Bill 32 Submission

Union Financial Disclosure and Dues Election Consultation

This submission is made in response to the request for consultation by the Alberta Ministry of Labour and Immigration, regarding Union dues collection and Union financial disclosure required under Bill 32.

This submission is made on behalf of the Membership of the International Association of Heat and Frost Insulators and Allied Workers, Local 110.

Organization and Background

The International Association of Heat and Frost Insulators and (Asbestos Workers) Allied Workers, Local 110 was chartered in the Province of Alberta May 01, 1950.

Local 110 currently represents Members working in the Mechanical Insulation Trade, Firestopping Industry, and Asbestos/Hazardous Removal in the Industrial, Commercial, and Residential sectors of our economy. In comparison to most labour organization in Alberta, Local 110 is considered to be relatively small. However, our organization is the largest Local throughout our International, with over 2000 Members represented.

Since the beginning our focus has been to better the working conditions and lifestyle of our Members, their Families, and Albertans in general. Working with these goals in mind Local 110 participates in collaborative collective bargaining with our Signatory Contractors. Local 110 provides a Health and Welfare Plan that covers over 3000 Canadians through Member participation. The Asbestos Worker Pension Plan has over 4000 Canadians currently receiving a pension or entitled to one in the future, allowing for the ability to retire with dignity. Local 110 has partnered with Synergy Respiratory Care, to not only provide care to our Members and Families, but to participate in long term studies regarding respiratory health. Additionally, Local 110 participates through our International with the Insulators Tissue Bank at Mt. Sinai Medical Center, that provides tissue to researchers around the world trying to find a cure for mesothelioma and lung cancers. These are just some of the benefits provided to our Members and the community, that are fully or partially funded through Union dues.

Local 110 is a fully democratic organization. Local 110 conducts secret ballot elections for all Union Management position, this includes President, Vice President, Business Manager, three Business Agents, five Executive Board Members, three Financial Trustees, two Sergeant at Arms, and one Recording Secretary. Although those elected are the management of the Union, all major decisions regarding the Union including the finances of the Union are voted on by the Membership at Monthly General Membership Meetings. This provides for a true majority rule governance of the Union.


Even with the unprecedented economic times, with COVID-19 and the Alberta economy in a sharp downturn Local 110 has dispatched a total of 1209 people to work with Signatory Contractors. This is less than one third of our normal yearly average. However, this is still a significant number of people that these Contractors were able to save the costs of recruiting, training, and mobilizing. The orderly dispatch process, with all its contributing parts, is a cornerstone of Local 110, and a core function of our Union for our Members and Signatory Contractors.

Union Financial Disclosure

  1. Local 110 is required by the International Constitution and Bylaws to provide financial disclosure to both our Membership and the International.

This is completed in a number of ways:

  • All expenditures are approved through previous motions voted on by the Membership.
  • Monthly financial reports are provided to the Membership at the General Membership Meetings. These reports are read out and presented on screen for review, with time for questions.
  • Quarterly the three Elected Financial Trustees meet to review all expenditures and ensure they are all appropriate, having proper motions documented for the expense, and proper documentation of the expense. After the review a report is provided by the Financial Trustees at the next General Membership Meeting.
  • Yearly an independent financial audit is conducted of the Local. These audits are presented in full at the next General Membership Meeting as well a copy is provided to the International office.
  • The International office also requires that International Vice Presidents enter the Local to review the financials throughout the year. Additionally, random audits are conducted by independent auditors supplied by the International.
  • All Members of Local 110 have the right to review the financials of the Local at anytime. The only stipulations are they must first set up an appointment and no copies are to be removed from the office.

With all these points of financial disclosure open to our Membership, Local 110 does not feel that government mandated disclosure is necessary or appropriate. However, if mandated additional disclosure should be tied to the yearly independent financial audit. In this way it will provide all relevant information without unmanageable extra cost to the Membership or skewed by Union Management.

  1. Unions should have the discretion to decide the best method of communication for financial disclosure to their Membership. However, in the case of Local 110 the current method of monthly reports at the General Membership Meetings and the ability for Members to review all financials at the Local Union office should satisfy the requirement.
  1. Any rules regarding the production of Local 110 financial statements must provide for confidentiality. This information has the ability to be used in negative ways against our organization, by a number of groups that would not be subject to the same requirements under legislation.

Union Dues Election/Revocation

Providing each Member, the option to opt “in” or “out” of specific portions of Union dues will be a costly and onerous task for both Contractors and the Union.

Due to the nature of our trade the, majority of Local 110 Members work short term projects, usually less than three months. These Members hire on for the project and when completed are laid off to seek employment with another Contractor. It is common for Members to have four or five employers in one year, and at the same time Contractors consistently increasing and reducing manpower can lead to hundreds if not thousands of employees in a year. The process required by a Contractor to ensure compliance with the legislation, would result in extensive administrative work causing onboarding delays that could result in project delays. These delays are unacceptable for Clients in shutdown, turnaround, or emergency situation.

  1. Any processes for opting in and opting out need to be simple as possible – both so that they are easily understood by members and easier to implement by unions and employers.
  2. Any reporting regarding any changes in the proportion of non-core expenses should be no more frequent than a union’s financial statements – so, at most frequent, annually
  3. The regulation should give discretion to unions to determine when and how a member can make or change an election.
  4. Local 110 cannot see anyway a “line-by-line” election on individual expenses would be feasible or cost effective.

The focus of Union dues is broken into two categories. The first is “core” this is dues that are utilized for the core functions of a Union and are not able to be opted out of, the second is “non-core” and is somewhat defined as political activities and causes. This “non-core” portion may become subject to individual Members opt “in” or “out” choice.

Political Activities

Local 110 is a nonpartisan organization. Our Membership is made up of all sectors of the population, with every possible political viewpoint. Local 110 believes in a collaborative approach to politics, focused on working with all parties to achieve the goals of Local 110. To this end Local 110 has not made any donations to any political parties since 2015.

All political activities of Local 110 are clearly defined and focused on issues that directly affect our Membership, due to their chosen profession. Lobbying, political engagement, responding to government requests for information to be used in the development of government legislation and policy, and informing the public on issues, are all core activities of a Union and would be impossible to separate from day to day operations.


The term causes leaves much to interpretation. Local 110 has always been active with charities throughout Alberta. Giving to such organizations as Alberta Cancer Foundation, Alberta Lung Association, Alberta Diabetes Foundation, and the Hope Mission to name a few. Even in the lowest points of employment during the 1980s Local 110 provided funds to organizations such as the Food Bank and others that were helping thousands of Albertans including some of our Members. Above these donations, when a Member passes their family has the option of in lieu of flowers a donation will be made to the charity of their choice.


Additionally, causes could extend into funds that are required to be remitted to by the International. Such as the Disaster Relief Fund that helped Members during the Fort McMurray Fires and Calgary Floods, or the funding for the Insulator tissue bank listed earlier. These “causes” are requirements of Membership with the International and if allowed to be part of an opt in or opt out process will still be required to be paid on all Members to the International office. As such mandatory “causes” that are required by a Unions parent organization must be part of the required dues structure.


Local 110 makes this submission while reserving its right to challenge the constitutionality of both the changes to the Labour Relations Code giving rise to the regulations and the regulations themselves. The proposed amendments of the Labour Relations Code and the regulations encroach on the Union and our Members Freedom of Association and Freedom of Expression to collectively fulfill our goals. The amendments seek to hold Unions to requirements which no other organization in Canada is required to abide, for no reason other than being a Union.

In close, Local 110 is an affiliate of the Building Trades of Alberta, as required by our International Constitution and Bylaws, as such we support the submission provided by Executive Director Terry Parker.