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OLB#O 14/96
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGATNTNG ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OLBEU (Giddings)
Grievor
- and -
The Crown in Right of Ontario
(Liquor Control Board of Ontario)
Employer
BEFORE W. Kaplan Vice-Chair
FOR THE Julia Noble
UNION Legal Counsel
Ontario Liquor Board Employees Union
FOR THE Michael Sherrard
EMPLOYER Counsel, Ogilvy Renault
Barristers & Solicitors
FOR GREAT Graham Nattress
WEST LIFE Legal Counsel, Great West Life
HEARING May 19, 1998
,
,’
2
Introduction
Several years ago, Mr. John Giddings, a Stationary Engineer employed by the LCBO,
was denied LTlP. In order to prepare for that case, the union sought disclosure of the
grievor’s LTIP file. That matter came before the Board in a hearing held in Toronto
on July 25,1996. After considering the submissions of the parties, and counsel for the
insurer, Great West Life, I concluded, applying the “arguably relevant” test, that the
entire file should be disclosed. In my reasons for decision, I subjected that release to
conditions consistent with those of Rule 30.1 and directed that “union
counsel...preserve the security of that file and...only disclose the contents of it to the
grievor to the extent necessary to obtain instructions from him.”
ln the aftermath of that decision, and in the context of a similar set of circumstances
but in an entirely unrelated case, the scope of my earlier award was brought into issue.
Accordingly, and at the request of the parties, and Great West Life, a hearing was
convened in Toronto.
Submissions of the Parties
In brief, the union took the position that it needed to share documents found in the
insurer’s files, documents such as functional abilities evaluations, doctor’s and
surveillance reports, and other related materials, with the grievor’s own doctor in
order to understand the basis upon which LTIl? had been denied. As union counsel
pointed out, she was not a doctor and needed help to understand the documentation
in the insurer’s file - to decide, for example, whether to proceed with the case or to
challenge the decision being made - and that meant contacting the grievor’s physician
and showing him or her all or parts of the file. Making use of the documents in this
way, and solely for the purpose of a proceeding before this Board, was not only
necessary but, the union argued, fully consistent with Rule 30.1 and my earlier award.
In the employer’s submission, however, the earlier award was clear and should not be
given an expanded meaning. Referring to that award, employer counsel pointed out
3
that access was limited to union counsel for the purpose of obtaining instructions
from the grievor. Any additional access, such as for the purpose of having the
documents reviewed by one of the grievor’s physicians should, in management’s
view, be made the subject of discussion between the parties, failing which the parties
should go before a panel of the Board for additional directions. The award was not,
employer counsel argued, capable of an expanded interpretation and the employer
asked me to make a declaration to that effect. For its part, counsel for the insurer took
the position that it simply required clarification of the earlier award.
Decision
Having carefully considered the submissions of the parties, and having carefully
reviewed my earlier award, I am of the view that it is entirely appropriate for union
counsel, as part of obtaining instructions from the grievor, to share documents found
in the file with one or more of the grievor’s physicians in order to satisfactorily
inform herself of the case. As union counsel pointed out, she is not a doctor and
obviously requires expert assistance in order to fully understand the basis upon which
a claim was denied. There may be situations where this process will lead the union
not to pursue a grievance; there may other situations where the information found in
the file - and it should be noted that in the earlier award I directed that the entire file
be disclosed - will result in the union pursuing a claim.
As part of the process of obtaining instructions from her client, union counsel will
inevitably speak with the grievor’s doctor. Limiting disclosure of relevant documents
to counsel for the purposes of discussing them solely with the grievor would, in most
situations, be of little or no use. The Giddings case, where the grievor was apparently
suffering from a mental illness, simply serves to buttress this point. Getting
instructions from a client must necessarily include obtaining appropriate expert
advice.
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Accordingly, and for the foregoing reasons, it is my view that the earlier award must
be applied in a way that makes practical and legal sense. The union and its lawyer
must be able, as part of the process of obtaining instructions from the grievor for the
purpose of proceedings before this Board, share documents found in the insurer’s file
with the grievor’s physician or other retained specialists after having, of course,
explained that the documents had been disclosed solely for the purposes of a
proceeding before this Board. There is no need, in the circumstances just outlined, to
seek the consent of the insurer or anyone else before doing so.
Dated at Toronto this 1” day of June 1998.
William Kaplan
Vice-Chairperson