Contractors Association

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1 Submission for Ratio Review of Refrigeration and Air-Conditioning Mechanic Ontario Pipe Trades Council Contractors Association Introduction Ontario Pipe Trades Council (OPTC): The Ontario Pipe Trades Council represents 16 affiliated locals that are chartered by the United Association of Journeymen and Apprentices of the Plumbing and Pipefitting Industry of the United States and Canada (UA). The OPTC is the designated Employee Bargaining Agency under the Ontario Labour Relations Act for the plumber and steamfitter trades in the industrial, commercial and institutional sector. The Council also represents its affiliated locals in the electrical power systems sector. The OPTC fully supports the submissions of its affiliate - United Association HVAC and Refrigeration Pipefitters, Local Union 787. Local 787 is a province-wide local representing journeypersons and apprentices in the Refrigeration and Air-Conditioning Systems Mechanic trade. Current Ratio: The current ratio provisions are set out in R.R.R.1990, Regulation 75/05 provides as follows: 6. (1) If an employer employs no more than seven journeypersons in the certified trade, the number of apprentices in the certified trade who may be employed by 1

2 the employer shall not exceed the number set out in Column 2 of the Table to this subsection opposite the number of journeypersons employed by the employer and set out in Column 1 of the Table. TABLE Column 1 Column 2 Number of Journeypersons Number of Apprentices Allowed (2) If an employer employs more than seven journeypersons in the certified trade, for every three journeypersons employed after the seventh journeyperson, the employer may employ an additional apprentice. For small employers (i.e., those covered by the above chart), the effective ratio is 2:1 or less. For larger employers, the effective ratio is 3:1. Submissions with Respect to Specified Criteria Criterion 1: The scope of practice of the trades. The Refrigeration and Air-Conditioning Mechanic trade comprises two branches: 2

3 Refrigeration and Air-Conditioning Systems Mechanic (313A) Residential Air Conditioning Systems Mechanic (313D) A Refrigeration and Air-Conditioning Systems Mechanic (313A) is qualified to work on any air conditioning and refrigeration system. A Refrigeration and Air-Conditioning Systems Mechanic (313A) is restricted to working on systems that are installed as independent units in dwellings, use a maximum of 240 volts/60 amps and for which the cooling capacity does not exceed 60,000 BTU (5 tons). Figure No. 1 compares other features of the two branches of the trade. Figure No. 1 Comparison: Refrigeration and Air-Conditioning Systems Mechanic (313A) and Residential Air Conditioning Systems Mechanic (313D) Refrigeration and Air-Conditioning Systems Mechanic (313A) Residential Air Conditioning Systems Mechanic (313D) Red Seal Yes No Training Period 9000 hours 4500 hours Compulsory Yes Yes Installation repair of hermetically sealed, self-contained, portable units (maximum 240 volts) is not covered by the trade regulation ((75/05) and can be performed without holding a Certificate of Qualification or being a registered apprentice in either branch of the Refrigeration and Air-Conditioning Mechanic trade. Similarly, workers engaged in manufacturing refrigeration and air conditioning systems are not covered by the trade regulation. Some aspects of the installation and repair of air conditioning and refrigeration systems may involve tasks that are regulated by the Technical Standards and Safety Authority (TSSA). This applies when there is a system interface with a gas or oil-burning furnace or with a pressure system. A separate TSSA certification is required to perform these tasks. 3

4 There is limited, but not significant, overlap between this trade and the Sheet Metal Worker trade, which is also a compulsory trade. The overlap is not material to ratio policy. As a general principle, Sheet Metal Workers install the air distribution portion of an HVAC system whereas Refrigeration and Air-Conditioning Mechanics are engaged primarily in the installation of the heating and cooling machinery. As a practical matter the scope of practice of the Refrigeration and Air-Conditioning Systems Mechanic trade is well understood in industry and reflects the organization of construction, maintenance and repair work across specialized trade contractors. Refrigeration and Air-Conditioning Systems Mechanics (313A) are a recognized trade for provincial bargaining under the Labour Relations Act. United Association HVAC and Refrigeration Pipefitters, Local Union 787 is the designated employee bargaining agency. The Ontario Refrigeration and Air Conditioning Contractors Association (ORAC) is the designated employer bargaining agency. The provincial agreement negotiated between Local 787 and ORAC covers both ICI and non-ici construction and maintenance, including residential work. The scope of trade distinction between Refrigeration and Air-Conditioning Systems Mechanic (313A) and the Residential Air Conditioning Systems Mechanic (313D) implicitly recognizes that there may be different skill requirements in the low-rise residential sector. It is important to note, however, that companies that operate in the low-rise residential sector are typically smaller employers. The ratios that would apply to these employers are there for the ratios set out in the table that is part of the trade regulation (reproduced at page 2). In other words, the effective ratio for employers in the low-rise sector is already 2:1 or less. Even setting aside, the likelihood of a slow-down in low-rise construction, there is no need to alter the journeyperson-to-apprentice ratio to accommodate the needs in the lowrise sector. For all practical purposes, the low-rise sector already operates with a ratio of 2:1 or less. 4

5 We conclude, therefore, that there is nothing in the scope of the trades, as defined by Ontario Reg. 75/05, which should lead this Review Panel to alter the current journeyperson-to-apprentice ratio. Therefore, based on Criterion One, the current ratio for both trades should continue without change. Criterion 2: The apprenticeship program established by the College. In addition to certain community colleges which are designated to deliver training in Branch One or Branch Two of the trade, there is also a training centre operated under the auspices of the Joint Training and Apprenticeship Committee (JTAC) which is a partnership of Local 787 and ORAC. Additionally some colleges also offer technician training which may enable a graduate to enter an apprenticeship with advanced standing or to take the Certificate of Qualification examination on a challenge basis. Figure No. 2 shows the number of seat purchases to support in-school training of apprentices over the past four years. These data were supplied to the Ontario Construction Secretariat by the Ministry of Training Colleges and Universities. Figure No. 2 Seat Purchases Refrigeration and Air-Conditioning Systems Mechanic Year Seat Purchase

6 As can be seen from Figure No. 2, seat purchases have been relatively stable. The apprenticeship program established by the College of Trades is fully viable under the current ratio provisions. Based on Criterion Two, there should be no change to the current ratio. Criterion 3: 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. Health and safety in the Refrigeration and Air-Conditioning Mechanic trade requires both comprehensive training and careful supervision. Evidence of the breadth and depth of safety training required can be gleaned from the Construction Multi-Trades Health and Safety published by the Infrastructure Health and Safety Association. The Manual applies to boilermakers, millwrights, refrigeration and air-conditioning mechanics, the pipe trades, sprinkler and fire protection trades, and insulators. The Manual is 471 pages in length which is indicative of the comprehensiveness of the safety training required. Younger workers - and most apprentices fall into this category - are often tempted to cut corners on health and safety practices, especially if they slow down completion of a task. Indeed, the Infrastructure Health and Safety Association advises that new and young workers in Ontario are four times more likely to be injured during the first month of employment than at any other time. 1 It is important, therefore, that the workplace be composed predominantly of experienced journeypersons who have been trained in the culture of safety consciousness and who can both supervise young 1 6

7 workers and reinforce the safety culture. The current ratio achieves this goal. Reducing the journeyperson-to-apprentice ratio will increase the likelihood of risky behaviour. Figure No. 3 shows the WSIB contribution rates for These contribution rates (per $100 or payroll) are a proxy for health and safety performance. Figure No. 3 WSIB Contribution Rates for Construction Industry Rate Groups Rate Group Premium per $100 of Payroll 704 Electrical And Incidental Construction Services $ Mechanical and Sheet Metal Work $ Power And Telecommunication Lines $ Industrial, Commercial & Institutional Construction $ Roadbuilding And Excavating $ Millwrighting And Welding $ Heavy Civil Construction $ Inside Finishing $ Homebuilding $ Siding And Outside Finishing $ Masonry $ Roofing $ Form Work And Demolition $18.31 The OPTC s affiliated local, UA Local 787, in its submission to this Review Panel describes in more detail the specific health and safety risks in dealing with pressure vessels and refrigerant liquids, exhaust fumes, high voltage and other hazards. We urge the Review Panel to take careful note of these hazards. The industry currently manages these hazards well as is evidenced by the WSIB premium which is among the lowest in the construction industry. One of the foundations of the safety consciousness culture that the industry has successfully instilled in the work place is the current journeyperson-toapprentice ratio. 7

8 Some may argue that the industry s safety performance is unrelated to the journeyperson-to-apprentice ratio and that this ratio could be reduced without jeopardizing health and safety performance. We acknowledge that there is no clear-cut empirical evidence on the relationship between health and safety performance and the journeyperson-to-apprentice ratio. WSIB claims data are often not readily available at the occupational level and certainly not at a level that distinguishes between journeypersons and apprentices. There may be merit in undertaking such research, but at this time, we must acknowledge that clear-cut data are not available. How then should the Review Panel approach the ratio question in the context of health and safety performance? We respectfully suggest that where safety is at issue, the Review Panel should proceed with great caution. In the absence of clear-cut and persuasive evidence that the ratio of journeypersons-to-apprentices could be reduced without increasing the risk to health and safety performance, the Review Panel should leave the current ratio as it stands. We further submit that no such evidence is available. The only indirect evidence that can be marshalled is workers compensation rates in different jurisdictions which may be lower than those in Ontario and which may coincide with lower journeyperson-to-apprentice ratios. This type of evidence, however, is far too weak to support the strong conclusions that some proponents would ask you to draw. In the first place, the technical definitions of rate groups are often not commensurate across jurisdictions. Second, many factors influence a premium level, including (especially in Ontario) the magnitude of the unfunded liability, the actuarial assumptions used to estimate future benefits costs, and the benefit structure itself. And third, premium rates are based on claims experience, not on actual injuries. Especially in inter-jurisdictional comparisons, reported claims do not bear a reliable relationship to actual injuries, since a great many injuries are unreported. 2 For all of these reasons, the Review Panel should attach little, if any weight, to inter-jurisdictional comparisons of workers 2 In a national survey commissioned for the Canadian Policy Research Network and conducted by Ekos Research, it was found that 40% of persons in the work force covered by workers compensation experienced lost-time injuries that they had not reported to the workers compensation authority in their province. Harry Shannon and Graham Lowe, How Many Injured Workers do not file Claims for Workers American Journal of Industrial Medicine, vol. 42, pp (2002) 8

9 compensation rates. Certainly such comparisons should not be relied on to make major changes in the journeyperson-to-apprentice ratio that could weaken health and safety performance in trades which are intrinsically dangerous. The current ratio is consistent with health and safety goals. Any significant reduction in the journeyperson-to-apprentice ratio could weaken the safety culture that currently operates in both branches of these trades. Based on Criterion Three, there should be no change to the current ratio. Criterion 4: The effect, if any, of the journeyperson to apprentice ratio of the trade on the environment. The Refrigeration and Air-Conditioning Mechanic trade is particularly relevant to good environmental practice. Again, we refer the Review Panel to the submissions of our affiliated local, UA Local 787, which describes in detail the importance of this trade to sound environmental practice. Poorly installed ventilation systems waste energy, reduce occupants comfort, and increase the risk of mould and bacterial cultures developing. When HVAC machinery is improperly installed, condensation and pooling can occur. This facilitates the multiplication of moulds and bacteria. The result is sick building syndrome and costly remediation. In the worst circumstances, there is the risk of a legionellosis culture developing. This bacterium causes the deadly legionnaires disease. Correctly installed refrigeration systems are essential to the preservation of food products. 9

10 The relevance of the journeyperson-to-apprentice ratio to environmental performance is similar to health and safety. Air conditioning and refrigeration machinery must be installed properly to meet the expected performance of the mechanical systems. There are several components to the construction system that ensure proper performance in a mechanical installation. Designers with a P.Eng designation, licensed contractors and certified journeypersons are all part of this system for ensuring the integrity of a large-scale air conditioning or refrigeration installation. It makes little sense to require that the mechanical system in a large, multi-resident building be designed and manufactured to a high standard, only to have it installed by a crew that has too many inexperienced apprentices to ensure proper installation. The current journeyperson-to-apprentice ratio is an integral part of the system for ensuring quality in the installation of air conditioning and refrigeration systems. This Review Panel should be cautious in reducing the ratio of journeypersons-to-apprentices lest it open the door to risks which are currently under control. The consequences of improper installation, especially in a large ICI project, justify a conservative approach to ratio policy. The risk to environmental performance from improper mechanical installation is significant. Absent compelling reasons, the Review Panel should not increase the risk of improper installation by enabling a reduction in the number of journeypersons on worksites and a commensurate increase in the number of apprentices. Based on Criterion Four, the current ratio should be renewed. 10

11 Criterion 5: 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. Figure No. 4 summarizes MTCU data on the number of journeypesons and apprentices in the Refrigeration and Air-Conditioning Mechanic trade (both branches): Figure No. 4 Refrigeration and Air-Conditioning Mechanic (Both Branches) Status Number Journeypersons 7,965 Apprentices 2,271 Implied Ratio 3.5:1 As can be seen from Figure No. 4, the current data indicated an implied ratio of 3.5:1 on a provincial basis. Clearly, the current ratio is not an impediment to hiring more apprentices. While there may be individual employers that are operating at the ratio limit, the average implies that most employers are operating above the permitted ratio and that, on a system basis, there is ample scope to increase the employment of apprentices. If employers are not hiring more apprentices, it is because they are constrained by the amount of work available, not because the current ratio impedes their hiring. Substitution Effect / Reduction in Crew Cost: In light of the data in Figure No. 4, the most probable consequence of reducing the journeyperson-toapprentice ratio would be to encourage substitution of apprentices for journeypersons so as to reduce the cost of a crew. While some types of trade work require the knowledge and experience of a journeyperson, there are other types of trade work that can be performed proficiently by fourth or fifth year apprentices. Moreover, these fourth and fifth year apprentices would know that their only 11

12 competitive attraction is that they are cheaper than a journeyperson. This means that these apprentices would have a diminished incentive to complete their training, since to do so would jeopardize their employment. The most likely impact of lowering the journeyperson-to-apprentice ratio in a context in which the effective ratio is currently above the permissible minimum would therefore be to increase unemployment among journeypersons and discourage completion of apprenticeship training. Other Risks: The second economic impact of reducing the journeyperson-to-apprentice ratio would be to increase the risk that is associated with using less skilled workers, since an increase in the number of apprentices necessarily implies using less skilled workers. There are four types of risk that will be increased: (1) the risk of lower productivity which will offset in whole or in part the benefits of lower hourly crew costs, (2) the risk to installation quality which may affect the performance of the installed system, (3) the increased risk to health and safety performance which is strongly associated with increasing the proportion of less experienced and younger workers, and (4) the risk of reduced quality of on-the-job training and the consequent failure to correct unsound or unsafe work practices and instill proper efficiency in the performance of trade tasks. (Note that 90% of an apprentice s training time is on-the-job training.) There is an asymmetry between who gains the economic benefit from reducing the journeyperson-toapprentice ratio and who bears the costs associated with these increased risks. As we noted above, the 12

13 economic benefit of reducing the journeyperson-to-apprentice ratio would be enjoyed primarily by (non-union) employers in the form of lower crew costs and higher profit margins. However, the majority of the risks would be borne by the owners of buildings (through increased risk to installation quality and productivity), workers (through increased risk to safety performance), apprentices (increased risk to training quality), the building inspection system (through increased risk to installation quality), the workers compensation system (through increased risk to safety performance), etc. The economic benefits flow in one direction. However, the economic costs associated with increased risk flow in another direction. Unbalancing the Labour Market: The most expert and objective forecast of supply and demand trends in the regulated trades is the projection published by the Construction Sector Council (CSC). As will be described later in this submission, the CSC`s long-term forecast is for a balance between supply and demand in the Refrigeration and Air-Conditioning Systems Mechanic trade. This forecast is predicated on current ratio patterns. Using the CSC forecast as the base, we can ask what the effect would be of increasing the number of apprentices beyond current projections. First, however, it is important to recognize that the demand for labour is a derived demand. That is to say, employment opportunities are determined by the volume of trade work. Increasing the supply of apprentices does not increase the volume of trade work. Only increased investment in construction and repair can increase the volume of trade work. In the absence of an increase in the volume of trade work, the effect of increasing the supply of apprentices is either to redistribute the existing work from journeypersons to apprentices or to increase the number of unemployed apprentices. These are not mutually exclusive impacts. Indeed, both are likely to occur. Those employers that are attracted to the opportunity to reduce their crew costs, will replace journeypersons with apprentices, thereby increasing unemployment among journeypersons. 13

14 Those employers that already operate with a higher journeyperson-to-apprentice ratio than required will continue to do so, thereby ensuring that unemployment is more widespread among apprentices than is currently the case. It is simply a delusion to believe that jobs can be created by reducing the journeyperson-to-apprentice ratio. As long as the labour market is in balance, the only effect of inducing an influx in the number of apprentices will be to unbalance the labour market and make unemployment more widespread. How much of that burden of that unemployment will be borne by apprentices or journeypersons will depend on how employers respond to the reduced ratio. Training System: The initial effect of a reduction in the journeyperson-to-apprentice ratio is likely to be an influx in the number of workers taking introductory training. However, as these apprentices move into a labour market where demand is restricted by the volume of trade work, many of them will experience long spells of unemployment and will abandon their apprenticeship studies. For the province and for these apprentices, training resources and training time were wasted. As anecdotal evidence of unemployment becomes more widespread, new registrations in the trade will drop off. The initial gains in new apprenticeship registrations will then be offset by subsequent declines. Colleges and other training deliverers will initially have their resources stretched. Then they will be forced to deal with redundancies when new registrations decline. There is already a significant degree of cyclicality in apprenticeship training. This cyclicality is an inevitable by-product of cyclicality in the construction industry. It makes no sense to needlessly exacerbate cyclicality in apprenticeship training by artificially inducing an influx of new apprentices only to oblige the system to subsequently correct for this imbalance. 14

15 Taking all of these factors into account, we conclude that the economic impact of reducing the journeyperson-to-apprentice ratio would be negative and that, based on Criterion Five, the current journeyperson-to-apprentice ratio should continue without change. Criterion 6: The number of apprentices and journeypersons working in the trade. As noted in the previous section (Figure No. 4, page 11) the current implied ratio of journerypersons to apprentices is 3.5:1 which is well above the permitted ratio. It is the view of the Ontario Pipe Trade Council that the current labour market of Refrigeration and Air Conditioning Mechanics is in balance. This view is supported by the analysis and forecasts of the Construction Sector Council. Figure No. 5 summarizes the labour market rankings estimated for 2012 and projected through to 2020 by the Construction Sector Council (CSC) for the Refrigeration and Air Conditioning Mechanic trade. The CSC s labour market rankings gauge the degree of balance (or imbalance) in the labour market, after taking account of demand and supply trends. The CSC uses a 1-5 scale, where 1 implies significant excess supply of workers (i.e., high rates of unemployment) and 5 implies significant excess demand (i.e., pervasive skills shortages). A ranking of 3 corresponds to an approximately balanced labour market in which the incentives to enter and remain in the trade are consistent with employers long-run skill needs. Figure No. 5 Labour Market Ranking Projections: Refrigeration and Air Conditioning Mechanics Construction Sector Council (Screen Capture, January 7, 2013) 15

16 As can be seen from Figure No. 5, the CSC ranks both the current and projected labour market conditions at 3 which implies an appropriate balance between supply and demand requirements. We conclude from this ranking that the number of journeypersons and apprentices in the trade is appropriate to both the skill needs of employers and the employability requirements of journeypersons and apprentices. Therefore, based on Criterion Six, the current journeyperson-to-apprentice ratio should continue without change. Criterion 7: The rates of completion for apprentices in an apprentice training program for the trade The only valid way to measure completion rates is through a longitudinal study that tracks cohorts over time. No such study has been undertaken, although the Ontario Construction Secretariat has commenced such a study. In the absence of a longitudinal study, the only procedure that can be used is to compare new registrations with completions. This comparison should not be used to compute a completion rate as the time taken to complete training varies over the construction cycle and is also affected by the quality of new registrations in a trade. Figure No. 6, which does not attempt to estimate completion rates, shows the number of new registrations per year compared to the number of completions. These data apply only to the Refrigeration and Air Conditioning Systems Mechanic branch of the trade. 16

17 Figure No. 6 Refrigeration and Air-Conditioning Systems Mechanic (313A): New Registrations and Completions (MTCU data provided to Ontario Construction Secretariat) Year New Registrations Plumbers Completions Average As noted at the beginning of this submission, the Refrigeration and Air Conditioning Systems Mechanic (313A) is a five year (9,000 hours) apprenticeship with three periods of in-school training. Some degree of dropping out should be expected. While it is not possible to derive an accurate completion rate from the data in Figure No. 6, the data do suggest that there may be room to improve the completion rate. On average, completions over the period to were around 43% of new registrations. This is somewhat lower than the completion comparison for Plumbers and Steamfitters. In these trades, a similar comparison would show completions over the same period equal to 49% in the Plumber trade and 62% in the Steamfitter trade. While no strong conclusions can be drawn from this comparison, a possible implication is that there may be scope to increase the proportion of apprentices who complete their training. (These are province-wide data, it should be noted. Local 787 has a high completion rate among their apprentices.) 17

18 If employers require more Refrigeration and Air Conditioning Systems Mechanics, then efforts could be made to increase the completion rate. Inducing an influx of apprentices by reducing the permissible journeyperson-to-apprentice ratio will not encourage stakeholders to address the completion challenge. Indeed, it would give the wrong signal. Based on Criterion Seven, there is no justification for altering the current journeyperson-to-apprentice ratio. Criterion 8: The journeyperson to apprentice ratio, if any, for a similar trade in other jurisdictions. The following table summarizes ratio rules that we believe to be current. Figure No. 7 Journeypersons-to-Apprentices Ratios Refrigeration and Air Conditioning Systems Mechanic (Red Seal Trade only) (Red Seal Secretariat: Ellis Chart) Journeypersons to Apprentices British Columbia n/a Alberta 1:2 Saskatchewan 1:2 Manitoba 1:1 Ontario 3:1 Quebec* 2:1 New Brunswick 1:1 Nova Scotia 1:1 PEI 1:1 Newfoundland & Labrador 1:2 *Quebec regulated ratios by sector. The ratio is 2:1 in all sectors except residential where it is 1:1. With the exception of Quebec and Nova Scotia, these ratio rules are general rules applied to all or most construction trades. In western Canada, governments have lowered the permitted ratio in an attempt to augment apprenticeship registrations to meet perceived skills shortages. We have no information on whether the actual journeyperson-to-apprentice ratio is in line with the permitted ratio. 18

19 Criterion 9: The supply of, and demand for, journeypersons in the trade and in the labour market generally. The most objective source of supply and demand information is the Construction Looking Forward forecast model supported by the Construction Sector Council. The Construction Sector Council is a stakeholder organization. Its forecasting model has been described by the Conference Board and the Centre for the Study of Living Standards as an example of a best practice in human resources planning. 3 The CSC forecasting model estimates overall demand, based on two factors. The first is economic demand which is measured by projected employment. The second is replacement demand which is determined by mortality and retirement trends. Economic demand is estimated based on an econometric forecasting model and an inventory of major construction projects. The CSC model estimates supply trends based on (1) an analysis of historic labour force trends, (2) apprenticeship registrations, (3) immigration, (4) inter-provincial migration, and (5) the movement of labour into (or out of) construction from other industries. As noted in the discussion of Criterion Six, the comparison of demand and supply trends then leads to a 1-5 ranking of expected labour market conditions. A ranking of 1 represents significant excess supply, while a ranking of 5 represents significant excess demand. A ranking of 3 is a balanced labour market. The CSC s ranking, and the projections that underpin them are reviewed and validated by industry committees. In other words, these rankings reflect both independent and expert economic analysis and also the view of industry. The CSC model is in public domain and can be consulted at: 3 Conference Board of Canada (2005), The Labour Market Information (LMI) Program: Acting on Human Resource Information to Build and Maintain Capacity in the Canadian Construction Industry Conference Board of Canada (2007) Construction Looking Forward: An Analysis of the Use, Value and Impact of the Construction Sector Council s Labour Market Information (LMI) Forecasting Tool Centre for the Study of Living Standards (2010), The State of Knowledge on the Role and Impact of Labour Market Information: A Survey of the Canadian Experience 19

20 As noted earlier in this submission, the CSC s rankings are consistently at the 3 level for the Refrigeration and Air Conditioning Mechanic trade. For ease of reference, we have replicated this summary again as Figure No. 8: Figure No. 8 Labour Market Ranking Projections: Refrigeration and Air Conditioning Mechanics Construction Sector Council (Screen Capture, January 7, 2013) We conclude, based on the CSC s analysis and forecast of the supply and demand of Refrigeration and Air Conditioning Mechanics and that, with reference to Criterion Nine, this Review Panel should decline to alter the current ratio. Criterion 10: The attraction and retention of apprentices and journeypersons in the trade. A further inference from the balanced labour market conditions described in Criterion Nine (and Criterion Six) is that the Refrigeration and Air Conditioning Mechanic trade is not experiencing any attraction or retention problems that are creating skills shortages. Based on Criterion Ten, therefore, there is no justification for altering the current journeyperson-to-apprentice ratio. 20

21 Criterion 11: The average age of apprentices and journeypersons in the trade and the projected attrition of journeypersons working in the trade. The Construction Sector Council forecast projects mortality and retirements for the construction industry. Figure No. 9 summarizes the projections for plumbers and steamfitters in Ontario: Figure No. 9 Refrigeration and Air Conditioning Mechanics - Projected Mortality, Retirements and New Entrants Construction Sector Council Mortality Retirements Total Over the period 2013 to 2020, replacement demand (i.e., the sum of mortality plus retirements) will average 245 persons. These numbers apply to both branches of the trade. Figure No. 5 (page 15) showed that the average number of completions in Branch One of the trade (Refrigeration and Air Conditioning Systems Mechanic - 313A) was 169 over the period to This accounts for 70% of new skill requirements. The remaining 30% will be accommodated by Branch Two apprenticeships (Residential Air Conditioning Systems Mechanic- 313D). There are no current data on the average age of either apprentices or journeypersons. However, data from the 2006 Census depict the following age structure: 21

22 Figure No. 10 Refrigeration and Air Conditioning Mechanics Age Structure, Ontario (2006) Statistics Canada, 2006 Census Age Group Number Percent 15 to 24 years 1, % 25 to 34 years 2, % 35 to 44 years 3, % 45 to 54 years 2, % 55 to 64 years 1, % 65 to 74 years % 75 years and over % 10, % As can be seen from Figure No. 10, 33.2% of the labour force in the trade is after 45 or older. However, 36.7% of the trade s labour force is under the age of 35. In other words, this trade is not facing a demographic cliff. Based on Criterion Eleven, there is no need to alter the current journeyperson-toapprentice ratio. Conclusion Taking all of the criteria into account, it is the view of the Ontario Pipe Trades Council that the current ratio provisions should remain intact and that the Review Panel should not direct any changes from the current regulation. Respectfully submitted, James Hogarth Business Manager Ontario Pipe Trades Council 22