The proposed compliance framework may be able to lead to real implementation steps that ensure the principle of equal protections for migrant workers is met. However, three critical changes are needed to ensure that these regulations do not end up doing the opposite:
1. The compliance mechanisms and sanctions must not in any way punish workers for their employers’ abuse. The regulatory mechanism should include open work permits, and access to permanent residency for migrant workers. Failure to do so would make these regulations extremely punitive for migrant workers.
2. There should be no exceptions to workplaces that are being inspected or sanctioned. All migrant worker employers, that is those who are part of the Seasonal Agricultural Workers Program, Live-In Caregiver Program and the Temporary Foreign Workers Program, should be equally and comprehensively assessed for abuse.
3. These regulations will result in a convergence, and possible confusion between provincial and federal jurisdictions. MOUs on information sharing, and specific protocols to ensure that migrant workers are able to gain lost wages, or have access to other entitlements under provincial jurisdiction, must be developed.
For our full submissions, click HERE.