Thank you so much.
Good afternoon, Mr. Chair and members of the committee.
My name is Pierre. I'm the founder of the Canadian College of Traditional Chinese Medicine. I'm also a licensed practitioner of Chinese medicine and acupuncture. I have experience with importation and regulation, and I'm also the subject matter expert through the Standards Council of Canada under ISO technical committees 249 and 215. I'm here to explain why, from the perspective of traditional Chinese medicine, it's important to pass Bill C-224.
First, we need to understand that “natural health products” is a very broad category. It includes everyday products such as herbs, vitamins, minerals, homeopathic medicine, traditional Chinese medicine, Ayurvedic medicine and also ethnomedicines of first nations. To make this easier to understand, currently, Health Canada classifies everyday products under “natural health products”: Toothpaste, sunscreen lotion and lip balms—these are considered some of the low-risk items. When we talk about natural health products, we're not talking about one uniform category of high risk covering everything; there are broad categories.
Risks can be very different. Even water has risks. If you label water as a natural health product.... The only difference between water and a natural health product is that a bottle of water does not label that it treats dehydration, but, when it does, it becomes a natural health product. If you label water as a natural health product, then you'll need risk information—the risk of overdosing, causing water poisoning or drowning. That's the difference between a natural health product and an everyday product.
This is important for Canada, because natural health product regulations address the unique nature of these things. Canada describes this framework today as “separate and distinct...from prescription drugs”, and it's appropriate to the generalities of the low-risk nature of NHPs. That doesn't mean we're claiming that natural health products are risk-free, as they're not—as an example, as I said previously, water is not risk-free, depending on the substance, dose, concentration, formulation, manufacturing quality and how this product is used—but we're claiming that NHPs are already regulated.
A finished natural health product generally requires a product licence before it can be sold, and manufacturers and importers are subject to site licensing. GMPs—regulating addresses, ingredients, dosage, health claims, warnings, contamination, adverse reactions and recalls—already exist, so to add these on top of it is just unnecessary. Traditional Chinese medicine—TCM—businesses already address quality issues such as identifying microbial contamination, pesticides and heavy metals, when applicable.
The question raised is whether Bill C-224 should remain within the Food and Drugs Act category of “therapeutic product”. Remember, this additional protection that people are talking about is Vanessa's Law. Its full name is Protecting Canadians from Unsafe Drugs Act, so it was applied, originally, to a drugs act, but it was not applied to health claims for food and things like that.
These additional authorities include mandatory recall for serious or imminent health risks, although Health Canada has already done recalls in the past. If you have products that require a recall, they say, “Okay, you have to recall or we'll fine you, or we'll take away your natural health product licence. We'll take away your site licence.” Those measures are already in place. You don't need an additional Protecting Canadians from Unsafe Drugs Act—also known as Vanessa's Law—to the Food and Drugs Act in order to take it out of the drugs act to apply it to natural health products.
An important question for the committee to talk about today is proportionality. What is the proportion you want to use? In Chinese medicine, a lot of the common herbs that we use are food. Ginger and cinnamon are common things that we use, in Chinese medicine, as therapeutic products. How much recall do you need for a piece of ginger that we have health claims for versus one that you sell in a supermarket?
Another example I like to use is Canadian ginseng. Right now, Canada is one of the biggest producers of North American ginseng in the world. Canadian farmers can harvest and grow ginseng as an agricultural raw material. Having this additional labelling actually prohibits these farmers from selling it as a natural health product in Canada. They could sell it as food and raw material. They would sell it to China to further process it, and then China would sell it back, because it's cheaper that way.
It is the same for our gas. That's what we're trying to do. We're creating red tape and then making further red tape reductions in the future, which makes no sense.