February 2023 Board of Health Meeting - Seasonal Housing Compliance Inspections - Fee Increase for Service Program Resolution

ISSUE

The Windsor and Essex County (WEC) leads the province of Ontario when it comes to agricultural activities, with a large number of greenhouse-producing crops. The greenhouse farm operations allow for high yields year-round, which is unique to this region. Many seasonal agricultural workers are offshore workers from Mexico and Caribbean countries. From a public health perspective, International Agricultural Workers (IAWs) must be provided with adequate housing conditions in accordance with all applicable guidelines and protocols. As of 2022, there are approximately 1,156 seasonal housing accommodations in our region that the Public Health Inspectors (PHIs) routinely inspect.

WEC has seen an influx of IAWs over the past three years in order to meet the rising demand of crop production. As a result, (Table 1), the WECHU has seen a significant increase in the number of requests for inspection of new seasonal housing accommodations, and in 2023, we anticipate an additional 15% amounting to a total of 1330 (annually). This growth has substantially impacted the human resources required for inspections, re-inspections, administrative management, program processes, and coordination within the Environmental Health (EH) department.

The initial cost recovery fee structure for the program introduced with WECHU’s Board of Health approval in 2020 ($75 per annual licensing inspection). This structure was based on a preliminary assessment of other Ontario health units operating the same program. In the fall of 2022, an updated scan of public health units was completed to understand how similar programs were being maintained given the increases in quantity and cost. It was identified that the majority of other health units were charging fees ranging from $105 - $125 for both licensing and other re-inspections. With this in mind, and in consideration of the ongoing growth in the number of seasonal housing facilities requiring inspections, and the increased demand on administration and resources it is recommended that the WECHU revise the current fee structure.

BACKGROUND

In 2022, 1156 seasonal accommodations were inspected, at least once, in WEC. These inspections are mandated under Part III of the Health Protection and Promotion Act (HPPA) and the Ontario Public Health Standards: Requirements for Programs, Services and Accountability 2018 (OPHS) and its related protocols and guidelines. The Environmental Health (EH) Department also works with Services Canada and the Foreign Agricultural Resource Management Services (FARMS) to approve all seasonal accommodations for occupancy. Our staff also works with local fire, building, and by-law enforcement to address issues that are associated with IAWs accommodations. The inspection and complaint process requires a great deal of coordination, tracking, and documentation as multiple government agencies are involved with the entire process, including the Mexican and Jamaican Consulates.

PROPOSED MOTION

Whereas the WECHU’s work related to seasonal housing is mandated by Part III of the Health Protection and Promotion Act (HPPA) and the Ontario Public Health Standards: Requirements for Programs, Services and Accountability 2018 (OPHS) and its related protocols and guidelines; and

Whereas the funds collected through a fee-for-service program have been utilized to support human resources in the WECHU Leamington office to meet the requirements of the seasonal housing program since 2020; and

Whereas the number of seasonal housing accommodation that requires inspections, documentation, and processing through the WECHU has significantly increased since 2020; and

Whereas the additional funds generated through an increase in the current fee structure would be more reflective of the rising operational costs attributed to this program.

Now therefore be it resolved that the Windsor-Essex County Board of Health supports a fee increase of $25 (increase from $75 to $100) increase for annual licensing inspections in the seasonal housing inspection program; and

FURTHER THAT, the Windsor-Essex County Board of Health supports the utilization of monies generated from the seasonal housing licensing inspection fees be used to support the increasing costs of program implementation within the Environmental Health Department, including supporting the department’s clerical staff complement.