top of page

Submission to the Standing Committee on Public Safety and National Security October 20, 2022


The survivors and families and affected community members that comprise the Danforth Families for Safe Communities experienced terror and tragedy from gun violence on a horrific night on July 22, 2018. It was a handgun that came to a retailer in one part of the country and was subsequently stolen and used in Toronto to kill a girl, a teenage woman, and injure thirteen (13) others. It is our view that despite our tragedy, as well as others before it and since, the country has not done enough to date to prevent similar incidents from occurring again.

We are by no means representing DFSC as experts in firearms or in the law, although we do have those with various levels of experience with both, within our grassroots group. We submit this document to SECU in order to express our point of view, based on our experience and what we have learned as engaged citizens.

We believe that the recipe for gun violence prevention is complex and will need many measures because the root causes and remedies for gun violence are varied. We have reviewed Bill C21, and from our point of view, believe it needs strengthening in some areas, but is comprehensive enough to benefit the safety of Canadians. We now call on SECU to work with urgency.

We are grateful to have been invited to make verbal comments to the Committee on October 20, 2022. The text of those comments appears as Appendix A to this document.

In addition to those comments, we offer the following as our perspective on Bill C-21.

Recommendations to the Committee and Supporting Points

1) We ask SECU to act with urgency.

a. In the absence of the measures in Bill C21, the incidents of gun violence continue to grow 1 and more families are enduring what we have had to endure because of the trauma inflicted on them by abuse of firearms.

b. Our position is that Bill C21 is comprehensive in scope, addressing many issues we agree with, such as measures to prevent gun smuggling, and budget for the Building Safer Communities fund. Curbing gun violence is about more than gun bans and buy back programs, but we still hold that reducing the supply of the most dangerous guns – assault style rifles – and ones most often used in crime – handguns - is a necessary plank in the overall strategy.

c. We see that the government has adopted some of the recommendations made in “A PATH FORWARD: REDUCING GUN AND GANG VIOLENCE IN CANADA”. We ask you to consider others that can be accomplished through a commitment to budget and resourcing such as #4 (stronger commitment and resources for tracing).

d. We feel that the recommendations around regulating gun parts (#28) and ghost guns (#29) is not strongly represented in Bill C-21 and will require subsequent action as counterfeit weapons become even more prevalent.

2) We support the need to bring intro force, the announced freeze on the handgun market, and to start to reduce their supply in private hands.

a. What happened on the Danforth was enabled by a legal handgun that was imported legally, retailed legally, and stolen. Theft is a foreseeable and unfortunate consequence of retailing. That gun – a Smith and Wesson M&P 40 caliber handgun - should never have been on a retail shelf in Canada, given the risk.

b. While we have a supposedly burdensome and intrusive 2-step licensing process – the RPAL - handgun take-rate in Canada has grown faster than the general growth of guns since 2015 so now we have 1.1 million or so in private hands. The concern with dangerous products, is that with more of them in circulation, the absolute number of death and injury will rise … and that sad reality has indeed accompanied the rise in handgun ownership 1. Statistics Canada (StatsCan) data complied from police reporting shows the format most often used in crime is a handgun. StatsCan data shows that homicides and violence using a gun are on the rise in Canada1. Toronto Police Service data shows the same

c. StatsCan data complied from police reporting and trace efforts (such as they are) says that more traces lead back to domestically sourced guns than smuggled guns, contrary to anecdotal reports that smuggled guns from the US are 90% of the crime guns. This “90%” lacks consistent framing or context when quoted and is often number repeated but not attributed to any data source such as from RCMP national tracing and/or the Ontario FATE database, for example.

d. We also see evidence that thousands of handguns are lost or stolen each year. We find it beyond credulity that none of these become a source of crime guns – especially since this is exactly what happened to enable the Danforth shooter.

e. We see several media reports from accredited sources (see Appendix A of this brief) - that show incidents of loss, theft, diversion and illegal acts carried out by licensed owners - on Spadina Road this past spring as alleged and as a recent example, but there are many others.

f. We agree that we also need to deal with smuggled guns – which Bill C21 addresses. But we have two issues of risk where handgun supply is concerned - smuggled guns AND incidents of loss/diversion/theft coming from the growing number of handguns in private hands.

g. We note that the UK banned handguns in the mid 90s and their per capita rate of gun violence is a fraction of ours.

3) Limit the number of exemptions that could undermine this freeze, and clarify those contemplated in Bill C-21.

a. Exemptions by their nature present opportunities to resist change and undermine the goal of freezing and reducing the handgun supply.

b. Most of these exemptions are for people that choose to use a handgun; however, gun users could use a rifle or shotgun and enter events that feature a long gun or use long guns for safety. Most Canadian license holders do not have handgun licenses. Most elite shooters today that make it to the Olympics are not in a discipline requiring a handgun.

c. The Olympic/Paralympic programme features the use of very specific pistols. Please clarify that the guns used by elite shooters are the guns very specifically within the ISSF/IOC specification 10 and not just “any deemed necessary for training” as the Bill currently reads. Also, to ensure that the assortment of handguns generated by the exemption does not expand, freeze the exemption to the caliber of guns in use at the time that the Bill is passed.

d. In our view recognizing less formal organizations such as IPSC, under the sport shooting exemption, would not restrict the assortment of guns in use. IPSC has five (5) categories for handguns 11 including an open category. In our view, the informality of IPSC versus the standards exerted by the IOC and ISSF, and the breadth of potential eligible guns that could be used, would be a pathway for continued growth of handgun ownership, undermining the intention of Bill C21.


1) Wording change for paragraph 43, referring to section 97 of the ACT:

Relevant clause currently reads:

97.1 Sections 12.2 and 19.1 do not apply in respect of an individual who ….

(iii) that the handgun in question is necessary for training, competing or coaching. Change clause (iii) to:

(iii) that the handgun in question is necessary for training, competing, or coaching in the pistol shooting disciplines of these programmes; such exemption for possession restricted to the particular handguns meeting the specifications for the programme of the International Olympic Committee (IOC) or the International Paralympic Committee (IPC), such specifications not to be further amended.

4) Do not create a commercial gun range ownership model by loophole

a. We also draw attention to the business exemption – this exemption must be clarifies as applying only to security firms and the limited commercial sales channel that supports these users (as well as those who have the wilderness carry exemption).

b. The number of points of sale – retailers and distributors - involved should be dramatically reduced and tight regulations should be enforced around verifying purchasers using the business exemption, as well as those authorized to sell to that market.

c. We are concerned that gun ranges might try to seek the business exemption, and purchase and hold weapons on behalf of members. The Shooting Clubs and Shooting Ranges Regulations ( seems to regulate a shooting range as a facility for owners of guns to use them, and does contemplate a range-as-business, that possesses weapons and then allows patrons, on mass, to use them. We have heard repeated statements in the media from police forces saying they are already resourceconstrained and stretched in their ability to enforce licensing and other provisions of the firearms laws. We are therefore concerned that 1) ranges are set up to be secure facilities that could house an arsenal of weapons and resist theft, or that 2) there are sufficient regulations and the resources to enforce these higher-risk approaches without risk to public safety. Let’s not back into this idea – exclude this potential exemption until, and only when, the regulations are amended, and resources are committed to mitigate the risk of this approach.

5) Adopt Recommendation #27 from A PATH FORWARD: REDUCING GUN AND GANG VIOLENCE IN CANADA – “That the Government of Canada amend current legislation to require a possession and acquisition license to purchase magazines in the same way as ammunition”

a. Our crime was exacerbated by the fact that the shooter bought seven extra magazines for his stolen gun using his credit card. The shooter had no PAL.

b. Please add “magazines” and where necessary, “any all accessories that attach to the gun, as well as parts”, wherever “ammunition” is noted in the Act, related to ammunition as having a requirement for a valid PAL or RPAL by the buyer.


DFSC stands willing to provide any additional input that the Committee may request. We also stand with groups providing input on these and other maters before the committee such as PolySeSouvient (several issues in agreement but especially those prohibiting high capacity magazines and defining and banning assault style rifles), the Quebec Islamic Cultural Centre (their ten point plan), and several groups working to adapt the red flag laws so they more practical, more protective and more responsive for those it intends to protect, that what has been proposed.


bottom of page