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AEFA - Standing Committee

Foreign Affairs and International Trade

 

Proceedings of the Standing Senate Committee on 
Foreign Affairs and International Trade

Issue No. 24 - Evidence - Meeting of May 11, 2017


OTTAWA, Thursday, May 11, 2017

The Standing Senate Committee on Foreign Affairs and International Trade met this day at 10:32 a.m. to discuss the subject matter of those elements contained in Division 1 of Part 4 of Bill C-44, An Act to implement certain provisions of the budget tabled in Parliament on March 22, 2017 and other measures.

Senator A. Raynell Andreychuk (Chair) in the chair.

[English]

The Chair: Honourable senators, I call this meeting of the Standing Senate Committee on Foreign Affairs and International Trade to order.

We are meeting today to begin our examination of the subject matter of those elements contained in Division 1 of Part 4 of Bill C-44, An Act to implement certain provisions of the budget tabled in Parliament on March 22, 2017 and other measures.

As we all know, this is a pre-study in our jargon on the bill, and we have been provided by the Senate Division 1 of Part 4 of Bill C-44.

Appearing before the committee on this new order of reference are, from the Department of Finance, Ms. Laura Bourns, Senior Economist, Trade Rules, International Trade and Finance Branch; and Patrick Halley, Director, International Trade Policy Division, International Trade and Finance Branch; and Jean Bédard, Q.C., Member and Acting Chairperson, Canadian International Trade Tribunal; and Mr. Nick Covelli, Executive Director.

Mr. Covelli is with us in the room. We had a technical problem. As I indicated to him, it wasn't a demotion, but it would be a delay if he were at the table. He is not going to be making the presentation; he is here to answer questions.

We welcome all of you to the committee. I will turn the floor over to you to make your presentation and then we'll turn to questions. Welcome to all our witnesses.

[Translation]

Patrick Halley, Director, International Trade Policy Division, International Trade and Finance Branch, Department of Finance Canada: Thank you, Madam Chair. It's a pleasure to be here with you. Here with us we have officials from the Department of Finance, the Canadian International Trade Tribunal, and Darryl Larson from the Canada Border Services Agency. They are here today to explain Division 1 of Part 4 of Bill C-44, which deals with amendments to the Special Import Measures Act.

The Special Import Measures Act is the main legislation governing the trade remedy system in Canada, under which duties can be applied to imports that are subsidized or dumped and that cause injury to Canadian producers. The Minister of Finance has the legislative and political authority he needs under the trade remedy system and the Special Import Measures Act. The trade remedy system is administered jointly by the Canada Border Services Agency and the Canadian International Trade Tribunal.

[English]

There are four key legislative amendments being proposed in Part 4, Division 1. The first change relates to the implementation of a World Trade Organization dispute settlement decision that found that Canada was not fully consistent with its international trade obligations.

With these changes, Canada's trade remedy system will allow for the termination of a trade remedy investigation against an individual exporter that has been found to have an insignificant margin of dumping or amount of subsidy.

The remaining three changes relate to proposals on which public consultations were conducted at around this time last year. There are two new proceedings that are going to be created related to the enforcement of trade remedy measures.

First, and these are primarily in clauses 87 and 89, there are new scope proceedings that will provide for binding and appealable rulings as to whether goods are subject to duty when imported into Canada. These proceedings enhance transparency and predictability related to trade remedy enforcement.

The second set of proceedings is primarily in clauses 84 and 89. There are new anti-circumvention investigations that will provide for the extension of duties to goods from exporters who are modifying their trade patterns specifically to avoid duties in Canada. So this will provide the Canada Border Services Agency with enhanced tools to address circumvention and ensure the effective enforcement of trade remedies in Canada.

Third, the CBSA will also be given new powers to respond to situations where market distortions in the country of export make prices unreliable for the purposes of calculating dumping margins during investigations in Canada, for example, if there are government controls over prices.

This will ensure that trade remedy duties accurately reflect the market realities in the country under investigation when these investigations are ongoing.

Budget 2017 also proposed something that is not in the bill, but I would like to mention it in the budget. There was a proposal that unions be provided the right to participate in trade remedy investigations. So this change is being made in parallel to regulatory amendments; therefore, it is not part of the bill. I wanted to flag that, as it has been mentioned in the budget.

Overall, these changes will strengthen Canada's response to unfair trade, better align Canada with our major trading partners, and they are consistent with our international trade obligations. They provide important new tools for trade remedy investigators while maintaining the trade remedy system's balance of interest between domestic producers, downstream users and consumers.

[Translation]

That concludes my opening remarks. I think Mr. Bédard also has some remarks.

Jean Bédard, Q.C., Member and Acting Chairperson, Canadian International Trade Tribunal: Honourable senators, I would first like to thank you for giving the Canadian International Trade Tribunal the opportunity to appear before the committee to discuss the proposed amendments to the Special Import Measures Act.

[English]

I would like to begin by describing the role of the CITT with respect to the Special Import Measures Act.

As already mentioned by Mr. Halley, the act is jointly administered by the Canada Border Services Agency, the CBSA, and the CITT. In the course of that joint administration, the CBSA is responsible for receiving and investigating complaints of dumping and subsidizing of imports.

The tribunal's role is to conduct a quasi-judicial inquiry as to whether the dumping or subsidization has caused or threatened to cause material injury to the domestic industry. The CBSA subsequently enforces any resulting anti- dumping or countervailing duties.

[Translation]

The Department of Finance consulted the Canadian International Trade Tribunal in the development of the proposed amendments to the Special Import Measures Act. Being a quasi-judicial body, the tribunal did not participate in the policy-making aspects of the proposed amendments. Our comments were confined to the potential impact on the tribunal's operations. Over the next few minutes, I would like to talk about that potential impact on the tribunal's operations.

[English]

It is clear that the proposed amendments to the act primarily impact the CBSA, notably the proposed provisions to address price distortions in the particular market situations.

Similarly, the proposed scope proceedings and anti-circumvention investigations would be conducted by the CBSA, not by the tribunal. In this regard, it would not be appropriate then for me to comment on circumvention as this is an enforcement matter for the CBSA.

Any circumvention determination would have to be implemented by order of the tribunal. However, the tribunal's role in these matters is expected to be minimal. Any order the tribunal would have to implement CBSA's circumvention determinations would be a mere formality, not involving any real work for the tribunal. Furthermore, appeals of these circumvention determinations by the CBSA would go to the Federal Court of Appeal, not to the tribunal.

CBSA scope rulings would be appealable to the tribunal, but we do not anticipate that it would have much impact on the tribunal. We are well prepared and well equipped to handle what we expect would be a relatively small volume of additional appeals as a result of those proposed amendments.

[Translation]

The proposed amendments to allow the CBSA to terminate investigations with respect of any exporter found to have an insignificant dumping margin or subsidy is also a matter for the CBSA. As such, there would be little impact on the tribunal. If the CBSA terminates an investigation with respect to such an exporter, then the tribunal's injury inquiry would no longer cover the exporter's goods, but it would continue with respect to all the other exporters' goods.

[English]

Finally, I understand that there will be regulatory changes later on to expressly allow for the participation of unions in inquiries under the act. This again should have little or no impact on the tribunal. The tribunal has already been allowing unions to participate in its inquiries. As far as the tribunal is concerned, the proposed changes would only formalize the tribunal's existing practice and make the regulations clearer on this point.

[Translation]

Madam Chair, this concludes my statement. Just like my colleagues around the table and Mr. Covelli, I would be pleased to answer any questions that you may have.

[English]

The Chair: Thank you, are there no further presentations? Perhaps just for clarification, you said some of the changes that are proposed came as a result of discussions on existing cases that were problematic. Could you give us an example of one of them, whether it is countervailing or anti-dumping? What would have led to the change by way of example?

Mr. Halley: The consultations that the department undertook were at around this time last year, between May and the end of July. They were on proposals for potential changes to the Special Import Measures Act. They weren't through the Canada Gazette process. We did go through that. That helped inform in the decision-making process in terms of the budget and what it is now in Bill C-44.

The Chair: But do you have any examples? What commodities? What were the difficulties that you are overcoming? I need an example. I appreciate the consultation. We thought we had a functioning act before. So what kinds of problems have we had that have led to these changes?

Laura Bourns, Senior Economist, Trade Rules, International Trade and Finance Branch (Department of Finance Canada): Generally the changes that we're making have been at the request of certain stakeholders that are users of the trade remedy system that would like to see our system more closely resemble those of some of our major trading partners. So in respect of the scope proceedings, what we have seen for example in the United States is that domestic producers do have the ability to request and participate in and defend their interests in proceedings relating to whether or not a good is subject to a trade remedy measure.

There was an instance where Canadian producers had become aware of the fact that CBSA had made a decision related to whether goods were subject to the measure that they did not agree with, and as a result of that, the industry sought the ability in future decisions by the CBSA to defend their interests and also to have the right to appeal those decisions.

So the scope proceedings will essentially provide all of the opportunities that the stakeholders have been seeking. They will be able to request these proceedings. They will be able to participate, and they will be appealable to the CITT.

The Chair: I am still wanting to know which are we talking about?

Senator Eaton: I have examples right here.

The Chair: I would like them on the record here. Can you tell us which sectors; agriculture, IT?

Ms. Bourns: The predominant user of the trade remedy system is the steel industry. About two thirds of trade remedy measures in force are related to the steel sector. The remaining measures in force would largely pertain to other manufacturing goods, often commodities like aluminum, copper. And then we also see some agricultural products such as potatoes, sugar, things like that.

The Chair: Thank you. That's helpful.

Senator Woo: Good morning, witnesses. I want to ask about the special market circumstances provision in this legislation, particular market situation clause. My question has to do with whether it affects the treatment of what we currently call non-market economies. That provision is already in place. So this particular market situation provision doesn't change how we treat non-market economies. But it would seem to me that if we are entering a regime where we take particular market situations in our assessment of distorted prices, that could in effect be the way we treat all economies so that there does not need to be a non-market economy designated as such. If there are particular market situations in market economies, then there will be particular market situations in so-called non-market economies. Could you comment on that please?

Ms. Bourns: I agree that there is the potential for overlap between these two designations, or recourses that the CBSA has. Essentially, these are grounded in different aspects of rules under the World Trade Organization. So particular market situation is potentially applicable to all countries, but it's slightly more limited in terms of the scope of what the CBSA can do where a particular market situation is found relative to what the CBSA can do if a non- market economy is found to be under investigation.

So the way that we have implemented the particular market situation provisions is where that condition is found, the CBSA cannot rely on domestic selling prices in the exporting market, but they can use the constructed cost or the cost of production as an alternative. They have much more flexibility, however, related to non-market economies, so, in the special import measures regulations, there are three countries that are designated as prescribed, so this would be potentially eligible for the application of a non-market economy methodology.

If there is found to be government intervention relative to the prices in the exporting market, the CBSA can use alternate prices, including surrogate country prices. So these are prices in a third country market that are considered to be representative of what prices would be in a market economy.

In that respect, I would say that non-market economies — it's an important flexibility for the CBSA to have because it's possible that in those economies, even using a constructed price methodology, it may not be sufficient to ensure that we're accurately reflecting what the price should be.

Senator Woo: In the case of non-market economies, you have additional tools to derive proxy prices that you would not have under this proposal to have particular market situation methodologies for market economies?

Ms. Bourns: Exactly. But the particular market situation provisions will be applicable to all countries. If and when non-market economy provisions fail to apply to a country that is currently considered a non-market economy, the particular market situation provisions would then apply to that country.

Senator Woo: I appreciate that. This is commentary more than a question. It would seem that we may be opening a pathway here. In my view, it is a positive pathway to reconciling some challenges we have around non-market economies because we have now established a methodology for dealing with non-market pricing in all economies. That's just a comment. Thank you very much.

Senator Eaton: Are these measures being brought into being for preparation for the NAFTA negotiations and what happened a couple of weeks ago when Trump sort of fired off against softwood lumber and our dairy industry, when you think of how the U.S. subsidizes its own farmers?

I notice here that amongst the countries the lists of goods currently subject to anti-dumping and countervailing measures include China, Romania, South Korea, Brazil, Japan, Taiwan and the U.S. So do you feel that this will give us a stronger hand when we re-enter NAFTA negotiations?

Mr. Halley: These are fairly distinct issues. This process was undertaken actually in last year's budget. There were some changes to the Special Import Measures Act and then consultation followed. The results of these consultations informed the measures that are in this bill. So it has been on a separate track.

With respect to measures against the United States, there are very few measures against the United States right now. I think there are more than 50 measures in place, and I think —

Senator Eaton: Copper pipe fittings, gypsum board, refined sugar and whole potatoes.

Mr. Halley: Yes, four or five as opposed to some other countries that are more around 75 per cent of the measures that apply to some of these countries, like China for example.

Senator Eaton: You never hear of Canada taking measures. I guess we're very discreet as a country. When we do take measures, we don't put it on the front pages of the newspaper, do we?

Mr. Halley: This is a process where it's driven by complaints from industry, so there is no government intervention. The industries can avail themselves of these tools. They would apply for measures and they would work with the CITT and the CBSA in that respect throughout the investigations. This is very much driven by industry. The government doesn't initiate these cases. Right now, these are all driven by industry.

Senator Eaton: Thank you very much.

Senator Downe: Could you elaborate on the public consultation. Was it by invitation, where was it held, online or in meetings?

Ms. Bourns: The consultations were conducted through the Canada Gazette. There was a posting in the Canada Gazette as well as on the Finance Canada website requesting submissions related to a series of potential amendments to the Special Import Measures Act and several questions related to each of those.

The consultations were open for a period of 60 days, and we received 46 submissions. The majority of these were from industries that are users of the trade remedy system, but we also had participation from other parties, downstream users and importers, and also some foreign business associations.

Senator Downe: The foreign business associations, how many of those did you hear from?

Ms. Bourns: We heard from several — foreign steel associations in support of the measures, and I believe there was one American agricultural association that wrote in.

Senator Downe: In addition to posting on the gazette and on the website, was there any outreach to people who might be affected, notifying them that they had to find it on their own?

Ms. Bourns: There was a list prepared of all known users of the trade remedy system and all trade lawyers who had appeared before the Canadian International Trade Tribunal over the period of the last two years.

Senator Downe: They were notified?

Ms. Bourns: They were all notified.

Senator Downe: Thank you. My second question is about changes for the union. Assuming they requested a number of things, what items did they request that they did not obtain?

Mr. Halley: To just complete what Laura was saying, the unions also used the consultation process to submit views and actually did request certain changes, some of which are included in the budget and are going to be subject to parallel regulatory amendments.

So what the amendments would be doing is they would be able to participate in trade remedy investigations, as Mr. Bédard was saying. It will be formalizing that.

There was also a request to be able to initiate complaints. When you file a trade remedy complaint, it does require a substantial amount of information with respect to the financial state of the industry in order to prove injury. That information is usually drawn from the books and the records of Canadian producers, not from the union, so it is not something that the unions would be able to do. But by having them participate, it is an important step to make sure that the investigations hear the points of the view of the unions with respect to how these investigations and potential outcomes may impact their workers.

Senator Cordy: Thank you very much for being here today. For clarification purposes, could you give us the difference between circumvention, when people are bringing things over, and those who are trying to evade paying duties or duty evasion?

Ms. Bourns: Generally, I would say that circumvention is related to activities where an exporter might make a modification to its goods or change the supply chain to involve a third country, in order that the goods no longer be subject to trade remedy duties. These changes are made essentially in an effort to avoid duties, but essentially the product that results is legitimately not subject, and that's why an anti-circumvention investigation would be required to change the scope of the measure in force, to ensure we are now covering these goods.

I can give you an example to help clarify this. If a change to a product, say to a steel product's chemical composition is made such that it falls outside the description of the order that the CITT had issued at the end of an investigation, the CBSA would no longer be able to apply duties in respect of that good. So an investigation could be conducted to show that, despite this change in the chemical composition of the good, it should be deemed essentially the same as the good that is subject, because it has the same end uses, same customers and essentially the same characteristics.

Duty evasion is a situation where, for example, either the origin of the good, the characteristics or description of the good or the selling price of the good is either mislabelled or intentionally misrepresented in order to avoid duties. In those instances, the CBSA would be able to apply duties so long as that mislabelling or misrepresentation is caught and clarified. So duty evasion activities fall under CBSA enforcement.

Senator Cordy: And they would be more fraudulent.

Last week I had a meeting with the Chicken Farmers of Canada, and they were speaking about circumvention and some of the challenges they were having with chicken coming from the United States. They said what was happening was the chicken was coming in with a barbecue sauce, or some kind of sauce, so that it fell under the rules where it was not counted in the amount of chicken that they should bring over.

Would the amendments that have been made in this bill help out the Chicken Farmers of Canada?

Mr. Halley: No. But there's a more fulsome answer.

This is a separate issue that is in a completely parallel process. I believe last November, Minister MacAulay, Minister of Agriculture and Agri-Food, did issue a statement that indicated that the government was looking at some of the issues that affect some supply management industries with respect to circumvention.

There is ongoing discussion with industry stakeholders on these issues that is taking place on a separate track, and that involves the Chicken Farmers of Canada.

Senator Cordy: You are looking at it. It's just not in this bill?

Mr. Halley: Correct.

Senator Gold: Just a follow-up question on the consultation process. Are the submissions made by those who sought changes publicly accessible and are they subject to any confidentiality agreements?

Ms. Bourns: They have not been made publicly available, but they are subject to ATIP, for example, and we have provided them in response to ATIP requests. In those cases, the consent of the parties has been sought, but all parties making submissions were informed that their submissions would be potentially subject to ATIP and could not necessarily be treated as confidential.

The Chair: You're saying that before it was a consultation between government and whoever came and it was always treated confidentially. Then we started to open up the process with ATIPs. Why would we, today — with a government that wants to be transparent and accountable, and that I think is what the public wants — have any consultations in private on matters of changing regulations and difficulties? This is not as if giving out information would help other competitors; it's really a question of how to improve the system and deal with the government.

Why are we still in that situation which we're at least now saying it might be subject to ATIP? Why aren't we just having open consultations?

Mr. Halley: The consultations were public. They were published in the Canada Gazette, so it was known that these consultations were ongoing. In this instance, or other important policy measures on which we've consulted over the years, what we've found is that the parties that want to participate in the consultation are a bit more open about what they want or their views if they can provide it with some business confidential information.

There is a balance here. I appreciate your question, and if that is helpful to the committee, we would be happy to give you a list of those that responded to the consultation and hopefully it would be helpful to the committee.

The Chair: My concern is that there may be a time for confidential consultations, but if we're talking about amending laws and reasons for it, we need a certain amount of openness. I'm wondering why we're still in a position where we publish a notice but then we have to go through an ATIP process to find out what was consulted.

I leave that rhetorically. I know it's in the hands of political authorities, but you might pass those comments on. Increasingly, we're being questioned about openness and transparency and a feeling that many things are held under confidence that don't need to be, and that we've widened that so much that it perhaps needs to be reconsidered to bring back confidentiality when necessary and public discourse when absolutely necessary.

That's not directed at you alone; it's directed at many departments and processes.

Senator Woo: Still on the subject of consultations. Were the importers of steel products, particularly the construction industry, was that industry consulted? Did they participate? What were their views? How did the department take into account their concerns or issues raised during the consultation?

Ms. Bourns: I think I failed to mention when I was asked about the notifications that we provided that we did also provide a notification of the commencement of public consultations to a very broad range of trade and business associations across Canada, including associations of downstream steel users such as automakers.

We did not receive any participation from any of those associations, and I would say most of the views of parties concerned about amendments to the trade remedy system that might strengthen enforcement were from trade lawyers that represent the interests of importers or exporters or exporting governments, typically in the process of trade remedy investigations.

The majority of the opposing viewpoints were expressed from those parties. There was very little participation from downstream steel users.

Senator Woo: Very little or no participation?

Ms. Bourns: I'll just consult my list.

Senator Woo: I thought I had heard previously that there was some representation from the construction industry.

Ms. Bourns: We did not receive any participation from downstream steel users.

Senator Woo: Thank you.

Senator Gold: This is a question about our competitiveness and how that may be affected by our trade remedy regime. Can you give us an idea of the order of magnitude of goods that are deemed to have been dumped or otherwise wrongly subsidized coming into Canada? What, in your opinion, is the impact on Canadian businesses' competitiveness of the trade remedy system in place or that you contemplate strengthening through this bill?

Mr. Halley: This is 2015 data that was in the report by the CITT. In 2015, the total imports that were subject to a dumping or countervailing duty measure was 0.34 per cent. Last year, there was $530 billion in imports. It's about 0.3 per cent of that.

As we discussed before, it's generally concentrated in steel, so I think 60 per cent of the measures affect steel products, and then there's a fair amount that are other commodities and some agricultural products.

With respect to the competitiveness, the trade remedy system is there to ensure that when there's unfair trade that there are tools available to ensure that this unfair trade is being addressed, when the unfair trade is injuring Canadian producers. So this is an important element available to all Canadian producers that feel there is ongoing unfair trade which injures their competitive situation, and it's a system that, despite the fact it's only 0.34 per cent, the presence of the system is important in respect of getting certainty.

There are situations that are injurious to Canadian industry and there are tools that are available that can address these situations.

The Chair: I have a few questions in the same sort of vein. How long do these investigations take? When you have an issue, resolution is what most businesses want and to move on. What would be the average length of the investigation? I'm presuming, by the changes, that either you're going to be more efficient or you are adding another process to it. Are you determining that it is going to be longer, or will it be better than your average today?

Ms. Bourns: The changes that we're making aren't going to have an impact on existing original investigations that currently last about eight months. There is some potential for extension in extenuating circumstances.

Essentially, the anti-circumvention investigation would be a parallel process and have no impact on an original investigation, although it's possible that by introducing these anti-circumvention investigations we'll be able to deal with some situations through an anti-circumvention investigation rather than through an original investigation. Those original investigations tend to be slightly more onerous on domestic producers because they need to provide a significant amount of information and also demonstrate injury to their domestic production, et cetera.

The Chair: Mr. Bédard, I think I heard from you that your case load you don't believe will be appreciably affected, so there should not be any further delays other than caseload management?

Mr. Bédard: First of all, Madam Chair, as was just mentioned, when it comes to the trade remedy investigations, we are under statutory time frames; therefore, a decision has to come out no matter what within a certain time frame. If we have more appeals, it's a question of managing our resources.

We already have the subjectivity appeal process that exists that is not the same as the new scope process that is being introduced in the legislation but which is already there. So that allows us to gauge, more or less, what we think will come our way. So it is what we consider as being manageable.

In two years, someone may tell you that I was famously wrong on that one, but this is our forecast at the moment.

The Chair: One final question, Mr. Halley. You're proposing amendments in Bill C-44. Are there any consequential regulations that will also flow?

We just received this and it's a pre-study. Will there be a need for regulations, and if so, in what areas?

Ms. Bourns: The majority of the key changes being made will require regulatory amendments as well. The only one that doesn't is the change we're making to conform with the World Trade Organization ruling, which is implementing the ability to terminate on an exporter basis. Those changes will come into effect immediately upon Royal Assent of the bill. The other changes will come into force at the same time as the regulatory amendments which we're forecasting for this fall.

The Chair: As we continue to see, much of the success of any amendment is in the regulations as much as it is in the bill. Will there be further consultations with those that have asked for these amendments pre-gazetting?

Mr. Halley: No, there will be no more consultations. We're very much in the implementation phase of the process now.

The Chair: Have any of the regulations been shared or have discussions taken place with those that are requesting — and those are what I call users — about regulations and how to handle that?

Ms. Bourns: We haven't specifically discussed the contents of the potential regulatory amendments with the users, but we have had ongoing discussions and close contact with those who request these amendments. They have provided detailed input in terms of what they think those regulatory amendments should be. We still do have ongoing discussions with them on certain points of policy related to those amendments.

The Chair: There are no further questions.

You've done your job, you've brought the amendments to us, and we appreciate the information you've given us. We will continue our pre-study of the clauses of the bill that were sent to us. Thank you for appearing before us.

Senators, I have one other issue to bring to your attention not to do with Bill C-44.

I met with the representatives of the EFTA countries, basically Liechtenstein, Norway, Switzerland and Iceland. It was a very good delegation, very well versed in Canada, so we had some excellent discussions about the new Europe, if I may call it that. Since they're not part of the European Union but they have agreements with them, they were keen to continue a relationship with Canada. They're very keen on seeing CETA and how it fits in with them because of the negotiations.

They're also caught in the situation of Brexit and what to do with Britain, because while formal negotiations can't take place, there are a lot of questions being raised.

All in all, I think we represented — the staff were there — this committee. They were quite pleased to get information from us about some of our views on trade perspectives on Europe and on our regional trade initiatives.

I think they went away very pleased that they had at least the opportunity to meet, and they understood that it was their time frame that caused us the difficulty. Nonetheless, they were pleased that they did have contact.

Senator Cools joined me towards the end of the meeting. I am reporting back for the record that we did have that contact.

I don't think we have a formal report. It's simply to indicate that it was useful for them, and I believe it will be for our ongoing studies.

(The committee adjourned.)

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