20 March, 2018
FSA's submission to DoL & the portfolio committee on labour on the National Minimum Wage Bill
attached for your information our Submission on the National
Minimum Wage Bill.
Submission provides a detailed analysis of our views on the
implementation of the NMW, motivations for changes thereto
In brief, the following are the
main recommendations that we have made:
- The implementation of the NMW be
put on hold until the economic environment improves to an
extent whereby the unintended consequences thereof will be
- Whenever the NMW is implemented,
the phasing in period (currently 90% of wage in May 2018,
moving to 100% of the wage in May 2019) be extended over a
minimum period of three years.
- The deductions currently
allowable in terms of the Sectoral Determination
vis à vis the provision of accommodation (max 10%
of wage), food (max 10% of wage), repayment of loans and
credit extended to workers and deductions that an employer
is required to make in terms of a Court or arbitration
award, be provided for in the NMW regulations.
- The annual review of the newly
established NMW Commission include the impact of the NMW
of employment levels and that representation thereof
include those who can speak on behalf of the unemployed.
- The exemption process be made
considerably easier and allow for non "employers'
organisations", such as FSA, to apply for "blanket
- The definition of "farm worker"
be extended to include workers working in "on site"
primary forestry processing facilities (e.g. sawmills,
mining timber mills, pole treating plants and charcoal
plants). This will allow their wages to be set at the
same level as those currently applicable to "forestry
workers" working in plantations.
Submission on National Minimum Wage
Forestry South Africa
Tel:+27 33 346 0344
Fax: +27 33 346 0399