[2012] FWA 1776

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FAIR WORK AUSTRALIA

DECISION

Fair Work Act 2009
s.185 - Application for approval of a single-enterprise agreement

Advanced Foundation Solutions (Aust) Pty Ltd
(AG2012/154)

SENIOR DEPUTY PRESIDENT O'CALLAGHAN

ADELAIDE, 5 MARCH 2012

Advanced Foundation Solutions (Aust) Pty Ltd CFMEU Collective Agreement 2011 - 2014.

[1] On 24 January 2012 Advanced Foundation Solutions (Aust) Pty Ltd (AFS) lodged an application for approval of the Advanced Foundation Solutions (Aust) Pty Ltd CFMEU Collective Agreement 2011-2014 (the Agreement) pursuant to section 185 of the Fair Work Act 2009 (the Act). That application was referred to me for consideration.

[2] On 31 January 2012 I issued preliminary findings wherein I sought advice of the day on which employees were informed of the time and place of the vote and the voting method to be used. A copy of those preliminary findings was forwarded to both the CFMEU and to a nominated employee bargaining representative.

[3] On 2 February 2012 the Master Builders Association of New South Wales (MBA) responded on behalf of its member, ASF, in the following terms:

[4] Attached to this advice was a copy of the advice from the employer to its employees of 3 January 2012 which was in the following terms:

[5] On the information provided to me, I am satisfied that this advice was provided to all the employees but I am not able to conclude that it provided employees with notification of the time and the place of the vote and the voting method to be used. The AFS in the Form F17 filed with the application, advised that this reflected the last Notice of Employee Representational Rights. However, I have not taken it as such a notice. Further, I have noted that a Notice of Representational Rights in the proscribed form was issued on 12 December 2011.

[6] The subsequent advice of 17 January 2012 gave employees only six days notice of the time and place of the vote.

[7] This application was the subject of a telephone hearing on 16 February 2012. Mr Glover of the MBA and Mr Longstaff of AFS appeared, together with employee representatives Mr Antony and Mr Parker. Mr Kelly appeared for the CFMEU.

[8] At this hearing, AFS confirmed that the voting method to be used at a future unspecified meeting was advised to the employees at the meeting held on 19 December 2011. AFS agreed that the 3 January 2012 letter referred to a meeting to be held "in approximately 2 weeks time". 1

[9] At the hearing, I sought advice in the following terms:

[10] The CFMEU could not confirm to me that it had advised the employees of the time and the place of the vote. The two employee representatives also agreed that they were informed in early January 2012 that a meeting would be held in approximately 2 weeks time and that the exact date was then confirmed on 17 January 2012.

[11] I provided AFS with the opportunity to withdraw the application and repeat the voting process but AFS urged me to adopt a position that the notification requirements set out in s.180 of the FW Act had been effectively satisfied. The CFMEU position was that:

Findings

[12] In light of the AFS position I have considered whether the Agreement can be approved. This issue is the only potential impediment to approval.

[13] I have noted that there are 11 employees to be covered by the Agreement and that all of the 11 employees voted to approve the Agreement.

[14] Section 180 states:

[15] The issue here is whether s.180 represents mandatory requirements which must be satisfied as a prerequisite for approval of an agreement or whether a purposive approach to the requirements of this section can be adopted. There is no argument that employees knew about the time and the place of the vote and participated in that voting process. It is simply the case that there is general agreement that the specified notice of the time and the place of the meeting was not given to the employees before the time specified in s.180(4).

[16] Section 188 states:

[17] There are numerous situations which may arise where there is doubt over compliance with s.180. Full Benches in Bland v Ceva Logistics 4 and National Tertiary Education Industry Union v University of NSW5 have dealt with Fair Work Australia's capacity to be satisfied about compliance with s.180 and the concept of "all reasonable steps" in so far as it relates to the preapproval steps required of an employer. Those decisions establish a degree of latitude available to Fair Work Australia in reaching a conclusion about these issues. They deal particularly with issues relating to the provision to every employee of all of the information identified in s.180 rather than the fundamentals of the actions taken by the employer.

[18] When it is patently clear that the employer's actions do not comply with the mandatory provisions of s.180, the FW Act does not permit Fair Work Australia to overlook such a substantial failure to conform with s.180 on the basis that this did not affect the voting outcome. Whilst it might be entirely logical for the legislation to allow Fair Work Australia to have the capacity to overlook omissions relative to preapproval steps where it is satisfied that these do not alter the voting outcome, the FW Act does not currently permit this. There is simply no legislative licence to ignore the obligations in ss.180 and 188.

[19] In these circumstances, because of the advice provided to me by the employer, the CFMEU and the two employee representatives, I cannot be satisfied that employees were advised of the time and the place of the vote by the start of the access period such that the Agreement can be approved consistent with s.186. The Agreement must be refused approval and the agreement making process repeated.

[20] Consistent with the advice I provided to the parties on 16 February 2012 I am satisfied that in all other respects the Agreement meets the prerequisite requirements for approval, and if a new application in the same terms is referred to me for approval it will be dealt with as expeditiously as possible.

SENIOR DEPUTY PRESIDENT

Appearances:

P Glover Master Builders Association of NSW and P Longstaff representing Advanced Foundation Solutions (Aust) Pty Ltd.

W Kelly on behalf of the Construction, Forestry, Mining and Energy Union NSW Branch.

B Parker and M Antony employee representatives.

Hearing details:

2012.
Adelaide (by phone):
February 16.

 1   Transcript PN32

 2   Ibid, PN35 - PN44

 3   Ibid, PN113 - PN115

 4   [2011] FWAFB 7453

 5   [2011] FWAFB 5163

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