Bill C-51 – Jackboot Inspections, Big Pharma Intrigue, or Good Government
Great work by aDam for picking up on the ideological stance being adopted by some natural health product (NHP) advocates concerning Bill C-51. The Health Minister’s 22 April 2008 speech on the Bill indicates the government’s desire to “gain the ability to continuously monitor the safety of products even after they are approved,” especially through licensing and inspection. The speech was given to a food and consumer safety conference and so was focused more on the food regulatory aspects than on NHPs. However, as aDam points out, much of the Bill’s criticism is coming from the NHP community, which is strange because, just a decade ago, they were trying to get Health Canada to regulate NHPs as a way of giving the products credibility.
In the mid 90s, it was the NHP community, and not “Big Pharma,” who pressured the government to compel Health Canada to develop and implement regulations for NHPs in Canada. The report Natural Health Products: A New Vision provides an overview, at least from the perspective of 1998. Bill C-51 is really just the logical extension of that implementation process.
To produce the report, the House of Commons Standing Committee on Health heard testimony from across the broad spectrum of NHP practitioners, industry and advocacy groups. Based partly on this testimony, the Committee established that:
With two of the Committee’s Guiding Principles being:
Quality: The NHP industry must meet clearly defined and established standards of quality.
To meet these Guidelines, the Committee recommended, again based on NHP advocacy, that:
GMP standards for NHPs include specific quality control and testing for herbal products;
Manufacturers, packagers, importers and distributors of NHPs, whether located in Canada or abroad, be obliged to hold valid establishment licenses;
Inspection activities be performed consistently and on a regular basis by inspectors knowledgeable about the products.
Bill C-51, in part, addresses these recommendations. Given that Natural Health Products: A New Vision was written 10 years ago when a different political party was in power, the implementation of C-51 is an amazing example of regulatory follow-through.
NHPPA’s discussion paper identifies many of the salient changes to the Food and Drugs Act that will be put into force by Bill C-51 but provides a paranoid assessment of the impact of those changes (although not as paranoid as the educate-yourself website where Bill C-51 equals “Nazi Germany’s 1933 Enabling Act”). The paper also illustrates the NHP advocates’ selective amnesia on their position:
Really? That’s funny. Back in 1998, the Advisory Panel on Natural Health Products (APNHP) preferred this now despised term:
Similarly, back then:
However now, when it has come time to implement the enforcement mechanism, we find that:
In the mid 90s, the NHP industry needed Health Canada to formally recognize NHPs through legislation in order to ensure safety and quality:
Now, they seem to be saying that you should trust the industry to ensure safety and quality, and therefore why bother with regulations, inspections and those difficult-to-meet licensing requirements. I guess the NHP industry just wants to be treated like their products – big on claims but not on formal evidence.