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PROGRAMS & SERVICES: ADVOCACY & POLICY ADVICE WHC's Response To The Health Protection Branch Transition Project's Discussion Papers and Workbook |
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Acknowledgments Thank you to the attendees of our discussion groups, the National Working Group on Women and the Health Protection Branch, the Centres of Excellence particularly the National Network on Women and Environment and the Maritime Centres, HAD-Europe and the clients, board, staff and volunteers of the Women's Health Clinic for your thoughts, vision and critiques. A special thank you to our writing team: November 12, 1998 Who We Are: Women's Health Clinic is a non profit community health centre for women established in 1981. Our roots are in the consumer health movement, particularly the Canadian Women's Health Movement. (See Appendix One for an overview of our philosophy, approach and services.) Our Experience with the Health Protection Branch The Women's Health Clinic is committed to addressing policy issues as they impact women's health status and the interests of Canadian women. As a result, we have been actively involved with issues relevant to the Health Protection Branch's mandate. This has meant we have had regular communication with the Branch as well as with other stakeholders such as health professionals, researchers and the manufacturing sector for over 15 years. Our Process This position paper was created through open community discussions funded through our community outreach and donations program. Contributors included individuals, students, researchers, board members: those who are nursing in hospitals, running health information centres, working with rural women, providing volunteer counseling regarding birth control and unplanned pregnancy, editing a women's magazine and newsletters, running support groups, working for a university students' association, among others. As well, we are part of an informal national network of groups and individuals working on gender, women and the Health Protection Branch review. Within the time constraints of this current phase of the review, we reviewed the various discussion papers and the workbook. The following comments and recommendations build on our experiences and learnings. Selected Examples of our Activities, Experiences and Learnings:
The Sum of our Experience Indicates:
The Context The public review of the HPB's plans in restructuring and reorientation is welcome, though long overdue. We have approached this discussion with a very clear understanding of the problems we feel need to fixed. We do not get a clear sense from the department regarding what problems they hope the transition process will address. We recommend that the HPB clearly articulate the problems they expect the Transition process to address. This review is occurring at a time when our new understandings of the health determinants are being integrated into the health system and the health service system and when there is growing pressure on our publicly insured health system. The work of the National Forum on Health and the integration of these new understandings into all aspects of government policy gives us a sense of optimism. However, the pressures on the health service system and on the economy along with the impact of globalization has brought about a revival of the debate as to the proper role of the "for profit" manufacturing and research sectors in health service. As Robert Evans notes in his article, Going for the Gold: the Redistributive Agenda behind Market-Based Health Care Reform "Conflict over the respective roles of the state and the market in health care has a long history. Current interest in market approaches represents the resurgence of ideas and arguments that have been promoted with varying intensity throughout this century. (In practice, advocates have never wanted a truly competitive market, but rather one managed by and for particular private interests.) Yet international experience over the last forty years has demonstrated that greater reliance on the market is associated with inferior system performance - inequity, inefficiency, high cost and public dissatisfaction." Nowhere is this more apparent than in those issues within the mandate of the Health Protection Branch. Health Protection is not a Business We are concerned that the HPB sees its mandate as protecting the interests of the industry and its economic growth. We worry that "health" is being seen as a business with the implication that it is an industrial sector and a source of jobs and profits. This commercial concept is at the root of many of the problems in the Health Protection Branch and is certainly perceived as a strong influence in its changing relationships with the pharmaceutical industry. As an example, the HPB talks about the economic benefits of serving the client and bringing new drugs rapidly to market, while consumers and policy makers in hospitals and provincial governments are faced with a plethora of increasingly expensive products, inadequately tested relative to older and cheaper drugs. Nor is there available the type of cost/benefit data necessary for evidence-based decision making. Our system is being cluttered with devices with theoretical effectiveness but little or no actual effectiveness. As well, we need to develop mechanisms to assess the fiscal consequences of new drugs and devices. For example, at the same time as costs of new drugs and total drug expenditures increase, huge cutbacks occur in such essential areas as nutrition support programs and home care. We recommend that Health Canada, and the Health Protection Branch, should have as its goal the protection and improvement of the health of Canadians and give no consideration to the impact of its decisions on the industry. We recommend that the Branch develop a relationship with provincial and national processes such as offices of technology assessment and the WHO Essential Drugs program. Health Determinants: A Missing Analysis The concept of "health as a business" appears at first blush as a way of increasing economic opportunities for Canadians and a method for addressing health determinants. Indeed, employment and income are determinants of health status. However, many women know from direct experience how unemployment and cuts in social programs impact negatively on their health and that of their families. If expansion in the pharmaceutical industry causes the income gradient to simply grow steeper without benefit to the individuals (or provinces) that are having to pay the costs of the new drugs, if jobs in the health care and the social sector are cut as the result of drug policies favoring industry profits, then women are likely to be net losers rather than gaining opportunities for employment. As well, although the discussion papers mention health determinants and issues such equity, diversity and gender, there is little to suggest these principles have been applied in any way to the new thinking within the Transition processes. New surveillance models are needed which will ensure that health impacts such as violence and unemployment are monitored and articulated. We recommend that all future strategy documents regarding the HPB include an expanded analysis regarding health determinants. This would include, for example, integrating this analysis into surveillance systems, device and product regulatory activities and risk management processes. A New Role for the HPB: Advocating for the Health of Canadians The Branch, in a proactive role, should become genuine advocates for healthy public policy, working to ensure that the impacts of other jurisdictional policies on health status are monitored and articulated. The HPB should provide leadership to ensure that health impact assessments are required and that they are publicly articulated. The new regulations should require health impact assessments on policies of other branches of government and their constituencies. We recommend that the Health Protection Branch become proactive in advocating for healthy public policy and use a health determinants approach in carrying out its mandate. We recommend that the new regulations require health impact assessments of the other departmental policies and policy change. Consumer Empowerment, Citizen Participation and the "Public" The definition of public used in the document is troubling. There is a lack of analysis of the various types of "publics" and their interests. We do not see the pharmaceutical and manufacturing sector as the public. It is true that they are stakeholders and their issues and concerns need to be included in discussions; however, these interests are very different from the interests of Canadians as consumers and funders of the health service system. As troubling is the assumption that researchers, health care institutions and universities are independent voices that can represent the interests of Canadians. As a result of the impact of changes in control of research dollars and examples such as the experiences at the Hospital for Sick Children, too often those who we might have expected to be our advocates are silent or silenced. New mechanisms need to be created and resourced. We recommend that those who would profit either directly or indirectly from HPB decisions should not be defined as part of the "public". The Minister of Health has noted that "health protection is everybody's business. All Canadians share responsibility for safeguarding and improving health, just as all Canadians share the benefits of having a healthy population and work force." We agree. However, we are concerned that this may mean that the onus is essentially being placed on the individual. While Canadians can and should take measures to protect their health, there are large-scale forces operating at a systemic level that threaten their well-being and put them at risk, and which are virtually out of their control. Women are significantly affected by these forces more so than men, given their lesser degree of control on the governance of society and their inferior socio-economic status. The state has a responsibility to influence societal factors that threaten health protection and to be, in itself, a protective and positive force, especially on behalf of groups in society that are disadvantaged. We strongly support the inferences in the discussion paper that mechanisms are needed to empower Canadians to make healthy choices and to be active participants in decision making. However this analysis should be made more apparent and put in context. Canadians have been demanding more input into decisions that affect their health and into the governance of the health service system. As a result of regionalization, citizens are reviewing and approving health service budgets. Consumers are no longer content to just be patients; they have the legal right to give informed consent. They own the information in their medical records and have the right to access it. Consumers are demanding to be active participants in policy development. The Health Protection Branch needs to rethink its approach to be effective in collaborating with the public. Our wide community experience has demonstrated repeatedly that, given appropriately supportive opportunities, consumers willingly become contributors to the discussions and decision-making that leads to more balanced public policy. The activities of health protection must be transparent, open and equal. This means that programs are needed to ensure that citizen groups have the resources to educate their members and develop position papers. New mechanisms to encourage education and debate need to be put in place. The Health Promotion Branch's community action program would be the ideal way for community based groups to have access to funding for these activities. Special attention must be taken to ensure equal participation by all citizens groups, particularly those who are the voices for the most at risk and who are often excluded. Equality principles are essential here. The summer release of the discussion papers, the short notice and lack of clarity regarding attendance at the public consultations, the lack of outreach and community-based educational activities mitigated against awareness of the Transition initiative. We fear this lack of awareness will reduce feedback on the discussion papers. We feel strongly that this should not be construed as a lack of interest, but rather that it reflects the reduced capacity of consumer and citizen groups to respond, primarily due to reductions of governmental funding which impacts on the resources available to facilitate the work of volunteers. We recommend that the HPB provide outreach and education activities as well as support to ensure equal participation in a more open and transparent process. Legislation The current Food and Drug Act is being described as an outdated, badly performing piece of legislation. It is interesting to contemplate what could possibly be outdated about an Act that is all about keeping our water, food and drugs safe and pure. We are concerned that opening the Act would make it vulnerable to changes that would not be in the best interests of the public. The process of regulatory change is less cumbersome than the process of changing an Act of legislation and would ensure its integrity would be maintained. We recommend that the Food and Drug Act be maintained and no changes be introduced that would eliminate or reduce the degree of criminal responsibility as it presently applies to the Minister, other Health Canada officials and to the industry. Funding Cuts We are very concerned that Canada's public health protection system has been weakened to a dangerous level of ineffectiveness. Cutbacks in funding leave very little leeway for the development of new policies that would allow for more inclusive patterns of research such as we believe are necessary to improve health quality for women. Cutbacks in resources and resulting change to the research capabilities of the Health Protection Branch create a growing reliance upon or participation in economic "partnerships". Partnering with the private sector or universities -- whose own funding is often reliant on the same industries who intend to profit through products for which they seek approval -- leaves the frightening perception that HPB is moving from its traditional role of protecting public health interests to the task of developing a profitable health industry at the expense of public safety. Most of us are familiar with the old expression, she who pays the piper calls the tune. Administrative assurances to the contrary, it is difficult to imagine how Health Protection Branch can work for the public good if the Branch's performance target is tied to the amount of fees it will collect. If greater numbers of approvals equal greater dollars, HPB is vulnerable not only to actual political and industry influence but also to the public's perception that these are its motivating factors. Fee for service licensing is unethical unless that fee is completely blinded from the approval process and is not an indicator of department effectiveness. We recommend that fees for review of drugs or devices should be returned to general revenues and not be seen as a source of departmental revenues or an indicator of effective performance. We are concerned that this policy also produces barriers to smaller companies who are unable to compete against the financial resources of large multinational, vertically integrated companies. For example, there is no corporation which wants to manufacture RU-486 in Canada, so it remains unavailable. Firms whose product lines are alternative therapies -- such as natural progesterone or herbs -- have little capacity to meet these licensing fees. We recommend that new mechanisms be found to ensure that products that are needed by the Canadian public are able to be reviewed in a timely manner not dependant on the licensing fee. Funding to Support In-House Research Testing for drug quality, toxicity, bioequivalence and clinical applications are no longer routine procedures done in-house. "Jobbed out" product review and the possibility that industry self-regulation may become accepted practice will do little to convince a skeptical public that we are the client for whom HPB is working. It is somewhat encouraging that budget restorations will bring funding close to the 1993-94 level in 1999-00. However, this funding is specific (AIDS and cancer research), it will do nothing to restore the in-house research that was the foundation of independent product review. We recommend that the HPB be funded adequately to retain its independence and expertise. Decision Making: A Needs-Based Approach to Drugs and Devices Transition discussion papers provide little sense of how the current problems in the system would be addressed. There is a need to examine the relationship between approvals and their funding from the funding insurance system. As new drugs or devices are not funded by the provincial governments, we see increasing privatization of this part of the health care system. Using criteria that includes "use effectiveness" and needs-based criteria would mitigate this situation. There are international models to review. The WHO's Essential Drugs program helps provide guidance to many countries. As well, Norway provides an interesting and significant example of a successful National Drug Policy[3]. It incorporates characteristics such as:
Development of an equitable National Drug Policy in Norway has occurred without any major conflict between the health authorities, the professional organizations and the drug industry. The reason for this may be that the Norwegian drug policy has developed in stages throughout this century and has been part of a health policy and an overall social policy where the emphasis on equity has been one of the main pillars. We note that part of the profit from drug sales is used to inform patients, doctors and pharmacists about drugs and their rational use, including when not to take them as solutions to everyday problems. Equally important is the need for open, transparent review processes that address social and ethical considerations. This requires public access to the research done by licence applicants, adequate public notification of applications and engagement mechanisms. We recommend that models and principles in programs such the World Health Organization's Essential Drug Program and Norway's National Drug policy be implemented in Canada. Addressing Risk Assessment of and managing risk is more than a documentation of the results of successful double blind clinical trials. The Health Protection Branch needs to grapple with social and ethical implications of a wide array of new drugs and devices from biotechnical/genetically-altered material to the increasing popularity of herbal and non-traditional therapies. Risk assessment must incorporate a long-term vision, such as the aboriginal philosophy of looking ahead to seven generations. It must be supported by an overarching ethical structure that considers environmental impacts as well as ethical, social and cultural determinants of health as they affect both individuals and groups:
Risks managed only in industry terms may mean that health protection standards move from proof of safety to proof of harm. Industry's interpretation of risk management puts too much emphasis on economic risk and corporate self-interest and could result in grotesque calculations that put dollar assessments on human lives. For example, Health Canada blood regulators, working with their "client" - the manufacturer of blood products - could decide that the benefits of distributing contaminated blood products (i.e. $100's of millions in revenue for the company) outweigh the costs (i.e. liability for loss of life and injury which is often difficult to prove). In developing HPB's risk assessment framework, the Branch is examining the degree of certainty the legislation should require prior to Health Canada's intervention when facing an emerging issue. An important lesson must be learned from the contamination of the blood supply. As stated by Justice Horace Krever in his final report:
We recommend that a new definition of safety must incorporate good research with sensitivity to gender, cultural and ethical issues and must also require assessments of the long-term effects of drugs and devices. We recommend that HPB adopt an active, not passive, approach to assessing risk that takes a broad definition of risk including social, ethical and long term risks. We are very aware that there is a need for new therapies to be made available to Canadians in a timely manner; however, criteria should be complex enough to allow immediate access to therapies for those dealing with life threatening illness and yet provide stringency on products which will be used for well individuals. New models of pro-active post marketing research programs -- engaging consumers and involving their input -- would restore confidence, be early indicators of unexpected outcomes, and corroborate needs-based evidence. We recommend that post marketing evaluation programs be removed from responsibility of the industry and new mechanisms for involving the Canadian public be undertaken. Compensation Fund Women's experiences with the Dalkon Shield, DES and silicone breast implants, and the Canadian public's experience of the tainted blood disaster, establishes the need for a compensation fund. Such a fund would ensure that Canadians are compensated for harm caused by the use of drugs or devices that are defective -- whether through unforeseen or other circumstances. Access to this fund should not preclude bringing suit or, for that matter, criminal charges against the responsible parties should neglect of duty be the key cause of harm. We recommend that a compensation fund be created to support compensation for unintended problems with drugs, products and devices. Harmonization of Standards It would appear at first glance to be a sensible plan to use the evidence of other countries, particularly if they are known to have like-standards of scientific rigor. It would, for instance, be one way in which standards for herbal and non-traditional therapies might be set up without the expense of testing in Canada. However, a cautionary tale must be included here. One of the legacies of the Reagan and Bush administrations in the US was a gutting of the budget and independence of the FDA. Women saw some of the consequences of this in the turn-around approval of Norplant and Depo-Provera. Trade agreements with other nations can affect Canada's autonomy when it comes to maintaining control in the market place. Our government's inability to cancel the use of MMT -- a gasoline additive seen to be without merit as well as environmentally destructive -- can be applied directly to rBST should it be approved for use in Canada. Political barriers will prevent its removal, even if Canadian evidence later proves it unacceptable to our national standards. Just as troubling is the fact that no government is immune from political pressure internally. The HPB will need mechanisms to assess this. Given the resistance to external reviewers, we remain skeptical that this can be undertaken which means that harmonization will not be workable. We recommend that if and where review processes are shared, the HPB must retain the ability to overturn decisions and the capacity to audit the processes in other jurisdictions to ensure no inappropriate influences were experienced. Harmonizing the review process with other countries should never result in lowering standards used in the Health Protection Branch. Consumer Education, Informed Consent and Informed Choice Over the past 100 years there has been a growing understanding of the spectrum of differences between unregulated and irresponsible advertising of health products, responsible advertising, accurate transparent information about a product and its use and educational information about a health concern. It is not clear in actual terms how much impact this critical thinking has had. Plain language leaflets, packaging and shelf signage are as important in the determination of effectiveness as is scientific research when it comes to protecting the public. Although patient inserts are now present, they are generally difficult to read and to comprehend. Materials designed to accompany drugs and devices -- whether over-the-counter or by prescription -- do not carry complete information regarding side-effects or are presented in a manner that encourages informed consent. This means that it is difficult for consumers to make informed choices and provide informed consent. We have often produced our own materials or worked with provincial governments and other consumer groups to ensure that there is useful information available. New understandings of use effectiveness, the role of prevention and health promotion activities must be communicated in accessible forms. Clearly spelling out use effectiveness in, for example, mammography, bone densitometry, or oral contraceptives for adolescents, would enlighten consumers and practitioners and would greatly enhance informed choice. There are few resources available for consumer groups or professionals to prepare and provide unbiased education about a health problem or issue and possible methods and or products to address them. It is time for a consumer health education process to be initiated, separate from promotional materials and the purview of the industry. We recommend that responsibility for the preparation of information materials be removed from industry and an independent mechanism for their development be initiated. Direct to Consumer Advertising Pharmaceutical industry marketing practices have a long history of poor compliance with ethical guidelines and standards in industrialized countries, such as Canada, as well as in developing countries. The industry is becoming a source of funds for consumer groups, medical education and research. Large corporate budgets determine market share of products. Direct to consumer ads reflect a further, serious erosion of balanced, independent sources of information for consumers and health care providers. Advertising is not education. It is a sales tool and is meant to stimulate a desire for the product it features. Commercial messages "leak" in through foreign media sources and can be found on the Internet. Review is needed and regulations imposed. This must be done quickly as our society already suffers from an overuse and misuse of medication. We recommend that the existing prohibitions about direct to consumer marketing be maintained and strengthened. Regulating Herbs and Other Non-Traditional Therapies Herbal and other non-traditional therapies are an increasing interest among women but using these products is problematic. Complementary medicines are looked upon with scepticism or hostility by allopathic providers. Naturopaths, herbalists and other non-traditional practitioners are unregulated. Smaller manufacturers often lack the resources to do research to have their products licensed. There are few quality controls in place. Products are sometimes withheld from sale in Canada. The market is generally one of "buyer beware" and it is left to the user to ferret out information on potency, quality, dosage and side-effects. We are very concerned about the risks to health in the current situation. For example, St John's Wort is a popular herbal compound available through health food specialty shops as well as chain drug stores. The specialty shops are generally knowledgeable about the product and usually will provide information and side-effects warnings. However, the product may also be purchased off a drug store shelf with no accompanying information. We recommend that new mechanisms be found that will assure standards for good quality control and accurate information on product use through labeling. Those with expertise in the use of herbs should be providing leadership in this process. Altered Foods: The Consumer's Right to Know Food that has been genetically altered may turn out to be a great boon, as is the current hope of the industry. Or it may become the root of health problems that have yet to be imagined. Until enough long-term evidence has been collected to be conclusive, a caution light should be flashing. The overall manipulation of plant and livestock biologies: to enhance production, to increase pest resistance, to provide a source of disease prevention or cure that is organic in nature are, at a glance, well-intended. Strong overarching principles of ethics must be in place to balance the quest for market control and profit. Under the present circumstances, there is little public confidence that such a balance is in place. Ultimately, it should be the consumer's right to choose or refuse products that have been genetically altered. Access to balanced information is an effective tool for consumers and reinforces their ability to make responsible and rational decisions. The responsibility of the Health Protection Branch is to make information available and widely distributed. We recommend that genetically altered food be identified by labeling. Women's Health Means More than Just Health Issues for Women Our interest in the Health Protection Branch is not only as major consumers of health products, drugs, devices and services. For many women, the health of their families and communities is also their business. Women are often the health guardians and advocates in society. Our sense of responsibility and concern gives us the legitimate right to speak out on all issues affecting health for everyone in our community, young and old, male and female. This includes everything from drugs to food and the environment; from non-enforcement of legislation to cutbacks which impact socio-economic determinants of health. As an example, in the context of the Health Protection Branch, health as women's business makes the Bovine Growth Hormone as legitimate an issue for women as Depo-provera or Tamoxifen. The women's health movement has developed an analysis that examines health problems from a holistic perspective. We recognize the impact of violence and poverty on health status and the impact of inequalities between men and women and among men and women as significant health determinants. If health is to be protected and enhanced, these impacts must be addressed. We see this as a new role for the Health Protection Branch; monitoring and communicating these risks to health. We recommend that the HPB staff include those with expertise in ethics, social sciences, gender and equity issues. Lack of Gender Analysis That the Health Protection Branch has not adequately addressed gender has been a longstanding issue. Gender refers to the array of social, behavioural and attitudinal differences between women and men (see Appendix Two). These are socially constructed and can be changed, indeed do change, as society evolves; it is sex and its related biological determinants that we can't change, although their impacts can be mitigated. We recommend that the legislative renewal process be submitted to a gender-based analysis (which is a federal and departmental requirement) and that health and women's organizations, among others, be invited to participate in developing the process Only belatedly has drug research been required to include women in clinical trials. Typically only minimal consideration has been given to distinct differences between the sexes in spite of obvious physical factors such as body weight, ratio of lean to fat tissue, concentrations of steroids in men's bodies, a difference in hormones as well as the artificial use of hormones by women as they proceed through various stages of their lives: birth control, fertility treatments, menopausal symptoms. It appears no consideration is given to cultural differences and the possibly different risk factors therein. Male bias also influences studies on occupational health and safety, often ignoring distinct risks faced by women who enter traditionally male job categories. In order to develop health policies that will provide equitable results, it is essential that research into threats to health be conducted in ways that will reveal whether or not there are gender-related risks attached. This requires not only that studies include women in sufficient numbers to obtain statistically significant results but also that the data be collected and analyzed in ways that will reveal this information. Qualitative and quantitative studies are needed. Moreover, such analysis may also have to consider whether specific groups of women (e.g., elderly women, pregnant women and various cultural and ethnic groups) are at particular risk whenever there is reason to suspect relevance of such differences. Women are not only under-represented in research, they are under-represented in decision-making. When products for women are under review, the absence of public hearings or other participatory mechanisms, prevents women's access to the Health Protection Branch. Equitable health policies and affordable avenues of communication are needed. We recommend that the HPB have explicit processes to address gender and to ensure that principles of equity and diversity are in place. We recommend that special meetings with women's groups and with equality groups be undertaken as part of the transition process and prior to the finalization of the white paper. Summary of Recommendations
Conclusions The Health Protection Branch Transition process presents an opportunity to restore its credibility. We urge the serious consideration of the issues and recommendations made in this document. The Women's Health Clinic would welcome an opportunity to work with the Health Protection Branch during this Transition process to ensure it is equitable, ethical and improves the health status of Canadians. Appendix One The Women's Health Clinic (WHC)-- Who We Are The Women's Health Clinic (WHC) serves as a community resource to a broad range of individual women - from teens to elders, as well as to service providers and agencies in Manitoba. It provides primary health care that emphasizes health promotion, education and client empowerment. In addition, the Clinic monitors emerging issues of importance to women's health, brings together coalitions and networks for debate and discussion, encourages and sponsors research and develops policy options and innovative service approaches within a population health framework. The Clinic strives to integrate practice with research and policy development, so that work in each area informs and enriches the quality of the other. In 1997, the WHC was recognized by the Commonwealth Secretariat and received the Commonwealth Award for Excellence in Women's Health Practice for its unique model of care. We are an active member of the Centres of Excellence for Women's Health, a program of Health Canada. Women's Health Clinic had its origins in the 1970s and has played a significant role in the Canadian women's health movement since that time. It developed from the vision of Manitoba women who identified the need for quality reproductive health care and contributed their time, effort and money to ensure that such services would be provided. The model of a clinic run by and for women evolved to include a broad range of programs and services that met women's health needs in a holistic way. Women's Health Clinic Philosophy The Women's Health Clinic Model of Care is based on the following philosophy and principles: All women deserve fundamental respect and have the right to make informed decisions about their health care. In particular, it is recognized that:
Recognizing that health promotion, primary prevention and healthy public policy are essential strategies for influencing the determinants of women's health, Women's Health Clinic emphasizes community and group-based approaches as a means to effect positive change in women's health status. Programs and Staffing Women's Health Clinic staff are an interdisciplinary team of health care providers who work collaboratively. Women's Health Clinic has a current staff complement of 18.5 EFTs, which include: physicians, nurse practitioners, health educators, a dietitian, counselors, outreach volunteer co-ordinators, client service workers, a medical assistant and administration personnel. WHC operates the following programs:
Endnotes [1]Robert G. Evans, Journal of Health Policy and Law, Vol 22, No 2, April 1997[2] Health Canada, Shared Responsibilities, Shared Vision: Renewing the Federal Health Protection Legislation, An Invitation to a Discussion... from the Minister of Health, Catalog number: H39-435/1998. [3]Norway's National Drug Policy: Its Evolution and Lessons for the Future., Marit Andrew, Bjorn Joldal and Goran Tomson. Development Dialogue 1995:1. Journal of the Dag Fammerskjold Foundation pp.25-53. [4]Maritime Centre of Excellence in Women's Health (MCEWH), October 1998, A Response to Health Protection Branch Discussion Papers, pp. [5]Canadian Health Coalition, September 1998, Transition=abdication, pp 6. [6]The Honourable Mr Justice Horace Krever, Commission of Inquiry on the Blood System in Canada, Final Report, Volume 3, 1997, pp 989. |
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