Thank you.

Good morning, Mr. Chair, honourable committee members, fellow witnesses, and members of the gallery.

The educational landscape in Canada has changed significantly over the last number of years. Students and employers may differ in their expectations of post-secondary education, but both agree on employability as an increasingly important outcome.

In response to these changes, students and institutions are making work-integrated learning an integral part of their educational experience. The expansive sphere of co-ops, internships, job placements, and so forth are indicative of changes that are occurring in the post-secondary sector. Students and young people today want the opportunity to graduate not only with knowledge from the classroom, but also experience in the field. Both students and employers recognize the value in having this experience, as it eases the transition into the workforce.

The Canadian Alliance of Student Associations is an advocate for ensuring that students and young people are protected and treated fairly in the workplace. We have been active on this file for some time, but most recently with Ms. Laurin Liu's private member's bill, and we were vocal opponents of the ill-advised remarks by Bank of Canada Governor Poloz.

CASA has worked with both the government and the opposition to support the protection of young Canadians. That is why we are pleased to see the government take action in Budget 2015 with a proposal to amend the Canada Labour Code to better protect interns. This and the additional budgetary measure of eliminating income tax on money earned in-study as part of the Canada student loans assessment are steps that demonstrate that the government sees supporting young people in work and study as a priority.

Certainly we can all agree on the importance of ensuring that students and young people are protected from abuse and exploitation while in the workplace. They must be treated fairly and, in the case of interns, be able to gain necessary experience to use in a future career.

With that said, CASA believes that the proposed amendment to the Canada Labour Code being put forward lacks clarity and still leaves interns vulnerable to exploitation and possible abuse. Requiring that interns be protected with basic health and safety standards goes without question. These changes alone, though, do not go far enough, and further steps are required to ensure that all interns are sufficiently protected. The proposed amendments do not provide interns with the same rights and protections as other federally regulated employees. Recognizing that interns have unique needs that would require exceptions, we believe that the greatest level of protection would be achieved by classifying them in the Canada Labour Code as employees.

Looking through the lens of public policy, the proposed amendments fall short of achieving the comprehensive protection that interns require. If the goal is to protect interns, then we should give them the same rights as employees under the labour code while carefully recognizing the exceptions that are unique to these internships. Why create more ambiguity and confusion when a simple alternative is available?

Without additional provisions, there are a number of areas under the proposed legislation in which interns may be vulnerable to exploitation from employers.

There is potential for interns and federally regulated industries to be in the position of having their work not be recognized or compensated, whether in the form of pay, academic credit, or some sort of certification. Instead, interns may be left with nothing to show for their time.

Secondly, with no limits on the number of consecutive internships, there's a concern that students or young people may find themselves in cycles of internships of either unpaid or low-paid work.

Thirdly, while the number of hours per work period is limited, because interns are not employees there is no limit to the number of hours in a day or week that an intern may have to work, and no overtime compensation if they do work additional hours.

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