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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. 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”).
  2. 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.

  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. Ontario Human Rights Commission Submission to the Accessible Built Environment Standards Development Committee Regarding The Initial Proposed Accessible Built Environment Standard

    October 2009 - The Ontario Human Rights Commission (OHRC) has reviewed the initial proposed Accessible Built Environment Standard prepared by the Accessible Built Environment Standards Development Committee pursuant to the Accessibility for Ontarians with Disabilities Act (AODA). The OHRC offers the following comment for consideration by the Committee and the Government as the Committee deliberates and prepares to submit to the Government a final proposed Standard following the public consultation period.
  8. Submission to the Employment Accessibility Standards Development Committee Regarding the Initial Proposed Employment Accessibility Standard

    May 2009 - The Ontario Human Rights Commission has reviewed the initial proposed Employment Accessibility Standard prepared by the Employment Accessibility Standards Development Committee pursuant to the Accessibility for Ontarians with Disabilities Act (AODA). The Commission would like to raise the following issues for consideration by the Committee as it deliberates and prepares to submit to government a final proposed standard following the public consultation period.
  9. Submission of the Ontario Human Rights Commission to the Ministry of Municipal Affairs and Housing's long-term affordable housing strategy

    December 2009 - The Ontario Human Rights Commission (the “OHRC”), commends the Province of Ontario for identifying the need for a long-term affordable housing strategy. The development of such a strategy was one of the main recommendations coming out of the OHRC’s own housing consultation report, Right at Home. The OHRC is very pleased to contribute to the Province’s development of this strategy. This written submission complements Chief Commissioner Barbara Hall’s verbal input to the Ministry of Municipal Affairs and Housing’s roundtable consultation sessions held on both June 22, 2009 and November 3, 2009.
  10. Comment of the Ontario Human Rights Commission on the City of Oshawa's student accommodation strategy

    March 2010 - The OHRC has made a commitment to educating and addressing human rights concerns regarding opposition to affordable housing, which has the potential to discriminate against groups protected by the Code. Oshawa has been attempting to address the student housing issue since it has been dealing with community tensions raised due to post-secondary off-campus student accommodation. Oshawa's strategy may have an impact on land use planning in communities across Ontario responding to similar tensions.

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