Thank you, Mr. Chair.

I think it's timely that this committee is considering the regulation of natural health products. This is the regulatory issue that is of most importance to Canadians.

By way of example, the organization I'm with, the Natural Health Products Protection Association, created over half a million citizen letters to targeted MPs for a single campaign just to support Bill C-368 concerning the regulation of NHPs.

Citizens are extremely engaged in this because they're concerned that Health Canada is going to increase the regulatory burden through the self-care framework. However, this committee needs to understand that the current regulations are far too dramatic and render us very uncompetitive in comparison with the United States.

I want to draw three major differences between how the U.S. and Canada regulate natural health products. I hope this committee understands that we arrived at these completely polar opposite regulatory approaches from consumer pressure.

In the late eighties and into the nineties, both the FDA and Health Canada were over-regulating natural health products by imposing the chemical drug regulations. The consumer rebelled with two messages: do not regulate NHPs like drugs, and we want increased access, meaning we want a reduced regulatory burden not an increase.

The citizen rebellion in the United States led to the passage of the Dietary Supplement Health and Education Act of 1994, which does three things completely opposite to how Health Canada manoeuvred us to regulate.

The first difference is that NHPs in the United States are classed as foods, but we've been manoeuvred into classifying them as drugs.

The second major difference—and listen carefully—is that NHPs in the United States are deemed by law to be safe, but we've been manoeuvred into the drug model where our NHPs are deemed by law to be dangerous.

The third major difference is that, in the United States, you don't need government pre-approval to sell a natural health product, but in Canada, because we've been pushed into the drug model, we have to jump through all of these regulatory hoops to get Health Canada permission in the form of a license.

This has driven the cost of Canadian NHPs through the roof compared to our American competitors, and that has removed them from low-income Canadians, who now don't have the option of using NHPs. This has health consequences.

The curious thing in the sole message by Health Canada is that we need these regulations for safety, and we can safely conclude that it is not true for several reasons. First of all, we weren't having a safety issue before the regulations. The United States isn't having a safety issue with how they're regulating. The big fraud is that every Canadian is free to import the unregulated natural health products from the United States and to use them personally, and a large number of Canadians are doing that because of the price difference.

Risk is always measured. There's a risk hierarchy. How many deaths per million of the population are there per year? Health Canada refuses to tell us what that number is because there likely isn't a credible death attributed to the entire NHP industry per decade, let alone per million per year.

Finally, if you want to have an honest risk analysis, if we're really here to regulate because of safety, then everyone on the committee knows that well over 70% of Canadians are regularly using natural health products, and a large number of those are effectively managing health conditions—some of them serious—with these products. Obviously, there's going to be a health consequence to taking products away that people are effectively using to manage their health, but we never have that type of discussion. We're just told that there's risk and that we need to increase our regulations. These are the most unpopular regulations in Canadian history, and they're likely the most damaging; there are health consequences.

I'll just close, as I think I'm getting close to my five minutes, by pointing out that I'm not suggesting, in any way, that we stop products at the border. That would not survive a section 7 Charter of Rights and Freedoms challenge. That's not the answer. The answer is getting rid of this regulatory burden that has nothing to do with safety, and moving more towards a model like the U.S. has.

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