Dean Review Consultation Questions

Written submission to Dean review

Submission number: DR-24

Name of organisation making submission: DR-24 Tri-Mach Group

Responses to questions in submission form

Section A - The Public Interest in this Review

1. What do you understand by public interest?

Does the public care about the issue

2. Who should the College serve? Who is “the public” in the public interest and what groups make up the public?

The college should serve the Province of Ontario. Lobbyists should not be considered "public"

3. How should the College make decisions in the public interest where different segments of the public may have opposing interests?

It should be decided by the board of governors through consultation with the other boards

4. Is the College currently protecting the public interest?

I do not know.

5. How should the College advance the public interest?

I do not know

Section B - Issues Related to Scopes of Practice (SoPs)

6. What impact do SoPs in regulation have on your daily work activities or on the way you conduct business? What aspects of an SoP are important to the work of your trade? Please explain.

The SoP's for the IMM was so poorly written it has had major impacts to what a millwright should and should not be allowed to do.

7. Do you agree with the suggestion that trades may have core elements as well as peripheral elements?

Absolutely. Millwrights have massive peripheral elements with virtually every trade, and yet it is considered core elements in the actual Millwright trade.

8. What should be the key elements of an SoP? In particular, should the SoP for a trade list all of the tasks, activities or functions in which an apprentice should be trained, only those that are unique to the trade, or only those that may pose a risk of harm to the public, tradespeople or other workers on the job? Please explain.

An SoP must be written to clearly show any person, whether a skilled trades person or not, what a particular trade is allowed to do anytime, sometimes, or not at all.

9. How should a review or change in SoP be carried out?

It should be started at the Trade Board level. Then it should move up to the divisional board. If both boards agree 100% it can be pushed farther up the ladder. If there is disagreements, they have to be cleared first between both boards through consultation.

10. Can or should the existing SoP provisions support the College’s diverse functions (e.g., apprenticeship training, enforcement, classification reviews)? Please explain.

Do not understand the question.

11. Should the entire SoP for a compulsory trade be enforceable or be subject to enforcement? Please explain.

Yes. Providing the SoP has been properly written for each particular trade. That is not the case as it stands today.

12. Could the College benefit from a distinct list of compulsory activities that may pose a risk of harm to the public, tradespeople or other workers on the job? Please explain.

In my opinion the answer is no. If a trade is being executed as per the way it is taught both in school and by a Journeyman, there is no need to add another layer of bureaucracy.

13. What is your understanding of what an overlap between SoPs is?

For instance, millwrights place equipment, and are trained and qualified to run air and waterlines, as well as duct work to that equipment. This is a part of the trade. It is also a part of sheet metal and of a plumber.

14. Do overlaps between SoPs in regulation have an impact on your daily work or on the way you conduct business? Please explain.

It did not to me personally for 25 years and the millwright trade itself for 100 years until the OCOT was created.

15. Does the application of the third legal interpretation principle on overlapping SoPs pose a risk of harm to the public, tradespeople, or other workers on the job? Please explain. If so, what can and should be done about it?

I do not understand the question

Section C - Classification or Reclassification of Trades as Compulsory or Voluntary

16. What makes a compulsory trade compulsory and what makes a voluntary trade voluntary?


17. Is the current classification of trades as either compulsory or voluntary aligned with the College’s duty to serve and protect the public interest?


18. Is it reasonable to assume that there may be elements in the SoP for a trade that are inherently hazardous or that may pose a risk of harm to the public, tradespeople, or other workers on the job?

Of course.

19. Could compulsory certification be limited to either the core elements of a trade or those tasks, activities, or functions that may pose a risk of harm to the public, tradespeople or other workers on the job? What kind of impact would these approaches have on your daily work or on the way you conduct business?

No. This would not be possible. It would mean a company would have to hire 4 different trades to complete something one Millwright would be capable of doing.

20. Should the College continue to rely on an adjudicative review panel approach (i.e., the Ontario Labour Relations Board model) or should a different model be considered? Please explain.

All trade related issues should be handled by the OCOT and not Labour Relations.

21. How should expert opinion be obtained?

Through the boards within the OCAT

22. Are the current criteria for trade classification reviews set out in O. Reg. 458/11 consistent with the public interest? Please explain.

No idea

23. Are the criteria specific, clear and measurable enough to inform you of what data and evidence are needed to meet those criteria?

No idea.

24. Are the existing criteria the right criteria?

No idea.

Section D - Decisions of the Ontario Labour Relations Board (OLRB)

25. Do the scopes of practice (SoPs) in regulation reflect the way in which work is actually assigned in your trade or sector?


26. Do you agree with the notion that most jurisdictional disputes arise from peripheral elements of the trades? Please explain.

Yes. Again, millwrights have crossover with almost every trade.

27. What consideration should the College give, if any, to the decisions made by the OLRB in jurisdictional or work assignment disputes under the Labour Relations Act? If the College were to adopt the OLRB's decisions, what impact would that have on your trade and the way you conduct business? Please explain.

No idea.

Section E - General Response and Comments

28. Please provide additional comments below, if any.

Respondent did not provide a response to this question