Bill C-21, RPAL training, and Cash in Transit labour supply

Questions

  • Will C-21 (An Act to amend certain Acts and to make certain consequential amendments (firearms)), make it harder to recruit qualified Cash in Transit (CIT) operators for Brinks?
  • Should CIT employers be assigned special status by the RCMP to provide RPAL (Registered Possession and Acquisition License) safety instruction and certification?

Background

Federal Bill C-21: An Act to amend certain Acts and to make certain consequential amendments (firearms)

Bill C-21 proposes a number of amendments to the Criminal Code, the Firearms Act, and other federal legislation that seek to fulfill the Government of Canada’s commitments in relation to gun control and to protect Canadians from firearms-related harm.

– Justice.gc.ca

The purpose is to increase regulations on hand gun ownership, prohibit the sale of certain weapons to the public, ban the altering of magazine capacity, and provide more power to police for data on ownership and enforcement at certain times.

Additional information

  • Restricted firearm training is provided under federal law (the Firearms Act and the Criminal Code) and administered by the RCMP's Canadian Firearms Program.
  • Provinces have responsibility for some aspects of data collection and coordinate regulated firearms training through the provincial Chief Firearms Officer, but it remains a federal program.
  • Provinces share in the administration of trainings and data collection of Canadian Firearms Program, for example BC supports Yukon training and safety certification.
  • A cursory look at trainings being offered indicates all province offer certification in RPAL multiple times a month. All trainings were reported as "full" for the rest of the year indicating high demand for RPAL safety certification.
  • A significant number of workers in the CIT industry received restricted firearms certification well before gaining employment.
  • Government-regulated work safety certification is usually separate from training provided by the employer.

The ask from CIT employers

The Cash in Transit (CIT) employers are concerned that increased regulation and the limiting supply of restricted guns will decrease the training available to the public on restricted firearms. The Cash in Transit employers state that this will in-turn reduce the labour supply to the private security industry of workers trained in the minimum application requirements.

The employers aim is to amend C-21 and/or its regulations so that the employer's trainers can be directly qualified by the RCMP to provide restricted firearm training. Essentially, allowing the employers' trainers to be RPAL certified across the country.

Recommendation

We propose that the federal government consider a regulatory change that would allow the Commissioner of the RCMP to certify CIT company trainers to provide the Restricted training course to Canadians wishing to be employed in the CIT workforce. This would create one national standard, governance, and compliance with the RCMP vs. each Provincial CFO. CIT companies want consistency in doctrine and compliance as it creates a safer ecosystem. We would continue to pay the current fees to the provincial agencies that have been delegated to provide RPAL certification by the provincial Chief Firearms Officer.

– Letter from CIT employers to the government

Analysis

There is no specific indication that changes outlined in C-21 will reduce accessibility to RPAL training used by those who need this certification to access work.

The expected goal of Bill C-21 is reduce the number of prohibited firearms owned by the public.

Restricted and prohibited weapons will still be available to certain class of worker and firearm related sports in Canada. All workers and individuals employed with a need to carry a firearm will need restricted firearm training to apply for licences to carry handguns.

The employers have suggested that because of the increased regulation of restricted weapon sales in Canada there will be a reduction in the frequency of RPAL training and fewer instructors available to provide training. There is currently no indication that access to training will be limited and it is equally likely that an increase in a regulatory environment will increase the demand for regulated firearms training.

Since many recruits for CIT are interested in firearms training before they apply to CIT, it is unlikely a just in time training safety certification provided by the employer to fill vacancies is the solution to the suggested labour tightness in the industry.

Many industries are dealing with the current tightness in the labour market and it is likely that issues faced by the industry are caused by much broader economic issues including pay rates, uncertainties about future employment in the industry, and lack of clear and competitive recruitment programs.

Supply of trained individuals for the Cash in Transit and many other occupations in need of restricted firearms training is a complex problem. As with all government regulated training that involves different classification of worker, a comprehensive training regime is required to ensure standardized access to certifications.

There is no evidence that this potential problem is immediate, specific to the CIT industry if it becomes a problem, or catastrophic to the established CIT employers. As such, a labour market wide solution for employment that requires firearms is likely the best way to deal with Restricted PAL certification.

Potential Issues Arising

  • A conflict of interest in training may arise where wants for new recruits by CIT companies conflicts with the regulated safety instruction provided.
  • Some provinces may not be supportive of having federally deemed instructors at CIT companies operating side-by-side provincially coordinated trainings as it has the potential to create two tiers of training.
  • Offering training through CIT instructors may create a divergence between training offered at the provincial level for restricted firearm training.
  • The RCMP would have to build a regulatory enforcement environment currently managed by the provinces. Or, provinces would have to regulate CIT company training separately to public-focused instructor-driven training.
  • Many industries in addition to CIT need restricted firearm training for their workers to qualify. An industry-specific solution will not solve any issues in the supply of qualified labour across such a broad need for certification.
  • Bill C-21 is a complex piece of legislation that has taken years to be brokered. It is unlikely last-minute amendments will be constructive to the adoption of this legislation.

Recommendations

  1. A review of training and certification processes should be carried-out by the RCMP. Restricted firearms training will continue to be essential in a post Bill C-21 era.
  2. The RCMP should work with the provinces through the Canadian Firearms Program to monitor instruction and training of instructors in restricted firearms to ensure access to training.
  3. A standardized training and safety certification for restricted/prohibited firearms may be necessary for workers in industries who carry firearms as part of their work.
  4. Data should be collected across the security industries where workers are require to carry firearms to track where workers gained certification training.
  5. Unifor should work with industry employers to support a broad campaign to recruit workers into the unionized industry that identifies clear training and certification requirements, including how to obtain those certifications.