What we heard: Proposal on the provision of menstrual products in federally regulated workplaces

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In May 2019, the Labour Program published a Notice of Intent in the Canada Gazette, Part I. This notice outlined a proposal to require employers to provide free menstrual products in their workplaces. The proposal referred to regulations under Part II of the Canada Labour Code (the Code) relating to occupational health and safety.

For a period of 60 days, stakeholders and members of the public had the opportunity to:

These questions aimed to collect specific information on issues including:

Who we heard from

In response to the Notice of Intent, the Labour Program received 42 submissions, during the consultation period. The 42 submissions included:

Find a list of the 13 organizations that provided feedback below:

What we heard – An overview

Participants were generally supportive of amending regulations under Part II of the Code to require employers to provide free menstrual products in the workplace. Out of the 42 respondents:

The 13 employers and organizations listed above, mostly favoured the proposal, to require employers to provide free menstrual products in the workplace. However, many participants raised further questions for consideration. As well, individuals who submitted feedback were more critical of the proposal. Out of the 29 submissions from individuals, the results demonstrated the following:

What we heard – By topic

This section provides an overview of the types of responses and common themes received by the Labour Program in response to the Notice of Intent. Input received from this consultation period will help to inform next steps.


Feedback indicates that if the Labour Program considers the proposal further, employers will need to provide pads and tampons in the workplace. Participants gave examples of products that employers could supply, such as:

Impact on the environment

Over 24% of the commenters expressed concern about the environmental impact of menstrual products. Participants indicated that the Labour Program should consider innovative and environmentally friendly products. In addition, multiple commenters were concerned that limited choices would deter employees from choosing more environmentally friendly options. It should be noted that 4 provincially regulated companies promoted their environmentally friendly products in their submissions.

Health concerns

Two commenters indicated that the Labour Program should ensure that the products that employers supply, be safe and free of toxins. A proposed solution was to turn toward organic and 100% cotton tampons and pads. This is due to the risk of ovarian and uterine cancers, and toxin exposure, which includes providing tampons and pads that do not contain:


The Labour Program received a number of suggestions for where employers should locate the products:

Some commenters noted that employers should not store and locate the products in common areas, as it would infringe on individual privacy. Instead, commenters suggested for workplaces to store and locate the products in washrooms and change rooms only. Commenters also noted that some workplaces have washrooms that are open to the public. Therefore, they suggested that workplaces make the products available in another gender-neutral, discreet location for employee access only.

One submission analyzed 5 possible solutions to provide menstrual products in workplaces. It noted that placing individual dispensers in every washroom stall would come at a significant cost. However, the submission also noted that this would maximize accessibility and minimize the potential for discrimination. On the other hand, placing a dispenser in a common area would guarantee maximum accessibility and maximum cost effectiveness, but created a greater risk for discrimination. It noted that not providing these products in a private manner could be discriminatory towards gender diverse employees. In other words, some employees may be forced to disclose their gender identity in order to access the products provided. This could expose them to potential harassment.

Gender neutrality and equity

Over 26% of the comments highlighted the need for menstrual products to be accessible and available in all washrooms or gender-neutral locations.

Two participants noted that all women’s washrooms should have products available. However, the majority restated the importance of safe and equitable access to menstrual products for all employees, which must include the gender diverse community.


Out of the 17 commenters against the proposal, 71% raised concerns about the financial implications to the employer. Some believed that providing free menstrual products would lead to theft, misuse and waste, or that only low-income facilities should have free access. Concern that if dispensers were required to hold menstrual products that this would add to the financial implications to employers.

Over 31% of the total submissions indicated that the cost to implement and maintain this initiative would be minimal. Several commenters mentioned that the dignity of employees, as well as their psychological and physical health and safety should come first. In addition, commenters mentioned that the cost for providing menstrual products would be marginal. Some commented that if employers can afford toilet paper, then they could also afford to provide menstrual products. These commenters were not concerned about misuse and waste of the products. This is because they do not believe toilet paper and soap are currently misused in the workplace.

Three participants provided rough estimated costs for dispensers and boxes of menstrual products. The estimates showed how costs to employers would change based on the number of full time and part time employees. Another respondent suggested that employers should be required to subsidize the cost of environmentally friendly products. These participants noted that, while reusable products require a higher initial investment than disposable ones, the cost is substantially less over time.

Workplace initiatives

Participants mentioned/discussed these current initiatives in Canadian workplaces:

Feedback quotes

“Gender equality is not about men and women being biologically the same, but is about addressing barriers to equality, and allocating resources to programs and decision-making that takes these barriers into consideration to level the playing field.”

“Females working for the government are well paid, and the taxpayers should not be burdened with providing their sanitary needs.”

“Overflow or menstrual cycle starting when you weren’t expecting it is definitely a constant reality.”

“Menstrual products supplied by employers should be safe and healthy, and meet environmental goals as well.”

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