Evidence of meeting #85 for Health in the 44th Parliament, 1st session. (The original version is on Parliament’s site, as are the minutes.) The winning word was industry.
A video is available from Parliament.
Liberal
The Chair Liberal Sean Casey
Mr. Skelton, we're at time for this round, so please answer in 30 seconds if you could.
President and Chief Executive Officer, Canadian Health Food Association
I think I would reference back to the congratulations to this committee for the work that was done in 1998 and 2004 on the extensive consultation—hundreds of testimonies and patient groups—and then to the complete lack of engagement on this one. We didn't hear about cost recovery until May 11, and it was gazetted on May 12.
Liberal
Liberal
Sonia Sidhu Liberal Brampton South, ON
Thank you, Mr. Chair.
Thank you to all of the witnesses for being with us.
My question is for Ms. Hyland.
In your testimony, you talked about how some brand names have different ingredients and about improving the safety of Canadians. How are these regulatory changes going to support a safer marketplace for Canadians who consume natural health products?
Vice-President, Operations and Privacy Officer, Institute for Safe Medication Practices Canada
I think I'll answer that with.... Health Canada's approach is seen as reasonable and supportive. We have seen some examples—I think, Gerry, you mentioned it—where they're embracing the new regulations for labels, so we have seen some examples where label changes have been made. I'm also hearing that we need more enforcement, that we have a lack of enforcement. The cost recoveries are intended to have that happen—with better compliance and better inspections.
Does that answer your question in terms of...?
The other part of the answer, maybe, is that, if we have product facts tables consistently on all products, similar to nutrition facts tables on our food products, I think it's going to be easier for both consumers and professionals to look at products, compare products and make selections without errors.
Liberal
Sonia Sidhu Liberal Brampton South, ON
Thank you, Ms. Hyland.
Do you want to add to that, Ms. Sheldrick—on why these regulatory changes are so important for Canadians?
Patient and Family Advisor, Institute for Safe Medication Practices Canada
Sure. Thank you.
The product facts tables that have been improved are very readable for the consumer. Consumers can go into the store and select the product they're looking for. They can read it, and it's clear so that they know what they're buying.
Sometimes what might happen is that, if you buy a product where the information is not clear, you spend an amount of money, you take it home and it's the wrong product. Then you can't return it, which is an additional cost to consumers because then they go back and replace it with another product. There are considerations for costs to consumers, but we have to look at it very carefully. Really, the priority is the clarity of those labels and getting that information to consumers as clearly as possible, because that will impact the safety and the quality.
Liberal
Sonia Sidhu Liberal Brampton South, ON
Thank you, Ms. Sheldrick.
Mr. Chair, I want to share my time with Dr. Hanley.
Liberal
Brendan Hanley Liberal Yukon, YT
Thank you.
I want to, again, thank all of the witnesses. All of this information has been really useful to inform further steps. I only wish that my Conservative colleagues had allowed us to get the most out of your testimony rather than theirs.
I certainly hear the concerns that industry representatives have brought forward, and these are really valid concerns. I just want to point out that, on cost recovery, my understanding is that consultations are still ongoing and that this is a draft proposal. I'm glad that we can get some of those concerns on record, including that Health Canada is still in the process of consulting with the industry.
I know I don't have a lot of time, but my questions will be for Ms. Hyland.
There have been many questions about the lack of ability to get the data that we need to have a good sense of the incidence of adverse effects. Under Vanessa's Law, my understanding is that this will add a mechanism to get better data on adverse effects. I wonder if you could comment on that aspect.
Vice-President, Operations and Privacy Officer, Institute for Safe Medication Practices Canada
First, most Canadians don't yet know where and what to report when they have concerns or incidents of harm. Truly, we don't have all of the data and the knowledge of the harm that natural health products might be causing.
With regard to your point, it's great to hear industry support for Vanessa's Law because, with Vanessa's Law, we will see more reporting and learning. This will inform continuous improvement, including the warning statements on packages for the consumer.
Does that answer your question?
Liberal
Liberal
Brendan Hanley Liberal Yukon, YT
I am aware of that.
There's been a lot of talk about getting the balance right. Will an improved sense of consumer confidence and safety be a potential plus for the businesses that we are all concerned about?
Vice-President, Operations and Privacy Officer, Institute for Safe Medication Practices Canada
I think the main point is—and I heard—that the regulatory requirements in Canada are perceived to be very strong. Yes, I think so much has been done to regulate NHPs. Canadians believe that all of these requirements are being met when they buy that product. All of this work that has been put in place by Health Canada to enforce the new authorities that are created is all being done because Canadians already expect that they are there. When they pick up a product in a store, they are expecting that it is safe and effective.
We heard that, in premarket, the work is very well done. We need more monitoring and compliance checking with the new requirements, as well as more reporting and learning, so that we have more data and more knowledge.
Does that answer your question?
Liberal
The Chair Liberal Sean Casey
It does indeed. Thank you, Ms. Hyland.
Mr. Thériault, you have the floor for two and a half minutes.
Bloc
Luc Thériault Bloc Montcalm, QC
Thank you, Mr. Chair.
My next question is about labelling. The more crowded a label is, the less likely the consumer is to read it. In Quebec, we have a particular problem, because a French version is required on the label. It is sometimes difficult to put everything on the same label, which will lead to more paper or packaging.
Personally, when I am not able to read the entire label, I do not buy the product.
We have here a proposed solution that will come into effect in six years. Manufacturers will have to make changes and incur costs, and the proposed changes are already out of date.
Could we not sit down, all of us together, and find a solution?
What do you propose as a solution?
Member, Canadian Health Food Association
One thing that I agree with my colleagues from the ISMP on as being very important is analyzing the information we have coming in. It's called the human factors analysis. There is good guidance from Health Canada regarding that.
I can say categorically—I have it in writing from Health Canada—that they refuse to conduct one regarding this most recent labelling initiative. One of the big irritants that industry has is that we aren't confident that we are solving the problem. For the problem you're describing, professionals from the University of Toronto have identified the fact that you can't solve all problems with labels. You have to look at other ways of communicating. The other issue we have is the length of warnings. We saw the green tea liver warning label double in size. It's essentially twice as many words. That's hard for people to understand. It's hard for them to get to.
What we really need to do is to sit down with experts, do the proper analysis and come up with solutions that don't put all our eggs in one labelling basket but actually find the correct solutions. There's a lot of good information coming from groups like the ISMP. We just need Health Canada to conduct the analysis in a way that we all respect and see it published. That has never taken place in the last four years of consultation. That's one thing that's really important: to find the correct analysis and the right tool to solve the problem.
Liberal
The Chair Liberal Sean Casey
Thank you.
The last questions will come from Mr. Davies, please.
You have two and a half minutes.
NDP
Don Davies NDP Vancouver Kingsway, BC
Thank you, Mr. Chair.
Before I leave labelling, I'm confused by numbers as well because Dr. Sharma left the impression with this committee that the vast majority of product samples that were reviewed by the Auditor General were advertised with misleading product information. However, Health Canada's own compliance monitoring project, which tested natural health products for vulnerable populations, found the opposite. They did a label review and found 92% to be compliant.
What do you have to tell the committee in terms of the accuracy of labelling on NHPs in this country?
Member, Canadian Health Food Association
We trust the compliance enforcement report that you referred to—the 90%. We have investigated the numbers used by the Auditor General. They're not representative of the population.
Essentially, of every single big-box store and pharmacy in the country, everyone, even Amazon, are 90% non-compliant? That's just false. We learned that those numbers were patently false. We see them repetitively used. The compliance numbers that you referred to, those are accurate.
NDP
Don Davies NDP Vancouver Kingsway, BC
I understand there's a controversy about whether the Auditor General was purposefully sampling or randomly sampling.