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PostPosted: Mon Jun 29, 2009 4:57 pm 
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Site Admin

Joined: Tue Mar 22, 2005 11:17 pm
Posts: 6501
Location: Ottawa
I received this e-mail from a friend:
Attention everyone, Health Canada is in public consultation period for
proposed amendments to the food and drug regulations:
"This regulatory amendment proposes to require the labelling of NMIs
on the labels of non-prescription drugs for human use (with some
exceptions). This may result in a positive impact on consumer health
and safety, by allowing individuals to avoid life-threatening
allergens and agents for which they have a history of adverse
reactions. Furthermore, this enables consumers to make informed
choices when purchasing nonprescription medications. While some
manufacturers voluntarily list NMIs on the outer labels of non-
prescription drugs, not all do so, and currently, it is not a legal
requirement." (from http://alert.scc.ca/wto_e/TBT-CAN-271-09.html)

They are open for comments until August 20th. We need to ensure our
needs are well heard and considered - greater numbers are required to
offset the economic considerations given to the pharmaceutical and
natural health product industries).
I've already submitted the following comments and URGE YOU TO BOLDLY
PLAGIARIZE AND SUBMIT AS YOUR OWN (minus the references to my son's
adverse reaction). We need to and maintain the public pressure on the
regulatory process to help ensure ALL top allergens are disclosed,
with no exceptions!

---------- Submitted message ----------
Subject: Comments regarding Project No. 743 (CG1 notice published 28
May 2009)
To: regaff-affreg@hc-sc.gc.ca


Policy Division,
Bureau of Policy, Science and International Programs
Therapeutic Products Directorate, Department of Health
1600 Scott Street, Holland Cross, Tower B, 2nd Floor, Address Locator:
3102C5, Ottawa, Ontario K1A 0K9
fax: 613-941-6458; e-mail: regaff-affreg@hc-sc.gc.ca

With reference to the notice of proposed regulations amending the Food
and Drug Regulations, project 743 – Non-Medicinal Ingredients
appearing in CG1 on June 6, 2009 (http://www.gazette.gc.ca/rp-pr/
p1/2009/2009-06-06/html/reg3-eng.html) and open for comments until
August 20, 2009.

1. The proposed amendment to C.01.004(1) exempts the sub-ingredients
of flavours, fragrances, and pharmaceutical inks. This does not
achieve the impact on the public as described in the RIAS. As a
minimum, the top allergens as identified by HC/CFIA (http://www.hc-
sc.gc.ca/fn-an/securit/allerg/fa-aa/index-eng.php) SHOULD ALWAYS be
disclosed (even when present only as sub-ingredients of flavours,
fragrances, and pharmaceutical inks).

2. Unclear whether probiotic supplements are considered non-
prescription drugs. My son suffered an adverse (allergic) reaction to
SISU Dophilus Chewables, which does not appear to carry a DIN or other
identification number. Refer to adverse reaction report MED-2085
submitted June 2009. Regulations should also apply to probiotics and
all such supplements.

3. Unclear whether the proposed regulations apply to substances
(other than ingredients) used in the processing of drugs intended for
human consumption and may still be present in the product. My son
suffered an adverse (allergic) reaction to SISU Dophilus Chewables
“from non-dairy source” although the manufacturer did inform me later
that milk is in fact used in the processing. Refer to adverse
reaction report MED-2085 submitted June 2009. Regulations should be
extended to include substances used in the processing of drugs
intended for human consumption and which may still be present in the
product.

4. Proposed regulations should encourage manufacturers to indicate
when they believe their product is otherwise not suitable for
consumption by persons with life-threatening allergies to top
allergens (as identified by HC/CFIA).

5. Proposed regulations should require labelling of top allergens (as
identified by HC/CFIA) in common terms (as used by HC/CFIA),
especially for children’s products – these are often administered by
parents, grandparents, teachers and other caregivers who may not be
used to deciphering proper or international nomenclature.

Marc

_________________
Moderator
Daughter: asthma, allergies to egg, milk, peanuts, tree nuts, most legumes (not soy) & penicillin. Developing hayfever type allergies.
Husband: no allergies
Me: allergies to some tree that flowers in May
Cat: allergic to beef, pork and lamb


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 Post subject:
PostPosted: Fri Jul 03, 2009 7:48 pm 
Offline
Site Admin

Joined: Tue Mar 22, 2005 11:17 pm
Posts: 6501
Location: Ottawa
CFIA has a survey that will let you comment on their labelling and advertising website.

Quote:
We want to know what you think of the CFIA's labelling and advertising website

The Consumer Protection Division (CPD) has posted an online questionnaire to evaluate the content and design of its labelling website available at http://www.inspection.gc.ca/english/fss ... etie.shtml.

All individuals who use the site are encouraged to complete the questionnaire. The results will be incorporated into revisions to the website design. The survey will be available until July 24, 2009 at the following address: http://inspection.gc.ca/survey/1

—---------------------------------------------------------------------------------------------------------------------------------------
Que pensez-vous du site Web de l'ACIA sur l'ιtiquetage et la publicitι?

La Division de la protection des consommateurs (DPC) a publiι un questionnaire en ligne afin d'ιvaluer le contenu et la conception de son site Web sur l'ιtiquetage, accessible ΰ l'adresse suivante : http://www.inspection.gc.ca/francais/fs ... etif.shtml.

Nous encourageons toutes les personnes qui utilisent le site ΰ rιpondre au questionnaire. Nous tiendrons compte des rιsultats du questionnaire dans les modifications apportιes ΰ la conception du site Web. Le questionnaire sera disponible jusqu'au 24 juillet 2009 ΰ l'adresse suivante : http://inspection.gc.ca/sondage/1

_________________
Moderator
Daughter: asthma, allergies to egg, milk, peanuts, tree nuts, most legumes (not soy) & penicillin. Developing hayfever type allergies.
Husband: no allergies
Me: allergies to some tree that flowers in May
Cat: allergic to beef, pork and lamb


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