Health Canada’s recently published Instrument Choice Framework for the Canada Consumer Product Safety Act represents a missed opportunity that fails to take advantage of international guidance or existing models, according to a Consumers Council of Canada’s submission to the ministry.

The Council recommends a 2015 publication Consumer Product System Safety – Identifying and Managing Risk as a comprehensive and informative document that explains in just a few slides the entire U.S. Consumer Product Safety Commission’s product hazard prevention strategies, including its instrument choice framework.

That publication is “readable, understandable, informative and helpful for business and consumers,” according to the Council’s submission, while the Health Canada document is “a smorgasbord of instruments available to Health Canada to mitigate risk, but no details on how those instruments will be employed,” and “replete with risk management jargon that is unhelpful to the reader.” As a result, it fails at its stated intent to provide clarity and transparency.

The Council’s paper notes that Health Canada often distinguishes consumers from stakeholders, when consumers are the primary victims of unsafe consumer products and the sole intended beneficiaries of the legislation.

Health Canada pledges to carry out its consumer product safety program while supporting a fair, safe and competitive economy and “…examining the potential impacts on economic growth, entrepreneurship and innovation for the benefit of Canadians and businesses.” The Council questions the lack of details in how consumer safety and the economic viability of suppliers will be weighted and urged Health Canada to send stronger signals “that consumer health and safety standards will not be compromised or lowered in the rush to accommodate business or government innovation agendas.”

The Council also noted that effective stakeholder engagement does not appear to factor into the instrument framework, and that consumers and organizations that represent them would have considerable expertise to enhance the consumer product safety compliance program.

The Council’s submission Missed Opportunities is available for purchase/download in the online store.