June 15, 2021 Re: Drinking…

June 15, 2021

Re: Drinking water and wastewater operator certification regulations

I am writing to express my grave concern regarding proposed changes to Ontario's drinking water and wastewater operator certification regulations ( O. Regs 128/04, 129/04).

I strongly urge the government to reconsider these proposed regulations as they put the health and safety of operators and the public at risk. These regulatory changes would allow system owners and operating authorities to utilize non-licensed workers during a declared emergency. These changes would have a significant impact on the training of operators (or lack of training) as well as impede fair collective bargaining by basically taking away the right to strike.

Specifically, I have concerns about the following:

First, the definition of 'emergency' is extremely vague as proposed and could allow an emergency to be declared for circumstances as varied as a natural disaster to a labour strike. While natural disasters are an emergency, a strike or lockout should not, nor should it ever be considered an emergency.

Second, the use of non-licensed operators, no matter their qualifications, poses huge accountability and safety risks to the operations of the plant they are working in and to the healthy and safety of all Ontarians. Non-licensed operators are not held to the same level standards and training as licensed operators who have years of training at the highest level. Allowing non-licensed operators to work undermines collective agreements which hold owners and operating authorities accountable to their employees.

Third, given how critical safe drinking water and contaminated wastewater are to public health, it would be unwise and unsafe for the government to adopt regulations which could risk healthy and safety by allowing non-licensed operators to run facilities. I should not have to remind the government that in May 2000, six Ontarians died as a result of poorly trained, unlicensed operators failing to address E. coli contamination at the Walkerton drinking water facility. Ontario cannot risk a repeat of this preventable tragedy by allowing non-licensed operators to work at facilities, especially in 'emergency' situations.

The changes proposed by the government now implies that drinking water and wastewater operators are essential workers without actually declaring us essential. If the government wants to make drinking water and wastewater operators essential workers, I would suggest that the government bring me and other operators in Ontario under the fold of being essential workers and bring us under legislation governing essential workers, instead of applying haphazard regulations that risk the public health and safety of all Ontarians.

Yours sincerely
Operator
City of Hamilton