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An Open Letter

Questioning NHPD regulations

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An Open Letter

Please share this letter with Leona Aglukkaq, Minister of Health

(update, January 30, 2012:Dr. Colin Carrie has provided his response)

An open letter to Colin Carrie, Conservative Member of Parliament for Oshawa, and Leona Aglukkaq, Conservative Member of Parliament for Nunavut and Minister of Helath, from Deane Parkes, owner of Preferred Nutrition.

Dear Colin,

Thank you for taking the time to speak to me Thursday Oct 20th.

Please share this letter with Leona Aglukkaq, Minister of Health.

Although I have a business in the natural health product category my primary interest in natural health products began as a consumer in 1973. I had my first health food store business in 1975. I have since worked in distribution & manufacturing and started my own distribution business in 2002 selling natural health supplements to health food stores across Canada.

I have seen the difference natural health products sold in health food stores can make in a person’s life. These products , sold for years without serious side effects or deaths. Yet health food stores will be the most negatively affected if Health Canada does not stop immediately the direction NHPD is taking.

I am quite certain this letter represents the voice for most health food store staff, managers and owners while also representing health food store consumers across Canada. This letter is to help you realize your new NHPD department if allowed to run the current course will seriously jeopardize my sovereignty as a Canadian citizen while also causing harm to an industry that does nothing but help people.

1.       “The # 1 concern of Health Canada is the safety of Canadians”.

This is the mantra from MPs across Canada when asked about the current regulatory process for NHPs.

During our conversation you made reference to the fact that in the past year there was not one incident of death from a natural health product in the World! Not just Canada but around the entire globe.

So why has Health Canada created the NHPD department that now employs 200 people to regulate products that are safer than house plants or dog bites? How many people are looking into house plant safety? Why is Health Canada spending large sums of tax payer dollars to regulate an industry that has proven to be very safe?  Why would you not employ 200 people to look into the serious side effects of properly prescribed prescription drugs that are now the # 1 killer of Canadians? Why are the priorities of this department so mixed up?

2.       Standard of Evidence is the issue with natural health products.

Since safety is not the issue then what is?  Apparently from our discussion, evidence supporting NHP claims is the issue. Health Canada does not seem to be able to get their heads around how to support the claims we want to make for our products. Perhaps it is because you have no personal experience with NHPs?

First let me get this straight. Pharmaceutical drugs, the # 1 cause of death, get approved whereas natural health products with ZERO deaths are being subject to 200 people assessing the claims and rejections?  I can freely choose to buy proven deadly consumables like cigarettes, pharmaceutical  drugs, alcohol without question BUT if I  choose a natural health product that is completely safe, though the claim may be suspect, my access may be denied?  In other words, choosing deadly products is fine but choosing safe products is not?  If the concern is that natural products may deceive the public, let me assure you that the women who do 80% of health shopping for the family are not easily deceived. Like any product if it does not work they would not buy it again. Health food stores would not be growing over the decades if the products did not work.

3.       So if standard of evidence is the issue then why have you hired 200 people with no experience in natural health products assessing the claims?

This actually baffles me. In Canada we have some of the world’s leading natural health product experts. These people have dedicated their lives to studying natural medicine. Why are these people not in charge of deciding if a claim is allowable? Instead of hiring 200 tax eating staff on NHPD you could align with the following groups or key informed individuals to create appropriate guidelines for each natural health category. 

Homeopathy – School of Homeopathy

Traditional Chinese medicine – Chinese medicine school

Ayurvedic medicine – Ayurvedic doctors

Plant Medicine – We have many top herbalists and herbal colleges in Canada. This includes indigenous herbal medicine from around the world.

Plant medicine in combination has been a real challenge for your regulators. Sure they have not caused any deaths yet how can they give a NPN to a combination of herbs. How do they justify the claims without proper science? How do you justify a blend of artificial ingredients, dyes, flavors, sweeteners without question and allow it to be sold as food?  Yet PLANT MEDICINE that has a long history of safety and efficacy has to jump through science hoops based on a drug model. Did anyone ever consider making drugs jump through the safety standards of herbs? Safety is your # 1 concern, is it not?! Would any drug get to market if this was actually true? Herbs must follow a drug model for efficacy while drugs get passed that are in most cases barely better than a placebo. Writing this makes me wonder at the motives behind the regulations.

Vitamins and Minerals – Orthomolecular association. I am confident they have experts who understand use of vitamins and minerals better than any of your 200 regulating employees.

As it is most vitamins will only come from China in the future so may require good manufacturing standards to ensure no harmful contaminants.

Probiotics – We have Canadian experts respected worldwide for their products and research

Enzymes – Use Canadian experts.

Sports Nutrition – Canada has top experts respected worldwide for their products and research

[Each].

As you can see I question you having on staff 200 people to oversee SAFE products especially since they are not qualified in the area of natural health. Alignment needs to be made with top Canadians in their chosen field of natural health to determine evidence and create appropriate regulations. This needs to be addressed.

4.       Manufacturing standards – As a consumer there are 2 things I consider when buying a natural health product. # 1 – what is on the label is actually in the bottle, # 2 – I am assured the product is below allowable amounts of heavy metals, bacteria, and any other contaminants. I am quite confident most Canadians who shop in health food stores would be fine with this. We will judge the claims for ourselves, we have been for over 40 years now without any harm or deaths so nothing needs to be fixed.

5.       How did Red Bull [I], Crest toothpaste, Nicorette, Sudafed, Listerine, CoverGirl makeup and 100s of other products become part of the natural health category?

Is this some kind of sick joke?  In 1997 when Alan Rock started us down this regulatory process I guarantee none of these non-health food products were ever considered part of natural health products. Somewhere along the line they got slipped in.

Just to be clear – products that contain artificial dyes, colors, sweeteners, etc are not considered a natural health product.  These types of artificial ingredients have a long list of issues most manufactures of natural health products would never consider. Walk into any health food store in Canada and you will not find products similar to these suspect OTC products that have been pushed into the NHP category. The fact that they have been included because they make a claim based on a natural ingredient shows how disconnected Health Canada is with natural health products. It is not just the active ingredient but also what is included in the entire formula that needs to be considered before qualifying products as an NHP. The general public knows this, try asking anyone if they think Nicorette gum or Crest toothpaste is a natural health product. …I’m sure many will raise their eyebrows and think you’re kidding.

6.       You mentioned how one of the biggest issues you have with us is how we seem to be split as an industry. I do believe the majority of people who sell and use ‘real’ natural health products would like to see us out of the drug category and appropriate regulations where safe products are not taken off the market. Where many of us differ seems to be how best to get Health Canada to change the current path it is on. I am quite sure most of us would prefer to be home with our families rather than spending our time trying to protect our human right to choose natural medicine. If we can choose to smoke, which is proven to cause cancer, then we should not be questioned if we decide to use a natural health product. No matter how the regulations for each category are set up the fact remains the same.  If I can smoke, drink myself blind, over eat junk food which causes obesity and diabetes, use OTCs like candy or consume any other proven harmful substance than WHY is Health Canada spending so much money, time, energy plus 200 people to regulate an industry with ZERO deaths? Does anyone have an answer to what seems to be a pretty obvious question? Or does Health Canada work for big business as has been suggested by many past employees?

7.       Codex – I found it odd you had trouble remembering the name of codex especially as you have a key position with Health Canada? I am quite sure most health food industry people know about codex even though opinions differ as to whether it will affect us since codex relates to food not drugs. Real natural health products cause NO HARM and should therefore not be part of any International Harmonization or trade agreement. I am Canadian and along with millions of other fellow Canadians have used natural health products for decades. Why so much interest in regulating safe products that have proven through consumer interest to help people enjoy healthier lives’?

8.       As an industry we want out of the drug category!

I had always thought this was more of a procedural issue until you told me getting out of the drug category is no easy task since it is THE LAW we are under drugs. After thinking this over, it means that we are now selling products outside the law. Regardless of the fact that Health Canada has delayed the enforcement date, natural health products are DRUGS by LAW. So already without giving any conscience to the fact that natural health products are SAFE, Health Canada put them under the drug category. This is so wrong I honestly have no idea how to express myself. How exactly do you justify putting safe products in the same category among the most deadliest products in Canada and consider this right action? Do you actually agree with this? Are you truly Canadian citizens? Do you think the money, people, energy, and convoluted process of NHPD to control safe products is really necessary?  Honestly?

Let me tell you some of the brilliance of the new regulations:

  • Illegal to sell Cinnamon in capsules or for that matter any single herb where NHPD does not think there is enough evidence to support the claim. However if I buy the same or more cinnamon in a bun with high sugar and fat content is fine. Eat as many as you like.
  • Probiotics/enzymes – where are the bodies? What is interesting is if a herb, like Kava, ‘may’ have a side effect like liver problems it is banned from the shelves. Even though in Fiji it is a national drink. Yet Tylenol the # 1 cause of liver damage sells merrily along in stores across Canada. Yet safety is Health Canada # 1 concern. Really?
  • Formulas created by people who study and have extensive schooling with NHPs have to be changed to appease some NHPD official with no appropriate training. This is wrong.  Proven formulas that Canadians rely on for their health are being watered down or completely changed. Remember no deaths.
  • At a recent meeting just prior to the March 2011 ‘enforcement date’ which was delayed, myself plus 10 or so small to medium businesses estimated the retail sales dollars of the SAFE products we would have to take off the shelves was approx. $80 million. In this economy Health Canada is looking to enforce safe products off the shelves with no consideration of the job loss, business stress and uncertainty of everyone currently selling NHPs. Not to mention the lack of consideration of the stress this will put on the millions of Canadians who will no longer have access to the safe and natural health products they have come to reply on. $80 million of SAFE products, that consumers choose from freely will be taken off the shelves…and why?? Yes I wonder WHY?! when I watch kids smoke under age outside my son’s school in an approved smoking area. How can you really claim that safety is Health Canada’s # 1 concern!
  • Oregano Oil – Although still allowed to be sold, the fact that NHPD is questioning oregano again makes one question the intent of the regulations. No harm done to date, millions sold to date yet NHPD has concerns. Perhaps they should concern themselves with peanuts or meat or? Not oregano oil. Has anyone ever tried it? See if you can handle more than a couple drops at a time. What a waste of time, energy and money!

The list could go on. Safety is clearly NOT the issue here. And to be honest I am not sure what the issue is?

The people/women who choose to shop in health food stores across Canada amount to about 5 million. Though not the majority of Canadians my experience has shown they are people who do not like to have their human right to choose natural medicine compromised or taken away. As it is most consumers are unaware that Health Canada is intent on pretty much ending our access to safe effective natural medicine.  It is time they found out!

What does Health Canada have to say about this? What is the agenda? Why do you have 200 people regulating a safe industry? Why do you insist on using unqualified people to access licenses instead of qualified Canadians? 

I have my doubts this letter will amount to much more than me getting it off my chest. However you can be certain that unless Health Canada starts to make serious efforts to change the current process you will be hearing from Canadian citizens just like me who are tired of being concerned whether we will be able to buy natural medicine we depend on while dangerous pharmaceutical drugs, cigarettes, junk food, alcohol, sugar drinks etc are easily accessible nationwide.

I read a Thomas Jefferson quote ‘if we allow the government to decide the food we eat and medicine we take we will be subjecting ourselves to the worst form of tyranny’.

And somewhat similar, our Health Minister Leona Aglukkaq after overruling the expert advisory group by putting energy drinks into the food category noting ‘individuals and parents should have the right to choose what they eat and drink’. Just add medicine to this and we have solved the entire issue.

Or do you not think Canadians should be able to choose their own medicine?

As a Canadian I should be able to smoke, drink, take prescription drugs and use natural health products, unless Health Canada and the government of Canada have decided to take away my basic human right and freedom to choose. This is not just about natural health products but about my human rights!

I am amazed that as fellow Canadians you actually agree with this process and support it.

Thank you,

Deane Parkes

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