< PreviousT he 2023 construction season is basically over and it’s time to put away the sweepers, paint machines, and water trucks. The graders will be adorned with their wing plows, loader plows are being prepped, and the excavator frost buckets are being dusted off. Thank you to all for mak- ing the construction season a successful one! The Saskatchewan Public Works Association (SPWA) is excited for the up- and-coming season. Here is some of what’s been going on – and is still coming up – since the last issue of The Roadrunner: • North Battleford hosted PWS Level 1 in the spring. This is a designation that SPWA now offers, giving participants in the public works sector the opportunity to test their skills while acquiring knowledge and testing all aspects of public works. • National Public Works Week went off without a hitch, and many differ- ent communities in Saskatchewan par- ticipated in the celebration by hosting employee appreciation barbeques, hold- ing information sessions in schools, organizing community clean-ups, and so much more. What better way to ‘Con- nect the World Through Public Works,’ than bringing communities together. • To celebrate public works, the SPWA also hosted a Water Sampling Workshop in Moose Jaw on May 25, 2023. This event focused on the daily water testing and de- chlorination methods that community operators are required to complete to meet the requirements of their operating per- mits. There was a great turnout for the workshop and rave reviews. • On June 14, 2023, we hosted our annu- al golf tournament at Dakota Dunes, which turned out to be an enjoyable day with some great networking. We are looking forward to bringing the SPWA A Message from the Saskatchewan Public Works Association PRESIDENT Staci Dobrescu Moose Jaw PAST PRESIDENT/ APWA COUNCIL OF CHAPTERS REPRESENTATIVE Dale Petrun Saskatoon PRESIDENT-ELECT Vacant TREASURER Stewart Schafer North Battleford DIRECTORS Andrew Stevenson Saskatoon George Jakeman Regina Neeraj Saroj, P.Eng., MBA Regina Eric Quail Saskatoon DIRECTOR – SMALL TOWN (<3000) Tammy Landry Village of Pierceland DIRECTOR - INDIGENOUS Kurt Shukin Northern Village of Sandy Bay DIRECTOR – RM (RURAL MUNICIPALITIES) Barry Wiebe RM of Sherwood SUPPLIER REPRESENTATIVE Rob Lozinski NSC Minerals Ltd. APWA PRESIDENT Keith Pugh, P.E., PWLF Asheville, NC APWA CHAPTER COORDINATOR Rhonda Wilhite Kansas City, MO REGION IX DIRECTOR Kristina Nelson, P.E. Port Orchard, WA CHAPTER ADMINISTRATOR Lindsay Muller Saskatoon Board of Directors Golf Tournament to southern Saskatch- ewan next year. • Following the success of the previous Contracts Roundtables, we are running a follow up for Contracts 401 on Septem- ber 29, 2023. Then, on October 19, we will be holding a ‘Large and Small Work Zone Safety’ education session (it is still being determined if it will be online or in person). For more information on the round- tables, education opportunities, golf tour- naments, and conferences, please refer to the SPWA website and join us for one of our events happening this year. Watch your email for more information on these events. (Remember that the discounted rate mem- bers receive at our combined yearly events pays for the annual cost of membership with SPWA). We are looking forward to being able to plan more of these events to benefit our Saskatchewan communities by provid- ing information and assistance to better sup- port their activities. As you can see, the SPWA is endeavour- ing to bring our members and others in the public works profession greater value in educational and networking opportunities. We will also continue to promote profes- sionalism in the public works field, advocate the essential role that public works plays in the quality of life, and promote it as a career choice for the workforce of the future. Visit our chapter website at http:// saskatchewan.apwa.org and check us out on Facebook and Twitter. You can also contact our Chapter Administrator for more information and details about upcoming SPWA events, or how to become an SPWA member. Staci Dobrescu President Saskatchewan Public Works Association The Saskatchewan Chapter strives to promote professionalism in the public works field and provide a network through which members can share and receive useful information. 10 UP FRONTManitoba Chapter Did you know that Manitoba is the longest serving of the Canadian Chapters and has been providing a forum for practitioners since 1955? We actively support our membership, the public, and policy makers to collaborate and maintain healthy communities throughout the province. Board of Directors PRESIDENT Randy Pitz PAST PRESIDENT Steve Blayney PRESIDENT- ELECT Vacant SECRETARY Lorie Gavelin TREASURER Rob Loudfoot DIRECTORS Jeremy Harrison Bonnie Konzelman Peter McDougall Kevin Medeiros Pam Richardson Ryan Sicinski Darren Wanless Justin Weibe, P.Eng. COUNCIL OF CHAPTERS REPRESENTATIVE Steve Blayney CPWA BOARD OF DIRECTORS REPRESENTATIVE Randy Pitz SOCIAL AND FUNDRAISING COMMITTEE CHAIR Justin Wiebe, P.Eng. EDUCATION AND AWARDS COMMITTEE CHAIR Jeremy Harrison COMMUNICATION COMMITTEE CHAIR Vacant OUTREACH AND STRATEGIC PARTNERSHIPS COMMITTEE CHAIR Randy Pitz ADMINISTRATOR Trina Miller WEBSITE manitoba.apwa.org T he last few months have been exciting for the exposure of the Manitoba Public Works Association and educating the public about who we are. Starting with attending the Association of Manitoba Municipalities (AMM) convention through National Public Works Week, we have been sharing a message about the value of the Canadian Public Works Association (CPWA). As a reminder – public works combines the physical assets, management practices, policies, and personnel needed for the public and private sectors to sustain structures and provide the ser- vices essential to the welfare and high quality of life for our citizens. We are here to work with the various public works agencies to improve the skills and com- petencies of the professionals working for your agencies. The National Board of the CPWA advocates for public works with the federal gov- ernment on the funding needs across Canada. One of the most significant developments has been the proclamation of National Public Works Week by the Province of Manitoba, as well as having the Department of Transportation and Infrastructure join the association as a group mem- bership. This demonstrates their clear support for public works professionals, and we hope to partner with the province in providing training opportuni- ties in the future. Now that the COVID-19 pandemic has moved to another stage of awareness, we have started to see municipalities, towns, and cities once again holding events for National Public Works Week, something that is critical to establishing a connection with the public and educating them about the value public works professionals provide to their daily lives. This also provides us the oppor- tunity to share about careers in public works. Just like our chapter is seeing challenges increasing membership and retaining those who join, public works agencies are also facing a larger problem of recruiting for all positions, but in particular, operators. We look at Public Works Week as a huge occasion to work with these agencies and other associations to showcase the opportunities in public works to school age kids, with the message that you can have a career right in your community after you graduate. A Message from the Manitoba Public Works Association This workforce shortage is not only in careers as operators and other public works profes- sionals, but also in the registration at technical schools in Civil Technology Co-op programs. In conversations with Certified Technicians and Technologists Association of Manitoba (CTTAM), several factors have contributed to this shortfall, such as the pandemic, which cancelled career fairs and denied public works a major source of outreach to schools. The Manitoba Chapter will continue collaborat- ing with CTTAM to discuss how we can work together to meet these challenges. CTTAM is also interested in exploring professional develop- ment opportunities to their members by partner- ing with our chapter. Another interesting partnership is with Engineers and Geoscientists Manitoba and its Manitoba Climate Resilience Training (MCRT) Infrastructure project. We will work with them on marketing, training, and visibility to our members. Right now, our board is finalizing plans on how we can continue building on our rec- ognition and partnerships, and the Manitoba Chapter is starting to plan for educational opportunities this fall. We are also committed to hosting the Mid Canada Snow Conference in the fall of 2024. We have also updated our website and have a Twitter and LinkedIn pres- ence. Please take a minute and view what we are doing. The Manitoba Chapter has recently elected a new board and we have been joined by pub- lic works professionals from one of Manitoba’s rural municipalities, as well as from the City of Brandon, which will provide us better insights into the needs and challenges of municipalities of all sizes. Along with this greater representation on the board – and in discussion with the Association of Manitoba Municipalities (AMM) – we will explore hosting professional development events in conjunction with the AMM convention and trade show and we will continue to build our strategic partnerships and offerings of professional development learning opportunities. I hope everyone has a great fall. Randy Pitz, CMC President Manitoba Public Works Association 11 UP FRONTT he summer of 2023 has certainly been challenging for our pub- lic works staff members across the province, and many of them have been asked to take on tasks outside of the norm. But this really is the hallmark of a public works staff member, and they have the skills, ability, and the grace to do what needs to be done. This is what I have come to know about this special group of people – that they are continually there to help the people of their communi- ties get through situations, from wildfires to floods. For those who may not know us already, the Alberta Municipal Supervisors Association’s (AMSA) mission is to unite members towards individual develop- ment, improved service to their munici- pality and the public, and to improve the members’ knowledge related to their role in public works. AMSA provides a forum for exchange, both online and in person at con- ventions, and the development of innovative ideas, as well as offers various professional development opportunities. I do encourage you to visit our website www.amsapw.ca to learn more about AMSA’s 40-plus-year his- tory of advocacy, sharing best practices, and training. Each year, AMSA hosts a spring and fall conference at the Edmonton Convention Centre with various presentations and guest speakers. For this fall’s lineup on November 7-9, 2023, we have Justin Yaassoub and A Message from the Alberta Municipal Supervisors Association High-Performance Leadership, as well as Jeanette Austin with a workshop on Wellness in Leadership. Our legal presenta- tion will focus on working alongside private property, right of ways, and other prop- erty issues that may come up. Typically, the group also reviews new legislation and technologies, as well as examines manage- ment strategies beneficial to both seasoned public works professionals and newcomers to the field. We are also hoping to include some water / wastewater information, as well as some interesting project profiles. I hope what remains of the construction season of 2023 will be more conducive to completing all the projects that we have lined up. There are many things on the to-do list for our public works staff members and they are all important tasks that help keep our communities functioning all year round. On behalf of AMSA and its more than 150 members, thanks goes out to our dedi- cated group of executives and directors for keeping the membership engaged and con- ventions interesting. And a final thanks to the associations’ many sponsors that assist with offsetting the costs on conventions and allow AMSA to keep its annual membership fees low and conventions accessible to more than 70 rural municipalities. Shaune Kovitch AMSA President Alberta Municipal Supervisor’ Association PRESIDENT Shaune Kovitch Special Areas Board PAST PRESIDENT Joe Duplessie Lac Ste Anne County VICE PRESIDENT Travis Wierenga County of Barrhead SECRETARY Zach Mazure Camrose County TREASURER Brandon Maier Lacombe County DIRECTORS, ZONE 1 Craig Pittman MD of Willow Creek Devon Thiele Lethbridge County DIRECTORS, ZONE 2 Erik Hansen Clearwater County Brad Plehnert County of Stettler DIRECTORS, ZONE 3 Curtis Creaser Athabasca County Wayne McLean County of Thorhild DIRECTORS, ZONE 4 Leonard Van Oort County of Northern Lights Josh Friesen MD of Greenview DIRECTORS, ZONE 5 Martin Biro MD of Provost Norm De Wet County of Minburn EXECUTIVE DIRECTOR Christine Heggart 403-845-4444 cheggart@amsapw.ca EXECUTIVE ASSISTANT Jennifer Mazurek jmazurek@amsapw.ca Board of Directors & Staff AMSA’s mission is to unite members towards individual development, improved service to their municipality and the public, and to improve the members’ knowledge related to their role in public works. AMSA provides a forum for exchange, both online and in person at conventions, and the development of innovative ideas, as well as offers various professional development opportunities. At conventions, AMSA members review new legislation and technologies, as well as examine management strategies beneficial to both seasoned public works professionals and newcomers to the field. 13 UP FRONTplanned to give them a chance to stretch, move around, change their body position, or get off their feet. For workers operating equipment or machinery, provide built-in foot rails or por- table footrests so they can shift body weight from one leg to the other. Effective job design also includes varying tasks that require changes in body position and using different muscles. Job rotation and teamwork are both ways to make work easier on the feet by alternating work tasks. Adjusting work practices A well-designed workplace combined with a well-designed job makes it possible to work in a physically balanced position with- out unnecessary strain on the body. Education and training will help the individual work safely, so they learn how to properly stand, move, or lift. Worker education and training should also address how to adjust specific work of a workplace ergonomics program, regular ergonomic assessments should be done to optimize workstations and the work environ- ment. Solutions should focus on physically removing the hazard wherever possible, fol- lowed by improving work design, adjusting work practices, and lastly, providing protec- tive equipment to support the worker. The program should also include worker educa- tion on the risk factors of prolonged stand- ing, and how to prevent them before any signs and symptoms develop. Improving workplace design It may not be possible to eliminate the need to stand on the job. But in a well- designed environment, workers should be able to frequently change among a variety of well-balanced positions. Where possible, a seat should be pro- vided to allow the worker to sit occasionally. When sitting can’t be incorporated into a worker’s job, regular rest breaks should be W hat do road workers and public works employees have in common with nurses, retail salespeople, cashiers, servers, and assembly line workers? The nature of their work keeps them on their feet and standing for prolonged periods of time. Even though standing is a natural human posture, it can become a health haz- ard if a worker must remain on their feet for extended periods of time without getting some relief by changing positions, walking, or occasionally sitting. Prolonged standing can lead to sore feet, swollen legs, and vari- cose veins. It can also cause issues in other parts of the body, such as lower back pain, stiffness in the neck, and general muscular fatigue. Eventually over time, it can even develop into rheumatic diseases due to ten- don and ligament damage. Eliminating hazards at the source is always the most effective solution. As part Get on the Right Foot By Canadian Centre for Occupational Health and Safety (CCOHS) Standing at Work: 14 IN EVERY ISSUE • Safety Reportmove – pain and fatigue result if shoes are too narrow or too shallow. When selecting footwear, it’s important to consider that feet naturally swell and contract throughout the day. Footwear that is too tight is unlikely to stretch with wear. Feet normally differ in size, so remind workers to have both feet measured when buying shoes, and to fit the bigger foot. Feet are likely to be swollen to their maximum size late in the afternoon. A well-designed job and workplace are essential to healthy and safe work. By recog- nizing ergonomic risks, you can help iden- tify and address the hazards that can lead to discomfort and injuries in workers whose jobs keep them on their feet. w The Canadian Centre for Occupational Health and Safety (CCOHS) promotes the total well-being – physical, psychosocial, and mental health – of workers in Canada by providing information, advice, education, and management systems and solutions that sup- port the prevention of injury and illness. Visit www.ccohs.ca for more safety tips. time standing on the job. Since the human foot is designed for mobility, maintaining an upright stance can be extremely tiring. Selecting the right footwear can help. Choose footwear according to the haz- ards at your workplace. Safety footwear, if required, should be CSA approved and carry the proper ratings for the hazard. Where the ground is hard, thick insulating soles and shock-absorbing insoles should be worn. The footwear should also provide ade- quate arch and heel support and cushioning while still being comfortable. Footwear that fits poorly or needs repair contributes heavily to foot discomfort. Pointed toes and high heels are particularly inappropriate as working foot- wear, though a small heel can decrease strain on the Achilles tendon and allow for more comfortable walking and standing. Footwear should also follow the natural shape of the foot. If the back of the shoe is too wide or too soft, the shoe will slip, caus- ing instability and soreness. It’s also a good idea to choose a pair with a firm grip for the heel. Toes should have the freedom to environments to the individual’s needs, which for road workers and public works employees, likely includes training on when to change positions and incorporate rest, and how to recognize early signs of injury and alert a supervisor. Rest periods are essential elements of the workday and should be provided to the worker so they can relax when muscles are tired, to move around when muscles are stiff, and to walk when work restricts the ability to change postures or positions. Employers must inform workers about health hazards in the workplace, including body movements and positions that can cause discomfort and potentially lead to chronic injury over the long term. They should also encourage workers to report any discomforts experienced during work. Reporting can help to identify ways to cor- rect working conditions. Factor in footwear Aching, flat, or tired feet are common among workers who spend most of their 15 IN EVERY ISSUE • Safety Reportright to participate in their workplaces and ask questions when they’re not sure how to do something,” adds Jones. “But further to that, workers should be empow- ered to propose solutions or ideas for how to do something more safely. This not only keeps them safe, but also keeps their coworkers safe.” Workers should stop work, or have col- leagues stop work, if they feel something is posing a health and safety risk. Workers should also immediately report health and safety concerns to a supervisor – and employers and supervisors should encourage this behaviour and respond accordingly. Even seasoned workers may need to undergo re-orientation when their work conditions change, or new hazards arise, like adapting to new work processes or equip- ment, moving to a different work site, or being assigned a different or new task. If you’re an employer, supervisor, or trainer, WorkSafeBC’s New and Young Worker Orientation Checklist can be cus- tomized for your workplace and used as part of your onboarding program. See something? Say something “We also want to reiterate to employ- ers that new and young workers have a M any employers, including municipalities, employ new and young workers. While workers of all ages can be injured at work, new and young workers need special atten- tion because they may be more at risk of injury then their more experienced coun- terparts – with young males seeing a sig- nificantly higher injury rate than the overall workforce. “When bringing in new and young workers, employers must identify the haz- ards in a workplace and give clear direc- tion on how to work safely,” says Alison Jones, Manager of Occupational Health & Safety Consultation and Education Services at WorkSafeBC. “It’s just as critical however to encourage new and young workers to ask questions about health and safety and voice their concerns.” More than half of all serious injuries occur during the first six months of employ- ment. Many of these injuries result from inadequate training, orientation, supervi- sion, inexperience, or a reluctance to raise health and safety concerns. In municipali- ties, the most common accident types for young workers are falls (at same level and from elevation), overexertion, and being struck by / against something. Last year, WorkSafeBC accepted 7,437 claims related to injuries from young work- ers. In the last five years alone, 15 young workers have died in workplace incidents. The importance of orientation and training Jones emphasizes that proper orienta- tion and training is crucial in preventing workplace incidents with young and new workers. “Employers must prepare workers for their roles before they begin working. Training should be tailored to the specific workplace and should continue as an ongo- ing process.” Safeguarding New and Young Workers By Alexandra Skinner, WorkSafeBC The Occupational Health and Safety Regulation defines a ‘young worker’ as any worker under age 25. A ‘new worker’ can be any age and includes those who are new to the workplace or location or facing new hazards. Photo courtesy of WorkSafeBC 16 IN EVERY ISSUE • Safety ReportAll employers must also have a system in place for workers to report health and safety concerns. Creating a strong workplace health and safety culture Jones says that workplace culture is influenced by many things, including lead- ership, management, and supervision styles and priorities, peer pressure, workplace con- ditions, design, and production logistics. “A safety culture means that workers actively participate and feel heard, valued, and respected,” explains Jones. “This is espe- cially crucial during labour shortages across various industries. Establishing a safety culture helps employers retain employees and cultivates a positive work environment where people want to be.” There are a few simple ways employers can encourage a culture of health and safety in their workplaces and engage new and young workers. • Conduct a 5-minute safety meeting every morning and ask workers to talk about safety concerns. • Take a walk across your worksites to identify potential risks together. • Review your joint health and safety com- mittee action items as a team. • Have an annual safety culture survey that asks staff to bring forward ideas. Choose one or two suggestions that will have a positive impact on the health and safety of workers and do something about them. These actions will show your workers that something happens when they bring concerns forward. • Encourage workers to report near misses to their supervisors, along with any ideas they may have to prevent future near misses. WorkSafeBC offers resources on its website, including Support for employers: Training and orientation for young and new workers.1 w Alexandra Skinner is the manager, govern- ment, and media relations, at WorkSafeBC. Reference: 1. https://www.worksafebc.com/en/resources/health-safety/books-guides/support- for-employers-training-and-orientation-for-young-and-new-workers?lang=en&_ ga=2.247495047.1411137630.1685399279-1435394991.1681339638 17 IN EVERY ISSUE • Safety Reportlow bidder; however, after the revisions were introduced, another bidder was the low bid- der. No opportunity was given to the bidders to revise their bids. The Court considered that the changes in scope after bid closing were a serious interference with the tendering process. Relying on Ron Engineering, the Court found that the tender and the contract documents did not permit the City to delete the items from the tender before acceptance. The privi- lege clause included in the tender reserved the City’s right to reject any or all bids or to accept any bid, but it did not give the City the right to delete major items of the tender. Such rights, the Court noted, would have arisen after the construction contract was made and only upon payment of compensation for the deletion of any major item. Dolyn Developments Inc. v Paradigm Properties Inc.8 illustrates conduct that was found to be supported by the tender process and documents. The case involved a construc- tion contract for an office space. All bidders submitted bids that were above the budget for the project. The owner engaged in nego- tiations with the lowest bidder, who proposed two cost-saving modifications to the scope of work and a reduced price. The owner asked the lowest bidder if it could provide the revised work at a lower price and, upon the lowest bidder’s refusal, the owner cancelled the tender and proceeded to negotiate with other bidders fairly and equally, and an obligation on the selected bidder to enter the work contract if selected.3 This duty of fairness owed by the owner to the bidders manifests in different ways, including the duty to award Contract B as tendered. This means that a Contract A / Contract B tender process requires the owner to pre-establish the terms of the tendered con- tract and limit changes after bid closing so that the bidders can submit their bids on the established terms and assumptions.4 As a result of this duty to award the contract as tendered, the owner is constrained from making material changes after the closing date of the tender.5 Owners must take great care when intending to stray from the terms of the tendered contract in a formal tendering process.6 An illustration of conduct that amounts to impermissible change is provided by the case of Ben Bruinsma & Sons Ltd. v Chatham (City). 7 In this case, the Court held that the City was not entitled to make substantial changes to the tendered contract after the receipt of bids. The tendered contract was for providing sod- ding or seeding services at a soccer field. After the tenders were opened, the City realized that considerable savings could have been made if certain items of work had been deleted from the tendered contract. The City proceeded to make the changes to the scope of work, before awarding the contract. Prior to the scope of work changes, the plaintiff bidder was the T ender law imposes strict rules on the tendering process that owners must follow. These rules restrict the owner’s conduct, and a breach of these rules may give rise to claims by bidders. While an owner’s needs or circum- stances in relation to the proposed project may change during the tendering process, the owner must observe limitations that operate for pro- curing entities in such situations or risk a poten- tial claim from aggrieved bidders. This article will discuss what owners can and cannot do when contemplating a change in course while the tender remains in full swing. This discussion is equally important for contractors wanting to understand their rights under the tender law. A duty of fairness In a tender process, the two-contract model established in R v Ron Engineering & Construction (Eastern) Ltd.1 applies, which pro- vides that once bids are submitted in response to an invitation to tender, a contract is formed (Contract A) between the owner and each compliant bidder. Contract A is to be dis- tinguished from the work contract (Contract B) to be entered into by the owner and the one selected compliant bidder. Contract A is governed by both express and implied terms,2 which are meant to preserve the integrity of the tendering process by imposing an overarching obligation on the owner to treat all bidders By Sonia Sahota & Marcela Ouatu, Civic Legal LLP Changes to the Tendered Contract After the Closing Date: What is Permissible? Changes to the Tendered Contract After the Closing Date: 18 IN EVERY ISSUE • Legal Brieflaw, owners have at least two avenues: (1) to reject all tenders and cancel the tender, if the tender documents reserve this right to the owner, and re-tender the project on a revised scope of work; or (2) award the contract as tendered to the selected bidder, and make changes to the scope of work, if the contract so permits, in exchange for compensation for the deleted items of work. w This article is intended for the general infor- mation of organizations in British Columbia. If your organization has specific issues or concerns relating to the matters discussed in this article, please consult a legal advisor. Marcela Ouatu is an Associate Solicitor and Sonia Sahota is a Senior Solicitor and cur- rent managing partner at Civic Legal LLP, a British Columbia law firm with expertise in municipal law, land development, construc- tion, procurement, and complicated contract on a modified scope of work. The contract was awarded to a party other than the original low bidder. The Court found that the owner’s conduct did not amount to unacceptable and unfair treatment of the bidders since all bids were clearly rejected, as was permitted under the tender’s privilege clause, and thus, all par- ties were relieved of their respective obligations under Contract A. Final thoughts The take-away from the case law is that owners are constrained under the tender pro- cess in their actions in response to chang- es that impact the tendered contract. The duty to treat all bidders fairly and equally is essential to preserving the integrity of the tendering process, which intends to replace negotiation with competition.9 In order to make changes that will affect the terms of the tendered contract, as suggested by the case References: 1. R v Ron Engineering & Construc- tion (Eastern) Ltd., [1981] 1 SCR 111 (SCC) 2. M.J.B. Enterprise Ltd. v Defence Con- struction (1951), [1999] 1 SCR 619 (SCC) 3. Martel Building Ltd. v R., 2000 SCC 60 4. Paul Emanuelli, Government Procurement, 4th ed. Lexis Nexis (2017) at pg. 833 5. Ibid 6. Ibid at pg. 834 7. Ben Bruinsma & Sons Ltd. v Chatham (City), [1984] OJ No. 978 8. Dolyn Development Inc. v Paradigm Properties Inc., [2007] OJ No. 63 9. Supra note 2 at para. 41 matters. Visit www.civiclegal.ca for contact and additional information. 19 IN EVERY ISSUE • Legal BriefNext >