Hon. Seamus O’Regan
Minister of Labour
80 Wellington Street
Ottawa, ON
K1A 0A2

Re: Amendments to Bill C-3

Dear Minister O’Regan,

We write to you today to stand in support of the Decent Work and Health Network’s call on the Federal government to make several important amendments to Bill C-3.

The Canadian Federation of Students-Ontario is the oldest and largest student organization in Ontario, representing over 350,000 college and university students in every region of the province. We represent undergraduate and graduate, part-time and full-time, domestic and international students – all of whom have different lived realities, especially during this pandemic. With the ongoing pandemic, the financial realities of many students continue to worsen as many are now employed as casual and precarious workers who do not have access to paid sick days. While the introduction of 10 paid sick days for only federally regulated employees is an important and necessary first step, it is essential that these paid sick days extend to all workers.

We support the Decent Work and Health Network’s campaign demands and urge the Federal government to make the following necessary amendments to Bill C-3:

  1. Leave with pay (s 239 (1.2))

We recognize that the call for paid sick days is vital for the health and safety of students who are working low-wage and precarious jobs, and to prevent the spread of COVID-19 and other communicable diseases. Paid sick leave must provide an adequate number of sick days for workers when they are ill so that they can stay safe, recover and protect those around them. While the current Bill C-3 allows for 10 paid sick days, they are not accessible upon employment and are accrued only after a month of employment. These barriers are contrary to public health expert recommendations on the measures that should be taken when a worker begins to experience symptoms. Workers should not have to face the difficult decision between working sick or taking the necessary time off to recover while losing out on pay.

We recommend that Bill C-3 (s 239 (1.2)) be amended to provide full access to 10 paid sick days after two weeks of continuous employment for all workers.

  1. Certificate – leave with pay (s 239 (1.6))

The skyrocketing cost of tuition fees is one of the many barriers college and university students continue to face. Students who are working low-wage jobs–or several low-wage jobs–have difficulties accessing healthcare. Allowing employers to require sick notes is an additional barrier for student workers. Many students access on-campus medical services as their primary healthcare provider which are operating at capacity and it is difficult for students to access appointments including sick notes. Additionally, international students do not have equitable access to healthcare which hinders their ability to request sick notes from a medical provider.

The provisions allowing employers to require sick notes disincentivizes workers from taking sick days. Student workers cannot afford to take unpaid sick leave with the high-cost of tuition fees, housing/rent costs and other important expenses such as groceries and medications. Additionally, students having to commute to their medical provider to request a sick note puts their communities at risk, especially when travelling on transit or waiting in a crowded waiting room. Allowing employers  to  require  a  medical  certificate  from  a  health  provider  would  create  barriers  to  access and  pose  risks  to  our  healthcare  system. It is vital to the health of students on campus and students living throughout the community that everyone has access to paid sick days without unnecessary barriers such as required sick notes.

We recommend that section 239 (1.6) be removed from Bill C-3. That is, remove the provision that enables employers to require a health provider’s certificate when accessing the new 10 paid sick days program.

The amendments to Bill C-3 are necessary and vital as it will help shape legislation for all the other provinces across the country when it comes to paid sick leave. In order for us to achieve a truly just recovery, paid sick days must be extended to include all workers and without the added barriers.

The call for amendments is not only supported by the Decent Work and Health Network, but it is also supported by healthcare providers, public health officials, unions, economists and businesses so that we can continue onto a path of just recovery that is both economically viable and safe.



Kayla Weiler
National Executive Representative, Canadian Federation of Students-Ontario