The 3 Part Plan
NHPPA Action Plan
The NHPPA has developed a three part plan to solve the current regulatory crisis. The plan includes:
- Seek a suspension of the Current Regulations.
- Start court proceedings to have the Natural Health Product Regulations
declared unconstitutional.
- Move to have the Charter of Health Freedom enacted to guarantee a reasonable legal environment for natural health products, and to prevent continued over-regulation of NHPs in the future.
Executive Summary
Current Regulatory Environment
After the largest citizen movement in Canadian history directed at increasing
our access to natural health products, Canadians should be enjoying increasing access.
Unfortunately, instead of enjoying increasing access, we are facing a crisis
where we are losing access to most of our natural health products. The Standing Committee on Health (“Natural Health Products: A New Vision” November 1998, containing the 53 recommendations) and the Office of Natural Health Products Transition Team (“A Fresh Start – Final Report of the ONHP Transition Team”, March 31, 2000) gave directions intended to increase access to natural health products. Despite these directions, Health Canada has imposed inappropriate drug-style regulations on the NHP industry.
The only logical consequence of the current drug-style regulations is to
drastically reduce access to natural health products. The regulations deem all NHPs to be illegal. Only those that can meet onerous conditions can remain on the market. There is no mechanism to prevent Health Canada from making the conditions more onerous. There is no mechanism to prevent Health Canada from adding new conditions.
Half of the NHPs that go through the licensing process fail to get a licence and
must be taken away. A large number of NHPs are not being put through the licensing process and must be taken away once enforcement action is stepped up. Thousands of foreign NHPs, are no longer available. By some estimates 75-80% of NHPs that Canadians have traditionally enjoyed will become unavailable under the current regulations.
The Government of Canada has not done a single risk-analysis to determine the
risk of removing tens of thousands of NHPs from Canadians who rely upon them for health conditions. In effect, the Government is pretending that products people rely upon for serious health conditions can be taken away without there being health consequences.
On the other hand, NHPs are seldom failing the licensing process because of
safety concerns. The overwhelming majority of NHPs that are deemed illegal because they fail to get a license are considered safe by Health Canada. Canadians demanded increased access to natural health products. Currently, they are facing a crisis where:
- the majority of natural health products they rely on for health conditions are being taken away;
- many of the most innovative herbalists and producers will be put out of
business, and
- innovation into new multi-ingredient NHPs is grinding to a halt. Herbalists
simply no longer believe they can get approval for new products.
In short the natural health product community is being destroyed by drug-style regulations designed to restrict access to natural health products. This is a dangerous development which must be stopped if Canadians want to continue to use natural health products.
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DOWNLOAD the 3 Part Plan
