HomeMy WebLinkAbout1998-0936.Sam et al.00-02-24 DecisionONTARIOEMPLOYÉS DE LA COURONNE
CROWN EMPLOYEESDE L’ONTARIO
GRIEVANCECOMMISSION DE
SETTLEMENTRÈGLEMENT
BOARDDES GRIEFS
180 DUNDAS STREET WEST, SUITE 600, TORONTO ON M5G 1Z8 TELEPHONE/TÉLEPHONE,(416) 326-1388
180, RUE DUNDAS OUEST BUREAU 600, TORONTO (ON) M5G IZ8FACSIMILE/TELECOPIE:(416) 326-1396
GSB # 0936/98, 0937/98, 0938/98, 0939/98, 0942/98, 0943/98
OLBEU # OLB346/97, OLB319/97, OLB320/97, OLB318/97, OLB295/97, OLB262/97
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Liquor Boards Employees Union
(Sam et al)
Grievor
- and -
The Crown in Right of Ontario
(Liquor Control Board of Ontario)
Employer
BEFORE Nimal V. DissanayakeVice Chair
FOR THE Julia Noble
GRIEVOR Counsel
Ontario Liquor Boards Employees Union
FOR THE Alison Renton
EMPLOYER Counsel
Liquor Control Board of Ontario
HEARING January 5, 1999
April 27, 28, 1999
May 6, 7, 1999
September 14, 15, 21, 22, 28, 1999
November 26, 1999
January 11, 12, 2000
DECISION
At the commencement of this proceeding I had before me nine
job competition grievances arising out of a job posting and
competition. However, at the hearing on April 27, 1999, I was
advised that grievors Abdool, Bhatia and Doiron had withdrawn
their grievances. That left for determination, the grievances
of George Everest, Ted Felora, Barry MacKay, Dave Patterson,
Doug Sam and George Velentzas.
Their grievances relate to a posting (File CR157/97) for
40 vacancies for Full-Time Customer Service Representative (CSR)
positions in Area A (Toronto). It is common ground that these
vacancies arose as a result of the application of a Letter of
Agreement on Permanent Vacancy Review, which inter alia,
required the declaration of a vacancy and posting, where a
casual employee had worked 1,700 hours or more in a retail
store. The posting in question was dated May 26, 1997 and had
a closing date of June 16, 1997.
The preamble to the posting reads:
Under the general supervision of the Manager, you
will provide prompt, courteous and knowledgeable
customer service in accordance with the Customer
Service Standards of Excellence, participate in and
comply with corporate initiatives as made mandatory
(e.g. PKCC levels, SMAART), keep abreast of and
3
participate in timely execution of Ready for Business
and Retailer of Choice Standards, receive, handle,
store and rotate stock in orderly, systematic and
safe manner; adhere to Occupational Health and
Safety, WCB and WHMIS guidelines; support and
contribute to a harmonious and productive work
environment, follow security procedures of LCBO
funds, stock and properties, exhibit ability to
operate computerized systems and interpret financial
information, promptly and accurately complete all
store reports and records; be prepared to work
extended hours based on operational requirements.
The following was listed under AQualifications@:
Position requires tact, diplomacy, good oral and
written communication skills, ability to maintain and
contribute to positive interpersonal relations with
customers, LCBO employees and trained
representatives, mathematical, clerical and
accounting skills, ability to operate computerized
terminals (office or cash register terminals), good
knowledge of cashiering and security procedures,
initiative and reliability, ability to work with
minimum supervision and routine checks, ability to
meet the essential physical requirements of the job,
general knowledge of products and services offered by
the outlet and by the LCBO which may include
servicing of licensees and agencies in a socially
responsible manner. You should also demonstrate an
awareness of and support the LCBO strategies
including Customer Service, Excellence, that=s The
Sprit, and Ready For Business Standards. You will
have successfully completed product Knowledge Level
II and working towards Product Knowledge Level 3.
The posting also stated:
PLEASE NOTE:
-The area of search will be the geographical
posting area.
-A Q-35 Form must be submitted with your store
number or department number. Employee
4
identification number and the appropriate
posting number accurately recorded.
-Qualified PPT candidates will be selected in
accordance with the procedures under Article
21 of the Collective Agreement.
-Candidates from Casual status will only be
considered when there are no qualified
Permanent Part-Time Employees.
-Casual candidates will be selected in
accordance with the procedures under Article
31.4 of the Collective Agreement.
-Candidates must meet the following minimum
criteria in order to be considered: a) Past
satisfactory work performance; b)
Satisfactory discipline and attendance
records; c) French language services
requirements where applicable.
-Casual candidate qualifications will be
determined through a process consisting of a
scored interview and scored past performance
appraisals.
-A circular will be issued announcing the
successful candidate.
The posting was open to all permanent part-time and casual
employees of the LCBO=s store system in Area A. Three permanent
part-time employees were offered positions in priority as
contemplated by the collective agreement, leaving 37 vacancies
to be filled through a competition among casual employees.
Approximately 230 casual employees applied. As required in the
posting, a form known as the AQ-35" was used to make application.
This form, titled AApplication for Posted Vacancy@ is extremely
5
brief and has space only for the employee name, date, present
position, store and Department, status (Permanent Full-Time,
permanent part-Time, or casual) and Social Insurance Number, and
is to be signed by the applicant.
Once the posting closed, the Human Resources Dept. screened
the applicants for interviews. One applicant was denied an
interview because he had not completed the pre-requisite AProduct
Knowledge II@. He did not grieve. Several applicants were
denied interviews on the basis of their active discipline on
file. Two of them grieved, namely grievors Patterson and
Velentzas. The employer selected 59 applicants to proceed to
the competition, which consisted of a scored oral interview and
a scoring of the 2 most recent performance appraisals. Through
this process the 37 positions were filled. Grievors Everest,
Felora, Mackay and Sam participated in the competition but were
not successful. They had more seniority than some of the
successful candidates, and grieved alleging that the employer
had contravened the collective agreement.
The successful candidates (incumbents) were provided notice
of this proceeding as required by law. Some attended hearings
more regularly than others. Some did not attend at all. The
6
Board made it clear that each incumbent was entitled to fully
participate in the proceedings as a party, with or without
counsel. Of those attending, some participated actively, while
others were mere observers. None of the incumbents testified
and none called any evidence.
The governing provision in the collective agreement is
article 31.4(b) which reads:
The Employer agrees to give consideration to the
qualifications and ability of casuals for permanent
full-time vacancies at the entry level in their
geographical area, provided that no permanent part-
time employees have applied. Where qualifications
and ability are relatively equal, seniority shall be
the determining factor.
The union made a two pronged argument. First, it pointed
out that there was substantial similarity between the duties and
responsibilities of a casual CSR and those of a full-time CSR.
All of the applicants had performed the duties of a casual CSR.
In the circumstances, it was argued that as long as the
applicants passed the initial screening (which recognises the
absence of any major concern and the presence of all pre-
requisites) they should be all deemed to be qualified and
relatively equal in qualifications and ability. That being so,
the argument went, there was no justification or need for any
further interview process, and the positions should have been
7
awarded on the basis of seniority alone. On this basis, the
union urged that the Board order that the positions be awarded
by order of seniority, to those applicants who passed, or should
have passed, the screening.
In the alternative, the union takes the position that the
competition process conducted by the employer was fundamentally
flawed in a number of ways and did not comply with article
31.4(b). The union contended that the results of such a flawed
process ought not be allowed to stand, and sought an order that
the competition be re-run.
Initially the union had taken the position that in the past
the employer had followed a practice of awarding full-time CSR
positions to casual employee applicants on the basis of
seniority alone, and that it was estopped from changing that
practice for this posting. However, during the course of the
hearing, union counsel advised the Board that the union would
not be pursuing that argument, without prejudice to its right to
raise it in other cases.
Article 31.4(b) is what is commonly described as a
Arelative equality@ clause, as opposed to a Athreshold ability@
8
clause. In the latter type, once applicants are found to meet
a threshold or minimum level of ability and qualifications,
seniority determines who among them are entitled to the
available vacancies. On the other hand, in the face of a
relative equality clause, the employer must not only determine
whether the applicants meet a threshold standard, but it must
also determine whether the applicants are relatively equal in
ability and qualification. This determination includes an
inquiry as to whether there is a substantial and demonstrable
difference in qualifications. Re Vaillancourt, 1120/87
(Wilson). Seniority becomes a determinative factor only among
those applicants found to be relatively equal. The screening
process undertaken by the employer was intended initially to
weed out those applicants who did not meet the threshold level
of ability and qualifications. Under a relative equality
clause, once a pool of minimally qualified applicants is
established through the screening process, the employer next has
to assess the relative abilities and qualifications among those
applicants.
The union=s argument is that the employer should have gone
from a determination of threshold ability, to an awarding of
positions on the basis of seniority. That would be to treat
9
article 31.4(b) as a threshold ability clause, which it is not.
Conducting interviews is one method open to the employer to
gather the information about the applicants= abilities and
qualifications for purposes of determining relative equality.
Review of the applicants= personnel files, performance
appraisals, resumes and references and consulting their
supervisors, are some of the other important sources of such
information. Provided they are conducted in a fair and
reasonable manner to elicit relevant information, interviews are
a useful and a legitimate tool available to an employer in
determining relative equality.
The evidence does support the union=s assertion that there
are substantial similarities between the full-time and casual
CSR duties and that all of the applicants had worked as casual
CSRs. However, the evidence also indicates that some applicants
had been exposed to a broader range of CSR duties than others.
Some had worked as CSR for a longer period than others, and had
greater experience. Therefore, the employer was entitled by
article 31.4(b) to determine who among the applicants were
relatively equal in qualifications and ability, and who were
not. The employer was not precluded from resorting to oral
10
interviews as one method of gathering information required to
make that determination.
For the foregoing reasons, the Board finds no merit in the
union=s position that the employer should have awarded the
positions to the applicants who passed the screening, on the
basis of their seniority. That would be tantamount to ignoring
the relative equality language in article 31.4(b). See, Re
Netta et al, 1404/97 etc. (Mikus)
Therefore the Board turns to consider the union=s alternate
argument that the competition process conducted was so
fundamentally flawed, that the results generated thereby should
not be allowed to stand.
The competition process
The evidence is that the employer had concerns that job
postings involving promotion of casual CSR=s to full-time CSR
positions, were being conducted inconsistently in the various
areas and regions within the province. With the inclusion of
the Permanent Vacancy Review Letter of Understanding in the 1996
collective agreement, it was anticipated that a substantial
number of such vacancies would have to be posted. Therefore, the
11
employer devised a new recruitment process to take effect in 1997
for the filling of vacancies that result from the application of
the letter to casual hours worked in 1996. The basic goal was
to have a process that would be applied consistently in all
locations within the province. A number of documents were
prepared setting out the new process. Mr. Wayne Zachar,
Director of Employee Relations, was closely involved in the
creation of this new recruitment process. He testified about how
the new competition process was intended to be implemented.
The basic steps in the Process are set out in a document
titled ACustomer Representative Recruitment Process@, as follows:
STEP 1 Post Vacancy
STEP 2 Screening Process
Eligible candidates= discipline,
attendance and performance appraisal
records are reviewed. Must have
satisfactory discipline, attendance and
performance appraisal or are screened
out.
STEP 3 Interview process
Determine the number of employees to be
interviewed by ranking in seniority
order and using between a 3-1 and 2-1
ratio. Look for gaps in seniority,
where possible.
Interview using bank of CSR questions.
12
Weighting of performance appraisal will
be 40%.
Weighting of interview will be 60%.
STEP 4 Determination of Successful Candidate(s)
Overall pass mark will be 50%.
Relatively equal spread will be 20%.
Rank in order of overall score.
Promotions are granted to the senior
employees within the 20% spread.
STEP 5 Not Enough Successful Candidates
Continue down the list and interview
until all potential vacancies are
filled.
Do not advise candidates of outcome
until ALL interviews are completed as
the successful candidates may change.
STEP 6 Prepare Applicable Documentation
to Process promotions/Appointments
With regard to Step 2, Mr. Zachar testified that
Asatisfactory discipline@ meant that if there was active
discipline on an applicant=s personnel file, management must be
satisfied that it was not serious enough to disqualify the
applicant, and that each case had to be decided on its own
merits. Mr. Zachar testified that the employer decided to review
13
attendance records because regular attendance was a necessary
qualification for a full time CSR. Similarly a review of
performance appraisals was seen as a useful tool in assessing an
applicant=s qualifications for the vacant position. It was
decided that only the two most recent appraisals on file would
be considered because that would provide Aa more balanced picture
of his performance.@ The two appraisals were to be scored out of
a maximum score of 25 points. The two appraisals were weighted
at 40 percent, of the total score for the competition, while the
balance 60 percent was allotted to the oral interview process.
Recognizing that different appraisal formats were used to
evaluate casual employees, the employer devised two rating
scales. Where an appraisal form had evaluated areas of
competency with a five point rating scale, points were assigned
as follows:
1.AOutstanding@ = 1
2. = .75
3.AMeets Requirements@ = .5
4. = .25
5.AChange Required@ = 0
Where a form evaluated areas of competency with a four
point rating scale, points were assigned as follows:
14
1.AMore than meets requirements@ = 1
2.AMeets Requirements@ = .75
3.ADevelopment Required@ = .25
4.AUnsatisfactory@ = 0
Areas of competency were allotted different weights,
depending on the employer=s view of what areas were more
important. For example, Acustomer service@ was weighted higher
than Aappearance= or Asafety and protection of LCBO assets@.
Mr. Zachar testified that in reviewing appraisals, the
process did not take into account anything other than the scores
assigned by the appraiser to the listed areas of competency.
Comments written out by the appraiser in the comments section of
the appraisal were not to be given any consideration because, in
his view, such comments Amerely substantiated the scores given@.
Where a AN/A@ (not applicable) was marked for an area, the
applicant got a zero for that because the N/A indicated that the
employee had not performed that particular function or skill.
When asked why applicants= resumes were not reviewed, Mr. Zachar
replied, AIt was felt that for this type of competition it wasn=t
appropriate - that it will give an unfair advantage to persons
more skilled in preparation of resumes.@
15
With regard to Step 3 in the process, the interview, Mr.
Zachar testified that 3 to 1 and 2 to 1 ratios were used to limit
the number of initial interviews, because it was not useful or
practical to interview everyone who applied. A bank of questions
was put together for use in these interviews, although Mr. Zachar
did not know who prepared those questions. He stated that the
typical interview panel was to consist of two members from
operational management and one from the Human Resources Dept.
Mr. Zachar was involved in the decision to assign 60 percent of
points in the competition to the interview and 40 percent to the
two performance appraisals. The percentages were assigned based
on the management=s view of the relative value of an interview
and a review of performance appraisals. The minimum percentage
required to be qualified was set very low at 50 because
management recognized that some employees may not interview well
and that appraisals may be subjective depending on the
relationship between the employee and the supervisor doing the
apprisal.
Referring to Step 4, Mr. Zachar explained how the 20
percent spread for relative equality was to be applied. Once the
highest scorer in the competition was determined, the scores of
16
every applicant who had more seniority than the highest scorer
were to be compared to determine whether their scores came within
20 percent of the highest score. All applicants within 20
percent of the highest scorer are awarded positions by seniority.
Next, if vacancies still remain after this process, the highest
scorer is awarded a position.
At this point the highest scorer goes out of the picture.
The next step is to determine who the second highest scorer was,
and he now becomes the comparator. All applicants not yet
awarded positions, and who are more senior to that second highest
scorer, are compared. Those scoring within 20 percent of that
second highest scorer are awarded positions by seniority. If at
the end of this process vacancies still exist, the second highest
scorer will then be awarded a position. Next the third highest
scorer, becomes the new comparator and this process is carried
out until all of the available vacancies are filled. If at the
completion of this process, not enough qualified applicants are
found to fill the available vacancies, additional interviews were
to be scheduled under Step 5.
The alleged flaws in the process
The union submitted that the employer failed to gather all
relevant information required to properly assess the applicant=s
17
abilities and qualifications. Instead, the employer relied
solely on interview scores and a numerical conversion of just 2
performance appraisals for each applicant. According to the
union there was much more useful and relevant information easily
available to the employer which it ignored.
The union took issue with the fact that the employer only
considered the last two performance appraisals on file. The
employees= personnel files contained much more information, which
was directly relevant to ability and qualifications. As
examples, the union pointed out that the grievors had more than
just two appraisals on file. Some of the appraisals not
considered, had very high ratings as well as very complementary
comments by the appraiser, which reflected positively on ability
and qualifications. Even in the 2 appraisals reviewed, the
employer ignored comments made by the supervisors. The personnel
file of one grievor contained a letter of commendation written
by the District Manager. This received no consideration. In
addition, the employer did not review any resumes.
The union pointed out to the evidence that the employer
policy required that performance appraisals be conducted on each
employee annually. This had not been done. As a result, some
18
of the applicants had appraisals on file covering 1996 and 1997.
Others did not. Their two most recent appraisals on file
included 1994, 1993 or even older appraisals. As a result some
had their performance some years ago scored, while others had
their recent performance scored. The time period assessed for
various employees was different. The union pointed out that one
incumbent, D. Leet, was assessed on the basis of his 1991 and
1992 appraisals. This inconsistency resulted from the employer=s
failure to comply with its own policy which required annual
appraisals.
The union further took the position that the weighting for
the review of the 2 appraisals was inappropriate, and that the
resulting scores failed to reflect the level of performance
indicated in the appraisals. The weighting resulted in
unreasonably low marks. For example, where an employee received
a score of 3 for an area of competence in a 5 point grid,
according to the legend in the appraisal form itself, that
indicated that the employee was Asatisfactory@ or Amet
requirements@ in that category. Yet the employer assigned only
a 50 percent score for that. Pointing out that the appraisal
scores accounted for as much as 40 percent of the total marks in
the competition, the union submitted that penalizing an employee
19
who is performing satisfactorily by deducting 50 percent of the
full mark was unreasonable. Counsel reviewed a number of cases
where the process resulted in a failing score for the employee=s
appraisals, i.e. less than 50 percent, even though the appraisals
gave a rating indicating that the employee met requirements. In
other words, the supervisor doing the appraisal had concluded
that the employee was performing satisfactorily, but under the
scoring system used, that employee gets a failing grade.
The union took serious issue with the weight of 60 percent
assigned to the interview. In the union=s view, that over-
emphasized the value of a 2 hour interview, in evaluating an
employee=s qualifications and ability. This was more so when
much more reliable information was ignored. According to the
union, information on file about the applicant=s actual job
performance should have received greater emphasis than interview
scores, specially because the posted positions were substantially
similar to the ones held by the applicants.
It was specifically pointed out that no resumes were
reviewed and supervisors were not consulted. As a result there
was no consideration given to the applicant=s past experience.
20
The union also took the position that the scoring of the
interviews by the 3 panel members was inconsistent and
subjective. Many examples were given of situations where one or
more members credited an applicant for providing a suggested
answer, while others did not. Counsel pointed to other alleged
defects. One of the panel members testified that 2 hour was not
enough to interview an applicant. Different questions were
assigned different marks, but the applicants were not made aware
of that. Counsel also characterized as Aproblematic@, the
evidence that the total marks for the applicants interviewed on
the first day had been erased and changed by one of the panel
members, after the marks given by the 3 members had been tallied
and averaged. The panel member who did the change could not
recall exactly when and why that was done.
Denial of interviews to two grievors
As noted, grievors Patterson and Velentzas were screened
out and were denied interviews. The onus is on the employer to
demonstrate that the screening was done in a fair and reasonable
manner. See Re Quan, 1797/91 (Gorsky). Ms. Heidi MacNeil, a HR
Assistant in the Central Region Office, testified about the
screening process for discipline. Ms. MacNeil sent to each
21
District Manager in the region, a list of employees from their
district who had applied pursuant to the posting. On June 23,
1997, she wrote to the District Managers requesting them to
Areview your list and notify me if any of your employees have
discipline that should disqualify them from getting an
interview.@ The evidence is that Ms. MacNeil was acting on the
instructions of Ms. Yolanda Simone, Manager of Human Resources
for Central Region. Ms. Simone testified that the personnel
files in the Human Resources Dept. were incomplete with regard
to employee discipline, and that this necessitated the contacting
of District Managers to get that information.
Under cross-examination Ms. Simone agreed that there was no
document or criteria outlining how applicants were to be screened
for discipline. The district managers were given no
instructions as to under what circumstances discipline will
disqualify an applicant. However, she stated that Aeveryone
knows what to do with discipline, it=s the same as it has always
been@. When asked what that process was that everyone knew, she
replied AYou can=t look at discipline beyond 3 years. If there
is discipline within the last 3 years, the manager has to decide
if that discipline is relevant, how old it is and how severe it
is. That is basically a call for the District Manager to make.@
22
She emphasized that the District Manager only makes a
recommendation, which may be accepted or rejected by the Regional
Director who had the final decision on whether to screen out an
applicant because of discipline.
The employer prepared an Eligibility Review List, which
inter alia, sets out the results of the screening for discipline.
Of those applicants who otherwise had the seniority to receive
an interview, 10 had discipline within the previous 3 years. The
outcome was as follows:
Employee
Linda
Wisniewski
Discipline
on
file
- Written
reprimand
July 27/95
re
altercation
with D.
Hildebrande
Supervisor
recommendati
-on
Mike
Stephens
requests
discipline
be waived as
employee has
shown
improvement
Regional
Director=s
decision
Recommendati
-on accepted
Ted Felora- 1 day
suspension
November
22/95 re
failure to
report for
scheduled
shift
- Written
reprimand
August 31/94
re leaving
store prior
23
to end of
shift and
improper
cashiering
procedures
Mike
Stephens
requests
discipline
be waived as
employee has
shown
improvement
Recommendati
-on accepted
Dave
Patterson
Written
reprimand re
incident of
July 3/96 -
employee
mistook
customer as
a former
shoplifter
and banned
from store
Ursula does
not
recommend
Recommendati-
on accepted
Colin EnricoWritten
reprimand
dated
October
13/95 re
failure to
report
Not
recommended
by G.B.
Recommendatio
n not
accepted
interview
granted
George
Velentzas
1 day
suspension
May 19/95 re
altercation
with another
employee
Ursula does
not
recommend
Recommendatio
n accepted
Bill
Tilley
Termination
re theft
reduced to
suspension
(August 12
to October
20/96) via
M.O.S.
Mike does not
recommend
24
Recommendati
-on accepted
Robert
Saliba
suspended 5
working days
November 11-
16/96 re
physical
altercation
on November
9/96
Outstanding
M.O.S.
allowing
application
for
promotion
Recommendati-
on accepted
Susanne
Scarcello
Written
reprimand
December
21/94 re
missing
envelope
Gerry would
not
recommend
Interview
granted
Recommendati-
on not
accepted
Joe
Perciasepe
Written
reprimand
February
15/96 re
inappropriat
e behaviour
toward asst
manager and
other staff
and 3
counsel
letters in
1996
Paul does
not
recommend
Recommendati-
on accepted
Kenneth
French
Written
reprimand
dated
September
22/95 re
failure to
report
Doug
recommends
Ken be
included
- employee
is on EAP
and is
showing
progress
Recommendati-
on accepted
25
Debra
Companaro
Written
reprimand
dated
December
12/94 due to
failure to
report
Doug
recommends
Debra be
included in
competition
Recommendati-
on accepted
Ms. Harfman testified about her own decision, as District
Manager, to recommend that grievors Patterson and Velentzas be
not interviewed. In chief, Ms. Hoffman was asked why she made
that recommendation for grievor Patterson. She replied AHe had
a poor rating in two columns in the appraisal and I didn=t
recommend that he be allowed to compete. There was also a
reprimand on file. I had also met with him and his manager
previously about his overall performance in cashiering@. She
reviewed Mr. Patterson=s performance appraisal dated September
30/96. She testified that it had a A4" for communication,
relationship and knowledge of operations and a A5" for
punctuality and attendance, and that it caused her concern
because that was below the standards expected. When asked what
Mr. Patterson=s reprimand was about, Ms. Hoffman stated, AHe had
approached a customer and accused him of being a former
shoplifter. It was a case of mistaken identity and the customer
complained and threatened legal action.@ When asked how that
discipline in 1996 factored in her decision to not allow Mr.
26
Patterson to compete in 1997, she said AWe have a performance
issue, a customer service issue. We have inaccuracies in
cashiering, and improvement was needed. Should he be rewarded
with a full time position?@
Ms. Hoffman was also asked in chief why she recommended
that grievor Velentzas be not interviewed. She replied that Mr.
Velentzas had a one day suspension which she considered to be
Aserious discipline@, because it involved a violent interaction
with another employee on the sales floor. She said that she was
aware that this discipline was over 2 years old, but stated that
Adiscipline lasts for 3 years before its forgiven.@
Under cross-examination Ms. Hoffman agreed that he only
looked at Mr. Patterson=s 1996 appraisal. She did not consider
his next previous appraisal which was in 1994, or the one done
in 1993. She acknowledged that in the 1994 appraisal Mr.
Patterson received a 1 for punctuality and attendance which
indicated exceptional performance. When counsel pointed out that
Mr. Velentzas= discipline was over two years old at the time, Ms.
Hoffman agreed, but added AThat still is within the 3 year period
and the discipline would count.@ When counsel asked ASo because
27
it was less than 3 years old you disqualified him@, she answered
Ayes@.
Ms. Hoffman testified under cross-examination that she
reviewed only Mr. Velentzas= 1997 appraisal. When counsel
pointed out that in that, Mr. Velentzas received an overall
rating of 2 indicating a better than satisfactory performance,
she agreed but explained AHis performance was not the issue. He
did his work well. The issue was that he had a violent
interaction with an employee. The discipline was not because of
poor work performance@.
The arbitral jurisprudence recognizes that in certain
circumstances past discipline may be relevant in assessing an
employee=s qualifications and ability to perform a job for which
he has applied. Brown & Beatty, Canadian Labour Arbitration,
(3rd Ed.) at 6:3310 summarizes the principles established in the
case law as follows:
There is a consensus of opinion that where it
is relevant to do so an employer may take into
account the grievor=s past disciplinary record,
including verbal warnings, in assessing his skill
and ability to perform a job for which he has
applied. For example, where an employee made an
application for a job which required its occupant
to be reliable and honest, and his prior
disciplinary record raised a reasonable doubt as
to his reliability, integrity, or responsibility,
28
it has been held that the employer could properly
consider and weigh such defects in character in
reaching its decision to deny the grievor the
job. By contrast, it has been regarded as
improper and unreasonable for an employer to rely
upon a disciplinary offence to deny an employee
a particular job where the nature of that offence
did not reflect on the employee=s ability to
perform the particular job, or where a
substantial period of time had elapsed since the
incident, during which the grievor had
demonstrated his reformation and rehabilitation.
Mr. Zachar testified that each incident of discipline was
to be Atreated on its own merits@, but did not explain what that
meant. According to the case law, discipline may only be
considered where it is relevant to the assessment of the
employee=s ability to perform the duties of the posted position.
The discipline in question must reasonably raise some concern
or doubt whether the employee has the ability to perform the
duties and responsibilities of the posted position. The mere
existence of any discipline, per se, would not be adequate to
disqualify an employee.
Thus in Re Miller, 348/82 (Samuels) at p.4, the Board
stated:
We do not agree with counsel for the grievor
when he suggests that the disciplinary record can
never be considered for purposes of promotion.
In our view, it all depends on the language of
the collective agreement concerning promotion.
In our case, the agreement requires that the
29
applicant be Aqualified to perform the job@. If
there are elements of the disciplinary record
which bear on the applicant=s qualifications to do
the job, then these elements can be considered.
The disciplinary record per se is not relevant,
but there may be matters in this record which do
assist the employer to judge the applicant=s
qualifications to do the job. This is the point
made in the case cited to us at the hearing by
counsel for the Liquor Control Board B The
Corporation of the Borough of Etobicoke and The
Borough of Etobicoke Civic Employees= Union, Local
185 (unreported dated October 23, 1981).
Moreover, even in the face of discipline which is
otherwise relevant, the employer must consider whether that
discipline has had a corrective effect on the employee, or
whether the employee is likely to demonstrate the same behaviour
in the future. For example, where an employee had been
disciplined two years earlier for failure to report to work on
time, but has had no punctuality problems since then, it is
indicative of the fact that the discipline has had the desired
corrective effect and that the employee is now rehabilitated.
In those circumstances, it is inappropriate to disqualify that
employee on the basis of his past incident of discipline, even
though punctuality is clearly relevant to the issue of
performance in any job. On the other hand, where an employee has
demonstrated a pattern of inappropriate conduct despite
discipline imposed, it would be reasonable to conclude that such
conduct may continue in the future and adversely affect
30
performance in the posted position. When reviewing past
discipline as part of a competition process, the purpose ought
not to be to reward for past good behaviour and penalize for past
misconduct, as Ms. Hoffman appeared to do. The only relevance
of discipline in this situation is whether or not that discipline
reasonably raises a concern about the individuals=s
qualifications and ability to do the posted job at the time of
the competition.
I have concluded for a number of reasons, that the
employer acted improperly in disqualifying grievors Patterson and
Velentzas. There is no evidence whatsoever before me to suggest
that Ms. Hoffman or the Regional Director, put their minds to the
issue of the relevance of the discipline to future performance
in the posted position, or to the issue of whether the two
grievors had been rehabilitated since the discipline. Ms.
Hoffman disqualified Mr. Patterson on the basis of an alleged
written reprimand in 1996 for an incident where the grievor had
mistaken a customer for a former shop-lifter. Prior to her
testifying, Mr. Patterson had denied that he received any
discipline for that incident. He testified that his manager
discussed the incident with him, but no discipline resulted. In
the face of this denial, it was incumbent on the employer to
31
produce evidence to establish that the discipline it had relied
on to disqualify Mr. Patterson in fact existed. This was not
done. Ms. Hoffman did not testify as to the source of her
information that the grievor had received a letter of reprimand
for that incident. No such letter was produced. Mr. Patterson
testified that the only discipline he had received was a written
warning in 1997 for directly accepting hours from another store.
There is no evidence that Ms. Hoffman was even aware of this
incident of discipline.
In any event, it was very clear form Ms. Hoffman=s
testimony that she did not put her mind to the issue of whether
Mr. Patterson or Mr. Velentzas had been rehabilitated or whether
they were likely in the future to exhibit the conduct that
resulted in the discipline. Her view was that as long as an
applicant had an incident of discipline within the 3 year period
recognized by the sunset clause, he was disqualified. This was
clear from her testimony with regard to Mr. Velentzas. She
agreed under cross-examination that he had otherwise been a good
employee, that his altercation was an isolated incident, and that
since that incident Mr. Velentzas had been discipline free for
over 2 years. However, she disqualified him because the
discipline was still less than 3 years old. She stated that the
problem with Mr. Velentzas had nothing to do with performance.
32
The problem was that he had discipline within the 3 year period.
That clearly indicates that she did not consider the issue of
rehabilitation and the relevance of the discipline to future
performance as an issue. As indicated by Re Miller, (supra) the
employer was not entitled to disqualify an applicant because of
discipline, unless that discipline reflected adversely on work
performance.
Ms. Hoffman=s approach is even more objectionable because
the chart set out above at pp. 21-23 indicates that some District
Managers did consider rehabilitation as a factor and allowed a
number of employees to compete despite the existence of
discipline within the 3 year period. For example, applicant
Linda Wisniewski had a written reprimand in July 1995 for an
altercation with another employee. District Manager Mike
Stephens recommended that the discipline be waived because Athe
employee has shown improvement@. Mr. Felora had a one day
suspension as well as a written reprimand within the 3 year
period. Yet Mr. Stephens recommended that he too be given an
interview because had had Ashown improvement@, Mr. Saliba had a
5 day suspension for a physical altercation as recently as
November 1996. His District Manager recommended that Mr. Saliba
be allowed to proceed in the competition because he had Aan
33
outstanding M.O.S.@. In each of these examples, the District
Managers= recommendations were accepted by the Regional Director.
There is no evidence as to what considerations went in to the
Regional Director=s decision to accept the recommendations
because he did not testify.
This evidence indicates that despite the employer=s goal
of having a consistent recruitment process, at least as far as
reviewing of past discipline was concerned there was no
consistency in this case.
Ms. Hoffman also considered a non-disciplinary discussion
she had with Mr. Patterson about cashiering procedures as a
factor in her recommendation that he be disqualified. According
to documentary evidence, as well as Mr. Zachar=s testimony, it is
clear that such non-disciplinary discussions did not form a
criterion in the screening process. There is no evidence that
other applicants were subjected to such scrutiny. That is yet
another example of inconsistency.
The evidence does not justify a conclusion that the
discipline of either Mr. Patterson or Mr. Velentzas brings into
question their ability to perform the duties and responsibilities
34
of a full-time CSR. With regard to Mr. Patterson, the employer
has not adduced any evidence to establish that the incident of
discipline it relied on even existed. The only discipline Mr.
Patterson had related to not following proper procedure for
obtaining hours from another store. Considering that there is
no evidence in Mr. Patterson=s appraisals or anywhere else, that
he habitually flouted procedures, it is not reasonable to
conclude that Mr. Patterson will not follow procedures in the
future. In any event, this discipline was not relied upon by the
employer. Mr. Velentzas had engaged in misconduct more than 2
years ago and had been punished. The fact that he had not
received any discipline whatsoever for over 2 years since then,
can only be seen as indicative that the discipline has had the
desired corrective effect on Mr. Velentzas. Certainly the
evidence does not justify a conclusion that Mr. Velentzas is
likely to repeat his misconduct.
Additionally, it is clear from the evidence that Ms.
Hoffman applied a much harsher standard on these 2 applicants
than the standards applied on other applicants by other District
Managers. Employees who had more serious incidents of discipline
than Mr. Patterson and Mr. Velentzas received interviews because
they had improved. These grievors did not receive that some
35
consideration from Ms. Hoffman. The employer is not entitled to
apply standards inconsistently. If the screening could not be
done centrally because the necessary information was not
available on file, the employer ought to have at least provided
some clear guidelines to the various District Managers on how the
screening was to be done. The failure to do that resulted in
some applicants being judged by lenient standards, while others
were subjected to harsher treatment. That is not acceptable in
a competition process.
For the foregoing reasons I find that the employer failed
to properly assess the qualifications and ability of Mr.
Patterson and Mr. Velentzas when they were denied interviews.
The appropriate remedy is set out later in this decision.
Alleged fundamental flaws in the competition.
In numerous decisions, this Board has reviewed the
obligations of an employer in assessing the qualifications and
ability of job applicants in the face of a relative equality
clause. Employer counsel questioned the relevance of prior GSB
decisions rendered under the OPSEU collective agreement, claiming
that Athe language was different@. However, she did not point to
any difference in substance and meaning, flowing from any
36
difference in language. I find that the present collective
agreement, like the OPSEU agreement, contains a relative equality
provision. The observations made by the Board in the OPSEU cases
were not peculiarly dependent on particular words in the OPSEU
provision. They are equally applicable to the relative equality
clause in article 31.4(b) of the LCBO agreement.
In Re Marek, 414/83 the Board observed as follows at p.5:
AIt is hard for this Board to understand how this
could occur, in view of the repeated direction
this Board has given on the need to consult
personnel files and candidates= supervisors,
particularly when one of the candidates only is
known to the interviewersCsee, for example,
MacLellan and DeGrandis, 506/81, 507/81, 690/81
and 691/81, wherein the jurisprudence is
summarized at page 25 and 26:
The jurisprudence of this board has
established various criteria by which to
judge a selection process:
1.Candidates must be evaluated on all the
relevant qualifications for the job as set
out in the Position Specification.
2.The various methods used to assess the
candidates should address these relevant
qualifications insofar as it is possible.
For example, interview questions and
evaluation forms should cover all the
qualifications.
3.Irrelevant factors should not be
considered.
37
4.All the members of a selection committee
should review the personnel files of all
the applicants.
5.The applicants= supervisors should be asked
for their evaluations of the applicants.
6.Information should be accumulated in a
systematic way concerning all the
applicants.
See Remark, 149/77; Quinn, 9/78; Hoffman, 22/79;
Ellsworth et al, 361/80; and Cross, 339/81.
In Leslie, 126/79, the primary basis on which
this Board ordered a new selection process was
the fact that the interviewers knew one of the
candidates, and had relied on the interviews
alone, without any recourse to the supervisors of
other candidates. Nor in, Leslie, had the
interviewers referred to the grievor=s personnel
file or performance appraisals. In our view,
this conduct alone fatally flaws the selection
process undertaken by the interview panel here.@
While the Board has repeatedly set out the foregoing as
a guideline for the proper conduct of a competition process, it
has not regarded the failure by the employer to comply with those
criteria by itself, as reason to quash the results of the
competition. Thus, in Re Saras, 457/85 (Swan), one of the
complaints of the union was that the selection panel had failed
to review the complete personnel files of the candidates. The
Board found that all candidates were permitted to fill out an
application form which provided space on two pages to describe
an applicant=s qualifications and employment history, and were
38
invited to submit any additional information on a separate sheet.
The grievor=s personnel file included information about some
temporary jobs the grievor had done which would have been of some
relevance. The committee=s failure to review personnel files
deprived it of this information. Yet the Board took into account
the fact that the grievor had the opportunity and had been
invited to set out his employment history in the detailed
application form. He had not mentioned the temporary jobs, which
he claimed would have assisted his candidacy. The Board
commented that the grievor must have not thought that the jobs
in question were sufficiently important to set out in the
application form. Noting that Ait is possible to pick holes in
almost any process run by mortal human beings@, the Board
dismissed the grievance, concluding as follows at p. 13:
In the result, while we may not be happy with
everything that happened in the course of the
selection, we have come to the conclusion that
the process as a whole was not unfair nor was it
calculated to lead to an incorrect result. We
have also concluded that, on a somewhat larger
body of evidence placed before us at the hearing,
and on an objective basis, Ms. Parisien was in
fact better qualified for the specific job at
issue than was the grievor.
In Re Falcioni, 2308/91 (Kaplan), the Board found that
AThe mistakes in this case are serious and disturbing, but we are
satisfied on the evidence before us that the selection committee
39
and the employer obtained the information it needed to choose
among the applicants and that the correct choice was ultimately
arrived at.@ The grievance was dismissed because A... none of
the mistakes is of such fundamental nature as to have
irreversibly tainted the result@.
In Re Laforest, 1983/87 (Roberts) the Board at p. 12
reviewed the list of McLennan and DeGrandis criteria, and
observed:
This Board has consistently held that failure
to consult personnel files and reports of
supervisors are significant flaws in the
selection procedure. Where the Board finds such
flaws to exist it generally invalidates the
competition in question.
Yet the Board has been prepared to overlook flaws in the
face of evidence that it did not prejudice the candidacy of the
grievor. Thus in Re Renton (Roberts), the selection committee
had failed to consult personnel files and reports of supervisors.
However, the evidence was that two of the three panel members
had directly supervised the grievors for a number of years, and
that they had briefed the third member completely and objectively
as to the qualifications and abilities reflected in the grievors=
personnel files. In the circumstances, the Board did not disturb
the results of the competition. In contrast in Re Laforest,
40
(supra) the Board found that the one member who briefed the other
3 panel members had only supervised the grievor for a few months
and that at a relatively low intensity level. There the Board
concluded that the failure to review personnel files and
supervisors reports raised great potential for prejudice.
In Re Wayne & Lowe (supra) the Board was critical of the
conduct of a panel which scored an interview process in the
following circumstances:
Once a consensus on scores was reached a list
of all competitors was drawn up with their scores
in all areas set out and totalled. It appears
that after this list was drawn up further changes
were made to various individuals= scores. Neither
of the two committee members who gave evidence at
the hearing was quite sure when the changes were
made.
In Re Wright/Wasky, 1832-33/91 (Watters) at pp. 41-42 the
Board wrote:
The Board has consistently determined that
this task cannot be properly or adequately
performed on the basis of just an oral interview.
It has required that a broader base of
information be assessed for purposes of complying
with the contractual direction contained within
article 4.3. This has included resort to
personnel files, particularly the performance
appraisals contained therein, and supervisory
comments. An example of where this approach was
employed is the award in Palatino, Ragos,
Patterson. The majority of the Board there
stated as follows:
41
A...We also find, however, that the
employer in this case relied too heavily
on the interview results. The authorities
are extremely clear that the employer must
not rely solely on interviews in job
posting cases. At the very least the
employer must also conduct reference
checks of all candidates with immediate
supervisors and review all applicants=
personnel files ...., if the employer
relies solely on the interview for making
an assessment of candidates it does so at
its peril.@
(Page 45)
It is clear to this Board that the panel in
this instance relied excessively on the scores
generated through the interview process. In the
case of Mr. Wasky, they did not conduct a
reference check nor review his performance
appraisals, as contained in the personnel files.
Ms. Inkster agreed that in assessing his related
experience, she relied exclusively on the
information he presented at the interview.
Similarly, Mr. Van Sickle appeared to make a
conscious decision to disregard knowledge that he
had pertaining to Mr. Wasky=s past experience.
Both panellists were of the view that it was
incumbent on all applicants to demonstrate their
experience, skills and qualifications through
their answers to the questions posed at the
interview. We have no doubt given the panel=s
failure to review other sources of relevant
information, that Mr. Wasky was effectively
excluded from further consideration solely
because of the interview scoring.
In Re Poole (1988) 2508/87, the vacancy had been awarded
solely on the basis of interview scores. The Board noted at p.4:
There must be a full gathering of information
concerning the qualifications and ability of the
applicants. It is simply not satisfactory to
42
conscientiously ignore information as was done
here. For some reason, the grievor did not do
well at the interview (we have a great deal of
difficulty understanding this and we will have
something to say about this in a moment). The
three members of the panel were left with the
impression that the successful candidate had
better qualifications and experience than the
grievor, but a look at their application forms
would have confirmed that the grievor was a
senior nurse with much experience in the very
matter which was to be taught to the 800 staff
members at the hospital, while the successful
candidate had just graduated from nursing school,
and had no experience whatso -ever in this area.
In our view, the decision of the panel was
simply perverse and this resulted from its
profoundly flawed procedure.
At p. 7 the Board concluded:
In summary, we find that the selection process
was entirely inadequate. The ultimate total
reliance on the interview as an information-
gathering and scoring tool resulted in an
assessment of the relative merits of the
candidates which had no real basis in fact. In
particular, the panel failed utterly to see the
grievor as she was, in spite of the fact that the
information was in its hands or readily
available.
DECISION
The process followed in this competition was very
different from many aspects from the typical competition. The
three person panel is not properly described as a Aselection@
panel. All of its members were emphatic during their testimony
that their sole responsibility was to interview and score the
43
candidates in accordance with Athe process@. Once the score
sheet was handed in, they had no further involvement in any other
aspect of the competition process. Indeed, there was no person
or persons who admitted to responsibility for actually selecting
the successful candidates. One of the panel members best
described the situation, when he was asked whether he was
involved in the selection of who gets the jobs. He replied ANo
one selected them. The process itself decided it@. The scoring
of the 2 appraisals was performed by human resources staff almost
as a clerical function, by applying a matrix to obtain scores to
the two performance appraisals. The fact that the process was
unusual is not by itself objectionable. The issue is whether it
resulted in proper consideration being given to all of the
relevant information available in assessing qualifications and
ability as contemplated by article 31.4(b). After a careful
review of the evidence I have concluded that as a result of the
cumulative effect of many deficiencies, the whole process was
fundamentally flawed so that its results cannot be accepted.
The Board has repeatedly held that reliance solely on
interview results is not acceptable as a means of assessing
qualifications and ability. The employer here did not do that,
but clearly over-valued the interview scores to the exclusion of
44
other relevant and more reliable information. The employer gave
consideration to attendance and discipline, but only for purposes
of the initial screening. Once applicants got beyond that
hurdle, apart from the interview scores, the only other
information considered was that contained in two appraisals. No
resumes were reviewed. Complete personnel files were not
considered. Supervisors were not contacted. Particularly
considering that all of the applicants had performed for
considerable periods in part-time CSR positions which had
substantially similar duties, the reliance on a one half hour
interview to the exclusion of other information, is unacceptable.
The grievors testified about the extra duties they had
performed in their part-time CSR positions, including in some
cases the running of shifts. This not only demonstrates
experience, but also the level of confidence the supervisors
exhibited in their ability and reliability. They had performance
appraisals which were satisfactory or better overall. When such
senior employees performed poorly on a one half hour interview,
it was not reasonable for the employer to simply accept the
scores as representative of the qualifications and ability of the
employees without consulting with the supervisors. The
supervisors have had first hand knowledge about the level of
45
performance of the employees. Their information is at least as
reliable, if not more reliable, than interview score. Mr. Zachar
took the position that resumes were not reviewed out of a concern
that it would give an unfair advantage to individuals who were
more skilled in writing a good resume. One cannot help but
wonder why the employer did not have a similar concern that
individuals who were good performers at interviews in an
atmosphere of pressure would have an unfair advantage, over
others who were competent workers but not good performers at
interviews.
If the employer did not wish to review resumes, it had
the obligation to obtain the information that would have been
contained in a resume in some other manner. Unlike in Re Saras
(supra), here the employer did not give the applicants an
opportunity to set out their experience, employment history or
any other relevant information such as letters of commendation,
in the application form. The applicants were required to use the
Q-35 form and it had space only for the most routine information.
The argument that experience was indirectly considered because
the applicants with more experience will be better able to answer
the interview questions is without merit. Experience is a matter
of fact, quite apart from an employees ability use that
46
experience to answer a question under the stressful conditions
of an interview. On the basis of the evidence I find that
experience received no consideration at all in the process.
There is no suggestion of anything sinister. However,
some of the evidence about the tabulation of scores is
troublesome. There were discrepancies in the scores entered for
the same applicant in different documents. No one could explain
why the same applicant had one mark in the initial recording and
a different score in the final document. Without going into any
detail, I note that on the interview sheets for many applicants
filled in by some panel members, a total mark had initially been
entered in pencil, then erased and a different mark written over.
The erased marks corresponded to the marks entered in another
document which was not used for the awarding of positions. This
clearly suggests that the interview sheets filled in and scored
by the 3 panel members were at some point totalled and an average
obtained by dividing by 3. The resulting score had then been
entered on a score sheet recording scores for all applicants.
Then someone had gone back and altered the scores on the
individual score sheets and the procedure was repeated, resulting
in a different average score. It was this latter score which was
used ultimately in the awarding of positions.
47
No one testified to explain why and how this process of
changing marks was carried out. Ms. Shelly McIntyre, one of the
panellists, admitted that she would have been the one who did the
erasure and the changes, but she had absolutely no recall of the
circumstances which led her to do so. The interview was an
extremely critical, if not determinative part, of the competition
process. It is imperative that the employer explain the process
it followed to arrive at interview scores. No assumptions can
be made that there was some sinister activity going on, from the
mere fact that Ms. McIntyre could not recall when, why or how she
changed the marks. After all, she was testifying several years
after the event. However, in a matter so critical to employee
rights under the collective agreement, it is to be reasonably
expected that the employer would keep a record of the process it
followed step by step, particularly where unusual steps are taken
such as erasing and substituting marks. By not doing so, it
invites suspicion, and challenges to the reliability of the marks
used. The employer should know that it would be obliged to
explain the process followed, in the event a grievance is filed.
It is imprudent, to say the least, for an employer to put itself
in a position where at arbitration it cannot explain how and why
marks happened to be changed.
48
The Board has considerable concern not only about the
failure by the employer to consider information other than the
2 most recent appraisals, but also about the manner in which it
considered those 2 appraisals. As the Board did in Re Netta et
al (supra) I find that the straight mathematical conversion of
appraisals, while simpler and easier to apply, failed to reflect
the true content and opinion expressed therein by the appraising
supervisor. The problem was compounded by the decision of the
employer to focus solely on the ratings for individual areas of
competency, and ignore the overall rating as well as positive
assessments in the comments section.
Through its failure to comply with its own policy of
carrying out annual performance appraisals, the employer found
itself in a position where it was not in a position to evaluate
the appraisals for the same period for all of the applicants.
However, it was in a position to compensate for that
disadvantage, by canvassing supervisors to satisfy itself that
the available appraisals were representative of the employee=s
qualifications and ability, and not an aberration from the usual
standards. The way the employer did it, the review of appraisals
became a matter of luck of the draw. For example, the 1995
49
appraisal that was reviewed for Mr. Patterson contained a less
than satisfactory rating for attendance and punctuality. This
was held against him in screening him out of the competition.
If a 1995 appraisal had not been done for him (some employees
had no appraisals done since 1992 or 1993) the employer would
have used his next previous appraisal, i.e. the 1994 appraisal
in contrast to the 1995 appraisal, the 1994 appraisal had an
excellent rating for attendance and punctuality. He lost out
because he happened to have a 1995 appraisal done.
Mr. Patterson=s case also illustrates another problem
with the employer=s process. Had the employer reviewed the
complete personnel file, it would have discovered that Mr.
Patterson=s attendance and punctuality dramatically changed
between 1994 to 1995. Remembering that the only relevant issue
is the likelihood of Mr. Patterson attending work regularly and
punctually in 1997 and thereafter, the question must necessary
arise whether or not his problems in 1995 were caused by some
particular reason such as an illness or some other personal
problem, and if so, whether such impediment still existed. To
answer this question the employer could have consulted Mr.
Patterson=s past supervisors, or Mr. Patterson himself could have
been asked for an explanation. Neither was done. Instead,
50
because the appraisal that happened to be reviewed had a negative
rating, he was screened out without any further inquiry.
A further flaw is apparent in the manner the employer
assessed the relative equality of the applicants. The Board has
no concerns about the 20 percent spread used for relative
equality. However, the problem is that the employer compared
applicants to the top score of 95 for each of the 37 vacancies.
When the top scorer is awarded a position, he is no longer
competing for the remaining vacancies. The comparison then must
be between the highest scorer among those not yet awarded a
position, and applicants who were senior to him. Indeed Mr.
Zachar testified that this was exactly what was contemplated by
the employer=s own policy. It is beyond doubt that in this
particular competition the employer erred and failed to follow
its own policy, resulting in an inappropriate consideration of
relative equality.
The Board does not doubt that the employer was making an
honest and legitimate effort to come up with a consistent and
administratively simple recruitment process. Subject to any
estoppel arguments the union may elect to make in future cases,
the employer was entitled to devise a new process, but only on
condition that it met its obligations under the collective
51
agreement. In view of the many defects the Board has found, and
the cumulative effect of those defects, the Board cannot agree
with employer counsel that despite these defects the results of
the competition should be allowed to stand. In all of the
circumstances, the process followed by the employer as part of
its obligation under article 31.4(b) to evaluate the relative
qualifications and ability of the applicants was inadequate, in
that it failed to elicit in a systematic fashion sufficient
information to permit a fair and reliable judgement about the
applicants. Therefore the results of this flawed process cannot
be allowed to stand.
The Board concludes as follows:
(A) The board allows the grievances of Mr. Patterson and
Mr. Velentzas in that it finds that the employer did not assess
their qualifications and ability in compliance with article
31.4(b) when they were denied interviews. The Board finds that
they were qualified and were entitled to participate fully.
(B) The Board allows the grievances of Mr. Everest, Mr.
Felora, Mr. MacKay and Mr. Sam to the extent that the competition
which resulted in their not being awarded positions was so
fundamentally flawed, that its results are not reliable.
52
Remedy
The union accepted that if the grievances are allowed on
the basis of fundamental flaws in the competition process, the
appropriate remedy is to order a re-run of the competition. The
employer also did not disagree with that. However, the parties
were in disagreement as to who should be allowed to participate
in the competition to be re-run. The union took the position
that the new competition should be restricted to the grievors and
the 37 successful candidates (incumbents) who were made parties
to this proceeding. The employer on the other hand submits that
all of the applicants who were found to be qualified to be
interviewed, including those who did not grieve, should be
allowed to participate in the re-run competition. Employer
counsel pointed out that in Re Netta (supra) the Board did not
restrict the competition ordered to be re-run to the grievors and
incumbents.
The Re Netta decision does not include any discussion
about who should be allowed to participate in the re-run
competition. The Board merely orders that AThe appropriate
remedy in the circumstances is to require the LCBO to re-run the
competition@. Thus it appears that the issue of the extent of
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participation was not raised in that case. Among the many GSB
decisions submitted to me, I have found some decisions which
restrict the re-run competition to the grievor(s) and the
incumbent(s), and others which place no such limitation.
However, none of those decisions contain any reasoning for the
order, suggesting that the issue was not argued before the Board.
In the present case the issue has been squarely put before me
and I must deal with it.
All of the applicants participated in the competition in
question. Of those unsuccessful, only some grieved that their
rights had been infringed. The others, the non-grievors, have
not asserted that their rights have been in any way infringed.
Nor has the union made such a claim on their behalf, by filing
a union grievance. In those circumstances the Board is of the
view that the remedy rendered in order to address these 6
individual grievances should not extend any rights or benefits
to those who did not grieve.
In Re Zuibrycki, 100/76 (Pritchard), affirmed R v.
O.P.S.E. et al, (1982) 35 O.R. (2nd) 670 (Ont. Div. Ct.), the
Board remedied a flawed competition by ordering the appointment
of the grievor to the vacancy. In that case the employer had
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argued that the Board should not award the position to the
grievor because there were other applicants who had not grieved,
but were also relatively equal and had more seniority than the
grievor. The Board rejected that reasoning. While the factual
basis in that case was different in that the Board there was
considering the appointment of the grievor, and not ordering of
a re-run, its observations are instructive, and in my view
equally applicable to the circumstances here. Thus it stated:
Turning to the particular facts of the case
before us, it must be remembered that the earlier
panel of the Board found that the grievor
possessed ability and skills at least equal to
all of the candidates in each competition. In
the result, he should have prevailed over [the
successful applicants], each of whom had less
seniority than the grievor.
There were other candidates more senior than
the grievor who, on the Board=s findings, were
relatively equal in ability and skills and who
therefore would have been entitled to prevail
over the grievor if they had grieved and if the
same findings of fact had been made. However,
they did not grieve and have not grieved to this
date. They therefore have forfeited any claim
they may otherwise have had to the positions. It
is widely accepted in labour relations that those
with a grievance should raise the matter in a
timely fashion so as to allow the parties to the
collective agreement to assess the situation and
respond appropriately. In particular, if the
other candidates had grieved, the grievor=s case
and the employer=s case may well have been
different. However, by not grieving the other
candidates are now foreclosed from claiming (or
having claimed for them by the employer) any
rights in this arbitration.
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See also, Re Harris-Bernard 97/94 (Roberts) and Re
Frisken, 2034/94 (Gray)which follow the same approach.
In consideration of all of the foregoing the Board orders
as follows:
(a) The employer shall re-run the competition restricted
to the six grievors and the incumbents, in accordance with the
requirements of the collective agreement and the findings in this
decision.
(b) To the extent it is possible, the employer shall
disregard the experience and knowledge acquired by the incumbents
as a result of performing in the posted position following the
first competition.
(c) If any of the grievors are successful in the
competition re-run, the employer shall compensate them for their
losses, calculated on the basis that they were entitled to have
been appointed on the day the appointments were made following
the first competition.
The Board retains jurisdiction to resolve any
disagreements the parties may have in the implementation of this
decision.
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Dated this 24th day of February 2000 at Hamilton, Ontario
Nimal V. Dissanayake, Vice-Chair