[English]
Good morning. I am pleased to appear before you today to discuss the Canadian General Standards Board, or CGSB, and how it engages Canadians in developing standards and providing conformity assessment services to meet the national interest.
[Translation]
With me is Desmond Gray, the senior executive responsible for the Canadian General Standards Board, or CGSB, one of the organizations under his direction, within the Acquisitions Branch of Public Works and Government Services Canada.
[English]
CGSB was created 80 years ago this year in 1934 to develop specifications and standards in support of government purchasing. It is the only federal organization with a mandate to provide standards and certification services. These services are provided in support of Canada's federal procurement, health, safety, trade, socio-economic, regulatory, and environmental interests.
CGSB develops standards in response to clear needs identified by Canadian stakeholders, such as government departments, industry, and consumers.
[Translation]
The Canadian General Standards Board does not itself write the standards, but rather manages a process to bring together the groups and organizations that have the knowledge of and interest in the standards, including manufacturers and users.
[English]
To do this, CGSB leverages a network of over 4,000 people, including technical experts, consumers, industry, academics, regulators, and others, who volunteer their time and expertise to develop standards and keep them current. This work also supports Canadian innovation and the Canadian economy.
Part of CGSB's role is to ensure that no one interest dominates the standards writing process. It does this by establishing an appropriate balance of members on technical standards development committees. In addition, the standards development process is open, fair, and transparent, to ensure various interests, including the Canadian public, have a voice, and that all views are considered and addressed.
CGSB has developed and manages over 300 standards in a wide range of areas. These include: petroleum, the CGSB standard for aviation fuel provides requirements for the composition, additives, testing, and inspection of fuel; protective clothing, for example, the CGSB standard for protection of firefighters' bodies against adverse effects during wild land fires; organic agriculture, which defines general principles and permitted substances, so that products that are certified to this standard can be labelled organic; construction, such as radon mitigation and glass. These construction standards are referenced in the National Building Code, which is the model code used by provincial-territorial building codes.
[Translation]
Recently, a new standard was developed for research ethics boards, which are required in Health Canada regulations for approval of clinical trials. The standard provides research ethics boards in Canada with a common platform for their governance, membership, operations, ethics review processes and quality management. CGSB was also recently approached to develop a standard for psychiatric service dogs. These dogs may be used to assist people with post-traumatic stress disorder, for instance.
The Canadian General Standards Board also offers a certification service when there is a need for a third-party, independent verification process to ensure that the products and services meet specific requirements. Certification allows suppliers to demonstrate that their products and services have been tested and meet the quality and performance characteristics the standard requires, providing assurance to buyers that the products and services will perform as expected.
[English]
Let me give you another example. The Department of Fisheries and Oceans designates private sector observers to monitor fisheries activities, such as the type and number of fish being caught and retained.
In 2012, Fisheries and Oceans asked CGSB to develop a program to certify that the companies employing these observers have the proper quality management systems in place, such as training programs. As part of the certification requirements, CGSB evaluates these companies every year and conducts on-site audits every three years. This provides confidence in the information that DFO relies on in supporting sustainable fisheries.
The Canadian General Standards Board also offers certification services to both the public and private sectors based on the International Organization for Standardization, ISO, standards for quality and environmental management. CGSB developed these programs in the early 1990s to meet the emerging market demand for ISO certification in Canada. As the private sector has since developed the capacity to meet this demand, CGSB is now refocusing its programs to support federal government requirements for this certification.
CGSB also partners with the Treasury Board Secretariat to certify personnel for the federal government procurement and materiel management community. This program certifies public servants delivering procurement and materiel management services with respect to clearly defined procurement requirements. That has been recently launched.
Internationally, Canada participates in agreements to recognize other countries' standards and certification systems and likewise to ensure Canadian standards and product certifications are recognized and accepted elsewhere, without the need for costly retesting. These agreements help provide Canadian businesses with access to global markets without additional administrative burden, delays, and costs. The Standards Council of Canada coordinates the national standards system and represents Canada internationally.
[Translation]
The Canadian General Standards Board and other Canadian standard development organizations—such as the Bureau de normalization du Québec, Canadian Standards Association and Underwriters Laboratories of Canada—participate in and contribute to this international work on behalf of Canada.
[English]
While CGSB typically works to harmonize its standards with international or North American standards, it also ensures that needs related to our country's unique climate, geography, and technological infrastructure are reflected in Canadian standards. For example, the standards being developed for radon mitigation need to consider Arctic-type extreme temperature conditions, Canadian soil geology characterized by high uranium content, unique geological formations, and Canadian building and construction work practices.
[Translation]
CGSB's work is carried out by a team of some 35 employees within PWGSC's Acquisitions Branch. CGSB's services are considered optional under the Treasury Board Common Services Policy, and the board derives approximately 80% of its budget from the recovery of costs from those who use its services.
[English]
Over the last 80 years, the CGSB has been a crucial forum for collaboration among Canadian stakeholders, helping develop standards that are supported and able to be implemented by industry.
To summarize, CGSB standards are often referenced in regulation, which helps minimize technical barriers to trade, as standards consider existing international requirements and are written in performance-based language, rather than vendor-specific.
CGSB standards allow Canadian industry to share knowledge and best practices, to foster innovation, and to be more competitive internationally. CGSB standards support government procurement by defining requirements in a consistent and efficient manner for goods that government needs to buy. CGSB standards and certification support federal government departments in protecting the health, safety, and welfare of workers and the public, in protecting our environment and in supporting the Canadian economy.
[Translation]
We trust this overview of the Canadian General Standards Board's programs and activities provides you with an understanding of the value of standardization for Canadians.
I would be happy to answer any of your questions.
[English]
Thank you very much.
Thank you, Mr. Sobrino, for the presentation. I guess you understand that the reason we've asked you to come here today is to explain some of the operations of the General Standards Board. It seems to those of us around this table that it's an organization that's been flying under the radar with very little scrutiny or oversight by any parliamentary committee for possibly many years—maybe ever.
I suppose, to put all of our cards on the table, there was a concern that there may be a duplication going on here, that this work may be being done effectively elsewhere by the Canadian Standards Association or whoever else manages these things. I guess your job here today will be to defend why the Government of Canada needs their own standards oversight organization.
I was interested to hear about the broad range of things the standards board is involved in. The designation of what can be labelled organic produce is something of great interest to Canadians, more and more. As they go to the grocery store and look to buy organic produce, can they really trust the label when it says this? If that's the type of thing the organization is involved with, then it seems to me, given the budget we're seeing, we're getting a real bargain. If we have 30 people looking for the best interests of Canadian consumers for a total price, after cost recovery, of $1.2 million.... That hardly makes up staff.
I notice that the budget is roughly $3 million, but the net cost is only $1.2 million. Where does the cost recovery come from? What kind of fees do you charge for this service—to the private sector, I imagine?
:
On the fees, I'll ask my colleague to look for that information.
The cost recovery is done from those who ask us to develop a standard, for instance. Back in the 2010 evaluation of the program, we had already instituted cost recovery, but they asked us to move to a full cost recovery organization. Most of the standards organizations are full cost recovery. They're driven by the fact that there's a particular interest across industry or by a regulator to institute a standard. We ask them to...under the common service policy we have, we recover costs that way.
The majority of our work, since about 2010, has been really refocused on government requirements. There are government departments who require standards for either regulatory purposes or for their particular mandates who ask us to come in and do those standards. Industry will approach us as well in areas where standards are just not viable in terms of the amount of investment to develop those standards. We're often asked to participate in doing that. So we tend to pick up those standards.
I think one of the important things, just to go back to one of the observations in your preamble, is that we have seven recognized standards organizations in Canada. One of the things we work on is to not duplicate the development of standards. We work with other standards organizations to try not to do the same work that others have done. It's costly and it takes a lot of time. Fundamentally, because standards organizations are accredited, they all follow the same process to arrive at the standards. There's no reason to suspect that another standards organization's standards aren't up to quality.
I will take another example—fuel, for instance. The interest that the federal government has on having a fuel standard is that we need fuel for aircraft that the government operates, for example; that fuel is specific to the needs of those kinds of aircraft. Those standards are set so that they can operate in the north in cold-weather environments, in high-humidity environments, and those kinds of things. Because we have to procure that fuel, we want to have a baseline where you then can actually go through a procurement that's not specifying a fuel but saying, “This is the fuel that has to perform to meet our requirements”. That's true of many of the standards we're facing.
On the cost recovery, Desmond has some information.
:
Yes, I can provide a bit more detail.
Basically, the work we do is really divided into two broad streams. One is actually the development of standards and maintaining standards, and then the certification activities that take place after.
It's an interesting comment you make about the value, because if you think about it, we have 4,000 Canadians contributing their time at really no cost to CGSB or the Government of Canada. So they participate and they come from all sectors, from industy, they come from the private sector, from consumer associations. They're academics and they participate in the committee work to develop these standards.
The only time we actually spend money in this area is for consumer groups when they have a challenge to provide funds for the travel, to make sure there's equity in the process and that all Canadian interests are represented in a balanced form. That's a very important part. But by and large, it's a very cost-effective model.
We don't charge any fees, in that sense, for the standards but we do get revenues from government departments because we're always based on the.... We don't simply develop a standard because we have an idea. It's at the request of some entity where there's a demonstrable need for some solution. For example, the Department of Transport may come forward and say it needs a solution, say, for fuel or for life jackets. Then we put together a balanced committee and seek funding, usually from one of these government entities, to help support this work. This is how it's done right across all of the major standards-writing organizations in this country.
Once we have the standard developed, of course, we then run a certification process where one is required, where there's a demonstrable need for a certification program. For example, I think if you talked to most standards organizations in Canada, they would say to you, be blunt about it. There's no money in writing a standard. Where the revenue stream comes in is in certification. For example, if you go into a home and you see the CSA mark on a light bulb, CSA receives a payment from the manufacturer every time that certification mark is put on a product, so that produces a revenue stream.
But for CGSB, because we're not in the private sector, we're focused on public interest in that sense, so we focus on.... We do have some certification programs. But we also do the ISO 9000 and ISO 14000. Again, we charge a fee to companies and to public sector entities that are being audited to that program, but at a very cost-effective model. So we're not, obviously, a for-profit entity, we're simply trying to recover our costs.
:
To be clear, we run the process that allows a standard to be established, so we don't set standards per se. What happens is someone comes in with a need. We pull together the committee to ensure that the technical committee can develop the standard. The committee is the one that develops the standard, but we'll facilitate the public comment period, all that. Then once that's done, the standard is established. It's then established under CGSB, so we put our name to it because it has followed the process to arrive at the standard.
So we have standards but we don't set them. We set them through the technical committees that are made up of all the interests that want to set the standards. That's why there's that confusion of we do and we don't. Those standards are then vetted through the Standards Council of Canada, which ensures that it's .... They accredit us for the system we run to set those standards.
In terms of everything has a standard.... In fact, we are the owners of the standard for the national flag of Canada. When I arrived in my job, one of the first things they showed me was the actual standard for the flag, which is an interesting piece. But standards are set everywhere for many things.
One thing though is that standards for certain things do come to an end. If we don't need those objects, they are no longer of interest to us, or another standards organization has begun to use that or modernize that standard, we'll drop them. We had about 1,000 standards back in 2008-09. We went through a rationalization process and we're now responsible for a little over 300 standards, which we continue to maintain.
Every standard has to be maintained and updated. We do it on a five-year cycle. We have to make sure that those standards are relevant to the Government of Canada, as opposed to things that we might have done in the past that have since moved into the private sector and are now available through private sector or the other standards organizations.
:
I can add a little to that.
That's a good question. Of course, you're absolutely right. ISO is like the United Nations. It's sort of the global level of standards. It's like a world body. It's in Geneva. It has about 20,000 standards globally. Canada participates in ISO along with 163 other countries. So you're right; there's a global structure for this.
ISO introduced the ISO 9000 quality management system standard in the early 1990s. I don't how many of you will remember that. The reason that became so significant in the marketplace at the time was that, in the early 1990s, the European community announced it would give preference to those in public procurement, in terms of their bid process, who demonstrated they met a demonstrable quality management system. The only one they recognized was ISO 9000. It just so happened. So there was an awful lot of take-up in Europe in terms of that standard, and then of course internationally companies that wanted to go into the European market had to move quickly to demonstrate they could achieve that certification.
We began this process in the 1990s to meet this demand in Canada, because the Canadian government recognized there was an urgent need to supply this service to Canadian companies, and the private sector simply had not ramped up yet to do it. We began to certify companies, private sector companies, that they had a demonstrable quality management system that met the 20 different components of the ISO standards.
So we'd go in to a manufacturing process.... I was an auditor. I'm a certified auditor. We would go in and review the books. We'd look at their processes. We'd review the manufacturing process. We'd look at their records. We'd interview their people to make sure they had a quality management system that met the standard and they were actually using it in an effective and demonstrable way to produce the correct products. That's what we've done.
Since then, the private sector has expanded hugely. In fact, now many national Canadian organizations do this. QMI is a big one in Canada, part of CSA. Also there are many international groups, such as BSI. The British are here, the Irish are here, and the Germans. It's a global community now that provides the support to business.
At CGSB, of course, our job is not to duplicate what is in the private sector. We do not compete with the private sector. So as that service has come to fruition, we have now refocused our energies on providing those services to public sector organizations.
In February 2013 Health Canada approached us to prepare a national standard for radon mitigation in residential buildings. It was part of the implementation of a Canadian strategy designed to refocus efforts to encourage indoor radon testing and the reduction of indoor radon levels. Health Canada's guidance document is called, “Reducing Radon Levels in Existing Homes: A Canadian Guide for Professional Contractors”, and this will serve as the core document that is going to help us develop this standard.
As you correctly pointed out, the differences in our climate and geography—and I mentioned this in my opening remarks—is that the mitigation standards and practices that come from the ASTM, the standards organization in the U.S., can't always be applied in situations where mitigation is an option to control the health risk from indoor radon exposure.
So we're working on developing two national standards. One is for radon control options in new low-rise residential buildings, and one will be for radon mitigation options for existing low-rise residential dwellings—what you have to do to retrofit, for instance.
Our objective is going to be to provide the requirements, the specifications, guidelines, and characteristics that can be used consistently to ensure that materials, products, processes, and services used in radon mitigation of low-rise residential homes are fit for their purpose. So we want to make sure that what people put into radon mitigation will actually work.
Our objective is to also harmonize technical specifications of products and services with the goal to make the industry and services related to radon mitigation more efficient, and to provide organizations and radon mitigation professionals in the industry a tool to ensure that product and services are consistent.
It's also about how they do it. It's not only what they use, but how they apply it, how they do it. Then we'll be following up with conformity, which is to ensure that the products and services meet the standards that are set, so that'll be the other side of our activity.
This is all with Health Canada. The complexity here, of course, is that radon is a very difficult gas to detect, so there's a big technical challenge in terms of that. We have academics participating, of course, the industry, the contractors, as well as health professionals.
So the standards' work will take the better part of two years to develop as we go back and forth with these discussions and they are quite open discussions. The technical committee is composed of all these participants and everybody puts their issues on the table. The goal is to have a standard so that the materials used for radon gas mitigation and how you apply it are understood and meet a standard that's going to be effective.
:
I think it's an interesting question.
Coming back to the previous comment, certainly the regime of certification is one that's very important. If you see a mark, and you cannot have confidence that the mark actually means something in terms of the product's performance, then, of course, we have a problem.
When I go out and buy something.... For example CGSB, for any of you who do construction if you ever get vapour barriers, installing a vapour barrier in your home, the ten mil vapour barrier, you will see the CGSB logo on it. Of course these products are tested.
So manufacturers have their product and they bring their product voluntarily to have it certified by us. We have a process to certify it including product testing. We use laboratories to certify and to test these products to make sure the samples perform. This is how we build confidence.
In many of these cases we do two things. We have what we call qualification and certification. We have a whole series of products we qualify, and that means we're doing it internally with laboratories to evaluate the product. In certification we actually have an external group that's also a third party review and provides for a greater degree of validation, if you want to put it that way. We use that often in higher-risk areas. For example we have medical gloves, which we certify for obvious reasons.
The certification regime itself is a critical piece of confidence in the marketplace to make sure people are getting a product that meets the standard, and they understand there's a consistent process that is being used, and a fair and accurate process that is being used. That's the confidence part.
:
Obviously there are those who may not want to have a standard in place for their products. The idea is to make sure that you're focusing your standard on limitations that are real such as health and safety, those kinds of things.
One of the important things that we believe standards provides is that, in terms of regulatory reform, in terms of regulation, regulations take years to amend and to change, but we're able to adapt regulations that reference to standards. We're able to change a standard and modernize a standard. We do it on a regular basis. In regulation, referencing to that standard makes sure that you're keeping up with the current state of the art.
The other thing with our standards is that, the way standards are written is performance based, so what we're looking for is the outcome of a product. It's not necessary that your personal flotation device be made by someone, but rather that it does certain things, that it's able to support certain weight, that it turns people over in the right direction if they're in water, and all that.
If your product meets that standard then that product can be certified and be out in the marketplace. It allows innovation; that's what it does. If someone comes up with a better way to make a personal flotation device, as long as it performs, it will be certified. In that sense, I think for small business, we support innovation. The more referencing to standards, the more in keeping with modern-day practices. Regulations take a long time to change.
:
I have two comments, and one is on the SME side. It comes back to some of the previous questions. In the past, because sometimes there is a challenge in terms of quality and consumer confidence in the marketplace, sometimes one of the solutions that private business looks to is to establish a standard where they get together with us. All the key participants create an objective standard and then we run a certification program, which is in a sense voluntary. You don't have to do it. There's no regulation that necessarily says you have to. What it does is it then tells consumers that this is what a good product is. This company meets the standards. An objective measure done by a third party gives confidence.
Sometimes in the past this has been used to distinguish for consumers between those companies that are well-managed, producing, and responsible companies, and those perhaps who have been less so. It provides for a clear mechanism for doing that. Often this is driven by business, because they recognize there's a need in terms of their industry to achieve this kind of distinction.
I do want to come back to your previous question. It was an excellent question. As part of the national standard system in Canada, every one of the standards-writing bodies has to follow a standard established by the Standards Council of Canada itself. We're audited every year on our processes and the work that we do. I just want to read to you in terms of one the things that we have to meet, because it relates to establishing and being aligned with international standards. It says our process is a requirement that reads:
When international standards exist or their completion is imminent, they, or their relevant parts, shall be used as the basis for corresponding standards developed by SDOs, except where such international standards or relevant parts would be ineffective or inappropriate.
So in a sense the whole structure, the whole approach is, let's see if there's an international standard first that we can use as a base document for the committee. We don't start off from scratch; we don't have to. We start off with an international standard where it exists and then we look at it in terms of Canadian needs.
As was mentioned by Pablo, ASTM had a standard for radon gas. We could have used that standard, but when we looked at it, parts of it simply didn't reflect Canadian need, so it had to be adjusted. In terms of harmonization, harmonization is always in the backs of our minds. It's part of our process. It's not just us; it's a requirement under our accreditation.
Mr. Gray, your last comment answered my first question in that there seemed to be a bit of a contradiction in the opening remarks. Pablo said that you do no development of standards, yet you answered Ms. Crowder's question by saying that you're currently developing two standards for radon. You more or less meant that you had to adapt existing standards to suit the Canadian reality. I understand that.
Again, in reading the notes that our analyst prepared for me, I'm very impressed with the amount of work and the volume of capacity in your shop, with 30 full-time employees, and what a bargain it is at $1.2 million net cost to the government for a lot of seemingly important consumer protection-type work. I can't think of another agency that operates with that kind of a net cost, so I'm very impressed with that.
Let me ask a question specifically, though, from the building industry, which is my background. I notice you've touched base on a lot of the regulations. I suppose the certification process for a construction contractor is, in your view, like a pre-qualification. Prior to bidding on government construction projects you'd have to be pre-qualified. But that was compromised and this committee dealt with that very issue on the West Block, for instance, where you can buy your way onto that list.
There is one famous example where the stonemason who was thrown off the job paid a Conservative lobbyist $10,000 a month for 15 months in a row and wound up not only getting on the pre-qualified list when he clearly wasn't, but ended up getting on the job and getting thrown off the job because he wasn't qualified. This is obviously an isolated incident but it's obviously in their best interest to get qualified and they're willing to pay a well-connected Conservative lobbyist in Montreal to get qualified.
It worries me that the system can be compromised. If you don't do any of your own standard development—and some standards are developed by industry for industry with some self-interest associated with it—are you the watchdogs to prevent that from happening?
Let's face it, when the ISO first came up it was part of that whole total quality management frenzy that swept—scientific management, TQM, PS 2000, or whatever it was called in various sectors. In the ISO standards, some industries set their own targets in order to meet those targets and that's all they had to do to get their ISO stamp. It was very easy to create your own. Meeting your own standards is different from meeting the needs stated by the customer.
What satisfaction can you offer us that the type of example I gave you with this Varin guy in Montreal and the corruption associated with being pre-qualified can't happen again?
:
I'm, of course, able to speak to that.
The most significant one had to do with moving to full cost recovery. We are now at about 80% to 90% of full cost recovery. We'll likely not achieve full cost recovery, because part of what the standards board does is help me in my other role in acquisitions, which is to set standards for things that I'm buying. Some of that work is internal, so I could move the money back and forth in my organization, but it would not really be full cost recovery. Essentially, any external work is now on full cost recovery. That was to meet one of the main recommendations of the evaluation.
The second thing had to do with what we're charging, and that was to ensure that we fully recovered costs. This goes back to an earlier question. Our standard rate at that time was about $1,000 a day, and the report recommended—and I don't know how they got to the dollar—$1,111 a day, and we're now up at about $1,300-a-day cost recovery to run the standards development process.
The certification services were at $1,050 per day, and it recommended that we move this up to about $1,275 a day. We're now just under $1,700 a day for the actual certification process. These rates are competitive. They're competing with the private sector. We're not below market. We're actually moving to market rates. This is what other standards organizations would charge to do these services. That, I would say, is the most important piece.
We also had some internal things, one of which was to develop a strategic plan as to where we are going. Certainly we have developed that. Getting out of almost 700 standards was part of that strategic plan. We wanted to focus on our core business and remove the standards that no longer need the federal government's involvement. We wanted to have those given to others.
:
The nature of this body is consensus-based. Consensus does not mean agreement. Essentially, what we do first of all is to ensure there's a balance of interests. So there are a number of things that we expect the committee to provide.
First of all, everybody who participates has to have a direct interest and has to have expressed an interest. So, if you've been invited to a standards committee, you have to actually be interested in the work of the standards committee of course. You have to demonstrate some ability and to make active contributions, so it is an engagement in the committee process. They have to represent a constituency, so they're not necessarily representing themselves but representing a constituency. Part of our role is to ensure that is happening in that discussion, that technical committee.
What we try to do is of course to get balance in the committee, some national representation, and that the committee is actually manageable—a committee of 500 isn't going to work—so the committee is a decent size.
What we do is in terms of consensus, so we ensure that every viewpoint is recorded and discussed and any point that continues to be strongly held focuses the discussion more on that point until the member who has that point of view is ready to accept, not agree, but accept that their view has been considered and incorporated. So it is really a consensus-building organization and this is why it takes a long time to get this committee to develop the standard.
If everybody is in violent agreement you can get a standard done in two or three meetings, but sometimes it takes two or three years as people go through this process. That might mean bringing other people into the committee for the discussion, bring in that expertise. We manage that process to drive that consensus discussion.
:
I'll take the example of the bicycle helmets as a good one.
For example, CSA runs a certification program. Let's say you're a manufacturer and you decided that suddenly you're in the market and you want to start manufacturing a bicycle helmet, a new innovation, but you want to have it certified. You would apply to CSA and say you were interested in having your product certified. There are certain requirements; you'll have to demonstrate, provide samples, provide documentation.
CSA has their own laboratories. They will test it. Of course, you will pay a fee for the actual application of the process. Then, as far as I understand it, you will then pay a per-unit fee as well, in terms of the application of the certification once you've achieved it, but there's an ongoing requirement to maintain your certification, to have regular tests and submissions to the CSA.
I want to go back to your other question because you raised the.... If you go into the marketplace today in Canada, you can see bicycle helmets certified by CSA; by ASTM, which is the American Society for Testing and Materials; for BSI, the British Standards Institution; because in the world, of course, it's an international market and manufacturers want to have accessibility to global markets. The notion of having multiple certifications, or a single equivalency, where if I get certified in Canada I can then go to the United States or go to the United Kingdom and have my product certified, these are more and more serious considerations for businesses, how they do that. Again, to instill confidence but without overly onerous long and complex processes.
The nice thing about this is that there is an ongoing process globally, economically, through the International Accreditation Forum, and other international bodies, to work toward mutual acceptance of certification marks.