Mandating Transparency in Garbage Worker Records

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The Regulation of the Comité paritaire des boueurs de la région de Montréal (Joint Committee of Garbage Collectors in the Montreal Region) establishes new mandatory administrative requirements for professional employers in the Montréal region’s solid waste removal sector. The regulation is issued under the authority of section 22 of the Act respecting collective agreement decrees and enforces provisions regarding the keeping of employee records, submission of monthly reports, and the collection of levies to support the Comité paritaire’s operations. This initiative ensures proper monitoring and accountability within the industry, with the ultimate goal of upholding workers’ rights, wage compliance, and transparency.

According to the regulation, professional employers must maintain a detailed register for each employee under their supervision. This register must include personal identification information such as the employee’s name, address, date of birth, social insurance number, and classification, as well as employment-related data for each pay period. Specific entries include the hours worked daily (noting start, pause, and end times), the type of work performed, regular and overtime hours, days worked per week, wage rate, gross and net pay, and any deductions, including insurance premiums. The register must also document vacation and statutory holiday entitlements, payment dates and methods, and contain a list of work locations. Records must be retained for three years and kept at the employer’s primary place of business. Timekeeping must be done through a punch-clock or approved time-sheet signed daily by employees, and a signed employment card must be created within seven days of hiring.

Additionally, the regulation mandates that employers submit a monthly report to the Parity Committee using a standardized form. The report must contain detailed employment data for each employee, including hours worked, earnings, allowances for holidays and vacation, and premiums related to group insurance plans. Reports must be submitted by the 10th of the following month, even in months where no work occurred. Reports can be sent via mail or electronically, provided the technology used is approved by the Parity Committee for compatibility.

The regulation also introduces a financial levy to fund the Parity Committee’s operations. This levy is set at 0.5% of gross wages from both the employer and the employee. Artisans not employed by a professional employer must pay a fixed fee of $25 per month. Employers are responsible for collecting the employee portion through payroll deduction and submitting both their own and the employees’ levies to the Parity Committee along with the monthly report.

This new regulation replaces three older regulations dating from the 1980s and 2015, which previously governed registration systems, monthly reporting, and levy contributions in the same sector. By consolidating and updating these requirements into a single, comprehensive regulation, the Comité paritaire aims to streamline oversight, improve compliance, and modernize administrative processes.

Quebec (576/2025) May 7, 2025
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