It's important to remember that incorporation by reference is a choice, not an obligation. There are different ways to implement our international obligations. We can do it through legislation, incorporation by reference or routine regulations. The regulatory authorities have a range of choices. Incorporation by reference is just one tool of many and is not mandatory. If concerns like this exist, they need to be studied conscientiously when deciding whether to use incorporation by reference.
These agencies and entities do not develop these regulations for their future incorporation by reference. They would do it anyway. Then, it is up to Canada to decide whether it wants to benefit from their expertise through incorporation by reference. The government can also choose to pass legislation to fulfill its obligations.