Massage Therapy in Ontario is regulated under the Regulated Health Professions Act, 1991 (RHPA). Under this legislation, the College of Massage Therapists of Ontario (CMTO) is required to act exclusively in the public interest, ensuring that Massage Therapy is delivered in a way that is safe, ethical, competent, and trustworthy.

This petition began as a call for clearer protections for Massage Therapists facing sexualized and abusive client behaviour. As this work is continually progressing, it has now become evident that this issue is not isolated, but instead reflects systemic gaps within Massage Therapy regulation that directly affect both practitioner safety and patient protection.

This update explains how recent regulatory, legal, and governance developments intersect — and why adherence to the RHPA, rather than further policy expansion alone, is key to meaningful change.

 
1. Federal Law Already Recognizes Practitioner Safety as Essential to Health Care

In December 2021, Bill C-3 amended the Criminal Code of Canada to explicitly protect:

• health care workers
• those assisting health care workers
• people accessing health services

The Criminal Code now makes it a serious offence to intimidate, threaten, or obstruct a health professional in the performance of their duties, with penalties of up to 10 years imprisonment.

This amendment reflects a clear federal recognition that:

Health care cannot be safe or accessible if the people providing care are subjected to fear, intimidation, or abuse.

Massage Therapists are regulated health professionals under the RHPA. However, these federal protections have not been meaningfully adopted within Massage Therapy regulation, particularly in private, clinic-based, and solo-practice settings where most RMTs work.

 
2. CMTO’s Recent Standards Changes Acknowledge Abuse — But Shift Risk Back to Practitioners

As of October 1, 2025, CMTO amended its Standards of Practice and Code of Ethics to allow RMTs to immediately discharge a client who engages in abusive behaviour, defined broadly by CMTO as:

• physical abuse
• sexualized behaviour
• verbal or psychological harm

While this change acknowledges the reality of abuse, the primary mechanism for managing unsafe clients is referral back to the Public Register.

This approach raises serious concerns:

• It does not prevent the client from re-entering the system.
• It transfers risk to other RMTs, many of whom also work alone.
• It places the burden of safety management entirely on individual practitioners.
• It does not align with the Criminal Code’s recognition of intimidation and obstruction as offences, not merely “conduct issues.”

In effect, the regulatory system acknowledges abuse without creating a structural safety response.

 
3. Practitioner Safety Is Not Optional Under the RHPA — It Is Foundational to Public Protection

The RHPA does not limit public protection to client outcomes alone. A regulatory college must also ensure:

• ethical practice environments
• professional integrity
• sustainable conditions for safe care delivery

Massage Therapy is unique among RHPA-regulated professions in that:

• 89% of practitioners are women,
• many work alone,
• there is no sector-specific workplace safety framework,
• there is no Ministry of Labour “Green Book”, and
• there are no standardized trauma-informed discharge or safety protocols.
• Other regulated professions (e.g., nursing, medicine, PSWs, ECE, Teachers, hospital-based care) operate within institutional violence-prevention systems managed through mandatory training. Massage Therapists do not.

This gap undermines the RHPA’s public-interest mandate, because unsafe practitioners cannot provide safe care.

 
4. Governance, Planning, and Resource Allocation Matter to Safety Outcomes

At the same time that practitioner safety remains structurally unaddressed, the CMTO has:

• initiated a rebrand and identity shift,
• expanded EDI governance structures,
• proposed a five-year strategic planning cycle, despite a mandatory three-year cycle in its Governance Handbook,
• increased registrant fees, and
• increased staff compensation and operational spending.

The CMTO’s own Governance Handbook warns:

“If time is spent on non-regulatory issues, College resources will not be available for matters within its mandate and the College may be seen as improperly exercising its statutory powers.”

The concern is not the existence of EDI work or strategic planning — both can be legitimate and applicable — but is whether core safety obligations are being deprioritized, and whether mandatory registrant fees are being used in a way that directly advances public protection.

 
5. This Is Not a Call to Dilute Regulation — It Is a Call to Enforce It Properly

This petition does not argue that Massage Therapy should be deregulated, nor that standards should be weakened.

Instead, it calls for:

• faithful adherence to the RHPA
• alignment between Criminal Code protections and regulatory practice
• recognition of sexualized client misconduct as an occupational safety issue
• structural supports that prevent harm before it occurs.

Where regulation fails to account for practitioner safety, it creates systemic risk — for therapists and for patients.

 
6. What This Petition Now Calls For

Based on legal review, regulatory analysis, and lived experience, this petition now calls for:

• Legislative recognition of sexualized and abusive client behaviour as a systemic occupational hazard across regulated health professions.
• Potential expansion of Criminal Code Bill C-3 protections into non-hospital, clinic-based, and private practice settings through provincial mechanisms.
• Sector-specific safety frameworks for Massage Therapy, comparable to those that exist in other regulated health professions.
• Trauma-informed discharge protocols and practitioner supports that do not simply transfer risk to other providers.
• Regulatory accountability, including transparent governance, financial stewardship, and adherence to the RHPA’s public-interest mandate.
   

Closing Statement

This petition exists because regulatory silence is not neutrality — it is a choice with consequences.

Protecting patients requires protecting the conditions under which care is delivered. The RHPA already provides the framework. The Criminal Code already recognizes the harm. What's missing is coherent, accountable implementation within Massage Therapy regulation.

This is not about image, branding, or optics.
It is about safety, trust, and the integrity of Ontario’s health-care system.