Ex-Health Canada NHP DG on product registration: ‘You have to ask yourself why you are doing it’
Adam Gibson previously held multiple senior positions within Health Canada and served for over three years as the Director General of Non-prescription and Natural Health Products Directorate. He’s also held senior positions with Consumer Health Products Canada and the Canadian Health Food Association, and so is uniquely qualified to discuss the positives and negatives of the Canadian regulatory system.
Gibson, who now runs his own company called True Moderation, noted: “Canada regulates dietary supplements under drugs on a legislative level. That created a little bit of a different dynamic from other countries, but some of the key things that are common to all countries are, one, the sheer number of products that were on the market. Because we regulated them as drugs, everything had to come in for some form of approval – not just a registration, but an actual validation of statements, efficacy, quality – and what happened was that there was a lot more on our market than we realized, and we ended up with a backlog.
“The basic advice that I have for any country getting into a registration process is to increase how much you think may be out there. There are many small players that are legitimate but will have to get used to interacting with government. There’s a lot of learning in the sector. For us it was perhaps a heavier learning curve because we regulated them as drugs and there are a lot of evidentiary requirements that come along with that.”
“Pull the Band-Aid off and let us know what your full plan is”
“For registration, you have to ask yourself why you are doing it,” added Gibson. “It’s important to know how many are out there, but why is it really important? I don’t need to know how many chocolate chip cookies are sold in my market so why do I need to know how many vitamin C pills are sold in my market?
“If it’s a staged process where ultimately, if in the case potentially in the United States, where now we know how many are out there let’s start looking at some other stuff, then that might be why there’s resistance. Pull the Band-Aid off and let us know what your full plan is… It can certainly aid in compliance and enforcement, but just be honest why you’re doing it.”
And on enforcement and compliance, Gibson said that for any regulatory system to work, it has to have robust compliance and enforcement.
“Dietary supplements and natural health products in Canada are the targets of organized crime. They are the target of bad actors,” he said. “It’s the natural human condition: everyone’s looking for a simple solution, and if you want to take a pill to fix something then the pills that are regulated in a way where there’s poor compliance and enforcement will be the target for organized crime. We’ve seen than in Canada and we see it in other jurisdictions as well.”
Gibson also discussed how a regulatory agency and system can deal with market places with high product turnover, and also compared and contrasted the CBD and cannabis landscapes in Canada and the US.
Watch the video above for the full interview.
