IWC’s response to the consultation on the Ontario’s proposed Critical Minerals Strategy addresses the high workplace injury rate of workers in the mining and quarrying industries and their need to have the same health and safety protections as all workers in Ontario. It calls on the government to state by regulation that there will be no exemptions for workers in special economic zones from the Occupational Health and Safety Act, the Workplace Safety and Insurance Act, the Labour Relations Act and the Employment Standards Act ….
Injured Workers Community Legal Cllinic
411-815 Danforth Ave
Toronto, ON M4J 1L2
June 11, 2026
Environmental Registry of Ontario
Consultation on Fortifying Ontario’s Economy
By email to: criticalminerals@ontario.ca
Dear Ministry of Energy and Mines
Re: comment on policy vision paper: Fortifying Ontario’s Economy
Injured Workers community Legal Clinic is a community legal aid clinic specializing in workers’ compensation law. Our mandate includes providing legal advice and representation and providing submissions on law and policy reform relating to injured workers. Thank you for theopportunity to comment on the proposals for updating Ontario’s Critical Minerals Strategy.
The Ontario government’s vision in “Fortifying Ontario’s Economy” begins by declaring that Ontario is an unapologetic champion of Canadian workers and minerals. The mining and quarrying industry already has one of the highest rates of workplace injury in Ontario and we are still learning about the health impact of past mining practices such as McIntyre powder causing Parkinson’s disease. We submit that it would be appropriate to carry through your support for Canadian workers by declaring that there will be no compromise on workers’ health and safety.
Under s.5 and 6 of the Special Economic Zones Act, the government can pass regulations that exempt a corporation or mining project from any provincial law or regulation or modify the application of any law. We expect the government does not want these exceptions to threaten the health and safety of Canadian workers and therefore we submit that this should be stated clearly in the regulations.
These sections of the Act provide that the exemptions are subject to conditions specified in the regulation. It is our submission that the government should state by regulation that there will be no exemptions from the Occupational Health and Safety Act, the Workplace Safety and Insurance Act, the Labour Relations Act and the Employment Standards Act. This will ensure that workers in the special economic zones will have the same health and safety protection as all workers in Ontario. A regulation like that will also contribute to the support of workers and organized labour for this work.
Thank you for the opportunity to comment on the proposal.
John McKinnon
Executive Director
Download IWC submission on Fortifying Ontario’s Economy (Critical Minerals Strategy)