Health Canada and Canadian Tobacco Manufacturer’s Council meeting: Proposed amendments to the Tobacco Reporting Regulations – August 30 and September 15, 2017
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Proposed amendments to the Tobacco Reporting Regulations (TRR)
August 30, 2017 and September 15, 2017 (Teleconferences)
Health Canada (SC)
- Denis Choinière
- Director, Tobacco Products Regulatory Office, Tobacco Control Directorate (TCD) (Chair)
- Acting Manager, Reports Control Division (TCD)
- Scientific Regulations Policy Analyst, Regulations Division (TCD)
Canadian Tobacco Manufacturer’s Council Technical Committee (CTMC TC)
- Paisley Cameron
- JTI-Macdonald Corp. (JTI)
- Richard Voisine
- Imperial Tobacco Canada (IT Can)
- Steve Chapman
- Rothmans, Benson & Hedges Inc. (RBH)
The initial meeting on August 30 was held at the request of the CTMC TC to further discuss the comments that it provided in response to the proposed amendments to the TRR that were pre-published in the Canada Gazette, Part I, on Saturday, May 27, 2017.
The Chair opened the meeting by doing round table introductions.
HC reiterated its international obligation to protect tobacco control policies from the vested interests of the tobacco industry. In addition, in the interest of transparency, the department stated that it would be making a record of the meeting publicly available.
Tobacco Reporting Regulations: Report on Manufacturing
CTMC TC confirmed that the purpose of the meeting was to discuss the comments it provided on the TRR, specifically with respect to section 10(1). The proposed regulations would require that the Report on Manufacturing include the manufacturing processes for each consumer tobacco product that a manufacturer sells, as well as for any cigarette papers, filters or mouth tips used in the manufacture of those consumer tobacco products. CTMC TC indicated that the manufacturing processes for the individual components used in the manufacture of its tobacco products are supplied by external suppliers and are not available to the manufacturers as suppliers consider them to be trade secrets.
CTMC TC proposed that the requirements in section 10(3)(c) of the TRR be modified from “if available, an engineering drawing of the product” to requiring a diagram of the consumer tobacco product. The diagram would be an image of the product that is cut open and depicts all the components, including their positioning within the tobacco product.
The Chair asked about the difference between a diagram and an engineering drawing. CTMC TC responded that, engineering drawings are full-scale and includes all the dimensions. CTMC TC does not have engineering drawings for the specific components that are supplied by external suppliers.
HC indicated that the proposed diagram would not provide an adequate understanding of new products and innovations within existing products. For example, in the case of a complex tobacco product where there are multiple ingredients, the diagram would not be sufficient to understand the product. The department seeks to fully understand how the raw materials are assembled into the product.
The participants discussed the feasibility of providing functional specifications in combination with the diagram, in order to provide the level of details sought by HC.
CTMC TC representatives wanted to discuss the issues among themselves before providing a final response to HC. This response will be provided to the Acting Manager, Reports Control Division.
HC reiterated that the information would need to be provided in a manner that facilitates understanding of how the ingredients are used in the manufacture of tobacco products as provided in section 11 of the TRR.
September 15, 2017
At the second meeting held on September 15, 2017, CTMC TC submitted a proposal to replace the requirements of section 10(1) for third-party-supplied components with a diagram of the tobacco product that depicts the components, including the link between the components, the ingredients and the specifications. The image would represent what can be seen when the component is sliced in two (transversal view).
HC responded that it would consider this proposal as along with the others that had been submitted to the department.
HC updated CTMC TC regarding the release of the vaping products consultation document. The department indicated that there could be changes to the TRR with respect to the new authorities in Bill S-5.
CTMC TC indicated that the comment period should be at least 60 days for changes to the TRR that are technical.
CTMC TC also asked for an update on their proposal to amend the testing requirements of section 14 (number of samples). HC indicated that a statistician is looking at this request.
The meetings were then concluded.
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