The following is a letter written by OHA board member Don Nichol regarding the future regulation of health products in Canada.


Sept. 9, 2002

Marie S. Lemaire, B. Pharm., D. Hom.
Natural Health Products Directorate
Health Canada
9th Floor, 171 Slater Street
Ottawa, Ontario K1A 0L3

Dear Marie,

Re: NHP Consultation Workshop Summary Report

From reading the recent Summary report it would seem that you are intending to have homeopathic medicines registered in Canada as natural health products and to change their DIN’s to natural health identification numbers or PN’s. We therefore have a number of questions about such a change.

1. If Canada classifies homeopathic remedies as natural health products will we have any difficulties in harmonizing our standard with those of other countries, such as the U.S. or Europe, where most of the remedies are manufactured and where they are registered as a unique class of drugs.

2. Will Canadian homeopaths be able to import homeopathic remedies from other countries if our remedies are classified as natural health products while theirs are classified as drugs? As we have indicated in previous letters, the market in Canada is relatively small and therefore the manufacturers will not be able to register all remedies here - especially the lesser prescribed remedies and the more recently proved remedies.

3. Will Schedules D and F products be registered as natural health products or as drugs or as both? It was our understanding, from the recent consultation workshop, that the substances found in these schedules would have to receive approval from the Biologic and Genetic Therapies Directorate in order to be registered. This would mean that all homeopathic remedies listed in these schedules will receive DIN’s upon receiving approval from the BGTD.

On page 5 of your Report you have indicated that the discussion group on the DIN issue made a specific proposal: i.e. to regulate homeopathic medicines as natural health products with Pn’s in place of DIN’s after a 5 year education campaign. Although this may be helpful for marketing purposes, our concerns as practitioners are not about consumer perception. We are more concerned about the harmonization of Canadian standards with international standards and about having full access to all existing and future homeopathic remedies. For the record, we do not recall this proposal as having come from the discussion group. The DIN discussion group, held on Thursday afternoon, was a relatively short meeting and there was not enough time in that session to hear everyone’s viewpoint.

Sincerely,

D. J. Nichol, D.H.M.S., H.D.
Director, Ontario Board of Homeopathic Doctors

As you can gather, the regulation of homeopathic remedies concerns us all. The OHA is active in voicing our opinion regarding this important issue. Look ahead to the response from Marie Lemaire of the Natural Health Products Directorate.

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