HomeMy WebLinkAbout2005-3631.Policy.06-07-24 DecisionCrown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
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# 2005-3631, 2005-3632, 2005-3633, 2005-3634, 2005-3635, 2005-3636
UNION# 06-11, 06-12, 06-13, 06-14, 06-15, 06-16
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Canadian Union of Public Employees - Local 1750
(Policy Grievance) Union
- and -
The Crown in Right of Ontario
(Workplace Safety and Insurance Board) Employer
BEFORE Marilyn A. Nairn Vice-Chair
FOR THE UNION Steven M. Barrett
Sack Goldblatt Mitchell LLP
Barristers and Solicitors
FOR THE EMPLOYER Gurjit Brar
Counsel
Workplace Safety and Insurance Board
HEARING June 26, 2006.
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Decision
Each of these six grievances relates to the evaluation of certain benchmark jobs for
purposes of updating the parties’ job evaluation system while maintaining pay equity. The parties
have bargained an extensive and complex job evaluation system. A feature of that process is the
valuation or rating of thirty-two benchmark positions from which the larger job evaluation is
then conducted. Each job is assessed against pre-determined factors. The parties have engaged
that process, but in the course of so doing have been unable to agree to the final valuation of six
of thirty-two benchmark positions. The union, in filing the grievances, seeks to have the Board
resolve the valuation of the disputed sub-factor(s) in each case.
The employer has raised a preliminary objection to the jurisdiction of the Grievance
Settlement Board (the “Board”) to hear and determine the matters. It is the employer’s position
that these grievances are, in substance, classification grievances over which the Board has no
jurisdiction as a result of section 51 of the Crown Employees Collective Bargaining Act
(“CECBA”). The union disagrees with that characterization of the issue and asserts that the
Board has jurisdiction to proceed. The preliminary objection is the same in respect of the six
grievances and they were heard together. The parties provided me with an agreed statement of
fact set out below. The job evaluation manual referred to in paragraph 18 of that statement of fact
was attached as an appendix but is not reproduced here.
The agreed statement of fact provides:
1. The Employer is a statutory corporation continued under the Workplace Safety and
Insurance Act, 1997 (the “Act”). It is responsible for administering the Act and
claims for benefits filed by injured workers in Ontario. It employs approximately
4400 employees, a majority of whom are represented by the Union as exclusive
bargaining agent.
2. The Employer is an agency of the Crown for the purposes of the Crown Employees
Collective Bargaining Act.
3. The Employer and Union are parties to a collective agreement (the “Agreement”)
which took effect April 1, 2005 and expires on March 31, 2008.
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4. All jobs covered by the Agreement are classified according to a salary grade or level.
They will also have an appropriate job title and job description.
5. The Agreement contains a “Job Listing” that sets out the jobs covered and their
associated salary grade. The salary grades begin at 815 and end at 890. The
Agreement does provide for two additional salary grades (805 & 810), however, at
present, no jobs are included therein.
II. JOB EVALUATION SYSTEM
6. In or about 1997 or 1998, the parties established and implemented a Job Evaluation
System (JES). Currently, it is enshrined in Article 18 of the Agreement.
7. The JES includes the job description process, job evaluation process, the maintenance
process, communication of results and dispute resolution.
A) Job Descriptions
8. Job descriptions document the nature and level of the work required in a particular
job. They include a short summary outlining the purpose of the job and a list of the
major duties, responsibilities and job requirements.
9. Job descriptions are written or reviewed when:
a) a new job is created;
b) when the duties and responsibilities have changed due to the introduction of
new technology, legislative requirements or restructuring in the organization
c) as part of regular maintenance.
10. New jobs are to be reviewed within 12 months of their creation to confirm the
accuracy of the job description, unless otherwise agreed to by the parties.
11. Since approximately 2002, responsibility for the content of job descriptions was given
to management and employees so they could be given a more active role in the
process and to ensure greater confidence in the fairness of job evaluation.
12. The Employer, through its management, is responsible for collecting job information,
reviewing and writing (or re-writing) job descriptions. The job descriptions are
validated by incumbents and management.
13. If an employee does not agree with the contents of their job description, a meeting is
held between the employee, manager, Union representative and Employer
representative to facilitate resolution. In the event that resolution is not possible,
management has the final accountability for the job content. The revised job
description is referred to the Joint Job Evaluation Committee (the “Committee”) for
evaluation.
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B) Maintenance
14. The Employer is responsible for regularly reviewing a job in accordance with the
prescribed timeframes (e.g. for maintenance or new jobs) to determine if the required
job duties and responsibilities have changed.
15. The Employer is responsible for ensuring that job descriptions accurately reflect the
required duties and responsibilities.
16. The Employer is required to review all jobs every four (4) years and submit the
results to the Committee for evaluation where required.
17. The Committee is provided with job descriptions that require a review within the
twelve (12) months and four (4) year intervals.
C) Job Evaluation
18. The Committee evaluates all bargaining unit jobs using the Job Evaluation Plan
(“JEP”) which is embodied in the document titled “Joint Job Evaluation Committee:
Evaluation Manual – Factors & Subfactors” attached as Appendix “A”.
19. The Committee is comprised of three Employer and three Union representatives. The
parties also appoint three alternative members each. A quorum for Committee
meetings is two members from each party.
20. The JEP; the Point Band Model Structure; Factor and Sub-Factor Weights, and a job
description are used for job evaluation.
21. Job evaluation is the process the parties have agreed to for measuring the relative value of
jobs.
22. This process uses the factors of skill, responsibility, effort and working conditions,
which are further subdivided into 18 sub-factors, as they are defined in the JEP.
23. The purposes of the job evaluation are:
measure the nature and level of the work.
group jobs having relatively equivalent point values into point bands.
assign point bands into pay grades in the salary schedule.
provide the basis upon which wage rates are negotiated.
24. When applying the JEP, the following rules apply:
The nature and level of work is evaluated,
The performance of an employee is not considered as part of the evaluation,
Jobs are evaluated without regard to existing wage rates,
Jobs are evaluated based on the level of skill, responsibility, effort and working
conditions required, and
The evaluation of each job is to be relative to, and consistent with, all other jobs
evaluated under the plan.
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25. Job evaluation is the responsibility of the Committee. The Committee reviews all
new and revised job descriptions. The Committee then meets to evaluate the
new/revised job description. After the meeting, the evaluation results are
communicated in writing to the line Manager who then advises the job incumbent(s)
of the result, in writing
D) Job Evaluation Plan
26. The JEP measures the factors of skill, responsibility, effort and working conditions.
Each of these factors are measured through the evaluation of sub-factors.
27. The sub-factors are as follows:
Factor Sub-Factor
Skill Job Knowledge
Regulatory Knowledge
Interpersonal Skills
Contacts
Communication Skills
Co-ordination and Dexterity
Responsibility Choice of Action
Independence of Action
Impact of Action
Planning/Organizing
Assistance to Others
Physical Resources
Information Resources
Effort Physical Demand
Sensory Demand
Working Conditions Environment
Hazards
Other work demands
28. Each sub-factor is given a corresponding numerical or alphanumerical rating level
which is used to evaluate the extent to which a particular sub-factor is utilized in a
job.
29. The factors and sub-factors are given pro-rated weightings as outlined in the
Exponential Point Plan.
30. Each sub-factor rating level is scored on a points system. The points increase in value
correlating with an increase in the rating level of a sub-factor. For example, a rating
of 1A for the sub-factor “Job Knowledge” equates to 34 points and a rating of 1B
equates to 38 points.
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31. When the Committee reaches consensus on the sub-factor rating levels for a particular
job, the points for all the sub-factors are added together producing an overall score for
the job.
32. The total score corresponds with the classification of the job on the “Point Band
Model Structure” which, in turn, determines the salary grade for the job. The total
score helps to establish the value of a job in comparison to other positions.
E) Dispute Resolution
33. Incumbents who disagree with the evaluation results may ask for reconsideration
within thirty (30) working days from the date of written notification of the decision,
unless otherwise agreed. This may only happen once and must be done in writing.
34. The reconsideration is to be heard within sixty (60) working days from the date of
submission to the Committee.
35. If the Committee is unable to reach consensus, the parties must designate one
representative to join the Committee to discuss the matter (the “Larger Committee”).
The Larger Committee attempts to achieve consensus, however, if there is only one
dissenting vote, the matter is taken as agreed. The decision of the Larger Committee
is final and binding.
36. If the Larger Committee is unable to reach an agreement, the Union is given the right
to apply to the Grievance Settlement Board (“GSB”).
37. If a decision is reached and the job(s) is reclassified to a higher pay scale, the parties
apply the rules for salary adjustment set out in Schedule “A” to the Collective
Agreement. The effective date of the reclassification is the date the Manager and
employee agree that the change in job duties occurred. If agreement cannot be
reached, the effective date is 20 days before the date the submission for review was
submitted in writing.
38. If the job(s) is not significantly changed but is reclassified to a lower salary grade, the
only the income protection provision in Article 6.07 of the Collective Agreement
applies.
III. PRESENT DISPUTE
39. In or about 2001, the Employer retained an external consultant to review the
bargaining unit job evaluation process. The purpose of the review was to streamline
all the processes associated with the Joint Job Evaluation Program. Representatives
from both the Employer and the Union were involved in this review.
40. In or about early 2002, recommendations were presented by the consultant. The
majority of these recommendations were accepted including:
• to review and, if necessary, revise the list of benchmark jobs which was originally
established in 1994. The review was done to ensure that the existing benchmark jobs
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were still stable and that they represented the level and variety of work performed by
the bargaining unit.
• management review of job descriptions for accuracy and updating of content if
required. This review and update was to be validated with job incumbents to solicit
their input and hopefully their agreement on the revised content.
• following the review and validation process, the revised job description was then to
be reviewed and re-evaluated, if required, by the Joint Job Evaluation Committee
(JJEC).
41. The list of benchmark jobs was reviewed and updated by the Employer and Union
representatives of the Committee. The Committee then asked management
responsible for the benchmark job descriptions to review, update and validate the
documents as per the recommendations.
42. The revised job descriptions were submitted by management beginning in or about
late 2003 and continued through until September 2005. Thirty-two (32) benchmark
jobs were reviewed.
Evaluation Process
43. When evaluation of the 32 benchmark jobs began, each member of the Committee
was provided with a copy of both the job description existing at the time along with
the associated rationale statement as well as the revised job description.
44. Each member of the Committee reviewed the job description and assigned a
preliminary rating level in each of the 18 sub-factors using the information provided
in the job description and applying the description of the levels in the plan.
45. The Committee members also took into consideration the previous evaluation of the
job and the previous application or usage patterns of the sub-factors, as evident by
previously agreed to evaluation of other bargaining unit jobs (i.e. comparing ratings
from other jobs).
46. For example, in the case of the Field Auditor job, the Committee considered rating
levels for the Regulatory Knowledge sub-factor in other jobs such as Adjudicator,
Employer Account Advisor, QI Specialist, and Workwell Evaluator. These rating
levels were used for comparison purposes to assist in determining what level should
properly be applied to the Field Auditor job.
47. Each member then shared their individual ratings in each sub-factor.
48. If the Committee required clarification/elaboration on aspects of the job, the Manager
of the job could be asked to provide further information.
49. The Committee also relied on other resources to obtain further information to assist
with evaluation. For example, in the case of the Field Auditor job, the Committee
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requested written submissions from employees and Field Supervisors in response to
specific questions.
50. The Committee discussed the ratings for each sub-factor based on the information
provided until consensus on each sub-factor was achieved. In those jobs where
consensus could not be reached, the Committee held numerous discussions to hear
and consider the Union and Employer positions.
51. The evaluation of all the benchmark jobs were then “sore thumbed”, i.e. compared
factor by factor, to ensure that the plan had been applied consistently across jobs.
52. A “Job Evaluation Rationale” was prepared which documented the Committee’s
rationale for the rating in each of the sub-factors for each job evaluated.
53. Each sub-factor rating level has a set number of points associated with it. Once
consensus was achieved for a particular job, these points were added together to
produce a total score for the job. For example, consensus was reached for the
position of Accounts Payable Payment Processor which received a total of 474
points.
54. The total number of points for a given job falls into a point band which is represented
by a salary grade. This salary grade was assigned to the job. In the example of the
Accounts Payable Payment Processor, the total number of points represented salary
grade 830. This was an increase from its previous salary grade of 825.
55. Of the 32 benchmark jobs evaluated by the Committee, consensus was not achieved
in six (6) jobs. These jobs were then referred to what is known as the Larger
Committee which is created by the addition of one Employer and one Union
representative to the original job evaluation Committee.
56. The Larger Committee met on approximately 2 to 3 occasions to review the areas of
disagreement concerning the six non-consensus jobs and to attempt to achieve
consensus. The two additional members were provided with all of the information
considered by the Committee along with the respective positions of the Employer and
Union representatives. The Larger Committee was unable to reach consensus.
57. The present grievances arise from the failure of the Larger Committee to reach
consensus on the application of various combinations of the following sub-factors to
the six jobs: Regulatory Knowledge, Human Relations Skills, Choice of Action, and
Independence of Action.
58. The dispute is summarized as follows:
A. Field Auditor
Disputed sub-factor: Regulatory Knowledge
Union’s position: sub-factor should be rated at Level F (240 points)
Total points for job should be 1376
Point Band Model classification range – 1301 to 1501
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Salary grade 870
Employer’s position: sub-factor should be rated at Level E (160 points)
Total points for job – 1296
PBM range - 1133 to 1300
Salary grade 865
B. Ergonomist
Disputed sub-factor: Independence of Action
Union’s position: sub-factor should be rated at Level E (200 points)
Total points for job – 1367
PBM range 1301 to 1501
Salary grade 870
Employer’s position: sub-factor should be rated at Level D (112 points)
Total points for job – 1279
PBM range 1133 to 1300
Salary grade 865
C. Adjudicator
Disputed sub-factors: Human relations, Choice of Action
Union’s position: Level G, E (140, 200 points)
Total points for job – 1603
PBM range 1502 to 1733
Salary grade – 875
Employer’s position: Level F, D (95, 112 points)
Total points for job – 1453
PBM range 1301 to 1501
Salary grade – 870
D. Appeals Resolution Officer
Disputed sub-factor: Choice of Action
Union’s position: sub-factor should be rated at Level F (350 points)
Total points for job – 2310
PBM range – 2302 to 2660
Salary grade 890
Employer’s position: sub-factor should be rated at Level E (200 points)
Total points for job – 2160
PBM range - 2001 to 2301
Salary grade - 885
E. Primary Adjudicator
Disputed sub-factor: Independence of Action (Decision-making)
Union’s position: sub-factor should be rated at Level D (112 points)
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Total points for job – 829
PBM range 732 to 844
Salary grade 850
Employer’s position: sub-factor should be rated at Level C (63 points)
Total points for job – 780
PBM range 732 to 844
Salary grade 850
F. Desk Auditor
Disputed sub-factor: Regulatory Knowledge
Union’s position: Level E (160 points)
Total points for job – 952
PBM range 845 to 975
Salary grade – 855
Employer’s position: Level D (90 points)
Total points for job – 882
PBM range 845 to 975
Salary grade – 855
59. The parties agree that the procedure for evaluating the jobs outlined in Article 18 of
the Agreement was fully followed.
*
At the hearing the parties further agreed that out of 806 incumbents, 509 adjudicator
positions were held by females. They also agreed that out of 24 incumbents, 18 primary
adjudicator positions were held by females. I was also provided with copies of the historical
collective agreements from and following the 1980-81 collective agreement. The term ‘job’ and
‘position’ may be used interchangeably in this decision.
Paragraph 36 of the agreed statement of fact is somewhat incomplete. Under the
provisions of the appeal process in Article 18.02 of the collective agreement, the parties each
rely on the following provision:
….
If the Larger Committee cannot agree, the Union may apply to the Grievance Settlement Board.
The Employer reserves the right to raise the preliminary objection of arbitrability. In the interim
the decision of the employer will be implemented.
* * *
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Section 51 of CECBA provides:
51. (1) An order of the Grievance Settlement Board shall not require the creation of a new
classification of employees or the alteration of an existing classification.
(2) An order of the Grievance Settlement Board shall not require a change to be made in the
classification of an employee.
* * *
In brief summary, these facts confirm that the job description for each of the disputed
jobs forms the basis of each job evaluation and is measured against four main factors; skill,
responsibility, effort, and working conditions. Those factors are broken down into eighteen sub-
factors. If a consensus is reached by the parties regarding the application of these factors to the
job description, the job is given a point total. That point total will fall within a predetermined
point band, reflective of a salary grade. The salary grade reflects the classification of the job.
The six jobs in issue here have been reviewed by the joint job evaluation committee and
by the ‘larger committee’. There is a disagreement concerning the appropriate weight to be given
to certain sub-factors in evaluating those six jobs. In each case the union seeks to assign a higher
weighting to a particular sub-factor(s) than the employer is prepared to recognize. The result of
assigning the higher weight would be a higher overall point total for that job. The union
acknowledged that in four of the six jobs in dispute, that higher scoring would correspond to a
higher salary grade.
It is the position of the union however that it is not asking the Board to place employees
in those jobs in the higher salary grade, effectively changing their classification. Rather, it argues
that it is asking the Board, as in any dispute concerning the interpretation of the collective
agreement, to be the mechanism whereby the parties’ disagreement may be determined based on
the criteria set out in the job evaluation system contained in the collective agreement. It argues
that CECBA does not prohibit the Board from dealing with the application of the parties’ job
evaluation system at large. It argues that there need be clear and explicit statutory language
before the Board is rendered powerless to assist the parties in administering a jointly agreed upon
job evaluation system. The union asks the Board to engage in the inquiry simply to determine the
appropriate scoring of the relevant sub-factor(s) for each of the disputed benchmark jobs.
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It is the position of the employer that, in substance, the union is asking the Board to
engage in an exercise that is prohibited by section 51 of CECBA as any determination has the
potential of requiring a change to be made in the classification, not only of one employee, but of
all employees holding a disputed job. The union, argues the employer, is asserting that the
employer has misapplied the sub-factors and, although the union is not directly seeking
reclassification of the disputed jobs, such is a necessary feature and result of applying the sub-
factors ‘properly’. The employer relies on OPSEU, Local 559 v. Centennial College (Ng), infra,
to highlight the close relationship between a job evaluation system and a classification system.
The employer referred me to and I have reviewed the following decisions: OPSEU v.
Ministry of Education (Foreman), [2005] O.G.S.B.A. No. 44 (Abramsky); OPSEU v. Ministry of
Environment (Dobroff), [2005] O.G.S.B.A. No. 23 (Dissanayake); OPSEU v. Ministry of Labour
(Frisken), decision of Vice-Chair Gray dated June 5, 1997 (#2034/94); OPSEU v. Ministry of
Health (Aitken et. al.), decision of Vice-Chair Gorsky et. al. dated December 21, 1993 (#678/87);
OPSEU v. Ministry of the Solicitor General and Correctional Services (Knaap), [2000]
O.G.S.B.A. No. 46 (Dissanayake); OPSEU v. Ministry of Transportation (Wilson), [2001]
O.G.S.B.A. No. 23 (Dissanayake); OPSEU v. Ministry of Environment (Boyer), [2001]
O.G.S.B.A. No. 67 (Abramsky); OPSEU v. Ministry of Citizenship, Culture and Recreation
(Rosamond), decision of Vice-Chair Leighton dated December 16, 1998 (#2086/96); and
OPSEU, Local 559 v. Centennial College (Ng), [2006] O.L.A.A. No. 176 (O’Neil).
The union referred me to and I have reviewed the following decisions: Workmen’s
Compensation Board, Ontario and CUPE, Local 1750, an interim decision of Arbitrator
Weatherill dated February 4, 1980, and his final award dated July 4, 1980; Workmen’s
Compensation Board v. CUPE, Local 1750, [1981] O.J. No. 173 (Div. Ct.); OPSEU v.
Management Board Secretariat (Collective Agreement Grievance), [2000] O.G.S.B.A. No. 115
(Petryshen); OPSEU v. Ministry of Finance (Lau); [2001] O.G.S.B.A. No. 27 (Watters); OPSEU
v. Management Board Secretariat (Union Grievance), decision of Vice-Chair Gray dated April 4,
2001 (#0196/00); Rizzo & Rizzo Shoes Ltd.(Re), [1998] 1 S.C.R. 27; Canada (Attorney General)
v. Abrahams, [1983] 1 S.C.R. 2; and Re Service Employees International Union, Local 204 and
Broadway Manor Nursing Home et. al., (1984) 48 O.R. (2d) 225 (C.A.). I was also referred to the
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recent text authored by Hadwen et. al., Ontario Public Service Employment and Labour Law,
Irwin Law, 2005.
* * *
It is somewhat instructive to compare the language of the collective agreements between
these parties prior to and following the introduction of section 51 to CECBA. I have no evidence
of any bargaining history. Prior to the introduction of section 51 and going back to 1980, the job
evaluation system contained in the collective agreements between these parties expressly
provided that disputes concerning the “accuracy of the [job] description” and disputes concerning
the “factor level ratings” (see for example, sections 22(e) and 23(e) of Schedule ‘A’ of the 1980-
81 agreement) were arbitrable and could be submitted to arbitration for determination. That
language was adopted by Arbitrator Weatherill in a follow-up determination arising out of an
interest arbitration. It differs from the instant case in that these grievances represent rights
disputes. There appears to be little or no dispute that an interest arbitrator would now be
prohibited from ordering the inclusion of such a provision in a collective agreement between
these parties given section 52 of CECBA (and see OPSEU v. Management Board Secretariat
(Union), supra.).
Interestingly, in these earlier collective agreements, any unresolved dispute concerning
the job description or factor level rating for a ‘specimen job’ (a benchmark job) resulted in
removal of that job from consideration as a specimen job. Although this language appears to have
continued following the enactment of section 51, the language changes in the 1999-2002
collective agreement and the clause from the appeal process in Article 18 reproduced above
appears for the first time. Any express reference to arbitrability of either the job descriptions or
the factor level ratings is eliminated. Specific reference to ‘specimen’ or ‘benchmark’ jobs also
appears to have been removed from the collective agreement. In the current collective agreement
there is a further change, consistent with paragraph 13 of the agreed statement of fact, that,
failing agreement as to the contents of the job description, the employer has final accountability
for the job content in the job description. All of those changes are consistent with the
identification of a dispute surrounding the effect of section 51 of CECBA on the parties’ job
evaluation process, leading to this case.
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It was not suggested by the employer that the terms of the Job Evaluation Plan filed as
Appendix A to the agreed statement of fact did not form part of the collective agreement. It is
referenced in Article 18.02 of the collective agreement, although the delineation of the sub-
factors and their scoring is set out in that plan and not in the collective agreement itself.
One may usefully begin the inquiry by reviewing the following summary from Ontario
Public Service Employment & Labour Law, supra, at pages 559, 566, and 568-570:
13) Restrictions of Remedial Authority
At the present time, CECBA imposes three restrictions on the remedial authority of the GSB.
The first two restrictions relate to discipline and discharge cases….. The third restriction is that
the GSB cannot create, alter or change an employee’s classification.
No such limitations apply to the remedial authority of arbitrators under the LRA. …..
The provision concerning classification is also notable for what it does not do. It does not
impose a legislatively-prescribed classification system that is thought to be in the public
interest. Rather, it limits redress for problems with the Crown’s administration of such a
system.
…….
c) No Creation, Alteration or Change of Classification
Section 51 of CECBA prohibits the GSB from requiring the creation of a new classification or
the alteration of an existing classification, and from requiring a change to be made in the
classification of an employee. (This has not prevented the parties from agreeing that the job
evaluation system is outdated and needs to be replaced, although there was no waiver of the
management right to manage the system. [OPSEU/MBS Collective Agreement, 2005-2008,
Appendix 34]
………
iii) Defining the Scope of the Restriction
While CECBA, section 51, generally prohibits the GSB from reclassifying employees, most of
the GSB’s relevant jurisprudence does not actually deal with section 51. A number of the
relevant cases arose under a specific, earlier, agreement between OPSEU and MBS that
stipulated that all classification grievances were withdrawn. In other cases, the employer
incorrectly relied on section 52 of CECBA without objection from the union. In any event, all
the cases discussed below deal with the scope of limitations on classification grievances.
Any grievance that involves the reclassification of the grievor “at some point in time”
is a ‘classification grievance”. In the leading case of Aitken, the grievance was not framed as a
classification grievance, but as one of proper placement on the salary grid. The GSB found that
the resolution of the grievance required resolution of a dispute about the grievor’s correct
classification at an earlier point in time (when she was in a former position) and therefore was
inarbitrable.
The same rationale has been applied to a requested adjustment of the date of an
employer reclassification of employees. The grievances in that case were characterized as
claims for retroactivity and compensation, but the GSB held that it was actually being asked to
engage in a prohibited comparison of the duties and responsibilities of different classifications
for classification purposes. It appears that the GSB will maintain that position even when there
is no real dispute about the comparison. The GSB has declined to adjust the date on which the
employer chooses to move an employee from an “under fill” or entry-level classification, to the
normal classification, even though the grievor had finished the entry-level training and
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orientation and the employer agreed that the work being done by the grievor was the same as
that of the higher-rated classification.
Other attempts to re-characterize classification claims have been resolved the same
way. The GSB has refused to accept that a grievance was, in “pith and substance” about the
grievor’s bumping rights after being surplused. The grievor wanted to return to a prior position,
but her classification had been downgraded and the collective agreement did not permit
bumping her up a classification. The GSB concluded that the grievance was, in essence, a
classification grievance, as it would require an examination of the job that the grievor was
doing before her classification was downgraded in order to decide the second issue of whether
or not the grievor had been denied her bumping rights. The same approach has been taken
concerning temporary-assignment grievances. Under the OPSEU/MBS Collective Agreement
Article 8.6.1, there is an entitlement to acting pay where an employee is “assigned temporarily
to perform the duties of a position in a classification with a higher salary maximum for a period
in excess of five consecutive working days. In order to be entitled to the acting pay the grievor
must prove an assignment to do “all the significant duties” and not just some of the duties, of
another higher-classified job. This could involve some of the same kind of analysis as would
take place in a classification grievance. So, the focus of the inquiry must be whether the work
of the claimed classification is being done and not the appropriateness of the classification. The
GSB has declined to deal with a claim for acting pay where there was a dispute about the
appropriate classification of the duties in question….
It has been usefully clarified that the prohibition on reclassifications only applies to
the reclassification of a position, and not to deciding whether a grievor should be in the
position. In a job-competition grievance, the GSB held that the remedy of assigning the grievor
to a new position that had a higher classification did not involve classifying a position and that
CECBA did not preclude the GSB from requiring that the employer put a grievor in a particular
position….
The union argued that section 51 of CECBA is a remedial limit and cannot be compared
with those decisions such as OPSEU v. Ministry of Health (Aitken), supra, which flowed from an
OPSEU/MBS agreement to withdraw classification grievances. In those cases, argued the union,
there was no jurisdiction to entertain the inquiry, as opposed to merely limiting the available
remedy.
The union is correct in noting that many of the cases reflected by the passage cited above
arose under an agreement between different parties and did not specifically deal with section 51,
and as a consequence, one must be careful before adopting them without further consideration.
However what this summary does reflect is the fact that the Board will look to the substance of
the dispute in determining whether or not the issue is one in which the Board’s authority has been
limited by the statute.
In OPSEU and Management Board Secretariat (Union), supra, the Board concluded that
section 51 of CECBA is a remedial limitation only; one which does not otherwise preclude the
Board from enforcing collective agreement provisions concerning or involving classification
matters. In that case the union grieved that the employer had implemented a new job description
16
format and re-introduced a job evaluation decision-making process in violation of Appendix 7(1)
of that collective agreement. That appendix confirmed the agreement of the parties that the
classification system overhaul was to be deferred for the duration of the collective agreement,
and for the period of its operation. The issue was whether or not that agreement prohibited the
employer from changing any aspect of the then existing classification process, or whether only
the existing classification standards and the values attached by the parties to the outcomes of
applying those standards were frozen.
In finding that the employer had not changed the classification system or breached its
agreement to defer implementation of the overhaul process, and therefore dismissing the
grievance, Vice-Chair Gray noted:
[28] …The employer does not dispute that by agreeing to defer the classification
system overhaul it agreed to retain the existing classification system. The parties’ dispute is
about what “classification system” embraces in this context so as to preclude its change. It
certainly embraces the standards by which OPSEU bargaining unit jobs are evaluated in order
to classify them. That is clearly the core of the classification system….
(emphasis added)
The Vice-Chair also dealt with the employer’s alternative argument that had it breached
Appendix 7 or otherwise purported to change the classification system, the Board would be
without jurisdiction to remedy the breach because of section 52 of CECBA. The Vice-Chair
reviewed that provision, concluding that it was not applicable to the Board. He then went on to
discuss section 51:
[38]….The employer’s assertion that [CECBA] permits it to unilaterally alter the
classification system with total impunity is certain to have adversely affected the parties’
labour relations, and unnecessarily so if it is untrue….Having concluded that section 52 of
CECBA does not have as broad a reach as the employer suggests, I think it is important to say
so in this decision.
…..
[40] The scheme of CECBA is that rights disputes – that is, disputes arising from the
interpretation, application, or alleged violation of a collective agreement – are to be referred to
the Grievance Settlement Board (“GSB”) for final and binding settlement by arbitration:
CECBA, subsection 7(3). In the result, the GSB is the only tribunal to which such rights
disputes may be referred. Matters relating to the GSB’s jurisdiction in such matters are
addressed in Part V of the Act, where section 51 is found. Section 51 imposes limits on the
remedies that the GSB may order if it finds that the employer has breached the provisions of the
collective agreement. It does not otherwise preclude enforcement of collective agreement
provisions concerning or involving classification matters.
…..
[42] Accordingly, I agree with the union’s submission that neither section 51 nor
section 52 of CECBA would preclude the GSB from making an order requiring that the
employer comply with [Appendix] 7, if such remedy were warranted. Enforcing the parties’
own agreement on a classification system does not amount to “determination…..of…a
17
classification system” in the sense intended by section 52 of CECBA. Subject to section 51, and
to the provisions of the collective agreement itself, the GSB does have jurisdiction to enforce
provisions that the parties have made in their collective agreement prescribing the
classification system to be used in determining compensation for bargaining unit employees.
(emphasis added)
The union relied on Vice-Chair Gray’s comments above to argue that, in the instant case,
a negotiated classification structure existed, and that the Board was not precluded from ordering
the employer to comply with its rules. Its goal was simply to ensure that the bargain made
voluntarily to implement that job evaluation scheme was fulfilled. It sought an order as to the
appropriate points to be accorded to the disputed sub-factor(s) for each disputed benchmark job.
The union acknowledged that the parties have already agreed to the consequences of any
assessment of points to each job. However, the union argued that if the employer refused to place
an employee in the salary grade reflected by the point total incorporating the Board’s assessment
of the sub-factor(s), it would be precluded from coming to the GSB to complain. The issue, it
asserted, centred on the parties’ agreement to jointly assess benchmark jobs. I note that
benchmark jobs are treated no differently in their evaluation than any other job.
Unlike section 52 of CECBA, section 51 limits remedy only. It does not limit the Board’s
jurisdiction to engage an inquiry. This lesser restriction must be in recognition of the fact that the
Board is the tribunal entrusted with determining disputes arising out of the interpretation,
application, and administration of collective agreements between parties subject to CECBA. That
is, it is the entity charged with enforcing the parties’ own agreements. It is also the case that
many matters arising under the terms of a collective agreement, including for example, wages,
hours of work, job postings, even discipline, have the potential to be characterized as giving rise
to a ‘classification’ issue. To preclude the Board from having the jurisdiction to entertain a
‘classification’ issue would have the potential of significantly limiting the Board’s jurisdiction far
beyond any issue of management’s right to determine job content and a classification system, and
as Vice-Chair Gray noted, would have a seriously adverse impact on the parties’ labour relations.
To take perhaps an extreme example of the potential effect of limiting the Board’s
jurisdiction, suppose parties bargained a 3% wage increase in their collective agreement.
However, following its implementation, the employer unilaterally downgraded the classifications
of all employees (while making no changes to any job content) such that the wage increase was
effectively eliminated. Precluding the Board from taking jurisdiction to enforce the parties’
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agreement because it involved the 'classification system', is a result that could not have been
intended by the statute. Similarly, if an employee were disciplined for poor performance but the
tasks assigned were asserted to be beyond the job description and outside the classification of that
job, one would expect that the Board would continue to have jurisdiction to inquire whether or
not the employer had cause to discipline the employee.
These are, perhaps less obviously, the kinds of issues dealt with by the Board in two cases
relied on by the union. In the case of OPSEU v. Ministry of Finance, (Watters), supra, the
grievances asserted that Investigators in the Ministry of Finance should have received the same
classification adjustment provided to Tax Auditors. The Board took jurisdiction and awarded a
compliance remedy in that case as the issue was the proper interpretation to be given to a Letter
of Understanding reached between the parties, that is, whether the Investigators were part of the
deal. As Vice-Chair Watters noted at the end of paragraph 96:
….A decision in the Union’s favour would not be tantamount to this Board creating a new
classification or altering an existing one. The parties themselves did this by way of the Letter of
Understanding. Rather, such a decision would simply give effect to the intention of the parties
as reflected in their Letter of Understanding. (emphasis added)
In OPSEU v. Management Board Secretariat (Petryshen), supra, the Board also provided
a remedy, notwithstanding section 51 of CECBA. In that case the union asserted that the
employer had failed to fulfill its obligations under Appendix 8 to that collective agreement which
required the parties to establish a joint ‘Senior Persons Committee’ to examine the workings of
the Joint System Subcommittee (“JSSC”) and to “make recommendations to improve its
operation”. The committee had been struck, it had met, but had been unable to reach a consensus
on its recommendations. Therefore it failed to make any. The Board directed the parties to fulfill
the obligation in the collective agreement to make recommendations.
At first blush, the impasse reached by the parties in that case seems similar to the one
before me. The parties engaged an agreed upon process but were simply unable to agree to its
outcome. The Board intervened. However, there is an important distinguishing feature in that
case. The Board did not intervene to determine the appropriate recommendations. It intervened to
direct the parties in respect of, and to complete their process. Although so couched in argument,
the union is not asking me to direct the parties to properly engage their process. It is, in my view,
effectively seeking a result, even in circumstances where there is no obligation in this collective
agreement requiring the parties to agree in the evaluation of the sub-factor(s).
19
There is a difference, to borrow Vice-Chair Gray’s words, between “enforcing
provisions” that the parties have made in their collective agreement “prescribing the
classification system to be used” in determining compensation, and actually applying the terms of
that prescribed classification system. If the Board were to hear this dispute, two possibilities
arise. The Board could determine that the employer’s rating of a sub-factor is correct and
effectively confirm what already obtains (as the collective agreement requires that the employer’s
decision be implemented while any dispute is outstanding). Alternatively the Board could declare
that the union’s rating of the sub-factor is the correct one and make no further order.
It is the case that any determination as to the appropriate point level to be assigned to a
sub-factor will require a review of the duties and responsibilities of the job in relation to its
historical duties and responsibilities, in relation to the requirements of the particular sub-factor,
and potentially in relation to levels assigned to other jobs; typically exercises in ‘classification’.
However and more to the point, it is also the case that any such determination will have as its
only purpose the confirmation of one or other of the parties’ view as to the appropriate weighting
to be accorded the various sub-factors and inherently, this Board’s view as to the appropriate
classification of the job. The total points assigned to a job determine its salary grade. Under the
terms of Article 18.02 1. (a) and ‘Schedule A’ of this collective agreement, the salary grade
represents the classification of the job.
While such a limited determination would not, strictly speaking, ‘require the alteration of
an existing classification’ or ‘require a change to be made in the classification of an employees’,
the union is, in effect, asking the Board to do indirectly what it cannot do directly. The union is
seeking a persuasive influence, which purpose can only be to generate an ‘alteration of an
existing classification’ or ‘a change to be made in the classification of an employee’, something
which CECBA prohibits this Board from ordering directly.
That persuasive influence is also being sought through the application of a standard of
review that holds there is a ‘correct’ valuation of the sub-factor(s). There is no suggestion that the
employer has acted in a manner that was arbitrary, discriminatory, or in bad faith in its
participation in this process. Such an assertion, if established, might well be subject to remedy
within the confines of section 51. The agreed statement of fact however confirms that the parties
20
fully engaged the process but have simply (and implicitly, reasonably) come to different views in
respect of their assessment of particular sub-factor(s) in relation to six jobs. These job evaluation
standards are at the core of the classification system. The employer says that the disputed sub-
factors are less important. The union would assign them greater importance. Arguably, to accept
the union’s position would be to alter the job content. Generally speaking, the employer has the
right to determine what it wants done. The employer must then also live with the consequences of
assigning less weight to these sub-factors should that issue arise in a job competition or in a
discipline context.
Having regard to all of the above, I am persuaded that, in the particular circumstances, the
union seeks to have the Board engage in an inquiry for the purpose of determining the very thing
which the legislature did not want the Board to remedy, and for which the Board, by virtue of
section 51, has no jurisdiction to remedy. I am also not persuaded that there is any labour
relations value in otherwise pursuing the inquiry. I therefore decline to engage the inquiry.
The union also argued that the Board may take jurisdiction in this matter under the Pay
Equity Act in order to maintain pay equity, given section 48 of the Labour Relations Act, 1995.
As the employer noted, just because a certain job title may currently be filled by a majority of
female employees, one does not therefore necessarily conclude that it is a female-dominated
position for purposes of pay equity. It is not at all clear to me that any determination of the
appropriate rating of these sub-factors in relation to these six jobs has anything to do with
maintaining pay equity across this bargaining unit and I decline to take jurisdiction under that
statute. The union may advance any such concern in the appropriate forum.
I note that the union has reserved its right, in the alternative, and without objection from
the employer, to argue that the provisions of CECBA contravene the Charter.
21
Having regard to all of the above, I find that, in the circumstances, section 51 of CECBA
limits the Board’s remedial authority in respect of the grievances before me and I see no labour
relations value in otherwise engaging the inquiry. Nor am I persuaded to take jurisdiction under
the Pay Equity Act. Accordingly, I decline to entertain the grievances and they are herby
dismissed.
Dated at Toronto, Ontario this 24th day of July, 2006.
Marilyn A. Nairn, Vice-Chair.