Redefining the Practice of Medicine

Euthanasia in Quebec

An Act Respecting End-of-Life Care (June, 2014)

Sean Murphy*

Full Text

Part 3: Evolution or Slippery Slope?

Introduction

Euthanasia laws frequently include guidelines and safeguards intended to prevent abuse, known in Quebec as balises ("safeguards" or "tags") to prevent  dérive ("drift" or "deviation" from the standard; "abuse").  Thus, the Quebec Bar emphasized the need to "to establish standards (normes) and specific and well-defined tags (balises) to protect and reassure patients and their families,"1 while the Quebec Ombudsman reviewed Bill 52 "to ensure that appropriate safeguards (balises) are in place and implemented in a practical way to prevent such abuses (dérives) as might occur."2

A number of those who appeared before the legislative committee studying Bill 52, while acknowledging the need for safeguards, expressed dissatisfaction with the bill because they believed it to be too restrictive: that it failed to make euthanasia more widely available.  Their criticisms would apply equally to ARELC, the text of which, in this respect, is not substantially different from Bill 52.

In view of this pressure for expansion of access to euthanasia, it is important to consider not only the elasticity of existing statutory provisions, but recommendations for expansion that might ultimately result in changes to the law, either by statutory amendment or judicial fiat.  This is relevant to concerns about freedom of conscience because increasing the range of circumstances under which euthanasia can be provided increases the likelihood of conflicts of conscience and conscientious objection.

Statutory eligibility

Eligibility criteria are the most basic guidelines or safeguards.  The criteria set out in ARELC to establish eligibility for euthanasia3 require that a patient

• be legally competent;
• be at least 18 years old;
• be insured under the provincial health insurance act;
• be "at the end of life;"
• "suffer from a serious and incurable illness;"
• be in an "advanced state of irreversible decline in capability;"
• "experience constant and unbearable physical or psychological pain which cannot be relieved in a manner the patient deems tolerable."

This seems fairly straightforward, but appearances are deceiving. 

Elastic eligibility

Competence

In the first place, the requirement for legal competence can be sidestepped through the provision allowing substitute decision makers to order the starvation and dehydration of legally incompetent patients (Euthanasia Beneath the Radar- EBTR).  Beyond this, there are strong indications that the reach of the law will be expanded to include legally incompetent patients.  

The provisions that make EBTR possible were not added to ARELC until after the 2013 hearings into Bill 52.  Thus, a number of the submissions to the legislative committee expressed concern, based on the original wording of the bill, that incompetent persons would be denied the benefit of euthanasia.  The Commission on Human Rights and Youth Rights warned that the failure to extend MAD criteria to allow physicians to kill legally incompetent patients impinged upon the patients' fundamental freedoms,4 and that denying euthanasia to people who are legally incompetent may constitute unlawful discrimination.5

Most of the complaints or suggestions concerned the failure to allow euthanasia based on an advanced medical directive, particularly in the case of those who prepared a directive while legally competent but who become incompetent, usually as a result of degenerative diseases, but also by accidents.  Allowing euthanasia based on advanced directives was recommended not only by the Quebec Association for the Right to Die with Dignity,6 but by

• the Collège des médecins;7
• the Federation of Quebec Medical Specialists;8
• the College of Social Workers & Marriage & Family Therapists of Quebec;9
• Association of Councils of Physicians, Dentists and Pharmacists of Quebec;10
• the Quebec Bar;11
• Professor Jocelyn Downie;12
• the Institute for Care Planning.13

The Collège des médecins urged consideration of euthanasia "for all incompetent individuals," (emphasis added) which, presumably, includes those who have never been competent;14 the  Quebec human rights commissioner made the same kind of recommendation.15

On this point, however, the College of Social Workers & Marriage & Family Therapists was more cautious.  The College felt that there was a sufficiently broad consensus to permit physicians to kill patients who had asked for euthanasia through an advanced directive.  However, it did not think it advisable to amend the law to permit the killing of people who had never been competent, and who, for that reason, had never asked for euthanasia.  The College believed there is not yet "a consensus of social acceptance large enough to actually impose it upon society, so "it would not be a good choice, in our view."

We must now, I think, accept what is accepted by the population, which allows us to take a step and then continue to talk calmly, in a non-partisan way, about the other dimensions.16

Insurance

The residency/insurance requirement would seem to preclude "euthanasia tourism." However, no one who is insured in another Canadian province would be denied medical treatment in Quebec prior to becoming an "insured person" under Quebec law.  Indeed: no uninsured person would be denied medical treatment.  The practice in such cases is to provide the treatment and bill the patient.  Someone from another province would then apply to his own province's health insurance plan for reimbursement, which would be limited to the fees payable under the other province's plan.17

Since the normal practice is to provide services for uninsured persons and then bill them, it is not clear what would happen if someone from another province who met all of the  requirements for ARELC (apart from residency/insured status) asked for euthanasia in Quebec. The Quebec Commission on Human Rights and Youth Rights has indicated that it would consider refusal in such circumstances to be unlawful discrimination.18

"At the end of life"

Bill 52 made no reference to time frames for euthanasia.  The Quebec Medical Association suggested that, while greater care is needed in providing euthanasia when death is not imminent, it is conceivable that some people might decide that death is imminent "at two years instead of three months."  The Association foresaw that euthanasia might be provided in such circumstances within the doctor-patient relationship, and that such cases can be reviewed by the Commission on End of Life Care.  Dr. Laurent Marcoux, President of the Association, said this would be an exception, but "You know, in life there are always exceptions."19 

On the other hand, Paul Brunet of the Council for the Protection of Patients saw no reason to consider this an exception.  Assuming that the patient met all of the other criteria, he asserted that the choice of timing should be up to the patient:

What is the difference between indignity when that person decides one morning to finish, five years before his death or eight days before his death? . . . What is the difference? . . . Who are we to come and say: No, you will wait maybe your death is imminent? Who are we, who am I? 20

A requirement was added to ARELC that patients must be at "the end of life" to qualify for euthanasia.  But when is a patient "at the end of life"?

The legislative committee studying Bill 52 was unable to answer the question. A reference to death being "imminent" was considered, but rejected after legal experts cautioned that the Supreme Court had decided that a threat to do something three years in the future could be considered "imminent."21 The same experts said that there are many ways to understand the term "end of life."22

It was acknowledged that it is very difficult to find a definition of end of life in medical literature,23 and that "the notion of the end of life is a concept that is interpreted very, very different in the groups."24  Mme Hivon, referring to the title of the bill, mused that it means being "really close" to death.25 One group thought the "end of life" could begin up to six months in advance of death,26 the Order of Nurses suggested it might mean a matter of weeks or days,27 and a legislator referred to a remark that "the end of life begins at the moment of our birth."28

Ultimately, the question remained unanswered, so the added condition that an applicant for euthanasia must be "at the end of life" provides only an opportunity for disagreement and judicial interpretation. 

"Serious incurable illness, advanced decline, pain"

With respect to the remaining conditions, note that the patient need not be terminally ill and remains free to refuse effective palliative treatments that he deems 'intolerable' and opt, instead, for euthanasia.  Moreover, most of the terms used are highly subjective; they can be variously understood and broadly construed.  A "serious and incurable illness" could conceivably include clinical depression, which could cause "unbearable psychological pain" that cannot be relieved because the patient finds the side-effects of anti-depressants intolerable.  Such a patient might end up in an advanced state of decline in capability, "irreversible" because of refusal to accept the (intolerable) treatment offered.

These interpretations (and others) are possible without changing a word of the statute, and one should not be too quick to dismiss them as mere fancies.  For example, the Quebec Ombudsman suggested that the Commission on End of Life Care "should really very thoroughly" study the possibility of providing euthanasia for the mentally ill.29  And Professor Margaret Somerville challenged the legislative committee members:

 I'd ask you to think, if a law with it would currently be murder, first degree murder, is not being obeyed, why do you think the restriction in Bill 52 would be obeyed? So, if our physicians are not obeying the law now, when it's the most serious crime on our books, why would they obey Bill 52?30

An incremental approach

Recall that, in relation to euthanasia for legally incompetent persons, the College of Social Workers & Marriage & Family Therapists advocated a step-by-step approach to expanding the law, moving forward in conjunction with the social consensus on such things.

This incremental approach to legalization was also recommended by others.  The Federation of General Practitioners, which also believed that the legislature should consider allowing euthanasia authorized in advance directives, nonetheless thought that this "should perhaps be in a second stage."31 The Quebec Bar, while recommended that applications to kill patients who have never been competent to consent to euthanasia should be handled by the courts,32 but thought it best to proceed slowly:

So what we are saying is that for these cases, maybe take the time to see how we will enforce the law, what will be, actually, the data that will be forthcoming, appeal to the Council on End of Life Care to see . . . how we can broaden the dialogue in society, and, possibly, at a second stage, perhaps include these cases. But for the sake of equilibrium - equilibrium you sometimes mention - it will, for now, in a first step, be limited to those able to clearly and freely express their will.33

Former Quebec Minister of Health, Dr. Yves Bolduc, agreed.  "[W]e are perhaps not ready to take the step of going directly there, but rather say: maybe do it in two stages."

[T]here could be one day when we will take the second step, that is to say, first, to settle what is for us, what we think is perhaps a little more obvious, and, [concerning] legally incompetent people, minors, gain experience, put a system in place . . . and, secondly, there may be a reassessment of the law, then we could decide, then, whether we could not go to the next step.34

"Getting over taboos"

With respect to authorizing the killing of patients who have never been legally competent, Ghislain Leblond admitted "we are not ready to do that right away."35  His co-presenter, Dr. Yvon Bureau spoke of a "duty" to those who have never been legally competent to ensure that "these people have the least amount of pain and they suffer as little as possible,"36 but acknowledged that  "society is not there" - yet - and urged that the matter be studied by the Commission on End of Life Care.  Leblond was insistent:

 I think we should get over our taboos. I know that there are some great souls who will become concerned, but the fact remains that there is a category of people who are condemned to atrocious lives of hell,  and parents and families who are sentenced to lives hell, and we must think as a society, if we are a community, we must get over our taboos and face up to this.37

In the meantime, the Quebec Ombudsman counselled patience and faith in evolution.  The Ombudsman believed it important to pass the bill "even conservatively."

And there is a social consensus that permits all that is in the bill to be accepted , I think we should move forward. And if there are still reservations that ensure that the bill could be blocked and delayed, in my opinion, it is better to start with what is a consensus , which is ensured, and let the law evolve.38

In what direction might the law evolve?  What other "taboos" might people have to "get over"?

Euthanasia for children

Making euthanasia available to minors and children might qualify as evolution.  This was recommended by the College of Social Workers & Marriage & Family Therapists of Quebec,39 Ghislain Leblond and Dr. Yvon Bureau,40 the Observatory for Aging and Society41 and the Commission on Human Rights and Youth Rights.42  The Commission was especially emphatic, putting the legislators on notice that restricting euthanasia to adults will be impossible.

The bad news for you is that, if the bill remains as it is when passed, I guarantee you there will be a 16 year old who will go to court, then the discourse will be judicial. And if I had a penny to put on the table, it will ... your legislation, the exemption, including the prohibition for incompetent minors will be quick-fried.43

The transcribed phrase "incompetent minors" (les mineurs inaptes) may not have accurately captured the statement, which would make more sense as "prohibition for incompetents and minors."  In any case, the Commission made it clear that preventing physicians from providing euthanasia for the uninsured, legally incompetent and minors would probably run afoul of human rights law, which imposes the criterion of "minimal impairment."

This criterion requires indeed that the measure adopted minimally affect the rights and freedoms restricted.  However, a full and unconditional ban as proposed in the bill imposed on minors, persons unable to consent to care, and those who are not insured under the Health Insurance Act is difficult to justify. In addition, the distinction between people who are incompetent to consent to care and others may constitute discrimination based on disability.44

While recognizing that introducing such amendments might be difficult, the Commission insisted that it was "essential." 

"It would be a shame," said Jacques Frémont, "after having courageously come this far, for the legislature to fail to protect the rights of  highly vulnerable people."45

Thus, while others wait for society and the law to "evolve," the Commission on Human Rights and Youth Rights seems poised to jumpstart the process.

Or, as euthanasia opponents argue, to grease the slippery slope.

Evolution or slippery slope?

Slippery slope

The danger of a "slippery slope"  is one of the perennial arguments advanced against euthanasia.  Briefly: the argument asserts that if euthanasia is legalized under restricted conditions, it will be impossible, in practice, to maintain the restrictions, and more and more people will be killed in circumstances never contemplated when the law was first changed.  Ultimately, it is said, people will be killed even though they might not wish to be.

Now, the transcripts of the hearings into Bill 52 certainly demonstrate that it is unrealistic to expect that ARELC's criteria for eligibilty for euthanasia will be maintained.  Patients and physicians can interpret them broadly even as they stand, and, in the longer term, it is obvious that powerful state institutions and influential groups in Quebec intend to see access to euthanasia expanded, moving incrementally to achieve their objectives.  This suggests that concern about a "slippery slope" is not unreasonable.

Evolution

However, supporters of Bill 52/ARELC emphatically reject concerns about slippery slopes, even as they urge legislators to make euthanasia more and more available.  The Quebec Association for the Right to Die, for example, told the legislative committee, "It is not a slippery slope to consider a new development, which is already predictable now." 46 The more common argument, however, is that society is evolving, and morality and ethics are evolving much faster than the law.47 Again, Dr. Yves Bolduc:

I have seen a lot in society, that the law lags behind ethics, and some point at the level of society we accepted things we did, they were accepted at the moral and ethical level, and laws had to be changed later, and I think it's this type of case that we now have.

"The proof," he said, "is that this is not the first in the world to do it, there are already four countries that do it. And then, at the medical level, there are doctors who are willing to do so, there are patients who are willing to have it."48

Véronique Hivon, the minister responsible for Bill 52 and ARELC,  asked, rhetorically, if legislators should ignore the evolution of society, especially "the consecration of the autonomy of the individual," and let people suffer by refusing applications for euthanasia even when they cannot be relieved by palliative care.49  While she acknowledged the fear of slippery slopes, she warned that "fear is never a good guide," saying, "I think caution is a good guide, and that's what guided me in developing the bill."50

The democratic process

In this regard, it is instructive to consider Mme. Hivon's rebuke of the Catholic bishops, responding to their attempt to demonstrate their concerns about a slippery slope:

 I tell you, and unlike you, democratic debate reassures me because I think that we, our role is to be in line with the demands of the people and listen to everyone without taboos. Sure it can hurt [the feelings of] people who have different values ​​to hear us  talk about this . . . quite freely. Should it expand? Should we consider legally incompetent people? People who say [they want physician assisted dying] when they are competent, but who become incompetent? People who are legally incompetent from birth? Minors? But I think it's a great sign of democratic health to be able to have this debate as we have had for almost four years, with such openness, where there are no taboos.51

In her view, the democratic process is an adequate safeguard against a slippery slope leading to uncontrolled killing.

When we say: perhaps a second stage, it's not because, overnight, we will not adhere to the guidelines: on the contrary. It's been three years since we discussed what should be done. And then we formed ​​another parliamentary committee for a month to discuss guidelines: this is because we want to make them with due care. Then, if there is democratic debate in a few years, will also, well, we, as elected officials, we must welcome that debate. . .52

Conflicting perspectives

Reiterating the point made earlier, it is reasonable to believe that ARELC's criteria for euthanasia will be broadened by interpretation, by statutory amendments and by court rulings or decisions of quasi-judicial tribunals, so that, as time goes on, there will be more euthanasia, not less.  Depending upon one's moral  or ethical perspective, this can be described as an uncontrolled descent down a slippery slope, a gradual process of natural evolution (for better or worse) or a democratically controlled ascent to a more liberal, compassionate and enlightened society. 

It is not necessary here to determine which of these conflicting perspectives is the most accurate.  It is sufficient, for present purposes, to observe that, based on the submissions to the legislative committee studying Bill 52,  the expansion of the eligibility criteria for euthanasia can be safely predicted.  This increases the likelihood of conflicts of conscience and conscientious objection to the procedure.

Notes:

1.  (". . .d'édicter des normes et des balises précises et bien définies pour protéger et rassurer les usagers et leurs proches.") Consultations & hearings on Quebec Bill 52 (Hereinafter "Consultations"), Thursday, 19 September 2013 - Vol. 43 no. 36: Quebec Bar (Johanne Brodeur, Marc Sauvé, Michel Doyon), T#006

2.  (". . . m'assurer que des balises appropriées soient prévues et mises en oeuvre de façon concrète afin d'empêcher que de telles dérives puissent survenir.") Consultations, Tuesday 24, Tuesday 24 September 2013 - Vol. 43 no. 37: Quebec Ombudsman (Raymonde Saint-Germain, Marc André Dowd, Michel Clavet), T#011

3.   ARELC, Section 26

4.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier), T#010

5.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier), T#011

6.  Consultations, Wednesday, 25 September 2013 - Vol. 43 no. 38:  Quebec Association for the Right to Die with Dignity (Hélène Bolduc, Dr. Marcel Boisvert, Dr. Georges L'Espérance), T#012

7.  Consultations, Tuesday, 17 September 2013 - Vol. 43 no. 34:  Collège des médecins (Dr. Charles Bernard, Dr. Yves Robert, Dr. Michelle Marchand), T#008(c)

8.  Consultations, Tuesday, 17 September 2013 - Vol. 43 no. 34: Federation of Quebec Medical Specialists (Dr. Gaétan Barrette, Dr. Diane Francoeur, Nicole Pelletier), T#111

9.  Consultations, Wednesday, 18 September 2013 - Vol. 43 no. 35: College of Social Workers & Marriage & Family Therapists of Quebec (Claude Leblond, Marielle Pauzé), T#016, T#092

10.   Consultations, Thursday, 19 September 2013 - Vol. 43 no. 36:  Association of Councils of Physicians, Dentists and Pharmacists of Quebec (Dr. Martin Arata, Annick Lavoie, Annie Léger), T#109

11.  Consultations, Thursday, 19 September 2013 - Vol. 43 no. 36: Quebec Bar (Johanne Brodeur, Marc Sauvé, Michel Doyon), T#028

12.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45: Professor Joceyln Downie, T#061,  T#062

13.  Consultations, Tuesday, 8 October 2013 - Vol. 43 No. 44: Institute for Care Planning (Danielle Chalifoux, Denise Boulet, Louise Boyd), T#021, T#022, T#029

14.  Consultations, Tuesday, 17 September 2013 - Vol. 43 no. 34:  Collège des médecins (Dr. Charles Bernard, Dr. Yves Robert, Dr. Michelle Marchand), T#009(d)

15.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier), T#010

16.  Consultations, Wednesday, 18 September 2013 - Vol. 43 no. 35: College of Social Workers & Marriage & Family Therapists of Quebec (Claude Leblond, Marielle Pauzé), T#092

17.  British Columbia Ministry of Health-Medical Services Plan- B.C. Residents: Leaving British Columbia  (Accessed 2014-06-11)

18.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43.  Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier) T#010, 011, 013

19.   Consultations, Tuesday, 17 September 2013 - Vol. 43 no. 34: Quebec Medical Association (Dr. Laurent Marcoux, Dr. Claude Roy, Mr. Norman Laberge),T#088

20.  Consultations, Tuesday, 1 October 2013 - Vol. 43 no. 40: Council for the Protection of Patients (Lucie Wiseman, Suzanne Fitzback, Pierre Hébert)T#050

21.  Consultations, Thursday, 10 October 2013 - Vol. 43 No. 46: Committee of Legal Experts (Jean-Pierre Ménard, Michelle Giroux) T#069, T#071 

22.  Consultations, Thursday, 10 October 2013 - Vol. 43 No. 46: Committee of Legal Experts (Jean-Pierre Ménard, Michelle Giroux) T#072 

23.  Consultations, Tuesday, 8 October 2013 - Vol. 43 no. 44: Quebec Order of Nurses (Lucie Tremblay, Claudia Gallant, Suzanne Durand, Sylvie Truchon), T#051

24.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45 Quebec Association of Clinical Ethicists (Delphine Roigt, Emilia Guévin, Michel Lorange) T#144  

25.  Consultations, Wednesday,9 October 2013 - Vol. 43 No. 45: Dr. Annie Tremblay, Dr. Pierre Gagnon,  T#036

26.  Consultations, Wednesday,9 October 2013 - Vol. 43 No. 45: Dr. Annie Tremblay, Dr. Pierre Gagnon, T#015 

27.  Consultations, Tuesday, 8 October 2013 - Vol. 43 no. 44: Quebec Order of Nurses (Lucie Tremblay, Claudia Gallant, Suzanne Durand, Sylvie Truchon), T#048

28.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45 Quebec Association of Clinical Ethicists (Delphine Roigt, Emilia Guévin, Michel Lorange) T#144

29.  Consultations,  Tuesday 24 September 2013 - Vol. 43 No. 37: Quebec Ombudsman
(Raymonde Saint-Germain, Marc André Dowd, Michel Clavet), T#080

30.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45: Professor Margaret Somerville, T#064

31.  Consultations, Tuesday, 17 September 2013 - Vol. 43 no. 34: Federation of General Practitioners of Quebec (Dr. Louis Godin, Dr. Marc-André Asselin), T#024

32.  Consultations, Thursday, 19 September 2013 - Vol. 43 no. 36: Quebec Bar (Johanne Brodeur, Marc Sauvé, Michel Doyon), T#029

33.  Consultations, Thursday, 19 September 2013 - Vol. 43 no. 36: Quebec Bar (Johanne Brodeur, Marc Sauvé, Michel Doyon), T#105

34.  Consultations, Thursday, 19 September 2013 - Vol. 43 no. 36: Quebec Bar (Johanne Brodeur, Marc Sauvé, Michel Doyon), T#041

35.  Consultations, Wednesday, 25 September 2013 - Vol. 43 no. 38: Ghislain Leblond, Dr. Yvon Bureau, T#126

36.  Consultations, Wednesday, 25 September 2013 - Vol. 43 no. 38: Ghislain Leblond, Dr. Yvon Bureau, T#130

37.  Consultations, Wednesday, 25 September 2013 - Vol. 43 no. 38: Ghislain Leblond, Dr. Yvon Bureau, T#016

38.  Consultations,  Tuesday 24 September 2013 - Vol. 43 No. 37: Quebec Ombudsman
(Raymonde Saint-Germain, Marc André Dowd, Michel Clavet), T#103

39.  Consultations, Wednesday, 18 September 2013 - Vol. 43 no. 35: College of Social Workers & Marriage & Family Therapists of Quebec (Claude Leblond, Marielle Pauzé), T#016, T#092

40.  Consultations, Wednesday, 25 September 2013 - Vol. 43 no. 38: Ghislain Leblond, Dr. Yvon Bureau, T#130

41.  Consultations, Tuesday, 1 October 2013 - Vol. 43 no. 40: Observatory for Aging and Society (André Ledoux, Gloria Jeliu, Denise Destrempes, Claude Tessier)T#129, T#130

42.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier), T#010, T#011, T#014

43.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier)T#114

44.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier), T#011

45.  Consultations, Friday, 4 October 2013 - Vol. 43 no. 43: Commission on Human Rights and Youth Rights (Jacques Fremont,  Renée Dupuis, Daniel Carpentier, Marie Carpentier)T#014

46.  Consultations, Wednesday, 25 September 2013 - Vol. 43 no. 38:  Quebec Association for the Right to Die with Dignity (Hélène Bolduc, Dr. Marcel Boisvert, Dr. Georges L'Espérance),T#066

47.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45: Professor Margaret Somerville, T#080

48.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45: Professor Margaret Somerville,T#068

49.  Consultations, Wednesday, 9 October 2013 - Vol. 43 No. 45: Professor Margaret Somerville, T#084

50.  Consultations, Tuesday 24 September 2013 - Vol. 43 no. 37: Coalition of Physicians for Social Justice (Dr. Paul Saba, Hélène Beaudin, Dominique Talarico), T#080

51.  Consultations, Thursday 19 September 2013 - Vol. 43 no. 36: Assembly of Catholic Bishops of Quebec (Bishop Noël Simard, Bishop Pierre Morissette),T#068

52.  Consultations, Thursday 19 September 2013 - Vol. 43 no. 36: Assembly of Catholic Bishops of Quebec (Bishop Noël Simard, Bishop Pierre Morissette), T#070