Project 8Ball

Currently, Consumer Product Safety (CPS) inspectors must verify the compliance of consumer products and cosmetics at various locations such as land border sites and at locations operated by their regulated party. In addition to verifying compliance as per the various regulations under the Canada Consumer Product Safety Act (CCPSA) and Food and Drugs Act (FDA), the program also collects information for documentation and surveillance purposes. Enforcement is typically taken on-site, however the current compliance verification process is slow due to the various steps involved. During this process inspectors are expected to review the past compliance history of the products and the regulated party, information that is typically stored in various sources such as internal Health Canada databases and the internet.

Inspired by the popular Magic 8 Ball fortune telling ball, Project 8Ball will stand as a resource for Government of Cananda employees to enter information and “magically” receive an instant answer of advice. Project 8Ball was created to leverage the technology developed in Project Cyclops to develop a user-friendly mobile application that will be used as a support tool for regulatory decisions on at the border. The scope of Project Cyclops was limited to focusing solely on natural health products (NHP). Project 8Ball was able to utilize existing technology to expand the scope of Project Cyclops to apply existing technology to focus on cosmetics. This tool will allow Government of Canada employees to have relevant and tailored information at their fingertips (see icon mock-ups in design process). The mobile application will include automatic label reference tool to detect cosmetic ingredients from the Restricted and Prohibited Hotlist to assist inspectors when making admissibility decisions at the border. As well, have capabilities to generate reports that may be used by inspectors for detailed documentation, compliance promotion, outreach, education, and future surveillance.

Development- Project Cyclops

Phase 1: Initiation & Stakeholder Engagement - Completed

During the initiation and stakeholder engagement phase, we will be finalizing work plans and obtaining approvals. We will then be identifying the requirements for product labels for NHPs as per the Food and Drug Act under natural health product regulations and guidance documents. A collaboration with ROEB programs will be required to apply data from inspection processes requiring label reviews. This will include the health program appliance to understand the inspection process, as well as the information recorded for compliance verifications or the compliance-monitoring project that would require label review, and the Border Integrity Program to understand the border inspection process, with the labeling review undertaken for NHPs reviewed at the border.

There will be a co-creation with BREAD, BSFO and IMSD to ensure the project aligns with the departmental approach for potential scalability.

Phase 2: Business Analysis and Functional Requirements (The Discovery Phase) - Completed

During the business analysis and Functional requirements phase, the business processes will be mapped for label reviews within ROEB, including the output required for the completion of the inspection specific to each group. Functional requirements will be identified; those of which would be required for the MVP for use in the field. During this process BRD and SRD will be developed and reviewed.

Phase 3: Development (Agile process)

During this phase, economies of speed will be used to procure professional service(s) that are able to identify the model required to test feasibility of a solution that is able to conduct functions. These functions include text scanning, with image and video analysis capabilities of 3D objects having varying predictive capabilities based on angular projections, and automation of real-time review and assessment of product labels using artificial intelligence enabled by predictive insight, with information from acute and legacy data. Proof of concept will be developed, which will be used to demonstrate features required for an MVP.

Next Steps – Project 8Ball

Stream 1

The scope of the 8Ball Project in Stream 1 is to develop the model, or a preliminary proof of concept that has demonstrable features that would be required for a horizontally designed Minimum Viable Product (MVP). IMSD will play a pivotal role in providing support and guidance to the vendor and ensure backend compatibility to Health Canada infrastructure. 

By using technology developed in Project Cyclops, the feasibility of the solution will be demonstrated. The MVP should be able to review product labels for a Cosmetic product during an on-site inspection with a random sampling of products, in a real inspection setting. 

The 8ball mobile application tool will provide digital photos, translations and the conversion of images, printed text or handwritten into machine encoded text (Optical Character Recognition (OCR)) in real time. Inspectors will be able to capture images of a product and with OCR the tool will cross-reference it to the frequently updated Hotlist Ingredient List (see images 5&6 in design process). The mobile tool will provide live translations of English, French, and other languages to verify compliance against labelling requirements and the Hotlist Ingredient List. Consumer Product Safety (CPS) has at least 16 regulations that include specific labelling requirements with pre-defined text specified. Labels would be scanned, and the existing text would be compared to the regulatory requirements. The process output would identify the deficiencies (view process flow below). Additionally, pending co-operation of Canada Border Services Agency (CBSA) officers, the application will be offered to the CBSA officers to be used on a voluntary basis to help focus on providing improved referrals to Health Canada.

Diagram of Project 8Ball process flow.

Stream 2

In the final stage of the project will assess if the MVP is appropriate for enterprise release. If appropriate, the project would seek to secure funding to scale accordingly via the Investment Plan process. The project will take an inclusive approach with both inputs and outputs, critical to perpetuate innovation. The tool will provide a voluntary sign-up-based platform for Canadians to access outreach information such as recalls and alerts of consumer products, consultations, reports, etc.

Design Process

The design process for the 8Ball user interface

Images 5 & 6: Mock-ups of 8Ball application and OCR capabilities

Benefits to Health Canada

The real-time compliance verification of products that the 8Ball Project presents will allow for numerous gains in accuracy, efficiency, and outreach such as:

• Ability to generate accessible reports that inspectors can share with regulated parties to promote outreach and regulation compliance
• Generated data from inputs allow for further and more thorough data analysis for future surveillance
• Provide a cohesive platform for inspectors to quickly and remotely access information
• Allows CPS to use the photographs taken by users to store the most up to date information on products such as accurate lot /model numbers, bar codes, product descriptions etc.
• Increase consumer confidence and government transparency by making information more easily accessible to members of the unregulated parties