Thank you, Chair.
On behalf of the Institute for Safe Medication Practices Canada, we appreciate the opportunity to provide our perspective regarding Bill C-368.
ISMP Canada is a pan-Canadian, not-for-profit and independent organization established in 2000 to improve the safety of drugs and health products for Canadians. Our key activities include expert analysis of error reports from consumers, providers and health care organizations to learn about the risks related to these products; to share evidence-informed recommendations for improved safety; and to work with consumers, care providers and other health system partners to reduce preventable harm.
We recognize that access to safe natural health products is important to Canadians. Through our work and that of others, we know that the manufacturing of NHPs and the use of NHP products are not without risk.
Many Canadians may not be aware that NHPs are a broad category and include more than vitamins, herbal remedies, traditional medicines and homeopathic medicines. For example, acceptable medicinal ingredients also include scopolamine, pseudoephedrine and methyl salicylate.
Consumers have shared with us that they believe that Health Canada has rigorously checked and approved all NHPs for safety. They also assume retailers will sell them only if they're approved by Health Canada and that they are safe for sale. Consumers said, “I trust what is on the shelf is good for you”, and that they are “safe since they are on the shelf.”
Over 700 incident reports related to NHPs have been reported to us, including 400 since 2019. Of these 400 reports, over 15% indicated some level of harm. Most were mild harm; however, two were reported as contributing to a death. Importantly, there is under-reporting of incidents to us.
We have two key areas of concern regarding Bill C-368. The first is that natural health products will be exempted from the important regulatory provisions under Vanessa's Law. We provide four specific examples of the impact.
Health Canada would no longer have the authority to recall a product from retail settings if there is an identified serious risk.
Health Canada would no longer have the authority to compel a label change if there is an identified serious risk.
Health Canada would no longer be able to advance new regulations that require licence-holders to conduct additional tests to help inform Health Canada's risk assessments.
Health Canada would no longer be able to advance new regulations that require that serious NHP adverse reactions be reported when a patient is seen in hospital. Reversing this capability is concerning because this information is essential to better understanding the magnitude and impact of the risks related to NHPs.