Bill on independent labour | The APTS criticizes Bill 10 for its glaring omissions

March 14, 2023

Image Bill on independent labour | The APTS criticizes Bill 10 for its glaring omissions

Québec City – On day one of special consultations on Bill 10 (the Act limiting the use of personnel placement agencies’ services and independent labour in the health and social services sector), the APTS (Alliance du personnel professionnel et technique de la santé et des services sociaux) suggested improvements to ensure that the public system’s release from the private sector is permanent and carried out in the most appropriate way. Addressing MNAs in a parliamentary committee, the union noted that urgent action to improve the working conditions of health and social service employees was first and foremost among these improvements.

The APTS began by saying that it welcomed the government’s commitment to limit the privatization of care provided by the health and social service system. “We agree that reducing the use of independent labour will have a positive impact on public finances,” said APTS president Robert Comeau.

However, the APTS believes that major omissions in the bill may undermine the government’s ability to reach its objectives. “Bill 10 puts the cart before the horse,” said the APTS president. “To end the system’s dependence on placement agencies, the government needs to recognize the value of work carried out in our public system, provide employees with better working conditions, and make sure they can achieve an appropriate balance between work, family, and personal life. We need to break the vicious circle of reliance on the private sector as soon as possible; otherwise, in 2026, we’ll find that subcontractors are used as often or even more often than today.”

The APTS presented nine recommendations to strengthen governance and make the health minister more accountable for the work of supervising the role played by agencies. The union also emphasized the fact that the bill does not deal with services (as opposed to labour) that are purchased by institutions. This leaves the door wide open to the private sector, especially with regard to services provided by professional and technical employees.

A plea for transparent governance and accountability

The APTS is seriously concerned to see how Bill 10 concentrates the responsibility for supervising the use of independent labour in the hands of the health minister. The minister will adopt regulations defining how agencies can be used, without being accountable to the National Assembly in this respect. That is why the union is urging the government to include in the bill the rules that would have been defined by regulation.

“To reach an accurate assessment of this bill, there needs to be a debate at the National Assembly about the exceptional circumstances that would allow health and social service institutions to use placement agencies,” explained Robert Comeau. “We’re also suggesting that institutions be audited every three years, that the minister be held to account once a year before a parliamentary commission, and that investigative powers be given to the Auditor General to make sure there’s no appearance of a conflict of interest.”

Bill 10 fails to deal with the purchase of services

For the largest union representing Québec’s health and social service professionals and technicians, there is also a need to deal with the services purchased from private suppliers such as radiology clinics or private labs. Close to $200 million was spent on services in 2021-2022, solely for technical medical services. Bill 10’s silence on this topic is highly problematic in the context of a transition intended to wean the public system from its dependence on the private sector.

“The private sector is draining the blood of our public system, making a profit off people who are waiting for tests or a diagnosis,” said Robert Comeau. “We can’t free ourselves from the private sector by closing the door to agencies while leaving the back door open for private labs and medical imaging clinics. We have to stop feeding a parallel system and invest in our public services to make sure Quebecers are provided with full access to the high-quality care they have a right to expect.”

Over the past six years, the money spent across Québec on independent workers hired to fill professional and technical positions (Class 4 personnel) has increased tenfold, with the total cost for Class 4 independent workers rising from $7.7 million in 2015-2016 to $89 million in 2021-2022. The amount spent on services went up from slightly over $100 million to $200 million over the same period.


The APTS (Alliance du personnel professionnel et technique de la santé et des services sociaux) represents more than 65,000 members who play a key role in ensuring that health and social services institutions run smoothly. Our members provide a wide range of services for all Quebecers, including diagnostic, rehabilitation, nutrition, psychosocial intervention, clinical support, and prevention services.