Taking environmental responsibility

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The Vision in Brief:

Canada's consumer health products industry is seeking to establish regulations to ensure that consumer health products are manufactured, used and disposed of through environmentally responsible processes. When this vision is achieved, Canadians will be confident that substances used in health products have been proven to be safe to both the environment and to human health, and that they can dispose of these products in a manner that is safe to the environment.

Summary:

As Canadians we all want to do what we can to protect our environment. Everyday we see the effects that our day to day life has on the environment and the world that surrounds us. We have increasingly become concerned of not only the safety of the products that we consume but how we dispose of these products.

Consumer Health Products Canada and its members are dedicated to ensuring the good health and safety of Canadians and the environment. Product stewardship is an approach to the production and management of products that addresses the environmental, safety and health issues throughout the lifecycle of a product. Under this approach a company is responsible for its product from manufacture through to disposal.

The consumer health products industry works for the benefit of all Canadians by ensuring that regulatory standards will be put in place so that all substances used in health products sold in Canada are assessed for environmental toxicity and that these regulatory standards are consistent with those of other major regulatory authorities around the world.

At the other end of a product's life, the consumer health products industry is working to ensure that a consistent approach is taken across the country for developing medications return programs. This will ensure that all Canadians, regardless of where they live, will have easy access to places to return unused or expired medications, and be confident that they will be disposed of in an environmentally responsible manner.

The Vision in Detail:

Chemical substances are everywhere around us - in the environment, our food, clothes, and even our bodies. Many of these chemical substances are used to improve the quality of our lives and most of these chemical substances are not harmful to the environment or human health. However, some have the potential to cause harm, in certain doses, and should only be used when the risks are appropriately managed. By taking a product stewardship approach, the consumer health products industry is working to ensure that chemical substances - from manufacture to waste management - are managed properly, thereby significantly reducing future costs associated with such things as water treatment, clean-up of disposal sites, and treating illnesses related to chemical exposure.

With the support of the consumer health products industry, the government has developed a plan that will build on Canada's position as a global leader in the safe management of chemical substances and products. The environmental assessment program evaluates substances that may pose a danger to the environment and to human health via environmental exposure. It will assemble new and evidence-based science to improve the assessment of substances used in products sold in Canada.

While the consumer health products industry supports this initiative, it believes that the regulatory regime that is developed for the environmental assessment of health products must have data requirements that are consistent with those of other regulatory authorities from around the world. Having an environmental assessment regulatory regime that is consistent with other major jurisdictions is necessary to improve the conditions for business in Canada by ensuring a level playing field and a predictable, science-based process.

The consumer health products industry also takes its extended producer responsibilities seriously. CHP Canada members and other companies that manufacture and market consumer health products are contributing funds to offset the cost of the curbside pick-up and recycling of packaging waste associated with their products in BC, Ontario and Quebec. They are also taking responsibility for diverting unused and expired consumer health products away from landfills and waterways and assuming the cost of proper disposal. This in turn also alleviates responsibility on the general taxpayer or local government.

In the mid-1990s, CHP Canada members provided funding to the British Columbia Medications Return Program, the first of its kind in North America. Since 2010, our members have funded other stewardship programs through the Health Products Stewardship Association. These programs are the Manitoba Medications Return Program (2011), the Ontario Medications Return Program (2012) and the Island Medications Return Program in 2015. Industries cover the full costs associated with the collection and safe disposal of unused and expired medications that have been returned to pharmacies in regulated provinces by consumers. The consumer health products industry supports a consistent approach through the development of medications return programs across the country. For more information on stewardship initiatives covering consumer health products, visit www.healthsteward.ca.

The Solution:

CHP Canada believes that environmental assessment regulations should be developed specifically for products that fall under the Food and Drugs Act and that the data requirements be consistent with those of other regulatory authorities from around the world. It is also working to ensure that a consistent approach is taken to the development of medication return programs in all provinces in order to maintain consistency and to provide a convenient and accessible program for all Canadians.

CHP Canada Successes to Date:

  • As one of the founding members, CHP Canada took a lead role in developing the BC Medications Return Program. Since 1997, the program has collected and disposed of over 236,000 tonnes of expired and unused medications.
  • CHP Canada successfully helped to ensure that a process was put in place to have ingredients that have been shown to be safe added to the In Commerce List thereby ensuring those products are able to stay on the market and available to consumers. The List is being finalized and will be rolled out in 2011.
  • The government agreed with CHP Canada that a separate regulatory regime must be developed for the assessment of substances in products regulated by the Food and Drugs Act and it must be consistent with international standards/jurisdictions.

CHP Canada in Action:

  • CHP Canada is currently in discussions with several provincial governments regarding the development of programs to manage medication disposal. It is recommending that the provinces develop programs modeled on the BC Medications Return Program. 
  • The federal government and industry stakeholders (including CHP Canada) are developing recommendations for the various regulatory approaches that may be necessary for assessing the environmental safety of the different product categories regulated under the Food and Drugs Act (i.e., pharmaceuticals, cosmetics, natural health products).
  • The federal government and industry stakeholders (including CHP Canada) are developing proposals regarding the minimum quantities of the substances used in the various categories of health products that would trigger the need to conduct an environmental assessment and what the data requirements would be.