Thank you for your recent email and attachments. This response is to assure you that they have been received by my office.
I have forwarded your e-mail to Mike Farnworth, the Opposition Critic for Public Safety and the Solicitor General, for his information. I have also sent your material to local Vancouver MLAs Jenny Kwan and Shane Simpson.
You have put an incredible amount of time and energy into this project; I appreciate you sharing it with me.
Please note that the confidentiality of all mail sent to this office is strictly adhered to and respected.
Carole James, Leader
New Democrat Official Opposition
I am very encouraged by her email. I wrote back:
Thank you so much for responding and acknowledging the time and effort that went into creating the revised guidelines. I am certain that if people just took the time to read them and see how harmful they are as they exist, they will recognize the benefits of the revisions, for the exotic dance industry as well as for maintaining clear and understandable government publications. Please contact me any time to discuss this further.
So without further ado, here are the final revisions as they were sent out. Please remember that the revisions were not made with the "upstairs" rooms in mind because we could not get consensus among industry members on how that might look, as well as that the current reg's seem not to touch those rooms anyhow (although inspectors still find their ways into those rooms for some reason).
Proposed Revisions to th
Liquor-Primary License Terms and Conditions –
A Guide for Liquor Licensees in
The following recommendations to revise one part of the regulations for Liquor Licensees in BC that pertain specifically to “Performances by Strippers, Exotic Dancers and Other Adult-Oriented Performers” (page 17), came as a result of the realization among exotic entertainment industry members that these guidelines are vague, undefined, and generally harmful to the members of the industry.
We (exotic entertainers) feel that such guidelines should be made in consultation with exotic entertainment industry members, to ensure that they (1) accurately reflect the industry as it exists; (2) have clear definitions so that enforcement does not depend on the individual discretion of inspectors, but is consistent across the province; (3) provide clear and detailed information about what would or would not constitute infractions; (4) do not require illogical practices surrounding the general nature of the industry; and (5) provide clear and obtainable expectations for exotic entertainers to fulfill their occupations in safety and free from violation or harassment.
As a community, we hope that the liquor license regulations for strip clubs might also prevent clubs in
The guidelines pertaining to the exotic entertainment industry currently found on page 17 in the guide are vague and open to misunderstanding.
Because the Liquor Board has the sweeping power to shut down clubs at their discretion, we feel that the rules and guidelines should be clearer and provide detailed explanations and specific terminology to ensure that infractions are not made in misunderstanding, and that inspectors are not making random judgments based on their own opinions rather than common industry standards.
To that purpose, we have created revised guidelines to replace the ones currently in use. We have included full explanations for the reasoning behind our recommendations.
Update: Following the creation of the proposed revisions,
Parts of the guidelines were then further revised to reflect the concerns mentioned during that conference call. And some of the current guidelines were explained further. It was discovered that although some inspectors have been using the current guidelines to make tipping of exotic dancers illegal in BC, tipping is actually quite legal and there are no regulations that prohibit it.
Susan Davis and
Who “We” Are
This report was written by
Sixty-six industry members were contacted by email for their input and a discussion was started in an industry section (only authorized members can participate) of The Naked Truth forums. Of the people contacted and invited to participate, eight former and current exotic dancers, four club employees, and two industry agents participated in creating the following revisions.
This project was completed with no funding whatsoever. Please consider how important these revisions are to our community that we would volunteer to spend so many hours working on them.
There are three parts to the specific section pertaining to the exotic entertainment industry (hereafter referred to as “the guidelines”). These are not separated or numbered in the guidelines, but we have separated them for the purposes of this report to make it easier to read and understand.
The guidelines start off with definitions of stripper, exotic dancer, and adult-oriented entertainer. The definitions used here do not reflect the definitions widely used by industry members themselves. While it was pointed out by Kari Toovey (Policy Analyst) that the definitions are not relevant to the guidelines, it is important to us that we are defined correctly in a public document.
Current Regulation: [entertainers]…must wear appropriate clothing while walking through the audience, both before and after performances. This clothing must not be part of their stage costume.
This rule is unrealistic because entertainers will need to access the stage in costume, therefore they wear their costumes while walking through the audience before performances, except where clubs have entrances directly to the stage from somewhere outside the boundaries of the public. The belief that this guideline is needed to protect dancers from audience members is unfounded.
Current Regulation: The exotic dancers / strippers may not act as servers or hold any other employment position in your establishment while they are also working for you as entertainers.
There does not seem to be a reason why this rule would constitute a safety issue or otherwise. Since many exotic entertainers will transition into serving when leaving the industry, this has historically been an avenue for that purpose. It also provides employment opportunities for exotic entertainers who start school or have families, and are not at liberty to travel like most dancers. Furthermore, we wonder why this rule applies specifically to entertainers defined as “strippers” or “exotic dancers”, but not to “adult-oriented performers.” If this regulation is an attempt to outlaw topless servers, it makes no sense. Strip clubs that have had “dancing servers” in the past did not have them serving topless. And many private events held in liquor licensed establishments do occasionally hire women to act as topless servers – so this guideline seems not to have impacted that issue in any way.
We also added a few rules to this section.
Proposed Addition #1:
As you will see in Part 3, there are currently regulations in place that make tipping the dancer open to interpretation by individual inspectors. Many clubs have rules against tipping the dancers for fear of having their clubs closed down.
Proposed Addition #2:
This proposed addition is very specific to the industry. Exotic dancers market their businesses with promotional items such as posters and key chains. Because of the ambiguity of the current regulations, individual inspectors could interpret them to the detriment of the club and safe work spaces for dancers. Therefore, we wanted to be as specific as possible to avoid any misinterpretations in the future.
Proposed Addition #3:
The nature of the exotic entertainment industry is to provide a platonic sexual outlet for patrons through sensual dance and fantasy. This in itself makes this particular rule confusing – what would each inspector consider realistic or simulated sex acts? For instance, would it be okay for an exotic entertainer to squeeze her breasts together, or is this a simulated sex act? Are exotic entertainers permitted to wiggle their bottoms suggestively, or would this be an infraction? Similarly in relation to the reference to violence, many theme shows involve bondage types of costumes and props – a particularly popular theme, in all honesty. Are themes like this considered infractions? It is unclear what exactly this rule is trying to accomplish. Our proposed revision assumes that this rule is meant to ensure safety of the customers watching the shows.
1) A desire to create guidelines that will protect the exotic dance industry as a non-contact industry where dancers are paid for their stage shows. There is a fear that if we do not protect these elements of our industry that it will degenerate into one like
2) A desire to create an industry that is supportive of non-contact options for exotic dancers and supports varying exiting strategies (such as becoming a dancing waitress).
3) A desire to create specific, understandable guidelines to ensure that enforcement does not depend on the individual discretion of inspectors, but is consistent across the province.
4) A desire to strengthen the exotic entertainment industry by providing alternative income generating possibilities (dancing servers, table dances, tipping) which will also draw more patrons into the clubs. Strengthening this industry is a key element in providing safe work spaces for women and reducing women’s reliance on survival sex work – work that has led to the disappearance and murder of many women in
It is our hope that the needs and desires of our community will be respected and these revisions enacted. We believe that we have ensured that any and all concerns that officials may have regarding our industry have been addressed in our revisions. If we have missed anything, we ask that we be consulted before any decision is made so that we can ensure there are no misunderstandings.
We realize that the current regulations were not created to deliberately harm us. But we also realize that our industry is a mystery to most people. It is our intention to bring understanding and accuracy to policies that impact us as citizens of this province.
Thank you for your time and attention to this matter.