• Public interest protection


STANDARD SETTING OVERSIGHT

Until 2011 the PIOB carried out a policy of 100% direct observation of meetings of the boards and committees under its mandate supported by staff briefings and due process analysis (limited reviews and extended reviews). A PIOB member was present at each meeting to determine whether due process was followed effectively and with proper regard for the public interest and to provide comments or recommendations. The knowledge that the PIOB had observed each meeting gave assurance to stakeholders that the public interest was being protected.

Direct observation enables the PIOB to evaluate the quality and effectiveness of the deliberation processes under its oversight mandate.  PIOB staff prepares briefing memos to support every PIAC and CAG observation conducted by PIOB members, highlighting any relevant issue. Each direct observation is  documented with an observation report. Based on this information, the PIOB forms an opinion on the appropriateness of each stage of the process used to develop individual standards.

Oversight Methodology

Due Process Oversight



Box 1 – PIOB oversight of the Standard-setting Process


Assessment point 1

The standard-setting board approves a project proposal. A task force (or several task forces in the case of larger projects), made up of board members and others, is set up to develop the project.
 

Assessment point 2

The task force consults with the board’s CAG to receive comments on the project proposal, which are conveyed to the board. The task force reports the results of the board’s deliberations back to the CAG. If it is agreed that the project will proceed, the task force writes the first draft.
 

Assessment point 3

The board considers whether a consultation paper or the holding of roundtables is necessary to develop the project further.
 

Assessment point 4

If this is the case, comments received are shared with the CAG.
The board approves and issues for public comment an exposure draft on the proposed standard together with an explanatory memorandum. The minimum exposure period is usually 90 days.
 

Assessment point 5

Comment letters are received from respondents. The staff and task force analyze these comments and prepare an issues paper for the board. This analysis includes an outline of the proposed disposition of comments and, as appropriate, the reasons to accept or not to accept changes recommended by respondents. The board deliberates and amends the draft standard accordingly.
 

Assessment point 6

The task force consults with its CAG on significant issues raised in comment letters to the exposure draft, and the CAG provides input on them. The CAG may offer comments verbally, which are included in the minutes.
 

Assessment point 7

The task force reports back to the CAG on how CAG comments have been dealt with by the board.
 

Assessment point 8

The board agrees on a final draft and considers whether changes introduced merit re-exposure. The board approves the final draft of the proposed standard by a required majority of members present at the meeting and, separately, considers and votes on re-exposure.
 

Assessment point 9

Senior board staff confirm that the board has followed due process in regard to the proposed standard. Board staff complete a basis-for-conclusions document, which summarizes the main comments received on public exposure of the proposed standard and explains how the board dealt with them.
The CAG chair provides the PIOB with a written report providing her/his opinion on the due process followed by the PIAC in responding to CAG input.
 

Assessment point 10

The standard is submitted to the PIOB for approval that due process has been followed with due regard for the public interest.
 

The standard is issued.

Oversight Plans