User Fee Proposal: Destination Inspection Service
The consultation closed 2012-02-16.
Consultation Document
Preamble
This paper is intended to act as a basis for discussion with stakeholders of a user fee proposal pursuant to the Canadian Food Inspection Agency Act. The goals of the consultation are:
- to propose revised service standards and an accompanying user fee schedule; and
- to obtain an enhanced understanding of the impact of proposed user fees and consider stakeholder perspectives, concerns and suggestions prior to finalizing user fee recommendations.
Table of Contents
- Executive Summary
- 1.0 Introduction
- 2.0 Legislative And Policy Framework
- 3.0 Current Service Standards And User Fees
- 4.0 Proposed Service Standards And User Fees
- Annex A: CFIA - DIS Service Fees, FY2011-12
Executive Summary
The CFIA was created in 1997 and retained the cost recovery approaches of its parent organizations. No new user fees or increases to existing fees were made before the year 2000. In 2002, the government extended indefinitely a commitment to introduce no new user fees or increases to existing fees, contributing to an inability to keep existing fees in-line with the costs of delivering services and to the complexity of the current CFIA fee schedule. The CFIA is now reviewing its service standards and user fees in an effort to align fees with the cost to deliver the service, adjust to technological advances, to recognize industry improvements in quality control and risk management, and to provide fair and equitable treatment across industry sectors.
Destination inspection is a quality-related inspection of fresh-produce shipments. The results of the inspections support the process by which the fresh produce industry settles commercial disputes, primarily between sellers and purchasers (referred to collectively as "dealers1").
The Destination Inspection Service (DIS) program provides two services (referred to collectively as "inspection services") to the fresh produce industry:
- inspection of domestic fresh produce or fresh produce entering Canada from foreign jurisdictions, primarily the United States or Mexico, and
- witnessing of the destruction/disposal of fresh produce and issuance of a Notice of Dumping or other Disposition.
Sellers in distant locations cannot determine the accuracy of a purchaser's assessment regarding the quality of the produce once it reaches its destination. They therefore rely on third-party quality-related inspections to ensure such assessments are accurate. In the absence of a fair and unbiased assessment, sellers may be at a disadvantage in the event of a dispute.
The DIS program provides inspection services that are of direct benefit to dealers. As such, the proposed cost recovery rate for this program is 100%. This recovery rate is based on the voluntary nature of the inspection services provided, the existence of private sector service providers, and the purpose for which dealers seek out inspection services. This rate of recovery is being phased-in over a three year period. This proposal fixes fees for year two of the phase-in period at a rate of 75% of full cost recovery.
The proposed service standard is to continue to respond to 80% of inspection requests within 8 working hours2 of receiving the request and 100% of inspection requests within 24 working hours; and to continue to respond to 100% of requests for the witnessing and reporting of destruction/disposal of fresh produce within 40 working hours (or 5 business days) of receiving a request.
The proposed fee structure is based on the hourly cost to provide inspection services. Each request for inspection services will be subject to a minimum fee of one hour at the hourly rate. Inspection services provided outside of working hours will be charged in accordance with the overtime rates set out in the CFIA Fees Notice. Cancellation of inspection services requests will be billed for ½ hour at the hourly rate where the cancellation request is received after an inspector has been dispatched. Travel costs will be recovered through the application of a flat rate travel fee assessed per inspection services visit.
| Description | Proposed User Fee FY 2012-13 |
|---|---|
| Inspection of domestic fresh produce or fresh produce entering Canada from foreign jurisdictions | $144.91/hr, assessed at $36.23 per 15 minutes, subject to a 1 hour minimum charge |
| Witnessing of the destruction/disposal of fresh produce and issuance of a Notice of Dumping or other Disposition | $144.91/hr, assessed at $36.23 per 15 minutes, subject to a 1 hour minimum charge |
| Travel Fee per inspection services visit | $92.13 |
| Cancellation of inspection services request after an inspector has been dispatched | $72.46 |
1.0 Introduction
1. The Canadian Food Inspection Agency (CFIA) is dedicated to safeguarding food, animals and plants, and contributing to a safe and accessible food supply and plant and animal resource base, thereby enhancing the health and well-being of Canada's people, environment and economy. The CFIA's activities are aimed at protecting Canadian and international food consumers, Canadian agricultural production (including forestry), and our environment. These activities benefit Canadian farmers, fishers, foresters, processors and distributors (including importers and exporters) as well as consumers.
2. The CFIA was created in 1997 and retained the cost recovery approaches of its parent organizations, Agriculture Canada and the Department of Fisheries and Oceans, in the agri-food and seafood sectors, respectively. The programs that migrated from Health Canada or the former Consumer and Corporate Affairs had no cost recovery component associated with their program activities.
3. The original intent of Parliament was for the CFIA to be partially dependant on revenue generated by user fees for its operations. However, the Government made a commitment to introduce no new user fees or increases to existing fees before the year 2000. The intent was to reassure Parliament that the proposed CFIA would achieve efficiencies through cost reduction and cost avoidance rather than through the imposition of additional fees. In 2002, the moratorium on new or increased user fees was extended indefinitely.
4. The Governments' commitment to introduce no new user fees or increases to existing fees has precluded the CFIA from reducing the complexity and inconsistency of the CFIA Fees Notice. A 2008 report by the Auditor General (OAG)3 found that many fees charged by government have not kept pace with increasing costs. The CFIA is now reviewing its service standards and user fees in an effort to keep pace with technological advances, to recognize industry improvements in quality control and risk management, and to provide fair and equitable treatment across all industry sectors.
5. Destination inspection is a quality-related inspection of fresh-produce shipments. The results of the inspection services support the process by which the fresh produce industry settles commercial disputes between dealers. The dispute resolution bodies serving the fresh fruit and vegetable industry rely heavily on inspection reports as evidence when hearing disputes and rendering decisions.
6. Sellers in distant locations cannot determine the accuracy of a purchaser's assessment regarding the quality of the shipment themselves and thus rely on third-party quality-related inspections to provide such assessments are accurate. In the absence of a fair and unbiased assessment, dealers4, domestic or international, may be at a disadvantage in the event of a dispute. A government-issued inspection certificate is widely recognized by the dispute resolution bodies and as such, may be preferred by some dealers over a private sector inspection certificate.
7. Approximately one million loads of perishable fresh produce are received in Canada each year from foreign markets. The CFIA performs approximately 15,000 destination inspections on shipments of fresh produce from the United States and Mexico annually.
8. Disputes may be resolved through the Fruit and Vegetable Dispute Resolution Corporation (DRC). The DRC is a private, non-profit organization of produce and transportation companies from Canada, Mexico, and the United States. While the beneficiaries of the DRC are primarily companies whose place of business is in Canada, Mexico or the United States, produce companies from outside North America may access the DRC when dealing with DRC members in North America.5
9. Studies and consultations undertaken by the fresh produce industry from 2002 to 2005 have led to the recognition that changes to the DIS program are required to meet service delivery requirements. The studies and consultations indicate that increased front line resources, new service standards and increased user fees to support these changes should be considered.6
10. In 2010-11, the Destination Inspection Service (DIS) program altered its approach to calculating user fees to one based on an hourly rate. Originally, fees were calculated based on the weight of product covered by the certificate issued and did not reflect the actual time spent performing inspection services.
11. This document sets out a user fee proposal for the DIS program. It pertains to year two of a three-year phase-in approach to fully cost recover the DIS program. In FY2012-13, fees will be increased to 75% of full cost and administered through the CFIA Fees Notice. In FY2013-14, it is the intention of the CFIA to charge fees that will fully cost recover the program; an updated user fee proposal will be prepared for FY2013-14 to consult on these changes.
12. The following information is presented in support of this proposal: the legislative authority to charge user fees; the current service standards and user fees; the proposed service standards and user fees; and jurisdictional comparisons.
2.0 Legislative and Policy Framework
13. Sections 24 and 25 of the Canadian Food Inspection Agency Act provide the authority for the Minister of Agriculture and Agri-Food to fix the fees for a service or the use of a facility, or to fix fees in respect of products, rights and privileges provided by the CFIA, respectively.
14. The CFIA's policy regarding user fees, as set out in its Cost Recovery Policy and Framework, states:
"The Canadian Food Inspection Agency will charge a user fee for services that provide service recipients direct benefits beyond those received by the general public."
15. In November 2004, Treasury Board introduced a Policy on Service Standards for External Fees. This policy represents the government's commitment to those who use its services. Service standards represent an important management tool for measuring, assessing, communicating and improving service performance.
16. In July 2008, Treasury Board updated its Guide to Costing. The guide is based on generally accepted management accounting principles and presents a logical seven-step approach to be used for all costing exercises, including the development of cost-recovery proposals.
3.0 Current Service Standards and User Fees
17. DIS provides two services (referred to collectively as "inspection services") to the fresh produce industry:
- inspection for domestic fresh produce or fresh produce entering Canada from foreign jurisdictions, primarily the United States or Mexico, and
- witnessing of the destruction/disposal of fresh produce and issuance of a Notice of Dumping or other Disposition.
18. The inspection of fresh produce shipments by DIS includes product sampling; assessment of the properties of the produce such as appearance, taste, colour, odour and feel; categorization of defects; and the provision of official results.
19. Dealers may refuse to accept a shipment when it does not meet the terms of the sales agreement agreed to by the seller and the purchaser. In these cases, at the request of the dealer, DIS inspectors may inspect the product and provide an inspection certificate which details the condition of the product, or observe the destruction/disposal of the shipment and provide a Notice of Dumping or other Disposition to the dealer.
20. The current inspection fee is $99/hour of inspection services and is administered through individual service agreements (refer to annex A for a summary of the current fees). This fee recovers approximately 50% of the cost of DIS inspection services.
21. The service standard for the DIS program is to respond to 80% of the requests for a destination inspection within 8 working hours and to 100% within 24 working hours of receiving a request; witnessing and reporting of the destruction/disposal of fresh produce is generally responded to within 5 business days of receiving a request.
4.0 Proposed Service Standards and User Fees
22. DIS will continue to provide two key services to the fresh produce industry:
- inspection for domestic fresh produce or fresh produce entering Canada from foreign jurisdictions, primarily the United States or Mexico, and
- witnessing of the destruction/disposal of fresh produce and issuance of a Notice of Dumping or other Disposition.
4.1 Service standards, performance measurement and tracking
23. The CFIA proposes to commit to respond to 80% of inspection requests within 8 working hours7 of receiving a request and 100% of inspection requests within 24 working hours.
24. The CFIA proposes to commit to respond to 100% of requests for the witnessing and reporting of destruction/disposal of fresh produce within 40 working hours (or 5 business days) of receiving a request.
25. In order to assess the timeliness of service delivery, the DIS program will record and monitor the time at which inspection services requests are received and the time at which the related service is responded to. The performance of the DIS program in meeting this service standard will be reported annually in the CFIA's Departmental Performance Report.
4.2 Cost Analysis
26. The cost analysis is based on the costs incurred by the CFIA to deliver the DIS program in FY2010-11. The full cost of the DIS program is defined as all resources consumed, including program support and internal services, to deliver the program. For the purpose of fixing fees for FY2012-13, we have assumed constant demand for DIS inspection services.
27. Of the 36.73 employees required to deliver the DIS program, 22.88 are inspectors. The total billable hours that accrued to inspectors in FY2010-11 was 23,731 hours, of which 19,103 were inspection hours and 4,628 hours were related to travel time. The remaining 13.85 employees are supervisors, trainers, providing quality assurance and management and administrative functions.
28. In order to account for the time difference in fixing fees for FY2012-13 based on costs incurred in FY2010-11, an inflationary factor is applied to adjust the costs. Refer to paragraph 41 for more details about the inflationary factor.
29. Based on FY2010-11 costs, the projected full cost to deliver the DIS program is in FY2012-13:
| DIS Program Full Cost | Amount | % of total cost |
|---|---|---|
| Salaries and Benefits | $3,167,116 | 66% |
| Operating and Maintenance | $354,923 | 7% |
| Accommodation | $298,965 | 6% |
| Amortization - vehicle | $65,524 | 1% |
| Program Support | $85,985 | 2% |
| Internal Services | $809,088 | 17% |
| Total Full Cost | $4,781,601 | 100% |
| Total Full Cost adjusted for Inflation (1.72% per year) |
$4,947,503 |
30. The average hourly rate of an inspector is calculated as follows:
| DIS Inspector Costs | Amount |
|---|---|
| Total Full Cost | $4,781,601 |
| Less: Labour costs for travel time | $864,172 |
| Less: Vehicle Cost | $130,688 |
| Less: Overtime Cost | $219,484 |
| Sub-total | $3,567,257 |
| Total Inspection Hours | 19,103 hrs |
| Hourly Cost | $186.74/hr |
| Hourly Fee at 75% Cost Recovery | $140.06/hr |
| Hourly Fee at 75% Cost Recovery adjusted for Inflation (1.72% per year) |
$144.91/hr |
31. The hourly cost of inspection services is based on the full cost to deliver the program less the labour costs incurred during travel, vehicle costs and overtime costs, which amounted to $186.74/hr. The hourly cost of an inspector is arrived at by dividing the DIS Inspector Cost Sub-total by the total number of inspection hours available to arrive at a rate of $186.74/hr. At 75% cost recovery and adjusted for inflation, this results in an hourly fee of $144.91/hr.
32. When inspection services begin and end during an inspector's regular working hours, the dealer will pay a fee of $144.91 for the first hour and an additional fee of $36.23/quarter hour for inspection services ending beyond the first hour, subject to a minimum fee of $144.91. The additional regular fee will be calculated forward to the nearest quarter hour.
33. The hourly fee applies during regular working hours. For the purposes of calculating fees for inspection services, the inspection or witnessing of dumping will commence at the time an inspector enters the premises where the inspection services are to be carried out and will end at the time the inspector completes the Certificate of Inspection or Notice of Dumping or the Applicant cancels his request for inspection services.
34. Services provided outside of regular working hours will be subject to the hourly fee that applies during regular working hours plus the overtime rates set out in the CFIA Fees Notice8.
35. Travel costs are calculated as follows:
| DIS Travel Costs | Amount |
|---|---|
| Labour costs for travel time | $864,172 |
| Vehicle cost | $130,688 |
| Sub-total | $994,860 |
| Average number of inspection services visits/year | 8,380 |
| Flat Travel Rate per inspection services visit | $118.72 |
| Flat Travel Fee per inspection services visit at 75% Cost Recovery | $89.04 |
| Flat Travel Fee per inspection services visit at 75% Cost Recovery adjusted for Inflation (1.72% per year) | $92.13 |
36. Travel costs are based on the labour costs associated with time spent travelling plus the vehicle costs, which amounted to $994,860. This amount, distributed over an average of 8,380 inspection services visits per year, is $118.72. At 75% cost recovery and adjusting for inflation, this results in a flat travel fee of $92.13/inspection services visit in addition to the fee for the inspection services.
37. Cancellation costs are calculated as follows:
| DIS Cancellation Cost | Amount |
|---|---|
| Hourly Inspector Cost | $186.74 |
| Inspectors time lost due to cancellation | 30 min |
| Total Cancellation Cost | $93.37 |
| Cancellation Fee at 75% Cost Recovery | $70.03 |
| Cancellation Fee at 75% Cost Recovery adjusted for Inflation (1.72% per year) |
$72.46 |
38. Charges for cancelled service requests will apply where the cancellation request is received after an inspector has been dispatched, but before inspection services delivery begins. Once dispatched, an inspector will lose approximately half an hour of time. Once inspection services delivery begins, the minimum hourly charge applies even if the service request is then cancelled. Where an inspector has not yet been dispatched, there will be no charge for cancelled requests.
4.3 Public vs. Private Benefit
39. The DIS program provides inspection services that are of direct benefit to dealers. The CFIA has already consulted with industry on a proposal to fully cost recover the DIS program. The following factors contributed to this decision:
- amendments to the Fresh Fruit and Vegetable Regulations and Licensing and Arbitration Regulations have removed the requirement for licensed dealers to obtain inspection services from the CFIA;
- in the absence of dealers, the CFIA would not provide this service; and
- dealers request inspection services, at their discretion, when they feel there may be a commercial dispute regarding the quality of the shipment as compared to the terms of the sales agreement.
4.4 User Fee
40. Proposed Fee Schedule:
| Description | Proposed User Fee | |
|---|---|---|
| FY2012-13 (based on FY2010-11 costs) | FY2013-14 | |
| Inspection of domestic fresh produce or fresh produce entering Canada from foreign jurisdictions | 144.91/hr, assessed at $36.23 per 15 minutes, subject to a 1 hour minimum charge | 100% of FY2011-12 costs |
| Witnessing of the destruction/disposal of fresh produce and issuance of a Notice of Dumping or other Disposition | $144.91/hr, assessed at $36.23 per 15 minutes, subject to a 1 hour minimum charge | 100% of FY2011-12 costs |
| Travel Fee per inspection services visit | $92.13 | 100% of FY2011-12 costs |
| Fee for the cancellation of inspection services request | $72.46 | 100% of FY2011-12 costs |
41. In order to project costs and revenues for the program over three years, the CFIA has assumed no change in demand or staff and applied an annual inflation adjustment. The annual inflation adjustment is the average of the percentage change in the consumer price index over the previous five years9 as reported by Statistics Canada10.
42. Projected Costs and Revenues*
| FY 2012-13 | FY 2013-14 | FY 2014-15 | |
|---|---|---|---|
| Costs | $4,947,503 | $5,032,600 | $5,119,161 |
| Revenue | $3,710,627 | $5,032,600 | $5,119,161 |
* based on FY2010-11 costs and billable hours and a 1.72% annual increase for inflation - refer to paragraph 28.
43. The CFIA is committed to reviewing fees every five years or more frequently if necessary. In the case of DIS, the costs associated with delivering the DIS program will be reviewed and reflected in a subsequent proposal to establish fees for the third year of the phase-in, at which point, the DIS program will move to 100% cost recovery.
4.5 Benchmarking
44. The CFIA considered four foreign jurisdictions for the benchmarking exercise: Australia, New Zealand, the United Kingdom, and the United States. The government regulatory bodies in Australia, New Zealand, and United Kingdom do not offer quality-related inspection services. A comparable service is, however, offered by the U.S. Department of Agriculture's Agricultural Marketing Service (AMS).
45. Given the presence of domestic private sector service providers of inspection services for quality and condition, a comparison was also made with the Ontario Produce Marketing Association (OPMA).
4.5.1 Australia, New Zealand, and the United Kingdom
46. The Australian, New Zealand, and United Kingdom government's role at the border is limited to quarantine and food safety inspection and verifying that the shipment does not conceal drugs, guns, illegal immigrants, etc. These jurisdictions do not offer quality-related inspection services in an official capacity by a regulating authority to the fresh fruit and vegetable industry as this issue is regarded as a commercial matter.
47. When fresh fruit and vegetable product is imported into these three jurisdictions, importers either inspect the product themselves or appoint an independent specialist to undertake this role on their behalf.
4.5.4 The United States
48. In the U.S., the Agricultural Marketing Service (AMS) administers programs that facilitate the efficient and fair marketing of U.S. agricultural commodities. Grading of fresh products is funded through user fees and, in the case of quality-related inspection services, is voluntary.
49. The results of destination inspections provide growers, packers, shippers, brokers, truckers, receivers, importers and other financially interested parties with quality, condition, temperature, count, net weight or other desired information pertaining to a shipment.
50. The AMS response time, upon receipt of a letter or fax requesting an inspection, is within 5 working days, with a commitment to schedule an inspection appointment within 24 hours of receiving the request. Inspection certificates may be issued from 20 minutes to 5 working days upon completion of the inspection, depending on the location of the inspection.
51. The AMS fee schedule is based on the quantities of packages involved and the number of commodities present. For each commodity being inspected, the price can range from US$69 (for quantities of less than 50 packages) to US$151 (for quantities in excess of 51 packages).
52. The AMS imposes a waiting time fee in the event an inspection is delayed because the commodity is not available or readily accessible. The U.S. also charges a cancellation fee. If the inspector has been dispatched the client is charged the total travel time (round trip) at the hourly rate. If the request is cancelled before the inspector is dispatched, then there is no charge.
53. The AMS also applies charges for overtime and travel costs. The overtime rate is US$38 in addition to the regular service charge for all inspections performed outside the regularly scheduled work week; the holiday hourly rate is US$74 in addition to the regular service charge. The rate for billable mileage is U.S$1.32/mile.
4.5.5 Domestic Private Sector Service Providers
54. The Ontario Produce Marketing Association (OPMA) is a non-profit organization which provides inspections of produce to support the settling of produce claims in the event of a dispute.
55. The inspections are generally conducted within 24 hours of the applicant's request and include services that are comparable to those provided by the CFIA DIS program. A preliminary written indication of the result is provided upon completion of each inspection and a written report is provided within 5 days.
56. The OPMA fee schedule is based on the number of cartons being inspected. The fee ranges from $137 (1-100 cartons) to over $300 (1501-2000 cartons) and includes digital photographs, a service not currently offered by the CFIA DIS program. When a shipment contains over 2001 cartons, the OPMA charges an hourly rate of $75.
57. If the service requestor is not a member of the OPMA, an additional 25% is added to all inspection fees, so fees would range from $171 to over $375. Annual membership fees range from $200 to $400 per year.
58. Dump certificates are charged at a rate of $75/hour. Inspections performed on pre-arranged overtime are charged at 1.5 times the regular fee. The rate for mileage is $0.50 per kilometre plus meals.
4.5.6 Comparison with CFIA Proposal
59. The CFIA DIS program proposes to maintain a service standard of responding to 80% of requested inspections within 8 regular working hours of receiving a request and 100% of requested destination inspections within 24 regular working hours.
60. This service standard is comparable to that of both the AMS and the OPMA. The AMS commits to scheduling inspections within 24 hours of receiving requests, if within the areas of the country served, and will respond within 2 working days (excluding travel time). The OPMA generally conducts inspections within 24 hours of the applicant's request.
61. The CFIA DIS user fee proposal bases its fees on the hourly rate to deliver the service. In FY2012-13, the CFIA will charge 75% of full cost recovery for its services. This amounts to an inspection and certification of destruction fee of $144.91/hour, a travel fee of $92.13/inspection services visit and a cancellation fee of $72.46.
62. The AMS and OPMA base their fees on quantities of packages and the number and types of commodities. OPMA fees range from $137 ($171, if a non-member) to over $300 (over $375, if a non-member), or may charge an hourly rate of $75/hr if the number of cartons is sufficiently large, in addition to an annual membership fee of $200-$400 per year. Fees charged by the U.S.-AMS range from USD$69 (<50 pkgs) to USD$151 (>51 pkgs)) and include a waiting time fee. The different basis for determing the fees (hourly rate vs quantity of product) makes it difficult to directly compare the fees charged by the AMS and OPMA to those being proposed for the DIS program, but the proposed fees for the DIS program are within the range of those being charged by others.
63. The DIS proposal is introducing a cancellation fee. The approach is similar to the U.S. approach in that there is no charge if the service request is cancelled prior to dispatching an inspector. However, the U.S. cancellation fee recovers the costs associated with travel, while the DIS proposal recovers the inspector's lost time due to the cancellation.
Annex A: CFIA - DIS Service Fees, FY2011-12
Inspector's Regular Working Hours
Inspector is on Overtime adjacent to Regular Working Hours
Overtime when the inspector is called back to work:
Notes:
Goods and Services Tax (GST) or Harmonized Sales Tax (HST) will be added to the fees.
1Base Time is based on an hourly rate of $99.00, calculated at 15 minute intervals ($24.75) or portions thereof (e.g. 25 minutes will be considered as two 15 minute intervals).
2 Call Back inspections or witnessing will be charged $84.00 or the amount of time at $8.25 per 15 minute increment, whichever is greatest.
1 The Canada Agricultural Products Act defines "dealer" as a person who (a) is engaged in the business of purchasing or selling agricultural products, (b) negotiates consignments, sales, purchases or other transactions involving agricultural products, (c) receives or handles, on commission, agricultural products, or (d) is prescribed as a dealer for the purposes of this Act.
2 "Regular working hours", as defined in the Interpretation section of the CFIA Fees Notice, means the time during which services are normally provided by employees of the CFIA at a particular service location.
3 Report of the Auditor General of Canada to the House of Commons, Chapter 1, Management of Fees in Selected Departments and Agencies, May 2008
4 The Canada Agricultural Products Act defines "dealer" as a person who (a) is engaged in the business of purchasing or selling agricultural products, (b) negotiates consignments, sales, purchases or other transactions involving agricultural products, (c) receives or handles, on commission, agricultural products, or (d) is prescribed as a dealer for the purposes of this Act.
5 www.fvdrc.com
6 findings from the industry's studies are available at: www.freshproducealliance.com/text/publication_Eng.htm or www.freshproducealliance.com/text/publication_Fr.htm.
7 "Regular working hours", as defined in the Interpretation section of the CFIA Fees Notice, means the time during which services are normally provided by employees of the CFIA at a particular service location.
8 overtime fees as set out in CFIA Fees Notice: http://www.inspection.gc.ca/english/reg/cfiaacia/feesfrais/interpe.shtml
9 2010: 1.8%; 2009: 0.3%; 2008: 2.3%; 2007: 2.2%; 2006: 2.0%
10 http://www40.statcan.gc.ca/101/cst-1/ECON46A-eng.htm
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