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December 11, 2023

Minister Arlene Dunn

Chestnut Complex
P. O. Box 6000
Fredericton, NB

E3B 5H1

Via email:

Dear Minister Dunn:

RE: Bill 27 re: Amending the Employment Standards Act

On behalf of The Coalition of New Brunswick Employers and our member associations from across New Brunswick, we are once again writing to voice concern as the proposed 10 paid sick day amendments, up from 5 unpaid sick days currently, will have significant negative consequences on employers in New Brunswick and on the provincial economy as a whole.

The Coalition of New Brunswick Employers is a provincial advocacy coalition that represents various business, trade and industry associations in New Brunswick that overall represent nearly 300,000 hard working employees in the province.

As we have stated prior … as New Brunswick moves on from the COVID-19 pandemic, our provincial economy is looking to take advantage of a growing global economy and trade. However, unlike other provinces in Canada, we are facing persistent and unique obstacles. Our provincial growth is limited by ongoing supply chain disruptions plus labour and skills shortages. Coupled with these challenges is rising inflation, threats of economic recession, and global instability. While many of these global challenges affect all Canadian provinces, New Brunswick has unique problems that must be addressed. Employers in New Brunswick are facing a difficult cost environment for the foreseeable future. Inflationary pressure, significant minimum wage increases, CPI increases, EI expansion, plus increasing carbon taxes plus property taxes add to a costly and uncompetitive business landscape.

Given all of the stress that New Brunswick employers currently encounter, Bill 27 to amend the Employment Standards Act does not take into account the high cost of doing business in New Brunswick. Employers clearly need to keep costs low to remain competitive and as such believe that the market should decide the outcome of sick day requirements. Furthermore, to put this additional cost on employers now would threaten the economic growth that the province has seen recently.

As you are aware, only three other Canadian provinces have legislated paid sick leave – British Columbia with five days, Quebec with two and Prince Edward Island with one day, increasing to three over the next 3+ years. Our province needs to maintain competitiveness with other jurisdictions including provinces, not only for our current employers but also for the government’s own planned investment attraction. The days of New Brunswick’s having a low-cost jurisdiction overall is in the past … the increased cost associated with paid sick days would add to increased competitive pressure.

We ask that the government not pass Bill 27.

The potential impact on employers throughout New Brunswick is too great to implement this drastic change.  As you are so very aware, it is the private sector that is responsible for economic growth in the province and this amendment will set our province back, clearly in the opposite direction of creating jobs and increasing the wealth of the province.

The Coalition of New Brunswick Employers would be happy to discuss this further with you, either as a group or with specific members, as we bring a unique perspective on this subject.


Ron Marcolin


Coalition of New Brunswick Employers

cc: Hon. Blaine Higgs, Premier, Province of New Brunswick

cc: Hon. Ernie Steeves, Minister of Finance, Province of New Brunswick

cc: Hon. Ted Flemming, Chair, NB Legislative Amendment Committee

cc: Susan Holt, Leader, Liberal Party of New Brunswick

cc: David Coon, Leader, Green Party of New Brunswick

Coalition of New Brunswick Employers Coalition des Employeurs du Nouveau-Brunswick 506-651-2251 /  
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