A Fresh Start: Final Report of the ONHP Transition Team

Appendix B: Interim Management Policy - Letter to the Minister of Health.

January 28, 2000

The Honourable Allan Rock, PC, MP
Minister of Health
Brooke Claxton Building, 16th Floor
Postal Locator 0916-A
Ottawa, Ontario

Dear Mr. Minister:

Re - Transition Team Recommendation for NHP Interim Management Policy

The Transition Team is nearing completion of its recommendations regarding the new Office of Natural Health Products and regulatory framework. However, the Team is cognizant of the time that will be required for development of these recommendations into a comprehensive framework.

It is with a great sense of urgency that we are seeking Ministerial approval for an Interim Management Policy to be established for the regulation of natural health products. We are making this recommendation for the following reasons.

For over two years, the Health Protection Branch, the public and industry stakeholders have laboured under interim policies governing the regulation of natural health products. The effects of these policies are taking their toll:

1. Current laws, regulations and policies do not reflect the direction and spirit of recommendations made by the Standing Committee on Health. Consequently, some current actions, including restrictive enforcement, have the effect of confusing stakeholders, the media and the public, and undermining progress in establishing the new Office of Natural Health Products and proposed regulatory change.
   
   
2. After two years, the public, industry and all other stakeholders anxiously await evidence that Health Canada is moving forward with the new Office and regulatory framework.

The official opening of the ONHP must coincide with its assumption of authority and primary responsibility for NHPs. As well, the operations and activities of the ONHP should be conducted in partnership with other government agencies and stakeholders.

This can be accomplished with an Interim Management Policy which meets Standing Committee recommendations 42 and 43. These recommendations call for more open and transparent communication on NHPs with the broader public and practitioners, including details about decisions and actions regarding NHP products (removal from market, change of status, etc.)

Therefore, the Transition Team recommends that Health Protection Branch immediately implement an Interim Management Policy for the current regulation of Natural Health Products. This Policy would include the following:

1. That the ONHP Executive Director be the level of interim management contact and decision-making.
   
   
2. That all matters of regulatory action on NHPs (or those products deemed NHPs under the ONHP's working definition) proposed by any HPB Directorate or other branch of Health Canada, be undertaken through the Office of Natural Health Products.
   
   
3. That all regulatory decisions and actions be conducted in an open manner and reported with full explanatory communications to all stakeholders and the Canadian public in a timely fashion.

Mr. Minister, we appreciate your attention to this matter and trust that you will deal with it in an expedient manner.

Respectfully submitted on behalf
of the Transition Team