Veterinary Health Products
What is the VHP?
The VHP (Veterinary Health Product) program is a section of Health Canada and the Veterinary Drugs Directorate that regulates natural health products in pets. VHP’s contain ingredients such as vitamins and minerals, botanicals, traditional medicines and homeopathic medicines with a history of safe use. There is a list of acceptable ingredients that companies can use to make their products. You can also get ingredients added to this list if they are deemed safe. These products are only meant to maintain or promote health and welfare of animals, not for treating, preventing, or curing disease.
Why was the VHP created?
This program was created because the government wanted to prevent natural antibiotics creating super bugs in animals that would then infect humans. This is emphasized on their website since the entire VHP program is a subcategory of Antibiotic Resistance in Animals on Canada.ca. One of the main products they targeted is Colloidal Silver, which has been shown to hinder antimicrobial resistance when paired with prescription antibiotics.
Is the VHP in place to protect my animal?
Not necessarily. The guidelines they set up are based on ingredients containing toxins and being safe to use. However, most of these ingredients are looked at from a safety to humans, not to pets. For example, there are many ingredients that are approved that are toxic to animals but are on the approved list of ingredients because they pose no threat to humans. The main goal of the program is to make sure there are no products that will create supper bugs to infect people.
What purpose does the VHP serve?
The purpose of the VHP program is to limit what a small company can put in a product and on a label. A company is not allowed to make a therapeutic claim, such as it will fix a disease. However, companies must state on their label what a product does to avoid customers misinterpreting the function of the supplement. This is as contradictory as it sounds.
When did the VHP program come into effect?
From 2012 to 2017, there was an Interim Pilot Program for the VHP program designed to finalize how the program was going to operate. A few larger companies were involved in this, leaving smaller companies at a disadvantage since those in this interim program were given a larger grace period after the VHP program was launched. In November 2017, the program was launched, and companies could begin registering their products and ingredients. It was not enforced (unregistered products taken off the market) until May 2018, which means there was a 6-month grace period given for products to be registered and legal. However, this was not enough time since the Veterinary Drug Directorate was ill-equipped to deal with the vast amount of applications they were going to receive and did not advertise the existence of the program adequately. There are still many companies that are not aware of these new laws governing natural health products for pets.
Who is in charge of the VHP?
The person in charge of the VHP is the Veterinary Drug Directorate of Health and Safety, Manisha Mehrotra. This entire program is run by veterinarians. This is concerning since natural medicine is not part of a typical veterinarian’s education and on several occasions they have stated that they do not understand how some of the ingredients they monitor work. The Veterinary Drug Directorate monitoring drugs makes sense to have veterinarians employed since they are extensively trained on pharmaceuticals, but nutraceuticals are completely different.
How does a product get a VHP approval?
In order to get a product approved as a VHP, companies must comply with Good Manufacturing Processes (GMP) set out by Health Canada. Next you fill out an application online and fill in the ingredients that are in your product. The only ingredients allowed are those listed in their Permissible Ingredients. From the time you submit it to the time of approval can take anywhere from a week to over a month. Products must be notified and registered 30 days before selling them. Even if all fields in the form are filled out, it is up to the person reviewing the product at the VHP to decide if it passes. This causes confusion and inconsistencies since standards differ from person to person. One application may be approved by one employee, and not by another.
How does an ingredient get VHP approval?
Ingredients are a little trickier. In order to get an ingredient approved you must fill out their online application for new ingredients. On this form it asks about the safety (not about the efficacy or intended use) of a substance, as well as its history of use in modern and ancient medicine. Ingredient applications are extensive and can take several days to fill out thoroughly. However, for it to become approved can take over a year! This means that businesses, especially small businesses, that have a natural product and finds out about the VHP program that needs to get an ingredient registered can easily go out of business before their application is even looked at. It’s scary to wrap your head around what that implies. Imagine selling a product for years, you have done the research and you know it is safe. You find out about the VHP program and must stop selling until your ingredients are approved. Are you able to go an entire year without selling? Because this program takes such an extended period of time it puts businesses at risk.
Does VHP approval mean a product is safe?
No, not necessarily, for two reason. One reason is that even though you are required to comply with GMP standards and test your products regularly for safety, this is rarely, if ever, ensured. The Veterinary Drugs Directorate does not have the appropriate number of employees in the VHP program to cover facility inspections. The second reason is that many of the ingredients on the VHP list are not safe in certain doses, and since they don’t inspect products, the level of ingredients, and ingredients themselves could be at unsafe levels. For example, arsenic is on the approved list, which in any dose is not safe. Grapes are also on the approved list an contain a compound in their skin that is toxic to dogs, as well as chrysanthemums.
Does VHP approval mean a product is effective?
No, it does not. Effectiveness is not tested. In addition, the rules of the program state that labels cannot make therapeutic claims. Therefore, even if a product is effective you cannot clearly say what a product does. The goal is to make general statements about health and well-being so that customers cannot inference a therapeutic claim on accident. This very much limits what can be allowed as a product as far as variety and customers may not know what a product does due to labels being too vague.
What changes need to be made to the VHP?
Due to inconsistencies in application submissions and approvals/denials, the program needs to be more automated, and less up to the opinion of the person reading the application. There also needs to be more people employed dedicated to the VHP program. The applications for products and ingredients take far too long, especially for small businesses that rely on these products for immediate income. Also, there needs to be a wider range of professionals hired to cover a larger variety of knowledge, such as nutrition, homeopathic medicine, botanicals, chemistry, and biochemistry. In addition, the rules need to be altered so that the manufacturer can tell the customer what a product does.
Who can make these changes?
The government and the Veterinary Drugs Directorate (Dr. Mehrotra) are the only ones who can make changes to this program. You are encouraged to contact Dr. Mehrotra (613-941-8775) and your local Member of Parliament to motivate change in this program to better the VHP program in order to help our pets.