HEALTH CANADA SITE/
ESTABLISHMENT LICENSING
COVID-19 SL
Be Prepared for End of Temporary License Measures

As site licenses (SL) issued under the expedited attestation process are temporary, companies with an interim COVID-19 SL could be notified soon to stop manufacturing and importing hand sanitizers,

OR you should apply for a valid (Regular) SL to continue importing and manufacturing.

When notified, you will have only 60 days to apply before the temporary license will expire.

QMRS is here to help...

Our expertise during the last 20 years includes projects pertaining to; drug establishments, Medical Devices, Natural Health products and helping clients to become a licensed Marihuana producer.

NATURAL HEALTH PRODUCTS SITE LICENSE REGULATIONS

A site licence is required for the physical site in Canada, if the business (person) manufacture or import a natural health product for sale.
To apply for a site license, applicant must provide to the NNHPD, a site license application, and Evidence of GMP Compliance.

EVIDENCE OF GMP

This may be demonstrated by one or more of the following:

Pre-cleared Evidence

Pre-cleared evidence includes:

1. Drug Establishment Licence (DEL). Applicant may submit a copy of their current DEL demonstrating compliance with the requirements of part C, of the Food and Drug Regulations.
By submitting a DEL, the site licence applicant is attesting to comply with the same standards for NHPs as for drugs.
2. Foreign Site Reference Number (FSRN) Authorization. The NNHPD may issue a FSRN to a foreign site that has demonstrated compliance to GMP Regulations via a separate FSRN application process. Once issued a FSRN, foreign site owners may authorize Canadian importers to reference their FSRN as an alternative to providing GMP evidence for their site.
3. Good Manufacturing Practices (GMP) Certificate from a Qualified Authority. A qualified authority is an authority member from a country, where Health Canada has a Mutual Recognition Agreement (MRA) regarding GMP for drug products, or an authority member of the Pharmaceutical Inspection Cooperation Scheme (PIC/S).

LIST OF MUTUAL RECOGNITION AGREEMENT (MRA) AUTHORITIES

NOTE:

The NSF International Standard for Dietary Supplements Certificate has been found to partially cover the requirements of HC GMP Regulations and may be submitted in support of a site licence application along with other additional supporting information, which may include: the finished product testing and stability information.

Quality Assurance Report (QAR):

Is considered to be an attestation by the applicant that the site meets all the requirements of the GMP. It is prepared by the site quality assurance manager, who has the training, experience and technical knowledge relating to the activities conducted. The report, in brief, is based on the GMP requirements that set out in Health Canada GMPs guidelines.

NOTE:

Manufacturers of homeopathic products must submit additional GMP evidence that associated to homeopathic medicines.

Alternate GMP Standards (and/or Accreditation Bodies)

The NNHPD promotes independent on-site verification of compliance as it may provide a greater level of assurance that products sold in Canada meet appropriate standard of quality.
Therefore, applicants may submit other audits or inspection reports along with their QAR to assist in demonstrating compliance with the GMP Regulations.
Please note that, qualifications of the auditor or the person responsible of the inspection, parameters (standard) adopted for the audit, and corrective actions are also required.
To review QMRS audit approach, please click HERE, and if you want to look at the auditor profile, please visit this LINK.

NOTE:

Canadian importers are required to be licensed and the onus is on them to provide evidence that products coming from foreign sites meet Canadian GMP Regulations.

FOREIGN SITE REFERENCE NUMBER

A Foreign Site Reference Number (FSRN) is issued by Health Canada to a manufacturer, packager and labeler of NHPs located outside of Canada, referred to as a foreign site. A FSRN indicates that the foreign site is found to be in compliance with the GMP   Natural Health Products Regulations. The FSRN application will benefit the Canadian importer and the foreign sites by:

1. Allowing direct communication between HC and the foreign site, maintaining confidentiality of the information provided;
2. Saving time, money and resources for foreign sites engaged with multiple Canadian importers by eliminating the need to supply the site GMP data to each importer several times a year.
3. Assessing the GMP compliance of a foreign site in advance, will also benefit the importer’s subsequent site license application.
4. A FSRN is considered pre-cleared evidence when referenced in support of an importer’s site license applications, and is therefore subject to a shorter service standard.

End of Temporary License Measures

Manufacturers, and importers will require a valid SL once the regular supply of hand sanitizers stabilizes.
Companies with an interim COVID-19 SL under the previous expedited attestation process will be notified when the interim period ends (when demand of alcohol-based hand sanitizers stabilizes).
When notified, you will have 60 days to:
1. Stop manufacturing, importing, packaging, labelling or distributing alcohol-based hand sanitizers.
2. Apply for a valid SL to continue producing hand sanitizer until you receive a decision on your application.

Certainly, QMRS can assist you to transfer the Temporary license to a regular one.

Applying for A Foreign Site Reference Number

The FSRN application process requires foreign sites to supply the same types of evidence of GMP compliance as Canadian manufacturers in support of their application.
To apply for a FSRN, applicants must provide an application to the NNHPD, with the evidence of GMP compliance for the site.

Foreign Site Reference Number Authorization Form

For each application, the FSRN holder should provide each Canadian importer with a completed Foreign Site Reference Number Authorization Form to allow the NNHPD to access the previously assessed GMP information for the foreign site in support of any application submitted by the importer.
The importer, in turn, will provide the authorization form to the NNHPD as part of their new site licence, renewal or amendment application.

QMRS EXPERTISE

In brief, whether you are a manufacturer or importer QMRS can assist you to fulfill your regulatory needed.

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    Related Definitions

    Drug establishment licence (DEL)

    A DEL is a licence issued to a person in Canada allowing them to conduct licensable activities in a building which has been inspected and assessed as being in compliance with the requirements of Divisions 2 to 4 of the Food and Drug Regulations.


    Foreign Site Reference Number Authorization Form

    An authorization form completed by a foreign site Senior Official (who maintains a valid foreign site reference number) that is used to support an importers site licence application.


    Importer

    A person who imports a natural health product into Canada for the purpose of sale. This would include bulk natural health products.


    Manufacturer

    A person who fabricates or processes a natural health product for the purpose of sale, but does not include a pharmacist or other health care practitioner who, at the request of a patient, compounds a natural health product for the purpose of sale to that patient.


    Quality assurance person

    The person who is responsible for assuring the quality of a natural health product before it is made available for sale. This person has the training, experience and technical knowledge relating to the specific activity conducted for a given building/site (e.g. manufacturing, packaging, labelling, and importing) and fulfills the requirements of Part 3 of the NHPD.