Thank you, Ms. Faisal.
Canadians must be able to make informed choices about natural health products. When a serious risk is identified, Health Canada must have the necessary authority to protect the public.
CPhA supports regulation that is proportionate to risk. We recognize concerns about unnecessary regulatory burden and the importance of access to natural health products. These products already have a distinct framework under the natural health products regulations. Their inclusion in the definition of “therapeutic product” also gives Health Canada specific safety authorities under Vanessa’s Law. CPhA’s position is consistent with the advocacy we have brought forward for more than a decade. We supported Vanessa’s Law when it was enacted in 2014, and in May 2023 Senate testimony, we raised concerns about the original exclusion of natural health products and supported extending these protections to help mitigate serious safety risks. We are therefore defending protections that CPhA previously advocated and continues to support.
Our concern is the loss of these specific safety authorities for the products excluded from the bill. Today, when a serious risk involving a natural health product arises, Health Canada can require information to assess that risk, order a label or package change and, where there is a serious or imminent risk, order a recall. These are targeted safety tools intended to allow the regulator to respond when significant concerns arise. Most manufacturers act responsibly when safety concerns present themselves, but a regulator must also have the authority to act when voluntary measures are insufficient. Patient safety should not depend solely on voluntary compliance.
Retaining Vanessa's Law protections does not mean imposing identical requirements on natural health products and prescription drugs. Natural health products already have a distinct regulatory framework. The issue before the committee is whether Health Canada should continue to have the authority to act when serious risks arise.
We also recognize concerns about costs, administrative requirements and patient access. Those concerns should be addressed through targeted, proportionate changes that preserve patient safety rather than through the removal of safety authorities that allow the regulator to respond to serious safety risks. Canadians should be able to access natural health products with confidence that serious risks can be investigated and addressed.
In summary, CPhA recommends that the committee not proceed with Bill C-224 in its current form. Natural health products should remain within the definition of “therapeutic product”—