Good morning, Mr. Chair, members of the committee. I'd like to thank you for giving us the opportunity today to speak to Bill S-11.
My name is Karen Proud. I'm the vice-president of federal government relations for the Retail Council of Canada. I'm going to keep my remarks fairly brief this morning because we've already submitted a brief to the committee and it details our position around Bill S-11.
The Retail Council of Canada represents over 9,000 members with 45,000 storefronts across Canada. Our members range from the large multinational companies that you're all familiar with to the smaller, independently run and owned companies.
In February of last year, a new grocery division was added to the Retail Council of Canada which amounts to about 95% of the total grocery industry in Canada. Our grocery members include: Loblaws, Walmart, Metro, Federated Co-ops, Co-op Atlantic, Sobeys, Costco, and Canada Safeway.
I'd like to start off by saying that RCC and our members fully support Bill S-11. This is evidenced by the fact that Minister Ritz announced the introduction of this bill at the location of one of our members and I was in attendance in support of that bill. I'd like to also mention that last week Minister Ritz appeared before you and said, “Consumers remain this government's number one priority when it comes to food safety and consumer confidence.”
I can tell you with certainty that if it was any one of our members sitting here today, they would say that exact same thing. Food safety is the number one priority for the grocery members. They expend considerable effort and resources ensuring that the products they sell to their customers are safe. In this, we are completely aligned with the policy intent behind this legislation.
As you will see from our brief, we are proposing a few amendments to the bill that we believe will improve it. I'm not going to go over these in detail as you've already been provided with a copy of our detailed brief, but I'd like to draw your attention to a couple of key points.
We do believe that there a few areas in the bill where the authorities are a bit broad. In the interest of transparency and clarity, we have suggested some minor changes that we feel don't detract from the intent of the bill and still provide the minister with the necessary authorities.
With regard to disclosure of confidential business information, we feel that the language that can be found in the recently passed Consumer Product Safety Act actually provides for a balanced approach that would give the minister necessary authorities in this area while recognizing the sensitive nature of this information.
As my friend, Mr. Laws, commented, we also have some concerns about incorporation by reference. We're not actually suggesting any sort of amendment to the bill, but we are asking that the committee make a recommendation that the Treasury Board Secretariat develop guidelines for departments in using this authority, as we've seen more and more pieces of legislation being passed that have the authority to incorporate documents by reference.
We'd like to make sure the departments are given guidance on how and when to use this authority, what sort of documents can be incorporated by reference, and the need for proper consultation with industry on those documents.
As I said, I wanted to be brief and I'm hoping that I achieved that. I would like to thank the committee again for providing us with the opportunity to share our views. I look forward to any questions you might have.