Again, thank you very much for the question.
We agree, and I share the committee's interest in seeing concrete actions because it is an enormously complex area and we actually want to see steps. Beneath this action plan, I can assure the committee that there are many substeps. So when you have a chance to digest the plan, you may say, why is something not showing a date until, for example, March 2013? That will be, I can assure the members, because we've said, “Okay, what are the steps? How do you build this computer system to make that happen?”.
For example, on the question of timeliness, of notifying clinical trial sites of compliance ratings, the Auditor General pointed out that we did not have a standard operating procedure. We would inspect the clinical trial and we didn't actually have a benchmark for when that would occur. Now we are establishing those timeframes very specifically, so that our inspectors know that if they find something in a clinical trial site, there is a benchmark by which they are to have notified that shortfall back to the company specifically. So it's those kinds of operating procedures.
The Auditor General made a number of findings, where they said, “You tell us you're doing this according to a risk base. We don't see the absolute problems...but we don't see the documentation that can show us.” For example, on timeliness, in number 2 of our action plan, we are specifically doing that.
In terms of timeliness, the actual recommendation is that we meet our service standards. As I mentioned, we have improved our monitoring of the service standards. We now have a database. We look at them monthly at our executive committee table. As I mentioned, we can see that in most of our areas, such as new drugs, we've eliminated the backlog and we can monitor them very specifically. We have adapted the new resources and have devoted new resources to, very specifically, moving forward on the generic drugs.
I note here that there was a comment made about conflict of interest. We took immediate action. Actually, the Auditor General said that we had not documented our general conflict of interest policies. Our forms were in keeping with the policies, but we had, perhaps, to go above and beyond in an area as sensitive as drugs. So last November we actually took every person in the branch, addressed that conflict of interest very specifically, and we have those now back from the vast majority of employees in the branch. We have also hired an outside resource to advise us as to whether, more specifically, there are best practices worldwide that should take us beyond that.
So there are a number of things here. We have built quite specifically on the post-marketing side as well.