Regarding the history of Health Canada's attempts at what is loosely termed “legislative renewal” for the Food and Drugs Act, you're correct that there have been numerous attempts in the past. For example, in the late 1990s there was an intention to roll the Food and Drugs Act into an omnibus act with 10 other acts of Parliament, which failed miserably, but only because of the actions of non-profit groups in bringing to the attention of Canadians the abysmal destruction of regulatory powers that was about to occur.
So the track record is not good. The issue here, in historic perspective, is that we have been through roughly 30 years of deregulation, beginning with the deprofessionalization of the agency in the 1970s and 1980s, removing people with expertise who could challenge drug companies. At the same time, we had regulatory indifference publicly. It was politically voiced as red tape--safety and so forth are nothing but red tape to regulators.
In the more final phases, we've had the dismantling of the actual department, the destruction of the drug research labs, the half-destruction of the food research labs, and the farming off of environmental health to a different department.
Now we are in the true final phase, fourth phase, of deregulation, which is dismantling the very legislation that creates the power to do such things as create a moratorium. We have that ability at the moment. It would be quite possible to do, but Health Canada not only does not enforce the regulatory authority it has, it now seeks to actually dispel itself, to dismiss the regulatory authority so it can no longer be held accountable when things go wrong.