Thank you, Mr. Chair.
Members of Parliament and members of the committee, thank you for having me here today and for the opportunity to provide my organization's comments on Bill C‑19, specifically on division 32 of part 5.
The Fédération des travailleurs et travailleuses du Québec is the largest central labour body in Quebec. With approximately 600,000 members, it represents over 40% of unionized workers in Quebec.
Our union is the main voice for salaried workers in Quebec. It is their privileged place for collective action and solidarity. The FTQ has members in every region and every sector of activity in Quebec, whether in offices, factories, shops or construction sites, in both the private and public sectors. In fact, we have members in public institutions. I would also like to point out that one third of the FTQ's members are women.
Division 32 of part 5 of the budget implementation bill tells us more about reforming the employment insurance appeals process.
In light of what was announced via press release in August 2019, we expected good news. However, it turns out that the bill is rather a source of concern for us. It does not correspond to what was stated in the press release. We are therefore greatly concerned about the way the reform is being set in motion by the Minister of Employment, Workforce Development and Disability Inclusion.
The first point I want to make is that the reform of the employment insurance appeals process is included in an omnibus bill that has five parts, the fifth of which has 32 divisions and three schedules. One would be hard-pressed to find a better way to bury the issue. Our fears that this reform will not get the attention it deserves are real, because of the number of topics included in the bill.
The number of places available in parliamentary committees, as we know, is not unlimited. So there is a real possibility that organizations with an interest in reforming the appeals process will be overlooked and not invited. So, we believe that division 32 of part 5 of Bill C‑19 should be removed from this omnibus bill and be the subject of a separate bill. This is what we recommend in order to ensure that the reform receives proper consideration and deliberation.
I would like to draw your attention to a second element: the bill on the reform of the appeals process must contain provisions for the new appeal board to report to the tripartite structure of the Employment Insurance Commission, not just to its chair. The government had promised a return to a tripartite body for the first level of appeal. This is a significant change in direction and a serious departure from the promise that was made. In our opinion, there must be a direct line of accountability to the Employment Insurance Commission. Why? In order to monitor how union and employer representatives are deployed and to ensure that people are properly trained and fulfilling their mandate on the appeal board.
In addition, provisions still need to be added to the appeals process reform bill to give employment insurance claimants the right to regional representation and the opportunity for an in‑person hearing. In 2018, we understood that reforming the employment insurance appeals process required reforms that were client-centred, flexible, and could accommodate diverse situations.
With respect to the appeal board, the bill provides for two categories of members: full-time and part-time. The reform bill should provide for all members of the appeal board to be appointed on a part-time basis. Giving separate employment status to different members of the appeal board may result in different levels of commitment and effectiveness for full-time and part-time members. Full-time appeal board members are deemed to be employees of the public service and members of the public service pension plan, but part-time members are not. Full-time members of the appeal board may be appointed as chair, vice-chair or coordinating member, but not part-time members. In our view, this is a perfect recipe for leaving room for unequal and inequitable information-sharing and for creating inequalities among appeal board members in terms of commitment and effectiveness.
The final point I want to make is that the reform bill must include language that specifies that the Employment Insurance Commission will oversee the selection process for the employee and employer members of the board of appeal.