No. 12-Page Limits and Formatting Requirements

1. Purpose

This Rule of Procedure establishes page limits and formatting requirements for written submissions filed with the Canada Industrial Relations Board (the Board).

These requirements are intended to promote the fair, efficient and expeditious conduct of proceedings before the Board while ensuring that parties have a reasonable opportunity to present their positions.

Parties are expected to present clear, concise and relevant submissions, avoid unnecessary repetition and focus their arguments on the issues that are material to the resolution of the matter.

2. Scope of Application

This Rule of Procedure applies to all applications and complaints filed with the Board (or referred to the Board by the Head of Compliance and Enforcement), as well as the responses and replies related to those applications and complaints, except for certain proceedings under the following provisions of the Canada Labour Code:

1. Applications for review of bargaining units or bargaining unit structure  (sections 18 and 18.1);
2. Longshoring and geographic certification applications (section 34);
3. Single employer applications (section 35);
4. Sale of business, transfer and related applications (sections 44, 45, 46 and 47);
5. Bargaining in bad faith complaints (section 50); and
6. Maintenance of activities applications (section 87.4).

The Board may, on its own initiative or at the request of a party, vary the requirements set out in this Rule of Procedure where the circumstances warrant it.

3. Page Limits

Unless otherwise directed by the Board, the following page limits apply to written submissions:

1. Application or complaint: 30 pages
2. Response: 20 pages
3. Reply: 15 pages

These limits apply only to the written submissions themselves, including statements of facts, arguments and representations made by the parties.

The following documents are excluded from the page count, unless otherwise directed by the Board:

1. cover pages;
2. tables of contents;
3. affidavits and sworn statements;
4. exhibits and documentary evidence;
5. appendices;
6. books of authorities and lists of authorities; and
7. other supporting documents filed in connection with the written submissions.

Parties are also expected to ensure that supporting documents are relevant to the issues in dispute and to avoid filing unnecessarily lengthy, duplicative or irrelevant material.

Supporting documents must not be used to circumvent the applicable page limits by including arguments or representations that should properly form part of the written submissions.

Replies should generally be limited to addressing matters and arguments raised in the response and should not be used to introduce new arguments that could reasonably have been raised in the original application or complaint.

Note: Written submissions of intervenors on the merits of a case and responses to an intervenor’s submissions on the merits of a case submitted pursuant to section 12.1(5) and (6) of the Board’s Regulations are subject to page limits of 20 pages and 15 pages for all applications and complaints covered by this Rule of Procedure. 

4. Formatting Requirements

To ensure consistency and readability, written submissions filed with the Board must comply with the following formatting requirements:

1. Page size: letter size, measuring 21.6 cm by 27.9 cm (8.5 inches by 11 inches);
2. Legibility: text must be presented in a clear and legible format;
3. Font size: the main body of the text must be in a font size of at least 12 points;
4. Footnotes: footnotes must be in a font size of at least 10 points;
5. Margins: margins must be at least 2.54 cm (1 inch) on all sides of the page (top, bottom, left and right); and
6. Page numbering: all pages of the written submissions must be numbered consecutively.

Parties must comply with these requirements to facilitate the review of submissions by the Board and the other parties to the proceeding.

5. Requests to Exceed Page Limits

In exceptional circumstances, a party may seek permission from the Board to exceed an applicable page limit. 

A request for authorization must be made as soon as the party considers it necessary to exceed the applicable page limit and, in any event, at least three business days before the filing deadline.

The request must:

1. identify the applicable page limit;
2. specify the total number of pages proposed, and the number of additional pages requested; and
3. provide clear and specific reasons explaining why the additional pages are necessary.

The request must be provided to the other parties in accordance with the applicable filing and service requirements. Other parties may submit observations to the Board on the request for authorization within 24 hours of receiving a copy of the request. If they do so, they must provide a copy of their observations to the requesting party and any other parties pursuant to the Board’s service requirements. 

The Board will consider each request considering the circumstances of the case, including the nature and complexity of the matter and the need to ensure the fair and efficient conduct of the proceeding.

Parties must comply with these requirements and should not assume that authorization to exceed a page limit will be granted.

6. Non-Compliance

Parties must comply with the page limits and formatting requirements established by this Rule of Procedure unless otherwise authorized by the Board.

Where a document does not comply with these requirements, the Board may, as appropriate:

1. require the party to file a revised version of the document that complies with the applicable requirements;
2. decline to consider any pages exceeding the applicable page limit; or
3. issue any other direction it considers appropriate to ensure the fair and efficient conduct of the proceeding.

7. Board's Discretion

The Board retains the discretion to vary or waive any requirement under this Rule of Procedure where the circumstances warrant it, in accordance with its powers under the Canada Labour Code and the Canada Industrial Relations Board Regulations, 2012.

8. Coming into Force and Transitional Provisions

This Rule of Procedure comes into force on January 1, 2027.

It applies to proceedings commenced before the Board or referred to the Board on or after that date.