SUPPORT THE HPA - WE PROMOTE AND PROTECT THE HEALTH PRODUCTS INDUSTRY
HPA Executive Secretary Deirdre Allen is calling on stakeholders in the health products industry to subscribe to and support the HPA in its ongoing endeavour to establish a reputable and robust industry in South Africa. In this letter, she outlines the challenges facing the health products industry and the advantages of being an HPA member.
Dear HPA Members
We have come to the end of a very difficult year for the industry and are now facing some important challenges. A very good reason to continue your membership of the HPA is that if you did not have an industry association that was alert and in touch with the various government departments and regulators the Recision of the 2002 Call-Up Notice would have been put in place and the industry would be in turmoil - the HPA immediately reacted to protect the CAMS industry when it learnt that such a decision had been taken by the MCC, and have taken the necessary legal procedures in order to stop this recision.
We have listed here below some of the challenges we face during 2010 and beyond...!
RECISION OF THE 2002 CALL UP:
The HPA Executive Council learned of the decision taken at the MCC meeting held on August 14th that a recision of the 2002 Call is pending. The HPA were able to obtain a copy of the Minutes of this MCC meeting held on August 14th 2009 confirming this decision. If the recision is put into practice it will have a major impact on the CAMS industry effectively making approximately 15,000 products illegal. The recision would then immediately put in place all the pending call-ups that were superseded by the 2002 Call Up. Call-ups such as the call-ups for herbals, amino acids, anti-inflammatories etc.
Following legal consultation, it was agreed that the HPA should lodge an official appeal to the decision to rescind the 2002 Call-Up. An official appeal was prepared by our legal advisors Edward Nathan Sonnenberg and was delivered to the Minister of Health and the Registrar on Friday November 6th 2009. The procedure is that the Minister will now have to constitute a Committee of Appeal but to date we have received no comment from the DOH.
The Appeal is based on a 7 year understanding that CAMS products could be sold, based on the submission of dossiers. There is also the expectation over many years that appropriate regulations would be published for CAMS products.
ASA CAMS APPENDIX:
The advertising playing field for CAMS products has been the cause of much concern amongst the industry and regulators. The HPA took the decision to approach the ASA to ask if they would consider us preparing an appropriate ASA Appendix for CAMS products. The DOH has been informed of this project and they are expected to approve of this CAMS ASA Appendix when it has been approved by the ASA. The HPA have a task team who is preparing this document and as we develop this, the steps are being reported back to all HPA members in order that they can give their comments and contribute. This document will be of enormous assistance to the CAMS industry and will clarify what claims can and cannot be made for CAMS products.
DRAFT CAMS REGULATIONS:
The HPA continue to monitor the progress of the draft regulations and try and ensure that they are not neglected by the DOH and the HPA puts as much pressure as possible on the DOH to publish these regulations for comment. The HPA will immediately call up the appropriate task teams to ensure that comment is made on the draft regulations when they are published - it is expected that the industry will be given three months to comment from date of publication.
GMP:
The HPA has decided that 2010 should be the year for GMP. It is very important that CAMS manufacturers are made aware of the rules and regulations that apply to their manufacturing procedures. The industry has to be vigilant in their manufacturing processing and companies who use manufacturers must be aware of the pitfalls and ensure that they are having their products made by reputable and responsible companies. The HPA, amongst other promotions regarding GMP, will be holding GMP seminars during the course of the year. The HPA's Self Monitoring Advisory Committee has extended its mandate in order to be able to table complaints against manufacturing companies who may raise suspicion amongst other manufacturer's or distributors of our products.
SELF MONITORING ADVISORY COMMITTEE (SMAC):
Please remember that this committee does not just deal with complaints, it also assists member companies with the advertising particularly advising them on claims that can or cannot be made. We have already mentioned that its mandate is to extend to manufacturing companies and a manufacturer has joined the Executive Council to assist.
PR & PROMOTIONS:
a. HPA Headlines: The HPA's quarterly newsletter is distributed to not only members of the HPA but also to members of the media, trade (supermarkets/health shops/pharmacies etc) DOH members, associated associations, and many other interested parties. It is a very informative newsletter on the CAMS industry and not only features local information but also includes information on the CAMS industry worldwide. HPA Headlines also does a feature on individual HPA members.
We remind members that any information they have about their company, pending launches, new products, visiting speakers can submit this information and it will be edited and published free of charge
b. HPA Inside Track: The HPA have this month launched a new service called Inside Track - every few months we will publish an article that has been featured in the world's leading nutritional publication "The Nutrition Business Journal". This journal is published in the States - articles that feature new trends and trade issues that are developing worldwide will be adapted to include a South African aspect. We are also adapting the same article to send out to all our media contacts in order to ensure the HPA stays a priority in the minds of the media and they too are kept updated on trends within our industry
c. Media: Over very many years the HPA has established an extremely good relationship with members of the media. They know that they receive accurate information about our industry via the HPA and can depend on the HPA for reliable and responsible information. We shall once again be hosting our annual media breakfast where we entertain the media to an appropriate speaker and update them on legislative trends.
d. HPA Webpage: The HPA webpage is updated monthly and once again it is a vehicle that can be used by all HPA Members and we are more than happy to ensure that your websites are made available on the HPA website and any information you would like to send to us we would be happy to consider publishing them on this website.
• NHI (National Health Insurance)
The HPA are anxious for the CAMS industry to be represented on the committee appointed by the Minister of Health that will develop policy direction for the NHI. We are making submissions in this regard.
LIAISON WITH GOVERNMENT
We continue to have a robust programme of interaction with the DOH, we are, for example, following through with our request to have a Directorate for CAMS appointed as soon as possible.
The HPA is at the service of its members, the Executive Council will welcome any suggestions to improve the service offered and members must please feel free to request a meeting with the Executive Council if they so wish.
The HPA runs on subscriptions and over many years has kept the cost of subscriptions down and have attempted to keep expenses within reasonable parameters. We have to this year increase our annual subscriptions by 6% (Six percent). It is not an easy task to predict what expenses are going to be required during the course of the year. Administrative costs are reasonably accurate, however we cannot foresee legal costs - we have managed to meet the legal costs of the Appeal against the rescindment of the 2002 call-up from our reserves but our reserves are now running extremely low.
The HPA Executive Council is looking at other ways to raise funds and will be launching a Company Council early in 2010. This kind of Council is part of many other associations and it basically means a council of managing director's of major companies whom are invited to attend a small function where the future challenges of the industry are discussed and understood by the major decision makers of the company. If major fund raising is needed they are immediately familiar with the requirements and the need for such extra funds.
A table of our 2010 Annual Subscriptions can be accessed on the website under Membership/Downloads.
On request a personalized invoice will be sent out. It is difficult to send out individual invoices until we know which company falls into which payment category.
With kind regards
Deirdre Allen