Let me address the “cosmetic” issue first. “Cosmetic” is currently defined in the Food and Drugs Act, and we are supportive of a revised definition in order to remove any confusion about the products addressed in this bill. These are known as non-corrective or plano lenses, and we believe that adding the word “cosmetic” to that definition will create confusion. There is already a separate definition that appears in the Food and Drugs Act and a separate regulatory framework that deals with cosmetics. So that's the first issue.
With respect to not being regulated, this is not the case. Non-corrective contact lenses have been regulated. What the bill is proposing is to put them in with products such as corrective contact lenses. Because they are likely made by the same manufacturers of similar materials, it was thought that they should be put with the medical devices regulations under the Food and Drugs Act.
Until this time, non-corrective contact lenses have been regulated under the authority of the Hazardous Products Act and the hazardous products regulations. More recently, they were considered under the Canadian Consumer Product Safety Act, which is where they sit right now. So it's not the case that they are not subject to regulation.
I think the proposed legislation would move these products into a regulatory framework that's more encompassing, that has pre-market requirements and post-market requirements, and that has quality requirements for the manufacturers.