Submission to the Ontario College of Trades. Journeyperson-to-Apprentice Ratio Review. General Carpenter Trade

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1 Submission to the Ontario College of Trades Journeyperson-to-Apprentice Ratio Review General Carpenter Trade February 4, Page 1

2 Introduction The Christian Labour Association of Canada (CLAC) has prepared a response to the Ontario College of Trades Journeyperson-to-Apprentice Ratio Review for the General Carpenter trade. CLAC notes that the only area where data exists to support changing the ratio is in the area of the current supply of Carpenters and projections for the future demand. CLAC has calculated (see our response to criterion ix.) that Ontario will need 32,276 journeypersons in the trade by Based on completion rates, this will require as many as 24,311 new apprentices to enter the system in order to meet this requirement for new journeypersons. The other significant factor for consideration is the obvious disparity in the ratio used for carpentry and the ratio used for all other restricted and voluntary trades as demonstrated on page 15. As such, on the basis that demand for Carpenters will outpace supply and because the uniquely restrictive ratio of 1:4 seems to produce no additional protection for now, CLAC is recommending that the current ratio schedule be changed to a ratio of 3 journeypersons to 1 apprentice (3:1) to ensure that the industry can take on sufficient numbers of apprentices to meet the requirement for 8,134 new journeypersons. CLAC proposes that the current ratio of 1:1 for the first apprentice hired by a firm be maintained. CLAC has responded to all criteria established by the College of Trades. Page 2

3 About CLAC Representation with Integrity Value on the Job Site Christian Labour Association of Canada (CLAC) is Canada s multi-craft construction union representing skilled tradespersons working in every sector of the construction industry in the province of Ontario. Every day, thousands of CLAC members in Ontario build bridges, roads, water and waste treatment plants, high-rise buildings, and retail shopping centres. Founded in 1952, CLAC is a union built on principle. Its name reflects the principles of dignity, democracy, freedom, justice, responsibility, and respect for all. Its goal is to establish a true partnership between employers and employees for the benefit of all. Through innovation and using a new model of advocacy and construction organization, CLAC has experienced remarkable growth in Ontario and across Canada. Its members have an enviable record of doing their work competently and safely, with results that count them among the leaders in their field. CLAC is an independent Canadian labour union representing over 55,000 workers in a wide range of industry sectors construction, health care, retail, service, transportation, manufacturing, and mining. The union serves its members from 14 regional offices in Alberta, British Columbia, Saskatchewan, Manitoba, and Ontario. CLAC s head office is in Mississauga. A Multi-Skilled Union CLAC organizes construction workers of all trades in a particular company into a single bargaining unit. In labour relations jargon, this is known as wall-to-wall bargaining, where construction workers in compulsory, voluntary, and uncertified trades are organized together in a single unit. This multi-skilled approach creates an efficiency not Page 3

4 met through any other model, eliminating trade silos and encouraging all workers to work together to complete construction projects safely, on time and on budget. Training for the Future CLAC provides training support for its members to acquire, maintain and upgrade their skills. Courses are designed to keep members up to date with legislative requirements and codes, as well as provide them with applicable health and safety training. CLAC established training centres in Ottawa, Grimsby, Mississauga, and Chatham, and opened a provincial training facility in Cambridge in CLAC works closely with Ministry of Training, Colleges and Universities (MTCU) apprenticeship offices in Ontario and in cooperation with community colleges and training organizations. By working together, CLAC ensures that those entering the construction trades acquire and develop the knowledge and experience for a skilled workforce for tomorrow s projects. Page 4

5 Response to Criteria As indicated earlier, CLAC is requesting the current ratio schedule (see below) be changed to a ratio of 3 journeypersons to 1 apprentice (3:1). We propose no change to the current 1:1 ratio for the first and second apprentice hired by a firm (herein after referred to as 3:1). Based on our calculations, CLAC is projecting that Ontario will need additional journeypersons by 2016 in order to meet anticipated increased demand for Carpenters due to: 1) Normal attrition 2) Retirements (the average age of a Carpenter with a CofQ is 65) and deaths 3) The low completion rate for the CofQ in this trade A change to 3:1 will help the industry to address the requirement for additional journeypersons. We believe this proposed change from the current ratio schedule provides: 1) A cautious approach to ratio reform allowing the College of Trades to collect objective data on the impact of the change from a variety of factors in preparation for the next round of ratio reviews in four years. 2) Negligible impact on existing journeypersons working in the trade as the changes are minimal and employers will continue to employ skilled journeypersons to mentor the new apprentices that could be hired after the ratio change is achieved (see our analysis in response to criterion v)). Page 5

6 3) No impact on the health or safety of journeypersons or apprentices working in the trade or the general public as there is currently a strong health and safety framework in place in Ontario through the Occupational Health and Safety Act and other legislated requirements enforced by the Ministry of Labour to ensure the health and safety of workers and the general public. Response to Specific Criterion Each of the eleven criterions is copied into the submission with CLAC s response below. i) The scope of practice of the trade. Ontario Regulation 1056 under the Trades Qualification and Apprenticeship Act governs the scope of General Carpenter trade. We anticipate no change, nor do we propose any change to the scope of practice that will be contained in the corresponding regulation to the Ontario College of Trades Act, 2009 (O. Reg. 275/11, s. 15). ii) The apprenticeship program established by the College. The established apprenticeship program for General Carpenter should be retained in its current form. iii) How the journeyperson to apprentice ratio for the trade may affect the health and safety of apprentices and journeypersons working in the trade and the public who may be affected by the work. In CLAC s view, there is no credible data from other jurisdictions that have changed their ratio on which we can rely for this review. Additionally, if specific data related to the effect of a change in ratio in other jurisdictions was available, it would fail to account for the various differences in the trade between jurisdictions. Page 6

7 The type of work, the predominance of difference in sectors (industrial/residential/institutional) and the fact that each jurisdiction will have its own unique health and safety legislative framework and enforcement mechanisms would create multiple variables and render such comparative analysis as quite nearly meaningless. We do not anticipate that an incremental shift from the current ratio schedule to 3:1 will have any impact on the health and safety of journeypersons, apprentices and the public. Ontario has a strong health and safety framework in place through the Occupational Health and Safety Act, and other legislated requirements enforced by the Ministry of Labour. The move to 3:1 will allow the College of Trades to intentionally monitor the impact, if any, on the health and safety [or lost time injury (LTI) data] of journeypersons, apprentices and the public over the next four years and to provide objective data for the next round of ratio reviews. iv) The effect, if any, of the journeyperson to apprentice ratio of the trade on the environment. The journeyperson-to-apprentice ratio has no impact on the environment. The Carpenter trade is highly regulated through a variety of legislative requirements and environmental protection enforcement mechanisms, all of which serve to protect the environment. A change in the ratio will in no way effect the efficacy of such legislation or enforcement of same. v) The economic impact of the journeyperson to apprentice ratio of the trade on apprentices, journeypersons, employers and employer associations and, where applicable, on trade unions, employee associations, apprentice training providers and the public. Page 7

8 Apprentices Changing the ratio to 3:1 will provide more opportunities for employers to hire more apprentices than under the current ratio. This will have a positive economic impact on apprentices. As noted earlier, Ontario will need 8,134 new journeypersons in the carpentry trade by To meet this goal, Ontario will need as many as 24,311 new apprentices entering the system by 2016 depending upon completion rates. Page 8

9 Journeypersons The concern that employers will choose to replace journeypersons with apprentices after a significant change to the ratio (such as moving to 1:1) is mitigated by CLAC s proposal for 3:1. Some have argued that lowering the ratio would encourage employers to replace well paid journeypersons with less costly apprentices. The table on the following page demonstrates that, under our proposed scenario, this concern is overstated. A contractor with a work force of more than 4, but less than 19, would at best be able to maintain the size of his/her current workforce with only one less journeyperson. The effect on the workforce, even if an employer chose to replace experienced journeypersons with apprentices, is quite negligible. The move to 3:1 will allow the College of Trades to intentionally monitor the impact on journeypersons over the next four years and provide objective data on matters such as compensation and average annual earnings for the next round of ratio reviews. Page 9

10 4:1 3:1 Increased # of App Journey App App Total as % of Workforce % % % % % % % % % % % % % % % % % % % % % % Employers The shift to 3:1 will help employers address looming shortages in Carpenters projected due to normal attrition, retirements (average age of Carpenters with a CofQ is 65 ), and the low completion rate for the CofQ. Page 10

11 Employer Associations CLAC does not anticipate any economic impact on employer associations. Apprenticeship Training Providers Moving to 3:1 will potentially require more spaces to be available for apprentices attending trade school. Space at trade school may also be a barrier to increasing the number of skilled workers, but that is a barrier to be dealt with separate from this review. Public The public benefits through this gradual change by ensuring an adequate supply of Electricians over the balance of this decade that will help keep costs in line for both public and private sector construction projects. vi) The number of apprentices and journeypersons working in the trade. General Carpenter Active Journeypersons 28,920 Active Apprentices 7,061 * Data provided by the Ministry of Training, Colleges and Universities and available from the College of Trades website. vii) The rates of completion for apprentices in an apprentice training program for the trade. In developing its analysis in response to criterion ix), CLAC relied on two sources of information to determine rates of completion. Page 11

12 1) The report by T.E. Armstrong Consulting, Compulsory Certification Project, 2008 (The Armstrong Report), Summary Table 3: Completion Rates by Trade, 1996 and 2005, reported a 31.4% Global Building & Construction Trades Completion Rate (pages ). Armstrong s data is based on The Apprenticeship System in Canada: Trends and Issues, Working Paper 2005 B-06, as part of the Skills Research Initiative of Human Resources Development Canada which reported the following completion rate data for the period on page 45: Page 12

13 The Armstrong Report used the above noted data to complete its analysis of completion rates as noted on pages of the Report: We submit that the 31.4% rate is a meaningful predictor of completion rate experience across all trades within the Construction Sector. We have used this percentage in our forecast in response to criterion ix). 2) The Construction Sector Council s Training Canada s Construction Workforce: Meeting the Industry s Needs, Appendix F, Carpentry Trades, reported on Apprentices, New Registrations and Apprentices, Completions over the period for the Carpentry trade Canada-wide (see 2 exhibits on next page). While this is a national snapshot, we believe it is applicable to Ontario. Page 13

14 If one looks at the historical difference between the number of new registrations (Exhibit #60) and the number of apprenticeship completions (Exhibit #61), one can visually estimate the historical completion rates, which over the period, is similar to the completion rate identified in the Armstrong Report. Page 14

15 In CLAC s view, journeyperson-to-apprentice ratio has no impact on completion rates. Completion rates, however, provide a useful indicator of the required number of apprentices to be registered to achieve one successful completion (i.e. at a completion rate of 31.4%, the Province must register 318 new apprentices to achieve 100 successful apprentices). viii) The journeyperson to apprentice ratio, if any, for a similar trade in other jurisdictions. Province NL NS PE NB QC ON * Ratio 1:2 1:1 1:1 1:1 5:1 1:1, 4:1 * See schedule on page 5. MB SK AB BC NT YT NU 1:1 1:2 1:2 N/A 1:2 1:1 1:2 In addition, CLAC highlights the disparity between ratios between Carpenters and all other voluntary and restricted trades in construction. There is no rationale to support to provide a higher ratio of Journeyperson to apprentice for this trade. All other construction trades operate at 1:1, 1:2, or 1:3, or some variety thereof. ix) The supply of, and demand for, journeypersons in the trade and in the labour market generally. CLAC completed an analysis that shows that through natural attrition, an insufficient number of new entrants into the trade, retirements and low completion rates, Ontario needs a significant number of additional journeypersons by 2016 in order to meet anticipated increased demand for Carpenters. CLAC s calculations, based on modest real GDP growth (as provided by the Construction Sector Council Labour Market Information data [CSC]) identifies that by 2016, Ontario will require 8,134 new journeyperson carpenters, assuming Page 15

16 we are at full employment. With completion rates as low as 31.4%, Ontario will need to attract and register as many as 24,311 new apprentices into the system by 2016 to fill that void. This estimate was completed as follows: Economic growth for the period suggests that 32,276 journeypersons will be required by 2016 (3,356 more than we have now based on MTCU report of 28,920 journeypersons). Deaths/retirements, as estimated by CSC, suggests that an additional 4,778 journeypersons need be replaced. Therefore, 7,634 apprentices (3, , 778) are required to complete their CofQ by It is estimated that MTCU will issue 500 CofQs to Challengers by We note there is a much higher percentage of challengers completing the CofQ in the Carpenter trade as compared other trades based on the Ministry data. Also, given that only two full years of data is available and we do not have an indication of the completion rate, we are not confident on the projection for this number. Notwithstanding these concerns, we have factored this estimate into the projection on the following page. This will require CofQs to be issued to 7,634 apprentices to meet the required 8,134 journeypersons. If we assume a 31.4% completion rate (based on our analysis in criterion vii)), Ontario has to register as many as 24,311 new apprentices to meet the overall goal of new journeyperson electricians by The detailed breakdown of this calculation can be found on the following page. The proposed cautious shift to 3:1 will support the electrical trade to bring more apprentices into the system and address the requirements for new journeypersons by Maintaining the current and outdated 4:1 ratio will only exacerbate the supply shortage Ontario is going to face in the electrical trade. Page 16

17 Page 17

18 x) The attraction and retention of apprentices and journeypersons in the trade. The apprentice-to-journeyperson ratio only improves the industry s ability to attract new entrants to the trade. There is no anticipated impact to retention of apprentices and journeypersons in the Carpenter trade. xi) The average age of apprentices and journeypersons in the trade and the projected attrition of journeypersons working in the trade. The following data was provided by the Ministry of Training, Colleges and Universities and made available on the College of Trades website: Average Age of Journeypersons 65 Average Age of Apprentices 27 Annual attrition in the Carpenter trade, as illustrated in our projections on page 17, shows a steady increase in attrition due to deaths and retirements from an actual 778 in 2011 to a projected 1,1010 in Contact Us Colin deraaf, Director of Ontario Training Christian Labour Association of Canada 64 Saltsman Drive Cambridge ON N3H 4R7 (519) (519) (fax) cderaaf@clac.ca Page 18

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