“An Act respecting the control of certain drugs, their precursors and other substances and to amend certain other Acts and repeal the Narcotic Control Act in consequence thereof”

A current, consolidated version of the CDSA, as amended.

These are the current, consolidated regulations of the Food and Drugs Act. Parts G and J regulate controlled drugs and restricted drugs, respectively.

These regulations, formerly aligned with Parts III and IV of the Food and Drugs Act, now apply to the CDSA which repealed Parts III and IV of the Food and Drugs Act when proclaimed in force 14 May 1997 by SI/97-47, below.

These are the current, consolidated regulations that now apply to the CDSA, since its predecessor legislation, the Narcotic Control Act, was repealed when the CDSA was proclaimed in force 14 May 1997 by SI/97-47, below.

These are the current, consolidated Natural Health Products Regulations.

After a decade long track record of failure, and repeated sanctions by the Supreme Court of Canada, Health Canada concedes drug dealing is beyond its core competency and is leaving patients to fend for themselves.

I suppose that’s why their epic fail is deemed an improvement. I’ll leave that for the reader to decide—after you’ve absorbed all 117 pages explaining the proposed improvements. Oh, the price is going up too.

The amendments to the Controlled Drugs and Substances Act made in this act come into force on this date.

“The purpose of this regulatory initiative is to prescribe, by regulation, midwives, nurse practitioners and podiatrists as practitioners under the Controlled Drugs and Substances Act so that they would be authorized to conduct activities (e.g. prescribing, administering and providing) with controlled substances provided they are already authorized to do so within their scope of practice as set out in provincial or territorial legislation or regulation.”

As part of its perfunctory “consultation” charade, Health Canada has this to say to those who “expressed reservations:”

“Some submissions focused on drug control policy issues that are beyond the scope of this regulatory amendment, such as issues pertaining to the effectiveness of criminal sanctions in combating illicit drug use.”

In other words, they don’t care whether this will work, and they don’t care to discuss it. Here is their entire reply to those who objected:

“The reservations included assertions that there is insufficient evidence to support scheduling of MDPV under the CDSA and that reducing access to MDPV would lead to increased use of other, potentially more harmful drugs. Health Canada considers, however, that the growing evidence of health and safety risks associated with this substance warrants the control measures associated with Schedule I to the CDSA.”

Zero evidence, growing or otherwise, is cited. As usual.

The Canadian Drug Policy Coalition submitted this excellent critique. I highly recommend it as an antidote Health Canada’s bumf.

Amendments to the Controlled Drugs and Substances Act made by the Safe Streets and Communities Act are set to come into force on 6 November 2012.

“This notice provides interested stakeholders with the opportunity to provide comments on Health Canada’s intent to add methylenedioxypyrovalerone (MDPV), namely 3,4-methylenedioxypyrovalerone and its salts, derivatives, isomers and analogues and salts of derivatives, isomers and analogues to Schedule I to the Controlled Drugs and Substances Act (CDSA).”

Benzylpiperazine and its salts, isomers and salts of isomers, and Trifluoromethylphenylpiperazine and its salts, isomers and salts of isomers, become Schedule III substances.

ChemSpider lists over 650 isomers of these two substances; are they also now Schedule III substances Health Canada?

The Regulatory Impact Analysis Statement on criminalizing the use of BZP and TFMPP. If you can stomach it, these pious and tiresome exercises are quite telling.

See if you can find a single substantiated fact—not vague conjecture, not shrill jeremiad—but real and compelling justification for criminalizing uncounted Canadians without notice. I seem to have missed it.

Allegedly dispassionate and objective, apparantly yoked and broken, Health Canada has done the Harper Government proud.

The judgement of the Supreme Court of Canada ordering the federal Health Minister to keep Insite, a safe site for injection drug users in Vancouver, BC, alive. Then Health Minister Tony Clement attempted to shutter the facility some years ago, to the dismay of anyone with half a brain and a jot of compassion.

The Court concluded that since Insite had irrefutably saved lives and improved the health of drug users, to close it was a violation of the Charter of Rights and Freedoms, Canada’s highest law. It found Clement’s decision to be “…arbitrary, undermining the very purposes of the CDSA, which include public health and safety. It is also grossly disproportionate.”

Current Health Minister Leona Aglukkaq, after “reviewing” the court order for two full hours, graciously agreed to “comply” with it. Canada’s Prime Minister, the Right Honourable Stephen Harper, found the ruling “disappointing.”

“An Act to enact the Justice for Victims of Terrorism Act and to amend the State Immunity Act, the Criminal Code, the Controlled Drugs and Substances Act, the Corrections and Conditional Release Act, the Youth Criminal Justice Act, the Immigration and Refugee Protection Act and other Acts”

“[The Bill] amends the Controlled Drugs and Substances Act to provide for minimum penalties for serious drug offences, to increase the maximum penalty for cannabis (marihuana) production and to reschedule certain substances from Schedule III to that Act to Schedule I.”

Part 2 of this bill is similar to Bill S-10 which died with the dissolution of the 40th Parliament.

The government has issued this summary of Part 2: Backgrounder: Safe Streets & Communities Act: Increased Penalties for Serious Drug Crime.

Health Canada’s latest attempt to frustrate access to medical marihuana. The title alone deserves an award for shameless partisan politicking. See also the consultation document below.

One of the alleged benficiaries (youth) of the proposed changes to the medical marihuana access regulations (MMAR) isn’t buying Health Canada’s feckless rationale: Canadian Students for Sensible Drug Policy (CSSDP) submission responding to Health Canada’s proposal to “improve” access to medical marihuana.

The statute created when Bill C-475, (below) received Royal Assent. It came into force 24 June 2011

“This enactment amends the Controlled Drugs and Substances Act to prohibit a person from possessing, producing, selling or importing anything knowing it will be used to produce or traffic in Methamphetamine or Ecstasy.” [From the Bill’s summary page.]

This bill received Royal Assent 26 March 2011. See S.C. 2011, c. 14, above.

“This notice provides interested stakeholders with the opportunity to provide comments on Health Canada’s proposal to add Tapentadol (Phenol, 3-[(1R,2R)-3-(dimethylamino)-1-ethyl-2-methylpropyl]-), its salts and its related analogues to Schedule I to the Controlled Drugs and Substances Act (CDSA) and to the schedule to the Narcotic Control Regulations”

“This notice provides interested stakeholders with the opportunity to provide comments on Health Canada’s proposal to add the plant Salvia divinorum (S. divinorum) and its main active ingredient Salvinorin A to Schedule III to the Controlled Drugs and Substances Act (CDSA)”

Health Canada issues regulations to save others being held liable for breaching regulations Health Canada forced upon them when their violation of said regulations is the result of Health Canada being unable to keep up with those very same regulations. These regulation expire after one month in force. I’m not making this up.

The Regulations Prescribing Certain Offences to be Serious Offences now defines several offences under the CDSA as “serious,” with respect to the Criminal Code.

“This enactment amends the Controlled Drugs and Substances Act to provide for minimum penalties for serious drug offences, to increase the maximum penalty for cannabis (marihuana) production and to reschedule certain substances from Schedule III to that Act to Schedule I.”[From the Bill’s summary page.]

This bill is similar to Bill C-15 which almost made it through the previous session—until Prime Minister Harper prorogued parliament and killed the bill. I guess deep down he’s soft on crime.

This bill died when the 40th Parliament was dissolved 26 Mar 2011.

A Legislative Summary of Bill S-10 prepared by the Parliamentary Information and Research Service is available and worth reading.

The government’s forced and belated response when section 54.1 of the Marihuana Medical Access Regulations was declared constitutionally invalid by the British Columbia Supreme Court as of 3 March 2010.

“This enactment amends the Controlled Drugs and Substances Act to prohibit a person from possessing, producing, selling or importing anything knowing it will be used to produce or traffick in Methamphetamine or Ecstasy.” [From the Bill’s summary page.]

This bill died when the 40th parliament was prorogued 30 Dec 2009.

The government’s forced and belated response when subsection 41(b.1) of the Marihuana Medical Access Regulations was declared constitutionally invalid by the Federal Court and the Federal Court of Appeal as of 23 April 2009.

“This enactment amends the Controlled Drugs and Substances Act to provide for minimum penalties for serious drug offences, to increase the maximum penalty for cannabis (marihuana) production and to reschedule certain substances from Schedule III to that Act to Schedule I.”[From the Bill’s summary page.]

This bill is similar to Bill C-26, tabled but not passed in the previous parliament. This bill passed both the house and the senate (with amendments). But it was all for naught; the bill was doomed when the 2nd Session of the 40th Parliament was prorogued 30 Dec 2009.

“This notice provides interested stakeholders with the opportunity to provide preliminary comments on Health Canada’s proposal to add a series of benzyl/phenyl piperazine derivatives to the schedules to the Controlled Drugs and Substances Act (CDSA), and to identify themselves for inclusion in any future consultation.”

The substances under consideration are

• 1-(Phenylmethyl)piperazine (BZP) and its salts
• 1-Methyl-4-(phenylmethyl)piperazine (MBZP) and its salts
• 1,4-Bis(phenylmethyl)piperazine (DBZP) and its salts
• 1-(1,3-Benzodioxol-5-methyl)piperazine (MDBZP) and its salts
• 1-(3-Trifluoromethylphenyl)piperazine (TFMPP) and its salts
• 1-(4-Fluorophenyl)piperazine (pFPP) and its salts
• 1-(4-Methoxyphenyl)piperazine (MeOPP) and its salts
• 1-(3-Chlorophenyl)piperazine (mCPP) and its salts

Health Canada summarizes the response to its proposal (see C. Gaz. 2007.I.2000) to add Tramadol to Schedule I of the CDSA.

“This enactment amends the Controlled Drugs and Substances Act to provide for minimum penalties for serious drug offences, to increase the maximum penalty for cannabis (marihuana) production, to reschedule certain substances from Schedule III to that Act to Schedule I, and to make consequential amendments to other Acts.”

This bill died when the 39th parliament was dissolved 7 Sept 2008.

“This enactment amends the Controlled Drugs and Substances Act to prohibit the production, possession and sale of any substance or any equipment or other material that is intended for use in production of or trafficking in methamphetamine”[From the Bill’s summary page.]

This bill died when the 39th parliament was dissolved 7 Sept 2008.

A response to concerns raised by the Standing Joint Committee for the Scrutiny of Regulations (SJCSR) regarding inconsistencies between the English and French versions, and non-substantive clarifications of certain provisions.

“The purpose of this initiative is to introduce midwives, nurse practitioners, and doctors of podiatric medicine (DPMs) as practitioners under the Controlled Drugs and Substances Act (CDSA) by prescribing them as such in a new regulatory framework.”

Health Canada proposes adding Tramadol to Schedule I of the CDSA.

“This enactment amends the Controlled Drugs and Substances Act to prohibit the production, possession and sale of any substance or any equipment or other material that is intended for use in production of or trafficking in methamphetamine”[From the Bill’s summary page.]

This bill died when the 39th parliament was prorogued 14 Sept 2007.

This amendment implements changes proposed in C. Gaz. 2005.I.2111.

Six additional “precursor” chemicals are added to Schedule VI of the CDSA, as proposed earlier in C. Gaz. 2005.I.2098.

The Schedule I entry for Methamphetamine is expanded to include “its salts, derivatives, isomers and analogues and salts of derivatives, isomers and analogues”

This amendment clarifies and corrects the situation created when Methamphetamine was moved, perhaps too hastily, to Schedule I from Schedule III by SOR/2005-235.

Health Canada’s position is that, notwithstanding the clarity restored by this amendment, salts such as Methamphetamine hydrochloride were at no point exempt from CDSA controls.

Citing section 2 of the Act:

“a reference to a controlled substance includes a reference to any substance that contains a controlled substance” and

“a reference to a controlled substance includes a reference to … all synthetic and natural forms of the substance”

“The salts of methamphetamine contain methamphetamine and are a synthetic form of methamphetamine”. (emphasis added)

By that reasoning, table salt contains sodium (a soft, silvery-white, highly reactive metal) and contains chlorine (a pale yellow-green gas that has its distinctive strong smell, the smell of bleach) [cf. Wikipedia].

Ketamine is added to the Narcotic Control Regulations in line with its addition to Schedule I of the CDSA by SOR/2005-271.

Ketamine is formally added to Schedule I of the CDSA.

There was no formal advance notice of this amendment in the Canada Gazette, Part I. However, Health Canada did signal their interest in Ketamine in C. Gaz. 2004.I.204, and later declared (in Status of Ketamine under the CDSA) that Ketamine shall be considered an “analogue” of Phencyclidine, a Schedule I substance.

Ketamine is removed from the Food and Drug Regulations in line with its addition to Schedule I of the CDSA (see also SOR/2005-271, above).

Methamphetamine moves to Schedule I from Schedule III.

Interestingly, in its former Schedule III location, the entry for Methamphetamine included “salts, derivatives, isomers and analogues and salts of derivatives, isomers and analogues”

Now relocated to Schedule I, the former qualifiers have been left behind and only the unadorned free base is listed.

While I doubt it was the intent of this amendment, it seems to me that, for example, salts such as Methamphetamine hydrochloride are, arguably, no longer captured by the CDSA as a result.

See C. Gaz. 2005.I.2098 below.

“The purpose of this proposed initiative is to amend Schedule VI to the Controlled Drugs and Substances Act(CDSA) and the Precursor Control Regulations (PCR) to strengthen the regulatory framework and minimize any negative impact of the Regulations on the legitimate trade of precursors.”

“Among other things, the proposed amendments will add six substances to the CDSA and the PCR: Gamma-butyrolactone (GBL), 1,4-Butanediol (BDO), Red phosphorus, White phosphorus, Hypophosphorous acid, Hydriodic acid.”

[From the Regulatory Impact Analysis Statement (RIAS).]

Health Canada now considers Ketamine to be an analogue of Phencyclidine a Schedule I substance.

“Analogue,” as defined by the CDSA, means “a substance that, in relation to a controlled substance, has a substantially similar chemical structure” The CDSA provides no definition for “substantially similar.”

See the CDSA definitions and interpretations for more about analogues.

This bill is similar to Bill C-10, tabled but not passed in the previous session of parliament.

This bill died when the 38th parliament was dissolved 29 Nov 2005.

This bill is similar to Bill C-38, tabled but not passed in the previous session of parliament.

This bill died when the 3rd session of the 37th parliament ended 23 May 2004.

Health Canada proposes to add Ketamine to the CDSA.

Amineptine is added to Schedule III of CDSA.

Health Canada proposes to add Red Phosphorous and White Phosphorous to the CDSA.

Health Canada proposes to add Gamma-butyrolactone (GBL) and 1,4-Butanediol (BDO) to the CDSA.

“The enactment amends the Contraventions Act to allow for the designation of certain criminal offences as contraventions and to specify that contraventions may be prosecuted by means of either a summons or ticket unless another Act of Parliament provides otherwise.”

“The enactment also amends the Controlled Drugs and Substances Act to create offences with respect to the possession of small amounts of cannabis (marihuana) and the production of cannabis (marihuana).”[From the Bill’s summary page.]

This bill died when the 2nd session of the 37th parliament ended 12 Nov 2003.

Health Canada corrects errors introduced by SOR/97-230 and identified by the Standing Joint Committee for the Scrutiny of Regulations, in the CDSA entries for Levargorphan and Clotiazepam.

Health Canada adds Remifentanil to Schedule I and Olanzapine to Schedule IV, and excludes Nalmefene and Naltrexone from Schedule I of the CDSA.

Health Canada proposes to add Remifentanil to Schedule I and Olanzapine to Schedule IV, and to exclude Nalmefene and Naltrexone from Schedule I of the CDSA.

“The amendments to the Controlled Drugs and Substances Act in this enactment deal with aggravating factors in sentencing and the criminal liability of law enforcement officers engaged in their duties.”[From the Bill’s summary page.]

One of four amendments Health Canada proposes to enact the Benzodiazepines and Other Targeted Substances Regulations. The Regulatory Impact Analysis Statement (RIAS) for this group is contained in the fourth and final amendment dated 27 Mar 1999 below.

Health Canada proposes to add Brotizolam, Midazolam, Quazepam and Clozapine, to Schedule IV, and expand the existing Schedule III entry for Flunitrazepam by adding “and any salts or derivative thereof.”

Health Canada proposes regulations for Benzodiazepines and other targeted substances.

“An exemption from publication of these Regulations in the Canada Gazette, Part I is requested as they deal solely with internal government management.”

[From the Consultation section of the Regulatory Impact Analysis Statement (RIAS) for this amendment.]

Notice of proposed scheduling of Remifentanil, Olanzapine, Nalmefene and Naltrexone.

Notice of a review of the regulations pertaining to Benzodiazepines and other targeted substances.

“This initiative was exempted from prepublication due to the urgency to address the major health and safety risks associated with the use of Flunitrazepam and GHB. In addition, prior notice of this amendment may negate the effectiveness of the immediate scheduling of these drugs.”

[From the Consultation section of the Regulatory Impact Analysis Statement (RIAS) for this amendment and for SOR/98-173, above.]

As enacted.

As proposed.

Health Canada sets the stage for comments regarding proposed Industrial Hemp Regulations. See C. Gaz. 1997.I.3905 above.

“An exemption from prepublication of this regulatory amendment in the Canada Gazette Part I was granted as extensive consultation has occurred with the passage of the Controlled Drugs and Substances Act”

[From the Consultation section of the Regulatory Impact Analysis Statement (RIAS) for this amendment, and SOR/97-515, above.]

“An exemption from prepublication of this regulatory amendment in the Canada Gazette Part I was granted for the following reasons:”

• ⇒  adequate consultation was conducted during the Parliamentary process introducing the Criminal Law Improvement Act, 1996
• ⇒  the amendment is the correction of an error which was inadvertently created with the coming into force of the Criminal Law Improvement Act, 1996 and
• ⇒  enforcement requirements mandate that the correction be made expeditiously.

[From the Consultation section of the Regulatory Impact Analysis Statement (RIAS) for this amendment.]

“An exemption from prepublication of this regulatory amendment in the Canada Gazette Part I was granted as adequate consultation was conducted during the Parliamentary process introducing Bill C-8, the Controlled Drugs and Substances Act.”

[From the Consultation section of the Regulatory Impact Analysis Statement (RIAS) for this amendment and for SOR/97-228, SOR/97-229, SOR/97-230 and SOR/97-234 above.]

“An Act respecting the control of certain drugs, their precursors and other substances and to amend certain other Acts and repeal the Narcotic Control Act in consequence thereof”[From the Bill’s summary page.]

The CDSA as enacted in 1996.

Representatives from from Cunningham, Swan, Carty, Little & Bonham

Reform Party MP Grant Hill tries to allay fears of bureaucratic overreach in Bill C-8, soon to become the Controlled Drugs and Substances Act, by correctly asserting the power of the bureaucracy had been severely reigned in (though he gives “his office” rather more credit than I would):

“Mr. Speaker, Bill C-8 has been a complex and long lived bill in this House. It was the first bill I was the watchdog for, so I have watched the process very carefully.”

“Reformers had one big concern with this bill in that the bill gave very broad powers to the minister and to the bureaucracy that would have affected the health food industry. The clause that caused us the most concern said that the minister could deem any depressant, stimulant or hallucinogenic and include those in the schedules. [my emphasis]”

“I am proud of Canadians on that issue. Canadians with a little bit of help decided that was not suitable. The health food industry has stimulants, depressants and hallucinogenics. Our office was a bit of a focus for what I consider to be a campaign against that clause in Bill C-8.”

“There were petitions, faxes and a huge amount of interest on the bill and we were able to get that clause kicked out. Our efforts were rewarded. [my emphasis]”

Hill goes on to say:

“I always thought that if we in Canada were going to have a change in direction it should have public scrutiny.”

Hear, Hear!

Representatives from the Department of Health, and the Department of Justice

Representatives from the Canadian Foundation for Drug Policy, the Department of Health, and the Department of Justice

Representatives from the Lambton Families in Action, and the Council on Drug Abuse

Reform MP Bill Gilmour reminds the House that Bill C-8 should not encompass natural products.

Representatives from Hempline Inc., the Canadian Industrial Hemp Lobby, the Cannabis Canada, Robert Hamon, Andy Rapoch, Nicholas Bureau, the HIV/AIDS Legal Network and the Canadian AIDS Society, City of Toronto, Downtown/Eastside Residents Association, Assembly of First Nations, and the National Coalition for Health Freedom

Appearances by the Canadian Bar Association and the Criminal Lawyers’ Association of Ontario.

Evidence of the Canadian Medical Association.

“An Act respecting the control of certain drugs, their precursors and other substances and to amend certain other Acts and repeal the Narcotic Control Act in consequence thereof” [From the Bill’s summary page.]

This bill is essentially identical to Bill C-7, tabled in the previous session but lost when the 35th parliament prorogued.

The background paper Illegal Drugs and Drug Trafficking prepared by Diane Leduc and James Lee for the Parliamentary Information and Research Service provides a good overview of the political context at the time.

The legislative summary Bill C-8: The Controlled Drugs and Substances Act prepared by Jane Allain and Peter Niemcza for the Parliamentary Information and Research Service is a good overview of the legislation, its torturous path to becoming law, and the arguments of its proponents and (many) critics.

Rather than start again from square one, the House allows Bill C-7 to pick up where it left off from the previous session, this time as Bill C-8

This may actually have been a good thing because had the Bill been tabled anew Health Canada might have tried, a third time, to restore the expansive powers that were struck out during committee review. Twice.

On the first day of the new session, members discuss which Bills deserved to be carried over from the previous session. By default, any Bill that had not made it through the House and the Senate and got Royal Assent would have to start all over again.

Such is Ottawa.

Evidence from Mr. Eugene Oscapella, barrister and solicitor, Madam Diane Riley, Mr. Glenn Gilmour and Mr. Benedikt Fischer, all of the Canadian Foundation for Drug Policy

This evidence is unavailable online from any government source. We are fortunate the Canadian Foundation for Drug Policy had the gumption to post it.

C-7 died when the 35th parliament prorogued on 2 Feb 1996, only to return with the next Parliament as Bill C-8.

Evidence from Mr. Robert Kellerman, barrister and solicitor from the Law Union of Ontario and Dr. Perry Kendall, President and CEO, Addiction Research Foundation (now CAMH: Centre for Addiction and Mental Health)

This evidence is unavailable online from any government source. We are fortunate the Canadian Foundation for Drug Policy had the gumption to post it.

Evidence from Mr. Bruce Rowsell, Director, Bureau of Drug Surveillance, Health Canada, Mr. Paul Saint-Denis, Senior Counsel, Department of Justice and Mr. Gérard Normand, Counsel, Department of Justice

This evidence is unavailable online from any government source. We are fortunate the Canadian Foundation for Drug Policy had the gumption to post it.

The Bill as amended by the Commons Sub-Committee on Bill C-7, and following third reading in the House.

A House of Commons committee hears evidence from witness, makes amendments to Bill C-7 and sends it back to the House for third reading i.e. “reports” it.

It’s difficult to follow even with the original at hand, but one key provision they expunged was the following sweeping interpretation clause from page 4 of Bill C-7 as tabled:

3. (1) For the purposes of this Act, a substance included in Schedule I, II or I II shall be deemed to include any substance:

(a) that is produced, possessed or provided by a person who intends that it be introduced into the body of another person for the purpose of producing a stimulant, depressant or hallucinogenic effect substantially similar to or greater than that of a substance included in Schedule I, II or III, and that, if so introduced, would produce such a substantially similar or greater effect; or

(b) that is represented or held out to produce, if introduced into a human body, a stimulant, depressant or hallucinogenic effect substantially similar to or greater than that of a substance included in Schedule I, II or III.

I don’t think Health Canada ever really got over their loss, or have accepted it to this day.

“An Act respecting the control of certain drugs, their precursors and other substances and to amend certain other Acts and repeal the Narcotic Control Act in consequence thereof.”

This bill is very similar to Bill C-85, tabled but not passed in the previous parliament.

“An Act respecting the control of psychoactive substances and their precursors and to amend the Criminal Code, the Food and Drugs Act and the Proceeds of Crime (money laundering) Act and repeal the Narcotic Control Act in consequence thereof.” [From the Bill’s summary page.]

This bill died when the 34th parliament ended 8 Sept 1993.

For those interested in a little history, and a reminder of how much worse off we might have been had Bill C-85 passed, I highly recommend the following:

• A Critique of the Proposed Psychoactive Substance Control Act. S. J. Usprich and R. M. Solomon, Criminal Law Quarterly, 1992, 35 (2), 211.
• Prohibition, Public Health and a Window of Opportunity: an Analysis of Canadian Drug Policy 1985-1997. Benedikt Fischer, Policy Studies, 1999. 20 (3), 197.
• The New Canadian Drug Law: One Step Forward, Two Steps Backward. Benedikt Fischer, Patricia G. Erickson and Reginald Smart. International Journal of Drug Policy, 1996. 7 (3), 1.

It may be hard for some readers to imagine, but there was a time Health Canada were serious about protecting the health and welfare of Canadians, rather than that of the Harper regime. A paper like this one could never be produced today or would never see the light of day in any event.