Thank you, Madam Chair and members of the committee, for this opportunity to provide Food, Health & Consumer Products of Canada's perspective on the proposed biocides regulations.
Food, health and consumer products sectors employ nearly 300,000 Canadians in businesses of all sizes across the country that manufacture and distribute the safe, high-quality products that are at the heart of healthy homes, healthy communities and a healthy Canada.
FHCP strongly supports the proposed biocides regulations.
The two key types of products captured by the proposed regulations—surface sanitizers and disinfectants—are currently governed under two separate pieces of legislation, the Food and Drugs Act and the Pest Control Products Act, and regulated by separate agencies. Given that these products have similar risk profiles and are used under similar conditions, this approach is cumbersome and inefficient for both government and industry. A single framework and regulator, as proposed under these regulations, is an important step forward for all, especially for consumers and taxpayers.
The COVID pandemic underlined the importance of sanitizers and disinfectants to all Canadians, as well as the vulnerability of our supply of these products. Through the extraordinary efforts of Health Canada and a broad range of Canadian companies, those supplies were bolstered by virtue of an interim order by the minister that allowed them to be authorized for sale in Canada based on foreign approvals. One of the key benefits of the proposed biocides regulations, in our view, is the creation of a permanent pathway for the use of decisions by trusted foreign regulators in authorizing products for sale in Canada.
FHCP is very encouraged to see Health Canada apply the lessons learned during the pandemic to modernize the framework. The “use of foreign decisions” provisions will create more competition and innovation in the marketplace, increasing consumer choice and, in so doing, will ease some of the inflationary pressure on these products. The UFD provisions do not compromise safety for Canadian product approvals. The ambulatory list of trusted regulators whose decisions can be leveraged is limited to those whose approval criteria align with those of Health Canada.
Since the supply chains for these products are generally North American in scope, it is natural that the United States Environmental Protection Agency is the first foreign regulator to appear on this list, but the regulations provide a process and pathway for other regulators to be qualified and to further increase the opportunities to reduce the amount of resources going to redundant reviews of the same safety information against the same criteria and generating the same outcomes.
Once approved, these products will be subject to the same postmarket oversight by Health Canada as all other licensed products. Should that postmarket experience result in questions about the safety of a product, all of the authorities from Vanessa's Law will be available to compel manufacturers to submit additional safety information, including the information submitted to the original foreign regulator.
Given the absence of any compromise on consumer safety and other regulatory outcomes, the appropriate use of foreign decisions in product regulation offers a great opportunity to drive costs out of the system and increase competition. This would give consumers more choice and more competitive pricing at a time when the cost of living is a significant concern for so many.
Canadian manufacturers can be very competitive, but many organizations, including the World Economic Forum, have noted a decline in our competitiveness and cite burdensome regulations as a principal cause of that decline. Regulatory modernization can have a dramatic impact on international competitiveness.
In the decade that followed the introduction of the natural health products regulations in 2004, we saw exports of these products more than double in Canada, to over a billion dollars. That is a growth rate in exports of more than double the overall average for Canadian manufacturing. This was because those new regulations were internationally recognized as being both robust and class leading and, at the same time, provided an efficient pathway for innovative products to reach market.
Only time will tell whether the biocides regulations will have a similar effect, but making the marketplace for these products more competitive is not something we should fear.
Thank you, Madam Chair.
I'm ready to answer questions from members of the committee.