Annual Report 1994/95 - Restructuring Our Approach to Marketing Practices Provisions

Over the past several years, as a result of concerns about efficiency, changes in the legal environment and resource constraints, the Marketing Practices Branch had to re-examine its mandate and role in the marketplace. A selective enforcement strategy was developed that focused on cases with the greatest economic impact. Within the context of the federal government's Program Review, we then undertook a comprehensive examination of the Branch's structure and its impact on operational efficiency and productivity.

The study demonstrated that a disproportionate amount of scarce resources was required for administrative tasks associated with maintaining regional units. In some cases, the ratio of administrative overhead to enforcement resource expenditure exceeded 50 percent. In addition, the study noted that the evolving marketplace and selective enforcement strategy imposed additional requirements on case officers which would be more effectively handled in a consolidated organization. It also would produce operational synergies because of increased exposure to larger cases and general enforcement issues, as well as specialized training in modern law enforcement techniques.

The study also determined that because the vast majority of misleading advertising complaints (97 percent) are made by telephone or by letter, the closing of local offices would have negligible adverse impact on the handling of complaints. Indeed, the study determined that the creation of a central complaints unit to handle all complaints, Bureau-wide, under the responsibility of Compliance and Operations Branch, would result in a more consistent and streamlined treatment of complaints and a more strategic allocation of resources. Coupled with a nation-wide 800 service, a central complaints unit would better serve the selective enforcement priorities of the Branch and help establish a national database free from the technical difficulties associated with the operation of regional offices.

Accordingly, my formal announcement of the decision to close all field offices of the Branch located in seven cities (Halifax, Montreal, Willowdale (Toronto), Hamilton, Winnipeg, Edmonton and Vancouver) and the consolidation of all staff at the Bureau's headquarters in Hull followed slightly after the end of the year, on April 19, 1995.7 The Branch will replicate the organizational model used in other enforcement branches in the Bureau (Criminal Matters Branch, Civil Matters Branch and Mergers Branch). These branches have operated effectively over the years despite little or no regional presence. A central unit within the Compliance and Operations Branch will handle complaints and public enquiries for all enforcement branches.

The consolidation of the Marketing Practices Branch should be completed before March 31, 1996. While all affected officers were invited to transfer their positions to headquarters from the regions, most of them chose to remain in their current locations and seek new career challenges within and outside the public service. It is expected that many of the new headquarters positions will be filled by transfers of employees from positions affected by the recent budgetary reductions in the federal workforce elsewhere in Industry Canada or the government generally. To ensure operational effectiveness, staff in other branches will be asked to become part of a core of experience within the reorganized Branch.