Committee Required to Evaluate the Skilled Trades and Apprenticeship Act (STAE) and the Designated Trades and Restricted Activities Regulation (DTRA), Particularly as it Relates to “Glazier’
On 2023-03-23, the PGAA met with representatives of the Alberta Government- Alberta Advanced Education-Skilled Trades & Professions. The meeting was called in response to a number of preliminary inquiries the PGAA had on the STAE and particularly on the Glazier section of the DTRA. There are no longer compulsory trades and all trades are now
The meeting was productive, and our input was appreciated. Behind the roofers association, we were the second industry group to approach them for clarity on the new documents and to begin to point out areas where clarity or amendments are required, in our opinion. There are two purposes to the two documents. First they are to lay out the requirements of the trade so that the apprenticeship program training requirements are understood. Secondly, the DTRA replaces the old system of compulsory and optional certification trade definitions. It outlines tasks that are to be performed by set classes of individuals, as set out in Schedule 2 of the DTRA. These include:
Classes of individuals
54 Only the following classes of individuals may perform a restricted activity within the designated trade of glazier:
(a) any individual who holds a trade certificate in the designated trade;
(b) any individual who holds an endorsement in the designated trade;
(c) any individual who does not hold a trade certificate in the designated trade but who, in the opinion of the individual’s employer, possesses the skills and knowledge in performing the restricted activity expected of an individual who holds a trade certificate in the designated trade;
(d) any apprentice with an apprenticeship education agreement approved by the Registrar under the Apprenticeship Education and Industry Training Programs Regulation in the designated trade;
(e) any individual who has filed an application for issuance of an Alberta Journeyperson Certificate in the designated trade if the application is subsisting and, during the time that the application is subsisting, the work of the individual in the designated trade is carried out under the supervision of an individual who holds a trade certificate or an endorsement in the designated trade;
(f) any individual who has filed an application for approval by the Registrar under the Apprenticeship Education and Industry Training Programs Regulation of an apprenticeship education agreement in the designated trade if the application is subsisting and, during the time that the application is subsisting, the work of the individual in the designated trade is carried out under the same conditions as those that apply to an apprentice with an apprenticeship education agreement approved by the Registrar under the Apprenticeship Education and Industry Training Programs Regulation in the designated trade;
(g) any individual who is registered in a student work training program in the designated trade;
(h) any individual who is registered in an education or training program that is recognized by the Administrator under section 12(d)(iii) of this Regulation as a program that, on successful completion, will result in a document recognized by order of the Board under section 14(2)(c) of the Act as being the equivalent of an Alberta Journeyperson Certificate in the designated trade if, during the time that the individual is registered in the program, the work of the individual in the designated trade is carried out under a mentor and the same supervision and ratio requirements as those that apply to an apprentice with an apprenticeship education agreement approved by the Registrar under the Apprenticeship Education and Industry Training Programs Regulation in the designated trade;
(i) any individual who is performing the restricted activity in accordance with an authorization granted by the Administrator under section 13 of this Regulation;
(j) any individual who is performing the restricted activity in accordance with section 14(2) or (3) of this Regulation;
(k) any individual who is performing the restricted activity in respect of any property that the individual
(i) owns,
(ii) has possession of or control over, and
(iii) intends only for personal and not-for-profit use by the individual;
(l) any individual who is performing the restricted activity in respect of a farming and ranching operation, as described in section 1.1(1) and (2) of the Occupational Health and Safety Code (AR 191/2021), if the individual
(i) is not paid wages, as defined in the Employment Standards Code, for the performance of farming or ranching work, or
(ii) is paid wages, as defined in the Employment Standards Code, for the performance of farming or ranching work and, in respect of the farming and ranching operation, is a person referred to in section 1(cc)(i)(B)(I), (II), (III) or (IV) of the Occupational Health and Safety Act;
(m) any individual who is performing a restricted activity within the designated trade that is the same as a restricted activity within another designated trade or branch of a designated trade and for which the same training is provided in both the designated trade and the other designated trade or branch of a designated trade if
(i) the individual holds a trade certificate or, if applicable, an endorsement in the other designated trade or branch of a designated trade, or
(ii) the individual
(A) is an apprentice with an apprenticeship education agreement approved by the Registrar under the Apprenticeship Education and Industry Training Programs Regulation in the other designated trade or branch of a designated trade, and
(B) has completed the training in respect of the restricted activity.
While this does occur to a great degree in our industry, there is no recognition of the use of labourers, the credentials for residentials framers installing window products, demountable companies supplying and installing their products, companies supplying and installing mirrors and shower enclosures, metals companies installing balustrades, etc. There is also no recognition of work occurring above two stories, or above ten stories, which get more complicated and increase the level of danger to the public and property.
While our initial queries and input were appreciated, the representatives of the Alberta Government- Alberta Advanced Education-Skilled Trades & Professions suggested that as the association representing the glazing industry that we form a committee, conduct a survey (of both our membership and non-members), and build a case for the changes that we would like to see.
Looking at the activities identified in the DTRA as ‘restricted,’ these include:
Restricted activities
53(1) In this section,
(a) “glass” means any type of commercial, residential, decorative or auto glass or related material and includes
- curtain walls,
(ii) skylites and sloped glazing,
(iii) frames and doors,
(iv) automatic doors,
(v) manual doors, and
(vi) mirrors;
(b) “undertakings of the designated trade” means the following:
(i) the glazing, setting, attachment, installation and removal of all types of glass on buildings, fixtures and other uses;
(ii) the installation, fitting, fabrication and attachment of architectural metals or related products for all types of buildings;
(iii) the cutting, preparation, fabrication or any other handling of glass for buildings, fixtures and other uses.
(2) The following activities, when performed within undertakings of the designated trade, are restricted activities within the designated trade of glazier:
(a) diagnosing problems and making repairs related to glazing;
(b) carrying out damaged lite removal procedures and installing and sealing new components;
(c) storing and handling glass;
(d) preparing and fabricating glass to specifications;
(e) selecting, cutting and fitting glass;
(f) cutting, etching and installing mirrors;
(g) installing glass into window frames;
(h) installing and renovating residential windows, tub enclosures, shower doors and related products;
(i) interpreting drawings and specifications;
(j) preparing, fabricating, installing and maintaining aluminum and glass doors, windows, storefronts, screens and associated hardware;
(k) fabricating and installing curtain walls;
(l) fabricating and installing skylites, sloped glazing, barrel vaults, solariums and other support structures;
(m) preparing and installing building envelope materials and sealants;
(n) installing structural glass, balustrades, handrails and smoke baffles;
(o) installing and maintaining automatic and revolving doors;
(p) operating hand and power operated equipment that is used in the designated trade.
Much of this is written to highlight the training that glaziers receive in the apprenticeship program and is very applicable. Apprentices should understand how residential products work, a bit about auto glass, which primarily resides with Auto Body Technicians today, as well as aspects like handling and storing glass.
However, it asks more questions than it answers, such as:
Do all automatic operator and automatic slider companies adhere to the one journey person to two apprentices ratio? Do they exclusively utilize journey people and apprentices?
Do all mirror and shower door companies adhere to the one journey person to two apprentices ratio? Do they exclusively utilize journey people and apprentices?
Do all guardrail companies/specialty metal fabricators adhere to the one journey person to two apprentices ratio? Do they exclusively utilize journey people and apprentices?
Do all demountable companies adhere to the one journey person to two apprentices ratio? Do they exclusively utilize journey people and apprentices?
Do all residential building and renovation companies, involved with windows, shower doors, tub enclosures, balustrades/guardrails, mirrors, skylights, and sunrooms adhere to the one journey person to two apprentices ratio? Do they exclusively utilize journey people and apprentices?
How does the storage and handling of glass pertain to fabricators for their in plant and delivery staffs? Likewise for demountable manufacturers and their field staff?
How does preparing and fabricating glass effect glass fabricators and aluminum fabrication shops? How about suppliers of automatic operators, mirror and shower door companies, guardrail companies, etc? Do written policies and procedures supersede these requirements?
Do those interpreting drawings and specifications in offices, like estimators, drafters, and other non-glazier staff, break the rules?
As there is no criteria for the employer to assess an individuals skills and deem them to perform restricted activities, is part two of the record book the criteria that should be applied? Are these people allowed to act as a journey person, or just an apprentice?
Are labourers acceptable in place of a registered apprentice? If so, what criteria do they need to meet?
Should there not be greater requirements for those working above two stories? Ten stories? Certainly the danger to themselves, the public, and property increases with height. How do we categorize this and apply for changes to the restrictions?
This comes down to whether, as an association and as an industry, we are concerned about jobs being done cheaply or done correctly. In the best interest of owners, contractors, workers, and the public at large, it would seem that having the job done right, the first time, with an eye towards maximizing the lifecycle of the building would be the correct desired result.
The PGAA needs volunteers to take this initiative to fruition. If you are concerned about your industry, about the quality and reputation we have as a trade, and want to see the restrictions and activities right-sized and enforced, please email your desire to participate to president@pgaa.ca? Likewise, if you would just like to share your opinion, please follow the same process?
Thanks in advance for your attention and your thoughts and ideas.