1. Prevalence of financial conflicts of interest among panel members producing clinical practice guidelines in Canada and United States: cross sectional study
2. 29. A recent decision by the Supreme Court of Canada is illustrative of this emergent transparency. The majority held that the confidential business information exemption from disclosure under the Access to Information Act, R.S.C. 1985, C. A-1, s. 20(1)(b), did not apply on the facts of the case because the information in dispute was, to a large extent, publicly available via the FDA's website. See Merck Frosst Canada Ltd. v. Canada (Health) 2012 SCC 3 at para. 182 [hereinafter Merck Frosst]. Also, in draft proposals intended to increase the transparency of its decision-making, the FDA has specifically highlighted greater levels of transparency at the EMA as a reason to pursue policy change. See FDA, Transparency Report, supra note 27.
3. 23. United States Government Accountability Office, FDA Advisory Committees: Process for Recruiting Members and Evaluating Potential Conflicts of Interest, September 2008, available at (last visited April 14, 2014).
4. Transparency battle resurfaces as EU trial revamp wraps up
5. 131. See Habibi, Lexchin, , supra note 112.