The Canadian Health Coalition is dedicated to preserving and enhancing Canada’s public health system for the benefit of all Canadians.

Founded in 1979, the coalition includes groups representing unions, seniors, women, students, consumers and health care professionals across Canada.

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"Public relations is not the answer.
Your job is to protect human health.
We can begin to trust you
if you begin to look after human health
and let industry look after industry."
-Hon. Mira Spivak, Senate of Canada, to David Dodge, May 13, 1999

Open letter to Health Minister Allan Rock

The Honourable Allan Rock,
Minister of Health,
Tunney's Pasture,
Ottawa, K1A 0L2

June 1st 1999

Dear Minister Rock,

Re: Duty to Protect Food and Drug Safety

1. As you know, the Canadian Health Coalition (CHC) was represented at a meeting in your Office convened by your senior policy advisor, John Dossetor, April 19, 1999, to discuss your department's proposal to create a consumer affairs office in the Health Protection Branch (HPB).
   
   
2. Participants of the April 19th meeting were assured by both Mr. Dossetor and the Assistant Deputy Minister, Dr. Joe Losos, that no action would be taken in advance of significant changes to the proposal. A revised proposal was to be circulated to the organization representatives attending the meeting. Participants from the CHC, the Canadian Women's Health Network, the Canadian Association of Physicians for the Environment, and the Alliance for Public Accountability agreed that a clear statement of the statutory health protection duties of the Minister of Health and a report on how the Department discharges these duties was required, before discussing a potential extra role for an office of citizen affairs. Mr. Dossetor said that the concerns raised in the meeting would be passed on to the Minister and that you would convene a second meeting to discuss a modified proposal.
   
   
3. Yet the public statements since then, made in the press and by Deputy Minister Dodge to the Senate Agriculture Committee, signal that you are pressing ahead and we have nothing that tells us that you are planning to re-present the idea before the fact to those attending the April 19th meeting. The May 14th Toronto Star article, ("Health Canada plans office for public gripes,") reports that the new office "is to be established by the fall." We must infer that we were misled. Adequate exposure of your aim and reasons to selected organizations at the April 19th meeting was not critical to your decision to create what Senator Spivak termed a public "relations" office.
   
   
4. Announcing to the public an office for "consumer affairs" to "handle complaints and track concerns" doesn't alter the fact that the Branch-wide function of HPB is to identify health risk, assess it and act under the precautionary principle to protect safety. Viewing Canadians as "consumers" in health matters is logically false and distracts attention from the Branch's statutory obligations. Health Canada's job is to protect health, and to insist that products be demonstrated to be safe before they are approved for use in Canada. This is your legal duty under the Food & Drugs Act.
   
   
5. The Health Coalition, the Senate Agriculture Committee and thousands of Canadians have called for an independent investigation of the Health Protection Branch. What you have offered instead, is an Office of Consumer Affairs and Public Involvement to provide "greater knowledge and understanding of how the system works" as you say in your May 19th News Release. The public already knows too much about how "the system works" by putting profits before lives. We anticipate that the new PR office will serve as an information office to downplay the responsibilities of the Minister and HPB to protect the public, and alert HPB to public anxiety over health disasters which will be placated through "risk communication".
   
   
6. On April 22, 1999, three days after the Health Coalition asked your office to clarify the statutory duties of the Minister of Health and report on how the Department of Health is discharging these duties, you announced together with the Minister of Agriculture and Agri-Food, the tabling of Bill C-80, the Canada Food Safety and Inspection Act. This bill would dismantle the Food & Drugs Act and seriously weaken your capacity to carry out your duties to protect public health. Senior regulators within your own Department have acknowledged that Bill C-80 calls for the Minister of Health to give his food safety compliance, enforcement, and investigation mandate to an agency (the Canadian Food Inspection Agency) that has a policy of non-enforcement, is in the process of eliminating its food inspectors, and is mandated to promote food production and trade.
   
   
7. It was unacceptable to hear your Deputy Minister, David Dodge, acknowledge in his appearance before the Senate Agriculture Committee (May 13, 1999) that Health Canada, in effect, approves food and drug products for use in Canada without knowing if the products are safe or not because there is no chronic health testing. According to Dodge, his departmental duty has been reduced to making use of "the best available science". He adds that: "It may be that in 25 years time we find ...more risk". In other words, Canadians are treated like lab rats in the application over a life time of non-therapeutic substances in an uncontrolled manner without any knowledge of the human or environmental consequences.
   
   
8. Speaking of scientific research, Dodge said, "We have chosen to use the tool of creating intellectual property rights to get the work done, as opposed to having government agencies do it themselves." Presumably, this accounts for the Chrétien government's decision to close agricultural research stations across the country, the Centre for Food and Animal Research, and the Bureau of Drug Research at the Health Protection Branch and many other strategic public research facilities. Dodge said that the research science that tends to get done is "proprietary research as opposed to public research". He told Senators that private "partnerships" will be formed to do the science. Dr. Nancy Olivieri of Toronto's Hospital for Sick Children is living witness to the fact that corporate "partnerships" imperil the integrity of research.
   
   
9. The Deputy Minister's statement that Health Canada can partner with the private sector for science research misrepresents the facts. No private labs in Canada have the multi-disciplinary teams and the legal authority to undertake independent investigative research in food and drug safety and conduct surveillance of problems with commercial products over prolonged periods of time without a financial conflict of interest. Dodge has also said that "the regulatory approach is an old-fashioned way to deal with risk".(Ottawa Citizen, November 21, 1998). As an economist, Mr. Dodge may not realize just how grotesque and dangerous these decisions are, especially coming from a senior public official charged with the legal duty to protect public health.
   
   
10. The Senate Agriculture Committee has sworn testimony that in the case of the rbST drug review, key scientific data was not provided in Monsanto's submission. (Gaps Analysis Report: www.nfu.ca). Instead, it appears that the new management approach outlined by David Dodge is to presume it will be safe because Monsanto says so. Meanwhile, the Canadian government has cut all scientific research in the public interest and has invested hundreds of millions of dollars in promoting genetically engineered food without investing a cent in chronic human health research and environmental assessment. So much for "evidence-based decision making".
    
    
11. If Canada still has "one of the world's safest food systems", as you purported in your May 19th News Release on the Office of Consumer Affairs, why is there a European ban on Canadian beef laced with hormones that may cause cancer? The European Union has released scientific evidence that drugs approved for use in Canadian cattle have inherent risks of causing cancer. There is also evidence that these dangerous drugs are used in Canada in an abusive manner without regulatory controls. The report of the Scientific Committee on Veterinary Measures relating to Public Health also states that: "Of the various risk groups, prepubertal children are the group of greatest concern". (http://europa.eu.int/dg24/health/sc/scv/index en.html.)
    
    
12. The Senate Agriculture Committee also heard sworn testimony from a Health Canada drug reviewer in the Human Safety Division of the Bureau of Veterinary Drugs, that Revalor-H, one of the hormones banned in Europe as a carcinogen, was approved by managers who over-ruled the reviewer on the file and her immediate supervisor both of whom raised concerns about human safety. ("Fears over hormone ignored, panel told - Scientists say they were pushed to approve drug later linked to cancer", Globe & Mail, May 4, 1999).
    
    
13. If Canada still has "one of the world's safest food systems", why is there a ban an genetically engineered Canadian canola? The British Medical Association has called for a moratorium on genetically engineered crops until there is a scientific consensus on the health and environment impacts. It insists on a precautionary approach, not 'the best science currently available', because "adverse effects are likely to be irreversible". (www.bma.org.uk/public/science/genmod.htm)
    
    
14. The Canadian government response to these disturbing revelations about the dangers of hormones in our food has been to request WTO authority to retaliate against the European Union (Office of the Minister for International Trade, News Release, May 14, 1999), to continue dismantling the regulatory functions in Canada, and to support the exposure of entire populations to risks that may be irreversible from transgenic crops and cancer causing hormones.
    
    
15. This trade action marks a sea-change in Canadian food policy. As Senator Whelan pointed out, Canada had, at one time, the safest food in the world. That was one of the best ways of exporting food. We could even get a premium price for it because it was the best. Are Canadians expected to feel pride in Canada's new food policy, where instead of producing safe food, we produce and export hormone laced and genetically engineered food that can cause toxic effects, allergic reactions, increased antibiotic resistance, reduced nutritional value, and potentially irreversible environmental damage? And if our European, Latin American or Japanese trading partners try to protect their citizens' health from our questionable food products, we line up with the United States and retaliate.
    
    
16. It is painfully obvious to a growing number of Canadians, including Parliamentarians and members of your government caucus, that the safety of Canadian food comes second to the promotion of industry and product exports. The systematic adulteration of the Canadian food supply with toxins, hormones and genetic engineering - all without a scrap of chronic health research - puts profits before lives. In the end, government collusion in corporate greed will also destroy the Canadian food industry as well as Canada's good name and reputation.
    
    
17. The Canadian Health Coalition will not assist in Health Canada's "transition" from active regulation of health in the public interest to passive regulation in industry's interest. All the evidence indicates that HPB Transition is abdication of regulatory authority (Transition = Abdication, www. Healthcoalition.ca). It is essential that the Minister of Health protect public health, especially with so many others ministers and government agencies protecting industry.
    
    
18. To responsibly arrest the worsening crisis in health protection, the Canadian Health Coalition makes the following recommendations to you and your cabinet colleagues:

Recommendations

1. Recommit to the statutory duty to protect the public from health hazards and fraud in the sale and use of food and drugs. Terminate HPB Transition immediately and strengthen and actively enforce the regulations that accompany the Food & Drugs Act.
   
   
2. Conduct an independent public investigation of Health Canada's failure to perform its duty.
   
   
3. Withdraw Bill C-80 and return responsibility for food safety enforcement, end-product inspections, and investigations of food poisonings to Health Canada.
   
   
4. Declare a cessation of further pollution of food system with genetically manipulated (GM) crops of uncertain safety; label all GM foods; and phase-in a complete ban on GM foods.
   
   
5. Ban the use of growth hormones in meat and the abusive use of antibiotics in agriculture.
   
   
6. Reinvest in government conducted science research in the public interest, especially in- house lab research on food and drug safety and independent, chronic health research and assessment of genetically engineered food.
   
   
7. Prosecute all government and industry officials for wrong-doing, including the withholding of chronic health data.

Sincerely yours,

Michael McBane,
National Co-ordinator
Canadian Health Coalition

cc: Members of the Senate of Canada
Members of the House of Commons of Canada
Office of the Auditor General of Canada
Delegation of the European Commission in Canada