April 8, 2013
As you know, Health Canada, Canada's public health sentinel, is deciding whether to allow a private donor blood clinic to open in Toronto, adjacent to a homeless shelter. As one of Ontario's key blood-related organizations, we thank you for recognizing the need for public consultations on this issue.
In the 1980s, thousands of Canadians were infected with HIV and Hepatitis C due to bureaucratic bungling and bad decision-making. A lesson learned should have been that transparent decision-making processes which include patient representatives are essential to ensuring a safe blood supply. We too are concerned with how far this application has proceeded without recipient consultation.
Despite new developments in screening technology and a track-record of safety in plasma derived medicinal products, we need to remain vigilant. While it is true that we currently test blood for HIV, Hepatitis C and other known pathogens, the fact remains that blood safety is not only about AIDS or Hepatitis C. It is just a matter of time before the next unknown pathogen emerges, and by definition, we don't test for that yet. We simply don't know what it is. But we do know how to lower risks.
The 2012 Dublin Consensus Statement proposes best practice for the safe and ethical collection of plasma. This statement indicates, "Donors should not be exploited by any individual or organization" and "plasma donations should not overwhelm the capacity of the donor to make an informed decision whether to donate." We fear the proposed clinic has the potential to exploit vulnerable populations and compromise judgment of those who may be at greater risk for blood borne viruses than the general population.
The proposed location of this clinic demonstrates a lack of sensitivity to the history of our blood supply. Among other factors, collection of blood products from high-risk populations contributed to the tainted blood tragedy. This proposed collection site indicates to recipients that this history is not understood. The poor judgment exercised in choosing a collection site does not instill in patients confidence that sound judgment will be used in ensuring recipient safety.
Hemophilia Ontario supports Canadian Blood Services making all reasonable efforts to increase the quantity of Canadian plasma for fractionation from non-paid donors and the number and quantity of plasma-derived products made from this plasma. We urge you to use your powers to delay the approval of the clinics until Canadian Blood Services has demonstrated that they cannot carry out the job of collecting the necessary plasma through the public system. If paid-plasma collection is allowed to proliferate in Canada, Canadian Blood Services should report to Canadians on a regular basis the impact of paid plasma collection on their ability to meet the needs of Canadian patients.