It sounds like there's nothing good that can possibly come of it, and I think that's very untrue. It's sort of a “sky is falling” type of approach.
You know, you may have said that about the regulatory approach before it was set up in government, too, but that's not the case. The regulatory approach serves a useful need. As was mentioned by our witnesses, for a document to be incorporated by reference, it must go through the regulatory process. So there is all that visibility in order to identify what documents would be incorporated by reference. That is gazetted.
There's also sort of a hierarchy, I think, and we know the hierarchy. That's what I was explaining before. There's legislation, there's regulation, and then there's incorporation by reference. It's a hierarchy that depends on the situation: you can't use regulations to make legislation, and you wouldn't use incorporation by reference to make regulations or legislation. They're meant to complement each other. They each have a role. I think what you're proposing here is actually being considered by CFIA, for example, right now.
The other thing I notice with your amendment is that we're under the Feeds Act here, but there is also incorporation by reference under the Fertilizers Act in this bill, the Seeds Act, the Health of Animals Act, and the Plant Protection Act. You didn't mention any of those. You only brought it up under the Feeds Act.
So I don't believe this is necessary.
Maybe the last point I'll make is that it says now “on the departmental website”. That's basically locking it into legislation. It doesn't really take into account, I think, evolving technology. Ten years from now, 15 years from now, websites may be passé. There may be new technology by which people access information. This is somewhat unduly restrictive. If you look back 10 or 15 years, apps were not known. Now we have apps. There are many different ways to communicate information, and I don't think legislation should narrowly define the way in which information is communicated. We are allowing, under the current wording of the act, that it must be “accessible”. That allows for transitions in technology over the next five, 10, 15, or 20 years without putting it right back through the legislative process to talk about how else it should be accessible.
Thank you, Chair.