As it is 8:45, we will begin the 38th meeting of the Standing Committee on Government Operations and Estimates immediately.
Today, we will hear from several witnesses who will speak about Bill .
During our last meeting, we heard from the. Today, we will hear from experts who will provide some clarification on the issue of administrative red tape that burdens businesses. Each witness will have 10 minutes to present.
We will begin with Ms. Jones and Ms. Moreau, who are here on behalf of the Canadian Federation of Independent Business. We will then move on to Ms. Coombs, from the Canadian Consumer Specialty Products Association, then to Mr. Aylward and Mr. West, for the Public Service Alliance of Canada. Following the three presentations, committee members will ask questions of the witnesses, until 9:45.
Without further ado, I give the floor to Ms. Jones and Ms. Moreau.
Thank you so much for being with us this morning.
:
Thank you very much. It's a real pleasure to be in Ottawa this morning, despite the cold weather.
My name is Laura Jones. I am the executive vice-president of the Canadian Federation of Independent Business. I am based in Vancouver.
Before I start, here are a couple of notes about CFIB. We are a group that represents small and mid-sized companies in Canada. We have 109,000 independently owned and operated businesses that are our members from coast to coast, across a number of different sectors of the economy. We are completely funded by those members, so we don't take any government funding. We are a non-profit organization. We take our policy direction from our small business members, so the positions that I present to you here today are reflective of those members.
If you turn to slide 3 on the deck, there is a little cartoon. We put this in because I think it captures beautifully the way small business owners often feel about red tape. They can certainly feel that they have more regulators than employees. Remember that most businesses in Canada have fewer than five employees. I think that sometimes, with the tough economy in some parts of the country, small businesses are feeling as if they have more regulators than customers.
This is really important, and it is a pleasure to be here to represent their perspective on red tape. I want to be clear about one thing, though, and that is that small businesses absolutely support necessary and important regulations, those regulations that protect human health, safety, and the environment. In fact, it might surprise some people to know that when we ask small businesses how much of the regulatory burden they think could be cut without sacrificing those important goals, they are saying between 25% and one third. It depends on whom you ask and how you ask the question, but it's roughly in that range. That means they're telling us that between two-thirds and three-quarters of the rules in the system are legitimate, necessary rules that they support.
However, red tape is extremely challenging for small business. That's where regulation becomes overly complicated or difficult to understand, or there is poor government customer service. This can come from legislation; it can come from regulation; it can come from related policies; it can come from the service around those policies.
We've done a number of studies looking at the cost of regulation. The next slide shows you that this is the second-highest priority for small business owners, right behind the total tax burden. We think of red tape as a kind of hidden, regressive tax. If you look at the next slide, you'll see that we've done an estimate of the total cost, which is $30 billion annually in Canada. I will tell you that this is a very, very conservative estimate of the cost.
We have broken that down by business size. Those businesses with the fewest employees pay the highest cost per employee. That makes sense because bigger businesses have more employees over whom they spread the burden. Big businesses often have whole departments, in fact, dedicated to regulatory compliance, whereas if you are a small business, you are doing a lot of that compliance yourself.
There are just a couple of other survey results to show you that excessive regulations add significant stress and take time away from family. I could show you a whole bevy of other results which show that they reduce productivity and cause people to think twice about starting businesses and about staying in business.
I do want to get to the next slide, because this is the one that shows that business owners are in general very, very supportive of the government's red tape action plan. In fact, as the action plan was developed, there were 15 consultations across Canada with small business owners. Many of our members participated in those consultations and made recommendations to the commission.
I think one of the great things about that commission was that, when you look at the reports it produced, it was in the words of small business owners. There was a “what was heard” report that was in their own words. There were a number of commitments made in that action plan; one of them was moving on the one-for-one rule and making it legislation. That's something that 83% of small businesses support. As you can see, many of them are very supportive of that initiative.
One of the things that CFIB often talks about with respect to regulatory reform when we are giving advice to governments in Canada, and we've also been asked for our advice outside of Canada, based on some of the work that's been done in jurisdictions such as British Columbia.... We see three key ingredients to effective reform: political leadership; accountability, which means measuring and reporting regularly; and constraints on regulators. One of the reasons we're very supportive of this bill is that we see it does touch on all three of those essential ingredients.
Before I open it up to questions, there are basically three messages that I want to leave you with today.
The first is that small businesses support necessary regulation and are very, very challenged by red tape. This is a very serious hidden regressive tax on small businesses.
The second message I want to leave you with today is that small businesses are strongly supportive of the one-for-one rule. Making it permanent or more permanent through legislation is something for which heads nod around small business tables.
The third thing I want to leave you with is this last cartoon. I think really the most important thing about regulatory reforms is the ultimate test as to whether they make a difference on the ground. It's way too early to tell whether some of the reforms that had been initiated are going to—we're very optimistic—have an impact on the ground. That's what we need to keep our eye on, and I think for the reforms to have a real impact on the ground, this is really the beginning of the beginning. We do need to continue to push. We need to continue to make progress and that will be something that small business owners will be cheerleading.
With that, I'll open it up to any questions you might have for me on the small business perspective of the bill, or red tape more generally.
:
Good morning, Mr. Chair and honourable members of the committee.
It's a pleasure to be here today to provide CCSPA's perspective on your review of the proposed legislation, Bill .
My name is Shannon Coombs and I'm the president of the Canadian Consumer Specialty Products Association. I have proudly represented the industry for the last 16 years and our many accomplishments as a proactive and responsible industry.
CCSPA is a national trade association that represents 35 member companies across Canada. We're collectively a $20 billion industry and employ 12,000 people in over 100 facilities.
Our companies manufacture, process, package, and distribute consumer, industrial, and institutional specialty products such as soaps, detergents, domestic pest control products, aerosols, hard surface disinfectants, deodorizers, and automotive chemicals, or as I call it everything under the kitchen sink. I have provided the clerk with copies of our one-pager, which has a picture of the products, and I'm sure many of you have used them today. Also, you would have received our goody bags in the spring, that is, of course assuming that your staff decided to share them with you.
Why are we here? CCSPA member companies are regulated. The ingredients in our products, the bottle, at times the end use—ant traps and disinfectants, for example—and all the labelling are regulated under the respective regulations and legislation. This is both for consumer and workplace use.
We support Bill because it adds the necessary checks and balances for regulation development, which in turn adds complexity and costs to doing business in Canada. The bill tackles the issue of administrative burden, which is very important to industry. While it may be very narrow in scope in only addressing regulatory burden brought on by paperwork, it is a positive step in the right direction.
It causes regulators to reflect on the costs to industry prior to the development and implementation of a regulation. Could the scope, the net, be bigger? Yes, we would argue that the scope could have included regulations that modernize labelling laws or ingredient regulations, which are very costly to industry.
We are currently faced with the implementation of the globally harmonized system of classification and labelling of chemicals for workplace chemicals. Industry will be changing all of its safety data sheets and labels to adopt the UN's globally harmonized system, GHS, which the U.S. recently adopted. This will be a significant cost to industry and the one-for-one rule does not apply. However, the spirit of the one-for-one rule was considered in the development of the regulation, and as Health Canada worked with officials from the U.S. Occupational Safety and Health Administration, OSHA, they reduced regulatory barriers so that industry could use one safety data sheet and one label within North America.
As per the RIAS, the Regulatory Impact Analysis Statement for GHS, it is “proposing to revise the classification and hazard communication requirements related to workplace hazardous chemicals in order to align the current system with that of the United States ... it is expected to reduce costs for industry while simultaneously enhancing the health and safety of Canadian workers.”
We support the GHS initiative and the intent to streamline regulations for the classification and labelling of workplace chemicals. We see Bill as a catalyst for change within regulatory development. It is the first in a stepwise approach to changing Canadian regulatory development processes and the culture that creates it, and it provides a rigorous check and balance function by Treasury Board.
Since the one-for-one rule has been introduced, we've seen officials within government open to ideas of harmonization to reduce regulatory burden with Treasury Board officials providing oversight and guidance to departments to ensure adherence to the policy. Both have been refreshing and effective.
For the proposed legislation to be successful, CCSPA would ask that the committee also undertake a review or accountability function to assess the successes and possible improvements by reviewing the scorecard and the metrics to develop that scorecard; by reviewing the successes not captured in the report, which I'm sure stakeholders could provide to you—I certainly can; by reviewing each of the departments forward regulatory plans; and also by ensuring departments publish and deliver on those plans and that the small business lens is being utilized within the departments.
Mr. Chair, thank you very much for the opportunity to comment on this important piece of legislation and provide our perspective. We support this legislation and will work with you and the officials to ensure the intent of the legislation is fulfilled.
I'd be happy to take any questions.
:
Thank you, Mr. Chair, and members of the committee for allowing representatives of the Public Service Alliance of Canada to appear before you this morning.
My name is Chris Aylward. I'm the national executive vice-president for PSAC.
PSAC represents public service workers who provide a broad range of regulatory, inspection, and enforcement services for Canadians. Our members protect Canadian consumers, and work in the fields of health and safety, food safety, transportation safety, and environmental protection, among others. They are proud of the work they do to protect Canadians.
Our major issue with Bill , an act to control the administrative burden that regulations impose on businesses, is that it is completely unnecessary. If members of Parliament and senators have passed laws and created regulations, we have to assume that they believed those laws and regulations were created in the public interest. The stated purpose of Bill C-21, the so-called red tape reduction act, is to eliminate one regulation for every regulation created, the one-for-one rule. If regulations are no longer deemed to be in the public interest after due consideration and consultation, the regulators have always had the ability to amend or delete them. In fact, they have done so on a regular basis. There is absolutely no need for the one-for-one rule. Everything that it claims to do can already be done.
Bill is filled with loaded terms like “red tape” and “administrative burden”. Laws and their accompanying regulations are important safeguards to balance rights in a democratic society. We should be proud that they exist and not paint them as red tape.
Administrative burden means anything that is necessary to demonstrate compliance with a regulation, including the collecting, processing, reporting and retaining of information and the completing of forms.
Why should it be a burden to obey the laws of the land? Why should it be a burden to make sure our citizens are protected?
Regulations in Canada have helped make this country one of the safest and best places to live. Canadians depend on regulations to protect our water, food, health, and consumer goods. Regulations ensure the safety of the roads we drive on and the environment we live in. They keep financial institutions, telecom companies, and other businesses in check. In the case of financial regulation, Canada's economy was sheltered from the worst of the 2008 global economic meltdown because our bank regulations were tougher than those in jurisdictions like the United States. Those regulations paid off and protected Canadians from the economic devastation that almost ruined some other countries.
Canadians also rely on their governments to enforce those regulations. Today, that reliance is in jeopardy. Not only are regulations on the chopping block, so are the people who enforce them. Federal inspectors in all sectors have seen their numbers and enforcement power reduced through successive budget cuts and freezes. For the past two years, for example, regulatory positions have been eliminated in beef research, aircraft service and maintenance, food-borne pathogen research, microbiological and viral disease research, civil aviation programs and road safety, cereal analysis, and aquatic ecosystem management and biosphere analysis. We are relying more and more on corporate self-regulation to the detriment of Canadians' health and safety.
Not only is Bill unnecessary, it will not adequately protect Canadians. While the bill says that the one-for-one rule must not compromise public health, public safety, or the Canadian economy, this is insufficient. It compromises a broader category of issues that concern Canadians, such as consumer protection and environmental protection. It could mean, for example, that our current strong financial regulations won't be there to protect Canadians in the event of future economic crises.
The immunity clause, clause 8, while absolutely essential if this bill becomes law, makes us wonder again why this bill is even necessary in the first place. This clause says that no action will be taken if this legislation isn't applied and that no regulation is invalid by reason only of a failure to comply with the act. As we understand it, the proposed legislation foresees that there will be occasions when the government will decide that the act can't and won't apply. If that's the case, and regulations can already be amended or deleted, what is the point of Bill ?
We believe there must be transparency around which current regulations will be traded away for new regulations. This is suggested in clause 9. However, clause 9 doesn't meet the test of transparency. Public or stakeholder consultation must occur openly before regulations are scrapped, not simply contained in a report after the fact. Our members believe that it is more important to the Canadian people that they spend time to actually inspect and enforce non-compliance.
For instance, in February of this year, in the case of Western Canada Wilderness Committee v. Canada (Fisheries and Oceans), the Federal Court declared that the Minister of the Environment and the Minister of Fisheries and Oceans acted unlawfully in delaying, for several years, the production of recovery strategies for four at-risk species. These species were threatened by industrial development, including the proposed northern gateway pipeline and tanker route.
The department's reasons for not meeting their legal obligations were staff shortages and not enough capacity. Yet between 2010 and 2017, Environment Canada will have cut, or plan to cut 21% of their staff, some 338 employees from the climate change division alone. At Fisheries and Oceans, there has been a further 30% cut of the staff who were responsible for the Species at Risk Act and the recovery and protection of all aquatic species in Canada.
ln 2014 there will be 60% fewer ground meat inspections than there were in 2013 at CFIA. This means that there will be less checking of fat content, filler, and fraudulent species claims. There will be no inspection of cooking oils. Less than half of the independent food retailers inspected in 2013 will be inspected this year.
Just last week the Transportation Safety Board said that the federal government isn't doing enough to enforce proper safety practices by Canada's railways, airlines, and marine operations. The board also said that there was an imbalance between auditing processes versus traditional inspections.
We agree with the Transportation Safety Board, and we believe that the Canadian public would agree. There needs to be more emphasis on real inspection and enforcement, not just on safety management systems. We certainly don't believe it's in anyone's interest to have public service regulators spending their time looking for regulations to cut just to meet the terms of this unnecessary bill. That would really be an administrative burden.
Bill is just one aspect of how regulations to protect Canadians are being undermined. First you eliminate the people who enforce the regulations, and then when you can no longer enforce them, you eliminate the regulations.
ln summary, we believe that Bill is unnecessary. At worst it is a make-work project that will mean regulatory and enforcement officers will have to spend their valuable time within a context of shrinking resources aimlessly looking for regulations to cut.
Thank you for your time.
:
With respect to the benefits that we're seeing, the scorecard is a very good first step to reflecting some of the first wave of regulations that the government was looking at to assess. From a metric standpoint, it's a really good review indicator of the potential that we have with respect to the policy.
It's a very transparent paper, and the way that the government has gone about it is very open and helpful to the industry. It sets the tone, and that's what I was talking about in my comments around the culture.
We're seeing a real willingness from the departments to look at the impacts on industry. From where I sit, and the number of companies that make soaps, detergents, and disinfectants, we're heavily regulated. We spend a lot of time with Health Canada and Environment Canada. I think there's a way that you can balance both the health and safety and environmental issues with looking at the cost to industry and keeping things competitive.
From a culture standpoint, we've seen a willingness from the departments to look at reviewing not just regulations but also guidance documents, which are very important to companies that are making free market submissions to the department and are able to have clear, predictable timelines, and information that they need to provide to the government for the review and approval of the products, so that we can bring new and innovative products to Canada.
:
I support what Shannon says about culture.
The one-for-one rule in British Columbia really had a huge impact on the culture of government. I've talked to civil servants there who have said they used to think of themselves as regulation makers. Now they think of themselves as regulation managers.
It is important that we all get serious about reducing the regulatory burden, because it continues to grow. This is what we hear from our members. Their capacity to deal with it is not growing.
If we are serious about protecting the environment, human health and safety, we have to encourage businesses to focus on the most important regulations. That culture change is enormous.
It also sends a very positive message to the business community around starting to get real about measuring this hidden tax. We should be serious about it. We should be as serious as we are about measuring the other fiscal taxes.
Those are two critical things that it does and many small businesses feel a bit like regulatory reform can be here today, gone tomorrow. Legislating sends a very different message.
:
I appreciate your saying in your presentation that political leadership is important as well as having accountability measures and constraints on regulators.
Both of you mentioned that there is a culture shift happening. Last week, Minister Clement said that he felt the implementation rules are leading to a positive cultural shift within the government. Now, particularly, the departments are more active in seeking solutions, so that again....
There's still compliance, Mr. Chair. I just want to make sure that people at home understand that regulations are going to be there, but it's looking at how we ask businesses to deal with the administrative burden and to report to government.
Ms. Jones, you mentioned earlier that there are other types of red tape, etc. Obviously, the government's action plan on red tape, and the commission that actually created it, did point out that there were other measures. I know the government is also working on another measure called the administrative baseline or burden baseline.
Do you think that, along with the one-for-one rule, is going to help to really identify and show accountability and report publicly, so that businesses can get an effective handle on how much they are being regulated?
My second question is for Ms. Coombs, Ms. Jones or Ms. Moreau, as the case may be.
Red tape is the hobby horse of all small and medium-sized businesses. Clearly, it's both popular and populist given that any business would like to avoid it as much as possible. It takes time, and time is money. Sometimes, a business grows and has to hire more people to deal with the paperwork.
On the other hand, we know quite well that had we not adopted regulations, for example for car seats for babies, they would not exist or would not be mandatory. Therefore, the regulations can also serve the business that develop the products.
When we will be faced with new products or events like those that took place in Lac-Mégantic, which required new regulations, don't you think the one-for-one rule will pose a problem?
:
I think it's important to understand, first of all, that the vast majority of small business owners care deeply about health and safety. Their employees are like family. You have fewer than five employees. During the recession, one of the things that really struck us was how many calls we got from small business owners who were doing everything they could to try to save the jobs of their employees, even when the bottom line didn't justify saving those jobs. So they do care deeply about those things.
One of the things we hear from small business owners is that if you load them down with too many complicated rules, or if they have to phone three times to get an answer to a straightforward question, that actually stops them from focusing on the most important rules.
It's always going to be challenging, you know, where that line is drawn, because to get a bit more safety sometimes can be very costly, and different people will draw that line in different places.
I don't think there is an easy answer to your question, other than to say that it is very important to small businesses. That's why, when you ask them how much of the burden of regulation could be cut without harming the legitimate objectives, they're not saying 100% or 50%; they're saying it's more like 25% to 30%, which I think is pretty reasonable.
:
I think in general, our members are not saying that you should cut all of the regulations. We haven't specifically surveyed and said, “which regulations do you like?” but when we talk to our members, they're generally quite supportive of rules that are fairly straightforward on the tax side. For example, they support the idea of paying their taxes. They support the idea of protecting their employees. They support the common sense environmental rules and regulations.
Really, what they don't support is when it's difficult to understand, when there's poor government customer service around it. For example, when you're trying to do your best to comply with tax rules, and you have to phone CRA five times, and you get three different answers on those five calls, and you're deciding to take the one that you hear the most, those are the things that really do frustrate small business.
We do appreciate that the Liberals, going back to the advisory committee on paper burden reduction which was a Liberal initiative, have supported red tape reduction.
In response to your comment about risks, I think the biggest risk of this is that we see the one-for-one rule as somehow accomplishing everything. It's a very powerful and important tool in the tool kit, but in order to make a difference on the ground, we have to complement that with the other initiatives that address some of the things that are outside of the one-for-one rule. That's really critical, that we not mistake the one-for-one rule....
Businesses get very nervous when governments think, “Okay, we've done that.” That's been the history of red tape reform in other jurisdictions in some provinces. I think that's the biggest risk here.
:
Thank you, Mr. Chair, and members of the Committee.
My name is Kendal Weber and I am the director general of policy, planning and international affairs in the health products and food branch at Health Canada.
Thank you for the opportunity to present Health Canada's perspective on Bill , the red tape reduction act.
As you know, Health Canada's primary mandate is to protect the health and safety of Canadians. We support the government's red tape reduction action plan, including enshrining the one-for-one rule in law to target and control administrative burden on business. Cutting red tape to business fosters growth, competitiveness, job creation, and innovation.
As one of the government's major regulators, Health Canada is committed to reducing regulatory administrative burden to industry, while ensuring that the health and safety of Canadians is not compromised.
Health Canada has an ambitious regulatory modernization agenda and follows good regulatory design principles, including the reduction of unnecessary administrative burden to industry. The good practices required by the one-for-one rule are consistent with departmental approaches to regulatory design.
With respect to reducing administrative burden, it is now a matter of practice within Health Canada that the development of regulations includes an assessment of the cost, alternatives, and consideration of ways to reduce the imposition of administrative burden on regulated parties, particularly small business.
This practice is embedded in the design of our regulations. Stakeholders are consulted throughout the regulatory development process, including on the assessment and costing of administrative burden, as well as identifying alternatives to minimize the burden without compromising on health and safety requirements.
Stakeholder consultations begin early and include publishing regulations in the Canada Gazette, part I. This pre-publication of regulations gives all Canadians a chance to submit their comments about a proposed regulation well before it is made. Bill would allow for a 24-month reconciliation of administrative burden. This flexibility over two years respects the realities of the timelines involved in introducing new or amended regulations through the Canada Gazette process.
ln implementing the requirements of the one-for-one rule over the past two years, we have recognized that there are opportunities within the 95 regulations which we administer to cut red tape and minimize burden on businesses while continuing to meet our mandate of protecting the health and safety of Canadians. These two objectives of health and safety and administrative burden reduction are not incompatible.
Here is an example of how Health Canada has been able to do just that: reduce administrative burden on business without compromising the health and safety of Canadians.
Pharmacists and their regulatory associations told us that certain requirements under the food and drug regulations were out of step with more modern provincial legislation and were unnecessarily prescriptive, requiring pharmacists to perform functions which could be safely performed by pharmacy technicians. We listened and amended the provisions that regulate prescription drugs. The regulations now allow the transfer of prescriptions by pharmacy technicians, an administrative task that was previously administered solely by pharmacists. This means that community pharmacies and retailers that dispense prescriptions may better utilize the skills of lower-salaried pharmacy technicians, thereby reducing the overall operating and administrative costs of business.
This change alone represents a net annual reduction of almost $15 million in unnecessary administrative burden and does not compromise the health and safety of Canadians. lt was of benefit to everyone, was practical, and made good sense.
As of June 2014, the department has contributed to approximately 70% of government-wide administrative cost reductions.
Health Canada will continue to seek opportunities to reduce unnecessary regulatory burden to industry implementing the one-for-one rule while protecting the health and safety of Canadians.
Furthermore, the department has embedded in its regulatory design a small business lens assessment to consider flexible regulatory options that reduce costs to small businesses.
Thank you for the opportunity to appear before you today on this important issue. I'm happy to answer your questions.
:
Mr. Chair, members of the committee, thank you for the opportunity to speak to you on behalf of Environment Canada about Bill , the red tape reduction act.
My name is Mike Beale. I'm the assistant deputy minister for environmental stewardship at Environment Canada. I'm here today with Stewart Lindale, who is the director of regulatory innovation and management systems at Environment Canada. Stewart oversees implementation of the one-for-one rule for the department.
[Translation]
Environment Canada administers over a dozen acts and more than 70 regulations that support the department's goal to provide Canadians with a clean, safe and sustainable environment.
[English]
The department has an active regulatory agenda. Our forward regulatory plan contains 42 initiatives that we anticipate advancing over the next two years. Since the one-for-one rule was introduced in April 2012, we have completed approximately 33 regulations or regulatory amendments.
[Translation]
As one of the government's most active regulatory departments, Environment Canada has, for many years, emphasized the importance of continual improvement in pursuit of regulatory excellence, and places high importance on strengthening the capacity of its people and its regulatory systems.
[English]
Before amending an existing regulation or designing a new one, we seek to ensure that it will be the right tool to achieve the risk management objective. When designing a regulation, we strive to ask only for information that is needed and only as often as required, maximize the use of online reporting, and actively engage regulatees in discussing ways to reduce administrative burden without compromising the attainment of environmental objectives.
To date, the one-for-one rule has been triggered for eleven Environment Canada regulatory initiatives, three of which added burden, and eight of which were regulatory amendments that reduced administrative burden without compromising environmental protection. In total, we have attained a net reduction in administrative burden of approximately $1.6 million over the past two years.
[Translation]
Environment Canada has actively engaged with the Treasury Board Secretariat in the implementation of the government's regulatory reform agenda, and going forward, we will continue to strive to minimize burden on Canadian business while fulfilling our environmental protection mandate.
[English]
Thank you.
I would be pleased to answer any questions.
:
Yes, for sure. Advancing any new regulation doesn't happen overnight. I think what's important is that we start the policy analysis process.
We do international comparisons. Sometimes, and we've done this most recently on nutrition labelling, we undertake an online consultation with the public at large, a Canadian public consultation. We then do a cost-benefit analysis. We use a cost calculator provided by the Treasury Board Secretariat.
That becomes a part of our regulatory package that is advanced to the Canada Gazette for consultation. In that RIAS, the regulatory impact assessment statement, we outline the costs and the benefits of the particular regulation that is going forward. It is put in the Canada Gazette for 30 or 75 days for consultation. We collect the comments, bring them back, advance to Treasury Board again, and then we publish in the Canada Gazette , part II.
In the instance I just mentioned, about the pharmacy technicians, we also engaged the pharmacists' association to conduct a survey to determine the costs to the industry. We actually engaged the pharmacists in the determination of that cost calculation.
:
I want to offer my thanks to you as presenters for being here today.
There are a number of questions I want to ask and some of them came out of the presentations from the last panellists.
Mr. Aylward indicated that he didn't support this particular bill and he gave a number of examples that I felt were dealing with health inspection issues and health issues in those areas. As you pointed out, Ms. Weber, they are completely exempt from this bill and not to be a part of it. I support the bill because those types of areas are not to be affected by the bill, health and safety in particular. I was pleased to see that the Canadian Federation of Independent Business supports necessary regulations, which is a part of this bill.
I've seen in Manitoba, where I come from, a number of situations where burdensome regulations have almost killed industries in our province. I think that it's important to make sure that this is taken into consideration when any of these changes are made. I noted that they indicated there are $30 billion in savings in this area if we look at red tape reduction. I'm not indicating that they can all be reduced, but that was their number. I think that's pretty significant given that it's 5% of Canada's debt in that area.
There is a move, I believe, that's needed to make sure that we do everything we can to be responsible about not putting a greater load on areas of small business and industries, particularly with small businesses. I know in Manitoba it's about 82% of the economy of the province.
With these two things I would ask for your comments again in regard to the issues of health and inspections, and in regard to impacts on the environment. I'll ask both Ms. Weber and Mr. Beale if that's part of the reason they support the bill, because of this area of protection of the health and safety issues.
:
First of all, there are two parts of the legislation. I think it's important to look at that.
There's the administrative burden that can be added with a regulatory amendment. It doesn't have to be a new title of a regulation. If a regulation is advanced that's an amendment to an existing regulation, we look at the administrative burden and how that can be reduced. That balance can be carried forward, as I mentioned earlier.
The second component is if a new title is introduced, a new regulatory framework. In Health Canada that doesn't happen often, so we don't actually have new titles that are added. But once a new title is added, it's at that point that a regulatory framework has to be removed within the two-year period. As I mentioned earlier, that has to be across the portfolio.
In the two-year forward plan—and we actually do forward planning that goes beyond that—we look at new regulatory amendments that may increase or reduce burden, and then also new titles, and then from that is the requirement to look for a repeal. It's not that it happens very quickly or overnight.
That's the process that we follow.
:
I can take a shot at that.
In response to this point, I think we have found that there have been some potential repeals that have quite clearly made sense. For example, in our forward regulatory plan, we're planning to remove the vinyl chloride release regulations. Those are regulations that have been in place for 22 years. The world has changed in those 22 years, and right now there's only one plant in Canada that is covered by those regulations. It's in Ontario. Ontario has a perfectly acceptable regulatory system there, so we decided there's really no value added to that regulation, and we've proposed its removal to the minister.
Similarly, we have a chlor-alkali mercury liquid effluent regulation. At the time that was introduced, it was a different situation. Right now there are no plants currently operating in Canada that are subject to that regulation.
So, we found regulations we could remove without any significant cost, in fact, without any cost at all to the environment.