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 then 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 expertise in:

• psychiatric medicine (an orthomolecular approach – see below),
• bio-identical hormone replacement therapy (including thyroid hormones), – chronic fatigue syndrome and fibromyalgia,
• environmental and electromagnetic hypersensitivity as well as
• all manner of chronic diseases

I have used an Orthomolecular approach during more than 40 years of general practice before retiring from medicine in 2022.

It is very important to understand the meaning of the word orthomolecular. The term, orthomolecular, was coined by two time Nobel Prize winner, Linus Pauling, in 1968. (16) It means using the “right” or “ortho”molecule to address disease. 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. Water, for example, is an orthomolecule and the lack thereof manifests as the feeling of thirst. One can temporarily slake feelings of thirst with a non orthomolecule, like beer or wine, but there will inevitably be negative side effects.

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 (which is why we use them), they are all toxic to the body and cause side effects. Not being recognized by the body, they are treated as “foreign” and must be metabolised and eliminated.

In other words, the body must “detoxify” itself from these substances through the liver, the digestive tract, the kidneys, perspiration and respiration.

Of course, it is obvious that medications have beneficial effects. Otherwise, why would we use them at all? However, since these molecules are foreign to the body, they must be metabolized (eliminated) through the aforementioned detoxification pathways.

When they are properly dosed for the appropriate indication (discomfort or dis-ease), the benefit must always outweigh the potential side effects. This is the calculation that doctors are always making, asking the question: “Will this medication have more beneficial effects as opposed to detrimental or toxic effects?”

As an example: Acetylsalicylic acid or ASA (i.e. aspirin & others) is a well known, effective and relatively safe anti inflammatory, anti pyretic (decreases fever) and analgesic (pain reliever). It is safe enough to be an OTC, sold Over The Counter; i.e. not requiring a doctor’s prescription. However, even aspirin has the potential to cause sometimes severe, toxic side effects.

It is well documented that ASA can cause serious, even life threatening bleeding or a severe allergic reaction. Many people are, in fact, allergic to or intolerant of ASA. A quick internet search revealed 46 “serious side effects” of acetylsalicylic acid enumerated on the website, drugs.com. (1) That is why medications are subjected to rigorous pre clinical (laboratory & animal) and clinical testing (on people) before they are licensed for use by the general public. They must also be monitored even after release to the public.

In many cases, despite research and clinical testing, serious side effects are often discovered after the medication is put on the market and released for widespread use.

Many of us remember the thalidomide disaster. Thalidomide was a medication tht was prescribed to pregnant women as an anti nausea and tranquilizer pill in 46 countries in the late 1950s. As it happened, only after being released for use to the general public was it discovered to cause miscarriages and severe limb deformities in newborns. One can easily find pictures on the internet of these severe, life changing, congenital limb deformities. There were 118 recorded cases in Canada (2) and over 10,000 worldwide. (3) Thalidomide was possibly the most dramatic example of medication side effects but there are many more post marketing examples of dramatic medication harm, too many to list in this presentation.

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 the large majority require a doctor’s prescription to be purchased and used. Adverse Drug Reactions (ADRs), or toxic reactions, are the result of either “normal” 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), it was found that fatal in-hospital ADRs resulted in an estimated 106,000 deaths in 1994. At that time, this figure was between the “4th and 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”.

The ADRs which were excluded from this study were:

• ADRs that did not result in hospitalization (those resulting in “outside of hospital” deaths, for example),
• errors in drug administration,
• non compliance,
• overdose,
• drug abuse and
• therapeutic failures.

If these categories of drug harm leading to death were included, the total adverse drug reaction figures would be significantly higher.

In a Canadian Medical Association Journal article published in 1999, it was reported 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, Adverse Drug Events, or 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 ADEs “are now the third leading cause of death in the United States”. (6) They estimated that ADEs are responsible for 250,000 deaths per year, “a greater number than deaths caused by strokes and respiratory disease”.

In addressing this worsening problem, the ASP has “rebranded” their campaign, calling it the Third Cause Campaign. At this rate, one can forsee the day when they will “upgrade” the rebrand to call it the second cause campaign or, eventually, the first cause campaign. In the same article, we learned of 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.

In Canada, the rule of thumb would be 1/10th the cost in the USA or more than $72 billion US which is almost 100 billion in today’s Canadian dollars. When thinking of these costs, we must also remember that the number of Adverse Drug Events is still increasing.

There are many reasons for the increase in medication use leading inevitably to increases in adverse events and increased costs:

1. the shockingly deteriorating health of our population in general and children, in particular, a well documented phenomenon.
2. deteriorating health leads to increased prescription medication use.
3. increased medication use leads inevitably to increasing incidence of ADRs.
4. new medications and medication classes inevitably cause new and unexpected, post marketing ADRs, especially as they are being prescribed to a sicker population. Being sicker, this population will have more difficulty with the detoxification pathways so necessary to eliminate “foreign” molecules.
5. doctors and other caregivers have less available time to evaluate and examine patients who are suffering from increasingly complicated health challenges. Ironically these health challenges actually require MORE time to be evaluated and treated.
6. writing a prescription is a quick and approved, even mandated, approach for the time constrained health care professional. This “solution” often merely addresses symptoms rather than the root cause of the dis-ease.

All of this represents a perfect storm for the poor and deteriorating health outcomes that we are observing.

The questions facing Canadians and their legislators:

• what can be done to improve health outcomes?
• what can be done to decrease health costs?
• is there an alternative to the mere symptom relief offered by most prescribed medications?
• can we improve health and decrease health care costs without medications?

Using “natural” or orthomolecules that the body recognizes is safer and addresses the disturbed metabolism which is the root cause of all diseases:

• 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 would our legislators treat them as if they are medications, mediacations which are known to be the 3rd leading cause of death?

Let’s examine the safety record of NHPs.

On Jan. 23, 2023, the Orthomolecular Medicine News Service published the conclusions of the recently issued 39th Annual Report of the American Association of Poison Control Centers (8). The report noted that there were zero deaths from vitamins or minerals. In reports over the previous 40 years, there were also no deaths reported. (9,10,11) In stark contrast, I remind the reader that medications are now the 3rd leading cause of death!

One can only speculate as to:

• why our legislators treat these natural, safe, orthomolecular substances as if they were dangerous pharmaceuticals?
• why the overwhelming evidence of their safety has been ignored?
• who benefits when safe supplements are treated as if they were medications? Certainly, it is not the Canadian public.

Our society is now faced with the rapidly increasing costs of “sick care” caused by an increasingly sick (and getting sicker) population.

The inevitable effects of legislation that treats safe supplements as if they were dangerous medications is to drastically and inevitably drive up their cost and restrict their supply.

How can this possibly benefit the Canadian population?

• In the face of increasing medication costs and hospital costs,
• in the face of our failing and increasingly inaccessible health care system,
• in the face of the deteriorating health of our population (20),
• in the face of the well documented decline in the nutrtional value of food (17,18,19) which inevitably leads to nutritional deficiencies and sickness and,
• despite the well documented harm caused by medications and the medical system in the past 30+ years and
• despite the over 40 years of well documented safety of nutritional supplements,

why would our legislators pass laws limiting access to these cheap, safe, plentiful and natural health products and why would they do this despite the overwhelming evidence of the benefits of these natural health products? (13,14,15). The above reference #15, in particular, is a 1409 page, fully referenced (312 references) and indexed tome on “Natural Medicine” by Alan Gaby

I implore the legislators to pass Bill C-224 that will return NHPs to their previous status as food supplements and remove them from inappropriate and wholly unnecessary restrictions. They are not prescription medicines and should not be treated as such. They are not dangerous.

They are nutritional supplements that are necessary to maintaining and improving the health of Canadians. They are not only beneficial but necessary in this era of declining food quality and nutritional value. They have withstood the test of time and are demonstrably safe

Sincerely,

Barry Breger, md (ret), health coach

REFERENCES

1. https://www.drugs.com/sfx/acetylsalicylic-acid-side-effects.html
2. Y. 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, P om from inappropriate useeranz BH, Corey PN. 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 Pison 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. Orthomolecular Medicine News Service, June 14,2011 https://orthomolecular.org/resources/omns/v07n05.shtml no deaths in 27 years 1983-2009
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. resumé of many docs who’ve used vits
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
16. Pauling L: Orthomolecular Psychiatry. Science, 1968; 160: 265-271.
17. An Alarming Decline in the Nutritional Quality of Foods: The Biggest Challenge for Future Generations’ Health. https://pmc.ncbi.nlm.nih.gov/articles/PMC10969708/
18. Examining the prevalence of nutrient deficiency in modern diets. https://www.revistanutricion.org/articles/examining-the-prevalence-of-nutrient-deficiency-in-modern-diets-110732.html
19. The Declining Nutrient Density in Modern Foods: Implications for Health and Solutions. https://acendhealth.com/the-declining-nutrient-density-in-modern-foods-implications-for-health-and-solutions/
20. The average life expectancy for Canadians decreased, and 4 other takeaways from a just-released health report. https://www.ctvnews.ca/health/article/the-average-life-expectancy-for-canadians-decreased-and-4-other-takeaways-from-a-just-released-health-report/