Four National Women's Groups: CCLOW · CFWEC · CRIAW · NOIVMWC

The proposed two-tier system of premiums and benefits is seriously flawed.

• To start with, there is no clear way to distinguish between legitimate layoffs and "abusers".

• Secondly, this proposal penalizes workers who work part-time, or on contract or move from one temporary job to another, or other types of "non-standard" work, which is a growing sector of the labour force. In particular, this proposal penalizes women, who make up the largest number of "non-standard" workers, including 80% of all part-time workers who are 25 years and over. The rise of piecework and "home" work, particularly among industries employing a large proportion of immigrant women, means that these women will suffer the brunt of this UI penalty, along with the low wages and poor working conditions that frequently are part of "home" work.

  The government's technical background paper on UI points out that women are currently less likely to be frequent users, but this is because most women in non-standard work are not even eligible for UI. Even if the system changes to provide coverage for these workers (which it must), they will be hit by the "two-tier" system.

  The nature of work is changing - as a nation, we are moving away from secure and stable jobs to a greater mix of types of employment, often short-term and highly changeable. Non-standard work will only increase in the future, especially with the changes brought on by the pressures of globalization. Although the Green Paper recognizes the needs of these workers, it makes no proposals to meet these needs. The Unemployment Insurance fund must expand to meet the needs of Canadian workers in this area.

• The Green Paper proposes penalizing employers whose workers frequently draw on UI. The proposal discourages employers from hiring people who are vulnerable to frequent layoffs (this includes women, and especially women with disabilities, immigrant women, visible minority women, and aboriginal women) because of the fear that if they must be laid off in the future, the employer will be penalized. This danger is especially present in "high-risk" enterprises, such as high-tech or new businesses - which are precisely the sectors where jobs are being created.

• Similarly, workers in this position (having been laid off twice in the recent past) would have an incentive to turn down short-term jobs or jobs that are in risky business sectors, in case they are laid off again and suffer the UI penalty.

  In effect, the two-tier system would discourage employers from hiring precisely those people most in need of employment, and would penalize vulnerable workers, especially women, for accepting the only work available.

  The Green Paper also proposes extending the time required to qualify for UI. This fails to recognize the seasonal nature of many jobs. For example, rural farm workers would generally be excluded from UI by a longer qualifying period. This puts these workers in a more vulnerable position, and also means farmers will lose good workers, who will be forced to look elsewhere for employment that does provide UI coverage.