International Trade committee  It varies by country. The U.S. is a good example. It depends on the sector. The American federation works a little differently from ours, so the jurisdiction can shift depending on the setting. For sanitizers that are used in a manufacturing facility, yes, there are state-level requirements that complicate the ability to do business.

International Trade committee  I think this regulatory proposal maximizes a lot of the opportunity that's available. If we're looking at the United States, we see that one of the beauties of the regulations is that the list of trusted foreign regulators is ambulatory. That means it can be amended. We can add to it.

International Trade committee  There are a number of ways that regulators do that. One of them is, for example, the use of foreign decisions. There is an element there where premarket review can be incorporated from a foreign jurisdiction. Most regulatory regimes also have postmarket requirements, so that's things like vigilance of the product once it's been sold, inspections of facilities, and so on and so forth.

International Trade committee  It's about ensuring that they have the appropriate resources in place and the appropriate processes. They can process some applications in batches. They have a variety of tools. I think it would be very helpful for the committee to highlight the need for a plan.

International Trade committee  Health Canada has to plan for this transition. We've seen it sometimes go well, and we've seen it other times go not so well.

International Trade committee  Yes. Health Canada has the capacity, and it has ways of dealing with transitions like this. It can be a risk-based compliance and enforcement mechanism for existing products. In fact, in situations where the transition is more dramatic, we've even seen things where.... There was reference to how long it took to get the natural health product regulations in place.

International Trade committee  I don't have the performance standards for those reviews at the tips of my fingers. I'm sorry, but that's something we could follow up with.

International Trade committee  Yes.

International Trade committee  Thank you for the question, once again. The idea of cumulative regulatory burden is one of the things we need to spend more time looking at. For example, we're talking right now about the biocides regulations, but the manufacturers of those products are also dealing with new regulations from ECCC around recyclability.

International Trade committee  Thank you for the question. I work in a world where our members also manufacture drugs, for example, and natural health products. For this type of efficiency and this type of leveraging of other decisions from other trusted regulators, I think if folks had a better understanding of how often the same data is reviewed for multiple products in multiple jurisdictions that arrive at the same outcome, the impetus there is not only in terms of market access, which of course from our perspective is the important issue, but also in terms of the resources being churned up in government.

International Trade committee  There's nothing I would love better than to see FDA allow these foreign decisions, such as those by Health Canada. I want to correct one thing however. Over 50% of our members are SMEs. Yes, I think if we want to look at it purely from a trade point of view, the industry would love to see the same kind of use of foreign decisions happening in the United States.

International Trade committee  Yes.

International Trade committee  Yes.

International Trade committee  One hundred per cent. That's precisely what my point was. That was an example of where modernized regulations made Canadian manufacturers' products more attractive outside the country and actually created export opportunities.

International Trade committee  Thank you, Madam Chair and members of the committee, for this opportunity to provide Food, Health & Consumer Products of Canada's perspective on the proposed biocides regulations. Food, health and consumer products sectors employ nearly 300,000 Canadians in businesses of all sizes across the country that manufacture and distribute the safe, high-quality products that are at the heart of healthy homes, healthy communities and a healthy Canada.