Child Care Licensing Regulations - Section 14

"They are students, not toddlers"

The biggest contributor to the lack of Out of School Care spaces are the child care licensing regulations.

From 9-3pm your kids are under the jurisdiction of the Ministry of Education.  Before school and after school your kids are then under the jurisdiction of the Ministry of Children and Family Development and the Child Care Licensing Regulation.  The Ministry of Health provides child care licensing officers to ensure the “space” is suitable from a health and safety perspective.

So for example a cafeteria that could comfortably seat 200 kids during the school day, would be restricted by the Ministry of Health to only seating 60 kids.  That is because the Child Care Licensing Regulation considers your kids to be toddlers (not students).  Therefore each “toddler” is required to have 3.7 square meters of floor space.

The Regulations would also require more washrooms (one toilet/basin per 10 kids).  These washrooms would need to be on the same level as the cafeteria.

So despite your kids being able to navigate their way around the school from 9-3pm as students, the Child Care Licensing Regulation still insists on treating them as toddlers.

As a result school facilities are being vastly underutilized.  Licensing officers are being forced to use a formula that was meant for toddlers in a day care, not students in a their own school.

The Child Care Licensing Regulation needs to be updated to reflect the reality of the kids they are meant to serve.  Out of School Care kids are students, not toddlers and the regulations should reflect their level of independence. 

Certainly a school that can meet the needs of these kids from 9-3pm can certainly meet their needs for an hour or two before and after school.

Maybe it’s time to place Out of School Care under the jurisdiction of the Ministry of Education.  After all they managed to look after these kids from 9-3pm . . . and the kids are already at the school anyways . . . and it’s a facility already designed and licensed to meet the needs of kids.  Why involve these other ministries?

Although, some would argue that it is not a school board’s mandate to provide childcare.  They would be correct.

BUT, it is already their mandate to provide the SPACE for childcare.

Section 85.1(2) (Use of Board Property) of the BC School Act states, “…a board must establish a policy promoting the use of board property by licensed childcare providers…”.  The authors of the school act knew working parents would need care for their kids before and after school.  That is why they created section 85.1.

There are 53 elementary schools in the city of Vancouver with onsite OSC waiting lists in excess of 1 year.  Of those 53, 29 schools have waiting lists in excess of 4 YEARS!!.

With a move to the Ministry of Education, there may be issues with the BCTF and CUPE insisting that staffing be provided by their members and not licensed care providers (like the YMCA and various neighborhood houses).  Regardless, it would be important to remember that any solution would need to be in the best interest of the kids and their parents.

Working parents are simply seeking access to Before/After School Care.  They are willing to pay for it, they just need someone to provide it.

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