Good morning. I too will be making my presentation in French, if that's fine with you.
I would especially like to thank Christiane Gagnon for inviting me here, as well as her team and the clerk for helping me prepare my presentation. I would also like to extend my congratulations to Health Canada and to the NHPD in particular for trying to be rigorous from a scientific standpoint and at the same time for keeping an open mind when broaching the subject of natural health products. I agree with you that a separate category should be created for these products.
I will come back to the very laudable principles behind the regulations, which are now recognized as a model around the world. As Philip Waddington stated, these principles are based on freedom of choice and access to natural health products, as well as on the assurance of safe and high quality natural health products.
Today, I want to touch on three main points: safety, natural health product and drug interactions and the importance of research. I am the only witness here today from the world of academia. As you will see, many things are directly related to research.
The first thing I want to discuss is safety. Health Canada and the NHPD have issued many guiding principles, but there are four areas in particular that I want to touch on. The first relates to evidence. Health Canada has demonstrated its innovative spirit by including as evidence information stemming from medical and traditional knowledge. That is very laudable. Of course, this information is at the bottom of the evidence scale, but it is important to include it as health evidence.
According to the second guiding principle, all of the evidence must be weighed from every angle. This brings me to the third point, namely risk management. Basically, the Health Canada approach consists of assessing risk against benefits. I will give you an example of this later. Another guiding principle is that when in doubt, a person should abstain from using a product. If there is any risk, a person is better off not using a product.
I'd like to discuss the use of natural health products. In Canada and around the world, between 65% and 80% of the world's population use natural health products, compared to a much smaller proportion of people who must use synthetic drugs. This is an important statistic to remember.
From the standpoint of pharmacovigilance, natural health products are considered to be safe and available information shows that unwanted side effects are very rare. In the majority of cases, poor product quality is to blame. For example, the side effects could be caused by a bad plant, cutting or contaminants, as Mr. Waddington mentioned. The regulations governing sound manufacturing practices already address many of these problems because they call for the identity of the plant and the presence of contaminants to be verified.
Another thing to consider is that some available over-the-counter drugs such as acetaminophen also pose a real, serious risk. If a person ingests 10 to 20 times the recommended dosage, death could ensue, although this is not in fact noted anywhere on the label. The manufacturer relies on consumers.
I also think that the Natural Health Products Directorate is being somewhat alarmist about natural health products. This attitude is fueled to some degree health care professionals. It also stems from the lack of knowledge of health care professionals and from the lack of evidence on natural health products. Research in this area is therefore very important.
The principle whereby a person should abstain from using a product when in doubt takes precedence over all the others. I would say that when in doubt, a person should rely on human experience and on traditional medicine.
I wanted to touch on several other points, but I will move directly to drug interactions. Here again, there is a disconnect between the perceived risk and the real risk. People often use theoretical evidence to issue a warning against the danger of combining natural health products. However, if we consider the real evidence, we see that there is very little evidence that this is in fact the case. I strongly recommend that solid evaluation mechanisms be developed to weigh both risks and benefits.
Finally, I would like to talk about the importance of research. The NHPD is the only regulatory body with the funding to promote research and the mandate to promote research on natural health products. Unfortunately, its funding has been withdrawn. While the $1 million in funding was not a large sum of money for Canada, it still had an important effect in terms of leverage. I strongly urge you to restore this funding to promote research so that we are better equipped to assess both the risks and the benefits.
Thank you.