Standing Committee on Finance and Economic Affairs

Ann Hoggarth, MPP, Chair
c/o Eric Rennie, Clerk

Room 1405, Whitney Block
Queen’s Park, Toronto, ON
M7A 1A2



RE: Bill 148, Fair Workplaces, Better Jobs Act, 2017


Dear Members of the Standing Committee on Finance and Economic Affairs,

On behalf of 350,000 college and university students in the province, I am writing to you today to express our support and recommend for the changes in Bill 148, Fair Workplaces, Better Jobs Act, 2017 that will benefit students and workers across Ontario. The Canadian Federation of Students-Ontario is the largest organization that represents full and part time college, undergraduate and graduate students in Ontario.

Students working minimum wage today need to work more than twice as many hours as previous generations to pay for a semester of school. In 1991, it took students on average 329 hours or 9 weeks working at minimum wage in Ontario to pay for tuition. Today, students must work at least 721 hours or 21 full time workweeks to pay for tuition fees in the province. Students across Ontario are facing skyrocketing tuition fees and mortgage-sized debt loads leaving them with no choice but to rely on precarious work to finance their education and make ends meet.

This submissions works to provide support for and recommendations on the government’s proposed changes to Bill 148.


Elimination of the Subminimum Wage

In Ontario, the increasing cost of living and mounting debt for college and universities students means that students require a model of equal pay for equal work. Students work the same jobs as their non-student counterparts but are paid less and discriminated against on the sole basis of their status as students. Currently, Ontario is the only province with a subminimum wage for students. Exempting student’s means that work done by those under the age of 18 is not valued equally, even when they are doing the same work as an older worker. We cannot assume that young workers have fewer expenses than their 19-year-old counterparts. As the cost of post-secondary education continues to increase, students cannot afford to be paid a rate less than the general population. Instead, the Employment Standards Act should look towards creating a more equitable system of pay where students are given fair wages for the work they are doing.

We recommend eliminating the student minimum wage and applying the general minimum wage to all students.


Fairer Scheduling

Scheduling issues are of the utmost importance for college and university students in Ontario. Many workers, including students, receive their schedules at the last minute and at different times every week. This practice is the cause of distress and the source of many problems for students who also have to deal with added challenges like class schedules, childcare and transportation.

For far too long students have faced precarious work situations due to longstanding gaps in the Employment Standards Act that fail to ensure fair scheduling. Currently, there are no provisions that require schedules be provided in advance. Employers expect part time workers to be available for five days a week but only schedule them for two or three. The Employment Standards Act lacks a requirement to provide schedules with reasonable notice. The expectation that workers will be available for erratic shifts creates an immense emotional and financial hardship as workers are routinely faced with the thought of being looked at disapprovingly, if they do not choose to take last-minute shifts, particularly over the holidays.

We strongly recommend further amendments to Bill 148, that will include posting work schedules two weeks in advance, paying employees an equivalent of one hours pay if the schedule is changed with less than a week’s notice, four hours of pay for schedule changes made with less than 24 hours’ notice and removing any exemptions from fair scheduling rules to ensure employers cannot get around their obligations.


Paid Emergency Leave

If Bill 148 is passed it will provide personal emergency leave to all employees, not just employees of employers who regularly employ 50 or more staff. This section of the bill outlines four general areas where personal emergency leaves may be taken. Each area is defined by events that are unplanned or out of the employee’s control and raises the possibility of serious negative consequences if not responded to. For the vast majority of working students in post-secondary education, final examination schedules are generally not publicized until four to six weeks prior to their undertaking. Further, it is common for individual examination schedules to be condensed into spans of ten days. Working students are often pressured to maintain their employment schedules while studying for final examinations. The fear of losing shifts and/or summer employment is a common concern.

We support the government’s proposal to extend this protection to all workers, with at least two (2) of these 10 emergency leave days being paid and additionally at least two (2) paid leave days with no doctor’s note, if the employee has been employed by the employer for one week or longer.

We strongly recommend that a category recognizing final examinations and mid-term examinations be considered as a reason for personal leaves due to the fact that these particular times are highly stressful and time consuming for students.


Exemption for Private Colleges

According to the Ministry of Advanced Education and Skills Development, there are over 500 private career colleges in Ontario, with students who face similar challenges in accessing and financing their educations. Since private institutions are not held to the same standards as public institutions, it is imperative that legislation is created to acknowledge the experiences of students in private colleges who are often working in unpaid or precarious placements.

We are strongly opposed to the removal of Paragraph 2 of subsection 3(5) of the Act, which will exempt students in private colleges from the Employment Standards Act, 2000. This is dangerous, as it will enable private colleges and employers to expand unpaid internships, and potentially replace entry-level jobs with unpaid internships.

We recommend that Bill 148 reinstate Paragraph 2 of subsection 3(5) of the Act, to honor the Ministry of Labour’s statement and the purpose of this review which, was to “ensure that all ESA requirements and entitlements would apply to people receiving training for work through their employer” in May 2017.



In conclusion, the changes to Bill 148 are greatly welcomed. If adopted, this would represent a huge victory for all workers and students, who are most often also workers. However, with this victory, there is still much more work to be done in order to win decent work for all. Bill 148 does not eliminate the subminimum wage for students and liquor servers; the equal pay language in the bill needs to be stronger to ensure that it be effective for all workers and exemptions from fair scheduling policies needs to be removed to ensure employers cannot get around their obligations. We would like to thank you for your time in reviewing this submission and taking steps to listen to the needs of hundreds of thousands of students across the province. Though we are disappointed that we were not selected for a deposition, we look forward to continuing to work together to ensure that workers’ – particularly student workers’ – needs are met.




Nour Alideeb