The Natural and Non-Prescription Health Products Directorate of Health Canada (NNHPD) periodically issues monographs describing “pre-cleared” information for common ingredients in natural health products in order to simplify and hasten their licensing process. For each of these monographs a short consultation period is opened to members of the public and industry for comment on their draft form. Bad Science Watch submits commentary on these consultations and advocates for the strengthening of the consumer protection regulations for natural health products (NHPs).

Bad Science Watch has constituted a standing committee on NHP monograph submissions.  The committee will be developing a rapid evidence check process and selection criteria to focus on higher-risk monographs.  The committee members are below.

Current Consultations

Canadian Clinical Trial Information Registry (AllTrials)

Bad Science Watch has prepared a statement for a Health Canada consultation on the Public Release of Clinical Information in Drug Submissions and Medical Device Applications. This is also in support of a letter prepared by Dr. Joel Lexchin, emeritus professor in the faculty of health at York University which describes important changes in the current consultation. This is part of our effort in support of the global AllTrials campaign that argues for all clinical trials registered, and all clinical trials reported. Read our consultation document below.

Health Canada Consultation on Release of Clinical Trial Information

New Framework for Regulation of Self-Care Products

We have evaluated and responded to the current public consultation by Health Canada: Consulting Canadians on the Regulation of Self-Care Products in Canada. The new framework for the licensing of NHPs, as well as cosmetics and non-prescription drugs, has the potential to make Canadians safer while allowing market access to low-risk products, as long as their claims are evaluated as scientifically valid.  We are urging Canadians to participate in the current consultation, as there are efforts by the NHP manufacturers to mislead their supporters into believing that Health Canada is on some sort of witch-hunt instead of re-committing to a science-based approach to evaluation of their products.

Please do not let the Canadian Health Food Association, the NHP manufacturers, and the hundreds of health food stores across Canada convince the government to turn a blind eye to the low quality and ineffective preparations that Canadians are told to rely on. Go to this link and tell Health Canada what you think. Below is our analysis for your consideration.

Consulting Canadians on the Regulation of Self-Care Products in Canada: A Response

Past Submissions

Multiple Ingredient Fixed Oil Products – Oral Feb 2015

Traditional Chinese Medicine Ingredients March 2014

Compendium of Monographs Consultation Oct 2013

Homeopathic Nosodes February 2013

Echinacea April 2013

Volunteer Opportunities

We are currently accepting applications for new members of this committee. Please email for more information.

Project Leader:

Michael Kruse

Michael is an advanced-care paramedic in York Region, just north of Toronto, Ontario. A theatrical lighting designer as well, he re-trained in 2005 as an EMT-Paramedic Specialist at the University of Iowa and as an advanced care paramedic at Durham College. Michael is currently enrolled at the University of Toronto working towards an undergraduate degree in physiology and the history and philosophy of science.

Michael has been active in the science advocacy community for 7 years and is committed to a compassionate defense of science for the betterment of all Canadians.

Committee Members:

Teresa Dean

Teresa holds a BSc from the University of Western Ontario and is a current graduate student at the University of Toronto. Through her work in academia, Teresa has learned that scientific knowledge is often inaccessible to non-experts. She became interested in volunteering for Bad Science Watch because she believes that we all have the right to clear, straightforward information about science or research that has the ability to inform the decisions which we make about our health or other aspects of our lives.

Chris Hebbern

Chris holds a PhD in Plant Sciences from the University of Copenhagen. Now based in Ottawa, he has completed an NSERC Visiting Fellowship in environmental epidemiology at Health Canada, studying temperature-related mortality and the health effects of climate change. He is currently a researcher in the field of air pollution and health interactions.

Kimberly Hébert

Kimberly Hébert is a registered Occupational Therapist with a Master of Science in Occupational Therapy from Dalhousie University. She also has a Bachelor of Science with Honours in Neuroscience from Dalhousie University and a Bachelor of Science in Psychology from Mount Allison University. She has been involved in science communication and consumer advocacy for many years. Her background in social sciences, scientific research, and health care have given her a passion for consumer protection particularly concerning products or services with associated lifestyle or health claims. She joined Bad Science Watch to help advocate for science-based health policies to better serve the public.

Nicholas St. Onge

Nicolas St. Onge is a third year pharmacy student at Université de Montréal. He’s involved in many projects, including the pharmacy students’ association at University (AÉPUM), of which he’s president. He’s interested on everything that concerns health and technology. During his studies in pharmacy, Nicolas is broadening his knowledge by working at the pharmacy department of Sainte Justine hospital in Montreal.

Justina Mak

Justina has been a keen scientist from a young age, which naturally led to a BSc at the University of Alberta. Her interest in cancer research took her across the Pacific Ocean to the University of Hong Kong, where she completed her Masters, studying drug treatments for acute myeloid leukemia. Since then, Justina has moved back to Edmonton and is an active volunteer in her community. In her spare time, she enjoys reading and playing board games.

Science Adviser:

Brian Foster, Ph.D,

Brian obtained his PhD in medicinal chemistry with Professor RT Coutts, University of Alberta, Faculty of Pharmacy and Pharmaceutical Sciences in 1982 and was a Senior Science Adviser and Research Scientist with the Therapeutic Products Directorate (the drug and medical device regulator) at Health Canada for 26 years when given the opportunity to explore new directions and challenges in July 2012.  During his tenure at TPD he oversaw several areas including external scientific advisory groups on HIV/AIDS, natural health products and blood products as well as internal Health Canada groups on personalised medicine, pharmacogenetics, synthetic biology, drug interactions, hepatotoxicity, and transmissible spongiform encephalopathies.

He has been an Adjunct Professor, Faculty of Medicine, University of Ottawa since 1999, and Head, Metabolomics Group, Centre for Research in Biopharmaceuticals and Biotechnology, University of Ottawa.  Brian’s research is focused on drug disposition, particularly cytochrome P450-related metabolism, with an emphasis on drug-natural health product interactions, and pharmacogenetics.

Brian has been a long-time member of Canadian Society for Pharmaceutical Sciences, and is a founding member of the Natural Health Products Research Society of Canada and the Chinese Medicines Research Society of Canada.

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