Evidence of meeting #79 for Health in the 44th Parliament, 1st Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was product.
A video is available from Parliament.
Assistant Deputy Minister, Regulatory Operations and Enforcement Branch, Department of Health
No. I'm sorry. We did 36 during the pilot. This year, we're hoping to do in and around 57. For the current structure we're in now, with no cost recovery, we would like to do even more.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
How many people do you have doing this?
Assistant Deputy Minister, Regulatory Operations and Enforcement Branch, Department of Health
In our program right now—in different functions, not just inspections—there are approximately 22.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
There are 22. How often do you do them?
Assistant Deputy Minister, Regulatory Operations and Enforcement Branch, Department of Health
How often do we do inspections?
Assistant Deputy Minister, Regulatory Operations and Enforcement Branch, Department of Health
Right now, companies are not on a cycle. They don't get inspected every two years or three years. We are constantly doing inspections.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
What I'm hearing is you're basically doing 100 per year out of how many businesses in Canada. I was a regulator for a profession in my previous life. I understand regulation very well. Ultimately, you talk about regulating, but it appears to me that you're not following the processes of how the regulations should be done.
What I'd like to get to is that you also talked about being open to feedback. It's fine to say you're open to feedback, but what are you going to do with that feedback? You can say you're open to feedback, but if you don't act on that feedback, what assurances do these businesses have that you actually will act on the feedback they give you?
Chief Medical Advisor, Department of Health
You don't have to believe us when we say that; we've actually demonstrated it. When we look at the labelling initiative, there were consultations before the initiative went forward. We put a proposal out, got comments and changed the proposal. We put in a six-year phase-in period to account for the feedback we got from industry, and we got comments from consumers. It was all incorporated. For that initiative, we did a full regulatory program. We took all that feedback; we put it into place, and then we finalized it. We intend to do that for any regulations we put forward.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
You basically got the feedback and you've tabulated that feedback so people can see what was sent to you, and therefore they can see.... That is available.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
Can you provide that for the committee?
Chief Medical Advisor, Department of Health
Yes. It's available online, but, yes, we can do that.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
Thank you very much.
When you get that feedback and it suggests to you that the fees are too high, what actions will you take?
Chief Medical Advisor, Department of Health
That's what we're in the process of doing now. The fee proposal is just that; it's a proposal. It went out for a 90-day consultation. We put that out. We got 4,700 comments. We are in the process of looking through those comments, and then we'll come back with any changes based on those comments.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
I look at this and, when I see what you're talking about, I still haven't heard from you what you would say to me that I could take out of this office. Can I say to my constituents that it's guaranteed that when they provide that feedback to you, they're going to be listened to? That's the assurance we need. That's what Canadians need, because you're going to tax them, and they need that assurance. How are you going to give that to them?
Chief Medical Advisor, Department of Health
Again, this is a cost recovery proposal. It is activities that are done by the regulator to regulate these products. Right now Canadians are paying 100% of those costs, and there are gaps that we need to fill. We need additional resources to do that. There are only two ways of getting those resources: Either Canadian taxpayers pay for it or the industry pays for some of it. Natural health products are the only health product line for which Canadian taxpayers pay all of those fees. It is a $5-billion-per-year industry in Canada. The cost recovery proposals are there based on a very standardized way that we calculate the fees. All of that is there in the proposals.
We have comments. A lot of the comments are, “We never want to pay fees.” It's a little difficult to do something with that. If there is constructive feedback or suggestions on how to modify things, we're absolutely open to looking through that.
Conservative
Robert Gordon Kitchen Conservative Souris—Moose Mountain, SK
If the business has an increased cost, that cost will be relayed to the people.
Liberal
The Chair Liberal Sean Casey
You're well past time, Dr. Kitchen.
Dr. Hanley is next, for five minutes.
Liberal
Brendan Hanley Liberal Yukon, YT
Thank you, Mr. Chair. I'm pleased to have another chance to ask a few questions.
I'm reflecting on the influence....
Speaking of feedback, I understand that the public accounts committee deliberated on these topics last year. I'm quoting some colleagues—Conservative friends—one of whom asked, “What is the level of the sense of urgency to actually get some real, strong deterrents and actual teeth”, in reference to the Attorney General report showing NHPs being contaminated.
Another one said, “Do you not find this disturbing, and are there any products out there right now that are supposed to be recalled and are not?”
I sense some perhaps mixed messaging from my Conservative colleagues about the need to address the safety of Canadians with measures like this. I for one am happy to see that Health Canada and the Minister of Health are stepping up to include natural health products where they pose risks, to make sure those gaps are closed.
Dr. Sharma, you've spoken a lot about costs. I think you've clarified a lot of our questions about costs and what they actually mean to consumers.
Can I come back to the $1.60 per Canadian again? Can you elaborate on that, so we understand what that means for Canadian consumers?
Chief Medical Advisor, Department of Health
Currently what's happening is that all of the costs are borne by taxpayer dollars for the entire framework.
If we're looking at the incremental increases from the cost recovery revenues, if we spread those costs across all Canadians—not just Canadians using products—if 100% of those costs were passed along by the industry to Canadians, that would be the equivalent of $1.60 per Canadian, regardless of whether they use the product or not. Again, it's really up to the companies what they do with those increased costs.
The $58,000 in terms of the fees, that's a class 3 product of the highest complexity, which is very novel and would take additional time. That's the minority.
The majority of products are class 1. The fee for a new product and seeking to market it in Canada would be just over $1,000. With the fee remissions for a small company, that would be $562. The equivalent of that for a pharmaceutical, prescription medication would be over $500,000 as a fee to Health Canada.
Liberal
Brendan Hanley Liberal Yukon, YT
Thank you very much.
Is it possible that presently we are underestimating some of the risks because of the need to close these gaps in information? Is it possible that we are actually underestimating some of the safety risks of natural health products?
Chief Medical Advisor, Department of Health
I think we don't know what we don't know with respect to the products, because we have a reactive system. In the postmarket space, in the inspection space, and in the advertising complaint space, it's reactive, so it's based either on doing pilots or on something coming to our attention. That's when we can investigate. We really don't have a system that's proactive. We're definitely missing things.
Again, I don't want to misrepresent these products as being riskier than prescription products. That's not the case. They are low-risk, but they are not no-risk. We know that in certain circumstances they can cause considerable harm because of how the products are used, if they're overused, if they're contaminated, if they're used inappropriately. There definitely is an underestimation of the risks.
Liberal
Brendan Hanley Liberal Yukon, YT
Given that a large percentage of our population uses natural health products, we want to make sure we address potential gaps in safety so that we can provide assurance to Canadians. It also helps support the many businesses that are appropriately profiting from the sale and production of these products.
I'm probably out of time right about now.
Liberal
The Chair Liberal Sean Casey
You are indeed out of time.
Mr. Thériault, you have two and a half minutes.