The principles that guide my more specific recommendations (c.f., 2 & 3) echo those placed on the international agenda by the Network of Sex Work Projects (c.f., Wolffers & van Beelen 2003; Bidman & Doezema 1997) as well as those identified more locally by Pivot Legal Society in Voices for Dignity: A Call to End the Harms Caused by Canada's Sex Trade Laws (2004). Thus, new social, legal and economic policies must ensure that:

• Sex workers receive the protection, respect, and opportunity to fully exercise their rights under the law afforded to all Canadians.
• Sex workers, sex worker advocacy groups, and other community organizations providing services to sex workers are consulted in formulating legal and policy changes that affect sex workers.
• All sectors of the sex industry (not just street-based work) are considered in formulating changes in law and policy.
• Legal, social and economic reforms undertaken at the federal, provincial, and municipal levels of government are gender-neutral and attentive to socio-economic differences.
• Systems are developed to facilitate the drafting of municipal, provincial, and federal legislation to ensure they operate in a complementary rather than contradictory manner.

It has long been recognized that criminalization is not an effective deterrent to prostitution. It does not protect the people engaged in it (women, men, and transgendered/transsexual people) or the communities in which it takes place (c.f., Fraser Committee 1985; Shaver 1985; FPT Working Group 1998; Lowman 1998). In addition-as Table 2 demonstrates-neither the Swedish model nor legalization is likely to be fully effective. Thus, I recommend that we:

• Section 210 (the bawdy-house provision)
• Section 211 (which prohibits the transportation of anyone to a bawdy-house)
• Section 212 (1) & (3) (the procuring provision) [Note: s.212 (l) (f) & (g) have to do with international trafficking and my research did not deal with these sections.]
• Section 213 ( the communicating provision)

• Section 173 (engaging in indecent acts)
• Section 174 (public nudity). They have resulted in an expansive interpretation of "public space" to include areas that are well out of the public "eye" and that would normally be considered private

2.3. Use existing legislation to counteract any criminal activity or other negative outcomes related to prostitution:

• Criminal laws to protect sex workers (e.g., assault in various forms (s.265, s.276, s.268); sexual assault (s.271, s.272, s.273), criminal harassment (s.264), forcible confinement (s.279(2)) etc.)
• Criminal & civil public disturbance laws to protect public from nuisance (ensure that the focus is on the disturbing activity and not the individual)
• Regard sexual procurement of children & youth as an abuse of power, not a prostitution contract (suggestion from Lowman, 1998)
• In the meantime use sexual interference (s.151) & sexual touching (s.152) to protect youth under 14.

2.4. Establish a committee to examine provincial laws and municipal bylaws regulating businesses and individuals involved in sex work. The committee should develop ways to:

• Ensure that decriminalization (as recommended in 2.2) does not lead to the creation of new quasi-criminal or punitive regimes through the use of fines or penalties.
• Ensure that the basic tenets of decriminalization are reflected at all levels of government
• No licensing or registration of individual workers
• No mandatory or contingent health tests
• Small groups of independent workers can operate without regulation
• Larger establishments are treated similar to businesses in other sectors
• Use of ‘red-light’ zones for street-based workers be non-mandatory.

It has long been recognized that legal reform on its own will not improve the health and safety of sex workers or the health of communities (e.g., Fraser Committee 1985; Shaver 1985; Benoit & Miller 2001). Consequently, we must integrate legal reform with social and education programs that address the underlying social problems that help maintain poor working conditions for sex workers. These conditions include the socio-economic disparity between women and men, the double standard of sexuality between women and men, and the gendered nature of violence. As Table 2 demonstrates, social intervention addressing the concerns of sex workers and residents will be most effective if developed in concert with the decriminalization of prostitution. Thus, I recommend that we:

3.1. Address sex work as work rather than as a criminal activity

• Ensure sex worker participation in all legal and policy discussions regarding sex work
• Facilitate the use of labour and work-place legislation at provincial and municipal levels to improve the work conditions and workplace benefits of sex workers.
• Ensure sex workers have the rights, protection, and respect afforded to all Canadians.
• Ensure the sex industry operates under the same health and safety rules as other similar businesses.

3.2. Eliminate stigma & marginalization in police & judicial responses.

• Provide education and training for law enforcement and judicial personnel as well as legislators at all three levels of government regarding the factors that increase or decrease risks to the health and safety of sex workers.
• Educate the police on how best to provide police services to marginalized populations such as sex workers.
• Introduce police-community liaisons to facilitate better police-sex worker relations.
• Include sex workers and their organizations in the design and implementation of these educational programs.

3.3. Educate the public & policy makers about the diversity in sex work and sex workers' lives

• Develop public education campaigns designed to dispel myths and misunderstandings about sex work and sex workers.
• Include sex workers and their organizations in the design and implementation of these educational programs.

3.4. Provide economic and organizational support for sex worker organizations

• All levels of government should make funding available for the further development of information brochures and seminars through local sex worker organizations designed to educate sex workers about:
• the laws related to their work
• health and safety risks
• economic security issues
• their rights as citizens and the options available to them when their rights are violated
• All levels of government should make funding available to sex workers' organizations to educate, support, and advocate for sex work and sex workers.

3.5. Inform sex workers about and facilitate their access to existing education and job training programs offered by all levels of government and through government-private partnerships. This includes access to:

• Academic education, including the means to complete high school
• Vocational training that is affordable and meaningful.
• Employment opportunities that match individual skills and interests

3.6. Support / Conduct pan-Canadian multi-site research (peer evaluated) to increase our knowledge about the industry and to investigate the broader issues underlying the harms involved both to sex workers and residents.

Canada is in an excellent position to be proactive and innovative in dealing with this challenge. We are looking for policy programs and actions that decriminalize prostitution activities and for social reforms promoting the health and human rights of sex workers, and the health of communities. There have been attempts in the past that did an excellent job of articulating appropriate directions for both legal and social initiatives (e.g., the Fraser Committee Report) but the political will to put them into place was not there. Now is the time to get it right! Researchers, sex workers, residents, and their community-based organizations (who have the highest levels of public confidence) are eager to help in this endeavour.

As members of the SSLR committee you are in an excellent position to mobilize these groups to address the issues in a fair, equitable, and effective fashion. I urge you to revisit the mandate of the Subcommittee and to rely on it as your guide. This will be especially important when hearing conflicting recommendations. The motion (M-192) read that:

The Standing Committee on Justice and Human Rights be appointed to review the solicitation laws in order to improve the safety of sex-trade workers and communities overall, and to recommend changes that will reduce the exploitation of and violence against sex-trade workers [my emphasis].

Benoit, C. & Millar, A. (2001) Dispelling myths and understanding realities: Working conditions, health status, and exiting experiences of sex workers. BC, Canada: Prostitutes, Education, Empowerment and Resource Society (PEERS). Available at: http://www.peers.bc.ca

Bindman, J. & Doezema, J. (1997). Redefining prostitution as sex work on the international agenda. London, UK: Anti Slavery International and Network of Sex Work Projects.

FTP (1998) Federal / Provincial / Territorial Working Group on Prostitution: Recommendations in Respect of Legislation, Policy and Practices Concerning Prostitution-Related Activities.(December).

Lowman, J. (1998). Prostitution law reform in Canada. In Shiibashi (ed.) Toward comparative law in the 21^st century (pp. 919-946). Tokyo: Chuo University Press.

Pivot Legal Society Sex Work Subcommittee (2004). Voices for dignity: A call to end the harms caused by Canada’s sex trade laws. Available at: http://www.pivotlegal.org/sextradereport

Shaver, F.M. (1985) Prostitution: A Critical Analysis of Three Policy Approaches. Canadian Public Policy XI (3): 493-503).

Wolffers, I. & van Beelen, N. (2003). Public health and the human rights of sex workers. Health and Human Rights. Volume 361, Number 9397 (June 07).