TABLE OF CONTENTS

REPORTS OF THE STANDING COMMITTEES

AND OTHER COMMITTEES

As Considered by

The Council of the City of Toronto

on March 4, 5 and 6, 1998

BOARD OF HEALTH

REPORT No. 3

1Appointment of Associate Medical Officers of Health

2Public Health Funding

3Other Items Considered by the Board Pertaining to Budget and Corporate Policy Matters

City of Toronto

REPORT No. 3

OF THE BOARD OF HEALTH

(from its meeting on February 23, 1998,

submitted by Councillor John Filion, Chair)

As Considered by

The Council of the City of Toronto

on March 4, 5 and 6, 1998

1

Appointment of Associate Medical Officers of Health

(City Council on March 4, 5 and 6, 1998, adopted this Clause, without amendment.)

The Board of Health recommends that Council designate the Medical Officers of Health and Associate Medical Officers of Health of the former municipalities as Associate Medical Officers of Health for the City of Toronto Health Unit on an interim basis, and that authority be granted for the introduction of the necessary Bill in Council to give effect thereto.

The Board of Health submits the following report (February 11, 1998) from the Acting Medical Officer of Health:

Purpose:

To update the Board of Health on the status of amalgamation related activities and seek Board endorsement on a matter requiring Council approval.

Funding Sources, Financial Implications and Impact Statement:

None.

Recommendations:

It is recommended that:

(1) this report be received for information; and

(2) the recommended interim designation of Associate Medical Officers of Health be forwarded to Council for approval; and

(3) authority be granted to introduce the necessary bill in Council to give effect to Recommendation (2).

Council Reference/Background/History:

The six former health units in Metro Toronto became one on January 1, 1998. As Acting Medical Officer of Health for the new amalgamated Toronto Public Health department, I have initiated a number of activities to facilitate the transition to a unified department, including:

(a) written confirmation to all staff that pre-existing roles and reporting relationships will remain in effect pending corporate restructuring;

(b) creation of an interim executive team to advise me on city-wide matters;

(c) establishment of interim administrative and programmatic "functional groups" to work on city-wide matters;

(d) discussion with the public health physicians, legal counsel and human resources about the interim designation of Associate Medical Officers of Health, pending corporate restructuring;

(e) attendance at 10 events (1-3 hours each) across the new City to speak to managers and staff about next steps for the new department and to engage in question and answer sessions.

Discussions:

In this time of uncertainty, it is critically important that programs and services continue to be delivered without disruption to the public. To maximize stability for staff and programs, each former health unit (now termed an "area office") is being managed by the same team as was in place December 1997 (with the exception of East York, in which the former Associate MOH has stepped in for the former MOH). As well, all past reporting relationships remain the same, with the exception that the heads of each area office report directly to me.

While it is "business as usual" for each area office on matters that are strictly local, issues that require city-wide coordination or resolution are dealt with at the Interim Executive Team (IET). The IET is comprised of the heads of each area office (i.e., the six former MOH's and the Regional Directors in Toronto) and is chaired by me. It meets weekly to share information and to manage city-wide issues, many of which are under consideration by the Board and/or Council and its Committees. In turn, my role is to ensure coordinated public health responses to city-wide issues and to be the primary interface between public health and the Board, Council, major media, etc.

To complement the IET, functional groups are being established to coordinate information and to advise the IET on a variety of issues that are either administrative (e.g., budget, human resources, etc.) or programmatic (e.g., environmental tobacco smoke by-law, Healthy Babies, Healthy Children, etc.). Membership on these groups is intended to maximize continuity with past roles and responsibilities where appropriate. It will also be used to provide new opportunities for staff at all levels in the organization to participate in discussions from a city-wide perspective, which will help build our capacity to identify and respond to health needs as a unified organization. All of this information has been shared with management and staff at "town hall" meetings throughout the City. These sessions have been a very positive step for all concerned; they will be continued on a regular basis and complemented by newsletters and other methods to ensure information flow on a timely basis.

All of the structures described above are "interim", pending the department's participation in corporate restructuring. In the meantime, immediate steps must be taken on an interim basis to provide other physicians in the department with medico-legal signing authority pursuant to the Health Protection and Promotion Act (HPPA). This is needed to ensure that the day-to-day medical work in each area office can proceed efficiently and to ensure that all physicians on the after-hours on-call roster have the necessary status. As Acting Medical Officer of Health, I am currently the only physician in the department with any signing authority on medical-legal matters. As a result, routine documents from area offices (e.g., letters, orders, etc.) cannot be signed by those staff but must be referred to me, which is highly inefficient and not consistent with their other roles and responsibilities. It also means there is no-one legally able to serve as my back-up should I fall ill or otherwise be unavailable.

Associate MOH designations are sought for all public health physicians currently on staff, both former MOH's and former Associate MOH's. The proposed designations would be strictly on an interim basis for the express purpose of providing continuity in medico-legal signing authority. It would be in no way reflective of current or future organizational structures, positions, or reporting relationships, a distinction that has been discussed with the incumbents. The final status of all public health physicians will be resolved in the course of corporate restructuring, subject to the applicable human resources policies approved by Council.

While designation of only some physicians was considered, this option is not recommended as it would further disrupt working relationships and conflict with existing roles and responsibilities at a time when program stability and clarity of roles is most needed. My advice to designate all current physicians as AMOH's reflects considerable discussion within the department as well as with legal counsel and the Executive Director of Human Resources. Final advice on physician complement and AMOH designations will be provided in the context of corporate restructuring.

Under the City of Toronto Act No. 2, City Council directly appoints the MOH and AMOH's, and these appointments must be ratified by the Minister of Health. Once these designations have been approved by Council, they will be forwarded to the Ministry with a request for expedited approval.

Conclusions:

This report describes the steps taken in the past month to maintain continuity of local programs and services while building capacity to coordinate issues at a City-wide level. Interim designation of Associate MOH's is a necessary step to ensure continuity in signing authority on medical matters, pending organizational restructuring. The Board is requested to endorse the proposed designations and forward them to Council for approval.

Contact Name:

Dr. Sheela Basrur

Acting Medical Officer of Health

Tel: 392-7402

Fax: 392-0713

e-mail: sbasrur@city.toronto.on.ca

2

Public Health Funding

(City Council on March 4, 5 and 6, 1998, amended this Clause by striking out and referring Recommendations Nos. (1) and (3) of the Board of Health to the Budget Committee for consideration during the budget process, viz.:

"The Board of Health recommends that:

(1) the current investments in public health be maintained and any savings resulting from the amalgamation be reinvested back into public health to ensure that:

(a) the Provincial Mandatory Health Program and Services Guidelines are met; and

(b) local health needs are met, including emerging health needs; and

(3) Council use as a guideline for future City budgets, the 'two percent solution', which is a proposal of the Citizens for Public Health that urges the new City of Toronto to allocate two percent of its total budget to public health programs.")

The Board of Health recommends that:

(1) the current investments in public health be maintained and any savings resulting from the amalgamation be reinvested back into public health to ensure that:

(a) the provincial Mandatory Health Program and Services Guidelines are met; and

(b) local health needs are met, including emerging health needs;

(2) standardization of user fees for Environmental Health Services be implemented to the highest level;

(3) Council use as a guideline for future City budgets, the "two per cent solution", which is a proposal of the Citizens for Public Health that urges the new City of Toronto to allocate two per cent of its total budget to public health programs.

The Board of Health reports having:

(1) found Council's directive to reduce the gross 1998 Public Health Operating Budget by fifteen per cent unachievable;

(2) advised the Budget Committee of its support for the "two per cent solution", which is a proposal of the Citizens for Public Health that urges the new City of Toronto to allocate two per cent of its total budget to public health programs;

(3) requested the Acting Medical Officer of Health, in accordance with the comments in her report (February 19, 1998) "State of the City's Health", to prepare a report to the Board which delineates where public health programs fall short of current requirements and where greater needs in Toronto require a higher level of service;

(4) requested the Acting Medical Officer of Health to report back to the Board on elements of a reinvestment strategy for public health;

(5) (a) requested the Acting Medical Officer of Health to present the Public Health 1998 Operating Budget of $84,663.30, inclusive of the savings within the "A" and "B" lists to the Budget Committee; and

(b) established a sub-committee consisting of the Chair and Vice Chair, in conjunction with the Acting Medical Officer of Health, to prepare a presentation to the Budget Committee which would address the cost-savings of the "A" and "B" lists, and the need to reinvest these savings;

(6) requested the Acting Medical Officer of Health to prepare an alternative budget to reflect costs if services were expanded to address current gaps;

(7) agreed to hold public deputations on the health implications of the proposed 1998 budget and the alternative budget and invited members of the Budget Committee to attend that meeting;

(8) requested the City Solicitor, in consultation with the Acting Medical Officer of Health, to report back to the Board on the statutory requirements of the Board of Health and City Council regarding the provision and funding of public health programs.

The Board of Health submits the following report (February 20, 1998) from the Acting Medical Officer of Health:

Purpose:

To present the 1998 operating budget estimates for Public Health in the context of the budget pressures facing the Corporation, and to outline the implications of a 15 per cent budget cut on public health programs and services.

Funding Sources, Financial Implications and Impact Statement:

Effective January 1, 1998 funding of public health is primarily a municipal responsibility, with over $40 million of provincial funding for public health programs being downloaded to the new City of Toronto. Provincial funding will continue only in specific areas, as outlined below.

Table 1a. Ongoing Provincial Funding for Specified Public Health Services

As well, the Province recently announced one-time (15-month) grants for the following Toronto programs, pending final resolution of long term funding:

Table 1b. One-time Provincial Funding for Specified Public Health Programs

Recommendations:

It is recommended that:

(1) the Board recommend to Council that current investments in public health be maintained and that any savings resulting from the amalgamation be reinvested back into public health to ensure that:

(a) the provincial Mandatory Health Programs and Services Guidelines are met; and

(b) local health needs are met, including emerging health needs.

(2) the Acting Medical Officer of Health report back to the Board on the elements of a reinvestment strategy for public health.

(3) the City Solicitor be requested to report back, in consultation with the Acting Medical Officer of Health, on the statutory requirements of the Board of Health and City Council regarding the provision and funding of public health programs and services; and

(4) the Board consider holding public deputations on the health implications of the proposed 1998 budget.

Background:

(a) Corporate Overview

For the past several months staff of the former municipalities have been working with the Toronto Transition Team to consolidate the separate budgets of the seven former municipalities that make up the new City of Toronto. Since each had its own way of presenting / consolidating budgets, it was necessary to develop a single consistent format for budget presentation purposes. For Public Health it was agreed that the budget estimates would be consolidated under 10 "sub-programs"¹; these are for budget purposes only and are not indicative of current or future organizational structure.

The Transition Team, in cooperation with the staff of the former cities, recently submitted a preliminary draft 1998 budget to Council. The Transition Team's draft budget assumes that existing service levels in the former municipalities are maintained across the new City in 1998. The preliminary gross operating budget for 1998 is approximately $6.4 billion, including the impact of provincial downloading. The budget is funded through a combination of grants, user fees, and other revenues, with the net balance funded through property taxes.

In its budget report, the Transition Team outlined major financial/budget pressures of $150 million (5.8 per cent potential tax increase), resulting from normal year-to-year pressures (Appendix A). To address these pressures, the Transition Team identified expenditure reductions and revenue enhancements of about $117 million (Appendix B) without reducing service levels, imposing any new user fees or deferring expenditures. They deemed the remaining $33 million worth of reductions as "achievable" resulting in a 0 per cent increase to the corporate budget prior to the impacts of downloading. Proposals for expenditure reductions or revenue enhancements submitted by the Public Health Service Review Team were reviewed by budget staff to ensure they were reasonable and that identified savings or increased revenues could be realized.

In addition to normal year-to-year budget pressures, the new City faces major increases in costs due to provincial downloading. In December 1997 the Province revised its estimates of the cost of downloading to the City from $66 million to $164 million. The $164 million represents a 6.4 per cent increase over the 1997 net operating budget, adjusted for changes in the education tax (Appendix C).

The Transition Team report also outlined one-time costs associated with amalgamating seven separate municipalities into one, ranging from $100 - $175 million in 1998. These costs include spending on computer technology required to achieve the efficiencies associated with identified savings, accommodation changes, relocation and retrofitting costs, and human resource costs including early retirements, severance, and retraining programs. Transition costs over three years are estimated to be about $385 million.

In order to address both the normal year-to-year budget pressures of $150 million, and the downloading pressure of $164 million, all departments, divisions, agencies, boards and commissions were directed by Council's Budget Committee to submit plans outlining how they would manage a budget reduction equivalent to 15 per cent of their 1998 gross budget estimates, including but not limited to the reduction strategies/revenue enhancements recommended by the Transition Team. Based on 1998 gross expenditure estimates, the 15 per cent target reduction equates to $13.4 million for public health and $0.8 million for animal services.

(b) Public Health Budget

The 1998 Preliminary Operating Budget Submission for Public Health is attached (Appendix D). This information was presented to the CAO on February 9, and staff advised at that time that the Board had not had an opportunity to review the budget submission and would be providing its own comments directly to the Budget Committee.

The 1998 net budget for Public Health (including Animal Services) is estimated at $89.2 million prior to the amalgamation savings/revenue enhancements recommended by the Transition Team. Net budget represents all expenditures minus revenues. These estimates are based on the 1997 budget of the six former Public Health and Animal Services units and assume that existing service levels in the former units are maintained in 1998. Overall the 1998 net budget is up $40.3 million over 1997. 99 per cent of this increase is due to provincial downloading.

The administrative and political process for budget consideration is in constant flux. At the moment, it appears the CAO will present to Budget Committee on Feb 23-24 a recommended budget that will outline measures to meet the internal pressures of $150 million while minimizing impacts on services. The report may also contain additional proposals for Council's consideration to address the downloading pressures of $164 million which, if adopted, will have a substantial impact on services across the corporation. Although details of the CAO's report are not yet public, its contents are expected to be based largely on staff submissions.

Following the CAO's report, staff will provide informal briefings to Budget Committee members from February 25 - March 3. Public deputations will occur when the budget is reviewed by Standing Committees (week of March 23) and then Community Councils (week of March 30). A 2-day session for public deputations on March 23-24 is also being considered. From there, the budget will be referred to Strategic Policies and Priorities Committee (April 7) and then to Council (April 15-17).

Comments and/or Discussion and/or Justification

The public health budget process at a staff level has mirrored that of other boards and operating divisions. Council's Budget Committee established a target reduction of 15 per cent on the gross budget, which includes expenses related to programs which are 100 per cent provincial funded. As cuts can only be made in municipal expenditures, the actual per cent target is somewhat higher for both public health and animal services (Table 2). This is magnified by the time already elapsed in 1998, which further reduces our flexibility and increases the amounts that must be found in 1998 to meet this target. These additional reductions cannot be absorbed in one-time expenses, putting our base budget at substantial risk of a permanent reduction that may exceed even the Budget Committee's target.

Table 2. Public Health 1998 Budget Reduction Targets ($000's)

The Public Health submission on the implications of such a reduction is contained in Section C of the budget submission (Appendix D). The reductions/revenue enhancements contained in the budget reduction plan are divided into three categories:

(A) Transition Team/Service Review Team Recommendations:

Outlines amalgamation savings and revenue enhancements recommended by the Service Review Teams, and approved by the Toronto Transition Team.

(B) Staff Recommendations:

Outlines additional cost reduction/revenue enhancement strategies recommended by Public Health.

(C) Not Recommended:

Outlines reductions in programs and services that would be inevitable in a -15 per cent scenario. These reductions are NOT recommended by Public Health staff.

Table 3a & 3b below summarizes the dollar savings identified in the three categories.

Table 3a -- Public Health

Table 3b -- Animal Services

Policy Issues:

(1) Provision of Public Health Programs and Services

The fundamental mandate of the Toronto Board of Health is to provide or ensure the provision of the health programs and services required by the Health Protection and Promotion Act (the HPPA), the Regulations and Guidelines. The Board may also provide any other program or service in any area of the City if it is deemed necessary or desirable in relation to local health needs and if Council so approves (referred to as "local programs").

Appendix D - Section C describes the potential impacts across Toronto of a 15 per cent budget reduction in 1998 on provincially mandated programs and on programs addressing local needs. With 82 per cent of the public health budget tied to staff, cuts of this magnitude will have a profound effect both on program delivery and on public health staff, whose numbers will have to be reduced. It will be very difficult to manage these losses in a manner that does not have some effect on the health of local communities. With over 50 per cent of staff currently assigned to programs in the areas of Infectious Diseases and Family Health, adverse impacts on these programs can be expected.

This would occur despite established evidence that public health interventions are cost-effective. For instance, every $1 spent on prevention of low birth weight saves $3 down the road in future hospital costs, physician visits and other services. Similarly, every $1 spent on vaccine preventable diseases saves $8 in future costs, while $1 spent on prevention of teen pregnancy saves $10 down the road.

It is anticipated in the longer term that some efficiencies in the planning, delivery and/or evaluation of programs and services could be achieved which would generate some savings. However, it will take a thoughtful process, considerable time and concerted effort by all concerned to identify these in a manner that does not undermine program delivery or mask a false economy. Moreover, such efficiencies are most likely to be identified in the course of corporate restructuring, which has not yet begun.

(2) Levels of Service

The Mandatory Health Programs and Services Guidelines prescribe a minimum standard that must be met across the province. Provincial needs-based planning methodology has shown that Toronto has the highest health needs of any urban area in Ontario; indeed, the former City of Toronto had the highest health needs of any health unit in Ontario. These data strongly support both the protection of current funding for public health and the value of additional reinvestments. In effect, the provincial minimum should be regarded as a "floor" rather than a "ceiling" when it comes to public health programs and services in Toronto.

The timing of the budget process is such that major financial decisions carrying significant health implications will be made before the Board has an opportunity to review and understand the full scope of current programs and services. In particular, there is great financial pressure to "level down" services designed to meet specific local needs, even though the Board has not had an opportunity to make policy decisions in this regard.

In light of the issues outlined above, it is strongly recommended that the Board recommend to Council that current investments in public health be maintained and that any savings resulting from the amalgamation be reinvested back into public health. This would help the Board ensure that both the provincial Mandatory Health Programs and Services Guidelines are met and that local health needs are met, including emerging health needs. It is further recommended that the Acting Medical Officer of Health report back to the Board on the elements of a reinvestment strategy for public health.

(3) Restructuring of Programs

Although dated December 1997, the new Mandatory Health Programs and Services Guidelines were not actually released until February 5, 1998. As a result, staff have not had sufficient opportunity to review the new standards and assess their resource implications. Such a review has been initiated, but it will be a complex task to assess compliance across six former health units, given their differences in organizational structure, funding and approach to program delivery. A status report will be provided to the Board as soon as this work can be completed.

(4) Requirements of the Health Protection and Promotion Act (HPPA)

To implement downloading, the provincial government passed late in 1997 an omnibus statute known as the Services Improvement Act (also known as Bill 152). This Act amended the HPPA to implement the provincial transfer of public health financing to the municipal sector. In summary, the amended HPPA requires the Board of Health to provide or ensure the provision of mandatory health programs and services, while Council is legally obligated to pay the expenses of the Board and the Medical Officer of Health in this regard.

The Toronto Board of Health is also affected by City of Toronto Act No. 2 (also known as Bill 148), which stipulates that Toronto Council shall provide to the board of health such employees of the municipality as Council considers necessary to carry out the functions of the Board, including the duties of the Board in respect of mandatory programs.

The legal requirements that apply to the Board and Council in respect of the budget process are technically complex and will be the subject of initial discussion with Ontario's Chief Medical Officer of Health on February 23. A further report to the Board from the City Solicitor on these matters is strongly recommended. This will ensure that both the Board and Council are properly advised of their legal authority and duties regarding the provision and funding of public health programs before final budget decisions are made.

Conclusion:

Provincial downloading poses a significant challenge for 1998. In addition, one time transition costs associated with the amalgamation of six health units and six animal centres must be addressed. In some cases Council will have to spend money and/or negotiate changes to collective agreements in order to realize future savings. Some of the savings identified under Part A of the Public Health Budget Reduction Plan (Appendix F) depend on up front investments in information technology. As well, many of the spending reductions and revenue enhancements identified by staff will not be achieved if decisions are delayed too late into the fiscal year.

The new City of Toronto has the highest health needs of all urban areas in the Province. In order to help build and maintain the infrastructure that makes our City healthy, it is critically important not only to protect but to enhance spending on public health programs in order to help people achieve optimal health and quality of life.

Contact Name:

Giuliana Carbone, Director of Administrative Services, North York Office

Tel: 395-7616

Fax: 395-7691

¹Program Administration/Other Communicable Disease Control, Dental, Environmental Health, Family Health, Healthy Lifestyles, Healthy Babies, Community Health Status & Evaluation, Public Health Grants, and Animal Services.

The Board of Health reports, for the information of Council, also having had before it the following communication/submission, and copies thereof are on file in the office of the City Clerk:

(i) (February 20, 1998) from Rita Luty, Chairperson, Northern Health Area Community Health Board of the former City of Toronto

(ii) (undated) from the Acting Medical Officer of Health, titled "1998 Budget Presentation"

________

(Copies of Appendices A to D, referred to in the foregoing report (February 20, 1998) from the Acting Medical Officer of Health, were forwarded to all Members of Council and the Board of Health with the agenda of the Board of Health meeting of February 23, 1998, and copies thereof are on file in the office of the City Clerk.)

3

Other Items Considered by the Board

Pertaining to Budget and Corporate Policy Matters

(City Council on March 4, 5 and 6, 1998, received this Clause, for information.)

(a) State of the City's Health.

The Board of Health reports having forwarded the following report (February 19, 1998) from the Acting Medical Officer of Health to the Community and Neighbourhood Services Committee, Budget Committee and City Council for consideration during the budget process.

(i) (February 19, 1998) from the Acting Medical Officer of Health regarding The State of the City's Health: Implications for Public Health;

(ii) (October 6, 1997) from the Assistant City Clerk, former City of Toronto, forwarding the former City of Toronto's action taken at its meeting on September 22 and 23, 1997 with respect to Clause 1 Board of Health Report No. 9, titled "Threats to Health in the Changing City: Choices for the Future", in which the former City of Toronto Council endorsed the actions of the former City of Toronto Board of Health;

(iii) (February 1998) from the Acting Medical Officer of Health, titled "The State of the City's Health: Implications for the Future".

(b) Current Gaps in Public Health Services for Children.

The Board of Heath reports having received the report (February 11, 1998) from the Acting Medical Officer of Health and, having taken into account the issues and needs raised therein when making decisions regarding the 1998 budget, forwarded this report to the Children's Action Committee and the Community and Neighbourhood Services Committee for consideration, and to the Budget Committee with a request that the Acting Medical Officer of Health provide that Committee with the amount of funding required.

(i) (February 11, 1998) from the Acting Medical Officer of Health regarding current gaps in public health services for children;

(ii) (February 20, 1998) from Rita Luty, Chairperson, Northern Health Area Community Health Board, of the former City of Toronto;

(iii) (February 20, 1998) from Gilles Barbeau, Acting Chair, French Language Services Committee, Metropolitan Toronto District Health Council.

(c) Business Plan for Toronto Animal Services for 1998-99.

The Board of Health reports having deferred consideration of the Animal Services Program component of the 1998 Operating Budget to its next meeting on March 24, 1998 and having:

(1) requested the Acting Medical Officer of Health to report to that meeting on an interim arrangement for the provision of Animal Services in the City of Toronto which could include an extension of the existing contract with the Toronto Humane Society for the provision of animal shelter services in the boundaries of the former City of Toronto;

(2) requested the Acting Medical Officer of Health to consult with appropriate staff and report back to that meeting with a review of the two business plans for animal services prepared by the Toronto Animal Services Management Team, and by the Toronto Humane Society;

and requested that the Special Committee to Review the Recommendations of the Toronto Transition Team be so advised of the Board's action in this respect.

(i) (February 11, 1998) from the Acting Medical Officer of Health regarding the Business Plan for Toronto Animal Services for 1998-99;

(ii) (February 20, 1998) from Jack Slibar, Chief Operating Officer, Toronto Humane Society;

(iii) (February 23, 1998) from Liz White, Director, Animal Alliance of Canada; Barry Kent MacKay, International Programme Director, Animal Protection Institute; and Rob Laidlaw, Director, Zoocheck Canada Inc.

(A copy of the report "Animal Services in the New Toronto - The Business Plan Years 1998 and 1999" prepared by the Toronto Animal Services Management Team was distributed to Members of Council and the Board of Health and a copy thereof is on file with the City Clerk.)

(d) Appointment of Medical Officer of Health.

The Board of Health reports having considered in camera, the matter of the appointment of the Medical Officer of Health. At the resumption of the public meeting, the Board requested appropriate City staff to prepare a confidential report on this matter for consideration at a special meeting of the Board of Health to be called during the week of March 2-6, 1998.

Respectfully submitted,

JOHN FILION,

Chair

Toronto, February 23, 1998

(Report No. 3 of The Board of Health was adopted, as amended, by City Council on March 4, 5 and 6, 1998.)