The Government of Ontario’s consultation on the potential for cannabis consumption establishments and/or cannabis special occasion permits

To the Government of Ontario,

RE: The Government of Ontario’s consultation on the potential for cannabis consumption establishments and/or cannabis special occasion permits

You have engaged the local health authorities to consult and participate for the consultation on the potential for cannabis consumption establishments and/or cannabis special occasion permits

On March 10, 2020, Ottawa Public Health has officially responded to the Province of Ontario’s consultations. OPH Submission – Cannabis Consultation

Following their submission, and due to COVID limitation, as a former board member and a current member of council who has help Ottawa Public Health align Cannabis, Hookah and Vaping into alignment ban of City bylaws on the second hand impacts of the smoke, I would like to offer some additional feedback to your questions concerning the Potential for Cannabis Consumption Establishments and/or Cannabis Special Occasion Permits.

First I would like to thank the Province of Ontario for taking all feedback, whether it is from our public health organizations or an individual, seriously – as you know, this is the best way to shape the way Cannabis is safely consumed while limiting exposure to vulnerable and non- vulnerable groups, while continuing offer consumers choices and convenience for access but a strong emphasis is needed with regards to the collective safety and the overall framework which informed the creation of the Smoke-free Ontario Act initially.

With that being said, in addition to what Ottawa Public Health as submitted, I would like to add some comments to your consultation:

Cannabis Consumption Establishments/Special Occasion Permits

Since the initial smoke-free Ontario Act, many Ontario Cities increase smoke-free environments to most public spaces including parks, bus stops, special events, to name a few. The goal of those smoke-free environments is to eliminate second-hand impacts as well as limiting exposure to limit adhesion to these products which have negative health impacts.

Based on the success of the Smoke-free Ontario Act, smoking lounges, like the old popular cigar lounges have disappeared and recently in Ottawa we have been able with alignment with the Act to expand our bylaws to ensure Hookah lounges are also included in this ban.

There are serious concerns that it sends the wrong public message if you allow a change in the gains of the SFOA for the category of Cannabis – no matter what substance you, or whether it is by vaping or smoking there are dangers with second-hand smoke and there are public health interest in protecting the cessation gains.

If consumption establishment were allowed, the onus would be on by law and health inspectors to demonstrate the substance that is burned – whether it is cannabis or other substances. The benefits of the restrictions put in place indoor and outdoor spaces cannot be undermined, as cannabis lounges would pose similar challenges to hookah lounges where the onus is on enforcement authorities to prove the substance the is being inhaled. This model of enforcement is not efficient, is costly and is very expensive for little return.

As the youngest elected official in the City of Ottawa, while I have been in public office for the last 10 years, I have seen the transition from when I was a young boy and people smoked everywhere, to the regulated environment of smoker/non-smoker zones to now ban in public spaces. I remain opposed to allowing smoke-lounges no matter the substance consumed.

If the government of Ontario were to permit the opening of lounges, the cannabis vape or smoked should only be available through purchase within the establishment. This would be to ensure the appropriate type of substances are consumed.

As for Special Occasion permit component of the consultation, I would again encourage that like smoking where we have made a public policy decision not to allow residents to socialize around smoking that we should continue those efforts. This measure would restrict cannabis consumption to someone’s property which would limit expansion of use, and second-hand influence and impact.

Festivals in Ottawa have been smoke-free for more than 10 years and the drinking environment at festivals and special events is controlled and provided by organizers which ads controls to under age, quality and manage risk of abuse.

We must reaffirm some of the current retail risk that the current Province of Ontario Cannabis legalization has left municipalities across Ontario with – Cities through AMO and other official consultation period highlighted its support for the sale of controlled substances under a similar model to the LCBO, the current Provincial government chose to head into a different approach for which municipalities highlighted the importance of additional measures that were never included such as separation distances. We are generally comfortable with the legalization of cannabis as it may overtime remove organize crime for such a controlled substance. However, municipalities want strong local businesses, and what is a success in that environment are commercial streets and areas that have strong business mix to encourage all age groups and demographics to enjoy the small local retail environment. Without separation distances the burden is left for the business community to shoulder the burden of potential risks of over- concentration – of greater concern are heavy tourist areas or near University and College campuses.

I strongly urge the provincial government not to allow inhaling of cannabis to be consumed at special events, including festivals on city-owned properties and to not introduce cannabis lounges in an effort to continue the success, in Ontario, of the smoke-free environments to maintain consistency in the approach and the successful results achieved by the Act when it

comes to health outcomes and drops in percentages of smokers in our population. I would urge you to approach smoking and vaping of cannabis as it is no different from Tobacco, both are legal substances. The collective health risk on the population should trump one individual choice to smoke.

Please don’t create an anomaly while all other legal smoking/vaping of substance is also ban in public spaces.

Where this questionnaire pertains to edible cannabis, I concur with Ottawa Public Health’s comments.

Thank for your consideration of this important public policy review.

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