Matthew Herder and Françoise Baylis assert there is no evidence for the need of paid plasma donations in Canada.

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Sometime before March 2013, Health Canada received an application for a license to collect plasma from Canadian Plasma Resources (CPR). Shortly thereafter, in April 2013, Health Canada hosted a closed-door, invitation-only round table meeting on the safety of paid plasma donations. This was followed, in June and July 2013, by a web-based consultation on the summary report of the round table discussions.

With both of these consultations, concerns were raised about CPR’s business model (paying people for their plasma), and CPR’s “choice” locations for its plasma collection clinics – next to a homeless shelter (See picture) and a drug treatment facility. The chosen locations making it clear that the target population is the poor and vulnerable. As well, concerns were raised about safety and, more specifically, Health Canada’s ability (and willingness) to adequately regulate CPR (and other plasma collection businesses that might enter the market place should CPR succeed in getting a license).

We share these concerns, but in addition we worry about what appears to us as an effort at “policy laundering” – a practice increasingly used by governments to fabricate a record of support for a pre-determined policy objective. A recent Canadian example of policy laundering can be found in a report on intellectual property issued by the House of Commons Committee on Industry, Science and Technology in March 2013. This report included a recommendation that the federal government ratify several key international intellectual property agreements. Yet the House of Commons Committee never heard evidence on this issue during its deliberations. It is anticipated that this recommendation, though originally unsubstantiated, will become “the” supporting evidence for subsequent claims of a similar nature.

In our estimation, Health Canada may well be engaged in a similar slight of hand in order to manufacture support for its policy preference – namely, endorsing compensation for plasma collection. The April 2013 round table report on payment for plasma includes a number of statements about the critical need for paid plasma, for which no evidence is presented.  We expect that these statements will later become “the” supporting evidence for subsequent claims in support of a pay-for-plasma policy.

While the summary round table report opens with the typical (disingenuous) disclaimer, “The views expressed herein are those raised by the participants at the meeting and do not necessarily reflect those of Health Canada or the Government of Canada,” Section 2.4 of the report, is on “key messages from the Canadian Blood Services and Health Canada.” This section of the report provides a clear indication of the government’s perspective on the issue (the disclaimer, notwithstanding).  In this section the following points appear, without any supporting evidence:

• The demand for plasma products is increasing and compensated plasma donors are currently critical to ensuring a sufficient supply of plasma products in Canada.
• Collecting enough domestic plasma to be self-sufficient in plasma products is not operationally or economically feasible with a volunteer model.

With policy laundering, we can expect to see these unsubstantiated statements presented as facts in subsequent documents that will reference back to these original assertions.  And yet there are no facts or evidence to substantiate this policy preference for paid plasma collection.

Health Canada does not know that voluntary (non-compensated) donation of domestic plasma cannot satisfy domestic demand for plasma products. It is not the case that a voluntary program aimed at domestic self-sufficiency (involving improved education, greater collection opportunities, and ‘rightsized’ demand for blood products) has been attempted and failed. Health Canada, therefore, does not know that a high-quality, well-resourced voluntary plasma donation program would not succeed.  Moreover, Health Canada cannot legitimately extrapolate from the experience of other countries that are culturally very different from Canada, do not have a similar health care system, or commitment to altruistic blood donation.

In addition to the absence of evidence that a robust voluntary plasma donation program won’t work, there is also no evidence to show that a commercial plasma collection system would, in fact, ensure a sufficient supply of plasma products in Canada. There is no requirement that CPR or any other for-profit plasma collection company preferentially sell their plasma products to Canada. On the contrary, there is considerable evidence regarding the behaviour of private companies suggesting that, unless contractually required to do otherwise, companies typically will sell their products to the highest bidder.  If this business norm were to play out with respect to CPR and the sale of plasma products, a for-profit plasma collection industry that benefits shareholders will have been created without necessarily benefitting Canadians in need of plasma products.

There is no indication that CPR has entered into a “supply Canadian Blood Services first” sort of contract and, even if that happens, how much comfort should this provide? Past experience in Canada suggests “not much”. Connaught Laboratories, an early 20^th century spin-off from the University of Toronto that was transformed into a for-profit entity by the Canadian Development Corporation in the 1970s, sold $500,000 worth of blood derivative products to the US market in 1974 (approx. $ 2,356,321 today) at the very moment when such products were in short supply in Canada.

In closing, paying people for plasma will not guarantee a sufficient supply of plasma products for Canadians. It will, however, guarantee the exploitation of the needy and the vulnerable among us (people living in shelters, seeking help for addictions). In our view, instead of allowing CPR to exploit conditions of poverty, Health Canada should seriously explore alternative strategies to encourage and facilitate voluntary plasma donation.

A copy of our submission to Health Canada is available here.

Matthew Herder is an Assistant Professor in the Faculties of Medicine and Law at Dalhousie University, Halifax, Canada.

Françoise Baylis is a Professor and Canada Research Chair in Bioethics and Philosophy at Dalhousie University, Halifax, Canada