis, the lower your risks are for potential health harms. That’s the prevention message that the current scientific evidence allows. Ideally, initiation is as late as possible in life. At the same time, the reality is that we have a lot of young people in teenage age groups who will make the decision, one way or another, to use cannabis.
The Chair: Okay. We’re going to have to speed it up a little bit. The vote, as I’m now told, is at 4:55. It’s an hour bell, and it started at 3:55. So 4:55 is the vote. I assume, though, that you will want to go for the vote. Yes. Okay. So 15 or 20 minutes travel time? You might leave a little earlier. So 20 minutes. All right, that means that we have 10 more minutes on this panel.
Senator Omidvar: Chair, is the vote at 4:45?
The Chair: At 4:55. I had the wrong information previously; it’s 4:55. We will wrap this up in 10 minutes. I have four questioners, so I’m going to have to ask you to just pose one question, and that’s it. I’m going to take two at a time, and then we will get the answers as we go. Otherwise, we will not get this done in 10 minutes.
Senator Marshall: I’ll talk fast.
This government talks a lot about results, and I was interested in what Dr. Fischer said about the comprehensive, independent assessment. The government has outlined three objectives of the legislation — I don’t know if you’ve seen it — to prevent young persons from accessing cannabis, protect public health and public safety and deter criminal activity. My question is: Do you think that the government is going to be in a position to conduct such an evaluation three or four years down the road? What do you think is the likelihood of a comprehensive, independent assessment?
Mr. Fischer: On the first one, it is probably relatively easy to assess that. There are surveys to determine the use prevalence among young people. Public health and safety are broad concepts that consist of many different kinds of indicators that need to be rigorously measured. There are a number of individual, parcelled, fragmented initiatives going on right now, but, at the end of day, we need a comprehensive assessment of whether public health and safety, as large comprehensive concepts, are protected and improved or whether things have gotten worse or whether there was any change. I’m not clear on how the different pieces out there now and all of the different players will come together into one comprehensive, empirical answer, so I have some concerns around that.
Senator Marshall: Can we give questions and get written answers from the witnesses after?
The Chair: You could do that, but could you put the question in writing? It’s just that we are running against the clock here.
Senator Marshall: I certainly can; I’ll give them to the clerk.
The Chair: We can do that certainly, yes.
Senator Galvez: Thank you for saying that consuming cannabis will eventually get into an addiction and that you will have to look for treatment for that. I’m a professor at university, so I have faced many times addiction problems in young people.
The cannabis of today is not the cannabis of the '70s or the '60s. The concentration is much higher, and, when you put it into edibles, it can go much higher. The uptake and effects are different. Two questions: Do you have any recommendations on the maximum concentration, and have you foreseen the capacity of hospitals to receive the people that will eventually need treatment? Are we prepared for that?
Dr. Jutras-Aswad: I don’t know if you referred to something I said. Basically, what I said is actually that some people who use cannabis, at some point, could develop addiction. I don’t think I said that we will start to see more people developing addictions related to cannabis. It is already something happening, whether or not it’s legal. It has nothing to do with that. We already have data showing that about 1 person out of 11 who use cannabis will develop a dependence. It is a minority of them, but it is still a significant number.
As for the impact on hospitalization, in my opinion, we don’t have any kind of data allowing us to predict that. Actually, we’re not even sure that it would happen at all, that there would be an increase in hospitalization at this point. That is one of the first times it will happen the way we will do it. I think it’s very early to say that there will be an increase in hospitalization at this point.
Hopefully, I didn’t mislead anyone by saying that there will be increase in addiction relative to cannabis. That’s not what I said.
[Translation]
Senator Mégie: You have already talked about that. You said that, if all we keep doing is prohibition, we are going around in circles. Yet many people are asking us to delay legalization because we do not yet know about all the harm and about the ways to deal with addiction. Why not wait? I would like to hear what you have to say about this. Why not wait longer to have all the information on hand before we legalize it?
[English]
Mr. Fischer: If you apply the same logic to alcohol or tobacco, we immediately have to criminalize both substances. There are a lot of things about the harms of those drugs we don’t know. We can’t properly treat them when dependence disorders develop, so the question is a little bit about where is that logic or whether it is consistently applied.
We will never completely know everything about the harms and risks or how to treat everyone. There are knowledge gaps right now around those kinds of things. At the same time, the overall evidence from alcohol and tobacco and other fields clearly suggests that legalizing and strictly regulating cannabis and regulating its access and product typologies, et cetera, is likely to reduce the adverse consequences of bad or harmful policy. We have massive adverse consequences for prohibition right now, and this is what legalization tries to address. It doesn’t mean it is a panacea and that there won’t be continued problems. Cannabis is evolving in terms of the substances. There is a lot we have yet to understand, but we need to differentiate those details from the overall regulatory or policy scheme that we believe will reduce harms to public health and safety overall. We still have to understand a lot of additional details.
Senator Omidvar: My question is to Dr. Fischer and it’s about home cultivation. The medical regime currently allows for home cultivation. You have to apply for a licence. Have you observed the kind of harms you outlined in your presentation in the medical regime that you feel will then also be present in the recreational regime?
Mr. Fischer: We have those provisions in the medical regime not because people genuinely believed this was a good idea for public health but because, in the beginning, the medical regime was so messed up and over-regulated and the supply chains were so restrictive to medical patients that this was provided as almost an emergency solution for the provision of the substance. Once legalization comes, I think those things also need to be rethought when we have the time and space to properly organize our medical regime. But overall, whether it’s for medical patients, recreational patients or people in the middle, growing cannabis at home in home environments is neither advised for users themselves nor for others that were concerned about their safety and well-being.
The Chair: Okay. I’m sorry that we cut this short because I’m sure there were more questions. Mr. DeVillaer, your presentation was so precise and, I think, so fully understood you didn’t get any questions.
Senator Omidvar: I did have a question.
The Chair: But we can’t do it. You can ask it personally.
Mr. Fischer: If it’s helpful, you can contact us directly, and if we can be of help we will continue this bilaterally.
The Chair: Thank you.
We will resume immediately following the vote in the chamber.
(The committee suspended.)
(The committee resumed.)
The Chair: We are now into our second panel on our continuing study of Bill C-45. We were scheduled to start half an hour ago, so we missed the first half hour. However, we can stay until 6:30. Another committee is coming in here at 6:45. If that’s okay, we’ll go past 6:15 and adjourn at 6:30.
Let me introduce who we have on this panel. First, from the Canadian Medical Association, Dr. Laurent Marcoux, President, and Dr. Jeff Blackmer, Vice-President, Medical Professionalism. Dr. Marcoux will give the opening remarks and Dr. Blackmer is here to also answer any questions.
From the Canadian Nurses Association, Karey Shuhendler, Program Lead, Public Policy, and Lynda Balneaves, Registered Nurse and Medical and Non-Medical Cannabis Researcher. Karey Shuhendler will make the opening remarks.
From the Canadian Psychiatric Association, Dr. Philip Tibbo, Professor, Department of Psychiatry, Dalhousie University.
Finally, from the Canadian Academy of Child and Adolescent Psychiatry, Dr. Robert Milin, Director of the Adolescent Day Treatment Unit, Youth Psychiatry Program, Royal Ottawa Mental Health Centre.
Welcome to all of you. We’ll start with the opening remarks. We have seven minutes for opening remarks. I know it’s tight, but I would appreciate if you could hold to that because we’re tight on our meeting.
Dr. Laurent Marcoux, President of CMA.
[Translation]
Dr. Laurent Marcoux, President, Canadian Medical Association: Thank you, Mr. Chair. My name is Dr. Laurent Marcoux, and I’m pleased to be here in my role as President of the Canadian Medical Association. I’m joined here today by Dr. Jeff Blackmer, Vice-President of Medical Professionalism at the CMA.
As the national organization representing over 85,000 physicians and physicians-in-training, the CMA has a mission of empowering and caring for patients, with a vision for a vibrant profession and a healthy population.
It has been more than 15 years since the CMA has taken a public health perspective regarding cannabis. In the interest of Canadians’ health, we continue, as health professionals and physician scientists, to urge the government to exercise caution in legalizing cannabis for non-medical purposes.
Our position is rooted in four key areas. First, we believe and urge the government to adopt a public health approach in the legalization and regulation of cannabis. Such an approach includes: the promotion of health through adequate regulation of marketing and appropriate education; prevention of drug dependence; access to assessment, counselling and treatment services; and a harm reduction perspective; all of which should be consistent with the Lower Risk Cannabis Use Guidelines. We support the steps announced in Budget 2018 for funding for research and education.
We know that children and youth are especially at risk of harm, given their brain’s development — and they are among the highest users of cannabis in Canada. This is why we continue to stress that the age of legalization be 21 years. In addition, the quantities and the potency of cannabis should be more restricted for those under age 25.
Second, education is required to develop awareness of the health, social and economic harms of cannabis use. The CMA submits that young people should benefit from public health education. The lifetime risk of dependence to cannabis is estimated at 9 per cent, increasing to almost 17 per cent for those who initiate use during adolescence. In 2012, about 1 per cent of people aged 15 years and over met the criteria for cannabis abuse or dependence — double the rate for any other drug — because of the high prevalence of cannabis use.
The harm reduction strategy should include the development of educational interventions, including training programs, social marketing interventions and mass media campaigns. Education should focus not only on cannabis’ general risks but also on its special risks for the young and its harmful effects on them.
Third, the marketing and advertising of cannabis should be tightly regulated. We support strict packaging and labelling of cannabis and believe the same strict approach should apply to health products containing cannabis. Canadians must be protected from any misleading claims and be made aware that health products such as natural health products, non-prescription drugs or cosmetics containing cannabis are not scrutinized like prescription drugs, despite being regulated by Health Canada. In some cases, these products — or the companies producing and marketing them — don’t even need to provide scientific evidence to support the claims made on the label.
Like tobacco and cigarettes, cannabis packaging and labelling provide an opportunity to raise awareness of the health, social and economic harms. This is why we recommend that packaging and labelling must be designed by governments and health professionals — not cannabis producers and distributors, or those with a financial or conflict of interest.
Finally, we believe that with the legalization of cannabis on the horizon, the need for two systems is significantly reduced. Once legalized, cannabis will be available for those who wish to use it — either with or without medical authorization. We therefore recommend only one regime for both medical and non-medical use. Should the government decide to maintain two separate systems, we agree with the amendment made by the House of Commons that the legislation be reviewed within three years. Criteria for evaluation should include the number of users in the medical system and the number of physicians authorizing medical cannabis use. The CMA welcomes the opportunity to be involved in the determination of such criteria and evaluation process.
In conclusion, the use of cannabis is linked to health risks. Legalizing cannabis won’t change the risks. In fact, legalization without strict regulation and public health education may lead to adverse outcomes for youth and adults who underestimate the consequences of cannabis consumption. The government has a responsibility to the public; its focus should therefore be first and foremost on protecting Canadians — especially young people — and reducing harms to health.
Thank you. Dr. Blackmer, our vice-president, and I are available to answer any questions you may have.
[English]
Karey Shuhendler, Program Lead, Public Policy, Canadian Nurses Association: Good afternoon, Mr. Chair and members of the committee. My name is Karey Shuhendler, and I am a registered nurse and program lead for public policy at the Canadian Nurses Association, the national professional voice of more than 139,000 registered nurses and nurse practitioners. I am pleased to be here today with Professor Lynda Balneaves, registered nurse and medical and non-medical cannabis researcher, who will be able to answer questions that may be more technical in nature.
At the outset, I would like to thank the committee for studying this important issue and for inviting CNA to provide its recommendations. CNA supports the passing of this bill and believes that, upon removal of cannabis from the list of controlled substances, adopting a legal framework is an excellent option for addressing the potential health and social harms of non-medical cannabis.
In addition, while we recognize that Bill C-45 is largely focused on the recreational use of cannabis, there are opportunities to ensure that the legislation does not inadvertently negatively impact access to medical cannabis.
CNA has provided several recommendations for amending the proposed legislation, all of which are outlined in our brief that will be submitted before the May 4 deadline. We encourage the committee to include all of CNA’s recommendations in your final report, including those related to the promotion and sale of cannabis and cannabis accessories, with considerations around promotion and use related to alcohol.
Cannabis should not be treated the same as alcohol. Harms of alcohol use and current alcohol policy can be downplayed at times and should not necessarily serve as the model for cannabis policy simply because it is a process that’s already established. Additionally, cannabis is different in that there are therapeutic indications and particular formulations for medical use.
Today, we’d like to focus on two of our recommendations, namely those related to medical cannabis and to youth criminal penalties.
Our first recommendation is to emphasize the need to exempt medical cannabis from the application of clauses 8 and 9 of the bill so as to effectively maintain a separate regime for medical cannabis.
CNA supports the need to preserve access to cannabis for medical purposes based on the principles of access and equity. This includes access to appropriate products, access without undue financial burden and access to care and clinical oversight for persons using medical cannabis. Without such clinical oversight, we’re essentially leaving patients to self-medicate and figure it out on their own.
CNA believes the intent of clauses 8 and 9 is to govern the use of non-medical cannabis. However, the impact of those provisions on users of medical cannabis has the very real potential of limiting access to a substance that could alleviate serious medical symptoms.
As per recommendations set forth to the Senate Committee on Legal and Constitutional Affairs by the Canadian Nurses Protective Society, clauses 8 and 9 of Bill C-45, if accepted as written, impose limits on individual possession and distribution that can have significant negative impact on both the providers’ ability to authorize more than 30 grams and a patient’s ability to possess more than 30 grams.
The bill’s prohibition of possession by young persons and prohibition of providing administration to persons under the age of 18 without clear exemption for cannabis for medical purposes mean that young persons 12 to 17 years of age would not be able to possess more than 5 grams or that a health care professional, including nurses and nurse practitioners, may be in contravention of the law if they authorize or administer medical cannabis to persons under 18 years of age.
Exempting medical cannabis from the application of clauses 8 and 9 of Bill C-45 is necessary not only to preserve appropriate access within a separate medical cannabis regime but to protect clinicians including nurses and nurse practitioners from liability.
Our second recommendation is specific to youth criminal penalties. Apart from the undue limitations that it may place on access to young persons to cannabis for medical purposes, proposed section 8 and related subsections state that a young person (aged 12 to 17) who possesses cannabis of one or more classes of cannabis the total amount of which, as determined in accordance with schedule 3, is equivalent to more than 5 grams of dried cannabis, is guilty of an indictable offence and would be liable and/or guilty of an offence punishable on summary conviction and is liable under the Youth Criminal Justice Act.
For youth, particularly those from marginalized or racialized groups, a criminal record can lend itself to considerable social harms. It can be a barrier to volunteer opportunities, which are often required by school curriculums. It can be a factor in scholarship decisions. It can also reduce career opportunities and contribute to poverty and poorer health outcomes. Given the evidence that 21 per cent of 15- to 19-year-olds in Canada have used cannabis in the past year, such legislation could potentially impact a large number of youth.
Alternatives to a traditional punitive approach to addressing both minor crime as well as problematic substance use have demonstrated success. Examples such as drug courts, which use restorative justice as a guiding principle, offer an alternative to traditional criminal justice processes. These models allow full engagement and accountability of the offender and help to address the broader range of contributing issues, such as poverty and health or social justice issues, which may have brought the person to commit the offence in the first place.
Consider a 15-year-old struggling with problematic cannabis use caught possessing more than five grams. He uses non-medical cannabis to self-medicate for undiagnosed anxiety and depression, which may be exacerbated by the stress associated with living in poverty. Would criminalizing possession or even a significant fine help this teen, or would he be better served through a drug court system with a restorative justice approach where the teen can be accountable in his own healing, provided with opportunities to link with health and social service organizations that can address the root causes of poverty and offer treatment services to address undiagnosed mental health and substance-use issues?
With this in mind, CNA recommends that youth possession of cannabis not be subject to criminal penalties, that the government use a restorative justice approach as the guiding principle for addressing youth possession and that such depenalization eliminate current or future repercussions for youth by removing the provision under proposed section 8 and related subsections of the cannabis act.
I would like to close by emphasizing that the legalization of cannabis is an excellent opportunity to reduce harms associated with both non-medical use and the illicit market, but we must get this right. We must ensure the legislation strikes the right balance of protecting the health of public with appropriate safeguards, while continuing to support access to medical cannabis.
CNA encourages the members of this esteemed committee to incorporate all of the amendments that we will put forward. Please include them in your final report on this important piece of legislation. Thank you.
Dr. Philip Tibbo, representative, Professor, Department of Psychiatry, Dalhousie University: Good afternoon. Just as a further introduction, I am a psychiatrist and mental health researcher from Nova Scotia. I’m the director of the Nova Scotia Early Psychosis Program at the Nova Scotia Health Authority, as well as a professor, and the Dr. Paul Janssen Chair in Psychotic Disorders, which is an endowed research chair position at Dalhousie University. I’m also currently the president of the Canadian Consortium for Early Intervention in Psychosis.
I’m pleased to be here today on behalf of the Canadian Psychiatric Association, which is the voluntary professional association for Canada’s 4600 psychiatrists and over 900 psychiatric residents. Important to this discussion today, the CPA is an evidence-based profession advocating for policies that allow for the best possible mental wellness for Canadians.
I would like to begin by thanking you on behalf of the CPA for the care and diligence this committee has exercised in fulfilling its duty to address many of the health issues contained in Bill C-45. The legalization of cannabis is indeed a complex undertaking involving a multitude of social, medical, economic and legal considerations.
With clinical research colleagues, I was privileged to write the CPA position statement entitled “Implications of Cannabis Legalization on Youth and Young Adults.” The CPA stands by its original position on the subject and strongly urges the committee to consider the mental health implications of cannabis consumption on youth and young adults in its review of Bill C-45.
Our 2017 position statement on the issue is supported and endorsed by the Canadian Academy of Child and Adolescent Psychiatry, The Canadian Academy of Geriatric Psychiatry, the Canadian Academy of Psychiatry and the Law and the Canadian Academy of Psychosomatic Medicine.
As you have heard, as it has been mentioned before, cannabis is the most commonly used currently illicit drug among Canadian youth, and Canadian youth are among the top users of cannabis in the developed world. While there are variations by jurisdictions, approximately 22 per cent of youth aged 15 to 19, and 26 per cent of young adults between 20 and 24, report using cannabis during the past year. However, in this group, 20 to 30 per cent report using daily or almost daily.
Bill C-45 will make 18 the legal age of use, purchase and possession of cannabis. While individual provinces have been allowed to set higher age limits, most are saying age restrictions for cannabis use will correspond to those already set for alcohol.
Canadian psychiatrists know that there is a strong evidence base showing that early and regular cannabis use can affect aspects of cognition, such as memory, attention and the ability to process thoughts and experiences. This in turn has implications on educational and occupational outcomes.
There is also substantial evidence for an association between early and regular use and the development of schizophrenia and other psychosis. There is currently moderate evidence of an association with depression, anxiety and bipolar disorder, as well as substance use disorders.
Research has shown, as has been brought up within this committee, that the human brain continues to develop until we are about in our mid-20s, and you have often heard the age of 25 being used. This process includes reorganizations, refinements and functional improvements. It is driven by changes in the brain’s gray matter due to synaptic pruning, which is the elimination of underutilized or unnecessary neural connections, as well as changes in white matter due to myelination, which allows for the fine-tuning of connections between different parts of the brain. Our human endogenous endocannabinoid system plays a role in this brain maturation, and therefore external cannabinoids can affect this process directly in a negative way.
For these reasons, the CPA continues to maintain that Canadians should not be legally allowed to use cannabis until the age of 21 and that legislation should restrict the quantity and potency of the drug until they are 25. Cannabis with high tetrahydrocannabinol, or THC, content can result in significantly worse mental health and cognitive outcomes. We have seen the THC content of cannabis rise over the years from about 1.5 per cent in the 1970s, 3 per cent in the 1980s, 14 per cent by 2010, with current estimates today of 28 per cent or higher. An increase in the incidence of psychosis onset is attributable to the rise in THC in regions where high potency cannabis is more prevalent.
We are pleased that Bill C-45 includes a commitment to public mental health education, targeting youth and young adults, around the effects early cannabis use can have on brain development. The CPA wants to underline its willingness to work with the government on critical components of the legislation related to research, public education and harm reduction.
In summary, the CPA recommends, from an evidence-based lens, that due to critical brain maturational processes in youth and young adults that can be affected by cannabis, in addition to the associations between early and regular cannabis use and negative mental and cognitive health outcomes, that Canadians should not be legally able to use cannabis until the age of 21.
As well, legislation should restrict the quantity and the potency of cannabis for those under the age of 25. Cannabis with high THC content does have significantly worse mental health outcomes.
Legislation should also address the need for public education targeting and resonating with youth and young adults around the effects early and regular cannabis use can have on brain development and subsequent cognitive and mental health.
Government should consider funding significant further research to better understand the impacts of cannabis on mental health, as well as its legalization on the mental health of Canadians. Support should be expanded for prevention, early identification and, importantly, cannabis cessation treatments within the framework of mental health and addictions.
As we’ve heard previously, legislation should be explicit and prudent with its advertising and marketing guidelines, including those clear markings of THC content as well as consistent public health warning messaging.
Thank you for the opportunity to appear before the committee on this important issue and, of course, I would be happy to answer any questions following.
Dr. Robert Milin, Representative, Head, Division of Addiction & Mental Health, Associate Professor, University of Ottawa, Canadian Academy of Child and Adolescent Psychiatry: Apart from being the clinical head for the adolescent day treatment unit, I am also the head of the division of addiction and mental health for the University of Ottawa and an associate professor at the University of Ottawa department of psychiatry.
I speak to you as a representative from the Canadian Academy of Child and Adolescent Psychiatry. We don’t have an official position paper on this, so these are essentially talking points, and I hope not to repeat my esteemed colleagues here and their important information.
We have to stipulate that this is a complex matter. There may not be right or wrong here, and we may be deciding how do we best approach it, recognizing that we may need to revisit the way we do something.
We are well aware of the adverse effects of marijuana use in adolescence. This is well established and not an issue to be discussed much, to be honest with you. It is overwhelming evidence. Even back when I started my residency as an addiction psychiatrist in the 1990s, we had very good evidence about its impact. In those days, we called it substance use, but it was typically alcohol and marijuana.
The potential negative consequences of short and long-term use of what we determine as recreational marijuana, and we actually don’t know what that means, are well documented across multiple life domains, including impact on cognitive abilities, mental health, mental disorders and in meeting the developmental tasks and challenges of adolescence, specifically academic and vocational functioning, as well as something that has gone unsaid here, and that is contributing to the unintentional deaths and injuries amongst adolescents who drive and use marijuana.
An earlier age of onset of marijuana use increases the risk of negative outcomes, so, obviously, onset in adolescence, as you heard earlier, particularly before the age of 16. However, it is still a risk factor as you move forward, up to at least age 21, including development of substance-use disorders other than cannabis, psychotic illness and other mental disorders. Marijuana use negatively impacts response to treatment of mental disorders in adolescents, as well as adults. Cannabis is not a benign substance, especially for vulnerable populations such as youth, children and adolescents.
We must remember that legalization of cannabis may very likely increase the already high prevalence of marijuana use by adolescents in Canada. You’ve already heard about those statistics. Drug-use disorders are actually more common than alcohol-use disorders in adolescents, based on U.S. statistics. This is because of the over-representation of cannabis-use disorder in adolescents and young adults. It is, in many respects, a unique drug of misuse for adolescents and young adults. We don’t exactly understand why, but we recognize that that’s what is really happening.
There are no definitions for recreational or safe use of marijuana, unlike for alcohol. We have well-established guidelines that tell us how much you can drink a day if you are a man or woman, how much is excessive drinking and what binge drinking is. These are well established, and we have other markers that we can look at. Continued regular, recreational use of marijuana — regular use simply means once a week — has the increased likelihood of impairing one’s ability to meet one’s potential. So we must indicate that, if you continue to use marijuana, your potential, as a person using marijuana, may be impaired. There are enough longitudinal and epidemiology studies that tell us that. As a group. That does not mean that a particular individual may not become a rock star.
We are aware that preference and regular daily use of marijuana are key markers for the risk of developing a cannabis-use disorder in adolescence and through young adulthood.
There are no evidence-based indications for the medical use of marijuana for mental disorders — that’s a policy statement of the American Psychiatric Association, which I have the privilege of participating in — and even more so in a developing adolescent and young adult, especially with respect to recreational marijuana use.
That does not mean that cannabis or cannabinoids do not have potential medical benefits. We have to study that. All drugs of abuse or misuse have medical or medicinal benefits. Thank God we have opioids for when we have an operation. It is the issue of how we control that potential for misuse.
The legalization of marijuana use will result in a very large business. This is a monster of a business economy-wise. Their push and slant on this issue will have an impact on potency. We know that from California studies, where assessment of medicinal marijuana has increased over time with the increase in THC because you come back because you get a euphoric effect. That’s why the guy next to him has a little higher dose. They go to him; he notices that. It’s a business. Advertisement, payment and even research must be recognized in its influence of the industry.
A consistent message of potential harm must be conveyed, especially for vulnerable populations like children and adolescents, and there must be close monitoring of the cannabis industry.
Laws governing cannabis use should mirror those of alcohol. They are very similar kinds of substances. You don’t want to rob Peter to pay Paul, so, if you’re indicating that, somehow, marijuana is less harmful than alcohol, there is no evidence to support this kind of conjecture.
So the question comes down to: How do you address this issue? How do you manage something like this? Is it legal for a minor to possess alcohol? Then, is it legal for a minor to possess marijuana for recreational use? That’s a complex question. I don’t have the answer for you. That’s why you guys are here, right? We may have to revisit it because we recognize that there are social determinants, but we have to also look at how many people are actually being charged for minor possession.
I thank you. We still have a lot to learn about marijuana and marijuana use over our lifespan.
The Chair: Let me ask one thing of you before I go to my colleagues, Dr. Milin. You’re the only one who hasn’t mentioned age. Did you have an age suggestion?
Dr. Milin: I have an age that I’d like. Do I have a practical age?
The Chair: A legal age for consuming.
Dr. Milin: The Canadian academy hasn’t set a particular legal age. We feel it should be similar to alcohol. We believe, with the CPA, that it should be 21. We agree with them. I was an expert on the council when they did the thing, and I said the same thing, that from a practical point of view, you cannot divorce it and set it at 16. You’re setting a different age. I, personally, would say that at least 19 would be the minimum age, the very minimum.
The Chair: Thank you very much. Members of the committee, given the time that we have left, let’s go with the usual five minutes. We have six people at the end of the table, though, and four organizations, so please direct your question, because if you ask one question of everybody, that’s going to be it.
Senator Seidman: Thank you all very much for your presentations.
My question will be for Dr. Marcoux. Yesterday, we heard testimony from the Non-Smokers’ Rights Association about gaps in the existing proposal for packaging and labelling of cannabis products. They raised a number of important issues highlighting some of the ways in which planned regulatory requirements for marijuana will be more lenient than existing standards for tobacco. In that vein, I’d like to ask you about two submissions that the CMA has made. One submission was to the government’s task force, and the other submission was, most recently, to Health Canada’s consultation on the proposed approach to regulation of cannabis.
In your submission, you have, on page 9 — this would be the submission to the task force — section 1, recommendations: “The CMA recommends that the federal government prohibit the marketing and advertising of marijuana and that packaging requirements include plain packaging, potency labelling and health warnings.” So you are saying prohibit — that’s definitive — the marketing and advertising of marijuana. The second point you make is: “The CMA further recommends that the federal government prohibit flavouring and shapes.” You have made two very definitive statements about how cannabis should be treated. I’d like to hear what you have to say, what your concerns are, about this situation in the current legislation.
[Translation]
Dr. Marcoux: Of course the words “prohibit” and “défendre” are very strong. As physicians, we have a duty to protect the health of the public, as our mission requires. That’s why I think adding flavours to marijuana in addition to how appealing it already is to young people, may well invite them to use it. We do not want that.
Our everyday experience in our offices shows that this product has negative effects on young people. Often, this causes them difficulties in life, ranging from psychosis to other insidious difficulties, such as lack of motivation. We feel that more studies are needed on the success rate of youth who use marijuana because not everyone will be successful in life. If they lose motivation, they face significant obstacles.
I don’t think a product like this should be advertised; it would be fooling all those young people who hear adults say that they have to take it, while studies show that it is harmful for them. And it would be crossing the line if flavours are added.
Dr. Blackmer, do you have anything to add?
[English]
Dr. Jeff Blackmer, Vice-President, Medical Professionalism, Canadian Medical Association: We need to learn from the experience with tobacco. We know very well that the tobacco manufacturers add flavours or they add things to packaging or make products slightly different to make them more attractive to youth. That’s our concern. When we are talking about shapes, you may have heard about the example of gummy cannabis. In some states where it has been legalized, people have left it out and children have been taking a handful of gummy cannabis and showing up in the emergency department with overdoses. It is really to prevent those types of occurrences and to learn from our experience with what the tobacco industry has done to try to entice youth to use their products.
Senator Seidman: We heard testimony in our previous panel to this same extent about prohibiting any marketing at all because there are so many dangers. You’re confirming that from the CMA’s perspective. I believe the tobacco regulations are very clear on flavours, but there is no mention in the cannabis legislation about prohibiting flavours and shapes. This is a concern.
Mr. Blackmer: That’s something we would like to see happen.
Senator Seidman: This question is for Dr. Tibbo. Your association supports restrictions on THC potency for those between ages 21 and 25, as you’ve described to us. It’s a pretty important thing about regulating THC, especially for developing brains, as you presented to us.
Does it concern you that, so far, the government has articulated no plans to limit THC potency other than cannabis oil? They proposed limitations on cannabis oil. Would it be preferable to regulate THC potency for all cannabis products to better support harm reduction for all users?
Dr. Tibbo: That’s a great question. The CPA does believe there should be regulation of the potency of the product. I believe the current legislation is recommending labelling the THC content in packaging but without putting strong limits on the potency of the product. Based on the evidence that we have with the higher potency products causing more negative outcomes, it’s important from our perspective with mental health that it should be regulated. What percentage that is, we are not entirely sure, but we do see within the current cannabis market now products with greater than 30 per cent THC. It should be definitely below 20 per cent, but I can’t give you a definitive number at this time because we don’t have a lot of that research. However, it should be regulated, yes.
Senator Petitclerc: Senator Seidman has asked one of my questions, so that’s a good thing.
My next question will be again for Dr. Tibbo. I’m continuing with that because I’m really concerned about that age group of 21 to 25. Everybody agrees that the young adult remains vulnerable until 25, and yet everybody seems to also have a bit of pragmatic consensus that the limit age will be lower than 25 — that is, 18, 19 or 21.
How do we protect that more vulnerable group? You have one suggestion, but do you think — and maybe others can answer — that we also have to protect them in terms of education and awareness; that is, group-specific awareness and education? In your knowledge, has it been done for that specific group, or should it be a specific message on the packaging? Do you have any thoughts on that?
Dr. Tibbo: That’s a great question. I think we have to approach this on multiple layers. We should look at regulating THC content or THC-CBD ratios within that particular product for those in that vulnerable age group, but it has to be supplemented with targeted education. One thing I mentioned in my notes is that education has to resonate with that particular age group and demographic, as well as the different populations that exist within our country. These are all important ways that we have to address this and allow for that protection to happen.
We have done some knowledge translation activities within our province that involved looking at focus groups both younger and older than 20 years of age. Definitely those over 20 have clearly solidified ideas about cannabis and a lot of them around the myths of cannabis that exist as well. Even by targeting much younger age groups, we are going to be helping them as they move through that age of risk of early 20s to mid-20s.
Senator Petitclerc: Thank you so much. Maybe I can have a quick clarification from Dr. Milin, because you mentioned something that I didn’t know. Right now, there are no existing guidelines about what is safe use. With alcohol, for example, we all know the guidelines. I want to clarify whether we don’t have the data, or we haven’t done the work, or if it’s impossible to do it.
Dr. Milin: It’s not impossible to do it. We haven’t done the work or calculated the work. We haven’t done those kinds of studies to start measuring it. To be honest, in some ways, the legalization will make that much easier to do because now you will be able to capture that population very easily. That’s why I often said you may have to revisit this, just like they did in the states.
One of the most successful things, if you ask people at NIAAA in the United States, is we raised alcohol use rates to 21. People ask how did that work. They actually consider it one of the most successful federal initiatives because it reduced the death rate by car accidents as well as on other issues. Did it get it out of all the colleges? Of course not, but it got it right out of high schools.
Senator Petitclerc: So it is possible to get those guidelines?
Dr. Milin: You would have to do the research. Some researchers in Europe have recommendations around the starting point. In Europe, they have recommendations where they use it in certain studies where they will say no more than twice a week or two days a week and no more than 1 gram a week.
Lynda Balneaves, Registered Nurse and Medical and Non-Medical Cannabis Researcher, Canadian Nurses Association: I wanted to present a slightly different perspective and one of reasons why the Canadian Nurses Association is sticking with 18 years as being minimal guidelines.
As has been mentioned, our youth and young adults are the highest users of cannabis. In order for them to actually have the exposure to public education that’s needed, and for a regulated supply where the concentration of the product they are using is actually known, that is one of reasons that we are encouraging that we stick to 18 years. Otherwise, those who are ages 18 to 21 will be accessing from an illicit market a substance of unknown quality. They may not know the potency of what they are using. We are also seeing a new phenomenon, where young adults and youth are concentrating cannabis they are receiving to even higher potencies, and that is the 30 or 40 per cent that was mentioned. If you restrict potency, we will continue to see this dangerous behaviour. However, if you have a range of potencies within a regulated market, the young adults and youth will have knowledge of what they are using and not exposing themselves to the harm of developing concentrates on their own.
Senator Galvez: Thank you very much for this clear, pragmatic and factual description of your position and opinions. I have observed the same thing as you. I am a professor in engineering. In the last years, I have observed an increase in the consumption of cannabis and an increase in the dropout rate of studies, so I know what you are talking about when it makes a major disturbance in the life of a young person.
My question concerns the mix of drugs, alcohol and cannabis, and the treatment of the addiction. I have taken students to psychiatric emergency because they have had a bad trip and a psychotic event. Doctors were very clear to say that there was an addiction and that there was not clear treatment for treating this addiction.
Now, in the schools, when you have an addition, it is considered as a handicap and you have to have accommodations in the schools. Therefore, it becomes an increased burden in the school system to accommodate for special needs, for course evaluations, et cetera.
What do you think is going to happen with this in the future?
[Translation]
Dr. Marcoux: My answer won’t be as scientific as that of Dr. Tibbo, who is a psychiatrist and sees these people regularly. We certainly know that this has harmful effects for young people. Of our 85,000 members, not everyone is a front-line worker, but the vast majority of those who see this type of patient have seen these negative effects, and that is why we are so worried and are speaking on their behalf.
I will let Dr. Tibbo talk about the effects of cannabis when combined with alcohol, something that is more related to his specialization. So if you don’t mind, Dr. Tibbo, I’ll give you the floor.
[English]
Dr. Tibbo: There are a number of different things within your comments and questions to address.
One thing to focus on with respect to our current treatments is that there are some out there with respect to cannabis cessation and addictions within the area of motivational interviewing and cognitive behavioural therapy but, to be honest, we don’t have a lot of successful treatments at this point in time mainly because we haven’t had the ability to do the research. This is the unfortunate place we are now at with legalization. This will be coming up, but we as psychiatrists in mental health don’t have the tools yet to really deal with the addictions angle of things.
I did a national survey with all our early intervention programs for psychosis across Canada a couple of years ago, which was published, and the majority of them — 80 to 85 per cent — had more of a passive approach to treating the addictions because that’s all that’s available.
With respect to this, this is why I mention within our points that we have to have more resources to look at how we treat these illnesses and the addictions, both to cannabis alone but also cannabis with other addictions. The alcohol-cannabis addiction is not uncommon. You mentioned as a professor in university that the most common substances in universities are alcohol and cannabis. Again, we don’t have a whole lot of research on that. Obviously, where a lot of research has come out is with respect to the effects on driving and with respect to fatalities with that link.
Dr. Milin: I hate to disagree with my esteemed colleague. We actually have excellent treatments for addictions. I am an addiction psychiatrist. That’s what I do with a good part of my other life. We have very good treatment. We don’t have good pharmacotherapy treatments, but that’s different. There are excellent psychosocial treatments. They mirror outcomes for treatment of chronic illnesses like diabetes and high blood pressure in terms of effectiveness. Many studies have been done. The Lancet, JAMA and the New England Journal of Medicine have published looking at these, not just recently but even before, and obviously with the addition of treatment of concurrent disorders. So we have pretty good treatment. We don’t have a lot of treatment available, so there is the difference. Treatments are there. We don’t have a lot that are available for access.
Ms. Balneaves: I am not discounting your experience as a professor. As a professor myself, I do see students with problematic use. However, it’s important to recognize that as we watch Colorado and Washington and we’re starting to get data from those jurisdictions, we’re not seeing at this time, through population-based surveys, an increase in use in youth and young adults. In some surveys, we’re actually seeing a slight reduction in cannabis use, which may reflect the public education campaign that is ongoing in those jurisdictions.
Senator Omidvar: My question is to the Canadian Nurses Association. I’m referring to your brief and comments on pages six and nine about the impact of criminalization on youth, in particular those youth from marginalized and racialized communities. I appreciate your comments here. You talk about not using the criminal justice system but thinking about restorative justice. Could you expand on that idea a little bit more?
Ms. Shuhendler: Thank you, senator. Absolutely. When we look at options for how to address youth who may be caught with cannabis that may be in contravention of an amount that’s in the act, we’re absolutely saying that criminal penalties would cause more social harm and disadvantage.
We even believe that going the route of a significant fine would still not have the same effect. A significant fine for under-served and impoverished populations could disproportionately impact that individual. They may not be able to pay that fine and it could result in an additional fine, which could result in involvement in the court system.
We look at the restorative justice approach, using examples of drug courts in Toronto and Nova Scotia where the individuals are really involved. They’re part of the decision-making process to come to terms with what the appropriate restitution should be for breaking the law. They’re involved in that communication and relationship building, and they’re also integrated into a system where they can access social services that may help to alleviate, as we said, some of the causes and things that brought them to have committed this crime. They can also access health services that may be essential that they might not otherwise have access to if they’re fed into a criminal justice system.
Senator Omidvar: The nurses and the doctors seem to have a diversity of opinion on a number of things outside age. Let’s just accept that as a diversity. Would you agree with Dr. Marcoux that the medical and non-medical regimes should be merged? You have a recommendation here about clauses 8 and 9 related to access issues.
Ms. Shuhendler: I did want to take the opportunity to say we agree with recommendations around harm reduction. That’s something we based a lot of our work on, and recommendations around public education. Those are huge.
We do have a divergence of opinions. In terms of the medical system, CNA supports that it should stay in place on the principles of access and equity for three key reasons.
One is access to products. We expect that in a consumer-driven, recreational and non-medical model, those products would likely have higher THC concentrations and be more psychoactive than something someone may require for medical purposes. So the product availability is likely to change if we have one system.
The other thing is there are undue financial barriers put on patients if we have one system. Products may no longer be covered by insurance companies, which is problematic for individuals.
Then also, as we put forward in our response to the consultation from Finance Canada, there is a proposition at the moment to include medical cannabis in the excise tax. We’re recommending that medicine not be taxed, and that could also help to remove undue financial stress.
Most important is access to medical and clinical oversight, including care by nurse practitioners who are able to authorize medical cannabis. We believe this to be an essential way for patients to continue to have those conversations about their health, assess therapeutic effect, speak about drug interactions and be involved in the circle of care and not have to access cannabis next to the local liquor store.
Ms. Balneaves: As someone who has done research with medical cannabis patients for the last 10 to 15 years, there is a great deal of stigma around the use of cannabis. If the only source for them is through the recreational market, they may experience even greater stigma beyond perhaps the health conditions or disabilities they’re living with.
Senator Omidvar: I want to follow up on that. We have heard that Bill C-45 will normalize the consumption and sale of cannabis to some extent. Would you not think that stigma would, in time, decrease?
Ms. Balneaves: You would hope so. I think research will be imperative to understand how society's framing of cannabis use will shift. However, we have been under prohibition for many years, and I believe that there are some very well-grained attitudes towards cannabis. For someone who has worked with people at end of life, experiencing that stigma, receiving inappropriate education related to substance use may not be the most appropriate venue for them.
Senator Poirier: Thank you all for being here and for your presentations. Some of my questions have been addressed, which is good, because it leaves me time for maybe some others.
My first question is for Dr. Milin. From what I understood, you have done some important research that found that cannabis use by people in their late teens is linked to an increase of risk, specifically in the users of a higher dosage. Do you believe the health risk to teenagers between 18 and 25 may have been downplayed a bit in this discussion?
Dr. Milin: I think so. We know from studies recently that this tends to be the area of highest growth and cannabis use disorders was in that age group of 18 to 21, college-age kids or university-age kids, depending on your source. We know that it has changed.
We also know that’s also the age with a likelihood of the onset of many substance use disorders. The likelihood of someone developing a cannabis use disorder who has never really tried cannabis before the age of 30 is almost zero. It probably is. It is a disorder of youth or young adults. Most substance use disorders are. That’s their age of onset. Cannabis has shifted a little younger than other harder drugs and even alcohol.
Senator Poirier: Based on that, would it be better to raise the minimum age a little bit higher than 18 for the consumption?
Dr. Milin: I personally think it should be 19 at minimum, but I understand the significant issues that you have if you have alcohol at 18 and marijuana at 19. How they bring that together, I don’t know. Is one year going to make that much difference? I can’t tell you that, but I can tell you that if you’re trying to bring it out of the most vulnerable, you’re looking at least at 19 years of age.
Senator Poirier: Thank you.
Dr. Milin: I agree with our CPA colleagues about 21 in an ideal world, just like alcohol should be 21 in an ideal world.
Senator Poirier: I think I heard you say in response to one of my colleagues that we do not have the tools and resources to treat the addictions now as you would like to be able to. We hear you saying that. We’ve heard rumours out there, depending on who you’re talking to. The RCMP doesn’t seem to be completely ready and trained to be able to detect who is under the influence. We’ve heard from municipalities that say they’re not sure how ready they are to have this in their community and how they’re going to monitor. We’ve heard from the RCMP and other people that they’re not going to be able to monitor if you have four or ten plants at home. Knowing all of that, are we ready for this legislation, or should we be doing a little bit more research and get ready for it before we put it out there and be proactive instead of reactive?
Dr. Tibbo: That is a really easy question. There is a balance to that. We are at this unique position where we haven’t been able to research things to the degree we want to research up to this point because cannabis was illegal. So that actually was a barrier to research. With legalization, we can actually proceed with some better research and more research, which is needed.
With respect to readiness, as we mentioned, there are treatments for cannabis addictions. Is it available and are people trained across the country in both urban and rural locations? Not at this date. If you ask me today whether we are ready to deal with cannabis abuse and dependence from a treatment angle, no, we’re not ready at this point. There has to be a lot of capacity building and also some research as to what are good treatment options.
It is a balance. We need to have some of the legalization there to be able to move the research forward. Could we delay? At what point do we delay and at what point do we say we have enough information to move forward? Because at this point, we have about 30 years' worth of research on cannabis, and we’re having this discussion at this point in time.
Ms. Shuhendler: I would agree. Legalization is important to improve access to research. By doing public education, that can help to reduce potential health harms, and legalization, as we had said before, can significantly reduce the social harms associated with a prohibition model, which we know does not work.
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Senator Mégie: I would like to hear Dr. Marcoux talk to us about the fact that the CMA proposed a single regulatory system for medical cannabis and recreational cannabis. I listened to the nurses’ opinion. What are the advantages of a single system, and do you have any reservations about that?
Dr. Marcoux: First, we are not out of step with the nurses. There is a long history of working with nurses, but perhaps we have different standpoints because of our professional cultures.
Physicians have always been responsible for prescribing; we are the ones who issue the prescription. I usually say that writing a prescription isn’t a recommendation from the neighbour. This prescription involves the physician’s responsibility. When we prescribe something, to actualize this responsibility, we refer to the medical evidence, that is, factual medicine.
How can we do this for a product — I won’t call it a medication, because it’s not a medication — on which there are very few studies, no double-blind studies, no knowledge of its interaction with other drugs that are prescribed to our patients and no indication in relation to our patient’s illness? Would we write a prescription for someone who wants to treat shoulder pain but at the same time has type 2 diabetes?
I don’t know how cannabis interacts with type 2 diabetes medications or diabetes itself if someone takes this product — which is not a medication — on a continuous basis. Lengthy studies are done before a drug is approved, and we rely on them when we issue prescriptions. That is why we say that if people think they need such a product, they can draw from a single supply source. Over time, if it becomes a medication, yes, we will make it a double prescription.
Maybe my colleague has something to add, from a point of view other than prescriptions.
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Dr. Blackmer: Dr. Marcoux covered a number of the really important points. We’re not in competition here, but it’s important to recognize that it really is the medical profession that’s been tasked with determining who qualifies and who doesn’t based on no scientific evidence. There is a small handful of nurse practitioners but 10,000 physicians. We’re really the ones with the frontline experience.
The arguments I heard for sustaining a medical system today and previously really don’t hold water. The idea that you need it for insurance, that’s not true. People get insurance coverage for non-prescription products. The idea of stigma doesn’t make sense because you will still be able to get it by mail order, as you can today, so there is no stigmatization. There are some important considerations, but I haven’t heard any arguments that have convinced me that there is a scientific or social or societal reason to maintain two separate systems, but a lot of arguments as to why it would make sense to collapse it into one system.
Ms. Shuhendler: I'm glad Dr. Blackmer acknowledged that it is not just physicians but also nurse practitioners who are able to authorize medical cannabis.
Ms. Balneaves: Physicians, nurse practitioners and nurses all have an essential role in supporting patients in making informed treatment decisions, even when we have imperfect evidence.
There is a growing body of evidence related to cannabis and cannabinoids. Some are the whole plant and some are the pharmaceutical forms of cannabis, things like Sativex and Cesamet. I think it’s essential that patients are able to feel comfortable going to their primary care provider or their specialist to receive the latest evidence related to the medical use of cannabis.
I feel that if we restrict them to one system where they may, in some municipalities, have to access cannabis — yes, they can go through mail order, but there are always complications in terms of receiving things through the mail. If people then need to go to a municipality where alcohol is also being sold, it will not be an environment where they’re going to receive the best education and have the privacy to have that informed support.
Also, I think it’s important to recognize that in order for our licensed producers to have the motivation to do the development that’s needed in creating specific products for the medical market — for example, high CBD strains that are not psychoactive — that will only happen if we maintain a separate medical system that has an actual consumer base to it. Otherwise, the focus is going to very much shift towards high THC, focused on receiving a psychoactive effect in a recreational sense.
Senator Martin: I’m not a regular member, but I have this opportunity today. I’m happy to have heard from most of you, not all. I apologize; I missed some of the presentations.
I have a follow-up question to what Senator Poirier asked about whether we are ready. I struggle about the need for legalization, for many of the reasons you’ve cited, but the lack of readiness that we are hearing about from so many different places, including municipalities. There is a municipality in my province that recently adopted a motion to say that even after legalization, until they see the exact regulations, they’re not going to let anything happen in their city. I’m not sure how they’re going to enforce that because of the fact that it will be legal, but it’s a bylaw. So it’s going to be very complicated.
In terms of legalization, if we are doing it right, when will be the best time? I know there is so much more to prepare, but we’re hearing that we’re not ready. Should we at least wait for certain essential elements to be prepared in order for this actual implementation to be more successful? I feel like we’re putting people more in harm’s way because of the lack of readiness. We know it’s something we have to seriously look at for the sake of Canadians, but perhaps it should be a longer time period for the implementation to happen. In Colorado and Washington, we heard on average at least a year to 18 months. Based on your knowledge and what you’re hearing, what would you advise in terms of how long before implementation happens? Because I just don’t think we’re ready. Perhaps I’ll ask Dr. Tibbo to start.
Dr. Tibbo: I tried to look away when you were asking that question. It is a great question. It’s very difficult to put a particular timeline on that because there are certain elements, for example, from the CPA perspective, which I speak to, and mental health and psychiatry, that we feel need to be fleshed out more, or more in place. I already commented on the need for that capacity building and the development of cannabis cessation and treatment programs, not only for the general population but for a specific group — for example, for individuals who already have psychosis, which is a different type of approach than you would perhaps have with the general population. Those elements are lacking as well.
I know that within our mental health field in Canada, we’re also lacking the ability to track data nationally. One thing I’ve been trying to spearhead in our early intervention programs nationally is to develop that database or platform where we can start collecting some of this data as we move forward. We haven’t yet been able to secure funds to do things like that.
These are some of the preparatory things that would be needed, from my perspective. The length of time it would take, it’s difficult to put a number to.
Senator Martin: Would this fall be a reasonable time frame, considering the complex system in which this needs to be rolled out in order to ensure the safety of our youth and the readiness of Canadians to have this be legal?
Dr. Tibbo: I can speak to the two points that I just mentioned. With respect to the ability to monitor and vigilance and having that platform and database, as well as the treatment and capacity building, the fall would be too close. We wouldn’t have that in place.
Dr. Milin: From the perspective of adolescents, I think a rate-limiting issue is the ability to assess intoxication in driving. If you’re looking from a public health perspective, the most common reason is alcohol and marijuana combined together. How do you measure that kind of intoxication?
If you’re thinking from a mental health perspective, we have a lot of information that tells us certain things, and we can learn more, and that’s how you go about it. They didn’t have that information on alcohol with prohibition. They learned how much people can drink and what are the health risks and stuff like that and then went ahead. Pharmaceutical companies are already engaging cannabis companies to start developing medication that they can market and put in randomized studies so they can treat it with a degree of accuracy, and they are pharmaceutical companies that you know will be able to produce that product.
Senator Manning: Thank you to our witnesses.
All your groups represent people right across our country. It seems to me that we will only end up with a patchwork of age limits. Different provinces are allowed to create different limits. The CNA talks about 18; Dr. Milin talks about 19; your group talks about 21. We can’t get agreement among the medical professionals themselves. I’m trying to determine how we get to the position of finding an age. Personally, I think it should be the same right across the country. Whatever the age is, it should be the same right across the country. Is there any way we can have the medical professions across the country come to agreement about what that age would be? I think it would mean much to the government if we had consensus from the people that are out there providing the service. That’s my first question.
Ms. Shuhendler: Thank you for the question. I just wanted to clarify: We do speak about the age of 18. Dr. Balneaves had mentioned that. CNA does not have an official position on the age, but we approach age from a harm reduction perspective. When we look at the harms associated with use, or the social harms, we think that prohibition is not the right approach for certain ages. We support the government’s decision to look at 18 as the minimum age, and I think that alignment with provincial alcohol regulation pragmatically makes sense for people to be able to enforce things. But the reality is, as Dr. Balneaves had said as well, while we don’t have an official numeric designation, if it’s set at 21 or 25, individuals below that age are still going to be using and they’re going to be getting it from an illicit source.
We’re always willing to work together with our colleagues in other professions to have these discussions, because, of course, this is not an easy thing to come to consensus on. I’m sure we’re not the only groups you’ve heard different ages from. I’ve heard things from the Canadian Paediatric Society and other organizations. We’re willing to have those conversations, but I think it’s going to be tough to come to consensus.
Dr. Milin: The Canadian Academy of Child and Adolescent Psychiatry doesn’t have an official age. We typically defer to the CPA, who has done their work, or the CMA. We don’t reinvent the wheel. I’m discussing it from a certain perspective. If you’re looking at children and adolescents and what the issues are, it’s the same with alcohol. We prefer the idea of 19. From a developmental perspective, it makes sense because 15 to 19 is a high developmental period — that’s probably agreeable — in brain issues, but they continue to develop. However, you are also looking at removing it from high schools and then making that next step.
Dr. Blackmer: If you are asking if there is consensus in the medical profession on the age, there is, and it’s 21. We’d like to see that across the country. The CMA is the only body that represents all physicians, and you’ve heard that from our esteemed psychiatry colleagues as well. So there actually is medical consensus on that age.
Senator Manning: Impaired driving is the big issue that we are hearing, especially with the police forces across the country. We have the science now to back up alcohol and determine the level of alcohol a person has. I haven’t seen the science to back up the impairment because of drug use. Is anybody here aware of the science that addresses that, or do we just not have that complete? Dr. Tibbo?
Dr. Tibbo: I should have been looking away again. We don’t have a lot of science with respect to that. There is still some work that has to be done on that. I’ll just leave it at that.
Dr. Milin: In some ways, you can think about it like alcohol. The Breathalyzer was developed because there was a need, so, eventually, we would hope that people are working on this issue to address how we can measure effective levels of intoxication acutely.
The Chair: There is a separate bill on this matter, Bill C-46. It is before another committee, but it is dealing with it.
We’re passed our time. We have to get out of here because there is another committee coming in. I want to thank the panellists and all the others who came to help to answer questions. You’ve helped us quite a bit.
With that, committee members, we are back here at 10:30 tomorrow morning, and the meeting is adjourned.
(The committee adjourned.)