Quebec’s college of pharmacists, the L'Ordre des pharmaciens du Québec (OPQ), presented their position on the province’s cannabis Bill 157 to the Quebec Commission on Health and Social Services yesterday as part of the government’s ongoing hearings from stakeholders. While most of their recommendations focus on provincial recreational cannabis legislation, the college was keen to communicate an important message regarding cannabis used for medical purposes: people who are prescribed such treatment must be able to benefit from the services pharmacists provide.
It was interesting in light of my previous article, which shows how amendments to the federal legislation (C-45) would allow medical cannabis to be distributed through Canadian pharmacies, rather than through the current mail order channels direct from licensed producers. The OPQ wants pharmacists to be entrusted with the distribution of therapeutic cannabis to 6300+ current registrants in the province, under certain conditions, to ensure that users receive care from a regulated professional – subject to a professional inspection mechanism, a code of ethics, respect for confidentiality and with resources to complete analysis of drug therapy.
"This position statement is the result of a long reflection," said Bertrand Bolduc, president of the OPQ. He said they arrived at the conclusion that, despite the special status of medical cannabis, patients who use it are not different from the users of any other drug. “That is why we are asking the Quebec government to accompany us in representations for an amendment to the federal regulation.”
Here are the highlights from yesterday’s announcement:
Formal ban on the sale of cannabis for non-medical purposes by a pharmacist
The OPQ says pharmacists should not be involved in the production or sale of cannabis for non-medical purposes. The college also requests that cannabis for non-medical purposes be subject to the same framework as tobacco, including the rules on advertising, but also the prohibition of sales in businesses adjacent to pharmacies.
Clear information and service corridors
The use of non-medical cannabis is not without risk, especially for people who suffer from health problems. In this sense, the OPQ recommends consumers be made aware of possible drug interactions and contraindications related to its consumption. In addition, the college asked that pharmacists have access to service corridors to direct patients with signs of psychosis or who need addiction support. "It should be avoided that patients who have such needs end up in the emergency," Bolduc said.
Maintaining the ban on homegrown culture: unreserved support
The OPQ supports the government's intention to maintain a ban on non-medical cannabis cultivation at home.
"In Colorado, the number of pediatric emergency visits for cannabis intoxication doubled after legalization, and a 34 per cent increase in cases referred to the poison control center was noted,” reads the OPQ’s announcement. ”Whether access to a plant or processed products, the more access to minors, the greater the risk of intoxication increase.”
Pharmacist presence on the vigilance committee
Bill 157 provides for the creation of a vigilance committee whose role would be to advise the minister on any questions relating to cannabis. Due to growing drug and drug issues, the expertise of pharmacists is crucial. The college therefore requests that a seat be provided for a pharmacist on this committee.
More details from the OPQ’s recommendations on Bill 157
- The Quebec government formally accompanies l’Ordre des pharmaciens du Québec in requesting a modification of the proposed federal regulations that would allow pharmacists in private practice to be included in the chain of distribution for cannabis for medical purposes.
- Add more information to article 51 51(4) about the efficacy, safety, adverse effects and utilization of different devices, forms and strengths of cannabis for medical purposes.
- Exclude the possibility of a pilot project permitting the sale of cannabis for non-medical purposes by a pharmacist. The government may, by order, authorize the minister to implement a pilot project on any matter within the scope of this Act or the regulations with a view to studying, improving or defining standards for those matters. It may also authorize the Minister of Finance to implement a pilot project on the retail sale of cannabis, with the exception of sale of cannabis for non-medical purposes by a pharmacist. The OPQ would also like to see article 18 of the Tobacco Control Act added to the bill. This article could read as follows: It is prohibited to sell cannabis in a business if a) a pharmacy is located within the business or b) the customers of a pharmacy can pass into the business directly or by the use of a corridor or area used exclusively to connect the pharmacy with the business.
- The government should modify article 77 of pharmacists’ Code of Ethics, which outlines the acts that are derogatory to the dignity of the profession, and add a paragraph related to the production and sale of cannabis for non-medical purposes.
- Replace article 24 of the Pharmacy Act with the following: it is prohibited for a pharmacist, in the course of practising his/her profession, to prescribe, provide to a person to whom a practitioner has provided a medical document, or to recommend to a person a medication produced by a business in which he/she has a direct or indirect interest or to substitute for a prescribed medication a medication produced by said business.
- Include a provision under article 26 that medication interactions and contraindications be part of the information that must be communicated by La Société Québécoise du Cannabis (a crown corporation and SAQ subsidiary) to all consumers, and this, for sales carried out via storefront or via the internet.
- Employees of La Société Québécoise du Cannabis should be required to complete a basic training program that will sensitize them to the risks related to the concomitant use of medications and cannabis. These employees should also have access to a communication tool, in paper or electronic format, designed to spread warnings required for consumers, for cannabis bought via storefront or the internet.
- The government should provide access, to both healthcare professionals and any stakeholders, to services for patients presenting signs of psychosis or who require addictions support, and they should be able to without requiring a medical referral.
- Create cannabis education programs for affected healthcare professionals, and/or fund them from cannabis revenues, or fund healthcare professionals to create research and harm reduction programs related through cannabis revenues.
- Maintain the prohibition against the at-home cultivation of cannabis for non-medical purposes.
- In relation to the advertising, promotion and packaging of cannabis for non-medical purposes, the government should apply and maintain, at a minimum, the same rules that apply for tobacco.
- Provide a seat for a pharmacist on the Monitoring Committee.
Will the federal government accept the OPQ’s suggested amendments to C-45, which would permit Quebec and other provinces/territories to pass resolutions enabling pharmacists to dispense medical cannabis?
Health Canada is holding a consultation on the Proposed Approach to the Regulation of Cannabis, which closes on January 20 (this Saturday), so stay tuned.