British Columbia (Public Service Employee Relations Commission) v British Columbia Government Service Employees' Union  British Columbia (Public Service Employee Relations Commission) v British Columbia Government Service Employees' Union [1999] 3 SCR 3, – called Meiorin for short – is a Supreme Court of Canada case that created a unified test to determine if a violation of human rights legislation can be justified as a "bona fide" occupational requirement (BFOR). Before "Meiorin", Human Rights violations were treated in one of two ways; either as "direct discrimination", pursuant to the analysis in "Ontario (Human Rights Commission) v Etobicoke (Borough of)", [1982] 1 SCR 202; or as "adverse effects discrimination", pursuant to the analysis in "Ontario (Human Rights Commission) v Simpsons-Sears Ltd", [1985] 2 SCR 536. Academic writing deeply criticized this bifurcation of analysis as arbitrary and unhelpful in protecting equality rights. With the "Meiorin" case, the court decided to confront this criticism and refashion the analysis. Tawney Meiorin was employed as a firefighter by the British Columbia Ministry of Forests. Three years after being hired, the government adopted a series of fitness tests that all employees were required to pass. She passed all the tests except for one that required her to run 2.5 km in 11 minutes. After four attempts, her best time was 49.4 seconds over the maximum allowed. As a result, she was fired. Though the fitness tests had a valid purpose of ensuring safety, the court found that the research that the tests were based on was incomplete and "impressionistic" and did not take into account the differences between men and women in establishing a standard. To reach this conclusion, the court examined the previous methods of analyzing Human Rights violations, noting where they were deficient, and then proposed a new ""Meiorin" Test" to which the current facts are applied. McLachlin J (as she was then) noted that the greatest deficiency in having two different approaches is that one afforded a greater amount of remedy than the other which provoked parties to abuse this distinction. There was the further problem that it had the overall effect of legitimizing systemic discrimination. As well, it created a dissonance between Human Rights analysis and "Charter" analysis. An employer can justify the impugned standard by establishing on the balance of probabilities:   In practice, this step has been shown to be easily satisfied.