Removing barriers to accessing medical cannabis for paediatric patients.

Medical cannabis (MC) may offer therapeutic benefits for children with complex neurological conditions and chronic diseases. In Canada, parents, and caregivers frequently report encountering barriers when accessing MC for their children. These include negative preconceived notions about risks and benefits, challenges connecting with a knowledgeable healthcare provider (HCP), the high cost of MC products, and navigating MC product shortages. In this manuscript, we explore several of these barriers and provide recommendations to decision-makers to enable a family-centered and evidence-based approach to MC medicine and research for children.

Canadian Regulatory Framework and Regulatory Requirements for Cell and Gene Therapy Products.

Health Canada regulates gene therapy products and many cell therapy products as biological drugs under the Canadian Food and Drugs Act and its attendant regulations. Cellular products that meet certain criteria, including minimal manipulation and homologous use, may be subjected to a standards-based approach under the Safety of Human Cells, Tissues and Organs for Transplantation Regulations. The manufacture and clinical testing of cell and gene therapy products (CGTP) presents many challenges beyond those for protein biologics. Cells cannot be subjected to pathogen removal or inactivation procedures and must frequently be administered shortly after final formulation. Viral vector design and manufacturing control are critically important to overall product quality and linked to safety and efficacy in patients through concerns such as replication competence, vector integration, and vector shedding. In addition, for many CGTP, the value of nonclinical studies is largely limited to providing proof of concept, and the first meaningful data relating to appropriate dosing, safety parameters, and validity of surrogate or true determinants of efficacy must come from carefully designed clinical trials in patients. Addressing these numerous challenges requires application of various risk mitigation strategies and meeting regulatory expectations specifically adapted to the product types. Regulatory cooperation and harmonization at an international level are essential for progress in the development and commercialization of these products. However, particularly in the area of cell therapy, new regulatory paradigms may be needed to harness the benefits of clinical progress in situations where the resources and motivation to pursue a typical drug product approval pathway may be lacking. This chapter is dedicated to provide an overview of Health Canada regulatory oversight of CGTP.

On what basis did Health Canada approve OxyContin in 1996? A retrospective analysis of regulatory data.

The marketing and sale of oxycodone (OxyContin) by Purdue Pharma has commanded a great deal of legal and policy attention due to the drug's central role in the ongoing overdose crisis. However, little is known about the basis for OxyContin's approval by regulators, such as Health Canada in 1996. Taking advantage of a recently created online database containing information pertaining to the safety and effectiveness of drugs, we conducted a retrospective analysis of Purdue Pharma's submission to Health Canada, including both published and unpublished clinical trials. None of the trials sponsored by Purdue Pharma sought to meaningfully assess the risks of misuse or addiction associated with OxyContin. The trials were short in duration (maximum length was 24 days) and only assessed safety and efficacy of a 12-h dosing interval. Also, the two trial reports that explicitly mentioned (but did not formally evaluate) the risk of misuse were not published, making it unclear how Health Canada concluded that there was no risk of misuse. In our view, these findings underscore the need for transparency of not only of clinical trial data, but also the regulator's interpretation of such data, which is currently lacking in Canada. Furthermore, they call into question why Health Canada's role in precipitating the overdose crisis has not received greater scrutiny, including in the context of recent litigation surrounding OxyContin.

COVID-19 pathophysiology and pharmacology: what do we know and how did Canadians respond? A review of Health Canada authorized clinical vaccine and drug trials.

Coronavirus disease 2019 (COVID-19) has resulted in the death of over 18 000 Canadians and has impacted the lives of all Canadians. Many Canadian research groups have expanded their research programs to include COVID-19. Over the past year, our knowledge of this novel disease has grown and has led to the initiation of a number of clinical vaccine and drug trials for the prevention and treatment of COVID-19. Here, we review SARS-CoV-2 (the coronavirus that causes COVID-19) and the natural history of COVID-19, including a timeline of disease progression after SARS-CoV-2 exposure. We also review the pathophysiological effects of COVID-19 on the organ systems that have been implicated in the disease, including the lungs, upper respiratory tract, immune system, central nervous system, cardiovascular system, gastrointestinal organs, the liver, and the kidneys. Then we review general therapeutics strategies that are being applied and investigated for the prevention or treatment of COVID-19, including vaccines, antivirals, immune system enhancers, pulmonary supportive agents, immunosuppressants and (or) anti-inflammatories, and cardiovascular system regulators. Finally, we provide an overview of all current Health Canada authorized clinical drug and vaccine trials for the prevention or treatment of COVID-19.

Current state of Health Canada regulation for cellular and gene therapy products: potential cures on the horizon.

We provide an overview of the regulatory framework, pathways and underlying regulatory authority for cell, gene and tissue-engineered therapies in Canada. Canada's regulatory approach uses three sets of regulations, namely, the Cells, Tissues and Organs Regulations, the Food and Drug Regulations and the Medical Devices Regulations. We provide an overview of each these sets of regulations as they apply to clinical investigation to post-market product lifecycle stages. Information is provided on the current sources of relevant Health Canada guidance documents. We highlight several regional success stories including Prochymal, a cell therapy product that achieved Canadian regulatory approval using the conditional marketing approval system. We also examine the perceived gaps in the Canadian regulations and how those gaps are being addressed by interactions between the government, stakeholders and international bodies. We conclude that the risk-benefit approach used by Health Canada for regulatory approval processes is sufficiently flexible to enable to development of novel cell and gene therapy products in Canada, yet stringent enough to protect patient safety.

Pediatric drug regulation: International perspectives.

There was a time when the predominant approach to exposing children to new drugs was to protect children from research. This has evolved over the past several decades into protecting children through research. To encourage pediatric studies and approval of pediatric medicines, governments have provided financial incentives as well as obligations/requirements for pharmaceutical companies to carry out pediatric studies in certain circumstances. The unique considerations for children have been acknowledged by the various governments and drug regulatory agencies through international dialogue and cooperation among patient and patient care representatives, regulatory agencies, and academic, clinical and manufacturing stakeholders. We describe pediatric drug regulation in five of the largest international drug regulatory agencies and additionally discuss efforts at international cooperation and discussion in pediatric drug regulation.

Comparison of nutrient profiling models for assessing the nutritional quality of foods: a validation study.

Nutrient profiling (NP) is a method for evaluating the healthfulness of foods. Although many NP models exist, most have not been validated. This study aimed to examine the content and construct/convergent validity of five models from different regions: Australia/New Zealand (FSANZ), France (Nutri-Score), Canada (HCST), Europe (EURO) and Americas (PAHO). Using data from the 2013 UofT Food Label Information Program (n15342 foods/beverages), construct/convergent validity was assessed by comparing the classifications of foods determined by each model to a previously validated model, which served as the reference (Ofcom). The parameters assessed included associations (Cochran-Armitage trend test), agreement (κ statistic) and discordant classifications (McNemar's test). Analyses were conducted across all foods and by food category. On the basis of the nutrients/components considered by each model, all models exhibited moderate content validity. Although positive associations were observed between each model and Ofcom (all P trend<0·001), agreement with Ofcom was 'near perfect' for FSANZ (κ=0·89) and Nutri-Score (κ=0·83), 'moderate' for EURO (κ=0·54) and 'fair' for PAHO (κ=0·28) and HCST (κ=0·26). There were discordant classifications with Ofcom for 5·3 % (FSANZ), 8·3 % (Nutri-Score), 22·0 % (EURO), 33·4 % (PAHO) and 37·0 % (HCST) of foods (all P<0·001). Construct/convergent validity was confirmed between FSANZ and Nutri-Score v. Ofcom, and to a lesser extent between EURO v. Ofcom. Numerous incongruencies with Ofcom were identified for HCST and PAHO, which highlights the importance of examining classifications across food categories, the level at which differences between models become apparent. These results may be informative for regulators seeking to adapt and validate existing models for use in country-specific applications.

Commentary: The Invention of Aboriginal Diabetes: The Role of the Thrifty Gene Hypothesis in Canadian Health Care Provision.

The purpose of this study was to analyze the extent to which the 'thrifty gene hypothesis' remains embedded within regimes of Canadian health care. The thrifty gene hypothesis, formulated by the American geneticist and travelling scientist James V. Neel in 1962, proposed that Indigenous peoples were genetically predisposed to Type 2 diabetes due to the foodways of their ancestors. The hypothesis was functionally racist and based on what biological anthropologists now call 'the myth of forager food insecurity.' Importantly, Neel reconsidered his own hypothesis in 1982 before he ultimately rejected it in 1999; nonetheless, in the mid-1990s, a team of Canadian scientists led by the endocrinologist Robert Hegele of Western University conducted a genetic study on the OjiCree community of Sandy Lake First Nation in northern Ontario. Thereafter, Hegele told the academic world and news media that he had discovered a thrifty gene in Sandy Lake. Like Neel, Hegele later came to reject his own study in 2011. Nonetheless, the 'thrifty gene hypothesis' and Hegele's Sandy Lake study continue to be cited, referenced, and reproduced in the current Clinical Guidelines of the Canadian Diabetes Association, as well as across state-related health literature more broadly. The purpose of this study, then, will be to apply the PHCRP to the thrifty gene hypothesis in a Canadian context.

Unregulated serving sizes on the Canadian nutrition facts table - an invitation for manufacturer manipulations.

BACKGROUND: Serving sizes on the Nutrition Facts table (NFt) on Canadian packaged foods have traditionally been unregulated and non-standardized. The federal government recently passed legislation to regulate the serving sizes listed on the NFt. The objective of this study was to compare the serving sizes on food product NFts to the recommendations in the 2003 Nutrition Labelling regulation (Schedule M) reference amounts, the Canadian Food Inspection Agency (CFIA) ranges, and Canada's Food Guide recommendations. An additional objective was to determine if food and beverage products that report smaller serving sizes have a higher calorie density, compared to similar products with a larger serving size. METHODS: Data for 10,487 products were retrieved from the 2010 Food Label Information Program (FLIP) database and categorized according to Schedule M categories. Correlations between calorie density and manufacturer stated serving size were tested and the proportion of products meeting recommendations were tabulated. RESULTS: 35% of products had serving sizes on the NFt that were smaller than the Schedule M reference amount and 23% exceeded the reference amount. 86% of products fell within the CFIA's recommended serving size ranges; however, 70% were within the lower-half of the range. Several bread and juice categories exceeded CFG's recommendations, while several dairy product categories were smaller than the recommendations. Of the 50 Schedule M sub-categories analyzed, 31 (62%) exhibited a negative correlation between serving size and calorie density. CONCLUSION: While most products fell within the CFIA's recommended serving size ranges, there was a tendency for products with a higher calorie density to list smaller serving sizes.

Assessing the nutritional quality of diets of Canadian children and adolescents using the 2014 Health Canada Surveillance Tool Tier System.

BACKGROUND: Health Canada's Surveillance Tool (HCST) Tier System was developed in 2014 with the aim of assessing the adherence of dietary intakes with Eating Well with Canada's Food Guide (EWCFG). HCST uses a Tier system to categorize all foods into one of four Tiers based on thresholds for total fat, saturated fat, sodium, and sugar, with Tier 4 reflecting the unhealthiest and Tier 1 the healthiest foods. This study presents the first application of the HCST to examine (i) the dietary patterns of Canadian children, and (ii) the applicability and relevance of HCST as a measure of diet quality. METHODS: Data were from the nationally-representative, cross-sectional Canadian Community Health Survey 2.2. A total of 13,749 participants aged 2-18 years who had complete lifestyle and 24-hour dietary recall data were examined. RESULTS: Dietary patterns of Canadian children and adolescents demonstrated a high prevalence of Tier 4 foods within the sub-groups of processed meats and potatoes. On average, 23-31 % of daily calories were derived from "other" foods and beverages not recommended in EWCFG. However, the majority of food choices fell within the Tier 2 and 3 classifications due to lenient criteria used by the HCST for classifying foods. Adherence to the recommendations presented in the HCST was associated with closer compliance to meeting nutrient Dietary Reference Intake recommendations, however it did not relate to reduced obesity as assessed by body mass index (p > 0.05). CONCLUSIONS: EWCFG recommendations are currently not being met by most children and adolescents. Future nutrient profiling systems need to incorporate both positive and negative nutrients and an overall score. In addition, a wider range of nutrient thresholds should be considered for HCST to better capture product differences, prevent categorization of most foods as Tiers 2-3 and provide incentives for product reformulation.

International Harmonization and Cooperation in the Validation of Alternative Methods.

The development and validation of scientific alternatives to animal testing is important not only from an ethical perspective (implementation of 3Rs), but also to improve safety assessment decision making with the use of mechanistic information of higher relevance to humans. To be effective in these efforts, it is however imperative that validation centres, industry, regulatory bodies, academia and other interested parties ensure a strong international cooperation, cross-sector collaboration and intense communication in the design, execution, and peer review of validation studies. Such an approach is critical to achieve harmonized and more transparent approaches to method validation, peer-review and recommendation, which will ultimately expedite the international acceptance of valid alternative methods or strategies by regulatory authorities and their implementation and use by stakeholders. It also allows achieving greater efficiency and effectiveness by avoiding duplication of effort and leveraging limited resources. In view of achieving these goals, the International Cooperation on Alternative Test Methods (ICATM) was established in 2009 by validation centres from Europe, USA, Canada and Japan. ICATM was later joined by Korea in 2011 and currently also counts with Brazil and China as observers. This chapter describes the existing differences across world regions and major efforts carried out for achieving consistent international cooperation and harmonization in the validation and adoption of alternative approaches to animal testing.

Cross-comparison of cancer drug approvals at three international regulatory agencies.

BACKGROUND: The primary objective of the present study was to examine the drug approval process and the time to approval (tta) for cancer drugs by 3 major international regulatory bodies-Health Canada, the U.S. Food and Drug Administration (fda), and the European Medicines Agency (ema)-and to explore differences in the drug approval processes that might contribute to any disparities. METHODS: The publicly available Health Canada Drug Product Database was surveyed for all marketed antineoplastic agents approved between 1 January 2005 and 1 June 2013. For the resulting set of cancer drugs, public records of sponsor submission and approval dates by Health Canada, the fda, and the ema were obtained. RESULTS: Overall, the tta for the 37 antineoplastic agents that met the study criteria was significantly less for the fda than for the ema (X̄ = 6.7 months, p < 0.001) or for Health Canada (X̄ = 6.4 months, p < 0.001). The tta was not significantly different for Health Canada and the ema (X̄ = 0.65 months, p = 0.89). An analysis of the review processes demonstrated that the primary reason for the identified discrepancies in tta was the disparate use of accelerated approval mechanisms. SUMMARY: In the present study, we systematically compared cancer drug approvals at 3 international regulatory bodies. The differences in tta reflect several important considerations in the regulatory framework of cancer drug approvals. Those findings warrant an enhanced dialogue between clinicians and government agencies to understand opportunities and challenges in the current approval processes and to work toward balancing drug safety with timely access.

Comparison of oncology drug approval between Health Canada and the US Food and Drug Administration.

BACKGROUND: The drug approval timeline is a lengthy process that often varies between countries. The objective of this study was to delineate the Canadian drug approval timeline for oncology drugs and to compare the time to drug approval between Health Canada (HC) and the US Food and Drug Administration (FDA). METHODS: In total, 54 antineoplastic drugs that were approved by the FDA between 1989 and 2012 were reviewed. For each drug, the following milestones were determined: the dates of submission and approval for both the FDA and HC and the dates of availability on provincial drug formularies in Canadian provinces and territories. The time intervals between the aforementioned milestones were calculated. RESULTS: Of 54 FDA-approved drugs, 49 drugs were approved by HC at the time of the current study. The median time from submission to approval was 9 months (interquartile range [IQR], 6-14.5 months) for the FDA and 12 months (IQR, 10-21.1 months) for HC (P < .0006). The time from HC approval to the placement of a drug on a provincial drug formulary was a median of 16.7 months (IQR, 5.9-27.2 months), and there was no interprovincial variability among the 5 Canadian provinces that were analyzed (P = .5). CONCLUSIONS: The time from HC submission to HC approval takes 3 months longer than the same time interval for the FDA. To the authors' knowledge, this is the first documentation of the time required to bring an oncology drug from HC submission to placement on a provincial drug formulary.

Post-market safety warnings for drugs approved in Canada under the Notice of Compliance with conditions policy.

AIMS: Health Canada has developed a pathway to approve drugs that have limited efficacy and safety data, the Notice of Compliance with conditions (NOC/c) policy. Increased safety reporting is required for these drugs but there has not been any systematic review of their post-market safety. This study compares safety warnings for NOC/c drugs with drugs with a priority and a standard review. METHODS: A list of drugs approved between January 1 1998 and March 31 2013 was developed and serious safety warnings for these drugs were identified. Drugs were put into one of three groups based on the way that they were approved. Kaplan-Meier curves were generated to examine the likelihood of NOC/c drugs receiving a serious safety warning compared with drugs with a priority and a standard review. The time spent in the review process for each of the groups was also measured. RESULTS: Compared with drugs with a priority review, NOC/c drugs were not more likely to receive a serious safety warning (P = 0.5940) but were more likely than drugs with a standard review (P = 0.0113). NOC/c drugs spent less time in the review process compared with drugs with a standard review. CONCLUSIONS: Possible reasons for the increase likelihood of a serious safety warning are the limited knowledge of the safety of NOC/c drugs when they are approved and the length of time that they spend in the review process. Health Canada should consider spending longer reviewing these drugs and monitor their post-market safety more closely.

The regulation of cell therapy products in Canada.

This article provides a high level view of how cell therapy products are regulated in Canada and addresses the regulatory framework, pathways and underlying regulatory authority. The regulatory approach involves, primarily, two major sets of regulations; and the scientific basis for product categorization and the application of each of these pathways is discussed. Products that undergo more than minimal levels of processing, or meet certain other criteria, are regulated as biological drugs under the applicable parts of the Food and Drug Regulations. Other cellular products, primarily those for allogeneic transplantation and with an established therapeutic use, are regulated under the more recently promulgated Safety of Human Cells, Tissues and Organs for Transplantation Regulations, which incorporate a standards-based approach. Various concerns and challenges for these classes of products are discussed and information is provided on current sources of relevant guidance, including specific Health Canada guidance currently being developed. Health Canada strongly supports and participates in efforts aimed at international regulatory convergence and harmonization.

Regulatory Oversight of Cell and Gene Therapy Products in Canada.

Health Canada regulates gene therapy products and many cell therapy products as biological drugs under the Canadian Food and Drugs Act and its attendant regulations. Cellular products that meet certain criteria, including minimal manipulation and homologous use, may be subjected to a standards-based approach under the Safety of Human Cells, Tissues and Organs for Transplantation Regulations. The manufacture and clinical testing of cell and gene therapy products (CGTPs) presents many challenges beyond those for protein biologics. Cells cannot be subjected to pathogen removal or inactivation procedures and must frequently be administered shortly after final formulation. Viral vector design and manufacturing control are critically important to overall product quality and linked to safety and efficacy in patients through concerns such as replication competence, vector integration, and vector shedding. In addition, for many CGTPs, the value of nonclinical studies is largely limited to providing proof of concept, and the first meaningful data relating to appropriate dosing, safety parameters, and validity of surrogate or true determinants of efficacy must come from carefully designed clinical trials in patients. Addressing these numerous challenges requires application of various risk mitigation strategies and meeting regulatory expectations specifically adapted to the product types. Regulatory cooperation and harmonisation at an international level are essential for progress in the development and commercialisation of these products. However, particularly in the area of cell therapy, new regulatory paradigms may be needed to harness the benefits of clinical progress in situations where the resources and motivation to pursue a typical drug product approval pathway may be lacking.

Is Canada Moving towards a More Agile Regulatory Approval and Reimbursement Process with a Shifting Role for Real-World Evidence (RWE) for Oncology Drugs?

Canada is known to have a complex pathway for new drug approval and reimbursement, resulting in delayed access for patients with serious and life-threatening diseases, such as cancer. Several recent publications from key stakeholders, including patients, physicians and policymakers, highlight patient helplessness, physician frustrations and policymakers entangled in a massive network of bureaucracy unable to make headway. Several quantitative and qualitative assessments using time from regulatory approvals to successful reimbursements confirm long review times and high rejection rates for oncology drugs, especially those receiving conditional approvals. A consensus forum of 18 Canadian oncology clinicians recently voiced frustration with the process and inability to deliver guideline-supported efficacious therapies to their patients. This manuscript compares data extracted from publicly available data sources from 2019 to June 2024 to previous publications. Methods: Public databases from Health Canada, the Canadian Agency for Drugs and Technologies in Health (CADTH), which is in the process of changing to Canada's Drug Agency, and the pan-Canadian Pharmaceutical Alliance (pCPA) were reviewed and the data collected were analyzed with descriptive statistics. Results: From the data, three trends emerge, (i) an increasing number of oncology drugs are receiving conditional approvals from Health Canada, (ii) the percentage of conditionally approved oncology drugs receiving positive reimbursement recommendations from CADTH is still low but appears to be improving, but delays in access are now contingent upon pCPA deciding whether to negotiate price and then the duration of any negotiation, and (iii) real-world evidence is no longer part of the decision-making for conditional approvals. A slight increase in the positive endorsement of RWE used to support CADTH recommendations was observed. Conclusions: The lack of timely access to oncology drugs hurts Canadian patients. While a small trend of improvement appears to be emerging, longer-term data collection is required to ensure sustained patient benefits.

Phase IV Drug Trials With a Canadian Site: A Comparison of Industry-Funded and Non-Industry-Funded Trials.

Recent regulatory reforms have favored expedited drug marketing and increased reliance on Phase IV clinical trials for safety and efficacy assurance. This study, utilizing ClinicalTrials.gov, assesses the characteristics of Phase IV trials, with at least one site in Canada, examining those funded by industry sponsors and those lacking industry funding. Additionally, it compares the publication status of industry-funded and non-industry-funded trials through a manual review of the medical literature. Between 2000 and 2022, 864 Phase IV trials were completed, with 480 (55.6%) receiving industry funding and 384 (44.4%) funded solely by non-industry sources. Industry-funded clinical trials were larger (mean 204 enrollees versus 70), more likely to be international (57.7% versus 9.6%) and reported results more promptly (1.21 years after completion versus 1.85 years), yet both types shared similar designs, outcomes, and completion times. Publication rates were 81.8% for industry-funded and 65.8% for non-industry-funded trials. The ClinicalTrials. gov registry displayed 48 inaccuracies in publication associations, raising concerns about its accuracy. Our findings underscore the existing institutional limitations in ensuring comprehensive reporting and publication of Phase IV trial results funded by both industry and non-industry sources.

Safety of titanium dioxide (E171) as a food additive for humans.

Titanium dioxide (TiO2), also known as E171, is commonly used as a white colorant in food, pharmaceuticals, cosmetics, and toothpaste. However, in May 2021, the European Food Safety Authority (EFSA) expert panel, in evaluating the safety of titanium dioxide (E171) as a food additive, concluded that a concern for genotoxicity could not be ruled out. This occurred several years after EFSA had previously considered titanium dioxide to be safe as a food additive. EFSA based this new interpretation on the results of genotoxicity tests of TiO2 nanomaterials. EFSA noted that available data are insufficient to define threshold doses/concentrations of TiO2 particles below which genotoxicity will not occur in tissues containing these particles. Here, it is argued that EFSA made a manifest error regarding the safety of titanium dioxide (E171) particles as a food additive for humans. First, the notion of particle size distribution of TiO2 particles is explained. Second, the changing opinions from the various EFSA evaluations in 2016, 2018, 2019 vs. 2021 are discussed. Third, the low toxicity of TiO2 particles is described in rats exposed by oral gavage and feeding studies in rats and mice. Fourth, the importance of low absorption rates from the gastrointestinal tract vs. circulation in rats and humans but not in mice is identified. Fifth, other international health scientists have weighed in on the EFSA (EFSA J, 2021, 19 (5), 6585) decision and generally disagreed with EFSA's opinion on the safety of E171 TiO2. A common theme voiced by the United Kingdom, Canada, Australia, and New Zealand agencies is that it is inappropriate to compare nanoparticle toxicity studies of dispersed/sonicated nanoparticles with the content of E171 TiO2 in foods because the test materials used in key studies considered by EFSA (EFSA J, 2021, 19 (5), 6585) are not representative of E171 TiO2 particles. Finally, a group of experts recently considered the genotoxicity of TiO2 and could not find support for a direct DNA damaging mechanism of TiO2 (nano and other forms). For these reasons, it is suggested that EFSA made a manifest error on the safety of E171 as a food additive.