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Submissions

The OHRC regularly makes submissions to various levels of government (provincial, federal and municipal) on laws or regulations that are being considered.

These submissions generally involve looking at the draft laws from a human rights perspective. The OHRC also makes submissions to international bodies like the United Nations, to other organization’s consultation and research projects, and to legal commissions and inquiries.

  1. OHRC Submission to the Independent Review of Police Oversight Bodies

    November 2016 - For nearly two decades, the Ontario Human Rights Commission (OHRC) has raised concerns about systemic discrimination that are part of the culture of policing in our province. There have been far too many instances of racial profiling, discriminatory use of force on people with mental health disabilities and/or addictions, and racism and sexism in investigations of missing and murdered Indigenous women and girls in Ontario to ignore. These incidents and related concerns have sparked multiple coroner’s inquests, recommendations, reviews and reports, stretching back for decades. Yet they all have failed to eliminate systemic discrimination in policing.

  2. Submission regarding Bill 89, Supporting Children, Youth and Families Act, 2017

    April 3, 2017 - The Ontario Human Rights Commission (OHRC) welcomes the introduction of Bill 89, Supporting Children, Youth and Families Act, 2017. The Bill responds to human rights concerns raised by the OHRC about various aspects of Ontario’s child welfare system,[1] including the overrepresentation of Indigenous and racialized children and youth in Ontario’s child welfare system.

  3. OHRC Submission to the Independent Street Checks Review

    May 1, 2018 - Regulation 58/16: Collection of Identifying Information in Certain Circumstances – Prohibition and Duties (the “Regulation”) was developed in response to numerous reports of racial profiling in policing across the province, with the goal of “ensuring that police-public interactions should be conducted without bias or discrimination”.  Unfortunately, in our view, the Regulation has not lived up to this promise and, as currently framed, cannot achieve its goal. Racial profiling in policing remains an ongoing reality for Indigenous, Black and other racialized communities.  The Ontario Human Rights Commission (OHRC) is hopeful, however, that through this review and the recommendations that come out of it, the Regulation can be amended so that it can finally meet its promise.

  4. Submission of the Ontario Human Rights Commission Concerning barrier-free access requirements in the Ontario Building Code

    March 2002 - This submission is in response to the Ministry of Municipal Affairs and Housing’s (MAH) public consultation on the accessibility provisions of the Ontario Building Code (the “Building Code”). It has become increasingly clear to the Commission that the barrier-free requirements in the current Building Code have not been sufficient to achieve the degree of integration and full participation for persons with disabilities that is intended by the Ontario Human Rights Code (the “Human Rights Code”).
  5. Submission of the Ontario Human Rights Commission to the Transportation Standards Review Committee regarding the Initial Proposed Transportation Accessibility Standard

    August 2007 - The Commission has grave concerns with significant aspects of the Transportation Standard. In a number of areas, the standard falls far short of human rights standards, not only failing to make progress towards equality for persons with disabilities, but regressing on gains previously made. The Commission urges the Committee to significantly revise the Transportation Standard in order to bring it into alignment with human rights standards and the purposes of the AODA.

  6. Submission of the Ontario Human Rights Commission to the College of Physicians and Surgeons of Ontario regarding the draft policies relating to establishing and ending physician-patient relationships

    February 2008 - The Commission’s concerns focus on the draft policy’s handling of discretionary decisions made by doctors in accepting patients, and in provision of care. As currently stands, the draft policy may in fact lead to confusion and to human rights complaints, in that physicians may see it as condoning practices that the Commission views as discriminatory.
  7. Submission of the Ontario Human Rights Commission to the College of Physicians and Surgeons of Ontario Regarding the draft policy, "Physicians and the Ontario Human Rights Code"

    February 2008 - The draft policy raises a number of new concerns. The following pages detail the Commission’s concerns and provide suggestions for how to address them. We hope that our comments assist the College in providing greater clarity and ensuring that physicians have correct and sufficient information about their obligations under the Code.
  8. Submission to the Ministry of Community and Social Services regarding the final proposed Accessible Transportation Standard

    March 2009 - The Ontario Human Rights Commission would like to congratulate the members of the Accessible Transportation Standards Development Committee for all their hard work in developing the most recent Proposed Accessible Transportation Standard. This Standard is a vast improvement over the initial standard proposed to government in 2007 and hopefully will become an important driver of change once passed into regulation under the Accessibility for Ontarians with Disabilities Act (AODA) 2005.
  9. Comment of the Ontario Human Rights Commission on the City of Toronto's Proposed Zoning By-law

    September 2009 - The Commission is providing comment on the City's proposed zoning by-law because the by-law has the potential to affect the housing rights of many people across the City, particularly with respect to those living in affordable housing (group homes, seniors' residences, shelters, lodging houses, etc.). The right to be free from discrimination in housing under the Code could extend to the development of affordable housing projects for people and groups identified by the Code. In addition, the Commission believes it is important to highlight the City's progressive vision of housing and human rights through its newly developed Housing Charter.

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