ࡱ> egdg k<bjbjVV 7dr<r<2T* : D PPPddd8\Dd+<<:vvvQQQv+x+x+x+x+x+x+$-50+PQQQQQ+PPvv+QvPvPvv+Qv+&(v1@'b++0+'Z11$((1P(QQQQQQQ++QQQ+QQQQ1QQQQQQQQQ : IN THE AUSTRALIAN HUMAN RIGHTS COMMISSION IN THE MATTER OF AN APPLICATION FOR AN EXEMPTION PURSUANT TO SECTION 55 OF THE DISABILITY DISCRIMINATION ACT 1992 FURTHER SUBMISSION ON BEHALF OF AED LEGAL CENTRE IN OPPOSITION TO THE APPLICATION INTRODUCTION This submission is made by AED Legal Centre (AED) further to its submission to the AHRC dated 29 October 2013 and should be read in conjunction with that submission. It is made in response to the further information provided by the Department of Social Services (Commonwealth) in support of its application for temporary exemption (Application) to exempt the use of BSWAT in Australian Disability Enterprises (ADEs) from the application of the DDA. The further information provided by the Commonwealth, like its original exemption application, does not provide any primary data or supporting detailed facts to support the broad assertions it makes. Further, the Commonwealth has not addressed important matters raised in the Commission Guidelines for dealing with exemption applications, nor important questions put to it by the AHRC. This further submission does not traverse all of the matters raised in the further information provided by the Commonwealth, as much of it consists only of broad assertions which AED has already addressed in its submission to the AHRC dated 29 October 2013. Rather, this further submission responds to several discrete matters raised by the Commonwealth. EFFECT OF NOJIN DECISION & CONTINUING UNLAWFUL DISCRIMINATION The Commonwealth continues to assert that the Full Federal Court decision in Nojin & Prior v Commonwealth [2012] FCAFC 192 (Nojin) does not render the use of BSWAT discriminatory per se. In that regard, we refer to the reasons of Justice Buchanan in Nojin, and note that His Honour made various general observations about the discriminatory effect of BSWAT on workers with an intellectual disability. In particular, His Honour said: It is not a sufficient answer to say that intellectually disabled people can do the test like everybody else, and may do their best. Intellectually disabled people are placed, at the outset, at a disadvantage which prevents effective compliance. They are not able to comply in substance, regardless of the outward form. The wage which is, under the award, to be assigned to an intellectually disabled worker is not, in my view, intended to represent the value of the employee to an employer measured in some abstract or theoretical way. The wages are intended to represent a relationship to the wage of a Grade 1 worker. Having regard to the nature of the tasks for which the Grade 1 rate is fixed, that relationship should be one which is reasonable having regard to the output of the disabled worker compared with the output of the non-disabled worker. The introduction and overlay of other theoretical considerations should not, in my view, be permitted to distract attention from this fundamental entitlement. The practical consequence of BSWAT appears to be that wages are reduced below the level that would otherwise be applied. The basic defect in the use of BSWAT is that it reduces wages to which intellectually disabled workers would otherwise be entitled by reference to considerations which do not bear upon the work that they actually do. In my view that approach is not reasonable. Furthermore, in refusing the Commonwealths application for special leave to appeal the Full Federal Courts decision in Nojin to the High Court, Justice Crennan said: The Full Court of the Federal Court, by a majority, concluded that the use of the BSWAT disadvantaged intellectually disabled persons. Although it was widely used, it was not reasonable. One component of the BSWAT involves the assessment of a persons competencies in the workplace. The unchallenged expert evidence was that the BSWAT produced a differential effect for intellectually disabled persons and reduced their score. We see no reason to doubt the conclusions of the Full Court. It is plain that the Courts findings in relation to the use of BSWAT have broader implications than just in the particular circumstances relevant to Messrs Nojin and Prior. Despite the Commonwealths assertion to the contrary, it follows from these judgments that the AHRC can be satisfied that in the event that the exemption sought by the Commonwealth is granted, workers with intellectual disabilities will be discriminated against in a way which would be unlawful save for the exemption. ASSERTIONS RELATING TO USE OF SWS AND BSWAT By letter dated 13 December 2013 the AHRC asked the Commonwealth a number of questions relating to the use of the Supported Wage System (SWS) or the use of only the productivity component of BSWAT. In answer, the Commonwealth made a number of assertions to which we respond as follows. The Commonwealths assertion that through using the SWS those supported employees with the highest support needs would fall out of employment because it would no longer be economically viable to employ this group is entirely unsupported by evidence or primary facts. If it could be compellingly demonstrated, AED accepts that it would be a significant factor in the AHRC's consideration. But at present it is no more than a bald assertion. Since it appears to be central to the Commonwealth's application, the lack of data should tell heavily against giving it any weight. Further, while it is true that workers in ADEs may not perform all of the subcomponent tasks of a particular position, the same is true of many employees without disabilities in open employment, who do not perform all of the tasks contemplated by a particular grade descriptor in an Award. There is also no evidence produced to support the Commonwealths claim that it is possible that the productivity only measure available through the SWS may not provide an accurate indication of true productivity of some employees. If that is so, it could surely be demonstrated by data, or at the least, actual examples of this situation arising. The Commonwealth asserts that it would take some time to transition to using the SWS, but, a move to using only the productivity part of the BSWAT would be relatively straightforward as data from existing assessments could be used. However, the Commonwealth asserts that there is no advantage in having both the productivity component of BSWAT and the SWS long term. However AED does not contend for the maintenance of two tests doing much the same work. The use of the productivity part of BSWAT is advanced as an immediately available mechanism, since by definition all BSWAT assessed employees have undergone a productivity assessment. The Commonwealth does not address the possibility of such an interim arrangement whereby workers who have already been assessed under BSWAT have their wages assessed using their existing productivity scores only, until such time as the worker is assessed under the SWS (or other productivity based wage assessment tool the Commonwealth determines to use). We submit that this is a practical and reasonable approach that could, and should, be adopted by the Commonwealth. It would allow it to transition to a new wage setting arrangement in an orderly fashion as it desires, while also ensuring, to the extent possible, that workers with intellectual disability are not paid discriminatory wages in the interim. The Commonwealth estimates that approximately 200 workers may be disadvantaged by the use of only the productivity component of BSWAT. First, we note that the productivity component of BSWAT has not been found by the courts to be unlawfully discriminatory. Further, using this figure, we deduce that some 10,500 workers may be better of (or unaffected) by the use of only the productivity component of BSWAT. We respond to the Commonwealths various assertions relating to the increased wages that would be payable if the SWS or only the productivity component of BSWAT was used to assess the wages of workers in ADEs below. SUSTAINABILITY OF THE SECTOR A persistent theme of the further information provided by the Commonwealth is the assertion that a failure by the AHRC to grant the exemption sought would lead to the closure of some ADEs and consequential job losses and reduced employment options leading to increased social isolation for people with disability. There is absolutely no evidence before the AHRC to support such an assertion. The Commonwealth has not produced any evidence or facts in support of its claim, nor have any of the ADEs that made submissions to the AHRC in support of the exemption application. This assertion is of such potential seriousness that the lack of supporting data implies that it is not capable of convincing support. At its highest, the Commonwealth states: Anecdotally, the Department is advised that an initial estimate of average increased wage costs for ADEs transitioning to the BSWAT productivity part only would be up to 70 per cent. Further, the Commonwealth did not answer the AHRCs question what evidence or analysis is available, or has been done, to support the submission that ADEs would close as a result of the increased wages? Instead, it referred to financial analysis undertaken for the years 2011-2012 which apparently demonstrates that 48% of ADEs had a medium to high risk of failure at that time. This is not attributable to BSWAT, nor is it evidence that supports the submission advanced by the Commonwealth. In that regard, we note the remarks of Justice Buchanan at [132] of his judgment in Nojin: The overall economic outcome of the use of BSWAT might assist ADEs in the (doubtless) difficult job of budgeting, but that benefit comes only at the price of imposing a comparative disadvantage on the intellectually disabled. The AHRC should not act on the basis of the Commonwealths claim that ADEs will close and workers will be left unemployed unless the exemption is granted without any evidence (other than anecdotal) or financial analysis to support that serious claim. REASONABLENESS OF THE APPLICATION It appears the crux of the Commonwealths application for exemption relates to sector sustainability. That workers have been paid unlawful discriminatory wages for 10 years cannot justify the continuation of the discrimination. This is particularly so where the Commonwealth was advised by the AHRC prior to implementing BSWAT that it likely contravened the DDA (as set out in our earlier submission). The Commonwealth suggests that the Commonwealths announcement of a BSWAT Payment Scheme somehow ameliorates the discrimination that would be suffered by the workers if the exemption is granted. In that regard, we note that details of key aspects of the payment scheme have not been developed or announced, including: Who will be eligible for a payment and in which circumstances; The value of the payments that will be available; Haw any payment will be calculated; and When payments will be made. Further, and perhaps most importantly the scheme expressly relates only to work performed in the past, and will not ameliorate any future discrimination. Presumably the Commonwealth intends for workers with intellectual disability to continue receiving inadequate and discriminatory wages for the next three years during the currency of the exemption sought, without any compensation relating to that three year period. The Commonwealth states that there is extensive work to be done in establishing a new wage assessment process. This work is a priority for the Department. However it cannot point to any steps it has taken to do so, other than consultation in the 14 months since the Full Federal Court decision in Nojin (or the 8 months since the High Court refused the Commonwealths special leave application). The Commonwealth ought not come to the AHRC seeking further time to develop a new wage assessment tool, and to allow an orderly transition, when it has already caused significant delay. Finally, we note that the Commonwealth did not respond to the question asked of it by the AHRC in relation to the concluding observations of the CRPD Committee relating to BSWAT on the initial report of Australia, adopted at its tenth session in September 2013. CONCLUSION If the AHRC grants the exemption sought by the Commonwealth, workers with intellectual disability will continue to be discriminated against in a way which has been found by the Courts to be unlawful. Such discrimination should only be permitted by the AHRC in very particular circumstances, namely, where the grant of the exemption is: consistent with the objects of the DDA; necessary; reasonable in the circumstances; and supported by facts and/or evidence. As set out in AEDs submission to the AHRC dated 29 October 2013, none of these factors are met in the present application. The further information provided by DSS does not alter this position. DATED 12 February 2014 MAURICE BLACKBURN LAWYERS Solicitors for AED Legal Centre  Commonwealth of Australia and Anor v Prior, Nojin and Anor [2013] HCATrans 101.     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