Dr. Breger’s Bill C-224 Brief to The Standing Committee on Health

Dear Committee members,

My name is Barry Breger. I am a retired medical doctor. After completing my medical studies in France and a 3 year family practice residency in Newfoundland, I practiced in isolated First Nation’s communities in Northern Manitoba and Northern Ontario before working as a general practitioner with responsibilities for in-hospital and intensive care patients in rural Quebec, my home Province.

Over the years, I have developed an interest and a certain expertise in psychiatric medicine, in bio-identical hormone replacement therapy, in chronic fatigue syndrome and fibromyalgia, in environmental and electromagnetic hypersensitivity as well as all manner of chronic diseases.
“You are what you eat” has been one of the guiding principles of my practice and personal life.

It’s important to understand what orthomolecular means. It means using the “right” or “ortho”molecule to address dis-ease. The “orthomolecule” is any natural molecule (from nature) or nutrient that is known and recognized by the human body. Vitamins, minerals, amino acids, essential fatty acids and bio identical hormones are examples of orthomolecules. The human body recognizes and requires these molecules in order to function. The body also has methods in place to efficiently metabolize (use and transform) and subsequently eliminate these molecules once they have fulfilled their function.

Drugs or patent medicines are not orthomolecules. They are molecules that do not serve a function in the normal metabolism or functioning of the bodily systems. They are not recognized by the body. As such, although they may have desirable effects, they are all toxic to the body and cause side effects. They are not recognized by the body and are treated as “foreign”. As such, they must be eliminated. In other words, the body must “detoxify” itself from these substances through the liver, the digestive system, the kidneys, sweat and respiration.

Of course, it is obvious that medications have beneficial effects. However, they are “foreign” to the body and must be metabolized through the aforementioned detoxification pathways. They are always potentially toxic.

That is why medications are subjected to rigorous pre clinical (before being used by people) and clinical testing before they are licensed. In many cases, despite research and testing before release to the general public, serious side effects are often discovered after the medication is put on the market and released for widespread use.

Since medications are always toxic to the body, they can only be used for specific reasons (indications) and at tightly controlled dosages. Our bodies treat them as toxic foreign substances. As such, they must be monitored and most require a doctor’s prescription to be purchased and used. Adverse Drug Reactions (ADRs), or toxic reactions, are the result of either drug side effects when properly used or arise from their inappropriate or incorrect use.

In a widely cited study done by Lazarou et al, published in the prestigious Journal of the American Medical Association (JAMA), fatal in hospital ADRs were estimated to have resulted in 106,000 deaths in 1994. At that time, this figure was between the 4th to 6th leading cause of death in the USA (4). In the same article, they concluded that a total of 2,216,000 hospitalized patients had experienced what they classified as “serious ADRs”.

In a CMAJ editorial (Canadian Medical Association Journal) in 1999, it was reporterd that ADRs prolonged hospital stay by an average of 4.6 days costing the Canadian taxpayer an extra $300 million dollars (5). This figure is equivalent to $534 million in 2026 dollars.

In 2021, 5 short years ago, ADEs were determined to be the 4th leading cause of death in the US. At that time, the Fourth Cause National Action Plan was launched. In a more recent posting on March 24, 2025, the American Society of Pharmacovigilance (ASP) reported that adverse drug events (ADE) “are now the third leading cause of death in the United States”. (6)

They estimate that ADEs are responsible for 250,000 deaths per year, “a greater number than deaths caused by strokes and respiratory disease”. In the same article, we learned of the widespread underreporting, that “94% of adverse drug reactions are not reported . . . . which delays the detection of vital safety signals”.

There is another side to the Adverse Drug Events story that should not be ignored. I’m referring to the financial cost of these adverse events to society, both to the government as well as to individuals. In a recent post on Yahoo Finance “Researchers estimated nearly a decade ago that adverse drug events cost more than $528 billion annually in medical care and hospitalizations—a figure experts believe is likely even higher today.” (7) In 2026 US dollars, this represents more than $718 billion.

The questions become:

• what can we do to improve health outcomes?
• what can we do to decrease health costs?
• is there an alternative to the mere symptom relief offered by many medications?
• can we improve health and decrease health care costs without medications?
• Is there any evidence that vitamins and minerals, orthomolecules, represent a danger to the consumer?
• Is there any evidence that Natural Products represent a threat to our health or that they can cause death?
• If not, why treat them as if they are toxic medications, the 3rd leading cause of death?

On January 23, 2023, the Orthomolecular Medicine News Service reported on the 39th Annual Report of the American Association of Poison Control Centers.(8) that there were zero deaths from vitamins or minerals, and no deaths were noted over the previous 40 years. (9,10,11)

As we have seen, medications are the 3rd leading cause of death. Yet no deaths have been reported due to vitamins or minerals since these statistics were first tabulated in 1983.

One can only speculate as to:

• why legislation now treats these natural, orthomolecular substances as if they were dangerous pharmaceuticals?
• where is the evidence that these natural molecules are dangerous?
• why has the overwhelming evidence of their safety been ignored?
• who benefits when safe supplements are treated as if they were medications?

Our society is now faced with the rapidly increasing costs of “sick care” caused by an increasingly sick (and getting sicker) population. In the face of increasing medication and hospital costs, what are our legislators doing to ease these health and financial burdens? The effect of legislation treating safe supplements as if they were dangerous medications is to drastically and inevitably drive up their cost and restrict their supply. How does this benefit the Canadian population?

In the face of our increasingly expensive yet failing sick care system, in the face of the rapidly deteriorating health of our population and despite the well documented harm caused by medications and the medical system in the past 30+ years, why would our legislators pass laws limiting access to these safe, natural, orthomolecular health products?

There is overwhelming evidence of the benefits of natural health products or NHPs, especially given the deteriorating and generally nutritionally poor quality of our food supply. (13,14,15)

I will only refer to these benefits in passing as that is not the focus of this brief. I have been focused on the lack of danger of NHPs. The above reference #15 is a 1409 page, fully referenced (312 references), fully indexed tome on “Natural Medicine”. I suggest that members of the committee, if they have any doubt as to the weight of scientific evidence supporting the use of natural health products, have a look at this extraordinary reference work.

I implore the legislators to pass the Bill C-224 that will return NHPs to their previous status as food supplements and remove them from inappropriate restrictions. They are not prescription medicines. They are not dangerous. They are nutritional supplements that are necessary to maintaining and improving the health of Canadians. They have withstood the test of time.

Sincerely,
Barry Breger, MD (ret), health coach

REFERENCES

(1) https://www.drugs.com/sfx/acetylsalicylic-acid-side-effects.html
(2) Canadian cases of limb deformities caused by thalidomide https://www.thecanadianencyclopedia.ca/en/article/thalidomide-in-ca
(3) Worldwide cases of limb deformities caused by thalidomide https://academic.oup.com/book/41267/chapter-abstract/351204626
(4) Lazarou J, Pom. Incidence of adverse drug reactions in hospitalized patients: a meta-analysis of prospective studies. JAMA1998;279:1200-5.
(5) Bains N, Hunter D. Adverse reporting on adverse reactions. CMAJ1999;160(3):350-1.
(6) https://www.prnewswire.com/news-releases/americas-silent-epidemic-worsens-adverse-drug-events-now-the-third-leading-cause-of-death-302408765.html
(7) https://finance.yahoo.com/news/adverse-drug-events-estimated-among-123800241.html
(8) 2021 Annual Report of the National Poison Data System from America’s Poison Centers 39th Annual Report, Clinical Toxicology, Volume 60, 2022 – Issue 12 https://orthomolecular.org/resources/omns/v19n06.shtml and https://www.tandfonline.com/doi/abs/10.1080/15563650.2022.2132768
(9) 7. Orthomolecular Medicine News Service, June 14,2011. https://orthomolecular.org/resources/omns/v07n05.shtml
10. OMNS, Jan. 16,2015. No Deaths From Any Dietary Supplement 2015. https://orthomolecular.org/resources/omns/v11n02.shtml
11. Aucun Mort Causée par des Supplements, 2019. https://orthomolecular.org/resources/omns/fra/v15n20-fra.pdf
12. Orthomolecular Medicine News Service. March 13, 2012. https://orthomolecular.org/resources/omns/v08n09.shtml
13. Doctors Say Vitamins Are Safe. https://orthomolecular.org/resources/omns/v02n07.shtml
14. NBCs Vitamin Ignorance. https://orthomolecular.org/resources/omns/v09n24.shtml
15. Nutritional Medicine, 2nd edition by Alan R. Gaby, Fritz Perlberg Publishing, 2017