Thank you, Chair.
My name is John Farrell. I am the executive director of the Federally Regulated Employers—Transportation and Communications. FETCO represents most of the major federally regulated employers in Canada. A list of FETCO members is attached to appendix A of my written presentation, which I believe the clerk will be able to provide you with later.
We are pleased to provide our views on the provisions of the budget implementation act regarding the proposed revisions to the Canada Labour Code covering the engagement of interns by companies operating in the federal jurisdiction.
FETCO members believe internships are a very important way to improve employment prospects and outcomes for Canadians seeking employment. Internships add value by providing practical workplace experience to complement an individual's education or life and working experiences and preparedness for future employment. Internships will allow educators and companies to connect and create a better ongoing understanding of each others' requirements to improve employment prospects for Canadians. They assist persons seeking new opportunities to get valuable work experience.
FETCO members believe that interns should be treated fairly. The primary objective of engaging interns is to improve the development of the individual for the sake of the individual.
When FETCO was advised that the government was considering legislation regarding interns in January of this year, we decided to survey our members to better determine the extent to which interns are engaged by member companies.
We learned the following. About 80% of FETCO members have some form of internship programs. About 83% of FETCO members that engage interns do so through formal co-op arrangements with recognized educational institutions. About 42% of FETCO members also have ad hoc internship arrangements that are often shorter in duration and less structured than formal co-op programs. Some interns are paid and others are not. In the federal jurisdiction and the companies that participate in FETCO, most of the interns are paid.
So the arrangements that apply to interns vary from company to company, and we would agree that we don't believe there's enough data to understand the full extent to which interns are used across the country, which is why we undertook to do our own study of our own members.
Let's turn to the analysis of the proposed legislation.
The proposed amendments to part II of the Canada Labour Code provide interns with full occupational health and safety protection. FETCO fully supports this requirement. However, we believe that they already had protection, and employers already had an obligation under the general duty provisions of the code to protect the health and safety of all persons attending at the employers' premises or operations. Nevertheless, we have no objection to including specific coverage under part II of the code.
The proposed legislation also introduces provisions to clarify the circumstances when interns can be unpaid. The first case would be when the internship is part of a program provided by a recognized secondary or post-secondary educational institution or vocational school. We agree with this provision.
The second would be if the internship meets a certain set of six criteria. I won't recite the criteria—I think they're clear in the bill—but we believe these provisions make sense because they will provide an opportunity to determine with some clarity under what circumstances interns will be treated.
With respect to establishing a time limit that an internship cannot exceed, either four months of full-time employment or the equivalent over a 12-month period—