OCBCC presentation to Bill 66 Committee hearings

This following is a transcript of OCBCC Board Member and AECEO President Dr. Brooke Richardson's presentation to the Standing Committee on General Government's hearings on Bill 66. 

             > Read our full submission on Bill 66 (PDF)

Dr. Brooke Richardson: Good afternoon. My name is Dr. Brooke Richardson.

Thank you to the Chair and Committee members for this opportunity to address Bill 66.

I am speaking here today as a Board Member of the Ontario Coalition for Better Child Care, and as the President of the Association of Early Childhood Educators Ontario. I am also a lecturer in Early Childhood Studies at Ryerson University, and a mother of four children under the age of 12.

Let me start with a little bit about who I am representing. The Ontario Coalition for Better Child Care is a broad-based, member-driven, coalition made up of hundreds of organizations including: child care programs, social justice, women’s and labour organizations and associations - including the Association of Early Childhood Educators Ontario.

I am here to address our concerns about Bill 66 and child care.

I am going to focus my remarks on Schedule 3 that proposes changes to the Child Care and Early Years Act and Education Act.

  • We are recommending that Schedule 3 be removed from the Bill in its entirety.
  • We are not suggesting amendments to the schedule, rather it is our position that the inclusion of these Education issues in an omnibus bill on business competitiveness is inappropriate and seems hasty and haphazard.
  • And we are especially concerned that the proposed home child care changes under Schedule 3 put young children’s health, safety and well-being at risk.

We take issue with both the substance of the proposals and the rationale for the changes.

So let’s look at the details of the home child care proposals:

Bill 66 proposes to increase the number of very young children that one person may legally care for in regulated and unregulated home child care settings.

The proposed changes would allow home child care providers to care for three children under two years of age (up from a current limit of two under 2 years), as well as additional allowable children over the age of two years, for a total of five children in unregulated and six children in regulated settings.

The changes also allow for home child care providers to care for any number of their own children four years of age or older at the same time.

Current laws allow for the provider’s own children four years old and over not to be counted in the total number while they are at school.

But the changes mean that these children never need to be included in the total number of children being cared for, even when they are present in the home before school, after school or on evenings and weekends.

This means that there would be no hard cap on the total number of children that can be cared for by a single adult in a home.

Let’s look at a concrete example: If an unregulated provider has three of their own school-age children, they could still look after five children for pay, swelling the total to eight children, including three babies, with one adult in an unregulated private home. This is simply too many very young children for one person to care for adequately.

These changes mean that children’s needs will not be well met, and at worst it could put their safety and security at risk.

Given the risks and seriousness of these changes, you would think that there must be a very pressing rationale for this. So let’s examine the reasons that have been publicly given for these changes.

The rationale given by Minister of Education Lisa Thompson for these changes at a January 29th press conference was to “increase access” to child care for parents, and to help home child care providers to “expand their businesses and earn more”.

While aiming to increase access to child care for parents is an admirable goal, it cannot be achieved at the expense of safety and quality considerations. Caring well takes time, energy, empathy and creativity. Caring cannot be made more “efficient” with strategies deemed appropriate for agriculture and pawnbrokers.

Young children’s wellbeing and the quality of their care environments must be paramount when it comes to setting laws and regulations around child care. Thus, the goal of increasing access to child care for parents is best met by continuing to invest in licensed child care to increase the number of quality sites and spaces.

Further, “expanding businesses” is not an appropriate goal for the Ministry of Education – the safety of children and the quality of their education and care must not be compromised by desires to “earn more”. The real bottom line here is children’s lives, not profit margins.

I would now like to turn to the proposed changes to before- and after-school care programs.

Schedule 3 lowers the age that children may attend authorized recreation programs rather than licensed child care programs before and after school. This is an inappropriate way to address the need for more before- and after-school child care programs. Young children starting school, especially the four year olds who are still adjusting to school would benefit from the smaller groups and more qualified staff that are emblematic of licensed settings.

Another change removes the requirement for third party operators providing before- and after-school care for School Boards to have Registered Early Childhood Educators (RECEs) lead their programs.

This is a clear lowering of program standards and will weaken program quality.

Ontario RECEs have specialized knowledge of child development and pedagogy in the early years. They create rich, inclusive, learning and care environments. Removing the requirement of ECE-led programs jeopardizes the quality of experiences for young children.

To review:

  • Simply put, Safety First. The changes proposed in Schedule 3 put the safety, security and wellbeing of young children at too great a risk.
  • The justifications for these changes are not adequate or appropriate to warrant these proposals.
  • Thus, we are recommending that Schedule 3 be removed from the Bill in its entirety.

Thank you very much for your time. I’m happy to take any questions.

The Chair (Mr. Dave Smith): Thank you. We’ll start with Mr. Tabuns.

Mr. Peter Tabuns: Ms. Richardson, thanks very much for being here today and making that presentation. I was present for the presentations and debate the last time we changed the child care regulations, and there was certainly a lot of concern at the time about the number of children who would be looked after by a single child care person in a home. One person said that she could carry out two kids in her arms, but she wasn’t sure if she could carry out three if there was a fire.

Can you tell us a bit about the safety concerns that you have with regard to this change in ratio?

Dr. Brooke Richardson: Yes, definitely. It’s very clear to me that eight children is just completely unreasonable for one person to be able to handle. That, to me, requires no explanation. I mean, I’m a mother of four, age range from 14 months to 11, and me and my husband have our hands very full. I couldn’t add three more children into that mix, let alone three babies.

Certainly safety is the paramount concern, particularly when it comes to infants. Like you said, regulated or unregulated home care settings meet very minimal health and safety standards already, so to just permit more children is leaving children in the same—I think it’s important to remember that this legislation came about because of the Ontario Ombudsman report entitled Careless About Child Care, where four infants and toddlers died within a seven-month period in Ontario in 2013-14. That is unacceptable, and that is exactly what’s going to happen again.

My question is, why do we have to keep waiting for children to die, and why would we keep permitting more children to be cared for when we know this is what is going to end up happening?

The Chair (Mr. Dave Smith): Ms. Fife?

Ms. Catherine Fife: Thank you very much, Brooke, for speaking on behalf of so many parents and the concerns that they have. Those are genuine concerns around safety.

We’ve been told that this is a solution to less child care, but also, in rural communities, less flexible options. Can you address that head-on? Because we know that schedule 3 will not create more spaces; it just changes the nature of that child care experience.

Dr. Brooke Richardson: So first of all, yes, there’s this fallacy that it’s going to create more spaces. Most of the people I have talked to and engaged with as members of an organization or just in general discourse are saying, “I can’t possibly take on any more children, even if I wanted to. It’s too hard. I’m going to be sacrificing something, and it’s not fair to the children.”

Interestingly, I’m working on another project right now looking at non-standard child care work, which relies heavily on unregulated and home child care provision. The problem is that as I talk to parents across the country, parents are not interested in—they want more than a place where their child is hopefully going to be alive at the end of the day, right? We need to set higher goals for child care in this country, and if that’s what we’re going by, that’s a real problem.

When I talk to parents—and my friends and colleagues are parents, as well; this really intersects both my personal and professional life—parents are interested in high-quality child care experiences for their children. They don’t want to have their children sat in front of a TV all day. They want constructive experiences, and it’s just literally impossible to do that if you have—I mean, can you imagine having three infants all day every day, with no other support?

Ms. Catherine Fife: No. It’s actually completely irresponsible, because—

Dr. Brooke Richardson: It is.

Ms. Catherine Fife: As you pointed out, we have a coroner’s inquest report on the death of two-year-old Eva, so for the government to move forward with this strategy, knowing what we know, knowing the research and the evidence—we are going to try to pull the entire schedule. We think it shouldn’t belong in this bill, as well, and we share your concerns that this is being described as a business idea —“open for business.” Even the minister, in the House, was like, “And that’s not all,” as if she was on the Shopping Channel, selling frying pans. It’s not appropriate language to be using when we’re talking about children.

Dr. Brooke Richardson: No, it’s not. It’s commodifying children, so ethically—and I am an ethics of care researcher. I have, certainly, major issues with it being included in Ontario’s competitiveness act. Yes, child care is a key component of a competitive economy, but that’s in creating high-quality, licensed child care spaces and not in downloading this work onto the backs of already marginalized, racialized women, who are very underpaid and undervalued.

Ms. Catherine Fife: How much time do I have?


Ms. Catherine Fife: Two minutes?

Let’s go back to the real problem. This morning, we heard from another group that pointed out that 80% of the child care in the province happens in informal home care situations because successive governments have not invested in rural child care options that are flexible, that are quality-based and that are affordable. But as you point out, the return on investment for child care is there, from an economic perspective.

Dr. Brooke Richardson: Yes.

Ms. Catherine Fife: Can you speak to that a little bit?

Dr. Brooke Richardson: We just have to look at Quebec, where they have a much more publicly supported child care system and the amount of earnings that women re-entering the workforce are contributing to the taxes is more than offsetting the cost of the system. Pierre Fortin is an economist who has done a great deal of research in this area.

So yes, I think it’s important to keep in mind that this is a public investment and with public returns, but only if it is high quality enough, only if it’s good enough, for the children and families that use it, or else you are not going to see that.

Ms. Catherine Fife: One final thing: Thank you for raising the before-and-after care, because our public education system and our schools in communities are there for those communities. We are underusing that resource for families and children. The original extended day was supposed to incorporate before-and-after from a not-for-profit sector. The fact that the government is looking at businesses infiltrating education to make money off of parents who are desperate for before-and-after—

The Chair (Mr. Dave Smith): Thirty seconds.

Ms. Catherine Fife: —just the final word on how misguided that is.

Dr. Brooke Richardson: I think it’s extremely ethically problematic. It’s problematic from an ethical and a bottom-line financial perspective. We can’t sacrifice children’s well-being in this profound way. This is not a minor ??tinkering; this is a profound—

The Chair (Mr. Dave Smith): Thank you.

Ms. Catherine Fife: Thank you.

The Chair (Mr. Dave Smith): From the government side: Ms. Skelly.

Ms. Donna Skelly: Thank you, Brooke, for showing up here today and making your presentation.

My kids are much older now, but like many parents, when my children were smaller, I worked in an industry that wasn’t a 9-to-5 kind of situation. I worked 4 to 12; my husband worked crazy hours. At that time, and I think it’s pretty consistent with what we’re seeing across Ontario today, the 9-to-5 model for child care, if you will, just doesn’t work for, I would actually argue, most families. I live in Hamilton. The commute to Toronto can be two to three hours each way. Parents are being forced to really think outside the box when it comes to being able to find what they consider good child care.

When my children started into junior kindergarten and kindergarten, we were always struggling to find adequate aftercare programs. The truth is, we were able to find them, and they weren’t always programs that were run by ECEs or programs that fit the model that you’re talking about. I’m just wondering if you could speak to that, because in today’s society, parents, as I said, don’t fit that 9-to-5 schedule.

Dr. Brooke Richardson: I think that’s a really good point. In fact, I’m working on a contract right now with Employment and Social Development Canada on non-standard child care in Canada. I’m actually in the process of interviewing parents about this very issue. And it is an issue. It is a problem, that 9 to 5 are the typical regulated child care hours. But there’s also a number of misconceptions along with that, which are that while home-based child care can be more flexible, can adapt to those needs, in actual fact, parents have as much difficulty trying to find before 7 a.m. or overnight care or evening care, whether in fact a child can be fed or go to bed. These are still extremely hard to find, even in unregulated and regulated home child care settings.

The solution that I think needs to be examined—there are some wonderful programs that exist. Discovery centre, which is in Winnipeg, has a flex-care program. So parents can sign up for a flex-care program and as long as there’s time ahead, they can schedule to have early morning or they can use later evening. The centre is open—I can’t remember the exact hours, but it’s somewhere along the lines of 6 p.m. till midnight. Most children are there between the typical hours, but they offer this other program which allows parents working a schedule, like you would be working, to also benefit from the quality learning environment. It’s a very popular program.

There are a few other cases like that in Canada. So I don’t think the solution is to simply privatize, because the reality is that these programs—I mean, as a parent even, I know the cost of programs is prohibitive. A lot of parents want to send their kids to arts programs, and these are great, but they’re very expensive and they’re not practical for many parents who need child care where their children are. They need something in the school. They can’t necessarily pick up and then drop off here and then pick up there, because they’re working.

There needs to be that seamless day, that seamless transition. It’s also extremely disruptive for children, let’s be honest, if they’re getting shuffled here, there and everywhere. If you can be in the same place, have consistent caregivers, have consistent space that they are comfortable with, that’s going to be much better for the well-being of children. It’s going to work better. What works better for families works better for children, and vice versa.

Ms. Donna Skelly: I would agree with you, but I want to go back to—I would argue that it doesn’t always have to be provided by ECEs or people that you believe are qualified to provide this care, because there are a number of programs that have been recognized as being educational but also simply fun for kids. I remember this, when my babies were small, I didn’t want to put them into yet another learning, if you will, experience, I wanted them to actually just relax and play after school. So I don’t think it’s always about forcing them to—

Dr. Brooke Richardson: No, and I think that’s a really good point. A really common misconception is that “early learning” is always about learning. No. In fact, here in Ontario, we have a play-based curriculum. It’s not about shoving more information into children’s brains; it’s about experiential learning. Everything children are doing, they’re learning. Right? So this is the knowledge that we need for young children.

My son, when he entered kindergarten, was three. I would not have wanted him in a room with 14 other people with no qualified early childhood educator. That, to me, is so problematic. Early childhood educators do have training in the early years about what children require, and that is different from school-aged children.

Ms. Donna Skelly: But would you agree that it’s not necessary to have these—and you mentioned that your preference is an early childhood educator to care for children in after-school programs, but there are options that involve people who know what they’re doing and who can provide an excellent, safe experience for young children.

Dr. Brooke Richardson: I think, of course, that exists in some places, but that is not, by and large, the default. It’s difficult to find, and it’s not supported by public policy infrastructure. So who is going to get access to those programs? The wealthy children whose parents can pay for those programs, whose parents can pay—there’s a van that comes to my kids’ school, who picks up kids, school transportation, and takes them to their after-school programs and then takes them—

Ms. Donna Skelly: There are affordable options.

Dr. Brooke Richardson: There are not as affordable options, and the affordable options, actually—there’s a place near my house that offers affordable options. I could never send my children there in good faith because there are 15 children who are four years old, and that’s chaos. And they don’t have centres built for that—the space isn’t built for that.

The Chair (Mr. Dave Smith): Ms. Hogarth. You have 30 seconds.

Ms. Christine Hogarth: Thank you Brooke for your statement there. I just actually want to continue on with what MPP Skelly was talking about. We have a lot of parents—and you talked about being a parent yourself and you talked about safety. Safety was paramount. As a stepmother, we had a daughter in after-school programs. It was done by the school. Don’t you believe that the parents should have a choice, and would you not interview those child caregivers?

Dr. Brooke Richardson: In fact, I wrote my dissertation on choice—

The Chair (Mr. Dave Smith): I’m sorry. We’re out of time.

Dr. Brooke Richardson: Oh.

The Chair (Mr. Dave Smith): Thank you very much for your presentation.

Dr. Brooke Richardson: All I want to say is you need to have options to have choice—

The Chair (Mr. Dave Smith): Thank you. Thank you.

Dr. Brooke Richardson: —and right now there are no options.

Ms. Christine Hogarth: Absolutely, choice. Yes, thank you.

Dr. Brooke Richardson: Options.