Rosemary Nestor
Acting Manager, Environmental Health Policy and Programs Unit
Office of the Chief Medical Officer of Health, Public Health
Ontario Ministry of Health
via email: rosemary.nestor@ontario.ca
April 29th, 2026
Dear Rosemary,
We are writing on behalf of Ontario Dietitians in Public Health (ODPH) to thank you for the opportunity to contribute to proposed amendments to the Ontario Food Premises Regulation (O. Reg. 493) within the Health Protection and Promotion Act.1 We applaud your commitment to exploring policy options to improve access to donated wild game meat in Ontario.
Following consultation with Indigenous Public Health colleagues and contributors as well as informed by a review of relevant literature and lived experiences, we have gained important perspective on the impacts of current policies and practices. We are not speaking on behalf of our partners; rather, we are learning from them and reflecting this understanding in our work and in the perspectives shared here.
ODPH is the professional association of Registered Dietitians working in Ontario’s public health system, with strategic priorities that include advancing health equity and strengthening Indigenous engagement. It is from this standpoint that we offer this correspondence. We acknowledge the expertise of our Public Health Inspector colleagues and defer to them regarding food safety considerations related to this regulation. We remain committed to addressing systemic barriers that undermine health and to supporting equitable access and opportunities for all populations, while continuing to learn, reflect, and act in solidarity with Indigenous communities.
Background Information
ODPH supports several themes identified in earlier engagement activities related to this regulation, including:
- Traditional foods are vital to Indigenous community connection, cultural identity and continuity, and cross generational learning opportunities; however, current regulations unnecessarily restrict these longstanding practices in schools, daycares, emergency food programs, hospitals, and other community settings, underscoring the importance of reducing regulatory barriers.
- Work with Indigenous groups in a meaningful way to identify traditional animals that could be included in the current permitted list.
As noted by Robin et al, “the Canadian settler state undermined and continues to undermine Indigenous food sovereignty through the imposition of food safety rules and regulations across federal, provincial, and territorial jurisdictions”.2 Both historical and contemporary legislation continue to reflect and reinforce colonial systems of oppression. These regulations are predicated on a western system of domesticated animals. Since pre-colonial Indigenous diets did not include animal domestication,3 these policies reflect a colonial framework that overlooks Indigenous wild harvesting practices and undermines Indigenous wellbeing.4 As written, the current regulation perpetuates negative connotations about traditional or country foods. By mandating the use of ‘conspicuous signage’ and collection of patron data, this can create the illusion that this food is ‘dangerous’ or ‘dirty’. This practice also disregards the intergenerational transmission of knowledge related to food safety and sustainable harvesting practices.
The regulation also prevents community agencies, including schools, daycares, food banks, hospitals, and meal programs, from serving wild game meat. Expanding access to wild game through Indigenous community organizations presents an opportunity to reduce barriers to culturally significant foods while advancing and actualizing Indigenous food sovereignty. Such changes would support Indigenous-led approaches to food systems, grounded in traditional knowledge, cultural practices, and community-defined standards of health and safety. As outlined in Equity: Traditional Food as Medicine, a briefing by Nourish, “Indigenous cultures and food systems are intrinsically linked to their local ecosystems, which traditionally have included hunting, fishing, cultivating and harvesting wild game and country foods such as caribou, berries, or rabbit. Both the foods and these practices are inseparable from many Indigenous communities’ understanding of health and well-being”.5 Despite this, Elders and Knowledge Keepers working with Nourish identify legislative restrictions, exclusionary Western-based guidelines, and harmful misconceptions—such as beliefs that Indigenous foods are “unsafe”—as key barriers to providing traditional food.5
Our Position
Food is a basic human right; however, previous and ongoing colonization continues to impact the access to traditional foods and cultural food knowledge. It is our collective responsibility to recognize the distinct health needs of Indigenous Peoples and remove barriers to accessing wild game in urban settings that contribute to worsening health inequities. Culturally significant food supports wellbeing in many ways- it is sacred, relational, nourishing, and traditional food improves diet quality and overall wellbeing among Indigenous Peoples. It is important to understand that not being able to “self-determine one’s food system, and thus health and culture, can result in feelings of isolation, a lack of belonging and in some cases dis-ease”.2
Wild game meat is a nutritious source of protein in the diet, as supported by Canada’s Dietary Guidelines for Health Professionals and Policy Makers.6 Traditional food also improves diet quality among Indigenous Peoples .6 However, it is important to acknowledge that food serves many purposes beyond nutrition and physical health, cultural practices and values such as kindness, generosity, reciprocity and sharing are all a part of traditional food systems. We believe that it is our collective responsibility to affirm food as medicine and acknowledge that traditional food practices and knowledge support not only physical and mental health, but also spiritual and emotional wellbeing. As noted in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), the Provincial government must respect and uphold Indigenous peoples’ inherent rights, including rights to traditional medicines, health practices and the highest attainable standard of physical and mental health.7
Any expansion to the Ontario Food Premises Regulation (O. Reg. 493), however, should carefully account for long-term resource sustainability, including potential overharvesting risks, while recognizing and respecting the knowledge and stewardship practices of traditional hunters that guide sustainable harvesting.
Recommendations:
- Meaningfully engage with Indigenous community members impacted by regulations to Indigenous food systems as an ongoing process, where connections are prioritized over quick outcomes.8
- Continue to engage with public health staff, including Public Health Inspectors, Registered Dietitians, and Indigenous specific positions, to ensure that the regulation and subsequent policies and procedures balance regulatory goals with operational realities.
- Continue to explore the feasibility of expanding the current legislation to allow for the donation, preparation and serving of wild game meat in areas such as schools, daycares, hospitals, community settings, emergency food programs (i.e. food banks) and other agencies serving Indigenous clientele.
- Maintain food safety standards while removing unnecessary regulatory burdens that create disproportionate burden or contribute to the stigmatization of wild game meat compared to other animal protein sources.
- Ensure that staff involved in the development, interpretation, implementation, and oversight of regulations impacting Indigenous food systems receive ongoing cultural competency training to support culturally informed decision-making and consistent application of public health standards, in alignment with Truth and Reconciliation call to action #23.9
In conclusion, ODPH is in support of improved access to wild game meat in Ontario. We would welcome the opportunity to consult on the next steps in the process.
Sincerely,
Kim McGibbon, RD Luisa Magalhaes, RD
Co-Chair ODPH Food Insecurity Workgroup Chair, ODPH
Cc:
The Honorable Sylvia Jones, Minister of Health
via email: sylvia.jones@pc.ola.org
Deborah Richardson, Deputy Minister of Health
via email: Deborah.Richardson@ontario.ca
References
- Ontario Ministry of Health. Reg. 493/17: Food Premises. Health Protection and Promotion Act, R.S.O. 1990, c. H.7. Toronto (ON): Government of Ontario; 2017. Available from: https://www.ontario.ca/laws/regulation/170493
- Robin T, Burnett K, Parker B, Skinner K. Safe food, dangerous lands? Traditional foods and Indigenous Peoples in Canada. Frontiers in Communication. 2021; 6:749944. doi:10.3389/fcomm.2021.749944
- Kuhnlein HV, Receveur O. Traditional animal foods of Indigenous Peoples of northern North America: the contributions of wildlife diversity to the subsistence and nutrition of Indigenous cultures. Centre for Indigenous Peoples’ Nutrition and Environment (CINE); 2017.
- Dennis M, Robin T. Healthy on our own terms. Critical Dietetics. 2020;5(1):4–11. doi:10.32920/cd.v5i1.1333
- Equity: traditional food as medicine. Innovation Brief. 2022 Oct. Available from: https://nourishleadership.ca/knowledge-hub/innovation-brief-traditional-food-as-medicine/
- Health Canada. Canada’s dietary guidelines for health professionals and policy makers. Ottawa (ON): Government of Canada; 2019. Available from: https://food-guide.canada.ca/sites/default/files/artifact-pdf/CanadasDietaryGuidelines.pdf
- United Nations. United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). New York (NY): United Nations; 2007. Available from: https://www.ohchr.org/sites/default/files/Documents/Publications/Declaration_indigenous_en.pdf
- Indigenous Primary Health Care Council. First Nation, Inuit, and Metis Community Engagement Guide for Public Health Agencies. 2025. Available from: https://iphcc.ca/post_resources/first-nation-inuit-and-metis-community-engagement-guide-for-public-health-agencies/
- National Centre for Truth and Reconciliation. Truth and Reconciliation Commission of Canada: Calls to Action. 2015. Available from: https://nctr.ca/about/truth-and-reconciliation-commission-of-canada-calls-to-action/
