Dear Scott Sawler and
the Natural Health Product Directorate:
I have spent four frustrating years writing letters and speaking to my provincial and federal public health servants. I am given blank stares and the same verbal script about how the government wants to keep Canadians safe. My grievances challenging the elimination of very safe
products are not being considered whatsoever in these conversations. This political system does not seem to belong to me or the people who feel as I do about Health Canada’s crushing Natural Health Product Regulations. I am writing this email to you in order to explain my
position, which is contrary to Health Canada’s Natural Health Product Directorate’s (NHPD’s) decision that will affect my use of enzymes and probiotics. It will cost me and other Canadians our well-being. Maybe this is the intention of pharmaceutical stakeholders such as Consumer
Health Products Canada, the Canadian International Pharmaceutical Association, Health Canada and others who persist in regulating NHPs within a pharmaceutical drug-style model.
For instance, the NHPD’s proposition against the free use of enzymes and the standardization of digestive aids such as unique probiotic formulations is undemocratic, authoritarian and discriminatory. In fact, it is based on zero supporting evidence. The panel of lower ranking Health Canada employees working on this file was extremely
dismayed with the biased way in which this decision on enzymes and probiotics was being made.
The Canadian Digestive Disorder Association states that more than 20 million Canadians suffer from digestive disorders every year. However, because few people speak openly about their digestive symptoms, government, employers and the general public underestimate the magnitude
of the problem. Statistics include the following:
• Digestive disorders cost $18 billion annually in
health care costs and lost productivity (as of 2000).
• Each year, nearly 30,000 Canadian’s die of diseases
of the digestive system.
Must I now be forced to litigate against all those responsible for these decisions that discriminate against me, someone who was diagnosed with irritable bowel disease and a hiatal hernia 20- years-ago? My argument represents the feelings of others who suffer from chronic
and terminal ailments. Our best insurance against malabsorption
is the use of enzymes and probiotics. There are full spectrum forces restricting the consumer from the convenient therapeutic use of Natural Health Products (NHPs). As an example, Consumer Health Products Canada (CHPA) was formerly known as the Non- Prescription Drug Manufacturers Association of Canada, the Proprietary Association of Canada and the Proprietary Articles Trade Association. Like a chameleon, this trade association seems to have changed its name over the years to suit an evolving agenda. It is a powerful lobby
group that speaks to Health Canada on behalf of major pharmaceutical industry members. It does not consist of NHP members. Its guiding motto is focused on “Advancing Evidence Based Self-Care,” but the scientific, drugstyle regulations it lobbies to enact on NHPs endanger the availability of life-essential NHPs that have never, prior to
these Regulations, faced recalls due to potential danger. Over the last few years, headlines in the mainstream media demanded that pharmaceutical companies be held accountable for over 107,000 annual deaths caused by prescription use while under medical supervision. Will the CHPC dare lobby the federal government for the
“Advancement of Safety Monitoring and Reporting of Pharmaceutical Drug Dangers and Clinical Trials”?
This fall, the Auditor General of Canada’s publication includes
a damning report on Health Canada’s regulation of pharmaceutical
drugs In my opinion, there are internal forces restricting access and diversity of Natural Health Products (NHPs), including those working within the NHP industry. I have heard business stakeholders explain that naturopaths may be granted “prescription-only” rights for select NHPs. This would mean consumers would have to book appointments
with practitioners in order to access many useful NHPs. There are factions of NHP organizations that are divided and compromising in their negotiations for fear of appearing uncooperative.
Large manufacturers can afford to commit human and financial resources to following the NHP Regulations. Some desire to reduce the number of their competitors within the NHP marketplace, as the NHP Regulations squeeze small and mid-sized manufacturers out of business. As a consumer, I ask, “Where is the desperate outrage from practitioners and retailers?” Why are they afraid to publicly discuss the dire future of NHPs in Canada? Consumers are simply not being
informed about what is taking place and how to defend their natural health interests.
Each of us stands to lose in the coming years, as NHPretailers in the country will carry little to differentiate one store’s product from the next. I noticed this whilst in Europe. There, you find very small sanitized, homeopathic pharmaceutical shops, with very few over-the-counter products. All vitamin and mineral supplements were locked up behind glass shelving. They were double in price compared to Canadian prices. Customer orders were given to the on-duty desk practitioners. Most products on the shelves were not pure or concentrates, but watered down and mixed with artificial preservatives and flavourings,
chemicals and “parfum.” The NHP industry cannot survive if products are compromised and when the synthesis of products for individualized treatments is no longer possible due to limited access. According to the proposed NHP Regulation on enzymes, I will be asked to pay for a naturopathic consultation each time I require three days worth of enzymes. If this is the case, I would like to be compensated for my natural healthcare costs for NHPs that are being forced to pass drug-oriented safety and efficacy requirements by Health Canada. It is only fair.
Additionally, this three-day, prescription-only restriction on enzymes is not founded in science. I have studied the work of Dr. Howell, a renowned expert on enzyme nutrition, who compiled his research into a
1,000-page book called Enzyme Nutrition. My family and close friends have safely used up to 30 enzymes a day for various ailments. Never have I experienced a health issue from continued use. Rather, I have personal testimonies of healing. Who will stand for the free access of enzymes and probiotics for the sake of all of the hundreds of thousands
of Canadians who are crippled by digestive disorders? If this regulatory change is approved, emergency rooms and walk-in clinics will be impacted. If we cannot simply purchase enzymes and probiotics and use them at our own convenience, we will suffer.
The NHP Regulations lack common sense. They discredit the honour of the NHP field. Countries are considering bans on Red Bull soft drinks, while Health Canada grants this product a Natural Product Number
(NPN) license! It contains dangerous acesulfame K and aspartame. Dangerous products that are not entirely natural are receiving NPNs. Rolaids and Crest toothpaste now have NPNs. I have met my threshold with the 2001 NHP Regulations. My life will be in danger if enzymes, probiotics and other digestive aids are standardized or restricted. This is a life threatening situation for 20 million Canadians.
F. Longo, Manitoba
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