As a key stakeholder of the Consumer & Hazardous Products Safety Directorate (CHPSD), which currently administers the Cosmetics Regulations, CA was interviewed as part of the audit being undertaken for Health Canada by the audit unit of the Public Health Agency of Canada. The auditor’s intent was to seek our industry’s observations and insights into the operation of CHPSD and hear our suggestions for improved efficiency and effectiveness.
In a wide-ranging discussion over nearly two hours, CA’s Darren Praznik and Beta Montemayor shared industry’s experience and frustration with a structure that regulates products – such as toothpastes, shampoos, and even lipsticks – under three significantly different regulations, administered by two separate directorates in two different branches of Health Canada, and with enforcement provided by two separate inspectorates. “What possibly could be inefficient with this model?”, noted Praznik, as he pointed out that it takes two Health Canada inspectors to check out the toothpaste aisle in a retail store.
“The opportunity for the much-needed systemic reform is right before us with Health Canada’s Self-Care Framework initiative”, noted Praznik and Montemayor, “and Health Canada just has to get on with finalizing and implementing the Framework.” Several aspects of the Framework important to our industry – such as the end of quarantine and re-testing for DIN imports – have already been implemented through our industry’s successful efforts to have them included in the CUSMA trade agreement which came into effect in July 2020.
Although the Self-Care Framework initiative was understandably delayed by the pandemic, the status quo has only served to continue the frustration. Examples provided to the auditors included transparency and timing in the process for implementing changes to the hot list, consistent treatment of ingredients between CHPSD and NNHPD, and most recently the issuing of two consultations this past summer on essentially the same matters (one by CHSPD and the other by NNHPD). Subjects covered included labelling (e.g. allergens) as well as the use of digital labels.
Praznik and Montemayor did point out that although there has been a marked improvement in the cooperation and coordination at the Director level, this has not yet fully made its way down to all the staff which continues to lead to much of the frustration such as the missed opportunity to coordinate this summer’s consultations.
It is hoped that the insights provided through this audit will reinforce the need to get on with completing and implementing the Self-Care Framework and making the necessary administrative changes. “The answer to almost all of these issues”, noted Praznik. “is to get the Self-Care Framework done!”