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Help Needed for Canadian Regulations

Canada may declare hemp a "novel food." This has formerly been reserved for putting regulatory hurdles in front of genetically modified foods and other totally new foods from the laboratory.

If we can show the officials that there is a long history of hemp usage throughout the world, they still have time to reconsider this.

So please, all of you historians, food entrepreneurs or hempsters. Now is the time to help us dig up all the historical references that we can that prove hemp's long usage in food. We can go way back in history or to foreign lands that still use the seed for these references. Some suggestions:

1. We need some expert in medieval foods to help us find studies of how hemp was used in this period.
2. We need ethnic recipes that use hemp as well as ethnic cookbooks that demonstrate its use. Just finding the names of some of these old recipes will help as we can then do an extensive search for them.
3. We need statistics of that show early 1900's use of hemp.
4. We need any scientific studies that have used hemp for food. If Edistin really was the standard laboratory protein in the early part of the century, prove it!
5. We need affidavits from travelers who have seen hemp being served commonly in areas of China or wherever. If there are an statistics on this modern use available, it would be great. How much hemp do the Chinese and Japanese consume in a year?

You get the idea. We need these references ASAP. This is crucial people, please pull together and help on this. Email or fax any information that will help us on this issue to me at the following address:
--
Don Wirtshafter, Ohio Hempery Inc. Products the Earth Can Afford
Call or write for our free catalog: Order Line 1-800-BUY-HEMP
7002 S.R. 329, Guysville, OH 45735 shop on line:
(740)662-4367 fax(740)662-6446
************

Jodi Koberinski, of Echo Oils received this from Mr. Eric Driscoll, Scientific Evaluator Nutrition Evaluation Division, Food Directorate Health Protection Branch, Health Canada

>Thank you for your inquiry. The Novel Food Regulations were published on the
>Food Program website recently and are now in effect. They will be
>published in
>the Canada Gazette Part II on October 27. You may find them at:
>
>/novel_foods_and_ingredient.html
>
>Because hemp containing foods do not appear to have a long history of safe use
>according to the definition of a novel food, it is our interim position that
>foods containing hemp-derived ingredients are novel foods and, therefore, your
>proposed products will likely fall under the novel food regulations.
>
>It is requested that you forward a notification of your intention to sell
>products containing hemp-derived ingredients with the information outlined in
>Section B.28.002(2) of the Regulations attached. Obviously, the main safety
>concern about hemp-derived food ingredients is the level of THC in the
>ingredient. If it is less than 10 ppm as outlined in the Industrial Hemp
>Regulations, the ingredient may be used in foods at this time. The most
>important information that should be provided is the analytical data for the
>level of THC in your hemp-derived ingredients and the amount of each
>ingredient
>used in your products. In order to prevent delays, if you do not have some of
>the information immediately available, please forward the information that you
>do have so that we can initiate the evalution.
>
>The Health Canada position regarding the level of THC in such products is
>under
>review. I have added you to our mailing list for manufacturers of hemp
>containing foods and you will be notified if there are changes to this policy.
>
>Additionally, if you have evidence that hemp containing foods have been
>consumed
>by humans for a period of time that could be described as a "history of safe
>use", please forward that information and it will be considered in evaluating
>the safety of your products.
>
>If you have any questions, please don't hesitate to contact me directly at any
>time.
>
>Regards,
>
>Eric R. Driscoll, M.Sc.
>Scientific Evaluator
>Nutrition Evaluation Division, Food Directorate
>Health Protection Branch, Health Canada
>
>Nutrition Evaluation Division
>Banting Bldg. (2203A)
>Tunney's Pasture
>Ottawa, ON K1A 0L2
>
>613-957-3841
>Fax: 613-941-6636
>eric_driscoll@hc-sc.gc.ca
>

**********
From: Don Wirtshafter
October 22, 1999
RE: Reply from Health Canada

I received a phone call from Eric R. Driscoll, the Scientific Evaluator for the Nutrition Evaluation Division, Food Directorate of Health Canada. He called in quick response to my faxed letter, copied below.

He called to assure me that the Food Directorate had no intentions on using the Novel Foods Regulations to slow down the merchandising of hemp. So long as hemp food products meet the 10 ug/g standard, they may be marketed in Canada "at this time." He explained that the Food Directorate is responsible for maintaining food safety in Canada. Because people in Canada are not familiar with this newly available product, the government will try to keep a close eye on the products and their producers.

So the Food Directorate has been asking hemp companies to register with their office on a voluntary basis. This is so that if there is trouble the government will quickly be able to find the responsible parties. At the same time, if substantial evidence accumulates that shows that hemp foods are safe for general use, the Directorate will then make a decision to cease its close scrutiny of the industry. No time period for this decision was given, but when the decision is made, industry representatives will be informed in writing.

I asked which level of industry needs to register. Would a small bakery using hemp nut in their breads need to apply. Mr. Driscoll was clear that it was the major manufacturers they were after. I asked if this was not already being done through the producer license requirements of the Therapeutic Products Programme of the Health Protection Branch of Heath Canada? He agreed in part.

I asked if there was any other natural plant that had ever been under the novel food scrutiny of the Food Directorate? He agreed that hemp was a unique example.

So the message is we really need to pull together and gather these historical and contemporary verifications of hempís known safety in foods. If we do a good job, we will be out of this deep water and have the blessing to go forward from an important agency. With the proper documentation in hand, I am confident they will take action. I asked how much time we had to put together a package for him? Would two weeks be too long? He was really comfortable with this.

So the challenge is on us, I have heard from a few people with research skills (but little spare time). We need a lot more volunteers. If you have access to interns or students or anyone who wants to pour through old books, now is the time. Please help. So lets make the deadline for submission of information Monday, November 8th. Anything received on that date will go into the initial packet to the Food Directorate. Anything received after November 8th will still be appreciated and submitted later.

For any Canadian producer who wants to register hemp food products with the Food Directorate, the forms are available at their website: novel_foods_and_ingredient.html
-----
Here is the letter I sent Eric Driscoll this morning:

October 21, 1999

Eric R. Driscoll, M.Sc.
Scientific Evaluator
Nutrition Evaluation Division, Food Directorate
Health Protection Branch, Health Canada
Nutrition Evaluation Division
Banting Bldg. (2203A)
Tunney's Pasture
Ottawa, ON K1A 0L2
BY FAX: 613-941-6636 and Mail (with enclosures)

RE: History of Safe Use of Hemp Foods

Dear Mr. Driscoll;

I am writing in response to your letter to my colleague, Ms. Jodi Koberinski of Echo Oils. Jodi forwarded your message to me because I am considered an expert on the legal and technical considerations of using hemp for food. I have been engaged in the Hemp Industry since 1991 when I co-authored and published The Hemp Seed Cookbook. My company was the first modern company to manufacture and distribute nutritional grades of hemp seed oil. The Hempery is deeply involved in the development of the Canadian hemp industry, both as a consumer and as an investor.

Unfortunately, I am leaving this morning for the Natural Products Expo in Baltimore, Maryland so I am not able to put together the lengthy response that is needed to fully address your concerns. Despite the uncertainty caused by the recent U.S. Customs action against imports from Kenex, Ltd., the Natural Products Expo is expected to feature at least 300 hemp products from more than 30 vendors. I write with concerns that your preliminary decision to classify hemp as a novel food, however interim, could endanger this growing industry that holds so much promise for Canadian farmers, processors, distributors and investors.

Despite the assertions in your letter, Hemp does have a long, rich history as an ingredient in food. This record dates back to beginning of recorded history and continues to the few modern cultures not affected by the modern bans on Cannabis production.

In the mailed version of this letter I will send you a couple of articles I wrote that detail the nutritional profiles of hemp seeds and hemp seed oils that oil expert Dr. Udo Erasmus and I complied. Hemp is extremely well endowed with quality oils and proteins. We checked for the presence of trace minerals and other substances that could be considered dangerous for human nutrition and found nothing of concern.

My company has sold hundreds of tons of hemp seeds and oil to thousands of customers for food use over the past nine years. I can report that we have never received one telephone call or other communication that indicates that any one of our customers has ever experienced an adverse reaction to the consumption of hemp foods. I can also say with some pride that the hemp seed and oil products that are now coming out of Canada contain 100 to 1000 less THC than the Chinese based products that we formerly carried.

It is clear that hemp foods do not have formal GRAS status in the United States. Neither do corn or wheat products. The Ohio Hempery did the work necessary to self-authenticate the GRAS status of hemp according to the provisions of the FDA regulations. We have helped other companies also establish their GRAS status. I will share this documentation with your agency.

When I return from the Natural Products Expo, I will be able to detail and authenticate for you the use of hemp in medieval foods and in ethnic recipes from various parts of the world. You should also receive information on the use of hemp for food in modern China and Japan. Indeed, Japanese "Shichimi Togarashi" or Red Pepper/Hemp Mix is still imported into the U.S. and Canada and is used in every Sushi restaurant. Roasted hemp seeds are sold like popcorn outside of movie theaters in much of China today. I will also provide several scientific articles that document the use of hemp foods in treating nutritional deficiencies.

I have put out the word to leaders in the hemp industry that you are looking for this historical documentation of the use of hemp in order to avoid the need for labeling hemp as a novel food and the resultant over-regulation of the product if that decision has to be made. I urge you and your administration to hold off any decision in this direction until the industry has a chance to more fully respond and provide you this documentation.

I urge you to call or email me if you have specific questions that I can answer.

Sincerely,

Donald Wirtshafter
Attorney at Law, President Ohio Hempery
--
Don Wirtshafter, Ohio Hempery Inc.
7002 S.R. 329, Guysville, OH 45735
(740)662-4367 fax(740)662-6446>
don@hempery.com
*************************************
C. Penn, HIA Secretary
Hemp Industries Association
PO Box 1080, Occidental, CA 95465
Tel: 707 874 3648 Fax: 707 874 1104
Email: info@thehia.org
Websites: &

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