FWC Bulletin

10 March 2022 Volume 9/22 with selected Decision Summaries for the week ending Friday, 4 March 2022.

Other Fair Work Commission decisions of note

Decisions of the Fair Work Commission

The summaries of decisions contained in this Bulletin are not a substitute for the published reasons for the Commission's decisions nor are they to be used in any later consideration of the Commission's reasons.

Summaries of selected decisions signed and filed during the week ending Friday, 4 March 2022.

1

CASE PROCEDURES – costs – no reasonable prospects of success – ss.394, 404, 587 Fair Work Act 2009 – a Servicing Theatre Supply Officer (employee) was dismissed by his employer (a hospital), on 30 October 2021 after he failed to get the COVID-19 vaccine or provide an exemption – employee made unfair dismissal application to the Commission – hospital made interlocutory application for the unfair dismissal application to be dismissed under s.587 of the FW Act because it had no reasonable prospects of success – in the alternative the hospital applied for an order under s.404 of the FW Act and r.55 of the Fair Work Commission Rules 2013 that the employee lodge security of $40,000 for the payment of costs because employee's claims had no or low prospects of success and hospital will incur future costs defending its position – Commission made provisional assessment that employee's case not strong, however the hospital's submissions did not meet the high jurisdictional threshold required for a case to be struck out under s.587(1)(c) – Commission's reasons included that there appear to be factual matters in dispute that may bear on substantive or procedural fairness; while it appears the hospital's argument that a valid reason for dismissal existed has force, claims regarding the availability of alternative duties have not been tested; and consideration needs to be given to whether employee's dismissal satisfied procedural fairness requirements – Commission considered Hansen v Calvary Health Care Adelaide Limited, Merribee Pastoral v ANZ Banking Group, Zornada v St John Ambulance Australia (Western Australia) Inc – Commission not satisfied that the justice of the matter required an order for the security of costs – Commission dismissed hospital's applications to dismiss the unfair dismissal claim and for a security for costs order – Commission will list unfair dismissal application for directions.

Sharif v Calvary Health Care Adelaide Ltd

U2021/10666

[2022] FWC 445

Anderson DP

Adelaide

4 March 2022

2

TERMINATION OF EMPLOYMENT – incapacity – inherent requirements – mandatory vaccination – ss.387, 394 Fair Work Act 2009 – applicant employed as Family and Carer Program Worker – prior to pandemic, applicant would call clients or meet in office or at outreach appointments – after onset of pandemic, a series of State Health directions operating from 1 October 2021 required respondent to ensure unvaccinated workers did not attend respondent's facility and worked from home unless they had an exemption due to a medical contraindication – respondent informed applicant of vaccination requirement – in reply, applicant said she was unvaccinated but did not need to attend the facility as she could successfully perform role from home – at 18 October 2021 meeting, applicant indicated she had appointment with GP but when advised by respondent that date fell outside the government-mandated timeframe for vaccination, applicant did not bring forward appointment – respondent claimed that in same meeting the applicant also stated the GP appointment was only to discuss vaccination options because applicant was uncertain for personal reasons whether to get vaccinated – further meeting on 26 October 2021 to discuss vaccine status – in meeting on 28 October 2021, respondent informed applicant that her decision not to be vaccinated in the required timeframe meant she unable to meet the inherent requirements of her role and her employment was terminated – Commission agreed that prior to pandemic, significant proportion of the applicant's time was spent in face-to-face meetings – accepted that the requirement for face-to-face service delivery remained a feature of the applicant's role during the pandemic – held respondent was entitled to require applicant to carry out the full requirements of her role which included attending respondent's facility – Commission accepted that applicant had no definite plan to be vaccinated – as result, there was no certainty as to when applicant would be capable of fulfilling inherent requirements of her role – concluded it would be unreasonable for respondent to waive for an indefinite period the requirement that applicant be able to carry out full range of her duties – found valid reason for dismissal – found opportunities provided to applicant to respond to reason for dismissal and at each opportunity applicant confirmed that she was undecided and would not be getting vaccinated within the required timeframe – found dismissal was not harsh, unjust or unreasonable – application dismissed.

O'Toole v Australian Community Support Organisation Ltd

U2021/10018

[2022] FWC 477

Masson DP

Melbourne

3 March 2022

3

TERMINATION OF EMPLOYMENT – remedy – reinstatement – s.394 Fair Work Act 2009 – applicants employed as Shift Managers at respondent's Fremantle Terminal – applicants directed to perform stevedoring work during a period where the respondent's stevedoring employees were undertaking protected industrial action – applicants stood down for their refusal to perform stevedoring work and subsequently dismissed – applicants contended the work was not contemplated by their contracts of employment, not included in position descriptions, and not work they had undertaken in the past in Shift Manager capacity – applicants further submitted that if the direction to work was lawful and reasonable, refusal to work was reasonable because to accede would undermine working relationships with stevedores following conclusion of industrial action and because they were not qualified to perform stevedoring work – applicants submitted that they were at all times ready and willing to perform the duties of Shift Managers – respondent submitted that the work applicants were directed to perform was incidental and alternative duties within the scope of their roles as managers – respondent submitted work was reasonable, necessary, and safe – Commission considered Mt Arthur – Commission considered position description required Shift Managers to supervise, manage, coordinate, and audit and did not include any incidental hands-on or manual labour – Commission considered stevedoring work not incidental to the role of Shift Manager – Commission found direction to perform stevedoring work not lawful or reasonable – found no valid reason for dismissal – found dismissal harsh, unfair, and unreasonable – Commission considered respondent's communication to applicants about work to be performed confusing and secretive and that respondent did not adequately address applicants' concerns about personal safety in context of strikebreaking – if direction reasonable, Commission found that dismissal would be harsh and unreasonable due to communication and safety issues – applicants sought reinstatement – respondent submitted applicants had failed to follow lawful and reasonable directions, could not be trusted not to abandon employment, and their loyalty appeared to be aligned with the MUA rather than the respondent – Commission considered all applicants were willing to perform Shift Manager duties at all relevant times – none of the applicants were dismissed for poor performance – Commission considered Perkins and Nguyen – found requisite trust and confidence could be restored – ordered applicants be reinstated with continuity of employment and back pay less any money earnt by each applicant in the intervening period.

Burkhardt and Ors v Qube Ports P/L

U2021/9115 and Ors

[2022] FWC 281

Riordan C

Sydney

28 February 2022

4

TERMINATION OF EMPLOYMENT – incapacity – inherent requirements – mandatory vaccination – s.394 Fair Work Act 2009 – application to deal with unfair dismissal – Victorian Chief Health Officer (VCHO) issued directions mandating COVID-19 vaccination for persons performing onsite mining work – applicant worked onsite at Yallourn Mine – respondent wrote to applicant on 4 October advising he could not work onsite unless vaccinated – applicant was unvaccinated – applicant's employment suspended without pay – applicant put on notice that employment may be terminated if he remained unvaccinated – respondent provided show cause letter to applicant on 10 October regarding his decision not to be vaccinated – show cause letter reiterated content of 4 October letter – applicant needed to: confirm by 15 October that he was partially or fully vaccinated, or make an appointment before 22 October for a vaccination, or provide a medical exemption – applicant responded on 14 October that he had booked a vaccination for 22 October – respondent confirmed that if applicant received the vaccination on 22 October he would be permitted to return to work – on 23 October applicant advised respondent he did not attend the vaccination appointment – respondent notified applicant on 25 October that his employment had been terminated with effect from 26 October – respondent submitted applicant was dismissed because he was unable to meet the inherent requirements of his role – not possible for applicant to perform role offsite – applicant submitted he should have been allowed time to research the benefits and risks of vaccination and to become comfortable with the idea of being vaccinated – Commission not persuaded by applicant's submission – Commission found applicant unable at the time of his dismissal to perform the inherent requirements of his role – found there was a valid reason for the dismissal related to applicant's capacity – no procedural defects in the dismissal process – dismissal not unfair – application dismissed.

Hillenaar v RTL Mining and Earthworks P/L

U2021/10067

[2022] FWC 484

Wilson C

Melbourne

4 March 2022

5

GENERAL PROTECTIONS – dismissal dispute – repudiation – mandatory vaccination – s.365 Fair Work Act 2009 – application to deal with contraventions involving dismissal – applicant employed as a Real Estate Sales Agent – between 11 and 14 October 2021 applicant and respondent engaged in discussions about COVID-19 health directives and performance of applicant's duties, including attending open homes and face-to-face-appraisals – on 19 October 2021, Victorian Government issued health directions that restricted the performance of work outside a person's home if the person was a real estate worker, unless the person was an 'excepted person' or had received their first vaccine dose by 22 October and their second by 26 November 2021 – on 22 October 2021 applicant contracted COVID-19 and was required to isolate – applicant subsequently informed respondent she had a vaccination exemption because her doctor had advised it was dangerous to receive the vaccine so soon after she had contracted COVID-19 – on 8 November respondent requested evidence of exemption and applicant refused to provide it – on 9 November 2021 respondent notified applicant of the termination of her employment, effective 16 November 2021, due to her 'inability to perform the inherent requirements of the role to work in Company premises in compliance with the Victorian Public Health Order' and because 'there is no other position the Company can offer you in the business or ability to provide you with useful work to perform from home' – respondent raised a jurisdictional objection that applicant not dismissed but rather repudiated her contract of employment by failing to get vaccinated and/or failing to provide proof of being exempt from vaccination requirement – respondent submitted that it accepted repudiation on 9 November 2021 – Commission considered Earney v Australian Property Investment Strategic P/L – Commission found communications between applicant and respondent on 8 and 9 November 2021 consistent with applicant being dismissed as a result of her not being able to meet the inherent requirements of her contract of employment, namely that she was unable to work outside her home and no alternative work was available – Commission noted the health directive does not require employees to be vaccinated but rather restricts the place that unvaccinated (and non-excepted) persons can perform work – Commission found that if it was true that applicant received medical advice that she could not be vaccinated so soon after a COVID-19 infection, then it appeared that the health directive would not have required applicant to be vaccinated to work outside her residence prior to cessation of her employment – Commission held that even if applicant was required to be vaccinated, applicant appeared to have become an 'excepted person' and thus as at 9 November 2021, her alleged repudiatory conduct had been cured – Commission found the health directive required employers to collect certain information but did not appear to require employees to provide medical evidence to support an assertion that they are an 'excepted person' – found that while it may have been open to respondent to give a 'direction' to applicant that she provide supporting evidence, respondent did not issue such a direction – Commission found applicant did not repudiate her contract of employment by not being vaccinated or by refusing to provide medical evidence to support her claimed 'excepted person' status – found employment ceased by way of a dismissal at initiative of respondent – jurisdictional objection dismissed.

Cordiano v Love and Co Real Estate

C2021/8318

[2022] FWC 467

Platt C

Adelaide

3 March 2022

Other Fair Work Commission decisions of note

Svitzer Australia P/L v The Australian Maritime Officers' Union

INDUSTRIAL ACTION – suspension of protected industrial action – threat of significant damage to Australian economy – s.424 Fair Work Act 2009 – application for suspension of protected industrial action for 3 months on grounds the industrial action threatened significant damage to the Australian economy – for more than 2 years, applicant has been bargaining for a replacement to the Svitzer Australia P/L National Towage Enterprise Agreement 2016 (expired December 2019) – protected industrial action involved notified 48-hr stoppages at ports in QLD, NSW, and WA between 17 February and 5 March 2022 – primary question whether the protected industrial action threatened to cause damage to the Australian economy that was 'significant' – Commission considered role of predictions and estimates of likely damage – Commission's satisfaction that damage is significant (or not) must have a proper basis – expert evidence about economic importance of seaborne trade and towing services, indicative total economic impact in order of $458-589 million, some sectors of economy disproportionately affected – Commission found 48-hour stoppages scheduled to occur after 18 February 2022 likely to cause at least $100 million damage between 18 February and 5 March 2022 – Commission satisfied of significant damage in relative and absolute terms – Commission required to make order to suspend or terminate the protected industrial action – remaining issue in contention was duration of suspension order – Commission noted that one consequence of making an order under s.424 of the Fair Work Act is that any other industrial action, including action that does not threaten significant damage to the Australian economy, loses the protection of s.418 – last of the 48-hour stoppages was scheduled to commence on 3 March 2022, but applicant asked for s.424 order that would have effect far beyond protecting affected economies from damage caused by the 48-hour stoppages – Commission observed that the practical effect of making an order with a duration of 3 months as sought by the applicant is that the union and its members would not engage in relief bans or shorter stoppages because they would have no protection under s.418 from the legal consequences of their actions – Commission decided to adopt the more cautious approach of making orders to suspend protected industrial action only for the period over which the 48-hour stoppages were scheduled – protected industrial action suspended until 6 March 2022.

B2022/75

[2022] FWC 493

Easton DP

Sydney

4 March 2022

Mathew

ANTI-BULLYING – constitutionally-covered business – s.789FC Fair Work Act 2009 – application for an order to stop bullying – respondent objected to application on 2 grounds, one being that applicant is not employed by constitutionally-covered business and therefore Commission has no jurisdiction to issue stop bullying order – applicant invited to provide response to respondent's views, no response received – respondent submitted that applicant was covered by agreement registered under Industrial Relations Act 1979 (WA) and that the respondent delivered health care services free of charge and did not engage in trading – any revenue raised by respondent was incidental to primary purpose – Commission satisfied that respondent excluded from definition of national system employer as they are established for a public purpose under state or territory law – considered test developed in Aboriginal Legal Service of WA Inc to determine if respondent was a corporation – Commission satisfied that respondent not engaged in trading and any revenue is incidentally generated – respondent not constitutionally-covered business – no reasonable prospects of success of an application for an order to stop bullying – application dismissed.

SO2022/22

[2022] FWC 320

Williams C

Perth

1 March 2022

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Workplace Relations Act 1996 - www.legislation.gov.au/Details/C2009C00075

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	1	CASE PROCEDURES – costs – no reasonable prospects of success – ss.394, 404, 587 Fair Work Act 2009 – a Servicing Theatre Supply Officer (employee) was dismissed by his employer (a hospital), on 30 October 2021 after he failed to get the COVID-19 vaccine or provide an exemption – employee made unfair dismissal application to the Commission – hospital made interlocutory application for the unfair dismissal application to be dismissed under s.587 of the FW Act because it had no reasonable prospects of success – in the alternative the hospital applied for an order under s.404 of the FW Act and r.55 of the Fair Work Commission Rules 2013 that the employee lodge security of $40,000 for the payment of costs because employee's claims had no or low prospects of success and hospital will incur future costs defending its position – Commission made provisional assessment that employee's case not strong, however the hospital's submissions did not meet the high jurisdictional threshold required for a case to be struck out under s.587(1)(c) – Commission's reasons included that there appear to be factual matters in dispute that may bear on substantive or procedural fairness; while it appears the hospital's argument that a valid reason for dismissal existed has force, claims regarding the availability of alternative duties have not been tested; and consideration needs to be given to whether employee's dismissal satisfied procedural fairness requirements – Commission considered Hansen v Calvary Health Care Adelaide Limited, Merribee Pastoral v ANZ Banking Group, Zornada v St John Ambulance Australia (Western Australia) Inc – Commission not satisfied that the justice of the matter required an order for the security of costs – Commission dismissed hospital's applications to dismiss the unfair dismissal claim and for a security for costs order – Commission will list unfair dismissal application for directions.
Sharif v Calvary Health Care Adelaide Ltd
U2021/10666				[2022] FWC 445
Anderson DP			Adelaide	4 March 2022


	2	TERMINATION OF EMPLOYMENT – incapacity – inherent requirements – mandatory vaccination – ss.387, 394 Fair Work Act 2009 – applicant employed as Family and Carer Program Worker – prior to pandemic, applicant would call clients or meet in office or at outreach appointments – after onset of pandemic, a series of State Health directions operating from 1 October 2021 required respondent to ensure unvaccinated workers did not attend respondent's facility and worked from home unless they had an exemption due to a medical contraindication – respondent informed applicant of vaccination requirement – in reply, applicant said she was unvaccinated but did not need to attend the facility as she could successfully perform role from home – at 18 October 2021 meeting, applicant indicated she had appointment with GP but when advised by respondent that date fell outside the government-mandated timeframe for vaccination, applicant did not bring forward appointment – respondent claimed that in same meeting the applicant also stated the GP appointment was only to discuss vaccination options because applicant was uncertain for personal reasons whether to get vaccinated – further meeting on 26 October 2021 to discuss vaccine status – in meeting on 28 October 2021, respondent informed applicant that her decision not to be vaccinated in the required timeframe meant she unable to meet the inherent requirements of her role and her employment was terminated – Commission agreed that prior to pandemic, significant proportion of the applicant's time was spent in face-to-face meetings – accepted that the requirement for face-to-face service delivery remained a feature of the applicant's role during the pandemic – held respondent was entitled to require applicant to carry out the full requirements of her role which included attending respondent's facility – Commission accepted that applicant had no definite plan to be vaccinated – as result, there was no certainty as to when applicant would be capable of fulfilling inherent requirements of her role – concluded it would be unreasonable for respondent to waive for an indefinite period the requirement that applicant be able to carry out full range of her duties – found valid reason for dismissal – found opportunities provided to applicant to respond to reason for dismissal and at each opportunity applicant confirmed that she was undecided and would not be getting vaccinated within the required timeframe – found dismissal was not harsh, unjust or unreasonable – application dismissed.
O'Toole v Australian Community Support Organisation Ltd
U2021/10018				[2022] FWC 477
Masson DP			Melbourne	3 March 2022


	3	TERMINATION OF EMPLOYMENT – remedy – reinstatement – s.394 Fair Work Act 2009 – applicants employed as Shift Managers at respondent's Fremantle Terminal – applicants directed to perform stevedoring work during a period where the respondent's stevedoring employees were undertaking protected industrial action – applicants stood down for their refusal to perform stevedoring work and subsequently dismissed – applicants contended the work was not contemplated by their contracts of employment, not included in position descriptions, and not work they had undertaken in the past in Shift Manager capacity – applicants further submitted that if the direction to work was lawful and reasonable, refusal to work was reasonable because to accede would undermine working relationships with stevedores following conclusion of industrial action and because they were not qualified to perform stevedoring work – applicants submitted that they were at all times ready and willing to perform the duties of Shift Managers – respondent submitted that the work applicants were directed to perform was incidental and alternative duties within the scope of their roles as managers – respondent submitted work was reasonable, necessary, and safe – Commission considered Mt Arthur – Commission considered position description required Shift Managers to supervise, manage, coordinate, and audit and did not include any incidental hands-on or manual labour – Commission considered stevedoring work not incidental to the role of Shift Manager – Commission found direction to perform stevedoring work not lawful or reasonable – found no valid reason for dismissal – found dismissal harsh, unfair, and unreasonable – Commission considered respondent's communication to applicants about work to be performed confusing and secretive and that respondent did not adequately address applicants' concerns about personal safety in context of strikebreaking – if direction reasonable, Commission found that dismissal would be harsh and unreasonable due to communication and safety issues – applicants sought reinstatement – respondent submitted applicants had failed to follow lawful and reasonable directions, could not be trusted not to abandon employment, and their loyalty appeared to be aligned with the MUA rather than the respondent – Commission considered all applicants were willing to perform Shift Manager duties at all relevant times – none of the applicants were dismissed for poor performance – Commission considered Perkins and Nguyen – found requisite trust and confidence could be restored – ordered applicants be reinstated with continuity of employment and back pay less any money earnt by each applicant in the intervening period.
Burkhardt and Ors v Qube Ports P/L
U2021/9115 and Ors				[2022] FWC 281
Riordan C			Sydney	28 February 2022


	4	TERMINATION OF EMPLOYMENT – incapacity – inherent requirements – mandatory vaccination – s.394 Fair Work Act 2009 – application to deal with unfair dismissal – Victorian Chief Health Officer (VCHO) issued directions mandating COVID-19 vaccination for persons performing onsite mining work – applicant worked onsite at Yallourn Mine – respondent wrote to applicant on 4 October advising he could not work onsite unless vaccinated – applicant was unvaccinated – applicant's employment suspended without pay – applicant put on notice that employment may be terminated if he remained unvaccinated – respondent provided show cause letter to applicant on 10 October regarding his decision not to be vaccinated – show cause letter reiterated content of 4 October letter – applicant needed to: confirm by 15 October that he was partially or fully vaccinated, or make an appointment before 22 October for a vaccination, or provide a medical exemption – applicant responded on 14 October that he had booked a vaccination for 22 October – respondent confirmed that if applicant received the vaccination on 22 October he would be permitted to return to work – on 23 October applicant advised respondent he did not attend the vaccination appointment – respondent notified applicant on 25 October that his employment had been terminated with effect from 26 October – respondent submitted applicant was dismissed because he was unable to meet the inherent requirements of his role – not possible for applicant to perform role offsite – applicant submitted he should have been allowed time to research the benefits and risks of vaccination and to become comfortable with the idea of being vaccinated – Commission not persuaded by applicant's submission – Commission found applicant unable at the time of his dismissal to perform the inherent requirements of his role – found there was a valid reason for the dismissal related to applicant's capacity – no procedural defects in the dismissal process – dismissal not unfair – application dismissed.
Hillenaar v RTL Mining and Earthworks P/L
U2021/10067				[2022] FWC 484
Wilson C			Melbourne	4 March 2022


	5	GENERAL PROTECTIONS – dismissal dispute – repudiation – mandatory vaccination – s.365 Fair Work Act 2009 – application to deal with contraventions involving dismissal – applicant employed as a Real Estate Sales Agent – between 11 and 14 October 2021 applicant and respondent engaged in discussions about COVID-19 health directives and performance of applicant's duties, including attending open homes and face-to-face-appraisals – on 19 October 2021, Victorian Government issued health directions that restricted the performance of work outside a person's home if the person was a real estate worker, unless the person was an 'excepted person' or had received their first vaccine dose by 22 October and their second by 26 November 2021 – on 22 October 2021 applicant contracted COVID-19 and was required to isolate – applicant subsequently informed respondent she had a vaccination exemption because her doctor had advised it was dangerous to receive the vaccine so soon after she had contracted COVID-19 – on 8 November respondent requested evidence of exemption and applicant refused to provide it – on 9 November 2021 respondent notified applicant of the termination of her employment, effective 16 November 2021, due to her 'inability to perform the inherent requirements of the role to work in Company premises in compliance with the Victorian Public Health Order' and because 'there is no other position the Company can offer you in the business or ability to provide you with useful work to perform from home' – respondent raised a jurisdictional objection that applicant not dismissed but rather repudiated her contract of employment by failing to get vaccinated and/or failing to provide proof of being exempt from vaccination requirement – respondent submitted that it accepted repudiation on 9 November 2021 – Commission considered Earney v Australian Property Investment Strategic P/L – Commission found communications between applicant and respondent on 8 and 9 November 2021 consistent with applicant being dismissed as a result of her not being able to meet the inherent requirements of her contract of employment, namely that she was unable to work outside her home and no alternative work was available – Commission noted the health directive does not require employees to be vaccinated but rather restricts the place that unvaccinated (and non-excepted) persons can perform work – Commission found that if it was true that applicant received medical advice that she could not be vaccinated so soon after a COVID-19 infection, then it appeared that the health directive would not have required applicant to be vaccinated to work outside her residence prior to cessation of her employment – Commission held that even if applicant was required to be vaccinated, applicant appeared to have become an 'excepted person' and thus as at 9 November 2021, her alleged repudiatory conduct had been cured – Commission found the health directive required employers to collect certain information but did not appear to require employees to provide medical evidence to support an assertion that they are an 'excepted person' – found that while it may have been open to respondent to give a 'direction' to applicant that she provide supporting evidence, respondent did not issue such a direction – Commission found applicant did not repudiate her contract of employment by not being vaccinated or by refusing to provide medical evidence to support her claimed 'excepted person' status – found employment ceased by way of a dismissal at initiative of respondent – jurisdictional objection dismissed.
Cordiano v Love and Co Real Estate
C2021/8318				[2022] FWC 467
Platt C			Adelaide	3 March 2022

Australian Capital Territory Level 3, 14 Moore Street Canberra 2600 GPO Box 539 Canberra City 2601 Tel: 1300 799 675 Fax: (02) 6247 9774 Email: canberra@fwc.gov.au	New South Wales Sydney Level 10, Terrace Tower 80 William Street East Sydney 2011 Tel: 1300 799 675 Fax: (02) 9380 6990 Email: sydney@fwc.gov.au	Newcastle Level 3, 237 Wharf Road, Newcastle, 2300 PO Box 805, Newcastle, 2300

Northern Territory 10th Floor, Northern Territory House 22 Mitchell Street Darwin 0800 GPO Box 969 Darwin 0801 Tel: 1300 799 675 Fax: (08) 8936 2820 Email: darwin@fwc.gov.au	Queensland Level 14, Central Plaza Two 66 Eagle Street Brisbane 4000 GPO Box 5713 Brisbane 4001 Tel: 1300 799 675 Fax: (07) 3000 0388 Email: brisbane@fwc.gov.au	South Australia Level 6, Riverside Centre North Terrace Adelaide 5000 PO Box 8072 Station Arcade 5000 Tel: 1300 799 675 Fax: (08) 8308 9864 Email: adelaide@fwc.gov.au

Tasmania 1st Floor, Commonwealth Law Courts 39-41 Davey Street Hobart 7000 GPO Box 1232 Hobart 7001 Tel: 1300 799 675 Fax: (03) 6214 0202 Email: hobart@fwc.gov.au	Victoria Level 4, 11 Exhibition Street Melbourne 3000 PO Box 1994 Melbourne 3001 Tel: 1300 799 675 Fax: (03) 9655 0401 Email: melbourne@fwc.gov.au	Western Australia Floor 16, 111 St Georges Terrace Perth 6000 GPO Box X2206 Perth 6001 Tel: 1300 799 675 Fax: (08) 9481 0904 Email: perth@fwc.gov.au

FWC Bulletin

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Decisions of the Fair Work Commission

Other Fair Work Commission decisions of note

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Fair Work Commission Addresses