Proposed changes to age groupings, group sizes and staff ratios will undermine the ability of child care staff to carefully and comprehensively nurture the children entrusted to their care.

Child Care Modernization
c/o Early Years Division
Ministry of Education
RE:          Regulatory Registry Posting related to the Child Care and Early Years Act, 2014 and the Education Act:  Phase 2 Regulations
On behalf of the Canadian Union of Public Employees (CUPE) Local 79 and our members who work in the City of Toronto’s directly-operated child care centres, I would like to provide input on the proposed regulatory amendments, Phase 2, made under the Child Care and Early Years Act, 2014 and the Education Act.
In the past, CUPE Local 79 has provided input on the Modernizing Child Care in Ontario initiative in 2012, and again in 2014, regarding amending Regulation 262 under the Day Nurseries Act.
CUPE Local 79’s concerns about ratios and age group changes have still not been addressed.  In fact the proposed Regulatory Changes in Phase 2 will compromise the goal of high quality, accessible child care, delivered safely by professionals.
Phase 2 regulatory changes present a host of problems for families needing and using child care, and for child care workers.  Regulatory changes should always be centred on the care of the child  ̶  not just changes to ‘fit the demand for child care’ as Ontario Education Minister, Liz Sandals remarked.  What works for a majority of parents who need child care services does not necessarily translate into a high quality of care for a child.
Proposed changes to age groupings, group sizes and staff ratios will undermine the ability of child care staff to carefully and comprehensively nurture the children entrusted to their care.  For example, the proposed composition of the toddler group would see one year old infants and two year old toddlers all placed in the same group.  This proposed grouping would prove detrimental to both 12-month old as well as 24-month old children.  The learning abilities and developmental needs of children in this age group vary widely.  There are widespread concerns about safety and the ability of front-line workers to nurture children properly in these unwieldy and unworkable groups.
The City’s directly-operated centres give parents with special needs children a high quality and professional option for their care.  These Phase 2 proposals have serious liability and health and safety implications, especially for children with special needs who require extra supports.
The process for modernizing child care in Ontario must be focused on raising the standards to achieve the highest quality care for infants, toddlers, pre-school and older children.  Changes to the age groupings, and increasing the number of children being cared for by fewer child care professionals is not the way to modernize or build a high quality child care system.
Our members are child care workers, parents, guardians, caregivers and part of Toronto’s many diverse communities.  CUPE Local 79 members care about the quality of public services – especially child care.
We all have a stake in high quality, accessible and safe child care.  The Ministry of Education, Early Years Division, should listen carefully and act accordingly to the best advice and research from child care advocates and engaged stakeholders.  There is no argument about the ever-increasing need for more child care spaces across the province and especially here in Toronto, but new spaces shouldn’t be created by changing the rules for ages or group sizes.
Yours truly,
Tim Maguire
President