HomeMy WebLinkAbout1986-0691A.Gustafsson.90-02-19EMPLOY~SDEL4 COURONNE DE L’*N~ARm
CPMMISSION DE
SETTLEMENT REGLEMENT
DES GRIEFS
691A/86
IN THE MATTER OF AN ARBITRATION
Under
TEE CROW4 EMPLOYBES COLLECTIVE BARGAINING ACT
Before
TEE GRIEVANCE SETTLRXBNT BOARD
BETWEEN OPSEU (Gustafsson)
- and - Grievor
The Crown in Right of Ontario (Ministry of Revenue)
M. Gorsky Vice-Chairperson I. Thomson Member H. Roberts Member
FORTHE
GRIEVOR
N. Roland
Counsel Cornish Roland Barristers & Solicitors
FOR THE EMPLOYER D; Daniels Counsel Mathews, Dinsdale, Clark Barristers & Solicitors
BEARING October 5, 6, 1989
7
DECISION
There were a number of individual grievors whose cases
were before us. However. by agreement of the Tarties. the only
case that was proceeded with was that of Joyce Gustafson, anl her
grievance was not to be treated as a representative grievanc? and
/ this decision will only affect Ms. Gustafson.
The grievance states:
"I grieve that I am improperly classif
General (Field Services Clerk)"
ied as a Clerk 4
The settlement desired is:
"That I be reclassified as a Clerk 5 General :'ield
Services Clerk) with full retroactivity in wages and
benefits."
Counsel for the union indicated that the claim for
reclassification was based on a best fit argument and that 110
other grounds were being relied upon.
Counsel for the parties also agreed that in the event
that this grievance succeeded we were to remain seized of the
subject of damages and interest.
We commend the parties for having considerably
shortened the time necessary to present evidence by fi!ing with
us an agreed statement of facts (Exhibit 9) which is appended to
th .s Award as Appendix "A".
The Class Standard with wh ,ich this case is concerned
(Exhibit 3) is part of the "Clerical. Typing, Stenographic and
Secretarial Class Series". which inc i udes five cerles. The
:
2
General Clerical.Series, with which we are concerned. is made c?
of seven classes. In the “Preamble” to the Class Standard. there
is a statement found at the outset:
“KINDS OF WORE COVERED: These five series cover ali
office positions and office supervisory positions that
are not covered by a specialized clerical, technicai.
equipment operating or professional class series.”
The description of the Clerk General class series found
in the preamble is as fol!ows:
“GENERAL CLERICAL SERIES - 7 CLASSES: This ser.iet
covers positions where the purpose is to oar-fern:
clerical work entirely or in combination’ w i t :Y
incidental typing, stenographic or machine operatin;
duties. Where exclusion of the latter wou i pi
significantly change the character of a position. -‘I
where they occupy a large proportion of the working
time, the position should be assigned to one of t?:e
specialized classes, e.g. Clerical Typist. Posit ion.2
for which specialized clerical series exist. e.c.
Clerk. Mail and Messenger. Clerk, Filing. etc. shoui,i
not be assigned to this series. Group 1 eader
responsibility normally begins at the third lrvei.
while the fourth and above usually cover positions
involving line supervision; however, non-supervisory
positions can also be included.”
In order to be able to do justice to the excellent and
subtle arguments presented by both counsel. it is necessary to
view these arguments in the perspective of each of t!Te
classifications found in the General Clerical series. w’nich arcs
appended to this Award as Appendix “B”.
An examination of the duties of the grievor (Appendix
“A” 1 in relation to the Clerk 4. General and Clerk 5. Gener5.l
class standards demonstrates the difficulty of deciding whi,:h
3
class standard represents the best fit. Many .of the duties are
found in either class definition. Our task is not made any
easier by the use (no doubt necessary) of the somewhat abstract
language defining the nature of the duties to be included within
the classifications. Some assistance can be ‘obtained from such
Exhibits as Exhibit No. 4. which contains, inter alia. the
“Branch Service Policy” :
In the “Statement of Agreed Facts” (Exhibit ci)
consistent with the “Branch Service Policy”. The “Purpose of
Position” identifies the significant service to, and education
of. the public elements of the position.
Counsel for the union, in reviewing the agreed duties.
emphasized the following:A recurring theme found in the agreed
description of duties is the incumbent’s responsibi 1 ity for
direct vendor contact involving the responsibilities of
furnishing explanation and interpretation to the public of
aspects of The Retail Sales Tax Act (the “Act”). The emphasis is
on one-to-one contact with those making enquiries. The activity
is practical rather than theoretical and the public being served
in the area of vendor permit applications is various in its
attitudes, education and degree of sophistication. The grievor
is required to elicit information and apply that ineormation in
the interpretation and application of the Act. Interpretation
duties also involve preparation of letters which might be
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interpretive of the leg islation. The ongoing duty to exp 1
procedures to the public being served brings with it the fur t
duty to provide follow-up explanations after an investigation
a i i-1
her
has
been carried out. T??e duty to explain is also car:-ieci forward
into the area of closing-out vendors. where the grie,ior 1s ,a!s.c
law and poli required to explain and interpret the cy relating to
the close-out function.
iie were referred to the 3orcej cas+ 21/e:;, 12/84, :Izf’e,i
(Verity). The Borqes case, was concerned with the ccilection of
monies owing to OHIP. As in this case. the difference between
the two class standards was “essentially a matter of degree of
complexity of the assigned responsibilities or the degree of
independent judgment required in the performance of %‘:>OSi
duties.” (Boraes case. p.12l.At pp.12-13 of the Borqes case there
are statements that was relied upon by counsel for the union:
“The Board is of the view that it would be indiscrete
on our part to review the methods and techniques
employed by Grievors in the execution of the.ir job
responsibilities. Suffice it to say that the position
in quest ion requires a i arge measure of tact,
sensitivity. aggressivness and firmness ir. addition to
a detailed knowledge and experience 1 !-? collection
procedures... .
. . . Having considered the evidence carefully. we are
satisfied that the Grievors perform responsible
clerical work which requires detailed knowledge of
legislation and local practices. Similiarly. the
judgment component of the job requires the
interpretation and application of p<,licy which in~~nives
the development of new methods. T:::-.p work performed by
the Gr ievors is carried out with 3 large mea:31:re of
independence as is contemplated by the :?igher Class
Standard. In addition, we are satisifed tin: the
typical tasks performed by the Grievor-s require the
interpretation and
legislation, in part
although many other _. .
5
explanation of department a 1
cular the Health Insurance Act.
statutes, both provincial and . . . federal, are rrequently utilizea. ln summary. t!w
Grievors perform job responsibilities which. in our
opinion. fall within the Clerk 5 Genera!
classification.”
Counsel for the emp!oyer. while he did not take issue with the
conclusion arrived at in the Borqes case, did take issue with the
approach of the Board. Counsel for the employer noted that %he
basis for the decision stated by the Board in the Boraes case was
the Board:s comparision of the duties of the grievors with t he
duties set out in the Clerk 5 General class standard. The errx-
identified was based on the fact that there was overlap between
the Clerk 4 and Clerk 5 General duties and that the Board failed
to compare both class standards in the light of the duties whi’ch
were core to the position. Counsel for the employer also pointed
out that the Board, in the Boraes case, did not correctly . ’
represent the duty with respect to knowledge of legislation, etc.
called for in the Clerk 5 General class definition. At the top
of Page 13 in the Boraes case, the Board found that the grievors
performed responsible clerical work which required: “detailed
knowledge of legislation and local practices. ” Ti-e class
definition in the Clerk 5 General classification states that
employees in the positions require: “detailed knowledge of a body
of regulations. statutes or local practices.” We do not regard
this as being a significant difference, as legislation could
include both regulations and statues.
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Counsel for the employer also argued that the Board in
the Boraes case also based its conclusions on a usage argument,
comparing the grievors with the Ministry of Government Services.
Collection Officers, concluding that the grievors. while they did
not perform the same job as collection officers with M.G.S.: did
perform a similar central core of duties. It shouid not matter
that the grievors in the Boroes case might be found to have
succeeded on both class standard and usage arguments.
Nevertheless, we agree with counsel for the employer that in
examining a best fit argument. it is necessary to examine the
class series as a whole as an aid to determining the meaning of
words within any of the classes within the series.
Counsel for the employer referred us to the case of
Lavcock 241/84, (Fisher). where reference is made. at p.3:to the
Clerk General series as being set up on a “cant inuum of
complexity”. In the Lavcock case, the grievor, who was employed
as an in-province processing clerk at the Ministry’s OHIP
facility located in Ottawa, claimed that she had been improperly
classified as a Clerk 3 General and sought reclassification as a
Clerk 4 General. In examining certain indicia in the light of
the language of Class 3, “requiring a background knowledge of”
and of Class 4, “requiring a good background knowledge of...“.
the Board concluded that:
8, . . it is clear that the inclusion of
in Class
+-he word good I
4 implies that in order to Cl0
the job
properly. something other than a background knowledge
of the applicable policies and procedures are required.
7
It isvery clear from Ms Laycock’s evidence that in
order to do the job as effectively~ as she does. which
apparently she does extremely well, it is necessary to
master a voluminous amount o’f material which has been
previously listed. The material to be digested is
certainly not of a straightforward pature as it ?bollnds
with complex medical terminology. Therefore. <on this
particular indicia it is clear that the c,ositicn
properly fits within the requirement of the class 4
standard. ‘I
Counsel for the employer noted that the Clerk 3 Generai
class definition provided for, “a background knowledge of
specific regulations, statutes or local practices. ” whi 1e tk?
Clerk 4 General class definition added the word “good” to the
provision with respect to knowledge of statutes,regulations and
local practices. We note that the Clerk 5 Genera; class
definition employs the adjective “detailed”. We were asked t2
find that the adjective “excellent”. which is found at Fnge 6 cf
Exhibit 9 under the “Agreed to Skills and Knowledge Required +f
the Grievor” was the equivalent of good background knowledge.
“Excel lent” is found in the following context:
“An excellent knowledge of and the ability to apply.
interpret, explain, advise about, research. investigate
and enforce relevent Retail Sales Tax Legislation.
policy rulings and procedures set out in Ministry
operating manuals (e.g. Understanding Ontario Sales Tax
Vendor Administration, Default and Deiinquency
Manuals). . .I’
.
In this context I would find that the adjective “excellent” goes
beyond a merely “good background knowledge”. In normal usage.
the word “excel lent” connotes a higher standard than is imp1 i22
by the use of “good”. A “background” knowledge. as is referred ?c
i
in the Clerk 3 General class definition indicates that the
knowledge is general rather than specific. Adding the word “good”
to the word “background” does not change the fact that the
knowledge requirement is still general.
We were referred by counsel for the union to pargaraph
4 of the “Clarification of Job Duties” found at Page 8 of Exhibit
0 - . where it is provided ihat in 5% of interpretation cases. the
solution is derived “directly from principles set out in th+
legislation.” The paragraph. in dealing with the question of
supervision, goes on to provided:
0, . . . In these circumstances Fields Services Clerks (sic1
are expected to review her (sic) interpretation with
the Supervisor. In 3ver half of these cases. answers
have already been given to the taxpayer. Field
Services Cierks in Hamilton are correct in a high
percentage of time (sic). If Field Services Clerks are
incorrect. Clerks usually must contact the taxpayer and
supply the corrected advice.
Counse 1 for the union asked us to compare the following
provisions in the class standards which touch on the question of
supervision. In the Clerk 4 General class standard the
provisions referred to us are as follows:
“Matters involving decisions that depart radically from
established practices are referred to Supervisors.”
Provisions of the Clerk 5 class definition which we were
referred to are as follows:
“Difficult technicai quest ions or those involving
policy determination are referred to Supervisors. ”
It was submitted to us by counse 1 for the union that. The
description of the job duties of the grievor in relation t.9
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interpretation of statute related material fits best within the
description of the level of supervision identified in the Cl.335
definition of the Clerk 5 classification. The supervision of the
grievor is more in the nature of a review for consistency of
decision-making. In the case of the Clerk 4. t:?e sup+rvisian is
with respect to matters that more comfortably iit within
established practices. The Clerk 4 position. it was submitted,
involves work which is more routine. following fairly clearly
delineated guidelines or standards.
Counse I for the union differentiated’ b.etween the
supervision of the grievor relating to matters of interpretation
and the review of certain forms and form letter3 for correctness
by the grievor’s supervisor. who would then approve the document,
as provided for in paragraph g. on Page 3 of Exhibit 9. We were
asked to find that this duty is consistent with that found in the
class definition of the Clerk 5 classification which provides
that:
“Although the work is carried out with a large degree
Of independence, it is reviewed for consistency 0 f
decision-making. ”
I have some difficulty in viewing the latter quotation as
relating to the supervisor’s review of forms or letters. It ,
appears.to relate to the interpretation or application of policy
or administrative directives which result in the conveying of
information to the public dealt with by the grievor.
10
On the.basis of the agreed to evidence befcre us. it is
difficult to conclude that the filling out of forms is
sufficiently closely tied to the decision-making function
described in the class definition. Nevertheless, the provisions
of paragraph 4 at page 8 of the “Clarification of Jcb Duties” in
Exhibit 9, indicate that the supervision is given after the fact
as in over half the cases the information has already been ,given.
It was submitted that this is closer to the provision in the
class definition of the Clerk 5 standard which provides that thr
review is for consistency of decision-making. We were also ask&
to find that the words: “difficult technical questicns or those
involving policy determination are referred to supervisors.”
referred to a limited number of matters which would Likely
require a response from a person qualified to practise law.
Counse 1 for the union interpreted the typical tasks
found in the class definition of the Clerk 4 General as not
requiring interpretation, explanation or application of statutory
material. In context, there would have to be some interpretior.
and .application of statutory and related material. although.
clearly. the degree of complexity in the Interpretion.
explanation and application function is somewhat greater in the
Clerk 5 General class definition.
Counsel for the union acknowledged that the ,;r:evcr
would have some need to perform the tasks set out under the Clerk
i
11
4 General class definition. but attrihuted this to the inevitable
overlap, especially as it related to the element of evaluaticr:
and assessment of materials. He stated that an examination of
the duties would demonstrate that such duties do not form the
core or essential nature of the grievor’s dui ies and
responsibilities. Counsel for the union pointed out chat the
class definition of typical tasks in the Clerk 5 Genera!
classification provides for an incumbent “requiring the abilit:.,
to make acceptable recommendations or provide functional ~advice-.
a duty that is lacking in the Clerk 4 General class definition.
and that the agreed to duties of the grievor require such tasks
to be carried out. In the Clerk 4 General class definition the
counterpart is I’. . .usual ly by authorising adjustments or
recommending payment or acceptance. . . ” with no reference be i rz;
made to the giving of advice or the making of recommendations
which are an essential feature of the Clerk 5 General.
Counsel for the employer agreed with counsel for the
union that there was a certain amount of overlap between the
Clerk 4 General and Clerk 5 General classifications and that our
task was to establish the best fit between the agreed to duties
and responsibilities and the respective Clerk 4 General and Clerk
5 General class standards as set out in Exhibit No. 3. He also
agreed with counsel for the union that the classifications we are
dealing with are part of a series and the particuiar class
standard must be examined in the light of the entire series. I r:
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12
his case, however. he would have us focus our attention beyond
the immediate Clerk 4 General and Clerk 5 General class
standards.
The Clerk 5 General class definition uses the word
“detailed”in relation to knowledge. which is an indication that
an incumbent possesses specific knowledge. rather than background
knowledge of the statutory materiai and practices. We find that
the use of the words “excellent knowledge” found at Rage 6 of
Exhibit 9. under “Skills and Knowledge Required by the Grievor”
to be more consistent with the words “detailed knowledge” than
with “good background knowledge” as found in the Clerk 4 General
class definition. That is. while we agree with counsel for the
employer: that assistance can be gained by examining the language
found in al1 of the classes within the class series. in this ,
case, the conclusion that we arrived at, while it was assisted by
an examination of a class or classes outside of the Clerk 4
Genera 1 and Clerk 5 General classifications, was not the
conclusion that we were asked to reach. Counsel for the employer
would have us find that the grievor need only have a “good
background knowledge”. Our examination of the grievor’s duties
and responsibi-lities cause us to cone lude that her
responsibil
knowledge”
knowledge”
ities go beyond having to have a “background
or “good background knowledge” but require a “detailed
I
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Counsel.for the employer also asked us to nc:s that the
Clerk 4 General class definition refers to “specific’rpguiations,
statutes or local practices” while the Clerk 5 &nerd! class
definition refers to “a body of regulations. statutes or local
practices.. . .I# He noted that the grievor in the Borzes case hsC
to deal with the Health Insurance Act and regulaticcs. Consume!
Protection Act, Bankruotcy Act.Personal Property Security Act and
the Land Titles Act. along with a number of ott;:e:- statuteas
whereas the grievor. in this case, by acknowledgment. >n!y ?~a? z
have a knowledge of the Retail Sales Tax Act. We were asked tc
note that the Clerk 4 General class definition dea!s with
“specific regulations. statutes or local practices” while the
Clerk 5 General ClkSS definition refers to “a body of
regulations. statutes or local practices”. We were also asked tr
look at the Clerk 6 General class definition which provides for:
“a wide variety of regulations, statutes or practices”. We wet-s
a better fit within the Clerk 1
ievor only has to deal with a single
asked to find that there is
General class because the gr
statute and its regulations.
We note that the knowledge required relates tc
“regulations, statues or local practices”. There is no quest io:
that the grievor deals with a body of loca! practices and her
responsibility is not limited to specific local praciices. There
is some merit in the argument presented by course1 f,,r t.r:+
employer, but it overlooks all of the other duties an<
14
responsibilities and how they fit into the class definitation.
When the essence of the duties and responsibilities of the
grievor are examined, being to explain,’ educate, advise and
interpret the legislation and local practices to the public. a+.
when the complexity of the duties required in order to perfo2-m
the work adequately is examined. the fact that only a single
statute and its regulations are dealt with is merely one factc?r
and. standing alone. would not cause us to conclude that the best
fit was within the Clerk 4 General class definition.
Counsel for the employer also referred to the decisicn-
making e 1 ement involved in classifying the position and
acknowledged that if the decision-making element in the class
definition for the Clerk 4 General classification was read alone
it might cause us to conclude that an incumbent would make
decisions largely dictated by Ministry policy. We were referred
to Lavcock 241/84 (Fisherlat Page 7, where it is stated:
I, . . . However, it is clear that in the overwhelming
majority of the cases (one could venture well over 98%
of the cases) the decision was made from “a selection
of
alternatives within a comprehensive framewrlrk or‘
guide1 ines” as described in the Class 3 standard. I n
other words, the alternatives are set forth in the
various reference materials that the grievor had access
to. It is true that in or$er to make that decision
intelligently it requires a lot of background
information, however, it is clear that the answer can
virtually always be found in the four corners of the
books provided to her.”
Further,
in the Lavcock case at, Page 8. t.he Board acknowledped
that the grievor, there, did, on very rare occasions, awly
15
meaningful judgment on criteria “probably not found within the
four corners of the books”. The number cf ocassions when this
was done was very small in relation to the overwhelmin; volume of
work which was decided employing clear guidelines. We were asked
to look not only at the Clerk 4 General and Clerk 5 IGeneral ‘zi3~s
definitions. but also at the Clerk 3 General class definition to
view the three levels of interpretation. The first level (Clerk
3 General1 was the simpiest and required the abi lit:.. to 1-e ,) $3 3
document and understand its meaning. T?: e second. and :hioh~?-
level (Clerk 4 General). required the ability to read information
setting out a rule or principle and to apply it to 3 sitilation
not squarely covered by the rule. The third, and stiil higher
level (Clerk 5 General). required the incumbent to function where
there were no rules available to help her. That is. where there
was no policy,or manual which set out a general rule. Iiere. an
employee would have to identify the first principles of the
governing legislation and develop an answer.
There is a nuanced development between the decision-
making responsibilities of the Clerk 3 General, Cler- 4 Gener-ai.
and Clerk 5 General Clerk 6 General. The difference is in the
nature of the guidelines available to answer the problems faring
an incumbent. Once again, there is considerable overlap between
t,he decision-making responsibilities of a Clerk 4 ~?eneral ,a(76 a
Clerk 5 General. In the case of the qr i ever . ::?e ev? cer!c‘”
discloses that she is faced with a broad variety of s?ecin!
16
cases which arise because of the many different kinds of persons
and situations which she encounters and which she is required to
respond to. Because of the wide variety of situations that she
must respond to. established guidelines cr standards must be
constantly adapted to meet the needs of t.he pers=ns she deals
with. The statement of “Skills and Knowledg,--? Required”. at P.ag+
6 of Exhibit 9, make it clear that the grievor must synthesize
responses which required “judgment in the interpretation a !?C
application of policy or administrative dir+ctiven to z!rcri- i ex
where the intent of existing instructions is obscure in cpecif i,:
cases”. Such duties go beyond the mere dealing, “with variations
from established guidelines or standards”. ?he sheer vcliume and
complexity of the materials to be employed by the grievor In
carrying out her duties brings her more squarely within the
decision-making definition found in the Clerk 5 General standard.
From the evidence, it would appear that the grievor’s work is
reviewed for consistency of decision-making, as was noted above.
and that only: “difficulty technical questions or those involving
policy determination are referred to supervisors”.
Counse 1 for the employer referred us to the
“Clarification of Job Duties”, found at Page a of Exhibit 0. He
referred to paragraph number 2 which provides:
“75% of the interpretation ques:ions are covered by
UOST manual although some questions require significant
research. ”
1
i 17
He categorized this kind of interpretation as falling within the
I
first category of difficulty. IHe referred to paragraph 3 of the
“Clarification of Job Duties”: 1
"20% of the interpretations are answered through
‘extrapolation’ from UOST by using analogicai
reasoning. ” I
He placed this level of difffculty of interpretation in t-be
second category, above referred to. He then referred t,o
paragraph 4 of the “Classification of Job Duties”. which is as
follows: I I
I
"5% of the interpretations require interpretation5
directly from principles set out in the legislation. In
these circumstances Fields (sic) Services Clerks are
expected to review her (sic1 interpretation with the
supervisor . In over haif these cases answers have
already been given the taxpayer. Field Services Clerks
in Hamilton are correct in a high percentage of time
(sic). If Field Services Clerks are incorrect, Clerks
must contact the taxpayer and supply the corrected
advice. ” I
Counsel for the employer categorised the latter interpretation
I. responsibility as falling yithin the third category of
difficulty. He referred to this interpretation obligation as one
that is not assisted by the manual: “not found within the four
corners of the manuals”.
Counsel for the employer categorised the category three
interpretation obl igat ion a? requiring variations from
1. established directions found fn the’ manuals. That is. the
manuals can be used as a guide! but the answers are not found in I
the manuals. This would leave 5% of the interpretation
I
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obligation within the third category: that. is. the level of
difficulty envisaged in the obligations set out in the Clerk 5
General class definition. Because only 60% of the grievor’s time
is spent in interpretation. this means that the category three
interpretation responsibility makes up only 3% of the grievor’s
job.
The submissions made by counsel for the employer in
relation to the interpretation function have considerable merit.
Although the UOST manual is quite voluminous. it is acknowledged
that 75% of the interpretation questions can be answered relying
on the information covered in those manuals. That I:. “decision-
making involves some judgment in the selection of alternatives
within a comprehensive framework of quidelines.” as Is set out in
the class definition of the Clerk 3 General classification.
Although. “some quest i’ ons require significant research” as is
pointed in paragraph two of the “Clarifiction of Job Duties” in
Exhibit 9, this merely means that some time has to be spent
finding the available alternatives contained in the UOST manual.
The decision-making with which the griever is involved
requires “judgment in the interpretation and application of
policy or administrative directives to problems where the intent
of existing instructions is obscure in specific cases”, and this
is. inevitably, assisted by the requirement that the grievor- have
a. “detailed knowledge” of regulations, statutes or local
19
practices. ‘I
Counsel for the employer has presente? a neat sol~l+.iori
to his problem of placing the grievor within the C!er:k 4 General
classification by a delineation of the difficulty of
interpretation questions. The language of the class series .ioes
not permit such a neat solution. The knowledge c.f the stat,L:ory
material and local practices is greater ir. the case of the Clerk
5 General. and the duties and responsibili: ies cf the ,;riev,;r 3re
closer to that definition. The less detai i?d kww1edq.l of
statutory material required by a Clerk 4 knera:. would impact on
his/her decision-making duties. The detailed knowledge required
of the grievor would impact on her decision-making obligations.
Furthermore, as was acknowledged, there is a signifi~:ant
responsibility placed on the grievor to adapt ex;!anations tc, the
ability of the pub1 ic dealt with to :understand her
interpretations. This impacts on her decision-making
responsibility and involves judgment in interpretation and
application of policy or administrative directives. It was
acknowledged that this frequently happens “where the intent of
existing instructions is obscure in specific cases.” Paragraph 5
of the “Clarification of Job Duties” notes that “there are no
manuals and no specific directives setting out how to deai with
this variety and the clerks must use their judgment. initiative
and social skills... in dealing with the vari,2us inquir i*s by
adjusting levels of sophistication. 1angua;e. tcne ar.d deta:l of
the i
expl
20
r explanation and queries in order to communicate (in both
anation and questioning)“. I cannot agree with counsel fc3r
the employer that the decision-making component of the grievor’s
duties and responsibilities fits more comfortably within the
Clerk 3 General classification. Rather, I find that the
decision-making with which she is involved calls for: ‘I...
judgment in the interpretation and application of policy or
administrative directives to problems where the intent of
existing instructions is obscure in specific cases. ” It must be
recalled that she is dealing not just with interpretation of
statutory material but with a wide variety of policy directives
and she must interpret these policy directives “...by explaining
and interpreting registration requirements... ,- (See paragraph
1 of the “Summary of Duties and Responsibilities in the Statement
of Agreed Facts”. Exhibit No. 9.1 In addition. as is pointed out
in paragraph 1 (bl of the latter document. in querying applicants
to obtain information necessary for the completion of
registration, questionnaires and related forms: “This function
involves the interpretation and the explanation of the law
relating to the specific sort of business the applicant is
engaged in so as to explain to the applicant what laws,
regulations, et cetera apply to them.. . .” In doing this. the
grievor is required to make use of a “detailed knowledge” of
statutes, regulations and local practices rather than a good
general background knowledge. Such a requirement f it-s mcJrr
comfortably within the Clerk 5 General class standard.
Counsel for the employer states that the interpretation
function’carried out by the grievor must be typical to the extent
that it coincides with that envisaged in the case of a llerk 5
General. As I have noted, the specific reference c.0
interpretation in the Clerk 5 General classification is with
respect to “policy or administrative directives... where the
intent of existing instructions is obscure in specific cases. ”
The only evidence that we have before us indicates that a
significant amount of interpretation in which the grievor is
involved requires a detailed knowledge of local practices which
are, in turn. governed by “policy or administrative directives”.
The argument presented by counsel for the employer does not give
sufficient weight to this factor. On all of the evidence. we
find that the interpretation function of the grievor involves a
large measure of detailed knowledge of the statutory material and
local practices and that the interpretation function is affected
by the need for this knowledge and by the use of this knowledge.
It manifests itself in a variety of ways.
Even if only a relatively small percentage of the time
spent by the grievor involves “interpretations directly from
principles set out in the legislation” (“Clari,fication of Job
Duties” , page 8. Exhibit 91, this is a vital and essential part
of the grievor’s duties and responsibilities and it colu~~rs much
of what she does. It is essential that she have specific
22
knowledge of the statutory’ material as well as applicable
policies to assist her in interpreting the legisiation. Of
Considerable importance is the need for her to a b 1 e i .O inc;: when
she is beyond that area where a good background k.nowl?ge is
needed (the second category identified by counsel fcr -..e th
employer, associated with the class standard for . ‘.‘? Clerk 4
General) and when she is involved in more complex intsrpreration
ithe third category identified . b.., counse 1 for trio
employer,associated with the class standard for t:he Clerk s
General). It is for this reason that percentages of -ime spent
involved in the three categories of interpretation icentified by
counsel for the employer cannot be determinative.
The “responsible clerical WC rk” performed b.b, the
grievor goes beyond that covered in the class definition of the
Clerk 4 General classification. The extent of the kncwledge
component possessed by the grievor is necessary in order tc carry
out the more sophisticated functions covered by the (Clerk 5
Genera 1 classification. The nature of the education.
explanation, advice and interpretation services afforde,i- the
public served require the qualifications set out in Exhibit 9 and
are more closely related to the duties and resconsibilities
covered in Clerk 5 General class standard.
Counsel for the emp 1 oyrr f oc.:sed on the requ:t’+ment
contained in the Clerk 5 Genera 1 rlass definition: :‘tj!cis
*.
23
frequently necessitates modifying work processes c!r the
development of new methods. ‘I We find that the grievor must
constantly modify work processes and develop new methods iit order
to carry out her responsibilities to the public: She has to use
“judgment in the interpretation and application of policy or
administrative directives to problems where the i n t ‘; !? t ,.:; f
existing instruct ions is ohscure in specific cases, ” because
there are, frequent !y , no instructions on how to co!llrnunicato with
the pub1 ic when interpreting and applying poi icy c.: r
administrative directives to that public. Such a requirco-nt can
not be found in the Clerk 4 General classification.
Counse 1 for the employer also directed us to the
difference between the qualifications called for in the Clerk 4
Genera 1 and Clerk 5 General classifications. In the case of the
Clerk 4 General. the qualifications state: “the ability to
communicate clearly both orally and in writing... .‘I In the case
of the Clerk 5 General paragraph 3 of Qualifications provides:
“Ability to interpret regulations and instructions into
procedures and practice: ability to prepare effective
correspondence, instructions and reports.”
Counsel for the employer stated that what is being referred to in
the latter quotation is the way in which an employee would have
to be involved in interpreting information: that is. the way in
which he or she goes about arriving at an interpretive answer.
We were asked to find that the description of duties .ancl
responsibilities of the grievor did no t contain anything relating
24
to the "modifying~ of work processes or the development of new
methods." We were asked to find that all that the grievor did is
respond creatively in modifying the communication of their
interpretive answers~. The language chosen is capable of beir,-
interpreted so as to mesh with what the grievor was required t:r~
do and did, in fact. do. She had to develop new methods ctf
communicating answers to meet a large variety of circumstances.
There were no set work processes in many cases and these appear-??.
to have been adapted to meet the various situations that the
grievor was faced with. Furthermore. the quaiifications referra?.
to by counsel for the employer include, as, was noted. the:
"ability to interpret regulations and instructions into procedure
and practice". The grievor had to interpret regulations an&
instructions so as to, at least. develop practices to meet -..? +?---
needs of the public she served. The Clerk 4 General, under the
same heading, need only have the: "the ability to communicate
clearly both orally and in writing... ." The qualifications
which would relate to an ability to interpret are not found in
the Clerk 4 General list of qualifications. The addition of tha’.
requirement to the qualifications for tT.5 Clerk 5 General
position is consistent with the requirements of the
classification as set out in the class definition where greater
emphasis on interpretation is set out. When counsel for tr:e
employer relies on the existence of manuals as drastically
limiting the ability of the grievor to modif./ work procedures. !-:,t
overlooks the grey areas found within the information contained
25
in the manuals.
Counsel for the employer also compared -he
qualifications of the Clerk 6 General and referred t0 the
provision found in paragraph 3 of the qualifications' section snd
particularly the portion: "ability to initiate an< TPV:.$e
procedures, and supervise the preparation of a variety of
reports... .'I We can nut see that this higher qualification
required of a Clerk 6 General can affect the fsct of what the
grievor actually does when it fits comfortably within tine
requirements of the position as set o*ut in the class definition
for the Clerk 5 General.
Counsel for the employer alss submitted that :he levei
of supervision which the grievor is subject to is more consistent
with the Clerk 4 General class standard:
"empIoyees receive specific instrjuctions only on unusua1 or
special problems as the work is performed under conditions
that permit littler opportunity for direct supervision by
others. Matters involving decisions that depart radically
from established practices are referred to supervisors.
We were, once again, referred to the Laycock case where ,3t pages
9 and 10 it is stated:
. ,I .The mere fact that the supervisor chose not to exercise
that supervision on a daily basis is indicative of the trust
and faith that he had in the grievor to perform her job well
without constant supervision. It is not appropriate to
interpret the Class 4 standard ae involving any sit*lation in
which a supervisor does not directly watch the employee
performing his duties because -his is unrealistle I i-i an
office setting. In a* Qff ice setting. by its very l-l,+. tlir e .
given that people are working a: desks on pieces of paper.
it is virtually impossible to directly observe th5 pzuson
26
doing his job unless one stands over his shoulder which is
an inappropriate method of supervision. For some reasonable
meaning to be read into this Class 4 standard, it must. mean
that they 4re referring to the fact that in certain
situations, the physical proximity o f the supervisor ir PIIC!I
that little opportunity for direct supervision is even
possible.. . .”
The nature of the supervision affecting the griever must be
viewed in the light of the duties and responsibilities which she
held. The supervision recei.ved by a Clerk 4 General and a Clerk
5 General is functionally similar. What differentiates the two
is the nature of the work that is being supervised. The Clerk 5
General is working at a higher level of sophistication thar. the
Clerk 4 General and, as noted above, the duties and
responsibilities of the grievor fit more comfortably within the
Clerk 5 General duties as set out in the class definition.
Most of the duties of the grievor deal with one-or-one
interactions providing customer service to vendors, businesses
and the genera 1 pub1 ic by explaining their rights and
responsibilities under The Retail Sales Tax Act. 75% of the work
is with what was referred to as “walk-ins” which involved 75% of
inquirers. Most vendor files and associated data base files were
reviewed by the supervisor. following registration, for
sufficiency of file records and correctness of the clerk’s
decisions. Although interpretive letters composed by the clerks
were reviewed and signed by the supervisor to ensure CGrrect
interpretation of the legislation, it follows from a dsscri>tlon
in paragraph 1 i.. found at page 3 ,of Exhibit 9. that most ,.zbzn,ir,!-
files were reviewed only after the work had been completec and
27
this is consistent with the provision -in the class definition of
the Clerk 5 General classification that the work: “is reviewed
for consistency of decision-making. Difficult technica!
questions or those involving policy determination are referred t:~
supervisors. ‘I This is consistent with the further provision in
paragraph 1 i. which states: “in rare and clnusual situations.
consulting supervisor to obtain guidance and assistance c’ 3
matters not covered by Ministry policy. procedures Gr
precidents ” This does not mean that the grie:!or is not required
to make difficult decisions from existing precedents and po! icy
and this is also consistent with her . recuiring a detailed
knowledge of the Act, regulations and local practices.
Counsel for the employer referred t.1; the case of Nec1i.a
and Mathews 70/85 and 71/85 (Swan) at pages 14 and 15:
“No doubt . . . there is very little need to spot check their
work, and they receive very little negative feedback or
advice from either the Senior Clerk or their supervisors.
The fact that they are particularly good at their jobs does
not alter the level of responsibility of what they do nor
does the fact of their competence make the Senior Clerks’
work easier detract from the responsibility assigned to that
position.”
We agree with this statement, however, our decision is not based
on the competence of the grievor but on her responsibilities as
stated in Exhibit 9.
Counsel for the employer argued t?.%t the fact that. t.:;e
grievor spends a good deal of time dealing directly with + ;-.+ _..._
28
.public does not point in the direction of a better fit w;ithin the
Clerk 5 General classification. While there is nothing in the
statement of typical tasks’ that points in the directic;n zvf direct
communication with the public in either classification. the tasks
typical to the Clerk 4 General classification say nothins about a
“clerical accounting function involving the intsrrretation.
explanation and application of a phase of depirtmenta!
legislation or regulations and requiring th:e ability ~3 provide
functional advice.” Rather. the Clerk 4 sS;nerai class stand-rd
focuses on:
“tasks typical to this level include the evaluation and
assessment of a variety of statements, applications. records
or similar material to check for conformity with specific
regulations. statues or administrative crders. resolving
points not fully covered by these instruct ions, ;.:sua 1 I? by
authorizing adjustment or recommending pa>T?.rnt QY~
acceptance. . ‘I
.
While we can agree with counsel for the employer that the typical
tasks are not “watertight”. the language found in the Clerk 5
General classification is much more apt in describing the typicai
tasks of the grievor in carrying out the general purpose of the
position
Counse 1 for’the employer responded to the position
taken by counsel on behalf of the union that the grievor had no
guidance as to how to deal with the interpersonal aspects of
dealing with the variety of vendors, business and the generai
public in expla ining the ir rights and resp,>nsibilities !under The -
29
Retail Sales ?ax Act, by noting that the understanding of the
Ontario Sales Tax manual, dealing with matters of ,default and
delinquency, considers the procedural side of interactif-,:-. with
the vendor. While that is the case, the “Clarification .>f Job
Duties” found at page 8 of Exhibit 9 notes that the griev.;.:’ must
adapt her mode of explanation depending upon whom she is clcaling
with and that ~there are “no manuals and no specific dirct ives
setting out how to deal with this variety and the clerks m.:at use
their judgment, initiative and social skills (eg: ta,::. et
cetera) in dealing with the various inquiries by adjusting the
level of sophistication, language, tone and detail of their
explanations and queries in order to communicate ef feet ive ly ( in
both explanation and questioning).
Counsel for the employer also stated that the Vendor
Administration Manual required approval of forms before any
change was to take place. This point was made in relation to the
statement contained in paragraph 1 i. at page 3 of Exhibit 9
that: “most vendor files and associated data base files were
reviewed by the Supervisor following registration for sufficiency
of file records and correctness of the clerk’s decisions.” This
comment was directed at the assertion of counsel for the union
that. for the most part, the grievor was only revieWed for
sufficiency of decision after the work had been completed.
Whatever the intent of the manual, the agreed to facts ir.icat.2
that the review of the grievor’s decisions only took place after
30
registration of a vendor. Given the agreed to statement of
facts. we can not go behind it.
Counse 1 for the union referred us to the statement
found at pages 12 and 13 of the Lavcock case:
“The third aspect of the class standard is tv..%.t <jf
qualifications. There was evidence. however. wh.ich was
uncontradicted from the employer’s witnesses. that this
particular provision of the class standard is ,:nly used as A
hiring criteria and does net form one of the fr::tot-s ,:.ssd ir:
classifying a job. This position has been .:y;heid irk the
previous awards referred to and therefore, this Board feels
bound-by those previous decisions and as such will no: apply
the qualification section of the class standard ic, the
decision.”
For the reasons given above. even if the qualifications are
considered, they do not support the position of the employer.
In the excellent arguments presented by both counsel.
for which we are grateful, there emerges a description of a
position which has elements of the Clerk 4 General and Zierk 5
General class definitions. As both counsel acknowledged. the
1 anguage of a class standard is, of necessity, written broadly
and not always ,with great clarity. The task of finding the best
fit can not be easily carried out without a clear Ricture of the
purpose of the position. It is to provide a customer service to
those who are or may be covered by The Retail Seles Ta?. Act.
There is an educative, explanatory and interpretive role, and the
various put-poses intertwine. The significant pcrtion of t?~:-
grievor’s time spent in interpretation, simi lar- :y insinuates
31
itself into the ~customer service role an? the rducat ive ro I e
The fundamental significance of having a detailed knowledge of
the legislation, as opposed to a good general knowledge of the
legislation. has a major impact on the 1a:guage set out in the
class standards. It affects the interpretive role and t l-l?
decision-making function. as well a&the mflning -zf the k i nd 0 f
supervision of an incumbent in the classifi:~%tion.
This was not a c5se that Ti3.S easy tr! dec idr
nevertheless, when we procee~ded to car:.:i o~lt the rxerclee.
fitting the duties and responsibilities of ‘-.he grievor into the
respective class standards presented to us, the ,:lear ‘best fit
was with the Clerk 5 General classificatiIn. Accordingly. the
grievance succeeds and the grievor 1 :‘ en: itled to the
classification sought in the grievance. 3y agreement of the
parties, we are to remain seized on the subject of further
relief. Counse 1 for the union indicated That if the grievance
was successful, and if the parties could net settle the matter of
further relief, he would be making submissions with respect to
damages and inter-es: payable.
32
DATED at Toronto this 19th day of F~duary, 11990.
=xv%+
M. Gorsky, Vice-Chairperson
--
H. Roberts, Member
CLERICAL. TYPING, STENOGRAPHIC. RllD SECRETAfUAL CLASS SCRICS
J KI::OS OF I;‘OR< COVEFUZD:
Thcsc five series cover all office positions and office supcrviscry
positions that are not covered by a specialitcd clerical, technical,
,~. 3 equipment operating, or professional class series. ,
GCNERRL CLERICAL SERIES - 7 CUSSES: -
: _
This series covers positions where the purpose is to perform clerical
work entirely or in combination with incidental typing, stcnoqralthic or
machine operating duties. Where exciusion of the latter would significantly
change the character of a position , or where they occupy a large proportion
of the working time, the position should be assigned to one of the
specialized classes, e.g. Clerical Typist. Positions for which specializcd
clerical series exist, e.g. Clerk, Mail and Messenger, Clerk, Filing,.ctc.
shculd.not be assigned 'to thij series. Group leader responsibility normally
begins at the third level, while the fourth and above usually cover positions
involvinq line supervision: however, non-supervisory positions can also be
included. . .
CLERICAL TYPIST SEXES - 4 CLRSSES:
This series covers positions which involve touch typing in addition to
clerical work, where the typing aspect is important to the extent that 1ts
removal would significantly change the character of the job. Touch typing
qua?ifications to Civil Service Commission standards are essential for
inclLrbents of these positions. All levels within this series arc based on
qraiations in complexity of the clerical work with thp first three also
depending on the degree of typing skill required.. However; the clerical 7
conta'r& of these positions is generally less onerous than those at
correspondin$'levels in the Clerk, General Series. The fourth level
represents first-line supervision where typing skill is taken for granted.
TYPIST SERIES - 4 CLASSES:
This series covers all posi'ti;ons &here typing duties account for at
least 75'1 of the employee's working time. Clerical duties are incidental
and nsually follow a set pattern - filing, duplicating, and receptionist
duties. Allocation of positions to the various levels in this scrics is
based on typing skill and relative frecdon from supervision, with the fourth
level representing first-line supervision.
- ._ .-,
(over]
CLERICAL STCNCGkAPIIEX SEfiIES - 5 CLASSCS:
This series covers positions which rcquirc shorthand (or sl*<.Pd-vriLingl.
and or dictaphom? and typing to Civil Scrvicc Commission st.rndrrrd!: in
comhin~tion with a significant element of clerical work.. Allocntion to the
various lcvcls wiLhin the series is based on the complexity of tlw clerical
work and degree of responsibility assigned to the incumbent. korr~lly, the
fourth and fifth lcvcls cover supervisory positions, and the third lcvcl
covers group leader positions; however, non-supervisory positions can also
bc included at any of these levels. The clerical duties involved in thcsc
positions vary widely in both type and Icvel. Althouqh individual clerical
duties may be comparable in level to those found in positions in
corresponding Clerk. General classes, .thc total clerical function is
gcncrally somwdrat lover. A small prbport=f the employee’s time may
be spent in dpcrating office appliances.
SECRETARIAL SERIES - 5 CLASSES:
This series covers positions of Sccretarics to one or mow .x+ministr;ltivc
officials. Receptionist duties, personal contact work and rclicving the
supervisor of administrative routines arc characteristic of thcsc positions.
Some clerical functions, e.g. minor record-keeping, checking cxpcnse.clains.
processing mail and filing are commonly found as incidental duties. Howcvar,
where the clerical work is substantial and present to a significant dcgrcc,
the position should be assessed against the Clerical Stenographer or Clerical
Typist Series. Although elements of supervisory responsibility are mentioned
at the 4 and 5 levels, if such a responsibility is a significant and important
part of the position, it- should be assessed against standards within other
series.
Ability to type at Civil Service Commission standards is a rcquircmcnt
for secretarial positions. Dictation is taken by shorthand, speed writing
and/or dictaphone. Allocation of individual positions to the various levels
within this series is based on an assessment of the judgcmcnt and initiative
required as indicated by the degree -of &legation in.such areas as:composing
correspondence, dealing with enquiries, arraniing appointments;:and
exercising judgernt in handling matters during the supervisor’s abscncc.
.’ -~ In addition to the foregoing elements, the nature of frequent and substantial
senior level contacts is an important allocation factor at’thc 5 level.
Revised June 1, 1978
CLERK 1. GENERAt
CLASS DEFINITION:
Rnployees in positions allocated to this class perform
elementary, routine clerical tasks, which require little knowledge of
office procedures and can be learned within a few hours. Assignments
that are not self-checking are preceded by dettied insttic’cions and
are checked.on completion. AlthoughFin some positions, employees
may assist others by performing parts of more complex assignments,
they are not themselves responsible for the satisfactory completion
of the overall tasks.
This is a texminal class for persons continuously performing
simple clerical activities. It may also cover positions of emplofies
in training for higher level clerical work.
QUALIFICATIONS:
1. Grade 10 education, preferably Grade 12; working knowledge of
arithmetic, spelling, punctuation and grammatical usage; some
familiarity with elementary methods of checking names and
numbers and of sorting and filing.
2. Preference may be given for some satisfactory previous work
experience or training.
3. Ability to ‘understand and carry out simple work instructions
in an office settins; ability to learn to use simple office.
equipment. -
Revised, December. 1963
- ._ .-,
_-
..-
‘) . .
. . .
CLASS DEFINITION: .
Enployees in positions sllocated to this class normally . -
perfona a number of clerical tasks of limited complexity according
to established procedures, where the prime responsibility is.for
accuracy and an acceptable rate of production; Decision+naking
consists of detenoinin g whether material conforms to specific,
set-out procedures or standards and requires little background
knowledge of regulations or statutes. mployees may initiate
standardized letters involving little origiii~qmposit~.?pn_such
as form letters,acknowledgments, reminders, et<; They may also
assist with the training of junior staff. Assignments of unusual
difficulty’are preceded by detailed instructions or are carried
out under close supervision The work is reviewed for adherence
to procedure and acceptable standards of accuracy and volume.
QUALIFICATIONS :
1. Grade lC..education, preferably Grade 12; working knowledge
of arithmetic, correct punctuation; spelling and grarmaatical
usage; some knowledge of common office practices. ~ I
2. At least two years satisfactory experience’as a Clerk 1,
General, or an equivalent combination of experience and
education.
3. Ability to follow specific clerical instructions; ability
and willingness to perform clerical work of limited complex-
ity atbcceptable standards of speed and accuracy. - 1
Revised. December, 1963
, <’
-._ --,
CLERK 3, GENERAL
CLASS DEFINITION :
Bnployees in positions allocated to this class, as ujourney-
man clerks”, perform routine-clerical work-of-some complexity accord-
ing tiY&tablished procedures requiring a background knowledge of spec-
ific regulations, statutes or local practices. Decision4aking involves
some judgment in the selection of alternatives within a comprehensive
framework of guidelines. Initiative is in the form of folloKing up errors - ..-- or omissions and in making Corrections as. necessary. Doubtfui matters
noi?&ered. by-precedent are referred to supetisors . Much of the work
is reviewed only periodically, principally for adherence to policy and
procedures.
Typical tasks at this level include the preparation of factual
reports, statements ‘or memoranda requiring scane judgment in the selec-
tion and presentation of data; assessment of the accuracy of statements
or eligibility of applicants, investigating discrepancies and securing
further proof or documentation as necessary; overseeing, as a Cmup
Leader, the work of a small subordinate staff by explaining procedures,
assigning and checking work.
This is a terminal class for many positions i.nvolviog the competent
performance of routine clerical York common to the office concerned.
QUALTFICATIONS : ’
1. Grade 12 or an equivalent combination of education, training and
eqeriencti. :
e 2. - About t&e years. satisfactory clerical experience’.
-- 3. Ability to understand and explain clerical procedures and require-
merits; ability to organize and complete work assignments within
prescribed time Limits; abilitp to maintain good working relation-
ships with other employees and the public served.
, ,:’
Revised, December, 1963 I
-.-. .-
‘I
QUALIFICATIONS: :
:I,$ 1. Grade 12 education or an equivalent combination of education,
.: @ training and experience.
i; ,~ 2. About four years of progressively responsible clerical exper-
,;: ; ience or au equivalent combination of experience and higher
1 f educational qualifications. --
.: 3. Ability to communi cate clearly both orally and in writing; -
3’9 ability to instruct and supervise the work of subordinates.
Revised, December, 1963 , , ./
4. CLERK 4, GEh’ERAL
.CLASS DEFINITION: ,.. .
/’ hlployees in positions allocated to thxd-class perform a
variety of responsible clerical tasks requiring a good background
> knowledge of specific regulations, statutes or local practices. L*< Decision-making involves judgment in dealing with variations from
restablished guidelines or standards. Normally, employees receive
J specific instructions only on unusual or special problems-as the
.~- work is performed under conditions that pennit little opportunity
( for direct supervision by others. Matters involving decisions that
.? depart radically from established practices are referred to super-
.’ visors. -
,’ Tasks typical of this level include the evaluation or assess--
J’:. ment of a variety of statements, applications, records or similar
/: material to check for conformity with specific regulations, statutes
/+’ or administrative orders, resolving points not clearly covered by
#these instructions~usually by authorizing adjustments or recoimaend-
:uing payment or acceptance; supervising a small group of ujourneyman
, :* clerks” or a larger gmup of clerical assistants by explaining proce-
$ dures, assigning and checking work and maintaining~discipline. ,
CUSS DEFINITION: -
I bployees. in positions allocated to this class perform respons-
2 ible clerical work requiring detailed knowledge of a body of regulations,
I statutes or local practices, together with a thorough understanding of
~. the objectives of the work unit. ” Decision-making involves judgment in
4 the interpretation and application of policy or administrative directives
(/ to problems where the intent of existing instructions is obscure in spec-
5’ ific cases. This frequently necessitates modifving work processes or the
y development of new methods. Although the work is carried out tith a large
4 degree of independence, it is reviewed for consistency of decision+&ing.
,,,: Difficult technicsl questions, or those involving policy determination are
, referred to supervisors.
, “. r Tasks typical of this level include responsibLl..ity for a signifi-
/4 cant non-supervisory, clerical, or clerical accountjng function involving
JY the interprqtation, explanation and application of a phase of departmental
.t ,+a legislation or regulations and requiring .the ability to make acceptable
I, recommendations or provide functional advice; supervising a group of
*’ “journeyman clerkss performing clerical duties of varying complexity or
:$ a smaller group engaged in more specislized work by planning, assigning
and revieving work, deciding-priorities, maintaining production levels
$ and carving responsibility for the total performs&e of the unit.
1.’ CJJALIFICATIONS :
2’ :. 1. Grade 12 education, or an equivalent combination of education, 17 training and experience; preferably completion of additional- + trsining,such as related correspondence and university exten-
4 v sion courses; thorough lmoirledge of office practices and pmce-
:c dures . -- .
-.
I-’ 2 #’ . About six years progressively responsible clerical experience
2f or an equivalent combination of experience and higher educa- : ‘;’ tion.
5H 3. Ability to evaluate the effectiveqess of clerical procedures
i ad staff performance; ab’iJLity to’supervise the work of other ”
f, i- employees; abilitJr to interpret regulations.~and instructions
.I of into procedures and practice; ability to prepare effective
; y correspondence, instructions and reports.
Revised, December, 1963
CUSS DEFINITION:
hployees in positions allocated to this class perforPl spccid-
i:ed complex clerical or sub-professional work which forms a signifi-
cant part of the administration of the organization concerned. Decision-
making requires the analysis of complex problems in specislized clerical
fields or arise from the supervision of a large staff where the volme,
variety and.complexity of the duties is extensive. Considerable judgment
7 in the inccrprccacion and application of a wide.variety of regulations,
statutes or practices is nciessary to resolve these problaas. The work
is reviewed through standardized reporting procedures, principally to
assess the contribution made to branch administration.
QUALIFICATLONS :
3. Grade 12 education, or an equivalent combinntion of education and
expcrirncc: preferably successful completion of extension courses
or similar training related to the work to be performed; thorough
knowledge.eof the techniguer of office management.
2. About cighr. years of responsible clerical experience,-preferably
involving Some related administrative responsibility, 0~ sn equiv-
, alenr combination of experience and higher education.
3. Sound judgment; ability to plan, organire and co-ordinate the activ-
ities of a relatively large group of Subordinates; ability to init-
iate and revise procedures, and supervise the preparation of a variety
.- of reports;‘ability to promote and maintain co-operative working rela-’
tionships . -- -.
Revised. l&ember. 1963
CUSS DEFINITION:
Eaployces in positions allocated to this classperform clerical
administrative work in the implementation of a departmental program.
Although these positions vary widely in the rauge of duties and the
diversity of supervisory responsibilities, they are characterised by
the finality of operational de,cisions made, the complexitp of the pro-
grams administered, and the confidence placed in the recousnendations
of the incumbents.
hployees in these positions receive general instruction on
departmental policy or changes in procedure from an administrative
official who initiates new assignments through expressed objectives.
They supervise personally, or through subordinates, sll activities
in a large clerical-administrative operation. They organise work
assignments, originate, install and maintain procedures, assist in
selection and replacement of staff and integrate the work to produce
results as expeditiously and efficiently as possible.
In some positions, their supervisory responsibility is of a
functional nature due to the geographical location of their subordinates.
In these positions they ensure conformity with departmental procedures,
observe expenditure trends, anslyze problem situations, ‘hnd are respons-
ible for all activities under their control. In other positions, they
perform specialised duties related to the drafting and presentation of
policy statements, instructions to staff and special rep4*s to their
supervisors.
In all positions, they are requirea‘to exerciue tact and judg-
ment and to develop effective working relationships in their personsl
contacts.
gxu.FKATIoNs :
1. Grade 12 education, or sn equivalent combirration of education,
experience, and training; preferably completion of related uuiver-
sity extension or other recognized courses; thorough knowledge of
the principles and techniques of office management; considerable
knowledge not only of the program related to their work assignment
but also of the policies and programs of the deparnaent as a whole.
2. About ten years of progressively responsible, related clerical or
administrative experience or an equivalent combination of related
experience, higher education and specialised knovledge.
(over)
, -2-
51012
QUALIFICATIONS: (Contcd. .)
3. Ability to analyze the cffkivencss of the program for which
they are responsible; superior Judgment in making dccisioas
and in the recon&ndations which they present; marked abiliw
to supervise and co-ordinate in their field of respoasibiliv;
ability to initiate, revise snd interpret a variety of complex
procedures; personal characteristics suitable to good inter- personal working relatiOnships with many professional persons.
Revised, December 1963
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i :
Ay,yr&;:,: “~A,” if ’ ‘r ’
STATEHENT OF AGREED FACTS
Description of the Duties of a Field Services Clerk in the Ministry of Revenue as of the date of Joyce Gustafsson's arievance.
The Puroose of Position
To provide a customer service to vendors, businesses and the
general public by explaining their rights and
responsibilities under the Retail Sales Tax Act:
To educate private and public sector regarding the
application of Provincial Sales .Tax by explaining and
advising those sectors as to their responsibilities under the
Retail Sales Tax .A&;
To register vendors in accordance with the requirements of
the and to maintain related records
manually and via use of an on-line computer terminal;
To provide clerical and reception support services for the
office;
All of the above must be done in a courteous, pleasant and
professional manner.
Summary of Duties and Responsibilities
1. a. Processes and ensures applicants (e.g. the general
public, businesses, lawyers; accountants, engineers,
75% M.P.P. offices, hospital administrators, Federal
Government offices, Municipal officers, school boards,
universities, etc.) registering for a vendor's Permit
meet the requirements and intent of prescribed
legislation, policy and procedures detailed in the
2
Ministry's manuals (e.g. Vendor Administration
Understanding Ontario Sales Tax Manual) by:
responding to verbal, written and in-person inquiries
requesting information on obtaining a Vendor's Permit by
explaining and. interpreting registration requirements
and, in cases of non-voluntary compliance, by contacting
vendors, potential applicants where there is the
possibility that new registration is required;
b. Querying applicants to obtain information necessary for
the completion of Registration Questionnaires and
related forms such as AC-27's (e.g. goods sold,
commencement date of business, value of purchase
chattels) L.L.B.O. licensing. This function involves
the interpretation and the explanation of the law
relating to the specific sort of business the applicant
is engaged in so as to explain to the applicant what
laws, regulations, etc. apply to them:
C. Assessing and interpreting information to determine
applicant's eligibility or need for a Vendor's Permit
and to identify the need for additional documentation:
d. Advising applicants a Vendor's Permit is not required
under the Retail Sales Tax Act due to the nature of
their business (e.g. wholesale manufacturer). This is
done by interpreting the Retail Sales Tax Act and by
eliciting the necessary information regarding aspects of
the business and aprjlying this information in the
interpretation and application of the Act:
e. Obtaining and checking Vendor application forms for
completeness and advising applicants of corrected action
required (e.g. additional partner's signature, proof of
incoruoration. etc.):
7
f.
4.
h.
1.
3
Accessing the data base file via an on-line computer
terminal to verify or identify applicants previously
registered for a Vendor's Permit and to obtain
information on their past history (e.g. compliance
record, file status). This is done in order to check if
the applicant already has a Vendor's Permit, owes money
(e.g. taxes due or delinquency), if the vendor had gone
bankrupt, if there is a take over from an existing
business i.e. whether there is a roll over and to whom
or if two accounts are to be linked. This also involves
arranging for a smooth transfer of a L.L.B.O. license in
cases where the vendor is impecunious;
Preparing forms such as AC-27's, AC-41's, TR-4's, Vendor
form letters etc. to adjust vendor accounts (e.g.
reverse default penalties, extend filing periods). AC-
27s and AC-41s are reviewed for correctness and approved
by the Supervisor:
Investigating periodic computer reports such as Net
Account Balance, Compensation Warning and Chattel Tax
Follow-Up Reports by reviewing vendor computer file,
obtaining and/or verifying information with vendor or
his representative, explaining procedure and preparing
necessary documents of action to be taken for
supervisor's signature (e.g. A103 initiating refund of
overpayment sales tax). This may involve providing
follow-up explanations after the investigation. A103s
require the approval and review for correctness of the
Supervisor.
In rare and unusual situations, consulting supervisor to
obtain guidance and assistance on matters not covefed by
Ministry policy, procedures or precedent. Most vendor
4
files and associated database files were reviewed by the
Supervisor following registration for sufficiency of
file records and correctness of the clerk's decisions.
Vendor files required initialling by the Supervisor.
The Supervisor provided monitoring of telephone advise
and the communication skills of clerks by listening to
clerks side of conversation only, while they were on the
phone. Interpretive letters composed by the clerks
were reviewed and signed by the Supervisor to ensure
correct interpretation of the legislation. Regular
meetings were held by the supervisor in order to
communicate and discuss any change in Ministry procedure
or interpretation, and to answer the questions of staff.
The reports outlined in paragraph l(h) were spot checked
by the Supervisor to ensure that files were being
actioned appropriately.
k. Actioning documents, applications, etc. for Senior
Citizen's Tax Grants (G.I.T.C.) and providing
information to 'cca3p;blic regarding these programs.
Actioning form +J-s for Corporation Tax Branch.
Actioning L.L.B.O. clearances. L.L.B.O. clearances were
reviewed for correctness and approved by the Supervisor.
2. Performs clerical and key-operator duties required for
the maintenance of tax roll data by:
15% a. Monitoring single event computer listing and noting
vendors to be deleted ‘from the data base file;
b. Contacting vendors, accountants, lawyers, etc. by phone
or correspondence to obtain and verify information
pertaining to the closed-out of vendors and preparing
necessary forms (e.g. T.R. 105). This involves the
explanation, interpretation of the law and policy
C.
d.
e.
f.
4.
h.
3.
10% ~a.
5
related to this function. This also requires a
determination that a close-out is an actual one versus
for example a mere transfer:
Following-up with vendors, purchasers etc. by telephone
and letters to resolve unidentifiable tax remittances
and to collect tax from the sale of boats or aircraft:
Preparing necessary forms and ensuring the correctness
of such forms as TR-4's, CO-lo's, AC-24's, AC-27's, AC-
41's, etc. for submission to Taxation Data Centre for
computer input:
Operating an on-line computer terminal to update the
vendor data base file on basis of information obtained
from telephone calls, correspondence and reviews (e.g.
address changes, raised assessments) this function
includes determining whether or not there are credits on
file and clearing them up if necessary. This involves
the maintenance of the data bases integrity:
Maintaining hard copy vendor records by filing
correspondence, transferring vendor files to appropriate
district office upon relocation of businesses etc.:
Maintaining a record of equipment malfunctions, repairs
and general maintenance, daily response/down-time of
terminals:
, .
Monitoring L.L.B.O. change list to ensure data base
integrity.
Performs other related duties such as:
Maintaining control of receipt books and petty cash
6
funds, accepting/verifying cash payments, issuing
receipts and making bank deposits;
b. Typing correspondence from notes, handwritten drafts and
verbal instructions:
C. Acting as receptionist by greeting public and/or
answering the telephone, providing forms and general
information etc.;
d. Opening and distributing incoming and outgoing mail:
e. Following-up with out-of-province contractors working in
the province to ensure no loss of sales tax;
f. Monitoring Registry Office property transfer list of
follow-ups and ensure taxes on chattel are paid. This
includes analysing, investigating and assessing these
transfer lists:
4. Maintaining a record of work activities (e.g. number of
telephone calls, visits (for report purposes);
h. Filing vendor hard copy records as required;
1. As assigned.
Skills and Knowledge Required *
An excellent knowledge of and the ability to apply,
interpret, explain, advise about, research, investigate, and
enforce relevant Retail Sales Tax Legislation, policy rulings
and procedures set out in Ministry operating Manuals (e.g.
Understanding Ontario Sales Tax Vendor Administration,
Default and Delinquency Manuals); excellent communication
7
skills and the ability to deal tactfully and courteously with
the public in a professional manner; this communication
involves the ability to communicate clearly, competently,
concisely, etc.: demonstrated satisfactory related clerical
experience: ability to handle stressful, complicated,
constantly changing interpersonal situations in which
interruptions occur frequently; ability to exercise sound
judgment, work independently under a low level of
supervision; ability to organise and ~complete work accurately
within strict deadlines on ones own: a general knowledge of
the Ministry's organisation programs; ability to type.
,
8
CLARIFICATION OF JOB DUTIES
1. 60% of the Clerk's time is spent in interpretation.
2. 75% of interpretation questions are covered by U.O.S.T.
manual, although some questions require significant
research.
3. 20% of interpretations are answered through
**extrapolation" from U.O.S.T. by using analogical
reasoning.
4. 5% of the interpretations require interpretations
directly from principles set out in the legislation. In
these circumstances Fields Services Clerks are expected
to review her interpretation with the supervisor. In
over half of these cases answers have already been given
to the taxpayer. Field Services Clerks in Hamilton are
correct in a high percentage of time. If Field Services
Clerks are incorrect, Clerks usually must contact the
taxpayer and supply the corrected advice.
5. There is a great variety of inquirers, from the barely
literate to the highly sophisticated and the Clerks are
required to deal with these persons (as set out in the
agreed statement) on a one by one basis (walkins - 75%,
telephone 20%, written - 5%) and must adapt their mode
of explanation dependently upon to whom they are
speaking at any given,time.. There are no manuals and no
specific directives setting out how to deal with this
variety and the Clerks must use their judgment,
initiative and social skills (e.g. tact, etc.) in
dealing with the various inquiries by adjusting the
levels of sophistication, language, tone, and detail of
their explanations and queries in order to communicate
”
9
effectively (in both explanation and questioning).
Some inquirers may be hostile and/or difficult to deal
with. The Clerk is expected to deal with these
problems on her own in the first instance. The
supervisor was available to assist with difficult
clients and did assist on some occasions. In "non-
voluntary compliance (l(a)) this problem is especially
acute. The Clerk must '*coaxV*, 11explain8' and "be firm"
without jeopardizing the image of the Ministry. This
element of the job description is the most difficult and
time consuming part of the job.
, .