In the interest of protecting patient safety, the Alliance for Safe Online Pharmacies (ASOP Global; www.BuySafeRx.pharmacy) is writing to express concern regarding any proposed federal legislation that would allow the dispensing of non-United States (US) Food and Drug Administration (FDA)-approved medicines to patients in the US from online pharmacies, including Canadian online pharmacies. Such action would put patients in this country at risk of harm from falsified medicines, financial and identity fraud, and medication misuse/abuse.

ABOUT THE ALLIANCE FOR SAFE ONLINE PHARMACIES

Founded in 2009, ASOP Global is a nonprofit organization based in Washington, D.C. dedicated to making the Internet safer for patients globally by addressing the public health threats posed by illegal online drug sellers. Convening over 35 national and international partners[1], ASOP Global works in the US, EU and Asia through activities in: (1) research, (2) education and public awareness, (3) advocacy, and (4) collaboration.

Our members include public health organizations and other nonprofits, patient advocacy organizations, consumers groups, academic institutions, healthcare provider groups, pharmacies, payment processors, pharmaceutical manufacturers, advertising providers, online pharmacy verification vendors, domain name registrars and registries, pharmaceutical wholesalers, and trade associations.

FACTS ABOUT ONLINE PHARMACIES

There are roughly 35,000 active online pharmacies operating at any one time. 96% of these are operating illegally, out of compliance with state and federal laws and/or pharmacy practice standards.  Over 3,300 of these websites sell controlled substances, often without a prescription.[2] 600 new illegal online pharmacy websites launch each month. Adding to the problem, 65% of online search results for prescription drugs lead US consumers to illegal and unsafe websites. Illegal online pharmacy sites are sophisticated (they can afford to be, as each site is estimated to make $1–2.5 million dollars a month, on average). These sites lure US consumers with offers of low-priced, “Health Canada-approved” medicines shipped right to their door from a licensed Canadian pharmacy. It sounds too good to be true because it is.

WHAT DO US RESIDENTS GET WHEN GOING ONLINE TO FIND A CANADIAN ONLINE PHARMACY?

Today thousands of websites claim to be selling Health Canada-approved medicines to US consumers. Unfortunately, this is just a bait & switch. While a US consumer might get lucky occasionally and receive a legitimate, Health Canada-approved medicine, we are unaware of any Canadian online pharmacy that consistently sells US consumers Health Canada-approved medicines. Instead, Canadian online pharmacies sell US patients medicines from India, Turkey, or Southeast Asia.  This is called the bifurcated supply chain: patients in Canada get Health Canada-approved medicines from licensed pharmacies but patients in the US receive products from foreign sources.

Medicines manufactured in these jurisdictions have been found to contain toxins or other adulterants, too much or too little active pharmaceutical ingredient, or are not properly handled or stored to maintain efficacy. Further, when buying from a Canadian online pharmacy, there is no way for a US consumer to know whether he/she received a Health Canada-approved medicine or something else entirely. This puts patient safety at risk.

CONGRESS SHOULD NOT ENCOURAGE US CONSUMERS TO BUY MEDICINES FROM FOREIGN SOURCES ONLINE

For the following reasons, ASOP Global urges Members of Congress to oppose any proposal that would allow US consumers to buy Health Canada-approved medicines from “legitimate” Canadian online pharmacies:

1. With more than 33,000 illegal online pharmacy websites operating at any one time,[3] it is nearly impossible for US consumers to find a legitimate online pharmacy today. For a US consumer, finding a safe source of medications online is like finding a needle in a haystack.
2. When it comes to US consumers, there is no such thing as a “safe” Canadian online pharmacy. We are not aware of any Canadian online pharmacy that consistently dispenses Health Canada-approved medicines to US consumers.
3. If Congress authorizes Americans to buy medicine from foreign sources, the number of illegal online pharmacies will skyrocket. And why not? According to Interpol, illegal online pharmacies make higher profits than sellers of illicit drugs and are much less likely to be caught given the complexities of international jurisdiction and the ability to hide/be anonymous online.
4. As such, we agree with the National Association of Boards of Pharmacy (NABP®) which stated that“sending consumers online to look for Health Canada-approved medicines is reckless, as US patients are likely to receive unapproved, substandard, and counterfeit drugs from unknown foreign sources, posing a serious risk to patient safety.”[4]
5. Even if there were dozens of Canadian online pharmacies that consistently dispensed Health Canada-approved medicines to US patients (which is not the case today), how would a US consumer distinguish these legitimate sites from the tens of thousands of other, dangerous sites selling counterfeit, adulterated, and unapproved products? Today, 54% of pharmacists could not identify a legitimate pharmacy website from a fake and 94% of physicians and pharmacists are unaware of the tools to help identify illegal online drug sellers. If trained healthcare professionals cannot distinguish real from fake sites, average consumer hardly has a chance.
6. Finally, no US law, penalty or government resource can protect US consumers from illegal foreign actors who blatantly disregard US laws and hide in jurisdictions that will not extradite criminals. As NABP observed, “even with the full force of US law enforcement going after illegal sites, thousands of illegal online pharmacy websites based offshore would continue to dupe US consumers into believing they are buying from a ‘real’ Canadian online pharmacy.”[5]

We appreciate your consideration of our comments. Please do not hesitate to contact ASOP Global’s Executive Director Libby Baney directly at Libby.Baney@BuySafeRx.Pharmacy or at (202) 312-7438.

Signed,

The Alliance for Safe Online Pharmacies