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Audit of NRCan’s Activities as a Regulator (AU1608)

Audit Branch
Natural Resources Canada

Presented to the Departmental Audit Committee (DAC)
September 22, 2016

TABLE OF CONTENTS

EXECUTIVE SUMMARY

Regulation is an important tool for protecting the health and safety of Canadians and for creating the conditions for an innovative and prosperous economy. Regulations are a form of law, often referred to as delegated or subordinate legislation. Like Acts, they have binding legal effect and usually state rules that apply generally, rather than to specific persons or situations. However, regulations are not made by Parliament. Rather, they are made by persons or bodies to whom Parliament has delegated the authority to make them, such as the Governor in Council, a Minister or an administrative agency, based on the Government of Canada’s (GoC’s) planned policy and strategic directions. Authority to make regulations must be expressly delegated by an Act. The GoC’s regulatory regime is guided by the Cabinet Directive on Regulatory Management (CDRM). This directive is intended to support the GoC’s commitment to protecting and advancing the public interest and well-being of Canadians through a more effective, efficient, and accountable regulatory system.

The Minister of Natural Resources is responsible for over 30 Acts, a number of which provide authority for making regulations and set out responsibilities for the day-to-day administration of regulations. Within the Natural Resources Portfolio, there are over 90 sets of regulations that exist or are being developed, where Natural Resources Canada (NRCan) either serves as the regulatory body or works with its portfolio agencies to support GoC priorities; however, compared to other government departments such as the Canada Food Inspection Agency or Health Canada who carry out extensive regulatory activities as part of their mandates, NRCan is not considered to be a heavy regulator. In its role as a regulator, NRCan is responsible for the administrative requirements of a given Act and associated regulations, including tasks such as monitoring compliance; collecting fees; issuing certificates, licenses, and permits; appointing arbitrators and mediators; and undertaking enforcement activities.

The NRCan legislative framework also includes Acts for which regulating authority is shared with other federal Ministers. In addition, the Department contributes to regulatory development where other Minister(s) is/are exclusively responsible for an Act and its regulations.

In terms of external oversight, the Treasury Board Secretariat’s Regulatory Affairs Sector (TBS-RAS) produces an Annual Scorecard Report intended to contribute to credible public reporting on the progress and performance of federal regulators in implementing systemic regulatory reforms, and to improve the transparency of the federal regulatory system. In addition, the Parliamentary Standing Joint Committee for the Scrutiny of Regulations periodically assesses whether departmental regulations are being reviewed and updated in a timely manner. The Standards Council of Canada also provides recommendations on NRCan regulations that make references to codes and standards, in its capacity as a Crown corporation.

The objective of the audit was to assess the adequacy of NRCan’s structures and processes in place to support regulatory activities.

STRENGTHS

In the area of regulatory governance and guidance, the audit found that roles and responsibilities of the Regulatory Working Group (RWG) and the Strategic Policy and Results Sector (SPRS) are understood and have been communicated to the Sectors. The RWG was observed as a positive initiative to promote horizontal practices and information-sharing within the Department, including making regulatory guidance tools available for the Sectors. The SPRS is also playing a significant function through regulatory coordination and public reporting for initiatives related to the Department’s commitment to the GoC’s Red Tape Reduction Action Plan.

In terms of regulatory assessment, the audit found that ongoing work is being performed to review and update departmental regulatory interpretation policy requirements and service standards. In addition, regulatory enforcement activities are being adequately managed within the Sectors, who hold these responsibilities. Moreover, based on external Treasury Board Secretariat’s Regularly Affairs Sector reviews, these Sectors are also periodically reporting on their individual regulatory activities and performance results, and they provide input into the Departmental Performance Report.

AREAS FOR IMPROVEMENT

An opportunity was identified to strengthen the assessment process regarding how regulatory activities align with the departmental mandate and whether existing regulations continue to meet policy requirements or require review and updating, to ensure compliance with the Cabinet Directive on Regulatory Management.

INTERNAL AUDIT CONCLUSION AND OPINION

Based on NRCan’s mandate and operations, its governance structures, regulatory life cycle management processes, and reporting processes to support regulatory activities are adequate. At the departmental-level, there is an opportunity to strengthen the periodic assessment process of the regulations framework for the purposes of strategic coordination and conducting updates as needed.  

I encourage the Department to continue the positive collaborative activities undertaken by the RWG and the Strategic Policy and Results Sector and to maintain up-to-date regulatory guidance tools for the Sectors.

STATEMENT OF CONFORMANCE

In my professional judgement as Chief Audit Executive, the audit conforms with the Internal Auditing Standards for the Government of Canada, as supported by the results of the Quality Assurance and Improvement Program.

Christian Asselin, CPA, CA, CMA, CFE
Chief Audit Executive
September 22, 2016

ACKNOWLEDGEMENTS

The audit team would like to thank those individuals who contributed to this project and particularly employees who provided insights and comments as part of this audit.

INTRODUCTION

Regulation is an important tool for protecting the health and safety of Canadians and for creating the conditions for an innovative and prosperous economy. Regulations are a form of law, often referred to as delegated or subordinate legislation. Like Acts, they have binding legal effect and usually state rules that apply generally, rather than to specific persons or situations. However, regulations are not made by Parliament. Rather, they are made by persons or bodies to whom Parliament has delegated the authority to make them, such as the Governor in Council, a Minister or an administrative agency, based on the Government of Canada’s (GoC’s) planned policy and strategic directions. Authority to make regulations must be expressly delegated by an Act. The GoC’s regulatory regime is guided by the Cabinet Directive on Regulatory Management (CDRM). This directive is intended to support the GoC’s commitment to protecting and advancing the public interest and well-being of Canadians through a more effective, efficient, and accountable regulatory system.

The Minister of Natural Resources is responsible for over 30 Acts, a number of which provide authority for making regulations and set out responsibilities for the day-to-day administration of regulations. Within the Natural Resources Portfolio, there are over 90 sets of regulations that exist or are being developed, where Natural Resources Canada (NRCan) either serves as the regulatory body or works with its portfolio agencies to support GoC priorities; however, compared to other government departments such as the Canada Food Inspection Agency or Heath Canada who carry out extensive regulatory activities as part of their mandates, NRCan is not considered to be a heavy regulator. In its role as a regulator, NRCan is responsible for the administrative requirements of a given Act and associated regulations, including tasks such as monitoring compliance; collecting fees; issuing certificates, licenses, and permits; appointing arbitrators and mediators; and undertaking enforcement activities.

NRCan plays a regulatory role mainly within the following four Sectors: the Minerals and Metals Sector (MMS); the Energy Sector (ES); the Strategic Policy and Results Sector (SPRS); and the Canadian Forest Service (CFS). The MMS administers the Explosives Act (and the Explosives Regulations, 2013), where NRCan is directly responsible for the issuance of licenses for factories and explosive storage magazines; permits for vehicles used for the transportation of explosives; certificates for carrying out activities relating to explosives; and permits for the importation, exportation, and transportation throughout Canada of explosives. Formerly housed within the SPRS, the MMS has also recently taken over the responsibility to administer the Extractive Sector Transparency Measures Act (ESTMA) that came into force in June 2015. The ESTMA requires businesses involved in the exploration or extraction of oil, gas, or minerals to publicly report every year on specific types of payments made to all levels of government, in Canada and abroad. Within ES, Energy Efficiency Regulations are being administered by the Office of Energy Efficiency (OEE), which address available energy efficient products, testing methodologies, labelling requirements, and international alignment requirements. The ES also plays a significant role in the development of regulations for NRCan’s portfolio agencies, such as the National Energy Board and the Canadian Nuclear Safety Commission. The Canadian Forest Service (CFS) is responsible for the Timber Regulations, which describe requirements for the cutting and removal of timber on federal lands, and the State of Canada’s Forests Regulations, which require annual reporting on the forest sector’s contribution to the economy and the environment.

The NRCan legislative framework also includes Acts for which regulating authority is shared with other federal Ministers. In instances where regulations can impact industry stakeholders of interest to NRCan or where the Department has certain technical and/or scientific expertise, NRCan also contributes to regulatory development where other Minister(s) is/are exclusively responsible for an Act and its regulations. For example, under the Transportation of Dangerous Goods Regulations administered by Transport Canada, the Chief Inspector of Explosives at NRCan, under the Explosives Act and Explosives Regulations, exercises his delegated authority in classification decisions for explosives.

In terms of external oversight, the Treasury Board Secretariat’s (TBS’) Regulatory Affairs Sector (RAS) produces an Annual Scorecard Report intended to contribute to credible public reporting on the progress and performance of federal regulators in implementing systemic regulatory reforms, and to improve the transparency of the federal regulatory system. In addition, the Parliamentary Standing Joint Committee for the Scrutiny of Regulations supports the federal regulatory regime by periodically assessing whether departmental regulations are being reviewed and updated in a timely manner. The Standards Council of Canada also provides recommendations on NRCan regulations that make references to codes and standards, in its capacity as a Crown corporation.

An audit of NRCan’s regulatory activities was included in the Department’s Risk-Based Audit Plan, approved by the Deputy Minister on March 12, 2015.

AUDIT PURPOSE AND OBJECTIVES

The objective of the Audit of NRCan’s Activities as a Regulator was to assess the adequacy of NRCan’s structures and processes in place to support regulatory activities.

Specifically, the audit assessed whether:

  1. The Department has designed and implemented adequate governance structures and processes to support regulatory activities and mitigate related Departmental risks;
  2. The Department has established effective processes to manage its regulatory activities using a life cycle and evidence-based approach in compliance with GoC direction; and,
  3. The Department has established adequate mechanisms to monitor and report on regulatory activities.

AUDIT CONSIDERATIONS

A risk-based approach was used in establishing the objectives, scope, and approach to this audit engagement. A summary of the potential key areas of risk taken into consideration included:

  • Whether governance structures and processes would adequately support departmental regulatory activities and mitigate related Departmental risks;
  • Whether NRCan’s processes to manage regulatory activities are based on evidence and on a life cycle approach to comply with GoC direction and to effectively achieve the desired outcomes; and,
  • Whether NRCan’s monitoring, reporting, and measuring of regulations adequately ensures that existing regulations are being regularly reviewed and updated, and senior management is receiving adequate information for risk management and strategic decision making.

SCOPE

The scope of the audit work included NRCan’s relevant regulatory activitiesFootnote 1, processes, protocols, related systems, and practices used to govern, manage, monitor, and report on NRCan’s regulatory activities. The audit focused on the most recent departmental regulatory activities within the CFS, ES, MMS, and SPRS beginning on April 1, 2014, and ending on March 31, 2016.

The audit examined regulatory activities where NRCan has a regulator role, for example, in the administration of the Explosives Act, the ESTMA, the Energy Efficiency Regulations, and the Timber Regulations.

This audit did not examine NRCan’s Major Projects Management Office or regulatory activities in which other Portfolio Agencies or departments are the primary regulator(s). Given that the CFS’ enforcement activities are managed by outside third-party agents, they were also not examined as part of the audit. In addition, given that the ESTMA only came into force in June 2015 and that the responsibility to administer the Act was recently transferred to the MMS from the SPRS during the conduct phase of the audit, the adequacy and effectiveness of applicable regulations associated to the ESTMA were not examined. 

APPROACH AND METHODOLOGY

The audit methodology was based on the TBS’ Policy on Internal Audit and the GoC’s Internal Auditing Standards and included the following:

  1. Interviews with key personnel with respect to the Department’s regulatory activities, governance structures, and related processes;
  2. Review of key documents including relevant regulations, policies, and directives; and,
  3. A detailed examination of information and documentation relating to the full life cycle of regulatory management.

The conduct phase of this audit was substantially completed in May 2016.

CRITERIA

Please refer to Appendix A for the detailed audit criteria. The criteria guided the audit fieldwork and formed the basis for the overall audit conclusion.

FINDINGS AND RECOMMENDATIONS

REGULATORY GOVERNANCE AND GUIDANCE

Summary Finding

The roles and responsibilities of the Regulatory Working Group (RWG) and the Strategic Policy and Results Sector (SPRS) are understood and have been communicated to the Sectors. The RWG was observed to be a positive initiative to promote horizontal practices and information-sharing within the Department, including making regulatory guidance tools available for the Sectors. The SPRS is also playing a significant function through regulatory coordination and public reporting for initiatives related to the Department’s commitment to the Government of Canada’s (GoC’s) Red Tape Reduction Action Plan.

Supporting Observations

Regulatory Governance

In September 2015, collaboration between departmental regulatory groups was enhanced through the creation of the Director General-level Regulatory Working Group (RWG), which was originally created to support the Department’s transition to a new government regime. The RWG has since evolved to a director/analyst-level working group to promote horizontal practices, collaboration, and information-sharing in the Department. The Chair of the RWG is the Director, Energy Systems Management, part of the Energy Safety and Security Branch, Energy Sector (ES). This role was assigned based on ES having the largest volume of regulatory activities in the Department. The objectives of the RWG, as specified in its Terms of Reference, are to build regulatory capacity at NRCan and to bring greater clarity and consistency to departmental regulatory processes. The RWG meets quarterly, or more frequently if desired, and is made up of volunteer members from across all NRCan’s Sectors. Members regularly contribute to the RWG’s weekly requests for updates to regulatory items and other Governor-in-Council requests. They also feed into prioritization exercises for drafting regulations, which are sent to NRCan’s Legal Services Unit.

The Strategic Policy and Results Sector (SPRS) has also been supporting regulatory coordination of the Department’s regulatory public reporting requirements and other Red Tape Reduction Action Plan initiatives, which include reducing the regulatory burden on businesses, enhancing transparency of regulations, and updating the Department’s upcoming regulatory activities through published Forward Regulatory Plans.

Regulatory Guidance

The audit team found that departmental guidance exists in the area of regulatory life cycle management and that Sectors have access to centralized tools being maintained by the RWG to manage common regulatory challenges. In addition, Sectors consult with each other and obtain advice from consultations with regulatory stakeholders such as NRCan’s Legal Services Unit and the Treasury Board Secretariat’s Regulatory Affairs Section (TBS-RAS). TBS also maintains a website with extensive guidelines and tools related to regulatory management for federal departments. The audit team confirmed with Sector interviewees that, in terms of common practices and guidance, it would be beneficial to create ‘common-look-and-feel’ regulatory packages for all departmental Sectors to allow for further efficiencies during the regulatory approval and publication processes. This is one of the activities currently being pursued by the RWG, as the audit noted references to some generic GoC guidelines and tools that are available on the TBS’ website, through the RWG’s GCDOCS link.

REGULATORY OVERSIGHT AND PRIORITIZATION

Summary Finding

Ongoing work is being performed to review and update departmental regulatory interpretation policy requirements and service standards. NRCan is also member of the Community of Federal Regulators (CFR), which encourages horizontal collaboration on policy issues and best practices.

With that said, limited effort has been dedicated towards the assessment of the departmental regulatory framework, as required under the Cabinet Directive on Regulatory Management (CDRM). At the departmental level, there is no process in place to regularly review existing regulations for the purpose of strategic coordination and conducting updates as needed.

Supporting Observations

Regulatory Oversight

According to the CDRM, “Departments and agencies are responsible for ensuring that regulation continually meets its initial policy objectives and for reviewing regulatory frameworks on an ongoing basis.” Based on this criterion, assessments should be performed regularly to determine the effectiveness of the overall departmental regulatory framework and existing regulations.

The audit team found that a departmental assessment process is not in place, including reviewing whether existing regulations continue to meet their initial policy objectives or require updating; however, the Department has performed updates to existing regulations when suggested by external regulatory bodies. For example, in 2015, the Parliamentary Standing Joint Committee for the Scrutiny of Regulations made inquiries into the progress of amendments on certain NRCan regulations, where amendments are currently outstanding or in progress. In the event that the Department is unable to update these regulations in a timely manner, this may ultimately result in part of a regulation or entire regulations being revoked.

In addition, in 2010, the Standards Council of Canada performed an assessment on select NRCan regulations that make reference to codes and standards, and observed that certain NRCan regulations required review and updating. As a result of this assessment, NRCan committed to work with the Council to address current out-of-date regulatory references by 2017, and to find mitigation strategies for any future out-of-date references. As a general rule of thumb, the Council recommends that departments follow a five-year review and update schedule for their existing regulations. NRCan does not currently follow a set schedule to update its regulations. In the case of the ES, where the majority of outdated references to regulations were noted, the Sector is in the process of either creating new or amending existing regulations to address the Council’s recommendations.

Regulatory oversight activities are also assisted through NRCan’s participation on the Community of Federal Regulators (CFR), an inter-departmental community of 27 federal departments and agencies working to strengthen the capacity of its regulatory professionals. This community encourages horizontal collaboration by providing opportunities for federal regulators to discuss issues of common concern and to share information. The CFR also conducts research and documents regulatory best practices to serve as learning tools for the community. NRCan’s regulatory Sectors have participated in CFR events and contributed to agenda items related to the departmental mandate.

In terms of regulatory updates, the Metals and Minerals Sector (MMS) recently completed modernization efforts on its explosives regulations, and this represented the first revisiting of the Explosives Act since its inception. The 2002 Public Safety Act broadened the mandate of the Explosives Regulatory Division to encompass not only safety-oriented, but security-related activities, including control of the sale of restricted components used to manufacture home-made explosives; implementation of export and in-transit explosives permits; collection of data to minimize the likelihood of illegal trafficking; and security screening of persons with access to certain explosives. These changes led to the development of the Explosives Regulations, 2013, including new regulatory provisions for security screening, transportation, and exportation of explosives.

For the other Sectors examined as part of the audit, audit interviews confirmed that beyond ongoing work related to updating regulatory interpretation policy requirements and service standards, limited work has been performed to review and update existing regulations.

Regulatory Prioritization

Audit interviews with the regulatory Sectors confirmed that a lack of regulatory prioritization exists within the Department. If the Department was able to provide its most urgent regulatory proposals to external regulatory stakeholders, such as the TBS-RAS, in a more structured manner, these stakeholders could more efficiently perform their due diligence and respond to NRCan Sectors in a timelier manner.

Clear direction regarding the strategic coordination of regulatory priorities across all Sectors would also assist NRCan’s Legal Services Unit, in terms of managing and coordinating their contributions to the regulatory process. Moreover, a lack of clear departmental regulatory priorities may make it difficult to adequately highlight the most urgent departmental items for discussion on Cabinet agendas.

The audit noted that the RWG is making progress at the working-level to better communicate regulatory priorities to TBS-RAS and NRCan’s Legal Services Unit, including ES-led consultations with representatives from the other Sectors; however, an agreed-upon departmental process to prioritize regulatory activities is not in place.

RISK AND IMPACT

If existing regulations are not reviewed and updated in a timely manner, regulations may not be relevant, effective or align with their original policy objectives. In addition, if regulatory activities are not adequately prioritized and coordinated at the departmental-level, NRCan could be in a position where it may not comply with the CDRM and/or achieve its strategic outcomes.

RECOMMENDATION

  1. It is recommended that the Assistant Deputy Minister Energy Sector (ADM ES), in collaboration with the ADM Minerals and Metals (MMS) Sector and the ADM Strategic Policy and Results (SPRS) Sector, develop an assessment process on department-wide regulatory activity to ensure that existing regulations are regularly reviewed for the purposes of strategic coordination and conducting updates as needed.

MANAGEMENT RESPONSE AND ACTION PLAN

Management agrees. In response to recommendation 1:

The ADMs of ES, MMS, and SPRS will work together to establish a process of periodic assessments of department-wide regulatory activities to allow strategic coordination. This will include ensuring that all new and existing regulations are periodically reviewed and that required updates are conducted in a timely manner.

The ADMs of ES, MMS, and SPRS will work to build on existing coordination of the regulatory business advanced by the Department. Work will include: 

  1. processes to brief Treasury Board Secretariat Regulatory Affairs on departmental regulatory priorities; prioritization of requests for drafting services from the Department of Justice; and
  2. development of regulatory tools, for example, a Regulatory Resource Library in GCDOCS. 

Positions responsible: Assistant Deputy Minister Energy Sector, Assistant Deputy Minister Minerals and Metals Sector and Assistant Deputy Minister, Strategic Policy and Results Sector

Timing: In place by November 2016

REGULATORY ENFORCEMENT AND REPORTING

Summary Finding

Regulatory enforcement activities are being adequately managed within the Sectors who hold these responsibilities. In addition, the TBS Annual Scorecard Report found the Department to be performing strongly against the CDRM’s requirements. In terms of informing for decision making, the RWG members provide input that can be used to brief NRCan management on policy or process changes, including through the Policy and Science Integration Committee and the Executive Committee, as required. The audit also found that senior management committees receive timely information related to regulatory activities. In addition, Sectors are reporting on their individual regulatory activities and performance results, as needed, and provide input into the Departmental Performance Report.    

Supporting Observations

Enforcement of Regulations

In view of the CDRM’s emphasis on the need for a life cycle approach to regulatory management, the audit examined how the MMS and the ES manage the effectiveness of compliance processes related to their enforcement activities, and found these activities to be adequate.

Both the MMS and the ES conduct enforcement activities under Memoranda of Understanding with the Canada Border Services Agency (CBSA), who assists NRCan in the administration of relevant Acts and regulations related to the importation and/or exportation of products. Energy Efficiency Regulations are monitored by the ES’ Office of Energy Efficiency (OEE), which reviews regulatory compliance using periodic dashboards provided by CBSA. The OEE has also established a ‘2016 Compliance and Enforcement Policy’, a complementary tool to support its existing regulations.

Similarly, for the MMS’ Explosives Regulations, CBSA Border Services Offices monitor and control explosive materials that enter and leave Canada, whereby the CBSA, in collaboration with NRCan, carries out risk-based compliance verification exercises that target inspections based on factors such as safety and security, prior to issuing import permits. Another MMS-administered enforcement activity is the issuance of ‘stop-work orders’ per Section 12 of the Explosives Act. The audit team found that this activity is currently tracked in a spreadsheet, and results feed into the Sector’s internal annual report as well as into its planning sessions for future follow-up inspections. The MMS is also planning to upgrade the explosives component of its current Licensing Management System, to provide for enhanced tracking of its licenses, permits/certificates, and compliance verification activities.

TBS Annual Scorecard Report

For the most recent 2014-15 Annual TBS Scorecard Report, the Department was either in full compliance or generally in compliance with reform commitments and guidance requirements, with minor corrective actions required. Both the ES and the SPRS were involved in ensuring that applicable CDRM requirements were met through their interactions with both the Sectors and the TBS-RAS and for coordinating the departmental process related to the Red Tape Reduction Action Plan, including keeping senior management informed on the progress and finalization of NRCan’s response.

Reporting for Decision Making

Based on its Terms of Reference, the RWG members provide input that can be used to brief NRCan management on any potential changes to NRCan regulatory policies and processes before changes are made, and inform the Policy and Science Integration Committee and the Executive Committee, as required. In addition, the ES Chair of the RWG sends out a weekly call letter to Sector committee members requesting input into a forecast document entitled the ‘Regulatory/Governor-In-Council Submissions’. The intent of this document is to provide weekly information updates to senior management on the status of regulatory packages and other items for Governor-in-Council approval.

The audit team found that senior management committees that support the Deputy Minister, including the Weekly Planning Committee and the Director General Issues Management – Access to Information and Privacy Committee receive timely information, including regular updates on Parliamentary and Cabinet activities, ATIP requests, and issues management activities related to regulatory activities. Regular updates on regulatory activities to Sector senior management are also taking place through media lines, notifications on publications such as the Departmental Performance Report, required action items, and final regulatory approval timelines.

Sectors examined as part of the audit produce annual reports, where required, which communicate the status of each regulation, provide key performance indicators, and summarize regulatory outcomes. For example, the State of Canada’s Forests Report is a legislated publication that provides the only national snapshot of the social, economic, and environmental status of forests and forestry in Canada. Similarly, the OEE’s Report to Parliament under the Energy Efficiency Act 2013-2015, produced every three years, outlines the actions taken by the GoC on energy efficiency and alternative transportation fuels. This report provides an overview of the importance of energy efficiency as well as a discussion of NRCan’s role in the development and enforcement of regulations, standards, and codes.

Further to metrics described in annual reports, the outcomes of Sector regulatory activities also feed into departmental reporting processes. The annual Departmental Performance Report links the Sectors’ priorities with their respective strategic outcomes at the sub-program-level, and also provides a summary of progress and performance analysis, and lessons learned, which may include regulatory work depending on the previous year’s activities. For instance, the FY 2014-15 Departmental Performance Report discussed the modernization efforts of the MMS  as “…clearer, reflect modern industrial explosives practices, and make it easier for stakeholders to comply with the Regulations, which will result in improved safety for citizens with respect to explosives.”

APPENDIX A – AUDIT CRITERIA

The audit criteria were developed primarily from frameworks of similar regulatory regimes in other government departments and the Government of Canada’s (GoC’s) Cabinet Directive on Regulatory Management (CDRM).

The objective of the audit was to assess the adequacy of NRCan’s structures and processes in place to support regulatory activities.

The following audit criteria were used to conduct the audit:

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