Thank you, Mr. Byrne.
One of the drawbacks to inscribing everything in regulation is that it is a very time-consuming process. If you want to amend or modify anything later, based on new evidence or new data, it's a very laborious process to go through to effect the regulatory change. Not counting the time it takes for an act, but just a regulation, it often takes about two years.
One of the things I alluded to is that when it comes to the observer programs, the foundation for what the requirements are to be an observer company or an observer are already subscribed in a regulation. The broad, overarching piece is already there. We use the CGSB qualification process on our own DFO policies to interpret how this will be carried out to achieve the goals that were envisioned by legislation.
In short, knowing that we make changes annually—we review things, we try to improve things, we communicate it with the industry—I think inscribing all the qualification programs into regulation would be challenging and may not meet our end goal. My comments might be slightly different from the others’ because of the way we use the program.
The other piece is that it's not black and white. Regulations are often black and white. If you fail to abide by a regulation, there's a punitive side to it. There's some action taken that's usually very abrupt and very succinct, and you must do what's prescribed in law. The way the qualification program works now, the goal is not to say that you're doing a good job, or you're not doing a good job and get out. The goal is that if you are not up to par, we want to work with you, and the CGSB wants to work with you, to identify what the deficiency is and get you to correct it.
Our ultimate goal is not to try to keep only certain individuals in; it's to keep whoever wants to be in the program there and allow them to participate, but to make sure that they all deliver a program of the same quality and standard, and that they're all playing in the same ballpark, I guess.