It is a pleasure to be here this evening. We welcome the opportunity to present our brief.
The Professional Institute represents 57,000 professionals across Canada in the public sector, many of whom work in the area of product safety.
Bill C-6, the proposed act addressing the safety of consumer products, gives Health Canada increased authority to protect the public's health and safety from unreasonable dangers posed by consumer products, whether manufactured in Canada or imported from abroad. The bill provides new authorities and tools to enforce compliance. The institute applauds the government's foresight in proposing this bill, and in broadening Health Canada's regulatory authority over consumer products. However, the institute is concerned that the funding is not sufficient. Present allocations may not allow Health Canada to hire enough product safety inspectors to successfully manage the increased responsibilities and obligations related to ensuring product safety.
There has been an exponential growth in the number of product recalls in Canada over the last few years. This is due to the increased number of imported products as well as the increased vigilance of product safety inspectors. Health Canada will become even more involved in providing safety rules and regulations for products—not only at the point of sale, but also during development, manufacturing, importing, and advertising. This stronger oversight role will be accompanied by increases in the reporting of dangerous incidents, product defects, labelling deficiencies, and recalls from other jurisdictions. There will also be increases in inspections of consumer products, seizures of consumer products, ordering of corrective measures, carrying out of recalls, and verifying of compliance. All reports will have to be reviewed and analyzed, and the physical in situ inspections and seizures will need to be stepped up.
Bill C-6 provides Health Canada with expanded powers to search, seize, and possibly destroy private property or take control of businesses if it has been determined that the act has been violated and unreasonable danger to the public health exists. Bill C-6 states that a review officer “shall complete the review within a reasonable time", and that the person who has requested the review is to be notified "without delay". This requires trained staff. It requires professional, qualified product inspectors. The work of a product inspector is exacting and demanding. Nowadays, citizens are requesting more information about the merchandise they buy for their families, and producers, importers, and manufacturers are urging timely action. It has been reported that some stakeholders are concerned about the amount of time it would take to review inspectors' orders for corrective measures. In light of this, we ask the following question: will there be sufficient inspectors to make sure that the new legislation is applied in a timely manner?
We are also concerned that the existing legislation already includes the provision to impose fines, but that these are rarely imposed. This is no doubt due to the lack of personnel needed to carry out the necessary follow-up in such cases. There are simply not enough inspectors.
There are over 630 scientific regulators, the SG group, across Canada, over 60 of whom are consumer product inspectors. Almost all SGs, 95%, are at the working level, with only 5% at the training level. Having so many experienced regulators is a positive, but the situation does not bode well for the future. As with the public service as a whole, a wave of retirements is about to take place. The time required to effect a proper transfer of knowledge is growing short. The loss of the corporate memory will make it difficult for Bill C-6 to be enforced.
The work of inspectors is becoming more technical. There are more demands placed on them, and inquiries are becoming lengthier. Moreover, the number of complaints is growing. It takes three to four years for a new hire to become independent in his or her work. A new product safety inspector will already have at least an undergraduate degree in science, perhaps combined with a few years of experience outside the federal government. More inspectors need to be hired, and experienced inspectors on the brink of retirement need enticements to stay on. This needs to happen very soon.
A clear Health Canada strategy is needed to deal with imported products at the border. Recurring problems are known to exist with some commodities. These need to be seized before they enter the Canadian market or need to be prevented from being imported. Recalls must be avoided. A coordinated effort on the part of the Canada Border Services Agency, or the CBSA, and Health Canada is required.
For example, some government departments and agencies prohibit certain goods from entering Canada. Other goods are controlled, which means that permits, certificates, labels or federal authorizations are needed before they can be released by the CBSA, which otherwise holds them until the importer meets the requirements. All parties must be trained to meet the requirements of Bill C-6. Increased controls must be in place before consumer products are imported into Canada.
Canada is a world leader in terms of food, health, and product safety. With regard to both food and health safety, federal regulators are involved in international education and policy-making. Canadians would benefit from the federal government hiring enough regulators and product inspectors to similarly help educate officials in other jurisdictions. This would reduce the likelihood of hazardous products being imported into Canada and subsequently being used by unsuspecting Canadians.
Our recommendations are for increased funding for Health Canada to allow it to fulfill its broadened mandate; a recruitment strategy to attract and train new inspectors; a retention policy to encourage current staff to remain in place longer in order to retain the corporate memory needed to train the new recruits—and the Expenditure Restraint Act's impact on public service salaries until 2011 is no help in this regard; and a coordinated strategy with the Canada Border Services Agency to prevent unsafe products from entering Canada.
Thank you.
