The OACFP represents most of…

The OACFP represents most of the bereavement profession’s active operators within the province. Our membership consists of cemetery, funeral home, crematorium, and transfer service operators from across the province as well as many other stakeholders within the bereavement sector. Each year, we collectively care for over 85,000 Ontario families at their time of loss and greatest need. Our members take great pride in their stewardship of the environment in their operations. The OACFP has also committed to support our members and we are therefore currently considering the implications that the requirements will have on operators across the province.

We are appreciative of the proposal to pause the implementation of some provisions of the On-Site and Excess Soil Management Regulation, O. Reg 406/19 until January 1, 2023. We have already heard from a number of our members that the implications of these provisions on the operation of Ontario’s cemeteries are onerous and very costly. It appears to us that Ontario’s cemeteries and their operations were not considered or at least, were not consulted with when these regulations and their provisions were originally drafted.

Ontario cemeteries, which are legally required to exist in perpetuity are unique operations that are managed by a vast array of entities. These include municipalities, religious groups, volunteer boards, not-for-profit and for-profit companies. When a decedent is buried in a casket, each burial each burial produces a minimal (3-4 m3) amount of excess clean soil. This will continue in perpetuity for each and every burial. Depending on the volume of burials a cemetery performs, this excess soil needs to be removed from the cemetery with appropriate frequency. The provisions of these new regulations will ultimately affect all cemetery operators in the province and will provide significant challenges for many both in terms of compliance and the cost of compliance.

All cemeteries provide an essential service to their communities. The ongoing nature of the service they provide is unlike other development and construction projects for which these regulations were intended, and which have clearly defined beginning and end points. For these reasons, as well as the others enumerated above, we respectfully seek consideration to be added under Section 2 of O.Reg. 406/19 as being exempted from the regulation.

We appreciate your attention to these concerns and the opportunity to provide comment. If at all possible, we would like to meet with your team, perhaps at a member’s cemetery, so that we can explain and even demonstrate our position and concerns. We look forward to discussing matters further with you. Should have any questions regarding these comments please contact our Executive Director at info@oacfp.com.