What is the test for supervised access in a custody and access case?

[178] I can however, order incidents of custody and access, including whether access should be supervised or exercised in the presence of a third party such as a therapist, pursuant to sections 28 and 34 of the Children’s Law Reform Act and I will so order. Supervised access is beneficial for children who require gradual reintroduction to a parent. In Miller v. McMaster, 2005 CarswellNS 420 (N.S. S.C.), the court held that "supervised access is not a long-term solution to access problems which usually arise in high conflict custody and access cases where distrust and negative parental allegations abound. Supervised access is appropriate in specific situations, some of which include where a child is being reintroduced into the life of a parent after a significant absence. In doing so, I encourage the therapist to assist in the reunification of the father and daughter relationship during the supervised access visits.