Thank you, Mr. Chair and committee members. I will be brief.
Canada's $55-billion-a-year chemistry industry is a significant contributor to the economy. We're also a fast-growing industry. Many would not know it, but we added $10 billion in new chemistry investments in Canada, announced during the past year. Nevertheless, to be perfectly frank, we believe Canada has a very serious problem with regulatory competitiveness.
According to the World Economic Forum, Canada ranks 14th out of all OECD countries in its overall competitiveness but 38th out of 40 when it comes to the overall burden of government regulation. Just imagine how far up the rankings we could move in our overall competitiveness if we could tackle this chronic issue of regulatory under-competitiveness.
What are our major concerns as a regulated community? Well, let's start with the serious levels of overlap and duplication across all levels of government, all jurisdictions. Add to that the rushed-out and poorly thought-out regulations that very rarely ever take into account the regulated entity's willingness to achieve the policy objectives but in a manner that will allow them to do so in a least-cost manner. We don't get that opportunity often enough. Then there are the uncertainty and timeliness issues we've heard about. Obtaining an approval in Canada generally takes an average of 249 days. That's double the OECD average and triple the amount of time required in the United States.
In short, we see a regulatory system that's multi-layered across departments and jurisdictions without clear authorities, which often results in delays, administrative burdens, and unnecessary costs to both government and business.
We're often asked in fora like this to identify one thing that could be done better to address this issue of regulatory competitiveness. I would encourage this committee to forgo simplistic solutions. You don't get to be a poor performer in any field by doing just one thing wrong. If you're at the bottom of the heap, there are a lot of things you're doing wrong, and you need to make systematic changes. This issue of regulatory competitiveness, to quote the deputy minister in Ontario, is a chronic disease with a heavy economic drag across the whole country.
While the regulatory burdens do cross multiple jurisdictions, we are here today to share our concerns specifically with the federal regulatory regime. We are also very, very pleased to see that our concerns are shared. In his fall economic statement, Minister Morneau did identify regulatory competitiveness as a key concern and did announce a number of measures to address it. Those measures included the recent cabinet directive on regulation. That's welcome, but I would suggest that there will be no meaningful improvement at all, whatsoever, unless the central agencies drive adherence to that directive with the same zeal and timeliness they drove government renewal and program review efforts more than two decades ago. Presently, we see absolutely no sign of this on a day-to-day basis.
I might also note, and perhaps this is most important of all, that the directive is completely silent on the question of jurisdictional issues within Canada and, unlike program review, poses no challenge for federal entities to consider the extent to which the issue in question is, or should be, the responsibility of our provincial governments and territories. The smart regulation initiative of 2004-05 offered a much more critical examination of the needs and benefits of cross-jurisdictional regulatory co-operation. As the issue of jurisdictional overlap and duplication is so prominent—perhaps the most perennial and important issue of all—this is an area in need of further urgent attention within that directive.
In my remaining minute, let me point out to you two examples of what in our view are actually very good practices of regulatory effort within the federal government. They both avoided many of the shortcomings that plagued the regulatory competitiveness issues in the system more broadly.
Within Health Canada and Environment Canada, the development and implementation of the chemicals management plan, first launched in 2006, has been a welcome exception. It's a complex program. It's difficult. But they've done a very good job managing the competitiveness aspects. The program remains on track to achieve all its objectives, and is being emulated by other jurisdictions across the world. Likewise, Transport Canada's multi-faceted approach to better managing the risks associated with the transportation of dangerous goods is also a complex policy and regulatory effort that has been remarkably well delivered. I encourage you to invite representatives of those programs to your committee to share their perspectives on why their regulatory initiatives are working so well when most of the others are simply not.
Finally, the Province of Ontario has also started important efforts in this area. A comprehensive red-tape challenge process was initiated by the previous government. The recommendations out of that are being delivered by the current government. Deputy Minister Giles Gherson has been at the helm of that exercise throughout. He too would make an excellent witness to this study. The deputy minister is guided by a vision of eliminating those regulations that add cost to business and to government but that do not add any benefit to the province or its citizens.
I'll just conclude by saying that the study being undertaken by this committee is most welcome and, in our view, urgently overdue. I encourage you to be honest and frank about Canada's regulatory competitiveness problems and to be just as broad and creative in your recommendations for addressing them.
Thank you for the opportunity to share our perspectives with you, and I certainly look forward to your questions.