From: Eileen N. [mailto:eileen@net]
Sent: Wednesday, April 17, 2019 3:44 PM
To: ‘manon.bombardier@canada.ca’
Cc: ‘hc.self.care.products-produits.autosoins.sc@canada.ca’; Alistair.MacGregor@parl.gc.ca; elizabeth.may@parl.gc.ca; justin.trudea@parl.gc.ca; ‘jagmeet.singh@parl.gc.ca’; ‘andrew.scheer@parl.gc.ca’
Subject: Re: your March 2019 Letter to Shawn Buckley/NHPPA
Importance: High
Madam Bombardier et al:
Having just recently read a copy of your March 1st letter (attached) to Shawn Buckley, President of the Natural Health Products Protection Association (NHPPA), to say I feel troubled is an understatement!
I have been trying for days to abbreviate this communiqué to you and the other recipients, as I believe everyone’s time is valuable and must be respected, but I am so outraged, abbreviating it, while still doing justice to my serious concerns, just wasn’t possible … so please, do bear with me.
What has happened (or not happened) at Health Canada that our ‘stakeholder action plan’ continues to be ignored, when it promised to be the ‘dynamic blueprint’ for our collective path forward?
I draw your attention to the 53 formal stakeholder Recommendations that emerged from the 2+ years’ Standing Committee process concluded by (then) Health Minister Alan Rock:
https://www.ourcommons.ca/DocumentViewer/en/36-1/HEAL/report-2/page-126 )
Perhaps you’ll recall: this process followed the tremendous public outcry that saw over 300 participants giving input, evidence and heartfelt testimonials to government, thus advocating for proper recognition and ‘handling’ of NHPs in this country, the largest public input process of its kind in the history of Canada!
In your letter to Mr. Buckley, am I remiss in asking: are you ‘brushing him off’ suggesting he address his/our concerns through ‘lower level’ staff members, which to date has not yet resulted in the proper direction nor achievement of critical goals and desired outcomes? I believe there is an urgent need for you to directly engage with him, personally, so he can more appropriately communicate critical, unique and valuable information and concerns to you, including the escalating concerns from the public-at-large.
As one of the over 4500 people you refer to in your letter (page 2, paragraph 1) who has participated in Health Canada’s “public consultations”, that I am repeatedly hearing will lead to a “modernization” of the current regulations, especially pertaining to natural health products (NHPs), raises grave concerns. Adding insult to injury, we’re also being told NHPs are to be classified as “self-care products”, lumped in with and regulated the same as other over-the-counter chemical
drugs!? What???
The changes Health Canada continues to ‘roll out’ and further propose are not anywhere NEAR reflective of the spirit or intent of the Standing Committee process and the resulting 53 Recommendations, nor are they at all congruent with what Canadians have repeatedly been asking for and been promised … for decades in fact!
The NHPPA is a federally incorporated non-profit organization which exists for one reason and one reason only: “To protect Canadians’ access to Natural Health Products and Dietary Supplements”. As such, this stakeholder group is a critically important, apolitical, industry watchdog voice. With Mr. Buckley as our President, we bring a uniquely important set of skills, credentials, information and an essential ‘bird’s eye view’ to the process! As an extremely knowledgeable and highly respected key spokesperson, Mr. Buckley carries vital historical knowledge and legal perspectives so integral to these matters. He is more than qualified to address the concerns so many of us have, which Health Canada seems repeatedly unwilling or unable to accept or respect! It is clear to me the Recommendations were crafted to ensure a broad collaborative process would occur, which doesn’t mean meaningful engagement with all in the stakeholders’ group were to be ignored as the complex process unfolds. I suggest the tone or apparent intent of your letter to Mr. Buckley is not congruent with that desired outcome.
Equally and even MORE troubling has been my discovery Health Canada representatives are repeatedly using the phrase: “these changes are non-negotiable”, especially in response to questions or concerns raised time and again by the public, myself included. This has happened countless times, in particular during Health Canada’s cross-country ‘public engagement’ sessions!
If it truly is the Ministry’s intention to respect the previous processes and Recommendations, further attempts to impose “non-negotiable changes” or any other such barriers to takeholder input can only be perceived by the natural health community as an obstruction of this stakeholder and public process! Meaningful engagement with you, ensuring all stakeholder input is taken seriously, is imperative! Anything less will most assuredly negatively affect millions of Canadians! With more than 85% of Canadians already safely and successfully using NHPs as an integral part of our ongoing wellness regime, a statistic that is slightly higher than the global one in fact, leads me to implore you: these matters are far too vastly important to be diminished or obstructed, which Health Canada’s current process and decisions are unwittingly doing in my humble opinion. Under your cooperative leadership, and collectively, we can and must do a much better job in this process!
Let me give you another example how I’ve come to perceive the current trajectory Health Canada is on, intentionally or unintentionally, demonstrates serious disregard and disrespect for the opinions, wishes and sacred time so many of us have contributed to this process. In particular, I call your attention to assurances in the Standing Committee Recommendations, which continue to be ignored or are in serious jeopardy:
Ø The draconian enforcement powers the government promised would not be applied to natural health products are in the process of being applied to natural health products!
Ø Health Canada’s position is that the changes being made are “non-negotiable”!
Ø Health information that legitimately deserves to be readily available, and which is backed by abundant verifiable scientific research, clinical and traditional use evidence, and including peer reviewed and published manuscripts, are at risk of being further ‘watered down’ (or worse), should the arbitrary ‘decision’ to lump them in as “self-care products” in the chemical drugs’ model is imposed!
Ø Censorship of truthful and verifiable information and evidence, pertaining to NHPs and their efficacy, appears to be imminent!
Ø Outrageous, unjustified punitive administrative penalties and licensing fees are to be levied against ‘violators’ in the natural health community, including some who are already provincially licensed!
Ø Our sovereign right and freedom to choose and have unfettered access to NHPs, as well as available, verifiable, legitimate information, evidence and knowledge, not arbitrarily censored by Health Canada (much of which is easily traced back through centuries of documented evidence, outcomes, traditional use, clinical use, practitioner testimonials, scientific publications and including access to support of provincially licensed natural healing practitioners) is in danger of being severely and arbitrarily diminished, at a minimum, by being lumped in to the inappropriate model applied to chemical drugs under the current Food and Drug Act!
As the sovereign right of Canadians, making informed choices and decisions concerning their health care, is further infringed upon, unquestionably demonstrated by these arbitrary and further proposed changes (I refer you to the ‘implementation schedule’ being followed by your Ministry), this and so much more is what compels me to write, urging you to swiftly intervene, first and foremost: by making suitable arrangements to personally meet with Mr. Buckley without further delay. I feel so strongly about how essential it is that you have meaningful, direct, ongoing discussions with him, to get this process back on track so it more accurately reflects the true spirit of those 53 Recommendations. I do hope you agree we are/should be bound by those? It is clear to me there are extremely serious oversights which must be rectified and I believe these need to include leadership by you/from your office.
There is no doubt in my mind this process has evolved into a very serious sovereignty issue! What gives anyone the right or the authority, including Health Canada, to impede or otherwise impair any Canadian’s right to access, or make fully informed choices about, their health care, including unobstructed access to NHPs, how or with whom they choose treatment, how they choose to maintain their ongoing health and wellness, especially involving the use of NHPs and accessing legitimate uncensored natural health and healing information, often with the qualified assistance of licensed and many other registered or highly trained natural health practitioners!
The 53 Recommendations clearly concluded: Health Canada’s current mandate and staff knowledge is lacking, both in “expertise and experience in the field of NHPs”. Surely you agree it is long past time for us all to get back on track by revisiting and properly adhering to the true spirit of those Recommendations?
NHPs rightfully qualify to be designated as a unique and separate category, which would neither be adequately captured under “food” nor “drugs”! (Do you know in the USA however, NHPs are categorized as “food” by the FDA and can be/are being sold in any grocery, health food or even corner store in the country?) The voices and opinions of Canadian consumers, practitioners, integrative medicine MDs and other provincially licensed or registered professionals, must NOT suffer such consequences, should Health Canada’s arbitrarily proposed and/or imposed regulatory changes proceed as so many of us are witnessing!
Mr. Buckley speaks for me and for many other Canadians in this regard! His input, so integral to this process, must NOT be ignored, dismissed or diverted. No one speaks better than he to the key and important historical and other issues we have repeatedly brought forward.
Earlier this year I had occasion to research and properly understand Health Canada’s mandate. I was shocked (but not entirely surprised) by what I learned. As I currently understand, it is twofold:
(i) to enforce the Food and Drug Act; and
(ii) to protect Intellectual Property (i.e. pharmaceutical patents).
As I reflect on the intended scope or intent of this mandate, having witnessed swat-like raids on natural health pharmacies for years, including right here on Vancouver Island, is forefront in my mind. Nowhere in that mandate, or in the Ministry’s past or current actions or decisions, do I feel at all confident my sovereign right to access natural health products, uncensored information, unfettered professional advice or treatments for my ongoing wellness, will be properly protected, supported or respected, as the important priority it is for me and as we were clearly assured would be the case in the Recommendations! The Ministry’s role was clearly and accurately identified in the Standing Committee process and reflected in the Recommendations!
Therefore, I ask that you take the required steps, without delay, to ensure meaningful, particularly from the public’s point of view, personal engagement, starting with a meeting with Mr. Buckley. I suggest such leadership by you, in your role as Director General of Health Canada, needs to include a sincere ‘sober second look’ at the entire process. In the truly collaborative approach so many Canadians expected and deserve, Mr. Buckley’s knowledge and input is extremely integral to the process. Having been involved for almost 25 years ‘on this file’, his unrestricted participation with you in this process is beyond essential.
I passionately believe you must fairly review and evaluate the steps which have led us to where we
(wrongfully) find ourselves today! Future Ministry decisions must be based on comprehensive and honest stakeholders’ input, fully reflective of our collective desired outcomes! Further arbitrary decisions must not be imposed in the absence of such robust engagement with all identified stakeholders!
Almost 100,000 Canadians have physically signed a NHPPA petition reiterating, yet again, our continued and escalating concerns. More and more people are signing every day! If your Ministry expects Canadians to believe and trust you are honestly “modernizing” Canada’s existing Health Act, a drastic change of course is clearly warranted. Just knowing Health Canada intends to slide these regulatory changes into law using the (almost obscure to most Canadians) Gazette process, rather than the usual Bill in Parliament that allows for three Readings, in-depth fair debate, and further consideration in the Senate, is also of grave concern to me and many others. I believe that should be revisited as well, especially since such a wide gap exists between public ‘sentiment’ and government intentions on this file?
The good news: there is a simple and reliable fix!
A ballooning number of Canadians support, and have been requesting proposed new legislation for, the establishment of:
Ø a Charter of Health Freedom, something Mr. Buckley can more than adequately bring you up to speed about ~ http://www.charterofhealthfreedom.org/ ; and
Ø formation of a new federal Ministry of Wellness, supported by a more adequate and appropriate mandate staffed by knowledgeable experts (see the Recommendations), that will ensure proper adherence to and enforcement of the Charter!
I will continue to watch the process unfold. Only yesterday I received the most recent email from Health Canada under the subject heading “2018 Consumer Consultations on Self-Care Product Labeling”.
To say it escalated my stress response in this matter is another understatement. What I and thousands of Canadians are looking for are assurances that Health Canada understands the expectations Canadians have as it relates to their sovereign and legitimate right to make health care choices, to choose and to access NHPs and to rely on the broad scope of qualified natural health practitioners available to us, without such government ‘interference’!
One last thing I’d like to offer for deeper consideration going forward: in countries like Taiwan, Japan, Thailand and others in Eastern Asia, every healing modality imaginable is freely available to patients through practitioners of every modality imaginable, including but not limited to MDs, Homeopaths, NDs, Acupuncturists and many more! In fact, laws have been passed in those countries legislating and guaranteeing broad support for and protection of citizens’ rights to choose and access whatever treatments, natural health products, healing modalities or what-have-you they, their practitioner, or their MD deems may or will result in improvement of their health outcomes. Please let that sink in! When considering a standard for individual health and wellness and one’s quality of life, isn’t that the gold standard we should all be striving to achieve in Canada?
I conclude with this statement, authored in response to a day in the past that Health Canada had set aside for Canadians which was called “Self Care Day”:
“For NHPPA and its nationwide community of supporters, every day is ‘self-care’ day. It is not something that we observe once a year. The choices we make to naturally support and enhance our health include a wide range of NHPs and traditional medicines, natural healing devices, whole foods and holistic health practices. They are a foundational part of our lifestyle. They define who we are and are every bit as important to our daily lives as the air we breathe.”
There is nothing more important to me, save and except the overall health of the planet, than unobstructed health freedoms for myself and all Canadians! While it may seem, to some, like an ‘unusual’ change of course for Health Canada, let none of us, intentionally or otherwise, do anything to make a mockery of the dedicated efforts that led up to the Recommendations including falling short of achieving those desired outcomes.
With deep concerns,
Eileen N.
***
—–Original Message—–
From: Prime Minister/Premier Ministre [mailto:PM@pm.gc.ca]
Sent: Thursday, April 25, 2019 10:01 AM
To: Eileen Nielsen
Cc: Ginette Petitpas Taylor, P.C.,M.P.
Subject: Office of the Prime Minister / Cabinet du Premier ministre
Dear Ms. Nielsen:
On behalf of Prime Minister Justin Trudeau, I would like to acknowledge receipt of your correspondence.
Please be assured that your comments have been carefully reviewed. In your correspondence, you raise an issue that falls within the portfolio of the Honourable Ginette Petitpas Taylor, Minister of Health. I have therefore taken the liberty of forwarding your email to Minister Petitpas Taylor for her information and consideration.
Thank you for taking the time to write.
R. Olshansky
Executive Correspondence Officer
***
From: Eileen N. [mailto:eileen@net]
Sent: April 25, 2019 4:22 PM
To: ‘Prime Minister/Premier Ministre’ <PM@pm.gc.ca>
Cc: ‘Ginette Petitpas Taylor, P.C.,M.P.’ <hcminister.ministresc@canada.ca>
Subject: RE: Office of the Prime Minister / Cabinet du Premier ministre
Thank you for that R. Olshansky, however, this matter is MUCH bigger than seemingly can be/is willing to be handled properly by just the MofH!! I absolutely intended and want to be assured the PM will examine what’s gone/going on here in the past decades, and in particular during his tenure, to see the magnitude of how Canadians are being held ransom by the antiquated allopathic system as it pertains to Natural Health Products in particular and natural healing modalities as a whole and important system of medicine. This deserves BIG attention and transformation!
I trust I will hear this isn’t just another “pass the buck” situation and that the PM will read or be made aware of the ‘hiccup’ in properly carrying out the 53 Recommendations laid down by the Standing Committee during Allan Rock’s tenure and the expectations of tens of thousands of Canadians.
I particularly expect to learn that Ms. Bombardier is expediting the setting up of a meeting with Mr. Buckley!
Respectfully,
Eileen N.
