HomeMy WebLinkAbout1987-2250.Giasson.88-11-07L..
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DNTARLO EMPLOYtSDEL.4 CO”RONNE
CROWN EMPLOYEES
! GRIEVANCE
OEL’ONTARIO
COMMISSION DE
mLEMENT RkGLEMENT
RD DES GRIEFS
IN THE MATTER OF AN ARBITRATION
UNDER
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
BETWEEN:
Before:
For the Grievor:
For the Employer:
HEARINGS:
BEFORE
THE GRIEVANCE SETTLEMENT BOARD
OPSEU (G..GIASSON)
- and -
THE CROWN IN RIGHT OF ONTARIO
(MINISTRY OF LABOUR)
F: V. Watters Vice-Chairperson
Klym Member
M. O'Toole Member
L. Rothstein
D. Wright
Counsel
Gowling & Henderson
Barristers and Solicitors
V. Malpass
Staff Relations Branch
Human Resources Secretariat
July 7, 1988
July 8, 1988
GRIEVOR
EMPLOYER
DECISION
This proceeding arose as a consequence of the grievor being
denied an’ interview for the posted position of Construction
Safety Officer in the Sudbury office of the Construction Health
and Safety Branch of the Ministry of Labour. The posting in
question stated that fluency in French was essential. The
‘L. grievor was denied the opportunity for an interview as he did not
possess such ability. This decision was subsequently grieved and
came before a different panel of this board on March 25, 1988.
At the commencement of that hearing, counsel for the employer
as to arbitrability. The argument raised a preliminary objection
presented with respect to this
which was chaired by J. B. Dev
issue was rejected by the panel,
lin, in a written decision dated
May 20, 1988. In dismissing the employer’s objection the board
stated:
. ..* the board has jurisdiction to determine whether
fluency in French which was required for the vacancy
in the position of Construction Safety Officer vhich
arose in Sudbury in the summer of 1987 was reasonably
related to the job to be performed.” (Page seven).
The panel of the board, as presently constituted, heard evidence
and argument on this question on July 7th and 8th, 1988.
./ ‘,’ 1%: :~. ::;, t... ~?. .~ I,
Claude Nadon. the successful applicant for the position, was
in attendance at the hearing and was advised of his right to
fully participate in the proceedings. His participation,
however, was limited to a brief statement at the conclusion of
the case.
The grievor was the sole witness called by the union. The
material part of his evidence may be stated as follows:
(1) From 1971 to the present date, he has been employed as a
Health and Safety Inspector in the Mining Health and
Safety Branch of the Ministry of Labour. This position
has the same classification as the Construction Safety
Officer. Both are classified as ‘Occupational Health
and Safety Inspector 2’. The move, therefore, would
have resulted in a lateral transfer, had he been
successful in the competition. For a substantial
portion of his period of employment, the grievor has
worked out of the Sudbury office. Indeed, this facility
.houses both the Construction Health and Safety and the
Mining Health and Safety Branchs.
(2) The grievor’s position requires that he enforce the
Occupational Health and Safety Act, and the regulations
enacted pursuant thereto, as they pertain to the mining
industry. In his estimation, the experience gained
the.refrom would be readily transferable to the job
applied for. Additionally, he stated that he has been
required to enforce the construction regulations in
respect of construction projects on mining property.
The grievor further testified that he had performed as
a Construction Safety Officer for a short period in the
summer of 1985. On the basis of this past experience,
he believed that he could perform the job sought.
(3) The grievor conceded that he only speaks English and
that he has no proficiency in French. He asserted,
however, that this had not adversely affected his .
performance in the mining sector. It was his
opinion that such sector had a higher proportion of
francophones in comparison to the construction sector.
The grievor also testified that he has never
encountered a problem vis a vis the need to
communicate in French during the eleven year period
of employment with the Ministry of Labour, including
his brief stint in the construction branch referred to
-2-
above. In his evidence, he stated that English.is the
language used on project sites in both sectors. He also
expressed the opinion that the Construction Safety
Officers of the Sudbury office did not use French 8s part
of the exercise of their daily responsibilities. This
view was premised on his informal discussions vith such
officers and on the fact that he cou,ld not recollect
the subject of French language having ever been a topic
for discussion at any Employee Relations Committee
meeting he may have attended in his capacity as a union
steward.
(4) Lastly, the grievor noted that other positions in the
Sudbury area had not been designated as bilingual.
Specifically, he stated that two subsequent positions
in the Mining Branch of the Flinistry did not require
fluency in French. Similarly, the position of Occupational
Health and Safety Advisor, for which he applied in
mid-1987, did not require such fluency. It was the
grievor’s opinion that there was a greater need for
French language skills in these pOSitiOns. He therefore
questioned why the requirement had been incorporated
into the posting for the Construction Safety Officer job.
In summary, he did not believe that this requirement was
reasonably related to the position and the duties to be
performed therein.
Mr. William 0, vens, the Usnager ,of the Construction Health
and Safety Branch in Sudbury, was the sole vitness called by the
employer. His evi, dence may be stated as follows:
L.. (1) He has occupied his present position with the Ministry
for approximately six and one-half years. Prior to
becoming Nanager, he had served as a Construction
Safety Office for a period of seven years.
(2) Mr. Owens assigns and coordinates the vork of seven
Construction Safety Officers throughout seven geOgraph-
ical areas in Northern Ontario. These areas or
districts are: Algoma, Wanitoulin, Sudbury, Parry
Sound, Nipissing, Timiskaming and Cochrane. Three
officers are located in Sudbury, two in Sault Ste. Marie,
and one in each of North Bay and Timmins. Work is
distributed to these officers according to vhere it is
to be performed. Specifically, they are involved in
inspections, investigations, prosecutions, inquests and
other vork, all of which is related to the enforcement
of the Occupational Health and Safety Act.
(3) Up until June, 1985, Mr. Owens had tvo bilingual officers
on staff vho could be called upon to deliver services in
(.~
(4)
(5)
(.
French when required. With the retirement of a Hr. Paul
Dubois from the Timmins office in that month, he was
left with only one officer who was fluent in French.
This was Mr. Raymond Boivin who worked out of the Sudbury
office. Generally, the officers in that office were
assigned projects on a rotating basis in the Sudbury,
Manitoulin and vest half of the Perry Sound districts.
Prom time to time, however. Ur. Boivin vould be aseigned
to work outside of these areas vhen.a request was made
for the delivery of services in the French language.
While evidence was adduced in respect of only-one
specific assignment to Kapuskasing, Mr. Ovens testified
that this particular employee used his French language
skills in the performance of his duties over a
substantial period of time. Indeed, ae noted, all
requests for services in French were directed to Mr.
Boivin after June, 1985.
The vacancy in question arose in June, 1987 vhen Mr.
Boivin left regular employment and went on long-term
disability benefits. It was at about that time that a
decision was made to insert the French language require-
ment into the job posting for the position. It is
apparent that this was the first occasion where fluency
in French was deemed as essential for the position.
WI-. Ovens testified that he and Mr. T. Aki, Regional
Manager, were “consul ted” as to the requirements for
the position. He recollected specifically having,hed
a telephone conversation with Mr. Aki in which he
communicated his opinion that a bilingual person should
be recruited given the past capability to deliver
services in French and in view of the demographics of
the region. At the time of this conversation, Hr. Ovens
was also aware of the enactment of the French Language
Services Act, 1986 and that five of the seven districts
under his management were designated pursuant thereto.
He stated that this legislative initiative was considered in
the making of his recommendation that French should be
required.
At the time Hr. Ovens spoke to Hr. Aki, he
was of the mistaken belief that francophones could
require French services in the Sudbury area. He was
not aware that the‘regulations necessary for the
effective implementation of the legislation had not
been passed. He was also unfamiliar with the specifics
of the process for designation of positions as bilingual
set out in the implementation manual prepared by the
Office of Francophone Affairs. It was Mr. Owens’ assess-
ment that this incomplete understanding of the Act ~88
immaterial in that the need to deliver servicesin the
French language existed independently of the legislative
requirement. His fourteen years experience “in the field”
had convinced him of the demand for French services in
the areas under his administration. While he appeared to
concede that having only one bilingual person for the
entire region might be somewhat inefficient, Mr. Ovens
expressed the opinion that at this point in time “it is
a practical necessity” in that it is the only way in
which he can deliver the needed service.
(6) Mr. Ovens candidly admitted that he did not make the final
decision in regards to the French language requirement.
Indeed, he could not provide the name of the ultimate
decision maker nor could he be certain 88 to the
grounds on which the decision was taken. His knowledge
was limited to the information and opinion he had
communicated to Mr. Aki in their telephone conversation
referred to above.
It was the position of the union that the employer had not
established, to the degree necessary, that the French language
requirement was reasonably related to the job to be performed.
In support of this argument, it va8 noted that two of the three
areas covered by the Sudbury staff, these being Parry Sound and
Manitoulin, are not designated in the Schedule appended to the
French Language Services Act.
It was further argued that census
data from 1981 reflected a greater population of francophones in
other areas of Northern Ontario within Hr. Ovens’ mandate. For
example, the Cochrane area is forty eight percent (48%)
francophone in comparison to thirty five and eight tenths percent
(35.8%) in the Sudbury district and twenty nine and six tenths
percent (29.6%) in the Regional Municipality of Sudbury. The
union emphasized that the position in question had not previously
required fluency in French and that the evidence of Hr. Boivin’s
use of the language was not extensive or detailed. It ~8s also
submitted that the employer should have adduced more specific
evidence a8 to how and why the decision was made in this instance
and vhy a similar initiative had not been taken in other 8reas
having a greater francophone population. Counsel further argued
that to the extent the French Languages Services Act ~88 relied
on, such reliance was miepleced in assessing the need for the
delivery of services in French. It was noted in this regard that
the rights provided for by section five of the legislation have
not crystalieed in that the necessary regulations have not been
enacted. The union therefore submitted that the employer erred
if it determined need on the basis of a mistaken opinion a8 to
the level of their obligations under the legislation.
The union further alleged that the imposition of the French
language requirement had a discriminatory effect which could
result in a contravention of The Human Rights Code, 1981, as
amended. Specifically, counsel argued that the requirement could
adversely impact those within the British ethnic group. Data
from the 1981 census was relied on to illustrate that such
requirement created a significant advantage to those of French
origin. Given this potential for prejudice, the union submitted
that the employer must establish, on clear and convincing
evidence, that the requirement ~8s imposed in good faith and that
such was reasonably related to the job. Indeed, it was suggested
that once a prima facie case of discrimination had been made, the
legal onus would shift to the employer to justify its action. It
was lastly argued that this hoard had the jurisdiction and duty
to interpret and apply The Human Rights Code to a case of this
type. The following authorities were relied on in support of
this submission:
-6-
Re Singh srrd The Crown In Right of Oatario (Ministry of
Correctional Services), 27 L.A.C.. (2d) 295 (M. Eberte, November
1980);
Cousens v. The Canadian Nurses Association, Canadian Bumen
Rights Reporter, Volume 2, Decision 78, Paragraphs 3251-3325;
Re Ontario Euman Rights Commission et al. V. Borough of
Etobicoke, 132 D.L.R. (3d) 14 (S.C.C.).
Re Ontario lfumen Rights Commission et al. v. Simpson Seers
Ltd., 23 D.L.R. (Ath) 321 (S.C.C.).
On the basis of the above argument, the board was asked to
order a rerun of the competition. Such would require a fresh :
posting with the French language requirement omitted. This
would ensure, in the union’s submission, that those persons, who
were initially disinclined to apply because of the restriction,
would have the opportunity to demonstrate their ability and
qualifications for the job of Construction Safety Officer.
L
In response, the employer submitted that management may
establish the qualifications required for a particular job as
long as it does so in good faith and the requirements are
reasonably related to the job to be performed. It was argued
that in this instance there was no evidence presented as to the
existence of bad faith, and that the evidence led before the
board demonstrated that the requirement was both reasonable and
needed. We were urged to accept the evidence of Hr. Owens as’to
the need for.8 bilingual officer subsequent to the departure of
nr. Boivin in June, 1987. Counsel submitted that Mr. Owens was
the best person to assess the everyday requirements of the
position, in that he could testify from actual experience. It
~88 suggested that the described need ~8s not premisqd on the
French Language Services Act. Reliance was placed on the
-7-
testimony of Mr. Ovens to the effect that French language
capacity was required because of the nature of the position and
the demographics of the region. Simply put, the argument
presented was that the need existed without regard to the statute.
It was therefore of no consequence that the ultimate decision
maker may have relied on it when electing to incorporate the
requirement into the job posting. Lastly, it was argued that the
grievor’s opinions as to the greater need for French in the
mining sector and his evidence as to other postings were not
helpful to the resolution of this case. With respect to the
former, the opinions were unsupported by any reliable data and
were simply subjective judgments. With respect to the latter, it
was submitted that evidence of practice in regards to other
positions was irrelevant to the particular posting under
consideration.
The employer also took the position that the imposition of
the French language requirement did not contravene The Human
Rights Code, in that language is not a prohibited ground as
contained therein. Further, it was argued that there was no
definite correlation between ethnic origin and ability to speak a
specific language,. The major thrust of the employer’s argument,
hooever, was that there was no provision in the collective
agreement restricting their right to require 8 given language
skill. It was’submitted, therefore, that this board did not have
the jurisdiction to interpret and apply the .Code. OPSEU (P.
Shipley) and Ministry, of Correctional Services, G.S.B. 0223186
i’
(Samuels) and OPSEU (B. Noah). and Hinistry of Community and
Social Services, G.S.B. 767185 (Draper) were relied on in support
Of this submission.
-B-
The issue before this board is whether the French language
requirement inserted into the posting for the position of
Construction Safety Officer in the Sudbury office was reasonably
related to the job to be performed. After considering all of the
evidence and argument presented at the hearing, our conclusion is
that we must answer this question in the affirmative. While the
ultimate decision maker was not called as a witness, we find that
Ur. Owens was best positioned to address the actual requirements
of the job. In this regard, the board accepts his evidence that
he previously had the capacity to deliver.French services
through two bilingual officers and that this ability was lost in
June of 1987. While the evidence as to the number of instances
in which l4r. Boivin used his language skills in the performance
of his job was not extensive, we have no reason to doubt Mr.
Ovens’ assertion that he utilised this employee for the delivery
of French services over a considerable period of time. Given
the demographics of the region under Hr. Ovens’ management, as
disclosed by the census data provided to us, we think it more
likely than not that the call for such services “8s more than
just an isolated occurrence. In light of his past experience,
the board finds it understandable why Hr. Owens vould want to
retain one bilingual officerrin the Sudbury complement. Hare
importantly, we have been persuaded that this prior practice
establishes that the restriction in question w8s “reasonably
related” to the job to be performed. We wish to make clear,
-9-
however, that our comments in this regard are limited to the sole
position posted. The evidence adduced is insufficient to permit
us to state vith any certainty vhether there is a need for more
than one bilingual officer in the Sudbury office.
The board can only speculate as to the effect that the
French Language Services Act had on the decision to attach the
contested requirement to the posting. As noted, the final
decision maker was not called to give evidence. ‘Both k!r. Ovens
c..:. and Hr. Aki were swsre of the legislation and the impact that it
could have on their daily operations. The former sppesrs to have
been under the mistaken impression that the legislation was in
full effect in June, 1987. Notwithstanding this fact, our
assessment of his testimony is that his conclusions as to the
need for the requirement were based primarily on his past
experience with the position. While Mr. Aki received l4r. Owens’
recommendation together with reasons, we cannot state with any
certainty that these reasons by themselves dictated the final
decision. It is likely that the existence of the legislation wss
factored into such decision. We note in this regard that the
employer, in responding to the grievance at Step One, referred in
a general way to the rights created therein. The board does not,
hovever, find this to be material. In our judgment, the need
for a bilingual officer in the Sudbury office predated the
legislation. It is apparent that the French Language Services
Act did not creste the need, although it rosy serve to magnify it -
in future. Indeed, Hr. Ovens testified thst such sn officer
would have been required without even considering the impact of
-lO-
this legisletive initiative. We 8re inclined to agree vith his
assessment on the basis of the evidence presented. In summary,
we have looked to the position rather than to the Act in reaching -
our conclusion that the restriction was reasonably related to the
tasks to be performed.. In the context of the particular case
before us, we do not think that much weight should be accorded to
the employer’s decision vis a vis. other postings in the area.
In our opinion, the employer may establish the
qualifications required for a job pursuant to its management
rights which, in this case, are reserved by section 18(l) of The
Crown Employees Collective Bargaining Act, R.S.O. 1980, Chapter
108 ss amended. We concur with the stsndard of.review as
articulated in Re Reynolds Aluminum Co. Canada Ltd. and
Internstionsl Welders and Allied Workers Union, Local 28, 5
L.A.C. (2d) 251 (S. A. Schiff, February, 1974) st page 254:
“In the ordinary exercise of management functions
employers may determine in the first instance what
specific qualifications are necessary for 8 particular
job and what relative weight should be given to each
of the chosen qualifications. After an employer has
made the determination, arbitrators should honour the
msnagerisl decisions except in one or both of two
circumstences: First, the employer in bad faith
manipulated the purported job qualifications in order
to subvert the just claims of employees for job
advancement under the terms of the collective agreement....
Secondly, whether or not the employer had acted in
good faith, the chosen qualifications bear no reasonable
relation to the vork to be done.”
In this instance, we csn find no evidence of bad fsith on the
part of the employer.’ Additionally, we have concluded that the
requirement for fluency in French wss ressonsbly relsted to the
-I l-
job to be performed. The union, however, asks this bosrd to
apply a further test, that is, does the restriction contravene
the specific provisions of The Human Rights Code. It v**
submitted that if a prima facie case of discrimination was
established, the legal onus should shift to the employer to
justify its actions.. While the submission msy be correct
in the context of a human rights proceeding, we are disinclined
to extend it to the present proceedings in which we can find no
violation of the collective agreement. We sre of the view that
alleged violations of the Code are more properly the subject
matter of proceedings before the Ontario Human Rights Commission.
We note in this regard the following comment found at page 4 of
the Noah award previously cited:
“The argument is made on behalf of the grievor that
the employer is in violation of the Human Rights Code,
1981, in that the grievor has been denied equal
trestment with respect to employment because of
handicap o.f diabetes. The issue of the board’s
jurisdiction to entertain that allegation is se
bv the decision of the Supreme Court of Canada
t
i
Board of Governors of ~Seneca College of Applied
and Technology v. Bhadauria, 124 D.L.R. (3d) 19
finding of the court was that the Code estshlis
exclusive procedures for the enforcement of its
tled
Ls
The .
es
7
h
substantive provisions and so provides comprehensively
for remedies for its breach.”
the
We slso note with interest that this approach was employed in the
interim award in OPSEU (MacKenzie) end Ministry of Transportation
and Communications, G.S.B. 1243187 (Ratushny),
remsrkably similar to the one before this panel
similarly concluded that they did not have juri
which is a csse
. The board there
sdiction to desl
-12-
vith the grievance to the extent that it purported to allege a
violation of The Human Rights Code.
Counsel for the union i
did not take iseue vith the
Services Act or the principl
n her argument stated that the union
intent of the French Language
e of bilingualism. Rather, the
union’s concern vas to ensure, in the interests of its members,
that moves taken by the employer to increase French language
services were effected in a rational and judicious manner.
Clearly, the employment prospects of union members with respect
to promotions and transfers stand to be impeded if the employer
can impose a French language requirement on vague or
unsubstantiated data. While ve have not found this to be the
case here, our task would have been made easier had the employer
produced the ultimate decision maker. While this failure did not
affect the result in this case, this should not be taken as an
assurance that the same vi11 obtain in other cases. We *re
ettracted’to the suggestion made by Chairman Shime in Consumers
Glass Company Limited and Aluminum, Brick and Glass Workers,
Local 269, (unreported, December, 1986) that “there is an onus on
the employer to adduce evidence about those aspects of the matter
which particularly lie within the employer’s competence and
knowledge” (page 9).
Given the union’s legitimate concern as to the effect the
French Language Services Act may have on the bargaining unit, it
should be accorded a fair opportunity to fully determine and
assess the need to designate a position as bilingual. This is
i i. ‘; .;, . 6~ !:,, :
especially so in situations where French fluency has not
previously been required. In cases vhere the dispute proceeds to
arbitration, the union should be entitled to cross-examine those
responsible for the decision to designate positions as bilingual.
For all of the above reasons, the grievance is denied.
DATED s.t Windsor, Ontario, this 7th day of November , 1988.
(y?.j, &J G tiL&
n. v. Wetters, Vice- Cnairperson
“I dissent” (Dissent attached)
P. hlym, idember
-14-
J. : ‘....
x.5.
2250/87
DISSENT
Based on the evidence presented to the Board, I must
respectfully dissent from the conclusions reached by the
majority.
When the employer designates a bilingual requirement
on a job posting, where no such requirement previously
existed, great care should be taken to properly explain
and justify the reasons for such a decision.
The evidence before the Board showed the following:
i)
ii)
iii)
iv)
The position specification for Construction
Safety Officer contains no bilingual requirement:
There had never been a bilingual requirement on
any previous job posting in this area for the
Construction Safety Officer job;
As late as June 1985, there was a job posting for
a Construction Safety Officer in Timmins with no
requirement for bilingual capability even though
the Cochrane District is 48% francophone. I" fact,
the person who was the successful applicant did
not have French speaking ability;
Two recent postings in 1987 for Safety Officers in
the Mining Safety Branch in Sudbury did not carry
a bilingual requirement.
The above evidence together with other evidence adduced
by the Union clearly established a prima face case regarding
their claim. It was then incumbent upon the employer to
explain by evidence to the Board why the bilingualism require-
ment was introduced on this iob oostine. In following the
reasoning of Chairman Shime in Consumers Gas Company Limited
,and Aluminum Brick and Glass Workers Local 269, "there is an
onus on the employer to adduce evidence about those aspects of
the matter which particularly lie within the employer's
competence and knowledge".
With respect to the conclusion reached by the majority,
my finding is that the employer has completely failed to
satisfy this onus. There is no evidence before this Board
as to the actual reasons for adding the bilingualism require-
ment. All we have before us is not evidence as to the reasons,
but solely speculation.
(‘..#.
:;p;
- 2 -
Mr. Owen’s testimony is fairly summarized in the
majority decision. In his evidence, Mr. Owen clearly
and unequivocally stated that he did not make the decision
in regards to the French language requirement, nor could he
tell the Board who was the ultimate decision maker, nor did.
he know the actual reason for the decision.
Mr. Owen testified that he had no role in the posting
for the Timmins vacancy in 1985, and could not comment why
his opinion was requested prior to the subject posting and
not in 1985.
The majority gives great weight to Mr. Owen's opinion
that'there was a need for French language capability even
without the existence of the French Language Services Act.
However, a careful review of this testimony reveals how sketchy
his evidence was on this point. He could give only one
instance where Mr. Boivin was required to give services in
French. He had no evidence for us regarding the number of
requests received for services in French or the frequency
and locations that French services are required - in spite
of his six and one-half years in this job. There may very
well be a need as he suggests, but I believe that more sub-
stantive evidence than that presented is required for us to
be able to come to that conclusion. This Board has to make
its decisions on evidence presented and not be placed in the
position where we are asked to make a decision on little more
than speculation.
In any event, it is my position that the opinions
expressed by Mr. Owen are not the governing factor in this
case. He clearly stated he does not know the reasons for
the decision to add this French speaking requirement. There-
fore, his opinions are no more than simply opinions, and we
are left with no evidence to explain why this requirement was
actually added.
The employer did not call as a witness the person or
peisons who made the decision or who knew the actual reason
for the decision. This is extremely troublesome for a Board
seeking to adjudicate this sensitive issue. We were not
advised of any problems with availability of witnesses or.other
reasons why they were not called. In a situation where
experienced counsel are representing a party and they do not
produce their best witness or offer an explanation, I believe
the Board is entitled to consider the impact of this failure
to produce the evidence and to give it appropriate weight. In
this case, the Union is particularly prejudiced because they
did not even know who was the decision maker and they could not
themselves subpoena him.
-3-
Without this critical evidence and with the limited
value of Mr. Gwen's evidence, a review of the other evidence
presented to the Board is required prior to a final determina-
tion of the issue.
There is a strong inference that the provisions of the
French Language Services Act were a major role in the decision
to add the bilingualism requirement. The employer's answer
in Step 2 of the grievance procedure states in part: "I under-
stand that Sudbury is an area designated'where French may be
essential". (Exhibit 11) Mr. Owen testified that he and Mr.
Aki discussed the coming into force of the French Language
Services Act and that it was one factor which he considered
in his recommendation. In addition, at the preliminary hearing
(.:
of this case on March 25, 1988, regarding the jurisdictional
issue, the employer's counsel raised an argument relying upon
the French Language Services Act, 1986, to justify the bona fides
of the requirement for fluency in French for the Sudbury vacancy.
If the r,eal reason for the requirement for French fluency
was actually the French Language Services Act, then before it
can be said that the bilingual requirement was reasonable for
this particular posting, we would be justified in satisfying
ourselves that the proper procedures as laid out by the Office
for Francophone Affairs in its "French Language ,Services Act
Implementation Procedure Manual" were carried out. This Pro-
cedure Manual spells out a very detailed process for management
to assess the service delivery needs and the staff required.
There is a detailed procedure for doing an inventory of exist-
ing staff and providing some language training to fully qualify
those on existing staff with sufficient potential. Only after
going through these steps is a job posted for staffing from
outside.
jT:;>~.. The apparent intent of the Act and this Procedures Manual
is to use the three year period following the coming into force
of the Act on November 18, 1986, to establish adequate French
language capability for the services to be required in the desig-
nated areas by November 1989 when they will be mandatory on
demand. If this Act was a major factor in the decision to add
a French fluency requirement to this job posting, then before
we can say that French fluency was required on this specific
posting, we must be satisfied that all the Procedures were
followed. If the services required could be delivered by
existing staff or by other means, then obviously, there would be
no need for this French fluency requirement.
If there was no French Language Services Act in effect,
then perhaps we could decide this case on the subjective opinion
of a manager's needs, provided he actually made the decision.
But the Act and the associated procedures add a new dimension
to the case. The Government has obviously seen the need to
adopt detailed procedures to provide for an orderly implementation
i.
./: c.’ r. ,’
- 4 -
of the Act's requirements to minimize conflict and to provide
some protection for the rights of existing employees. Is it
then proper for management to claim they imposed a French
fluency requirement on a job in a designated area for other
reasons and that the French Language Services Act and its pro-
cedures shoud not be considered, even though they are in
full effect? How are we to differentiate and conclude that
the Act had no bearing - particularly when we do not have such
evidence presented to us.
It does nobody any good if management is allowed to side-
step the Act and the Procedures by claiming they made the posting
bilingual for other reasons, and thus escape the bother of the
details in the Procedures. This type of action borders on bad
faith and should be strongly resisted by the Grievance Settlement
Board. Indeed, a good argument can be made that with the
French Language Services Act and the Procedures in place, no
position should be designated as bilingual without first follow-
ing these Procedures, regardless of the other reasons which may
exist or have existed.
I would comment briefly on the Human Rights argument pre-
sented by the Union and its disposition by the majority.
In this grievance, both the violation claimed and the
remedy requested are well within the purview of the Collective
Agreement and the Crown Employees Collective.Bargaining Act.
On the question of reasonableness of the French fluency
requirement, I believe we have a right and a duty to consider
the Human Rights Act provisions to assist us in making this
determination. JIf the requirement apparently violates the
Human Rights 'Act., then it is appropriate for the Board to
conclude that it would not pass a Collective Agreement test of
reasonableness. Thee Collective Agreement itself would then
allow a remedy to be fashioned. I do not believe this is
inconsistent with the general content of the cases presented to
us regarding the Human Rights issue.
The Canadian Human Rights Reporter in Volume 2, Decision
78, concluded that the intent of the Ontario Human Rights Code
is to prohibit effective discrimination on ancestry even 1
though the particular manifestation may be in language (see
paragraphs 3286, 3289, 3290). AlSO, in paragraph 3294 it states
that extensive and detailed language requirements often will be
completely justifiable in the context of the position in question.
In the Ontario Human Rights Commission et al V. Borough
of Etobicoke case which involved a mandatory retirement age
for fire-fighters, the Supreme Court of Canada ruled:
"The onusfor proving that a mandatory retirement age
lower than that prescribed by the Code is warranted is on the
employer. The onus is not discharged by addressing impression-
istic evidence to the effect that fire-fighting is a 'young
man's game'. Although no fixed rule covering the nature and
sufficiency of the evidence required can be laid down, in a
case such as this statistical and medical evidence based upon
observation and research on the question of aging would have
been more persuasive."
The information filed with the Board from the 1981 Census
of Canada (Exhibit 8) shows that in Ontario, 71.1X of the
French ethnic group has French speaking ability compared to only
5.4% of the British ethnic group. If we accept the decision
of the Ontario Human Rights Commission that there is effective
disc~rimination on the prohibited grounds of ancestry even though
the particular manifestation may be in language, in our case we
have a prima facie case of discrimination established.
The onus for bringing forth proper evidence to show a
justifiable language requirement in this particular job posting
is on the employer. As stated earlier, the employer has not
discharged this onus. Therefore, the arguments presented to us
regarding the Human Rights Act serve further to lead to the
conclusion that it has not been shown that the French fluency
requirement was a reasonable condition on this posting.
For the above reasons, I would find that the grievance
should succeed and a re-run of the job posting should be held.
I wish to add that I recognise and agree with the goals
of the French Language Services Act and the need to provide
services in French to the francophone population in the designa-
ted areas. Because of the importance of providing these services
in French, it is essential that the employer scrupulously follow
the procedures laid out for the implementation of the Act to
avoid unnecessary controversy and not to make decisions under
the management prerogatives which cause existing employees
to perceive unfair treatment for them.
With the French Language Services Act in place, it does
not bode well for smooth labour relations if the employer is
allowed to decide when a bilingual requirement on a job posting
is due to the French Language Services Act or to claim it is
for some other reason and thus escape the laid down implementation
procedures.
Peter Klym.