HomeMy WebLinkAbout1987-0959.Ethier.89-06-02EMPLOY& DE LA COURONNE
DE L’ONTARIO
GRIEVANCE C$IMMlSSlON DE
;;W&MENT REGLEMENT
DES GRIEFS
180 Lwm*s STREET WEST, TORONTO, ONT*R,o. M.50 1Z8 - sum *ml
,8R RUE o”N*As OUEST. TORONTO. ,ONTlRIO,~M50 x8- BURUU21W
Between:
TELEPHONEIT~LdPHONE
,,,8,588-05.98
959j87
IN THE RATTER QP AN ARBITRATION
Under
TRE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
TEE GRIEVANCE SBTTLERENT BOARD
OPSEU (Ethier)
- and.-
Grievor
The Crown in Right of Ontario (Ministry of Health)
Before: R.w. Wright
J.D. McManus
M.F. O’Toole
Employer
- Vice-Chairperson - Member - Member
APPEARING FOR M. Ruby
TRE GRIRVOR:~ Counsel Gowling & Renderson Barristers & Solicitors
8. de Matte0
Representative Ontario Public Service Employees Union
APPEARING FOR W. Parson
TRR EMPLOYER: Counsel Sanderson, Laing Barristers & Solicitors
REARING: June 13 & 14, 1988 September 15, 1988 November 21 6 22, 1988
January 26, 1989 - Written Submission by Mr. Ruby February 17, 1989 - Written Submission by Ms. Parson March 3, 1989 - Written Reply by Mr. Ruby i
DECISION
This case is about video display terminals (VDTs). The
Grievor and her Union are apprehensive about the possibility
that the VDTs may release invasive radiation 'emissions. The
Employer is confident ,that the VDTs are safe. Predictably, the
parties adopt positions which are quite contradictory.
The relevant provision of the Collective Agreement reads
as follows:
"18, 1 The Employer shall continue to make reasonable
provisions for the safety and health of its
employees during the hours of their employment.
It. is agreed that both the Employer. atid the
Urnon shall co-operate to the fullest extent
possible in the prevention of accidents and
in the reasonable promotion of safety and health
of all employees."
IunderliniQg added)
The factual background of the case is extremely important.
Although the Grievance is dated January 14, 1987 the situation
actually began to evolve in October' 1985. The Grievor has been
employed at all relevant tirries by OHIP. OHIP employs, we were
told, the largest number of data entry opera& &an any other
department- of the. Provincial Government in Ontario. For some
time, OPSEU Local 628 had been active in the' ergonomics aspect
of OHIP's operations, the Union's objective being to obtain a
better work,. environment' for the operators and, specifically,
to ensure that the WDTs did not leak harmful radiation.. Accord-
ingly, on October 8, 1985 Peter Slee, OPSEU's.staff representative
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in its Sudbury Regional Office wrote:! a letter to Mr. il. A. Laurin, 1!
Olrectof of OHIP's Sudbury District Office as follows:
"Please consider this letter a formal request for
permission to have the KIT equipment in your operation
tested for radiation leakage at the cost of the Union.
Please advise me whether such teiting would be permitted
and contact this office to arrange a mutually convenient
date and time for the testing.': :' II
The reply to Mr. Slee's letterml came from Mr. J. Campbell,
il
Acting Director of the Sudbury Dist,ri,ct OHIP office by a letter
dated October 17. 1985 which said: \:
II
"In regard to your request fof permission to have
the V.D.T. equipment in our operation tested for radia-
tion leakage. I
We will permit such testing pro&ding that O.P.S.E.U.
assume the total cost of the itest; makes all the
necessary arrangements and works +ith us for a mutually
agreed "to-date" and time to avoid little if any inter-
ruption of our operation." I,
'I
The VOTs at the Sudbury OHIP office were thereupon tested
at the expense of the Union by Radiatiin Environmental Management
Systems Inc. The testing by the latfer firm was conducted by
Dr. Hari Sharma. who is Professor of Chemistry at the University
of Waterloo and who has a background in,,Nuclear Yaste Management.
Dr. Sharma's report was submitted in]Oecember 1985. A total
of 17 VOTs were tested for electromagnetic radiation emissions.
Dr. Sharma tested the VOTs for ultraviqlet. infrared, microwave,
I,
radiofrequency. very-low-frequency and ,, extremely-low-frequency
,
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radiation. One of Dr. Sharma's conclusions was a,s follows:
"All above mentioned units showed very low emission
level of x rays, uv, ir, microwave and rf radiation.
The levels were found to be well below the maximum
permissible levels considered safe with respect to
occupational exposure to the radiation."
The acronyms have the following meanings:
uv -- ultraviolet.
ir -- infrared
rf --.radiofrequency
Dr. Sharma's report expressed some concern, however, about
3 of the units tested in that they' emitted magnetic fields in
the extremely-low-frequency range particularly when the operator
is seated within a distance of 25 cm. of the video display
terminal. Dr.. Sharma's report contained "Comments on Health
Effects due to Exposure to Pulsating Electric and Magnetic~ Field".
' He stated in part: ,.
"The biological effects due to prolonged exposure
to such fields are not 'yet well documented. As a
precautionary measure we recommend shielding of
terminals which we believe, may have E- (electrical)
and H- (magnetic) field of high enough magnitude at
the surface, so as to cause 'adverse' health effects
like excessive fatigue, headache, nausea etc. to a
significant fraction of VDT workers. .It is intended
to follow latest developments in this area .and -keep'
our clients informed of the latest results. In the
meantime while making xecomnendations we follow the
internatianally accepted ALARA (as low as reasonably
achievable) principle in the area-ofradiatlti. Hore-
Ger, it is 'our opinion that shielding of terminals
can be achieved at a reasonable cost and RENS (Radiation
Environmental Management Systems Inc.) can provide
assistance, if need be, in designing an appropriate
shield for a particular model of terminal. It must
be emphasized that the shielding of the fly-back
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transformer is often not sufficient. There are other
components, namely the yoke. jtwo coils and in some
instances switching power supply unit which emit vlf
radiation.' I,
I
The Sharma report was the subje& of discussion at an Employee
II Relations Committee meeting held at Sudbury on April 24. 1986.
The meeting was attended by senior management personnel including
Mr. C. G. Friday, Manager of the ;iOHIP office at Sudbury and,
on the side of the Union, Mr. Slee and the Grievor who was then,
!i
and still is. the President of OPSEU Local 628. The Minutes
il of that meeting, which were prepared by Management, reflects
the discussion which took place. )\
I!
"Item 1 - Radiation Report on Terlninals
Data Entry Terminals 2, 3 and;/4 in back row had a
higher reading. After discussion Hr. Slee agreed
to obtain trade name of shielding material from 8.
natteo and approximate cost. ;'Possible that present
shield inside left hand side surface of casing should
be realigned or replaced. Mr.: Slee to contact Or.
Sharma for recommendations on ;I procedure to shield
terminals and will endeavour to have reply in one
month." li ii II
Dr. Sharma was contacted. He volunteered to see what could
I)
be done to provide shielding if one of the machines were loaned
i
to him for work in his laboratory. ip'. Sharma asked the Union
to pay the cost of shipping a machin! to his laboratory and he,
Dr. Sharma. would test a shield devic). install it and test the
shield for emissions. Apparently, if. Sharma was prepared to
do that work at his own expense, that if to say, without fee.
,. ,
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Mr. Slee said that a spare VOT was available at that time
since it was not in use. He called, Mr. Friday, who' expressed
enthusiasm for the idea; Mr. Friday is quoted as having said
"Great. A good idea!" Mr. Slee agreed Lthat the Union would
pay the shipping costs involved. ~About a week later, however,
Mr. Friday called Mr. Slee stating that he would have to take
the matter up with his head office in Kingston. Mr. Slee testified
that he was told that the Sharma report would be submitted to
the Ministry of Labour.
In December 1986 Or. A,. M., Muc, Supervisor, Non-Ionizing
Radiation Safety; Special Studies and Services Branch submitted
a statement on the subject which turned everything around. Or.
Muc said the following:
"Report was reviewed and brief. conanents are attached.
The reported measurements confirm the conclusion reached
by RPS and other agencies, that there is no health
hazard due to low level radiation from VOTs.
Advice.to IHSB
No action necessary. ,.
Except for the "very-low-frequency vlf ( kHz - 3 MHz1
range, REMS dismisses all emissions as insignificant.
For the vlf rahge REMS ignores the car.)-esponding limit
cited in the'table on page 2 (100 mW/cm for which the
equivalents are 600 V/m and 1.6 A/ml and makes' up
its own - 25 V/m and 4 A/m at the viewing screen,
100 V/m. and 100 A/m at other surfaces except"for the
.top where 30 A/m is accepted. However these limits
are' irrelevant since for all the machines tested,
the vlf electric and magnetic fields at 25 cm (about
10 inches) from all: surfaces' were reported as zero
or negligible. Therefore worker exposures, are all
zero or negligible and no further action is necessary.
The ,extremely low frequency magnetic fields reported
at 25 cm from the various surfaces of the VOTs are
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comparable to the natural ambient magnetic field of the earth. The variabllityli probably results froa
minimal enhanceemnts or cancellations produced by
the terminals. Again no action!)is indicated.*
/I I
i\
Not surprisingly, Mr. Slee was (upset by this turn of events.
II His unhappiness is reflected in a rletter which he wrote to Hr.
Friday on December 18, 1986 which reais as follows:
.I
j
‘I received yesterday, a copy ;!of the report from A.
H. Muc of the Ministry of Labour relating to the report
of Or. Sharma on radiation emission from the video
display terminals in your operation.
Needless to say, we dispute Mr;. Muc's report and will
'be processing an appeal through the appeal procedure
under the OCcupational Health and, Safety Act.
Meanwhile, I %alieve that an' understanding exists
between yourself and Local 6281) whereby an effort to
determlne the feasibility of shielding this equipment
mould be made. Further to that understandlng. an
offer to shield, free of charge, one of the pieces
of equlpeent was made by Or.;: Sharma and forwarded
to you through this office. Should the cost of shipping
be a problem, Local 628 has i)dicated a willingness
to pay even this cost. J
Therefore, given that you have al)study from a reputable
scientist recommending that shielding take place,
plus an offer to perform prototype shielding free
of charge, so that the feasibility of shielding can
be determined, I suggest that fai,lure to take advantage
of the offer of prototype shielding would be unreason-
able in the circumstances, and I'might well constitute
a violation of Article 18.1 of the Collective Agreement.
Further, I suggest such failure jould be also a breach
of good faith.
I trust therefore, that you will be fulfilling the
conitments made earlier in this matter and will be
so advising us in the near future.;;
I would point out again, that Local 628 is prepared
to pay for the shipping costs if such assistance is
required by the Ministry." I
I
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It will be noted from the third last paragraph of the letter
quoted above that Mr. Slee was, giving some thought then to filing
a Grievance for violation of Article 18.1 of the;Cqllective Agree-
ment.
Mr. Friday replied to fir. Slee on January 2, 1987 as follows:
"This is to acknowledge receipt of your letter dated
December lath, 1986.
At the time of your verbal offer that' Local 628 was
prepared to shield one of the pieces of equipment
by Dr. Sharma, I conveyed to you that any. further
action on our part was. after discussion and guidance
from our Kingston Head Office.
Accordingly I contacted' the Ministry of Labour on
November 19th. 1986, regarding the report completed
by RENS on VDT terminals.
The Ministry of Labour inspector Mrs. 'Joanne Derks,
met 'with ~. myself, Muriel 'Ethier, DPSEU President and
Mrs. Doreen Peters, Administration Manager on December
11, 1986. and presented the Report Review from Dr.
A. M. Muc, Supervisor ,Non-Ionizing.Radiation Safety
Branch of the Dept. of Labour. This report states
that there is no health hazard due to low level
radiation from VDT's and,that no action is necessary.
Based on this information from the Ministry of Labour,
I would suggest we have taken all reasonable pre-
.~ cautions, and on the basis of this report no further
action will be taken.
'For your information a copy of this letter will be
forwarded to the Dept. of Labour for their information."
, Mr. Slee felt that the position t'aken by Or. Muc had under-
mined wha‘t had been..previously achieved by the parties. The
Union, therefore, appealed against the disposition *of the matter
by Dr. Muc. An "appeal meeting" was held nn February 28, 1987 _
which was attended by representatives of ~management and labour
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at Sudbury and also by B. Thomson, Area Administrator, Industrial
I' Health and Safety Branch, Ministrj of Labour, who obviously
1 attempted to mediate the dispute and,,bring the parties to a mutual
agreement. Following the "appeal ()meeting" , Hr. Thomson wrote
to Dr. Muc on March 2, 1987 as follow::
I I
"I met with both union and man$gement representatives
on Friday, February 20. 1987 in an effort to bring
about a mutually acceptable solution.
At the conclusion of the meetin; Mr. Peter Slee [Staff
Representative, Sudbury Regional I)Office. Lasalle Blvd.,
Suite 2021, Sudbury, Ontario, P8A 1281 requested that
the Ministry of Labour answer the following questions
prior to his making a decision whether to continue
with the Appeal. )I
First, is the Ministry of Labour:, prepared to reconmusnd
to the Ministry of Health that they should accept
the offer of free testing by Dr. Sharma?
Secondly, if the Ministry of Labour is not prepared
to reconvnend the testing, they? would like to know
why we would not proceed and are of the view that
our report is undermining the 1.R.p.
Could you respond to these questions either directly
to Mr. Peter Slee or through my'loffice. This matter
is also being grieved by the uni,,on under Article 18-l
of the collective agreement with the step-2 meeting
set for March 11. 1987. If possible, Peter Slee has
requested our response prior to this meeting." 1;
I
Dr. MIX'S reply left no doubt patever as to his views.
He responded on March 18. 1987: !I \(
"The Radiation Protection ServicelJ has been intimately
involved in investigating the ':various claims and
allegations of radiation hazards from VDTs since well
before the issue attained prominence in Ontario in
the late 1970's and early 1980's. ;
In all good conscience the Radiation Protection Service
cannot "recozmnend anything that is considered to be
I I I
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an almost total waste of time and effort. It is for
this reason that the Service has not done any routine
testing of VDTs for radiation emissions in over five
years. We cannot ourselves (and indeed should not)
expend valuable resources where we have. every reason
to believe (as Dr. Sharma's own measurements have
confirmed) that worker exposures are zero or negligible
and consequently we would not "reconunend" that anyone
else do so. In our view, the more testing that is
done (even though nothing significant has ever been
found) the more people are led to believe that there
might be something hazardous to protect against.
The Radiation Protection Service. fails to see how
its assessment of the issue is undermining the I.R.S."
(underlining added)
DPSEU did not take too kindly to Dr. Muc's disposition of'
the matter and the issue was appealed by the Union to the Director
of Appeals pursuant to Section 32 of the Occupational Health
and Safety Act, R.S.O. 1980, c. 321 and amendments thereto.
The Director of Appeals exercised her jurisdiction under Section
1412)(g) of, the Act. As will be seen later; the Employer attaches
great importance to the, decision of the Director of Appeals and
we set out, therefore, at this point the provisions of Section
1411) and 14(2) of the Act.
I 4.-(l) An employer shall ensure that.
(a) the equipment. materials and protective devices as
prescribed are provided :
(b) the equipment. materials and protective devices
provided by him are maintained in good condition; ;
(c) the measures and procedures prescribed are carried
out in the work place: ., _
(d) the equipment. materials and protective devices
provided by him are used as prescribed: and
(6) a floor. roof. wall. pillar. support or other part of a
work place is capable of supporting all loads to which
it may be subjected without causing the materials
therein to be stressed beyond the allowable unit
stresses established under the Building Code .irt.
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(2) Without limiting the strict
an employer shall.
(a) provide information, instruction and supervision to
a worker to protect the healt,h or safety of the worker:
(6) when appointing a supervik, appoint a competent
. person:
b (c) acquaint a worker or a peF;son in authority over a
worker with any hazard m the work and m the
handling. storage. use. disp&l and transport of any
article. device, equipment oi:a biologxal. chemical or
physical agent: I:
Id) afford assistance and co-op&tion to a committee
and a health and safety tepr&ntative in the carrying
out by the committee andlithe health and safety
representative of any of then functmns;
‘I
(c) only employ in or about a w&k place a person over
such age ss may be prescribe$
cfl not knowingly permit a p&on who is under such
age as,may be prescribed to!;be in or about a work
place : ‘I II k) take every precaution retinable in the circum-
stances for the protection of p worker: and
(I) past, in the work place, a c:py of thh Act and any
explanatory material prep+cf by the Ministry.
both in English and the majority langunge of the
work place, outlining the rig?& responsibilities and
duties of workers. !;
ii
(underlining added)
/I The Union's case was supported bylithe evidence of Or. Kenneth
Taylor, a physicist with the highest kedentials. The case for
I!
the Ministry of Labour was supported by the evidence of Dr. Muc. I'
The decision of the Director of Appea:is sumafizes Dr. .Taylor's
position in the following words: in
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"It was Dr. Taylor's opinion that the study of the
effects of non-ionizing radiation is a new field which'
needs further investigation. Dr. Taylor himself has
tested VDTs for ioniting radiation and found that
there is no problem in this area. He has not tested
VDTs for non-ionizing radiation and has no knowledge
with regard to the question of whether any specific
level of non-ionizing radiation would have negatives'
health effects on operators. or persons exposed to
VDTs. Dr. Taylor suggested that there may be some
phychological and physiological effects of exposure
to VDTs'and that eliminating the non-ionizing radiation
emissions with. shielding would satisfy the users of
these devices. Dr. Taylor was not able to state that
there was any hard scientific data to support this
position other than the fact t,hat it would be a simple j
technique not only to measure the levels but to reduce
the emissions without high economic costs and that
it would ma@ scientific sense to do so."
Dr., Muc's position was firm. It is quite correct, we believe,
to say that Dr. Muc was dogmatic in his position and he allowed :
for no margin of error in his views. His evjdence is suasnarized
by the Director of Appeals as follows: .- -~
"On cross-examination, Dr.: Muc abreed that standards
for VDT emissions are just being'developed and that
no~one knows with any certainty whether there are any
detrimental effects at any specific level over the
long term. However, without any data other than
.,anecdotal material, Dr. Muc did not feel that there
-is sufficient evidence to order that any action be
taken. This position took into-account both Dr. Sharma's
report and Dr. Muc's review of the scientific liter-
ature. Dr. NC'S position was that this area is being
actively pursued because there is a dearth of inform-
ation and scientists are interested in expanding their
knowledge in this field. Based on the scientific
evidence in peer-review papers and conferences which
he has attended and after consulting with other
professionals knowledgeable in this area, Dr. MUC
did not feel that there was any reliable evidence
of detrimental e ec s ff
emissions fromVFfs."
(underlining added)
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The foregoing positions were cl/Tracteristic of the postures
adopted before us by both parties. (On the one hand, the Union's il expert witness sounds a warning that there may still be lessons II
to be learned and calling for cautio) in order to avoid, however
unwittingly, the possibility of cobitting injury to health.
II On the other hand, the Employer's ex;yett witnesses express total
confidence that there is nothing more)to be learned on the subject
Ii and consequently no further need to take precautionary steps I
to achieve reduction in radiation &issions. In fact,one of I
the Employer's expert witnesses sawi further study or research
;(
on the subject as being disturbing to the peace of mind of the
ij
,employees in question!
At any rate. the Director of Appials, who is a lawyer, con-
cluded as follows:
"There is no hard evidence before&m to say that there
is a hazard in the workplace against which the employer
should be taking reasonable precautions and it would
be inappropriate to use this section of the Act in
such a speculative manner. Of course, if scientific
information comes forward such that there is scientifi-
cally reputable information upon\ which to rely, at
that time it would be appropriate to reconsider the
issue.
not
However. in the absence oflsuch data, it would
have been appropriate for the Ministry of Labour
to order any employer or employee to take any steps
with regard to this issue.' 1
I( (Underlining added)
Ii
J
II
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On January 14, 1987 the Grievor filed her.Grievance which
is to the following effect:.
"STATEMENT OF GRIEVANCE
' I grieve that the failure of the Sudbury OHIP admini-
stration to take advantage of an offered free study
into the feasibility of ,shielding the office's VOT
equipment constitutes a violation of Article 18.1
of the Collective Agreement.
SETTLEMENT DESIRED~ '
That the offered,feasibility be accepted and implemented
by the Employer immediately."
I.
.’ ~. ,
The Grievance invokes Article 18.1 of the Collective Agree-
ment hereinbefore set for~th at the beginning of this Award.
Both sides introduced a great deal“ of technical evidence . .,
before us. The Union relied'upon the evidence of Dr.' Karel Marha, .I
a' Ph.D. ~* in physics with impressive ,credentials. The Employer
called two highly qualified witnesses, one being Dr. Maria Ann : I*
Stuchly, a Ph.D. in electrical engineering and Dr. -Alison D.
: 1: ,:.,
McDonald, a Medical Doctor specializing in epidemiology and pre
.
and post-natal development of children. The Employer acknowl,edged _~ ::
that Dr. Marha was an expert in his field. The Union acknowledged
that Dr. Stuchly and Dr; M&dnald'were experts in their respective
fields. '
. . 1
I.
.,
He were bombarded by' both sides with technical evidence
F 'we had the expertise co decide which arguments' had the
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I:
greater valfdity. The difference in the conclusions drawn between
1 the experts is startling. The evidence of the Ministry's two
(I
experts was to the effect that there is no danger of radiation
;!
exposure from the video display terminals. Their evidence was
II
that there is no greater danger from VDTs than there is from
Ji exposure to electricity in the home;
I'
They concluded that there
is absolutely no need for any more research on the subject.
I) One of the Ministry's witnesses described such research as "a
waste of time and effort". In fairness to them we point out
II that they presented substantial research in support of their
conclusions. (/ Indeed. both of the Ministry's experts participated
II in much of the research.
\
The expert witness called by th'e Union,
li
on the other hand,
adopted a much less dogmatic approach. He refused to state
!I categorically that video display terminals emitted radiation
II
which would have adverse biological (effects. Instead, he said
that scientists should be punctuatjhg their research writings
I/ with exclamation marks and' that they should be expressing a
1
caution or a warning to anyone who,; is studying the subject.
Dr. Marha, II the Union's expert witness, stated that scientists
s still do not know all that should be known concerning the physical
effects of exposure to electromagnetic fields.
I:
He warned that
the emissions from VDTs could have an effect on cellular activity;
:I he was cautious to say that VDTs could -- not would -- have such
adverse physical effects. Indeed, Dr! Marha stated that recent
I)
.
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research would suggest that there must be constant ongoing testing
and research. Dr. Marha pointed to recent experiments being
carried on in six laboratories in Canada, Spain,. Sweden and the
United States. The purpose of this set of experiments, which
is known as Project Henhouse, was to examine the effects of a
weak, low frequency, pulsed magnetic field on early embryonic
development of the fertile chickens egg. Ne' referred us to a
report published in the Bioelectricmagnetics Society Newsletter
of May/June 1988 in which the following appeared:
"Two of the six .laboratories demonstrated a
significant increase in the incidence of developmental
%Iormallt1es. Three of the remaining four laboratories
maanetic i
,osure to the low-level pulsed
~-a~-- - .ield was found..
made to have ldentici
While every attempt was
Gnditions in .each laboratory,
some variables could not be,controlled, and differences
in the results between laboratories were observed.
On the basis of all their results, the investigators
in Project Henhouse have concluded that exoosure to
weak pulsed magnetic fields, under certain conditions
as yet undefined, can cause significant developmentai
abnormalities in the chicken embryo."
(underlining added)
The importance of the experiment in our context is that
the emissions to.,the baby chicks were similar to those emitted
by video display terminals. Dr. Marha was careful to point out
that one cannot extrapolate automatically that the biological
effects on humans would be the same as those on baby chicks.
We were also referred by Dr. Marha to an article published by
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a scientist in Finland entitledl' "Measurements of extremely
low-frequency magnetic fields video display terminals".
The study concluded as follows:
"In conclusion, the ELF magnet:c fields around a VDT
are not hazardous to human health according to present
knowledge. However, several :biological experiments
suggest that also weak magnetic fi(ields may have biologi-
cal effects with unknown mech.anisms. Additional
biological experiments are necessary to contlrm the
suggested effects and to find the mechanisms and dose-
response relationships or these e~ttects."
l (underlining added)
Counsel for the Employer placed much emphasis on the decision
Ii
of the Director of Appeals under T,he Occupational Health and
Safety Act which upheld the Minis&y's position. The action
taken under the Act is not an impedim&t to our exercise of juris- - II
diction which flows from Sec. 19 of the Crown Employees Collective
Bargaining Act.
1
The Ministry asks us to apply the same onus
II of proof as did the Director of Appealsllunder the Act. For reasons
which follow we do not agree. I) -
I Ii This Board has no hesitation in/ disclaiming competence to
II
make an informed decision as to wheiher or not video display
terminals involve harmful radiation. i, Fortunately, in order to
exercise our jurisdiction we do not have to make that decision
and, indeed, we expressly refrain from &ing so. Our responsibility
is to interpret and apply i j the relevant~ section of the Collective
3reemant between the parties -- Article 18.1. Counsel for the
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Ministry seeks to impose a very heavy ,burden of proof upon the
Union. We,have the advantage of. having received from counsel
for both parties extremely well-prepared and researched legal
submissions. The following excerpts from the submission of counsel
for the Ministry state the burden which the Employer says must
be discharged by the Union:
"The union has failed to demonstrate a real or serious
possibility of harm due to radiation from VDTs, and
even if it had, there is no evidence to prove that
the alleged harm would be reduced by the union's proposal
to allow Dr. Sharma to design shielding."
. ..there can be no enforceable duty to cooperate
independently of a health hazard that triggers it.
In the absence of a health hazard, there is no issue
.requiring cooperation. If the union is dissatisfied
with the employer's response to a perceived health
and safety issue, it must bear the burden of proving
that the risk of harm is a real and serious one, not
a remote one, before it can enforce the duty of co-
operation under the agreement. The union has failed
to discharge that onus."
"Furthermore, where the union seeks cooperation in
a Very specific course of action, as it does' here,
it bears the burden of proving that the proposed course
of action would reduce the harm to health. The union
has failed to do so by its failure to call any admissible
evidence on Or. Sharma's shielding proposal."
We do not agree that the Union must prove actual or real
harm before Article 18.1 of the Collective Agreement can be
invoked. Indeed, we find it surprising' that the Employer seeks
to detach itself from the underlying problem and to impose the
entire onus upon the Union. Surely the Union is entitled, in
- 18 -
the language of Article 18.1 of the Collective Agreement, to
11
co-operation fran the Employer "to thei/fullest extent possible...in
the reasonable promotion of safety a$d health to all employees"
without first having to establish thit a situation of proveable
harm or damage exists. There are sim$ly too many incidents where
the envirotxnent has been invaded by iunknown factors which have
come to light only after the harm his been done. Ye do not -
;I agree that the Union must prove actue;pr real harm before Article
18.1 of the Collective Agreement can bc invoked.
II
1,
__-_ -, -- -.
This question has beeh dealt wi;th previously by a panel
of this Board in the case of OPSEU ((elen Barssl and The Crown
in the Right of Ontario (Ministry of Education) G.S.8. File~345/81
(Jolliffel. I In fact, the issue in tha; case involved the safety
of VOTs. That decision discussed th+, nature or extent of the
burden which rests upon a Grlevor who aileges that a video display
terminal Is unsafe or unhealthy. Ye?;can do no better than to
quote the unanimous decision In Barss atlpp. 30-32: - ',
"The intent of the legislation w& anticipated in the
exhaustive review of arbitral jurisprudence made by
Professor Palmer In Steel Co. of Cbnada Ltd. and U.S.Y.
Local 1005 (19751 8 L.A.C. Ii!dl I; 375. After cltlng
II
II
. .
- 19 -
numerous cases (which need not be repeated here) he
made at page 379 ,the following Statement, with which
we concur:
It follows therefore, that in .fact there
may be no serious danger; but; if it is
possible for a reasonable person to come
to this conclusion, that suffices to satisfy
this point. Thus if a person is given advice,
even if eventually shown to be incorrect,
by,his doctor not to undertake certain act-
ivity, such advice can be used as a basis
for drawina the conclusion that a oerson
was acting -reasonably in following it.' See
Re U.A.W. Local 636 and F.M.C. of Canada
Ltd. Link Belt Speeder Division (lY71), 23
. * . 4 (O'Shea).
Professor Palmer then offered' the ~following qualifi-
cations:
Ii the same vein, where senior officials
of. the employer, knowledgeable in the area,
have given assurances of safety to a person;
it tends to show a lack of reasonability.
on the part of that person if he continues
to refuse to do the work SO pronounced safe.
See Gen'l ,Truck Drivers' Union, Local 879'
and Guigley Construction Ltd. Llm 13 L A C . . .
45 (Revillel (.
The final requirement in this area is
that the grievor must, at the time of the
refusal, communicate his reasons fork refusal
to his employer...
On the last two points above we are not persuaded that
any person "knowledgeable in' the area" gave assurance
of ~safety to Ms. Bars:. Mr. Ahrens did not testify,
but the employer's expert witnesses said they-had re-'
ceived no inquiry from Mr. Ahrens of his office. In
this case of cdurse.the grievor as'ked that she be allowed
to perform other ,duties. and the employer complied,
so that the, question of "refusal" does riot' arise.,
Secondly, she certainly made her reasons clear, orally
and in a detailed letter supported by Dr. Isenberg's
recommendation. .I
The facts here' are ~ve,ry different from those in the
case decided by Professor Pilmer, but we thinkkthe
tests he used are entirely appropriate.
- 20 -
II
First, was the type of app$,ehended danger, whether
real or imaginary, of sufficie()t seriousness to justify
the grievor's request for a change of duties?
As to this test, our view is that the grievor's fear
of harm to her unborn child was indeed a serious matter,
whether or not her fear had a basis recognized by
scientists.
Secondly. assuming for the moment that there was no
real danger, did the grievor hyave "reasonable grounds"
for believing that exposure ;o VOT radiation would
put her child at risk? II
Our answer to this question musi be in the affirmative.
Every pregnant woman (unless she is a fool) consults
her physician and is entitled Ilto rely on his advice,
whether he be proved right qr wrong by subsequent
inquiry. We cannot accept 'the argument that there
is an onus on the employee in circumstances such as
these to prove actual danger.\, The argument is not
consistent with the provisions [Iof Article 18.1 in the
collective agreeDlent. In any evient. it would be absurd
to require an individual employee to mobillte all the
scientific expertise available toJmanagement.'
: II II We adopt the reasoning in Barss. We reject the proposition that
'I the Union has a "burden of proving 'that the risk of harm is a II
real and serious one" or that the Union bears the onus of "proving
that the proposed course of II action would reduce the harm to
II
health." Article 18.1 of the Collect{,ve Agreement cannot possibly
be read as imposing such an onus up+ the Union. Article 18.1
imposes a joint obligation on 'both!ithe Employer and, the Union
- II (to) co-operate to the fullest extent fossible...in the reasonable
prMnotion of safety and health of a!1 employees".
/
It is fair
to say that Article 18.1 imposes an onus of equal weight on both
;I
the Employer and the Union -- to "co-dperate to the fullest extent
possible II . ..in the reasonable promotion of safety and health of
II L
-'21 -
all employees." Although we reject the standard of proof asserted
by the Employer we 'say th,at even if the submission by counsel
for the Employer should be correct then the Union ,has satisfied
the onus by the ~nature of the evidence presented. by Dr. Marha.
The Union's request was originally accepted by the Ministry as
reasonable and if the Ministry had followed its own instincts
the imnediate issue involved in this case would have, been settled
a long time ago. The Union asked only to have one of the VDTs
made available to Dr. Shana to enable him to make a prototype
shield. Nothing else was asked by the Union of the Ministry.
The plan was for the machine to be transported to Dr. Sharma
at the Union's expense, and Dr. Sharma's work would not involve
the Ministry in a p'enny of expense. The terminal would be returned
by the Union to 'the Employer at the Union's expense. Truly,
it was a "free ride" for the Ministry.~ We are of the opinion
that it was absolutely unreqsonabl'e for the Ministry to deny
the Union's request. Certainly, the hapless taxpayer would have
been spared a great deal of expense ~if, in the language of Article
18.1, "the Employer and the Union (had) co-operated to the fullest
extent possible".
It may be that nothing will come of Dr. Sharma's .attempt
to construct an effective shield but you never know unless you've
tried. What .I find surprising is the lack of curiousity on the
part of the Ministry which I consider to be inconsistent with
the scientists' avowed quest for knowledge.
We allow the Grievance. We direct the Mnistry to make
available forthwlth to the Union a video display terminal of
the type orlglnally contemplated fbr the experimental purpose
herelnbefore described. The Union (i is II to complete its part of
the arrangement In accordance with 1,ts original proposal to the
;I
Minlstry Including picking up and deilivering the machine to Dr.
Sharma and retumlng it to the Emp&yer when Dr. Sharma's work
has been completed. ;I The Union is to! make Or. Sharma's findings
available in full, without charge, to the Ministry together with
)I
the research done by Dr. Sharma. ift is our intent that the
\' Employer should be provided with all; and any research which is
'I given by Dr. Sharma to the Union; I\ other words, we seek to
ensure that both sides will extend $o-operation to the fullest
extent possible". 11
li
Ii
We shall remain seized of this (matter in the event that
I! any difflcultles should be encountered In Implementing this
Decision. 'I
I
DATED AT OTTAWA this 2nd
I/
day ofi bone, 1989.
I!
“I dfssint” (Dlsscnt attached)
H. OOTo;jle. Member
. .
DISSENT C959/'ijl
Although I am dissenting from the majority decision, I do so
with some reluctance as the ,Employer Initially indicated a
willingness to co-operate with the Union's proposal. The
Zmployer's change of heart may be bad labour relations. slit
this Soard is without jurisdiction to grant relief to the Union
unless the Employer's withdrawal of co-operation constitutes a
violation of Article 16.1. The majority decide that such is
the case. However, S cannot avoid concluding that the majority
-made several errors in reaching this decls'ion and I must
therefore, respectfully dissent. .
I shall first briefly summarize these errors and then discuss
each ia detail. They are as follows:
1)
2)
3 1.
The majority misstate the scope of the
obligation imposed on the. Employer by
Article 18.1;
They misstate the onus to be discharged
by the Union in proving a vloiatlon by the Employer
of Article 13.1;.
Their finding .that the Employer violated
Article la.1 2s not supported by the
4 ,I
weight of the evidenceland is 11\. a:
clrcuaetances unreason≤
I
The relief granted 12 :nappropriate as
there is no reliable eiidence before the
Board of its likely etrfcacy.
Scow of Article la.1
Whlie the najorlty correctly state that there isa fo:nt I
obligation on the Employer ,and the Union to co-operate, they
1: appear to lose sight of the word l+reasonablen In this Article
ii which qualities the obllgatibn. I, It is submitted that
"reasonable" is to be interpreted r$aving regard to the pmpose
I! of the Article which is the protection of the health and safety
or employees. I! Thls implies that t;e duty to co-operate is or.Iy
operative where there is a reasom)le health or safety risk to
employees . I
(I
ii
ij :t is fmther submitted that "reasonable" :s to be :nterpreted ;I on an objective basis. In other wcfds it is not sufficient for
the ,Cnlon to establish that it hesIan honest bel:eP that there
Is a health risk. It must demonstiate some objective basis t0r I
its bel:er. j/
2 \
I!
oniis of ?r00f
The ma:ority at page I? f.lnd :t "surprisirig that the Employer
seeks to detach itself from the underlying problem and to
Impose the entire onus upon the Union. I’ I, in turn, am
'surprised by .this statement as it seems to contradict a
fundamental rule of procedure, namely, that the party alleg:ng
a breach of the collective agreement bears the tinus of proving
:t, that is, establlshlng a prima facie case. The allegat:on
'In the grievance ls that the Employer breached its duty of co-
operatfon under Article 18.1 . Accordingly, it seems
straightforward that the Union should bear the "entire onus" on
this point.
This leads to the question .of. the appropriate'standard of proof
to~'be applied. Clearly, the usual rule should apply, namely,
proor on a balance of probabilities.
What must be proved ?
~The majority correctly state what must not be proved at page -
17, namely, "actual or real &in." The'najority represent the
foregoing as being the Eaploye- "'8 tormu:ation of what has to be
proved. That formulation is set out verbatim by the majority
at page I+. The key words mused are.'"a real or serzous
possibility of harm due to rahiatlon from VDTs". According to
my understanding possible harm is something quite differert
from actual or real harm. It eeems clear to .me that the
sa.jority has misunderstood the Employer's formulation of the
3’
standard of proof. ;R the process they set up a "straw man"
and then proceeded to knock :t d&n by reference to the Sarss
dec.lslon. I This begs the quest?on of what is the correct
standard of proof. In my view th:l formulat:on o: the Employer,
properly read, expresses the apprd'priate standard of proof.
jl
Nor do I see the Barss decision & being an authority against I!
thls formulation. The facts In Biirss are qd:e dl,“terent from
I’
this case. There the grievor's k-quest was based on her fear
\I ror her unborn child as supported by a written medical opinion.
II The Employer's response to,the gklevor's request included an
I! assurance of safety but It was mad6 without any lnqiiries being
!I made of medical or scientific experts. The latter was done
only atter the filing or the grikvance.
i(
The Board in 3arss
essentially found at page 32 that the grievor's fear was
1; reasonable because it concerned he; unborn child and because it
was supported by a medical oplnlonz
I\
In the Instant case pregnancy is not a consideration and before
I! the filing of the grievance the grievor had not only the ll recommendation for shielding of Dt;. Sharma but an assurance of
II safety by the Employer which was 'kupported by the unequivocal 'I
written opinion 0r an expert, Dr\ Muc (see pages 5-7 of the
maiorlty decision). Th.erefore, uijlfke u, here there were
II prior to the filing of the grievance two competing expert !! opinions on the subzect matter of ihe grievance. I! I
II
I
4 II
!I
. .
It necessarily follows that this Board cannot judicially assess
the reasonableness of the Employer's rejection of shielding
. without weighing the evidence in support pf each of the
competing ~oplnions. This does not require the Board to make a
definitive statement "as to whether or not ,video display
termlnals Involve harmful radiation." Rather the Board is only
required to state which opinion should be given greater weight
on a ,balance of probabilities. In the past this Board has not
hesitated in appropriate cases to weigh the evidence of
scientific experts In drawing legal Inferences. Without so
doing in this case the Board cannot effectively discharge the
responsibility the majority themselves becognize at page 16 ",
internret and abaly . . . . . Article 16.1."
The Exsert Evidence
Prlor to the filing of the grievance the only expert evidence
relied on by the Union in support of the need for shielding was
.the recommendation of Dr. Sharma of same as a precautibnary
measure against fields which ?nay” be of “high enough magnitude
at the surface so as to cause "adverse" hedlth effects." Dr.
Sharma was not called as a wltness in these proceedings and so
neither the scientific basis of his recommendations nor his
status as an expert were proved in these Proceedings nor 'under
cross.-examination. On that basis alone his opinion does not
constitute reliable evidence.
.:n these pro&eedings the Cnion relied upon the opinion of Dr.
Marha whose"evidence is summarized at pages 14 and 15 of the
5
majority decision. As is pointed out at I
sh:eld:ng on the sole basis that ‘I the
could have an etrect on cellular acti
statement of a mere possibility, not
probab:lity.
Moreover, Dr. Marhe referred to the concl
by a scientist in Finland, set out at pa,
dec:s:on. as conf lrming his opinion.
contains a positive sta:ement that “the
around a VDT are not hazardous to. humer 1ij
present knowledge." While the study
fields “may heve blologlcal effects with
it does not suggest that they are neces:
does it recommend shielding but only ”
experiments” to identify these effects.
?age 14 he supported
emissions from VDTs
ity; “. This is a
even approaching a
sion of a study made
I 16 of the majority
In fact t-he study
ELF magnetic fields
health according to
scognizes that such
mknown mechaoisms”,
Irlly “adverse”, !lOF
iditlonal biological
Zn the result the expert evidence adduced by the Union and I! relied on by the majority is at best equikvocal in support of
1 eSleld:ng and then only on the basis Ofi) “poes:ble” adverse
health e’fects. & I:
1 Xn contrast the evidence of the two experts relied on by the I’ Employer and summarlzed at page 14 was unequivocal “that there il is no danger of radiation exposure irony the video display
I terminals n and so no need, ror shielding. 1.n sum their opinion Ii amounted to a scient:f:c “certainty” of/I no adverse health \I
effects. II
6
The majority appear to discount the expert opinion relied on by
the Employer as mdogmatic" despite the .fact that It was
supported by "substantial research" of which the majority'offer
no critichm.
Instead, they prefer the expert evidence of the Union
notwithstanding that, at'most, it can only estab.lish the mere
possibility of harm. It is submitted that in law a bare
possibility is too remote to constitute a "reasonable" risk
that triggers the Emp~loye.r*s duty under Article 13.1. In
support of this proposition I need only point out that an
employer may not bar an employee who has recovered from an
injury from returning to, work based only on the mere
possibility of a recurrence .of his injury. (see m
International Nickel Co of Canada Ltd. ((1974 7 LAC (2d) ~196
( Rayner ) )
it 'seems logical that the converse of the above should apply,
namely. that an employee may not refuse or otherwise challenge
work based solely on the' mere possibility of harm. The
majority appear to reject the converse based~ on the fallowing
statement at page 18:
"There are simply too may incidents where the
environment has been invaded by unknown factors which
have come to light only after 'the harm has been done."
7
r ;I
The foregofng : t s not at all applicable to thls case as the
tac-.or here /( is known and as no,, harm has been shown to be II
::kely.
c
in my opinion the evidence adduced) at the hearlng, when weighed
according to the groper standard, 1 ‘can only support a finding of II 20 reasonable risk of harm to ‘&nployees )! from VDT radiation
rendering ArticJe 18.1 inoperative,/ in the circumstances.
T?re Relief Oranted ‘1 I
3 allowing the grievance the ma{ority order the Employer to
provide a terminal to Dr Sharma for the design of appropriate II
shielding. 3ut there was not a t’;:ttie of evidence cor?cernir?g
I! Dr. Sharma’s expertise in the d&sign of MT shielding other
II than his having volunteered to do so.
11
Accordingly, there 2s no
reliable evidence to support l,the relief granted by the il
3a;ority. 1
Ii
1; For all the foregoing reasons =’ would have dismissed the Ii grievance.
M!/ F. O'Toole - Member ;i
(:
(j
8 / j
I/