The good news is, that it looks like we are not going to completely lose our ability to get Digestive Enzymes in the new future.
The bad news is that they will still contain a three day warning on them. This doesn’t of course affect me or my patients directly as it also states: “Consult a health care practitioner for use beyond three days” to “For long term use consult a health care practitioner”. We have until May 05 2012 to get comments into the NHPD.
You might remember from earlier blogs, that this short three day use window is due to the fact that some feel that if digestive enzymes are use over three day, they might cause a habit among the user. Unfortunately we are too late for that. I strongly feel this is based on old outdated and false information. This is mostly due to the poor shape of Canadians digestive health. There are 20 million Canadian suffering from digestive problems every year. This is costing Canadians over 18 billion dollars a year. This is bad enough, but poor digestion is starting point for a cascade of more serious health issue.
In the 1970 through 1990, digestive health among Canadian was poor, but not that bad. Now we see extremely poor digestion in over 80% of clients we see for all ages. This is of course especially true of people over 40 years of age. Virtually all elder (over 65 years of age) do not digest his or her food without the use of some form of digestive aid. This ultimate means they need to take some form of Digestive Enzyme for several months, until they can improve their digestion.
As most herbalist, we have created formulas that will rebuild the digestion, so they will not have to take Digestive enzyme forever, but these takes time. The one I most often use is called Stomach Tonic. The dosage is 2 capsule with two meal daily, for 3 – 9 month, or until digestion is improved. During the first 3 to six months, I get them to take the Digestive enzymes (1 – 3 capsules @ each meal, depending on the size and density of the meal), so they can at least get optimal use of the nutrients from their food and supplements. As you can see I get the person to continue for three months after the use of the enzymes with the Stomach Tonic. This usually gets the digestion back on line. Of course curbing things like stress, eating too fast and poor food combination will speed up the process.
The addition of this ‘duration of use’ on the label of all Digestive Enzymes is just the kind of information that confuses the consumer. Of course it can send more people into practitioner offices, but we are already burdened with other more significant related health issues.
If you use Digestive Enzymes, I strongly advise you to write the NHPD before May 05, to register your opinions. If you are a practitioner; this even more important!
I have copied the last BEEP, for your perusal.
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Message Giving Advance Notice to Natural Health Products Stakeholders Regarding Products Containing Enzyme Ingredients and Notification of Consultation The Natural Health Products Directorate (NHPD) will be seeking your feedback on proposed revisions to the enzyme abbreviated labelling standards (AbLS). In September 2011, NHPD published 12 AbLS for enzyme ingredients outlining the minimum documentation requirements and specifications for products containing these enzymes. Since posting the new AbLS, NHPD has been consulting with stakeholders regarding the requirements for products containing enzymes. As a result of these consultations, NHPD has revised the 12 AbLS for enzymes and developed a new Multi-Ingredient Enzyme AbLS. These will be published for a 30-day consultation period. Consultation starts from the time the documents are officially posted on the Health Canada website.
Proposed Revised and New Enzyme Abbreviated Labelling Standards
As always, companies can choose to comply with the AbLS or apply outside the scope of these documents by providing additional evidence to support the safety and efficacy of their products. Revised Enzyme AbLS NHPD is publishing for consultation 12 proposed revised AbLS for amylase, alpha-galactosidase, fruit and stem bromelain, cellulose, chymotrypsin, lactase, lipase, pancreatic enzymes, papain, fungal proteases, and trypsin. The duration of use, unless otherwise stated, has been revised from “Consult a health care practitioner for use beyond three days” to “For long term use consult a health care practitioner”. The AbLS also have a new general claim “Digestive enzyme” New Multi-Ingredient Enzyme AbLS A proposed new Multi-Ingredient Enzyme AbLS which includes pre-cleared information for 25 additional enzyme ingredients. Medicinal Ingredients β-Glucanase, β-1,4-Glucanase, Glucoamylase, Amyloglucosidase, Acid maltase, Hemicellulase, Invertase, Sucrase, Malt diastase, Diastase, Maltase, Pectinase, Xylanase, β-1,3-xylanase, β-1,4-xylanase, Bacterial protease, Neutral protease, Pepsin, Pepsine, Catalase, Phytase, 1-Phytase, 3-Phytase, 4-Phytase, and 6-Phytase.
All comments received during the consultation period will be considered prior to finalizing the pre-cleared information. Once finalized, the pre-cleared information will be made available on the Natural Health Products section of the Health Canada website, and NHPD will work with stakeholders to ensure a smooth transition for their products if required. To ensure minimal market disruption, companies would have a one-year transition period to make changes to their products where required.
How to Get Involved
This consultation will be open for comment for a 30 day period from the time the documents are officially posted on the Health Canada website. Stakeholders will be notified once the consultation period begins.
Respectfully, The Natural Health Products Directorate Health Canada