URGENT ACTION!!! new Harper cash grab threatens small health businesses

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Boy they are just bound and determined!!!! Please pass on!!! Even if you aren't Canadian you can register your concern about this attack on health!! ************************************************* bobmccandlessTo: bobmccandlessSubject: FW: Outrageous cash grab by Harper GovernmentFri, 18 May 2007 19:02:43 -0700 The "COST RECOVERY PROGRAM" seems to be a cash grab by the Harper Government that will put small manufacturers like us out of business. We now pay Health Canada thousands of dollars a year in application fees. They want to raise the fees, plus add new"license fees" of $940 per product

- almost HALF A MILLION DOLLARS PER YEAR! Maybe we could pay these fees by doubling or tripling our prices. But this will cause extreme hardship for most of our customers, who pay for these products out of their own pockets.We believe preventative medicine saves Canada's Healthcare system millions of dollars a year. Canadian consumers want natural health products to be available at reasonable prices to all, including low-income families and seniors.If the Government insists on creating higher prices under the Cost Recovery Program, many small manufacturers (including us) will be out of business by Christmas!Please join us in protesting these outrageous fees. Details below. Robert McCandless, Master Herbalist, Clinical Herbal Therapist Vancouver ---------------------Gaia Garden Herbals2672 West BroadwayVancouver, BC V6K 2G3May 14, 2007Project Manager, Cost Recovery Initiative SecretariatHealth Products and Foods BranchBuilding #7, Tunney’s PasturePostal Locator: 0701B, Office 1110Ottawa, OntarioK1A 0K9Dear Sir or Madam,We are a small, Vancouver-based herbal remedy manufacturer and retailer that serves a wide range of local consumers with safe and natural preventive medicine. We have stores in Kitsilano and Granville Island and are a prime example of the type of company that would be instantly put out of business if Health Canada's exorbitant annual licensing fees come in to

effect (that's not even considering the even more expensive initial fees that have been proposed in regards to filing a NHP application). As a result, we have begun educating our customers about the ramifications of the cost recovery framework and we have also begun collecting a petition to voice dissatisfaction with Health Canada’s proposal that is shared by the natural health product consumers we serve.Perhaps the most trying aspect of this situation for us has been our willingness to register all of our products with the NHP program since the regulations were first proposed. We're in favour of sound regulations that protect natural health product consumers and believe that we have an organization that is an industry leader in terms of safe and quality controlled herbal remedies. Yet at no point since we began this process as willing participants has the Natural Health Directorate ever shown an ability to either

consistently process our NHP submissions (they are years away from even beginning to process products with multiple ingredients) or even enforce a single guideline that they've mandated. As a result, our efforts to cooperate with Health Canada have compromised us worse than companies who have simply dug their head into the sand. We have devoted much of our resources towards making accurate NHP applications and yet if the entire program turns into a complete boondoggle that has to be put down (similar to the federal gun registry scenario) we will be at a competitive disadvantage to natural health companies that simply ignored Health Canada and/or failed to ensure the safety and efficacy of their products. In other words, we will be hurt whether the NHP program continues (exorbitant fees) or is terminated (waste of resources)--and yet we are a company that

diligently attempted to comply with regulations!In a sense, the cost recovery framework really is a silent killer that the directorate has levied against the industry. The actual application process is resource intensive, however the sheer scope of the capital and annual costs involved in the proposed framework will put our 18 employees out of a job overnight. For the sake of argument, even if we tried to stay in business, every single product that we manufacture-and we make small batches of over 1000 distinct remedies--would cost at least double the current price at which they currently retail. Our consumers would never be able to handle this strain and our sales would utterly collapse. The cost recovery framework appears to be a poorly planned, ad-hoc scheme for a regulatory initiative that also seems to have been poorly planned and ad hoc since

the beginning.Please accept our comments and feedback as a genuine indication of the crisis that Health Canada has created for the natural health community.Sincerely,Gaia Garden Staff

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