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OGGO Committee Report

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CHAPTER TWO: STANDARDS IN CANADA

Standards Council of Canada

The SCC is a federal Crown corporation established in 1970 that reports directly to Parliament under the Industry Canada portfolio. It is the organization that accredits Canadian SDOs. It also represents Canada internationally on matters related to standards. It is mandated by the Standards Council of Canada Act to promote efficient and effective standardization.

The SCC has a 13-member Governing Council appointed by the federal government and about 90 employees. It also has a Standards Development Organizations Advisory Committee that, according to a PWGSC official, meets two to four times a year to discuss governance and cooperation.

On an annual basis, the SCC assesses the various Canadian SDOs, including the CGSB. This assessment consists of a series of criteria that are rated as being adequate, inadequate, not applicable or omitted from the assessment. The criteria look, for example, at the SDO’s ability to organize tests and develop standards, as well as the number of supplier complaints.  

Standards Development Organizations

According to their official, the SCC has a repository of all Canadian standards. If an SDO is interested in developing a standard and has the appropriate expertise, it submits a request to the SCC, which consults its standards repository to make sure that no similar standard already exists for the same product, and if no other SDO is opposed, it may proceed. The BNQ official confirmed that before developing a standard, an SDO must also verify whether an equivalent standard for the same product already exists in Canada or elsewhere.

In some cases, an international standard is adapted to specific Canadian conditions, such as climate. A Canadian Fuels Association representative gave the following example:

Because Canada is such a large country, with such a varied climate, it’s very specific. It’s one of the coldest places to live in the world in the winter. Essentially the standard identifies those attributes that are specific to Canadian conditions, whether it is the fuel we use in our aviation, for example, the fuel that we need to heat our northern communities, to provide diesel in our coal mines, or to provide gasoline for our vehicles as they travel huge distances in climates that vary from day to day and week to week. That’s why CGSB is good. It essentially helps in adapting the standards, which are probably 90% to 95% standardized between Canada and the U.S. But it’s that 5% or 10% that’s specific to the particular climatic conditions of Canada that CGSB helps us to address.

In order to develop a standard, an SDO must first establish a technical committee whose members represent the various stakeholders, such as experts, employers’ representatives, researchers and consumer groups. As stated by the BNQ official with respect to committee membership, there must be balanced representation of three parties: manufacturers, users, and general interest groups such as regulatory bodies and experts. A PWGSC official noted that members of the committee elect their chair. Her colleague added that committees are consensus-based, so while a standard can be developed in two to three meetings if everyone is in agreement, it could take two to three years when there is significant disagreement. Officials from PWGSC and the BNQ specified that committee members are volunteers.

As explained by the SCC official, the draft standard must then be released for public scrutiny. Each public comment received must be reviewed by the chair of the committee and, if required, the draft standard must be amended before it is approved by the SCC in order to be designated a National Standard of Canada.

According to the BNQ official, the developer of a National Standard of Canada is required to assess the need for revisions at least every five years to ensure that the standard is still relevant, given how frequently technology changes. A PWGSC official said that the CGSB consults industry before changing a standard, since changes may have a significant impact on costs for companies.

Once a standard had been developed, conformity assessment bodies ensure that companies follow the standard. According to a PWGSC official, there are hundreds of these bodies; and according to the SCC official, these are accredited by the SCC.

Impact of Standardization

At the outset of this study, a PWGSC official explained to the Committee that ultimately the purpose of a standard is to “have an objective, performance-based statement of how a product should behave for a specific outcome.” He also noted that standards are useful for developing regulations, since regulations can then simply refer to the standard, rather than specifying what the product must be able to do. He added that standards also support government procurement “by defining requirements in a consistent and efficient manner for goods that government needs to buy.” In addition, they support federal departments “in protecting the health, safety, and welfare of workers and the public, in protecting our environment and in supporting the Canadian economy.”

A PWGSC official stated that it is the companies themselves looking for standards to be set in their field. Regardless of whether regulations make them mandatory, standards allow companies selling high-quality products and services to stand out.

Standards can also have the effect of promoting innovation. In fact, the ULC Standards representative defended the idea that standards should be utilized more often to support innovation and to attract the establishment of research facilities and factories here in Canada. In the case of the CGSB, its main client is the federal government. Their standards may often be developed to create regulations. However, these regulations may drive companies to innovate in order to comply with them. A PWGSC official affirmed that the CGSB supports innovation since most standards specify requirements in relation to the performance of a product, meaning what a product is able to do, rather than the process, meaning how that performance is to be achieved. In his view, this drives companies to find the best way to achieve the objective in relation to the performance of a product.

The SCC commissioned a study on the impact of standardization in Canada in July 2007. One of the conclusions of the report, Economic Value of Standardization, was that between 1981 and 2004, standardization accounted for 17% of the growth rate in labour productivity and 9% of the growth rate in Canada’s real gross domestic product.

A PWGSC official added that standardization puts small businesses on a level playing field with larger ones, since all companies must comply with this standard if required by regulations. If there are no regulations, the standard can give small businesses an idea of what their products must do to be considered of high quality.

Harmonization of Standards

Standards and regulations are not always harmonized in Canada among provinces and territories or between Canada and other countries, which often results in higher costs for manufacturers. The ULC Standards representative also noted that in some instances, provincial or territorial regulations refer to earlier versions of standards. The CGSB is not responsible for determining which standards are to be included in provincial and territorial regulations. However, a PWGSC official reiterated that before developing a standard, an SDO must ensure that there is not already a Canadian or international standard for the same product.

The ULC Standards representative also referred to the Agreement on Internal Trade, which includes provisions regarding standards and is managed by the Internal Trade Secretariat. He said that this agreement could help better harmonize how standards are used in provincial and territorial regulations. The BNQ official was also in favour of harmonizing the use of standards in provincial and territorial regulations. The SCC Provincial-Territorial Advisory Committee, which promotes cooperation and communications between the provinces, could also play a role in this.

With regard to standards harmonization, several witnesses suggested that the federal government, through either the Standards Council of Canada or another organization, should take the lead in harmonizing federal, provincial and territorial standards in order to promote the use of the same standards where appropriate. This simplification could help make Canadian companies more competitive.

North American and International Standards

With respect to North American standards, the Canada-United States Regulatory Cooperation Council Secretariat, under the Privy Council Office portfolio, is involved in improving consistency in both countries’ regulations and in joint standards development. For example, according to Canada-United States Regulatory Cooperation Council News February 2015, Environment Canada is working with the U.S. Environmental Protection Agency on the development and implementation of aligned standards on greenhouse gas emissions, which should lower compliance costs for companies.

Committee members believe that the Canada-United States Regulatory Cooperation Council Secretariat should make developing joint standards between both countries a priority, continue its work in this regard and expedite the joint standards development process.

There are also international standards, such as those developed by the International Organization for Standardization (ISO). The SCC official  said that the three largest international SDOs, including the ISO, manage a total of 30,000 standards, whereas there are only 2,600 National Standards of Canada.

The SCC official told the Committee that his organization represents Canada at international conferences and with organizations such as the ISO. It also coordinates the participation of Canadian SDOs such as the CGSB in technical committees developing international standards. He also said that in 2014, of the 1,160 standards incorporated in federal regulations, 38% were domestic standards and 62% were North American or international standards.