Media discussion in the run–up to the current Canada Grain Act review has focused on two issues: cost of Canadian Grain Commission operations and alleged duplication of services as grain companies push to replace independent CGC inspection with third-party inspectors.
Cost and efficiency are important, and concern would be warranted if justified by the facts, but it isn’t. While commission costs have risen marginally over the last decade, the real issue is that farmers now pay all but $6 million of the CGC’s annual budget, including virtually all of the public good/quality assurance costs associated with the act.
This is while the commission is providing ever fewer direct services in support of its mandate to establish and maintain standards and regulate grain handling “in the interests of producers.”
Meanwhile, duplication of services complaints continue to rely on false equivalence between privately purchased third-party inspections and those of the independent public regulator.
There is another story — the farmer perspective — and it needs addressing.
Like the media discussion, it’s focused on two key issues, but there the similarity ends. These issues — relevance of the CGC to individual farm operations and recriminations over grade and non-grade values assigned at the elevator — are widespread and real. These concerns threaten the legitimacy of the commission and its ability to fulfil its mandate.
Consider the dwindling audit trail. At one time the GCG inspected every single rail car for grade and dockage, giving farmers an independent assessment of each load. Inward inspection, the next stage in the audit trail, was lost in 2012, conceding the CGC’s opportunity to assess overall grain quality before it enters the terminal system.
The CGC also jettisoned its longstanding incremental ship-loading protocol, which ensured consistency throughout the entire load, in favour of less rigorous composite loading, in which only the average of the entire load must comply with the specifications. This change has prompted numerous complaints from Canada’s customers.
Assistant commissioners, who for almost a century policed primary elevators and their equipment and investigated disputes between producers and elevators, have also been lost. Monitoring of elevator grading, dockage and testing and weighing equipment, a key rationale for creation of the Canada Grain Act, has been privately contracted.
Sadly, this loss of rigour has become the rule, but a one-sided rule. Primary and inward inspection, assistant commissioners, CGC equipment-monitoring: they all disappeared because grain handlers considered them expensive or impractical. While the changes might be favourable to grain handlers, none are helpful to farmers or in keeping with the CGC’s quality assurance and producer interest mandate.
These failings can be corrected, but only if they’re addressed. The current CGC commissioners must act to restore the commission’s relevance and independence. Inward inspection, equipment monitoring, and the commission’s respected incremental loading protocol must be restored. Also, creation of an independent, professional office of assistant commissioners in the three provinces would help assure producers that CGC scrutiny of the trade is as rigorous, comprehensive and technologically sophisticated as the trade’s scrutiny of farm deliveries.
Farmers don’t expect the CGC to always take their side, but they do expect a vigorous, independent regulator — an honest cop. This policing function must be seen to be effective.
Only by restoring the commission’s presence on the beat — hands-on in the primary elevators and terminals — can producers be assured the CGC is truly regulating Canada’s grain-handling system in the “interests of producers.”
Bruce Dodds is a former field representative with the Agricultural Producers Association of Saskatchewan, and Cameron Goff farms near Hanley, Sask.