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2156/87
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
Between:
OPSEU (Union Grievance)
Grievor
- and -
Before:
For the Grievor:
For the Employer:
HEARINGS:
The Crown in Right of Ontario
(Ministry df Natural Resources)
Employer
N. V. Dissanayake Vice-Chairperson
.I. McManus Member
H. Roberts Member
Ian Roland
COUllSel
Gowling & Henderson
Barristers & Solicitors
Brent Labord
Counsel
Hicks Morley Hamilton Stewart Storie
Barristers & Solicitors..
April 13, 1988
August 8, 1980
August 9, 1988
,,.I~ ..^. ;.. . “.. ..~ . . . . . _,-:.: ,,_...
2
This is a union grievance which states:
The Union grieves that the Ministry of Natural
Resources has violated article 13.7.2 by
failing to pay overtime to schedule 6
employees assigned to forest fire fighting on
"prescribed burns". .,
Central to the issue in dispute between the parties
is article 13.7.2 of the collective agreement which
reads:
-13.7.2 Notwithstanding 13.7.1 and Article
19.6. (Holiday Payment), employees who are in
:~ classifications assigned to Schedule 6 .and who
are assigned to forest 'fire fighting or
related duties, shall be paid one and one-
half (1 l/2) times the employee's basic hourly
rate, to be calculated on the basis of thirty-
six and one-quarter (36 l/4) hours per week,
for all such work.after eight (8) hours in a
24-hour period.
It is agreed between the parties that employees in
schedule 6 (under the Public Service Act) are excluded
from the overtime provisions of the collective
agreement, except as specifically- provided in article
13.7.2. With some exceptions, it is not a regular duty
of schedule 6 employees to engage in fire suppression.
However the evidence is that from time to time they are
used in suppression of wildfires, as well as duties
related to prescribed burns.
3
A "prescribed burn" is a deliberate application of
fire to a specific area of the forest . "n'ilt'r
predetermined conditions. A prescribed burn may be
carried out for silvicultural, wildlife, forest
management, sanitary or hazard reduction objectives.
The evidence is that the majority of prescribed burns
have silvicultural objectives, mainly as a means of site
preparation for planting.
The Ministry agrees that article 13.7.2 requires payment
of overtime' when schedule 6 employees are engaged in :
fire-suppsession.or~lrelated duties in connect,ion with a
.i';..T
wildfire: Also, where, a prescribed ~burn exceeds its
boundaries and is formally declared a wildfire,
schedule 6 employees are paid overtime under article
13.7.2. However, the Ministry has not paid overtime
under article 13.7.2 when those employees are used in
fire suppression or related duties in connection with a
prescribed burn. The nature of the dispute is clear.
The Ministry takes the position that when a schedule 6
employee is assigned to duties-* in connection with .a
prescribed burn, he or she is not assigned to "forest
fire fighting or related duties" within the meaning of
article 13.7.2.
4
The bulk of the evidence received by the Board
during three days of hearing related to the tasks
involved in connection with a prescribed burn and the
tasks that are performed in suppressing a wildfire. As
noted, prescribed burns are in most cases used for site
preparation purposes. Such a process is usually
initiated by a client within the government such as a
biologist or forest manager. It must be noted that in
i additionto~.using prescribed burns, site preparation is
also done by other means. That is mechanical site
‘g' preparation,(use of.;equipment such as bulldozers) and
,hC, cbemicali~site .:;.preparation.(spraying of.,.~chemicals) . The
evidence is that only about 15: percent. ~of all site
.>:preparation is -,done through prescribed burns. Initial
planning for a prescribed burn may begin as early as 5
years before the actual burn date. Since the grievance
does not relate to the preparation stage, it is not
necessary to review that evidence. Suffice it to note
that a substantial amount of preparation is involved in
a prescribed burn. The burn arsa is defined, and the
number of employees, equipment, overtime hours etc.
required are estimated and budgeted. The required
weather conditions are established and using the weather
5
data available a burn date is established. As part of
the plan, boundaries for the burn are established, using
natural boundaries such as lakes or rivers if possible.
The evidence indicates that based on training and
skills, the Employer maintains a roster for each
district, of all persons who may be assigned to fire
suppression or support service duties. It is frsm this
common roster that persons are assigned to duties
relating to both.wildfires and prescribed burns. While
employees in several classifications in schedule 6 may
be.,involved in the planning stages of a prescribed burn,
only a- <few classifications ~.are:used..efterthe.ignition
of a prescribed burn. These include pilots, biologists,
foresters-and /weather technicians. -Among~.these pilots
appear to have the most involvement in the suppression
aspects of a prescribed burn.
The Board heard some evidence relating to a
"Pilots' Floater Agreement" and a "Fire Emergency
Compensation System”
that are in--effect. It is agreed
that the former is the subject of a grievance before
this Board, and at the time of the hearing in this
matter, no decision had been rendered. The Fire
Emergency Compensation System applies only in situations
declared as an emergency. The Board does not find the
6
evidence relating to either of these of any assistance
in determining the issue in this grievance.
The Board has carefully examined the evidence
relating to the duties and responsibilities involved in
suppression of a wildfire on the one hand and the
suppression of fire in a prescribed burn on the other.
By definition there is a basic difference between a
wildfire and a prescribed burn. That is, in the latter
..~the intention is to burn off a pre-determined area of
forest. In the former the fire is not deliberately set,
-c~.although '.:.the evidence. is that the Employer uses
.ghistprical:.. .and , mathematical,. -data to :predict the '_~
.likelihood and the general location..of wildfires.
However, there .:gis substantially more planning. involved
in a prescribed burn and there is a greater degree of
predictability because the fire is ignited under
predetermined conditions.
Counsel for the Ministry contends that wildfires
and prescribed burns are "completel'y different animals".
He points out the following differences.
(1) The purpose - A wildfire has no useful purpose,
while a ~prescribed burn has an intended forest
management function.
1
(2) The Ignition - A wildfire is not intentional.
A prescribed burn is deliberately set under pre-
determined conditions.
(3) Duration - A wildfire can last from one day to
several months in some cases. A prescribed burn usually
lasts a day although smoldering and mopping up may go
on for about a week.
(4) Size - A wildfire can be a small one or it can
involve as much as 25,000 acres of forest. A prescribed
burn is usually 200 to 300 acres.
(5). Timing - A wildfire can occur at any time and
.under any conditions and only limited prediction is
,,.possible~. In contrast, a.prescribed burn. is,planned
well in advance and takes place only under:.controlled
conditions.
(6) Suppression - In .a wildfire there is always
suppression activity. In a prescribed burn,
suppression is required ~only where the fire exceeds the
-established lines or there are fire jumps.
Keeping in mind that the Board-is required .here to
interpret the words "assigned to forest fire fighting
or related duties", in our view the focus must be on
.the actual duties of employees in the suppression of a
fire. The only comparison that is useful is that
between the duties and responsibilities of the employees
8
when assigned to the two types of fire suppression or
related duties. Therefore, the distinctions relating to
purpose, ignition etc. are not helpful. Quite apart
from that, the Board notes that in relation to size and
duration, while it is generally true that wildfires are
larger than prescribed burns this is not necessarily so.
A larger prescribed burn may cover a larger area than a
small wildfire. Similarly, a very small wildfire may
not take any more time to
Put off, than a larger
prescribed burn which has significant escapes and jumps.
:.
: ‘i :;:, r:3 .
Mr. Mike Willick, the Assistant Director for Fire .;_
Management for the Ministry testified that the basic
difference between a wildfire and a prescribed burn is
that "in the latter we are in control. We know how it
starts and we know pretty well how the fire will
behave". Mr. Willick disagreed with the evidence of the
union witnesses that every prescribed burn has at least
one or two jumps that must be suppressed. Under cross-
examination, Mr. Willick agreed th'at the first task when
a wildfire is identified is to establish a control line
and that all efforts acre then directed towards
prevention of the fire spreading beyond that control
line. He .also agreed that every prescribed burn also
has a control line, and that the only difference is that
9
in a prescribed burn the control line is established
.
well in advance. Mr. Willick agreed that once a control
line is established, in both wildfires and prescribed
burns the suppression activity is directed towards
extinguishing the fire beyond the control line.
The Ministry characterized the role of a schedule 6
employee in a prescribed burn situation as one of
"watching and monitoring" as opposed to active fire
fighting. To the extent that suppression of fire is
required in a prescribed burn, Counsel submits that that
(.: -'pi kind.;' of fire suppression does not come within the ~... .. ..,*- ii ..:. ,+>. meaning of'! "fighting a forest, fire". He submits that ..~ .;,:.:.,. :~,f,-$+&ft;.~.. y.“: ids
the.h.Sword
I~+ :..~ . . . . ~. .~.~ .,"~ ..( I "fighting" denotes active .and offensive
g ..; ._I
suppression, as opposed to the monitoring function in a
.., p,
prescribed burn which he characterizes as "defensive
suppressing". He urges the Board to find that article
13.1.2 does not .apply to the latter kind of fire
suppression.
The Board heard testimony from two schedule 6
employees who have worked as pilots in both prescribed
burn and wildfire situations. Their evidence is
uncontradicted that once the.prescribed burn is ignited,
for all practical purposes, their functions are .,._. ; .~ ~-.....
indistinguishable-from their tasks when they are engaged
10
in fighting a- wildfire. The evidence is that they are
less active in a prescribed burn, and one witness stated
that it is less hectic. Also the fire suppression
usually takes longer in a wildfire. The core of their
duties, in relation to both wildfires and prescribed
burns, is either water-bombing or transportation of
crews, equipment and supplies. In the former, they
circle the fire in a plane with a load of water and'drop
the water when directed to do so by radio. They water-
bomb at the time and locatioaas directed. This is the
same in the cease of a wildfire and a prescribed burn.
+~+~It~is~noteworthy~that when a prescribed burn is .declared
::,I t&be:.: a wadfire, the-pilots are, not-advised-of this.
..,.,*
.: ~O&&an infer that they are. snot. so *-;advised,'because the '
changes in the status-of the-fire-makesno, difference to
-%the. pilots';duties. ~:!In the duties of transporting of
crews, equipment and supplies, the evidence does not
indicate any difference between wildfire situations and
prescribed burns.
The evidence establishes that once the fire in a _v
prescribed burn is lit, the duties of the pilots are no
different, except in the degree of activity and the
length. of time, than their duties in fighting a
wildfire. In a prescribed burn a control line is
established in advance as part of the plan. The task
11
after ignition takes place is to contain the flames
within the control line and prevent it from exceeding
that line. One of the first tasks when a wildfire is
identified is to establish control lines. The only
difference here is that this takes place not in advance
but after the fire is discovered. However, once control
lines are established, like in a prescribed burn, the
objective is to prevent a wildfire from spreading beyond
that control line. In both wildfires and prescribed
burns,~ escape routes are established. The equipment,
procedures and:techniques employed are the same.
The involvement of biologists, foresters and
weather -technicians in fire ,-suppression is less
frequent. However,,~the evidence~,is that.when .they. are
involved, their duties are also similar whether the fire
is a wildfire or a prescribed burn.
There are some differences between the two types cf
fires. For example the purpose, size and duration.
However, the evidence is tha< overtime hours are
inherent in a prescribed burn, although not to the same
extent as in a wildfire. The evidence is uncontradicted
that from time to time the flames in a prescribed burn
exceeds the allowable limits. The prescribed burn is
1%
not declared a wildfire.in every such instance. Indeed,
the evidence is that there are. disincentives operating
against making such declarations.
On the basis of the evidence the Board does net
see any material difference between the duties ir. a
wildfire and the duties involved in a prescribed b,~rn
after ignition. As noted earlier, there was conflict
as to the extent of actual suppression required in a
pres&ibed '~.~burn. .. 'However, in our view that -: 5
4: irrelevant 'to the issue before us. Article 13.7.2
-. provides for overtime pay not for hours spent in ~','. <, ~“.:;~~ght~*g : f o+es t .c, f ire s . .' Overtime- pay----'is.~due..'for hours.
"when an employee-is "assigned. to forest fire fighting cr
related‘duties".? Surely, an'employee who -is~ monitoring
a fire in readiness to go into action if required must
come within that term. The employee is on duty in a
fire fighting or related role whether or not he is in
fact required to go into action. Despite counsel's able
submissions, the Board does not accept the distinction
.v
between offensive and defensive fire suppression. We
conclude that an employee performing duties after the
ignition of a prescribed burn 1s "assigned to forest
'fire,fighting or related tasks" within the meaning of
",article,:l3;'7':~2,-and .-is -therefore entitled to overt~ime pay
as per that article. Therefore, by failing to comply
13
with article 13.7.2 in relation to prescribed burns. the
Employer has contravened that article. This grievance
is accordingly upheld.
In view of our finding, it is not necessary to
consider the extrinsic evidence relating to collective
bargaining history that was adduced. The Board does not
find an ambiguity in article 13.7.2 as would warrant or
justify resort to that type of evidence.
On the question of remedy, counsel for the Employer
.:submits that the only appropriate remedy is a
. .: : declaration. Inthe I alternative, counsel submits that
~! ~-if--'the Board is .inclined -to ..award.~..compensation to
individual employees, retroactivity should be limited to
.‘20 days prior to. September%lO,. 1987, the date of the
filing of the grievance. Counsel for the union requests
compensation and is content if retroactivity is limited
as requested by Employer counsel.
The only reason offered for not awarding
compensation was that this is &policy grievance and
that there may be difficulty in determining the time
spent on fire suppression duties by each employee. This
is likely to be an on-going difficulty. The parties
must attempt -to .devise means-.for.keeping,a record of
14
time spent on fire suppression by each employee for
overtime purposes. The Board does not see that as an
insurmountable problem in that the parties must cop2
with the same situation when schedule 6 employees are
used in wildfires or prescribed burns declared to be
wildfires. The Board is not convinced that there is a
valid reason not to redress employees who have been
denied .overtime pay in contravention of the collective
agreement. The fact that this is a union grievance is
also no reason to deny compensation. There is no legal
reason offered as to why it is inappropriate to award
compensation on a union grievance. To do so, would be
to::.force.each.,affected employee in the bargaining unit
toXfile an individual- grievancey-rathers"than"resort to
the~more efficient and expedients means' of filing a
$)' policy gr5evance .'~' That is -not -something to be
encouraged.
The Board hereby directs the Employer to compensate
each scheduled 6 employee, who would have been entitled
to overtime pay under article 13.7.2 for work performed
in relation to prescribed 'burns after ignition. The
compensation will be retroactive to twenty days from the
date of the filing of this grievance, namely, September
15
10, 1987. The Board remains seized in the event the
parties are unable to agree UPOIl the amount of
compensation payable.
Dated at Hamilton., Ontario this .?T!nd day.o~f Wovember~.,l988.
A=-%.5 Nimal V. Dissanayake
Vice Chairperson
J. McPlanus
..rF5-w ,
i H. Roberts
Member