Thank you very much, Mr. Chair.
Thank you for the invitation.
I am the vice-president of the Centrale des syndicats démocratiques, the CSD, and I'm here to present the written brief jointly with the three other labour federations in Quebec: the Confédération des syndicats nationaux, or CSN, the Fédération des travailleurs et travailleuses du Québec, or FTQ, and the Centrale des syndicats du Québec, or CSQ. Together, our four labour federations represent more than 1,165,000 workers in all regions of Quebec, in both the public and private sectors.
In a joint brief, the federations are presenting a series of recommendations to the federal government to adjust the employment insurance program to the reality of today's work organization, pending a major reform of the program.
The program is broken, complex and inaccessible, and it also provides inadequate benefits. Before the pandemic, only 40% of unemployed workers in Canada were entitled to benefits. Part-time workers—especially part-time workers who are women—are struggling to accumulate enough hours of work to qualify for benefits.
We therefore recommend that a comprehensive modernization of the Employment Insurance Act be introduced and passed as quickly as possible in order to improve the program and meet the needs of workers as quickly as possible.
With regard to unemployment and seasonal work, we need to end the EI black hole. The weeks between the end of employment insurance benefits and the start of employment are what we call the “black hole”. To try to contain the EI black hole, the government adopted temporary rules in 2018. The government introduced a pilot project in 13 regions where EI is characterized by significant seasonal economic activity and high unemployment. This pilot project allows unemployed workers considered “seasonal” to benefit from five additional weeks of benefits, for a maximum of 45 weeks. The special measures were to end on October 28, 2023. Budget 2023 proposes extending these supports until October 2024.
For the labour federations, it's obvious that the end of the pilot project would be catastrophic. In those regions, workers choose to work in seasonal industries because full-time year-round work is often not possible or accessible, despite the many solutions put in place in the industries to extend the working season. People working in seasonal industries generally have long working weeks in the high season, and their work is often intensive and strenuous. They are the backbone of industries that are vital to communities, which unfortunately rely on a fragile and undiversified economic fabric. This situation is common across Canada.
The average duration of a seasonal job is less than 16 weeks, and the average duration of benefits is 17 weeks. The extra five weeks do not help fill the black hole for most seasonal workers, unless they live in a region where the unemployment rate is higher than 16%.
Quebec's labour federations reached a consensus containing 15 requests to reform the program, for example, to introduce a universal standard of eligibility for benefits after 420 hours or 12 weeks of work, and to provide a minimum of 35 weeks of benefits.
We also recommend that, pending a comprehensive reform of the EI program, measures relating to workers in seasonal industries be amended to make an additional 15 weeks of benefits available to eligible claimants, and that the criteria for selecting claimants eligible for additional benefits be reviewed, so that it's no longer based on an individual's previous benefits, but rather on the employer's track record or the reason for seasonal layoffs. In other words, a person working for a seasonal company would automatically be eligible, given the nature of the company's activities. In addition, the calculation of the benefit rate would have to be calculated on the best 12 weeks of work, regardless of the regional unemployment rate, and additional benefits for seasonal work should be made permanent.
Furthermore, the creation of an appeals board is another important element in having a true tripartite appeals system. When it was announced in spring 2019 that an appeals board would be created to hear EI appeals, the Quebec labour federations welcomed this decision. Four years on, the situation remains unresolved.
Some progress has been made. First of all, all board members will have part-time worker status. This will ensure that the difference in status between part-time and full-time members doesn't lead to different levels of commitment and effectiveness. Second, Bill C‑47 provides that appeals will be heard in the appellant's region, except in prescribed circumstances.
However, two major problems persist: the bill doesn't insist on in-person hearings, and the proposed new subsection 43.02(2) of the Department of Employment and Social Development Act states that the executive head of the Board of Appeal, who is responsible for managing the day‑to‑day work of the board, reports “to the Commission, through the Chairperson of the Commission, on the overall performance of the Board of Appeal”.
This means that the board of appeal will not be fully tripartite if its top manager is accountable only to the government representative of the Employment Insurance Commission, and not to the commission as a whole. In this regard, we recommend that the Employment Insurance Board of Appeal be established.
Still with regard to Bill C‑47, in subclause 43.04(2), we recommend that the words “through the Chairperson of the Commission” be deleted.
We also recommend, in proposed subclause 43.16(2), that “in the format selected by the appellant” be changed to “in person, except in exceptional circumstances”.
Before I close, I'd like to mention one last point concerning workers who have experienced a lockout. A lockout is a unilateral decision by the employer. The workers didn't choose to go through this situation, because the lockout often ends after several months. When these people aren't called back to work, they don't have access to EI benefits because they aren't considered to be employed for the duration of the lockout. It's a situation they can do nothing about, and it puts them in an incredibly precarious financial and social situation.
This needs to be corrected, as do the federation recommendations.