OFA provides comments on mandatory requirements for employer-provided accommodations in the Temporary Foreign Worker (TFW) Program. OFA believes that all farm workers, from both Canada and abroad, should be treated with dignity and respect, and be provided with a safe, fair and rewarding work environment. OFA supports access to foreign agricultural labour provided there is a shortage of Canadian workers seeking agricultural employment. OFA recommends that public health be recognized as the main determining factor behind policy decisions about employer-provided accommodations for TFWs. OFA also recommends the proposed federal standard be implemented following the principles used to apply the Greenhouse Gas Pollution Pricing Act (GGPPA) in different jurisdictions across Canada, where provincial jurisdiction is respected and a federal default standard is only applied where a satisfactory provincial standard does not exist. For employers seeking to meet one or more elements of the federal standard, OFA believes cost-share funding support should be provided to make the associated investments needed to modify existing accommodations and/or establish new accommodations needed to meet the new requirements.
Stakeholder questions are addressed regarding proposed requirements, public health considerations, impacts of new requirements, and inspections. OFA recommends the federal and provincial government build on existing cooperation between their inspection departments (for example, past collaboration between ESDC and Ontario’s Ministry of Labour, Training and Skills Development (MLTSD)), to streamline inspections of farms employing temporary foreign workers. OFA appreciates the opportunity to provide comments to this consultation.