What We Learned: External Consultation on Openness and Transparency Report

What We Learned – External Consultation on Openness and Transparency Report (PDF - 5,062 kb)

This report summarizes feedback received from external stakeholders during the Openness and Transparency consultation held from June 20 to August 2, 2018.

Introduction

The Canadian Food Inspection Agency (CFIA) plays a foundational role in protecting the health of Canadians and safeguarding our food, plant and animal resources. In an increasingly connected world, Canadians expect to have access to information that will help them make informed decisions in their day to day lives, and to hold government departments and agencies accountable for delivering results.

To meet these expectations and maintain public trust in Canada's regulatory system for food, plants and animals, the CFIA first launched its Transparency Agenda in 2011 as part of its ongoing efforts to be a more service-oriented, responsive and accountable organization. The Agency continues these efforts, by proactively releasing more data and information that is relevant, accurate and timely, while appropriately protecting personal and confidential information.

Openness and transparency continue to be core values guiding government operations. Many pressures, including the need to align with the Government of Canada Open Government initiative and enable Canadians to exercise their right to information, have caused the CFIA to re-evaluate its approach to openness and transparency. From June 20 to August 2, 2018 the CFIA held a public consultation in which external stakeholders were asked to provide feedback on its proposed approach to enhance openness and transparency at the agency. This report summarizes what we learned during this consultation.

Our Approach

Our Main Objectives

Clearly explain to stakeholders how and why we developed the proposed approach to enhance openness and transparency at the CFIA
Consult stakeholders on the proposed approach and collect comments and feedback that would be used to improve the approach
Create spaces for stakeholders to have informed discussions with the Agency and to promote a better understanding of the material being consulted on

Who did we reach out to?

General public
Industry and Industry Associations
Consumer associations
Academia
International, Provincial and Municipal governments

What we did

New consultation page for Enhancing Openness and Transparency at the CFIA
Survey
Interactive webinars in both official languages for industry and the general public
Social media posts promoting the consultation on Facebook, LinkedIn and Twitter
Communicated with stakeholders via e-mail

What we learned

At a Glance

Key Themes

Stakeholders were asked four key discussion questions for ideas and input around the following themes from the proposed Openness & Transparency Framework : Empower, Equip, Report and Innovate. The questions were:

How can the CFIA provide Canadians with more useful, timely and accessible information about food safety, animal health and plant protection to help them make informed decisions?
Which additional information and tools could the CFIA provide to help industry comply with regulatory requirements?
How can the CFIA share more information about its compliance and enforcement activities?
What can the CFIA do to help stakeholders and the public learn more about regulatory science, and have access to research and information from CFIA scientists?

All comments and feedback received from the four key discussion questions were taken into considerations, as well as:

Survey responses
Formal written submissions, including e-mails
Webinar sessions

Six key themes emerged that exemplified areas stakeholders would like the CFIA to focus on. In no particular order, these are:

Increase access to information and tools for the general public
Increase transparency of engagement activities
Increase access to information about compliance and enforcement actions
Share more CFIA research and science
Open up CFIA resources used by CFIA personnel
Enhance stakeholder access to CFIA expertise

These themes are described in more detail in the following sections.

1. Increase access to information and tools for the general public

We heard from all stakeholders that there is a growing expectation that government information should be made publically available in a useful, accurate and timely manner. Industry believed it was important that Canadians be provided with a level of general education about how the CFIA works as a precursor to releasing more complex information requiring context – for example, inspection results. Providing more information also means that the general public can learn and be knowledgeable about the CFIA's mandate, and how it differs from those of its domestic and international counterparts.

Consultation participants indicated that increased access to information in usable formats will help them understand the CFIA's processes, how it makes decisions, and this in turn would encourage greater engagement and understanding of its overall mission.

What participants said about how the CFIA can increase access to information and tools:

Invest more in educating the public about CFIA's role in safeguarding food, animals, and plants, and protecting the health and well-being of Canadians, the environment and the economy
Provide more educational and promotional materials for consumers and the next generation of consumers (such as children) so that they may make informed decisions about the food they consume and have an understanding of their role in food safety
Develop a user-friendly, searchable one-stop CFIA website where stakeholders can access information with ease

2. Increase transparency of engagement activities

Transparency of engagement activities is intended to improve trust as stakeholders will have an opportunity to have their voice heard in the development of CFIA regulations, programs, policies, and services, as well as to better understand the rationale behind regulatory decisions. Fostering trust is essential to ensure that stakeholders will continue to share their views and provide feedback that helps continually improve CFIA programs and services.

Throughout the consultation, stakeholders consistently said that while they appreciate the opportunity to participate in engagement activities, they felt that the results and outcomes of such activities could be more transparently communicated and shared. In addition to providing feedback, stakeholders said they want to know how all feedback is considered in development of the final product.

What participants said about how the CFIA can increase transparency of engagement activities:

Provide access to records of meetings held between CFIA officials and stakeholders, as well as documents showing rationale for policy and regulatory decisions
Provide opportunities to engage on a more continuous basis on policy and regulatory development. When developing new regulations, this means engaging on the ground floor prior to pre-publication in the Canada Gazette
Release more detailed information about comments submitted to public consultations, and enhance outputs of consultations (for example What We Learned Reports) to include more rigorous analysis of input, what the CFIA has done with the comments and what changes were made based on them
Continue to improve engagement with stakeholders during emergencies, as well as recalls and other food safety, animal and plant health events

3. Increase access to information about compliance and enforcement actions

Compliance and enforcement information, such as inspection outcomes, is of interest to Canadians. It has the potential to influence decisions about the products Canadians choose to purchase and allows them to hold the CFIA accountable for its actions.

From feedback received, the CFIA learned that industry was cautiously supportive of this approach and underlined the need to ensure that compliance and enforcement action information is placed within its proper context so that the public understands how to use it accurately, and what it should not be used for. Industry indicated that sharing information of this nature must be done responsibly, so as not to unduly damage the reputation of individual sectors or international trade of Canadian products.

Industry also noted there was value in having access to certain compliance reports both as an educational and a risk management tool. Similarly, they said that it would be useful to share best practices and lessons learned as part of optimizing food safety and other outcomes, and fulfilling their responsibility to ensure the health and well-being of those who consume and purchase their products.

What participants said about how the CFIA can post more information about compliance and enforcement actions:

Provide information on the outcomes of inspections, in particular those inspections related to food safety and animal health (for example, humane transport)
Publish more detailed compliance information such as notices of violation/non-compliance, Administrative Monetary Penalties (AMPs), and information about seizure of product
Publish an annual summary report of compliance and enforcement activities highlighting trends observed during inspections and allowing industry to prevent issues and manage risk by learning from others
Provide more detail about information collected by the CFIA Complaints and Appeals Office, especially relating to the facts and outcomes related to challenges of regulatory decisions

4. Share more CFIA research and science

The CFIA is one of Canada's largest science-based regulatory agencies, and works with scientific organizations in Canada and internationally, with industry, academia and other partners to support and develop science that contributes to evidence based decisions. Participants showed great interest in having increased access to the scientific information used in regulatory decision-making processes. We learned that stakeholders use scientific information such as outcomes of research, surveillance and monitoring reports, risk assessments, and epidemiological studies as part of their own learning, research, and decision-making processes.

What participants said about how the CFIA can share more CFIA research and science:

Provide more information on CFIA scientific activities in clear language that is easy to understand
Engage stakeholders in the establishment of CFIA research priorities and ensure timely sharing of information resulting from research activities
Increase digital dissemination of all outputs of scientific activities and research in a consistent and timely way
Provide more information about the science-based evidence behind CFIA's regulations, procedures, guidelines, and directives
Ensure the CFIA is up-to-date with the latest science as part of developing flexible regulatory approaches that will encourage industry innovation and fair competition

5. Open up CFIA resources used by CFIA Personnel

The CFIA already makes regulatory and interpretative guidance publically available. Stakeholders, in particular industry, told us they would like increased access to materials to help them understand how CFIA inspectors conduct their regulatory inspections and support compliance with requirements.

What participants said about how the CFIA can open up resources used by CFIA personnel:

Make operational procedures and other guidance materials used by CFIA inspectors publicly available

6. Enhance stakeholder access to CFIA expertise

Throughout the consultation we learned that stakeholders often relied on the expertise of CFIA staff to help answer questions about regulations. Stakeholders highlighted that they prefer to receive information from CFIA's subject matter experts. To access this information, stakeholders indicated using the CFIA website, emailing and telephoning the CFIA. What we heard was that while information collected via these sources was generally useful, stakeholders either found response times could be improved, or that information was not received in a timely manner, in many cases rendering it outdated for decision-making purposes.

What participants said about how the CFIA can enhance stakeholder access to CFIA expertise:

Enhance Ask CFIA. The Ask CFIA service provides regulated parties with a single point of entry to ask questions to help them understand and reply with requirements. Industry stakeholders said that while it is an encouraging initial step, that enhancements should be made to allow responses to questions in real-time
Decrease response times, and create a searchable database of questions previously answered by Ask CFIA
In addition to digital services, provide a telephone hotline recognizing limited internet access in some remote areas

Next Steps

Revise Open and Transparent Agency Framework and Policy

The Open and Transparent Agency Framework and Policy are being revised using the comments and feedback received from both external stakeholders and CFIA employees during consultation.

Implementation and Action Plan

During the consultation in summer 2018, the CFIA indicated its plans were to post the improved framework and policy to its website in late fall of 2018. To ensure the CFIA duly considers all comments received, a public release is now anticipated for spring 2019.

In the case of the framework, an action plan will be developed to bring it to life. This action plan will consider:

Bridging known gaps between the openness and transparency practices of the CFIA and its domestic and international regulatory counterparts
Comments and input received through this consultation, and consultation held with CFIA staff in early 2018
The need for the CFIA to balance the diverse needs of all stakeholders and to maintain its regulatory independence

Becoming more open and transparent requires a change in the way that we think and view our work. Pacing will be important, recognizing there will be a learning curve for both staff and stakeholders. Openness and transparency measures will be implemented in a way that is manageable for the Agency and our diverse stakeholders alike while preserving neutrality as a trusted federal regulator.

Thank you

The CFIA wishes to acknowledge all stakeholders and Canadians who participated in the consultation and the exceptional quality of the feedback provided. The discussions generated throughout the engagement activities have yielded invaluable insights and will help us deliver to you a more open and transparent CFIA.

Questions about this report?

Send us an email: transparency.transparence@inspection.gc.ca

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