I think most reasonable people would agree that healthy lifestyles are a key component to maintaining good health. That includes, of course, exercise, clean air and water, and nutritious food. Many years ago a person could maintain good health by getting access to clean air and water and nutritious food, but time has changed that quite dramatically.

In Canada between 1994 and 1996, 1.4 billion pounds of toxic chemicals were released into the environment. That included about 280 million pounds of known carcinogens. Dr. Samuel Epstein, who's quite renowned, says that we now carry 500 different compounds in ourselves, compounds that didn't exist at all before 1920.

Thirty years ago, the World Health Organization said that 89 percent of all cancers were caused by toxins, pesticides and various other toxic chemicals in the environment. We believe illness is caused by an immune system weakened by our daily exposure, starting at birth, to chemicals and toxins in air, water, food, clothes, toiletries and our environment around us, but also by a significant reduction in the nutrients that we consume today. We just don't provide enough nutrients for an immune system that has to deal with a much heavier load of toxins.

The level of nutrients has dropped over the last 20 years about 50%. Iron is down by 70%. Magnesium is down by 30%. Between 1920 and 1968, the essential minerals in grain have dropped by a factor of ten. It now takes 500 bushels of grain to produce the same level of essential minerals as 50 bushels produced in 1920. Of course that will be much different even today from what it was in 1968.

What's even worse is that the level of processed foods in our diets has increased dramatically. In North America our diets now consist about 90% to 95% of cooked and
processed foods. When you process foods, you destroy 100 percent of the enzymes in the food, and you destroy a large percentage of the nutrients, about 80 percent.

Why are we concerned? The Natural Health Foods Directorate mirrors the drug model in its structure and licensing and approval processes, and that's a great concern to us. Health Canada's track record has not been comforting. It has approved drugs that should not have been approved. It has removed many supplements from the market over the last years, supplements that are important to individuals. It has created great distress for a number of supplement manufacturers and vitamin-store owners.

The supplement industry is experiencing a major structural change. The size of the manufacturers and retailers is increasing. This is being driven-as Lorna has said-by the nutraceuticals and functional foods industry. This concentration of power happened in the pharmaceutical industry with severe consequences.

There is a very interesting report released April 5 of this year by the House of Commons Health Committee in the U.K. It is an extensive report, with 48 recommendations, which will have a major impact in the pharmaceutical and medical industry in the U.K.

Just to illustrate, from one paragraph that is very interesting to show you how serious this report is:

"Our over-riding concerns are about the volume, extent and intensity of the industry's influence" -this is the pharmaceutical industry- "Not only on clinical medicine and research but also on patients, regulators, the media, civil servants and politicians. This makes it all the more important to examine critically the industry's impact on health and to guard against excessive and damaging dependencies."

We very much caution against what has happened in the pharmaceutical industry happening in the supplements area. This is just to give you an example of what can happen. Helke Ferrie is a medical science writer, and she went to Germany a few years ago to attend to her mother and went to the local pharmacy store to get vitamin C. The pharmacist, who the family had known for 25 years, offered her 12 tablets of 10 milligrams each of synthetic vitamin C for $10. I take 12 grams of Vitamin C.... that would technically cost $1,000 a day (if we follow the Germany model).

Now, I take a large quantity of vitamin C personally. I take 12 grams of vitamin C daily, and it's natural vitamin C and that's 100 times the dosage she got. That would technically cost me $1,000 a day. In fact, the actual cost to me is 30 cents a day. Germany has been under the pharmaceutical drug model for supplements for many years, and that's what happens to cost.

A report prepared by the Canadian government to investigate the costs of regulating dietary supplements in 1994 and also another report 10 years later indicated that most manufacturers would have to give up about a third of their product line, so about 20,000 supplements would disappearfrom being accessible to our citizens in Canada. They also said-which is astonishing-80 percent of small to medium-sized manufacturers and retailers would disappear. Well, why are they attempting to destroy business in Canada? Why aren't they focusing on areas where we do have some reasonable foothold, in the organic foods market or in the herbal development markets?

Although Health Canada indicates that their standards of evidence program with respect to safety and efficacy for natural health products is flexible and that they will accept current research, we don't believe there's evidence at all to support this kind of program. There are no bodies in the streets. As we've heard here, there is little relative risk from using supplements, and I think that's what we have to focus on. There are eight times more deaths caused by honeybee stings than there are by using supplements.

HANS Recommendations:

There should be a moratorium established immediately on the program going through the standards of evidence for natural health products, and that the Minister of Health should be advised to cease this program.

Reintroduction of supplements should occur. How should this happen? First of all, a number of supplements have been removed that people have relied on to deal with pain and for maintenance and indeed survival. There probably should be an independent committee that can review the supplements that have been removed and, if it's appropriate, recommend reintroduction.

Yes, the nutraceuticals and functional foods industry is big. It's growing rapidly and is very likely needed. There's such a difference between nutraceuticals and
functional foods that they should be separated from dietary supplements. The NHP Directorate should in fact be refocused on the area of nutraceuticals and functional foods, and dietary supplements should remain in the food category.

Supplements should be regulated as food. They have a long history of safety. There have not been any measurable deaths that are meaningful in the food category. It aligns with the DSHEA in the U.S. If Bill C-420 had been approved, this would likely have been solved. But it was not approved.

Finally, on claims for supplements, supplements that have been in the marketplace for a long period of time should be allowed reasonable claims, as they are in the U.S. If companies want to go through an approval process to make claims for new supplements that have not been out for long, we would also agree to that.

We want to say that there are going to be millions of Canadians angry when they realize that they cannot get access to the supplements that they've had access to for many years. They're going to be angry at mainstream media for not reporting it. They're going to be very angry at political members for not protecting their rights. It's critical that access to low-cost supplements remain.

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