I think that is in the development of the regulations where we really need to consult. Our intent is to get that balance between science and innovation and biosafety and biosecurity, which means that the burden is going to be much less in terms of level 2 than for select 3s and 4s.
We think the level 3 and 4 laboratories already comply--almost all of the 150 laboratories--with the current human pathogens importation regulations. So for them this is essentially already in place.
I think what we're hearing today, and what we have heard in the information sessions and in a letter that British Columbia has crafted, are some of the details, and the devil really is in the detail of implementation. How would you structure your program so that cost is minimized? How would you structure a program for people who are working with the less dangerous pathogens, the risk group 2s? We're suggesting a less stringent requirement. So if you have no requirement for security clearance, if the inventories are very basic and you don't have risk groups 3 and 4, we're promoting a basic level of a national standard on laboratory biosafety.
I think the risk group 2 discussions are interesting, because we already require that people who import risk group 2 pathogens follow the laboratory biosafety guidelines under the human pathogen importation regulations. What we're suggesting is that for the 3,500 labs that we know are already doing this--including risk group 2 for importation purposes--we level the playing field in terms of all the other ones also requiring reasonable laboratory safety guidelines. If you remove risk group 2, you're going somewhat backwards on the human pathogen importation regulations and saying we're going to have a lower level than what we currently have for the 3,500 laboratories.
I think we will discuss all of the issues in terms of security clearance, costs, and not duplicating efforts already being made in the provinces in terms of how they're already looking, for example, at inspections of laboratories. We'll see where we can harmonize processes and increase efficiency in the development of the programmatic framework and the regulations development.