USW Response to Final Report of Ontario's Gender Wage Gap Strategy Steering Committee

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In October 2015, the Gender Wage Gap Steering Committee started its consultations with individuals and organizations across Ontario on closing the wage gap between men and women. There has been significant research and consensus on the existence of the gap, which is currently 31.5% based on average annual earnings. The wage gap is even larger for racialized women (36.7%), Aboriginal women (44%), women with disabilities and LGBTQ women.

The August 25, 2016, Final report and recommendations of the Gender Wage Gap Steering Committee outlines 20 recommendations to reduce the wage gap, categorized into five key parts, broadly covering the balance between paid and unpaid responsibilities, better valuing women’s work, improving workplace practices, challenging the less tangible causes of the wage gap and additional ways for the government to close the gap.

Overall, the United Steelworkers (USW) contends this is an important first step and welcomes the strong emphasis on accessible child care. We are, however, concerned about the absence of recommendations regarding immediate action that could have substantial near-term impacts on closing the gap. USW is also concerned about the omission of numerous recommendations that had widespread support in the original submissions, in particular those that directly address women’s over-representation in low-wage, part-time and insecure work. The recommendations also require a clear action plan and timeframe for implementation.

There are several important recommendations in the Final Report that, if properly implemented, will serve to diminish the wage gap. In particular, USW applauds the strong focus on the need for accessible and subsidized child care, and the Steering Committee’s recognition of the consequences of the disproportionate share of care work taken on by women. The need for accessible and subsidized child care was the single most prevalent recommendation in the original submissions. This is the first recommendation to appear in the Final Report. It includes the acknowledgment of the lack of availability and affordability of child care and the impact that has on women’s paid employment.

USW, in its original submission, focused on the prevalence of women performing care work, in both paid and unpaid work. One of the causes of the wage gap is a combination of occupational segregation and the widespread undervaluing to the work that women are more likely to perform. This leads to many types of work being undervalued and underpaid, including child care and other types of care work. The proxy method of pay equity for broader public sector workers has not had the effect of improving wages in highly feminized sectors. We appreciate the recognition of this in Recommendation 7, which states the government should assess the proxy method and “examine ways achievement of pay equity with wage enhancement programs in the Broader Public Sector.” We are concerned, however, with the possible interpretation of this recommendation: wage enhancements (and access to collective bargaining) are essential for women in low-paid precarious work, but this should not replace any legal pay equity obligations, particularly for those who have not yet undergone the process. We also urge the government to make a strong and clear commitment to ensure adequate funding and employer compliance to fulfill proxy pay equity requirements.

USW praises the Steering Committee’s emphasis on the care gap, the need to better share care responsibilities between men and women and to provide better funding and social supports to ease the burden of certain domestic responsibilities, including child and elder care. We believe the recommendations must be complemented by the final recommendations in Changing Workplaces Review specifically, expansion of coverage under the ESA, extension of paid sick days, changes to the Ontario Labour Relations Act that would facilitate unionization and access to collective bargaining, among others [USW includes a full analysis of its recommendations on labour law reform as it relates to the wage gap in its original submission to the Steering Committee].

USW also supports the basic premise that increased pay transparency is essential [outlined in Recommendation 9, which may require pay transparency in the broader public sector and Ontario Public Service, but merely recommends that the private sector increase its pay transparency]. We believe this recommendation could be strengthened by tying it to the impact of collective bargaining and stronger requirements for the private sector. Not only does unionization and collective bargaining lead to pay transparency, but it also provides the concrete means to address pay inequality, though it must be emphasized that collective bargaining alone cannot replace any legal pay equity obligations or processes.

Many of the identified causes of the gender pay gap are difficult to articulate, as they involve stereotypes and long-held assumptions about women’s and men’s capabilities, as well as other forms of discrimination. USW is glad that the Steering Committee recognizes the importance of such contributing factors and the recommendations to use education and training to address commonly-held beliefs about women’s abilities and to target both men and women to enter “non-traditional” types of employment. As with many of the recommendations, we believe the action plan itself related to recommendations 15 and 16 should be more concrete, with specific targets trough the Ministry of Advanced Education and Skills Development and apprenticeship programs. To go beyond the emphasis on skills training and providing some type of (not clearly defined) supports to women working in traditionally male-dominated occupations, we believe there must be stronger commitments regarding hiring from equity-seeking groups.

The Steering Committee’s recommendations do not fully reflect those of the individual and written submissions on strategies to close the wage gap, summarized in the April Consultation Summary. While there are certainly some positive steps that will be taken based on the final recommendations, there are insufficient substantive changes that will increase the ability for working women to collectively fight for better pay and working conditions. USW believes the Steering Committee missed an opportunity to make explicit recommendations to improve access to unions, particularly for low-wage, racialized women working in precarious environment. The Final Report itself includes significant information on the clear link between unionization and the reduction of the gender wage gap, though saves any action on that front to “other government initiatives.” We are hopeful that unions and our allies can ensure that the changes necessary to truly close the gender wage gap will emerge through the Changing Workplaces Review process. Again, this includes expansion of coverage under the ESA, better protected leave provisions for workers, amendments to the Labour Relations Act to facilitate unionization and protection of successor rights, among other key recommendations. 

We are also concerned about the absence of some of the immediate remedies to close the gender wage gap. These include raising the minimum wage and mandating equal pay for equal work to help alleviate the lower pay for contract and temporary workers. Women – in particular racialized women – are over-represented in minimum/low wage and contract work.

Finally, the USW worries that the recommendations regarding the Pay Equity Act itself are insufficient to remedy the issues raised in various submissions. This includes a lack of proper funding to the pay equity commission and for proxy pay equity adjustments, lack of access to and knowledge of the complaint system, and accessible and mandatory job evaluation tools. USW believes the recommendations focus too heavily on supporting employers, while neglecting to focus on workers and unions as they relate to the Act; we also contend that processes around enforcement and ensuring employer compliance must be stronger.

Overall, USW believes the recommendations contained in the final report constitute a first step to close the gender wage gap. We will, along with our allies, continue to push for the implementation of these recommendations and to ensure that more concrete action plans emerge from this. Finally, USW will push for the inclusion of many of the omissions as it relates to unions’ importance in closing the gender wage gap in the Changing Workplaces Review final report and recommendations.

With continued action to improve the recommendations in the Final Report and to fill the gaps where we believe there were omissions, we can start to close the unacceptable gender wage gap caused by the following factors:

USW will also work to fulfil its own recommendations about the steps that unions can take internally to ensure that this issue becomes a central labour issue, including using a gender and equity lens in bargaining, supporting women’s involvement in job evaluation to ensure that women’s work ceases to be undervalued and a focus on eliminating discrimination through education.

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