Dean Review Consultation Questions

Written submission to Dean review

Submission number: DR-104

Name of organisation making submission: DR-104 Chemistry Industry Association of Canada (CIAC)

Dear Mr. Dean:

Please accept the following input from the Chemistry Industry Association of Canada (CIAC) as part of the review of College of Trades. CIAC is the voice of the industrial chemical industry, underpinning the broader $53-billion chemistry industry in Canada. CIAC members produce petrochemicals, inorganic chemicals, industrial biochemicals and specialty chemicals in all regions of the country, with about 44% of the industry located in Ontario.

By the nature of their facilities and processes, chemical companies have an ongoing need for construction trades for routine plant maintenance. This demand is heightened when plants are completely shut-down for major overhauls, which happens on a regular cycle every few years. Over the past two decades there has been minimal investment in Ontario in new plant capacity which is when the demand for construction labour is at its highest. However, that situation is changing, and the prospects for new investment by the chemical industry are now looking much more positive. This is being driven by a number of factors, primarily:

  • the shale gas revolution that is sweeping North America
  • competitive taxation policies, federally and provincially
  • the emerging potential for commercialization of new technologies that convert biomass into chemicals.

In order to take maximum advantage of this looming investment wave, Ontario needs to ensure that it remains a competitive location in which to build major new facilities. A critical element of construction project costs relates to labour efficiency. Therefore, CIAC supports initiatives that improve labour efficiency, without compromising worker safety or environmental impact. Workplace safety and minimization of environmental impact are cornerstones of CIAC's Responsible Care® ethic that requires mandatory compliance on the part of its members. To that end, we offer the following specific comments:

  • the College should avoid converting trades that are currently voluntary into compulsory. We have a concern that this would limit the ability to use cross-training as a means to address skill bottlenecks, and result in inflation of project construction costs that would undermine the attractiveness of Ontario as an investment location.
  • it is important to retain the current exemption from compulsory certification for skilled tradespersons that are permanent employees of chemical companies. These employees are trained to be multi-skilled and thereby able to undertake a variety of tasks related to plant maintenance and modification. This skill flexibility is important when it comes to scheduling of labour and managing costs.
  • the College has an opportunity to further liberalize the apprentice-to-journeyperson ratios for construction trades. Some progress in this direction was made when the trades were reviewed in 2013, but the ratios in Ontario are still more restrictive than in competing jurisdictions like Alberta.

Thank you for the opportunity to offer our views. Schedule permitting, we plan to attend one of your in-person consultation sessions in April.

Yours truly,

Originally signed by John Margeson Director,
Business & Economics
613-237-6215 x230