Commentaires de l’Ordre aux modifications proposées à la Loi sur les EPE

The College of Early Childhood Educators (the College) has responded to the consultation document on proposed regulatory changes under the Day Nurseries Act (DNA) and the Early Childhood Educators Act, 2007 (ECE Act) to support the Government of Ontario’s child care modernization agenda.

The primary focus of the College’s comments is on the proposed amendments to the ECE Act, as this is the legislation that governs the profession of early childhood education, and is most properly within the scope of the College’s statutory mandate. These proposed amendments speak to the sectors from which the government would seek to appoint their 10 public members to the Council of the College.

The College is supportive of Francophone, First Nations, Métis and Inuit persons serving on the College Council as public appointees and points out that to some extent this is already the case. However, the College notes that Council members, whether elected or publicly appointed, have a fiduciary duty to the College, its members and the broad public interest, and not to specific sectors of society as is further suggested by the proposed regulation.

With regard to proposed regulatory changes under the DNA, the College recognizes that the regulatory framework for licensed child care centres and private home child care is largely outside its statutory scope. However, where the safety of the environment may be compromised through the proposed ratio changes, there is some concern that the registered early childhood educators (RECEs) in the program may be held accountable through their professional standards for circumstances outside their control.

The College is pleased at the implicit recognition that RECEs have specialized skills and knowledge that contribute positively to the development of children and would prefer to see this recognition reflected in higher minimum RECE requirements in programs for children ages 0-5 years; and a presence of RECEs in programs for the 6-12 age group.

The College is pleased with a proposed requirement that home visitors working with private home day care agencies be RECEs; and is in agreement with amendments that would support the use of Ontario’s Early Learning for Every Child Today (also known as ELECT or the Early Learning Framework) principles through a provincial policy statement as they are closely aligned with the scope of practice of early childhood education and the Code of Ethics and the Standards of Practice by-law of the College.