:
Good morning, ladies and gentlemen. Welcome to the Standing Committee on Government Operations and Estimates meeting number 47. We are assembled today to continue our study on the Standards Council of Canada.
We can welcome today two witnesses, one by video conference, and one present with us in the room.
First of all, by video conference, we have Mr. Jean Rousseau.
You are very welcome, Mr. Rousseau. We apologize for having you attend the committee last week when we were called away for votes in the House of Commons and were unable to accept your testimony. Thank you very much for making the time to be with us here again today.
Also, we are joined by Mr. Graham Rae Dulmage, the director of the standards department, government relations, of the Underwriters Laboratories of Canada, who will make a submission in person to us today.
We are going to proceed in the order that we have in our agenda. We will invite Mr. Dulmage to make a brief opening comment, and then we'll ask Mr. Rousseau and go to questions following both of the submissions.
Mr. Dulmage, you have the floor for opening remarks, please.
Good morning, my name is Jean Rousseau. I am the senior director of the Bureau de normalisation du Québec. I am pleased to appear before the members of this committee. I would like to share with you my knowledge about the area of standardization. I hope that my answers to your questions will be able to help you with your thoughts and your inquiries.
My presence here today comes from the fact that the organization I represent is involved in the same area as the Canadian General Standards Board (CGSB) in terms of the services we provide. The Bureau de normalisation du Québec is also governmental in nature. So let me introduce you to the BNQ.
The BNQ was established by the Government of Quebec in 1961. So the BNQ is a little younger than the CGSB. Since 1990, the BNQ has been an operational branch of the Centre de recherche industrielle du Québec, which reports to Quebec's ministère de l'Économie, de l'Innovation et des Exportations. The Government of Quebec recognizes the BNQ as the central organization in matters of standardization, certification and the provision of information about standards, and as Quebec’s voice at the Canadian General Standards Board, or any other standardization body.
The initial reason for its creation was to give Quebec an organization that could draw up specifications for all procurements bought by the Government of Quebec. Since then, those needs have changed; the mission of the BNQ today is to act as a partner in business, industrial, social and governmental matters by providing solutions for their needs through the development of standards and certification programs.
The BNQ is a member organization of the Canadian General Standards Board, which is affiliated to the International Standards Organization, the ISO. It conducts its activities in the following areas: developing standards, certifying products, processes and services, and evaluating the competencies of testing and analytical laboratories.
The various accreditations, such as the Standards Council of Canada accreditation that the BNQ holds, guarantees clients that the mandates they entrust to us are conducted according to international criteria that embody best practices in standardization, certification and registration of management systems.
In conclusion, the BNQ conducts its activities in a large number of sectors, including construction, the environment, sustainable development, forestry and public works, health and safety, agriculture and agri-food. Our team has a little more than 50 employees and can call on a large network of subcontractors. In addition, the BNQ is supported by about 700 members of various committees, all of them volunteer.
There you have the organization. I have been working in the standardization area for about 30 years and I will be pleased to answer all your questions. Thank you.
:
There's a fairly lengthy answer. I'll try to give a short one.
If you compare Canada's standards system to those of other countries, we and the U.S.A. are a little different, because we have independent or private standards development systems. Most other countries, such as those in Europe or Australia, have a state-owned or a state-related member body, such as the SCC, which is the member body for ISO. One of the complexities in our system is that we don't have, compared to our peers, a huge number of standards. I think that's because historically, due to our constitution and the way the country is set up, standards are used more to promote or relate to regulatory matters and less for industrial needs, so you see a lower number. Someone might say they have 30,000 standards. A lot of those 30,000 standards might be used by industry. Are they audited? Probably not. So there's a variation in that.
The other complexity we have in the way we develop our system is that as SDOs, we often run into the case where province A or regulator A refers to four editions back of our standard, but all the rest, or half of them, refer to the latest edition. For us that creates some maintenance headaches and a lot of phone calls from somebody who's trying to figure out which one they should certify to.
Our system has a parallel system called the code system. You have the Canadian Commission on Building and Fire Codes, which I sit on as the representative for SDOs. It writes the codes. It is not formally part of the standards system, but it is a key element. We try to coordinate and work on it very much. We've developed a guideline for coordination between the SDOs. Our biggest challenge is getting members. We're all getting older. The industry in the country is not as strong as it used to be. We don't like to have a representative from a branch plant; we'd rather have an expert.
We carry our weight very heavily at the international level, at ISO and IEC, but I see coming down the pipe the need to really get down to harmonizing cross-country. As a country, and in terms of standards systems, we have to deal with the case that the Europeans and the Chinese are increasingly influencing what we have to write and what we have to measure to. We have to get together as a group and do that.
The SCC has, therefore, changed its way of working. When I was there it was very much inward looking. It's looking out to see how it can drive the system through innovation. To me, the key to our system is that we have to move away from writing standards through regulation to writing standards to create innovation, so that people will want to locate their factories and their research centres in this country and build out from there.
Thank you.
Is it possible to simplify the Canadian system? I would say that the Canadian system works in more or less the same way as other countries in the world. The exception is that, in Canada, activities are controlled by an organization, the Standards Council of Canada. That council accredits organizations in, among other areas, “developing standards”. That is the context in which organizations like Normes ULC, the Bureau de normalisation du Québec, the CGSB or the CSA work to develop standards.
The mandatory aspect is another point. Often the mandatory aspect of standards is brought up. I feel that we must make a small distinction. In some cases, standards become mandatory when they are referenced in regulations. But many standards are voluntary in nature. That is a major tool in the economic development of companies and organizations that want to adopt methods on which there is consensus when evaluating products or services.
To conclude, I would add that, when a standards development organization wants to develop a new one, it has the obligation to check whether, anywhere in the world, a standard already exists that has been published by a standardization organization and whether, in Canada, a standard has already been recognized as national. That checking has to be done before establishing a new standard and setting things in motion.
:
Gentlemen, thank you for joining us today.
Prior to being elected to this wonderful place, I was in the association management business for 12 years in the greater Toronto area. I had an opportunity to work with different government officials on different regulations and rules and standards, in this case as it related to the housing sector. It was certainly my impression that the people involved in these sectors, the people who do the hands-on work every day, were far better attuned to the standards and what needed to be achieved than, quite frankly, the bureaucrats ever were. The bureaucrats did the best job they could but they were not practical, hands-on people in the industry.
It seems as if there are several associations and boards all doing the same thing. Duplication is likely going on, which is likely costing companies that have to comply in extra time and extra money. Is that what's happening here? Do we have a duplication of services? Maybe we're not using as much of the expertise of private sector operators who know their businesses and know what needs to be achieved.
If that is the case, is there not some way we can pare this down so we have one set of standards, one body that does the accreditation and sets the standard? Should it not be the goal at the end of the day, to have one seamless system that works for everybody?
I'll start with Mr. Dulmage, and then Mr. Rousseau can certainly comment as well.
:
If I understand your question, you want to know if there should be a one-size-fits-all solution or one solution.
In Canada, we're much ahead of the U.S. The U.S. has 15,000 regulators, and we have thirteen times four in the sectors.
You're right that I often run into issues where an authority has an idea but hasn't talked to the sector, and the sectors get up in arms. We now have eight SDOs. We could have a system, such as the Germans do, whereby the accredited SDOs would prepare and publish the standards, and you wouldn't go to an association to get them because you would get these inherent or unintentional biases. You would use the system, let it develop for you, and adhere to it. That, to me, would be where we should go.
Should we have one SDO? My guess is that in 30 or 40 years we will have one, because our economic needs are so great that we'll have to be in sync with the rest of the world, but right now I think the eight we have can do the job, working with the SCC. We do try to avoid duplication if we can.
:
The standards are published. The people who work on the technical content of those documents are members of the standardization committees, with all the other members. So you must have a committee with some balance.
However, we must not forget a really important aspect. The standards development organizations, such as the BNQ, the CGSB, the ULC or the CSA, manage a process that copies what the ISO does internationally, as do organizations in other countries.
That idea really has to be understood. Here is the difference. Yesterday, for example, the BNQ published a standard on explosives and safe distances for explosives. The BNQ does not provide the technical content of that standard, because the criteria are established by the experts in the area, the various parties involved, doing a lot of work at meetings of the standardization committees. That is all done under the supervision of the organization, such as the BNQ, that manages the standard development process: the committee work, all the public consultation, reviewing the comments, the official publication of the standards and the follow-up when changes are needed. It is about reviewing the standards in question with the methodology and the frequency required.
That is the information I wanted to add.
:
I just hope that during my brief statement I don't cause any indigestion for committee members.
Mr. Chair, if you allow me, I will read my statement and then as you get to dessert, we'll be able to entertain questions.
On behalf of the Standards Council of Canada, I appreciate the opportunity to provide my comments on the programs and activities of the Canadian General Standards Board. As you are aware, the SCC is Canada’s national accreditation body. We accredit organizations that are in the business of developing and maintaining standards. In our lingo, we call those bodies standards development organizations, so when an organization develops standards, the acronym we use to refer to it is SDO. You'll hear me talking about SDOs. I apologize if I get into acronyms. We also accredit bodies that certify products to ensure they meet the standards. Those bodies are called conformity assessment bodies or CABs. So you have organizations that develop standards and organizations that test products according to those standards. We accredit both types of organizations at SCC. SCC, it's very important to note, does not develop standards itself, so we are not in the business of developing standards, and we do not certify products either. From that vantage point, SCC is not a competitor to the Canadian General Standards Board, CGSB. Our role is to accredit this organization when it develops standards or in a case where it certifies products. That's our relationship with CGSB.
Up until three years ago, there were only four organizations that were accredited to develop standards in Canada. One was the CGSB. That's the subject of our discussion this afternoon. Then there's the Canadian Standards Association, CSA, which is the largest one in Canada. So that's another one. You also heard Rae Dulmage earlier this morning from Underwriters' Laboratories of Canada, ULC; and Monsieur Rousseau from the BNQ. So those are the four organizations that we accredited previously. Since 2012 the number of SCC-accredited bodies to develop standards has been expanded to eight. So now we accredit eight organizations. The additional organizations include the American Society for Testing and Materials, ASTM. It's a very large U.S.-based organization with hundreds of standards being used across Canada. There is Underwriters' Laboratories, UL; the Air Conditioning, Heating, and Refrigeration Institute, AHRI; and the last one recently, the National Sanitation Foundation, NSF, which is in the business of developing standards for water quality and testing. I will explain the impact of this important development in a few minutes.
In order to maintain SCC accreditation, all SDOs must follow a standards development process that we have developed and are maintaining. This process is based on internationally accepted guidelines. It is in compliance with the Code of Good Practice from the World Trade Organization. In a few words, it promotes the open, transparent, and inclusive standards development process. The SDOs that we accredit must establish standards development committees that consist of a balanced matrix of representatives from affected stakeholders. That's one thing. The second thing is that committee members are selected based on their ability to represent a combination of interests and expertise. No single group in our committee structure can dominate the agenda or decide the outcome. A balanced matrix of interests means a balance between regulators and industry, consumers and academics, so that you come to a consensus when you develop a standard.
One important aspect of our process is that—and you heard it this morning—the developer of the standards is required to assess the need for revisions at least every five years. If that needs to be done more frequently, then the SDOs will do that. This is an important feature of the standards development process. In response to technological change, health and safety, and market conditions, many standards are under almost constant review and revision.
I want to talk to you about trends regarding standardization in the country, which impact CGSB, consumers, and regulators.
Over the past decade, we have seen a clear shift from developing and using domestic standards to developing and using either North American or international standards in Canada. Our catalogue of domestic standards, which used to contain more than 5,000 different documents about 15 years ago, has shrunk to 2,600 this year—so it's been diminished by roughly half—and that downward trend will continue, so we'll have fewer and fewer specifically Canadian standards in our current marketplace in terms of standards development. Conversely, we have seen a significant growth of activity at the international level. If you think about the major standards development organizations internationally, such as ISO, IEC, which deals with electro-technical standards, and ITU, which deals with telecommunications, their combined catalogue of standards exceeds 30,000 documents. We see about 1,000 to 2,000 standards being published every year by these three large organizations, so the catalogue of standards internationally is growing by leaps and bounds.
Our role at SCC is to coordinate the effective participation of more than 2,600 Canadians in international standards development activities to ensure that our strategic interests are reflected in the key standards that are being developed. The issue here is that we have to make a distinction, given the scope of activity, between those areas in which we have to agree and accept that we are standards-takers, while accepting that these international standards can be used in Canada, and those areas in which we have to become standards-makers, areas in which we have a strategic interest in ensuring that those standards reflect our needs. That's a distinction that wasn't made in the past and now we need to focus on it more and more. We're seeing industry reducing its investment in domestic standards and at the same time, when you look at regulators, we're seeing increasing reliance on international standards.
SCC maintains a database of all standards that are incorporated by reference in federal regulations. In 2014, we found more than 1,160 different standards incorporated in federal regulations. Only 38% of those standards are domestic. Everything else is either a standard from the U.S., a regional standard or an international standard. The trend is continuing, so as our domestic catalogue is shrinking, we see regulators using more and more regional and international standards.
I've spoken to you about the accreditation of those four additional SDOs in Canada. We should note that these organizations have been active in the country for many years. For example, ASTM, which is a very large U.S.-based testing business, has more than 1,400 Canadians participating in its committees. It's not as though it's a U.S.-based organization that has no roots in the country. It has significant roots in the country. We're just recognizing a fact of life now with the accreditation of this organization in Canada.
In terms of the trends, we're also seeing that Canadian business interests have been loud and clear on the need for one standard, one test accepted everywhere, in order to maintain their competitiveness vis-à-vis other regional markets, such as those in Europe and Asia. This is why our accreditation of these new standards development organizations makes sense: they will allow for the development of joint Canada-U.S. standards.
From a public policy perspective, we also need to step up our efforts on the standards front to develop more joint Canada-U.S. standards in order to support the objectives of the Regulatory Cooperation Council, the RCC. One example that we've recently announced is that UL will be developing joint Canada-U.S. standards for life jackets and marine abandonment suits. These will facilitate the harmonization efforts between Transport Canada and its counterparts in the U.S. Once developed, these standards will be adopted as national standards for Canada as well as the U.S. These standards will replace outdated domestic standards that are currently in CGSB's standards catalogue.
Over the course of the last three years, as part of its maintenance process, SCC has reviewed and looked at CGSB's standards catalogue. We've seen a trend here that I think is important for you to be aware of. We've asked CGSB to review and update its standards that have not been maintained according to our accreditation requirements. Although CGSB did withdraw more than 650 outdated standards from its collection, over half of the standards currently in its catalogue remain out of date. This situation is problematic for key stakeholders, including regulators, industry, and consumers.
As you continue your study, I hope this provides some context surrounding standardization in Canada, and I would be pleased to take any comments or questions.
Mr. Girard, I represent the constituents in the riding that was devastated by the Lac-Mégantic disaster on July 6, 2013. My constituents in Saint-Jean-sur-Richelieu are questioning the balance between rail safety standards and oil transportation risks. I mention oil transportation, but you could probably tell us about other such cases.
In your remarks, you talked about the growing trend away from domestic standards. In Quebec's case, it would even be provincial standards because we have a provincial regulating body. So there is a shift away from provincial and national standards towards binational, or regional, as you said, and international standards.
Because of that trend, are safety considerations specific to our reality likely to fall by the wayside when it comes to the transportation of dangerous goods by rail? By their very nature, international standards require broader consensus, resulting in added risk at the local level.
Does the trend concern you?
:
That's a great question.
We can't be involved in all international standards development activities around the world. Having the presence of mind to know which standards are strategically important, or even essential, to Canada is necessary. And those are the committees we need to contribute to. When Canada determines that certain products or processes are strategically important to the country, committees are established with a view to shaping those standards on the international stage.
Canada is well-received. Our representatives are extremely effective when participating in these international meetings, whether at the ISO or elsewhere. The same is true when you look to the U.S. As I see it, it's necessary to determine which standards are of strategic value to the country and whether health- or safety-related issues need to be considered in a different light. That is the way to establish a standard, and ensure that international standards and our needs coalesce.
Given the four new SCC-accredited organisations in Canada and the process we follow, we require that the Canadian process be applied when standards for use in Canada are being developed. The balanced matrix approach I mentioned earlier ensures that consumers, Canadians, have a place on the committees. That is the de facto approach to developing and maintaining these standards.
The first step is making choices, and the next step is to make sure those standards are aligned with our expectations and needs. As Mr. Rousseau pointed out earlier, if an international standard isn't to our satisfaction, we can always modify it and incorporate additional criteria.
:
About four years ago, under the clean air agenda, SCC accessed additional funds to develop standards to help northern communities adapt to a changing climate. There were no international standards for managing homes when the permafrost melts. It did not exist; there was no need.
We put money on the table. We issued an RFP, a request for proposal, and all of the accredited SDOs were able to compete in order to get the contract. CSA was able to deliver the contract. They've now issued standards for snow loads in the north, for permafrost melting, and for thermosiphons, which are tools you use to keep the permafrost frozen, and even for community drainage systems.
We are world leaders now, and I think that eventually you'll see these standards being reflected internationally as well. That's what we need to do in this country. We need to use our limited resources and focus on critical areas, and agree and accept to be standards-takers in areas where there's no additional risk. This way, we all win.
There's credibility in the system. It is invisible to most people, but it's there.
:
Oh yes, for prototype products, we see in mature sectors such as electrical or plumbing that the cost of prototyping a new product could be up to 50% of the expected revenues for the first year. If you multiply the number of requirements, that makes Canadian SMEs less competitive.
I'll contrast this with what is happening in the European Union. For the past 20 to 25 years the European Union has been putting a system in place so that once our European counterpart to the SCC, CENELEC, approves a standard, every single country under the commission, the European Union, will have to adopt that same standard and withdraw any competing standards from their books. We're talking here about France, Germany, and Italy. The Europeans have created a common market of 600 million consumers.
Here in Canada, because jurisdictions within Canada are not aligned, we hear industry telling us that they sometimes have to do two, three, or four tests for products in order to access the Canadian market. In the U.S., it's one or two. Generally speaking, it is one for the continental U.S. and then one additional one for California, because California has more stringent requirements for energy efficiency and those types of things. But that is two tests for 350 million people versus two, three, or four tests here for a market of 35 million people. That's why we believe there's a really urgent need to align standards among jurisdictions in Canada.