Further on the Unconscionable CBSA / Health Canada / CFIA Withholding of My Wife's Collagen Shipment

At some point last afternoon until my younger brother set me straight just after mid-morning today, I absolutely believed that today was Saturday.

I knew yesterday right up until into the noon hour that the day then was Wednesday, but at some point over the afternoon I became lost in time without being aware of it.

As a result, I sat up late last evening with my brother, all the while operating our Android TV Box to watch a couple of the T.V. series that we follow in common (specifically, Versailles, then American Ninja Warrior, and finally United States of Tara). Had I realized the true day, I would have gotten to bed earlier for the early a.m. overnight walk that has become a feature of my Thursdays.

And so this morning I rose ─ earlier than usual, as it happened, for I found myself awake shortly after 5 a.m. and tried for over an hour to return to sleep ere I gave up; I even checked outside for the Saturday morning newspaper that I subscribe to, and was annoyed that it was not there.

And then before my brother was yet up for the day, I had some exercise out in the backyard toolshed ─ exercise that I do not normally engage except on Mondays, Wednesdays, Fridays, and Saturdays.

But perhaps it is all for the best. In fact, I do believe that henceforth I shall have my walks overnight in the a.m. of Fridays instead of Thursdays because my brother usually buses off to a pub to rendezvous with as many as three of his drinking buddies on Thursdays, and thus he is not home again until well past 9:30 p.m.

Normally I sit up awaiting him so that we can watch a couple or so of the T.V. series that we follow, but now I can just get to bed early to make rising at 2:30 a.m. for my upcoming overnight Friday walk far easier on me than such walks are when I sit up until maybe 11 p.m. Wednesday nights and have to confront the walk early on Thursday as has been my past wont.

Nevertheless, how was it that I lost my grasp of the calendar ─ and how did that transition take hold from knowing the date to somehow entirely accepting a wholly false sense of the same day? 

A mini-stroke, perhaps? I am 72, after all.

Whatever the cause for that time lapse, this morning when my brother and I got together to watch some T.V., we never actually finished watching anything worthy of mention, so I will drop the topic.

The afternoon has been largely sunny and gorgeous. Unfortunately, I was too much in need of an early afternoon nap to take advantage of the sunshine, but following my nap I did go out into the backyard and ─ attired just in a pair of shorts ─ sunned myself frontally from 3:06 - 4 p.m.

There is more sunshine in store over the next few days as well, so I am hoping to get in some regular consecutive days of full sunning for the first time this year.

I also want to start work on a new post at one of my two hosted websites. It has been just over two months since I last published a post at one of them. I hope to actually begin work on that new post come tomorrow ─ today I have just been amassing material for the post (which typically can reach or even exceed 30,000 words).

In other news, the female CFIA inspector I have been involved in E-mail exchanges with concerning my wife's DHL Thailand shipment which has been in "Clearance Event" limbo ever since it fell into CBSA's hands last April 14, has not responded to my angry rebuttal yesterday to her E-mail earlier that day that stated that one of the three products in the shipment would not be released to us.

The product is Boom Collagen+ (that link is entirely in Thai) and comprises 36 ingredients, but the CFIA inspector claimed that according to Health Canada, three of the ingredients are not allowed in Canada as food additives, and I would have to submit a formal petition to Health Canada to have them reviewed for acceptance.

I could tell from her E-mail that her grasp of what she was trying to tell me was weak ─ here is one of her suspect statements:

Upon assessing this product, one of the listed ingredients “Haematococcus pluvialis” (extract from astraxanthin) is not permitted to be used in this product. Astraxanthin is permitted in fish feed used as a colour additive but, not as an additive in food under Health Canada’s Lists of Permitted Food Additives.

First off, there is no "r" in astaxanthin, the proper name of the antioxidant. Yet she spelled it wrong several times. As well, the astaxanthin in Boom Collagen+ was derived from the algae (Haematococcus pluvialis) ─ the algae was not being extracted from the astaxanthin, which is what she seemed to be saying.

Apart from that, however, astaxanthin is commonly sold all over Canada ─ every nutritional supplement section of pharmacies and major food stores sell astaxanthin. I even pointed out to her that astaxanthin is so abundant in salmon that it is the reason for the pink and red colour to such fish flesh. In other words, we are eating it all the time in salmon and other foods!

As for the source of Boom Collagen+'s astaxanthin ─ the algae “Haematococcus pluvialis” ─ I located references (see below) on Health Canada's own website where recommendation was given as to how much dried “Haematococcus pluvialis” is acceptable for consumption on a daily basis (one gram, to be precise). 

I also found it listed on the Health Canada website that neither the algae nor astaxanthin are "novel foods" ─ in fact, they were listed as being "non-novel".

Without offering me any proof that either item was itself a "novel food", she had provided this definition of what the term means:

A novel food is:

·         A substance, including a microorganism (a living thing so small you need a microscope to see it), that does not yet have a history of safe use as a food
·         A food that has been manufactured, prepared, preserved or packaged by a process that:

          o   Has not been previously used for that food, and
          o   Causes the food to undergo a major change

When a product contains “novel ingredient(s)”, it is necessary for the responsible party to make an application to Health Canada describing the usage of each of the novel ingredients in the product. The safety of a novel food ingredient (which includes a substance, process, or modification), must be established before it may be used as an ingredient.

Well, whoop-de-do! That's just wonderful to know ... but as I already proved, neither ingredient is listed as being novel.

But that was not all. She even stated that the third ingredient ─ acerola cherry extract as the source of the vitamin C included in the product ─ is a "novel ingredient". 

The cherry? ... or the vitamin C? Be clear!

So in my angry reply, I said:

I very much dispute that astaxanthin nor acerola cherries are incontestably listed anywhere as being prohibited. Heck, Haematococcus pluvialis and acerola cherries are listed in Appendix 3 of Health Canada's Drugs and Health Products: Antioxidants where is described the maximum daily doses of these substances. The dried algae Haematococcus pluvialis all on its own is cited as being acceptable for ingestion in an amount of one gram daily; acerola cherries at 100 grams fresh or 10 grams dry daily.

Merely quoting what a novel food is defined as, but not actually showing anywhere that acerola cherry is indeed identified as falling within that category hardly proves the case in light of the reference I have provided.

There was no reply from her today.

I have no doubt that she is entirely out of her element and does not understand anything about these three ingredients ─ the murkiness of her statements proves this. And now that I have made my case with references that solidly fortified my contentions ─ references at Health Canada's own website ─ she realizes that she is not dealing with someone who is going to be cowed simply because she used language that she thought this high school dropout could not possibly comprehend.

Making vague reference to a weblink that does not mention any of the three ingredients being contested, and then defining what the term "novel food" implies even though the term was nowhere applied at the Health Canada website to any of the three ingredients, does not carry the damned day. 

Hell, I even showed that Health Canada refers to all three ingredients as being "non-novel".

She is either lying to save face over having held up delivery of my wife's shipment for over two months, or else she is not qualified to be speaking on the subject of the three ingredients. She did not seem to understand what they were; and she was unable to point directly anywhere to information at Health Canada that verified her claims about them.

Anyway, early this evening I found further evidence bolstering my stand, so I forwarded it to the woman:

I wish to add the following Health Canada references for all three of the ingredients you were informed were "novel foods" or "novel ingredients", but which I can show conclusively are all approved by Health Canada.

1. First, Haematococcus pluvialis extract ("Approved Herbal Substance")
2. Second, astaxanthin (two examples, both of which are "Natural and Non-prescription Health Products")
3. Third, Acerola (nine examples, all of which I believe are cleared as  "Natural and Non-prescription Health Products")

There is absolutely no legitimate reason any longer to be withholding delivery of my wife's shipment.

I just wish that we had been informed in timely fashion (i.e., two months ago) about this gross error.

Maybe I should get hired as a part-time researcher about supposedly suspect food / medicinal ingredients coming into Canada. I could easily work from home and get the workload done.

My evening is now deep upon me ─ I must take my leave for today.