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Section II – Analysis of Program Activities by Strategic Outcome

Strategic Outcome #1 - Canada's grain is safe, reliable and marketable and Canadian grain producers are protected

As a regulatory agency, the Canadian Grain Commission is mandated to, in the interests of grain producers, establish and maintain standards of quality for Canadian grain and regulate grain handling in Canada to ensure a dependable commodity for domestic and export markets. The Canadian Grain Commission has one strategic outcome that reflects the daily delivery of Canadian Grain Commission program activities and the long-term benefit to Canadians stemming from the Canadian Grain Commission’s mandate and vision. To measure its success in delivering upon its strategic outcome, the Canadian Grain Commission has identified two performance indicators with associated targets.

Performance
Indicators
Targets Performance
Status5a
Number of instances where buyers are dissatisfied with Canadian Grain Commission standards, methods or procedures used to ensure a dependable commodity for domestic and export markets Zero instances Mostly Met
  • There were three instances where buyers of Canadian grain expressed dissatisfaction with Canadian Grain Commission standards, methods and/or procedures used to ensure a dependable commodity for domestic and export markets. To put this in context, the Canadian Grain Commission certified the quality of 8,257 cargoes representing 29.6 million tonnes of grain in 2010-11. Going forward:
    • The Canadian Grain Commission will work collaboratively with industry stakeholders to adjust methods and/or procedures, where appropriate, to ensure a dependable commodity for domestic and export markets and to maintain market access for Canadian producers.
    • Communication will be enhanced in crop years where growing conditions cause increased quality concerns to ensure producers, handlers and buyers are aware of grading impacts and availability of higher quality product.
Level of producer satisfaction with Canadian Grain Commission producer protection services Zero unresolved or unaddressed complaints Met All
  • The Canadian Grain Commission continued to offer key protection services to Canadian grain producers. These services contribute to producers' ability to receive fair payment for the quality and quantity of grain they produce and deliver. The Canadian Grain Commission met its target of zero unresolved or unaddressed complaints by responding to all known instances where Canadian grain producers were dissatisfied with Canadian Grain Commission producer protection services. Additional information on the programs and services that contributed to successfully meeting this target is included in the Producer Protection Program Activity section.

5a Performance "Status" Legend

  • Exceeded: More than 100 per cent of the expected level of performance (as evidenced by the indicator and target or planned activities and outputs) for the expected result identified in the corresponding RPP was achieved during the fiscal year.
  • Met All: 100 per cent of the expected level of performance (as evidenced by the indicator and target or planned activities and expected outputs) for the expected result identified in the corresponding RPP was achieved during the fiscal year.
  • Mostly Met: 80 to 99 per cent of the expected level of performance (as evidenced by the indicator and target or planned activities and expected outputs) for the expected result identified in the corresponding RPP was achieved during the fiscal year.
  • Somewhat Met: 60 to 79 per cent of the expected level of performance (as evidenced by the indicator and target or planned activities and expected outputs) for the expected result identified in the corresponding RPP was achieved during the fiscal year.
  • Not Met: Less than 60 per cent of the expected level of performance (as evidenced by the indicator and target or planned activities and expected outputs) for the expected result identified in the corresponding RPP was achieved during the fiscal year.

During 2010-11, the Western Standards Committee and the Eastern Standards Committee met several times to recommend specifications for grades of grain, and to select and recommend standard samples to the Canadian Grain Commission. Four sub-committees composed of marketers, grain handlers and producers continued to advise the Western Standards Committee on commodity-related concerns for wheat, barley and other cereal grains, oilseeds, and pulses. Broad representation on the Committees ensures that the views of all principals are considered, that any changes to the grading system are grounded in thorough research and investigation, implications for the handling system are understood, and that the grading system is responsive to the needs of producers, the Canadian industry, and domestic and overseas buyers. Committee membership and 2010-11 Western and Eastern Standards Committee recommendations related to the grading system are available at the following links: http://www.grainscanada.gc.ca/gscommittee-comiteng/wgsc-cngo-eng.htm, http://www.grainscanada.gc.ca/gscommittee-comiteng/egsc-cnge-eng.htm.

Liaising with AAF Portfolio partners and other federal government departments (e.g. Health Canada and DFAIT), the Canadian grain industry, and international agencies concerning grain safety matters and trade implications continues to be very important. In addition, Canadian Grain Commission scientists and technical experts continued to play an important market support role by liaising with buyers, marketers, industry and producers and providing technical advice and information on grain quality, grain safety, and end-uses. Liaison activities and client feedback are critical components to continuously improving Canada’s GAQS and Canadian Grain Commission programs and activities.

During 2010-11, the Canadian Grain Commission took part in nine international market support missions to investigate, train, or convey the quality of Canadian grain to customers. Additionally, 36 international delegations and 38 groups from Canada visited the Canadian Grain Commission to learn about the Canadian Grain Commission and Canada’s GQAS. Domestic and overseas buyers have stated that they are satisfied with the overall quality of Canadian grain and Canada’s GQAS. Canadian Grain Commission efforts towards modernizing the Canada Grain Act and the Canada Grain Regulations are ongoing with the goal of ensuring that Canadian Grain Commission legislation, programs and services continue to meet the evolving needs of Canadian producers and the grain industry and that the Canadian Grain Commission can effectively and successfully deliver upon its strategic outcome and program activities.

How the Canadian Grain Commission tracks and reports:

The following sections identify the expected results for each program activity and 2010-11 performance measured against targets as established in the Canadian Grain Commission's Performance Measurement Framework. The Canadian Grain Commission is committed to providing fair and reliable performance information. Performance data is collected and managed using different methods and procedures. The Canadian Grain Commission continuously evaluates progress against plans that are identified in the RPP through a quarterly monitoring and tracking tool. This tool also provides an opportunity to address challenges and capture ‘lessons learned’. The Canadian Grain Commission will continue efforts to refine the monitoring tool to facilitate improved evaluation of progress against plans.

Performance assessment and analysis:

Canadian Grain Commission performance assessment and analysis includes both quantitative and qualitative information to give context to the Canadian Grain Commission’s performance story. It is important to note that the majority of Canadian Grain Commission services and activities are mandated by the Canada Grain Act. In addition, provision of inspection and weighing services are largely dependent on Canadian export volumes which are in turn dependent on factors such as crop production, crop quality, price, production choices, and weather. Given this variability, a quantitative comparison of services provided between years and/or to other organizations is not a reliable indicator of performance. The performance analysis discussion identifies the key activities and major accomplishments that contributed to and/or impacted upon program activity performance. Independent verifiable performance information is included where available.

Program Activity 1: Quality Assurance Program

Program Activity Description 

Canada's grain quality assurance system (GQAS) assures consistent and reliable grain quality that meets the needs of international and domestic markets. Daily provision of grain inspection and grading services as mandated by the Canada Grain Act as well as strong scientific and technical support programs and services are integral components to the overall delivery of an effective GQAS. Canada's GQAS is continually adapted to the end-use needs of domestic and international buyers of Canadian grain, and to the ongoing structural changes within the grain industry to maintain Canada's reputation as a consistent supplier of quality grain. An effective GQAS is a key factor in permitting Canadian exporters to market successfully in competitive international grain markets and is essential for producers in order to realize maximum value from their grain.


2010-11 Financial Resources ($ thousands)
Planned Spending6a Total Authorities6b Actual Spending6c
21,176 44,918 39,095

6a Planned spending appears low because it does not include ad-hoc appropriation of $26.0 million as well as access to $11.4 million of operating surplus. These amounts were not approved at the time of the Canadian Grain Commission's ARLU and RPP reports.

Planned spending differs from Main Estimates 2010-11 with respect to non-appropriation funding because planned spending includes respendable revenue of $37.1 million based on projected grain volumes of 50.0 million tonnes while Main Estimates reflects the authority limit of respendable revenue for 2010-11 of $42.5 million.

6b The difference between planned spending and total authorities is that planned spending reflects only the Canadian Grain Commission's approved authorities while total authorities include additional funding approved subsequent to the publication of the RPP.

6c The difference between total authorities and actual spending is because:

  • The 2010-11 expenditure framework was based on the Canadian Grain Commission planning to respend revenue of $37.1 million which is $5.4 million less than the authority limit of $42.5 million, and
  • In keeping with the spirit of cost containment and the Canadian Grain Commission's reliance on ad-hoc funding, the Canadian Grain Commission manages and monitors operating expenditures conservatively and capital expenditures were limited to 'mission critical' acquisitions. There were no significant program changes during 2010-11.

2010-11 Human Resources (FTEs)
Planned7a Actual Difference7a
117 359 242

7a 2010-11 planned human resources (FTEs) as reported in the RPP were 117 based on approved authorities at that point in time. However, given all additional authorities secured by the Canadian Grain Commission, the full planned FTE complement for this program is 382. This represents an actual variance of -23 (the difference between 382 and the 2010-11 actual FTEs of 359).


Expected
Results
Performance
Indicators
Targets Performance
Status
Consistent and reliable grain quality and grain safety assurance to meet the needs of domestic and international markets Number of justified cargo complaints due to a breakdown in Canadian Grain Commission quality and/or safety assurance Zero justifiable cargo complaints Met All
  • Canadian Grain Commission staff certified the quality of 8,257 cargoes representing 29,566,354 tonnes of Canadian export grain.
  • The Canadian Grain Commission received complaints regarding 20 of those cargoes. Upon investigation, it was determined there were zero justified cargo complaints.


Key Program Risk:  Misalignment or inability to adapt

The Quality Assurance Program must continue to align with and be able to respond to the changing requirements of domestic and international grain markets to ensure consistent and reliable grain quality and grain safety assurance.

Key Risk Mitigation Activities:
  • Industry Services Quality Management System internal and external audits were completed. Identified non-conformances were actioned (Refer to Lessons Learned).
  • Industry Services Management meetings focused on program development and delivery to meet grain industry needs based on recommendations and feedback received from the Western Standards Committee, the Eastern Standards Committee, producers, grain handlers, and domestic and overseas buyers and processors.
  • Recruitment and retention activities to meet current and future human resource needs continued.

Additional information on the programs, services, and initiatives that contributed to the Quality Assurance Program is available at: http://www.grainscanada.gc.ca/quality-qualite/iaqm-mrsq-eng.htm

Performance Summary and Analysis of Program Activity

During 2010-11, the Canadian Grain Commission met the expected result and target associated with the Quality Assurance Program. Daily provision of grain inspection and grading services as mandated by the Canada Grain Act, as well as scientific and technical support programs and testing services, continue to be integral components to this program activity. During 2010-11, the Canadian Grain Commission provided the following inspection and testing services as per ISO 9001:2008 Standards in support of the Quality Assurance Program:

  • inspected 290,471 railcars upon receipt at licensed terminal and transfer elevators (compared to 294,985 in 2009-10),
  • inspected 29,566,354 tonnes of Canadian grain for export from licensed terminal and transfer elevators (compared to 29,555,831 tonnes in 2009-10), and
  • certified 2,601 samples submitted for grading by producers (compared to 1,531 in 2009-10) and 14,841 samples submitted by grain companies (compared to 14,642 in 2009-10).

There were 4,844 grade changes on official re-inspection representing a Canadian Grain Commission inspection accuracy rate of 98.3 percent. This compares to an accuracy rate of 98.8 percent in 2009-10 and 98.7 percent in 2008-09.

The Canadian Grain Commission certified the quality of 8,257 cargoes in fiscal year 2010-11 and investigated complaints from buyers regarding 20 of those cargoes. Upon thorough investigation of the loading process, including analysis of cargo samples and vessel loading documentation, the Canadian Grain Commission’s Chief Grain Inspector concluded that none of the complaints were substantiated. This compares to one justifiable cargo complaint in fiscal year 2009-10 and zero justifiable cargo complaints in fiscal year 2008-09 when the Canadian Grain Commission certified the quality of 7,911 and 5,267 cargoes respectively.

Wet weather in western Canada during the spring and summer of 2010 affected the crop through all stages, from seeding to harvest. These wet conditions impacted the quality of the 2010 harvest with the most common grading factors being frost and mildew in wheat, bleaching and staining in lentils, and mould and weather staining in beans. In response to this year’s grading issues, the Western Standards Committee recommended new standard samples, standard prints and guide samples for wheat, peas, pea beans and lentils at its meeting in November 2010. These tools are used by grain company inspectors and Canadian Grain Commission inspectors when grading grain. http://www.grainscanada.gc.ca/media-medias/press-presse/2010/2010-12-20-eng.htm

The Canadian Grain Commission continued monitoring programs for the presence and source of non-registered and de-registered varieties to support the Canadian Grain Commission certification processes and maintain end-use processing quality. In addition, the Canadian Grain Commission continued to provide grain safety assurances on pesticides, trace elements, mycotoxins, fungi, and moulds to meet buyer and consumer demands and ensure Canadian grain is meeting international grain safety and sanitation tolerances. Responding to increasing demands for grain safety assurances from buyers and national food inspection authorities was a Canadian Grain Commission priority during 2010-11. While significant progress was made towards meeting the goals of this priority, grain safety assurance will remain a priority going forward with the focus on mycotoxins. Further information on current Canadian Grain Commission strategies for grain safety assurance is available at: http://www.grainscanada.gc.ca/quality-qualite/gsa-asg/safety-salubrite-eng.htm.

The Canadian Grain Commission’s Quality Assurance Program must continually adapt and respond to challenges to remain relevant, meet the needs of domestic and international markets, and ensure that Canada’s reputation for consistent grain quality and grain safety is maintained. This is critical to the Canadian Grain Commission’s success in delivering upon its strategic outcome. As such, the Canadian Grain Commission continued to assess the use of objective tests and continued to evaluate new technologies to measure end-use quality and safety with the goal of increasing efficiency, reducing costs, and enhancing testing capabilities. Results achieved under the Canadian Grain Commission’s three operational priorities identified in Section I are significant in the development of new methods and processes aimed at maintaining and strengthening the Quality Assurance Program and Canada’s GQAS to ensure a safe, dependable commodity going forward.
Lessons Learned

All Canadian Grain Commission inspection services are delivered as per ISO 9001:2008 Standards. During 2010-11, there were a total of 61 inspection related Improvement Requests (IRs). In addition, there were six inspection/weighing related IRs for a total of 67. Nine of the IRs were a result of non-conformances identified during internal and external audits. Non-conformances occur when Quality Management System (QMS) procedures or work instructions are not followed. IRs are also created when there are inconsistencies in documentation, if there are changes to Canadian Grain Commission inspection programs, or changes required to work processes. The Canadian Grain Commission has reviewed the summary reports that were completed during the audits. The IRs have been submitted to the procedure owner with an appropriate corrective action identified and a timeframe attached to ensure completion. IRs allow the Canadian Grain Commission to adjust service procedures as necessary and identify or adjust training requirements to maintain and/or enhance the effective and consistent delivery of inspection services and programs.

Program Activity 2: Quantity Assurance Program

Program Activity Description

The Canadian grain quantity assurance system assures the weight of grain loaded into or discharged from conveyances and in storage in the licensed terminal and transfer elevator system to meet the requirements of the grain industry from producers to customers. Daily provision of grain weighing services as mandated by the Canada Grain Act forms a major part of the Quantity Assurance System. To maintain relevancy and to address constantly changing industry demands, ongoing technical support is provided in support of the grain quantity assurance system.


2010-11 Financial Resources ($ thousands)
Planned Spending8a Total Authorities8b Actual Spending8c
8,479 15,245 12,557

8a Planned spending appears low because it does not include ad-hoc appropriation of $26.0 million as well as access to $11.4 million of operating surplus. These amounts were not approved at the time of the Canadian Grain Commission's ARLU and RPP reports.

Planned spending differs from Main Estimates 2010-11 with respect to non-appropriation funding because planned spending includes respendable revenue of $37.1 million based on projected grain volumes of 50.0 million tonnes while Main Estimates reflects the authority limit of respendable revenue for 2010-11 of $42.5 million.

8b The difference between planned spending and total authorities is that planned spending reflects only the Canadian Grain Commission's approved authorities while total authorities include additional funding approved subsequent to the publication of the RPP.

8c The difference between total authorities and actual spending is because:

  • The 2010-11 expenditure framework was based on the Canadian Grain Commission planning to respend revenue of $37.1 million which is $5.4 million less than the authority limit of $42.5 million, and
  • In keeping with the spirit of cost containment and the Canadian Grain Commission's reliance on ad-hoc funding, the Canadian Grain Commission manages and monitors operating expenditures conservatively and capital expenditures were limited to 'mission critical' acquisitions. There were no significant program changes during 2010-11.

2010-11 Human Resources (FTEs)
Planned9a Actual Difference9a
71 119 48

9a 2010-11 planned human resources (FTEs) as reported in the RPP were 71 based on approved authorities at that point in time. However, given all additional authorities secured by the Canadian Grain Commission, the full planned FTE complement for this program is 130. This represents an actual variance of -11 (the difference between 130 and the 2010-11 actual FTEs of 119).


Expected
Results
Performance
Indicators
Targets Performance
Status
Consistent and reliable quantity assurance of Canadian grain shipments Number of justified cargo complaints due to a breakdown in Canadian Grain Commission assessment of quantity Zero justifiable cargo complaints Mostly Met

There was one justified cargo complaint due to a breakdown in Canadian Grain Commission assessment of quantity during 2010-11. Program adjustments were made to address the complaint.


Key Program Risk: Misalignment or inability to adapt

The Quantity Assurance Program must align with and be able to respond to the changing requirements of the grain industry to effectively ensure consistent and reliable quantity assurance of Canadian grain shipments.

Key Risk Mitigation Activities:
  • Industry Services QMS (ISO) internal and external audits were completed. Identified non-conformances were actioned (see Lessons Learned below).
  • Industry Services Management meetings focused on program development and delivery to meet industry needs.
  • Recruitment and retention activities to meet current and future human resource needs continued.

Additional information on the programs and services that contribute to the Quantity Assurance Program is available at: http://www.grainscanada.gc.ca/quantity-quantite/iaqnm-mrsqn-eng.htm

Performance Summary and Analysis of Program Activity

During 2010-11, the Canadian Grain Commission continued to deliver all weighing services as per ISO 9001:2008 Standards to ensure consistent and reliable quantity assurance of Canadian grain shipments. For example, to meet the legislative mandate of the Canada Grain Act and the requirements of the grain industry from producers to customers, the Canadian Grain Commission:

  • officially weighed and certified 300,567 railcar unloads upon receipt at licensed terminal and transfer elevators (compared to 312,927 railcar unloads in 2009-10), and
  • monitored and certified 26,237,496 tonnes of grain prior to export from licensed terminal and transfer elevators (compared to 29,555,831 tonnes in 2009-10).

The Canadian Grain Commission logged and investigated five weight-related export cargo complaints at the customer’s request. Upon thorough review and analysis of the information documented at the time of loading, the Canadian Grain Commission’s Chief of Weighing concluded that the original statement of quantity for four of the shipments was correct while one complaint was justified. Consequently, the Canadian Grain Commission was not successful in meeting the target of zero justified cargo complaints due to a breakdown in Canadian Grain Commission assessment of quantity. This compares to zero justifiable cargo complaints during 2008-09 and 2009-10.

The Canadian Grain Commission continued efforts to provide ongoing technical support and advice to the Canadian grain industry. These activities contributed to the Canadian Grain Commission’s strategic outcome of ensuring that Canada’s grain shipments are reliable and that Canadian grain producers are protected. For example:

  • Canadian Grain Commission Weighing Systems Inspectors conducted 506 weighing system device inspections to verify the accuracy and reliability of licensed terminal and transfer elevator weighing equipment. In 176 instances (35 percent), the device under inspection required an adjustment or servicing. Of these 176 inspections, 67 (38 percent) were found to be operating with measurement errors of 0.10 percent or greater.
  • Canadian Grain Commission staff conducted ten official weigh-overs of all stocks in store at licensed terminal and transfer elevators to verify the overage or shortage of grain, grain products, or screenings in an elevator pursuant to the tolerances stipulated in the Canada Grain Regulations.

Although the Canadian Grain Commission does not provide binding arbitration for weight shortages, the Canadian Grain Commission’s Dispute Resolution Settlement (DSR) neutral third-party railcar investigation process provides key information to support shippers’ entitlement to adjustment for excessive grain shortages at unload. During 2010-11:

  • the Canadian Grain Commission conducted 434 weight-related investigations on railcars,
  • 893 railcars required their weights officially apportioned due to the mixing of grain from two or more railcars in a common grain reception area as the cars were unloaded,
  • 28 cars required their origin weight to be verified and assigned as the official unload weight due to incidents around un-recovered spills, and
  • 4,388 exception reports were completed for railcars unloaded March 31, 2010 to March 31, 2011. 608 of those reports were cars that arrived at unloading facilities with low soundings and 103 reports were for cars arriving with empty compartments.
While client claim success rates are confidential, clients maintain that the information supplied by the Canadian Grain Commission’s DRS is a very significant part of their claim and is the most reliable information for processing a successful claim. During 2010-11, there were zero instances where disputes with respect to weight were not addressed and feedback not provided. http://www.grainscanada.gc.ca/services-services/receival-reception/drs-rd-eng.htm
Lessons Learned

Canadian Grain Commission weighing policies and procedures are monitored and evaluated on an ongoing basis through a series of reporting policies and national discussion and review forums. This allows the Canadian Grain Commission to adjust service procedures as necessary and identify or adjust training requirements to maintain and/or enhance the effective and consistent delivery of weighing services and programs. During 2010-11, there were four weighing/registration related non-conformances identified through internal and external audits. Non-conformances occur when Quality Management System (QMS) procedures or work instructions are not followed. The Canadian Grain Commission has reviewed the summary reports that were completed during the audits. In order to take appropriate actions, an Improvement Request (IR) form was submitted to the procedure owner, and an appropriate corrective action was identified. A timeframe was attached to ensure completion. IRs are also created when there are inconsistencies in documentation, if there are changes to Canadian Grain Commission weighing programs, or changes required to work processes. This resulted in an additional ten IR forms being submitted during 2010-11.

Program Activity 3: Grain Quality Research Program

Program Activity Description

The Canada Grain Act requires the Canadian Grain Commission to undertake, sponsor and promote research related to grains. The Canadian Grain Commission conducts research in support of the GQAS to address emerging issues and permit the effective marketing of Canadian grain in the interests of producers and the Canadian grain industry. The Canadian Grain Commission's Grain Research Laboratory researches methods to measure grain quality, new quality factors, and new grain standards. Grain quality research supports the continual improvement of the GQAS.


2010-11 Financial Resources ($ thousands)
Planned Spending10a Total Authorities10b Actual Spending10c
3,564 9,083 10,075

10a Planned spending appears low because it does not include ad-hoc appropriation of $26.0 million as well as access to $11.4 million of operating surplus. These amounts were not approved at the time of the Canadian Grain Commission's ARLU and RPP reports.

Planned spending differs from Main Estimates 2010-11 with respect to non-appropriation funding because planned spending includes respendable revenue of $37.1 million based on projected grain volumes of 50.0 million tonnes while Main Estimates reflects the authority limit of respendable revenue for 2010-11 of $42.5 million.

10b The difference between planned spending and total authorities is that planned spending reflects only the Canadian Grain Commission's approved authorities while total authorities include additional funding approved subsequent to the publication of the RPP.

10c The difference between total authorities and actual spending is because:

  • The 2010-11 expenditure framework was based on the Canadian Grain Commission planning to respend revenue of $37.1 million which is $5.4 million less than the authority limit of $42.5 million, and
  • In keeping with the spirit of cost containment and the Canadian Grain Commission's reliance on ad-hoc funding, the Canadian Grain Commission manages and monitors operating expenditures conservatively and capital expenditures were limited to 'mission critical' acquisitions. There were no significant program changes during 2010-11.

2010-11 Human Resources (FTEs)
Planned11a Actual Difference11a
30 71 40

11a 2010-11 planned human resources (FTEs) as reported in the RPP were 30 based on approved authorities at that point in time. However, given all additional authorities secured by the Canadian Grain Commission, the full planned FTE complement for this program is 79. This represents an actual variance of -8 (the difference between 79 and the 2010-11 actual FTEs of 71).


Expected
Results
Performance
Indicators
Targets Performance
Status
Research and development on grain quality and grain safety to support and improve Canada's GQAS Assessment of grain quality and grain safety research undertaken, sponsored, and/or promoted by the Canadian Grain Commission "Excellent" on a scale of excellent, good, fair or poor Met All

Grain quality and grain safety research undertaken, sponsored and/or promoted by the Canadian Grain Commission was assessed as "excellent" during 2010-11. Several project milestones and outcomes were delivered on time and on budget (details are provided below).

Key Program Risk: Misalignment or inability to adapt

The Canadian Grain Commission's science and technology capacity must keep pace with the needs of domestic and international markets in order to ensure Canada's grain is safe, reliable and marketable.

Key Risk Mitigation Activities:
  • Continued to identify research priorities to strengthen the existing GQAS based on feedback received by Canadian Grain Commission personnel from overseas and/or domestic buyers, processors, producers, grain handlers, and the Western and Eastern Standards Committees.
  • To remain abreast of new developments, GRL personnel continued liaison activities with Canadian and international scientific, academic, analytical, and grain industry organizations.
  • Continued people planning initiatives to ensure that the Canadian Grain Commission is able to attract, develop and retain sufficiently qualified human resources in the GRL and continued succession planning strategies.

Additional information on the programs and services that contribute to the Quantity Assurance Program is available at: http://www.grainscanada.gc.ca/research-recherche/iarm-mrsr-eng.htm

Performance Summary and Analysis of Program Activity

During 2010-11, the Canadian Grain Commission’s Grain Research Laboratory (GRL) successfully undertook, sponsored and promoted research related to grains as mandated by the Canada Grain Act. The GRL completed several research projects within cost and timelines and successfully met the milestones of numerous other ongoing research projects. While there were some project variances, these are considered normal within a research environment. Close cross-divisional collaboration between the GRL’s Crops Section and the Technologies Section along with the Canadian Grain Commission’s Industry Services Division is critical to successfully achieve results associated with the grain quality research program and to successful delivery of the Canadian Grain Commission’s strategic outcome. Improved collaboration and coordination of research efforts both internally and with external research partners ensured that the GRL was able to adapt research priorities to emerging challenges and use resources effectively. This has been particularly important in the grain safety and plant biotechnology research areas. In addition, the GRL continued to successfully conduct research as recommended by the Western Standards Committee and the Eastern Standards Committee in support of grade specifications and the grading system and provided information to facilitate Committee recommendations. As such, the 2010-11 performance results for the grain quality research program activity were assessed as “excellent”.

The GRL’s Crops Section scientifically assessed the quality of the 2010 Canadian grain harvest, assessed how grading factors affect end-use qualities, researched new uses for Canadian grains, and assessed new and improved methods for evaluating and measuring end-use quality factors for all grains. In addition, new varieties were assessed for quality as part of the variety registration process. This research continues to be a significant factor in permitting effective marketing of Canadian grain in the interests of producers and the Canadian grain industry and continues to facilitate end-use diversification of Canadian grains. Research areas include analytical services, applied barley research, Asian end products and wheat enzymes, basic barley research, bread wheat research, durum wheat research, milling research, oilseeds monitoring, oilseeds research, and pulse research. The following are some of the Crops Section research highlights during 2010-11:

  • The GRL received and analyzed 9,393 producer samples to determine the year’s crop quality as part of the Harvest Sample Program. The Harvest Sample Program is voluntary and provides Canadian grain producers with an opportunity to receive a free, unofficial Canadian Grain Commission grade and quality results. The samples submitted during the Harvest Sample Program are used to determine the quality of harvest and provide buyers from all over the world with information on the quality of Canadian grain. Quality reports were published on Eastern and Western Canadian wheat, Western Canadian malting barley, Western Canadian canola, Western Canadian flaxseed, Western Canadian pea beans, Western Canadian chick peas, Western Canadian lentils, Western Canadian mustard, Western Canadian peas, and Canadian soybeans. http://www.grainscanada.gc.ca/quality-qualite/geuq-quf-eng.htm
  • Efforts are ongoing to evaluate how grain grading factors affect end-use qualities and provide a source of information to assist in determining if changes are needed to grading factors to reflect processing needs or to protect the quality reputation of Canadian grain. For example, the durum wheat research community found the traditional method for predicting the yellowness of final pasta products, a total semolina yellow pigment measurement, was not predicting pasta colour effectively. A protocol was developed based on the colour of a dough sheet of semolina and this was found to be much better at predicting pasta yellowness. The dough sheet method is now a routine test in the Canadian Grain Commission’s durum wheat quality assurance programs (harvest survey, cargo monitoring, and plant breeder line evaluation) and other research projects.
  • Research continued on emerging quality issues and new end-use quality traits to meet changing producer, industry, and customer demands and to facilitate the end-use diversification of Canadian grains. For example, higher seeding rates for malting barley have been found to reduce maturity times, lower grain protein, often improve yields, but reduce grain size. The malting industry demands plump barley because of increased beer potential therefore higher seeding rates have not been advised for malting barley. However, a collaborative project with AAFC found barley from higher seeding rates actually processed better resulting in higher quality malt. The results were transferred to producers at numerous winter meetings and higher seeding rates for malting barley are now becoming common across the prairies.
  • Efforts are ongoing to develop and refine measurement protocols to support and enhance standards associated with the Canadian grain grading system and determination of end use quality. For example, near-infrared reflectance spectroscopy (NIR) instruments were evaluated to measure chlorophyll content in samples of canola seed. Preliminary test results are positive and evaluation will continue with another year of testing. In addition, in close collaboration with the GRL’s Technology Section, methods for rapidly measuring falling number in samples of wheat were further assessed. Researchers are studying two technologies. The ELISA-based system is a diagnostic tool used in other industries. It can detect and quantify the key enzyme which impacts wheat quality when a kernel begins to sprout. A hyperspectral imaging system is also being assessed. This is an imaging tool that can see different materials that make up an object that are not visible to the human eye.
  • Quality evaluation of new breeders’ lines was carried out to determine the lines that meet the quality guidelines and needs of the class for wheat, barley, and canola. GRL personnel interpret quality data based on their intimate knowledge of changes in world processing technology and market needs to ensure that new varieties do not present a threat to Canada’s GQAS. This third party unbiased information is a key component of the CFIA registration process for new varieties. Approximately 180 wheat and 95 malt barley breeders’ lines were assessed and reported on a timely basis. In addition, the Canadian Grain Commission assessed approximately 2,500 canola breeders’ samples by NIR for oil, protein and glucosinolate content, and complete fatty acid composition by gas chromatography. GRL staff also recommended changes in quality targets to breeders, as appropriate, on the basis of discussions with grain processors and buyers in North America and overseas.

The GRL’s Technologies Section continued efforts to study and develop technologies and methods to assess the quality and safety of Canadian grains. Research efforts are aimed at developing new and improved methods for evaluating and measuring grain quality and grain safety to increase efficiency, reduce costs and enhance the testing capabilities of the Canadian Grain Commission and the Canadian grain industry. Research areas include grain biotechnology research, image analysis, microbiology, spectroscopy, trace elements, trace organic analysis, variety identification monitoring, and variety identification research. The following are some of the Technologies Section research highlights during 2010-11:

  • Continued efforts to develop a hyperspectral imaging method for detecting Fusarium damaged kernels in wheat and to evaluate instruments that can rapidly determine the levels of deoxynivalenol present in fusarium damaged kernels for potential use at grain elevators.
  • The Canadian Grain Commission’s image analysis researchers and inspection experts worked collaboratively to develop a canola/rapeseed colour guide that shows the shades of green that, if found in crushed canola or rapeseed, could be determined as distinctly green. This is a new grading tool for grain inspectors and is intended to increase consistency in the evaluation of distinctly green seeds.
  • The Canadian Grain Commission continued to evaluate hyperspectral imaging technology to assess mildew levels in wheat. Preliminary results have been encouraging.
  • Research efforts continued on wheat and barley DNA and protein fingerprinting. The aim is to develop tests for identifying and quantifying varieties of grains in shipments in order to develop the capacity for identifying multiple variety composition and enable segregation of variety specific shipments.
  • Conducted collaborative research with AAFC and the grain industry in mycotoxins (ochratoxin A) focusing on mycology studies and storage/sampling research to support Canadian Grain Commission grain safety assurance. In addition, collaborative research with the grain industry in rapid test technology for mycotoxin analyses was undertaken. The focus was on multi-toxin/simultaneous analytical technology.
  • Collaborative research with AAFC and Pulse Canada was initiated in spatial and temporal studies for heavy metals in soybeans. The project is aimed at identifying crop districts producing elevated levels of heavy metals (e.g. cadmium), provide background levels of other trace elements of issue in grain safety (e.g. boron), and identify/develop non-accumulating heavy metal varieties.
  • Research continued in pesticide residue analyses. This research focused on improving analytical throughput and improving method limits of detection. Research is required to meet the challenges of changing grain safety maximum limits in grain and the development of new sophisticated instrumental technology.
Lessons Learned

During 2010-11, significant progress was made towards readiness for an ISO/IEC 17025 accreditation pre-audit for certain methods in the GRL’s laboratory testing environment. Focus is on four key grain safety analytical methods which include determination of Ochratoxin, Trichothecenes, Cadmium, and GMO content in Canadian grain. ISO/IEC 17025 accreditation will give customers increased confidence in the GRL grain safety processes and testing methods that support Canada’s GQAS.

The GRL uses a range of tools to insure the consistency and reliability of results from its testing. Tools include proficiency programs, professional calibrations of equipment and daily running of check samples. During 2010-11, the GRL participated in 15 proficiency programs involving numerous tests. Test scores were consistently on a satisfactory basis but whenever a score tended towards non-compliance, corrective actions were taken immediately.

GRL staff will continue to attend scientific conferences and technical missions to facilitate assessment of current grain quality methods and technologies and the adequacy of Canada’s GQAS. Information gathering activities as well as client feedback will continue to be used to identify research priorities to build upon and strengthen the existing GQAS to ensure continued relevance. An ongoing challenge in the GRL is the resources required to respond to increased testing and monitoring requirements under the Quality Assurance Program. The increased demand has potential to limit resources available for fundamental and/or long term research. In addition to numerous knowledge transfer activities throughout the year (e.g. presentations at conferences, journal publications, authoring book chapters), the GRL continues to investigate the production of a report to highlight GRL research activities on an annual basis. This report would significantly augment the performance information provided in the DPR.

Program Activity 4: Producer Protection Program

Program Activity Description

The Canadian Grain Commission is mandated to serve producer interests by upholding the Canada Grain Act and as such has implemented a number of programs and safeguards to ensure the fair treatment of Canadian grain producers. These include the licensing and security program, allocation of producer cars for producers and producer groups that wish to ship their own grain, and producer liaison measures including a grain grade appeal system. In addition, the Canadian Grain Commission collects and updates grain quality data and grain handling information to facilitate producer sales and marketing decisions.


2010-11 Financial Resources ($ thousands)
Planned Spending12a Total Authorities12b Actual Spending12c
903 3,163 3,688

12a Planned spending appears low because it does not include ad-hoc appropriation of $26.0 million as well as access to $11.4 million of operating surplus. These amounts were not approved at the time of the Canadian Grain Commission's ARLU and RPP reports.

Planned spending differs from Main Estimates 2010-11 with respect to non-appropriation funding because planned spending includes respendable revenue of $37.1 million based on projected grain volumes of 50.0 million tonnes while Main Estimates reflects the authority limit of respendable revenue for 2010-11 of $42.5 million.

12b The difference between planned spending and total authorities is that planned spending reflects only the Canadian Grain Commission's approved authorities while total authorities include additional funding approved subsequent to the publication of the RPP.

12c The difference between total authorities and actual spending is because:

  • The 2010-11 expenditure framework was based on the Canadian Grain Commission planning to respend revenue of $37.1 million which is $5.4 million less than the authority limit of $42.5 million, and

  • In keeping with the spirit of cost containment and the Canadian Grain Commission’s reliance on ad-hoc funding, the Canadian Grain Commission manages and monitors operating expenditures conservatively and capital expenditures were limited to ‘mission critical’ acquisitions. There were no significant program changes during 2010-11.


2010-11 Human Resources (FTEs)
Planned13a Actual Difference13a
8 31 23

13a 2010-11 planned human resources (FTEs) as reported in the RPP were 8 based on approved authorities at that point in time. However, given all additional authorities secured by the Canadian Grain Commission, the full planned FTE complement for this program is 36. This represents an actual variance of -5 (the difference between 36 and the 2010-11 actual FTEs of 31).

Expected
Results
Performance
Indicators
Targets Performance
Status
Producer satisfaction with the grain handling system Canadian Grain Commission response to producer complaints Zero unresolved or unaddressed complaints Met All

There were zero unaddressed complaints with respect to the producer protection programs administered by the Canadian Grain Commission.

Key Program Risk: Misalignment or inability to adapt

The producer protection framework must align with and be able to adapt to the evolving needs of producers and the grain industry to ensure that producers are compensated fairly for the quality and quantity of grain delivered and shipped.

2010-11 Key Risk Mitigation Activities:
  • Continued to investigate all producer concerns/complaints and consulted with and evaluated feedback from producers on the programs and services offered under this program activity.
  • Continued to monitor licensees using the licensing risk assessment framework to determine audit priorities. Developed a risk-based audit plan that is reviewed and updated quarterly and enhanced protocols to better manage 'at risk' licensees, enforce compliance, and protect producers.
  • Continued communication efforts to ensure producers are aware of their rights under the Canada Grain Act and to increase awareness of Canadian Grain Commission producer protection activities and services.

Additional information on the programs and services that contribute to the Quantity Assurance Program is available at: http://www.grainscanada.gc.ca/protection-protection/iappm-mrspp-eng.htm.

Performance Summary and Analysis of Program Activity

Producer support programs include mediating and/or arbitrating producer complaints concerning transactions with licensed grain companies, re-inspection of samples on producer request, and investigation of quality and dockage complaints. In addition, licensed elevators and grain dealers are required to post security with the Canadian Grain Commission to cover their liabilities to producers in the event of a company default. During 2010-11, the Canadian Grain Commission responded to numerous inquiries and complaints from producers, which focused primarily on contract disputes between producers and licensees, grading disputes, non-payment/slow payment to producers, inquiries related to shrinkage and tariff deductions, and complaints regarding proper issuance of documents. Grain producers submitted 100 samples to the Canadian Grain Commission for quality determination under “subject to inspector’s grade and dockage”. This service allows producers to ask the Canadian Grain Commission to determine grade and dockage and make a binding decision in the event there is a disagreement upon delivery at a primary elevator.

The Canadian Grain Commission responded to all producer complaints related to compensation received for the quality and/or quantity of grain delivered within the licensed grain handling system and all producer concerns regarding fair payment. The Canadian Grain Commission was successful in meeting the program activity target of zero unaddressed complaints with respect to the producer protection programs administered by the Canadian Grain Commission. During 2010-11, the Canadian Grain Commission formalized a complaints protocol that outlines the process to be followed when responding to producer complaints and investigating violations of the Canada Grain Act. The protocol will be implemented in early 2011-12 and will act as a guide to ensure the Canadian Grain Commission responds appropriately and consistently to all producer concerns. In addition, the Canadian Grain Commission clarified the enforcement protocol with respect to statistical reporting requirements and primary elevator weigh-over reporting obligations. This has resulted in significant improvement in the timeliness of licensee reporting and has reduced the number of outstanding primary elevator weigh-over reports.

Communication activities continued to play a key role in promoting the activities and services provided under the Producer Protection Program. As part of its communications activities, the Canadian Grain Commission designed new information products for grain producers including an Eastern Canadian producers’ brochure, a Western Canadian producers’ booklet, three information cards, tough and damp tables and posters, and a variety of promotional items and apparel for its trade exhibition program. Also, the Canadian Grain Commission trade exhibition program was expanded to include participation for the first time at Canada’s Outdoor Farm Show in Woodstock, Ontario and the Smoky River Agricultural Show in Falher, Alberta where issues such as the Canadian Grain Commission Licensing Program, variety declarations for wheat, services available to resolve grading disputes, the Harvest Sample program, Canadian Grain Commission user fee consultations, and many others were discussed with grain producers.

The Canadian Grain Commission remains committed to ensuring that adequate notice is given to producers when grain varieties are deregistered. Growing registered grain varieties helps maintain Canada’s reputation for marketing high quality grain and helps preserve access to key international markets for Canadian grain. http://www.grainscanada.gc.ca/media-medias/press-presse/2010/2010-07-19-2-eng.htm. In addition, the Canadian Grain Commission continued to collect and update grain quality data and grain handling information and make it available to producers and other interested parties to facilitate producer sales and marketing decisions. http://www.grainscanada.gc.ca/statistics-statistiques/sim-rsm-eng.htm

Prior to fiscal year 2010-11, the Canadian Grain Commission consulted extensively with licensees, the grain handling industry, producer organizations, and producers on changes related to the calculation of moisture shrinkage, as prescribed by Canadian Grain Commission Order, and comprehensive shrinkage, as prescribed in the Canada Grain Regulations. Responses during the consultation process from producers and producer organizations were generally supportive of the proposals and responses from industry organizations were mixed. After consideration of all comments received, a decision was made to proceed with both proposed changes. Effective August 1, 2010 the Canadian Grain Commission adjusted the formula for calculating moisture shrinkage by eliminating the 1.1 percent moisture rebound factor for grain artificially dried at licensed primary elevators. Effective March 19, 2011, the Canada Grain Regulations were amended to fix the maximum shrinkage allowance at zero for all Canadian Grain Commission licensed elevators. This amendment ensures that the maximum shrinkage allowance is the same regardless of the type of elevator to which the grain is delivered. This improves transparency to producers and improves the consistency of the Canada Grain Regulations.

As of March 31, 2011 the Canadian Grain Commission had issued licences for 340 primary elevators, 47 process elevators, 15 terminal elevators, 13 transfer elevators, and 85 grain dealers. The Canadian Grain Commission continues to investigate known unlicensed companies to determine if they require licensing under the Canada Grain Act. In cases where the Canadian Grain Commission has determined a licence is required, the licensing process has been initiated. During the previous fiscal year (2009-10), the Canadian Grain Commission initiated the process of reviewing the classification of each licensee, to ensure consistent application of the Canada Grain Act and the Canada Grain Regulations so that producers understand their rights and protections, licensees understand their responsibilities, and similar companies experience similar regulatory requirements. A Notice of Intent was sent to all licensees and the Canadian Grain Commission has since reviewed all licensees to determine proper licence classification. Licence reclassification, where required, began on August 1, 2010 and is being handled on a case-by-case basis through regular program administration and the licence renewals process. As a result of this initiative, all licensees, with the exception of eight, are classified correctly. It is anticipated that the remaining eight will be properly classified by August 1, 2011.

During 2010-11, 59 licensees were audited by the Canadian Grain Commission to ensure appropriate security coverage. Financial statements from all licensees were reviewed. The Canadian Grain Commission continued to use and refine the risk assessment process to regularly review and assign a financial risk rating and an overall risk rating (high, medium, low) for all licensees in order to determine audit priorities and other courses of action. The risk-based Audit Plan continued to be updated quarterly to ensure that high risk audits are focused on and to facilitate planning. During 2010-11, Canadian Grain Commission staff responded to all known instances of licensing non-compliance and there were zero licensees that failed to meet producer payment obligations.

The Canadian Grain Commission has sole responsibility for the allocation of producer cars for both Canadian Wheat Board (CWB) and non-CWB grains. During 2010-11, the Canadian Grain Commission continued to work closely and cooperatively with the CWB, grain companies, and the railways in an effort to ensure that producer car orders are filled in a timely manner. The Canadian Grain Commission received and processed 13,165 applications from producers for producer cars and responded to all complaints with respect to administration of the allocation of producer cars. Efforts continued to re-engineer the producer car software application and producer car database to assist with data management and reduce the reliance on printed reports. It is anticipated this will be implemented effective August 1, 2011.
Lessons Learned

The Canadian Grain Commission continually strives to improve its programs and activities aimed at facilitating fair treatment of producers within the licensed grain handling system. During the fall of 2010, the Canadian Grain Commission contracted with Ipsos Reid to conduct a survey of Canadian grain producers to gain a better understanding of producer perceptions and impressions of the Canadian Grain Commission, satisfaction levels with the Canadian Grain Commission and its activities and services, and perceptions and impressions of cost-recovery for Canadian Grain Commission services and user fee adjustments. Preliminary analyses of survey results suggest that Canadian grain producers are aware of the Canadian Grain Commission, have a positive overall impression of the organization, and consider it to be useful to producers. Going forward, the Canadian Grain Commission plans to further evaluate survey results to determine ways to better support producers. The Canadian Grain Commission will continue to work closely with officials from Agriculture and Agri-Food and other departments and agencies, to advise the Minister with respect to amendments to the Canada Grain Act and Canada Grain Regulations to ensure the Canadian Grain Commission’s legislation, programs, and services continue to meet the evolving needs of producers and the grain industry.

Program Activity 5 : Internal Services

Program Activity Description

Internal Services are groups of related activities and resources that are administered to support the needs of programs and other corporate obligations of an organization. These groups are: Management and Oversight Services; Communications Services; Legal Services; Human Resources Management Services; Financial Management Services; Information Management Services; Information Technology Services; Real Property Services; Materiel Services; Acquisition Services; and Travel and Other Administrative Services.

2010-11 Financial Resources ($ thousands)
Planned Spending14a Total Authorities14b Actual Spending14c
8,455 13,486 13,156

14a Planned spending appears low because it does not include ad-hoc appropriation of $26.0 million as well as access to $11.4 million of operating surplus. These amounts were not approved at the time of the Canadian Grain Commission's ARLU and RPP reports.

Planned spending differs from Main Estimates 2010-11 with respect to non-appropriation funding because planned spending includes respendable revenue of $37.1 million based on projected grain volumes of 50.0 million tonnes while Main Estimates reflects the authority limit of respendable revenue for 2010-11 of $42.5 million.

14b The difference between planned spending and total authorities is that planned spending reflects only the Canadian Grain Commission's approved authorities while total authorities include additional funding approved subsequent to the publication of the RPP.

14c The difference between total authorities and actual spending includes:

  • The 2010-11 expenditure framework was based on the Canadian Grain Commission planning to respend revenue of $37.1 million which is $5.4 million less than the authority limit of $42.5 million, and
  • In keeping with the spirit of cost containment and the Canadian Grain Commission's reliance on ad-hoc funding, the Canadian Grain Commission manages and monitors operating expenditures conservatively and capital expenditures were limited to 'mission critical' acquisitions. There were no significant program changes during 2010-11.
2010-11 Human Resources (FTEs)
Planned15a Actual Difference15a
71 91 20

15a 2010-11 planned human resources (FTEs) as reported in the RPP were 71 based on approved authorities at that point in time. However, given all additional authorities secured by the Canadian Grain Commission, the full planned FTE complement for this program is 93. This represents an actual variance of -2 (the difference between 93 and the 2010-11 actual FTEs of 91).

Performance Summary and Analysis of Program Activity

Internal Services include only those activities and resources that apply across an organization and not those provided specifically to a program. The Canadian Grain Commission does not have formal expected results, performance indicators and targets for this program activity. However, because internal services are enabling activities, success can be measured by the Canadian Grain Commission’s ability to meet the expected results of its strategic outcome and other program activities. Performance can also be measured by tracking activities and results against the goals of various government-wide initiatives.

During 2010-11, the Canadian Grain Commission focused attention and resources on:  effective people management, developing a stable and sustainable funding mechanism, participating in the Management Accountability Framework Round VIII Assessment, further implementing the Internal Audit and Evaluation functions, security planning, and developing and implementing effective communication tools. Results for these initiatives are provided in Section I under Management Priorities 1 and 2.

The Canadian Grain Commission’s Finance Division supports Canadians through the provision of Financial Management Services to facilitate the delivery of the Canadian Grain Commission’s strategic outcome and to support Government of Canada initiatives to strengthen accountability and transparency. During 2010-11, the Canadian Grain Commission prepared departmental future oriented financial statements in support of the RPP to assist Parliamentarians in their understanding and consideration of Canadian Grain Commission authorities. Significant progress was made towards implementation of Treasury Board's Policy on Internal Control. The objective of the policy is to adequately manage risks relating to the stewardship of public resources through effective internal controls, including internal controls over financial reporting. The Canadian Grain Commission established a steering committee with representation from Finance, Information Technology and Internal Audit and an action plan was developed that covers the next three years. In addition, entity level controls were documented and assessed for their design effectiveness. Efforts towards full compliance with the Policy will continue in 2011-12.

A skilled and motivated workforce is critical to the Canadian Grain Commission in delivering its services to Canadians. During 2010, the Canadian Human Rights Commission (CHRC) completed an audit of the Canadian Grain Commission. This was followed by an Employment Systems Review, an internal Employment Equity and Diversity survey, and a national Self-Identification campaign. The CHRC audit report indicates the Canadian Grain Commission has made improvements and achieved a level of compliance in many of the requirements of the Employment Equity Act. Areas where improvement can still be made are detailed in the CHRC report. An analysis has identified three key areas requiring attention. As a result, the Canadian Grain Commission will:

  • continue to work towards increasing its representation of women and visible minorities, as well as maintaining the level of representation of Aboriginal persons and persons with disabilities, in order to have a workforce representative of the Canadian population,
  • continue to promote understanding and practices that support Employment Equity and Diversity and a Respectful Workplace with all managers, supervisors and employees, and
  • strengthen and support our national and regional Employment Equity and Diversity Committees.
A focus on these areas will help ensure that all current and prospective employees have equitable opportunities and can enjoy a fair, positive and respectful workplace free of discrimination and harassment.