HomeMy WebLinkAbout2005-3601.Sin.07-04-24 DecisionCrown Employees
Grievance Settlement
Board
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180 Dundas St. West
Toronto, Ontario M5G 1Z8
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Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB# 2005-3601
UNION# OLB001/06
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Sin) Union
- and -
The Crown in Right of Ontario
(Liquor Control Board of Ontario) Employer
BEFORE Nimal V. Dissanayake Vice-Chair
FOR THE UNION Laurie Kent
Koskie Minsky LLP
Barristers and Solicitors
FOR THE EMPLOYER Alison Renton
Counsel
Liquor Control Board of Ontario
HEARING April 17, 2007.
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Decision
The grievor, Mr. Lawrence Sin, is a casual employee employed by the employer. He has
filed a grievance with respect to a job posting for the position of Product Consultant, for which
he had applied unsuccessfully. That grievance came before the Board for hearing on April 17,
2007.
At the commencement of the hearing, the parties raised an issue that had arisen between
them. The employer noted that the grievance alleges a violation of article 31.4(b) of the
collective agreement, which provides:
The Employer agrees to give consideration to the qualifications and ability of casuals
for permanent full-time vacancies at the entry level in their geographic area, provided
that no permanent part-time employees have applied. Where qualifications and
ability are relatively equal, seniority shall be the determining factor.
The employer had given notice to the union that it would be making a motion to the
effect that the Board lacked jurisdiction to deal with the grievance. Employer counsel pointed
out that article 31.4(b) requires the employer to give consideration to the qualifications and
ability of casuals only with respect to permanent full-time vacancies “at the entry level”. The
vacancy which forms the subject of the grievance filed by the grievor, the position of Product
Consultant, is not an entry level position. It is a higher ranked position with a higher rate of pay
than the entry-level position in the stores system, which is the position of Customer Service
Representative. On that basis employer counsel was proposing to move that the Board decline to
hear the grievance.
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The union disputed the employer’s position that article 31.4(b) had no application to the
circumstances of the instant grievance. However, besides opposing the employer’s motion on its
merits, union counsel took the position that in any event the employer was not entitled to take
this position for the first time at arbitration. The union asserted that the employer is estopped
from taking such a position. Secondly, the union took the position that the employer had waived
any right it had to object to the arbitrability of the grievance by proceeding through the grievance
procedure without any objection. It was pointed out that the objection was first raised after the
grievance had been referred to arbitration and the hearing scheduled.
The parties requested that the Board initially hear and determine the waiver issue. While
there appears to be several issues in dispute between the parties, including the issue of whether
article 31.4(b) has application to the facts of this case, whether the employer is estopped from
claiming that it has no application, and whether the employer acted in a manner that was
arbitrary, discriminatory or in bad faith, even if article 31.4(b) had no application, this award
deals solely with the issue of whether the employer is precluded from making the proposed
motion by the operation of the doctrine of waiver.
Union counsel cited the following authorities. Re Regency Towers Hotel Ltd., (1973) 4
L.A.C. (2d) 440 (Schiff); Re Falconbridge Ltd., (2002) 112 L.A.C. (4th) 243 (Shime); Re
Municipality of Metropolitan Toronto, (1995) 49 L.A.C. (4th ) 289 (Tacon) and Re Campbell and
Stephenson et al, (1984) 44 O.R. (2d)656 (Ont. Div.Ct.).
Employer counsel relied on the following authorities. Re Bell G.S.B. 683/01
(Dissanayake); Re Atomic Energy of Canada Ltd., (1994) 41 L.A.C. (4th) 310 (Knopf); Re
Children’s Aid Society of Toronto, (2002) 111 L.A.C. (4th) 43 (Devlin); Re Ontario Power
4
Generation and Society of Energy Professionals, (2004) 137 L.A.C. (4th) 44 (Goodfellow), and
Re Hawker Siddeley Canada Inc. (1991) 21 L.A.C. (4th) 289 (Joyce).
Relying on the authorities listed above, union counsel submitted that the grievance
procedure set out in the collective agreement is intended to provide an opportunity for the parties
to discuss, and if possible resolve, all issues relating to the grievance. The parties here did not
get that opportunity because the employer did not raise the issue it now raises, that article 31.4(b)
has no application to the grievance, at any time during the grievance procedure.
The employer’s response is that only procedural defects may be waived. Counsel
submitted that substantive rights and jurisdictional objections are not subject to the doctrine of
waiver. Counsel stated that it was unfortunate that the objection was not identified and raised
earlier. However, she submitted that since the objection is not based on a procedural defect, the
employer was entitled to raise it at any time.
Union counsel did not dispute the proposition that a jurisdictional objection is not subject
to waiver. That proposition is well established. For example, in Re Atomic Energy of Canada
(supra), at p. 319 the Board wrote, “The late raising of this jurisdictional objection is unfortunate.
But a jurisdictional defect cannot be waived. It can be raised at any time because of the
fundamental importance of the issue.” However, union counsel argued that the objection raised
here did not directly go to the Board’s jurisdiction, but was rather a matter of a dispute between
the parties on the proper interpretation of article 31.4 (b).
I agree that the objection raised by the employer is not properly characterized as a
“jurisdictional” objection. Nevertheless, in my view, the objection raised by the employer is not
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subject to waiver. Article 31.4(b) confers a substantive right on casual employees to have their
qualifications and ability considered in job competitions in certain circumstances. The
employer’s proposed motion is to the effect that in this particular grievor’s circumstances, he is
not entitled to that substantive right. The objection is about the grievor’s entitlement to rely on
the rights conferred by article 31.4(b). In those circumstances, the employer cannot waive its
right to argue that the grievor is not entitled to the substantive rights under article 31.4(b) in his
particular circumstances. The objection is not based on a procedural defect, but on the grounds
that the grievor does not meet the pre-requisites for entitlement to substantive rights set out in
article 31.4(b). As I held in Re Bell (supra), substantive rights are not subject to the doctrine of
waiver. While union counsel is correct that the substantive right under article 31.4(b) is that of
the grievor, and not of the employer, that does not change the result. The employer is not subject
to waiver because of its delay in taking the position that the grievor does not meet the
prerequisites to claim the substantive rights conferred by the provision.
In the result, I find that the doctrine of waiver does not preclude the employer from
proceeding with its motion.
I remain seized with jurisdiction to deal with all outstanding issues relating to the instant
grievance.
Dated this 24th day of April 2007 at Toronto, Ontario.
Nimal Dissanayake
Vice-Chairperson