Thank you very much, Chair.
As Mr. Lemieux mentioned, the incorporation reference authority has been sought in other acts of Parliament recently—the Safe Food for Canadians Act and the Food and Drugs Act—in terms of incorporation of food additives. Incorporation by reference is really a regulatory tool that has been used for hundreds of years.
What we are doing in this authority is seeking a very clear authority as to how we would proceed on incorporation. What it does is allow the regulations to incorporate a document either as it exists at a specific time or as it's amended from time to time.
It allows us to have flexibility. The Governor in Council proposes regulations that contain a document, and that document can be referenced out. Then, as future changes can happen to that document, that's what gets incorporated into the regulations. It goes through a strict Governor in Council process. When we propose to incorporate a document, it goes through the entire regulatory process of GIC approval—CG1 and CG2—so the choice to incorporate that document by reference is done very deliberately.
What we've been doing at the Food Inspection Agency, because we were given this authority in the Safe Food for Canadians Act, is working diligently with stakeholders on how we would go about using the incorporations by reference authority on a consistent basis across all of our statutes. We're developing clear guidelines on consultation with industry, on the choice of documents, and then on how those documents may change in the future.
What the amendment would seem to do is that any time the Governor in Council wishes to put forward a regulation that would incorporate a document by reference, that regulation would then have to be tabled in front of Parliament for approval. For us, that would then add a lot to the regulatory process. It's above and beyond the bar that we normally have to do for all regulations, and the use of incorporation by reference is really to clarify, to provide details on things that maybe don't need to have the wait in regulation. I'm thinking of schedules of approved ingredients, where the provisions and approval part is in the regulation, and then you detail out the list in an incorporated document.
From our perspective, if we had to table those GIC-approved regulations in front of Parliament each time we wanted to incorporate a document, we very likely would not use that authority at all. We would go back to making regulations of schedules and lists, doing those directly in the regulation, and suffering through the regulatory process. When a new ingredient is added and industry really wants it, we would then have to go through the regular regulatory process, so from us, especially in contrast with the Safe Food for Canadians Act, the Food and Drugs Act, and the Department of Justice's own incorporation by reference bill, which all would not impose this.... Anyway, thank you very much.