An Office of Consumer Affairs and Public Participation

Box 3458
Salmon Arm, B.C.
V1E 4S2
May 13, 1999

Joel Weiner
A/Director General
Policy, Planning & Coordination Directorate
Health Protection Bldg., Room 245
Tunney’s Pasture
Ottawa, ON K1A 0L2

Dear Joel,

I am writing to you now to summarize my perceptions of our meeting on May 10/99, for much of which Mary Hegan was also present, and to which Dr. Joe Losos paid a brief visit.

The meeting was held to discuss the draft paper ‘Building a More Citizen-Focused HPB’ relating to the proposed establishment of the Office of Consumer Affairs and Public Involvement (OCAPI).

Our meeting began, as you will recall, with your outlining the thrust of the paper. You then asked me what I thought of the document, and I indicated that I was unsure, as I felt the paper, condensed from an earlier longer and more detailed manuscript, was too general to be distinctive or clear. I did interject at this time that the panel of individuals chosen to review the paper on April 19/99 was well chosen, and that their conclusion was that there was evidence of some measure of sincerity behind the paper’s genesis. You were at first a little dismayed when I commented that the HPB and Health Canada in general were seen as the prime entry point into the process of changing health and environmental practices within the Federal government, because I think you felt that I was suggesting that HPB/HC were the main stumbling blocks in this sector. I think you were reassured when I clarified that I meant that many groups felt that HPB/HC was more susceptible to input from outside than, for example, Environment or Industry, Trade and Commerce.

We then moved on to a more detailed discussion, and I suggested a number of concrete measures, which I will review at the end of this letter. However I did note that the gradual lengthening of the HPB ‘Transition’ process was construed, in some quarters, as evidence that the process itself was more substantive than originally planned, and hence potentially more meaningful. You pointed out, as we discussed this further, that many managers within the Branch felt threatened by the possibility of an entity like OCAPI, feeling that it would interfere with their autonomy. I responded that their discomfiture was a good sign, indicating that they indeed sensed that this new office might represent a new, more citizen-responsive direction. I elaborated that had they not been concerned, this would have been a clear sign that the OCAPI initiative was simply ‘business as usual’.

We then discussed the fact that there was a perceived need, among knowledgeable observers of the HPB, for a cultural shift in attitudes within the Branch. You recognized that this was, in fact, what I was suggesting, and that it was necessary for outside groups to be openly involved in what was taking place. I added that the presentation of cautious, sceptical, or even outright hostile responses to HPB suggestions was a far better sign than no response at all or simply bland responses, since the latter would indicate complete mistrust of HPB initiatives and motives.

At this point Mary Hegan joined the meeting, and reiterated strongly that the OCAPI draft was intended to indicate that a sincere attempt was being made to introduce change into HPB operations.

Shortly thereafter Joe Losos also joined the meeting briefly, and we discussed process. He indicated that there was a need to temper expectations with realism. I suggested that most external ENGOs and NGOs had no illusions about the forces arrayed against change, but were seasoned and in for the long haul.

You asked around this time what might be construed as ‘confidence-building measures’ by external groups. I suggested that an oversight body watching the OCAPI, with ‘teeth’ (i.e. the capacity and power to initiate meaningful change in its modes of operation) would be helpful, and added that measures like the establishment of ‘a registry of consumers and consumer representatives’ was an interesting and constructive gesture. We wound down our meeting with your reiteration that the kind of sweeping changes I was portraying would need to be tempered by realism, and my response that the sorts of seasoned groups that were analyzing Federal government behaviour were not naive about the depth of resistance to change, and were therefore likely to be realistic in their expectations.

I added that if HPB truly wanted to counterbalance the pressure of the corporate sector, it would be wise to utilize the moral authority of the ENGO/NGO community, but that this could only be accomplished by allowing the latter to be genuinely privy to the workings of the processes within HPB/HC.

I would now like to enumerate some of the concrete measures that I made reference to throughout our meeting, and which I feel would be part of any realistic initiative to develop a more ‘citizen-focused HPB’, whether through the OCAPI or otherwise.

  1. Material support for citizen participants. This must entail both expenses and recompense for lost income (to counterbalance the fact that industry hires staff to interact full-time with HPB/HC).
  2. Full, transparent disclosure of all inputs into HPB/HC process. This would entail, for example, sharing all documents and significant communications from industry/commercial/other special interest sources, up to and including phone logs were appropriate.
  3. Maintenance of technical capacity. The current trend to downsize away all technical and scientific personnel means that no real citizen involvement can take place, because technical issues cannot be addressed if there are no qualified, knowledgeable staff to answer detailed, well-informed questions. For OCAPI to become a bureaucracy of ‘communicators’ would be unfortunate, but for HPB to become a bureaucracy of ‘regulators’, but lack expert, hands-on technical and scientific depth, would be a disaster. OCAPI cannot of itself solve communication issues if there is no technical depth behind it.
  4. Communications arising from OCAPI or anywhere else must be timely and manageable. No last-minute meetings (minimum advance notice 3-4 weeks), and no avalanche of jargon-filled technical documentation with little time to digest and absorb it.
  5. Painfully transparent process. Activities of the OCAPI and the HPB in general must be guileless. Groups and individuals must be able to find out, for example, who is going to respond to an inquiry or request, who will be reviewing it, who decides on how a response is carried out (or if it will take place), by when the response will be (for sure) available, how the process of responding will proceed, who will have veto power over a response or particular action, and how an appeal process might be carried out. Freedom of Information processing should be only very rarely necessary.
  6. Citizen involvement on an event basis and an ongoing basis. The OCAPI might be responsible for organizing special events to allow major citizen input on topical and important issues, but it must also establish day-to-day processes for meaningful citizen input, from dealing with questions arising in all forms and media, to a timely response to current events in the community at large. It is likely by the latter processes that the OCAPI (or the HPB for that matter) will be judged, because spontaneous questions and issues will reveal how deep — or, correspondingly, how superficial — is HPB’s commitment to citizen involvement.
  7. Whistle-blower capacity. Without true protection for whistleblowers, both within HC and the HPB and in the community at large, much of the above becomes meaningless. Workable, accessible whistleblower protection legislation is critical to transparency and a commitment to honesty.

I enjoyed meeting with you, Joel, and with Mary Hegan and Joe Losos. I wish to thank you all for setting the time aside to discuss these issues with me, issues about which I care deeply, and which our organization is firmly committed to addressing. I look forward to hearing from you soon, and to your comments on the above, as well as your suggestions for further interaction.

I would comment in closing that HPB has established relatively few points of contact with citizens or citizen groups through the Transition process, apart from the initial round of public involvement meetings. Given that there are some very knowledgeable and well-informed observers of HPB activities in communities across the country, I think you might find it valuable to incorporate many more citizen input sessions, formal or informal, into your deliberations.


Warren Bell MD

cc: Kapil Khatter
Trevor Hancock
Joe Losos
Mary Hegan


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