CMEC: Regulatory Reform & Red Tape Reduction
February 12th, 2012
The report opens up the possibility of new regulatory reform legislation which in turn gives us an opportunity to propose changes to promote regulatory efficiency – supporting good ideas in the Committee’s report as well as ensuring that a broader set of issues are raised that are important to manufacturers.
The report also raises two issues that we should be concerned about.
It focuses on administrative costs (paperburden) rather than all compliance costs – I think we need to broaden the debate to emphasize reforms that would affect the overall compliance burden facing manufacturers.
Second, it recommends that the User Fee Act be reviewed and amended to make it easier to introduce User Fees. Since the User Fee Act was introduced in the first place because the Government had no quality control (or overall financial control) of the fees it was introducing, and since it requires regulators to set competitive service standards in the administration of regulations (for which fees are paid), its principles are fundamental to regulatory management.
I would like to propose that we prepare a letter that would outline our issues and concerns with respect to the Committee’s report and make recommendations for the type of regulatory reforms we believe to be most effective for manufacturers.
I suggest that we convene a teleconference at 11:00 am next Tuesday, February 7th, to discuss a CMC response. The call-in number is: 1 866 201 0077 – passcode: 122407.
We will subsequently circulate a draft of the letter to all CMC members.
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