Thank you.
Mr. Chair, members of the committee, thank you for giving me the opportunity to provide input into your study of e-cigarettes.
My name is Gerry Harrington and I am the director of policy for Consumer Health Products Canada.
Consumer Health Products Canada is the trade association representing the companies that make evidence-based, over-the-counter medicines and natural health products. These are the products you can find in medicine cabinets in every Canadian home, from sunscreens to vitamins to pain relievers and allergy medications. People use consumer health products to maintain their health and manage minor ailments. This is a fundamental part of self-care, which is vital to the health of Canadians and to the sustainability of our health care system.
Consumer Health Products Canada is very proud of the contribution that our members' products make to the reduction of tobacco use in Canada. Specifically, nicotine replacement therapies regulated as natural health products, such as gums, patches, inhalers, have been demonstrated to dramatically increase the odds that a quit attempt will be successful, and have made a very meaningful contribution to the reduction of tobacco use in Canada over recent decades. These products are clinically tested as smoking cessation therapies and are supported by both self-directed and health profession administered programs aimed at ending dependence on nicotine and tobacco smoke.
lt is our view that the evidence available today strongly supports smoking cessation as the most appropriate therapeutic end point for the use of nicotine-containing products. We want people to quit smoking, and when there is a sufficiently low potential for relapse, to quit using nicotine as well. The natural health products regulations are designed to ensure that products authorized for sale under their provisions offer Canadians benefits that outweigh any risks associated with their use. Ending a user's dependence on tobacco and their exposure to the extensive and well-documented harms associated with smoking is demonstrably a benefit that far outweighs the risks associated with short- to medium-term use of nicotine. However, the science is less clear on the net benefit to patients when they continue to be addicted to inhaled nicotine.
I emphasize that this science is still evolving, and we understand that's one of the key challenges before the committee today.
lt's extremely important to note that the approval of a smoking cessation product under the natural health products regulations requires not only clinical evidence of quality, safety, and effectiveness of the product as a nicotine replacement therapy, but also the provision of labelling and other patient information and supports that guide users through a program that aims to end their dependence on tobacco. Nicotine-containing natural health products are not merely nicotine delivery vehicles; they are proven, comprehensive smoking cessation therapies with both pharmacological and behavioural program elements.
While it may be arguable that long-term exposure to nicotine and the other components of e-cigarette vapour may be less harmful than cigarette smoking—and I think that is fairly self-evident—this harm reduction model is not consistent with the philosophical or legal underpinnings of the natural health products regulations themselves. Additionally, the availability of e-cigarettes as products intended for long-term use creates significant risks to Canada's tobacco control strategy. Specifically, by mimicking smoking behaviour, widespread e-cigarette use could renormalize smoking—something I know the committee has heard from other witnesses before—undoing decades of hard-fought changes to social attitudes toward this unhealthy behaviour. Further, dual use of e-cigarettes and combustible tobacco cigarettes may delay or undermine quit attempts and couId compromise the intent of public health measures banning the use of combustible cigarettes in public spaces. We've seen even today some of the advertising that speaks directly to that risk.
Finally, the very real risk of e-cigarette use acting as a gateway to nicotine use was reinforced by recent findings published by the U.S. Centers for Disease Control that more than a quarter million youth who had never smoked a cigarette used e-cigarettes in 2013. That's a threefold increase over the previous year.
In addition to our concerns about the risk to human health associated with approving e-cigarettes for long-term use, the status quo where illegal cigarette sales flourish in the absence of any real enforcement of the existing regulations exposes Canadians to further potential harms associated with the absence of provisions to prohibit unproven health claims for e-cigarettes; the absence of quality assurance to ensure the safety of both the e-cigarette devices and the supply of nicotine-containing fluid; the absence of child-resistant packaging for the nicotine-containing fluid; the absence of control over advertising, and specifically advertising directed to minors—and when I say advertising, I include the full range of promotional activities that would be addressed in those kinds of regulations; the absence of a prohibition on sale to minors over the condition and place of sale, including accessibility to minors; and finally, the absence of recall provisions and adverse event reporting provisions. As we have heard numerous times over the course of this study, the science is still evolving and hence the value of collecting adverse events has to be considered.
Today we're talking about e-cigarettes, but we don't know what new products the future will bring. CHP Canada urges the health committee to recommend that all nicotine-containing products, including e-cigarettes, be regulated to the same standard of quality, safety, and efficacy as natural health products, and that perhaps more importantly, these regulations be enforced by Health Canada to protect the health and well-being of Canadians.
Thank you. I look forward to your questions.