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To: IAHF List
Subject: Canada to Harmonize Vitamin Regs to Australia? Trueman Tuck Warns Chretien of Political Timebomb
From: "IAHF.COM"
Date: 19 Jun 2003 01:26:01 -0000

IAHF List: Please read the letter (below my comments) from Canadian health food store owner and activist Trueman Tuck of Friends of Freedom to Prime Minister Chretien.

Canada was scheduled to gazette new regs today which would harmonize their vitamin laws to Australia's (where over 1600 dietary supplements were wrongly removed from the shelves under false pretenses this summer.)

Canada's effort to do this will constitute a POLITICAL TIME BOMB, Tuck warns. He reminds Prime Minister Chretien that 3 lawsuits are already pending against Health Canada over this and that a huge groundwell of support behind C-420 threatens to drive the current health minister from office and really hurt the ruling Liberal Party at the polls in the coming election.

The Canadian situation underscores my urgent global alert: we MUST monkeywrench the Cartel's global takeover plans by donating to the Alliance for Natural Health's lawsuit to overturn the EU's Food Supplement Directive. Do that via

Americans in particular take note: We can't ignore what is happening on our northern flank in Canada- we're seeing an effort to isolate us in the world and take us last via the mechanisms of globalization. The best way to arrest this global process of harmonization is to help ANH launch their lawsuit to overturn the EU FSD due to how it threatens to impact Codex, which in turn would impact the planet. If you haven't already read my article on this see it at


From: "Trueman Tuck"
To: "Marjory Loveys"
Subject: Urgent - grassroots' briefing from Trueman Tuck as promised for the Prime Minister's immediate attention
Date: Mon, 16 Jun 2003 20:04:41 -0400

PMO's Office
Health Desk

Attention Marjory Loveys:

Thank you for speaking with me last week.

I was very shocked that you were not aware of the ground swell of anger from grassroots' citizens concerning the total sell out and betrayal occurring with the PHARMACARTEL controlled Health Canada officials that has been brewing since Gazette 1 came out in December 2001, and Kava Kava was needlessly removed instantly and totally from the Canadian market in August 2002.

As we discussed, our organizations representing literally millions of Canadians, organized the largest grassroots protest in Canadian history in 1997 and 1998 over these same issues. One of our coalition partners - Freedom of Choice in Health Care submitted a 250,000-name petition in 1998 saying, Our foods are not drugs.

In our new 2003 coalition campaign we have already collected and had filed with the House, 100,000 signatures in May and June alone, with more pending and a summer of campaigning ahead of us.

Our target is 500,000 petitions supporting "OUR FOODS ARE NOT DRUGS" regulatory regime via new legislation [see Bill C-420 which was drafted by our permanent Health Freedom Legal Defense Team].

The details are on the Friends of Freedom website at - see especially the MAIN MENU - top left - Health Freedom Action Campaign downloads - HC regulatory history.

There are currently three lawsuits filed and pending one on June 26, 1997 being brought back first court date June 20, 2003, another filed May 29, 2003, and another filed June 12, 2003 all of which our permanent legal team are assisting in.

Unless Gazette 2 is stopped, and our groups are Let Inside as concerned stakeholders to help design Appropriate Legislative Renewal several other complementary suits are planned as well.

Gazette 1 is a complete betrayal of all recommendations and promises and must be stopped this week. It is also legally outside the delegated authority of the Governor General to implement under the 1920 drafted Food and Drugs Act, made law in 1927, amended in 1934, and last before Parliament in 1952.

There have been over 400 pages added by questionable regulatory delegation to this 20 page 1952 legislation. This was commented on in the introduction of the 1998 Standing Committee Report see our referenced section of our website for copy.

Even DINs are legally questionable, as is most current Food and Drugs policy and regulations.

Our groups finally met with Heather Watson from the Ministers office, after over 8 months of being refused any meeting, on May 29, 2003. We calmly, professionally, and with full documentation, presented our case for stopping the drug-style third category regulations that will actually make some 60,000 very safe, and affordable food-based, non-drug medicines "DRUGS' subject to equal or greater control than deadly and dangerous synthetic prescription drugs.

You had asked me for a briefing on the major issues that several million concerned Canadians have with Gazette 1, and the just released Gazette # 2, that the PHARMACARTEL INTERESTS IN HEALTH CANADA ARE TRYING TO FORCE INTO LAW THIS COMING WEDNESDAY, JUNE 18, 2003.


In general, the concerns that our groups, (including the millions of citizens and countless industry members whos views we represent), have regarding the upcoming NHPD regulations, (Gazette 2 poised for imminent release), include the following:

A partial list of potential problems and pitfalls of the new Natural Health Products Regulations:


In general, the concerns that our groups, (including the millions of citizens and countless industry members whos views we represent), have regarding the upcoming NHPD regulations, (Gazette 2 poised for imminent release), include the following:

FACT 1: The new Natural Health Products regulations have taken a much different course than that which was set out for them by the Standing Committee on Health and the Transition Team. In the Transition Teams final report document, which was signed-off on by the Minister of Health, a process of Legislative Renewal was stated to be unavoidable if the recommendations of these groups were to be achieved, [ref: live]. This means that a new Act separate from the Food and Drugs Act would be necessaryto achieve a true third category for Natural Health Products, (NHPs),separate from either foods or drugs.

CONCERNS: In the process that has taken place over the past five years, Health Canada has refused to engage in a process of Legislative Renewal, instead opting for a separate directorate and regulatory framework in which NHPs are classified as a subset of drugs, (all of which are subject to restriction using the devices of Schedule A, Sections 3(1), 3(2), and Schedule F, [see below]). In this light, the current regulatory proposals are in contempt of Parliament. They seem to be following a much different agenda than that prescribed for them, and have not even come close, to protecting the rights of Canadians to freely access NHPs of their choice.

FACT 2: The regulations maintain complete power to arbitrarily restrict any given NHP by blocking its sale, and/or make it available by prescription only [ref: Section 96, Gazette 1, entitled: Prescription Natural Health Products]. Health Canada has refused to implement the Transition Teams recommendations to revoke sections 3(1), 3(2) and Schedule A of the Food and Drugs Act dealing with disease claims.

CONCERNS: The regulations reserve the right of the Minister to issue a direction to stop sale of any product, [ref: Section 15], suspend or cancel any given product license, [ref: Section 16], and/or suspend a product license before giving the licensee an opportunity to be heard, [ref: Section 17], all based on the Minister having reasonable grounds to believe that a Natural Health Product may no longer be safe. The critical words here are believe and may. Human history is replete with examples of horrendous acts and tyranny carried out under the pretense of belief; and may automatically implies may not. In these Sections it is not even mentioned that this belief has to be supported by reasonable and adequate evidence and that this evidence must be presented prior to a restrictive action.

Furthermore there are no mechanisms in the regulations providing for accountability of the department officials administering them. If an official had the intention, these clauses could be dramatically abused. Given that the HPB over the last 25 years has continually demonstrated its bias against, and its will to suppress the Natural Health industry, wording such as this is of grave concern.

Additionally, given that NHPs under these regulations will be forced to state a claim on their labels, it is of great concern that Health Canada has refused to delete Sections 3(1), 3(2), and Schedule dealing with disease claims. This creates a huge gray zone in terms of which claims will be considered structure function, and which will be considered disease claims. Health Canadas dramatic inconsistencies dealing with such issues in the past may mean that a claim acceptable today may not be tomorrow, and provides another mechanism by which products may be restricted or blocked from market. Furthermore, in some instances natural products have been extremely well scientifically validated, (as stated in the Transition Team report [ref: live]), to be effective in mitigating disease.

FACT 3: The three criteria that were stated by the Natural Health Product Directorate to have been continually asked for by Canadians as consultations took place, and hence, three of their main stated objectives for the regulations were that (1) first and foremost, Canadians wanted increased access to a wider range of NHPs including many that are available in the United States, but restricted for sale in Canada, (2) they wanted assurance that what was on the label was in the bottle, (3) they wanted more information on the label regarding what the product was for. To achieve these objectives the regulations will mandate that every NHP make a claim, which is to be supported, must pass through a Standards of Evidence Procedure. [Ref: Standards of Evidence Draft Document; live], and then appear on an approved label for that product.

CONCERNS: The regulations are attempting to implement standards, which are inappropriately rigorous for NHPs. They fail to acknowledge the long-standing safety and low risk of NHPs, (fully acknowledged by the Standing Committee on Health), and insist on the continued application of a pharmaceutical drug model of regulation. Moreover, the Standards of Evidence Procedure can easily be abused to block a product access to market if that is the will of the officials administering it. NHPs are once again being made to justify their existence, when their longstanding safe usage should be justification enough. NHPs are once again being treated like drugs when the entire point of the third category was to differentiate the two. If this wasnt acceptable to the public when they protested in 1997, why is it acceptable now?

Fears regarding inferior and/or dangerous NHPs that do not meet their label claims are largely unsubstantiated by actual examples. A huge majority of Canadian NHP suppliers already strictly follow Good Manufacturing Practices and the last death attributed to an NHP in Canada occurred in the 1950s, (administered by a physician). There is a much better method of ensuring public safety without over regulating, (see: The Natural Health Industry Wants Appropriate Regulations document).

FACT 4: Due to labeling and claim requirements, once these regulations are enforced strictly, they will be a barrier to the import of countless products from the U.S. and abroad.

CONCERNS: This may include products that Canadians have been safely using for decades and are perfectly happy with. The regulations do not take such citizens into account. Aspects such as this meant that instead of protecting Canadians rights to access NHPs of their choosing, the regulations seriously threaten this right. Given the regulatory history of the Health Protection Branch, as written, the regulations will almost surely result in decreased, not increased, access to NHPs.

FACT 5: The regulations requirements are not financially feasible for many small to medium sized producers of NHPs, whose companies would be seriously destroyed.

CONCERNS: There is a much more effective method of achieving the above stated objectives without shutting down small manufacturers, and/or employing methods which can be applied in a biased manner, (see The Natural Health Industry Wants Appropriate Regulations document).

FACT 6: The regulations demonstrate a failure to consider crossover effects into and from other legislation. i.e. GST, Income Tax act, Excise Act, Canada Health Act, etc.

CONCERNS: For example, due to these regulations, GST has been charged retroactively, back to 1998, to companies based on the claim by CCRA that due to the new definition of a Natural Health Product, (i.e. acting on legislation that has not even been passed yet), these companies should have been charging GST on a wide variety of products, [ref: CCRA document P-240].

Given their regulatory history, and the involvement of an immensely powerful drug lobby, the Health Protection Branch cannot be trusted to administer the new regulations fairly. Despite the verbal assurances of well-meaning NHPD officials, the words that are written on paper in Gazette 1 mean that if these regulations are at any point administered by officials with a bias against NHPs it could mean the end of the industry as it now exists.

The regulations, take a market in Canada with approximately 60,000 food-based, non-drug medicines that should be if the promises made in 1998 were kept somewhere over 75,000 products without decades of unnecessary HEALTH CANADA interference, and take everything off the market unless site and product is properly licensed by the PHARMACARTEL DRIVEN Health Canada officials.

The 1994 DSHEA in the US was the leading edge "Food-based, non-drug medicines act in the world. Its weakness was GMP which we all want "appropriate GMP" in our new Canadian legislation. Unlike the drug style regulatory third category DSHEA grand fathered every existing safe product into the new regulatory regime.


Health Canada admits that only 10,000 of the 60,000 NHP's [more properly called food-based, non-drug medicines] have DIN's now. Health Canada also admits that hundreds of small and medium wholesalers and manufacturers in Canada, and outside Canada will not be able to afford to make the transition.

It is also fact, which in the early 1990s when the Modern Medical Investment Interests were successful with drug style regulatory regime in Australia over 30% of independent health food stores was put out of business in the next few years. This really pleased the mass-market grocery and drug store, and the chain health food retailers.

There has been no effort to truly implement what non-trade associations requested. Public interest is not in anyway being properly incorporated into the new regulatory regime. Legal issues constitutionally are also being ignored, as well as the need to fully integrate Modern medicine with Traditional Health Care.

These regulations are not delivering what the involved parliamentary groups prescribed, and seem to be following a much different agenda. As a result, if these regulations proceed as written, Canadians will in due time not have their unfettered access to NHPs as promised to them by the Government of Canada.

Politically, this is a time bomb, that will be very dangerous to any politician that chooses Bottom line support of Modern Medical Investment Interests over that of the good health and well-being of Canadian voters. If Gazette 2 is published the attached E-Protests [they are addressed to me as an insert in the federal MP list to obtain copies] will grow into over 1,000,000 very upset citizens literally chasing every MP in their riding all summer.

Every MP received a personally addressed copy of these, and this is just via the website.

Our coalition is expanding exponentially daily. Also, go to our website scroll down on the left side and click on TRUEHOPE VS HEALTH CANADA for one of many stories that we are assembling and posting.

There will be several new websites dedicated to what the PHARMACARTEL driven Health Canada officials have been doing since the PHARMACARTEL 1934 Food and Drugs Act Amendment was passed [see copy on our website]. Attached is an industry brief save our Industry for your information as well.

I will call you tomorrow morning as a follow-up.


Thank you for listening.

Trueman Tuck
National Coordinator

Friends of Freedom
Freedom of Choice in Healthcare
The Canadian Coalition for Health Freedom

International Advocates for Health Freedom
POB 10632 Blacksburg VA 24062 USA;
800-333-2553 N.America
540-961-0476 World