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Sylvia Hyland

44th Parl. 1st Sess.
October 30, 2023
Context: Department of Health's Regulatory Changes for Natural Health Products Committee Business (HESA) - Oct/30/23
Ms. Sylvia Hyland (Vice-President, Operations and Privacy Officer, Institute for Safe Medication Practices Canada)
  • 11:09:23 a.m.
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Thank you, Mr. Chair. On behalf of the Institute for Safe Medication Practices Canada, ISMP Canada, we are pleased to be here today to speak to this important topic. I am Sylvia Hyland, VP operations and privacy officer, and joining me is Melissa Sheldrick, patient and family adviser. ISMP Canada is a pan-Canadian, not-for-profit and independent organization established in 2000 to improve the safety of drugs and health projects. Our key activities are the analysis of errors; making recommendations for improved safety, including labelling and packaging; and supporting consumers, care providers and other health system partners to implement these recommendations. Through our reporting and learning programs, we have received reports of preventable harmful errors involving natural health products. We have shared information through the numerous Health Canada consultation processes and stakeholder engagements. In our analyses, we identified three main areas of concern related to natural health product labels. The first concern is the inability to easily and consistently identify ingredients on the label. We recently received a report about a selection error involving an umbrella brand name. This means the same brand name is used for products that have different key ingredients. The report describes purchasing a product for a baby believing that the product had vitamin D in it. The reporter was upset to find that unlike another product with the same brand name and typically associated with vitamin D, the product purchased had no vitamin D. We have also received reports of selection errors in products using the same brand name for both a non-prescription drug that has a drug identification number or DIN, and a natural health product that has a natural product number or NPN. An example is a consumer reporting harm from taking a ginger and willow bark product when she had intended to take the dimenhydrinate product with the same brand name. Consistent use of a product facts table will identify key information for the consumer and also the health care provider. It is essential for both to easily and consistently find the ingredients when selecting and comparing products. The second concern is unclear information about the dose on the label. Consumers and health care providers need to easily locate and understand the recommended dose for the product on the label. We have had reports of harm due to misunderstanding the dose information for a natural health product. The third concern is the lack of an important warning or the inability to easily read warnings, when selecting the product from the shelf. The list of NHP medicinal ingredients is broad and includes ingredients known to have possible adverse reactions. Examples include scopolamine, pseudoephedrine and salicylates. We fully support the improved NHP labelling requirements. We also fully support the inclusion of natural health products under Vanessa's Law. Consumers trust that there are requirements being followed for the products they buy. It is important that Health Canada has the authorities and resources to conduct regulatory activities, provide enhanced oversight for compliance and monitoring, and also to sustain the improvements being made.
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