HomeMy WebLinkAbout1992-3278.Pound.96-02-08F
&PLOY& DE LA COURONNE
DE L’ONTARIO
COMMlSSlON DE
RiiGLEiVlENT
DES GRIEFS
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i : GSB # 3278/92 ' ,
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QLBEU # OLB437/92
IN TilE MATTER OF AN ARBITRATION .
UnUer
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ,ACT. _'
Before
THE GRIEVANCs SETTLEME-NT E@ARD
BETWEEN 1 OLBEU (Pound) Grievdr
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The Crown in,Right of Ontario
, (Liquor Control Board of Ontario)
_ Employer
BEFORE: F. Briggs Vice-Chairperson ' . .
FOR THE GRIEVOR
s. Philpott ,. Counsel Kos'kie.& Minsky Barristers & Solicitors I .
FOR THE A. Raso
.EMPLOYER Counsel ,Hicks, Morley, Hamilton, Stewart, Storie Barristers C Solicitors ~' ,
HEARING August 23, 1995
The &rievcn, Karen Pound, was twice absent from work due to a compensable injury. She ,
ultimately returned to work in August of 1992. She grieves that she is a victim of adverse
,. impact discrimination because the Employer failed to allow her to continue to accrue
6 vacation and attendance credits during the period of her absence without pay from work-due
to the- compensable injury..
The parties agreed on the facts required to deternnne this matter which are set out below:
1. . This is no issue between the parties regarding the calculation of the grievor’s vacation and/or
attendance credits.’ That is, there were no errors in calculation made.
2. On October 10, 1989, the grievor was injured at work .and commenced an absence due.to a
compensable injury. She was absentuntil January 21, 1991, on which day she returned to
work on modified duties.
3. From October 10, 1989, to January 10, 1990 the grievor received full salary with no
reduction of accrued credits in accordance with Article 12.5 of the Collective Agreement.
She also continued to accrue credits for that period.
“Where an employee is absent from work by reason of a condition for which
the Workers’ Compensation Board assumes liability, the employee shall be
eligible for Compensation Leave for a period not exceeding three (3).months
or a total of sixty-five (65) working days where such abseties are
intermittent for each unrelated claim. During-such leave the employee shall
receive full salary with no reduction of accrued credits but vacaiion and _ _
attendance credits shall continue.to accumulate during the period.”
4.
5.
From January 11, .199Oto January 20, 1991 the grievor was paid Workers’ Compensation
benefits (“WC benefits”) equal to 65 %- of her regular salary; and’ her WC benefits were
“topped up” to 100 % of her regular salary by an amount deducted from her accumulated
vacation and attendance credits. It is the LCBO’s policy to utilize an employee’s attendance
credits first to top up WC benefits to full salary, and then, if necessary,the employee isgiven
the option to utilize vacation credits to top up to full salary. The Grievor chose this option.
During this period, the employee is considered to be on a leave of absence with pay for the
purposes of accumulation of vacation credits and attendance credits and, accordingly, the
grievor continued to accrue credits for that period. ’ . .
The grievor’s accumulated vacation and attendance credits were exhausted on August 2, 1990
and thereafter, in accordance with Article 12.8 of the Collective Agreement she was
considered on a leave without pay. Article 12.8 of the Collective Agreement provides:
,
“Where an employee receives an award under the Workers’ Compensation
Act, and the award applies for longer than the period set out in Artide 12.5
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and the employee has exhausted all accumulated credits, the employee will
be considered on leave without pay.”
On October 24, 1991 the grievor suffered a recurrence of her- injury. She again received WC
benefits and drew from her bank of accumulated attendance and vacation credits to top up her
‘income to 100% of her regular salary. Her accumulated credits were exhausted on
November 20, 1991 and from that day ‘until her return to modified work on August 4, 1992,
she was considered to be on a leave without pay and accrued no further vacation or
attendance credits for that.period.
The periods in respect of which the grievor was in receipt only of WC benefits (when her
accumulated credits were exhausted) are deemed to be without pay by Article 12.8 of the
Collective Agreement,.. Article 12.8 leaves without pay, as well as other types of leaves
without pay have historically been treated by the parties as a hiatus in the accumulation of
vacation and attendance credits in accordance with Article 15.1 of the Collective Agreement
’ which provides:
“Leave-of absence without pay and without accumulation of credits
may be granted to an employee by the Employers.”
The parties have historically treated employees as entitled to ‘accumulate vacation and
attendance credits only when the employee is at work or on a leave of absence with pay for
at least one full day during a calendar month. This is in accordance with Articles 8.7, 9.4
and 9.5 of the Collective Agreement which provide as follows:
“Except as provided under Article 8.8 below, an employee is entitled to
vacation credits under Article 8.6 in respect of a calendar month in which
he/she is at work or on a leave of absence with pay for at least one (1) full
day.” ’
“An employee is entitled to attendance credits under Article 9,.2 in respect
of a calendar month in which he/she is at work or on leave-of-absence with
pay for at least one (1) full day.”
“Notwithstanding the provisions of Article 9.4 an employee is not entitled
to attendance credits under Article 9.2 in respect of a month in which the
employee is absent from work.” ’
Ms. Philpott, for the Union, reinforced that there is no dispute between the parties that the
current practice of non accumulation of benefits during an unpaid leave of absence has been -. .
in effect for a considerable period and continues to the present day. However, it was the
Union’s position that to-allow the non accumulation of benefits to employees absent on
Worker’s Compensation is contrary to the provisions of the Human Rights Code, R.S.O.
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1990, c. II-19.(hereinafter referred to as “the Code”. -The/relevant sections of the Code are
‘as follows:
5.( 1) Every person has a right to equal treatment. with respect to employment without
discrimination because of race, ancestry, place of origin, colour, ethnic origin, citizenship,
creed, sex, sexual orientation, age, record of offences, marital status, family status or
handicap.
10. In Part I and in this Part,
“because of handicap” means for the reason that the person has or has had, or is believed to
have had,
+9 an injury or disability for which benefits were-claimed or received under the
Workers’ Cqmpefisation Act;
17.(l) A right of a person under this Act is not infringer for the reason only that the person is
.incapable of performing or fulfilling the essential duties or requirements attending the exercise ’
of the right because of handicap.
The Union submitted that to tie the accrual of vacation and attendance credits to actual
attendance at work, given that the grievor was absent from’work due to a compensable ,
injury; is discrimination. TheUnion had two arguments for,the Board to consider. .The f&St
was that the grievor was treated differently from other employees on other types of leaves
of absence without pay. The second submission, in the alternative, isthat the grievor was
treated differently than ,everyone else in the- bargaining ‘unit. ?
‘- Regarding the first argument, the Union suggested that in.accordance with Article 12 of the
Collective Agreement, members of the bargaining unit are entitled to sickness and injury
leave. The Collective Agreement also provides for a variety of other leaves including, but ’
not ‘limited to, maternity leave, military heave, and bereavement leave. Some ofthose leaves
allow for the continuation of wages and accumulation of benefits. Jn some provisions, like
maternity leave there is a period of compensation and a period of absence without pay. All .’
employees should &treated in the same fashion despite&the reason for their absence from
the workplace. That rs to say that all employees who are on leaves of absence ought to be
able to accrue vacation and attendance credits.
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Ms. Philpott asked the Board to consider some recent cases.. In Re Riverdale Hospital
(Board of &&nors) and Canadian Union of’Public Employee& Local 79 (1993), 39
L.A.C. (4th) 63 (Stewart), a grievance was allowed that adjusted an employees seniority after
an absence due to a maternity leave. The arbitration board determined that thegrievor was
absent-on a leave without pay and’ was treated differently from other employees in the
bargaining unit who were absent without pay, contrary to the Code.‘,
In Rb Memorial Hospital; Boma@lle and Ontatio Nurses’ Association (1993), 35 L.A.C.
\ (4th) 401, Arbitrator Thome four&hat a nurse was improperly terminated when the Hospital
discharged her in accordance with a “deemed termination” provision. The grievor had been
absent from work due to a disability for which she was receiving ..long term disability
insurance for a period in excess of thirty months. The board of arbitration found that the.
hospital could not terminate the grievor’s employment as she was entitled to the same
standard as other employees, that is, just cause for discharge. It was decided that the matter
-was similar to Re Chporation of City of Stratford and Canadian Union of Public 1
Employees, Local 197 (1990), 13 L.A.C. (4th) l.(M arszewski). In that decision, which was
upheld in Divisional Court, it was found that a “deemed termination” was contrary to.the
’ Code because the grievor was ,“not entitled to challenge his termination pursuant to the just
cause standard’.
It was argued by the Union that these cases stand for the proposition that employees ought
not to be penalized for an absence due to a handicap. In the instant matter, the grievor was
penalized by the Employer’s disallowing the-accumulation of vacation and attendance credits
for the period of her absence. ,The Union also relied ‘on Re Victoria County Memorial
Hospital and Canadian ‘Auto Workers, Local 607 (1994); 42 L.A.C. (4th) 194 (O’Connell) ,
and Re Toronto Hospital and Ontario Nurses’ Association (1992), 3 1 L.A.C. (4th) 44 (P.
Picher).
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The alternative position.of the Union is that the grievor ought to be treated the same as other
members of the bargaining unit. That is to say that she Ms. Pound ought to be allowed to
accrue vacation and attendance credits irrespective of whether she attended at work. As her
co-workers accumulated these benefits, so should the grievor. The Employer’s failure to
allow this accrual-is discriminatory because the grievor-was absent from work due to a
disability. If not for her handicap, she would have been present at work and accruing the
benefits.
Ms. Raso, for the Employer, asked the Board to keep in mind that the Union has not alleged
that there is any violation of the Collective Agreement. Rather, it was asserted by the Union
that the Collective-Agreement is discriminatory and should, in part, be struck down; It is the
position of the Employer that there is no adverse impact discrimination regarding the ‘grievor
and therefore the Code has not been offended and this matter must be dismissed. The past
._ practice of the Employer is that all employees, irrespective of the reasons for their absence,
are treated equally. That is to say employees do not continue to accumulate vacation and
attendance credits,during the period of any absence which is without pay. .I.
The Employer, like the Union, referred to a number of,previous cases. In Re Andrews v.
Law Society of British Columbia (1989), IO C.H.R.R. D/5719 (S.C.C.) discrimination was
defined taking into account the fmdingsaf other courts. It was stated at page 173 that “it
arises where an employer..... adopts a rule or standard... which has a discriminatory effect
upon a prohibited ground on one employee or group of employees in that it imposes, because
of some special characteristic of the employee or .group,- obligations, penalties, .or restrictive
conditions not imposed on other members of the work force”.
Ms. Raso submitted that two elements must be present for a finding of discrimination. First,
there must be a causal connection between the group being denied and a prohibited ground.
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In the instant .matter, the grievor is not being tieated differently. Any employee who is
absent without pay has not and does not accumulate vacation or attendance credits. This .is . .
‘not a prohibited ground under the Co$ and therefore there is no causal connection. Sec,ond, .
there must be a restriction which is not imposed on other employees. Obviously, as stated
above, any emnloyees who is absent without pay is not accumulating vacation or attendance
credits. Therefore, the grievor is treated the same as other employees. The Code does not
address employees. with different attendance records.
This very issue was considered by ‘a board of arbitration in Re Windsor Western Hospital
and Ontario l$ublic Service Employees Union (October 24, 1994), unreported (Stanley).
The Hospital did not allow the grievor to accrue vacation and sick leave entitlement during : ,
the period that the grievor was absent on a compensable injury and in receipt of Worker’s ~ Compensation Benefits. In considering the matter, the Board .stated at pages 11 and 121
The issue we must decide is whether the provision in the collective agreement which denies
employees on a leave of absence the right to accrue vacation and sick leave is
“discriminatory”. If it is, it can only be so because of the broader definition of diirimination
found in S. 11 of the Code. In accordance with that section, what we have to ask is whether
the collective agreement provision - ‘:results in the exclusion, restriction or preference of a ’
group of persons who are identified by a prohibited groundof discrimination and of whom
the person is a member. ” The “group” which the collective agreement singles out to deny
accrual of sick leave and vacation is not “a group of persons who are identified by a
prohibited ground of discrimination”. The group denied accrual of sick leave and vacation
is all those employees who are on leaves of absence. The Code does not list “being on a
leave of absence” as a prohibited ground of discrimination. I
\ It might be argued that employees with a “disability” are a group within thislarger group and
are therefore covered by the language. That is really the essence of constructive
discrimination - that a general innoduous exclusion sweeps in all members of a protected
group. In this case there are really two protected groups - those with “handicap” and the
person who is defined as handicapped because he/she “has or has had, or is believed to have
or have had an injury or disability for which benefits were claimed or received under the
Workers’ Compensation Act.” However, not all employees with a handicap, or all
employees who have or have had an injury for, which benefits are claimed, are going to be
on leaves of absence. Thus the general exclusion does not sweep in all or even a majority of
me members of a protected group.
If we had to decide whether the qualification was reasonable and bona fide, since it is
accepted in so many collective agreements that vacation and sick leave are benefits earned
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through attendance‘at work, we would conclude that the qualification in this case is reasonable
and bonafide.
The Employer argued that Article 12.5 of the Collective Agreement allows employees to I ”
continue to accumulate vacation and attendance credits for the first sixty five days of an
absence from work for which the Worker’s Compensation assumes liability. During this
period of time the employees are paid 100% of their regular salary. Employees do not cease
accruing those benefits until such time as they are on a leave of absence without pay. It is
that change in their status which disallows the continuation of benefit accrual.
Ms. Raso assertedthat it has. been decided that Worker’s Compensation Benefits are ‘not -
insurable earnings.for the purposes of Unemployment Insurance according to Re Blondhi
v. Minister. of Employment (1988), 89 C.L.L.C. 12,020 (F.C.A.) It was suggested that. this
1 is an analogous situation. Therefore, there can be. little doubt that employees who are absent
from work and who are in receipt of Worker’s Compensation,Benefits are to be considered
to be employees absent from work without pay.
’ The Employer submitted that the appropriate group of comparators are other employees on
unpaid leaves of absence and not the rest of the bargaining unit. In We Canadian.Airlines . .
International Ltd. knd Canadian Union of Public Employees, Airline Division (1993),
32 L.A.C. (4th) 398 .(Spri.ngate), it was determined that it is not discrimination for the’ i .
employer to treat employees absent from work differently from:employees remaining at
work. It was stated at page 408:
. . ..If taken to its logical conclusion’ the union’s position would appear to require that an
- employer “make whole” an employee on maternity leave and treat her for pay and benefit
purposes as if she was still actively at work.
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The Canadian &man Rights Act prohibits an employer from differentiating adversely in
relation to an employee based on a prohibited ground of discrimination. To conclude that this
goes beyond requiring that employees on maternity leave be treated as well as other
employees off work for health-related reasons, and instead requires that they be treated in the
same manner as employees actively at work, would require that I give the Act an
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interpretation much broader than similar provisions have been given to date. As indicated ..’
above, the arbitral jurisprudence, although limited, has -rejected this type of approach..
Further, although the Supreme Court of Canada in the Brooks case expressed concern about
pregnant women-bearing a disproportionate amount-of the costs of procreation, it did. not I’
adopt the approach being advanced by the union. Instead the courtheld only that employees
on maternity leave were entitled to be treated in a manner similar to other employees who
were off work for health-related reasons. _
The Employer also relied on Re Hick1ing.v. Lanark Leeds and Grenville County (1986),
7 C.H.R.R. D/3546 (Board of Inquiry); Re Stelco Inc., Hilton Works and United -
Steelworkers of America,, Local PO05 ( February 13, 1995), unreported (0. Gray); Re Glen
Haven Manor Corp. and, Canadian Union of Public Employees, Local 2330 (1991), 19
L.A.C. (4th) (Darby); Re Town.of Ajax and Canadian Union of Public Employees, Local
54 (1991), 23 L.A.C. (4th) 77 (Rayner); Re The Hamilton Entertainment and Convention
Centre and International Alliance of Theatrical Stage Employees’and MovingPicture
Machine Operators of the United States and Canada, Local 129 (October 30, 1993),
mrkported (Marcotte); Re Family Service Association of Metropolitan Toronto and
Ontario Public Service ‘Employees Union, Local 594’ (October 19, 1994), unreported
:SchifQ; Re’Versa Services Ltd. And Milk & Bread Drivers, Dairy Employees Caterers
& Allied Employees Union, -Local 647 (1994), 39 L.A.C. (4th) 196 (R. M. Brown).
Ms. Raso contended that the parties in the instant matter are sophisticated and‘knowledgable. -_
They knew the Code and have known their obligations for some time. It is clear from the
language of the Collective Agreement and the long standing practice that the parties knew
that they here not offending the Code. ’
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The Employer asserted that, in considering the affect of the. Code, this., Board must
differentiate between issues of participation for employment and matters of compensation
for employment. Section 17 of the Code requires the accommodation for people with
handicaps to enable them access to-employment. However, the issue at bar is not a matter
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accommodation but one of compensation. At page 20 of Re Stelco (supra); it &as stated:
Section 17 of the Code makes it clear that a difference in treatment will not infringe the Code
if it flows from an incapacity which cannot be accommodated, even if the incapacity is a
result of handicap. Counsel for the union acknowledged during argument that the-Code did
not oblige the employer to pay wages to the grievor for the period he was ‘absent due to his
compensable injury, in the amount he would have earned had he worked during that period.
This must surely be so. If there has been no denial or work contrary to the Code during that
period - and there is no suggestion that there has - ‘then it is difftcult to see how it could have
been a breach of the Code that he was not paid for work he did not and-could not perform.
Although counsel for the union resisted so characterizing it,. the vacation pay in issue here is
another element of the comperisation to which an employee becomes entitled for performing
work during the “vacation year”. When all of the vacation pay provisions of article 11 are
read together, it is apparent that, like wage compensation,’ the amount ~of that additional,
deferred compensation depends onthe amount of work performed, although the relationship -
is not as linear as it is for wages Lie wages, vacation pay is earned by performing work.
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The Employer asserted that the Board ought to take into .account that the’ Code does not
oblige the employer to pay an injured worker..one hundred percent of their wages. Furthei,
it does not require employers to pay full vacation pay or other benefits. In summary, the -
Board was asked to dismiss the grievance. ’ .:
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RECISION, -
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: After careful consideration of the ablesubmissions put forward by counsel for the parties and
be substantial jurisprudence provided, I am of the view that this grievance must fail. I have
Deen persuaded by the Employer’s submission that there are two aspects. to the matter of
3iscrimination regarding employment which fall into two categories, participation and
;om@rsation. The matter at issue is one of compensation. The. Employer’s long standing
and continuing practice of disallowing the accrual of vacation and attendance benefits timle ,
employees are absent without pay is not a matter of discrimination which impacts upon an
employees’ access to employment. It is a matter of an .employees’ level of compensation.
The ‘Collective Agreement between these parties is clear that attendance benefits and
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vacation benefits are earned by attendance in the workplace after the initial sixtj4ive ‘days
considered iq Article 12.5.
The instant matter differs from most of the cases put forward by the Union. In those cases,
the gr+vors’ employment was terminated in acc&dance with a “deemed termination”
provision. That is to say that employees were terminated after a specified period of time and
-without any consideration of whether there was just cause for the discharge. The protection k
of the standard ‘of just cause is afforded- to all other employees and for an employer to
dis~$itle handicapped.people to the protection of the just cause standard would clearly be
discrimination. That denial of the protection of just cause was an employment participation
matter, not a matter of compensatiofi. In the instant matter, the’continuation’of the grievor’s
status of employment was not affected. This was not a matter of employment status or
seniqrity ,accrual but rather an issue concerning the grievor’s abilitj to accrue certain benefits
during her unpaid leave of absence. / _
The Union suggested, in the alternative, that the appropriate group to compare the grievor
to is the entire bargaining unit. Again, I cannot agree. The appropriate employees tq
consider in determining adverse impact discrimination for this grievor are ‘other employees
on leaves of absence tiithouf pay. Employees on leaves of absence without pay in receipt
of Worker’s CompenSation Benefits are not being treated differently than other employees
who were on leaves of absence for other reasons. The scheme under this Collective
Agreement provides that employees at work will accrue certain benefits and .those who are
not at work and are not being paid by the employer, do not.
Employees who are absent from work and in receipt of Worker’s Compensation Benefits are
paid an &nount of money that is less than what employees attending at work would otherwise
earn. As in the Stelco case, there was no suggestion from the Union that the grievor was
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monetarily cotipensated in an amount that is contrary to the Code. During tlie period when
she was in receipt of Worker’s Compensation Benefits, Ms. Pound was compensated @ a
manner that was consistent with the Code.’ ‘The fact that she did not continue to accrue
certain benefits which were earned by her co-workers who attended at work i$ not
discriminatory. The earning of those benefits is dependant upon-attendance at work. That
qualification does not, in my view, offend the Code.
As noted in Versa Servic,s (sup-a), Section 17 c&ot be held to’mean that a handicapped
person should receive the same compensation as others in the work place because there is :
nd reference to compensation in that section. Arbitrator R. M. Brown thought it noteworthy
that the legislation was lacking a provision for equality of comperisation. He fetid that-the
absence 3f such a provision indicates a legislative. intention to “apply a different ,-
understanding of equality to matter of compensation”. He’continued that a handicapped
employee had only the right to be compensated-in the same way as an employee without a
handicap. In the instant matter the grievor was treated in the same fashion as any other
employee who was absent from work without pay..
A number of boards of arbitration have .spent much time and deliberation on this issue.
Dete rmining whither there is a contravention-of human rights legislation requires the most
thoughtful and careful consideration. It is essential .@at adjudicators are ‘assured that
employees do not lose employment benefits based on a ground which is prohibited by the
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legislation. ‘.
In the instant Collective Agreement, the parties specifically put their mind to providing. a
benefit specifically for employees absent due to ti compensable injury oi illness. At Article
12.5, those employees have their pay kept whole and receive all benefits for the first three
months. After that three month (or sixty-five day) period, those employees are treated like
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’ other-employees who are absent from the workplace without pay. At the point where they
are being paid a lesser amount, their benefits are also reduced. Indeed, at that point
employees who are on a leave without pay who are in receipt of Worker’s Compensation
Benefits are treated equally to those employees who are on other unpaid leaves of absence. I
It is undoubtedly unfortunate that employees, like the grievor, become injured or ill as a
result of their employment.’ However, I am of the view that the grievor was neither treated ’
differently than any other employee who was absent from work without-pay nor was she
discriminated against when she was disallowed from continuing to accrue vacation and
attendance credits.
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For all of those reasons, the grievance is dismissed.
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