OFA outlined key concerns and recommendations regarding Section 22 of the Health Protection and Promotion Act 2009 (HPPA) in regard to Temporary Foreign Workers. The HPPA serves a vital purpose, allowing regional Medical Officers of Health to create Class Orders that target local health concerns and emerging issues in a more timely and accurate way. During this pandemic, the Ministry of Health has provided guidelines to regional Health Units on how to address COVID-19 and reduce the incidence of outbreaks on farms, including those that employ and house Temporary Foreign Workers. Some Health Units have issued Class Orders that go above these guidelines, placing significant restrictions on the housing of Temporary Foreign Workers residing at that farm workplace. We have seen these additional restrictions inflict unnecessary and long-term economic damage to farmers subject to the Orders, disproportionate to those in neighbouring jurisdictions. OFA requests that the Ministry of Health develop a clear and consistent process for consultation that regional Health Units across Ontario are obligated to follow when they are considering implementing measures under Section 22 of the HPPA that impacts farm operations. Our goal is to have a meaningful consultation process that is robust and transparent, and that an Order issued under Section 22 is truly based on reasonable and probable grounds and not conjecture.