I thank you for your question.
The previous witness spoke about collaborative governance with first nations. I think in Canada that's a model that can bring another voice to the table. Certainly in the CSAS process, it is one that excludes first nations despite their duty to consult being triggered.
I think one of the things, particularly with respect to finfish aquaculture, is that Canada needs to be more closely guided by the OIE's guidance and it's aquatic animal health code and manuals. For example, when DFO recently let industry licensees vote on how to diagnose HSMI, heart and skeletal muscle inflammation, a disease caused by PRV, it provided those folks with no direction, no terms of reference or no guidance either with respect to Canada's legal duties under the Fishery (General) Regulations or under the OIE's aquatic code.
As a result, they adopted a definition for disease that's almost impossible to make a diagnosis from. They departed from diagnosing disease in individuals at all for this disease and will only now diagnose HSMI if there is population mortality attributed to it. Of course, that creates a logical absurdity. You can't attribute population-level impacts if you aren't diagnosing individuals, and you can't diagnose—according to DFO's process—individuals unless you have population-level impacts. This departs from DFO's obligation to implement the precautionary principle; that is, anticipate, attack and prevent harm. Instead, DFO is looking for proof that the harm has occurred before it will act.
It also deviates from the OIE's aquatic manual in terms of the criteria for establishing sensitivity for diagnosis of outbreaks in epidemiological units and relying on a scientific perspective for diagnosis in an individual.
Moreover, it created significant conflicts of interest where industry licensees were asked to vote on how to diagnose a disease that, if diagnosed, would create significant regulatory burdens on their operations.
I think we need to follow the OIE's international guidance on managing those conflicts of interest, but DFO and CFIA also need to follow that international guidance on reporting emerging diseases.
When PRV was first detected in 2011 in British Columbia, that should have triggered DFO's and CFIA's obligation to report an emerging disease, that we now had a foreign virus detected in British Columbia that was causing disease in endangered chinook. Instead, that disease was—