I'm not so sure about that.
My point is that if you change the word, there are two things going on. There are two suggestions you made.
If you replace the word “they” by “CFIA”, then what you're saying is that the CFIA—not the inspector, but the CFIA—as an institution must have reasonable grounds. That's very different from the inspector who has been vested with certain authorities through legislation and through the CFIA having reasonable grounds. It is institutionalizing that portion of the decision. That was my main comment. I think that will slow it down because now the CFIA, as an institution, must have reasonable grounds. They must communicate that to the company, document or no document.
Your second point, though, is that the reasonable grounds must be documented. I appreciate your clarification, but I think just inserting the word “document” doesn't necessarily achieve what you want it to achieve. When you look at some of the things the inspector is doing, this will grant the ability for the inspector to examine, or test, or take samples of anything that is in the place, or open a package that is in the place, or examine a document that is in the place.
Again, you are asking the inspector, who must have reasonable grounds—it can't just be on a whim, but there must be reasonable grounds for doing so—to write it out, submit it back into the institutional CFIA, have the institutional CFIA allow him to do these rather reasonable inspection-type activities.
I do find that onerous. I understand that you're saying you don't want it to be onerous. I get it. But I actually think it will be onerous because when you read it and start thinking about how this would work, it would become onerous. It would become slow, and the response time of inspectors would drop dramatically.