REVIEW PANEL DECISION Ratio Review RR20-2012 Ratio Review for: Powerline Technician Submitted to: Board of Governors, Ontario College of Trades Submitted by: Ratio Review Panel RR20-2012 Submitted on: July 18, 2013
Contents Introduction... 2 The Review Process... 2 Submissions Received... 3 Criterion 1 Scope of Practice of the Trade... 3 Criterion 2 Apprenticeship Program Established by the College... 4 Criterion 3 Journeyperson to Apprentice Ratio Effect on the Health and Safety of Apprentices, Journeypersons, and the Public... 5 Criterion 4 Effect on the Environment... 6 Criterion 5 Economic Impact... 6 Criterion 6 Number of Apprentices and Journeypersons Working in the Trade... 6 Criterion 7 Rates of Completion for Apprentice Training Program...6 Criterion 8 Ratios in Other Jurisdictions for a Similar Trade... 7 Criterion 9 Supply and Demand for Journeypersons... 8 Criterion 10 Attraction and Retention of Apprentices and Journeypersons... 8 Criterion 11 Average Age and Projected Attrition... 8 Analysis and Decision... 9 RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 1
Introduction This Ratio Review, RR20-2012, is being undertaken per Part IX of the Ontario College of Trades and Apprenticeship Act, 2009( OCTAA ) and Ontario Regulation ( O. Reg. ) 458/11. The Review Panel ( the Panel ) members are: Jack Slaughter (Chair), Robert Bradford, and Scott McCoy. There is one trade included in this Review, it is Powerline Technician. The current journeyperson to apprentice ratio for the trade is 1:1. The Review Process The invitation for written submissions for RR20-2012 was publicized on December 21, 2012. Information about the location, date, and time of the oral consultation was posted on the College website on December 21, 2012. The written submission deadline was February 4, 2013 and all submissions were posted on the Ontario College of Trades ( OCOT or the College ) website by February 21, 2013. Information about the oral consultation was provided to the parties who made requests to make submissions on February 8, 2013 and further confirmed on June 5, 2013. There was no Oral Consultation for this Ratio Review. O.Reg. 458/11 stipulates that the Review Panel shall review the written and oral submissions against the following criteria in determining the appropriate journeyperson to apprentice ratio for these trades: i/ The scope of practice of the trade. ii/ The apprenticeship program established by the College. iii/ How the journeyperson to apprentice ratio for the trade may affect the health and safety of apprentices and journeypersons working in the trade and the public who may be affected by the work. iv/ The effect, if any, of the journeyperson to apprentice ratio of the trade on the environment. v/ The economic impact of the journeyperson to apprentice ratio of the trade on apprentices, journeypersons, employers and employer associations and, where applicable, on trade unions, employee associations, apprentice training providers and the public. RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 2
vi/ The number of apprentices and journeypersons working in the trade. vii/ The rates of completion for apprentices in an apprentice training program for the trade. viii/ The journeyperson to apprentice ratio, if any, for a similar trade in other jurisdictions. ix/ The supply of, and demand for, journeypersons in the trade and in the labour market generally. x/ The attraction and retention of apprentices and journeypersons in the trade. xi/ The average age of apprentices and journeypersons in the trade and the projected attrition of journeypersons working in the trade. Submissions Received Three timely submissions were filed. A joint submission was filed by the Electrical Contractors Association of Ontario ( the ECAO ) and the International Brotherhood of Electrical Workers- Construction Council of Ontario ( the IBEW-CCO ). Individual submissions were received from the Power Workers Union (the PWU ) and Hydro One Networks Inc. ( Hydro One ). All of the submissions support maintaining the existing ratio. Although all participants advocate keeping the current ratio, we are still obligated to consider and evaluate the written submissions against the established criteria in order to make the determination we are required to make in the review process. No party chose to make an oral presentation to the Review Panel. Criterion 1 Scope of Practice of the Trade The scope of practice of the trade is defined in Ontario Regulation 275/11 made under the Ontario College of Trades and Apprenticeship Act, 2009, S.O. 2009, ch. 22 ( the Act ). The relevant portion reads as follows: RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 3
Powerline technician 30. The scope of practice for the trade of powerline technician includes the following: 1. Operating, maintaining and servicing power lines used to conduct electricity from generating plants to consumers. 2. Constructing or assembling a system of power lines used to conduct electricity from generating plants to consumers. As the submissions of the PWU and the ECAO/IBEW-CCO correctly point out, the practice of the trade regularly involves work related to high-voltage electricity. The Powerline Technician s work pertains to the transport and delivery of electricity through overhead and underground transmission systems to residential, commercial, municipal and industrial users. As such, the work is both important and potentially dangerous. It is not an exaggeration to say that a mistake by a Powerline Technician could result in a serious injury or death. Accordingly, proper apprenticeship training is of vital importance. Criterion 2 Apprenticeship Program Established by the College To date, the College of Trades has not established a formal apprenticeship program for the Powerline Technician trade. Pursuant to the Act, the responsibility for establishing apprenticeship programs has transferred to the College from the Ministry of Training, Colleges and Universities ( the MTCU ). Until such time as the College reviews or amends those programs, the programs established by MTCU will continue to be in effect. The training programs described in the discussion under this criterion are the MTCU programs. The prevailing ratio is set out in R.R.O. 1990, Regulation 1067 to the Trades Qualification and Apprenticeship Act, R.S.O. 1990, c.t-17, section 9, which provides: The number of apprentices who may be employed by an employer in the certified trade shall not exceed, (a) where the employer is a journeyperson in the trade, one apprentice plus an additional apprentice for each additional journeyperson employed by that employer in the trade and with whom the apprentice is working; and (b) where the employer is not a journeyperson in the trade, one apprentice for each journeyperson employed by that employer in the trade and with whom the apprentice is working. RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 4
The net effect of the regulation is a 1:1 ratio. Currently apprenticeship training for the trade is delivered through the Infrastructure Health and Safety Association ( the IHSA ), Hydro One at its facility in Kleinberg, and four colleges having Training Delivery Agency status. The majority of training is done through the IHSA and Hydro One. From 2004 to 2008, the number of apprenticeship registrations increased from 651 to 1,314. A national study undertaken by the Electricity Sector Council in 2009 did not find any impediment to recruiting new apprentices into the trade arising from the journeyperson to apprentice ratios then in place 1. Criterion 3 Journeyperson to Apprentice Ratio Effect on the Health and Safety of Apprentices, Journeypersons, and the Public The submissions of both the PWU and the ECAO/IBEW-CCO highlight the importance of health and safety considerations in the Powerline Technician trade. We agree with the assertion made by the PWU that in a trade where failure to properly perform a task could mean thousands of volts of electricity flowing to ground and endangering the lives of the public the best protection is the training a certified journeyperson receives through his or her apprenticeship. We also adopt the statement contained in the ECAO/IBEW-CCO submission that there is no clear-cut empirical evidence on the relationship between health and safety performance and the journeyperson to apprentice ratio. In that regard, we refer to the following observation from the Armstrong Report (also known as the Compulsory Certification Report), which we cited in Brick and Stone Mason Ratio Review (RR10-2012, March 11, 2013): The key issue on the health and safety impact question turns, then, on whatever empirical evidence exists to support or refute the proposition that those trained under a compulsory/restricted regimen have superior health and safety records to those trained under voluntary/unrestricted systems. I have searched in vain for data that would enable me to provide a reliable, supportable response to this key question. We do not find anything in the materials before us to indicate that any change to the ratio should be made arising from concerns about health and safety. On the contrary, the relatively low 2013 WSIB Contribution Rate for this trade as set out in the ECAO/IBEW-CCO submission provides distinct and independent support for the position of the participants that the ratio should be maintained at the current level. 1 Electricity Sector Council, The Powerline Technician Trade in Canada, April 2009 RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 5
Criterion 4 Effect on the Environment None of the participants provided any data that would demonstrate any effect upon the environment that would arise from a change in the journeyperson to apprentice ratio. Criterion 5 Economic Impact According to the unchallenged data supplied by the MTCU and cited in the ECAO/IBEW-CCO submission, the electrical industry could hire more than 4,000 apprentices without any limitation under the existing ratio. In light of this information, we find that any reasonable ratio that might be selected would have minimal economic impact on how work is performed in the industry and on the general public. Accordingly, we find that this criterion is neutral. Criterion 6 Number of Apprentices and Journeypersons Working in the Trade According to the unchallenged data supplied by the MTCU and cited in the ECAO/IBEW-CCO submission, as of October 1, 2012, there were 5,481 active journeyperson Powerline Technicians and 1,278 active apprentice Powerline Technicians working in the electrical industry. Therefore, the effective ratio of journeypersons to apprentices is 4.3 to 1. In these circumstances, there is plenty of room for the industry to hire further apprentices within the existing ratio. This criterion provides no reason to change the current ratio Criterion 7 Rates of Completion for Apprentice Training Program Hydro One states that its Powerline Technician apprentices have a successful completion rate of 98%, and that Red Seal (interprovincial) Certification is a mandatory requirement for its apprentices. The PWU, presumably speaking about the same people, asserts a 95% completion rate for the PWU/Hydro One apprenticeship program. The results are exceedingly impressive; whichever of the two very high figures is most accurate. The ECAO/IBEW-CCO submission indicates that completion rates are not as high for the Powerline Technician apprenticeship generally, although there has been marked improvement in recent years. Accordingly to MTCU data the completion rate when measured against new registrations (same year) for the 2010-11 year was 62.2%, which improved to 72.5% for the 2011-2012 year. RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 6
These are good numbers when contrasted with completion rates for the construction trades generally, as reflected in ratio review decisions released to date. We find nothing in this criterion that supports any change to the current journeyperson to apprentice ratio. Criterion 8 Ratios in Other Jurisdictions for a Similar Trade The journeyperson to apprentice ratio across Canada is as follows for the Powerline Technician trade, according to the Ellis Chart cited in the ECAO/IBEW-CCO submission: Newfoundland and Labrador 1:2 Nova Scotia 1:1 Prince Edward Island 1:1 New Brunswick 1:1 Quebec Manitoba N/A N/A Saskatchewan 1:3 Alberta 1:2 British Columbia N/A Yukon Territory 1:1 North West Territory 1:2 Nunavut Territory 1:2 Four jurisdictions have the same ratio as Ontario. The other Canadian jurisdictions that have established a ratio have lower ratios than Ontario. These rates provide some evidence that lower ratios can work and are acceptable in certain other provinces and territories. Nevertheless, we note here, as was the case in Terrazzo, Tile and Marble Setter Ratio Review (RR6-2012, February 6, 2013), the data comes with no real explanation as to what might be the particular supply and demand issues at play in the other jurisdictions. Furthermore, four jurisdictions have adopted the same ratio as Ontario. RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 7
In these circumstances, we do not find that this criterion provides any meaningful evidence supporting a change in the current ratio. Criterion 9 Supply and Demand for Journeypersons The ECAO/IBEW-CCO brief notes that there are no public domain forecasts for supply and demand in the Powerline Technician trade. The ECAO/IBEW-CCO submissions indicate the expectation of those parties that demand will increase, but can be accommodated by the existing journeyperson to apprentice ratio. Hydro One submits that the current ratio will support high quality, manageable trades development. The PWU says it does not experience any extraordinary difficulty in either the supply or demand of journeypersons. The information before us does not indicate any imbalance in the supply and demand for journeypersons now or in the foreseeable future. Criterion 10 Attraction and Retention of Apprentices and Journeypersons The information and representations before the Review Panel do not indicate any problems in attracting Powerline Technician apprentices to, or retaining journeyperson Powerline Technicians in, the industry. The number of new registrations has trended generally upward over the past decade, and the ratio of completions to new registrations (same year) has steadily increased to 72.5% for the 2011-12 year, according to MTCU data supplied to the Ontario Construction Secretariat. The PWU is engaged in admirable efforts to attract new apprentices to the trade through enhanced awareness by means of school visits, career fairs and trade shows. The PWU is giving special focus to non-traditional populations including First Nations and females. We do not find anything in this criterion that warrants a change in the current ratio. Criterion 11 Average Age and Projected Attrition Neither the PWU nor Hydro One produced any data under this criterion, but neither party expressed any dissatisfaction with the current ratio under this criterion. RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 8
The ECAO/IBEW-CCO cited a 2006 Census Report by Statistics Canada 2. That report indicated that nearly 63% of Powerline Technicians then fell between the ages of 35 and 54, while 25% were age 34 and under. Therefore 88% of the Powerline Technician workforce was then under age 55. More recent MTCU data supplied to the Ontario Construction Secretariat discloses 1,832 new apprenticeships and 619 new completions over the past 8 years. No party supplied any useful information about the attrition rate in the industry. Based upon our review of all the information provided to us, it appears that the industry is generating sufficient new apprentices and retaining sufficient journeypersons to meet industry demand. Accordingly, there is nothing in this criterion that provides any distinct support for a change in the existing journeyperson to apprentice ratio. Analysis and Decision This ratio review is not a specific response to any particular problem identified by the College. In these circumstances, the existing ratio is presumed to be appropriate unless there is evidence persuasive to justify a change presented under the enumerated criteria set out above: see Precast Concrete Erector Ratio Review (RR3-2012, July 16, 2012); and Brick and Stone Mason Ratio Review (RR10-2012, March 11, 2013). All of the participants in the review process support maintaining the existing 1:1 journeyperson to apprentice ratio. Our review of the criteria does not lead us to a different conclusion. All criteria either support retention of the current ratio, or do not provide any meaningful reason for a change. Therefore, we recommend no change to the prevailing 1:1 ratio. **************************************************************************** Signed: Jack J. Slaughter Chair, Ratio Review Panel RR20-2012 Powerline Technician Date: July 18, 2013 2 Statistics Canada, Age Distribution Powerline Technicians, 2006 Census. RR20-2012 Powerline Technician Ratio Review Decision July 18, 2013 9