Thank you, Madam Chair.
I appreciate that the committee has undertaken a review of this subject and that you have invited me to speak.
I am the owner of Flexo Products, a Canadian company that's been in Niagara Falls since 1918. I'm the great-grandson of the founder. My son, who will be the fifth generation, has also joined our company. I have an engineering degree and an MBA from the University of Toronto, and I'm a registered professional engineer in the province of Ontario.
My company employs 85 people and is a manufacturer and distributor of cleaning chemicals and supplies to industrial customers. We stock 7,000 products in seven warehouses. We sell these products to school boards, day cares, health clubs, universities, nursing homes, cleaning contractors, hotels, restaurants and industry. We are both a manufacturer and a distributor to end-users. We make approximately 60,000 deliveries a year in our own trucks. During COVID, my company was on the front lines, trying to fulfill the requirements of customers for not only biocides but also other needed supplies, such as hand sanitizers, gloves and masks.
My company has been making registered biocides for over 35 years. We currently have a list of 26 products in the Health Canada drug product database. While the current regulations have been effective over the years, we welcome the development of a new category of regulated products through the creation of a single framework.
When our company decides to produce a new disinfectant cleaner, we reach out to various producers of biocidal active ingredients to find an appropriate formula for our needs. These companies, all based in the U.S., own master registrations and have completed all the work to prove to Health Canada that their formula has verified biocidal claims. Our registration documents go to Health Canada, together with a letter of authorization from the raw material manufacturer and a label proposed by us. We wait for our notice of compliance. Upon approval, we buy the main disinfectant raw material and make the product in our facility.
The majority of manufacturers in Canada would not have the resources to make and sustain the necessary biocidal claims without the work the U.S. companies perform for us. Typical testing to certify a new product costs over half a million dollars per product. There are no guaranteed results. As new bacteria and viruses arise, we rely on these companies to update their claims, so we can update ours. During COVID, as a result of their work, we were able to update labelling on many of our products. The Canadian market needs these companies and their R and D. We need access to new technologies. Most current biocides are made from corrosive and sometimes flammable raw materials, and the push for safer and greener products in our environment requires new technology.
There's no shortage of Canadian manufacturing capacity to make the end-use product. Our company and many of my competitors in Canada have highly scalable facilities. Our biggest problem during COVID was not that we didn't have the proper products to kill the virus, or that we couldn't get the appropriate label claims. In fact, during COVID, Health Canada staff were very responsive. They gave us excellent support and worked overtime to process requests. The real problem was that we could not get enough of the raw materials in a timely manner. We need to consider how to ensure we get these raw materials should another pandemic occur.
The financial impact to Canadian manufacturers of recognizing foreign registration is a dual-edged sword. We need the U.S. registrations and their technologies. What will likely come is more U.S. manufacturers selling their products into Canada. It will cause a reduction in sales among domestic manufacturers. The moderately reduced fees that have been proposed for Canadian manufacturers in no way mitigate that problem.
I was happy to see the new regulations propose changes to labelling. I get to see and talk to many end-use customers. I would like to suggest that the labelling of bottles be reviewed with more emphasis on helping the end-user. Many users in janitorial positions do not have the education or expertise to fully understand all the information on existing labels. Current labels are frequently packed with huge amounts of data not needed for the application of the product.
In the scope of the new biocides regulations, it was proposed to exclude air sanitizers at this time. During COVID, one of the major requests from customers was to help them sanitize rooms through the use of hand-held sprayers. Huge amounts of sanitizers were sold for this use. It is a potentially dangerous operation to perform without proper safety standards. Should another similar pandemic arise, there will be countless people once again wanting to do this, and I would suggest that regulations on air sanitization be reviewed as soon as possible.
I appreciate the time you have afforded me. I look forward to your questions and comments.