That Canadian Medical Association recommend all levels of government across Canada urgently review legislation governing all aspects of drinking water from source to consumption to ensure that comprehensive programs are in place and being properly implemented, with effective linkages to local, provincial and territorial public health officials and Ministries of Health.
That Canadian Medical Association recommend all levels of government across Canada urgently review legislation governing all aspects of drinking water from source to consumption to ensure that comprehensive programs are in place and being properly implemented, with effective linkages to local, provincial and territorial public health officials and Ministries of Health.
Text
That Canadian Medical Association recommend all levels of government across Canada urgently review legislation governing all aspects of drinking water from source to consumption to ensure that comprehensive programs are in place and being properly implemented, with effective linkages to local, provincial and territorial public health officials and Ministries of Health.
That the Canadian Medical Association examine the Health Canada's Non-Insured Health Benefits Plan's refusal to remunerate physicians for completing pre-authorization request forms.
That the Canadian Medical Association examine the Health Canada's Non-Insured Health Benefits Plan's refusal to remunerate physicians for completing pre-authorization request forms.
Text
That the Canadian Medical Association examine the Health Canada's Non-Insured Health Benefits Plan's refusal to remunerate physicians for completing pre-authorization request forms.
The Lancet Countdown on Health and Climate Change
Policy brief for Canada
1 Finding: Exposure to wildfires is increasing in Canada, with more than half of the
448,444 Canadians evacuated due to wildfires between 1980 and 2017 displaced in the
last decade.
Recommendation: Incorporate lessons learned from recent severe wildfire seasons
into a strengthened pan-Canadian emergency response approach that anticipates
increasing impacts as the climate continues to change.
Finding: The percentage of fossil fuels powering transport in Canada remains high, though
electricity and biofuels are gaining ground. Fine particulate air pollution generated by
transportation killed 1063 Canadians in 2015, resulting in a loss of economic welfare for
Canadians valued at approximately $8 billion dollars.
Recommendation: Develop provincial and territorial legislation requiring automakers to
gradually increase the annual percentage of new light-duty vehicles sold that are zero
emissions, working toward a target of 100% by 2040.
Finding: Canada has the third-highest per capita greenhouse gas emissions from healthcare in
the world, with healthcare accounting for approximately 4% of the country’s total emissions.
Recommendation: Establish a sustainable healthcare initiative that assembles experts from
research, education, clinical practice, and policy to support Canada’s healthcare sector in
reducing greenhouse gas emissions and preventing pollution-related deaths, consistent with
healthcare’s mandate to ‘do no harm’ and the timelines and goals of the Paris Agreement,
charting a course for zero-emissions healthcare by 2050.
Finding: The health of Canadians is at risk due to multiple and varied risks of climate
change, including those described in this policy brief (see Figure 1). An ongoing,
coordinated, consistent and pan-Canadian effort to track, report, and create healthy
change is required.
Recommendation: Integrate health considerations into climate-related policymaking
across sectors, including in Canada’s updated 2020 Nationally Determined Contribution
Commitments under the United Nations Framework Convention on Climate Change
(UNFCCC) process, and increase ambition to ensure Canada commits to doing its fair share
in achieving the goals of the Paris Agreement.
Introduction
Climate change is the biggest global health threat of the 21st century,1 and tackling it could be our greatest health opportunity.2
“The health of a child born today will be impacted by climate change at every stage in their life. Without significant intervention, this new era
will come to define the health of an entire generation.”3
However, another path is possible: a world that meets the ambition of the Paris Agreement and proactively adapts to protect health from the
climate impacts we cannot now avoid. This year’s briefing presents key findings and recommendations toward this path.
Key messages and recommendations
Health and climate change in Canada
Imagine an infant born today in Canada. This child enters a country warming at double the global rate, with the average temperature in
Canada having increased 1.7oC between 1948-2016.4 The North is warming even faster: areas in the Northwest Territories’ Mackenzie
Delta are now 3oC warmer than in 1948.5 Climate-related impacts on health and health systems are already being felt,6 with examples
outlined in Figure 1. By the time the child is in their twenties, in all feasible emissions scenarios, Canada will have warmed by at least
1.5oC as compared to a 1986-2005 reference period.4
Two scenarios are possible for the remainder of the child’s life.
If GHG emissions continue to rise at the current rate (a situation referred to by the Intergovernmental Panel on Climate Change (IPCC) as
the “high emissions scenario,” or ‘RCP8.5’) temperature increases in Canada will continue after 2050, reaching 6oC relative to
1986-2005 by the time the child is in their child’s sixties.4 Globally, this degree of warming places populations at a greater risk of
wildfires, extreme heat, poor air quality, and weather-related disasters. It will also lead to changes in vector-borne disease, as well as
undernutrition, conflict, and migration. These impacts and others negatively impact mental health,3 including via ecological anxiety
and grief.8 Climate change will not impact everyone equally, and can widen existing disparities in health outcomes between and within
populations, with Indigenous populations, people in low-resource settings,28 and future generations29 disproportionately affected.30 This
degree of warming has the potential to disrupt core public health infrastructure and overwhelm health services.2
Alternatively, if global emissions peak soon and quickly fall to net zero, consistent with the IPCC’s low-emissions scenario, (RCP 2.6),
temperatures will remain steady from 2040 onwards.4 Measures needed to accomplish this, such as increasing clean energy, improving
Figure 1: Examples of impacts of Climate Change on Health and Health Systems in Canada
Indicators of climate-related health impacts
and adaptation
This year’s policy brief presents information on three key indicators of climate-related health impacts and adaptive responses. Additional
recommendations can also be found in the 2017 and 2018 policy briefs.6,24
Wildfires
Lancet Countdown data indicates that the number of daily population wildfire exposure events increased from an average of 35,300 in
2001-2004 to 54,100 in 2015-2018, not including those subjected to wildfire smoke. Canadian data supports increasing impacts: more
than half of the 448,444 Canadians evacuated due to wildfires between 1980-2017 were displaced in the last decade.35 These exposures
not only pose a threat to public health, but also result in major economic and social burdens.
2019 marks a crux point for humanity: choices and policies made in
the lead up to the 2020 UNFCCC Nationally Determined Contribution
submissions will determine whether the world follows the disastrous
high-emissions scenario, or the safer low-emissions path. Children
are taking to the streets to demand a livable world. It is the task of
today’s political leaders and other adults to exert maximal effort
within their spheres of influence in order to set a course for a
healthy response to climate change.
public transit, cycling and walking rates, and adhering to a plantrich
diet in accordance with Canada’s new food guide,
decrease emissions, and also improve health and decrease
healthcare costs.30
Canada is not on track: in 2016, total Canadian GHG emissions were
704 Mt CO2e, an increase of more than 100 Mt since 1990.31
Policies and measures currently under development but not yet
implemented are forecast to reduce national emissions to 592 Mt
CO2e by 2030,32 79 Mt CO2e above Canada’s 2030 target of 513
MtCO2e
32—a goal which is itself too weak to represent a fair
contribution by Canada to the emissions reductions necessary to
meet the goals of the Paris Climate Change Agreement.
The Earth as a whole is warming less quickly than Canada—but still
far too fast. The IPCC and the World Health Organization have
emphasized that keeping global surface temperature warming to
1.5oC is key to obtaining the best outcomes now possible for human
health.33,34 To do so would require global net human-caused
emissions to fall by about 45% from 2010 by 2030, reaching ‘net
zero’ by 2050.34 Updated Nationally Determined Contributions to
the Paris Agreement are due to be submitted by 2020: policymakers
must integrate health considerations through proposed
interventions.
Figure 2: Number of Wildfire Evacuees in Canada 1980-2017.*
Source: Wildland Fire Evacuation Database, Natural Resources Canada.35 (used with permission)
*N.B. Reporting for 2017 only includes evacuations up to and including July
In a mid-range GHG emissions scenario, wildfires in Canada are
projected to rise 75% rise by the end of the 21st century,36
necessitating a strong adaptive response. Human health impacts of
fire include death, trauma, and major burns,37 anxiety during
wildfire periods,35,38 and post-traumatic stress disorder, anxiety
and depression related to evacuations.39,40 Wildfire smoke also
travels vast distances41 and increases asthma and chronic
obstructive pulmonary disease exacerbations, with growing evidence
of an association with all-cause mortality.41 Impacts on health
systems can be severe: during the Fort McMurray fire hospital staff
evacuated 103 patients in a matter of hours,10,42 and the 2017 British
Columbia wildfires resulted in 700+ staff displaced, 880 patients
evacuated, and 19 sites closed by the Interior Health Authority, at a
cost of $2.7 million.12 Such devastating events also generate
significant emissions, contributing to climate change, and helping to
generate conditions conducive to future blazes.43
Much can be done to lessen the health impacts of wildfires.
Qualitative data indicates that populations who are better-briefed
on the local evacuation plan, as well as ways to lessen the risk of fire
to their property, are not only more prepared but also less
anxious.35,38 Building codes can be changed to help keep smoke out,
primary care practitioners can ensure vulnerable patients receive
at-home air filtration systems and respiratory medications prior to
wildfire season,44 public health professionals can collaborate with
municipal officials to maximize smoke forecast-informed outdoor
and well-ventilated indoor recreation opportunities,38 and health
personnel can help ensure evacuation plans are clearly
communicated.45
Sustainable and healthy transport
since 2000, they account for less than 4% of the energy used in
transport (Figure 3). This rate of change is inconsistent with the
emissions pathway required to keep today’s and future children
safe.
Support is therefore required for investments in public transit,47
and cycling infrastructure,48 creating win-wins for health by
increasing physical activity levels and improving community
cohesion, while reducing chronic disease, healthcare costs and
GHG emissions.49,50 Zero emissions vehicles also reduce air pollution
and are increasingly affordable: the up-front cost of electric vehicles
is forecast to become competitive on an un-subsidized basis from
2024 onwards.51 British Columbia recently passed legislation
requiring all new cars sold to be zero-emission by 2040.52 Other
provinces would benefit from matching this ambition.
Figure 3: Per Capita Fuel Consumption for Transport in Canada.
Source: Lancet Countdown
Transport-related pollution is harming the health of Canadians. Fine
particulate matter (PM2.5) air pollution related to land-based
transportation was responsible for approximately 1063 deaths in
2015 in Canada, resulting in a loss of economic welfare for
Canadians valued at approximately $8 billion dollars.24 Additionally,
Canada has the highest pediatric asthma rate amongst countries of
comparable income level, with nitrogen dioxide (NO2) from traffic
responsible for approximately 1 in 5 new cases of asthma in
children.46
With transport responsible for 24% of national GHG emissions in
2017,31 decarbonizing this sector must be prioritized. Progress is
entirely too slow: total fuel consumption for road transport per
capita decreased 5.4% from 2013 to 2016. While per capita
use of electricity and biofuels for transport increased by 600%
Healthcare sector emissions
Though Canadians are proud of the care they provide for one another
with this country’s system of universal healthcare,53 Lancet Countdown
analysis reveals an area which should give pause to all who endeavor to
“do no harm”: Canada’s healthcare system has the world’s third highest
emissions per capita.
Previous analysis showed healthcare sector emissions to be responsible
for 4.6% of the national total,54 as well as more than 200,000 tons of
other pollutants, resulting in 23,000 disability-adjusted life years (DALYs)
lost annually.54 Emissions from the health sector represent a strategic
mitigation target in a single-payer healthcare system straining under
the weight of an inexorably increasing burden of disease.
While Canadian healthcare sector emissions are increasing, the
world-leading Sustainable Development Unit in England reported an
18.5% decrease in National Health Service, public health and social
care system emissions from 2007-2017 despite an increase in clinical
activity.55
Despite healthcare being a provincial jurisdiction, there is a role for
pan-Canadian sustainability initiatives to unite diverse experts
spanning public health and the spectrum of clinical disciplines,
economics, sustainability science and beyond. This demands health
sector-wide education, consistent with existing efforts to increase
environmental literacy for health professionals.56
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K, et al. The continued rise of Lyme disease in Ontario, Canada: 2017.
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29. Walpole SC, Rasanathan K, Campbell-Lendrum D. Natural and unnatural
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References
Organisations and acknowledgements
The concept of this brief was developed by the Lancet Countdown on Health
and Climate Change.
This brief was written by Courtney Howard, MD; Chris Buse, PhD; Caren Rose,
PhD; Andrea MacNeill, MD, MSc; and Margot Parkes, MBChB, MAS, PhD.
Review was provided by Owen Adams, PhD; Ian Culbert; and Sandy Buchman,
MD.
Thanks to Sarah Henderson, PhD; Peter Barry, PhD; Brian Wiens, PhD;
Robin Edger, LLB, LLM; Jeff Eyamie, and Ashlee Cunsolo, PhD for their
assistance.
Contributions and review on behalf of the Lancet Countdown were provided
by Jess Beagley and Nick Watts, MBBS.
THE LANCET COUNTDOWN
The Lancet Countdown: Tracking Progress on Health and Climate Change is an
international, multi-disciplinary collaboration that exists to monitor the links
between public health and climate change. It brings together 35 academic
institutions and UN agencies from every continent, drawing on the expertise
of climate scientists, engineers, economists, political scientists, public health
professionals, and doctors. Each year, the Lancet Countdown publishes an
annual assessment of the state of climate change and human health, seeking
to provide decision-makers with access to high-quality evidence-based
policy guidance. For the full 2019 assessment, visit www.lancet
countdown.org/2019-report .
THE CANADIAN MEDICAL ASSOCIATION
The Canadian Medical Association (CMA), formed in Quebec City in 1867,
has led some of Canada’s most important health policy changes. As we
look to the future, the CMA will focus on advocating for a healthy population
and a vibrant profession.
THE CANADIAN PUBLIC HEALTH ASSOCIATION
The Canadian Public Health Association (CPHA) is a national, independent,
non-governmental organization that advances public health education,
research, policy and practice in Canada and around the world through the
Canadian Journal of Public Health, position statements, discussion
documents and other resources.
Homeless and vulnerably housed populations are heterogeneous
and continue to grow in numbers in urban and
rural settings as forces of urbanization collide with gentrification and austerity policies.2
Collectively, they face dangerous living conditions and marginalization within health care systems.3
However, providers can improve the health of people who
are homeless or vulnerably housed, most powerfully by following
evidence-based initial steps, and working with communities and
adopting anti-oppressive practices.1,4,5
Broadly speaking, “homelessness” encompasses all individuals without stable, permanent and acceptable housing, or lacking the immediate prospect, means and ability of acquiring it.6
Under such conditions, individuals and families face intersecting
social, mental and physical health risks that significantly increase
morbidity and mortality.7,8 For example, people who are homeless
and vulnerably housed experience a significantly higher prevalence of trauma, mental health conditions and substance use disorders than the general population.7,9 Canadian research reports
that people who experience homelessness face life expectancies
as low as 42 years for men and 52 years for women.7
A generation ago, homeless Canadians were largely middleaged, single men in large urban settings.10 Today, the epidemiology has shifted to include higher proportions of women, youth,
Indigenous people (Box 1), immigrants, older adults and people
from rural communities.13,14 For example, family homelessness
(and therefore homelessness among dependent children and
youth) is a substantial, yet hidden, part of the crisis.15 In 2014, of
the estimated 235 000 homeless people in Canada, 27.3% were
women, 18.7% were youth, 6% were recent immigrants or
migrants, and a growing number were veterans and seniors.10
Practice navigators, peer-support workers and primary care
providers are well placed to identify social causes of poor health
and provide orientation to patient medical homes.16,17 A patient’s
medical home is “a family practice defined by its patients as the
place they feel most comfortable presenting and discussing their
personal and family health and medical concerns.”18 Medical
care is “readily accessible, centred on the patients’ needs, provided throughout every stage of life, and seamlessly integrated
with other services in the health care system and the community”
(https://patientsmedicalhome.ca). Primary care providers are
also well positioned to mobilize health promotion, disease prevention, diagnosis and treatment, and rehabilitation services.19
GUIDELINE VULNERABLE POPULATIONS CPD
Clinical guideline for homeless and vulnerably
housed people, and people with lived
homelessness experience
Kevin Pottie MD MClSc, Claire E. Kendall MD PhD, Tim Aubry PhD, Olivia Magwood MPH,
Anne Andermann MD DPhil, Ginetta Salvalaggio MD MSc, David Ponka MDCM MSc, Gary Bloch MD,
Vanessa Brcic MD, Eric Agbata MPH MSc, Kednapa Thavorn PhD, Terry Hannigan, Andrew Bond MD,
Susan Crouse MD, Ritika Goel MD, Esther Shoemaker PhD, Jean Zhuo Jing Wang BHSc, Sebastian Mott MSW,
Harneel Kaur BHSc, Christine Mathew MSc, Syeda Shanza Hashmi BA, Ammar Saad, Thomas Piggott MD,
Neil Arya MD, Nicole Kozloff MD, Michaela Beder MD, Dale Guenter MD MPH, Wendy Muckle BScN MHA,
Stephen Hwang MD, Vicky Stergiopoulos MD, Peter Tugwell MD
n Cite as: CMAJ 2020 March 9;192:E240-54. doi: 10.1503/cmaj.190777
CMAJ Podcasts: author interview at https://soundcloud.com/cmajpodcasts/190777-guide
See related article at www.cmaj.ca/lookup/doi/10.1503/cmaj.200199
KEY POINTS
Clinical assessment and care of homeless and vulnerably housed
populations should include tailoring approaches to a person’s
gender, age, Indigenous heritage, ethnicity and history of
trauma; and advocacy for comprehensive primary health care.
As initial steps in the care of homeless and vulnerably housed
populations, permanent supportive housing is strongly
recommended, and income assistance is also recommended.
Case-management interventions, with access to psychiatric
support, are recommended as an initial step to support primary
care and to address existing mental health, substance use and
other morbidities.
Harm-reduction interventions, such as supervised consumption
facilities, and access to pharmacologic agents for opioid use
disorder, such as opioid agonist treatment, are recommended
for people who use substances.
GUIDELINE
CMAJ
MARCH 9, 2020
VOLUME 192
ISSUE 10 E241
However, the social and health resources available to homeless
and vulnerably housed people may vary based on geographic
setting, municipal resources, housing coordination, and patients’
mental health and substance use–related care needs. In addition, many physical and mental health disorders remain undiagnosed or inconsistently treated because of missed opportunities
for care, patient mistrust of the health care system or limited
access to health services.3
Homeless and vulnerably housed people can benefit from
timely and effective health, addiction and social interventions.
Our guideline provides initial steps for practice, policy and future
research, and is intended to build collaboration among clinicians, public health providers and allied health providers. Values
such as trauma-informed and patient-centred care, and dignity
are needed to foster trust and develop sustainable therapeutic
relationships with homeless and vulnerably housed people.20,21
Scope
The purpose of this clinical practice guideline is to inform providers
and community organizations of the initial priority steps and effective interventions for homeless and vulnerably housed people. The
guideline addresses upstream social and health needs (i.e., housing), as well as downstream health-related consequences of inadequate housing. The target audiences are health providers, policymakers, public health practitioners and researchers.
Our guideline does not aim to address all conditions associated with homelessness, nor does it aim to discuss in depth the
many etiologies of homelessness, such as childhood trauma, the
housing market, or the root causes of low social assistance rates
and economic inequality. Rather, this guideline aims to reframe
providers’ approach toward upstream interventions that can
prevent, treat and work toward ending the morbidity and mortality associated with homelessness.
A parallel set of Indigenous-specific clinical guidelines is currently being developed by an independent, Indigenous-led
team.22 This process recognizes the distinct rights of Indigenous
Peoples, including the right to develop and strengthen their own
economies, social and political institutions; the direct links
between historic and ongoing colonial policies and Indigenous
homelessness; and the need for Indigenous leadership and participation in research that is about Indigenous Peoples.
Recommendations
The steering committee and guideline panel members developed
and approved recommendations to improve social and health
outcomes for homeless and vulnerably housed people. The order
of these recommendations highlights priority steps for homeless
health care. We list a summary of the recommendations in Table 1
and we present our list of good practice statements in Table 2.
These good practice statements are based on indirect evidence
and support the delivery of the recommendations.
The methods used to develop the recommendations are
described later in this document. A summary of how to use this
guideline is available in Box 2.
Permanent supportive housing
Identify homelessness or housing vulnerability and willingness to consider housing interventions.
Ensure access of homeless or vulnerably housed individuals to
local housing coordinator or case manager (i.e., call 211 or
via a social worker) for immediate link to permanent supportive housing and/or coordinated access system (moderate certainty, strong recommendation).
Evidence summary
Our systematic review (Tim Aubry, University of Ottawa, Ottawa,
Ont.: unpublished data, 2020) identified 14 trials on permanent
supportive housing (PSH).30–43 Several trials across Canada and the
United States showed that PSH initiatives house participants more
rapidly compared with usual services (73 v. 220 d; adjusted absolute difference 146.4, 95% confidence interval [CI] 118.0 to 174.9);30
increase the number of people who maintain stable housing at
2 years (pooled odds ratio [OR] 3.58, 95% CI 2.36 to 5.43);30,40 and
significantly increase the percentage of days spent stably
housed.41 No trials showed a significant improvement in mental
health symptoms compared with standard care.30,31,33,34,41,42
Two studies found that the mental health of PSH participants did
not improve as much as that of usual care participants (e.g., mean
difference –0.49, 95% CI –0.85 to –0.12).30,31
The At Home/Chez Soi trial showed small improvements in quality
of life for high-needs (adjusted standardized mean difference 0.15,
95% CI 0.04 to 0.24)30 and moderate-needs (mean difference 4.37,
95% CI 1.60 to 7.14) homeless participants in patients receiving PSH.41
Youth receiving PSH saw larger improvements in their quality of life
during the first 6 months (mean difference 9.30, 95% CI 1.35 to 17.24),
which diminished over time (mean difference 7.29, 95% CI –1.61 to
16.18).44 No trials showed a significant improvement in substance use
compared with standard care.30,33,41–43 Most trials reported no effect of
PSH on acute care outcomes (e.g., number of emergency department
visits and percentage of participants admitted to hospital).30,41 However, 2 trials suggest that PSH participants had lower rates of hospital
admission (rate reductions of 29%, 95% CI 10 to 44) and time in hospital (e.g., mean difference –31, 95% CI –48 to –14).34,38,45 One trial found
no effect of PSH on job tenure, hours of work per week or hourly wage
compared with standard care.46 Participants receiving PSH may have
increased odds of employment, but this depends on the severity of
participant needs.46 One trial found no effect on income outcomes.46
Box 1: Indigenous homelessness
Indigenous homelessness is a term used to describe First Nations,
Métis and Inuit individuals, families or communities who lack
stable, permanent and appropriate housing, or the immediate
prospects, means or ability to acquire such housing. However, this
term must be interpreted through an Indigenous lens to
understand the factors contributing to this condition. These
factors include individuals, families and communities isolated
from their relationships to land, water, place, family, kin, each
other, animals, cultures, languages and identities as well as the
legacy of colonialism and genocide.11 It is estimated that urban
Indigenous people are 8 times more likely to experience
homelessness than the general population.11,12
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The certainty of the evidence was rated moderate, because
blinding of participants and personnel was not feasible in any of
the trials we examined as a result of the nature of the intervention. Furthermore, several trials did not employ allocation concealment or blinding of outcome-assessment procedures, which
could introduce high risks of detection and performance biases.
Income assistance
Identify income insecurity.
Assist individuals with income insecurity to identify incomesupport resources and access income (low certainty, conditional recommendation).
Evidence summary
We identified 10 trials on income-assistance interventions, including
rental assistance,47–56 financial empowerment,47 social enterprise
interventions,48 individual placement and support,48,54 and compensated work therapy.52 Our systematic review showed the benefit that
income-assistance interventions have on housing stability (Gary
Bloch, University of Toronto, Toronto, Ont., and Vanessa Brcic, University of British Columbia, Vancouver, BC: unpublished data, 2020).
Rental assistance increased the likelihood of being stably housed
(OR 4.60, 95% CI 3.10 to 6.83).56 Rental assistance combined with
case management increased the number of days in stable housing
per 90-day period compared with case management alone (mean
Table 1: Summary of evidence-based recommendations
Recommendations and clinical considerations Grade rating*
Recommendation 1: A homeless or vulnerably housed person Moderate certainty
Ensure access for homeless or vulnerably housed individuals to local housing coordinator or case manager (i.e., call
211 or via a social worker) for immediate link to permanent supportive housing and coordinated access system.
Clinical considerations: Many jurisdictions will provide alternative housing services for specific marginalized
populations, for example, Indigenous people, women and families, youth, those who identify as LGBTQ2+, those
with disabilities, refugees and migrants.
Strong recommendation
Recommendation 2: A homeless or vulnerably housed person with experience of poverty, income instability or
living in a low-income household
Low certainty
Assist individuals with income insecurity to identify income-support resources and access income.
Clinical considerations: Consult poverty screening tools when needed (e.g., https://cep.health/clinical-products
/poverty-a-clinical-tool-for-primary-care-providers).
Conditional recommendation
Recommendation 3: A homeless or vulnerably housed person with multiple comorbid or complex health needs
(including mental illness and/or substance use)
Low certainty
Identify history of severe mental illness, such as psychotic or mood and anxiety disorders, associated with
substantial disability, substance use, or multiple/complex health needs.
Ensure access to local community mental health programs, psychiatric services for assessment, and linkage to
intensive case management, assertive community treatment or critical time intervention where available.
Clinical considerations: Call 211 or consult primary care providers, social workers or case managers familiar
with local access points and less intensive community mental health programs.
Conditional recommendation
Recommendation 4: A homeless or vulnerably housed person currently using opioids Very low certainty
Identify opioid use disorder.
Ensure access within primary care or via an addiction specialist to opioid agonist therapy (OAT), potentially in
collaboration with a public health or community health centre for linkage to pharmacologic interventions.
Clinical considerations: Encourage all patients taking opioid medication to have a naloxone kit. Though barriers
to prescribing methadone and buprenorphine remain, be aware of new regulations that aim to facilitate OAT
access and options in your jurisdiction, in particular for buprenorphine.
Conditional recommendation
Recommendation 5: A homeless or vulnerably housed person with substance use disorder Very low certainty
Identify, during history or physical examination, problematic substance use, including alcohol or other drugs.
Identify the most appropriate approach, or refer to local addiction and harm-reduction/prevention services
(e.g., supervised consumption facilities, managed alcohol programs) via appropriate local resources such as
public health or community health centre or local community services centre.
Clinical considerations: In case of active opioid use disorder, facilitate patient access to OAT. Patients should be
made aware of supervised consumption facility locations (Appendix 1, available at www.cmaj.ca/lookup/suppl/
doi:10.1503/cmaj.190777/-/DC1).
Conditional recommendation
Note: LGBTQ2+ = lesbian, gay, bisexual, transgender, questioning and two-spirited.
*See Box 2 for definitions.
†211 is a special abbreviated telephone number reserved in Canada and the United States as an easy-to-remember 3-digit telephone number meant to provide information and
referrals to health, human and social service organizations.
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difference 8.58, p < 0.004).55 Compensated work therapy was found
to reduce the odds of homelessness (OR 0.1, 95% CI 0.1 to 0.3).52 No
income interventions showed an effect on mental health
outcomes.47,52,55,56
The impact of these interventions on substance use outcomes
were mixed. Provision of housing vouchers did not affect substance
use over 3 years;55 however, compensated work therapy showed
immediate reductions in drug (reduction: –44.7%, standard error [SE]
12.8%; p = 0.001) and alcohol use problems (–45.4%, SE 9.4%; p =
0.001), as well as the number of substance use–related physical
symptoms (–64.4%, SE 8.0%; p = 0.001).52 These differences, however, tended to decline with time. No significant effects were found
on overall quality-of-life, finances, health and social relations scores.
Provision of housing vouchers resulted in higher family-relations
score and satisfaction, and quality of housing compared with standard care.55 One trial reported that rental assistance was associated
with reduced emergency department visits and time spent in hospital, but this reduction was not significantly different than in the comparator group.56 Individual placement and support was found to
improve employment rates only when there was high fidelity to the
model (OR 2.42, 95% CI 1.13 to 5.16).54 Financial-empowerment education and provision of housing vouchers had no effect on employment outcomes.47,55 Financial-empowerment education and individual placement and support had no effect on hourly wages.47,54
Provision of housing vouchers had no effect on monthly income.55
The certainty of the evidence was rated low because several
trials introduced high risk of detection and performance bias. Furthermore, 1 trial reported low consent rates of 47% and a 1:4 sampling ratio that further limited statistical power.52 As well, participants in the control group wanting to enter income-assistance
programs after completing the study had incentives to underreport
symptoms, which introduced high risk for measurement bias.
Case management
Identify history of severe mental illness, such as psychotic or
mood and anxiety disorders, associated with substantial disability, substance use disorders, or multiple or complex
health needs.
Ensure access to local community mental health programs,
psychiatric services for assessment and linkage to intensive
case management, assertive community treatment or critical
time intervention where available (low certainty, conditional
recommendation).
Evidence summary
Our systematic review examined the effectiveness of standard
case management, as well as specific intensive casemanagement interventions, such as assertive community treatment, intensive case management and critical time intervention
among homeless and vulnerably housed populations and corresponding level of need (David Ponka, University of Ottawa,
Ottawa, Ont.: unpublished data, 2020). We included a total of
56 citations, of which 10 trials reported on standard case management,51,57–65 8 trials on assertive community treatment,66–73
16 trials on intensive case management74–89 and 5 trials on critical
time intervention.90–94
Box 2: How to use and understand this GRADE guideline
(www.gradeworkinggroup.org)
This guideline supplies providers with evidence for decisions
concerning interventions to improve health and social outcomes
for people who are homeless or vulnerably housed. This guideline
is not meant to replace clinical judgment. Statements about
clinical considerations, values and preferences are integral parts of
the recommendations meant to facilitate interpretation and
implementation of the guideline. Recommendations in this
guideline are categorized according to the Grading of
Recommendations Assessment, Development and Evaluation
(GRADE) system as strong or conditional recommendations.
Strong recommendations indicate that all or almost all fully
informed patients would choose the recommended course of
action, and indicate to clinicians that the recommendation is
appropriate for all or almost all individuals. Strong
recommendations represent candidates for quality-of-care criteria
or performance indicators.
Conditional recommendations indicate that most informed
patients would choose the suggested course of action, but an
appreciable minority would not. With conditional
recommendations, clinicians should recognize that different
choices will be appropriate for individual patients, and they should
help patients arrive at a decision consistent with their values and
preferences. Conditional recommendations should not be used as
a basis for standards of practice (other than to mandate shared
decision-making).
Good practice statements represent common-sense practice, are
supported by indirect evidence and are associated with assumed
large net benefit.
Clinical considerations provide practical suggestions to support
implementation of the GRADE recommendation.
GRADE certainty ratings
High: further research is very unlikely to change our confidence in
the estimate of effect.
Moderate: further research is likely to have an important impact on
the confidence in the estimate of effect and may change the estimate.
Low: further research is very likely to have an important impact
on our confidence in the estimate of effect and is likely to change
the estimate.
Very low: any estimate of the effect is very uncertain.
Table 2: Good practice statements to support delivery of care
Good practice statement
Indirect
evidence
(reference)
1. Homeless and vulnerably housed populations
should receive trauma-informed and personcentred care.
23–26
2. Homeless and vulnerably housed populations
should be linked to comprehensive primary
care to facilitate the management of multiple
health and social needs.
27
3. Providers should collaborate with public health
and community organizations to ensure
programs are accessible and resources
appropriate to meet local patient needs.
28,29
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Of 10 trials on standard case management, 10 evaluated
housing stability. Only 3 reported significant decreases in homelessness,57,62,63 an effect that diminished over time in 1 trial of a
time-limited residential case management in which participants
in all groups accessed substantial levels of services.57 A program
tailored to women reduced the odds of depression at 3 months
(OR 0.38, 95% CI 0.14 to 0.99), but did not show improvements in
the women’s overall mental health status (mean difference 4.50,
95% CI –0.98 to 9.98).64 One trial reported higher levels of hostility (p < 0.001) and depression symptoms (p < 0.05) among female
participants receiving nurse-led standard case management
compared with those receiving standard care.60 Few studies
reported on substance use, quality of life, employment or
income outcomes.
Findings of assertive community treatment on housingstability, quality-of-life and hospital-admission outcomes are
mixed. Two trials found that participants receiving the treatment
reported fewer days homeless (p < 0.01)71 and more days in community housing (p = 0.006),70 whereas 2 trials reported no effect
on episodes of homelessness or number of days homeless.66,73
Further, these interventions showed an added benefit in reducing the number of participants admitted to hospital (mean difference –8.6, p < 0.05) and with visits to the emergency department
(mean difference –1.2, p = 0.009).67 Most trials of assertive community treatment reported no significant differences in mental
health outcomes, including psychiatric symptoms, substance
use, or income-related outcomes between the treatment and
control groups.
Intensive case management reduced the number of days
homeless (pooled standardized mean difference –0.22, 95% CI
–0.40 to –0.03), but not the number of days spent in stable housing.78,80,89 In most studies, there was no major improvement in
psychological symptoms between the treatment and control
groups. However, 1 trial reported significantly greater reductions
in anxiety, depression and thought disturbances after 24 months
(mean difference change from baseline –0.32, p = 0.007), as well
as improved life satisfaction (mean difference 1.23, p = 0.001)
using intensive case management.86 One trial reported no significant difference in quality of life.83 Findings on substance use
were mixed. Six of the 10 trials reported that intensive case management was associated with improvements in substance use
behaviours.74,78,82,84,87,88 Participants receiving intensive case management reported fewer visits to the emergency department
(mean difference 19%, p < 0.05) but did not have shorter hospital
stays compared with control groups.85 Intensive case management had no effect on the number of days of employment, or on
income received from employment; however, income received
by participants through public assistance increased (e.g., mean
difference 89, 95% CI 8 to 170).78,85
Critical time intervention was beneficial in reducing the number of homeless nights (mean difference –591, p < 0.001) and the
odds of homelessness (OR 0.23, 95% CI 0.06 to 0.90) during the
final 18 weeks of follow-up.91 Participants receiving the treatment were rehoused sooner than those receiving standard
care,95 but did not spend more days rehoused.90 Adults receiving
critical time intervention showed significant improvements in
psychological symptoms (mean difference –0.14, 95% CI –0.29 to
0.01).90 However, findings for children’s mental health were
mixed: children aged 1.5–5 years showed improvements in internalizing (ß coefficient –3.65, 95% CI –5.61 to –1.68) and externalizing behaviours (ß coefficient –3.12, 95% CI –5.37 to –0.86),
whereas changes for children aged 6–10 years and 11–16 years
were not significant.93 There were no significant effects of critical
time intervention on substance-use,90 quality-of-life90,92 or
income-related outcomes.96 Two trials reported mixed findings
on hospital admission outcomes; in 1 study, allocation to critical
time intervention was associated with reduced odds of hospital
admission (OR 0.11, 95% CI 0.01 to 0.96) and total number of
nights in hospital (p < 0.05) in the final 18 weeks of the trial.97
However, another study reported a greater total number of
nights in hospital for the treatment group compared with usual
care (1171 v. 912).98
The certainty of the evidence was rated low because several
trials introduced high risk of detection and performance bias.
Opioid agonist therapy
Ensure access to opioid agonist therapy in primary care or by
referral to an addiction specialist, potentially in collaboration
with public health or community health centre for linkage to
pharmacologic interventions (low certainty, conditional
recommendation).
Evidence summary
We conducted a review of systematic reviews on pharmalogic
interventions for opioid use disorder.99 Twenty-four reviews,
which included 352 unique primary studies, reported on pharmacologic interventions for opioid use disorder among general
populations.100–123 We expanded our inclusion criteria to general
populations, aware that most studies among “general populations” had a large representation of homeless populations in
their samples. We did not identify any substantial reason to
believe that the mechanisms of action of our interventions of
interest would differ between homeless populations who use
substances and the general population of people who use substances. Reviews on pharmacologic interventions reported on
the use of methadone, buprenorphine, diacetylmorphine (heroin), levo-a-acetylmethadol, slow-release oral morphine and
hydromorphone for treatment of opioid use disorder.
We found pooled all-cause mortality rates of 36.1 and 11.3 per
1000 person years for participants out of and in methadone
maintenance therapy, respectively (rate ratio 3.20, 95% CI 2.65 to
3.86), and mortality rates of 9.5 per 1000 person years for those
not receiving buprenorphine maintenance therapy compared
with 4.3 per 1000 person years among those receiving the therapy (rate ratio 2.20, 95% CI 1.34 to 3.61).116 Overdose-specific
mortality rates were similarly affected, with pooled overdose
mortality rates of 12.7 and 2.6 per 1000 person years for participants out of and in methadone maintenance therapy, and rates
of 4.6 and 1.4 per 1000 person years out of and in buprenorphine
maintenance therapy.116 Compared with nonpharmacologic
approaches, methadone maintenance therapy had no significant
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effect on mortality (relative risk 0.48, 95% CI 0.10 to 2.39).110 With
respect to morbidity, pharmacologic interventions for opioid use
disorder reduced the risk of hepatitis C virus (HCV) acquisition
(risk ratio 0.50, 95% CI 0.40 to 0.63)112 and HIV infection.103
Adverse events were reported for all agents.100,109,119,122 Treatment with methadone and buprenorphine was associated with
reduced illicit opioid use (standardized mean difference –1.17,
95% CI –1.85 to –0.49).109 Availability of buprenorphine treatment
expanded access to treatment for patients unlikely to enrol in
methadone clinics and facilitated earlier access for recent initiates to opioid use.117 The relative superiority of one pharmacologic agent over another on retention outcomes remains unclear;
however, use of methadone was found to show better benefits
than nonpharmacologic interventions for retention (risk ratio
4.44, 95% CI 3.26 to 6.04).110
The certainty of evidence ranged from very low to moderate,
primarily because of inconsistency, high risk of bias and evidence
from nonrandomized studies.
Harm-reduction interventions
Identify problematic substance use, including alcohol or other
drugs.
Identify the most appropriate approach or refer to local addiction and harm reduction/prevention services (e.g., supervised
consumption facilities, managed alcohol programs) via appropriate local resources, such as public health or community
health centre or les centres locaux de services communautaires (low certainty, conditional recommendation).
Evidence summary
We conducted a review of systematic reviews on supervised
consumption facilities and managed alcohol programs.99 Two
systematic reviews, which included 90 unique observational
studies and 1 qualitative meta-synthesis reported on supervised
consumption facilities.124–126 For managed alcohol programs,
1 Cochrane review had no included studies,127 and 2 greyliterature reviews reported on 51 studies.128,129
Establishment of supervised consumption facilities was associated with a 35% decrease in the number of fatal opioid overdoses within 500 m of the facility (from 253.8 to 165.1 deaths per
100 000 person years, p = 0.048), compared with 9% in the rest of
the city (Vancouver).124 There were 336 reported opioid overdose
reversals in 90 different individuals within the Vancouver facility
over a 4-year period (2004–2008).125 Similar protective effects
were reported in Australia and Germany. Observational studies
conducted in Vancouver and Sydney showed that regular use of
supervised consumption facilities was associated with decreased
syringe sharing (adjusted OR 0.30, 95% CI 0.11 to 0.82), syringe
reuse (adjusted OR 2.04, 95% CI 1.38 to 3.01) and public-space
injection (adjusted OR 2.79, 95% CI 1.93 to 3.87).125 These facilities mediated access to ancillary services (e.g., food and shelter)
and fostered access to broader health support.125,126 Attendance
at supervised consumption facilities was associated with an
increase in referrals to an addiction treatment centre and initiation of methadone maintenance therapy (adjusted hazard ratio
1.57, 95% CI 1.02 to 2.40).125
Evidence on supervised consumption facilities was rated very
low to low, as all available evidence originated from nonrandomized studies.
There was a lack of high-quality evidence for managed alcohol
programs. Few studies reported on deaths among clients of these
programs.128 The effects of managed alcohol programs on hepatic
function are mixed, with some studies reporting improvement in
hepatic laboratory markers over time, and others showing
increases in alcohol-related hepatic damage;129 however, this may
have occurred regardless of entry into such a program. This evidence suggested that managed alcohol programs result in stabilized alcohol consumption and can facilitate engagement with
medical and social services.128 Clients experienced significantly
fewer social, health, safety and legal harms related to alcohol
consumption.129 Individuals participating in these programs had
fewer hospital admissions and a 93% reduction in emergency service contacts.128 The programs also promoted improved or stabilized mental health128 and medication adherence.129
Cost effectiveness and resource implications
Permanent supportive housing
We found 19 studies assessing the cost and net cost of housing
interventions.30,41,45,130–145 In some studies, permanent supportive
housing interventions were associated with increased cost to the
payers, and the costs of the interventions were only partially offset by savings in medical and social services as a result of the
intervention.30,41,131–134,142 Six studies showed that these interventions saved payers money.135,137,139,141,144,145 Four of these studies,
however, employed a pre–post design.135,139,141,145 Moreover,
1 cost-utility analysis of PSH suggested that the provision of housing services was associated with increased costs and increased
quality-adjusted life years, with an incremental cost-effectiveness
ratio of US$62 493 per quality-adjusted life year.136 Compared
with usual care, PSH was found to be more costly to society (net
cost Can$7868, 95% CI $4409 to $11 405).138
Income assistance
Two studies55,146 focused on the cost effectiveness of incomeassistance interventions. Rental assistance with clients receiving
case-management intervention had greater annual costs compared with usual care or groups receiving only case management.55 For each additional day housed, clients who received
income assistance incurred additional costs of US$58 (95% CI $4
to $111) from the perspective of the payer, US$50 (95% CI –$17 to
$117) from the perspective of the health care system and US$45
(95% CI –$19 to $108) from the societal perspective. The benefit
gained from temporary financial assistance was found to outweigh its costs with a net savings of US$20 548.146
Case management
Twelve publications provided evidence on cost and costeffectiveness of case-management interventions.44,55,67,69,73,75,88,96,147–150
Findings of these studies were mixed; the total cost incurred by
clients of standard case management was higher than that of
clients receiving usual or standard care61,88 and assertive
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community treatment,67,147 but lower compared with a US clinical
case-management program that included housing vouchers and
intensive case management.55 Cost-effectiveness studies using a
societal perspective showed that standard case management
was not cost effective compared with assertive community
treatment for people with serious mental disorders or those with
a concurrent substance-use disorder, as it was more expensive.67
For intensive case management, the cost of supporting housing
with this program could be partially offset by reductions in the use
of emergency shelters and temporary residences.41 Intensive case
management is more likely to be cost effective when all costs and
benefits to society are considered.41 A pre–post study showed that
providing this program to high-need users of emergency departments resulted in a net hospital cost savings of US$132 726.150
Assertive community treatment interventions were associated with lower costs compared with usual care.66,67,73,148,149 We
identified only 1 study on the cost effectiveness of critical time
intervention that reported comparable costs (US$52 574 v.
US$51 749) of the treatment compared with the usual services
provided to men with severe mental illness.96
Interventions for substance use
We identified 2 systematic reviews that reported findings from
6 studies in Vancouver on the cost effectiveness of supervised
consumption facilities;124,125 5 of these 6 studies found the facilities to be cost effective. After consideration of facility operating
costs, supervised consumption facilities saved up to Can$6 million from averted overdose deaths and incident HIV cases. Similarly, Can$1.8 million was saved annually from the prevention of
incident HCV infection.
Clinical considerations
Providers can, in partnership with directly affected communities,
employ a range of navigation and advocacy tools to address the
root causes of homelessness, which include poverty caused by
inadequate access to social assistance, precarious work, insufficient access to quality child care, social norms that allow the
propagation of violence in homes and communities, inadequate
supports for patients and families living with disabilities or going
through life transitions, and insufficient and poor-quality housing stock.151 In addition, providers should tailor their approach to
the patient’s needs and demographics, taking into account
access to services, personal preferences and other illnesses.152
Providers should also recognize the social and human value
of accepting homeless and vulnerably housed people into their
clinical practices. The following sections provide additional evidence for underserved and marginalized populations.
Women
A scoping review of the literature on interventions for homeless
women (Christine Mathew, Bruyère Research Institute, Ottawa,
Ont.: unpublished data, 2020) yielded 4 systematic reviews153–156
and 9 randomized controlled trials (RCTs)36,60,92,95,157–161 that focused
specifically on homeless and vulnerably housed women. Findings
showed that PSH was effective in reducing the risk of intimate partner violence and improving psychological symptoms.158 For women
with children experiencing homelessness, priority access to permanent housing subsidies can reduce child separations and foster
care placements, allowing women to maintain the integrity of their
family unit.158 As well, Housing First programs for families, critical
time interventions during times of crisis, and therapeutic communities are associated with lower levels of psychological distress,
increased self-esteem and improved quality of life for women and
their families.92,155 A gender-based analysis highlighted the importance of safety, service accessibility and empowerment among
homeless women. We suggest that providers focus on patient
safety, empowerment among women who have faced genderbased violence, and improve access to resources, including
income, child care and other social support services.
Youth
A systematic review on youth-specific interventions reported
findings from 4 systematic reviews and 18 RCTs.162 Permanent
supportive housing improved housing stability. As well, individual cognitive behavioural therapy has been shown to result in
significant improvements in depression scores, and family-based
therapies are also promising, resulting in reductions in youth
substance use through restoring the family dynamic. Findings on
motivational interviewing, skill building and case-management
interventions were inconsistent, with some trials showing a positive impact and others not identifying significant benefits.
Refugee and migrant populations
A qualitative systematic review on homeless migrants (Harneel
Kaur, University of Ottawa, Ottawa, Ont.: unpublished data,
2020) identified 17 qualitative articles that focused on the experiences of homeless migrants.163–179 Findings indicated that discrimination, limited language proficiency and severed social networks negatively affected homeless migrants’ sense of belonging
and access to social services, such as housing. However, employment opportunities provided a sense of independence and
improved social integration.
Methods
Composition of participating groups
In preparation for the guideline, we formed the Homeless Health
Research Network (https://methods.cochrane.org/equity/
projects/homeless-health-guidelines), composed of clinicians,
academics, and governmental and nongovernmental stakeholders. The Homeless Health Guideline Steering Committee (K.P.
[chair], C.K., T.A., A.A., G.S., G.B., D.P., E.A., V.B., V.S. and P.T.) was
assembled to coordinate guideline development. Expert representation was sought from eastern and western Canada, Ontario,
Quebec and the Prairie provinces for membership on the steering committee. In addition, 5 people with lived experience of
homelessness (herein referred to as “community scholars”180)
were recruited to participate in the guideline-development activities. A management committee (K.P., C.K. and P.T.) oversaw the
participating groups and monitored competing interests.
The steering committee decided to develop a single guideline
publication informed by a series of 8 systematic reviews. The
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steering committee assembled expert working groups to operationalize each review. Each working group consisted of clinical
topic experts and community scholars who were responsible for
providing contextual expertise.
The steering committee also assembled a technical team,
which provided technical expertise in the conduct and presentation of systematic reviews and meta-analyses. Finally, the steering committee assembled the guideline panel, which had the
responsibility to provide external review of the evidence and
drafted recommendations. The panel was composed of 17 individuals, including physicians, primary care providers, internists,
psychiatrists, public health professionals, people with lived
experience of homelessness, medical students and medical residents. Panel members had no financial or intellectual conflicts of
interest. A full membership list of the individual teams’ composition is available in Appendix 2, available at www.cmaj.ca/lookup/
suppl/doi:10.1503/cmaj.190777/-/DC1.
Selection of priority topics
We used a 3-step modified Delphi consensus method (Esther
Shoemaker, Bruyère Research Institute, Ottawa, Ont.: unpublished
data, 2020) to select priority health conditions for marginalized
populations experiencing homelessness or vulnerable housing.
Briefly, between May and June 2017, we developed and conducted
a survey (in French and English), in which we asked 84 expert providers and 76 people with lived homelessness experience to rank
and prioritize an initial list of needs and populations. We specifically asked participants, while answering the Delphi survey, to
keep in mind 3 priority-setting criteria when considering the
unique challenges of implementing health care for homeless or
vulnerably housed people: value added (i.e., the opportunity for a
unique and relevant contribution), reduction of unfair and preventable health inequities, and decrease in burden of illness (i.e.,
the number of people who may have a disease or condition).181
The initial top 4 priority needs identified were as follows: facilitating access to housing, providing mental health and addiction care,
delivering care coordination and case management, and facilitating
access to adequate income. The priority marginalized populations
identified included Indigenous people; women and families; youth;
people with acquired brain injury, or intellectual or physical disabilities; and refugees and other migrants (Esther Shoemaker, Bruyère
Research Institute, Ottawa, Ont.: unpublished data, 2020). Each
working group then scoped the literature using Google Scholar and
PubMed to determine a list of interventions and terms relating to
each of the priority-need categories. Each working group came to
consensus on the final list of interventions to be included (Table 3).
Guideline development
We followed the GRADE (Grading of Recommendations Assessment, Development and Evaluation) approach for the development
of this clinical guideline, including the identification of clinical
questions, systematic reviews of the best available evidence,
Table 3: Descriptions of priority-need interventions
Intervention Description
Permanent supportive housing
Long-term housing in the community with no set preconditions for access. Housing may be paired with the
provision of individualized supportive services that are tailored to participants’ needs and choices,
including assertive community treatment and intensive case management.
This guideline groups the Housing First model (a homeless assistance approach that prioritizes providing
housing) with permanent supportive housing.
Income assistance
Benefits and programs that improve socioeconomic status. This may include assistance that directly
increases income and programs that help with cost reduction of basic living necessities.
This guideline also groups employment programs (e.g., individual placement and support, and
compensated work therapy) in this category.
Case management
Standard case management allows for the provision of an array of social, health care and other services
with the goal of helping the client maintain good health and social relationships.
Intensive case management offers the support of a case manager who brokers access to an array of
services. Case-management support can be available for up to 12 hours per day, 7 days a week, and each
case manager often has a caseload of 15–20 service users.
Assertive community treatment offers team-based care to individuals with severe and persistent mental
illness by a multidisciplinary group of health care workers in the community. This team should be available
24 hours per day, 7 days per week.
Critical time intervention supports continuity of care for service users during times of transition. Case
management is administered by a critical time intervention worker and is a time-limited service, usually
lasting 6–9 months.
Pharmacologic interventions for
substance use disorder
Pharmacologic interventions for opioid use disorder, including methadone, buprenorphine,
diacetylmorphine, levo-a-acetylmethadol and naltrexone.
Pharmacologic agents for reversal of opioid overdose: opioid antagonist administered intravenously or
intranasally (e.g., naloxone).
Harm reduction for substance
use disorders
Supervised consumption facilities: facilities (stand-alone, co-located or pop-up) where people who use
substances can consume preobtained substances under supervision.
Managed alcohol programs: shelter, medical assistance, social services and the provision of regulated
alcohol to support residents with severe alcohol use disorder.
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assessment of the certainty of the evidence and development of
recommendations.182 We conducted a series of systematic reviews
to answer the following clinical question:
Should PSH, income assistance, case management, pharmacologic agents for opioid use, and/or harm-reduction interventions
be considered for people with lived experience of homelessness?
Systematic reviews for each intervention were driven by a logic
model. A detailed description of the methods used to compile evidence summaries for each recommendation, including search
terms, can be found in Appendix 3, available at www.cmaj.ca/
lookup/suppl/doi:10.1503/cmaj.190777/-/DC1. We sought evidence on questions considering population, interventions and
comparisons according to published a priori protocols.183–186 We
used relevant terms and structured search strategies in 9 bibliographic databases for RCTs and quasi-experimental studies. The
technical team reviewed titles, abstracts and full texts of identified
citations, selected evidence for inclusion and compiled evidence
reviews, including cost-effectiveness and resource-use data, for
consideration by the guideline panel. The technical team collected
and synthesized data on the following a priori outcomes: housing
stability, mental health, quality of life, substance use, hospital
admission, employment and income. Where possible, we conducted meta-analyses with random effects and assessed certainty
of evidence using the GRADE approach. Where pooling of results
was not appropriate, we synthesized results narratively.
In addition to the intervention and cost-effectiveness reviews,
the technical team conducted 3 systematic reviews to collect
contextual and population-specific evidence for the populations
prioritized through our Delphi process (women, youth, refugees
and migrants) (Christine Mathew, Bruyère Research Institute,
Ottawa, Ont.: unpublished data, 2020; Harneel Kaur, University
of Ottawa, Ottawa, Ont.: unpublished data, 2020).162 Additionally,
we conducted 1 qualitative literature review to capture patient
values and preferences, focused on the experiences of people
who are homeless in engaging with our selected interventions.20
Drafting of recommendations
The steering committee hosted a 2-day knowledge-sharing
event, termed the “Homeless Health Summit,” on Nov. 25–26,
2018. Attendees included expert working group members, community scholars, technical team members, and other governmental and nongovernmental stakeholders. Findings from all
intervention reviews were presented and discussed according to
the GRADE Evidence to Decision framework.187 After the meeting,
the steering committee drafted GRADE recommendations (Box 2)
through an iterative consensus process. All steering-committee
members participated in multiple rounds of review and revision
of the drafted clinical recommendations.
Guideline panel review
We used the GRADE Evidence to Decision framework to facilitate
the development of recommendations187–189 (Appendix 4, available
at www.cmaj.ca/lookup/suppl/doi:10.1503/cmaj.190777/-/DC1).
We used GRADEpro and the Panel Voice software to obtain input
from the guideline panel.190 Panellists provided input on the wording and strength of the draft recommendations. They also provided
considerations for clinical implementation. We required endorsement of recommendations by 60% of panel members for acceptance
of a recommendation. After review by the guideline panel, the steering committee reviewed the final recommendations before sign-off.
Good practice statements
We developed a limited number of good practice statements to support the delivery of the initial evidence-based recommendations. A
good practice statement characteristically represents situations in
which a large and compelling body of indirect evidence strongly
supports the net benefit of the recommended action, which is
necessary for health care practice.191–193 Guideline-development
groups consider making good practice statements when they have
high confidence that indirect evidence supports net benefit, there
is a clear and explicit rationale connecting the indirect evidence,
and it would be an onerous and unproductive exercise and thus a
poor use of the group’s limited resources to collect this evidence.
The steering committee came to a consensus on 3 good practice
statements based on indirect evidence.
Identification of implementation considerations
We completed a mixed-methods study to identify determinants
of implementation across Canada for the guideline (Olivia
Magwood, Bruyère Research Institute, Ottawa, Ont.: unpublished
data, 2020). Briefly, the study included a survey of 88 stakeholders and semistructured interviews with people with lived experience of homelessness. The GRADE Feasibility, Acceptability, Cost
(affordability) and Equity (FACE) survey collected data on guideline priority, feasibility, acceptability, cost, equity and intent to
implement. We used a framework analysis and a series of meetings (Ottawa, Ont., Jan. 13, 2020; Hamilton, Ont., Aug. 16, 2019;
Gatineau, Que., July 18, 2019) with relevant stakeholders in the
field of homeless health to analyze our implementation data.
Management of competing interests
Competing interests were assessed using a detailed form adapted
from the International Committee of Medical Journal Editors Uniform Disclosure Form for Potential Conflicts of Interest194 and the
Elsevier sample coauthor agreement form for a scientific project,
contingencies and communication.195 These forms were collected
at the start of the guideline activities for the steering committee,
guideline panel and community scholars. All authors submitted
an updated form in June 2019 and before publication.
The management committee iteratively reviewed these statements and interviewed participants for any clarifications and
concerns. A priori, the management committee had agreed that
major competing interests would lead to dismissal. There were
no competing interests declared.
Implementation
Our mixed-methods study (Olivia Magwood, Bruyère Research
Institute, Ottawa, Ont.: unpublished data, 2020) looking at guideline priority, feasibility, acceptability, cost, equity and intent to
implement, identified the following concerns regarding implementation of this guideline.
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Stakeholders highlighted the importance of increasing primary care providers’ knowledge of the process of applying to
PSH programs and informing their patients about the resources
available in the community.
The major concerns regarding feasibility arose around the limited availability of existing services, such as housing, as well as
administrative and human resources concerns. For example, not
all primary care providers work in a team-based comprehensive
care model and have access to a social worker or care coordinator
who can help link the patient to existing services. Furthermore,
wait lists for PSH are frequently long. Despite this, all stakeholders agreed that access to PSH was a priority and is a feasible
recommendation.
Allied health practitioners and physicians do not always agree
with their new role in this area. Some feedback suggested pushback from family physicians who have limited time with patients
and less experience exploring social determinants of health, such
as housing or income. The initial steps outlined in this guideline
would come at an opportunity cost for them. Stigma attached to
the condition of homelessness was recognized as an important
barrier to care for homeless populations.
Many stakeholders recognized that successful implementation of these recommendations may require moderate costs to
increase the housing supply, income supports and human
resources. However, supervised consumption facilities, with their
range of benefits, were perceived as cost-saving.
Many interventions have the potential to increase health
equity, if available and accessible in a local context. Many stakeholders highlighted opportunities to increase knowledge of the
initial steps and advocate on a systematic level to increase availability of services.
Suggested performance measures
We developed a set of performance measures to accompany this
guidleline for consideration by providers and policy-makers:
The proportion of adults who are assessed for homelessness
or vulnerable housing over 1 year.
The proportion of eligible adults who are considered for
income assistance over 1 year.
The proportion of eligible adults using opioids who are
offered opioid agonist therapy over 1 year.
Updates
The Homeless Health Research Network will be responsible for
updating this guideline every 5 years.
Other guidelines
This guideline complements other published guidelines. This
current guideline aims to support the upcoming Indigenousspecific guidelines that recognize the importance of Indigenous
leadership and methodology that will recognize distinct underlying causes of Indigenous homelessness (Jesse Thistle, York University, Toronto, Ont.: personal communication, 2020).
The World Health Organization has developed guidelines to
promote healthy housing standards to save lives, prevent disease
and increase quality of life.196 Other guidelines specific to opioid
use disorder exist,197,198 including 1 for “treatment-refractory”
patients.199 In the United Kingdom, the National Institute for
Health Care and Excellence has published guidelines for outpatient treatment of schizophrenia and has published multimorbidity guidelines (www.nice.org.uk/guidance). The National
Health Care for the Homeless Council in the US has adapted best
practices to support front-line workers caring for homeless
populations.200
How is this guideline different?
This guideline distills initial steps and evidence-based
approaches, to both homeless and vulnerably housed people,
with the assistance of patients and other stakeholders. It also
introduces a new clinical lens with upstream interventions that
provide a social and health foundation for community integration. Its initial steps support the vision of the Centre for Homelessness Impact in the UK, which envisions a society where the
experience of homelessness, in instances where it cannot be prevented, is only ever rare, brief and nonrecurrent.201 Finally, we
hope that our stakeholder engagement inspires and equips
future students, health providers and the public health community to implement the initial step recommendations.
Gaps in knowledge
Evidence-based policy initiatives will need to address the accelerating health and economic disparities between homeless and general
housed populations. As primary care expands its medical home
models,27 there will be a research opportunity for more traumainformed care202 to support the evidence-based interventions in
this guideline. Indeed, clinical research can refine how providers
use the initial steps protocol: housing, income, case management
and addiction. With improved living conditions, care coordination
and continuity of care, research and practice can shift to treatable
conditions, such as HIV and HCV infection, substance use disorder,
mental illness and tuberculosis.203
Medical educators will also need to develop new training
tools to support the delivery of interventions. Curricula and training that support the delivery of interventions, such as traumainformed and patient-centred care, will also be needed.12 Many
of the recommended interventions in this guideline rely on collaboration of community providers, housing coordinators and
case management. Interdisciplinary primary care research and
maintenance of linkages to primary care will benefit from new
homeless health clinic networks. Monitoring transitions in care
and housing availability will be an important research goal for
Canada’s National Housing Strategy and the associated Reaching
Home program.
Conclusion
Homelessness has become a health emergency. Initial steps in
addressing this crisis proposed in this guideline include strongly
recommending PSH as an urgent intervention. The guideline also
recognizes the trauma, disability, mental illness and stigma
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facing people with lived homelessness experience and thus recommends initial steps of income assistance, intensive case management for mental illness, and harm-reduction and addictiontreatment interventions, including access to opioid agonist
therapy and supervised consumption facilities.
The successful implementation of this guideline will depend
on a focus on the initial recommendations, trust, patient safety
and an ongoing collaboration between primary health care,
mental health providers, public health, people with lived experience and broader community organizations, including those
beyond the health care field.
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Competing interests: Gary Bloch is a founding member, former board
member and currently a clinician with Inner City Health Associates
(ICHA), a group of physicians working with individuals experiencing
homelessness in Toronto, which provided funding for the development
of this guideline. He did not receive payment for work on the guideline
and did not participate in any ICHA board decision-making relevant to
this project. Ritika Goel, Michaela Beder and Stephen Hwang also receive payment for clinical services from ICHA, and did not receive
payment for any aspect of the submitted work. No other competing interests were declared.
This article has been peer reviewed.
Affiliations: C.T. Lamont Primary Health Care Research Centre (Pottie,
d Wendy Muckle led
the Homeless Health Summit. Esther Shoemaker led the Delphi consensus. Olivia Magwood led the reviews on lived experiences and substance
use, Tim Aubry led the review on housing, Gary Bloch and Vanessa Brcic
led the review on income, David Ponka and Eric Agbata led the review
on case management, Jean Zhuo Jing Wang and Sebastian Mott led the
homeless youth review, Harneel Kaur led the homeless migrant review,
Christine Mathew and Anne Andermann led the homeless women
review, Syeda Shanza Hashmi and Ammar Saad led medical student
engagement and competency review, Thomas Piggott co-led the GRADE
Assessment with Olivia Magwood and Kevin Pottie, Michaela Beder and
Nicole Kozloff contributed substantially to the substance use review,
and Neil Arya and Stephen Hwang provided critical policy information.
All of the named authors engaged in the writing and review, gave final
approval of the version of the guideline to be published, and agreed to
be accountable for all aspects of the work.
Funding: This guideline was supported by a peer-reviewed grant from
the Inner City Health Associates, and supplemental project grants from
the Public Health Agency of Canada, Employment Social Development
Canada, Canadian Medical Association and Champlain Local Integrated
Health Network. Personnel from collaborating agencies provided nonbinding feedback during the preparation of systematic reviews and the
guideline. The funders had no role in the design or conduct of the study;
collection, analysis and interpretation of the data; or preparation,
review or final approval of the guideline. Final decisions regarding the
protocol and issues that arose during the guideline-development process were solely the responsibility of the guideline steering committee.
Acknowledgements: The authors thank everyone who participated in
the development of this guideline, including community scholars, technical team leads, guideline panel members and working group members.
Endorsements: Canadian Medical Association, Canadian Public Health
Association, Canadian Federation of Medical Students, The College of
Family Physicians of Canada, Public Health Physicians of Canada, Canadian Association of Emergency Physicians, The Canadian Alliance to
End Homelessness, Canadian Nurses Association
Disclaimer: The views expressed herein do not necessarily represent
the views of the funding agencies.
Correspondence to: Kevin Pottie, kpottie@uottawa.ca
The Canadian Medical Association (CMA) appreciates this opportunity to respond to the notice as published in the Canada Gazette, Part 1 for interested stakeholders to provide comments on Health Canada’s intent to establish a single set of regulations under the authorities of the Tobacco and Vaping Products Act (TVPA) and the Canada Consumer Product Safety Act (CCPSA) with respect to the labelling and packaging of vaping products.1
Canada’s physicians, who see the devastating effects of tobacco use every day in their practices, have been working for decades toward the goal of a smoke-free Canada. The CMA issued its first public warning concerning the hazards of tobacco in 1954 and has continued to advocate for the strongest possible measures to control its use.
The CMA has always supported strong, comprehensive tobacco control legislation, enacted and enforced by all levels of government, and we continue to do so. This includes electronic cigarettes (e-cigarettes). Our approach to tobacco and vaping products is grounded in public health policy. We believe it is incumbent on all levels of government in Canada to continue working on comprehensive, coordinated and effective tobacco control strategies, including vaping products, to achieve the goal of reducing smoking prevalence.
Introduction
In our most recent brief, the CMA expressed its concerns regarding vaping and youth. This included marketing, flavours, nicotine levels, and reducing vaping and e-cigarette use among youths.2 In April 2019, the Council of Chief Medical Officers of Health expressed alarm at the rising number of Canadian youths who are vaping, having found this trend “very troubling.”3 The CMA concurred with this assessment and supports Health Canada’s intention to further tighten the regulations.2
Identifying Vaping Substances
The findings of a recent Canadian study indicate an increase in vaping among adolescents in Canada and the United States.4 The growing acceptance of this practice is of concern to the CMA because of the rapidly emerging popularity of vaping products such as JUUL® and similar devices.4 It will be very important to identify clearly on the packaging all the vaping substances contained therein, along with a list of ingredients, as not enough is known about the long-term effects users may face.5,6 Users need to know what they are consuming so they can make informed choices about the contents. Studies have found substances in e-cigarette liquids and aerosols such as “nicotine, solvent carriers (PG and glycerol), tobacco-specific nitrosamines (TSNAs), aldehydes, metals, volatile organic compounds (VOCs), phenolic compounds, polycyclic aromatic hydrocarbons (PAHs), flavorings, tobacco alkaloids, and drugs.”7
Nicotine Content
As Hammond et al noted in their recent study, “JUUL® uses benzoic acid and nicotine salt technology to deliver higher concentrations of nicotine than conventional e-cigarettes; indeed, the nicotine concentration in the standard version of JUUL® is more than 50 mg/mL, compared with typical levels of 3-24 mg/mL for other e-cigarettes.”4 The salts and flavours available to be used with these devices reduce the harshness and bitterness of the taste of the e-liquids. Some of its competition deliver even higher levels of nicotine.8
The CMA has expressed its concerns about the rising levels of nicotine available through the vaping process.2 They supply “high levels of nicotine with few of the deterrents that are inherent in other tobacco products. Traditional e-cigarette products use solutions with free-base nicotine formulations in which stronger nicotine concentrations can cause aversive user experiences.”9
The higher levels of nicotine in vaping devices is also of concern because it “affects the developing brain by increasing the risk of addiction, mood disorders, lowered impulse control, and cognitive impairment.”10,11 The CMA has called on Health Canada to restrict the level of nicotine in vaping products to avoid youth (and adults) from developing a dependence.2
4
Health Warnings
The CMA reiterates, again, its position that health warnings for vaping should be similar to those for tobacco packages.12,13 We support placing warning labels on all vaping products, regardless of the size of the package. The “space given to the warnings should be sufficient to convey the maximum amount of information while remaining clear, visible, and legible. The warnings should be in proportion to the packaging available.”13 The need for such cautions is important as there is still much that is not known about the effects vaping can have on the human body.
A US study found “evidence that using combusted tobacco cigarettes alone or in combination with e-cigarettes is associated with higher concentrations of potentially harmful tobacco constituents in comparison with using e-cigarettes alone.”14 Some researchers have found that there is “significant potential for serious lung toxicity from e-cig(arette) use.”15,16
Another recent US study indicates that “adults who report puffing e-cigarettes, or vaping, are significantly more likely to have a heart attack, coronary artery disease and depression compared with those who don’t use them or any tobacco products.”17 Further, it was found that “compared with nonusers, e-cigarette users were 56 percent more likely to have a heart attack and 30 percent more likely to suffer a stroke.17
A worrisome development has emerged in the United States. The Centers for Disease Control and Prevention is working in consultation with the states of Wisconsin, Illinois, California, Indiana, and Minnesota regarding a “cluster of pulmonary illnesses linked to e-cigarette product use, or “vaping,” primarily among adolescents and young adults.”18 Additional possible cases have been identified in other states and are being investigated.
Child-Resistant Containers
The CMA supports the need for child-resistant containers in order to enhance consumer safety; we have adopted a similar position with respect to cannabis in all forms.19,20 The need to include warning labels should reinforce the need for packaging these vaping products such that they will be inaccessible to small children.
Recommendations
1. The CMA recommends more research into the health effects of vaping as well as on the components of the vaping liquids.
2. Health Canada should work to restrict the level of nicotine available for vaping products to avoid youth and adults from developing a dependence.
3. The CMA reiterates its position that health warnings for vaping should be like those being considered for tobacco packages. We support the proposed warning labels being placed on all vaping products.
4. The CMA recommends that all the vaping substances be identified clearly on the packaging, along with a list of ingredients.
5. The CMA supports the need for child-resistant containers.
5
1 Government of Canada. Canada Gazette, Part I, Volume 153, Number 25: Vaping Products Labelling and Packaging Regulations. Ottawa: Government of Canada; 2019. Available: http://gazette.gc.ca/rp-pr/p1/2019/2019-06-22/html/reg4-eng.html (accessed 2019 Jul 10).
2 Canadian Medical Association (CMA). Health Canada Consultation on Reducing Youth Access and Appeal of Vaping Products. Ottawa: CMA; 2019 May 24. Available: https://policybase.cma.ca/en/permalink/policy14078 (accessed 2019 Jul 10).
3 Public Health Agency of Canada. Statement from the Council of Chief Medical Officers of Health on the increasing rates of youth vaping in Canada. Ottawa: Health Canada; 2019. Available: https://www.newswire.ca/news-releases/statement-from-the-council-of-chief-medical-officers-of-health-on-the-increasing-rates-of-youth-vaping-in-canada-812817220.html (accessed 2019 Jul 24).
4 Hammond David, Reid Jessica L, Rynard Vicki L, et al. Prevalence of vaping and smoking among adolescents in Canada, England, and the United States: repeat national cross sectional surveys BMJ. 2019; 365:2219. Available: https://www.bmj.com/content/bmj/365/bmj.l2219.full.pdf (accessed 2019 Jul 24).
5 WHO Report on the Global Tobacco Epidemic, 2019. Geneva: World Health Organization; 2019. Available: https://apps.who.int/iris/bitstream/handle/10665/326043/9789241516204-eng.pdf?ua=1 (accessed 2019 Jul 30).
6 Dinakar, C., O’Connor GT. The Health Effects of Electronic Cigarettes. N Engl J Med. 2016;375:1372-81. Available: https://www.nejm.org/doi/full/10.1056/NEJMra1502466 (accessed 2019 Jul 30).
7 National Academies of Sciences, Engineering, and Medicine. Public health consequences of e-cigarettes. Washington, DC: The National Academies Press; 2018. Available: https://www.nap.edu/catalog/24952/public-health-consequences-of-e-cigarettes (accessed 2019 Jul 29).
8 Jackler RK, Ramamurthi D. Nicotine arms race: JUUL and the high-nicotine product market Tob Control 2019;0:1–6.
9 Barrington-Trimis JL, Leventhal AM. Adolescents’ Use of “Pod Mod” E-Cigarettes —Urgent Concerns. N Engl J Med 2018; 379:1099-1102. Available: https://www.nejm.org/doi/pdf/10.1056/NEJMp1805758?articleTools=true (accessed 2019 Jul 30).
10 Chen-Sankey JC, Kong G, Choi K. Perceived ease of flavored e-cigarette use and ecigarette use progression among youth never tobacco users. PLoS ONE 2019;14(2): e0212353. Available: https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0212353 (accessed 2019 Jul 30).
11 U.S. Department of Health and Human Services. E-Cigarette Use Among Youth and Young Adults. A Report of the Surgeon General. Atlanta, GA: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Center for Chronic Disease Prevention and Health Promotion, Office on Smoking and Health; 2016. Available: https://e-cigarettes.surgeongeneral.gov/documents/2016_sgr_full_report_non-508.pdf (accessed 2019 Jul 30).
12 Canadian Medical Association (CMA) CMA’s Recommendations for Bill S-5: An Act to amend the Tobacco Act and the Non-smokers’ Health Act and to make consequential amendments to other Acts. Ottawa: CMA; 2017 Apr 7. Available: https://policybase.cma.ca/en/permalink/policy13641 (accessed 2019 Jul 30).
13 Canadian Medical Association. Health Canada consultation on tobacco products regulations (plain and standardized appearance) Ottawa: CMA; 2018 Sep 6. Available: https://policybase.cma.ca/en/permalink/policy13930 (accessed 2019 Jul 30).
14 Goniewicz ML. et al. Comparison of Nicotine and Toxicant Exposure in Users of Electronic Cigarettes and Combustible Cigarettes JAMA Network Open. 2018;1(8):e185937. Available: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2718096 (accessed 2019 Jul 30).
15 Chan LF. Et al. Pulmonary toxicity of e-cigarettes Am J Physiol Lung Cell Mol Physiol. 313: L193–L206, 2017 Available: https://www.physiology.org/doi/pdf/10.1152/ajplung.00071.2017 (accessed 2019 Jul 30).
16 Li D, Sundar IK, McIntosh S, et al. Association of smoking and electronic cigarette use with wheezing and related respiratory symptoms in adults: cross-sectional results from the Population Assessment of Tobacco and Health (PATH) study, wave 2. Tob Control. 0:1-8, 2019.
17 American College of Cardiology. E-Cigarettes Linked to Heart Attacks, Coronary Artery Disease and Depression. Media Release March 7, 2019 Available: https://www.acc.org/about-acc/press-releases/2019/03/07/10/03/ecigarettes-linked-to-heart-attacks-coronary-artery-disease-and-depression (accessed 2019 Jul 30).
18 Centers for Disease Control and Prevention. CDC, states investigating severe pulmonary disease among people who use e-cigarettes. Media Statement 2019 Aug 17. Available: https://www.cdc.gov/media/releases/2019/s0817-pulmonary-disease-ecigarettes.html (accessed 2019 Aug 20).
19 Canadian Medical Association (CMA). Health Canada Consultation on Edible Cannabis, Extracts & Topicals Ottawa: CMA; 2019 Feb 20. Available: https://policybase.cma.ca/en/permalink/policy14020 (accessed 2019 Aug 6).
20 Canadian Medical Association (CMA). Proposed Approach to the Regulation of Cannabis Submission to Health Canada. 2018 Jan 19 Available: https://policybase.cma.ca/en/permalink/policy13838. (accessed 2019 Aug 6).
The Canadian Medical Association (CMA) appreciates this opportunity to respond to Health Canada’s consultation on potential markets for cannabis health products that would not require practitioner oversight.1
The CMA’s approach to cannabis is grounded in public health policy. It includes promotion of health and
prevention of problematic use; access to assessment, counseling and treatment services; and a harm reduction perspective. The CMA endorsed the Lower-Risk Cannabis Use Guidelines2 and has expressed these views in our recommendations to the Task Force on Cannabis Legalization and Regulation,3 and recommendations regarding Bill C-45.4 As well, we submitted comments to Health Canada with respect to the consultation on the proposed regulatory approach for the Cannabis Act, Bill C-45.5 We also responded to Health Canada’s recent Consultation on Edible Cannabis, Extracts & Topicals.6
Overview
The CMA first expressed its concerns about the sale of natural health products containing cannabis in our response to the proposed regulatory approach to the Cannabis Act, Bill C-45.5 We recognize that, in general, health products include prescription health products, non-prescription drugs, natural health products, cosmetics and medical devices. Although all these products are regulated by Health Canada, they are subject to different levels of scrutiny for safety, efficacy and quality, and in some cases, industry does not need to provide scientific evidence to support the claims made on the label.
Health Claims
As with all health products, the CMA supports an approach in which higher risk products, that is, those for which health claims are made, must be subject to a more meticulous standard of review. Rigorous scientific evidence is needed to support claims of health benefits and to identify potential risks and adverse reactions.
We support Health Canada’s proposal that authorized health claims for cannabis health products (CHP) would be permitted for treatment of minor ailments, on the strict condition they are substantiated via a strong evidentiary process. It is the view of the CMA that all such products making a health claim must be reviewed thoroughly for efficacy, as well as safety and quality, for the protection of Canadians.5
Recent experience in the United States supports this approach. A warning letter was sent to Curaleaf Inc. of Wakefield, Massachusetts, by the US Food and Drug Administration (FDA) “for illegally selling unapproved products containing cannabidiol (CBD) online with unsubstantiated claims that the products treat cancer, Alzheimer’s disease, opioid withdrawal, pain and pet anxiety, among other conditions or diseases.”7
This is not the first time it was necessary for the FDA to take such action. The agency had sent letters on previous occasions to other businesses over claims “to prevent, diagnose, treat, or cure serious diseases, such as cancer. Some of these products were in further violation of the Federal Food, Drug and Cosmetic Act because they were marketed as dietary supplements or because they involved the addition of CBD to food.”7
The CMA shares the FDA’s concerns that such claims “can put patients and consumers at risk by leading them to put off important medical care.”7 A study conducted by Dalhousie University found that only 35.8% of respondents were familiar with the biochemical properties of CBD when asked what cannabinoid they thought was potentially a pain killer.8 Systematic reviews and guidelines have highlighted the state of the science and the limited indications for which there is evidence.9,10,11
Both cannabis and CBD specifically have been approved for use in a few conditions, but more research is needed in this rapidly growing field. For example, medical cannabinoids have been approved in several jurisdictions for the treatment of multiple sclerosis but the evidence of how well it works is limited. As the Canadian authors note, “carefully conducted, high-quality studies with thought given to the biologic activity of different cannabis components are still required to inform on the benefits of cannabinoids for patients with MS.”12 Consumers need to be reassured that health claims are being assessed thoroughly so they can make informed decisions.13
4
Packaging and Labelling Requirements
The CMA has laid out its position with respect to packaging and labelling with respect to cannabis products.5,6 Strict packaging requirements are necessary as their wider availability raises several public health issues, not the least of which is ingestion by young children. Requirements for tamper-resistant and child-proof containers need to be in place to enhance consumer safety. To reiterate:
a requirement for plain and standard packaging
prohibition of the use of appealing flavours and shapes,
a requirement for adequate content and potency labelling,
a requirement for comprehensive health warnings,
a requirement for childproof packaging, and
a requirement that the content in a package should not be sufficient to cause a poisoning
Prescription Drugs Containing Cannabis
The CMA addressed prescription drugs containing cannabis in a previous brief.5 The level of proof required to obtain a Drug Identification Number (DIN) for prescription drugs is considerably higher than the level of proof required for a Natural Product Number (NPN); rigorous scientific evidence to support claims of efficacy is needed for a DIN but not for an NPN. Consumers generally do not know about this distinction, believing that Health Canada has applied the same level of scrutiny to the health claims made for every product. As a result, consumers presently do not have enough information to choose appropriate products.
Prescription drugs are subject to Health Canada’s pharmaceutical regulatory approval process, based on each drug’s specific indication, dose, route of administration and target population. Health claims need to be substantiated via a strong evidentiary process. All potential prescription medications containing cannabis must meet a high standard of review for safety, efficacy and quality, equivalent to that of the approval of prescription drugs (e.g., Marinol® and Sativex®), to protect Canadians from further misleading claims.
The CMA urges caution especially around exemptions for paediatric formulations that would allow for traits that would “appeal to youth.” The CMA understands that these products, used under strict health professional supervision, should be child friendly, for example, regarding palatability, but we do not support marketing strategies that would suggest their use is recreational (e.g., producing them in candy or animal formats).
Recommendations
1. The CMA recommends that all cannabis health products, including those with CBD, making a health claim must be reviewed thoroughly for efficacy, as well as safety and quality, for the protection of Canadians.
2. The CMA recommends that strict packaging requirements be put in place with respect cannabis health products as their wider availability raises several public health issues, not the least of which is ingestion by young children.
3. The CMA recommends tamper-resistant and child-proof containers need to be in place to enhance consumer safety.
4. The CMA recommends that all potential prescription medications containing cannabis must meet a high standard of review for safety, efficacy and quality, equivalent to that of the approval of prescription drugs to protect Canadians from further misleading claims.
5
1Health Canada. Document: Consultation on Potential Market for Cannabis Health Products that would not Require Practitioner Oversight. Ottawa: Health Canada; 2019. Available: https://www.canada.ca/en/health-canada/programs/consultation-potential-market-cannabis/document.html (accessed 2019 Aug 8).
2 Fischer B, Russell C, Sabioni P, et al. Lower-risk cannabis use guidelines: A comprehensive update of evidence and recommendations. AJPH. 2017 Aug;107(8):e1-e12. Available: https://ajph.aphapublications.org/doi/abs/10.2105/AJPH.2017.303818?url_ver=Z39.88-2003&rfr_id=ori%3Arid%3Acrossref.org&rfr_dat=cr_pub%3Dpubmed&. (accessed 2019 Aug 8).
3 Canadian Medical Association (CMA). Legalization, regulation and restriction of access to marijuana. CMA submission to the Government of Canada – Task Force on cannabis, legalization and regulation. Ottawa: CMA; 2016 Aug 29. Available: https://policybase.cma.ca/en/permalink/policy11954 (accessed 2019 Aug 8).
4 Canadian Medical Association (CMA). Bill C-45: The Cannabis Act. Submission to the House of Commons Health Committee. Ottawa: CMA; 2017 Aug 18. Available: https://policybase.cma.ca/en/permalink/policy13723
(accessed 2019 Aug 8).
5 Canadian Medical Association (CMA). Proposed Approach to the Regulation of Cannabis. Ottawa: CMA; 2018 Jan 19. Available: https://policybase.cma.ca/en/permalink/policy13838 (accessed 2019 Aug 8).
6 Canadian Medical Association (CMA). Health Canada Consultation on Edible Cannabis, Extracts & Topicals Ottawa: CMA; Available: https://policybase.cma.ca/en/permalink/policy14020 (accessed 2019 Aug 8).
7 Food and Drug Administration (FDA). FDA warns company marketing unapproved cannabidiol products with unsubstantiated claims to treat cancer, Alzheimer’s disease, opioid withdrawal, pain and pet anxiety. Media Release. Silver Spring, MD: FDA; 2019 Jul 23. Available: https://www.fda.gov/news-events/press-announcements/fda-warns-company-marketing-unapproved-cannabidiol-products-unsubstantiated-claims-treat-cancer (accessed 2019 Aug 15).
8 Charlebois S., Music J., Sterling B. Somogyi S. Edibles and Canadian consumers’ willingness to consider recreational cannabis in food or beverage products: A second assessment. Faculty of Management: Dalhousie University; May, 2019 Available: https://cdn.dal.ca/content/dam/dalhousie/pdf/management/News/News%20%26%20Events/Edibles%20and%20Canadian%20Consumers%20English_.pdf (accessed 2019 Aug 20).
9 Allan GM. Et al. Simplified guideline for prescribing medical cannabinoids in primary care. Canadian Family Physician. Feb 2018;64(2):111. Available: https://www.cfp.ca/content/cfp/64/2/111.full.pdf (accessed 2019 Aug 29).
10 Health Canada. Information for Health Care Professionals. Cannabis (marihuana, marijuana) and the cannabinoids) Dried or fresh plant and oil administration by ingestion or other means Psychoactive agent. Ottawa: Health Canada; October 2018. Available: https://www.canada.ca/content/dam/hc-sc/documents/services/drugs-medication/cannabis/information-medical-practitioners/information-health-care-professionals-cannabis-cannabinoids-eng.pdf (accessed 2019 Aug 29).
11 National Academies of Sciences, Engineering, and Medicine. The health effects of cannabis and cannabinoids: Current state of evidence and recommendations for research. Washington, DC: The National Academies Press; 2017. Available: http://www.nationalacademies.org/hmd/reports/2017/health-effects-of-cannabis-and-cannabinoids.aspx (accessed 2019 Aug 29).
12 Slaven M., Levine O. Cannabinoids for Symptoms of Multiple Sclerosis JAMA Network Open. 2018;1(6):e183484. Available: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2706491 (accessed 2019 Aug 26).
13 Food and Drug Administration (FDA). What You Need to Know (And What We’re Working to Find Out) About Products Containing Cannabis or Cannabis-derived Compounds, Including CBD Consumer Updates. Silver Spring, MD: FDA; 2019 July 17. Available: https://www.fda.gov/consumers/consumer-updates/what-you-need-know-and-what-were-working-find-out-about-products-containing-cannabis-or-cannabis (accessed 2019 Aug 29).
The Canadian Medical Association (CMA) is pleased to provide the House of Commons Standing Committee on Finance this pre-budget submission. It provides recommendations to address major pan-Canadian challenges to the health of Canadians: improve how we provide care to our growing elderly population; improve access to primary care across the country; increase digital health literacy to take advantage of the benefits of new health information technologies; and better prepare for and mitigate the health impacts of a changing climate on Canadians.
Seniors Care
Health systems across the country are currently struggling to meet the needs of our aging population. People aged 85 years and over—many of whom are frail—make up the fastest growing age group in Canadai.
Provincial and territorial health care systems (as well as care systems for populations falling under federal jurisdiction) are facing many challenges to meet the needs of an aging population. Canadians support a strong role for the federal government in leading a national seniors strategy and working with the provinces to ensure that all Canadians have the same level of access and quality of services, no matter where they live.
The 2017 federal/provincial/territorial funding agreement involving $6 billion over 10 years to improve access to home care services is a welcomed building block. But without greater investment in seniors care, health systems will not keep up. To be truly relevant and effectively respond to Canadians’ present and future needs, our health care system must provide integrated, continuing care able to meet the chronic and complex care needs of our growing and aging population. This includes recognizing the increased role for patients and their caregivers in the care process.
The federal government must ensure transfers are able to keep up with the real cost of health care. Current funding levels clearly fail to do so. Health transfers are estimated to rise by 3.6% while health care costs are expected to rise by 5.1% annually over the next decade.ii
Recommendation:
The federal government ensure provincial and territorial health care systems meet the care needs of their aging populations by means of a demographic top-up to the Canada Health Transfer.iii
Providing care often comes with a financial cost such as lost income due to the caregiver’s withdrawal from the workforce to provide care. There are also increasing out-of-pocket costs for both caregivers and care receivers for health care-related expenses—privately covered expenditures on home and long-term care for seniors are projected to grow by an average of 5.8 per cent annually—nearly 1.5 times the pace of household disposable income growth. While the federal government offers tax credits that can be claimed by care receivers/caregivers, they are significantly under-utilized. While representing a significant proportion of caregivers, those with low or no income receive little to no federal government support through these programs. Middle-income earners also receive less than those earning high incomes.
4
Recommendation:
The federal government create a Seniors Care Benefit that would be an easier, fairer and more effective way to support caregivers and care receivers alike.iv
Access to Care
Since the mid-1990s, the federal and provincial/territorial governments (FPT) have provided sustained leadership in promoting and supporting the transformation of primary care in Canada. In 2000, the First Ministers concluded the first of three Health Accords in which they agreed to promote the establishment of primary health care teamsv supported by a $800 million Primary Health Care Transition Fund (PHCTF) funded by the federal government, but jointly governed. The PHCTF resulted in large-scale sustained change in primary care delivery models in Ontario, Quebec and Alberta with interest in other jurisdictions as well.
However, the job is far from finished. Across Canada, access to primary care is challenging for many Canadians with a persistent shortage of family physicians. In 2017, 4.7 million Canadians aged 12+ reported they did not have a regular health care provider.vi Even those who have a regular provider experience wait time issues.
There has been widespread interest in primary care models since the development of the College of Family Physicians of Canada’s (CFPC) vision document Family Practice: The Patient’s Medical Home (PMH), initially launched in 2011vii and recently re-launched.viii The model is founded on 10 pillars depicted in Figure 1.
Figure 1. The Patient’s Medical Home, 2019
The updated model places increased emphasis on team-based care and introduces the concept of the patient’s medical neighborhood that sets out connections between the primacy care practice and all delivery points in the surrounding community. While comprehensive baseline data are lacking, it seems
5
safe to conjecture that most Canadians are not enrolled in a primary care model that would measure up to the model’s 10 pillars.
Recommendation:
The federal government, in concert with provinces and territories, establish a targeted fund in the amount of $1.2 billion to support a new time-limited Primary Health Care Transition Fund that would build on the success of the fund launched in 2000 with the goal of widely introducing a sustainable medical home model across jurisdictions. This would include the following key elements:
Age-sex-weighted per capita allocation across the provinces and territories;
Joint governance of the FPT governments with meaningful stakeholder engagement;
Respect for the Canada Health Act principles;
Common objectives (e.g., modeled on the CFPC Patient’s Medical Home framework);
Sustainability plans.
Digital/Virtual Care
Canada and most industrialized countries will experience a digital health revolution over the next decade with great potential to improve patient and population health. Digital health can be described as the integration of the electronic collection and compilation of health data, decision support tools and analytics with the use of audio, video and other technologies to deliver preventive, diagnostic and treatment services that promote patient and population health.
While most Canadian physicians’ offices and health care facilities are now using some form of electronic record keeping and most households have internet access, there remains a large deficit in using virtual care, both within jurisdictions and across provincial/territorial boundaries. Recently the CMA, the Royal College of Physicians and Surgeons of Canada and the College of Family Physicians of Canada established a Virtual Care Task Force to identify opportunities for digital health to improve health care delivery, including what regulatory changes are required for physicians to deliver care to patients within and across provincial/territorial boundaries.
To take full advantage of digital health capabilities it will be essential for the population to have a functional level of digital health literacy: the ability to seek, find, understand and appraise health information from electronic sources and apply the knowledge gained to addressing or solving a health problem.ix This also includes the capability of communicating about one’s health to health care professionals (e.g., e-consults), self-monitoring health (e.g., patient portals) and receiving treatment online (e.g., Web-based cognitive behavioral therapy).x
There are no current data available on health literacy in Canada, let alone digital health literacy. One basic barrier to achieving digital health literacy is access to, and usage of the Internet, which has been termed the “digital divide” (e.g., older Canadians and low income households are less likely to have Internet access).Error! Bookmark not defined.
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In 2001 the federal government established the Financial Consumer Agency of Canada (FCAC). Its mandate includes informing consumers about their rights and responsibilities in dealing with financial institutions and providing information and tools to help consumers understand and shop for financial products and services.xi In 2014 the FCAC appointed a Financial Literacy Leader who has focused on financial literacy, including activities such as conducting financial capability surveys and the development of a National Strategy for Financial Literacy.xii
Considering the anticipated growth of digital/virtual care it would be desirable to understand and promote digital health literacy across Canada. What the federal government has done for financial literacy could serve as a template for digital health literacy.
Recommendation:
The federal government establish a Digital Health Literacy Secretariat to:
Develop indicators and conducting surveys to measure and track the digital health literacy of Canadians;
Develop tools that can be used both by Canadians and their health care providers to enhance their digital health literacy; and
Assess and make recommendations on the “digital divide” that may exist among some population sub-groups due to a lack of access to information technology and lower digital health literacy.
Climate Change and Health
Climate change is the public health imperative of our time. There is a high level of concern among Canadians about their changing climate. A 2017 poll commissioned by Health Canada demonstrates a high level of concern among Canadians about their changing climate: 79% were convinced that climate change is happening, and of these, 53% accepted that it is a current health risk, with 40% believing it will be a health risk in the future.
The World Health Organization (WHO) has identified air pollution and climate change as one of the biggest threats to global health. Health care professionals see first-hand the devastating health impacts of our changing climate including increased deaths from fine particulate matter air pollution and increased heat-related conditions. Impacts are most common in vulnerable populations such as adults over 65 years, the homeless, urban dwellers and people with a pre-existing disease.
Canada’s health care system is already treating the health effects of climate change. A lack of progress in reducing emissions and building adaptive capacity threatens both human lives and the viability of Canada’s health system, with the potential to disrupt core public health infrastructure and overwhelm health services, not to mention the economic and social costs. The federal government must provide leadership to deal with the impact already being felt in Canada and around the world.
Recommendation:
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The federal government make strong commitments to minimize the impact of climate change on the health of Canadians by:
Ensuring pan-Canadian and inter-jurisdictional coordination to standardize surveillance and reporting of climate-related health impacts such as heat-related deaths, develop knowledge translation strategies to inform the public, and generate clinical and public health response plans that minimize the health impacts;
Increasing funding for research on the mental health impacts of climate change and psychosocial adaptation opportunities; and
Ensuring funding is provided to the health sector to prepare for climate change impacts through efforts to increase resiliency (i.e., risk assessments, readiness to manage disease outbreaks, sustainable practice).
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i Statistics Canada. The Chief Public Health Officer's Report on the State of Public Health in Canada, 2014: Public Health in the Future. Ottawa: Statistics Canada; 2015. Available: http://www.phac-aspc.gc.ca/cphorsphc-respcacsp/2014/chang-eng.php; (accessed 2016 Sep 19).
ii The Conference Board of Canada. Meeting the care needs of Canada’s aging population. Ottawa: The Conference Board; 2018.
iii Canadian Medical Association. Meeting the demographic challenge: Investments in seniors care. Pre-budget submission to the House of Commons Standing Committee on Finance. August 3, 2018. https://policybase.cma.ca/documents/Briefpdf/BR2018-16.pdf
iv The Conference Board of Canada. Measures to Better Support Seniors and Their Caregivers. March 2019. https://www.cma.ca/sites/default/files/pdf/health-advocacy/Measures-to-better-support-seniors-and-their-caregivers-e.pdf
v Canadian Intergovernmental Conference Secretariat. News release – First Ministers’ meeting communiqué on health. September 11, 2000. http://www.scics.ca/en/product-produit/news-release-first-ministers-meeting-communique-on-health/. Accessed 04/22/19.
vi Statistics Canada. Primary health care providers, 2017. https://www150.statcan.gc.ca/n1/en/pub/82-625-x/2019001/article/00001-eng.pdf?st=NGPiUkM5. Accessed 04/21/19.
vii College of Family Physicians of Canada. A vision for Canada. Family Practice: the patient’s medical home. http://www.cfpc.ca/uploadedFiles/Resources/Resource_Items/PMH_A_Vision_for_Canada.pdf. Accessed 04/22/19.
viii College of Family Physicians of Canada. The patient’s medical home 2019. https://patientsmedicalhome.ca/files/uploads/PMH_VISION2019_ENG_WEB_2.pdf. Accessed 04/21/19.
ix Norman C, Skinner H. eHealth literacy: essential skills for consumer health in a networked world. J Med Internet Res 2006;8(2):e9. Doi:10.2196/jmir.8.2.e9.
x Van der Vaart R, Drossaert C. Development of the digital health literacy instrument: measuring a broad spectrum of health 1.0 and health 2.0 skills. J Med Internet Res. 2017;19(1):e27. Doi:10.2196/jmir.6709.
xi Financial Consumer Agency of Canada. About FCAC.
xii Financial Consumer Agency of Canada. National Strategy for Financial Literacy. Phase 1: strengthening seniors’ financial literacy. https://www.canada.ca/content/dam/canada/financial-consumer-agency/migration/eng/financialliteracy/financialliteracycanada/documents/seniorsstrategyen.pdf. Accessed 06/24/19. https://www.canada.ca/en/financial-consumer-agency/corporate/about.html. Accessed 07/01/19.
The Canadian Medical Association (CMA) appreciates this opportunity to respond to Health Canada’s consultation on Reducing Youth Access and Appeal of Vaping Products - Consultation on Potential Regulatory Measures.1
Canada’s physicians, who see the devastating effects of tobacco use every day in their practices, have been working for decades toward the goal of a smoke-free Canada. The CMA issued its first public warning concerning the hazards of tobacco in 1954 and has continued to advocate for the strongest possible measures to control its use.
The CMA has always supported strong, comprehensive tobacco control legislation, enacted and enforced by all levels of government, and we continue to do so. This includes electronic cigarettes (e-cigarettes). Our approach to tobacco and vaping products is grounded in public health policy. We believe it is incumbent on all levels of government in Canada to continue working on comprehensive, coordinated and effective tobacco control strategies, including vaping products, to achieve the goal of reducing smoking prevalence.
The CMA has stated its position to the federal government on electronic cigarettes and vaping clearly in recent years.2,3 In our April 2017 submission on Bill S-5 to the Senate Standing Committee on Social Affairs, Science and Technology we recommended that the restrictions on promotion of vaping products and devices should be the same as those for tobacco products.2 We also argued that the government should take the same approach to plain and standardized packaging regulations for e-cigarettes as has now been implemented for tobacco products.2
In our most recent brief we addressed the two main issues outlined in the government’s Notice of Intent with respect to the advertising of vaping products: the placement of that advertising and the use of health warnings.3,4 We expressed concerns that the proposed regulations leave too wide an opening for vaping manufacturers to promote their products, especially to youth. Further, we reiterated our position that health warnings for vaping should be like those being considered for tobacco packages.
This brief will address the issues of greatest concern to the CMA with respect to vaping and youth. This includes marketing, flavours, nicotine levels, and reducing vaping and e-cigarette use among youths.
Introduction
The Council of Chief Medical Officers of Health have expressed alarm at the rising number of Canadian youths who are vaping, finding this trend “very troubling.”5 The Canadian Medical Association concurs with this assessment and appeals to the federal government to move urgently on this important public health issue.
As our knowledge about the risks of using e-cigarettes increases, there is an even greater imperative to dissuade youth from taking up the habit. This is important because those youth “who believe that e-cigarettes are not harmful or are less harmful than cigarettes are more likely to use e-cigarettes than youth with more negative views of e-cigarettes.”6
Marketing
The e-cigarette marketplace is evolving quickly as new products emerge. The industry has made clever use of social media channels to promote their wares by taking advantage of the belief that they are a safer alternative to cigarettes.7 They have also promoted “innovative flavoring and highlighted the public performance of vaping.”7 It is no surprise that the United States Food and Drug Administration (FDA) has referred to youth vaping as an “epidemic,” calling it “one of the biggest public health challenges currently facing the FDA.”8 As the US National Academies of Sciences, Engineering, and Medicine has noted “young people who begin with e-cigarettes are more likely to transition to combustible cigarette use and become smokers who are at risk to suffer the known health burdens of combustible tobacco cigarettes.”9
However, some of the efforts employed to convince youth to take up vaping are especially troublesome. As the
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US Centers for Disease Control and Prevention (CDC) reported, “one in 5 (US) high school students and 1 in 20 middle school students reported using e-cigarettes in the past 30 days in 2018,” a significant rise in the number of high school students between 2011 and 2018.10 The use of social media campaigns employing “influencers” to capture more of the youth and young adult market or influence their choices shows the need to be especially vigilant.11 In an attempt to counter this influence, a group of over 100 public health and anti-tobacco organizations from 48 countries “are calling on Facebook, Instagram, Twitter and Snap to take “swift action” to curb advertising of tobacco products on their platforms.”12
As much as the industry is making major efforts to attract or sway customers through advertising, youth themselves may hold the key to countering that pressure. A recent US study found that “adolescents generally had somewhat negative opinions of other adolescents who use e-cigarettes. Building on adolescents’ negativity toward adolescent e-cigarette users may be a productive direction for prevention efforts, and clinicians can play an important role by keeping apprised of the products their adolescent patients are using and providing information on health effects to support negative opinions or dissuade formation of more positive ones.”13 Health Canada can play a major role in encouraging and facilitating peer-to-peer discussions on the risks associated with vaping and help to offset the social media influencers.14
We reiterate the concerns we expressed in our recent brief on the potential measures to reduce advertising of vaping products and to help diminish their appeal to youth. The CMA noted that the sections most problematic to the Association were those encompassing public places, broadcast media, and the publications areas.3 Vaping advertisements should not be permitted at all in any of these spaces, with no exceptions.3 These areas need to be addressed on an urgent basis.
Flavours
As of 2013, over 7,000 flavours had been marketed in the US.15 The data indicated that “about 85% of youth who used e-cigarettes in the past 30 days adopted non-tobacco flavors such as fruit, candy, and dessert.”15 Flavours are helpful in attracting youth, especially when coupled with assertions of lower harm.13 And they have been successful in doing so, as evidenced by the rise in the rates of vaping among youth.8, 16
The addition of a wide variety of flavours available in the pods makes them taste more palatable and less like smoking tobacco.16,17,18 The concern is that e-cigarettes “may further entice youth to experiment with e-cigarettes and boost e-cigarettes’ influence on increased cigarette smoking susceptibility among youth.”15 More worrisome, flavoured e-cigarettes “are recruiting females and those with low smoking-risk profile to experiment with conventional cigarettes.”19
Limiting the availability of “child-friendly flavors” should be considered to reduce the attraction of vaping to youth.19 In a recent announcement, the US FDA has proposed to tighten e-cigarette sales and “remove from the market many of the fruity flavors …blamed on fueling “epidemic” levels of teen use.”20 As we have noted in previous submissions, the CMA would prefer to see flavours banned to reduce the attractiveness of vaping to youth as much as possible, a sentiment shared by other expert groups. 2,3,21
Nicotine Levels
One of the most popular devices to vape with is JUUL™, entering the US market in 2015.22 JUUL’s™ nicotine pods contain 5% nicotine salt solution consisting of 59 mg/mL in 0.7 mL pods.17 Some of JUUL’s™ competition have pods containing even higher levels (6% and 7%).17
The CMA is very concerned about the rising levels of nicotine available through the vaping process, especially by the newer delivery systems. They supply “high levels of nicotine with few of the deterrents that are inherent in other tobacco products. Traditional e-cigarette products use solutions with free-base nicotine formulations in which stronger nicotine concentrations can cause aversive user experiences.”23
Nicotine, among other issues, “affects the developing brain by increasing the risk of addiction, mood disorders, lowered impulse control, and cognitive impairment.15,24 In addition to flavours, and to ease delivery and to make the taste more pleasant, nicotine salts are added to make the e-liquid “less harsh and less bitter” and “more
5
palatable despite higher nicotine levels.”17
Addressing the Rise in Youth Vaping
There are many factors that lead youth to experiment with vaping and e-cigarettes. For some it is simple curiosity, for others it is the availability of different flavours while still others perceive vaping as “cool,” especially when they can use the vapour to perform “smoke tricks.”25 The pod devices themselves (e.g., JUUL™) help enhance the allure because of the “unique aesthetic appeal of pod devices, ability to deliver nicotine at high concentrations and the convenience of using them quickly and discreetly.”26
As vaping continues to grow in popularity, it will not be easy to curb youths’ enthusiasm for it. However, it is too important of a public health issue to not intervene More research is needed into how youth perceive vaping and e-cigarettes as they do not hold a universally positive view of the habit.7,13 As well, there is evidence to suggest that many are coming to see vaping as being “uncool” and that there are potential health consequences to continued use.25
In view of the still-evolving evidence of the safety of vaping and e-cigarettes, “strategic and effective health communication campaigns that demystify the product and counteract misconceptions regarding e-cigarette use are needed.”25 Further, “to reduce youth appeal, regulation efforts can include restricting the availability of e-cigarette flavors as well as visible vapors.”25 Another approach to consider is the state of Colorado’s recent creation of “a health advisory recommending that health care providers screen all youth specifically for vaping, in addition to tobacco use, because young people may not necessarily associate tobacco with vaping.”27
Recommendations
1. The CMA calls for all vaping advertising to be strictly limited. The restrictions on the marketing and promotion of vaping products and devices should be the same as those for tobacco products.
2. The CMA recommends the limitation of number of flavours available to reduce the attractiveness of vaping to youth.
3. Health Canada should work to restrict the level of nicotine available for vaping products to avoid youth becoming addicted.
4. Health Canada must play a major role in encouraging and facilitating peer-to-peer discussions on the risks associated with vaping and help to offset the social media influencers.
5. Health Canada must develop communication campaigns directed at youth, parents and health care providers to demystify vaping and e-cigarettes and that create a link between tobacco and vaping.
1 Government of Canada. Reducing Youth Access and Appeal of Vaping Products - Consultation on Potential Regulatory Measures. Ottawa: Health Canada; 2019. Available: https://www.canada.ca/en/health-canada/programs/consultation-reducing-youth-access-appeal-vaping-products-potential-regulatory-measures.html (accessed 2019 Apr 11).
2 Canadian Medical Association (CMA). CMA’s Recommendations for Bill S-5: An Act to amend the Tobacco Act and the Nonsmokers’ Health Act and to make consequential amendments to other Acts. Ottawa: CMA; 2017 Apr 7. Available: https://policybase.cma.ca/en/permalink/policy13641 (accessed 2019 May 13).
3 Canadian Medical Association (CMA). Health Canada consultation on the impact of vaping products advertising on youth and non-users of tobacco products. Ottawa: CMA; 2019 Mar 22. Available: https://policybase.cma.ca/en/permalink/policy14022 (accessed 2019 May 13).
4 Government of Canada. Notice to Interested Parties – Potential Measures to Reduce the Impact of Vaping Products Advertising on Youth and Non-users of Tobacco Products. Ottawa: Health Canada; 2019. Available:
https://www.canada.ca/en/health-canada/programs/consultation-measures-reduce-impact-vaping-products-advertising-youthnon-users-tobacco-products.html (accessed 2019 Feb 27).
5 Public Health Agency of Canada. Statement from the Council of Chief Medical Officers of Health on the increasing rates of youth vaping in Canada. Health Canada; 2019. Available: https://www.newswire.ca/news-releases/statement-from-the-council-of-chief-medical-officers-of-health-on-the-increasing-rates-of-youth-vaping-in-canada-812817220.html (accessed 2019 May 14).
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6 Glantz SA. The Evidence of Electronic Cigarette Risks Is Catching Up with Public Perception. JAMA Network Open 2019;2(3):e191032. doi:10.1001/jamanetworkopen.2019.1032. Available: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2729460 (accessed 2019 May 14).
7 McCausland K., et al. The Messages Presented in Electronic Cigarette–Related Social Media Promotions and Discussion: Scoping Review. J Med Internet Res 2019;21(2):e11953). Available: https://www.jmir.org/2019/2/e11953/ (accessed 2019 May 14).
8 Food and Drug Administration (FDA). Statement from FDA Commissioner Scott Gottlieb, M.D., on new data demonstrating rising youth use of tobacco products and the agency’s ongoing actions to confront the epidemic of youth e-cigarette use. Silver Spring, MD: FDA; February 11, 2019. Available: https://www.fda.gov/news-events/press-announcements/statement-fda-commissioner-scott-gottlieb-md-new-data-demonstrating-rising-youth-use-tobacco (accessed 2019 May 17).
9 National Academies of Sciences, Engineering, and Medicine. Public health consequences of e-cigarettes. Washington, DC: The National Academies Press; 2018. Available: https://www.nap.edu/catalog/24952/public-health-consequences-of-e-cigarettes (accessed 2019 May 17).
10 Kuehn B. Youth e-Cigarette Use. JAMA. 2019;321(2):138. Available: https://jamanetwork.com/journals/jama/fullarticle/2720740 (accessed 2019 May 14).
11 Kirkum C. Philip Morris suspends social media campaign after Reuters exposes young 'influencers'. New York: Reuters; May 10, 2019. Available: https://www.reuters.com/article/us-philipmorris-ecigs-instagram-exclusiv/exclusive-philip-morris-suspends-social-media-campaign-after-reuters-exposes-young-influencers-idUSKCN1SH02K (accessed 2019 May 13).
12 Kirkham C. Citing Reuters report, health groups push tech firms to police tobacco marketing. New York: Reuters; May 22, 2109. Available: https://www.reuters.com/article/us-philipmorris-ecigs-socialmedia/citing-reuters-report-health-groups-push-tech-firms-to-police-tobacco-marketing-idUSKCN1SS1FX (accessed 2019 May 22).
13 McKelvey K, Popova L, Pepper JK, Brewer NT, Halpern-Felsher. Adolescents have unfavorable opinions of adolescents who use e-cigarettes. PLoS ONE 2018;13(11): e0206352. Available: https://doi.org/10.1371/journal.pone.0206352 (accessed 2019 May 14).
14 Calioa D. Vaping an 'epidemic,' Ottawa high school student says. Ottawa: CBC News; November 27, 2018. Available: https://www.cbc.ca/news/canada/ottawa/vaping-epidemic-ottawa-high-school-student-says-1.4918672 (accessed 2019 May 14).
15 Chen-Sankey JC, Kong G, Choi K. Perceived ease of flavored e-cigarette use and ecigarette use progression among youth never tobacco users. PLoS ONE 2019;14(2): e0212353. Available: https://doi.org/10.1371/journal.pone.0212353 (accessed 2019 May 17).
16 Drazen JM, Morrissey S, Campion EW. The Dangerous Flavors of E-Cigarettes. N Engl J Med 2019; 380:679-680. Available: https://www.nejm.org/doi/pdf/10.1056/NEJMe1900484?articleTools=true (accessed 2019 May 17).
17 Jackler RK, Ramamurthi D. Nicotine arms race: JUUL and the high-nicotine product market Tob Control 2019;0:1–6. Available: https://www.ncbi.nlm.nih.gov/pubmed/30733312 (accessed 2019 May 20).
18 Reichardt EM., Guichon J. Vaping is an urgent threat to public health. Toronto: The Conversation; March 13, 2019. Available: https://theconversation.com/vaping-is-an-urgent-threat-to-public-health-112131 (accessed 2019 May 20).
19 Chen JC. et al. Flavored E-cigarette Use and Cigarette Smoking Susceptibility among Youth. Tob Regul Sci. 2017 January ; 3(1): 68–80. Available: https://www.ncbi.nlm.nih.gov/pubmed/30713989 (accessed 2019 May 20).
20 LaVito A. FDA outlines e-cigarette rules, tightens restrictions on fruity flavors to try to curb teen vaping. New Jersey: CNBC; March 13, 2019 Available: https://www.cnbc.com/2019/03/13/fda-tightens-restrictions-on-flavored-e-cigarettes-to-curb-teen-vaping.html (accessed 2019 Mar 20).
21 Ireland N. Pediatricians call for ban on flavoured vaping products — but Health Canada isn't going there. Toronto: CBC News; November 17, 2018 Available: https://www.cbc.ca/news/health/canadian-pediatricians-flavoured-vaping-second-opinion-1.4910030 (accessed 2019 May 20).
22 Huang J, Duan Z, Kwok J, et al. Vaping versus JUULing: how the extraordinary growth and marketing of JUUL transformed the US retail e-cigarette market. Tobacco Control 2019;28:146-151. Available: https://tobaccocontrol.bmj.com/content/tobaccocontrol/28/2/146.full.pdf (accessed 2019 May 21).
23 Barrington-Trimis JL, Leventhal AM. Adolescents’ Use of “Pod Mod” E-Cigarettes — Urgent Concerns. N Engl J Med 2018; 379:1099-1102. Available: https://www.nejm.org/doi/pdf/10.1056/NEJMp1805758?articleTools=true (accessed 2019 May 20).
24 U.S. Department of Health and Human Services. E-Cigarette Use Among Youth and Young Adults. A Report of the Surgeon General. Atlanta, GA: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Center for Chronic Disease Prevention and Health Promotion, Office on Smoking and Health; 2016. Available: https://e-cigarettes.surgeongeneral.gov/documents/2016_sgr_full_report_non-508.pdf (accessed 2019 May 20).
25 Kong G. et al. Reasons for Electronic Cigarette Experimentation and Discontinuation Among Adolescents and Young Adults. Nicotine & Tobacco Research, 2015 Jul;17(7):847-54. Available: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4674436/pdf/ntu257.pdf (accessed 2019 May 21).
26 Keamy-Minor E, McQuoid J, Ling PM. Young adult perceptions of JUUL and other pod electronic cigarette devices in California: a qualitative study. BMJ Open. 2019;9:e026306. Available: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6500190/pdf/bmjopen-2018-026306.pdf (accessed 2019 May 21).
27 Ghosh TS, Et al. Youth Vaping and Associated Risk Behaviors — A Snapshot of Colorado. N Engl J Med 2019; 380:689-690.Available: https://www.nejm.org/doi/full/10.1056/NEJMc1900830 (accessed 2019 May 21).
The Canadian Medical Association (CMA) appreciates this opportunity to respond to Health Canada’s consultation on Potential Measures to Reduce the Impact of Vaping Products Advertising on Youth and Non-users of Tobacco Products under the authority of the Tobacco and Vaping Products Act (TVPA).
Canada’s physicians, who see the devastating effects of tobacco use every day in their practices, have been working for decades toward the goal of a smoke-free Canada. The CMA issued its first public warning concerning the hazards of tobacco in 1954 and has continued to advocate for the strongest possible measures to control its use. The CMA has always supported strong, comprehensive tobacco control legislation, enacted and enforced by all levels of government, and we continue to do so. This includes electronic cigarettes.
This brief will address the two main issues outlined in the Notice of Intent: the placement of advertising and health warnings.
Placement of Advertising
The CMA’s approach to tobacco and vaping products is grounded in public health policy. We believe it is incumbent on all levels of government in Canada to continue working on comprehensive, coordinated and effective tobacco control strategies, including vaping products, to achieve the goal of reducing smoking prevalence.
In our April 2017 submission on Bill S-5 to the Senate Standing Committee on Social Affairs, Science and Technology we recommended that the restrictions on promotion of vaping products and devices should be the same as those for tobacco products. This would include the same approach to plain and standardized packaging regulations under consideration for tobacco products.2,
The CMA is concerned that the proposed regulations leave too wide an opening for vaping manufacturers to promote their products, especially to youth. It is from a public health perspective that the CMA is calling for all vaping advertising to be strictly limited. The CMA supports the provisions proposed for point-of-sale information. The material offered will need to have the health warnings included in this Notice of Intent.
However, the sections of the proposed regulations most problematic to the CMA are those encompassing public places, broadcast media, and the publications areas. Vaping advertisements should not be permitted at all in any of these spaces, with no exceptions.2 The advertisements permitted currently seem to have managed to find their way to youth, even if they are not directed at them, as claimed. A report published by the World Health Organization and the US National Cancer Institute indicated that websites dedicated to retailing e-cigarettes “contain themes that may appeal to young people, including images or claims of modernity, enhanced social status or social activity, romance, and the use of e-cigarettes by celebrities.” Social media provides an easy means of promoting vaping products and techniques, especially to youth.21 A US study found that the landscape is “being dominated by pro-vaping messages disseminated by the vaping industry and vaping proponents, whereas the uncertainty surrounding e-cigarette regulation expressed within the public health field appears not to be reflected in ongoing social media dialogues.” The authors recommended that “real-time monitoring and surveillance of how these devices are discussed, promoted, and used on social media is necessary in conjunction with evidence published in academic journals.”6
The need to address the issue of advertising around vaping is growing more urgent. Vaping is becoming more popular and more attractive to Canadian youth, especially with the arrival of more high-tech versions of electronic cigarettes such as the pod-based JUUL™. , A similar trend has been observed in the United States where a recent study indicated that “use by adolescents and young adults of newer types of e-cigarettes such as pod-based systems is increasing rapidly.”
JUUL™ entered the US market in 2015 “with a novel chemistry (nicotine salts) enabling higher concentrations in a limited aerosol plume.” JUUL’s™ nicotine levels contained 5% nicotine salt solution consisting of 59 mg/mL in 0.7 mL pods. Some of JUUL’s™ competition have pods containing even higher levels (6% and 7%).10 The nicotine salts are “less harsh and less bitter, making e-liquids more palatable despite higher nicotine levels.”10 It has been noted by researchers that “among adolescents and young adults who use them, pod-based e-cigarettes are synonymous with the brand-name JUUL™ and use is termed “juuling,” whereas “vaping” has typically been used by youths to refer to using all other types of e-cigarettes.”9
The addition of a wide variety of flavours available in the pods makes them taste more palatable and less like smoking tobacco.10, The purpose in doing so is because “smoking is not a natural behavior, like eating or drinking, the manufacturers of these devices commonly add flavoring to the liquid from which the nicotine aerosol is generated, to make the initial exposures more pleasurable. The flavoring enhances the appeal to first-time users — especially teenagers.” The CMA and other expert groups would prefer to see flavours banned to reduce the attractiveness of vaping as much as possible.2, It is very important that the pod-based systems are cited specifically to ensure they are included under the new advertising regulations for all vaping products.
Youth vaping has reached the point where the US Food and Drug Administration referred to it as an “epidemic,” calling it “one of the biggest public health challenges currently facing the FDA.” Durham Region Health Department, using data from the Ontario Student Drug Use and Health Survey conducted by CAMH and administered by the Institute for Social Research, York University, noted that 17% of high school students in that region had used an electronic cigarette in the past year (2016-17), numbers that are similar for the rest of Ontario. In the United States, a survey indicated that, among high school students, “current e-cigarette use increased from 1.5% (220,000 students) in 2011 to 20.8% (3.05 million students) in 2018;” between 2017 and 2018 alone it rose 78% (from 11.7% to 20.8%).
Concern is growing across Canada among educators seeing a rise in the number of youths turning to vaping. , , The problem has reached the point where a school official resorted to removing the doors from the washrooms to “crack down” on vaping in the school. Youth themselves are aware of the increasing problem; many are turning to YouTube to learn “vape tricks” such as making smoke rings. Some refer to the practice of vaping as “the nic;” as a University of Ottawa student noted “They call it getting light-headed. Sometimes it's cool.”
As the Canadian Paediatric Society noted in 2015, efforts to “denormalize tobacco smoking in society and historic reductions in tobacco consumption may be undermined by this new ‘gateway’ product to nicotine dependency.” , Decades of effort to reduce the incidence of smoking are in danger of being reversed. A growing body of evidence indicates that vaping can be considered the prime suspect. A Canadian study provides “strong evidence” that use of electronic cigarettes among youth is leading them to the consumption of combustible tobacco products. In a similar vein, a “large nationally representative study of US youths supports the view that e-cigarettes represent a catalyst for cigarette initiation among youths.” Granting vaping manufacturers scope to advertise will likely exacerbate this problem.
Health Warnings
The CMA reiterates its position that health warnings for vaping should be like those being considered for tobacco packages.2,3 We support the proposed warning labels being placed on all vaping products. The need for such warnings is important as there is still much that is not known about the effects vaping can have on the human body.
Substances that have been identified in e-cigarette liquids and aerosols include “nicotine, solvent carriers (PG and glycerol), tobacco-specific nitrosamines (TSNAs), aldehydes, metals, volatile organic compounds (VOCs), phenolic compounds, polycyclic aromatic hydrocarbons (PAHs), flavorings, tobacco alkaloids, and drugs.” Researchers have noted that there is a “striking diversity of the flavorings in e-cigarette liquids, (and that) the effects on health of the aerosol constituents produced by these flavorings are unknown.”
A US study found “evidence that using combusted tobacco cigarettes alone or in combination with e-cigarettes is associated with higher concentrations of potentially harmful tobacco constituents in comparison with using e-cigarettes alone.” Some researchers have found that there is “significant potential for serious lung toxicity from e-cig(arette) use.” ,
Another recent US study indicates that “adults who report puffing e-cigarettes, or vaping, are significantly more likely to have a heart attack, coronary artery disease and depression compared with those who don’t use them or any tobacco products.” Further, it was found that “compared with nonusers, e-cigarette users were 56 percent more likely to have a heart attack and 30 percent more likely to suffer a stroke.”32
The need for parents to be educated on the impact of vaping on children is also very important. A study examining how smoke-free and vape-free home and car policies vary for parents who are dual users of cigarettes and e-cigarettes, who only smoke cigarettes, or who only use e-cigarettes demonstrated that these parents may perceive e-cigarette aerosol as safe for children. It noted that “dual users were less likely than cigarette-only smokers to report various child-protective measures inside homes and cars.”33
Recommendations
1. The CMA calls for all vaping advertising to be strictly limited. The restrictions on the marketing and promotion of vaping products and devices should be the same as those for tobacco products.
2. The CMA recommends that vaping advertisements should not be permitted in any public places, broadcast media, and in publications of any type, with no exceptions.
3. The CMA supports the provisions proposed in this Notice of Intent for point-of-sale information. This should include health warnings.
4. The CMA reiterates its position that health warnings for vaping should be like those being considered for tobacco packages. We support the proposed warning labels being placed on all vaping products.
5. The CMA recommends more research into the health effects of vaping as well as on the components of the vaping liquids.
Government of Canada. Notice to Interested Parties – Potential Measures to Reduce the Impact of Vaping Products Advertising on Youth and Non-users of Tobacco Products Ottawa: Health Canada; 2019 Available: https://www.canada.ca/en/health-canada/programs/consultation-measures-reduce-impact-vaping-products-advertising-youth-non-users-tobacco-products.html (accessed 2019 Feb 27)
Canadian Medical Association (CMA) CMA’s Recommendations for Bill S-5: An Act to amend the Tobacco Act and the Non-smokers’ Health Act and to make consequential amendments to other Acts Ottawa: CMA; 2017 Apr 7. Available: http://policybase.cma.ca/dbtw-wpd/Briefpdf/BR2017-06.pdf (accessed 2019 Mar 1).
Canadian Medical Association. Health Canada consultation on tobacco products regulations (plain and standardized appearance) Ottawa: CMA; 2018 Sep 6 Available: http://www.cma.corp/dbtw-wpd/Briefpdf/BR2019-01.pdf (accessed 2019 Mar 5)
Gagnon E. IMPERIAL TOBACCO: Kids shouldn’t be vaping; our marketing is aimed at adults. Halifax Chronicle Herald March 5, 2019 Available: https://www.thechronicleherald.ca/opinion/imperial-tobacco-kids-shouldnt-be-vaping-our-marketing-is-aimed-at-adults-289673/ (accessed 2019 Mar 8)
U.S. National Cancer Institute and World Health Organization. The Economics of Tobacco and Tobacco Control. National Cancer Institute Tobacco Control Monograph 21. NIH Publication No. 16-CA-8029A. Bethesda, MD: U.S. Department of Health and Human Services, National Institutes of Health, National Cancer Institute; and Geneva,
CH: World Health Organization; 2016. Available https://cancercontrol.cancer.gov/brp/tcrb/monographs/21/docs/m21_complete.pdf (accessed 2019 Mar 8)
McCausland K, Maycock B, Leaver T, Jancey J. The Messages Presented in Electronic Cigarette–Related Social Media Promotions and Discussion: Scoping Review J Med Internet Res 2019;21(2):e11953 Available: https://www.jmir.org/2019/2/e11953/ (accessed 2019 Mar 14)
Glauser W. New vaping products with techy allure exploding in popularity among youth. CMAJ 2019 February 11;191:E172-3. doi: 10.1503/cmaj.109-5710 Available: http://www.cmaj.ca/content/191/6/E172 (accessed 2019 Mar 1)
Crowe K. Canada's 'wicked' debate over vaping CBC News February 2, 2019 Available https://www.cbc.ca/news/health/vaping-juul-vype-health-canada-cigarette-smoking-nicotine-addiction-1.5003164 (accessed 2019 Mar 8)
McKelvey K et al. Adolescents’ and Young Adults’ Use and Perceptions of Pod-Based Electronic Cigarettes. JAMA Network Open. 2018;1(6):e183535. doi:10.1001/jamanetworkopen.2018.3535 Available: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2707425 (accessed 2019 Mar 1)
Jackler RK, Ramamurthi D. Nicotine arms race: JUUL and the high-nicotine product market Tob Control 2019;0:1–6. doi:10.1136/tobaccocontrol-2018-054796 Available: https://www.ncbi.nlm.nih.gov/pubmed/30733312 (accessed 2019 Mar 12)
Reichardt EM., Guichon J. Vaping is an urgent threat to public health The Conversation March 13, 2019 Available: https://theconversation.com/vaping-is-an-urgent-threat-to-public-health-112131 (accessed 2019 Mar 14)
Drazen JM., Morrissey S., Campion, EW. The Dangerous Flavors of E-Cigarettes. N Engl J Med 2019; 380:679-680 Available: https://www.nejm.org/doi/full/10.1056/NEJMe1900484 (accessed 2019 Mar 13)
Ireland N. Pediatricians call for ban on flavoured vaping products — but Health Canada isn't going there CBC News November 17, 2018 Available: https://www.cbc.ca/news/health/canadian-pediatricians-flavoured-vaping-second-opinion-1.4910030 (accessed 2019 Mar 13)
Food and Drug Administration Statement. Statement from FDA Commissioner Scott Gottlieb, M.D., on new data demonstrating rising youth use of tobacco products and the agency’s ongoing actions to confront the epidemic of youth e-cigarette use Media Release February 11, 2019 Available: https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm631112.htm (accessed 2019 Mar 11)
Durham Region Health Department Students’ use of e-cigarettes in the past year, 2016-2017 Quick Facts December 2018 Available https://www.durham.ca/en/health-and-wellness/resources/Documents/HealthInformationServices/HealthStatisticsReports/E-cigaretteAlternativeSmokingDeviceStudents-QF.pdf (accessed 2019 Mar 11)
Cullen KA et al. Notes from the Field: Use of Electronic Cigarettes and Any Tobacco Product Among Middle and High School Students — United States, 2011–2018 Morbidity and Mortality Weekly Report November 16, 2018 Vol. 67 No. 45 Available: https://www.cdc.gov/mmwr/volumes/67/wr/mm6745a5.htm (accessed 2019 Mar 13)
Munro N. Vaping on the rise in Nova Scotia high schools Halifax Chronicle Herald March 5, 2019 Available: https://www.thechronicleherald.ca/news/local/vaping-on-the-rise-in-nova-scotia-high-schools-289761/ (accessed 2019 Mar 11)
Soloducha A. Is your child vaping? Regina Catholic Schools educating parents as trend continues to rise CBC News March 1, 2019 Available https://www.cbc.ca/news/canada/saskatchewan/regins-catholic-schools-vaping-education-1.5039717 (accessed 2019 Mar 11)
Emde W. Growth of vaping labelled ‘crisis’ in Vernon. Kelowna Daily Courier Available http://www.kelownadailycourier.ca/life/article_253d6404-4168-11e9-934f-7b6df68fb0fd.html (accessed 2019 Mar 11)
Lathem C. Ottawa principal's solution to student vaping: Remove the washroom doors. CTV News January 9, 2019 Available https://www.ctvnews.ca/canada/ottawa-principal-s-solution-to-student-vaping-remove-the-washroom-doors-1.4246317 (accessed 2019 Mar 11))
Calioa D. Vaping an 'epidemic,' Ottawa high school student says CBC News November 27, 2018 Available https://www.cbc.ca/news/canada/ottawa/vaping-epidemic-ottawa-high-school-student-says-1.4918672 (accessed 2019 Mar 11)
Schnurr J. New data is showing a worrisome trend about vaping and smoking among teens CTV News January 18, 2019 Available https://ottawa.ctvnews.ca/new-data-is-showing-a-worrisome-trend-about-vaping-and-smoking-among-teens-1.4260008 (accessed 2019 Mar 11)
Stanwick R. E-cigarettes: Are we renormalizing public smoking? Reversing five decades of tobacco control and revitalizing nicotine dependency in children and youth in Canada Policy Statement Canadian Paediatric Society March 6, 2015 (Reaffirmed February 28, 2018) Available: https://www.cps.ca/en/documents/position/e-cigarettes (accessed 2019 Mar 12)
Fairchild AL., Bayer R., Colgrove J. The renormalization of smoking? E-cigarettes and the tobacco
“endgame.” N Engl J Med 370:4 January 23, 2014 Available: https://www.nejm.org/doi/pdf/10.1056/NEJMp1313940 (accessed 2019 Mar 12)
Hammond d. et al. Electronic cigarette use and smoking initiation among youth: a longitudinal cohort study. CMAJ October 30, 2017 189 (43) E1328-E1336; Available: http://www.cmaj.ca/content/189/43/E1328 (accessed 2019 Mar 1)
Berry KM et al. Association of Electronic Cigarette Use With Subsequent Initiation of Tobacco Cigarettes in US Youths JAMA Network Open. 2019;2(2):e187794. doi:10.1001/jamanetworkopen.2018.7794 Available: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2723425?resultClick=3 (accessed 2019 Mar 12)
National Academies of Sciences, Engineering, and Medicine. 2018. Public health consequences of e-cigarettes. Washington, DC: The National Academies Press. doi: https://doi.org/10.17226/24952. Available: https://www.nap.edu/catalog/24952/public-health-consequences-of-e-cigarettes (accessed 2019 Mar 13)
Dinakar, C., O’Connor GT. The Health Effects of Electronic Cigarettes. N Engl J Med 2016;375:1372-81 Available: https://www.nejm.org/doi/full/10.1056/NEJMra1502466 (accessed 2019 Mar 13)
Goniewicz ML. et al. Comparison of Nicotine and Toxicant Exposure in Users of Electronic Cigarettes and Combustible Cigarettes JAMA Network Open. 2018;1(8):e185937 Available: https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2718096 (accessed 2019 Mar 13)
Chan LF. Et al. Pulmonary toxicity of e-cigarettes Am J Physiol Lung Cell Mol Physiol 313: L193–L206, 2017 Available: https://www.physiology.org/doi/full/10.1152/ajplung.00071.2017?url_ver=Z39.88-2003&rfr_id=ori:rid:crossref.org&rfr_dat=cr_pub%3dpubmed (accessed 2019 Mar 13)
Li D, Sundar IK, McIntosh S, et al. Association of smoking and electronic cigarette use with wheezing and related respiratory symptoms in adults: cross-sectional results from the Population Assessment of Tobacco and Health (PATH) study, wave 2. Tob Control. 0:1-8, 2019.
American College of Cardiology. E-Cigarettes Linked to Heart Attacks, Coronary Artery Disease and Depression. Media Release March 7, 2019 Available: https://www.acc.org/about-acc/press-releases/2019/03/07/10/03/ecigarettes-linked-to-heart-attacks-coronary-artery-disease-and-depression (accessed 2019 Mar 13)
Drehmer JE, Nabi-Burza E, Hipple Walters B, et al. Parental Smoking and E-cigarette Use in Homes and Cars. Pediatrics. 2019;143(4):e20183249 Available: https://pediatrics.aappublications.org/content/early/2019/03/07/peds.2018-3249 (accessed 2019 Mar 13)
Health care professionals, including physicians, play an essential role in promoting health and preventing disease among all Canadians. A significant proportion of death, illness and injury in Canada is preventable. These preventable health problems place a substantial burden of suffering on individuals, families and communities as well as a heavy burden on society because they draw on scarce health care resources.
The World Health Organization defines health promotion as "the process of enabling people to increase control over and improve their health." Health promotion activities generally seek to influence either a person’s individual behaviours such as smoking and sedentary lifestyle. Effective health promotion also addresses the broader social determinants of health, for example, income, access to services and physical environment.
The CMA views prevention and health promotion as a responsibility to be shared among all health care providers, rather than the sole responsibility of any one group or specialty.
At a collective level, medical and other health organizations can be involved in prevention and health-promotion activities such as organizing public education campaigns, advocating for legislation that promotes health, such as laws to control pollution and tobacco products, and disseminating clinical practice guidelines to enhance standards of preventive care.
At an individual level, the role of physicians in the continuum of patient care is an important one, with the potential for further enhancement, and can include:
Health enhancement: As part of daily practice, physicians routinely offer information to support the prevention of disease. These activities include appropriate discussions with patients about nutrition, physical activity and access to social supports. In providing these services, physicians consider the social, economic and environmental conditions in which their patients live.
Risk avoidance: Physicians ensure that people take measures that will prevent specific risks of disease. Examples include providing immunizations, promoting breast-feeding, physical activity and the use of bicycle helmets.
Risk reduction: Physicians screen, counsel and work with individuals or segments of the population at higher risk of disease or injury to reduce their risk. Examples include screening for risk factors for the development of heart disease or diabetes, such as nutrition, smoking and alcohol use.
Early identification: Physicians screen people to detect diseases at an asymptomatic stage, when intervention can improve the outcome. Papanicolaou smears to detect cancer of the cervix and breast exams to detect breast cancer are two types of tests being used in early detection. With the increase in public awareness and interest in prevention, physicians often spend time with their patients discussing the pros and cons of tests such as mammographic screening of women and the prostate-specific antigen screening test for men.
Complication reduction: Physicians can prescribe therapy to prevent complications in patients with diagnosed conditions or diseases. For example, the use of medication to reduce the incidence of stroke or myocardial infarction in high risk patients.
Recommendations
1) Physicians should continue to incorporate all levels of health promotion and disease prevention into their practices, emphasizing activities for which there is sufficient scientific evidence.
2) Education in prevention and health promotion both at an individual and at a collective level, should be given high priority in undergraduate medical programs, in residency training and in continuing medical education.
3) Physicians should be encouraged to work with other health care professionals in the office setting and the community to enhance delivery of care that incorporates prevention and health promotion.
4) Remuneration systems should support a multidisciplinary approach to the delivery of these services; they should also support the provision of these services by individual physicians.
5) Patients should have access to a family physician who can provide care that includes prevention and health promotion. Family physicians should continue to develop professional relationships with their patients that encourage the long-term promotion and maintenance of good health.
6) Clear, simple and current guidelines for prevention and health promotion services should be widely distributed to physicians. The Canadian Task Force on Preventive Health Care regularly develops and updates guidelines in this area.
7) Simple, easy-to-understand patient guidelines for prevention and health promotion should be developed and made available to the public. Physicians should continue to develop, improve and promote patient-counselling programs and office-management systems that encourage effective delivery of preventive care and health promotion.
8) Governments should give high priority to public policies that take account of the broad range of determinants of health, and proposed legislation should be routinely reviewed for any impact on the health of individuals and the community. CMA, in collaboration with other health professions and governments, will continue to explore means to ensure that public policies are developed with due attention paid to their potential health consequences.
Approved by the CMA Board in 2001.
Last reviewed and approved by the CMA Board in March 2019.
That access to quality health care must be available to all Canadians, in a manner consistent with provincial/territorial human rights legislation and the Canadian Charter of Rights and Freedoms.
That access to quality health care must be available to all Canadians, in a manner consistent with provincial/territorial human rights legislation and the Canadian Charter of Rights and Freedoms.
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That access to quality health care must be available to all Canadians, in a manner consistent with provincial/territorial human rights legislation and the Canadian Charter of Rights and Freedoms.
That the Canadian Medical Association warns that Canadians will face medical and psychological consequences as a result of decreasing physical activity.
That the Canadian Medical Association warns that Canadians will face medical and psychological consequences as a result of decreasing physical activity.
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That the Canadian Medical Association warns that Canadians will face medical and psychological consequences as a result of decreasing physical activity.
That the Canadian Medical Association work with provincial and territorial Divisions in carrying out the federal coordination of activities to identify and disseminate information on health effects of air pollution.
That the Canadian Medical Association work with provincial and territorial Divisions in carrying out the federal coordination of activities to identify and disseminate information on health effects of air pollution.
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That the Canadian Medical Association work with provincial and territorial Divisions in carrying out the federal coordination of activities to identify and disseminate information on health effects of air pollution.
BD98-05-93 -That the Canadian Medical Association support the principle of equal treatment for all qualified licensed physicians in Canada, based on training and competence.
BD98-05-93 -That the Canadian Medical Association support the principle of equal treatment for all qualified licensed physicians in Canada, based on training and competence.
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That the Canadian Medical Association support the principle of equal treatment for all qualified licensed physicians in Canada, based on training and competence.
Concussions and head injuries are a common occurrence in sport and leisure activities, and frequently occur in occupational settings as well. While the majority of individuals who suffer from a concussion will recover with time, others may be at risk for serious and lasting complications. These include (1) children; (2) previous history of head injury or concussion; (3) prior mental health symptoms; and (4) missed diagnosis and management.
This aim of this advocacy and policy document is to improve safety during activity by raising awareness of concussions, and by working to improve the detection and safe management of concussions when they occur. It is not a clinical practice guideline. It should not be perceived as a plea to avoid sports or leisure activities, but rather as a call for safer sporting, leisure, and occupational practices. The documented health benefits that result from establishing an active lifestyle in youth and maintaining it throughout life cannot be overstated.
Achieving balance of safe play in sport, leisure and occupational activities while promoting greater physical activity levels for Canadians would have the effect of reducing health care costs in Canada, while promoting a healthier concussion recovery culture for all Canadians.
Therefore, to promote better concussion and head trauma awareness and prevention, as well as better management/treatment practices, the following policy recommendations for key target audiences across all levels of sport, leisure, and occupational activity are made.
Key Concussion & Head Injury Principles:
a) The detection of concussions and head injury should be a shared responsibility and any stakeholder/observer to such an injury should verbally raise their concerns that a concussion may have occurred.
i. It is important to understand that individuals with a possible concussion, or head injury, may not be able to recognize that they are suffering from a concussion;
ii. It is important to recognize that engrained within popular culture are dangerous notions (e.g., to minimize, ignore, downplay, or play through the pain, etc.) that cause individuals/observers to ignore the real, often hidden, dangers of such injuries.
b) Broadly speaking, access to the latest edition of the internationally recognized Concussion Recognition Tool (CRT) should be promoted/available to help identify the signs and symptoms of a possible concussion;
c) Any individual who sustains more than a minor head injury should be immediately removed from play, activity, or occupation, and not permitted to return on the same day3 (regardless of whether a concussion is later suspected).
i. These individuals should be the subject of observation for developing/evolving concussion symptoms or emergency warning signs (especially within the first 4 hours post-injury, but also up to 48 hours when red-flag symptoms are present).
d) Following first aid principles, where an individual displays signs of a serious head or spinal injury, that individual should lie still (not moving their head or neck) until a qualified individual has performed an evaluation; to determine whether emergency evacuation for medical assessment is necessary.
e) Any individual with a suspected concussion (especially where red-flag symptoms are present), or more severe traumatic brain injury, should be promptly evaluated by a physician to:
i. Either rule-out or confirm a diagnosis via an appropriate medical assessment; and
ii. Institute the provision of an age-appropriate follow-up care plan (including progressive return to school, work, and play protocols) if such an injury is confirmed.1
f) Ideally, a physician knowledgeable in concussion management determines when, and how, a concussed individual should progressively return to both cognitive (school or work) and physical activities.
g) Following a suspected, or diagnosed concussion, an individual should not return to play, or resume any activity associated with a heightened risk of head trauma, until cleared by a physician to do so.1
Recommendations For:
1. Physicians:
Should:
a) Where possible, encourage safe play practices in sports, and where appropriate, educate patients about the risks of head injuries (associated with high-risk behavior in sports, leisure and occupational activities).
b) Gain/maintain, through relevant continuous medical education, competencies related to the assessment, diagnosis and management of concussion according to most current clinical practice recommendations (e.g., latest edition of the CRT, SCAT, Child SCAT, Acute Concussion Evaluation Tool, etc.).
c) Be aware that clinical practice guidelines and assessment tools exist to assist in assessing and treating concussed individuals (e.g., Ontario Neurotrauma Foundation, Parachute Canada, etc.).
d) When assessing a patient with a potential concussion:
i. Rule out the presence of more severe traumatic brain and musculoskeletal injury;
ii. Assess for any previous concussion history, risk factors and newly arising complications;
iii. Educate and instruct parents, athletes and any individual that sustains a concussion about what to do, and what to expect, in the post concussive phase. (This should be based on the most current age-appropriate concussion management guidelines);4
iv. Provide individualized recommendations on how to optimally apply the progressive return-to-school, work, and play strategies with consideration for the specificities of the patient’s usual activities and responsibilities;4
v. Work to provide concussed patients timely access for medical reassessment in the event of worsening or persistent symptoms (including mental health); and
vi. In the presence of persistent or worsening symptoms (including mental health), consider what external, evidence based, concussion resources may be necessary as well as referral.
2. Medical Colleges & Faculties:
Should:
a) Promote/support medical education regarding; awareness, detection/diagnosis; and the appropriate management of concussions, throughout the continuum of medical education (undergraduate, post-graduate, and continuing medical education).
b) Support research in concussion prevention, detection, and treatment or management.
3. Athletes in Contact/Collision Sports:
Should:
a) (Prior to the commencement of the sporting season) be given age-appropriate instruction2 to understand:
i. How to identify the signs and symptoms of a possible concussion using the latest edition of the internationally recognized CRT (e.g. Concussion Recognition Tool, or Concussion Awareness Training Tool (CATT));
ii. The risks associated with concussion (including long term and mental health); especially, the risks of potentially life-threatening complications associated with continued sport participation, while presenting with signs or symptoms of a possible concussion;
iii. What to do/expect if a concussion is ever suspected (including for teammates), and the expected role of the athlete and team members;
iv. Removal and progressive returns to school, work and play policies/procedures, and the expected role of the athlete in the recovery process; and
v. How to foster a healthy sporting culture (that promotes: safe play practices; fosters concussion/injury prevention and reporting; peer-to-peer support; and combat injury stigmatization).
b) Have such instruction reinforced periodically throughout the sporting season as needed.
c) Be aware of, and seek treatment for, potentially serious mental health issues that may arise post-concussive injury.
4. Parents with Minors in Contact/Collision Sports:
Should:
a) Prior to the commencement of a sporting season, request and be open to receiving instruction2 on:
i. How to identify the signs and symptoms of a possible concussion using the latest edition of the internationally recognized CRT (e.g. Concussion Recognition Tool, or Concussion Awareness Training Tool (CATT));
ii. The risks associated with concussion; especially, the risks of potentially life-threatening complications associated with continued sport participation, while presenting with signs or symptoms of a possible concussion;
iii. What to do/expect if a concussion is ever suspected for an athlete;
iv. Removal and progressive returns to school, work and play policies/procedures, and the expected role of the parent(s) in the recovery process; and
v. How to foster a healthy sporting culture that promotes: safe play practices; fosters concussion/injury prevention and reporting; peer-to-peer support; and combats injury stigmatization.
b) Have such instruction reinforced periodically throughout the sporting season as needed.
c) Be prepared to address potentially serious mental health issues that may arise post-concussive injury.
5. Individuals Who Sustain a Head Injury Outside of Organized Sports:
Should:
a) Be aware of possible signs and symptoms of a possible concussion, and immediately withdraw from activity and seek medical assessment a possible concussion is suspected.1
i. Refer to the latest addition of the internationally recognized CRT (Concussion Recognition Tool) for further guidance on signs and symptoms.3
b) Understand the risks associated with concussion; including the risks of potentially life-threatening complications associated with repeated head injury if signs or symptoms of a possible concussion are present.
c) In the event of a diagnosis of concussion, judiciously implement the medical recommendations received regarding their gradual return to cognitive and physical activity (including the need for medical reassessment in the presence of persistent symptoms).
d) Openly communicate their recovery needs and work with any group or individual who might support them in their recovery process (e.g., employers, family members, school, etc.).
e) Be aware of, and seek treatment for, potentially serious mental health issues that may arise post-concussive injury.
6. Coaches, Trainers, Referees, & First Responders:
Should:
a) Receive certified emergency first aid training.
b) Receive periodic education (ideally annually) on national standards regarding the signs and symptoms, potential long-term consequences, appropriate steps for initial intervention, and immediate management (including: athlete removal-from-play; observation; determining when medical assessment is necessary; and progressive return to school, work and play procedures).
c) Be trained in the use of the latest edition of the internationally recognized CRT (Concussion Recognition Tool) – to detect whether an injured individual is suffering from a concussion.2
d) Be knowledgeable and responsible to ensure safety and safe play practices are applied throughout the sporting season.
e) Be responsible for fostering a healthy sporting culture (promote safe play practices, foster concussion/injury prevention and reporting, peer-to-peer support and combat injury stigmatization).
f) Be prepared to address potentially serious mental health issues that may arise post-concussive injury.
7. Licensed Health Care Providers Involved as Therapists in Sport Environments:
Should:
a) Be fully licensed in their professional field and pursue continuing professional development to maintain competencies related to concussion and head injuries.
b) Promote the implementation of properly adapted concussion management protocols (that comply with the most current clinical recommendations, based on consideration for the specificities of each sport environment and available resources).
c) Work with qualified physicians to initiate/implement tailored medically supervised concussion management protocols that define:
i. Mutual and shared health professional responsibilities to optimize the quality, and safety of patient care (within one’s scope of practice); and
ii. The optimal corridors for timely access to medical (re)assessment with due consideration for available resources.
d) Be prepared to address potentially serious mental health issues that may arise post-concussive injury.
8. Educational Institutions & Sports Organizations:
Should:
a) (Especially in the cases involving minors) implement, and keep updated, prevention strategies to include:
i. Safety standards that include safe play policies; and
ii. Mandatory safety gear/equipment (tailored to individual sport settings).
b) Mandatory concussion and head injury protocols that work to:
i. Reduce the occurrence of concussions and head injury by promoting: safe play practices; fostering concussion/injury prevention and reporting; peer-to-peer support, and combatting injury stigmatization;
ii. Ensure the prompt detection, and standardized early management of concussion and head injuries, by informing all potential stakeholders (in the preseason phase) about the nature/risks of concussion and head injury, and how any such occurrence will be dealt with should they occur;
iii. Enshrine into practice removal-from-play, and post-injury observation of athletes;
iv. Progressively reintegrate students back into symptom guided educational and physical activities based on the most current recommendations;2
v. Reintegrate injured athletes back into unrestricted training activities and sport once medical clearance has been obtained; and
vi. Foster better lines of communication for injury management/recovery between: parents, athletes, coaches, school personnel, therapists and physicians.
vii. Address potentially serious mental health issues that may arise post-concussive injury.
9. Employers (Occupational Considerations)
Should:
a) Comply with workplace safety laws and implement safety standards to reduce the incidence of head injuries in the work environment.
b) Integrate considerations for concussion and head injury in health and safety protocols that work to:
i. Reduce the occurrence of concussions and head injury by promoting: safe practices; concussion/injury prevention and reporting; peer-to-peer support, and combats injury stigmatization;
ii. Ensure prompt detection and standardized early management of concussion and head injuries by informing potential stakeholders about the nature/risks of concussion and head injury, and how occurrences will be dealt with should they occur;
iii. Enshrine into practice/ workplace culture the removal-from-work, and post-injury observation of workers;
iv. Progressively reintegrate workers back into symptom guided cognitive and physical activities based on the most current recommendations;
v. Reintegrate injured workers with a confirmed diagnosis of concussion, progressively back into work activities only once medical clearance has been obtained; and
vi. Foster better lines of communication, and support for, injury management between: employees, employers, medical professionals and insurances.
vii. Address the potentially serious mental health issues that may arise post-concussive injury.
10. Governments & Professional Regulatory Bodies:
Should:
a) Implement comprehensive public health strategies for the Canadian population to:
i. Increase awareness that concussions can be sustained in accidents, sports, leisure and occupational contexts;
ii. Inform head injuries should be taken seriously; and
iii. Explain how and why concussions should be prevented and promptly assessed by a physician where they are suspected to have occurred.
b) Define appropriate scopes of practice for all health professionals involved in the field of concussion detection, management, and treatment.
c) Work with key stakeholders to develop compensation structures to support physicians to allocate the time necessary to: (1) conduct appropriate assessments to rule out concussions, (2) provide ongoing concussion management, and (3) develop detailed medical clearance plans.
d) Work with key stakeholders to develop standardized educational tools for physicians to provide to patients with concussions.
i. Ideally this would include contextualized tools for sports teams, schools, and employers.
e) Adopt legislation or regulation for educational institutions and community-based sport associations to establish clear expectations/obligations regarding concussion awareness and management for youth in sports (e.g., Ontario’s Rowan’s law).
i. To have meaningful impact, such initiatives must also be accompanied by: implementation funding to support the development and implementation of sport specific concussion management protocols; and monitoring/compliance programs.
f) Establish a national concussion and sports injury surveillance system (with standardized metrics) to collect detailed head and sport injury related information. Thus, providing the ability to research such injuries in an ongoing and timely manner.
g) Provide research opportunities/funding on concussions. Specific examples of research areas to prioritize include:
i. Effective prevention strategies for both adults and children in a range of sport, leisure, or occupational environments;
ii. The incidence and impact of concussions in children, and how to reduce their occurrence (inside and outside of sport);
iii. Address knowledge gaps for concussion identification, management, and medical clearance for physicians not specialized in concussion care;
iv. Explore all health professionals’ participation in concussion management providing for respective: competency, expertise, interdisciplinary collaboration, and appropriate roles;
v. Evaluate how emerging point of care diagnostics and biomarker testing will be incorporated into sport, leisure and work environments;
vi. Continued development of effective, user-friendly, and age appropriate management strategies/tools for physicians regarding concussion identification, management, and medical clearances; and
vii. Develop a harmonized understanding of “concussion” and “mild traumatic brain injury” (MTBI) constructs/concepts, so that adults with concussion signs or symptoms, who do not meet the more restrictive MTBI criteria, are properly managed.
McCrory P, Meeuwisse W, Dvorak J, et al. Consensus Statement on Concussion in Sport - the 5th International Conference on Concussion in Sport Held in Berlin. Br J Sports Med 2017, 51: 838-847.
Parachute Canada. Canadian Guideline on Concussion in Sport. 2017. Available: http://www.parachutecanada.org/injury-topics/item/canadian-guideline-on-concussion-in-sport (accessed 2018 Jul 31).
Concussion in Sport Group. Concussion Recognition Tool 5. Br J Sports Med 2017 51: 872. Available: https://bjsm.bmj.com/content/bjsports/early/2017/04/26/bjsports-2017-097508CRT5.full.pdf (accessed 2018 July 31st). (accessed 2018 Jul 31).
Ontario Neurotrauma Foundation. Guidelines for Concussion/Mild Traumatic Brain Injury & Persistent Symptoms. Health Care Professional Version. 3rd Ed, Adults (18 + years of age). Toronto: Ontario Neurotrauma Foundation; 2018. Available: http://braininjuryguidelines.org/concussion/fileadmin/media/adult-concussion-guidelines-3rd-edition.pdf (accessed 2018 Jul 31).
Concussion in Sport Group. Sport Concussion Assessment Tool – 5th Ed. Br J Sports Med 2017, 0:1-8. Available: https://bjsm.bmj.com/content/bjsports/early/2017/04/26/bjsports-2017-097508CRT5.full.pdf (accessed 2018 July 31).
Approved by the CMA Board of Directors March 2019
Antimicrobials (which include antibiotics) are a precious public resource and an essential tool for fighting infections in both humans and animals. Their importance to human medical, nutritional and economic security cannot be understated. Yet globally, antimicrobials are losing their effectiveness more quickly than new such drugs, treatments and therapies are being identified and introduced to market.1 Over time, this dynamic has eroded the human antimicrobial arsenal, placing the lives and futures of an unacceptable number of people at risk.
Antimicrobial resistance (AMR) occurs when microorganisms such as bacteria, viruses, fungi and parasites come into contact with antimicrobial drugs, such as antibiotics, antivirals, antifungals, antimalarials and anthelmintics, and undergo changes. The drugs are rendered ineffective and cannot eradicate infections from the body.
AMR is an international challenge that threatens to reverse over a century of progress in public health, health care and human development attributable to antimicrobial use. Indeed, the effects of AMR are already being felt across Canada’s health care system. Currently, Canada’s dedicated investment in solutions to militate against encroaching AMR in the AMR and antimicrobial stewardship (AMS) fields (both federally and provincially/territorially) can only be viewed as wholly inadequate to address the scope of the problem and the risks it poses for the health of Canadians.
Therefore, to: (1) promote awareness of AMR; (2) incentivize investment in AMR mitigation strategies; and (3) support the mobilization of an effective suite of more clinically effective management/treatment practices and policies, the following target audience recommendations are offered.a
a All the policy recommendations made in this document are not meant to be interpreted as clinical practice guidelines. Any individual who suspects they may have an infection should promptly consult a physician.
2
Key AMR principle — the “One Health” approach
a) The complexity of AMR underscores the need for coordinated action known as the “One Health” approach. The term implies integrated strategies that span the human, animal/agricultural and environmental sectors. Thus, cooperation across a wide variety of stakeholders is necessary to address the collective nature of AMR. These stakeholders include governments, health professionals, private and public partners, and the public at large.
b) The One Health approach will require attention and investment in the following domains: (1) surveillance of antimicrobial prescribing and usage; (2) infection prevention and control practices that mitigate the spread of resistant pathogens; (3) stewardship programs and practices that educate health professionals, the public, and the private sector and nudge each into more appropriate patterns of supply and demand; and (4) a program of innovation, research and development focused on diagnostics, vaccines and alternative treatments to reduce reliance on antimicrobials. This includes the development of novel antimicrobials that expand the currently available arsenal.
c) Given the global dimensions of AMR, a successful One Health approach will require ambitious investments in global AMR mitigation. Given that health infrastructure and resources are limited in low- to middle-income countries, the impacts of AMR will primarily be felt in those settings.
Recommendations
1. Physicians and allied health professionals
Should:
a) Be aware that AMR is a serious public health crisis.
b) Know that various Canadian prescribing aides/guidelines are available to assist physicians in choosing appropriate antibiotics and improving practice (e.g., Choosing Wisely Canada).
c) Know that using antibiotics appropriately can help combat AMR and that diagnosis and laboratory testing play a key role. This includes only prescribing antibiotics for conditions that are clinically infectious and of a non-viral nature. Viral infections are the greatest source of antibiotic misuse.
d) Consider delayed prescriptions and/or prioritize follow-up for patients when diagnosis is initially undifferentiated or when symptoms worsen, progress or are prolonged.
e) Know that prevention of infections through hand hygiene, vaccination and appropriate use of antibiotic prophylaxis is evidence based and effective
f) Know that durations of therapy and dosage rates for treating many infections change with time and that you should prescribe antimicrobials for the shortest effective duration (using the narrowest spectrum possible).
3
g) Consider the potential side effects of antibiotics (including C. difficile and allergic reactions) in prescribing and when counselling patients as to their potential side effects.
h) Engage in conversations with patients about antimicrobials regarding:
i. their appropriate use;
ii. their potential risks;
iii. when to delay, begin or end an antimicrobial prescription (e.g., delayed prescriptions); and
iv. when to seek medical reassessment if symptoms worsen or persist.
i) Ask your local hospital or specialty organization about educational initiatives related to antibiotic prescribing.
j) Collaborate where possible with colleagues in other prescribing professions to reduce unnecessary antimicrobial use.
2. Patients and the Canadian public
Should:
a) Be aware that AMR is a significant problem that is linked to the inappropriate use of antimicrobials like antibiotics. Therefore, commit to only taking antibiotics if they are prescribed and only as directed by an authorized health professional.
i. Never share, or use, the antibiotics of others as it may contribute to AMR and have serious consequences for your health.
b) Consider that your expectations about antimicrobials may unduly pressure physicians, and other prescribers, to provide you a prescription when an antimicrobial would not be appropriate or helpful.
c) Engage in a conversation with prescribers about:
i. whether an antimicrobial is necessary;
ii. the risks associated with taking an antimicrobial;
iii. whether there are simpler and safer options to pursue; and
iv. when you should take further actions if your symptoms worsen or do not improve.
d) Rather than keeping antimicrobials in your medicine cabinet, throwing them in the garbage/toilet or sharing them with family or friends, practise a One Health mindset. Dispose of all unused and expired antimicrobials at your local pharmacy. This will limit the spread of resistance and prevent antimicrobials from finding their way into the environment.
e) Help limit resistance by staying up to date with all recommended vaccinations, and practise good hand hygiene.
f) If you or a family member have had personal experiences with AMR, consider sharing them with local politicians (provincial/territorial and federal).
3. Governments (federal, provincial/territorial)
Should:
4
a) (Including internationally) immediately make substantial, long term, coordinated and directly dedicated financial investments in AMR and AMS. Specific areas to prioritize include:
i. AMR and AMS awareness campaigns targeted to the public;
ii. campaigns that support health professionals to incorporate AMS principles into their everyday practice;
iii. detailed, and integrated, action plans based on clear metrics of success and that address the needs of communities, primary care practitioners, patients and health care organizations (including long-term care facilities);
iv. practical surveillance of antimicrobial resistance, purchasing, prescribing and use that maximizes the opportunity to respond to changing landscapes;
v. studying in detail the links, and associated risks, between animal health and agricultural practices and human health;
vi. scaling up local AMS initiatives at the provincial/territorial and national health care delivery levels;
vii. pharmaceutical development pipelines and non-pharmacological treatment options for AMR infections;
viii. inexpensive, accurate and timely point-of-care diagnostic tests (usable in the community, at the bedside or in a clinic) to optimize prescribing; and
ix. fostering clinical research, development and innovation in the fields of AMR and AMS.
b) Scale up coordination between federal and provincial/territorial AMR and AMS activities.
c) Hold regular, high-level meetings of ministers of health, agriculture and finance (both federally and provincially/territorially) to discuss the implications of unchecked AMR and how best to mobilize public finances to address it.
d) Strongly consider an arms-length, national-level taskforce to address AMR and AMS.
e) Strengthen the roles of the chief public health officer and the provincial/territorial chief medical officers in addressing AMR and AMS.
f) Undertake a timely review of the Canadian Antimicrobial Resistance Surveillance System (CARRS) with an emphasis on:
i. scaling up the system;
ii. standardizing all AMR reporting metrics across the country; and
iii. injecting adequate resources into AMR surveillance and tracking antimicrobial usage rates.
g) Establish a permanent review body on infectious disease, including pharmacists, microbiologist and other experts, to evaluate the forthcoming Pan-Canadian Action Plan on AMR and release regular progress reports.
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4. Health care institutions and organizations
Should:
a) Implement strategic AMR plans that are coordinated, cross-departmental and adopted institution wide. These should be premised on:
i. standardized and comprehensive reporting metrics for AMR and antimicrobial usage;
ii. tailored infection prevention and control programs to screen for and effectively prevent new AMR infections;
iii. improving public and professional awareness of AMR organization wide;
iv. improving conservation measures such as prescribing practices (audit and feedback, incentives programs, etc.); and
v. supporting and incentivizing appropriate prescribing of antimicrobials.
b) Evaluate whether existing policies and procedures, diagnostics and testing capacities, and multidisciplinary and organizational cultures are strategically geared toward combatting AMR.
c) Where possible, develop collaborations with other local health institutions, clinical researchers and community, public and private partners to promote AMS.
5. Accreditation and regulatory bodies
Should:
a) Regularly review and establish meaningful criteria for accreditation, ethical codes and regulatory practice standards surrounding AMR and AMS so that practitioners and health institutions can be informed, supported and kept up to date on emerging AMR trends, practices and issues.
b) Adopt profession-specific mandatory requirements for AMR and AMS (proper credentialing and training, regular updating of knowledge and competence for prescribing antimicrobials, appropriate data collection regarding antimicrobial usage, etc.) as part of credentialing.
c) Work to promote, support and enhance existing AMS practices and programs.
d) Collaborate with health institutions, professional health associations and other accreditation and regulatory bodies to implement AMS goals/plans.
6. Colleges and faculties for medicine and allied health professions
Should:
a) Promote and support more educational resources for AMS and AMR, throughout the continuum of education (undergraduate, postgraduate and continuing education).
i. Topics for these resources should include (1) awareness of AMR and AMS, (2) appropriate diagnostic testing, (3) strategies to minimize antimicrobial use and (4) personal prescribing practices.
b) Promote and support research on AMR and the implementation and dissemination of effective AMS strategies.
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1 Public Health Agency of Canada. Tackling antimicrobial resistance and antimicrobial use: a pan-Canadian framework for action. Ottawa: Public Health Agency of Canada; 2017. Available: https://www.canada.ca/content/dam/hc-sc/documents/services/publications/drugs-health-products/tackling-antimicrobial-resistance-use-pan-canadian-framework-action/tackling-antimicrobial-resistance-use-pan-canadian-framework-action.pdf (accessed 2018 Aug 10).
BACKGROUND TO CMA POLICY
Antimicrobial Resistance
See also CMA Policy Antimicrobial Resistance PD19-08
OVERVIEW
The world is at the tipping point of a post-antibiotic era. “Worldwide, we are relying more heavily on antibiotics to ensure our medical, nutritional, and economic security; while simultaneously causing the decline of their usefulness with overuse and ill-advised use.” It is estimated that the world’s use of antimicrobials increased by 65% between 2000 and 2015 — mainly in low- to middle-income countries.
Dr. Margaret Chan, the former head of the World Health Organization (WHO), described antimicrobial resistance (AMR) as a slow-moving tsunami for public health. Other experts have characterized AMR as a looming “antibiotic apocalypse,” warning that all countries “will face disastrous consequences if the spread of AMR is not contained.” Others are now calling AMR the “climate change” of health care. According to the UK’s review on AMR, an estimated 10 million people globally will die annually by 2050, and AMR will surpass cancer to become the leading cause of death.
AMR occurs when “microorganisms (such as bacteria, fungi, viruses, and parasites) change when they are exposed to antimicrobial drugs (such as antibiotics, antifungals, antivirals, antimalarials, and anthelmintics). … As a result, the medicines become ineffective and infections persist in the body, increasing the risk of spread to others.” Microorganisms that develop antimicrobial resistance are sometimes referred to as “superbugs.” “Nightmare bacteria,” as they have been dubbed, are bacterial strains that no conventional antimicrobial can effectively treat; their incidence is on the rise.
AMR represents a unique challenge for the medical profession as it is estimated that as many as 50% of current antibiotic prescriptions are either inappropriate or unnecessary. In addition, taking an antimicrobial involves potentially considerable exposure to side effects or risk. At stake are many currently routine, and lifesaving, forms of medical treatment. Critically, these include many medications for currently treatable bacterial infections, and many forms of surgery (including cesarean delivery), radiation therapy, chemotherapy and neonatal care.4
THE UNDERLYING DYNAMICS OF AMR
AMR is driven by a complex set of interlocking factors. These include: (1) increased global travel and medical tourism; (2) inappropriate, and unnecessarily high, use of antimicrobials in the agrifood sector; (3) poor medical prescribing practices; (4) inadequate implementation of infection prevention and control measures; (5) lack of knowledge, inappropriate expectations and misuse of antimicrobials on the part of the general public; (6) availability of poor-quality antimicrobials; (7) lack of access to rapid, affordable and accurate rapid diagnostic tools and infrastructure; (8) inadequate and underused surveillance data from AMR surveillance systems; (9) international travel rates; and (10) low commercial interest in, or support for, new antimicrobial research and development.
To make progress on AMR, we need to carefully think about how to address its various drivers. Antimicrobial stewardship (AMS) is a term describing coordinated efforts, at any program level, to: (1) promote the appropriate use of antimicrobials; (2) improve patient outcomes; (3) reduce microbial resistance and preserve the effectiveness of antimicrobials; and (4) decrease the spread of infections caused by multidrug-resistant organisms. AMS efforts are based on the “One Health” approach. These include: (1) surveillance; (2) conservation of existing AM effectiveness; (3) innovation through research and development; and (4) infection prevention and control.
Fundamentally, AMR can be thought of as a collective action problem, similar in character to the problem of climate change.3, While all stakeholders have a role to play in combatting AMR, each has very different resources, abilities and perspectives on AMR. Canada and much of the developed world have the luxury of health infrastructures, finances and regulatory frameworks that can make AMR mitigation possible. But in low- to middle-income countries — places where antibiotics might be the only real health care available — the very discussion of AMS can be perceived as threatening. Simply put, this illustrates the fact that solutions to AMR need to mobilize and leverage a collective strategy that is as broad and as connected as possible. To be successful, these solutions will need to do so in a manner that acknowledges the local reality of health care delivery.
Global investment in antimicrobial research and development is underwhelming, a dynamic described as a “drying up” of the pharmaceutical pipeline.8 This is evidenced by the recent large-scale withdrawal of major pharmaceutical companies from antimicrobial research and development, reflecting the lack of profitability in this area. On the pharmaceutical side, there are clear barriers to companies investing in the development of novel antimicrobials. Underlying factors include: (1) 10-year timelines, and an estimated minimum $1 billion price tag for development; (2) high development failure rates for new antimicrobials; (3) the inevitable emergence of resistance to any newly developed antimicrobial; (4) antimicrobials being offered at relatively cheap dosage rates over shorter durations of use; and (5) the need to preserve the efficacy of any antimicrobial’s future use, which limits their economic viability.8
WHAT ARE THE CANADIAN CONTEXTS?
AMR is already a major costly public health challenge in both the US and Canada. AMR infections are clearly linked to poorer health outcomes, longer hospital stays and higher mortality rates.3 The Public Health Agency of Canada (PHAC) estimates that roughly 18,000 hospitalized Canadians contract drug-resistant infections per year. The Canadian Patient Safety Institute estimates that 8,000 Canadian patients die annually with an AMR-related infection. It is estimated that close to 23 million antibiotic prescriptions are written annually for patients in Canada, the approximate equivalent to 1.6% of the population being on an antimicrobial on any given day.
An action plan in Canada is being developed by PHAC. On the surface, the action plan appears comprehensive in that it outlines a One Health approach.10 However, despite commitments to take comprehensive, measurable action on AMS, Canadian leadership on AMR has historically lagged because of a lack of concrete coordination between PHAC and the provinces and because it has been challenging to implement local initiatives systemically.
Previous shortcomings were highlighted in the Auditor General of Canada’s 2015 report and again in a 2017 issue brief by HealthCareCAN.18 Although efforts continue and the action plan is set for release at some point in 2019, concerns remain that: (1) the scope of coordinated efforts with the provinces and territories requires an interest in cooperation that may not exist between the two levels of government; (2) relative to the scope of the problem, sufficient and dedicated resources won’t be allocated; and (3) efforts on the industrial and agricultural fronts may not be sufficiently coordinated with AMR efforts for human health.
In the spring of 2018 the House of Commons Standing Committee on Health (HESA) released a report outlining 10 recommendations for action on AMR in Canada. Although the federal government “accepted” most of the committee’s recommendations, no meaningful (and dedicated) AMR funding has been announced in advance of the action plan’s launch. Indeed, the federal government’s response to the HESA report sought to downplay the need for either urgent action or additional resources. This was done by pointing to nominal federal AMR efforts over the span of more than a decade.
It should be noted that a small number of excellent localized AMS initiatives exist and have begun yielding promising local AMS results in Canada. AMR and AMS champions such as Choosing Wisely Canada, Do Bugs Need Drugs, and the Association of Medical Microbiology and Infectious Disease Canada have long argued that with proper resourcing, localized initiatives can be scaled up to a systemic level of application within provincial health care systems.
GLOBALLY, WHERE DOES AMR STAND?
Urgent action is required at an international level to combat AMR. Although AMR remains a complex public health challenge, the benefits of AMS are clear. The preservation of these precious resources will save lives and can positively affect both quality of care and health care delivery costs.7,14 Globally, many higher income nations and, increasingly, middle-income countries have now developed AMR/AMS action plans. Like the situation in Canada, these emerging and existing global action strategies remain largely unimplemented. Initial cash infusions into the AM drug development pipeline are beginning to emerge.8
Despite this, experts warn that such investments are too short term and wholly inadequate to address the scope of the looming AMR crisis.8, This reflects the many complexities that exist in the implementation of AMR action plans, owing in large part to: (1) a general lack of resources or prioritization; (2) complacency about AMR as a pressing public health concern; (3) difficulties in generalizing local AMS efforts; (4) coordination between sectorial actors; and (5) a lack of tangible AMR metrics and evidence.
If AMS gains are to be made in low- and middle-income countries, the impact of limited resources in those settings will need to be considered.13 Realistically these countries will require various forms of monetary incentives and assistance to be able to effectively adopt AMR programs. If such support is not provided, human health rights will be affected and global AMS efforts will be undermined. Finally, there are now well-established calls for an international model, even a treaty, to be implemented on AMR/AMS.12,
The Canadian Medical Association appreciates this opportunity to respond to Health Canada’s consultation on the proposed regulations for edible cannabis, cannabis extracts, and cannabis topicals.
The CMA’s approach to cannabis is grounded in public health policy. It includes promotion of health and prevention of problematic use; access to assessment, counselling and treatment services; and a harm reduction perspective. The CMA endorsed the Lower-Risk Cannabis Use Guidelines and has expressed these views in our recommendations to the Task Force on Cannabis Legalization and Regulation, recommendations regarding Bill C-45. As well, we submitted comments to Health Canada with respect to the consultation on the proposed regulatory approach for the Cannabis Act, Bill C-45.
Canada’s physicians have a longstanding concern about the health risks associated with consuming cannabis. , Consumers use these products for both recreational and medical purposes, compelling the need for accuracy in the labeling as well as quality control in the manufacturing process.10
Cannabis Edibles, Extracts and Topicals
Cannabis will have a different effect on the user, depending on whether it is smoked or ingested, as in an edible. It has been found that “smoking marijuana results in clinical effects within 10 minutes, peak blood concentrations occur between 30 and 90 minutes, and clearance is complete within 4 hours of inhalation. Oral THC does not reach significant blood concentration until at least 30 minutes, with a peak at approximately 3 hours, and clearance approximately 12 hours after ingestion.” Because of the delay in absorption when ingested, people might consume more to feel the psychoactive effects faster. This might lead to the consumption of very high doses and result in toxic effects, such as anxiety, paranoia and in rare cases, a psychotic reaction with delusions, hallucinations, incoherent speech and agitation.
Rates of use of edibles are not well known. A recent study in California high schools found that “polyuse via multiple administration methods was a predominant pattern of cannabis use and report the first evidence, to our knowledge, of triple product polyuse of combustible, edible, and vaporized cannabis among youths.”
We are limiting our response to Health Canada’s consultation questions that pertain to the CMA’s position with respect to cannabis and relate to our expertise and knowledge base.
Proposed THC limits for the new classes of cannabis products
Standardization within all classes of cannabis products in a legal regime is essential. Tetrahydrocannabinol (THC) levels in black market products can vary widely so one can never be assured of the strength being purchased, creating the potential for significant harm. ,
Experience in jurisdictions where cannabis has been legalized has shown that restrictions on the potency of products (i.e., THC limits) are necessary, given the higher risks of harm associated with higher potencies.2 Prohibition of high potency products is important.3
THC limits should be based on the best available evidence of safety for consumers. The increased potency of cannabis over the years raises concerns about its use in edibles, extracts and topicals, offering a significant challenge with respect to regulating their use. This becomes particularly worrisome with respect to preadolescents and adolescents who should avoid using cannabis due to concerns with the impact on the developing brain.2 Use has been associated with a “significant increased risk of developing depression or suicidality in young adulthood.”
More research is needed with respect to the effects of cannabis on all age groups, especially children, adolescents and seniors. Saunders et al describe the case of an elderly patient with a history of coronary artery disease suffering what appears to have been a myocardial infarction after ingesting most of a marijuana lollipop that contained 90 mg of THC. Such cases demonstrate how crucial it is to establish appropriate levels of THC. This is an especially important consideration because “consuming cannabis-infused edibles may inadvertently result in toxicity because absorption can take hours, compared with minutes when smoking. An individual who does not yet feel an effect may over-consume.”
Small children and people with cognitive impairment will not be able to read labels, so preventive measures are very important, as with any pharmaceutical. Since legalizing cannabis, Colorado’s Rocky Mountain Poison & Drug Center has reported an increase in calls related to edible exposures. Children can accidentally eat products that contain cannabis, making them ill enough to seek medical assistance.
The CMA maintains that the proposed draft regulations of 10 mg per discrete unit and package is too high and should be established at a maximum of 5 mg per dose, given the higher risks of overconsumption with edibles, the risks of accidents in children and the experience in other jurisdictions. Colorado’s limit was set at 10 mg per unit, and health authorities recognize that a lower limit would have been warranted to prevent more accidents. Other preventive measures, such as child proof packaging, are considered in other sections of this brief.
The amount of THC must be displayed clearly and prominently on the package to help prevent accidental or overconsumption of the product.
Rules addressing the types of ingredients and additives that could be used in edible cannabis, cannabis extracts, and cannabis topicals appropriately address public health and safety risks while enabling sufficient product diversity
The CMA concurs with the proposed regulations. Experience in areas such as caffeinated, high-sugar alcoholic beverages provides ample evidence to proceed with restraint concerning the types of ingredients and additives that may be permitted in edible cannabis, cannabis extracts, and cannabis topicals.
Proposed new rules for the packaging and labelling of the new classes of cannabis products
The CMA reiterates its position with respect to the packaging and labelling of cannabis products as presented in its submission on the proposed approach to the regulation of cannabis.5 This includes:
a requirement for plain and standard packaging
prohibition of the use of appealing flavours and shapes,
a requirement for adequate content and potency labelling,
a requirement for comprehensive health warnings,
a requirement for childproof packaging, and
a requirement that the content in a package should not be sufficient to cause an overdose.
Plain and standardized packaging is necessary with respect to edibles as their wider availability raises several public health issues, not the least of which is ingestion by young children. It is imperative that the packages and labels of edibles not resemble popular confectionaries, for example. As the Canadian Paediatric Society has noted, “the unintended consumption of edibles manufactured to look like sweets by younger children is particularly concerning.”15 Also, by “restricting the extent to which marijuana edibles can look and taste like familiar sweets, (it) could also keep the psychological barriers to marijuana initiation among children and adolescents from being lowered.” The CMA has adopted similar positions with respect to tobacco and vaping products. , ,
It is recognized that these regulations are targeted at products meant for the adult market, but the entry of these new classes also creates challenges beyond that audience. Teens are attracted to vaping cannabis rather than smoking it because “smoke is not combusted and also may allow for more covert use given the reduction in odor.” , As well, as “edibles have no odor, they are largely undetectable to parents.”23
The CMA views this as an opportunity to educate Canadians about the health, social and economic harms of cannabis especially in young people. Package inserts must outline and reinforce the health risks involved; they must also be designed by governments and health professionals, not cannabis producers or distributors.
Inserts should include:5
information on securing the product in the home to prevent access by youth and children,
recommendations not to drive or to work with hazardous chemicals or operate equipment while using the contents of the package,
information on the health and social consequences (including legal penalties) of providing cannabis to those under a designated minimum age for purchasing, and
contact information for hotlines for poison control and for crisis support.
Cannabis topicals, as outlined in the proposed regulations, would fall under the category of health products and be found in non-prescription drugs, natural health products, and cosmetics. The CMA believes that all health claims need to be substantiated with sufficient evidence that meets standards for efficacy, besides safety and quality, to protect Canadians from misleading claims.5 This is important because the level of proof required to obtain a Drug Identification Number (DIN) for prescription drugs is considerably higher than the level of proof required for a Natural Product Number (NPN); rigorous scientific evidence for effectiveness is needed for a DIN but not for an NPN. Consumers generally do not know about this distinction, believing that Health Canada has applied the same level of scrutiny to the health claims made for every product.5
Requirements for tamper-resistant and child-proof containers need to be in place to enhance consumer safety. More research is required to address the environmental concerns with extra packaging, which would result from single dose packaging. It is critical to put in place measures that make it difficult to ingest large doses of THC. Simply adding grooves to chocolate bars or baked goods, for example, separating different doses, is insufficient to prevent people, particularly children, from ingesting more than a dose (which in of itself is designed for an adult). As well, there is no guarantee that the THC is spread out uniformly throughout the product.
More research is needed with respect to “determining risks and benefits through proper clinical trials;” that includes determining the safest level of THC for extracts and topicals to reassure consumers will not be harmed by these products.18
With regards to cannabidiol (CBD), it would seem that “published data from around the world has taught us that misleading labels as well as harmful contaminants are real and actual problems for CBD products.”18 Health claims need to be substantiated via a strong evidentiary process. There will be a need for careful monitoring of the health products released in the market and the health claims made.5 Experience has shown that regulations can and will be circumvented, and these activities will have to be addressed.
Edible cannabis and the requirement for all products to be labelled with a cannabis-specific nutrition facts table
Yes. The CMA supports the use of a cannabis-specific nutrition facts table (NFT) as described in the proposed regulations.1 These products should have the same standards and regulations applied to them as traditional food products do under the Food and Drugs Regulations. As such, a cannabis-specific nutrition facts table will help consumers differentiate them from standard food products.
The proposal for the labelling of small containers and the option to display certain information on a peel-back or accordion panel
The size of the container should not be an impediment to supplying consumers with the necessary information to make informed choices. Manufacturers should be required to use whatever method (peel-back or accordion panel) is most efficient and conveys all the necessary information. As the CMA noted in a recent brief with respect to tobacco labeling the “amount of space given to the warnings should be sufficient to convey the maximum amount of information while remaining clear, visible, and legible. The warnings should be in proportion to the packaging available, like that of a regular cigarette package.”20 Adding warnings on individual cigarettes, as we recommended, illustrates that it is feasible to apply important information to even the smallest surfaces.20
It is important to note that key information should be visible on the external part of the container, including the standardized cannabis symbol, ingredients and warnings.
Proposal that the standardized cannabis symbol would be required on vaping devices, vaping cartridges, and wrappers
Yes. As noted earlier, the CMA called for strict packaging requirements around both tobacco and vaping products.22 The requirement for the standardized cannabis symbol is an extension of that policy and to the labelling of cannabis products in general.5
Proposed new good production practices, such as the requirement to have a Preventive Control Plan, appropriately address the risks associated with the production of cannabis, including the risk of product contamination and cross-contamination
Yes. The CMA concurs with this requirement.
The requirement that the production of edible cannabis could not occur in a building where conventional food is produced
Yes. The CMA concurs with this requirement. Separate facilities are necessary to prevent cross-contamination for the protection of consumer health and safety.
Conclusion
The CMA supports the federal government’s commitment to a three-year legislative review as it affords the opportunity to evaluate the regulations’ impact and adjust them as needed. It continues to be important to have good surveillance and monitoring systems, as well as to continue to learn from other jurisdictions where cannabis is legal for recreational purposes.
Public education and awareness must accompany the introduction of new forms of cannabis, emphasizing the risks of accidental ingestion and overconsumption. It should also emphasize the need for safe storage of cannabis products, as well as personal possession limits.
Much more research is needed into the impact of these new classes across all age groups, and into public health strategies that discourage use and increase harm reduction practices. It is fundamental that profit driven commercialization is rigorously controlled through taxation, regulation, monitoring and advertising controls, in a manner that is consistent with a public health approach.
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Standardized Appearance). Ottawa: CMA; 2018. Available: https://policybase.cma.ca/en/permalink/policy13930 (accessed 2019 Feb 05).
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FIREARMS CONTROL (UPDATE 2001)
Summary
Firearms are a major cause of death and injury in Canada and account for nearly 1,400 deaths annually. The CMA has made several recommendations to governments and other bodies undertaking legislative review and public policy change. These recommendations relate to the regulation of firearms, education for the safe handling of firearms, broad-based violence prevention programs, and research and information provision. In addition, the CMA has produced guidelines to assist physicians in identifying and counselling patients at risk of violent behaviour and in reporting patients at risk.
Firearms are a major cause of death and injury in Canada.. The cost to society of firearm-related injury, particularly spinal cord and head injuries, is considerable.
Over the short term, policy should focus on firearms and the user. Applying stringent controls on firearms, however, may have little effect on the rates of death and injury if the underlying problems of violence in society are not addressed.
In an effort to accommodate both short-term and long-term solutions the CMA recommends the following to governments and bodies undertaking legislative review and public policy change.
Regulation
The object of regulation should be to deter people at risk for violent or self-destructive behaviour from having easy access to firearms. A regulatory policy should address (a) the acquisition of firearms (e.g., licensing of firearms and/or users, processes to screen would-be purchasers who are at risk), b) secure firearm and ammunition storage methods and modifications to firearms that would render them less accessible to children or those acting on violent impulses and (c) severe penalties for offenses such as the use of a firearm in the commission of a crime or an act of violence, including family violence.
Education
Training in safe handling of firearms is strongly recommended, particularly for all first-time firearm users. Broader-based education programs aimed at the prevention of violence (e.g., in schools) may also be efficacious and should be evaluated for their impact in reducing violence.
Research and information provision
CMA encourages research in a number of areas, including the following.
Firearm surveillance: the types of firearms or classes of ammunition disproportionately involved in intentional deaths and injuries, the circumstances surrounding a firearm incident (e.g., argument between friends, alcohol involvement) and data on injuries and deaths.
Determination of behavioural or environmental risk factors for violent behaviour: the relative risk or benefit of keeping a firearm at home for protection i.e.. the scientific assessment of the deterrence effect):
The effects of factors such as alcohol, drug use and family history of violence on the risk of violent death; and how accurately experts can identify people at risk.
Case-control and cohort studies on gun control, crime and the antecedents of violent behaviour.
Evaluation of education programs that discourage firearm-related violence or promote safe handling of firearms.
Role of physicians
The CMA recommends that physicians consider the following guidelines.
Management of patients at risk
It is not always possible to identify people at risk of violent or self-destructive behaviour; however, the CMA recommends that physicians be alert to warning signs that a patient may be at risk and manage that patient accordingly. For example, always ask depressed patients about suicidal and homicidal thoughts and plans (asking will not plant ideas); admit suicidal patients to hospital, even against their will, particularly if they do not have supportive families who can monitor them at home; have the family remove all firearms from the home of a patient at risk; and monitor the patient frequently, writing small prescriptions if medication is required.
Good clinical judgement and close follow-up are perhaps the most effective ways of managing a self-destructive or violent patient.
Reporting of patients at risk
No specific guidelines exist for the reporting of patients at risk of violent behaviour. The physician should consider whether the risk of harm to society (or a third party) posed by a patient outweighs that patient's right to confidentiality.
Counselling and public advocacy
A physician may be asked for a reference for an applicant of a firearms acquisition certificate. Before providing the reference the physician should consider the applicant carefully for risk factors, recommend appropriate firearms training and caution against the concomitant use of firearms, alcohol and other drugs.
A physician should become an advocate for nonviolent conflict resolution. As research accumulates about the most effective interventions for nonviolent conflict resolution the health sector may be able to draw on this research to work to reduce violence in society.
Like motor vehicle and bicycle safety, firearm safety is a public health issue. The CMA holds that physicians, as advocates for the health of Canadians, can help reduce firearm-related damage and address the concomitant underlying problem of violence in society.
