THE STANDING SENATE COMMITTEE ON SOCIAL AFFAIRS, SCIENCE AND TECHNOLOGY
EVIDENCE
OTTAWA, Thursday, May 11, 2023
The Standing Senate Committee on Social Affairs, Science and Technology met with videoconference this day at 11:32 a.m. [ET] to examine the subject matter of those elements contained in Divisions 8, 13, 14, 15, 16, 17, 18, 19, 25, 27, 28, 29, 35 and 38 of Part 4 of Bill C-47, An Act to implement certain provisions of the budget tabled in Parliament on March 28, 2023; and, in camera, for the consideration of a draft agenda (future business).
Senator Ratna Omidvar (Chair) in the chair.
[English]
The Chair: I call to order this meeting of the Standing Senate Committee on Social Affairs, Science and Technology. I would like to begin by welcoming members of our committee, our witnesses and members of the public watching our proceedings. My name is Ratna Omidvar. I am a senator from Ontario and chair of this committee.
I would like to begin by doing a round table and asking senators to introduce themselves, starting with the deputy chair of the committee.
Senator Bovey: Patricia Bovey, Manitoba.
Senator Seidman: Judith Seidman, Montreal, Quebec.
[Translation]
Senator Mégie: Marie-Françoise Mégie from Quebec.
[English]
Senator Bernard: Wanda Thomas Bernard, Nova Scotia.
[Translation]
Senator Petitclerc: Chantal Petitclerc from Quebec.
[English]
Senator Kutcher: Stan Kutcher, Nova Scotia.
Senator Moodie: Rosemary Moodie, Toronto, Ontario.
Senator Burey: Sharon Burey, Ontario.
Senator Osler: Gigi Osler, Manitoba.
Senator McPhedran: Marilou McPhedran, Manitoba.
The Chair: Today, our committee begins its study on the subject matter of divisions of Bill C-47, An Act to implement certain provisions of the budget tabled in Parliament on March 28, 2023, that were referred to our committee on April 27, 2023.
In total, 14 divisions of the bill were referred to our committee, and we have a reporting deadline of June 2. This gives us a lot of material to cover in a short amount of time.
I remind senators that in reporting on the divisions that have been referred to us by the Senate Finance Committee, our committee can make observations, and we will be allocating time at the end of each meeting to discuss observations on a rolling basis so that the analyst can prepare a draft report for our consideration at the end of this study.
Our first panel will be focusing on Division 27, which deals with amendments to the Food and Drugs Act relating to natural health products.
Joining us today in person are Aaron Skelton, President and Chief Executive Officer of the Canadian Health Food Association; and Dr. Barry Power, Editor-in-Chief and Acting Chief Pharmacist Officer with the Canadian Pharmacists Association. Thank you very much for being with us today.
Before we begin, I would like to ask members and witnesses in the room with us to refrain from leaning in too close to the microphone or removing your earpiece should you do so. This will avoid any sound feedback that could negatively impact the committee staff in the room.
I remind our witnesses that each organization has five minutes for opening statements, followed by questions from senators.
Mr. Skelton, the floor is yours.
Aaron Skelton, President and Chief Executive Officer, Canadian Health Food Association: Thank you, chair and members of the committee, for having me here today. I am grateful for the opportunity to speak before you today. My name is Aaron Skelton, and I’m the President and CEO of the Canadian Health Food Association.
For almost 60 years, the Canadian Health Food Association has represented the natural, organic and wellness industry, working alongside and in collaboration with Health Canada. Natural health products are important to Canadians and the Canadian economy. As many as 71% of Canadians use natural health products, such as vitamins and supplements, as part of their proactive health care. Providing Canadians with access to safe, effective and regulated products is crucial.
The natural health product industry plays a valuable role in the Canadian economy. Our sector, mainly comprised of small and medium-sized enterprises, directly employs approximately 55,000 Canadians and contributes $11.3 billion to GDP. Natural health product manufacturers, wholesalers, importers and retailers can be found in almost every riding across the country, providing jobs and tax dollars back to the community.
Today, I am here to talk about the Protecting Canadians from Unsafe Drugs Act, also known as Vanessa’s Law. An amendment to the Food and Drugs Act was included in Annex 3 of the budget that will include natural health products under Vanessa’s Law — an inclusion that was a surprise to our association and industry.
Originally, the act was conceived for pharmaceutical drugs. It applies to therapeutic products including prescription and over‑the-counter drugs, vaccines, gene therapies, cells, tissues, organs and medical devices. Vanessa’s Law does not currently apply to natural health products or cosmetics.
Although the Canadian Health Food Association supports the intention to protect Canadians from unsafe drugs, we cannot support the amendments listed in Division 27, Part 4 of Bill C-47 and request that it be removed from the bill. We expect transparency through robust consultation. However, recent events have eroded our confidence in the process.
Frankly, the procedure for this amendment was wrong. In 2014, the Standing Committee on Health debated this exact issue, deciding that natural health products would be exempt from the powers conferred by Vanessa’s Law. Instead, a framework for lower-risk products was proposed, called the “self-care framework.”
Almost a decade later, that work is incomplete, and we appear here today as an industry that is frustrated. The 2014 commitment to the self-care framework feels as if it has disappeared. Rather than a dedicated framework for low-risk products, Health Canada has taken a piecemeal approach that is hurting industry, Canadians and, ultimately, regulators.
We have a world-leading system here in Canada, but we do not have a world-leading application of this system. Health Canada has strong regulatory powers to enforce the rules as they currently stand, including mandatory reaction reporting, mandatory label changes based on safety concerns, seizures, stop sales, cancellations and suspensions of licences. The problem is they continue to add regulations but do not appropriately enforce what exists.
Specifically, for the extension of powers conferred under this act to natural health products, there was no meaningful consultation with industry. Without consultation, we do not know the extent to which these powers will go, whether they will be used at all or abused in enforcement. We simply don’t know what we don’t know.
For our industry, the lack of meaningful consultation does not stop there. New labelling regulations were introduced less than a year ago. The consultation on the most expensive regulatory changes faced by our industry to date was run simultaneously with two other consultations, over the summer months, with aggressively tight timelines. Our concerns for small businesses and modern electronic labelling, to be direct, were ignored.
To add to these initiatives, the department has signalled that they intend to introduce a fee system to recover costs in the next two years, which will impact the entire industry and further affect Canadian business. Again, no consultations on costing and methodology have been shared to date.
I would like to make this clear. As an industry, we continue to support regulation and legislation that protect Canadians, are transparent and developed in a responsible and appropriate manner.
Today, we ask this committee to consider removing Division 27, Part 4 from this bill. The Senate amended the budget in 2017, and we urge you to consider the precedent here. The extension of this act to natural health products should not be made until the self-care framework for lower-risk products is communicated and properly consulted upon. It is what the industry and Canadians expect and deserve.
I thank you again for your time. I am happy to answer any questions you might have on this topic.
The Chair: Thank you, Mr. Skelton. Dr. Power, please go ahead.
Barry Power, Editor-in-Chief and Acting Chief Pharmacist Officer, Canadian Pharmacists Association: Good morning, members of the committee, and thank you, chair, for inviting us to provide our views on the budget provisions related to the Food and Drugs Act, specifically to extend some of the safety measures that currently apply to other prescription and over‑the‑counter drugs to natural health products.
As the association representing Canada’s 45,000 pharmacists, we have a unique understanding of medications whether they are prescription, over-the-counter or natural health products. As the largest publisher of drug information in Canada, our organization’s focus is also to help pharmacists and other health professionals understand how to appropriately use medications and counsel patients on a wide variety of drug products.
The Canadian Pharmacists Association, or CPhA, has been a strong supporter of Vanessa’s Law since it was introduced in 2014, but at the time, we expressed concerns that natural health products, or NHPs, were excluded from the bill. We’re glad this is being revisited now.
NHPs are a widely used category of products that can be sold in pharmacies as well as in many other outlets. Although natural health products are often seen as low-risk, we need to keep in mind that “low-risk” does not mean “no risk,” and “natural” does not mean “safe.” NHPs do have the ability to cause harm, and given their widespread use, we are pleased to see that further regulations have been proposed to help protect the health and safety of Canadians.
However, this isn’t just about the risk profile of natural health products. The provisions, as we understand them, would also provide further powers to trigger recalls in cases where there is an issue with the product itself, for example, contamination, which is something we’ve seen with other drugs and NHPs in the past.
It would also ensure that labelling changes can be made more expediently where specific risk factors are identified. In fact, a 2021 independent auditor’s report found that of 75 licensed products for sale on Canadian websites, 56% of the products were marketed with misleading label information, such as unauthorized health claims, incorrect dosing information and incomplete lists of ingredients.
We recognize that while many NHPs may be beneficial, post‑market safety oversight is necessary to ensure that all drugs and health products meet the high standards that Canadians expect. By extending some of the provisions in the Food and Drugs Act to NHPs, we can ensure that health care professionals and patients in Canada have access to better information, that they can make well-informed decisions for their health and make sure everybody has a good understanding of the actual risks associated with the products.
We look forward to working with the government to help ensure the successful implementation of this important legislation, and as further regulatory amendments are considered, we strongly encourage officials to engage early and consistently with all impacted stakeholders.
Thank you for your time, and I look forward to your questions.
The Chair: Thank you very much, Dr. Power. We will now move to questions.
I remind senators that you will have four minutes for your questions, and that includes the answer. Witnesses, please try to keep your answers succinct. You can submit additional answers to us in writing after our meeting if you wish. Colleagues, please indicate if your question is directed to one or both witnesses, and if it is directed to both, indicate who should go first.
We have a long list of questions, but I will kick off with the first one.
This is for both of you. Vanessa’s Law was passed if 2014. It has been almost 10 years. Can you comment on how consumer behaviour with regard to NHPs has shifted in that time?
Mr. Skelton: Over that time, through some macro forces that have happened, such as the pandemic, more Canadians are looking to take control of their health care and are looking to make some decisions and utilize products they see as a best fit for them. Ultimately, it’s a choice that we encourage, and more Canadians are looking to the category as a tool for them to use in the way that they manage their health care.
Mr. Power: I would agree that the number of people using natural health products has likely increased in the past decade. Some of the changes that have been made with the Natural Health Products Directorate, for example, have provided some better information at the consumer level. We know that, in pharmacies, it’s a frequent question that we get about how to use natural health products. There is a lot of discrepant information out there; there is a lot of information on the internet that may go well beyond what is licensed through the Natural Health Products Directorate.
So it’s very important that we clarify and provide as much information to consumers as possible.
The Chair: Thank you. Dr. Power, you’re saying that this regulation amendment is just in time, and for you, Mr. Skelton, it’s too soon.
Mr. Skelton: Yes.
To clarify, the powers conferred under Vanessa’s Law would not address the questions that I think are valid that Dr. Power has raised. Education and enforcement are not necessarily improved under the inclusion of NHPs in Vanessa’s Law, and I think that’s why study and debate have been critically missed in this process.
The Chair: Thank you very much. The next question comes from the deputy chair of this committee.
Senator Bovey: I want to thank you both. My question is sort of a comment as well. I’ve got two.
First, we live in an age of disinformation, it seems, and we’re having to correct disinformation everywhere, and we’re not really sure how. Dr. Power, do you think this regulation would help expel the disinformation on some of these products?
I’m concerned as I watch friends, and especially the next generation down, using things because they see it on TV. I’m concerned about the amount of advertising that’s on TV, and I don’t know what to believe. I might have some intelligence; I certainly don’t have intelligence in that direction, but I wonder if you could just talk about the disinformation a little bit.
Mr. Skelton, do you think this should not be in this bill? In other words, is this bill too much of an omnibus bill, and these issues should be dealt with elsewhere? That’s where I’m coming from.
Dr. Power first.
Mr. Skelton: I can address the first question. I think that education programming and efforts by Health Canada and by associations are critical. We don’t see the connection between imparting the powers within Vanessa’s Law to improving that, but we do see a need for enhanced and expanded education programs. That’s something we, as an association, have committed to. It’s something we believe strongly in — the safety of Canadians is paramount — but the use of the powers within Vanessa’s Law would not correct that.
Could you repeat the second question?
Senator Bovey: I’m wondering about it as an omnibus bill, but I would like to hear Dr. Power, too, on the disinformation, if I may.
Mr. Power: I agree that Vanessa’s Law would not correct the information that is available out there. We live in a global society where a lot of the information that people get about their health care, whether NHPs or prescription products, comes from the internet. Anyone who is in health care has been approached by a patient who says they have done a Google search about something. Everybody is well aware of that.
The benefit of having the adverse reaction reporting required is that it will help to increase the credible evidence that we have available in Canada, similar to what we have for prescription drugs. Frequently, health care professionals will receive summaries of evidence from Health Canada that clarify questions around rare side effects. We can’t find all of the rare side effects that occur with the medication until they’re widely used, and we have a reporting system that feeds back into the systems that we have.
It’s critical that we have a comparable system for all medications or products that people are using to affect their health.
Mr. Skelton: I just have a quick response. I think the increased powers in Vanessa’s Law really only change mandatory reporting within hospital settings. So there is mandatory reporting.
Senator Seidman: Thank you both for your presentations. I should start off by saying that in 2014, I sat at the table as a member of the Social Affairs Committee but also as the sponsor of Vanessa’s Law in the Senate, so I come with a particular mindset on this. I do recall the conversation about including natural health products in the legislation, and it was quite a discussion, shall we say, with a lot of opinions around the table. In the end, the government decided not to include them but to do further study around it.
Finally, we have arrived. I think that post-market surveillance and monitoring for safety around natural health products are urgent. The very term “natural health products” already conveys to an audience a certain perception that perhaps one has to be careful of.
I’m sure you’re familiar with the audit conducted by the Commissioner of the Environment, which Dr. Power referred to. The report was out in 2021 on natural health products, and auditors “. . . found that 88% of these products were advertised with misleading product information,” including:
- health claims not authorized by Health Canada because they might not have been proven, such as claims to relieve fatigue, enhance endurance, or burn fat
- an erroneous statement that the product was recommended for children of ages 3 and older when it was authorized only for adolescents and adults . . .
as well as “the wrong dosage of medicinal ingredients.”
The report also found that although “natural health product‑licence holders are required to tell the department which licensed facilities manufactured the products before selling them,” fewer than 5% of active licence holders did so. This is from the commissioner’s report. Non-compliance with product manufacturing and product quality was at a very high level in the industry.
When Health Canada reviewed 35 companies testing results, they found problems at all sites, including the use of expired raw materials, unacceptable amounts of contaminants and product tests that did not confirm the product expiry date.
All this leads me to ask you, Mr. Skelton, how we cannot have post-market surveillance of natural health products.
Mr. Skelton: Senator, thank you for the question. In reference to the report, I think what’s critical is the framing of that report. That was both licensed and unlicensed, regulated and unregulated. The Canadian Health Food Association would agree that there are needed improvements in how that is managed. What I would express, though, is that Vanessa’s Law would not address that. That is an enforcement issue. Unfortunately, what is contained within this budget would not address that. Given the degree of challenges that were identified in the report, further study on how best to address that would be prudent. That’s not what happened here.
To your point, back in 2014 there was extensive debate. That debate has not occurred now. After nearly 10 years since that decision was made, no further communication has come from the department on what has been seen and how best to address that.
To clarify, the association is not against the review of what is best. What we are concerned about is the lack of that review and engagement for proper discussion and debate.
Senator Osler: Thank you to the witnesses for appearing here today. I’ll note that Health Canada has indicated that stakeholder engagement and consultation have been ongoing since 2016. And I have a question for each of you, and the first is for Mr. Skelton.
In the information note that you sent to the committee, you flagged that:
Discussions still need to occur on the broader self-care framework and whether the extreme powers conferred by Vanessa’s Law for prescription drugs are appropriate for low-risk products.
My question for you, Mr. Skelton, is this: Could you kindly elaborate on what measures and requirements in Vanessa’s Law you believe would be inappropriate for the regulation of natural health products and why?
And for Dr. Power, could you kindly elaborate on what measures and requirements are not in Vanessa’s Law that you believe would be appropriate for the regulation of natural health products?
Mr. Skelton: Thank you, senator, for the question. The position of the association is less about what is included or excluded and very much the lack of proper study and debate.
As I referenced in my opening statement, we don’t know what we don’t know. Without the proper investigation and consideration with all those stakeholders, I’ll highlight that with Vanessa’s Law, the biggest change would be around the mandatory requirement of adverse reaction reporting for hospitals. That industry has also not been brought into that discussion. It’s hard for us to convey specifics when we haven’t been engaged in the discussion of why it’s required at all.
Mr. Power: Thank you for the question. Mr. Skelton is correct. The Vanessa’s Law requirement is within health care institutions, so it would not apply necessarily to the larger consumer society outside of an institution setting. I think that this is something that is needed, perhaps not in legislation, but perhaps through an education program that highlights the need for people to report adverse effects that they do have. Consumers do have the ability to report adverse events for prescription medications and vaccines currently, and people need to be aware that a similar submission can be made when they’re using natural health products. I think that is where we will get the critical mass of information that we really need to better inform everyone in the health care system, whether they’re patients or health care professionals.
Senator Kutcher: Thank you, witnesses, for being here. My questions will be for Mr. Skelton, but I want to put them into a framework. I just want to make sure we cut through the fog, like a good Maritimer.
This legislation is around improving the safety of natural health products, not about education about them. Those are two separate issues.
This is very timely. CH Alliance and JAMA just published a study on melatonin. Poison control calls in the United States for gummy bears for melatonin went up 530% in the last decade. That is a huge and very troubling increase. They studied 25 different preparations of melatonin, and they found another disconcerting problem, that the dose on the label was not the dose in the product. In fact, 1 of the 25 studied had absolutely no melatonin in it. Most of them had much more, ergo the poison, and only three had a dose within 10% either way, so 20% of what the label said. So we have a huge problem. I’m not going to go into all the research, which is something that I actually know something about.
The question here is about improving the safety of natural products. That’s what the legislation is about. Mr. Skelton, do we understand that your industry is against helping ensure that natural health products are safe and effective and that the labelling is correct? And do we understand that the interests of your industry should trump the health of Canadians?
Mr. Skelton: Thank you, senator, for the question. The priority of the association is the safety, efficacy and quality of products that are accessible to Canadians. Canada has a world‑leading regulatory regime to address that. All products that are brought to market in Canada have to be licensed by Health Canada, and Health Canada has the ability to review all risk information, contraindications and adverse reactions that are submitted. They have the ability to and often do ask for further scientific data to prove if they don’t feel they have significant data to validate that safety. That exists in today’s regime.
Health Canada also has extensive powers to seize product, stop the sale of product, remove licences from facilities and product licences, which effectively removes that product from being accessible to Canadians. We firmly support that intent. Quite possibly, there could be further steps that need to be taken, but it is so widespread and important that doing so without extensive debate and study, we feel, is inappropriate. Yes, we support it, and, yes, we believe it is important.
Senator Kutcher: What I’ve heard you say is that you support safe, effective and proper labelling, so I don’t see why you don’t have any trouble with the legislation, frankly.
Mr. Skelton: I believe our concern is that the powers that are being discussed have not been reviewed and debated. The potential for overreach and unnecessary regulation is significant, and that deserves debate.
Senator Kutcher: Profits should not trump Canadians’ health.
Senator Moodie: With the comments that have already been made, we see that Canadians are seeking more control of their health care and looking to natural health products to do so. We are also hearing of an environment in which, as outlined by the auditor’s report, there is a high level of non-compliance — of dosing and other product misinformation.
Speaking to the need, potentially, for enforced post-market surveillance, I would like to ask Dr. Power two questions. Does this legislation go far enough to provide a regulatory framework for natural health products?
The second question is this: Why not put it in legislation? Should we be considering where Vanessa’s Law for natural health products now applies? Is it just hospital settings?
Mr. Power: Thank you for the question. In terms of the setting, as I mentioned earlier, the more reports that come in, the better information we have. I believe Vanessa’s Law was focused on the hospital setting initially as a way to start the process and to require it. If we start expanding it into community-based settings, then we do need to have discussions around the time required for the reporting and also who is going to be reporting and what the implications are if they don’t report. So there are a lot of implications with expanding it beyond the institutional setting.
I’m sorry, can you repeat the first part?
Senator Moodie: Does the legislation go far enough in providing a regulatory framework for natural health products?
Mr. Power: There is separate legislation for natural health products that governs labelling, production, et cetera. I don’t know that Vanessa’s Law is necessarily the right vehicle to do that. It would be better to address it through the legislation that is specific to those products.
Senator Moodie: Mr. Skelton, the question I would ask you is this: Are there some risks to consumers presently under the current regulatory regime that you could identify?
Mr. Skelton: No, I think we have a very strong regulatory regime today. Health Canada has extensive powers and tools to limit products that make it to market. The largest concern that has been raised — and that we would support — is along the enforcement of those regulations. We have good tools. We need to use them. Imparting additional tools without consultation through an omnibus bill is not appropriate.
I would add on to the previous comment that there is mandatory reporting on adverse effects of natural health products for industry. That has been in place for more than 70 years and continues to be in place. The mandatory aspect of reporting does exist outside the hospital setting; it is mandatory for industry.
Senator Moodie: Do you think that legislation requiring people’s attention will change that?
Mr. Skelton: I don’t know that enforcement would be impacted by reporting, no. I think the tools exist and they just need to be applied.
The Chair: Thank you.
[Translation]
Senator Mégie: I’m going to the core of this. I used to be a family physician. I had patients who would come in with a bag of products and would rather take those products and say, “This is natural, doctor, your products are making me sicker.” There are actually different types of names — health foods, natural health products... What is the difference between them in terms of production and their therapeutic role? It’s about the health of the population. The population needs to be aware of what they are taking. When you say “natural food,” people say, “Oh, it’s natural, doctor, I’m taking it.” A natural health product? “Oh, that’s also natural, I’m taking it.” What’s natural about that and what’s the difference between the two?
Even when we study the topic in the bill, why does one have precedence over the other? I’m asking you both. Mr. Power, as a pharmacist, I’m sure you still have the same requests in your pharmacy and Mr. Skelton, if you have any idea what the difference is, I’d love to know, please.
Mr. Power: Thank you for the question. I will answer in English.
[English]
From a therapeutic point of view, there is very little difference between a prescription drug and a natural health product. They are both a product you take into your body to exert a specific effect or to prevent something from happening, whether it’s a calcium supplement, a vitamin product, something like echinacea, which many people use for cold prevention, or something like an ACE inhibitor to help regulate heart function or hypertension. I think there has been a perception by the public — exactly as you have outlined — that natural health products are safer because they have the word “natural” in them. They are promoted as coming from a plant, quite often. When I deal with somebody in a similar situation where they are trying to move away from prescription drugs toward natural health products, I often point out that a number of drugs that are prescribed are derivatives of plants that can be quite toxic.
We need to ensure that Canadians have a good understanding of the scope of the products, the risk of them and the best way to use them so we have tools for the consumer and the health care professional to have those discussions.
Mr. Skelton: I would agree with what Dr. Power has said. The one point I would highlight, though, is that the risk profile between those two categories is different. That was part of the extensive debate in 2004 with the 53 recommendations made by the standing committee. It was again highlighted in 2014, when natural health products were determined to be excluded. It is the reason we have a natural health product regulation that is different from drugs.
I agree with what Dr. Power is referring to, which is around education. I think much more work needs to be done on that front, and I think we as an association play a role in that in working in conjunction with Health Canada. The things we are here to discuss and debate today around Vanessa’s Law would not impact that. That is a clear point of difference I would like to highlight.
The Chair: Thank you very much.
[Translation]
Senator Petitclerc: I will ask my question in French. My question is mainly for you, Mr. Skelton. I must admit that I have trouble understanding the negative aspect of Division 27 for the natural health products sector. Let me explain. On the one hand, you say that the rigour is there and that you have regulations specific to your sector, and on the other hand, we hear it here and in the public, there is sometimes in that sector a certain.... People are not sure, they are afraid, they need more credibility. It seems to me that, on the contrary, this bill is positive for Canadians in terms of information and feeling safe, but it’s also positive for the sector in terms of credibility. That’s my question. If we have some time, you talked a lot about having more debates and more studies. I’d like to get some specifics.
What do you want as a debate or need as a study? You could answer me in two short parts.
[English]
Mr. Skelton: I’ll try to answer the first part.
I think the concern is that we have rules that are in place today — and to your point that there are some questions and discussions in the public about what is best — nothing that is discussed in this part of the bill would address that. Getting mandatory reporting into hospitals and creating a bigger tool to use on enforcement would not address that. I think what the Auditor General of Canada’s report did highlight is the lack of enforcement on the tools that were already in place.
We fully support that, and, again, I want to highlight that the Canadian Health Food Association’s mandate is to ensure that Canadians have access to safe, effective and quality products. That would be the answer to the first question.
Senator Petitclerc: I don’t mean to cut you off, but I only have a few minutes.
I understand that it’s not about that; I get that, but I do not see the downside. That’s the part I do not see. I understand it’s not doing everything that maybe the population would like to see in this area, but this, I fail to understand the downside of it.
Mr. Skelton: I think the concern is that we don’t know what the potential downside is, because we haven’t had the debate and the study in a meaningful way.
I’ll say on record that I think the association would be open to a stand-alone bill that discusses and reviews that; I think that would be appropriate. But the procedural way in which this was done is inappropriate, and that leaves a lot of questions unanswered.
Senator Petitclerc: Thank you.
Senator Burey: Thank you so much for coming here today.
I would like to reiterate the importance of this legislation. I heard words about “labelling,” “enforcement” and “not quite the right law to do this,” but also about the importance of transparency and accountability. Paramount, of course, is the safety of Canadians.
Now, Dr. Power, you said something that caught my attention: Low risk doesn’t equal no risk. As a physician myself, I understand that serious interactions occur with so-called natural health products and other prescribed products. Can you elaborate on this fact?
And, Mr. Skelton, could you give me an understanding of what you see as your industry’s role in making sure these products do not cause serious interactions? You have definitely alluded to the fact that it is an increasing industry and that far more people are using these products. So on your side, could you elaborate your role?
And for Dr. Power, could you tell us more about the seriousness of these interactions?
Mr. Power: Sure. Thank you for the question.
I can give you a few quick examples. There is a product called ginseng, which is widely used for energy, and it’s in products to prevent colds and boost the immune system. There have been cases where it has been reported that people taking it have had an increase in their blood pressure. It’s a good example of something that is widely used but can have an unintended consequence. If we don’t have a system to report this sort of thing, it can result in ongoing harm.
There is a drug called Ginkgo biloba that is used for memory enhancement, and many older people will take it. There have been reports of bleeding associated with it. Many older people are also on anticoagulants, so it can compound the risk. That’s a fairly serious side effect, in my opinion.
There are a number of products where there can be interactions. Echinacea is widely used to help prevent colds, and there is some thought that it may affect the metabolism of drugs and that it will speed up the removal from the body of drugs for seizures and for birth control. There needs to be more investigation of those to establish whether or not they are clinically relevant, but those are concerns that I would raise as being more than just minor.
Mr. Skelton: Thank you, senator, for the question.
I think we would align with everything Dr. Power said. I think there is a requirement to ensure we are identifying risks and contraindications where they are appropriate.
Health Canada has the ability today, as they approve any licensed product or facility, to do so, and it has the ability to ask for further research and study where they feel there is an ongoing health concern. That has been done with updates in recent memory. In 2017, there was an update related to green tea extract. In 2023, there was an update to the requirements around biotin.
The tools exist to address the concerns that Dr. Power has raised. Again, I would emphasize that we don’t see how the inclusion of Vanessa’s Law would alleviate or change any of that.
Senator Burey: Dr. Power, do you think the two —
The Chair: Five seconds.
Senator Burey: Sorry.
Mr. Power: Yes, the current legislation does facilitate that.
The Chair: Thank you.
Senator McPhedran: Thank you to the witnesses, who came in person today.
I am very informed by this discussion, but at this point, I want to check in with both of our witnesses to make sure that I’m understanding your key points today.
I don’t think there is any difference in this room on the purpose of Vanessa’s Law and the need for Vanessa’s Law. What I think I’m hearing — and this is what I want to check with you — is whether what we have before us is actually fit for purpose in relation to natural health products. I think I heard from each of you, in your own language, a message that this is not the way to reach that purpose in terms of natural health products. Please correct me if I didn’t understand that.
Secondly, if that is true, what is the scenario that is actually going to place safety first in relation to natural health products? If it’s not this, what is it?
Mr. Skelton: Thank you for the question, senator.
I agree that I think some of the concerns that were raised around this committee today are valid and require further conversation, but I would agree that the purpose of Vanessa’s Law does not connect to the concerns that I have heard today.
I would emphasize, again, that the tools exist within Health Canada, and the Auditor General’s report highlighted that the tools exist but are not being utilized and enforced. So we would like to work closely with Health Canada to elaborate and expand the education tools that we have, both to the public and to the sector, as well as to evaluate in a deeper way how to find some improvements within compliance and within enforcement.
This is an enforcement question, and we are not looking for a bigger tool to do that. They exist today.
Mr. Power: I would say that we do support inclusion of natural health products, or NHPs, within Vanessa’s Law.
The number of people who would be started on a natural health product in a hospital is very small, but the number of people who would come into the hospital on a natural health product would be very large. We heard from Mr. Skelton that over 70% of Canadians admit to using it. We would expect that there would be people coming into hospital on a natural health product.
It could be that they were admitted because of an adverse effect that may be, in part, due to the natural health product, so I think it’s critical that we include it to capture those situations.
Senator McPhedran: Thank you.
Just to make sure I’m clear, what I’m hearing from you, Mr. Skelton, is that there is no new legislation needed to address this concern.
And what I’m hearing from you, Dr. Power, is that, indeed, this is a legislative change that is desirable.
Mr. Skelton: There has been no information that would lead us to that conclusion that it’s required, no.
The Chair: Dr. Power I see you nodding your head, sadly.
Mr. Power: Yes, your understanding of our position is correct. We do support the inclusion of NHPs within Vanessa’s Law.
Senator Bernard: Thank you both for your testimony and your responses.
I want to talk a bit about the diversity of the population we are talking about as consumers of these products. The Statement and Impacts Report on Gender, Diversity, and Quality of Life accompanying Budget 2023 states that the measure proposed in Division 27 may have more of an impact on certain people who use NHPs more frequently, “ . . . including women, Indigenous people, 2SLGBTQI+ people, and Black and racialized people.”
So I have two questions for both of you: What populations may use NHPs more often than the average Canadian and why? Second, how might the measures proposed in Division 27 impact these diverse populations?
Mr. Skelton: I can take the first question. We wouldn’t have specific data to support the diversity question. I think it’s an excellent question. We are undergoing some market studies to evaluate that. What I would emphasize and what is known is there are a lot of traditional products that are captured under natural health products, and I think protecting the right of choice to those products of diverse communities is critical. I don’t know that Vanessa’s Law is a negative or a positive to that. Again, we won’t know because the process that we believe should have been undertaken wasn’t. So diversity is part of the mandate around traditional products, which are captured by NHPs, but I wouldn’t know the impact of Vanessa’s Law because there has been no review or study of that.
Senator Bernard: There is no research that has been done — is that what you’re saying?
Mr. Power: Among the diverse populations that I would say are more likely to use natural health products, we know that women often do use them more often, but women are also the prime purchaser of health care products in many households to begin with. Then, definitely Indigenous people, and also traditional Chinese medicine is widely used within some Asian populations.
From my understanding of Vanessa’s Law, there is nothing that would restrict their access to it by including natural health products in the requirement for reporting. If anything, it would help to capture data that would better inform both practitioners using those products and consumers so that they would be able to make better-informed decisions when we have better information.
Senator Bernard: Okay.
The Chair: Thank you. We will go to the second round, but we only have five minutes for the second round. I would like to ask Senator Seidman to go to her unanswered question. Then we can ask questions in the five minutes, and the witnesses can get back to us in writing.
Senator Seidman: I would like to get at this issue about “we don’t need it because it’s not going to do anything that isn’t already available.” In fact, this would provide the Minister of Health the ability, for example, to order recalls for unsafe products or require companies to revise labels, which would certainly improve Health Canada’s ability to respond to serious health and safety risks.
The whole purpose of Vanessa’s Law was to ensure exactly this post-market surveillance around the safety risks of products already on the market. I would like you to respond to the question that has been put by many of my colleagues sitting around the table and, most recently, very directly by Senator Petitclerc, saying, “What problem does this create?” This does have serious monitoring for safety risks.
Mr. Skelton: Thank you, senator, for the question. My comment previously was that there are tools in place that already allow for those things to happen. Stop sales, seizure — at any point during the chain of custody of products, Health Canada has the right to do that. Even on labelling compliance, Health Canada already has the tools in its regulations to force changes on products, and they have done that extensively.
My succinct comment would be we don’t know why we need it. The investigation has not happened; the study hasn’t happened; the debate hasn’t happened. That’s our concern and, on a more macro level, the way that Health Canada is approaching these types of discussions or lack thereof.
Mr. Power: I would say that we need to include it because we need the information to better inform people about the risks that are out there. We don’t know a lot about that.
Senator Seidman: Because it hasn’t been included, right? That’s the whole point. Because it wasn’t included in the 2014 proposal, we don’t know the risks very well because we don’t have the adverse reaction reporting.
Mr. Power: That is correct, yes.
Senator Seidman: This would ensure that we have that information ultimately.
Mr. Power: It would ensure at least within the context of an institution, yes.
Senator Seidman: Thank you.
The Chair: I will invite Senators Osler, Moodie and Mégie to ask their questions and request Dr. Power and Mr. Skelton to respond in writing.
Senator Osler: My question is for Mr. Skelton. Thank you again for your testimony today as President and CEO of the Canadian Health Food Association. I was heartened to hear earlier this morning your testimony where you said — and I will try to quote you — your priority is the efficacy and safety of natural health products.
Yet, there are currently high levels of market non-compliance, as Senator Seidman had pointed out, quoting the April 2021 report of the Commissioner of the Environment and Sustainable Development, where 88% of products reviewed were advertised with misleading information, including health claims that were unproven.
So your statement does not align with that data. I would ask you to submit to this committee in writing more elaboration from you in terms of your statement and the data.
Senator Moodie: My question to both gentlemen is whether the current amendments to Vanessa’s Law will prevent the right of choice for consumers.
[Translation]
Senator Mégie: I want to go back to my point. I got the whole explanation from Mr. Power regarding natural health products, but I didn’t really get any examples — just one or two — of natural foods. Then, as my colleague Senator Seidman said, when you have done all the studies on safety, how is that information going to be conveyed to the public, in terms of labelling and so on?
[English]
The Chair: I regret that we can’t get your answers at this point, because it does make a difference if there is a fluid Q & A, but our time is restricted.
Thank you so much to both Mr. Skelton and Dr. Power for sharing your perspectives with us. This will inform our observations accordingly.
We now move to our second panel, which is focused on Division 28, which deals with amendments to the Food and Drugs Act related to cosmetics testing on animals.
For our second panel, we welcome by video conference Darren Praznik, President and Chief Executive Officer of the Cosmetics Alliance Canada. Thank you very much for being with us today. I now invite you to provide opening remarks. I remind you that you have five minutes allocated for statements, followed by questions from our members and I wish to inform my colleagues that Mr. Praznik can only be with us until 1:15 p.m.
Mr. Praznik, the floor is yours.
Darren Praznik, President and Chief Executive Officer, Cosmetics Alliance Canada: Thank you very much, Madam Chair. Best wishes and greetings to all members of the committee. We very much appreciate this opportunity to comment on these amendments as proposed in the budget bill that you are now considering.
I’m here in a very unique capacity today because not only am I representing industry through Cosmetics Alliance Canada, but the history of this legislation, which has been ongoing from probably 2014 to 2015, has led to a lot of work for us as stakeholders. We’ve distributed to you today a series of correspondence, the last being a letter to you dated May 8, 2023, and it’s a letter that we have jointly signed representing the Animal Alliance of Canada, Cosmetics Alliance Canada on behalf of industry, Cruelty Free International, Humane Society International and both Cruelty Free and Humane Society’s retail partners. We as industry represent a number of retailers coming to the table.
It seems quite a few years ago, we found our way through a variety of circumstances to work together on working through the details of this common objective. We were able to succeed through a lot of hard work on the part of our respective organizations, and we came to an approach that we could all agree on to adopting the ban in Canada based on the principles of the European Union. Of course, that would be within the framework of the Canadian regulatory structure because Europe regulates somewhat differently than Canada, so the principles had to fit within our regulatory structure.
We also agreed as stakeholders that it was absolutely fundamental that these amendments be drafted with Health Canada, by Health Canada, working with us to ensure that they fit within the complexity of the Food and Drugs Act and the regulatory regime. On top of this, during this process, as Health Canada was undergoing — is still undergoing — a major reform of how cosmetics, natural health products and non-prescription drugs are being regulated, called the self-care framework, we wanted to make sure these amendments fit within that reform.
We’re pleased to tell you that several years ago Health Canada officials met with us and over a period of years — probably a little less than a year — were able to develop a principles paper that they took to their minister that we all concurred with.
We have been pushing, as you can see from our correspondence jointly, for a number of years to have the government include this legislation. We thought given it’s a rather small number of amendments that it would be best to do through a regulatory or budget bill. So we suggested that to them.
The COVID, of course, has been a delay for I think everything happening, but we were pleased this year that it was included in the budget bill. I can tell you we also had a briefing, all of us as stakeholders, with staff on the details, including a briefing with the legal staff who drafted it, and we were all in concurrence that these amendments, as drafted, work and represent the principles we had advanced. We also had the opportunity to have a discussion with the minister’s office and we have conveyed a similar letter to them of our support.
We appreciate that this issue came to the public realm through a private member’s bill, I think, back in 2015, and it has worked its way through the process, and I think a lot of the details that needed to be worked out have been worked out with Health Canada officials, so we would very much commend this bill in your consideration for approval as is.
Again, from the letter we provided, we certainly have the support of all of the stakeholders representing animal advocacy organizations and industry and the input of the regulator.
The Chair: Thank you, Mr. Praznik. Some of us here around the table will remember our colleague Senator Stewart Olsen and her advocacy on this particular issue. You made it come alive for us again.
We will go to questions. Colleagues, you will have four minutes per question and answer. We will start with the deputy chair of the committee, Senator Bovey.
Senator Bovey: I’d like to thank you, sir, for being with us today. I want to thank you and the stakeholders and all those who have been working with diligence on this over the years. I was part of those earlier discussions and I know well that these important issues take a lot of time and a lot of partners to make sure they work. I thank you for your diligence.
I hear you agree with this in this particular bill.
I have one sort of a side question, if I may. I’m being asked this by people, maybe not now but earlier, a few years ago, when this was at the fore: Instead of testing on animals, can you tell us what other methods of testing will protect consumers?
Mr. Praznik: That was a very good question. As I have learned a great deal on this, Canada’s centre for this is located at the University of Windsor, and we have gotten to work very closely with its director. Myself and colleagues from Humane Society International and Cruelty Free also sit on a board of an international collaboration of advancing animal-testing alternatives.
What you learn is that it’s not that you’re converting one test to another. Non-animal alternatives involve a host of different points and ways of rethinking. It’s a very different paradigm of testing.
I think the challenge Canada is going to have now that this bill is important, but we’ve also recognized the need to reduce animal testing through the amendments and the modernization of the Canadian Environmental Protection Act as a goal, is that we’re going to have to develop the training of our regulators, our scientists, our formulators in those new methods. I would really commend to the Senate to have a look at that Centre for Alternatives to Animal Methods at the University of Windsor. It is the only centre we have really focused on that, and every country that has adopted a ban has had a centre.
I can’t get into all the details, but they’re a varied group that can get into the kind of model and the paradigm you need to be able to do non-animal testing alternatives.
Senator Bovey: I would like to thank you for that. I’m hearing you say that as this bill is looking at the safety for Canadians, that with the work that’s being done that you’re aware of, we can say that, yes, our consumers are safe.
Mr. Praznik: Yes. And the irony, senator, of this, is because of the work that was done out of Europe and the investment out of the European Union and by industry over the last 20 years, effectively, we don’t do animal testing on cosmetics here in Canada today. But it’s very important Canada symbolically join that world movement.
The real challenge, moving out of our sector into other sectors and environmental testing, will be to not only advance animal testing alternatives but, just as importantly, have them accepted by regulators. That’s going to require regulators, formulators and scientists to be trained on those new methods. It’s a very different paradigm.
Not only does it work but it has the potential, we believe from what we’ve seen, to give us even more accurate information on how things perform with the human body. Again, it’s a whole paradigm, and that’s going to be the next challenge.
Senator Bovey: Thank you so much.
Senator Seidman: Mr. Praznik, thank you very much for reviving our memories of 2017, when, I believe, you appeared in front of this committee.
Mr. Praznik: Yes.
Senator Seidman: Yes, indeed. You talked a bit about the concerns and the revamping of the industry’s approach to this type of legislation. What I’d like to know from you — you did have concerns about the piece of legislation back in 2017, which you expressed to this committee, and I’d like to know if you could remind us what your concerns were then and whether they have been rectified with this piece of legislation.
Mr. Praznik: Thank you. I can share with you, having been a provincial legislator in Manitoba many decades ago and probably long forgotten, and having been a minister who had complex legislation, private members’ bills are great for advancing a principle. Sometimes they work very well, but often, while they’re drafted by legal counsel in the Senate, there isn’t the familiarity with complex legislation like the Food and Drugs Act. We had major reform going on at the time. Our concerns really were with the details and the unintended consequences.
It may sound silly how, but at the time, the way the original bill was drafted, it would have meant it would have been illegal to test a dog shampoo on a dog to see if it worked. It was just because of the definitions.
Our concern wasn’t with the principle and the objective. It was the workability. I think in sitting down with the stakeholder groups after that bill got talked out in the House of Commons — in fact, before that — we were able to work through the issues, and what we felt was most important was that the regulators who have to make this work had to be at the table working through those details. This bill today does it. We think it works well. All of those unintended consequences have been addressed, and we’re all marching together to the same objective.
Senator Seidman: Thank you.
Senator Osler: As a fellow Manitoban, I want to thank Mr. Praznik for his service to our province. Thank you for your testimony today.
This legislation bans the testing of cosmetics on animals in Canada, but would you know what happens for products from other countries that don’t have the ban that are sold online? Is e‑commerce adequately addressed in the legislation?
Mr. Praznik: Senator, it’s always good to see a fellow Manitoban, and I always try to promote my province.
You’ve asked two very good questions. First of all, the law applies to any products sold in Canada. So if you’re making it somewhere else and bringing it in, you have to abide by our law. For the vast majority of countries in the world, our industry is by and large out of animal testing. There is one exception, and that is China. We are a big exporter of cosmetic products to China. Canada is a major importer and a major exporter. We have some very large companies that produce a lot of products for international companies. China still required animal testing on imported cosmetics until a few years ago. After much lobbying, they agreed to provide an exemption, but only if you had a government-issued GMP certificate. So we worked with Health Canada officials for over a year to develop a means of providing that certificate, but, regrettably, due to the siloed nature of government, Health Canada has yet to agree to do it.
We have a temporary fix from Ontario’s and Quebec’s ministries of industry, so products made here don’t have to have animal testing. It’s all unnecessary because there is no need for it. But we are still waiting for someone at the senior levels of Health Canada to say we just need to do it. It was the old excuse that “it’s not our mandate.” But you are inspecting these facilities now that often have a drug establishment licence or they have a natural products site licence or they’re meeting GMP. We worked out all the details with the officials but we were told “not our mandate.” If it’s not your mandate, whose mandate? That’s the one piece that there is still work to do on. I don’t know if I’ve answered all of your questions, senator.
Senator Osler: Thank you.
The Chair: I have a question about the exceptions to the proposed prohibition, which apply to cosmetic products sold in Canada before coming into force, which is six months after Royal Assent. Can you tell us how many cosmetic products that use data from animal testing are currently sold in Canada and would be grandfathered under the proposed prohibition?
Mr. Praznik: I’m going to now share some of the secrets of our industry.
The Chair: I love secrets.
Mr. Praznik: Although we promote all our products being new and innovative, et cetera, the truth is that the vast majority of ingredients used in our products are ingredients that have been around a long time. They are commercial substances purchased from ingredient suppliers. They’re used in natural health products, in foods, in non-prescription drugs and other products. They’re by and large commodity chemicals.
Many of them, over the years, to meet government regulatory requirements, did have animal testing done on them at some time or another. What do you do with that? Those products have been long used in the marketplace. These bans everywhere in the world really start from the day they come into force for how they apply to new substances and new testing requirements on them. The European ban was the same way because, quite frankly, if you’ve used a product that 30 years ago required an animal test from Health Canada, that ingredient is still being used today.
The products themselves have not had animal testing on them like the eye irritation on the bunny. That hasn’t been used for 20‑plus years. It’s really ingredient testing for health and the environment. Most of these ingredients have been around for decades and are commonly used. How do you say, “Did that have an animal test 30 years ago?” That’s why these things are forward-looking as opposed to backward-looking.
The Chair: So in other words, despite this amendment, we will not be completely pure.
Mr. Praznik: Purity is in the eye of the beholder. That’s a good question and a good statement, but if you have an ingredient that was approved for use 30 years ago and it has been safely used for those 30 years, you can say that human use over those decades has demonstrated the safety. Initially, to come on the market, it may have required that test, but where do you draw the line? It’s a tough one, isn’t it? As a legislator, it’s really a tough one.
The Chair: Thank you for sharing that with us.
[Translation]
Senator Mégie: Thank you for joining us today.
Is the GMP certificate intended to endorse the safety of a product or to confirm the fact that there was no animal testing?
If is the latter, when the certificate is given to China, are they given a passport under the table, so that they can come to the market without us knowing whether the products were tested on animals or not?
[English]
Mr. Praznik: This is a very good question because it’s a fairly complex area. What China has traditionally done is if you import what’s called an ordinary cosmetic into China — not a sunscreen, as that would be considered a natural health product or drug — up to a few years ago, they required importers in China to do a series of animal tests to demonstrate the safety of the product for the Chinese consumer. We suspect there was a bit of a trade issue there, but whatever.
We lobbied as an industry very hard. We said, “None of these tests make sense. They’re not needed for anything. This is really old technology. You have to do away with it. Would you please eliminate that?” China agreed to eliminate it, but they required as a replacement for the exception to eliminate, to not have that requirement, that you have to produce from your government a certificate for those products that says this is compliant with good manufacturing practices for cosmetics to demonstrate that it’s safe.
No state government in the world issues those certificates for cosmetics. They inspect facilities, but they just haven’t issued them. As a trade association, we put together the material and we issue them, but we’re not government. So we went to Health Canada and said, “Listen, we’ll work with you to put this together.” All of the manufacturing facilities in Canada this would apply to — a dozen or so — almost all of them or, in fact, all of them have a Health Canada drug establishment licence because they’re making non-prescription drug products as well, or they have a natural health product site licence or they meet ISO standards for cosmetics GMPs. So we said, “If they document that to you, will you issue a Health Canada GMP certificate just for China so they don’t have to do animal testing?” We worked out all the details with officials, but at a senior level, they said, “Well, that’s really not our job; someone else should do it.” But there is nobody else to do it.
Thankfully, the Governments of Quebec and Ontario, which don’t even inspect those facilities, are issuing those certificates right now, which means our products can go into China without animal testing. But it’s a Band-Aid for what should be a Government of Canada solution.
[Translation]
Senator Mégie: Who follows up once the products are on the market, even for Canadian products? We are sure that these products have not been tested on animals and have not harmed them, but there should be a follow-up every five years. Does this exist? Are there inspectors dedicated to doing the follow-up?
[English]
Mr. Praznik: Yes. Health Canada has applied to our products two different inspector groups. They do cyclical inspection. There is a complaint-driven process — if you have complaints about health issues on a product that you report, they inspect. Every year, they pick a different area of product they inspect. They are pretty diligent.
The Auditor General looked at the cosmetics branch a few years ago, and of 55,000 cosmetic notifications every year, I think they found 50 that didn’t meet the ingredient standards. Those were all small importers, not big companies. So if you look at the compliance, it’s very high.
[Translation]
Senator Mégie: Thank you very much.
Senator Petitclerc: I will also ask my question in French.
This is a short question. My understanding of the bill is that once the ban goes into effect, the products that are already on the market will remain on the shelves until they are sold out? That seems reasonable. Do you think that’s a reasonable approach? Have you seen, in other countries where this kind of ban has been implemented, immediate action to remove products? Has that ever been seen?
[English]
Mr. Praznik: First of all, I would make the point that we do not do animal testing on products. There is no need for it, and we don’t. We use ingredients that have been approved and are allowed to be used. Some of those ingredients going back decades may have required animal testing to meet government standards. They’re all grandparented in, essentially.
This bill goes forward, so as of the date it comes into place, you will not be able to rely upon animal testing for any safety of those kinds of things going forward.
Quite frankly, it’s not going to really change anything in the market because we’ve pretty much gotten rid of it years ago, but it’s really important that Canada join the rest of the world.
The Chair: Mr. Praznik, we’ve talked a lot about China in your comments, and that is because China is a huge export market for us and a significant import hub for us as well.
Are there other non-EU jurisdictions that should be taken into consideration?
Mr. Praznik: Of the factories in Canada that produce cosmetics — one in particular, in fact, produces some 180 million lipsticks a year that get exported from Canada, so this is pretty big exports — the largest share goes into places like the United States because we supply regionally. There is a little bit into Europe, some into Asia, and China is the big one.
China is the only one of our export destinations that still has this unnecessary animal-testing requirement. They do have the exemption, but it’s a bit problematic, as we noted, and we’d like Health Canada to solve it for the interests of Canadian industry and exports.
The Chair: Thank you, colleagues.
Thank you very much, Mr. Praznik, for your time. We’ve gained a lot of wisdom from your testimony and we appreciate it a great deal.
Colleagues, this brings us to the end of our second panel. I would suggest we suspend very briefly to move in camera for a brief discussion on future business related to the study.
(The committee continued in camera.)