Thank-you for the…

Thank-you for the opportunity to comment on this important regulation and creating an opportunity to reduce red tape and create efficiencies.

I have been a strong advocate of the concept of having all certificates issued in accordance with O. Reg. 128\04 held by an individual renew at the same time. This could be extended to include licenses issued in accordance with O. Reg. 129\04.

Having all certificates held by an individual renew at the same time has many advantages including, but not limited to:

a) Eliminating the confusion currently experienced by the Operator and the Operator's employer regarding which certificate renewal the education and training requirements must be submitted with.
b) Creating efficiencies for all Operators and Operating Authorities as they only need to pull and become familiar with the details of the certificate holder’s file once every 3 years to make application for certificate renewal instead of each time a certificate nears expiry.
c) Creating efficiencies in issuing payment for renewal fees as it needs to be done only once every three years rather than each time a certificate nears expiry.
d) Creating efficiencies for OWWCO staff processing the applications as they will need to open and become familiar with the file of each Operator only once every three years rather than each time a certificate nears expiry.
e) Creating efficiencies in receiving and processing payment for renewal fees as it needs to be done only once every three years rather than each time a certificate nears expiry.

All the above leads to: reduced red tape; elimination of confusion; reduced burden on staff resources (for many Operators it will cut the total workload at least in half and much more for those holding more than 2 certificates); and reduced costs.

The message from the MECP regarding this concept has been consistent in that they will only address the matter if the regulation is opened for some other reason. The regulation is now opened to address qualified staffing during an emergency. This provides opportunity to move the concept forward into implementation.

We know that it is possible to do this as there was a period of time when the Ministry provided instruction on how to align the renewal dates. Unfortunately this process was dissolved as it was deemed by the Ministry that the legislation did not allow for this.

I am hopeful that the regulation will be revised to reduce the red tape and create the efficiencies that are available.