ARCHIVED - Alternative Service Delivery Policy Consultation Summary Report

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Alternative Service Delivery Policy

The Canadian Food Inspection Agency (CFIA) is developing an Alternative Service Delivery (ASD) policy and has completed its first consultation seeking input from stakeholders. A policy will promote consistency in the development and oversight of ASD arrangements. ASD is a form of arrangement that the CFIA enters into with another party to deliver services or programs, where appropriate.

The 60-day online consultation began on April 25th 2012 and ended on June 24th 2012. The consultation was open to the general public, government employees, industry associations, businesses, unions, non-governmental organizations (NGOs) and other stakeholders. The CFIA used an online survey tool, however, participants were also able to complete and submit consultation responses via email or mail. Participants were asked to rate and comment on three areas pertaining to the CFIA's future ASD policy:

  1. Drivers and objectives;
  2. Guiding principles; and
  3. Application.

This report summarizes the input received from the consultation.

About the Respondents

In total, 266 participants completed the consultation; 210 completed the consultation on behalf of themselves, 52 completed on behalf of an organization and four completed on behalf of a group of individuals. The participants were asked to provide some general information about themselves and/or their organization, which is summarized in tables 1 through 4 below.Footnote 1

Table 1: Category of respondents
Category of respondents Total responses Distribution
Federal government 129 48%
Municipal government 1 0.4%
Business 56 21%
Member of the general public 16 6%
Industry association 32 12%
Other 13 5%
Provincial government 14 5%
NGO 5 2%
Table 2: Location of respondents
Location of respondents Total responses Distribution
Alberta 33 12%
British Columbia 50 19%
Manitoba 20 8%
New Brunswick 11 4%
Newfoundland and Labrador 2 1%
Northwest Territories 1 0%
Nova Scotia 6 2%
Nunavut 0 0%
Ontario 102 38%
Prince Edward Island 5 2%
Quebec 7 3%
Saskatchewan 20 8%
Yukon 1 0%
Other 9 3%
Table 3: Respondents who are currently directly affected by CFIA programs and services
Status Total responses Distribution
Affected 211 79%
Not affected 43 16%
Unsure 12 5%
Table 4: Respondents who use programs or services provided by an alternative service provider recognized by the CFIA
Status Total responses Distribution
Affected 84 32%
Not affected 146 55%
Unsure 36 14%

What We Heard

Drivers and Objectives of ASD arrangements

Participants were asked to rate, either as high, medium, low or do not know, how influential the listed drivers and objectives should be when the CFIA establishes ASD arrangements. The data indicate a high level of influence was most often selected for the listed drivers and objectives, with the exception being with respect to increased flexibility for regulated parties (see table 5 below).

Table 5: How influential should the listed drivers and objectives be when the CFIA establishes ASD arrangements
Listed drivers and objectives % that selected a high level of influence % that selected a medium level of influence % that selected a low level of influence % that selected "do not know"
To improve the quality of programs or services 76% 18% 5% 2%
To improve access to specialized expertise 55% 33% 9% 2%
To increase flexibility for regulated parties 39% 42% 18% 1%
To increase the efficiency and/or timeliness of programs or services 74% 21% 4% 1%
To increase cost effectiveness for the CFIA and regulated parties 48% 28% 12% 1%
To improve client and/or customer satisfaction 51% 38% 9% 2%
To rebalance the roles of industry and government with respect to providing services 51% 38% 9% 2%

Further to rating the drivers and objectives, respondents were asked to identify which one(s) should be the most influential in establishing an ASD. In response to this question, the most frequently identified drivers and objectives were:

  • improving the quality of programs or services, and
  • increasing efficiency and/or timeliness of programs and services.

Participants were asked to identify any other drivers/objectives that the CFIA should keep in mind when establishing an ASD arrangement. Overall, those identified by participants cover broad themes such as:

  • the role of the ASD service provider and the CFIA
  • cost implications
  • safety, and
  • international considerations.

A number of respondents commented that the services provided through an ASD arrangement must be available across the country, of quality, reliable and that the approach to regulations and inspections be consistent. Some respondents remarked that ASD service providers must be knowledgeable and provide objective and impartial decisions and there needs to be consequences for non performance/compliance. Similarly, several respondents indicated that the CFIA needs to retain its expertise, continue to conduct audits and accredit ASD service providers. As well, some participants emphasized that the CFIA should continue to develop, implement and monitor programs and remain accountable and responsible for regulations. Generally, respondents indicated that the roles and responsibilities of an ASD service provider and the CFIA must be clearly defined.

Other themes raised by participants include the cost effectiveness of ASD arrangements in that they must be financially feasible for companies and stakeholders. As well, a number of participants remarked that the health and safety of Canadians and the security of Canada's food system and resources must be protected. Similarly, several respondents indicated that consumer confidence must be maintained and there must be assurance that quality standards are met. Finally, respondents commented on the need to meet international standards and that the use of ASD must be accepted by international partners.

Guiding principles for developing ASD arrangements

Participants were asked to indicate, either by high, medium, low or do not know, how important the listed guiding principles should be for establishing the CFIA's ASD arrangements. In general, respondents indicated that all of the listed guiding principles should be considered highly important (see table 6 below).

Table 6: How important should the listed guiding principles be for establishing the CFIA's ASD arrangements
Listed guiding principles % that selected high importance % that selected medium importance % that selected a low importance % that selected "do not know"
Decisions to establish and monitor ASD arrangements should be supported by scientific rigour and professional and technical competence. 88% 9% 2% 1%
ASD arrangements should support the CFIA's reputation and credibility. 70% 27% 3% 0%
The perspectives of affected stakeholders should be reflected in the development of ASD arrangements. 52% 39% 8% 2%
ASD arrangements should maintain the CFIA's regulatory independence to take necessary actions to safeguard food, animals and plants. 86% 12% 0% 1%

Twenty-seven percent of respondents indicated that there are other guiding principles that the CFIA should identify to support the future ASD policy. These can be organized under five main themes:

  1. CFIA values and ethics must be maintained along with developing and retaining the CFIA's expertise.
  2. Any ASD arrangement must be accountable for the service provided, enforceable, abdicable and not be a duplicated service that is provided by other Government of Canada departments or offices.
  3. The service must be transparent and free from conflict with the ASD service provider or other parties.
  4. Any ASD arrangement must respect existing international agreements and regulations of other Government of Canada departments.
  5. ASD arrangements must be economically feasible and cost effective and without lengthy time delays.

Appropriate application of ASD arrangements

Participants were asked to rate their level of support for establishing an ASD arrangement to deliver a program or service in several scenarios, on a scale of strongly support, support, neutral, object and strongly object. In general, there was support for using ASD arrangements in the various scenarios listed (see table 7 below).

Table 7: Support for the application of ASD arrangements in various scenarios
Scenarios regarding the potential application of ASD arrangements % that selected “strongly support” % that selected “support” % that selected “neutral” % that selected “object” % that selected “strongly object”
An international agreement specifies that the program or service must be delivered by a government body 21% 25% 17% 16% 18%
If the program or service were not delivered properly, significant risks may be posed to the health and safety of Canadians 44% 19% 9% 12% 17%
If the program or service were not delivered properly, significant risks may be posed to the environment 32% 29% 12% 13% 15%
If the program or service were not delivered properly, significant risks may be posed to the economy 28% 30% 18% 14% 9%
The program or service mainly contributes to the good of the general public 38% 25% 16% 5% 3%
The program or service mainly contributes to the good of the private entities 24% 32% 27% 8% 6%
The program or service mainly contributes to the good of the general public & private entities 30% 38% 19% 9% 3%
An ASD arrangement would benefit Canadian consumers 38% 36% 18% 4% 3%
An ASD arrangement would benefit Industry 36% 38% 18% 4% 3%
An ASD arrangement would benefit International trade 33% 35% 18% 8% 5%
There is sufficient demand for this program or service to support the establishment of an ASD arrangement 26% 40% 25% 5% 4%
There is sufficient expertise, capacity and interest in the private and/or not-for-profit sectors to establish an ASD. 27% 35% 25% 7% 6%

Twenty-nine percent of respondents indicated that they thought there were other factors that should be considered to determine if an ASD arrangement could be appropriate for delivering a particular program or service. The major areas of concern identified by these respondents were the need for appropriate oversight and the possibility for conflict of interest between the government and industry. Within that context, the importance of neutrality and transparency were cited.

Others felt that there had to be a clear cost benefit and that ASD arrangements should only be implemented if they offered greater efficiencies. Ensuring the safety of the public, and both animal and plant health were also recurring themes. Several respondents expressed concern about the potential loss of CFIA expertise and capacity and wondered if ASD arrangements would diminish the knowledge base of the Agency's inspectors. A few respondents indicated that ASD arrangements should ensure the ease of incorporating new technology into the inspection program. Three participants felt that they needed to know which commodities were being considered, before they offered their opinions.

General Comments

In terms of additional suggestions, concerns or comments about the future CFIA policy on ASD arrangements, appropriate regulatory oversight drew the most comments from respondents. Additionally, some wondered who would be responsible and possibly liable. Others sought assurances that food safety and animal welfare would remain paramount and that the CFIA's solid reputation would not be tarnished. Similarly, commentators did not want the industry to be harmed and sought to avoid any conflict with trading partners. Some participants identified areas where provincial collaboration for ASD arrangements could be explored and identified the CFIA's existing organic and beef ASD arrangements as potential models for future arrangements. Lastly, consulting with stakeholders and being cautious when developing ASD arrangements were suggestions received from several participants.

Conclusion

The CFIA would like to thank everyone who contributed their time, participated in the consultation process and shared their views. The feedback received was considered by the CFIA when it developed its ASD policy.

The CFIA is committed to on-going consultations with stakeholders, including government employees, industry associations, businesses, unions, NGOs and the general public. As such, the CFIA will be undertaking a second consultation on the draft policy.

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