Good morning, Mr. Chair and members of Parliament. It's a pleasure to be here today to provide our proposal for your consideration and to include in the clause-by-clause consideration of Bill C-97.
My name is Shannon Coombs and I'm the President of the Canadian Consumer Speciality Products Association. For 21 years, I have proudly represented the many accomplishments of this responsible and proactive industry. Today, I provided a one-pager, “Imagine Life Without Us?”, which illustrates the types of products CCSPA represents. I'm sure you have used many of them today.
CCSPA is a national trade association that represents 35 member companies across Canada, collectively a $20-billion industry employing 12,000 people across 87 facilities. Our companies manufacture, process, package and distribute consumer, industrial and institutional speciality products such as soaps and detergents, domestic pest control products, aerosols, hard surface disinfectants, deodorizers and automotive chemicals, or as I call it, everything under the kitchen sink.
I would also like to thank those MPs around the table who are assisting CCSPA with our social media campaigns on Lyme awareness, tick prevention and hand washing.
Why are we here today? Bill C-97 makes amendments to various pieces legislation. Part 4, division 9 of Bill C-97 includes provisions to support regulatory modernization in Canada. Four of the acts included within the regulatory modernization section impact our members. These pieces of legislation are the Pest Control Products Act, the Weights and Measures Act, the Food and Drugs Act, and the Hazardous Materials Information Review Act.
I would be pleased to answer any questions you may have regarding those acts. However, our primary focus today is not these but the Hazardous Products Act.
First and foremost, CCSPA applauds the government's commitment to support regulatory modernization in Canada. Minister Morneau's fall economic statement underscored the need for regulatory reform to make it easier for Canadian businesses to grow and remain competitive while still protecting the health and safety of Canadians. Given this commitment, we are here today to request the removal of a costly and unique-to-Canada provision in the Hazardous Products Act via Bill C-97.
The requirement found in paragraph 14.3(1)(a) of the Hazardous Products Act requires suppliers to keep a “true copy” of labels for workplace chemicals housed on a server in Canada for six years. This unique-to-Canada provision was included in the omnibus bill of 2014, when amendments were made to the Hazardous Products Act to allow for the modernization of the hazardous products regulations. As the provision for the “true copy” was included in the legislation, it did not have to go through any costing for companies. In the development of the regulations, it also avoided regulatory costing oversight as it was considered “compliance” and outside the scope of the regulations and the one-for-one rule. To date, no clear policy intent or objectives have been provided to us related to the true copy provision.
The cost for our member companies to comply with the true copy requirement is prohibitive and is realized throughout the entirety of the Canadian supply chain. On average, CCSPA members will have an initial investment for the first year of $4.2 million, $17 million in ongoing investment for each year for human resources, and up to $10 million associated with the Canadian server. If we were to break it down and look at the impact on an individual company, annual costs for one member with four manufacturing sites are estimated at $400,000 to inspect, photograph and catalogue 23,000 receipts of their raw materials annually. The costly process has been captured on the left-hand side of the the document that I provided to the clerk for your reference.
As members can see from the diagram on the right-hand side, costs are not just borne by the manufacturer but upstream by the supplier and downstream by the distributors. Everyone will have to collect and retain the label information already captured on the safety data sheet. The redundancy of collecting this information at multiple points in the supply chain is an unnecessary burden and one without a clearly defined benefit.
As mentioned earlier in my remarks, regulatory modernization must work together for the “health and safety of Canadians” policy objective. The removal of the true copy provision within the HPA does not diminish the protection of Canadian workers. Industry is obligated to provide safety data sheets for all hazardous materials and chemicals used in the workplace. Under the Hazardous Products Act, suppliers are required to retain a copy of all safety data sheets for six years. This requirement is aligned with the United States and the EU requirement for safety data sheet retention. We are the outlier with respect to this unique label data collection.
The role of a safety data sheet is such that employers are obligated to train workers on hazardous chemicals that they work with and to ensure that workers read and understand the safety data sheets before they begin handling the products. This helps to ensure that their workers are protected when they use those products. The safety data sheet, which contains all of the important information on how to use that product, is the most comprehensive document that can be used to train workers on the hazards and precautions specific to that product. As members can see from the copy of the SDS that the clerk has shared with you, it is the most comprehensive piece of information. The label is a limited restatement of those hazards and precautions that already appear on the SDS.
CCSPA has been and remains committed to working with this government to support an efficient and effective regulatory climate for businesses so that we can be competitive at home and abroad. We believe that the issues, as outlined, support our collective goal of meaningful regulatory change as per the government's regulatory reform agenda.
For companies who wish to be competitive in North America, this unusual paper burden, unique to Canada, is a disincentive to innovation and keeping businesses here. We respectfully request that the finance committee help us to remove this unique legislative burden and deliver against the government's regulatory reform agenda.
Thank you, Mr. Chair.