Report on Health Canada's Achievements (2000-2004) Under the Canadian Environmental Protection Act of 1999 (CEPA 1999) in Support of Parliamentary Review

7.0 Recommendations

• 1. Integrate CEPA Governance, Strategic Planning, and Program Delivery Within Health Canada. Responsibility for delivering CEPA is split among many HC organizations, and no single organization is responsible for all aspects of CEPA. This limits HC's ability to plan, fund, and conduct the work; to assess and report on achievements; and to justify and secure appropriate long-term CEPA funding. Since several HC organizations also undertake non-CEPA activities, it would be difficult to create a dedicated "CEPA-only" unit within the department. However, CEPA should be horizontally integrated across the relevant HC organizations (likely through an organization such as the SSOD, which was created specifically to help this situation). Some specific actions that would improve overall program effectiveness include:

• Improving the governance of the CEPA program. This would include assessing options to reorganize the structure and reporting relationships of the eight organizations working on CEPA in HC. (Not all HC CEPA organizations presently report to the same Director, DG, or ADM.)
• Even in the absence of reorganization, a horizontal CEPA management structure should be implemented. That is, governance, planning, communication, and collaboration should be done across all the various CEPA-relevant HC organizations, as opposed to only improving planning within some individual bureaux or divisions.
• Setting integrated short- and long-term strategies for CEPA overall. This would include laying out consistent definitions of activities and outputs wherever possible, and setting goals and milestones tied to human health outcomes, the RMAF and the HC CEPA logic model. (See also recommendation #5 re: best practices).
• Improving and streamlining the work flow planning process. This includes better internal communication among HC CEPA organizations regarding: the nature and number of substances being worked on, the nature and number of substances coming "down the pipe" from one organization to another, and other activities and outputs (e.g., regulatory controls). The intent is to help plan for expected future workloads; e.g., as assessments being done by one organization lead to the need for regulatory instruments to be developed by another, with associated financial and human resource (HR) requirements.
• Setting priorities and allocating appropriate financial and HR resources among different HC CEPA organizations. Resource allocations should be tied to the anticipated health and work load implications of the substances being worked on, with those judged more dangerous, and/or difficult to assess or regulate, obtaining more resources.
• Systematizing the collection, verification, and reporting of CEPA expenditures, outputs, outcomes and achievements against goals and milestones. All HC CEPA organizations should use the same, consistent system. Reporting to the Minister or the public by HC would be done on a CEPA-wide basis. (Currently, it is often done only by individual bureaux or programs.)
• Improving the interdepartmental management of CEPA across HC and Environment Canada. This includes addressing all the points above, ideally including joint reporting and evaluation of achievements. The current reporting done separately by each department makes it very difficult to determine overall CEPA achievements because of overlaps and gaps in the individual reports.

• 2. Improve the Tracking and Reporting of CEPA Activity, Output, and Expenditure Data. These data are relatively high in quality (i.e., accurate, current, complete, and consistent across all HC's CEPA-relevant organizations). However, other data are not, or cannot be easily accessed, or are non-existent. The lack of timely, high-quality data hinders the ability to govern, plan, integrate, and report on CEPA activities within the Department. The first step is to set up a simple, doable reporting system across CEPA-relevant organizations. Some elements to be considered (and that are consistent with previous Capacity Check ^TM findings) include those shown below. We note that these points are currently being addressed by HC through the work being carried out in the MAF, and there are plans to move towards results-based budgeting.

• Develop an approach to obtain acceptance of the RMAF throughout HECS. (This may require modification of the current document. For example, AHED uses another logic model with a different perspective.)
• Implement the mutually agreed-upon RMAF throughout HECS with the short-term goal of using it to track actual cost per activity and the long-term goal of estimating cost per output
• Develop a data collection strategy tied to the RMAF and CEPA logic model, incorporating IT support wherever practical to facilitate data collection and analysis. (Ideally, data on expenditures would be tracked with respect to the five major activities shown in the CEPA logic model, although the reporting burden placed on staff must be weighed against the benefits for improved planning and work flow.)
• Establish the reporting requirements and develop and implement infrastructure.

• 3. Continue efforts to assess CEPA resource allocations, including the identification of under-invested areas. The department is aware of areas of under-resourcing and plans to conduct studies to address this.
• 4. Provide Adequate Funding for the CEPA Program. It is recommended that CEPA seek additional funding for areas not fully funded in Budget 2005, for example monitoring and surveillance, research, and education. It is our understanding that the department is planning such an initiative.
• 5. Investigate Best Practices. For several reasons, it is very difficult for CEPA to determine whether activities and outputs correspond to best practices worldwide, or even within Canada. This limits the ability to optimize HC's organizational structure and operational processes. Two kinds of studies are appropriate to address this:

• An "operational benchmarking", which documents how HC plans, conducts, and manages its CEPA work, comparing these against the structural and operational features used by similar organizations world wide. This would include investigation of lessons learned by these other organizations.
• A "performance benchmarking", in which the quantity and quality of HC's activities and outputs are compared against best practices worldwide. This is inherently more difficult than an operational benchmarking in that items such as the amount and quality of the science being undertaken come under review. Thus more complex methods such as peer review (either on-site, or remotely through review of publications and internal reports) would probably have to be employed.

• 6. Conduct a Rigorous Evaluation of CEPA Risk Management Strategies. For CEPA to be effective for Canadians, HC's risk management strategies such as control instruments and inter-government agreements must be appropriate and effective. If recommended practices are not followed, or compliance is not monitored, or regulations are not enforced, then impacts will likely be small. A critical next step should be a rigorous evaluation of the appropriateness and effectiveness of the risk management strategies and instruments. This should ideally be done CEPA-wide; i.e., integrated with a study of similar strategies developed by Environment Canada. Any lessons learned here (e.g., barriers to the effective implementation of a new regulation) would help improve HC's and EC's CEPA processes.