ۥ- dsn:,  v4A:C Human Rights and Equal Opportunity Commission Report of an Inquiry into Complaints of Discrimination in Employment and Occupation Age Discrimination in the Australian Defence Force HRC Report No. 8 Copyright (C) Commonwealth of Australia 2000 Copying is permissible with acknowledgment of the authorship of the Human Rights and Equal Opportunity Commission, Sydney, May 2000. Designed by Page & Picture/Liam Gash. Printed by J S McMillan. Letter of transmission here Contents Complaints of age discrimination in the ADF The nature of this report The Commissions jurisdiction and complaint handling functions Discrimination in employment and occupation under the Act Summary of the four complaints Summary of findings and recommendations Notice of my findings and recommendations Procedural history of the four complaints The main legal points in issue in the four complaints Action taken by the ADF as a result of my findings and recommendations Appendix A Section 35 notice in the matter of Bradley and the ADF 1. The Commissions jurisdiction 2. The complaint 3. Submissions 4. The basis of the findings 5. Discussion of recommendations 6. Notice of findings of the Commission 7. Reason for findings 8. Recommendation for compensation Appendix B Section 35 notice in the matter of Barty and the ADF 1. The Commissions jurisdiction 2. The complaint 3. Progress of the inquiry 4. Oral evidence for the respondent 5. Written submissions of the parties 6. Findings 7. Recommendations 8. Notice of findings of the Commission 9. Reasons for findings 10. Recommendations Appendix C Section 35 notice in the matter of Petersen and the ADF 1. The Commissions jurisdiction 2. The complaint 3. Progress of the inquiry 4. Oral evidence for the respondent 5. Written submissions of the parties 6. Findings 7. Recommendations 8. Notice of findings of the Commission 9. Reason for findings 10. Recommendation Appendix D Section 35 notice in the matter of Van Den Heuvel and the ADF 1. The Commissions jurisdiction 2. The complaint 3. Process of the inquiry 4. Submissions and findings on liability 5. Submissions on recommendations 6. Discussion of recommendations 7. Notice of findings of the Commission 8. Reason for findings 9. Recommendations Complaints of age discrimination in the ADF The nature of this report This is the eighth report to the Attorney-General on inquiries made by the Human Rights and Equal Opportunity Commission (the Commission) into complaints of discrimination and violations of human rights under the Human Rights and Equal Opportunity Commission Act 1986 (Cth) (the Act). The Act provides for the Human Rights Commissioner (the Commissioner) to perform these functions. The subject of this report is once again age discrimination in employment and, specifically, the report deals with four separate complaints of age discrimination by the Commonwealth in the Australian Defence Force (the ADF). The complaints were made by three prospective entrants to the ADF and one serving member of the ADF. The complaints were by Mr Robert Bradley who complained about the upper age limit of 35 for applicants for helicopter pilots in the army Mr Kenneth Barty who complained about the upper age limit of 35 for applicants for Administrative Officer positions in the Royal Australian Air Force (the RAAF) Mr E W Petersen who complained about the upper age limit of 35 for applicants for Administrative Officer positions in the ADF generally and Mr Ken Van Den Heuvel who complained about the upper age limit of 35 for remustering to a Load Officer position in the RAAF. The essence of all four complaints was that the upper age restrictions on entry into various positions within the ADF were discriminatory. In each of these complaints I found that the particular age limit constituted discrimination in employment and that it could not be justified as being based on the inherent requirements of the particular job. In respect of Mr Van Den Heuvels complaint, discrimination was conceded by the ADF. I issued notices in respect of my findings of discrimination and made various recommendations for the payment of compensation, for the removal of the age restrictions and, in one case, for an apology. In each of these matters, with the exception of Mr Van Den Heuvels complaint in which liability was conceded, the ADF challenged my findings by way of an application for an order of review in the Federal Court. Following the decision of the Full Federal Court in Commonwealth v Human Rights and Equal Opportunity Commission and Anor (1999) 167 ALR 268 which upheld my decision in relation to Mr Bradleys complaint, the proceedings in the matters of Messrs Barty and Petersen were discontinued and I am now in a position to report to the Attorney-General, as required by section 31 of the Act. This report to the Attorney-General summarises the various complaints and my findings and recommendations in relation to those complaints. It annexes the four notices issued in relation to the various complaints. The report should be read in light of the Commissions broader investigation into age discrimination. In this investigation, I issued a discussion paper entitled Age Matters? A Discussion Paper on Age Discrimination in April 1999. Over 50 submissions were received on the discussion paper, and I am now reporting to the Attorney-General on the broader issues of age discrimination in a separate report. The Commissions jurisdiction and complaint handling functions The long title of the Act is an Act to establish the Human Rights and Equal Opportunity Commission (and) to make provision in relation to human rights and in relation to equal opportunity in employment .... The Commission has specific statutory functions and responsibilities for the promotion of human rights and the elimination of discrimination under the Act. In particular, the Commission must inquire into complaints of acts and practices that may be inconsistent with or contrary to any human right or that may constitute discrimination (section 11(1)(f) and section 31(b)). Part II Division 4 of the Act confers functions on the Commission in relation to equal opportunity in employment in pursuance of Australias international obligations under the International Labour Organisation Discrimination (Employment and Occupation) Convention 1958 (ILO 111). Section 8(6) of the Act provides that the Human Rights Commissioner shall perform the Commissions function of inquiring into complaints of any act or practice that may constitute discrimination as defined by the Act. Under section 31(b) of the Act the Commissioner is to inquire into any act or practice that may constitute discrimination and (i) where the Commissioner considers it appropriate to do so - to endeavour, by conciliation, to effect a settlement of the matters that gave rise to the inquiry and (ii) where the Commissioner is of the opinion that the act or practice constitutes discrimination, and the Commissioner has not considered it appropriate to endeavour to effect a settlement of the matters that gave rise to the inquiry or has endeavoured without success to effect such a settlement - to report to the Minister in relation to the inquiry. The Commissioner is required to give the parties an opportunity to make written and/or oral submissions in relation to the complaint (see sections 27 and 33). Where, after an inquiry, the Commissioner finds discrimination, the Commissioner is required to serve notice on the respondent, setting out the findings and the reasons for those findings (section 35(2)(a)). The Commissioner may include recommendations for preventing a repetition of the act or practice and for the payment of compensation or the taking of any other action to remedy or reduce the loss or damage suffered as a result (section 35(2)(b) and (c)). If the Commissioner makes a finding of discrimination the matter must be reported to the federal Attorney-General under section 31(b)(ii) of the Act. The Attorney-General must table the report in Parliament in accordance with section 46 of the Act. The recommendations made are not enforceable. Discrimination in employment and occupation under the Act Under section 3(1) of the Act discrimination is defined as (a) any distinction, exclusion or preference made on the basis of race, colour, sex, religion, political opinion, national extraction or social origin that has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation; and (b) any other distinction, exclusion or preference that: (i) has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation; and (ii) has been declared by the regulations to constitute discrimination for the purposes of this Act; but does not include any distinction, exclusion or preference: (c) in respect of a particular job based on the inherent requirements of the job;.... Article 1(1)(a) of ILO 111 prohibits discrimination on certain specified grounds. Those grounds are contained in the Act in subparagraph (a) of the definition of discrimination. Article 1(1)(b) of ILO 111 provides that ratifying States may address discrimination on additional grounds. The Act provides in subparagraph (b)(ii) of the definition of discrimination for the adoption of regulations to declare additional grounds in accordance with this provision in ILO 111. Under this power the Human Rights and Equal Opportunity Commission Regulations in 1989 declared age as a ground of discrimination for the purposes of the Act with effect from 1 January 1990. According to accepted principles in domestic law, a statute such as the Act that contains language that derives directly from an international instrument should be interpreted in accordance with the meaning the language has been given at the international level. The comments of the International Labour Conference Committee of Experts on the Application of Conventions and Recommendations (the Committee of Experts) are relevant to the interpretation of the Acts definition of discrimination. According to the Committee of Experts, there are essentially three elements to the definition of discrimination in ILO 111 1. an objective factual element, being the existence of a distinction, exclusion or preference which effects a difference in treatment in comparison with another in the same situation 2. a ground on which the difference of treatment is based that is declared or prescribed and 3. the objective result of this treatment, that is, a nullification or impairment of equality of opportunity or treatment in employment or occupation. Further, the Committee of Experts has expressed the view that the adoption of impersonal standards based on forbidden grounds and apparently neutral regulations and practices [that] result in inequalities in respect of persons with certain characteristics also constitute discrimination. The Committee of Experts has also commented on the ILO 111 provision of any distinction, exclusion or preference in respect of a particular job based on inherent requirements of the job. To be an inherent requirement, the condition imposed must be proportionate to the aim being pursued and must be necessary because of the very nature of the job in question. The Committee stated, for example, that the exception refers to a specific and definable job, function or task. Any limitation within the context of this exception must be required by characteristics of the particular job, and be in proportion to its inherent requirements. In addition the Committee of Experts has agreed that an intention to discriminate is not necessary for a finding of discrimination under ILO 111. Summary of the four complaints This report deals with four complaints relating to age discrimination in the ADF. In summary Mr Bradley alleged that he had been denied entry into the Specialist Service Officer (SSO) Pilot Scheme on the ground that he was over the age of 27 Mr Barty alleged that his application for the position of Administrative Officer with the RAAF had not been considered by reason of his age Mr Petersen complained generally about the practice of the ADF in requiring entrants to be within a 17 to 35 age range and specifically that he had been denied the opportunity to apply for a position by reason of his age Mr Van Den Heuvel alleged that the ADF discriminated against him on the ground of age when it rejected his application to remuster from his position as a RAAF Ground Support Fitter at Williamstwon Air Base to the position of Aircraft Loadmaster. Summary of findings and recommendations In relation to Mr Bradley, I found that the act and practice complained of, namely that Mr Bradley was denied the opportunity to apply for a position in the SSO Pilot Scheme on account of his age, constituted discrimination in employment based on age. I recommended that the ADF pay Mr Bradley compensation of $5,000, being general damages. In relation to Mr Barty, I found that the act complained of, namely that the ADF refused to process further Mr Bartys application for the position of Administrative Officer in the RAAF, and the practice complained of, namely that the ADF enforced a maximum age of 35 for appointment as an Administrative Officer in the RAAF, constituted discrimination in employment based on age. I recommended that the upper age limit contained in the selection criteria for Administrative Officer positions in the RAAF be removed and that the ADF pay Mr Barty compensation of $5,000, being general damages. In relation to Mr Petersen, I found that the practice complained of, namely that the ADF enforced a maximum age of 35 for appointment as Administrative Officer in the ADF, constituted discrimination in employment based on age. I recommended that the upper age limit in the ADF for admission to Administrative Officer positions or equivalent positions, however titled, be removed. In relation to Mr Van Den Heuvel, I found that the act complained of, namely that the ADF rejected his application to remuster to the position of Aircraft Loadmaster on account of his age, constituted discrimination in employment based on age. I recommended that the upper age limit contained in the selection criteria for Aircraft Loadmaster positions be abolished, that the respondent provide an apology to Mr Van Den Heuvel and pay him compensation of $10,000, being general damages. Notice of my findings and recommendations Under section 31(b) of the Act, I am required to serve notice of my findings and recommendations on the respondent. My notice in respect of each matter is appended to this report as follows:  Notice Date Appendix Mr Bradley 5 March 1998 A Mr Barty 16 September 1999 B Mr Petersen 16 September 1999 C Mr Van Den Heuvel 16 September 1999 D Procedural history of the four complaints My inquiries leading up to the issue of the notices in respect of each of the four complaints are detailed in the notices at Appendices A to D. In each matter, I considered the parties submissions and evidence in making my findings and recommendations. The notice in the Bradley matter was issued on 5 March 1998. The ADF challenged my findings by way of an application for an order of review in the Federal Court. By decision dated 16 October 1998, his Honour Wilcox J dismissed the application (see Commonwealth of Australia v Human Rights and Equal Opportunity Commission & Anor (1998) 158 ALR 468). The ADF appealed against the decision of Wilcox J and the decision of the Full Federal Court was reserved in February 1999. On 17 September 1999 I issued notices in the Barty, Petersen and Van Den Heuvel matters. The ADF made application to the Federal Court for orders of review in respect of the Barty and Petersen matters. On 4 December 1999 the Full Federal Court handed down its decision dismissing the appeal from the decision of his Honour Wilcox J in the Bradley matter (see Commonwealth of Australia v Human Rights and Equal Opportunity Commission & Others (1999) 167 ALR 268) and thereby upholding my findings. The ADF subsequently withdrew its applications for review in the Barty and Petersen matters. The main legal points in issue in the four complaints In deciding whether each matter complained of constituted discrimination within the terms of the Act I was required to consider five main issues: 1. whether there was an act or practice under the Act 2. whether the act or practice arose in employment or occupation 3. whether there was a distinction, exclusion or preference based on age 4. whether the distinction, exclusion or preference nullified or impaired equality of opportunity or treatment and 5. whether the distinction, exclusion or preference in respect of the particular job was based on the inherent requirements of the job. I was then required to consider whether, and on what basis, I would make recommendations relating to loss and damage suffered, including recommendations as to compensation. As is evident from the notices at Appendices A to D, there were a number of matters in dispute in relation to the first four elements. However, the major matter in dispute became the fifth element listed above. Not all distinctions, exclusions or preferences are discriminatory within the meaning of the Act. An employer may make a distinction, exclusion or preference on the basis of age where the distinction, exclusion or preference is based on the inherent requirements of the job. In each case (except that of Mr Van Den Heuvel in which liability was conceded), the ADF primarily relied on this aspect of the definition to argue that it had not acted in a discriminatory fashion. In the Bradley case, I considered the various interpretations as to which requirements could constitute an inherent requirement. I adopted a narrow construction on the basis that exemptions to human rights provisions should be interpreted narrowly. Although a broader view of the scope of inherent requirements was taken by the High Court in its subsequent decisions in Qantas Airways Ltd v Christie (1998) 193 CLR 280 and X v Commonwealth (1999) 167 ALR 529, the Full Federal Court agreed with Wilcox J that my approach taken in the Bradley matter did not amount to an error of law. In the Barty and Petersen cases, I found in favour of the ADF in relation to what could constitute an inherent requirement of the job. Thus, for example, in relation to Mr Barty, I found that it was an inherent requirement of the job of Administrative Officer to possess a level of combat fitness sufficient for ground combat operations to defend a bare base in the north of Australia. The critical question became whether the distinction based on age could be said to be based on the inherent requirements of the particular job. In both cases I answered this question in the negative. In coming to this conclusion I relied on the reasoning of Wilcox J in the Federal Court in the Bradley matter. For example, in relation to Mr Barty, I found: In my view, the critical matter is the possession by a person of a certain level of physical and medical fitness. This level is appropriately set in accordance with the requirement for deployment in combat. The ADF has medical and fitness tests which are designed and intended to be an adequate determinant of whether a person has the requisite level of fitness. Both Colonel Warfe and Wing Commander Johnston gave evidence as to the nature of the relevant tests. There was no suggestion in the evidence that the tests are incapable of detecting physical deterioration or medical problems. The medical and fitness standards are clearly based on the inherent requirement of the requisite level of combat fitness. The age exclusion, on the other hand, is not so based. It operates instead as a proxy for the possession of the required medical and fitness characteristics. In evidence, the respondent tendered studies to show the increased rate of injury and medical discharge for older persons in the defence forces. These studies indicate that on average older persons have higher rates of injury and medical discharge. In Bradley, Wilcox J drew specific attention to evidence which pointed to the difference between an average rate of performance and the performance of individuals. The only evidence that I have been presented with in this matter is evidence as to average performances. Indeed, I heard anecdotal evidence from a number of the respondents witnesses about persons who were over the age of 35 who were performing the relevant jobs and doing so to the required standard. In my view, I should apply the approach adopted by Wilcox J in Bradley. In that case, his Honour said: The term based on requires more than a logical link. The Macquarie Concise Dictionary gives, as the meaning of the verb base when followed by on or upon, to establish, as a fact or conclusion. So the distinction, exclusion or preference must be established upon the inherent requirements of the particular job. The correlation must be, at least, close. His Honour considered the analysis of Sackville J in AMC v Wilson (1996) 68 FCR 46 as to the meaning of based on. However, cases which have considered the meaning of the term based on in the context of establishing whether discriminatory conduct has occurred provide limited assistance in this case. With respect to beneficial legislation the meaning to be given to the phrase in the context of a defence is not necessarily the same as it would be in the context of establishing an element of discrimination. To the extent that the respondent relies on AMC v Wilson and Cosco Holdings Pty Ltd v Do (1997) 150 ALR 127 for the proposition that an exclusion will be based on the inherent requirements of the job except where the inherent requirements are merely a subterfuge or a specious foundation, I do not accept this submission. In any event, Wilcox J has addressed this very issue. His Honour required a tight correlation between the inherent requirements of the job and the relevant distinction, exclusion or preference. His Honour made reference to the policy behind the legislative scheme and continued: If the words based on are so interpreted that it is sufficient to find a link between the restriction and the stereotype, as distinct from the individual, the legislation will have the effect of perpetuating the very process it was designed to bring to an end. So it is not appropriate to reason that because extreme fitness is an inherent requirement of a job of an SSO pilot and younger pilots tend to be more fit than older pilots, therefore the requirement for SSO pilots to be under 28 years of age on appointment is based on the requirement of fitness. Unless there is an extremely close correlation between the selected age and fitness requirement so that age may logically be treated as a proxy for the fitness requirement, the legislation will have the effect of damning individuals over the age of 28 years by reference to a stereo-typical characteristic (less physical fitness) of their age group. The respondents submissions rely on the inappropriate reasoning described by Wilcox J and, for the reasons he gave, I am unable to accept them. In summary, it may be that more persons over the age of 35 than below it fail to meet the admission standards into the ADF. However, these applicants are entitled to be assessed on their individual merits and, if they fail, to fail on the basis of their individual failure to meet specific medical or fitness or suitability standards that apply to all applicants and not because they fall within a stipulated age bracket, regardless of their ability to meet the other criteria. Applicants outside the stipulated age bracket who can meet the other selection criteria ought to be admitted for training and not excluded on the basis of an age distinction. For these reasons, I am not satisfied that the exclusion of all persons above the age of 35 years from employment as Administrative Officers in the RAAF is based on the inherent requirements of the job of Administrative Officer. Accordingly, I find that the acts and practices complained of by the complainant constitute discrimination in employment on the grounds of age. The Full Federal Court in its decision of 4 December 1999 concerning the Bradley matter agreed with this reasoning of Wilcox J. Black CJ found that the definition adopted by Wilcox J that is, as requiring a connection that is tight or close sits easily with the language of par (c) and promotes the objects of the Act by closing a path by which consideration of individual merit may be avoided. I therefore agree with his Honour that no error was made by the Commission in its construction of the expression based on for the purposes of par (c) (per Black CJ at 285 and see also Tamberlin J at 288). I awarded compensation by way of general damages for loss of opportunity in each of the Bradley, Barty and Van Den Heuvel matters. Mr Bradley initially sought review in the Federal Court of the amount of compensation awarded but the application was not pressed. No further applications in respect of the manner of calculating compensation were made. I have set out my reasoning in relation to the calculation of general damages in my notice in the Van Den Heuvel matter at Appendix D. Action taken by the ADF as a result of my findings and recommendations Under section 35(e) of the Act I am required to state in my report to the Attorney-General whether the ADF has taken or is taking any action as a result of my findings and recommendations. As indicated above, following the issue of my notices in each of the above matters (except for Mr Van Den Heuvels complaint in which liability was conceded), the ADF commenced Federal Court proceedings seeking judicial review of my findings. On 4 December 1999 the Full Federal Court upheld the decision of Wilcox J at first instance which had upheld my findings and recommendations in the Bradley matter. Federal Court proceedings in the Barty and Petersen matters were then discontinued. Following the conclusion of the various Federal Court proceedings, I wrote to the ADF to seek its advice as to what action it had taken or proposed to take as a result of my findings and recommendations. I was advised in relation to Mr Bradleys complaint that the sum of money awarded as general damages had been paid in relation to Mr Bartys complaint that the sum of money awarded as general damages had been paid in relation to Mr Van Den Heuvels complaint, that the sum of money awarded as general damages had been paid, that an apology to Mr Van Den Heuvel from Air Vice-Marshal Titheridge, Acting Chief of the Air Force, had been sent and that the upper age limit for loadmasters was being reviewed. Further, in relation to the Bradley, Barty and Petersen matters generally, I was advised that a review was undertaken to develop revised age guidelines for entry into the ADF which, wherever possible, would replace age-based criteria with merit criteria certain age limitations would continue to apply taking into consideration the rigours of military training and the physical impacts that such training can have on individuals as they age and the legal occupational health and safety duty of care obligations the review process has resulted in a paper that will be presented to the Chief of Staff Committee (COSC) by the end of June 2000 clearance by COSC will be followed by the promulgation of a Defence Instruction (General) giving effect to the new policy which is expected by the end of October 2000 this process is in relation to entry to the ADF only and does not deal with transfer between services or promotion. These matters will be separately considered when the current review is finalised. Endnotes  I have referred throughout to the respondent to the various complaints as the ADF although technically the respondent is the Commonwealth of Australia.  Ratified by Australia in 1973.  Notified in the Commonwealth of Australia Gazette on 21 December 1989.  Koowarta v Bjelke-Petersen & Others (1981) 153 CLR 168 at 265 (Brennan J); Minister for Foreign Affairs and Trade & Ors v Magno and Another (1992) 112 ALR 529 at 535-6 (Gummow J).  International Labour Conference, Equality in Employment and Occupation: General Survey by the Committee of Experts on the Application of Conventions and Recommendations ILO, Geneva, 1988, at 23.  Ibid, at 138.  Ibid, at 22.  The original appendices to the notices have been omitted as they include material set out in this summary.  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