Dean Review Consultation Questions

Written submission to Dean review

Submission number: DR-12B

Name of organisation making submission: DR-12B Canadian Federation of Independent Business (CFIB)

Dear Mr. Dean:

The Canadian Federation of Independent Business (CFIB) is a not-for-profit, non-partisan organization, which represents the interests of 109,000 small and medium-sized businesses across Canada, 42,000 of which are in the province of Ontario. On behalf of our members who operate across all sectors of the economy and in all skilled trades in the province, we appreciate the opportunity to provide our recommendations on some of the areas under your ongoing review of the Ontario College of Trades.

Small and medium-sized businesses account for 98 per cent of all Ontario businesses, provide the bulk of new jobs and act as an important cornerstone to communities across the province. Given the critical role they play in the economy, the views and concerns of this sector should be given careful consideration in your review. Although we cannot comment on each of the proposed questions as some are not applicable to our members, we will address the following areas of the review: public interest, scopes of practice and compulsory certification.


Since the Ontario College of Trades (OCOT) became operational in April 2013, we have been receiving consistent feedback from our members about its mission, role and operations. Specifically, our members are pleased with the advertisement campaigns launched by the College to promote and increase awareness of the skilled trades. However, despite the College having been in operation for almost two years, small businesses are still confused about the actual role that it plays. The following are areas where our members believe the College should improve its operations: enhancing customer service, reducing the regulatory and financial burden on small businesses and focusing on education before enforcement.

Lack of Quality Customer Service

Small business owners’ experience with self-regulating agencies at arm’s-length from government, including the College of Trades, has traditionally been extremely frustrating and challenging. This is because such entities usually fail to demonstrate transparency and accountability to the stakeholders they are providing the services or oversight to.  In this case, our members frequently point out to the poor customer service they receive from the College, despite paying membership fees. For example, our members have routinely informed us that information is difficult to find on the OCOT’s website, and that clarification is sometimes impossible to obtain over the phone as a result of long wait times. Some business owners and apprentices indicate that it is not uncommon to spend 30 to 45 minutes on the line, before an OCOT customer service agent becomes available. In many instances, the agents cannot even provide correct information.  In addition, our members have indicated that inspectors can be extremely rude and aggressive in carrying out audits. It is imperative that the College immediately improves its customer service standards so that it can better serve its primary stakeholders: those that work and provide employment in the skilled trades.

Red Tape

Our members report that at times the College threatens their livelihood through punitive regulatory requirements and membership fees. Many apprentices and business owners still believe that the OCOT is nothing but a new level of bureaucracy that creates additional red tape for the skilled trades. For one, the dual registration process is a major regulatory burden. Apprentices are required to register with both the Ministry and the OCOT, and although the fees are paid to the College, they have to go to the Ministry to complete their exams. This duplication leads to confusion about the OCOT’s role in the skilled trades. Instead of simplifying administrative processes, the result has been a more complex and frustrating environment, which deters both apprentices from going into the trades and businesses from engaging in apprenticeship training.

High Membership Fees

Under the College’s membership fee structure, journeypersons are now paying 600 per cent more than the $60 that most tradespeople previously paid over a three year period to retain their licenses. One of our automotive members pointed to the fact that the fee does not help to enrich his expertise in the skilled trades, nor does it help to match him with potential apprentices - he continues to do the same job and faces the same challenges, but with less money to invest into his employees and his business.

We would like to acknowledge that the current OCOT fee structure appears to benefit tradespeople holding multiple certificates of qualification or statements of membership as they only pay one membership fee annually. However, that is provided the membership fees do not increase in the future, which we find highly unlikely.

Education before enforcement

To better serve the public and to improve the issues related to scopes of practice (SoPs), the College has a role to play in educating the general public, business owners, journeypersons, apprentices, and potential new workers in the skilled trades about its role and the accompanying regulatory requirements. Instead, the OCOT has focused on enforcement, rather than education.

According to the College, enforcement officers are to check the qualifications of those working in the compulsory trades for proper training and certification. Simply checking whether members have paid the mandatory fee does not guarantee in any way that these members are in fact qualified trades people. Instead, enforcement without education is simply seen as a tax grab by our members and does nothing to improve the quality of the trades; nor does it help to build a collaborative relationship between employers and the College.


According to the terms of reference, scopes of practice are a primary focus of this review. One important aspect of the SoPs are restrictive journeyperson-to-apprentice ratios in some trades. As such, the review needs to seriously consider how these ratios impact the provision of apprenticeship training.

Ratios in certain trades (electrical, construction, etc.) have become so onerous that both our members and prospective tradespeople identify them as a huge barrier to engaging in apprenticeship training. In fact, Ontario’s ratios are currently out of touch compared to the rest of the country given that many provinces in Western and Atlantic Canada  have significantly reduced and even eliminated ratios altogether.  For example, floor covering installers in Alberta only require one journeyperson to oversee two apprentices, whereas in Ontario, there must be two journeypersons to oversee one apprentice.  It is clear that the argument made by many labour unions in the skilled trades that restrictive ratios are needed to ensure workplace safety has become irrelevant a long time ago. If B.C., Alberta and the Atlantic provinces have cut apprenticeship ratios without compromising safety, why cannot Ontario follow suit? It is time for the province’s apprenticeship system to better reflect the needs of the market and to ensure that apprenticeship training programs remain competitive with the rest of the country.


The terms of reference also outline the need to review the classification or reclassification of trades as compulsory or voluntary. Although various rationales for the move to compulsory certification have been offered – increasing health and safety, improving the labour supply, making the skilled trades a better place to work – a survey of the various expert studies, submissions, and media reports on this issue indicates that these arguments are based more on rhetoric, rather than solid research. CFIB is encouraged to see that the review questions whether every single activity under a voluntary trade should become compulsory, if the trade is reclassified. Nevertheless, the most important question is whether reclassification is necessary and what the corresponding impacts on apprentices and the employers who offer apprenticeship training would be.

Ontario has the largest number of compulsory trades, with the exception of Quebec, where, effectively, all construction trades are compulsory. In 2004, British Colombia removed all of its compulsory trades, giving employers more flexibility to provide apprenticeship training. Research on the compulsory trades in Canada indicates that other provinces are working to ease the restrictions to allow for more flexible apprenticeship training. Given the high cost of regulatory compliance in the compulsory trades, our members question the need to expand compulsory certification. Since the College is funded on the membership dues that it collects, it is in the interest of the OCOT to expand compulsory certification, as this would yield higher revenues. But, the question remains: is this what is best for the skilled trades?
CFIB strongly cautions against the expansion of compulsory trades. The determination of compulsory status for the sake of generating more members and revenue to the College would only replace one problem with another. The College needs to remain mindful that increasing the cost of membership is seen as a tax grab by those the College is mandated to serve. Fees should not be determined on the basis of simply funding the College’s operations, but on the value that it provides to its members. High fees are a major deterrent to journeypersons and apprentices in the voluntary trades seeking membership with the College. Finally, higher fees and reclassification of trades from voluntary to compulsory would also encourage growth in the underground economy, as some would attempt to avoid compulsory status in order to minimize costs.


We offer the following recommendations to help the College build collaborative relationships and to provide value to apprentices, trades people and employers who participate in apprenticeship training. The College should:

    • Work towards improving all aspects of the customer service it provides to its members;
    • Simplify and eliminate duplicative administrative requirements;
    • Focus on educating stakeholders about its role and the corresponding regulatory requirements;
    • Move quickly to reduce restrictive journeyperson-to-apprentice ratios in certain trades; and
    • Refrain from expanding the number of compulsory trades, while working to address the problems within the existing framework.

We strongly urge you to seriously consider the views of Ontario’s job creators, outlined in this submission. CFIB appreciates the opportunity to comment on this review and looks forward to attending the in-person consultations to further expand on the points made in our submission and to provide you with any required clarifications on the issues raised above.

Please have your scheduler contact us at 416-222-8022 ext. 471 to find a mutually convenient time to meet. We look forward to working with you to further support the skilled trades in Ontario.

Original signed by:

Plamen Petkov
Vice-President, Ontario

Anna Gontcharova
Policy Analyst, Ontario