NHPPA 3 PART PLAN
SUSPENSION OF THE CURRENT REGULATIONS.
The NHPPA recognizes that seeking concessions under the current regulations, such as seeking relaxed standards of evidence, may buy the natural health community more time. It needs to be recognized, however, that temporary concessions will not solve the problem.
The current regulations deem all natural health products to be illegal. Only those which can overcome onerous conditions can remain on, or enter, the market. The purpose and design of the current regulations is to restrict access. The current regulations can only do what they are designed to do: restrict access. It is false to believe that:
- the current removal of tens of thousands of NHPs is unintended or accidental, or
- the current disaster can be solved by “tweaking” some of the onerous conditions.
The current regulations need to be suspended and replaced with balanced regulations that:
- honour the desire of Canadians to increased access to natural health products;
- create a balanced risk analysis that recognizes the extremely low level of toxicity inherent in NHPs so that the risk of removing safe and effective health products is reduced when taking into how to best protect Canadians;
- deem natural health products to be legal as they are in the United States;
- permit small and medium sized producers to thrive.
For all intents and purposes natural health products were unregulated until 2004. Even now, most of the products Canadians regularly purchase in health food stores are illegal and non-compliant with the current regulations. Suspending the NHP Regulations would not suddenly create an unregulated environment. Indeed, there would not be much of a change at all. All that would change is that natural health products Canadians have been relying on for decades would stop disappearing while a review of how to regulate them occurs. Health Canada would be in the same position it was in up to 2004. It could take targeted action against products where there was a legitimate health risk.