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Submission to the Standing Committee on General Government
Bill 69, Regulatory Modernization Act, 2006

Bill 69, the Regulatory Modernization Act, 2006

On behalf of Retail Council of Canada (RCC) and our members operating across the province, please accept this submission regarding Bill 69, the Regulatory Modernization Act, 2006 (the Act).

RCC and its members support the intentions of the Act to achieve greater protection of the public, workers and the environment; to reduce duplication in the regulatory compliance activities to which business are subject; and to maximize government resources. However, we are concerned that the Act as currently drafted may in fact frustrate those intentions.

Since the Act was introduced in February 2006, RCC has been working with the Ministry of Labour alone and as part of a stakeholder working group to ensure that the Act does not have unintended consequences that pose risks for existing and future investment in the province. In partnership with the Canadian Manufacturers and Exporters, the Council of Ontario Construction Associations, the Canadian Council of Grocery Distributors, the Canadian Petroleum Products Institute, the Cement Association of Canada, the Ontario Restaurant, Hotel and Motel Association, the Ontario Forestry Industry Association, the Canadian Restaurant and Foodservices Association, the Canadian Chemical Producers Association, the Ontario Mining Association and the Canadian Steel Producers Association, RCC has both written to and met with the Minister of Labour and Ministry of Labour representatives.

We understand from these meetings that the intent of the Act is to focus on chronic violators and to give the government the tools necessary in order to use and share compliance information. However, the ability to target the small segment of the business community that commit serious repeat violations of regulatory statutes should not come at the expense of the freedom of the rest of the business community, which is law-abiding and responsible.

We believe that the issues and recommendations outlined in this submission, if acted upon, will strengthen the proposed Act towards the government's stated intentions.

All of which is respectfully submitted,

Ashley McClinton
Director, Government Relations (Ontario)