Good morning, Mr. Chair and honourable members of the committee.
It's a pleasure to be here today to provide CCSPA's perspective on your review of the proposed legislation, Bill C-21.
My name is Shannon Coombs and I'm the president of the Canadian Consumer Specialty Products Association. I have proudly represented the industry for the last 16 years and our many accomplishments as a proactive and responsible industry.
CCSPA is a national trade association that represents 35 member companies across Canada. We're collectively a $20 billion industry and employ 12,000 people in over 100 facilities.
Our companies manufacture, process, package, and distribute consumer, industrial, and institutional specialty products such as soaps, detergents, domestic pest control products, aerosols, hard surface disinfectants, deodorizers, and automotive chemicals, or as I call it everything under the kitchen sink. I have provided the clerk with copies of our one-pager, which has a picture of the products, and I'm sure many of you have used them today. Also, you would have received our goody bags in the spring, that is, of course assuming that your staff decided to share them with you.
Why are we here? CCSPA member companies are regulated. The ingredients in our products, the bottle, at times the end use—ant traps and disinfectants, for example—and all the labelling are regulated under the respective regulations and legislation. This is both for consumer and workplace use.
We support Bill C-21 because it adds the necessary checks and balances for regulation development, which in turn adds complexity and costs to doing business in Canada. The bill tackles the issue of administrative burden, which is very important to industry. While it may be very narrow in scope in only addressing regulatory burden brought on by paperwork, it is a positive step in the right direction.
It causes regulators to reflect on the costs to industry prior to the development and implementation of a regulation. Could the scope, the net, be bigger? Yes, we would argue that the scope could have included regulations that modernize labelling laws or ingredient regulations, which are very costly to industry.
We are currently faced with the implementation of the globally harmonized system of classification and labelling of chemicals for workplace chemicals. Industry will be changing all of its safety data sheets and labels to adopt the UN's globally harmonized system, GHS, which the U.S. recently adopted. This will be a significant cost to industry and the one-for-one rule does not apply. However, the spirit of the one-for-one rule was considered in the development of the regulation, and as Health Canada worked with officials from the U.S. Occupational Safety and Health Administration, OSHA, they reduced regulatory barriers so that industry could use one safety data sheet and one label within North America.
As per the RIAS, the Regulatory Impact Analysis Statement for GHS, it is “proposing to revise the classification and hazard communication requirements related to workplace hazardous chemicals in order to align the current system with that of the United States ... it is expected to reduce costs for industry while simultaneously enhancing the health and safety of Canadian workers.”
We support the GHS initiative and the intent to streamline regulations for the classification and labelling of workplace chemicals. We see Bill C-21 as a catalyst for change within regulatory development. It is the first in a stepwise approach to changing Canadian regulatory development processes and the culture that creates it, and it provides a rigorous check and balance function by Treasury Board.
Since the one-for-one rule has been introduced, we've seen officials within government open to ideas of harmonization to reduce regulatory burden with Treasury Board officials providing oversight and guidance to departments to ensure adherence to the policy. Both have been refreshing and effective.
For the proposed legislation to be successful, CCSPA would ask that the committee also undertake a review or accountability function to assess the successes and possible improvements by reviewing the scorecard and the metrics to develop that scorecard; by reviewing the successes not captured in the report, which I'm sure stakeholders could provide to you—I certainly can; by reviewing each of the departments forward regulatory plans; and also by ensuring departments publish and deliver on those plans and that the small business lens is being utilized within the departments.
Mr. Chair, thank you very much for the opportunity to comment on this important piece of legislation and provide our perspective. We support this legislation and will work with you and the officials to ensure the intent of the legislation is fulfilled.
I'd be happy to take any questions.