HomeMy WebLinkAbout1987-2431.Churchill et al.89-04-10EMPLOYc3 DE LA COURONNE DEL’*NrAmo
C$lMMISSION DE
REGLEMENT
DES GRIEFS
IN TAE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING~ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
Between: OPSEU (Church::: et al)
- and -
Before :
APPEARING FOR
THE GRIEVOR:
APPEARING FOR
THE EMPLOYER:
Hearing:
Grievor
Employer
Z. Forbes-Roberts Vice-Chairperson
P. Klym Member
A. $:+.pletW! Member
A. R. Rae
Human I?csources Secretariat
Staff Reiati<>!i:; 81'.%iC~!
DECISION -__-----
The instant case lnvolves a number of identical grievances filed by Residential.Counsellors at the W. Ross MacDonald School
(“the School”) which is located in Brantford, Ontario. The School
provides services to blind and visually impaired persons, most if
not all of whom aze residents.
Because of this factor the School
must be staffed twenty-four (24) hours a day, seven (7) days a
week,
including holidays as prescribed by article 48 of the
collective agreement. The contentious issue between the parties
is the rate of pay vhlch attaches to vork performed by Residen-
tial Counsellors on these holidays.
By vay of background, the grlevors are compr lsed of emp-
loyees in both the Residential Counsellors’ II and III classlfi- cations. Both groups are regularly scheduled for tvelve (12) hour shifts. Because the School is a residence part or the
majority of those tvelve (12) hours may be nocturnal during which
the normal expectation ii that students will be asleep. Reslden-
tlal Counsellors are expected to do the same. Thus thelr shifts are, or may be divided into “periods of vork” and “sleep-in
hours”, terms vhlch vi11 become important as ve turn to the
specific language of the collective agreement.
The parties are In disagreement over vhlch provisions of the
collective agreement govern the rate of premium pay vhlch should
attach to hours “vorked” on an holiday.
The relevant portions of the collective agreement are as follovs:
ARTICLE 9 - SCHEDULED TOUR OF DUTY OR SHIFT
9.1 A shift vhich does not commence and end on the same
calendar day shall be considered as falling vholly
vlthln the calendar day on vhlch the shift corn
mences.
ARTICLE 19 - HOLIDAY PAYMENT
19.1 Where an employee Kprks on a holiday included under
Article 48 (Holidays), he shall be paid at the rate
of tvo (2) times his basic hourly rate for all
hours vorkad vith a minimum credit of seven and
one-quarter (7 i/4) eight (8), or the number of
regularly scheduled hours, as applicable.
ADDENDUM TO THE WORKING CONDITIONS AND EMPLOYEE
BENEFITS UNDER THE COLLECTIVE AGREEMENT
The parties hereto have agreed to the terms of this Addendum
covering employees in classifications of Residential
counsellor I. II andIII in the Institutional Care Category
-2-
. . . . *
This Addendum shall be attached to mformt of the
Worklna Conditions and uovee BeA=- Aarm
The terms of the settlement are as follow:
. . .
(b) ) &r soiclfled hereyn....Sleeo-in hRurs orlor to or
follovina a oeriod of vork shall not form a Dart
of the vork shift for anv ouroose of this aareg-
?IaL
(* It vas not disputed that the above dillneated group
includes the grlevors.)
APPENDIX 3
SCHEDULE A
. . .
Hours Worked on Holidays or Other Regular Workdays:
(a) &&J-hours vowon a hol-lday included under
Article 48 (Holidays) f&all be Daid at the rate
of tvo (2) )
emol vee vas receivina v&n the hpbldav vas work:&
(all emphasis added.)
The facts giving rise to the grievances relate to the
Remebrance Day holiday, November 11, 1987. The grieving Reslden-
tial Counsellors commenced shifts on November 10, 1987 vlth
“sleep-in” hours. They then commenced their respective periods
of vork on November ll.ln accordance vlth the residents usual
rising time. Their actual hours ~vorked on November 11 varied
from tvo (2) to ten (10). Because they commenced their shifts on
November 10th the Employer took the position that in accordance
with article 9.1 of the agreement (above) they were not entitled
to premium pay for any hours m vorked on the 11th.
At the hearing Union counsel argued that the specifics of
the Addendum override the generalities of the main body of the
agreement. Because in the Addendum the parties have deliberately
turned their minds to the peculiar vork demands and schedules of Residential Counsellors, article 9.1 of the agreement does not
apply. The Residential Counsellors are entitled to be remunerat-
-3-
ed under the terms of the Addendum.
The Employer argued that to ignore article 9.1 of the
agreement somehov created a split shift for Residential Counsel-
lors,a condition prohibited by article 10.4.
We agree with the Union’s position. In the main body of the
agreement article 9 deems that a shift is a shift is a shift, denoting a continuous period of vork. However the Addendum does
not address this issue in the abstract. Rather itaddressesthe
specific requirements of a residential School, recognizing that
shifts can be notionally divided without being actually split.
Within a single tvelve (12) hour shift there can be “sleep-
in hours” and “vork hours”. By virtue of the Addendum, and for
obvious reasons, “sleep-in hours” are specifically excluded from
premium pay provisions. This does not mean that premium pay
provisions are not to be found for this specialized group of em-
ployees. Appendix 3 - Schedule A dictates that for hours vorked
on a holiday Residential Counsellors vi11 be paid at double time.
Thus, appropriate to the nature of a Residential Counsel-
lor’s duties, the Addendum does not treat a shift as a conti-,
nuous, monocromatic event. Rather it deals vith the portions of
a shift. As correctly argued by Union counsel, the event
triggering premium payment is the act of vork on a holiday.
The grievances hereby succeed. The Employer is ordered to
pay the grievers at double time for hours vorked on November 11,
1987 regardless of vhen their shifts commenced. The Board shall
remain seized in the event that the parties have difficulty
implementing this avard.
Dated at Toronto this 22nd day of Hareh Dated at Toronto this 22nd day of Harch , 1989. , 1989.
P. Klym, Hehbcr
/ l‘i. 4 . . JIL,A L?‘ ._.
___-----_-------________________
A. Stapleton, Member
Under
TEE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
Between:
THE GRIEVANCE SETTLIMENT BOARD
,
OPSEU (Jones)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of Community and Social Services)
Employer
Before:
APPEARING FOR
THE GRIEVOR:
APPEARING FOR
TEE EhPLOYER:
HEARING:
J. Forbes-Roberts - Vice-Chairperson
I.J. Thomson - Member
M.F. O'Toole - Member
A. Ryder
Counsel
Gowling & Henderson
Barristers & Solicitors
R.J. Anderson
Senior Solicitor
Legal Services Branch
Ministry of Community and Social Services
June 3, 1988
August 16, 17, 1988
October 11, 19aa
November 17, 1988
The grievor, Mr. Ronald Jones is employed vith the Ministry
of Community and Social Services (“the Employer”) as a Parental
Support Worker (“P.S.W.*). He has vorked in the Employer’s
Income Maintenance Programme for approximately tventy (20) years,
and barring the instant matters has apparently had a clean
record. He has before this Board five (5) grievances all dealing
vith disciplinary penalties handed out to him from October 9,
1987 to January 19,1988. They are as follovs:
October 9, 1987 - vritten reprimand
October 14, 1987 - vritten reprimand
January 11, 1988 - one day suspension
January 13, 1988 - three day suspension
January 19, 1988 - five day suspension
A single issue, thaugh not a single set of facts forms the basis
of the dispute betveen the Employer and the grievor.
It ‘is the Employer’s contention that the grievor refused to
perform his assigned duties. It 1s the grievor’s position that
the Employer ordered him to perform at vorst an illegal land at
best an immoral act.
The facts are as follovs.
A P.S.W. helps social assistance recipients to enforce
support orders. This may involve negotiating agreements to pay,
enf arcing court ordered support payments, and/or collecting
payments vhich are in arrears. Prior to 1981 the P.S.W. assisted
the custodial parent vho vas seeking to enforce an agreement or
order by helping to complete the documents and affldavit mater-
ials vhich vould be put before the court. Central vas Form 35
Request For Enforcement (see Appendix A). The P.S.W. helped the
custodial parent complete this af f.idavit and then commissioned
her* svorn signature.
Arrears vere
creditor, sometimes
ledgers.
ascertained based on information from the
Hovever prior
clerical function.
from the debtor, and ‘by examining the court
to 1987 the P.S.W. vas not limited to this
The sources of information used to ascertain
the amount of arrears vere recognized as potentially less than
accurate. The court ledgers vere sometimes incomplete or out of
date. The creditor sometimes did not knov if she had received
out of court payments, oz thelr amounts. Sometimes the debtor
* Evidence vas heard that the vast majority of custodial parents
seeking to enforce orders are mothers. For simplicity ve vi11
USC thf female pronoun throughout.
- 2 -
could not be found and therefore could not give his side of the
past payments story.
Recognition of this potential inherent inaccuracy vas
granted in tvo 12) vays. First, ln paragraph 4 of form 35
follovlng “The order is in default in the amount of S . ..“. the
P.S.W. was permitted to add the phrase “as per the court ledger”.
There vas thus no suggestion that the affidavit’s deponent or the
commissioning P.S.W. had performed any calculations themselves,
but rather were
simply relying on the courts’ information.
Indeed in extreme cases the P.S.W. vas permitted to insert the
phrase “amount of arrears unknovn” and the judge vould then
simply deem the amount oving.
As part and parcel of this system the P.S.W. vas granted
standlng before the court. He or she could thus flag for the
judge any “guesstimates” in the affidavit or supporting materials
and leave it to the bench to make a final determination.
In 1987 the Support and Custody Order Enforcement Act
(“S.C.O.E.A.“) came into effect. Following the enactmentof this
legislation changes occured in the grievor’s function and in the
enforcement procedure itself. P.S.W.‘s began using vhat was knovn
as a S.C.O.E.A. filing package. Part of this package vas Form
35A Statement of Arrears (see Appendix Bl vhich replaced Form 35.
It remained the P.S.W.‘s function to assist the creditor In
collecting the financial lnformatlon necessary to file this form,
I and to commission her sworn signature. Hovever there ended the
similarity betveen Form 35 and Form 35A. In using Form 35A the
P.S.W. vas not permitted to insert in paragraph 4 the qualifying
phrase ‘as per court ledger” or “amount of arrears unknovn”.
Instead an m figure had to be svorn as due and ovlng by the
debtor. Indeed the exact statement of arrears had to be broken
dovn precisely in Schedule A on a month by month basis. The
creditor had to swear both these statements and the P.S.W. had to
commission her signature. In addition the P.S.W. could no longer
appear in court to clarify ambiguities or Nguesstimatesw.
S.C.O.E.A. also made provlslon for assignment of support
orders to the Llnlstry. In those cases the P.S.W. vas expected
to svear to the statement of arrears himself in an effort to
realise on default orders.
Unfortunately the new legislation and forms did not improve
the sources or quality of information upon which the forms vere
completed. Court ledgers were still often out of date, the
creditor still often didn’t knov if unrecorded monies had been
pald to her, and the debtor vas still often not available to tell
his side of the story. Nevertheless under S.C.O.E.A. the grievor
. .
-3-
vas being asked to personally svear to or to advise a client to
svear to the accuracy of information gathered from these sources.
It is over this issue that the Employer and the grievor came
to an impasse.
Under this nev regime if the grievor knev that a client vas
uncertain of the amounts owing and they could not be reliably
ascertained he refused to advise the client to sign the Form 35
nor vould he commission her signature. In the case of an
assignment to the Ministry in vhlch the grievor vas uncertain of
the amounts owing he vould not personally svear the Form 35A or
attendant Schedule A. Both acts prevented filing of the-
S.C.O.E.A. packages.
The Employer took the position that there was no difference
betveen Forms 35 and 35A, and thus the grievor’s refusal to
complete the S.C.O.E.A. packages constituted an improper refusal
of a legitimate vork assignment. and therefore was insubordina-
tion. The grievor took the position that to svear or to counsel
the svearlng of a false affidavit vas illegal and could leave him
open to criminal or civil liability.
By vay of clarification it vas agreed that the’grlevor
completed approxlmately eighty (SO) per cent of the S.C.O.E.A.
cases assigned to him. It was only when he was unsure of certain
information that he refused to act as commissioner or deponent on
an affidavit. This apparently amounted to three (3) files,
Taylor, Bressette and Desblens.
Beginning with the Taylor file the grievor attempted to make
his concerns understood to his supervisor, Mr. Peter Lovery.
This vas done both verbally and in writing. We do not find that
nr . Lovery ever particularly took the grievor’s concerns serious-
ly nor that he attempted to respond to them in a meaningful vay.
By letter dated October 2, 1987 the grievor outlined to Mr..
Lovery the nature of his concerns, highlighting the issue of Form
35A. He requested a vritten response. This came in the form of
Appendix C. We hardly find Appendix C responsive to Mr. Jones’
concerns..
It became clear from Mr. Lovery’s oral testimony that he
believed the Form 35A only represented a statement which had to
be true to the best of the deponent’s ability and based on the
available information. This quite obviously begs the question of
vhat to do vhen the information is IN& available. Indeed one of
the Employer’s ovn vltnesses, Ms. H. A. Moretta conceded that if
one could not stipulate the amount owing or in arrears one u
& swear or comml5slon a Form 35A, the exact position consis-
tently held by the grievor.
The grievor ultimately vas assessed two (2) written varnings
. .
-4-
and a one (1) day suspension for his refusal to complete the
Taylor file. He ausbsequently received a three (3) day suspen-
sion for refusing to file a Form 35A in the Bressette flle, and a
five (5) day suspension for refusing to file one in the Desblens
file. All were over the exact concern highlighted in his October
2, 1987 letter to Lovery.
The Employer called evidence as to what actions the grievor
could have taken to acquire financial information sufficient to
satisfy his conscience yis a via the Form 35A declaration. Union
counsel quite correctly, pointed out that information was neither
sought out nor certain-ky not in the Employer’s mind at the time
the discipline vas imposed and is thus irrelevant. The narrov
issue becomes did the Employer have just cause to impose disci-
pline on the grievor?
We find that it did not. The S.C.O.E.A. filing package 15
put out by the Ministry of the Attorney General. Under the title
Instructions on Hav To Complete Statement of Arrears it states:
The Statement of Arrears is sworn under oath. You I@,!,&
be absolutelv accwate in statina I.he amcwts YOU l&i& as not havlna been&& Every payment which has not
been made must be identified individually.
(emphasis added)
The grievor was left in a very unpallatable position. His
supervisor’s instructions and those contained in the very package
he was being ordered to complete were at odds. The latter only
confirmed the grievor’s belief that to follov the former was to
perform or to counsel an illegal act, and to ignore the dictates
of his own conscience.
The Employer sought to invoke the “obey nov, grieve later”
doctr lne. In the event of a subsequent civil or criminal action
one vonders what .defence this would leave available to the
grievor. (Fortunately this Board does not have to determine if
fear of one’s supervisor is sufficient to constitute the defence
of necessity.)
We do not find this an appror late case for the af oremen-
tioned doctrine. We do not believe that the grievor’s potential
liability could be cured by subsequent recourse to the gr ievan:e
procedure. Knowingly swearing an untrue affidavit is not a
breach of the collective agreement, but rather a breach of a
statute. Further ve find that the Employer’s orders to commission
and/or svear the Statements of Arrears in the Taylor, Bressette
and Desbiens cases vere unreasonable and unfair in the circum-
stances. Indeed given the clear instructions in the S.C.O.E.A.
. .
-5-
filing package there is a strong argument that t4r. Lovery was
giving orders which were w for the grievor to follow.
The grievances are hereby alloved. All references to the
October 9, 1987, October 14, 1987, January 11, 1988, January 13,
1999 and January 13, 1989 disciplinary actions are to be expunged
from the grievor8 record and he is to be made whole for any
from their imposition. The Board will monetary loss flowing
remain seized in the
tion of this award.
event of any difficulty in the implementa-
Dated at Toronto this 10th day of April, 1989.
\qqp----
J. Forbes-Roberts. Vice-Chairperson
1-J. Thomson, Member
0 \ _ t4.F. O’Toole, t4em&
a I”..,,Y#U. ““Ye.
(Family Division)
$y=arl& A Request for Entorcement
-1s,,
I. the undersigned. make oath and sav:
1. I seek to enforce the following ardrr *Nch soal:
Date of order ceun
2. The order is being enforced for the b&fit of ’
Court file no.
Full nameIs Relationship to creditor
3. I authorizc the court to receive. record and pay out to me of my nrigne all rwnr plvablc under the order, including costs. --
4. lhi order is not in default.
or
The order is in dofrult in the amount of S ’ . as of todJv.
5. I request that the ada be enforced against the debtor nowjj~~$,+#omri.ca!!v upon any $tura default. by means Of a
1, notice of default requiring the debtor to file I sutammt of financial information. &ear befor;ik~~ to explain under
oath the default up to the date of that appewana wd to pay into mwt the costs of the pwxeding. incurred bv me or
those acting on my behalf.
6. I also request that the debtor submit to m exuninrtion of anests and rnaan~ if &directed by the clerk of the court.
7. I request the court to consider enforcement of this order bv ordering any or all of the remedies set forth in the Familv
Law Reform Act. including imprisonment. as mav seem worowiatc to the ~)urt.
Provincial Court fiPperlc+JX 1,
Statement of Arrear.
(Family Division) Form 35A court file “0.
n I
,ddrssl
Creditor
=I Addwu far ,cwicc ,*,mr * ““rnbW, rn”rnEip7lil”,
I, the undersigned. make oath and say:
1. I am the creditor under the following -
III order
Date Of order cuun
0 agreement filed with the court
Date Of agreemenr Date filed
2. The following amounts due under the order/agreement have not been paid:
Date ,myme”t due Amount due Date raid
Court file no.
Sworn before at the
in the
this _ day of
FD 211 (‘U m/86,
of
of
,19-. A mmm;n;oncr. etc.
Total Arrears S
Total interest to da; calculated at -
TOTAL $ .
Ministry of
the Attorney
General
Pp/am+% ”
SCHEDULE “A”
Support and Custody
Enforcement Branch
Amount Due Amount Paid
Community and Services SOCiaUX
Social Services et communautaires
Ontario
720 North,Christina Street
Sarnia, Ontario
N7V 3C2
Tel.: 337-3735
October 7, 1987.
Mr. Ron Jones,
Parental Support Worker,
Sarnia, Ontario
Dear Mr. Jones,
In response to your letter of October 2nd, 1987
please be adviceed that you are to continue to
exercise your responsibility as a Parental Support
Worker and in so doing complete the Support and
Custody Orders Enforcement Act applications.
As you are aware it is Management's right to
assign work. Failure by an employee to do work
assigned cqnstitutes insubordination and is subject
to disciplinary action.
Should you disagree with my position please contact
your Ontario Public Service Employees Union
representative.
Yours truly,
Income Maintenance Branch,
Sarnia.
PL/eds.