Case Synopsis

The Bloom Clinic of the WellFort Community Health Services in Brampton, Ontario is mandated to serve six specific populations for HCV (Hepatitis C Virus) testing. The Bloom Clinic also tests for all Hepatitis viruses, HIV and STIs. The six priority populations listed below were identified as at-risk peoples due to having barriers “accessing traditional forms of health care” (Ministry of Health and Long-Term Care, 2013).

  • Substance users
  • People involved with the correctional system
  • Homeless people and those with inadequate housing
  • Aboriginal Peoples
  • Street-involved Youth
  • People with tattoos and/or piercings

The specially designed, multidisciplinary Bloom Clinic HCV team consists of a coordinator, outreach worker, nurse, and a psychosocial support worker (Ministry of Health and Long-Term Care [MOHLTC], 2013). Currently, the Hepatitis C Team Program Guidelines by the MOHLTC do not include sex workers. However, some sex workers are captured within the six identified specific populations. The mandate's goal is to reduce the spread of HCV by providing accessible support for testing and treatment (MOHLTC, 2013). Statistics show 20% of sex workers work outdoors (e.g. street corners) and the other 80% work indoors (e.g. their own home or client’s home, or commercial venues) (Canadian Public Health Association, 2014).

Sarah Briar, the outreach worker for the Bloom Clinic, presently builds partnerships with various organizations, health care providers, and community leaders. Building partnerships is part of the Bloom Clinic Outreach Strategy (Exhibit 1).

Sarah sat at Peel's Harm Reduction meeting and was informed by Constable Radishwich of the potential passing of Bill C-36 legislation. Bill C-36 is intended to criminalize those who purchase sex; this legislation is to resemble the Nordic Model in Sweden. Bill C-36 is the proposed amendment to the Criminal Code (1985); however, there is a concern that Bill C-36 will drive more sex workers to work underground and create barriers for health services outreach strategies.

Sarah shares with her team the potential impact of Bill C-36 and how it will affect the outreach strategies for HCV and HIV prevention and treatment. The team is Ministry funded, with limited resources and governance power to improve the provisions of Bill C-36.

Case Objectives

  1. Learning the implications of legislation (Bill C-36) on accessibility of services for the vulnerable (outreach strategies).
  2. Division of Powers (Federal and Provincial) in reference to Bill C-36.
  3. Challenge Bill C-36 by applying the Oakes test – Canadian Charter of Rights and Freedoms. 4. Challenges working within a Ministry funded program; in regards to exceeding the Hepatitis C team Program Guidelines and objectives.

Case Study Questions

  1. Apply the Nordic Model (Sweden) to the Canadian context. What are similarities and differences within the two judicial systems and demographics?
  2. Discuss the Oakes test – Canadian Charter of Rights and Freedoms; is Bill C-36 proposed provisions connected to its purpose?
  3. After developing a concept map of the social determinants of health for sex workers, which outreach strategies would you implement?


Oakes test, Hepatitis C Virus (HCV), harm reduction, accessibility, social determinants of health, Criminal Code, health behaviours, Canadian Charter of Rights and Freedoms, advocacy

Additional Author Information

Jaspreet Bhullar, RN, BScN, MPH

Rebekah Vaughan, BScN, Bloom Coordinator

Gerald McKinley, PhD, Assistant Professor



Recommended Citation

Bhullar, J., Vaughan, R., McKinley, G. (2017). Where are the Sex Workers?, in: John-Baptiste, A. & McKinley, G. [eds] Western Public Health Casebook 2017. London, ON: Public Health Casebook Publishing.