Self-care is an important part of preventive health, which is crucial to supporting the well-being of Canada’s growing—and aging—population. Millions of Canadians use cosmetics, natural health products (NHPs) and over-the-counter medication to support a healthy lifestyle every day, with 77 per cent of our population using NHPs. Canadians are increasingly interested in playing a role in maintaining their health. They take regular steps to lead healthy lifestyles, and they should feel confident in the support and oversight offered by government. This is precisely why it is so important for Health Canada to strike the right balance in regulating health products, and precisely why so many consumers and businesses are concerned.
Over the past two decades, Parliamentarians and Health Canada have taken a thoughtful and thorough review of how NHPs should be regulated, and determined that they were distinctly different from foods and drugs. This led to the Natural Health Products Regulations. Both Health Canada and Parliamentarians have acknowledged that different types of self-care products require different regulations. This is why they have made repeated efforts to improve Canada’s regulations to promote the quality and accessibility of self-care products, which the Canadian Health Food Association has supported in the past.
Health Canada’s latest attempt to modernize their regulatory approach, Consulting Canadians on the Regulation of Self-Care Products in Canada, misses the mark of achieving a framework that works for all health products. While the CHFA believes regular review lies at the root of improving the regulatory system for self-care products, we are concerned that this review will result in pre-ordained regulatory changes, based on initial research that is fatally flawed.
Health Canada commissioned a consumer poll to examine this issue before setting the broader consultation in motion. The poll asked out-of-context questions regarding consumer knowledge on the regulation of products, yet failed to ask consumers whether they think a SPF lipstick, or vitamin C, should be regulated under the same framework as pain relievers, or cold and sinus pills that contain pseudoephedrine. We feel that this is a question consumers deserve to have a say in, as it lies at the core of the department’s objectives. The process for this review, and the misguided research on which it was built, will negatively impact the millions of Canadians who rely on NHPs.
The release of Health Canada’s consultation document was alarming for many businesses in the NHP sector. Since the most recent improvements to the NHP Regulations in 2008, members of CHFA have spent millions of dollars to ensure products are compliant and satisfy Health Canada’s pre-market approval process for product efficacy and safety. As a result, consumers can choose from over 100,000 compliant NHPs to support their healthy lifestyles, all of which they can trust, because the department has reviewed them.
Under the new proposal, the most concerning recommendation is that some products that do not make claims about health benefits would be allowed to come to market without any pre-market review by Health Canada. These products would carry a disclaimer to the effect of, “This product has not been reviewed by Health Canada.” This approach may work for some cosmetic-like products, but will certainly create more confusion, while providing less information, for Canadians trying to make healthy choices in regards to their supplement use, and will not lead to any increase in safety.
While there is room for Health Canada to educate the public about self-care products and to provide more information to consumers, the system in place for NHPs is working well. The CHFA cannot support steps that will undo years of progress just to solve a problem that is poorly defined, or worse yet, simply doesn’t exist. Because of the years of work done by Parliamentarians, Health Canada, and industry, Canada is viewed as a world leader in regulating NHPs. Let’s keep it that way.
Helen Long is the president of the Canadian Health Food Association.
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