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[2026] FWC 697
General information, not legal advice.
Fair Work Commission
2026-03-04
Original judgment source is linked above.
s.739 - Application to deal with a dispute
Dispute about matter arising under an enterprise agreement - alleged failure by employer to consult over changes to recruitment practices - whether the enterprise agreement required the employer to consult with employees and the union regarding the changes - relief sought in nature of declaratory order or advisory opinion - dispute resolved between the parties for practical purposes - lack of utility in making determination - consultation not required in any event
[1] Airservices Australia Pty Ltd is a government-owned organisation responsible for managing air traffic in Australia and for providing aviation rescue and firefighting services. It operates the Aviation Rescue Fire Fighting Service (ARFFS) at 27 aerodromes in Australia. There is a fire station at each aerodrome, managed by an Aerodrome ARFFS Line Leader (AALL).
[2] The AALL is the first level of ARFFS management at an aerodrome. They are responsible for the day-to-day operational and administrative running of the fire station, and have certain responsibilities in the event of an incident at the aerodrome (for example, a plane crash or a fire at the terminal). While the "core" hours of the position are 9.00 to 5.00, Monday to Friday, the AALL is required to be on call at all other times (when not on leave) to respond to incidents. It is not a requirement of the role that the AALL perform "on the ground" firefighting duties.
[3] The Civil Aviation Safety Authority (CASA) is a statutory authority responsible for ensuring the safety of aviation in Australia. It requires Airservices to have a dedicated AALL at each aerodrome.
[4] Historically, Airservices had a permanent full-time AALL at each aerodrome. Any vacancies which arose were filled through internal recruitment. However, over the years it has become more difficult for Airservices to fill vacancies on a permanent basis. Employees from the firefighting workforce have instead been placed into vacant AALL roles on short-term secondments. Despite several internal recruitment campaigns over recent years, as at May 2025, 16 out of 27 AALL positions were occupied by employees on secondment.
[6] At a meeting on 16 May 2025, Airservices informed the United Firefighters' Union of Australia - Aviation Branch (UFUA) of its decision. During the meeting, the UFUA raised a number of concerns with the external recruitment of AALLs. It also contended that Airservices was required to consult with its employees and the UFUA about the matter, under clause 15 of the Airservices Australia (Aviation Rescue and Fire Fighting) Enterprise Agreement 2024-2027 (Agreement), prior to taking any action to implement the decision. Airservices expressed its view that the circumstances did not give rise to an obligation to consult under clause 15.
[7] On the same day, Airservices commenced advertising externally for AALL candidates.
[8] Correspondence between the parties after 16 May 2025 failed to resolve the dispute. Consequently, on 8 July 225 the UFUA made an application under section 739 of the Fair Work Act 2009 for the Commission to deal with the dispute (Application). In broad terms, the Application reiterated the UFUA's position that clause 15 of the Agreement required Airservices to consult with its employees and the UFUA in relation to the planned external recruitment of AALLs, and that proceeding with that recruitment would be in breach of the provision. The UFUA sought an order from the Commission that Airservices cease the implementation of its proposal until it had engaged in consultation as required by clause 15.
[10] In the meantime, Airservices prepared a Safety Case Assessment and Reporting Determination (SCARD), which was in the nature of a risk assessment regarding external AALL recruitment. The SCARD identified that a hazard that might arise was that external applicants may not hold extensive experience in aviation-related operating environments. The SCARD listed a number of "controls" in relation to that hazard, one of which was the development of an induction program to address, amongst other things, any experience-based skills or knowledge gaps.
"As discussed at the meeting today, CASA is aware of the Airservices ARFFS approach to undertake external recruitment for ARFFS Aerodrome Line Leader positions where successful applicants must:
CASA has not identified any compliance concerns, at this stage, based on information provided by Airservices (SCARD 2025_911 and External LL Induction program v2)."
[12] In August 2025, Airservices completed the recruitment process it had commenced in May. One internal candidate and seven external candidates were offered and accepted employment as AALLs.
[13] As at 21 November 2025, there remained eight vacant AALL positions.
[14] To provide context to what follows, clause 15 of the Agreement is relevantly in these terms:
(a) changes to work practices which materially alter how an employee carries out their work;
(b) changes to or the introduction of policies or guidelines relevant to workplace matters (unless the changes are minor or procedural);
(c) major change that is likely to have a significant effect on employees;
(d) implementation of decisions that significantly affect employees;
(e) changes to employees' regular roster or ordinary hours of work (subject to any other relevant provisions in this Agreement); and
(f) other workplace matters that are likely to significantly or materially impact employees.
Provisions for consultation on major change and introduction of a change to regular roster or ordinary hours of work of employees
(a) proposes to introduce a major change to production, program, organisation, structure or technology in relation to its enterprise that is likely to have a significant effect on the employees; or
(b) proposes to introduce a change to the regular roster or ordinary hours of work of employees.
15.9 In this clause, a major change is likely to have a significant effect on employees if it results in, for example:
(a) the termination of the employment of employees; or
(b) major change to the composition, operation or size of the employer's workforce or to the skills required of employees; or
(c) the elimination or diminution of job opportunities (including opportunities for promotion or tenure); or
(f) the need to relocate employees to another workplace; or
15.10 The following additional consultation requirements in clauses 15.11 to 15.18 apply to a proposal to introduce a major change referred to in clause 15.4(c).
The UFUA's proposed questions for determination
[15] The UFUA submitted the following "Questions for Determination":
"1. In respect of its decision to expand recruitment for Aerodrome ARFFS Line Leader roles to external candidates (including those without Airservices ARFFS experience), conduct a national advertising campaign for those roles; and employ external candidates into those roles (including candidates without ARFFS experience), was the Respondent required to comply with clause 15 of the Airservices Australia (Aviation Rescue and Fire Fighting) Enterprise Agreement 2024-2027?
2. If the answer to question 1 above is, 'Yes,' in implementing that decision did the Respondent fail to comply with:
a. clause 15.4, by failing to provide employees and the Applicant a genuine opportunity to influence the decision prior to a decision being made
b. clause 15.4, by failing to provide all relevant information to employees and the Applicant in a timely manner to support consideration of the issues;
c. clause 15.4, by failing to consider feedback from employees and the Applicant in the decision-making process;
d. clause 15.4, by failing to advise employees and the Applicant how their feedback was considered in the decision-making process;
e. clause 15.11, by failing to consult prior to a decision being made;
f. clause 15.12, by failing to appoint a primary point of contact and provide their details to employees and the Applicant;
g. clause 15.13, by failing to notify employees and the Applicant of the proposal to introduce major change until after the decision had been made;
h. clause 15.14, by failing to discuss with affected employees and the Applicant the proposed change, the effect the change was likely to have on employees, and proposed measures to avert or mitigate adverse effects, and by failing to provide any relevant information in writing for the purpose of those discussions; and/or
i. clause 15.15, by failing to give prompt and genuine consideration to the matters raised about the major change by the Applicant in its correspondence between 2 and 13 June 2025."
"The questions for determination concern whether the Respondent was required to, and failed to, comply with cl 15 of the Enterprise Agreement in respect of its decision to expand recruitment for Aerodrome ARFFS Line Leader (AALL) roles to external candidates (including those without ARFFS experience), advertise for those roles, and employ external candidates into those roles (including candidates without ARFFS experience) (Decision).
Those questions should be answered in the affirmative. That is, in respect of the Decision, the Respondent was required to consult in accordance with the Enterprise Agreement, and it failed to do so."
"We are writing to you on a without admissions basis, to commence consultation in relation to a further round of ARFF Line Leader recruitment."
[21] That suggests that the question of whether clause 15 imposes an obligation to consult on the external recruitment of AALLs does not involve an entirely historical analysis, or is a matter of academic interest only.
The dispute has for all practical purposes been resolved
[22] But the dispute regarding the answer to that question has, for all practical purposes, been resolved. In the same letter of 4 November 2025, Mr Firman wrote:
"Airservices does not consider that this change is a 'major change that is likely to have a significant effect on employees' under the Airservices Australia (Aviation Rescue and Fire Fighting) Enterprise Agreement 2024-2027 and, therefore, there is no obligation to consult prior to a decision being made. However, Airservices has decided that it will consult with the UFUA prior to making a final decision on a without admissions basis." (My emphasis)
"As you know, this matter is currently before the Fair Work Commission and the parties have different views as to the interpretation of the consultation provisions under the Airservices Australia (Aviation Rescue and Fire Fighting) Enterprise Agreement 2024-2027 (EA).
As such, I do not propose to enter into a debate in respect of this, save to say that Airservices does not concede that the external recruitment of ARFF Line Leaders (AALL) constitutes a major change within the meaning of clause 15 of the EA or that consultation is required.
Airservices are nonetheless reaching out to the UFUA in the first instance, in circumstances where the UFUA is actively disputing the external recruitment of AALLs on behalf of its members.
While Airservices does not concede that the consultation obligations under the EA are triggered, it is prepared to proceed as though they apply, in good faith and without admissions.
Accordingly, Airservices is commencing formal consultation under Clause 15 (Consultation and Change) of the EA regarding proposed external recruitment of AALLs for a number of positions nationally.
Airservices will also begin consulting directly with employees shortly in respect of the external recruitment for AALL roles.
In the meantime, Airservices will commence internal recruitment for AALL roles.
External recruitment will only be pursued if all necessary positions are not filled via internal recruitment." (My emphasis)
"So it's a letter dated 13 November. It's electronically signed by you. It says in the second paragraph that Airservices does not concede that external recruitment constitutes a major change. It then goes on in the fourth paragraph to say:
While Airservices does not concede that the consultation obligations under the EA are triggered, it is prepared to proceed as though they apply in good faith and without admissions.
When you say that you are prepared to proceed as if they apply, are you referring to all of the obligations under clause 15, including [those] that would apply if it were a major change?‑‑‑Yes, that's correct."
[25] Mr Firman was not challenged on that evidence.
"Airservices Australia is commencing formal consultation regarding proposed external recruitment of Line Leaders for 4 positions nationally.
This process ensures that all affected employees and their representatives are provided with detailed information about the proposed change, its rationale, its likely effects, and an opportunity to provide feedback or propose alternatives before any decision is made.
A number of current Line Leaders are secondees. The end dates of the secondments are approaching, with [a] majority of the secondments due to end by 6 January 2025. As such, there is an urgent business need to recruit permanent Line Leaders for those positions.
In total 4 Line Leaders will need to be recruited across Sydney, Broome, Whitsunday Coast and Karratha.
Airservices will first be recruiting for these positions by advertising the positions internally.
However, if the roles cannot be filled with internal candidates, Airservices is proposing to recruit externally.
Airservices has considered a number of concerns raised by the UFUA and ARFF employees regarding the recruitment of external line leaders. These concerns, and Airservices' response, are summarised below:
Employees and/or their representatives are invited to consider the Proposal and provide your views in relation to any impact of the Proposal on employees, and any alternative proposal.
We invite you to attend a meeting to discuss these changes and provide feedback. A link to this meeting will be issued for you to accept."
[28] The UFUA denied that the proceedings lack utility. Leaving aside alleged historical non-compliance, the key premise of its position was that Airservices "continues to fail" to meet its consultation obligations. But it did not make out its case in that regard.
"Thank you for meeting with us on Wednesday, 26 November 2025.
Airservices appreciates the time you took to provide feedback on the current Line Leader recruitment proposal.
After reviewing the items raised by the UFUA, Airservices would like to outline its position on the key points discussed: ..."
[30] The email then set out in a table the "feedback items" raised by the UFUA and Airservices' position on each item. It is not necessary to reproduce the table in its entirety. I note in particular the following statements as to Airservices' position:
"We appreciate the union's feedback regarding the induction course. In Airservices' view, the length and structure of the course is appropriate to meet its stated objectives. We also note that the induction course material has been submitted to, and endorsed by, CASA. However, based on the union's input and recent consultation sessions with employees, to alleviate concerns, we have made adjustments to extend the time available to candidates and refine how assessments will be completed, including post-arrival on station. Any changes to course duration are guided by formal training recommendations to ensure comprehensive coverage of critical subjects and maintain the highest standards of preparedness.
We appreciate the union's feedback regarding career progression. Based on this input and recent consultation sessions, Airservices has adjusted its recruitment approach: internal candidates will be given priority for leadership roles, with external recruitment only considered if suitable internal applicants cannot be identified. In addition, we are reviewing a structured development program supported by targeted training and mentoring to help current employees prepare for these opportunities. In addition, there are still a number of vacant roles that internal applicants could apply for if they would like to do so.
Airservices acknowledges the UFUA's view regarding consultation on External Line Leader recruitment. While our position is that formal consultation is not required under the applicable provisions of the enterprise agreement, we have proceeded with consultation with employees and the union on a without admissions basis. We have actively engaged with staff and the union through discussions and feedback sessions. These sessions were designed to ensure transparency, gather input, and address concerns raised during the process. We remain committed to open communication and will continue to provide opportunities for feedback as recruitment progresses."
"We appreciate the constructive comments and suggestions shared.
While some recommendations have been incorporated, others were not feasible due to business requirements and operational flexibility.
If you have any further questions or would like clarification on any point, please feel free to reach out to me directly.
Thank you again for your engagement and commitment to improving our processes."
[33] Further, the email refers to a meeting that took place on 26 November 2025. The UFUA did not seek to lead evidence regarding that meeting to demonstrate a failure to consult. Further, the UFUA did not put to Mr Firman (the only Airservices witness required for cross-examination) that the organisation was continuing to fail to consult.
"Now, there is a practical utility to determining this, because it is going to give the parties guidance and it's going to give the parties clarity as to what Airservices' obligations actually are or what it needs to do to comply with its consultation obligations."
[37] In summary, Airservices has provided the UFUA with a commitment to undertake consultation with the UFUA as if clause 15 applies and the external recruitment of AALLs is a "major change" within the meaning of that clause. That commitment was not expressed in the documents to which I have referred to be subject to the outcome of these proceedings, and Airservices made no suggestion to that effect in its evidence and submissions. In those circumstances, I accept Airservices' submissions that there is little utility in the Commission determining whether clause 15 imposes such an obligation to consult on Airservices. That dispute has, for all practical purposes, been resolved.
[38] But there is another consideration. Underpinning that dispute is another (and arguably more fundamental) conflict as to whether, and if so under what arrangements, Airservices should externally recruit AALLs.
[39] The parties have made little progress towards resolving that conflict. To an extent, the UFUA's evidence and submissions suggest that it is likely to remain opposed to the external recruitment of AALLs regardless of what consultation occurs. Even so, I have formed the impression from the evidence that the question as to whether clause 15 applies has become an impediment to, or a distraction from, a resolution to the underpinning conflict. Determining whether the clause applies in the present circumstances might facilitate more constructive dialogue between the parties as Airservices continues to recruit externally for AALLs.
[40] For that limited purpose, I will answer the question: the external recruitment of AALLs under the arrangements that Airservices has implemented does not give rise to an obligation to consult under clause 15.
[41] Given the matters traversed above, I will set out my reasons for reaching this view relatively briefly.
The principles to apply in construing the Agreement
(1) The starting point is the ordinary meaning of the words, read as a whole and in context.
(2) A purposive approach is preferred to a narrow or pedantic approach - the framers of such documents were likely to be of a practical bent of mind. The interpretation turns upon the language of the particular agreement, understood in the light of its industrial context and purpose.
(4) A generous construction is preferred over a strictly literal approach but agreements should make sense according to the basic conventions of the English language.
(5) Words are not to be interpreted in a vacuum divorced from industrial realities but in the light of the customs and working conditions of the particular industry.
[43] The UFUA submitted that consultation was required under clause 15 because the decision to recruit externally for AALLs:
(1) constituted a major change that is likely to have a significant effect on employees (clause 15.4(c));
(2) was a decision the implementation of which would significantly affect employees (clause 15.4(d)); and
(3) was likely to significantly or materially impact employees (clause 15.4(f)).
[44] The UFUA submitted that clause 15.4 is engaged because the decision:
(1) reduces job opportunities for existing employees by limiting opportunities for secondment and promotion into the AALL role. This was said to be a "major change" of the kind referred to in clause 15.9(c);
(2) increases risks to employee health and safety; and
(3) results in a change to the composition of Airservices' workforce and the skills and knowledge of the AALL employees. This was said to be a "major change" within the meaning of clause 15.9(b).
Applying the terms of the clause to the circumstances of this case
[45] I will address initially the UFUA's case as to the safety implications of the decision to recruit external candidates into AALL roles, as my findings in this regard have a bearing on some of the other grounds on which it relies.
[46] Each of the UFUA's witnesses gave evidence to a similar effect as to their concerns in this regard. They distil to two issues: training and experience. The evidence may be summarised in this way:
(1) On the issue of training, the ARFFS Training Academy in Melbourne provides training to members of the ARFFS. That includes Certificate II training for recruits and Certificate IV training for firefighters who are becoming officers. The training involves aviation-specific modules, including practical training and assessments in responding to aviation incidents. In contrast, external candidates need only hold a Diploma level qualification of Public Safety (Fire Fighting Management) awarded by a CASA-approved registered training organisation. If that diploma is not awarded by the ARFFS Academy, the candidate will not have received aviation-specific training. To be able to manage aerodrome fire stations safely and effectively, an AALL requires that training. The two-week induction program that Airservices has developed for externally-recruited AALLs is inadequate to make up that knowledge deficit.
(2) On the issue of experience, firefighters in the ARFFS develop on-the-job knowledge in aviation fire safety that is unique to their environment. That knowledge cannot be gained through experience as an urban firefighter or in other non-aviation settings.
[47] I accept that the UFUA's witnesses genuinely hold the concerns they voiced. But the arrangements that Airservices has implemented, including the qualifications that an external candidate must hold and the two-week induction program they must undergo, have been approved by CASA, the relevant safety regulator. The UFUA's evidence does not displace the fact that CASA has found no impediments from a safety perspective to Airservices recruiting externally for AALLs under the arrangements it has set up. I do not propose to second-guess the regulator. I am not persuaded that the external recruitment of AALLs creates a risk to the health and safety of employees such as to give rise to an obligation to consult under clause 15.
[48] That conclusion is relevant to the application of other provisions of clause 15 on which the UFUA relied. The meaning of the phrase "a major change [that] is likely to have a significant effect on employees" is provided by clause 15.9. On the terms of clause 15.6, clause 15.9 will only apply (relevantly for present purposes) if Airservices "proposes to introduce a major change to production, program, organisation, structure or technology to its enterprise that is likely to have a significant effect on the employees". The UFUA submitted that Airservices' decision was a major change to its production or organisation.
[52] For these reasons, I am not persuaded that the change is of a kind described in clause 15.6(a). On the terms of the Agreement, clause 15.9 does not apply. However, for completeness I make the following observations.
"It relies on the same facts and circumstances as that argument, but, in a nutshell, prior to the change, the respondent's workforce was comprised in such a way that line leaders had this deep operational knowledge that we've spoken about from their training and experience that internal recruits have, but that is no longer necessarily the case. The line leaders will no longer have that, necessarily have that degree of operational knowledge, and that changes the composition of the workforce insofar as it is comprised of line leaders with particular knowledge and experience. I'm not saying that there is a change to the number of line leaders or a change to reporting lines or anything like that, it's a change to the composition in that way, and it really just relies on the same matters as the health and safety."
[54] The reasons I have set out earlier in relation to the asserted health and safety implications of the change largely deal with these submissions. The fact that externally-recruited AALLs may be differently qualified to internal candidates does not make them unqualified. Further, there will be the same number of AALLs at the same number of locations, each performing the same duties or responsibilities, whether internally or externally recruited. There is no change, much less a major one, to Airservices' workforce.
[55] For the same reasons, I do not accept UFUA's contention that Airservices has effected a major change to the skills required of employees within the meaning of clause 15.9(b).
[56] The evidence does not support the UFUA's argument that the change has resulted in the elimination or diminution of job opportunities within the meaning of clause 15.9(c). I make two observations in this regard.
[57] First, as at the date of the hearing, there were eight vacant AALL positions. Airservices made it clear in the correspondence to its employees and the UFUA to which I have referred that it would seek to fill those vacancies through internal recruitment in the first instance, and only recruit externally if vacancies remained. On the evidence, all but one internal candidate who applied for an AALL role was successful in securing one. There is no relevant reduction in the opportunities for employees to apply for an AALL role. To the extent that the AALL offers a career path to existing employees (despite it being one taken less often over time), I observe that in his email to Mr Garrett of 18 December 2025, Mr Firman stated that Airservices was "reviewing a structured development program supported by targeted training and mentoring to help current employees prepare for these opportunities".
[59] The case the UFUA advanced requires secondments to be seen as "job opportunities" within the meaning of clause 15.9(c). I do not accept that the term should be read in that way, in that I do not regard a short-term secondment to be a "job". In context, job opportunities are described in the clause as including "opportunities for promotion or tenure". In the circumstances of this case, a secondment is neither.
[60] While I have determined that the external recruitment of AALLs under the arrangements that Airservices has implemented does not give rise to an obligation to consult under clause 15, I do not consider that this should, or anticipate that it will, cause Airservices to resile from the commitment it gave to its employees and the UFUA to consult on the external recruitment of AALLs as if this were a major change under the clause.
Mr Ruben Clark, Counsel, on behalf of the United Firefighters' Union of Australia
Mr Andrew Crocker, Counsel, on behalf of Airservices Australia Pty Ltd
[1] In this decision, when I refer to an AALL role being vacant, I am describing a situation where there is no permanent full-time incumbent and the role is occupied by an employee on temporary secondment
[2] United Firefighters' Union of Australia v Airservices Australia [2025] FWC 2669
[3] Statement of Andrew Firman, 21 November 2025, Annexure AF-10 (Court Book p 592)
[4] UFUA Submissions for Arbitration of a Dispute, 31 October 2025, pars 2 and 3
[5] AB v Tabcorp Holdings Limited [2015] FWCFB 523 at [11], cited in Reliable Petroleum Pty Ltd v Fraser Murray [2017] FWCFB 5843 at [31]
[8] Statement of Andrew Firman, 21 November 2025, Annexure AF-19 (Court Book p 624)
[9] Statement of Andrew Firman, 21 November 2025, Annexure AF-21 (Court Book p 628)
[11] Statement of Andrew Firman, 21 November 2025, Annexure AF-22 (Court Book p 630)
[13] [2017] FWC 2432 at [33(f)], citing Schweppes Australia Pty Ltd v United Voice [2012] FWA 643 at [41].
[16] Construction, Forestry, Maritime, Mining and Energy Union, Matthew Howard v Mt Arthur Coal Pty Ltd T/A Mt Arthur Coal [2021] FWCFB 6059 at [250]
[18] See for example Tasmanian Water & Sewerage Corporation Pty Ltd T/A Taswater v Construction, Forestry and Maritime Employees Union [2024] FWC 966 at [6] and [10]
[19] See Construction, Forestry, Maritime, Mining and Energy Union, Matthew Howard v Mt Arthur Coal Pty Ltd T/A Mt Arthur Coal [2021] FWCFB 6059 at [106]- [109]
[20] See generally Automotive, Food, Metals, Engineering, Printing and Kindred Industries Union' known as the Australian Manufacturing Workers Union (AMWU) v Berri Pty Limited [2017] FWCFB 3005 at [114]. See also Linfox Armaguard Pty Ltd T/A Linfox Armaguard v Transport Workers' Union of Australia [2024] FWCFB 373 at [38]- [43]; WorkPac Pty Ltd v Skene (2018) 264 FCR 536; [2018] FCAFC 131 at [197]; Svitzer Australia Pty Limited v Construction, Forestry, Maritime, Mining and Energy Union, The Australian Institute of Marine and Power Engineers and Another [2023] FWCFB 259 at [109]- [115]
[21] Amcor Limited v Construction, Forestry, Mining and Energy Union (2005) 222 CLR 241; [2005] HCA 10 at [2] (Gleeson CJ and McHugh J); [96] (Kirby J)
[22] Linfox Armaguard Pty Ltd T/A Linfox Armaguard v Transport Workers' Union of Australia [2024] FWCFB 373 at [39]
[23] Kucks v CSR Ltd (1996) 66 IR 182 at 184, quoted with approval in Svitzer Australia Pty Limited v Construction, Forestry, Maritime, Mining and Energy Union, The Australian Institute of Marine and Power Engineers and Another [2023] FWCFB 259 at [114]
[25] Communications, Electrical, Electronic, Energy, Information, Postal, Plumbing and Allied Services Union of Australia v Jemena Asset Management Pty Ltd [2016] FWC 6494 at [30]
[26] Construction, Forestry, Maritime, Mining and Energy Union, Matthew Howard v Mt Arthur Coal Pty Ltd T/A Mt Arthur Coal [2021] FWCFB 6059 at [133]
[28] Statement of Michael McDonald, 30 October 2025, par 19 (Court Book, p 104)
[29] Statement of Patrick Shanahan, 30 October 2025, par 27 (Court Book p 171)
Printed by authority of the Commonwealth Government Printer
United Firefighters' Union of Australia
Airservices Australia Pty Ltd [2026] FWC 697
(2018) 264 FCR 536
(1996) 66 IR 182
(2005) 222 CLR 241