Describe the similarities and differences between the Canadian labor relations system and the U.S. labor relations systems.

Canada and the U.S. have a similar foundation for labor relations systems but there are some distinct differences in the details. Structurally, U.S. and Canadian firms and unions are very similar and operate under similar market conditions. The Canadian labor law is patterned after the Wagner Act and includes exclusive representation, similar bargaining structures and strategies, and union contracts are very similar. However, the Canadian labor law is not as centralized as the U.S. with each of the provinces making different decisions on a variety of factors. Some provinces, for example, provide for card check recognition, instant elections, and first contract arbitration. Canada does not have right-to-work laws and some provinces do not allow decertification elections during a strike or permanent strike replacements (and some do not even allow temporary strike replacements). Most strike replacements are not considered part of the bargaining unit and are not allowed to vote on union matters. Hence, there are some striking contrasts between the U.S. and Canadian systems of labor relations.