To Health Canada:

Please forgive me if I don't seem very appreciative of Health Canada's so-called tobacco control efforts.

Personally, I believe that Big Tobacco -- not just in Canada, but globally -- should be completely run out of business... and there are not just one, but two completely legal ideas to achieve just that.  Obviously, the toppling of Big Tobacco won't happen overnight, but it would be 'phased out', over a period of 20 or 30 years.  All that's required, ultimately, is a little (or perhaps a great deal of) political will. 

Again, forgive me... but after reading just the one-page "Consultation on amendments to the Tobacco Reporting Regulations", I had neither the time nor the inclination to proceed any further.  That said, I had a quick look at the TRR... and, with the utmost of respect, it seems to me that one would have to be a lawyer to 'interpret' much of that document.  And, as I'm sure you well know, when it comes to lawyers, few are better paid and more successful than those who are part of Big Tobacco's small army of lawyers.  However, I digress... 

Below are some excerpts from Health Canada's "Consultation on amendments to the Tobacco Reporting Regulations" (I've highlighted the parts that are of particular concern to me):


We are suggesting changes so:

  • we can get better information from tobacco makers(1) and importers
  • tobacco makers(2) and importers can use modern methods to test tobacco

These improvements will help us to make better decisions and policies aimed at continuing to reduce tobacco use in Canada.


For this consultation, we are looking for comments from:

  • health partners
  • the Canadian public
  • interested members of the tobacco industry(3)


The purpose of this consultation is to get comments on:

  • modern tobacco testing(4) methods
  • improving the information we collect from tobacco makers(5) and importers

You'll notice that I've inserted numbers (1 - 5) after each reference to tobacco, above.

Again, with respect, if one didn't know better, one might think that Health Canada (HC) and Big Tobacco (BT) were working together, in a spirit of cooperation and teamwork... dare I suggest, as "partners"?!?

Under "Why",

1)  Given BT's extensive half-century plus history of deceit, deception, corruption, fraud, manipulation, lies, etc., why would HC believe a single word from BT?  If you're serious about getting "better information from tobacco makers", HC Inspectors (HCIs) should have the right to enter any and all of BT's facilities, with no advance notice...and collect any and all information, product samples, etc. that they want.  And if BT has an issue with that, have the police escort the HCIs, with or without a warrant; and

2)  Let me see if I understand this correctly:  "We [HC] are suggesting changes [to the TRR] so...tobacco makers and importers can use modern methods to test tobacco."???  Again, bearing in mind that I'm at somewhat of a disadvantage here, simply because I have not read the entire TRR, the above quote clearly implies, to me, that tobacco makers and importers either do no testing, currently, at all or are using old/antiquated testing methods.  Or perhaps it implies that the "modern methods" have been available for a long time, but tobacco makers have not been allowed to use them?!?  BT spends BILLIONS on Research and Development (including, I suspect, "modern methods to test tobacco" that are probably -- and again, with all due respect -- light years ahead of HC's testing methods) of their addictive, debilitating and deadly products and, while I can't speak to BT's 'attitude' toward the debilitating and deadly parts, I can assure you, 200%, that BT has ZERO interest in either reducing or eliminating the addictivene$$ of their products.  Regardless of the testing method, if you seriously expect straight answers from BT, regarding those test results, I respectfully refer you back to #1, above.  If you want real, valid and legitimate test results, you've got to either do the testing yourself or have BT people do it, using their equipment and/or HC's, under the strictest possible supervision.

Under "Who",

3)  You say you're "... looking for comments from... interested members of the tobacco industry." (emphasis mine).  Again, with respect, if this was the 1950s or '60s, I might understand the interest in feedback from BT.  But it's 2017!  And again, I ain't no lawyer, but I strongly believe that such an 'invitation' is in blatant violation of the World Health Organization's Framework Convention on Tobacco Control, which Canada ratified almost 13 years ago! But, FCTC or not, why would HC pay any attention -- or give any credibility -- whatsoever to anything that BT has to say?

Under "What",

4)  You say that you want to "get comments on... modern tobacco testing methods".  Of the three groups mentioned under "Who" ("health partners", "the Canadian public" and "interested members of the tobacco industry"), I would think that the only people who would have even remotely relevant info on that matter would be certain individuals within the third group... BT people.  And if they value their jobs -- and have no interest in doing the right thing...and becoming whistleblowers -- they're not going to provide HC with any useful info whatsoever; and last, and perhaps least,

5)  Please tell me how this is different from #1, above;  "...we can get better information from tobacco makers..." vs. "...improving the information we collect from tobacco makers." (emphasis mine)  Again, see my comments, re #1, above.

Bottom line:  At the very least, illegitimate Big Tobacco -- and its billions in blood money, much of which it uses to 'buy' politicians and other policy-makers -- taints everything it's involved in...including this entire TRR process, etc. 

Inviting Big Tobacco to participate in this is as bizarre as if Stalin was invited to a meeting on the health and welfare of Ukrainians... or inviting the Ku Klux Klan to a discussion about Black Lives Matter!  Or hey, how about inviting ISIL to Sunday Mass at the Vatican?

Don't laugh!  Deadly and destructive as Stalin, the Klan and ISIL were/are, even combined, they pale in comparison to Big Tobacco!   

As I said before, Big Tobacco, with its 50 plus years of lies, fraud, corruption, etc. -- not to mention the 7 million dead people, globally, it leaves in its wake, annually -- needs to be dismantled.  In the meantime, BT is not to be believed/trusted, period!

And frankly, as long as Big Tobacco is part of this process, I will have nothing to do with it -- nor any/all future HC so-called tobacco control initiatives -- and I will be encouraging many of my colleagues to boycott it as well.

I look forward to your earliest response.  Thank you.


Errol E. Povah

President, Airspace Action on Smoking and Health