Submission

To Whom it May Concern:

Thank you for the opportunity to provide input as part of the review of Part III of the Canada Labour Code. As a federally regulated employer, we appreciate the opportunity to voice feedback on behalf of our company and of our industry.

ISSUES

From the consultation paper; we would like to address the following:

Section II: Looking at Existing Federal Labour Standards: What works? What doesn't Work?

Question 2: Do any current provisions of Part III of the Canada Labour Code need Improvement? Are there problems with the application of Part III of the Code that need examining? What works and what doesn't work from your perspective?

BACKGROUND

Our company is called Atlantic Turbines and we are a repair and overhaul facility for Pratt & Whitney Canada PW100, PT6A and JT15D gas turbine and turbofan engines. As a member of the aerospace industry, we feel our business demands justify the requirement to have employees work hours in excess of the 48-hours per week maximum as is currently identified in the Canada Labour Code. Obviously, the requirement to work would be based on production demands as well as the willingness on behalf of the employee. Under no circumstances, would an employee be forced to work additional hours. In addition, any hours worked over the standard 40-hours per week are compensated at time and a half.

We feel this request satisfies the purpose of this review as it attempts to modernize federal labour standards, ensuring they remain relevant and effective in today's business environment. Quite simply, we feel the 48-hour weekly maximum is neither relevant nor effective for our company and/or the aerospace industry as a whole.

The nature of the work in the aerospace industry is cyclical as well as customer driven, requiring us to respond appropriately to both the peaks and valleys. An ability to meet customer demands and timelines is of critical importance and ultimately will determine the successfulness of our business. Without greater flexibility in scheduling, we would simply not be able to maintain the levels of employment we currently enjoy. As this is the nature of our business, short-term peaks create the need for additional hours to be worked, however, such short-term requirements do not justify the need for an additional hire. Such customer demands are to be expected in this industry and only secure the jobs that currently exist.

RECOMMENDATIONS

We are recommending that the aerospace industry be made exempt from the hours of work prevision limiting the maximum number of hours worked to 48-hours per week. Without question, we understand the importance of employees having their personal time aside from work commitments. As a company, we work to promote a healthy life/work balance for all our employees. However, to ensure the continued employment of our workers, we must be able to meet customer demands if we are to remain in business in this highly competitive industry.

Should the aerospace industry be made exempt from this provision, employees would only surpass the weekly 48-hour maximum when necessary to meet production demands.

CONCLUSION

Again, we would like to thank you for the opportunity to allow employers operating within the Canada Labour Code to provide feedback as you conduct this review of the Canada Labour Code. Should you wish to discuss the issue described above in further detail, please do not hesitate to contact Maureen Mix, Human Resources Director at (902) 888-1817 or by email at mmix@atlanticturbines.com.

Sincerely,

John MacDougall
President
Atlantic Turbines International Inc.

JM/er