Policy: Rules and Regulations in the BPS
The Broader Public Sector (BPS) has many rules that affect food procurement. Previous Green Papers have already explored some of these, but there are a number of other rules that have implications for local food procurement.
Healthcare is the most regulated sector, but only a few regulations have implications for food. All the Long-Term Care (LTC) homes in Ontario are governed by the LTC Homes Act (2007), which was passed to help ensure that residents of LTC homes receive safe, consistent, high-quality, resident-centred care. It is highly prescriptive and outlines several requirements for food and nutrition. For example, a LTC home must:
- Provide a variety of foods each day from all food groups, including fresh seasonal food, in keeping with Canada’s Food Guide.
- Review and update menus at least annually.
- Offer each resident a minimum of three meals daily, a between-meal beverage in the morning and afternoon, a beverage in the evening after dinner, and a snack in the afternoon and evening.
- Include menus for regular, therapeutic, and texture modified diets for meals and snacks.
- Include alternative choices of entrees, vegetables, and desserts at lunch and dinner.
- Provide alternative choices of beverages at meals and snacks.
- Develop an individualized menu for the residents with special dietary needs.
LTC homes are also required to spend a minimum amount on resident meals, which is currently $7.87 per resident per day. LTC homes may spend above this amount if they want, but they are not allowed to spend less than this amount.
Hospitals, on the other hand, are far less regulated as it relates to food procurement. They may follow many of the same practices that a LTC home does, but they are not required to do so by any regulation. The Ministry of Health and Long-Term Care does not regulate food budgets in hospitals. Rather, each hospital establishes its own food and nutrition budget based on the overall operating budget. In most cases, the budgets end up being comparable.
The food that is provided in public schools are influenced by different policies and guidelines. In particular, the Program/Policy Memorandum 150 (better known as PPM 150) is a commitment from the Ontario government to make schools healthier places for students. It establishes rules around the types of food that can and cannot be served in schools, and is targeted at eliminating junk food. PPM 150 establishes limits on the amount of fat, sugar, and salt that a given food can contain, and eliminated the use of deep fryers.
Elementary schools also offer Student Nutrition Programs (SNP), which provide nutritious meals and snacks to children and youth to support their learning and healthy development. The Ministry of Children and Youth Services has established guidelines that apply to the all the organizations that organize and/or offer the food being served through SNPs that use provincial funding. The 2014 guidelines include a section on how to procure food, saying “procurement strategies should reflect best practices related to food safety and traceability.” This focus on food safety and traceability were not included in the previous guidelines from 2008, and appear to make it more difficult to source food directly from farms and local food groups. However, the guidelines provide appendices to help SNPs identify safe food sources, including a checklist that can be used to identify farms that adhere to food safety best practices. There is also an appendix that highlights common safe-food sources, including farmers markets and community food hubs.
Rules and regulations designed to be beneficial to students, parents, and residents of BPS institutions can make it complicated to buy more local food.
Progress Being Made
- Healthcare facilities faced with lean food budgets have found creative ways to support local food. If a local option happens to cost more, pairing it with a less expensive option can offset the added expense. For example, St. Joseph’s Health Centre-Guelph found they could serve local and sustainable beef when they made the other meal option a less expensive casserole. The total cost of serving the combined meal options balanced out.
- After PPM 150 was passed, the Toronto District School Board had to close 32 cafeterias. The limitations the policy placed on meal options at the schools drove students off campus to other food outlets. In response, the school board created a student engagement strategy to ask them what foods they wanted to eat, and then worked with George Brown College to reinvent their menus and the meal experience.
The barriers that rules and regulations create in the BPS are often more perceptual than real, and in most cases they can be overcome with some creativity.
- The LTC Homes Act asks that seasonal food be used in resident meals. Use this as an opportunity to source fresh, local produce.
- Try looking at the whole menu when trying to balance the costs of local food.
- Use recipes that feature local food and fit with rules and regulations to avoid headaches when trying to buy more local food. For existing recipe resources, see the Greenbelt Fund’s website.
- If you want to sell local food to the BPS, make sure you are aware of the food requirements in each sector. For example, SNPs have food safety requirements, and PPM 150 has limitations on junk food in schools.
Keep your eyes open for our next Local Food Solution Paper, Foodservice Regulations in the BPS. Follow @ontariofresh on Twitter to join the conversation.
This series is written with contributions from: Kathy Macpherson, Franco Naccarato, and Brendan Wylie-Toal.