Health Canada is the department of the government of Canada with responsibility for national public health. Through their programs and policies the health of Canadian residents, citizens and visitors are protected. These policies exist to ensure basic standards are achieved. Their goal: to prevent death, to prevent serious injury, to prevent acute and chronic illness or disease, and most likely in that order of priority. This is not a health enhancement policy that aims to fine tune and magnify or improve your state of health – these policies exists to avoid disaster and to prevent bad things from happening.
When researching any product or service it is helpful to know that we’re getting something that is safe. Government mandated policies exist to help achieve this.
Consumers everywhere are being falsely influenced as it relates to the “Health Canada” approved designations. Some manufacturers compete against one another positioning their product as Health Canada approved as a way to qualify themselves as being superior, and more safe (even though a competing product is made of exactly the same components or ingredients). In some instances service providers and resellers may even use this language even though their product or equipment HAS NOT been registered with Health Canada. The Health Canada Approval designation is being used incorrectly and its important to clear up this message and how it is being used to raise doubt, instil fear, and influence you the consumer in your decisions.
The article raises questions and alarm in the language used to talk about what happens to traditional tattoo pigments in the body.
“Tattoo pigments transported to lymph nodes, corpses show”.
At first glance, this is a headline clicker. Anything involving the lymph nodes raises concern and the fact that “corpses” are involved means death has occurred.
The messaging in this headline is a high quality sales tactic aimed at getting you to do two things:
1) click on that headline, spend some time on the website and
2) interact with advertisers.
More important misleading messages happen later in the article:
“‘Cosmetic pigments [or ingredients] are not approved by Health Canada,’ the regulator said in an email to CBC News.”
“‘It is the responsibility of the manufacturer or importer to meet the requirements of the Food and Drugs Act and Cosmetic Regulations, and ensure that the product they are selling is safe. The same requirements apply to tattoo inks containing nanoparticles.'”
There is good reason why Cosmetic Pigments or ingredients are not approved by Health Canada. It is simply not within its mandate. Health Canada does not have a formalized process for the submission of cosmetic tattoo pigments with a review and approval path. Health Canada only gets involved when any prohibited substance is found in anything that involves the health of Canadians. This is an important distinction. Health Canada’s objective is to keep the public alive, and in a state of good health. They do not have ongoing review program that assess every product that enters into the Canadian marketplace in a structured way. They simply set out the rules and guidelines for what products are allowed in terms of their ingredients and enforce those guidelines when a product is not in compliance. Their formalized practices are focused on other areas, namely the approval of pharmaceuticals and medical devices.
Why is this important? Because Health Canada doesn’t approve a wide variety of many things that we use on our body, and this language is used incorrectly to position products and services in the market place. This same language is being used among doctors and aesthetic providers as a means of addressing the competition.
Health Canada is not in the business of approving cosmetic pigments – and to say that something is not “Health Canada approved” does not disqualify it from use, it does not establish its compliance. It’s simply not a part of their approval program or practice.
Some businesses will posture against each other and make claims that: “They’re not using Health Canada approved equipment or products”. When in fact Health Canada is not in the practice of approving these specific products or devices in the practices in which they are being used. It’s a question of relevance, it’s a question of principles. It misleads consumers into a false set of standards and distracts them from other important qualities.
It is important to realize that malpractice and injury can happen even with Health Canada approved devices and ingredients, and even among those professionals with a lifetime of career experience. A Health Canada approval over a device that is used in the wrong way does nothing to protect you the consumer. Health Canada approval is not an inherent and automatic shield of safety.
In this recent article by MacLeans it has been raised that Health Canada is directly funded by the industry that is serves (a difference from how other departments receive their funding) and now has a client service relationship directly with its applicants. This is an important highlight to the Health Canada designation that should be fully considered by consumers.
There are other practical complications with using Health Canada approval terminology in our products. Some high-end leading sun care brands have creams that are NOT Health Canada approved as an SPF. Why? Because Health Canada does not allow dual claims for products. A skincare manufacture cannot advertise a product both as a great moisturizer for breakout skin AND an SPF. They must choose between the two. In some cases manufacturers will choose to register as a cosmetic instead, as the approval path is much easier. It allows a very effective product to service Canadians in an expedited way. As a work-around the manufacture still promotes the SPF ingredients such as Zinc Oxide and Octinoxoate which the public will understand to be used for sun care.
It would therefore be absurd and unfair for the competition to discredit the use of such creams for SPF use, simply because they have not achieved a Health Canada approval certification.
The next time you see a medical or aesthetic professional announce that their service (devices and products) are “Health Canada approved” do have them fully elaborate on what they mean by this point. If this language is to be used to sell you on a service or product then it is important to consider that this may be the wrong service provider.
Using “Health Canada” approved terms to promote our services is a basic standard of care language. It would be my hope that we will all pursue services and products that aim for a much higher standard – not just those that keep us from injury and death. Our clients expect and deserve much better.