Tuesday, 15 March 2011

The C.F'n.I.A.: Part Two

I have one particular story that best describes my dislike for the CFIA.  As mentioned in part one, the CFIA has control over what you can say in regards to product benefits.  They also have the ability to take a product off the market or not renew product registrations if they believe the product exhibits drug or medication type properties. 
In their minds, if a product is used on an animal only a few times, even if it just contains a mixture of different single ingredients, then it must be correcting a metabolic problem.  “Feed” is given over a long period of time not over the short term.  Therefore, any product used for the short term is used to correct a metabolic problem and is therefore a drug…kaboom!...there goes your registration.  Since they don’t oversee drug and medication use, you now have to go through Health Canada to get a drug number attached to your product.  This is both costly and very, very lengthy. 
When we register products with the CFIA we are not allowed to advertise any claims that may exist with the product unless we have demonstrated the results through trials done in Canada.  Trials completed by the manufacturer do no count.  We sell many protein ingredients where we believe the protein quality is high and has improved digestibility over competitive products but we can’t say that without spending a whole bunch of time and money on trial work.  My company is small, we don’t have the resources to complete expensive trial work that larger companies can afford.  It’s a barrier to trade that punishes small business and helps larger companies.
In fact, we can properly register a product in Canada and advertise properly but the CFIA may find that the U.S. manufacturer’s website makes too many claims on the product and they will take it off the market.

My example consists of a product that the CFIA had already registered and they gave it the "OK" for use in Canada.  It was a product used for dairy cows and it was given to them just once after birthing a calf.  Dairy cows can be tricky after calving and do no always eat enough afterwards.  Our product consisted of energy, vitamins and minerals, nothing more.  It simply tied them over until their appetite came back.  Thats how we registered it and promoted it. 

When it came time to re-register the product, the CFIA went onto the U.S. manufacturer's website, who makes a lot more claims on the product than we did, and the CFIA would not re-register it.  They didn't like the claims the company made on their website (from a different country!) and even though they had already registered the product once they said NO to the re-registration and said if we wanted to sell it, we had to consider it a drug and go through Health Canada (which takes years and lots of money).  All the time and money and effort we had spent selling the product was out the window.  Six years later, we still get calls from dairy farmers asking if the product is available.  The producers want it, we want to sell it but a government agency has said we can't trade this product on themarket without going through a ridiculous drug registration process.   
My problem with this mess is two-fold: first it’s a barrier to trade and second it undermines local producers who want to make choices for themselves.  The market can decide so many of these things.
The CFIA, in regulating our ability to advertise and make some claims, has essentially told the rest of the industry that they are not able to take care of themselves.  When we have an ingredient to sell, we distribute the product to feed companies who incorporate the product into the final feed and then they sell it directly to the farmer.  We have to go to the feed company and convince the nutritionist, who is trained for this, that our product performs and will do what it is supposed to do.
Instead the CFIA wants to disallow products from entering the market first before anyone can even try it for its intended purpose.  Why can the market not deal with it and why does the CFIA feel the need to protect consumers?  If I come to a producer with a bag of wheat bran and tell him that it will triple his productivity, the producer will find out for himself if I’m full of it or not.  We don’t need a government agency spending everybody’s tax money for something that can be dealt with easily within the industry itself.
It’s just one instance in this country where government spends our money to protect or serve only a small sample of citizens.  Add this up over a number of industries and you can see how a centralized government can quickly and inefficiently burn up millions of OUR dollars taking care of issues that the average person does not care about.  It’s time to let freedom work.

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