With diabetic retinopathy being the leading cause of sight loss in working-age adults, CNIB supported Petition e-4177 that called on the federal government to ensure Health Canada’s approval process for new medical devices includes an accessibility assessment; and work with insulin pump manufacturers to address the safety concerns with existing insulin pumps. Initiated by Ryan Hooey from Tecumseh, Ontario, the petition received 2,775 signatures and was formally presented by MP Bonita Zarrillo (Port Moody—Coquitlam, British Columbia) to the House of Commons on March 6, 2023.
While the Minister of Health tabled the response to Petition e-4177 on April 19, CNIB finds it inadequate as it continues to place the responsibility on the manufacturer to ensure medical devices, such as insulin pumps, are accessible. Health regulators such as Health Canada have a role to play in guaranteeing that devices coming into the market are accessible, usable and safe. For far too long, regulators have also accepted warnings provided by manufacturers that insulin pumps are “not safe for use by people who are blind” which further perpetuates inequity in healthcare access.
CNIB believes Health Canada’s approval process for new medical devices should require manufacturers to follow the principles of universal design to ensure their devices are accessible to everyone, including people with disabilities.
In the federal government’s response signed by MP Adam van Koeverden, Parliamentary Secretary to the Minister of Health and to the Minister of Sport, it noted:
"Health Canada’s pre-market reviews of devices include the assessment of device safety in relation to the medical conditions, purposes or uses for which it is manufactured, sold or represented. This includes consideration of the intended target population for a given device. As such, Health Canada’s review evaluates evidence from usability testing to ensure the device can be used safely by the target population. In this usability testing, patients are asked to try to complete important device tasks, and the manufacturer confirms these tasks can be done safely without introducing errors."
If Health Canada's pre-market reviews include evidence from manufacturers’ usability testing, the government has a responsibility to ensure the manufacturers’ usability testing includes people with disabilities and that their products meet universal design standards. If the government aims to find, remove, and prevent barriers facing people with disabilities, Health Canada must include accessibility as part of its evaluation and approval process for new medical devices such as insulin pumps.
CNIB is working with manufacturers, regulators, researchers, community members with lived experience and healthcare professionals to collaborate on solutions to this issue. While we are encouraged by our discussions thus far, we will continue to meet with Health Canada to advocate for accessible insulin pumps for Canadians who are blind, partially sighted or Deafblind.