Processed under the provision of the Access to Information Act I Revise en vertu de la loi sur l?aooes a l?information [l 7 2015 Ministre de la S?curit? publique BUREAU DU LCOMMISSAIRE Commissioner Bob Paulson Royal Canadian Mounted Police 73 Leikin Drive Ottawa, Ontario KIA 0R2 Dear Commissioner Paulson: I write today regarding ?rearms classi?cation. Namely, the process of developing expert opinions on the classi?cation of ?rearms by the Canadian Firearms Program (CFP), and the dissemination of that opinion across government and to a large number of ?rearms stakeholders through the Firearms Reference Table (FRT). Hunting and sport shooting is a multi-billion dollar industry in Canada that is responsible for thousands of jobs. A large component?of this industry relates to the sale of ?rearms. In order to be competitive, Canadian businesses must offer consumers the most relevant products possible. To that end, new ?rearms are being both developed in and imported for sale to the Canadian market. It is the goal of our government to see this process occur free of needless red tape that does not help to keep the public safe. It has been brought to my attention that the FRT is used as much more than an aid to law enforcement. It is used as a key legal classi?cation tool by many agencies across the Government of Canada, as well as shared with international bodies. The Order Amending the Order Declaring an Amnesty Period (2014) describes the FRT as ?an administrative Web-based database that contains determinations regarding the classi?cation of all known ?rearms in Canada. Before a ?rearm can be imported or registered in Canada, an FRT record must be generated.? 800 Canada 000001 Processed under the provision of the Access to Information Act I Revise en vertu de la loi sur l?aooes a l?mformation I found this deeply troubling. This brings me to the reason for my letter. I recall the considerable public turmoil and legal jeopardy caused for thousands of otherwise law-abiding Canadians as a result of the decision to unilaterally ?reclassify? ?alter the FRT entries of- the 02-858 and Swiss Arms families of ri?es. I am ?n'ther advised that there are signi?cant delays in processing new requests for classi?cation of ?rearms. In fact, I have had a Canadian business bring to my attention a case in which they waited three years to receive an answer. In my view, this is not the manner in which we ought to respond to the needs of law-abiding Canadians, including Canadian businesses. Like you, keeping Canadians safe is my highest priority, and I support fulsome study of ?rearms before they?enter the Canadian marketplace. However, a sensible balance must be struck. Therefore, pursuant to Section 5 of the Royal Canadian Mounted Police Act, I direct you to ensure that the following steps are undertaken by the CFP when providing an expert opinion on the classi?cation of a ?rearm, and the creation of any record relating thereto: 1. All requests for classi?cation determinations for the purpose of selling ?rearms must be acknowledged, in writing, by the Canadian Firearms Program within two (2) business days of receipt. 2. If an FRT number has not been issued within 60 days following the date of the request for classi?cation, a phone call between the requestor and the CFP must occur to discuss any additional information that may be required to bring the process to a speedy conclusion. 3. [fan FRT number has not been issued within 120 days of the date of the request, an of?cial letter is to be sent to the requestor to outline reasons for the delay, including any additional information that may be required to bring the process to a speedy conclusion. 000002 8. Processed under the provision of the Access to Information Act I Revise en vertu de la loi sur l?aooes a l?information -3. Ifan FRT number has not been issued within 180 days ?'om the date of the request, and provided the requestor has submitted all information reasonably requested and necessary to complete the classi?cation decision, the proposed classi?cation contained in the technical data package is to be deemed correct and an FRT number is to be issued. Once an FRT number is issued, if a requestor disputes the result they must able to make submissions to support a review the decision by a different analyst within the CFP within 60 days of receipt of the number. The CFP must render a decision on the review of the decision within 30 days of the review application being made. In compliance with SOR 2014-198, an entry altered once it has been in place for 365 days, subject to any review proceedings referenced above. A new entry created for a ?reann that is substantially similar to a ?rearm already in the FRT. I believe the application of this framework to processes governing the FRT will enhance safety and ef?ciency, while respecting the principles of transparency and the rule of law. Should any of the above elements present process difficulties or resource implications, I would be pleased to receive your input on such matters. Sincerely, Steven Blaney, P.C., MP. Minister of Public Safety an Emergency Preparedness 000003