Food Insecurity Archives - Ontario Dietitians in Public Health

May 11, 2026

The Honourable Julie Dabrusin, P.C., M.P.

Minister of the Environment, Climate Change and Nature

Subject: Submission on 2026-2029 Draft Federal Sustainable Development Strategy

Dear Minister Dabrusin,

Please accept this submission on behalf of Ontario Dietitians in Public Health (ODPH) in response to the 2026-2029 Draft Federal Sustainable Development Strategy. ODPH is the official association of Registered Dietitians working in Ontario’s public health system. We are commenting on two goals included in the draft SDS: Goal 1.3 Reduce poverty in Canada and Goal 2.2 Strengthen the resilience and sustainability of Canadian agriculture.

Goal 1.3 Reduce poverty in Canada

As public health professionals guided by evidence and committed to health equity and the upstream determinants of health, we support Goal 1.3, which aligns with efforts to improve the conditions that enable healthy eating and overall well-being. We recommend strengthening the Strategy through a more explicit focus on advancing a national Guaranteed Livable Basic Income (GLBI).

Since 2015, ODPH has strongly supported the concept of a GLBI as an effective policy lever to reduce household food insecurity (HFI) in Canada (1). HFI, defined as inadequate or insecure access to food due to financial constraints, is a serious public health issue, a marker of material deprivation, and a matter of public policy (2). It ranges from compromised diet quality to missed meals and, in severe cases, going days without eating.

In 2025, HFI in Canada remains near its highest level since national monitoring began nearly 20 years ago, affecting one in four Canadians (24%), or approximately 9.8 million people, including 2.4 million children (3). These figures exclude First Nations communities and the territories, where rates are often even higher. Provincial rates varied significantly, ranging from 19.8% in Quebec to 30.9% in Alberta, highlighting the need for a coordinated national response (3).

HFI is fundamentally an income issue. In 2023, 70% of households relying on social assistance experienced HFI, and notably, 58.6% of food-insecure households reported employment as their main source of income (3). This reflects a growing prevalence of low-wage, precarious employment, unstable hours, and a lack of essential benefits that undermines financial stability (5). At the same time, the cost of living continues to rise, with substantial increases in the cost of shelter, food, and transportation since 2021 (4).

The health impacts of HFI are profound. Canadian research consistently shows strong associations between HFI and poorer physical and mental health outcomes, including increased risk of hospitalization, longer hospital stays, and premature mortality (6). The likelihood of depression, anxiety, and other mental health conditions increases with the severity of HFI (6). These outcomes place significant strain on Canada’s publicly funded healthcare system (7), underscoring the importance of income-based interventions that can both improve population health and reduce public expenditures. These savings must be considered with a national GLBI.

Despite decades of reliance on charitable responses, food banks are not a solution to HFI. In March 2025 alone, food banks across Canada recorded over 2 million visits—a nearly 100% increase compared to 2019 (4). Yet, only about one-quarter of food-insecure households use food banks, and for those who do, food insecurity typically persists (8). Recent declarations of food insecurity emergencies by municipalities[1] across Ontario further highlight the scale and urgency of this issue.

Evidence is clear that policies which improve income adequacy such as public pensions, child benefits, and minimum wage increases, lead to reductions in HFI (8). The most compelling example is Canada’s public pension system, where eligibility has been shown to reduce food insecurity among low-income seniors by nearly 50% (10). Extending this approach to working-age adults through a GLBI would establish a consistent income floor, ensuring individuals and families can meet basic needs regardless of employment status.

According to the Parliamentary Budget Officer, a national GLBI would reduce poverty by up to 34% for nuclear families and 40% for economic families, based on the Market Basket Measure (11). The National Advisory Council on Poverty has also highlighted the potential of a targeted basic income to ensure all individuals reach at least Canada’s Official Poverty Line (12).

Given the scale of household food insecurity and its significant health and economic impacts, Canada requires coordinated, income-based policy solutions. Advancing a GLBI would directly address the root causes of poverty, strengthen financial resilience, reduce inequalities, and improve health and social outcomes across the population.

[1] City of Mississauga; City of Toronto; City of Kingston; City of Brantford; Town of Smiths Falls;  City of Brockville; Town of Cochrane; City of Orillia

Recommendation:

To strengthen Goal 1.3, ODPH recommends the following:

Include a new implementation strategy to advance a national guaranteed livable basic income. For example: Implementation strategy 1.3.1.5: Develop and implement a national framework for a guaranteed livable basic income, such as that proposed in Bill S-206 (13), to ensure all individuals can meet basic needs, reduce poverty, and improve health and social outcomes.

Goal 2.2 Strengthen the resilience and sustainability of Canadian agriculture

ODPH works to advance food systems that are healthy, just, and sustainable. In this capacity, we express our support for Goal 2.2, which aligns with public health objectives to support healthy eating. We also recommend strengthening the Strategy through a more explicit focus on protecting Canada’s prime agricultural lands as a foundational element of a resilient and sustainable food system.

Agricultural Land Loss

The loss of prime agricultural land poses a significant and growing threat to Canada’s long-term food security and sustainability. Prime agricultural lands comprised of the highest capability soils, are a non-renewable, finite resource essential to the existence of a healthy, sustainable food system. Class 1, 2 and 3 are considered prime agricultural soils that have the highest capacity for agricultural production.

Only 5.4% of Canada’s land base is free of severe constraints for agricultural production with the largest share located in Ontario (14). Loss of farmland is a growing concern. In Ontario alone, more than 319 acres of farmland were lost per day between 2016 and 2021 (15). Once developed, these lands are effectively lost forever. Protecting them is critical not only for food production but also for the long-term health of our economy, communities, and ecosystems.

The conversion and fragmentation of prime agricultural lands disrupt the peri-urban agricultural base that supplies regional food markets and reduces local food self-reliance. In the context of rising inflation, supply-chain disruptions, and global trade instability, protecting farmland is critical to strengthening Canada’s food system, supporting domestic food production and maintaining economic resilience.

Land use planning decisions directly influence access to nutritious, affordable, and locally produced food. As such, protecting agricultural land is not only an environmental or economic priority—it is a public health imperative. Sustainable land use planning is essential to advancing community food security and enabling healthier populations.

Without explicit federal recognition and measurement of agricultural land loss, Goal 2.2 cannot fully deliver on its aim to strengthen the resilience and sustainability of Canadian agriculture.

Food Sovereignty

Recent global disruptions have underscored the importance of food sovereignty and the risks associated with over-reliance on imported food and complex global supply chains. Food supply chain weaknesses and heavy reliance on imports and processing capacity render Canadian communities vulnerable.

Canada currently imports approximately 30% of all food and beverages, including 80% of fruit and 60% of vegetables. This reliance increases vulnerability to external shocks and limits national and regional resilience (16).

Canada depends on foreign ports, global shipping routes, intercontinental trucking networks, and just-in-time distribution models to feed its residents, which assumes uninterrupted energy, transportation, and communications infrastructure (17). To strengthen resilience, Canada’s Sustainable Development Strategy must go beyond domestic production and export growth by leveraging existing community infrastructure and capacity and investing in agri-food resources that improve access to affordable, nutritious food while supporting economic stability for agricultural producers.

Achieving food sovereignty requires a strong policy foundation that protects the essential resource underpinning the food system: agricultural land. Without safeguarding prime agricultural lands, efforts to build resilience, sustainability, and self-reliance will be fundamentally constrained.

Addressing the interconnected challenges of climate change, community food security, and population health requires integrated, cross-sectoral approaches that consider environmental, economic, and social factors. Collaboration across all orders of government—federal, provincial, territorial, municipal—and with Indigenous partners is essential to ensuring that agricultural viability, community well-being, and long-term sustainability remain central to policy development.

Recommendations:

To strengthen Goal 2.2 and support a resilient, sustainable, and equitable food system, ODPH recommends the following:

Explicitly recognize the protection of prime agricultural lands as a core component of agricultural sustainability and community food security within Goal 2.2.
Support policies and investments that enable diversified production of nutritious foods, while strengthening local and regional food supply chains to improve access to healthy food and enhance farm viability.
Introduce a measurable target (e.g., Target 2.2.2) to track and report on the annual percentage of agricultural land loss across Canada.
Include a corresponding implementation strategy to support action on this target. For example, Implementation strategy 2.2.2.1: Support the protection of prime agricultural lands by collaborating with provinces, territories, municipalities, and Indigenous partners to strengthen land use planning policies, and establish consistent national monitoring and reporting on farmland conversion, including the loss of high-capability agricultural soils.

Just and sustainable food systems begin with secure access to land. Protecting Canada’s prime agricultural lands is essential to ensuring long-term access to fresh, nutritious, and affordable food. Embedding strong farmland protection measures within the Federal Sustainable Development Strategy will advance food system resilience, support food sovereignty, and promote the health and well-being of Canadians.

We respectfully request that this submission be considered as part of the official consultation process.

Thank you for your consideration.

Sincerely,

Luisa Magalhaes, RD, MHSc

Chair, Ontario Dietitians in Public Health

Cc.
Ontario Federation of Agriculture (OFA), Drew Spoelstra, OFA President, drew.spoelstra@ofa.on.ca

National Farmers Union of Ontario (NFU), Max Hansgen, NFU-O President, president@nfuontario.ca
Ontario Farmland Trust, Martin Straathof, Executive Director, info@ontariofarmlandtrust.ca

References:

Ontario Dietitians in Public Health (ODPH). Position Statement and Recommendations on Responses to Food Insecurity. (2020). Available at: https://odph.ca/section/food-insecurity/
Food Insecurity Policy Research (PROOF). Understanding Household Food Insecurity [webpage online]. Available at: https://proof.utoronto.ca/food-insecurity/
Food Insecurity Policy Research (PROOF). (2025) New Data on Household Food Insecurity in 2025. Available at: https://proof.utoronto.ca/2026/new-data-on-household-food-insecurity-in-2025/
Food Banks Canada. (2025). Hunger Count 2025. Available at: https://content.foodbankscanada.ca/wordpress/2025/10/FBC_HungerCount_EN_2025.pdf
Martin JC and Lewchuk W. (2018). The Generation Effect: Millennials, employment precarity and the 21st Century workplace. Available at: https://pepso.ca/documents/the-generation-effect-full-report.pdf
Food Insecurity Policy Research (PROOF). (2023). What are the implications of food insecurity for health and health care? Available at: https://proof.utoronto.ca/food-insecurity/what-are-theimplications-of-food-insecurity-for-health-and-health-care/
Tarasuk V. (2017). Implications of a basic income guarantee for household food insecurity. Northern Policy Institute – Research Paper No. 24. Available at: https://proof.utoronto.ca/wpcontent/uploads/2017/06/Paper-Tarasuk-BIG-EN-17.06.13-1712.pdf
Li T, Fafard St-Germain AA, Tarasuk V. (2023). Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Available at https://proof.utoronto.ca/
Food Insecurity Policy Research (PROOF). What can be done to reduce food insecurity in Canada? Available at: https://proof.utoronto.ca/food-insecurity/what-can-be-done-to-reduce-food-insecurity-incanada/
McIntrye L, Dutton D, Kwok C et al. (2016). Reduction of food insecurity in low-income Canadian seniors as a likely impact of a Guaranteed Annual Income. Canadian Public Policy. 42(3), 274-286. Available at: https://utppublishing.com/doi/10.3138/cpp.2015-069
Office of the Parliamentary Budget Officer. (2025). A Distributional Analysis of a National Guaranteed Basic Income – Update. Available at: https://www.pbo-dpb.ca/en/publications/RP-2425-029-S–distributional-analysis-national-guaranteed-basic-income-update–analyse-distributive-unrevenu-base-garanti-echelle-nationale-mise-jour
Government of Canada. (2025). 2025 Report of the National Advisory Council on Poverty. Available at: https://www.canada.ca/en/employment-social-development/programs/poverty-reduction/nationaladvisory-council/reports/2025-annual.html
Parliament of Canada. Bill S-206 (45-1): An Act to develop a national framework for a guaranteed livable basic income [Internet]. Ottawa, ON: Parliament of Canada; 2025 May 26. Available from: www.parl.ca/LegisInfo/en/bill/45-1/S-206
Ontario Farmland Trust. (March 19, 2026). Farmland Forum: Municipalities and Farmland Protection. Webinar.
Statistics Canada. (2022). Table 32-10-0156-01: Farms classified by total farm area, Census of Agriculture historical data. Available at: Farms classified by total farm area, Census of Agriculture historical data
University of British Columbia. Resource, Environment and Sustainability (IRES) and School of Public Policy and Global Affairs (SPPGA). Available at: The Story of Canada’s Fruit and Vegetable Supply
The Functionary. Kathryn May. (2026) Available at: Community food systems are critical to Canada’s national security

Recommendations

That the government support the implementation of a Guaranteed Livable Basic Income (GLBI) to enable Canadians to meet their basic needs, reduce poverty, and improve health and social outcomes.
That the government raise the maximum Canada Disability Benefit (CDB) to cover the true costs of living with a disability.
That the government increase the Canada Child Benefit (CCB) for low-income families.

Situation

Household food insecurity (HFI) in Canada remains near its highest level since monitoring began nearly 20 years ago. In 2025, 24% of people in the ten provinces lived in a food insecure household (1). This represents 9.8 million people, including 2.4 million children (nearly one in four), living in households that struggled to afford food (1). These figures exclude First Nations communities and the territories, where rates are often even higher. Since 2022, the prevalence of moderate and severe HFI have increased significantly, indicating the urgency of this growing public health problem (2).

Background

About Ontario Dietitians in Public Health (ODPH)

Ontario Dietitians in Public Health (ODPH) is the professional association of Registered Dietitians working in Ontario’s public health system. As public health professionals, we are guided by evidence, a commitment to equity and upstream determinants of health.

Household Food Insecurity is an Income Issue

HFI is the inadequate or insecure access to food due to financial constraints (3). The experience of HFI can range from concerns or problems of food access (marginal HFI) to the inability to afford a balanced diet and/or missing meals (moderate HFI), to extreme cases of not eating for days (severe HFI).

In 2023, 70% of households receiving social assistance experienced HFI, while 60% of food insecure households in Canada relied on employment income (4). A 2025 Canadian study further found that nearly 90% of those employed have a primary earner with a permanent, full-time job (5). These findings are indicative of income inadequacy affecting households on social assistance and those with employment due to low wages, precarious work, inadequate benefits, and rising costs of housing, food and transportation. HFI is a highly sensitive measure of pervasive material deprivation making it an important measure for understanding poverty and guiding policy decisions.

Health and Economic Impacts

HFI is strongly associated with poorer physical and mental health outcomes, including higher rates of hospitalization, longer hospital stays, and increased risk of premature mortality (3). The likelihood of depression, anxiety, and other mental health conditions increases with the severity of HFI (3). These outcomes place significant strain on Canada’s publicly funded healthcare system and federal health transfers, underscoring the importance of income-based interventions that can both improve population health and reduce public health expenditures.

Current Responses Are Not Ineffective

It is unacceptable that the charitable sector and community-based food programs, including student nutrition programs, are burdened with the responsibility to respond to HFI. Recent declarations of food insecurity emergencies by municipalities[1] across Ontario further highlight the scale and urgency of this issue.

Similarly, while the Canada Groceries and Essentials Benefit was intended to help Canadians afford food and other necessities, these short-term and modest income supplements are insufficient to address the structural drivers of HFI (6,7).

[1] City of Mississauga; City of Toronto; City of Kingston; City of Brantford; Town of Smiths Falls; City of Brockville; Town of Cochrane; City of Orillia

Evidence and Impacts

Recommendation 1 – That the government commit to the implementation of a Guaranteed Livable Basic Income (GLBI), such as that proposed in Bill S-206, so that all Canadians can meet their basic needs, reduce poverty, and improve health and social outcomes.

Evidence consistently demonstrates that policies which improve income adequacy such as public pensions, child benefits, and minimum wage increases, lead to reductions in HFI (3). The most compelling example is Canada’s public pension system, where eligibility has been shown to reduce HFI among low-income seniors by nearly 50% (8). Extending this approach to working-age adults through a GLBI would establish a consistent income floor, ensuring that all individuals and families can meet their basic needs regardless of employment status.

According to the Parliamentary Budget Officer, a national guaranteed basic income would reduce poverty by up to 34% for nuclear families and 40% for economic families, based on the Market Basket Measure (9). The National Advisory Council on Poverty has similarly emphasized that a targeted basic income would ensure all individuals reach at least Canada’s Official Poverty Line (10).

Given the scale of HFI and its significant health and economic impacts, Canada requires coordinated, income-based policy solutions. Advancing a GLBI would directly address the root causes of poverty, improve financial resilience, reduce inequalities, and improve health and social outcomes across the population.

Recommendation 2 – That the government raise the maximum Canada Disability Benefit (CDB) to cover the true costs of living with a disability.

At its current maximum amount of $200 per month, the CDB will not lift households out of poverty anywhere in Canada. Though the CDB does reduce the depth of poverty by bringing incomes closer to the deep poverty line in some areas, this is not enough to end disability poverty.

People with disabilities face significantly higher rates of HFI compared to those without disabilities. According to Statistics Canada, 26.4% of individuals with disabilities reported some level of HFI, more than double the rate among those without disabilities (12.5%) (11). The severity and number of disabilities further increase this risk. Even after adjusting for various sociodemographic factors, people with disabilities remain twice as likely to experience HFI (12).

Without an adequate CDB, people with disabilities will continue to be disproportionately affected by HFI. Immediate action is needed to ensure the CDB truly meets the needs of those it is intended to support.

Recommendation 3 – That the government increase the Canada Child Benefit (CCB) for low-income families.

The introduction of the CCB in 2016 decreased severe food insecurity among low-income families with children by about one-third (13,14). Expanding and increasing the CCB – particularly for low-income households – would further reduce the prevalence and severity of household food insecurity (15,16). The additional amount provided by the CCB to families with children under the age of six has been shown to reduce their risk of household food insecurity (14).

In 2024, nearly one in three children under 18 (32.9%) in the ten provinces lived in a food-insecure household (1). This indicates that the CCB is insufficient to meet the needs of the most vulnerable families (19). The poverty rate for children under age 18 in Ontario more than doubled to 12% in 2023 from a low of 5.6% in 2020 (20).

Children with parents who do not have regularized immigration status are unfairly and arbitrarily excluded from the CCB. Compared to the general Canadian population, non-permanent residents have a much higher poverty rate, and their children are among those most in need of financial support. They are caught in an unfair system that requires them to contribute to the tax system but excludes them from benefiting from tax-delivered supports such as the CCB (21).

References

Food Insecurity Policy Research (PROOF). (2026) New data on household food insecurity in 2025. Available at: https://proof.utoronto.ca/2026/new-data-on-household-food-insecurity-in-2025/
Government of Canada. (2024). Levels of food insecurity increased in 2022 after being relatively stable from 2017 to 2021. Available at: https://www150.statcan.gc.ca/n1/daily-quotidien/241016/dq241016b-eng.htm
Li T, Fafard St-Germain AA, Tarasuk V. (2023). Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Available at https://proof.utoronto.ca/
Food Insecurity Policy Research (PROOF). (n.d.) Who are most at risk of household food insecurity? Available at: https://proof.utoronto.ca/food-insecurity/who-are-most-at-risk-of-household-food insecurity/#:~:text=Food%20insecurity%20remains%20a%20serious,people%20with%20a%20single%20income.
Food Insecurity Policy Research (PROOF). (2026). The Main Income Earner of Most Food-Insecure Working Households Has a Permanent, Full-Time Job, New Research Reveals. Available at: https://proof.utoronto.ca/2026/the-main-income-earner-of-most-food-insecure-working-households-has-a-permanent-full-time-job-new-research-reveals/
White A. (2026) A step in the right direction: The new Canada Groceries and Essentials Benefit in context. Maytree. Available at: https://maytree.com/publications/a-step-in-the-right-direction-the-new-canada-groceries-and-essentials-benefit-in-context/
Samson R, Yassin S, Petit G. (2026). Slaying myths about income support. Policy Options. Available at: https://policyoptions.irpp.org/2026/02/income-support-myths/
McIntrye L, Dutton D, Kwok C et al. (2016). Reduction of food insecurity in low-income Canadian seniors as a likely impact of a Guaranteed Annual Income. Canadian Public Policy. 42(3), 274-286. Available at: https://utppublishing.com/doi/10.3138/cpp.2015-069
Office of the Parliamentary Budget Officer. (2025). A Distributional Analysis of a National Guaranteed Basic Income – Update. Available at: https://www.pbo-dpb.ca/en/publications/RP-2425-029-S–distributional-analysis-national-guaranteed-basic-income-update–analyse-distributive-unrevenu-base-garanti-echelle-nationale-mise-jour
Government of Canada. (2025). 2025 Report of the National Advisory Council on Poverty. Available at: https://www.canada.ca/en/employment-social-development/programs/poverty-reduction/nationaladvisory-council/reports/2025-annual.html
Gupta S, Fernandes D, Aitken N, Greenberg L. (2024). Household food insecurity among persons with disabilities in Canada: findings from the 2021 Canadian Income Survey. Health Rep. Available at: https://www150.statcan.gc.ca/n1/pub/82-003-x/2024008/article/00002-eng.htm
Fafard St-Germain AA, Li T, Tarasuk B. (2025). Changes in households’ vulnerability to food insecurity in Canada before and after the COVID-19 pandemic. Available at: https://www150.statcan.gc.ca/n1/pub/82-003-x/2025012/article/00001-eng.htm
Brown EM, Tarasuk V. (2019). Money speaks: Reductions in severe food insecurity follow the Canada Child Benefit. Available at: www.sciencedirect.com/science/article/pii/ S0091743519303524?via%3Dihub
Men F, Fafard St-Germain AA, Ross K, Remtulla R, Tarasuk V. (2023). Effect of Canada Child Benefit on Food Insecurity: A Propensity Score−Matched Analysis. Available at: www.sciencedirect.com/science/article/pii/S0749379723000375?via%3Dihub
Government of Canada. (2025). Canada Child Benefit (CCB) – Who can apply. Available at: www.canada.ca/en/revenue-agency/services/child-family-benefits/canada-child-benefit/who-apply.html
Government of Ontario. Ontario Child Benefit. (2025). Available at: www.ontario.ca/page/ontario-child-benefit
Brown EM, Tarasuk V. (2019). Money speaks: Reductions in severe food insecurity follow the Canada Child Benefit. Available at: www.sciencedirect.com/science/article/pii/ S0091743519303524?via%3Dihub
Men F, Fafard St-Germain AA, Ross K, Remtulla R, Tarasuk V. (2023). Effect of Canada Child Benefit on Food Insecurity: A Propensity Score−Matched Analysis. Available at: www.sciencedirect.com/science/article/pii/S0749379723000375?via%3Dihub
Food Insecurity Policy Research (PROOF). (2023). A more generous Canada Child Benefit for low-income families would reduce their probability of food insecurity. Available at: https://proof.utoronto.ca/2023/a-more-generous-canada-child-benefit-for-low-income-families-would-reduce-their-probability-of-food-insecurity/
White A. Maytree. (2025) Poverty rising: How Ontario’s strategy failed and what must come next. Available at: https://maytree.com/publications/ poverty-rising-how-ontarios-strategy-failed-and-what-must-come-next/#:~:text=The%20Ontario%20 Child%20Benefit%20(OCB,of%20child%20poverty%20in%20Ontario
Income Security Advocacy Centre. (2018). Every Child Counts: Making sure the Canada Child Benefit is a benefit for all children. Available at: https://incomesecurity.org/wp-content/uploads/2020/04/Every-Child-Counts-Canada-Child-Benefit-for-All-September-2018.pdf

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/

Ontario Dietitians in Public Health (ODPH) appreciates the opportunity to offer input on Ontario’s 2026 budget consultation. ODPH is the professional association of Registered Dietitians (RDs) working in Ontario’s public health system. We are recognized leaders in public health nutrition representing local public health agencies across Ontario. One of ODPH’s key priorities is working towards effective solutions to reduce household food insecurity (HFI).

HFI is the inadequate or insecure access to food due to financial constraints (Li et al., 2023). The experience of HFI can range from worrying about not having enough food (marginal HFI), to the inability to afford a balanced diet and/or missing meals (moderate HFI), to extreme cases of not eating for days (severe HFI). HFI is a critical indicator of a household’s financial situation and a highly sensitive measure of material deprivation, making it an important measure for guiding policy decisions.

Among households reporting HFI, those reliant on social assistance experience the highest prevalence and severity of HFI. In 2023, 70% of households relying on Ontario Works (OW) or the Ontario Disability Support Program (ODSP) were food-insecure and 43% were severely so (PROOF, 2025a). Ontario’s social assistance rates remain far below the poverty line ‒ most recipients living in deep poverty earn less than 75% of the Market Basket Measure, Canada’s Official Poverty Line (Laidley & Oliviera, 2025). Although Ontario does provide limited nutrition-related financial supports, such as the Pregnant and Breastfeeding Nutritional Allowance and the Special Diet Allowance, these allowances are far below what is needed to meet basic nutritional requirements. HFI is strongly linked to income. As income decreases, both the risk and severity of HFI increases, making income-based policy solutions critical.

The urgency is evident with severe HFI in Ontario rising markedly from 4.8% of households in 2022 to 7.9% in 2024 (Ontario Agency for Health Protection and Promotion, 2025). HFI is a major financial liability for Ontario’s healthcare system. Adults living with HFI account for a disproportionate share of health care costs, including mental health-related emergency visits and hospitalizations, with the greatest costs associated with severe HFI (PROOF, ND). Without effective policy action, HFI will continue to escalate with worsening consequences to Ontario’s economic progress and to the health and well-being of Ontarians.

ODPH recommends increasing social assistance rates and nutritional allowances to reflect actual costs of living and indexing Ontario Works rates to inflation.

Recommendation 1: Increase Ontario Works (OW) rates to align with the actual cost of food and housing and index rates to inflation annually.

OW rates have not increased since October 1, 2018, despite an inflation rate of more than 20% since then, significantly reducing purchasing power and living standards (Tabarra and Laidley, 2024).

Food cost data collected in May-June 2024 by 32 Ontario public health units were compiled and compared to OW incomes for various household scenarios. The analysis found that these households are unlikely to be able to afford the cost of food needed to meet the nutritional needs of all household members. Further, estimated monthly rent and other basic living costs exceed OW shelter and basic needs allowances by approximately $1000-$2000 per month (Ontario Agency for Health Protection and Promotion, 2025).

Recommendation 2: Increase Ontario Disability Support Program (ODSP) rates to align with the actual cost of food and housing.

ODPH commends the Ontario government’s efforts to support vulnerable Ontarians, including increasing the earned income exemption for ODSP from $200 to $1000 and indexing ODSP rate increases to inflation that began in July 2023. However, further action is needed to strengthen income security for ODSP recipients.

Food cost data collected in May-June 2024 by 32 public health units showed that a single adult and a single pregnant adult receiving ODSP would need to spend approximately 30% of their monthly income to afford a nutritionally adequate diet. This would leave just over $1,000 per month for rent and all other living expenses, estimated to exceed $2,100 per month (Ontario Agency for Health Protection and Promotion, 2025).

Recommendation 3: Increase the Pregnancy and Breastfeeding Nutritional Allowance and Special Diet Allowance for all eligible conditions.

The monthly allocations in the OW and ODSP Policy Directives for the Pregnancy/Breastfeeding Nutritional Allowance (PBNA) (ODSP Policy Directive 6.5 and OW Policy Directive 6.5) and Special Diet Allowance (SDA) (ODSP Policy Directive 6.4 and OW Policy Directive 6.6) have not increased in over a decade, even though the cost of food and infant formula have increased significantly.

Food cost data collected in May-June 2024 by 32 public health units, and compared with ODSP for a single adult, showed that 29% of monthly income would be required to purchase a nutritionally adequate diet. This would leave just over $1,000 per month for rent and all other living expenses, estimated to exceed $2,100 per month (Ontario Agency for Health Protection and Promotion, 2025).

Conclusion

The analyses of Ontario’s income security programs to actual cost of nutritious food and estimates of other living costs provide compelling evidence of the insufficiency of OW and ODSP, resulting in high risk of severe food insecurity, which is related to poorer health and well-being (Ontario Agency for Health Protection and Promotion, 2025).

ODPH calls for immediate and sustained investment to increase social assistance rates and nutritional allowances in Ontario. Without bold, measurable action, HFI will continue to undermine community well-being, strain municipal resources, deepen inequities and increase pressure on Ontario’s health care system. Investing in income security is both a social responsibility and an economic imperative.

References

Government of Ontario, Ministry of Labour, Immigration, Training and Skills Development. (2025) News Release: Ontario Raising Minimum Wage to Protect Workers. Available at: https://news.ontario.ca/en/release/1006550/ontario-raising-minimum-wage-to-protect-workers

Laidley J, Oliveira T. (2025) Welfare in Canada, 2024. Maytree. Retrieved from: https://maytree.com/

Li T, Fafard St-Germain AA, Tarasuk V. (2023) Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Retrieved from: https://proof.utoronto.ca/

Ontario Agency for Health Protection and Promotion (Public Health Ontario). (2025) Food insecurity & food affordability in Ontario. Toronto, ON: King’s Printer for Ontario. Retrieved from: https://www.publichealthontario.ca/en/Health-Topics/Health-Equity

Ontario Dietitians in Public Health. (2020) Position Statement and Recommendations on Responses to Food Insecurity. Available at: https://odph.ca/section/food-insecurity/

Ontario Living Wage Network. (2025) Updated 2025 Rates. Available at: https://www.ontariolivingwage.ca/updated_2025_rates

PROOF (Food Insecurity Policy Research). (2025a) Ontario Election 2025: Putting a plan for adequate social assistance on the table. Available at: https://proof.utoronto.ca/2025/ontario-election-2025-putting-a-plan-for-adequate-social-assistance-on-the-table/

PROOF (Food Insecurity Policy Research). (2025b) New data on household food insecurity in 2024. Available at: https://proof.utoronto.ca/2025/new-data-on-household-food-insecurity-in-2024/

PROOF (Food Insecurity Policy Research). (ND) What are the implications of food insecurity for health and health care? Available at: https://proof.utoronto.ca/food-insecurity/what-are-the-implications-of-food-insecurity-for-health-and-health-care/

Tabbara M and Laidley J. (2024) Too many income supports still aren’t indexed. Maytree. Available at: https://maytree.com/publications/too-many-income-supports-still-arent-indexed/

Tarasuk V, Li T, Fafard St-Germain AA. (2022) Household food insecurity in Canada, 2021. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Retrieved from: https://proof.utoronto.ca/

Le 7 janvier 2026

L’honorable Claude Carignan, sénateur, président du Comité des finances nationales Claude.Carignan@sen.parl.gc.ca

L’honorable Éric Forest, sénateur, vice-président du Comité des finances nationales Eric.Forest@sen.parl.gc.ca

L’honorable Clément Gignac, sénateur, membre du Comité des finances nationales Clement.Gignac@sen.parl.gc.ca

L’honorable Andrew Cardozo, sénateur, membre du Comité des finances nationales Andrew.Cardozo@sen.parl.gc.ca

L’honorable Pierre J. Dalphond, sénateur, membre du Comité des finances nationales PierreJ.Dalphond@sen.parl.gc.ca

L’honorable Rosa Galvez, sénatrice, membre du Comité des finances nationales Rosa.Galvez@sen.parl.gc.ca

L’honorable Martine Hébert, sénatrice, membre du Comité des finances nationales Martine.Hebert@sen.parl.gc.ca

L’honorable Joan Kingston, sénatrice, membre du Comité des finances nationales Joan.Kingston@sen.parl.gc.ca

L’honorable Jane MacAdam, sénatrice, membre du Comité des finances nationales Jane.MacAdam@sen.parl.gc.ca

L’honorable Elizabeth Marshall, sénatrice, membre du Comité des finances nationales Elizabeth.Marshall@sen.parl.gc.ca

L’honorable Krista Ross, sénatrice, membre du Comité des finances nationales Krista.Ross@sen.parl.gc.ca

Sara Gajic, greffière, Comité des finances nationales Sara.Gajic@sen.parl.gc.ca

Comité des finances nationales NFFN@SEN.PARL.GC.CA

Monsieur le président, Monsieur le vice-président, Mesdames et Messieurs les membres, Madame la greffière du Comité des finances nationales du Sénat du Canada,

L’organisme Diététistes en santé publique de l’Ontario (ODPH), l’association professionnelle des diététistes autorisés travaillant dans le système de santé publique de l’Ontario, vous écrit pour vous demander de soutenir le projet de loi S-206, Loi concernant l’élaboration d’un cadre national sur le revenu de base suffisant, actuellement à l’étude par le Comité des finances nationales du Sénat. Depuis 2015, l’association des Diététistes en santé publique de l’Ontario a fermement soutenu l’idée d’un revenu de base garanti comme levier politique efficace pour réduire le problème répandu de l’insécurité alimentaire des ménages au Canada.[1]

Le programme de recherche Food Insecurity Policy Research (PROOF) définit l’insécurité alimentaire des ménages (IAM) comme étant « l’accès insuffisant ou incertain à la nourriture en raison des contraintes financières » et ajoute qu’il s’agit d’un grave problème de santé publique, d’un indicateur de privation matérielle généralisée et d’un enjeu de politique publique.[2] L’expérience de l’insécurité alimentaire peut aller de préoccupations ou de problèmes d’accès à la nourriture (une IAM marginale) à l’incapacité de se permettre une alimentation équilibrée et/ou à des repas manqués (une IAM modérée), jusqu’à des cas extrêmes où les personnes sont privées de nourriture pendant plusieurs jours (une IAM grave). »

En 2024, l’insécurité alimentaire au Canada a atteint son niveau le plus élevé depuis le début de la surveillance nationale il y a près de 20 ans. Un Canadien sur quatre (25,5 %) habitant dans les dix provinces a connu l’insécurité alimentaire, ce qui représente environ 9,9 millions de personnes, dont 2,5 millions d’enfants – 75 % de ces enfants vivaient dans des ménages confrontés à une insécurité alimentaire modérée ou grave.[3] Ces estimations n’incluent pas les communautés des Premières Nations ni les territoires, où les taux sont généralement encore plus élevés, en particulier au Nunavut. Les taux provinciaux variaient considérablement, allant de 19,8 % au Québec à 30,9 % en Alberta, ce qui souligne la nécessité d’une réponse nationale coordonnée.3

L’insécurité alimentaire est fondamentalement une question de revenu, et pas seulement un « problème alimentaire ». En 2023, 70 % des ménages dont la principale source de revenu était l’aide sociale au Canada ont déclaré avoir connu l’insécurité alimentaire.³ Cependant, l’emploi n’est pas nécessairement une protection, 58,6 % des ménages en situation d’insécurité alimentaire déclarent que leur emploi est leur principale source de revenu, ce groupe affichant quand même la plus forte augmentation en insécurité alimentaire entre 2021 et 2022.³ Un récent sondage mené par les Banques alimentaires Canada a révélé que les bas salaires et le nombre d’heures de travail insuffisant figuraient parmi les principales raisons pour lesquelles les gens se tournaient vers les banques alimentaires.[4] Les recherches soulignent également une tendance croissante à la précarité des emplois, avec des horaires instables et un manque d’avantages sociaux essentiels, ce qui crée des défis importants pour la main-d’œuvre actuelle.[v] L’IAM est un indicateur essentiel de la situation financière d’un ménage, car les ménages qui n’ont pas les moyens de se nourrir ont également du mal à satisfaire d’autres besoins fondamentaux. Les revenus n’ont pas suivi le rythme de l’augmentation du coût de la vie : depuis 2021, l’indice des prix à la consommation a augmenté de 26 % pour le logement, de 25 % pour l’alimentation et de 20 % pour les transports.⁴

De nombreuses données canadiennes démontrent que l’insécurité alimentaire est étroitement liée à des effets néfastes sur la santé physique et mentale, outre l’influence d’autres déterminants sociaux de la santé. Des recherches établissant un lien entre les données sur l’insécurité alimentaire issues d’enquêtes sur la santé de la population et les dossiers administratifs de santé ont fourni des preuves solides que les personnes en situation d’insécurité alimentaire sont plus susceptibles d’être hospitalisées pour un large éventail de pathologies, de rester plus longtemps à l’hôpital et de mourir prématurément (avant l’âge de 83 ans) de toutes causes confondues à l’exception du cancer.[6] Il existe un lien particulièrement fort entre l’IAM et une mauvaise santé mentale. Le risque de souffrir de dépression, de troubles anxieux, de troubles de l’humeur ou de pensées suicidaires augmente avec la gravité de l’insécurité alimentaire, tant chez les adultes que chez les jeunes.⁶ Les conséquences de l’insécurité alimentaire sur la santé sont extrêmement coûteuses pour le système de santé public canadien.[7] Les politiques conçues dans le but de réduire l’insécurité alimentaire des ménages ont le potentiel de faire le contrepoids aux dépenses publiques considérables en matière de soins de santé pour les gouvernements fédéral, provinciaux et territoriaux. Ces économies doivent être prises en compte dans le cadre national proposé pour un revenu de base garanti.

Depuis plus de trois décennies, les banques alimentaires constituent la principale réponse à l’insécurité alimentaire au Canada. Malgré des investissements massifs dans un système alimentaire secondaire destiné aux personnes qui n’ont pas les moyens de se procurer de la nourriture de la manière la plus digne socialement (c’est-à-dire en achetant chez des détaillants alimentaires), les banques alimentaires ont plus que jamais du mal à répondre à la demande. En mars 2025, les banques alimentaires ont enregistré plus de 2 millions de visites au Canada, soit une augmentation de 5 % par rapport à mars 2024 et de 99,4 % par rapport à mars 2019.⁴Bien que les banques alimentaires puissent apporter une aide alimentaire temporaire, elles ne s’attaquent pas à la cause profonde de l’IAM, des revenus insuffisants et instables.¹ En fait, seul environ un quart des ménages en situation d’insécurité alimentaire ont recours aux banques alimentaires, et le problème persiste même pour ceux qui le font.[8]

Au cours des 12 derniers mois, plusieurs municipalités de l’Ontario ont déclaré des situations d’urgence en matière d’insécurité alimentaire, notamment Mississauga, en novembre 2024; Toronto en décembre 2024; Kingston, en janvier 2025; Brantford, en février 2025; Brockville, en juin 2025 et Orillia, en août 2025. Ces déclarations démontrent clairement que l’insécurité alimentaire a atteint un niveau critique dans tout l’Ontario, ce qui entraîne une demande insoutenable pour le système alimentaire caritatif et oblige les administrations municipales et les organisations communautaires à demander aux gouvernements fédéral et provincial d’intervenir avec des solutions politiques à long terme.

Les seules interventions qui ont démontré leur efficacité dans la réduction de l’insécurité alimentaire des ménages sont celles qui améliorent les revenus des ménages vulnérables.^[ix] Les recherches sur les politiques fédérales et provinciales en matière de revenus, notamment les pensions publiques pour les personnes âgées, l’aide sociale, les prestations pour enfants et le salaire minimum, ont montré une réduction de l’insécurité alimentaire lorsque ces interventions améliorent les revenus des ménages à faible revenu.⁸ Les recherches sur l’impact du régime de pensions publiques du Canada pour les personnes âgées constituent le parallèle le plus fort avec le revenu minimum garanti. Il a été démontré que le fait d’atteindre l’âge d’admissibilité à la pension publique réduit de près de 50 % le risque d’insécurité alimentaire chez les adultes à faible revenu et sans famille. ^[10]

La mise en place d’un revenu minimum pour les Canadiens en âge de travailler et leurs familles (similaire à l’aide que reçoivent les personnes âgées dans le cadre des programmes publics de pensions de retraite) réduirait la vulnérabilité des ménages qui dépendent des revenus du travail mais qui ne parviennent toujours pas à joindre les deux bouts, tout en garantissant un revenu suffisant aux personnes qui ne font pas partie de la population active pour couvrir leurs besoins fondamentaux. Selon un rapport récent du directeur parlementaire du budget, un revenu de base garanti à l’échelle nationale réduirait considérablement la pauvreté au Canada d’ici 2025, soit de 34 % pour les ménages définis comme des familles nucléaires et de 40 % pour ceux définis comme des familles économiques, selon la mesure du panier de consommation.[11]

Compte tenu de l’ampleur de l’insécurité alimentaire des ménages et de ses répercussions profondes sur la santé et les coûts économiques, le Canada a un besoin urgent de solutions politiques fondées sur le revenu qui s’attaquent directement à cette question. Le rapport 2025 du Conseil consultatif national sur la pauvreté a pris en considération l’idée d’un revenu de base ciblé afin de garantir que tout le monde atteigne au moins le seuil officiel de pauvreté au Canada grâce à son salaire ou aux prestations gouvernementales. ^[12] Le soutien au projet de loi S-206 est une étape cruciale vers la réalisation de cette vision, car il jette les bases d’un cadre de revenu de base susceptible de réduire la pauvreté et d’améliorer les résultats en matière de santé au Canada. L’ODPH invite respectueusement le Comité des finances nationales à soutenir le projet de loi S-206 et à contribuer à bâtir un Canada plus fort, plus sain et plus équitable. Nous vous remercions de votre attention.

Salutations distinguées,

Luisa Magalhaes, M.Sc.S., Dt.P. Karina Kwong, M.S.P., Dt.P.

Présidente, ODPH Vice-présidente, Groupe de travail sur l’insécurité alimentaire

c.c L’honorable Kim Pate, sénatrice

Loretta Ryan, directrice générale, Association des agences locales de santé publique (Ontario)

Références

1. Diététistes en santé publique de l’Ontario (ODPH). Disponible (en français et en anglais) à : https://odph.ca/section/insecurite-alimentaire/

2. Food Insecurity Policy Research (PROOF). Understanding Household Food Insecurity [page Web en ligne]. Disponible à : https://proof.utoronto.ca/food-insecurity/

3. Food Insecurity Policy Research (PROOF). (2025) New Data on Household Food Insecurity in 2024. Disponible à : https://proof.utoronto.ca/2025/new-data-on-household-food-insecurity-in-2024/

4. Banques alimentaires Canada. (2025). Bilan-Faim 2025. Disponible à : https://content.foodbankscanada.ca/wordpress/2025/10/FBC_HungerCount_FR_2025.pdf

5. Martin JC and Lewchuk W. (2018). The Generation Effect: Millennials, employment precarity and the 21^st Century workplace. Disponible à : https://pepso.ca/documents/the-generation-effect-full-report.pdf

6. Food Insecurity Policy Research (PROOF). (2023). What are the implications of food insecurity for health and health care? Disponible à : https://proof.utoronto.ca/food-insecurity/what-are-the-implications-of-food-insecurity-for-health-and-health-care/

7. Tarasuk V. (2017). Implications of a basic income guarantee for household food insecurity. Northern Policy Institute – Research Paper No. 24. Disponible à : https://proof.utoronto.ca/wp-content/uploads/2017/06/Paper-Tarasuk-BIG-EN-17.06.13-1712.pdf

8. Li T, Fafard St-Germain AA, Tarasuk V. (2023). Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Disponible à : https://proof.utoronto.ca/

9. Food Insecurity Policy Research (PROOF). What can be done to reduce food insecurity in Canada? Disponible à : https://proof.utoronto.ca/food-insecurity/what-can-be-done-to-reduce-food-insecurity-in-canada/

10. McIntrye L, Dutton D, Kwok C et al. (2016). Reduction of food insecurity in low-income Canadian seniors as a likely impact of a Guaranteed Annual Income. Canadian Public Policy. 42(3), 274-286. Disponible à : https://utppublishing.com/doi/10.3138/cpp.2015-069

11. Bureau du directeur parlementaire du budget. (2025). Analyse distributive d’un revenu garanti à l’échelle nationale – Mise à jour. Disponible à : https://www.pbo-dpb.ca/en/publications/RP-2425-029-S–distributional-analysis-national-guaranteed-basic-income-update–analyse-distributive-un-revenu-base-garanti-echelle-nationale-mise-jour

12. Gouvernement du Canada. (2025). Le rapport de 2025 du Conseil consultatif national sur la pauvreté. Disponible à : https://www.canada.ca/fr/emploi-developpement-social/programmes/reduction-pauvrete/conseil-consultatif-national/rapports/annuel-2025.html

January 7, 2026

The Honourable Claude Carignan, Senator, and Chair, National Finance Committee Claude.Carignan@sen.parl.gc.ca

The Honourable Éric Forest, Senator, and Deputy Chair, National Finance Committee Eric.Forest@sen.parl.gc.ca

The Honourable Clément Gignac, Senator, and National Finance Committee Member Clement.Gignac@sen.parl.gc.ca

The Honourable Andrew Cardozo, Senator, and National Finance Committee Member Andrew.Cardozo@sen.parl.gc.ca

The Honourable Pierre J. Dalphond, Senator, and National Finance Committee Member PierreJ.Dalphond@sen.parl.gc.ca

The Honourable Rosa Galvez, Senator, and National Finance Committee Member Rosa.Galvez@sen.parl.gc.ca

The Honourable Martine Hébert, Senator, and National Finance Committee Member Martine.Hebert@sen.parl.gc.ca

The Honourable Joan Kingston, Senator, and National Finance Committee Member Joan.Kingston@sen.parl.gc.ca

The Honourable Jane MacAdam, Senator, and National Finance Committee Member Jane.MacAdam@sen.parl.gc.ca

The Honourable Elizabeth Marshall, Senator, and National Finance Committee Member Elizabeth.Marshall@sen.parl.gc.ca

The Honourable Krista Ross, Senator, and National Finance Committee Member Krista.Ross@sen.parl.gc.ca

Sara Gajic, Clerk, National Finance Committee Sara.Gajic@sen.parl.gc.ca

National Finance Committee NFFN@SEN.PARL.GC.CA

Dear Chair, Deputy Chair, Members, and Clerk of the National Finance Committee of the Senate of Canada:

Ontario Dietitians in Public Health (ODPH), the professional association of Registered Dietitians working in Ontario’s public health system, is writing to urge your support of Bill S-206, an Act to develop a national framework for a guaranteed livable basic income, currently being considered by the National Finance Committee of the Senate. Since 2015, ODPH has strongly supported the concept of a basic income guarantee as an effective policy lever for reducing the pervasive problem of household food insecurity in Canada (1).

Food Insecurity Policy Research (PROOF) defines household food insecurity (HFI) as “the inadequate or insecure access to food due to financial constraints,” and further states it is a serious public health problem, a marker of pervasive material deprivation, and a matter of public policy (2). The experience of HFI can range from concerns or problems of food access (marginal HFI), to the inability to afford a balanced diet and/or missing meals (moderate HFI), to extreme cases of not eating for days (severe HFI).

In 2024, HFI in Canada reached its highest level since national monitoring began nearly 20 years ago. One in four Canadians (25.5%) living in the ten provinces experienced HFI, representing approximately 9.9 million people, including 2.5 million children – 75% of these children lived in households facing moderate or severe HFI (3). These estimates do not include First Nations communities or the territories, where rates are typically even higher, particularly in Nunavut. Provincial rates varied significantly, ranging from 19.8% in Quebec to 30.9% in Alberta, highlighting the need for a coordinated national response (3).

HFI is fundamentally an income issue, not just a “food problem.” In 2023, 70% of households with social assistance as their main source of income in Canada reported experiencing HFI (3). However, employment is not necessarily protective – 58.6% of households experiencing HFI report employment as their main income source, with this group showing the largest increase in HFI from 2021 to 2022 (3). A recent survey by Food Banks Canada found that low wages and insufficient hours were among the top reasons people turned to food banks (4). Research also highlights a growing trend of precarious jobs with unstable hours, and a lack of essential benefits, creating significant challenges for today’s workforce (5). HFI is a critical indicator of a household’s financial situation, as households unable to afford food also struggle to meet other basic needs. Incomes have not kept pace with the cost of living – since 2021, the Consumer Price Index has increased by 26% for shelter, 25% for food and 20% for transportation (4).

Extensive Canadian evidence demonstrates HFI is tightly linked to adverse physical and mental health outcomes above and beyond the influence of other social determinants of health. Research linking HFI data from population health surveys with administrative health records, has provided strong evidence that people experiencing HFI are more likely to be hospitalized for a wide range of conditions, stay in hospital longer, and die prematurely (before the age of 83) from all causes except cancer (6). A particularly strong relationship exists between HFI and poor mental health. The risk of experiencing depression, anxiety disorders, mood disorders, or suicidal thoughts increases with the severity of HFI for both adults and youth (6). The health consequences of HFI are extremely costly to Canada’s publicly funded healthcare system (7). Policies designed with the aim of reducing HFI have the potential to offset considerable public expenditures on healthcare for federal, provincial and territorial governments. These savings must be considered in the proposed national framework for a guaranteed livable basic income.

For more than three decades, food banks have been the primary response to HFI in Canada. Despite massive investments in a secondary food system for people who cannot afford to obtain food in the most socially dignified manner (i.e., buying from food retailers), food banks are struggling more than ever to meet demands. In March 2025, there were more than 2 million visits to food banks across Canada, representing a 5% increase compared to March 2024, and a 99.4% increase compared to March 2019 (4). While food banks can provide temporary food relief, they do not address the root cause of HFI – inadequate and unstable income (1). In fact, only about one-quarter of households experiencing HFI use food banks, and for those who do, the problem persists (8).

Over the past 12 months, several Ontario municipalities declared food insecurity emergencies, including Mississauga, November 2024; Toronto, December 2024; Kingston, January 2025; Brantford, February 2025; Brockville, June 2025 and Orillia, August 2025. These declarations clearly demonstrate HFI has reached crisis levels across Ontario, resulting in an unsustainable demand on the charitable food system, and requiring municipal governments and community organizations to call on Federal and Provincial governments to step in with long-term policy solutions.

The only interventions proven to reduce household food insecurity are those that improve the incomes of vulnerable households (9). Research on federal and provincial income policies, including public pensions for seniors, social assistance, child benefits, and minimum wage, has documented reductions in food insecurity when these interventions improve the incomes of low-income households (8). Research on the impact of Canada’s public pension system for seniors provides the strongest parallel to a basic income guarantee. Reaching the age of eligibility for collecting public pensions has been shown to reduce the risk of food insecurity for low-income, unattached adults by almost 50% (10).

Establishing an income floor for working-aged Canadians and their families (similar to the support seniors receive through public pension programs) would reduce vulnerability among households that rely on employment incomes but are still unable to make ends meet, while also ensuring adequate income for those not in the workforce to cover basic needs. According to a recent report by the Parliamentary Budget Officer, a national guaranteed basic income would significantly reduce poverty in Canada by 2025 – by 34% for households defined as nuclear families and by 40% for those defined as economic families, based on the Market Basket Measure (11).

Given the magnitude of HFI and its profound health impacts and economic costs, Canada urgently needs income-based policy solutions that directly address this issue. The 2025 Report of the National Advisory Council on Poverty has included consideration of a targeted basic income to ensure everyone reaches at least Canada’s Official Poverty Line through wages and/or government benefits (12). Supporting Bill S-206 is a critical step toward this vision, laying the foundation for a basic income framework that can reduce poverty and improve health outcomes in Canada. ODPH respectfully urges the National Finance Committee to support Bill S-206 and help build a stronger, healthier, and more equitable Canada. Thank you for your consideration.

Sincerely,

Luisa Magalhaes, MHSc, RD Karina Kwong, MPH, RD

Chair, ODPH Co-Chair, Food Insecurity Workgroup

cc:

The Honourable Kim Pate, Senator

Loretta Ryan, Executive Director, Association of Local Public Health Agencies (Ontario)

References

1. Ontario Dietitians in Public Health (ODPH). Available (in English and French) at: https://odph.ca/section/food-insecurity/2. Food Insecurity Policy Research (PROOF). Understanding Household Food Insecurity [webpage online]. Available at: https://proof.utoronto.ca/food-insecurity/
3. Food Insecurity Policy Research (PROOF). (2025) New Data on Household Food Insecurity in 2024. Available at: https://proof.utoronto.ca/2025/new-data-on-household-food-insecurity-in-2024/
4. Food Banks Canada. (2025). Hunger Count 2025. Available at: https://content.foodbankscanada.ca/wordpress/2025/10/FBC_HungerCount_EN_2025.pdf
5. Martin JC and Lewchuk W. (2018). The Generation Effect: Millennials, employment precarity and the 21st Century workplace. Available at: https://pepso.ca/documents/the-generation-effect-full-report.pdf
6. Food Insecurity Policy Research (PROOF). (2023). What are the implications of food insecurity for health and health care? Available at: https://proof.utoronto.ca/food-insecurity/what-are-theimplications-of-food-insecurity-for-health-and-health-care/
7. Tarasuk V. (2017). Implications of a basic income guarantee for household food insecurity. Northern Policy Institute – Research Paper No. 24. Available at: https://proof.utoronto.ca/wpcontent/uploads/2017/06/Paper-Tarasuk-BIG-EN-17.06.13-1712.pdf
8. Li T, Fafard St-Germain AA, Tarasuk V. (2023). Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Available at https://proof.utoronto.ca/
9. Food Insecurity Policy Research (PROOF). What can be done to reduce food insecurity in Canada? Available at: https://proof.utoronto.ca/food-insecurity/what-can-be-done-to-reduce-food-insecurity-incanada/
10. McIntrye L, Dutton D, Kwok C et al. (2016). Reduction of food insecurity in low-income Canadian seniors as a likely impact of a Guaranteed Annual Income. Canadian Public Policy. 42(3), 274-286. Available at: https://utppublishing.com/doi/10.3138/cpp.2015-069
11. Office of the Parliamentary Budget Officer. (2025). A Distributional Analysis of a National Guaranteed Basic Income – Update. Available at: https://www.pbo-dpb.ca/en/publications/RP-2425-029-S–distributional-analysis-national-guaranteed-basic-income-update–analyse-distributive-unrevenu-base-garanti-echelle-nationale-mise-jour
12. Government of Canada. (2025). 2025 Report of the National Advisory Council on Poverty. Available at: https://www.canada.ca/en/employment-social-development/programs/poverty-reduction/nationaladvisory-council/reports/2025-annual.html

Ontario Dietitians in Public Health (ODPH) appreciates the opportunity to contribute to the development of the next Ontario Poverty Reduction Strategy (OPRS). ODPH is the professional association of Registered Dietitians (RDs) working in Ontario’s public health system. One of ODPH’s key priorities is working towards effective solutions to reduce household food insecurity (HFI).

HFI is the inadequate or insecure access to food due to financial constraints (Li et al., 2023). The experience of HFI can range from concerns or problems of food access (marginal HFI), to the inability to afford a balanced diet and/or missing meals (moderate HFI), to extreme cases of not eating for days (severe HFI). It is a critical indicator of a household’s financial situation. When households have trouble affording food, it shows they cannot meet basic needs because they do not have enough money. HFI is a highly sensitive measure of material deprivation making it an important measure for understanding poverty and guiding policy decisions.

HFI has increased dramatically over the past several years. In 2024, 1 in 4 Ontario households experienced HFI; this translates to over 4 million Ontarians (PROOF, 2025b). This is an increase of over 1.7 million Ontarians since 2021 (Tarasuk et al., 2022). Households with children are at particularly high risk, with 1 in 3 children in Ontario living in a food insecure household in 2024 (PROOF, 2025b).

HFI is a major financial liability for Ontario’s healthcare system. Adults living with HFI account for a disproportionate share of health care costs, including mental health-related emergency visits and hospitalizations, with the greatest costs associated with severe HFI (PROOF, ND). Without effective policy action, HFI will continue to escalate with worsening consequences to Ontario’s economic progress and to the health and well-being of Ontarians.

The OPRS must prioritize adequate incomes for Ontario households to afford basic costs of living, including adequate shelter and nutritious food. ODPH commends the Ontario government’s recent efforts to support vulnerable Ontarians, including increasing the earned income exemption for the Ontario Disability Support Program (ODSP) from $200 to $1000, indexing ODSP rate increases to inflation that began in July 2023, exempting the Canada Disability Benefit from social assistance payment clawbacks, and increasing the minimum wage rate from $14/hour in January 2020 to $17.60/hour in October 2025. These are important measures for strengthening income security in Ontario.

Building on these important steps, ODPH offers the following recommendations for the 2025-2030 OPRS.

Recommendation 1: Improve employment income adequacy

While the recent increases to minimum wage have been much needed, the current rate of $17.60/hour (Government of Ontario, 2025) falls short for the over 800,000 employees in Ontario who earn minimum wage.

The Ontario Living Wage Network prepares annual living wage rate calculations based on real costs of living across the province. The living wage in Ontario in 2025 ranges from $21.05/hour in the London Elgin Oxford region to $27.20/hour in Toronto and the Greater Toronto Area (Ontario Living Wage Network, 2025). Nowhere in Ontario could someone work full time earning minimum wage at $17.60/hour and afford the basic costs of living. Aligning annual increases to Ontario’s minimum wage with living wage rates will ensure all working Ontarians can afford basic needs, including food.

Employment does not guarantee protection against HFI. In 2022, 58.6% of Ontario households experiencing HFI reported employment or self-employment as their main source of income (Li et al., 2023). To reduce HFI, jobs need to provide a living wage, stable hours, benefits, and protections against precarious work.

Recommendation 2: Strengthen social assistance

Ontario Works (OW): increase the rates and index rates to inflation annually;
Ontario Disability Support Program (ODSP): increase the rates;
Pregnancy and Breastfeeding Nutritional Allowance (ODSP Policy Directive 6.5 and OW Policy Directive 6.5): increase the monthly amounts; and
Special Diet Allowance (ODSP Policy Directive 6.4 and OW Policy Directive 6.6): increase the monthly amounts for all eligible conditions.

Households reliant on social assistance experience the highest prevalence and severity of HFI. In 2023, 70% of households relying on OW or ODSP were food-insecure and 43% were severely so (PROOF, 2025a). This is because social assistance income for both OW and ODSP are far below Canada’s Official Poverty Line (the Market Basket Measure, or MBM), with most recipients living in deep poverty, income below 75% of the MBM (Laidley & Oliveira, 2025).

The current maximum amounts for a single individual to cover basic needs and shelter each month are $733 for OW and $1,408[1]. for ODSP. These rates are far from adequate for an individual to afford housing and nutritious food anywhere in Ontario. It is particularly concerning that OW rates have not been increased since October 1, 2018, with more than 20% inflation since then; this loss in purchasing power means a significant worsening in a person’s standard of living (Tabbara & Laidley, 2024).

The monthly allocations in the OW and ODSP Policy Directives for the Pregnancy/Breastfeeding Nutritional Allowance and Special Diet Allowance have not been reviewed or increased in over a decade, even though the cost of food and infant formula have increased significantly.

Local public health units (PHUs) in Ontario monitor food affordability by reviewing the cost of a basic nutritious diet (not considering any special dietary needs) and local rental housing rates within the context of a variety of household income scenarios. Data collected by 32 PHUs in 2024, averaged and weighted proportionally by population, showed households dependent on social assistance could not afford a basic nutritious diet. To do so, households reliant on social assistance would need to allocate an unreasonable proportion of their income to food: $1,229/month (42%) for a family of four receiving OW; $427/month (48%) for a single adult receiving OW; and $451/month (30%) for a single pregnant person receiving OW (Ontario Agency for Health Protection and Promotion, 2025).

[1] Note: ODPH acknowledges an error in the original submission of the Poverty Reduction Strategy Consultation, November 2025. The submission incorrectly stated that the current maximum basic needs and shelter allowances for a single individual receiving ODSP were $1534/month. This figure was incorrect, and it has since been corrected to $1408/month.

Recommendation 3: Set measurable targets to reduce HFI and eliminate severe HFI by 2030

HFI is a reliable marker for economic hardship. Establishing measurable targets ensures accountability, provides clear benchmarks to monitor progress and impact, and supports the implementation of evidence-informed policies. Having targets also demonstrates Ontario’s commitment to equity, health, and economic stability by addressing the root cause of HFI, rather than relying on ineffective, short-term food-based responses.

HFI is not a food problem and cannot be solved by food charity or other programs, such as community gardens or food waste diversion initiatives (Ontario Dietitians in Public Health, 2020). Poverty places significant downstream pressures on municipalities to deliver essential public services and respond to increasing demands on social programs (e.g., emergency supports for people without adequate shelter and food) with limited sources of revenue and resources to do so. In the past 12 months, several Ontario municipalities declared food insecurity emergencies, including Mississauga, November 2024; Toronto, December 2024; Kingston, January 2025; Brantford, February 2025; and Brockville, June 2025. These declarations clearly demonstrate HFI has reached crisis levels across Ontario, resulting in an unsustainable demand on the charitable food system, and requiring municipal governments and community organizations to call on Provincial and Federal governments to step in with long-term policy solutions.

The urgency of this recommendation is evident in the sharp rise in severe HFI in Ontario, which increased from 4.8% of households in 2022 to 7.9% in 2024 (Ontario Agency for Health Protection and Promotion, 2025). HFI is strongly linked to income, disproportionately affecting those with inadequate or unstable income, few assets and limited access to credit (Li et al., 2023). As income decreases, both the risk and severity of HFI increases, making income-based policy solutions critical.

In conclusion, ODPH urges immediate and sustained investment to reduce poverty in Ontario. Without bold, measurable action, poverty will continue to erode community well-being, strain municipal resources, and deepen inequities across the province. Addressing poverty is not only a social responsibility – it is also an economic imperative.

References

Laidley J, Oliveira T. (2025) Welfare in Canada, 2024. Maytree. Retrieved from: https://maytree.com/

Ontario Dietitians in Public Health. (2020) Position Statement and Recommendations on Responses to Food Insecurity. Available at: https://odph.ca/section/food-insecurity/

Ontario Living Wage Network. (2025) Updated 2025 Rates. Available at: https://www.ontariolivingwage.ca/updated_2025_rates

PROOF (Food Insecurity Policy Research). (2025b) New data on household food insecurity in 2024. Available at: https://proof.utoronto.ca/2025/new-data-on-household-food-insecurity-in-2024/

Tabbara M and Laidley J. (2024) Too many income supports still aren’t indexed. Maytree. Available at: https://maytree.com/publications/too-many-income-supports-still-arent-indexed/

This document provides background information on Early Childhood Food Insecurity and alPHa Resolution A24-05

Prepared by Ontario Dietitians in Public Health

We acknowledge that this document refers to breastfeeding. Breastfeeding is traditionally understood to involve an individual of the female sex and gender identity who also identifies as a woman and mother. However, it is important to recognize that there are individuals in a parenting and human milk feeding relationship with a child who may not self-identify as such and who may prefer to use the term “chestfeeding” rather than breastfeeding.

Nutrition is fundamental for growth and development in the early years of life (1). Early childhood malnutrition presents a considerable burden to the health care system in Ontario. The long-term effects of malnutrition during early childhood include increased risk of hypertension, dyslipidemia, insulin resistance in adulthood, poor school achievement due to impaired cognitive development and increased risk of mental illness (2). These conditions cost millions of dollars in health care expenditures.

Food insecurity, inadequate or insecure access to food due to household financial constraints, continues to be a serious and pervasive public health problem. While the prevalence of infant-specific food insecurity has not been formally investigated, as no provincial surveillance system exists, it is likely significant considering that nearly 1 in 4 children under the age of six live in a household experiencing food insecurity (3).

In the last year, Statistics Canada data demonstrated that the price of food has increased by 10.6%, rising at a rate not seen since the early 1980s (4). During the same time, the price of infant formula increased 35.5% in Ontario (5). Exclusive breastfeeding is recommended for up to two years and beyond to support healthy growth and development (6), yet many families choose to offer infant formula instead of breastfeeding for a variety of reasons. Women who experience food insecurity tend to stop exclusive breastfeeding sooner than those who are food secure and they tend to struggle more often to maintain an adequate supply of breastmilk (7,8). Medical conditions such as food allergies are another reason one may choose to offer infant formula. For those with a medical diagnosis* requiring the strict avoidance of standard soy and milk proteins, there is no substitute for breastmilk other than specialized infant formula. It is estimated that 5,125 infants and children 0-24 months of age in Ontario have a medical diagnosis requiring strict avoidance of standard soy and milk proteins and must have specialized infant formula to meet their nutrient needs (9). When household food insecurity results in unreliable access to breast milk or formula, both infant health and parental mental health are threatened which can have significant implications for our healthcare system.

*Medical diagnosis can include an IgE mediated food allergy and/or a non-IgE mediated food allergy, such as food protein-induced enterocolitis syndrome (FPIES), food protein-induced enteropathy (FPE), allergic proctocolitis (AP), eosinophilic esophagitis (EoE) and several others. Due to the variability in clinical presentation and lack of validated diagnostic tests, a diagnosis relies on a detailed medical history, physical examination, and a trial elimination of the suspected food allergen.

Provincial interventions that reduce the prevalence of food insecurity, optimize breastfeeding, and improve access to infant formula, including expansion of the Ontario Drug and Benefit program, must be actioned.

References

Britto, P. R., Lye, S. J., Proulx, K., Yousafzai, A. K., Matthews, S. G., Vaivada, T., Perez- Escamilla, R., Rao, N., Ip, P., Fernald, L. C. H., MacMillan, H., Hanson, M., Wachs, T. D., Yao, H., Yoshikawa, H., Cerezo, A., Leckman, J. F., & Bhutta, Z. A. (2017). Nurturing care: promoting early childhood development. The Lancet, 389(10064), 91–102. https://doi.org/10.1016/s0140-6736(16)31390-3
Martins, V. J. B., Toledo Florêncio, T. M. M., Grillo, L. P., Do Carmo P. Franco, M., Martins, P. A., Clemente, A. P. G., Santos, C. D. L., Vieira, M. de F. A., & Sawaya, A. L. (2011). Long-Lasting Effects of Undernutrition. International Journal of Environmental Research and Public Health, 8(6), 1817–1846. https://doi.org/10.3390/ijerph8061817
Li T, Fafard St-Germain AA, Tarasuk V. (2023). Household food insecurity in Canada, 2022. Toronto: Research to identify policy options to reduce food insecurity (PROOF). Retrieved from https://proof.utoronto.ca/
Statistics Canada. Consumer Price Index, February 2023. Retrieved 13 April 2023 from https://www150.statcan.gc.ca/n1/daily-quotidien/230321/dq230321a-eng.pdf.
Statistics Canada. Monthly Average Retail Prices for Selected Products. Retrieved March 19 2024 from Monthly average retail prices for selected products (statcan.gc.ca)
Health Canada, Canadian Paediatric Society, Dietitians of Canada, & Breastfeeding Committee for Canada. (2014). Nutrition for healthy term infants: Recommendations from six to 24 months. Canadian Journal of Dietetic Practice and Research, 75(2), 107.
Orr, S. K., Dachner, N., Frank, L., & Tarasuk, V. (2018). Relation between household food insecurity and breastfeeding in Canada. Canadian Medical Association Journal, 190(11), E312–E319. https://doi.org/10.1503/cmaj.170880
Frank, L. (2018). Finding formula: Community-based organizational responses to infant formula needs due to household food insecurity. Canadian Food Studies / La Revue Canadienne Des Études Sur L’alimentation, 5(1), 90. https://doi.org/10.15353/cfs- rcea.v5i1.230
Ontario Dietitians in Public Health and Food Allergy Canada. (2023). Call to Action: ODB Program Amendments to Support Infants and Children with a Medical Diagnosis* Requiring Strict Avoidance of Standard Soy and Milk Proteins. Retrieved from www.odph.ca

Association of Local Public Health Agencies (alPHa) Resolution A24-05, June 2024

TITLE: Early Childhood Food Insecurity: An Emerging Public Health Problem Requiring Urgent Action

SPONSOR: Ontario Dietitians in Public Health

WHEREAS
Provincial action is urgently needed to protect young children 0-24 months of age from the harmful effects of household food insecurity; and

WHEREAS
alPHa’s advocacy efforts have long underscored the need for income-based solutions to food insecurity and have previously resolved on the following areas: A15-04 (Basic Income Guarantee), A18-02 (Minimum Wage that is a Living Wage), A18-4 (Extending the Ontario Pregnancy and Breastfeeding Nutritional Allowance to 24 Months), A18-05 (Adequate Nutrition for Ontario Works and Ontario Disability Support Program Participants and Low Wage Earners), A23-05 (Monitoring Food Affordability); and

WHEREAS
food insecurity is a potent social determinant of health, and infants and young children are particularly susceptible to adverse effects of household food insecurity, including associated parental stress, lower breastfeeding rates, and financial barriers to accessing adequate infant formula, when needed; and

WHEREAS
when food insecurity results in early childhood malnutrition, infants and young children may experience growth faltering, compromised health, and cognitive impairments which may hinder their lifelong potential and result in considerable burden for the provincial health care system; and

WHEREAS
food prices including the price of infant formula have increased over the past year; and

WHEREAS
the Ontario Dietitians in Public Health and Food Allergy Canada has called on the Provincial government to amend the Ontario Drug Benefit program to support infants and children with a medical diagnosis*requiring strict avoidance of standard soy and milk proteins; and

WHEREAS
the Windsor-Essex County Board of Health passed the resolution Food Insecurity Compromises Infant Health in March 2024 in response to a notable local increase in infant food insecurity

NOW THEREFORE BE IT RESOLVED
that the Association of Local Public Health Agencies call on the Provincial government to optimize early growth and development among families most impacted by food insecurity and health inequities, by:

Increasing the Pregnancy and Breastfeeding Nutritional Allowance and the Special Diet Allowance to ensure families reliant on Ontario Works or the Ontario Disability Support Program can afford the products they need to adequately nourish their infants.
Expanding the Ontario Drug Benefit include specialized infant formulas for families whose children (0-24 months) have a medical diagnosis* requiring strict avoidance of standard soy and milk proteins.

AND FURTHER THAT
alPHa continues to advocate for income-related policies to reduce household food insecurity, especially for households with children where prevalence of food insecurity is highest.

Dr. Kwame McKenzie Chief Executive Officer Wellesley Institute

Via email: kwame@wellesleyinstitute.com

May 13, 2024

Dear Dr. McKenzie,

Ontario Dietitians in Public Health (ODPH), the official voice of Registered Dietitians working in the Ontario public health system, is writing to offer feedback on the Wellesley Institute’s policy brief, Time to regulate food prices like a utility. ODPH provides leadership and expertise in public health nutrition practice, including food insecurity, family and child health, school health, and food systems.

ODPH firmly agrees that access to affordable, nutritious food is a health equity issue that requires urgent action, and that policymakers must ensure nutritious food is affordable for all Canadians. However, we disagree that regulation of the cost of foods included in the National Nutritious Food Basket (NNFB) will lead to food affordability for all Canadians who experience food insecurity. This approach is not supported by existing evidence. Moreover, it diverts attention from policy interventions that ensure wages and income supports are sufficient to meet basic needs of Canadians.

As presented in our Position Statement and Recommendations on Responses to Food Insecurity, policy interventions that improve the financial circumstances of vulnerable households are fundamental to effectively address food insecurity. Although the name of the problem implies it, food insecurity is not strictly indicative of food deprivation but rather a symptom of overall financial hardship and pervasive material deprivation.

Households struggling to afford food also struggle to afford other costs of living such as housing, personal care, clothing and transportation.

The policy brief aptly asserts that food and nutrition can be considered optional while other necessities are not − this is precisely why addressing income inadequacy is essential to reducing food insecurity. In other words, the way to address food insecurity is to ensure adequate income for inelastic costs of living. The elasticity of food expenditures means that financial hardships can be detected more sensitively through measurement of food insecurity – if a household is compromising its food spending, they are struggling financially in many ways.

The fact that Statistics Canada has reported 78% of families experiencing food insecurity had incomes above the poverty line does not mean food insecurity is breaking away from poverty, but rather it underscores a problem with relying solely on Canada’s official poverty line, the Market Basket Measure (MBM), to understand Canadians’ financial hardships and inform social policy. As an experience-based measure of material deprivation, household food insecurity captures financial hardship in a way that income-based measures of poverty do not, accounting for the security, stability, and sufficiency of income.

Since 2008, Ontario public health units (PHUs) have been mandated by the Ministry of Health to monitor food affordability. This is achieved by comparing sample single- person and family household income estimates to local rental housing rates combined with the local cost of the Nutritious Food Basket. Food affordability reports by Ontario PHUs (see examples from Huron-Perth, Thunder Bay, Ottawa) and similar reports from other jurisdictions such as British Columbia consistently and repeatedly illustrate that households with low incomes (e.g., minimum wage employment and social assistance) cannot afford the basic costs of living.

The situation is most severe for social assistance recipients where monthly benefits are woefully inadequate. The inadequacy of Ontario Works rates is particularly glaring for single people as demonstrated by the following 2023 food affordability data from selected PHUs.

a includes Basic Allowance ($343) + Maximum Shelter Allowance ($390)

b includes GST/HST tax credit ($26), Ontario Trillium Benefit ($75 or $89 in northern regions), and Climate Action Incentive Payment ($31 or $34 in non-CMA regions)

c cost of the Ontario Nutritious Food Basket, collected by Public Health Unit in May/June 2023

d cost of market rental rates obtained from CMHC data tables (October 2022) or from municipal housing authorities; may or may not include utilities

Ontario Disability Support Program recipients are slightly better off, but in most PHU jurisdictions ODSP rates are still inadequate for just rent and food. In the second half of 2023, ODSP rates increased by 5% and indexing to inflation began. These changes will be reflected in our 2024 analyses.

ODPH’s well-established experience monitoring food affordability demonstrates that regulating the cost of the 61 Nutritious Food Basket items would do little to mitigate food insecurity for individuals and families when income is far below what is needed to pay for market rate rental housing and food costs. Policy interventions shown to reduce food insecurity include income support programs that align with the costs of living and are indexed to inflation (e.g., social assistance and seniors public pensions), adequate minimum wages (e.g., living wages), as well as the prospect of a guaranteed liveable basic income.

ODPH’s recommendations for reducing food insecurity are consistent with those of Dietitians of Canada and are well-supported by PROOF’s policy evaluation research. It is essential that these are the focal point for advocacy to reduce food insecurity.

Thank you for taking the time to review this letter. ODPH would welcome an opportunity to further discuss our position with the Wellesley Institute.

Sincerely,

Laura Abbasi, RD
Co-Chair ODPH Executive

Erin Reyce, RD
Co-Chair ODPH Food Insecurity Workgroup