Thank you for your question.
According to my reading of the regulations, there are no limits on the ability to issue multiple penalties, as long as there are separate violations. For the same violation, of course, there will only be one penalty. If there are multiple violations, that can result in a number of measures, and it will be up to the commissioner to decide, in theory, whether there will be multiple penalties. It will be up to him to decide how to administer this.
As for the cumbersome nature or length of the process, as I mentioned, it's a well-established regime. That's my impression, but again, I'm not in the decision-makers' shoes. This is a well-established practice elsewhere in the federal government and elsewhere in Canada. I think the commissioner could learn from what's being done elsewhere and draw on the expertise of others, but it will be up to him to decide how he will manage this.