The Ontario Federation of Labour (OFL) is the central labour organization in the province of Ontario.  It has an affiliated union membership of over 700,000 members from all regions of the province.  With most unions in Ontario affiliated, membership includes nearly every job category and occupation.

As a province-wide central labour body, the OFL works to develop and coordinate policy as passed at our conventions and by our executive bodies.  One of the key roles of the OFL is to try to influence public policies that affect all working people, their families and communities.  One of the most important areas of public policy that we try to influence is the prevention of work related injuries and illnesses, including occupational cancers.

We welcome the opportunity to comment on these latest proposed revisions to the Regulation respecting Control of Exposure to Biological or Chemical Agents (O.Reg. 833).

Introduction

If we are to prevent future occupational disease, we must aim now to reduce the use of existing toxic substances or processes and provide the framework for development of new, non-toxic substances and processes in production.  This goal has much in common with environmental objectives.  The successful reduction of toxic substances and processes in the workplace will also play a key role in diminishing environmental pollutants.

Statement of Environmental Values

In previous consultations on proposed changes to Ontario’s occupational exposure limits we commented on the Ministry of Labour (MOL) Statement of Environmental Values which it had prepared as is prescribed under O. Reg. 73/94.  According to the statement, one of the ways that the MOL contributes to the environmental well-being of the province is ”encouraging the substitution of hazardous substances with those that are less hazardous.”

We were unable to find a single occasion in which the MOL had actually been “encouraging the substitution of hazardous substances with those that are less hazardous” and concluded that the MOL had not incorporated this commitment into its activities in the field. In previous submissions we encouraged the MOL to take steps to actually follow through on this commitment.