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Vol. 138, No. 9 — February 28, 2004 Regulations Repealing the Radiation Dosimetry Services Fees RegulationsStatutory Authority Financial Administration Act Sponsoring Department Department of Health REGULATORY IMPACT Description The purpose of this request is to repeal the Radiation Dosimetry Services Fee Regulations that define the fees, products and services for the National Dosimetry Services (NDS). NDS provides an optional service to monitor the personal occupational lifelong exposure of Canadian workers to ionizing radiation. NDS currently serves approximately 95 000 Canadians working in over 13 000 organizations. Occupational fields include medicine, research, education, industry and government, where exposure or possible exposure to sources of ionizing radiation occurs. Examples include medical and dental practices, hospitals, mining and refining companies. Dosimetry products and services are regulated by federal, provincial, and territorial authorities for health and safety. Since 1951, the NDS has been providing optional dosimetry services to Canadian organizations. Regulations for pricing dosimetry products and services were set out in 1952, and increased in 1980, 1984, 1989, and 1994. The current fees are based on 1994 costs. Despite performance levels between 95 and 100 percent, the NDS is left with a budget shortfall. Prices have not changed since 1994. Services requested by customers have changed as technology has improved and these new products and services are not included in the existing Regulations. The fee regulations have not allowed NDS to be sufficiently responsive in setting prices to cover costs to meet customer needs. The repeal of the Radiation Dosimetry Services Fee Regulations is intended to allow NDS to take proactive measures to balance revenues with expenses and to react to required changes in a responsive manner. The relevant legislation is the Financial Administration Act. Following repeal of the Regulations, a new product and services price structure will be developed and managed through contracting processes. A plan to amend the fees in 1999 was delayed due to software implementation (SAP) and Y2K issues. A significant effort in terms of human resources was required to deal with Y2K issues as the NDS was tasked to ensure continuity of its government-wide mission-critical database. During 1999/00, SAP/FIRMS replaced the Departmental Finance System (DFS). The new system did not provide financial revenue reports during this transition period in a timely or responsive manner. The re-direction of staff priorities and the limited resources available impacted on the startup of the products, services and fees revision. This was compounded in 2001 by the events of September 11, which required an increased focus on emergency response. What is a dosimeter? A dosimeter is the prime device used to measure the levels of ionizing radiation. Ionizing radiation is one cause of cancer, although it can cause lesser health effects up to death depending on the amount of exposure. Dosimetry is used to ensure that radiation health and safety best practices are in place and working. Dosimeters are worn by occupational workers such as X-ray and laboratory technologists for a specified duration. They are then returned by mail for processing, analysis and reporting. Dosimetry services Dosimetry services are regulated by the Canadian Nuclear Safety Commission under a licensing program. All dosimetry work is guided by a Quality Assurance Program where strict service standards must be met. Customer organizations are enrolled in a service (Thermoluminescent Dosimeter (TLD), Ring, Uranium Mines or Neutron) based on their work environment. NDS sends a calibrated dosimeter plaque and holder to the customer who will wear it for a pre-determined period of time (from two weeks to three months, depending upon the work environment). Normally, the customer retains the holder and the dosimeter plaque is sent back to the NDS for processing. During processing, customers are sent new plaques, which are then loaded by the customer into holders which are retained at their work location. Some customers request dosimeter plaques, to be pre-loaded into the dosimeter holder upon receipt. Delivery of pre-loaded dosimeters reduces potential contamination by users and contributes to better dosimetry by improving the accuracy of readings. At the end of the wearing period, the dosimeter is returned to NDS. The returned dosimeters are scanned, batched and delivered for processing. The plaque is read and the results interpreted. An exposure report is produced and sent to the customer. The dosimeter is then re-calibrated and re-circulated to another customer. Customer service agents interface with the customer, make adjustments to the customer's requirements in the database and ensure that all needs are met. Alternatives The alternative to repealing the Regulations is to continue with the current system by amending existing Regulations. Under the current system the cost of the regulatory burden of administration for NDS would continue to impact the customers. This could lead to continued imbalance between prices and expenses. Because of this imbalance between expenses and revenues, the Treasury Board and Government of Canada policy on cost recovery would not be met. This alternative does not allow the NDS to respond to customer needs, in a timely and responsive manner. The NDS does not have a regulatory responsibility to provide personal dosimetry services. Clients may choose to purchase dosimetry services from other service providers. Therefore, Regulations are not required to allow NDS to set fees for such services. Using regulations for this purpose has negative consequences for clients: it increases the administrative burden of NDS and the costs are then passed on to the customers; limits the capacity of the program to react responsively and quickly to customer needs and the requirements of changing technology; and delays the implementation of new services that are of potential health benefit to the end user. Time delays inherent in the regulatory process reduce the capacity of NDS to adjust fees to cover all costs. Benefits and costs Benefits There are a number of important benefits from the proposed repeal of the Radiation Dosimetry Services Fee Regulations and their replacement by fee-setting under contract. First, repealing the Regulations and replacing them with fees set by contract represents an appropriate response to managing an unnecessary administrative burden for both NDS and the client. Second, setting fees under contract would allow NDS greater flexibility to set a realistic fee structure and align revenues to business costs. This will allow NDS to attain a stable financial position through prices that will more accurately reflect the cost of doing business. NDS will strive to continually improve efficiencies, and pricing will be set in compliance with Treasury Board's External Charging Policy dated August 2003. Third, new services could be introduced more quickly to address emerging health and technological needs, increasing choices for clients, and potentially improving health outcomes (e.g. increased compliance with dosimeter use through innovative design). These changes will address needs as defined by customers and identified in the customer surveys. The increase in products and services will improve customer satisfaction in accordance with the Policy framework for Service Improvement in the Government of Canada. Transparency and fairness of pricing will continue to be protected through ongoing and regular communication and consultation with clients using existing communication tools such as newsletters, journals and the Web site (www.hc-sc.gc.ca/nds), and through the publication of fee changes in the Canada Gazette, Part I. The industry will benefit from more open, level competition. NDS prices will reflect the true cost of doing business in this industry. This will improve the sustainability of the industry. Moving NDS prices to full cost may encourage Canadian commercial competition by reducing any concerns for the commercial radiation monitoring industry with regard to competition. Keeping the expertise and knowledge in Canada will benefit the industry as a whole. In addition to the benefits to the customers and NDS, Canada will benefit by retaining the critical capacities to respond to and deal with radiological events and emergencies. This is important for the safety and security of Canadians in times of nuclear emergency. Costs The proposed new services and fee structure will better reflect the true costs of the NDS. Customers have not seen the prices for dosimetry services increased in 10 years. According to the results of customer surveys, the current costs of dosimetry services represents less than one percent of the expenses incurred. The proposed increase should not bring the cost of dosimetry services above that one percent. All prices for current services and products will be increased to match current costs to NDS to supply the service (processing, for example, will increase from $3.98 to between $4.28 and $8.26 depending upon the volume processed; see NDS Description of New Products, Services and Fees). Accounts which are late or negligent in returning the dosimeters or which have returned damaged dosimeters will be required to pay an increased fee to fully cover the cost of replacement and increased workload for NDS. New products and services will be introduced and fees will be set in accordance with Treasury Board's cost recovery policy. Consultation The consultation process began in 2000. NDS clients were informed that the fee structure was being reviewed and that fees would increase. In 2002, two surveys were conducted with stratified representative groups of clients. The sample of the NDS customer base used represents a sample taken from all areas of industry. The first survey helped us determine client satisfaction with existing business lines and solicit information on new products and services. The second focused on customer feedback on the pricing methods for both existing and enhanced products and services, and on economic and business impacts. Overall, clients were satisfied with the high quality of existing business lines and would continue to use NDS's services and pay more for both existing and enhanced products and services. Based on the results from the second survey, a pricing model was constructed for the new Regulations. In addition to the two surveys, NDS consulted with clients on repealing the Regulations. Over 130 clients where called. More than 30 percent of respondents supported the repeal of the Regulations. NDS communicated formally using newsletters, inserts and information packages: Newsletters — Spring 2002 (March 2002) Article "NDS Product, Service and Fee Review Project" — Winter 2000-2001 (December 2000) Article "Rate Change" Inserts — April 2000 "Advance Notice" — February 2002 "NDS Product, Service and Fee Review Project" Proposals and information packages — Information packages and proposals that were sent out in 2000, 2001 and 2002 indicated that our fees were under review. Compliance and enforcement There are no compliance or enforcement implications to the proposal. Contact Antonio Mattioli, Radiation Protection Bureau, Safe Environments Programme, Healthy Environments and Consumer Safety Branch, Address Locator 6302C1, Ottawa, Ontario K1A 1C1, (613) 954-6697 (Telephone), (613) 941-3497 (Facsimile), antonio_mattioli@hc-sc.gc.ca (Electronic mail). PROPOSED REGULATORY TEXT Notice is hereby given that the Governor in Council, pursuant to paragraph 19(1)(a) (see footnote a) of the Financial Administration Act, proposes to make the annexed Regulations Repealing the Radiation Dosimetry Services Fees Regulations. Interested persons may make representations with respect to the proposed Regulations within 30 days after the date of publication of this notice. All such representations must cite the Canada Gazette, Part I, and the date of publication of this notice, and be addressed to Antonio Mattioli, Radiation Protection Bureau, Safe Environments Programme, Healthy Environments and Consumer Safety Branch, Department of Health, Address Locator 6302C1, 775 Brookfield Road, Ottawa, Ontario K1A 1C1 (tel: (613) 954-6697; fax: (613) 941-3497; e-mail: antonio_mattioli@hc-sc.gc.ca). Persons making representations should identify any of those representations the disclosure of which should be refused under the Access to Information Act, in particular under sections 19 and 20 of that Act, and should indicate the reasons why and the period during which the representations should not be disclosed. They should also identify any representations for which there is consent to disclosure for the purposes of that Act. Ottawa, February 3, 2004
EILEEN BOYD
REGULATIONS REPEALING THE RADIATION DOSIMETRY SERVICES FEES REGULATIONS REPEAL 1. The Radiation Dosimetry Services Fees Regulations (see footnote 1) are repealed. COMING INTO FORCE 2. These Regulations come into force on July 1, 2004. [9-1-o] S.C. 1991, c. 24, s. 6 SOR/90-109 |
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