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Dean Review Consultation Questions

Written submission to Dean review

Submission number: DR-53

Name of organisation making submission: DR-53 Greater Sudbury Chamber of Commerce

Dear Mr. Dean:

Thank you for the opportunity to make this submission regarding the key areas of the skilled trades system falling under the mandate of the Ontario College of Trades (OCOT).

The Greater Sudbury Chamber of Commerce (GSCC) has been involved in the Ontario College of Trades discussion since the Ontario College of Trades and Apprenticeship Act was first introduced in 2009.  Since that time, we have worked with the Ontario Chamber of Commerce to represent our members’ concerns regarding the College and the state of the skills trades in the province.

Since the College’s inception, the GSCC has reinforced that it is critical that decisions concerning the trades be evidence based and analysis subject to review by business, educators, tradespeople and unions.  It is also vital that the College not cause unnecessary costs or regulatory burdens for tradespeople and employers. 

The chamber was pleased to hear that the government moved forward with initiating a review of OCOT.  We are however disappointed that this review does not cover many key elements under the College’s mandate including ratio reviews and the promotion of trades.  High journeyperson-to-apprentice ratios and low completion rates in the trades are among the key barriers to addressing the labour shortages and skills mismatches being experienced across the province.

We are hopeful that this review will bring clarity and transparency to the OCOT and will allow it to fulfill its mandate of increasing the number of skilled workers in Ontario and protecting the trades.

We look forward to meeting with you in April to further discuss some of the below mentioned items.

Yours truly,

Originally signed by Debbi M Nicholson
PRESIDENT & CEO
Greater Sudbury Chamber of Commerce

The Public Interest

The public interest of the College should be representative of not only the consumer but also of tradespeople and employers.  Public safety and the protection of consumers is vital.  Equally important however is job creation and ensuring tradespeople and employers are not hit by unnecessary regulation, burdens or costs. Protecting the general public should go hand in hand with safeguarding jobs as well as the economy.   The achievement of one goal must not come at the cost of another.

The public interest of the College needs to be clearly defined and communicated to stakeholders.  A clear definition of the public interest will also lead to clarification on who the College is accountable to.  To uphold accountability, OCOT should consider surveying those who hold membership with the College on a consistent basis about their satisfaction with the College.  The College should be transparent in clearly demonstrating to their members how their membership fees are being invested.  Tradespeople will only see value in their membership if they feel the OCOT is successfully promoting the trades, helping them to hire additional apprentices or providing better access to the tools they need to perform their jobs.  

OCOT Processes: Trade Classification Review

Although we respect the neutrality of the OCOT review panel, decisions on the trade classification process or ratio reviews should not be made on public submissions alone.  In addition to insufficient responses received during the review process, this system lends itself to the potential of decisions being made based on anecdotal evidence, bias or the personal opinions of others.

Robust quantitative and qualitative analysis needs to take place and be integrated within the process to have truly representative results.  We echo the Ontario Chamber of Commerce in stating that decisions on trade classification and ratio reviews must also be informed by sound Labour Market Information (LMI).  The OCOT has stated that organizations are responsible for providing their own data in order to make submissions.  Many organizations wanting to have input into the process are however often faced with a dilemma of not having sufficient information to make their own submission or to provide evidence to support their claims.  Smaller organizations are at a particular disadvantage as they are less likely to be able to mine and present their own data for this review process.  This requirement can also result in a review process biased towards larger organizations with higher levels of capacity.

It is also critical that the OCOT better communicate the process by which compulsory and non-compulsory trades are determined; if a trade goes from non-compulsory to compulsory, what precipitates this process and identifying what the transition process criteria is must be clearly communicated and agreed upon. The OCOT has set out seven criteria in its trades classification review.  However it seems as if different panels have used these criteria differently and inconsistently depending on the trade under review.  The current criteria do not address the wide variety of issues relevant to the trades.  The broader socioeconomic impacts must be looked at when deciding whether a trade should be compulsory.  Key questions also need to be asked including whether there would be sufficient training resources available across the province to facilitate this type of change if it were to occur.  Grandfathering provisions should also be considered in advance of any decision taking place.

Health Professions Regulatory Advisory Council Model

The OCOT should consider different options to allow for objective data collection and analysis to take place. We echo the sentiment of the OCC and other stakeholders that have advanced the creation of an independent advisory council, modeled after the Health Professions Regulatory Advisory Council (HPRAC) as an alternative method in order to address these types of concerns related to the lack of robust evidence and to allow for the consideration of sources other than submissions received alone. The process has the capacity to include key informant interviews in addition to the input of interested stakeholders.  The HPRAC also conducts an extensive research process including literature reviews as well as jurisprudence reviews.  Additionally, there is a possibility for HPRAC to seek further submissions from experts to help inform their review processes.  We believe that embracing this type of a model will go a long way in terms of encouraging decision making that is sound, representative and objective.

There is also a need for the OCOT to better share the data it does have access to.  Currently, the public lacks basic information around certain trades that would aid in making a submission.  Baseline factual information should be provided to the public in advance on issues such as the number of apprentices working in the respective trade, completion rates, employment rates, and the history of the trade to allow the public to have the sufficient background it needs to make informed submissions or to provide input. 

In addition to empirical research in both trade classification and ratio review processes, a direct active dialogue with industry, unions, colleges and other stakeholders needs to consistently take place in order to keep these groups aware of the process and to solicit their feedback.

Regional and Employer Considerations

In its current form the trade classification review is limited and lacks a broader understanding of the needs of particular regions and employers across the province.  The review process should take into consideration regional needs and differences.  In Northern Ontario for example, we are particularly concerned as we are disproportionately affected by labour and skills shortages in comparison to the rest of the province.  We do not feel like the unique needs of different regions are represented in this type of review.  We believe a HPRAC-type model as mentioned above could help in this regard by providing an outlet to access for regionally specific information and concerns.  We also believe more can be done to encourage submissions and input from northern and rural communities, often underrepresented in the review process.

There is also a concern with the lack of representation from employers in ratio and trade classification review processes, particularly the limited voices coming out of the SME sector.  Without a broad representation of views, stakeholders and regions, the review processes will fail to produce an outcome that is the best for the whole of Ontario and for the public interest.

We often hear from our members that they had no idea that a trade classification or ratio review process for a particular trade was taking place or that by the time they find out the deadline has already passed. More has to be done to encourage submissions beyond posting passive information on the OCOT website alone.  The review process should be marketed to all relevant stakeholders and the broader public and submissions should be actively sought out and encouraged to ensure diverse perspectives and opposing views.  The way stakeholders are informed needs to be reformed.  As of now there are tight timelines around the receipt of public input submission.  More advanced notice should be provided to stakeholders to allow them to adequately prepare and consult for their submission.

Concluding Comments

The trade classification and ratio review process must not be separate from the College’s mandate and view of ensuring that there is a sufficient pool of skilled trades’ workers across the province to meet current and future needs.

Although beyond the scope of this review, we believe the decision-making processes on apprenticeship ratios need to be re-examined.  Ontario continues to have some of the highest apprenticeship ratios in the country.  Lowering these ratios will allow businesses, particularly SMEs, to hire more apprentices and contribute to higher apprenticeship completion rates.  The OCOT should also work with colleges and the Ministry of Training, Colleges and Universities to better align certification standards with training needs and realities.  Beyond the OCOT, to ensure that the apprenticeship system is more flexible and responsive to local labour markets, Ontario should consider transferring government apprenticeship administration to colleges.

The College should also ensure that their actions and mandate do not duplicate that of other ministries.  Many stakeholders have argued that the regulatory functions of the College are already being covered in different capacities by alternate entities such as the Ministry of Labour.   Duplication in regulation and red tape hits the bottom line of tradespeople, business and the general public.  The OCOT should re-examine whether they should be in the business of regulation in certain cases.  A move away from regulation can also translate into a greater emphasis on working towards building a 21st century workforce.