Relaxing the “Drop Dead Date” — Then and Now

A STAY OF EXECUTION IS STILL A DEATH SENTENCE

With the news that 2011 will be the year of full compliance and enforcement of the NHP Regulations, many natural health stakeholders are feeling betrayed by Health Canada. Despite their best efforts to comply, to discuss and to explain, the industry is beginning to realise that compliance has, and will, merely delay the dismantling of the natural health community.

Attempts at compliance have not only assisted with the decimating of an industry; they have had untold consequences in harm done to those Canadian citizens who rely on natural products for their health, wellbeing and often their very lives.

We have not wavered from the ‘radical’ and unpalatable truth: that taking away vital health products is inherently dangerous and leads to death and suffering. This entirely predictable result of the NHP regualtions as they are written is still mostly hidden.  You will not find it in the mainstream media.  Most MPs do not realize that the current situation is causing harm instead of reducing harm, since their information comes directly from Health Canada. However, the evidence is out there for those who choose to see it.

Health Canada could have known and ought to have known. To this day, no risk analysis has been carried out to show the number of deaths that should be expected by forcing many of the 21,300,000 Canadians who regularly take natural health products into the chemical pharmaceutical model. Health Canada employees have been made aware, with documentary evidence, of the distress and ill-health their implementation of these Regulations has caused and continues to cause. And yet their response is to appease the industry with token delays and minor amendments to a fundamentally criminal system.

You cannot force many of those 21,300,000 Canadians out of the natural health model which has never led to a documented death and into the chemical pharmaceutical model which is a leading cause of death, without serious health consequences.

It is time to reiterate, loud and clear, what the NHPPA has known and stated from its inception in 2008. The NHP Regulations are inappropriate and dangerous. They are specifically written to annihilate our industry and their existence can only lead to pain, distress and ill health. They must be suspended and replaced.

Here is what the NHPPA had to say in December 2009:

Relaxing the “Drop Dead Date” — Complacency Reigns

By Natural Health Products Protection Association

December 2009

Many in the industry are understandably relieved with the publicity that Health Canada will not start its strict compliance plan against unlicensed natural health products until 2011.

The industry has also been thrown another concession, a review of a handful of the Schedule F (i.e. prescription drugs).

It is frightening that these are seen as “positive” developments.  They are “positive” in the sense that the industry is being granted a few concessions.  What is frightening, however, is how grateful and complacent the natural health community becomes when Health Canada slows its drive to re-shape the NHP industry into something that only the larger companies want.

The natural health community has become so afraid of Health Canada that a slowing of the “inevitable” death of the natural health product industry as we knew it becomes a cause of relief.

The reality is that:

  • we are going to lose 75-80% of our natural health products;
  • the “types” of products will change.  Many multi-ingredient products will not remain;
  • innovation into multi-ingredient products will be stifled;
  • our children will not have access to the types of products we enjoyed;
  • many quality firms will not survive;
  • many will be terrorized by Health Canada enforcement action when full compliance is a reality;
  • eventually we will face cost recovery.

What is perhaps most troubling is that Canadians who rely on NHPs that will be lost are going to suffer health consequences.  This is an ethical crisis that we face.  We know that the natural health community is more than a marketplace or a business environment:  it is a place where many find healing and relief.  We also know that by rendering the majority of NHPs illegal, that many will suffer health consequences.  Most of us are standing by and watching as this happens.

The over-regulation of the NHP industry is not an accident.  It is not a mistake.  It is not due to any misunderstanding of the meaning of the NHP Regulations.  The death of the NHP industry as we knew it is the inevitable result of the Regulations as they are currently written.  Doing nothing, or trying to achieve minor concessions can only lead to the result we are all witnessing happen.

The NHPPA is not willing to celebrate minor concessions while NHPs continue to be relentlessly driven from the shelves.

The natural health community is facing a crisis of belief.  Many believe they have to settle for the truncated industry that Health Canada will allow.  Many believe that we cannot have a vibrant industry that celebrates innovation and common sense.  Many believe that putting vulnerable Canadians at risk as vital health products are taken away cannot be stopped.  Many believe that Canadians cannot have the freedom to access natural health products that they previously enjoyed.  The NHPPA does not subscribe to any of these beliefs.

In its short history the NHPPA has demonstrated the power of positive action and belief.

The NHPPA does not believe that the natural health community needs to settle for the bleak future Health Canada is offering.  The NHPPA does not believe that we can ethically pass this challenge by accepting complacency and fear.  Indeed, complacency and fear are necessary for Health Canada to succeed.

The public supports this industry and is passionate and motivated about protecting access to natural health products.  We do not have to settle.  We can re-focus and move forward.

The NHPPA is calling on the entire natural health community to shake off complacency and fear, and work towards ensuring we have a vibrant and growing future.