I was recently asked to testify as an expert witness in front of a House of Communes Permanent Committee that wanted to know about the benefits and issues the Canadian General Standards Board provides Canadians. Below is a transcript of my testimony.
June 3rd, 2014 / 8:50 a.m.
Michel Comtois President, Micom Laboratories Inc.
Thank you, Mr. Chairman. Good morning.
My name is Michel Comtois and I am the president of Laboratoires Micom inc., in Dorval. Our company was founded 15 years ago. Prior to that, I worked for 12 years in another laboratory. I have therefore been working with the CGSB for 25 years. As in a marriage, I have seen the best and I have seen the worst.
I work with the CGSB in three capacities.
First, I am a CGSB client. Since the establishment of my current company, as well as during my previous career, the board has been my laboratory accreditation services provider. The services have been necessary in order to guarantee that the laboratory’s quality control procedures are up to standard.
I also provide services for the CGSB. The CGSB has a list of approved products that is used for advanced product assessments so that potential buyers can then purchase these products without worrying about their reliability or their compliance. It is somewhat like buying a hair dryer at the store. You are not going to be concerned about whether or not the hair dryer is dangerous if you can see that it has been certified by the CSA Group. Laboratories and organizations have made sure that the product is safe for the user.
We provide laboratory services to the CGSB, who is therefore our client.
Furthermore, over the past 25 years, I have sat as an expert member on a number of technical committees that set CGSB standards. These committees deal, for all intents and purposes, with all CGSB standards, whether they apply to office furniture or to other products such as latex gloves and ink or recycled cartridges.
I was a member of the ISO/TC 136 committee. I was the head of the Canadian delegation that dealt with ISO standards for office furniture. We represented the Canadian position.
I have divided my remarks into three main parts. The CGSB also provides inspection services but I have never been involved in that. I therefore do not feel that I am in a position to speak to that aspect of the CGSB’s work.
Let’s turn now to laboratory accreditation programs. It is easier for a new laboratory to acquire accreditation under the CGSB’s program than the corresponding Standards Council of Canada Program. It is easier from a technical perspective and from a cost perspective, especially because—I feel—the Standards Council of Canada sets exorbitant prices for its services.
There is some overlap between the accreditation programs of the CGSB and the Standards Council of Canada but for new SMEs it makes for an easier start.
We have received CGSB auditors over several years. I have always felt that they were competent. I think it is important to state that. However, the CGSB can only provide accreditation for laboratories under programs for which they provide certification services to government or to an industry. Over the years, my company has expanded and has had to change registrars simply because it could no longer certify us for all the services we were offering.
Another aspect of the CGSB is its list of approved products. That is the list I was referring to earlier. This is a list of products that have already been certified, which gives buyers an opportunity to obtain these products without having to wonder whether they are compliant or not. For example, the CGSB has a list of latex gloves, surgical gloves, and gloves that doctors use in hospitals. These are gloves that are used by dentists, physicians, etc mylan bupropion xl.
One of the problems with the CGSB is that it cannot promote its programs because of its internal operation rules. These programs are good for potential clients, whether they be hospitals, for example in the case of latex gloves, or users who may be purchasing them in a pharmacy. However, it does not have the right to advertise itself to the public or to users.
A few years ago my wife was sick and we had to go to the hospital. There was a box of latex gloves on the wall. Given that I work in the area, I checked to see if the gloves were certified. Usually there is a logo on the box that states that they have been certified. There was no logo.
Obviously hospitals work under budgetary constraints. They often tend to choose the lowest bidder. In any case, the government often works that way. If there is no requirement to buy certified products to ensure quality, then obviously it can be tempting to save money and choose a brand that is not certified and for which a minimum level of quality has not been guaranteed. Hospitals choose the product because it costs 10¢ less. I think it is important to raise awareness about the value and advantages of services offered under this program. If people are not aware of this, then they will not ask for it.
Another program that should be used extensively but that is actually used infrequently is the program for office equipment purchases. The federal government alone purchases 100 million dollars’ worth of office equipment annually. Some governments require that a part of this program be used, including the Quebec government; it requires compliance with the standards of the Canadian General Standards Board. There was a time when they also required compliance with the QPL program. The cities of Halifax and Winnipeg, as well as some colleges and universities, also require compliance with the CGSB standards for office furniture.
Public Works and Government Services Canada requires compliance with national standards. In the past, the department required that providers be accredited under the CGSB standards and also be on the QPL list in order to be able to sell products to the government. There has been a lack of competent resources within the CGSB, a lack of internal policies within Public Works Canada and pressure on the part of the industry, including from American companies. Public Works Canada had been very patient with the CGSB but it finally withdrew the requirement for manufacturers to be on the QPL list for the purposes of selling their products to the federal government.
In terms of furniture, the QPL was working and continues to work slowly. For its part, Public Works and Government Services Canada is constantly changing its procurement policies and is reducing its monitoring of technical compliance for furniture, because it does not have enough internal technical resources, and it feels that the process of insuring that providers are compliant with the CGSB’s national standards is too onerous.
If we look at the numbers, we can see that the federal government purchases $100 million of office equipment every year. According to my quick calculations, the cost of certifying products in order to ensure a minimum level of quality, that is compliance with CGSB standards and listing with the QPL, make up approximately .5% of the government’s total annual procurement.
Furthermore, the tests required under CGSB standards for listing with the QPL use North American standards. Like all Canadian industries, the furniture industry exports approximately 80% of its office furniture to the United States. In order to sell to major institutions and companies, as well as to the American government, that is probably the biggest buyer of office furniture in the world, companies must meet certain performance standards. Those standards are perfectly compatible with the CGSB standards. A considerable amount of work has been done to harmonize CGSB standards and those of the BIFMA, which represents the American industry. If you include the 80% of exported furniture, the .5% of annual procurement goes down to .1%. In my humble opinion, it is not a lot to pay if what you get is a robust and efficient procedure that guarantees an appropriate level of performance and quality.
On April 7, PWGSC held consultations on its draft procurement policy for office furniture. I attended those consultations and I recommended that the use of the CGSB QPL should be mandatory. This new procurement policy is not yet in effect, but from what I have heard, the use of the new QPL will not be mandatory.
In a procurement policy where contracts are awarded to the lowest compliant bidder, why would Crown suppliers choose to voluntarily adhere to a verification program intended to maintain a certain level of quality? The question almost answers itself. In my humble opinion, I am not sure it is necessarily in PWGSC’s advantage not to require that.
We have to look a bit at the CGSB as a gear in a gear box. It’s one thing to question if it’s the right gear or if there are the right number of teeth on that gear, but then if that gear doesn’t engage with the rest of the gear box because the stakeholder is within the government—for instance, my two examples for DataTech Labs, or for the furniture—well, then, we have to wonder why that gear is there, or we have to wonder how we get that gear to work properly with the rest of the gear box.
In that regard, the government has several options. It can opt for the status quo, in other words continue on in the same way, even if that is not as effective as it should be, at least as far as the programs I have seen are concerned.
To make the CGSB more effective, PWGSC and the other departments and agencies would have to be required to use QPL certified products as much as possible.
Recently, I studied another case where seats reserved for the public had been sold to the government. There was no requirement to meet CGSB or BIFMA standards. One of the chairs was broken and someone was injured when they sat on it. A complaint was filed with the supplier and the supplier had to change his furniture.
Government representatives rightly wondered how they could ensure that these chairs would be safe. Our client called us and we told him that we would test the chairs according to national standards. And in fact that is what should have been done from the beginning, at the bidding stage. We conducted tests, and we showed that by modifying the chairs, they could be adequate.
If things had been done in the correct order, there would have been a requirement that these products meet the standards before they were offered to the government. Then that person would not have been injured. They went through all the steps, but not in the right order, so there was a waste of time and energy. Everyone was dissatisfied with this purchasing process.
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My career has been focused on simulating real life in the lab under controlled yet accelerated conditions. My passion for lab testing lead me to start Micom Laboratories Inc. 16 years ago. Through time I made sure Micom has the necessary equipment to simulate various environmental parameters such as the sun, vibrations, heat, cold, thermal shocks and humidity. I wanted to be able to move things back and forth, apply stresses to the products and materials we test and see how they react to the various stimuli. To do so we test products and materials against known standards and specifications (certification) and in many cases by creating my own test protocols and specifications (this is the cherry on top of the sundae…). This is what led me to participate in many standards writing committees and to become chairman of some of these committees.