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HomeMy WebLinkAbout1993-1201.Hammond.95-11-09 Decision ONTARIO EMPLOYES DE LA COURONNE CROWNEMPLOYEES DEL'ONTARIO GRIEVANCE COMMISSION DE SETTLEMENT REGLEMENT EMBOARD DES GRIEFS C � 180 DUNDAS STREET WEST, SUITE 2100, TORONTO, ONTARIO. M5G 1Z8 TELEPHONE/TELEPHONE: (416) 326-1388 180, RUE DUNDAS OUEST, BUREAU 2100, TORONTO (ONTARIO), M5G 1Z8 FACSIMILE/TELECOPIE: (416) 326-1396 GSB # 1201/93 OPSEU # 93GO02 IN THE MATTER OF AN ARBITRATION Under THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT Before THE GRIEVANCE SETTLEMENT BOARD BETWEEN OPSEU (Hammond) Grievor and The Crown in Right of Ontario (Ministry of Health) Thames Valley Ambulance Employer BEFORE S. Kaufman Vice-chairperson FOR THE A. Lee GRIEVOR Grievance Officer Ontario Public Service Employees Union FOR THE P. Whalen EMPLOYER Barrister & Solicitor HEARING May 11, 1995 June 16, 22, 1995 1 DECISION Lynda Hammond, an Ambulance officer with Thames Valley Ambulance in London, Ontario grieved on June 16, 1993 that she was denied a full-time contract to replace Erica Daudlin while Ms. Daudlin was on maternity leave, and that the denial was contrary to Article 12 of the local 1990-91 Memorandum of Settlement. She requested appointment to a full-time con- tract as Ms . Daudlin' s replacement or credit for seniority and compensation for lost earnings as of the date of Ms. Daudlin' s maternity leave. The Evidence: A collective agreement between Thames Valley Ambulance Limited and OPSEU and its Local #106 in effect April 1, 1988 to March 31, 1989 (Ex. 1 ) contains the following under its Leave of Absence provisions: 12.03 In considering written requests for leave of absence, or extension thereof, the Company shall consult with the Union. 12.06 The Company agrees that in all cases where an employee is granted leave of absence without pay for a period exceeding four weeks, that the position will be filled by a temporary full-time posting. That agreement expired on March 31, 1989. A copy of a signed Memorandum of Agreement between Thames Valley Ambulance Services and OPSEU and its Local 106 dated March 21, 1989 (Ex. 5) states that all Articles of the Collective Agreement "shall apply to employees covered by this Agreement" "unless otherwise specified in this Agree- ment" and that it would be in effect from April 2, 1989 until March 31, 1990. An unsigned copy of a local Memorandum of Settlement dated February 14, 1991 (Ex. 2 ) was provided in evidence. The parties agreed that it had been siy::ed and was in effect 2 at the time of the events that gave rise to this ( .spute. It appears to have succeeded the March 21, 1989 Memorandum. The February 14, 1991 Memorandum (Ex. 2 ) stat.as in part: 1. The provisions of the prior collective agree- ment, if any, shall be continued except as modified herein in Schedule "A" . 2 . The provisions of the memorandum of settle- ment concerning central issues is attached and forms a part hereof. Schedule A in that Memorandum contains the following Articles referred to in Ms. Hammond' s grievance: 12.03 Where the company has granted a leave-of- absence in excess of one ( 1 ) week, under Article 12, Article 13 or Article 38 of this Agreement, the position may be filled by temporarily appointing the most senior part-time employee to fill the full-time position for the duration of the leave. 12.06 The company agrees that in all cases where an employee is granted leave of absence without pay for a period exceed- ing four weeks, that the position will be filled by a temporary full-time posting. Art. 12.06 in the February 14, 1991 local Memorandum is the same as Art. 12.06 of the Collective Agreement. It was not in dispute that Erica Daudlin was absent and on Workers ' Compensation benefits from December 28, 1992 to June 1, 1993, at which time she commenced a maternity leave to December of 1993, the employer assigned various part-time employees to fill her shifts and in June of 1993 Ms. Hammond was at the top of the part-time seniority list. Ms. Hammond's evidence was that between 1989 and 1993 she had done a number of temporary full-time contracts repla- cing other employees then on leave of absence and receiving long-term disability or Workers ' Compensation benefits. Dur- ing that period she may have unknowingly been assigned to the shifts of absent full-time employees on an open-shift basis. Schedules are posted 2 weeks in advance, but at times staff are assigned to shifts on 2 days ' notice. She inquired about 3 Erica Daudlin' s vacancy, possibly to Jack Mercer, probably in February of 1993, while Ms . Daudlin was off work on Workers ' Compensation benefits. She did not grieve after Mr. Mercer did not assign her to Ms. Daudlin' s schedule or any time thereafter until June, 1993 when Ms. Daudlin was on maternity leave. She recalled having spoken to Chris Ferris around the time she spoke with Mr. Mercer and recalled Mr. Ferris having told her that ongoing negotiations were dealing with the wording. She said that the union told her not to grieve at that time. Chris Ferris is a full-time ambulance attendant who has held a number of union roles including Chair of the Health and Safety Committee, Shop Steward, Unit Steward, Unit Chair, Local President, Regional Director of OPSEU Ambulance for his region for 2 years, and 3 terms on the local negotiating com- mittee. He was on the team which negotiated the local Memo- randum of Settlement dated February 14, 1991 containing Art. 12.03 and 12.06 and attended all except the last two meet- ings. Art. 12.03 was the union' s proposal. Until the 1991 Memorandum of Settlement was signed, the employer was not obliged to fill vacancies caused by the absences of full-time employees unless the absences were longer than 4 weeks. The union's 1991 proposal was an attempt to expand the situations where part-time employees would be "drawn onto full-time con- tracts" . When the vacancy was over 4 weeks in duration, the employer "was filling the positions by contract" . There is no paid leave of absence. Absences due to work-related inju- ry, non-work-related sickness or accident, personal, educat- ional, and maternity leave were filled by "temporary full- time contracts" . After the Knopf award, the employer "ceased full-time contracts except in the case of personal leave of absence" . The parties agreed that the Knopf award (Ex. 7 ) is dated July 1, 1992. Mr. Ferris reviewed the union's proposals regarding the replacement of employees on leave of absence. In the 1989-90 round of contract negotiations, the union proposed: 4 Art. 12 : Provide for temporary full-time posting to cover all leaves without pay exceeding two weeks. , and the parties ultimately agreed to the following: 12 .03 Where the company has granted a leave-of- absence in excess of one ( 1 ) week, under Article 12, Article 13 or Article 38 of this Agreement, the position may be filled by temporarily appointing the most senior part-time employee to fill the full-time position for the duration of- the leave. The 1989-1990 round of negotations resulted in the February 14, 1991 local Memorandum of Settlement (Ex. 2 ) . The em- ployer resisted the word "shall" and maintained it wanted discretion as to whether there would be a temporary posting for 1 to 4 week vacancies. During the 1990-1991 round of negotiations, the union proposed to change the word "may" in Art. 12.03 to "shall" . In one proposal it sought to add STD and WCB to Art. 12.06, and in a second proposal, it sought to add wording regarding pay administration to Art. 12.06. The wording of both 12 .03 and 12.06 remained the same at the end of the 1990-1991 round of negotiations. ` In the 1991-1992 round of negotiations, the union pro- posed a new Article 4.05: The most senior and available part-time employee will be placed on a full-time contract position to cover any full-time position open due to W.C.B. , S.T.D. , L.O.A. , maternity leave or an approved union leave, provided. That the said opened posi- tion exceeds a period of four (4 ) weeks. Normal wage and benefit provisions will apply. The union' s intention was to move the issue from Art. 12 to Art 4 which deals with postings. Art. 4.05 was intended to replace Art. 12.03 and 12.06. The union also proposed to delete and renumber certain clauses in Art. 12. Its propo- sals were denied in the July 1, 1992 Knopf award (Ex. 7 ) , 5 which set the terms of the central agreement for the period January 1, 1992 to December 31, 1993. In the 93/94/95 round of negotiations the union proposed the following new Art. 4.05: The most senior and available part-time employee will be placed on a full-time contract position to cover any full-time position open due to W.C.B. , S.T.D. , L.O.A. , Pregnancy or Parental Leave or an approved union leave provided that the said opened position exceeds a period of four (4 ) weeks. Nor- mal wage and benefit provisions will apply. This proposal was dealt with in the second Knopf award, dated March 6, 1995 (Ex. 14) covering the period from January 1, 1994 to April, 1996. Mr. Ferris acknowledged in cross-exami- nation that local negotiations for the January 1, 1994 to April 1996 agreement may not have begun before January 10, 1995 and that the union did not submit its demands to the employer for that agreement before January 10, 1995, which included the above proposal. In cross-examination, when asked whether the employer rejected the above proposal during the negotiations prior to the interest arbitration hearing in March 1995, Mr. Ferris said that the proposal was totally recycled and that the only change that had occurred was that around the spring of 1993, about the same time as the grievance, and possibly as early as the July 1, 1992 Knopf award, the employer stopped placing people on full-time contracts. He said that the employer's position at that point was that everything had a monetary cost or an administrative burden. He did not dispute that the employer 's objections were similar to those it had raised during the previous round of negotiations. He acknowledged that Staff Representative Carol Warner had proposed that the union would delete the last line of its proposed Art. 4.05 in an effort to seek the employer's agreement to the clause. Mr. Ferris recalled Ms. Hammond having approached him in the winter or early spring of •1993 about the full--time con- tract to replace someone who was off on Workers ' Compensation 6 benefits. He counselled her that she did not have a griev- ance at that time because the collective agreement did not require the employer to replace a person on Workers ' Compen- sation benefits with a contract, and told that her they were in negotiations and discussing the issue. In June or July of 1993 Ms. Hammond asked him about going on contract to replace an employee going on maternity leave. He told her to contact Mr. Mercer about start dates for her contract and later as- sisted her in filing a grievance under Art. 12 .06. In cross- examination Mr. Ferris said that he was not sure that he was in negotiations in early 1993 when Ms. Hammond spoke to him regarding the Worker' s Compensation leave taken by a full- time employee. Mr. Ferris acknowledged that Art. 12.03 was agreed to in 1991, that it referred to Art. 12 leave without pay, Art. 12 .05 union leave without pay, and Ex. 13 maternity leave, and that a person on maternity leave receives full benefits from the employer. He added that an employee on union leave also receives full benefits from the employer. He acknowled- ged that Art. 12.03 refers to Art. 38 which deals with sick leave and sick leave credits. Mr. Ferris said that because the Art. 12.03 provision pertaining to I - 4 week vacancies was not being used, the union intended to eliminate the provision pertaining to such vacancies with its proposed Art. 4.05. He agreed that the addition of references to W.C.B. and S.T.D. and maternity leave in its proposed Art. 4.05 were new. He acknowledged that leaves of absence in Art. 12 were without pay, and that Art. 4.05 does not confine leave of absence to without pay circumstances. He agreed that a person on maternity leave is entitled to Unemployment Insurance benefits, and that such benefits are paid for by the employer' s premiums, and added that the employee contributes to the premiums as well. He said that if a maternity leave was under 4 weeks in length, it was addressed by Art. 12.03. He acknowledged that the words "maternity leave" first appear in the proposed Art. 7 4 .05, and stated that it was current practice. He did not agree that the union had indicated to management that Art. 4.05 included expanded rights for the union. In his view, "leave of absence" in Art. 12.03 and 12 .06 includes personal, maternity and union leave of absence, which, in his view, are leave of absence without pay. He acknowledged that throughout the negotiations leading to interest arbitration in 1992 management had indicated the following concerns about the union's proposal: after 3 months on a contract, apart-time person would be entitled to benefits; management had sufficient part-time employees to fill vacancies due to Workers ' Compensation abences, short- term disabilities, and maternity leaves; it would restrict management 's right to staff as it saw fit and as required by the Ministry of Health; and it would cause management extreme administrative difficulties because at any time there are staff on Workers ' Compensation or short-term disability or maternity leave benefits. Mr. Ferris said that the union thought that replacing staff on an ad hoc basis placed a far greater administrative burden on management. He acknowledged a document summarizing management's position regarding the union's proposal at arbitration (Ex. 10) which indicated it would be difficult for management to monitor who is on bene- fits and who is entitled to benefits and that it was admini- stratively easier to utilize part-time staff. He acknowledg- ed the brief filed on behalf of OPSEU (Ex. 11 ) and the union's rationale therein for its proposed Art. 4.05: Preference for hiring of part-timers to fill temporary vacancy. OPS has an article requir- ing posting of vacancies; we are similarly here trying to increase protection for exist- ing employees. Reflects current practice for past 2 years. He acknowledged that the employer denied that that was the current practice. 8 Mr. Ferris stated in cross-examination that his under- standing, i.e. that in each case where full-time employees had been on leave of absence over 4 weeks in length and on Workers ' Compensation, short-term disability or maternity benefits, the employer used a part-time employee on a con- tract, was based on anecdotal evidence and that he had no documentation. He acknowledged that the employer does the scheduling and makes leave arrangements. He acknowledged having told the grievor that there was no onus on the em- ployer to replace an employee absent on Worker's Compensation with a contract employee. He said that management was repla- cing such employees of its own volition, and that there was no means of enforcement of the practice. When asked to agree that there was no obligation on the employer to replace an employee on maternity leave of absence with a contract, he replied that the union believes the opposite, because over the previous 3 to 4 years employees on leave due to materni- ty, disability and work-related injury or accident had been replaced by contract. He agreed his knowledge was anecdotal and that nothing in the collective agreement caused him to tell the grievor that replacement of employees on maternity leave was covered in the agreement. He acknowledged that the right to replace absent employees came under Arts. 12.03 and 12 .06, and said that that would include personal, union, and maternity leave' of absence, and sickness, but not absence while on Workers ' Compensation benefits. He acknowledged that before and after June 16, 1993, when Ms. Hammond' s grie- vance was filed, the union had been pursuing its proposal of a new Art. 4.05 and that a pre-hearing of her grievance was held on October 10, 1993. Mr. Ferris acknowledged that the pre-hearing took place while the union continued to negotiate for the adoption of its proposed Art. 4.05. Blair Bushell has worked as an ambulance attendant on a part-time basis for this employer since 1989, and full-time since November of 1991. He filled in on a full-time contract basis several times when full-time employees were absent and 9 on Workers ' Compensation, short-term disability and maternity benefits. He covered Eleanor Barr' s maternity leave from March to June of 1990 as a result of having learned of it through Supervisor Walt Smith. He covered someone else's leave from December 89 to March 1990. From December of 1989 to March of 1991 he was employed under consecutive contracts of various types. He was not aware of any of the contracts having been posted. He said he actually signed contracts for the replacement positions, but not on each occasion, and that he did not have copies and was not given a copy of every contract that he had signed. Irene Carruthers has been an administrative employee of Thames Valley Ambulance for 14 years, and has been Assistant Manager for about 8 years. She has been a member of the em- ployer' s negotiating team for 7 to 8 years. She handles the financial aspect of administration and keeps records of who is on leave at any given time. She advised that there were about 50 full-time employees and 30 part-time employees in June of 1993. Ms. Carruthers identified exerpts of the union's and employer' s briefs (Ex. 12 and 13) for the interest arbitra- tion resulting in the March 29, 1995 Knopf award (Ex. 14) . She denied that the employer had a practice of filling all leaves with a part-time employee on contract, and said that the employer has never had that practice. She said that the employer "replaces" with part-time employees generally and "there may have been the odd one that might have gone on a contract" but that the majority of absences due to leave of absence have been filled by part-time employees. The super- visors usually do the scheduling and they call the part-time employees "according to seniority, just on a random basis off our calling sheet" either on a day-to-day basis or by slot- ting part-time employees into full-time employees ' usual hours. In cross-examination Ms. Carruthers said her duties did not include scheduling the employees. 10 Ms. Carruthers said that she believed that four materni- ty leaves had been taken in the 14 years in which she had been with the employer, by Astrid Foot, Eleanor Barr, Dawn Elliot and Erica Daudlin. A part-time person was not given a contract during Ms. Foot 's and Ms. Elliot 's leaves and their schedules "would have been" filled by using part-time people "on a random basis" . Mr. Bushell was given a contract for part but not all of Ms. Barr's maternity leave and the ba- lance of her leave was filled by scheduling other part-time employees in her shifts on a random basis. In cross-examina- tion she said that Ms. Foot's maternity leave occurred over 10 years ago, prior to Ms. Hammond's date of hire, Ms. Barr' s leave was possibly from March to June of 1990 and Ms. Elliot began leave in the summer of 1993 after Ms. Daudlin returned. Ms. Carruthers did not dispute that Mr. Bushell replaced Ms. Barr while she was on leave and receiving Workers ' Com- pensation benefits from December of 1989 to March of 1990 and while she was on maternity leave from March to June of 1990. She did not dispute that Mr. Bushell had worked under conse- cutive contracts from December of 1989 to March of 1991 and that Ms. Hammond worked under contracts in 1992 and replaced Ms. Pepper while she was on leave of absence. In re-examina- tion she said that Ms. Pepper attended a university course while on leave, and agreed that that was a leave of absence without pay, to which the employer felt Art. 12.06 applied. She explained in cross-examination that when she said that Art. 12 .06 applied only to personal leave of absence, she meant that it applied only to leave without pay, a leave where the employee "would just go off and do something on their own for any reason, personal leave of absence" . She said that she did not consider maternity leave a personal leave of absence, but considered it instead a leave with pay, but not a leave of absence. She agreed that "Art. 12.06 is mandatory" where the leave of absence without pay exceeds 4 weeks . 11 Ms . Carruthers said that during the negotiations leading to the February 14 , 1991 local Memorandum (Ex. 2 ) , the em- ployer had rejected the proposal to change the word "may" to "shall" . Its explanation at the time was that it had suffi- cient part-timers to fill those leaves and did not need to go on a contract basis . The employer rejected the union' s ini- tial proposal of a new Art. 4.05 because it had sufficient part-time employees to utilize and had already implemented it a few times and found it very difficult, and had decided to continue to utilize part-time people "on a random basis" . She agreed that the employer had done a few contracts between 1989 and 1991, because the article said "may" and therefore left it at their option, although the employer does not have to. She said not all full-time leaves of absence were con- tracted out to part-time employees between 1989 and 1991. The employer tried contracts for a few years, found it wasn't working out, and returned to using part-timers on a random basis . The decision to put a part-time employee on a con- tract to fill a full-time employee's leave of absence had been made by Mr. Duffield when a part-time employee requested such a contract, but it was always the employer's option to exercise or not. The problem that arose was that after a part-time employee on a temporary full-time contract had been working for 3 months, they were entitled to benefits through London Life, and very. often they would be put on benefits and their contract would expire before London Life had processed their application, and it was frustrating both her and London Life, and the employer decided it wasn't working out. She acknowledged that the employer had taken the position stated in Ex. 10 throughout the 1991 - 1992 round of negotiations. In cross-examination Ms. Carruthers said that other records had to be adjusted when an employee went from part- to full- time, and "when the union started to demand it, Mr. Duffield said I guess it ' s time to stop it" . By "on a random basis" she meant that part-time employees ' are called from their 12 seniority list, called a "fallback sheet" , to replace full- time employees on their open shifts, if they are available. Ms. Carruthers said that the employer contributes to the Unemployment Insurance premiums and that employees on mater- nity leave receive Unemployment Insurance benefits. Employees on maternity leave receive a taxable benefit while on leave in the form of the employer's contribution to their London Life and Unemployment Insurance premiums. An employee on maternity leave would be aware of having received a taxable benefit during the leave when they received their T4 slip. In cross-examination, Ms. Carruthers said that Art. 12 .06 is applied when a person is granted personal leave of absence without pay for a period exceeding 4 weeks, and that the. words "leave of absence without pay" do not include all leaves of absence without pay. She said that when the em- ployer had used a contract, it had done so under Art. 12.03. She agreed that Art. 12 .03 was first agreed to in the Febru- ary 14, 1991 local Memorandum of Settlement (Ex. 2 ) . She agreed that her evidence had been that the employer had used contracts to replace full-time employees on leave of absence from 1989 to 1991, that she had usually replaced a full-time employee. on leave of absence with a part-time employee, and that the vacancies caused by full-time employees on leave were called open shifts on the schedule. She acknowledged that Ms. Hammond and Mr. Bushell had possibly worked on seve- ral contracts between 1989 and 1991, and that she had said that the employer had done the odd one or two contracts over that period. She agreed that in filling an open shift, the employer must follow the criteria in Art. 37 .05 in the local Memorandum of settlement dated February 14, 1991. Art. 37 .05 provides: 37 .05 Where an open shift exists, or a replace- ment is needed the following procedure shall be followed: ( 1) the hours shall first be offered to part- time employees, by seniority, until 13 either the opening is filled, no part- time employee is available, or all part- time staff have been scheduled for twen- ty-four (24 ) hours. (2 ) If after step ( 1 ) there are hours still to be filled, it shall be offered to available full-time employees, by seniority. (3 ) If after step (2 ) there are hours still to be filled, they shall be re-offered to part-time employees as in Step ( 1 ) until all part-time staff have been scheduled for forty (40) hours. (4 ). If none of the above steps result in the filling of the shift, scheduling shall be at the discretion of the Company. (5 ) For the purposes of this Article the fol- lowing shall apply: a) Shifts may be split into four (4 ) or Five (5) hour segments, b) Where a number of shifts are avail- able, all will be offeres (sic) , not just the first shift available. C) Every employee shall have a minimum of seven (7 ) hours off between shifts. (7 ) It is the responsibility of each employee to refuse any shift violating conditions in number (5) above. (8 ) Where an error has been made following the open shift protocol in Articles 37 . 05 ( 1 ) , (2 ) and (3) , the employer will dis- cuss the error with the steward and com- pensate the employee by offering to him the next mutually agreed available shift. The Union's Arguments: The employer has violated Art. 12 .06. The evidence of three union members was that the practice has been not to put up a posting, but to ask the part-time employees if they were interested. The union contends not that the employer is re- quired to post, but that it must ask the part-time employee 14 with the highest seniority to take the position, and that was what the employer had been doing. The language in Art. 12 .03 covers a leave of absence ex- ceeding one week and up to 4 weeks under Articles 12, 13 or 38, and is discretionary. Where a leave of absence exceeds four weeks, in all cases of leave of absence without pay, the employer must appoint the most senior part-time employee to fill the full-time position. Mr. Ferris testified that two employees were on materni- ty leave. Article 13.01 of the collective agreement states that maternity leave shall be governed by the Employment Standards Act and regulations and that the employer shall maintain benefits for the period covered by Unemployment In- surance benefits. S. 35 of the Employment Standagds Act says an employee is "entitled to a leave of absence without pay" , i.e. it says that maternity leave is a leave of absence with- out pay. As a result, Art. 12.06 requires the employer to replace an employee on maternity leave by giving a part-time employee a temporary full-time contract. S. 42( 1 ) of the Em- ployment Standards Act indicates that an employee continues to participate in each benefit plan unless she elects not to do so. Art. 13.01 of the agreement requires the employer to maintain the bnefits of an employee on maternity leave. The grievor was at the top of the part-time seniority list on June 16, 1993 when she grieved. She was entitled to fill in for Ms. Daudlin. The evidence established that that was the practice. Ms. Carruthers ' evidence as to the four employees who had taken maternity leave indicated that one leave occurred before Ms. Hammond was hired, and there was no evidence as to the language of the contract at that time. Ms. Carruthers confirmed that Mr. Bushell replaced Ms . Barr while she was on maternity leave from March to June of 1990, and that he replaced her during other periods. Ms. Elliot ' s maternity leave commenced after this grievance was filed. At the time of the July 1, 1992 Knopf award there was no allegation of abuse or improper assignment, which Arbitrator 15 Knopf states on page 7 of her award. Mr. Bushell and Ms. Hammond testified that they had filled in for a number of full-time people on contract for many different reasons . The absence of specifics in their evidence does not mean these contracts did not occur. The employer has the record and could have produced them, but chose not to. As the negotiating history regarding 1995 occurred after June 16, 1993, the date of the grievance, the negotiating history is not relevant to this case and should be given no weight. Mr. Ferris ' evidence regarding the negotiating his- tory is that in negotiations the union has attempted to change the language in Art. 12 to reflect the employer' s practice, and as a matter of housekeeping, to move the matter from Art. 12 to Art. 4 which deals with filling vacancies. The employer has argued that replacing a full-time em- ployee with a part-time one on contract caused difficulties. The language in Art. 37.05 of the February 14, 1991 local Memorandum requires the employer to strictly follow its terms when replacing open shifts . It must first offer the shifts to part-timers on the basis of seniority, if they have less than 24 hours in a week. If all part-timers have more than 24 hours, the open shifts are offered to full-time employees. If after having offered the open shifts to full-time emplo- yees open shifts still remain to be filled, the employer must return to part-time employees who work over 24 hours, and they are paid at time-and-a-half. Full-time employees who work over forty hours a week are also paid at time-and-a- half. The employer must follow that process each time it is arranging schedules. Replacing a full-time employee for his/ her entire leave with a part-time employee on contract is an easier process than the Art. 37 .05 process. Due to the re- quirement to pay at the overtime rate in Art. 37 .05, the cost could be greater for the employer by using Art. 37 .05 to replace full-time employees on leave of absence than to offer a contract to a part-time employee. 16 Ms. Carruthers ' evidence regarding difficulties with the insurance company is irrelevant and should not determine why the employer does not follow Art. 12.06. There is no ambiguity in Art. 12 . 06; the language is clear. If there is an ambiguity, it is latent, one not appa- rent on its face, but in its application. The evidence de- monstrated that Art. 12 .06 has been used to cover a number of absences including maternity leave and has established a past practice of the employer. Estoppel sould also be applied in this case. The employer filled these vacancies with a full- time contract to the most senior part-timer. One party by word or conduct has acted in a manner such that the other party has relied on it. Although Ms. Carruthers said the employer filled those vacancies with contracts to the most senior part-timer as a favour, the language of Art. 12 .06 made the employer's actions mandatory. Art. 12 .061says the employer must offer a temporary full-time contract in all cases of leave of absence without pay. The Employment Standards Act says maternity leave is a leave of absence without pay. The employer's past practice was to replace employees on maternity leave with full-time contracts until 1993, at which time they chose not to do so any longer. The union did not accept the position that the employer was not required to do so and filed the grievance. The union requests a finding that the employer has vio- lated Art. 12.06, that Ms. Hammond should have replaced Ms. Daudlin during her maternity leave which exceeded 4 weeks, that Ms. Hammond be compensated for the money she would have earned during that period, i.e. the difference between what her earnings as a part-time employee and what she could have earned for the full-time hours she could have worked, plus interest on the difference, and that the arbitrator remain seised with respect to implementation. 17 The Employer' s Arguments: The language in the collective agreement is clear and supports the employer' s position. The only mandatory con- tract situation arises when there is a leave of absence with- out pay. It does not support a maternity leave of absence being filled with a contract. In the alternative, the collective agreement is ambigu- ous, and the negotiating history can be considered. A consi- deration of .the negotiating history and the two interest ar- bitration awards will result in the employer's view being preferred. If there is any estoppel, it operates against the union rather than the employer. Art. 12.03 and 12.06 deal with two entirely different situations. There are separate components. Art. 12.03 deals with a leave of absence in excess of one week arising under Arts. 12, 13 and 38. Art. 12.06 deals with leave of absence without pay. Art. 12 is headed "Leave of Absence" , but it deals with leave of absence without pay at 12.01, and with union leave at 12 .05, which is also a leave of absence without pay. The scheme of Art. 12 is to deal with two kinds of leaves of ab- sence without pay. In the original collective agreement (April 1, 1988 to March 31, 1989 - Ex. 1) , Art. 12.06 referred to leave of ab- sence without pay. Art. 12.06 was contained within Art. 12 . Art. 12 dealt directly with personal and union leave. Art. 12.03 in the February 14, 1991 local Memorandum refers to Art. 13, which deals with maternity leave. Maternity leave is leave of absence with pay, and is to be distinguished from personal leave without pay in Art. 12 . Art. 38 deals with sick leave, and is an employer-funded sick leave credit pro- gram. While an employee is on leave, he receives sick leave credits. If the sick leave credits are not used, an employee can cash it in at the end of the year. If the sick leave creedits are used up, the employee can go on short- or long- 18 term disability benefits . The employer pays the employee for each day of absence up to a maximum in relation to his banked sick leave credits . There is no difference in any of those programs on the issue of funding; the employer pays the insu- rance premiums and the sick leave credit. Unemployment Insu- rance, Workers ' Compensation, short- and long-term disability are all employer-funded programs. One case indicates that a person receiving money from those sources is on leave of absence with pay. Art. 12.03 deals with one leave of absence without pay situation, i.e. Art. 12 leave, and Art. 13 and 38, which are leave of absence with pay. Under Art. 12 .03, in all three kinds of leave, the employer has a discretion where the leave exceeds one week; the proviso is not mandatory. At most, the union' s case falls within Arta 12 .03, and the union can ask the employer to consider it. The employer is exercising the discretion it is entitled to exercise. Art. 12.06 should be contrasted to Art. 12 .03. Art. 12 .06 does not refer to the three articles referred to in Art. 12.03. In Art. 12 .06, the circumstances are limited to a so-called leave of absence without pay. Art. 12.06 is the only article that uses the term leave of absence without pay. It does not use the terms maternity, Workers ' Compensation, short-term disability leave of absence. That wording shows up only in negotiations. Art. 12.06 simply refers to leave of absence without pay. The concept "without pay" means the individual receives no monetary or any other pecuniary remuneration. A person on maternity leave receives Unemployment Insurance benefits and benefits under the collective agreement. The concept "with- out pay" must be distinguished from the concept of "wages" . The union wants "without pay" to be read as "without wages" . "Wages" is narrower than "pay" . The terms "wages" appears in Art. 39, which states "all payment of wages shall be made in accordance with the wage rate set forth in Shedule 'A' here- to. . . to Schedule A, which contains the wage grid, does not 19 include benefits . Within this collective agreement, the con- cept of wages is strictly the person' s hourly rate, but "wag- es" is not "pay" . In this collective agreement, "pay" goes beyond "wages" . "Pay" in this agreeent covers the welfare and pension benefits in Art. 40, the life insurance benefits found in Schedule B, and the short- and long-term disability benefits found in Scheule BB. Art. 5 deals with the concept of "pay cheques" and receipt of "pay" and the collective agreement refers to taxable benefits. The concept of pay in labour relations includes payment for holidays, vacation, call-in and stand-by pay, severance pay and Workers ' Compensation. Where the parties wanted to say leave-of-absence with pay or with penefits, they provided that wording. Art. 9 deals with compassionate leave as a leave of absence with pay. Art. 10 deals with attendance in court. Art. 11 provides for leave of absence with full pay for education and training courses where the Ontario Ministry of Health pays the Company all costs relating to such cour- ses, and leave of absence without pay and without loss of seniority or benefits for writing examinations for relevant training programme courses. Art. 14 deals with paternity leave. where the parties meant leave without pay, they said , that, and Art. 12 .06 refers to leave without pay. In JBG Management Inc. and C.U.P.E. , Local 2040 ( 1987 ) 30 L.A.C. (3d) 101 (Haefling) , the arbitrator equated all amounts paid to an individual as pay. In that case, Workers ' Compensation benefits were included as pay. Regardless of the source, where the employer pays a premium, the leave is "with pay" . In ,JBC the employee sought vacation pay while on Workers ' Compensation benefits. The board had to determine gross annual earnings, and considered what gross earnings meant. At p. 104, supra, the board noted a series of cases which indicated that "gross pay" included previous vacation pay, and at p. 110 it indicated that all compensation consti- tutes "pay" . Unemployment Insurance and Workers ' Compensa- tion benefits are statutorily required insurance programs. 20 Both are part and parcel of the concept of "pay" , which JBG equates to be "all compensation and benefits" . Northern Electric Employee Ass 'n, Unit 4, and Northern Eelctric Co. Ltd. ( 1962 ) 13 L.A.C. 60 (Reville) says the same thing as JBG, that pay is not just wages, but all money bene- fits. The Northern board had to interpret the word "earn- ings" and determined that it meant wages and other pecuniary benefits bargained. OPSEU is arguing that pay does not in- clude everything they have negotiated over the years. The board should consider both Knopf interest arbitra- tion awards and the fact that the union' s proposal of Art. 4.05 was rejected in both awards. The language is clear. Art. 12.03 and 12.06 cover different situations. Ms. Hamm- ond's situation falls within Art. 12.03, not Art. 12 .06. Maternity leave is a benefit with pay. Alternatively, the board may determine that the term "leave of absence" is ambi- guous as to what it includes, or that leave of absence with- out pay includes maternity leave. The ambiguity can be latent or patent. With regard to the negotiations, the union's first pro- posal of a new Art. 12 .03 included reference to Art. 13, which is maternity leave, and included the word "shall" . It would not make logical sense for the union to want to negoti- ate an Art. 12.03 which really mirrors Art. 12.06 except for the time frame. The union's initial proposal contemplated Art. 12 .06 would remain the same as in the collective agree- ment, so two scenarios were considered in Art. 12 .03, i.e. Art. 12 leave without pay, and Art. 13 and 38, which were leaves with pay. The union's proposal was watered down from "shall" to "may" because the employer did not want a situa- tion where all those types of leaves resulted in a contract position. The employer resisted that proposal as far back as the 1989 negotiations. The union revisited the same situa- tion in a new Art. 4.05 in the 1991-1992 negotiations. Mr. Ferris agreed that the employer resisted the union' s proposal for the reasons set out in its brief (Ex. 10) and in cross- 21 examination acknowledged that the employer disputed the exis- tence of any clear practice and held that position during the negotiations. Although the union suggested to Arbitrator Knopf that its Art. 4.05 had been the practice for the past two years, in cross-examination Mr. Ferris said that Art. 4.05 expanded the rights held by the union under Arts. 12 .03 and 12.06. The union was seeking a contract replacement for those on maternity leave of absence in the 1992 set of negotia- tions, which is what they are seeking of this board. The employer flatly rejected this request in 1992 and it was re- jected by Arbitrator Knopf. The union is seeking in a rights arbitration what it did not get in interest arbitration. The fact that they are seeking it in a rights arbitration indi- cates that they did not already have it. The union's proposal for the 1995 negotiations (Ex. 9, p. 16 ) indicates that the union was again seeking its pro- posed Art. 4.05, this time with Parental and Pregnancy Leave, rather than maternity leave. In 1995 the union advanced its position in its brief, Ex. 13, and its submissions are set out in the 1995 Knopf award, and at pp. 2 - 4, Arbitrator Knopf accepted the employer's arguments and rejected the union's demands. The union requests you to find a long-standing practice. The board should consider Brown & Beatty regarding Extrinsic Evidence, Negotiating History, and Past Practice, and stan- dards of evidence. The evidence of Mr. Ferris, Mr. Bushell and Ms. Hammond indicates there has been insufficient prac- tice, and the evidence is insufficient to allow the conclu- sion that the union' s interpretation is correct. The third criteria referred to at p. 3-54 in Brown and Beatty, "acqui- escence in the conduct which is either quite clearly express- ed or which can be inferred from the continuance of the prac- tice for a long period without objection" was not met. The evidence of past practice covers a short period and must be over several years and a few contracts. 22 Mr. Ferris acknowledged in cross-examination that Arts . 12.03 and 12 .06 do not include Workers ' Compensation leave. Art. 12 .03 and 12 .06 read together do not cover maternity leave exceeding 4 weeks any more than they cover Workers ' Compensation leave. Nothing in Art. 12 .06 supports the dis- tinction Mr. Ferris gave to Ms. Hammond, that she did not have a grievance regarding a Workers ' Compensation leave, but had one for a maternity leave. The board should dismiss the grievance on the basis of ambiguity. The parties placed a clear and unambiguous interpretation on it both at negoti- ations and at interest arbitration. In Beatrice Foods Inc. and R.W.D.S.U. . Loc. 440 ( 1994 ) , 44 L.A.C. (4th) 59 (MacDowell) , the union argued estoppel and claimed that an overtime premium was payable for both statu- tory holidays and hours actually worked. Arbitrator McDowell spoke of estoppel having to be a long-standing practice, and of the employer having to give notice to the union of the in- tention to stop the practice, failing which as estoppel would arise due to detrimental reliance. In this case, there was no employer representation from 1989 to 1995. The employer has resisted the notion of a mandatory_contract and has never lead the union to believe it would agree to that. From 1989 to 1995 the employer opposed an inclusion in the agreement regarding contracts during leaves and took the position that there was no practice and would not give that right, as a result of which the union was aware from square one that the employer would not agree to this right in the agreement. Evidence was provided by two of 45 to 50 full-time and 30 part-time employees. The grievor said she would not know whether she was substituting for someone on leave when she was assigned to open shifts and did not know what the em- ployer' s practice was. Mr. Bushell had a contract for only a portion of the maternity leave. Mr. Ferris ' evidence was hearsay and anecdotal. Ms. Carruthers ' evidence, that even while offering contracts, they were also replacing employees on the open shift method, was uncontradicted. There was ne- 23 ver a practice of assigning contracts to every leave of ab- sence of full-time employees . If any estoppel arises, it is against the union, as the employer had a long-standing practice to assign part-time em- ployees to open shifts as it saw fit. Mr. Ferris ' evidence and the documentary evidence shows that the union at no point asserted that it had the right to post a contract for a full- time leave of absence. The employer detrimentally relied upon the union's silence. The fact that s. 35 of the Employment Standards Act uses the words "leave of absence without pay" does not require this board to interpret the collective agreement on the terminology in the Act. The parties used the words "with pay and "without pay" in various articles in the agreement. The board should look within the collective agreement for the agreement's own schemes. The parties used the terms they meant in the various articles. The union argued that there was a latent ambiguity and that Art. 12.06 was used to cover a number of absences. There is no evidence that Art. 12 .06 was used on any document to cover any of the situations that the union alleges. Ms. Car- ruthers said it was her business to know who was on leave, and there was never a practice of handing out a contract for any other circumstances, and that was not contradicted by the evidence of the union' s witnesses. If compensation is ordered, interest is inappropriate in this situation. The grievance should be dismissed on all grounds. , The Union's Reply: The employer does not pay an employee on maternity leave of absence. The Employment Standards Act should not be ignored. Benefits are not paid to an employee while she is on maternity leave. "Pay" means wages only. Unlike this case, JJJQ is as Workers ' Compensation case. Employees do not contribute to 24 Workers ' Compensation premiums, but they do to Unemployment Insurance Premiums . The union does not argue that earnings from Unemployment Insurance would not be considered part of "gross annual earnings" , but they are not pay from the em- ployer. As Northern Electric does not deal with the same issue, it is not relevant. Unemployment Insurance payments are earnings, not pay. Sick leave credits are earned by an employee, who must work to earn them. Employees receive only 6 sick leave cre- dits per year, and if they are absent in excess of 6 days, they are absent without pay. Therefore, sick leave under Art. 38 can be a leave of absence without pay. The employer narrowly interprets Art. 12 .06 as applying only to union and personal leaves. Art. 12 .03 refers to ma- ternity leave and Art. 12.06 says "in all cases" . As Ms. Carruthers ' evidence was that contracts were given as early as 1989, and as Art. 12.03 was not negotiated until 1991, the contracts she referred to were given under Art. 12 .06. There were only two maternity leaves of absence during the time the board is asked to review, one for which Mr. Bushell was given a full-time contract, and the other is the subject of this grievance. The practice occurred over a long " period, from 1989 to 1992 or 1993, and went through at least two rounds of negotiations. Two of the union' s witnesses were part-time employees from the top of the seniority list who would be those most affected by the full-time contracts. The employer' s submissions regarding an estoppel have been raised here in argument for the first time and should therefore be given no weight. Interpret only the articles in question in reference to the Employment Standards Act, rather than the entire collective agreement. It would be appropriate to award interest on compensation the grievor lost. 25 Considerations : At p. 110, in JBG, supra, Arbitrator Haefling stated . . . I agree with the general; proposition that "gross annual earnings" must be taken as referring to amounts received by employees as "pay" . . . .It is apparent that the word "earnings" used alone is wider in scope than the term "wages" , but that the latter is more commonly used to refer to the specific periodic remuneration an employee re- ceives for hours, days and weeks actually worked. . . .it is clear that most other arbitrators have considered the wider term "earnings" , unless it is qualified and made more restrictive, as being ca- pable of including "all compensation which is re- ceived by an employee by way of pay The foregoing, upon which the employer relies, inter- prets "earnings" in a context quite different from "pay" or "without pay" in relation to leave of absence and is of limi- ted usefulness in resolving this dispute. Arbitrator Reville construed the term "earnings" in Nor- thern Electric, supra, and concluded at p. 73: It is the opinion of this board that the term [earnings] is not ambiguous and is only susceptible of one meaning, namely all wages and other pecunia- ry compensation payable to an employee by reason of the provisions of the collective agreement under which he works and binding on him, his union, and the company for whom he works. That being so, this board is of the opinion that the inclusion or ex- clusion of the word "total" or the phrase "total annual" in connection with the word "earnings" is quite immaterial and, in fact, is redundant. . . . As Arbitrator Reville did not interpret the expression "with pay" or "without pay" , his remarks are also of limited assistance in resolving this dispute. What must be determined initially is whether the parties in this case intended, by utilizing the term "leave of ab- sence without pay" in Art. 12.06 to have included or excluded leaves of absence wherein an employee received Unemployment Insurance maternity benefits and the benefit of the employer maintaining its contribution to an employee' s benefits while on maternity leave. 26 The employer argues, essentially, that the term "pay" is equivalent to the term "earnings" and must be construed as in JJJQ and Northern Electric, supra. The union argues that the parties intended maternity leave to fall within the parties ' intended meaning of the phrase "leave of absence without pay" in Art. 12 .06 because Art. 13 indicates that maternity leave "shall be governed by the Employment Standards Act and regu- lations" , and s. 35 of the Employment Standards Act states that a pregnant employee "is entitled to a leave of absence without pay The first approach to be taken is an effort to determine the expressed intention of the parties in the words they have used in their collective agreement and Memoranda of Settle- ment. If their expressed intention can be determined from their words without an ambiguity arising, it will not be necessary to consider the evidence of past practice and nego- tiating history. In determining the meaning the parties gave to the words they used in their collective agreement, the ordinary meaning should be applied to those words unless an absurdity would result. The Oxford Encyclopedic English Dictionary (Clarendon Press: Oxford, 1991) defines "pay" as "wages; payment" . It defines "wage" as " (in sing. or pl. ) a fixed regular payment, usu. daily or weekly, made by an employer to an employee, esp. to a manual or unskilled worker (cf. SALARY) " . It defines "salary" as "a fixed regular payment, usu. monthly or quarterly, made by an employer to an employee, esp. a pro- fessional or white-collar worker (cf. WAGE n. 1 ) " . It defines "payment" as n. 1 the act or an instance of paying. 2 an amount paid. 3 reward, recompense. Thus, there are two ordinary meanings of "pay", i.e. "wages" , which specifies the employer as the payor, and "pay- ment" , which is more generic and does not designate the employer as the source of payment. 27 The employer' s position as argued is that essentially, any payment received by an employee while s/he is on leave, to which the employer has contributed, directly or indirect- ly, removes it from the description "leave of absence without pay" within the meaning of Art. 12 .06 . An employee on maternity leave is entitled to up to 17 weeks of Unemployment INsurance benefits, and the employer has contributed to the premiums for those benefits . The ordinary meaning of "pay" as "payment" would support the employer's position as it would remove maternity leave from the description "leave of absence without pay" . The ordinary meaning of "pay" as "wages" would bring maternity leave within the description "leave of absence without pay" as argued by the union. In view of this conundrum, it may be helpful to consider the provisions of the entire collective agreement in which the terms "leave of absence with pay" , "without pay" , or as otherwise modified, appear with a view to determining whether there is a scheme in the parties ' use of these terms in vari- ous articles which will assist in interpreting their inten- tion in respect of the term "leave of absence without pay" in Art. 12.06. ARTICLE 9 - COMPASSIONATE LEAVE 9.01 In the case of a death in the family of an employee, being father, . . . the Compa- ny shall grant a leave of absence, with pay, for a maximum of three (3 ) scheduled working shifts. . . . 9.02 In the case of a death in the family of an employee, being spouse, . . . the Compa- ny shall grant a leave of absence, with pay, for a maximum of five (5)working shifts. . . . 9.03 In the case of serious illness in the im- mediate family of an employee, the Com- pany may grant a leave of absence, with pay, for a maximum of three (3 ) scheduled working shifts. . . . 28 9.04 In the case of a death in the non-immedi- ate family of an employee, the Company shall grant a leave of absence, with pay for one ( 1 ) day . . . 9 .05 In the case of a death contemplated by this Article, an employee, being in charge of required funeral arrangements, shall be granted a leave of absence, with pay, for a maximum of three (3 ) scheduled workings shifts . . . ARTICLE 10 - ATTENDANCE IN COURT 10. 04 An employee, who attends Court, in mat- ters in which such employee has an inte- rest, shall on giving under the circum- stances, reasonable notice, be granted leave for such attendance. Such leave shall be without pay, but without loss of benefits or seniority. 10.05 An employee, who is jailed, pending a court appearance, shall be on leave of absence, without pay, during such period. ARTICLE 11 - EDUCATION MATTERS 11 .01 In all cases, where the Ministry of Health . . . pays to the Company all costs relating to education or training cour- ses, an employee shall be entitled to a leave of absence, with full pay, for such purposes. 11.05 Upon seventy-two (72 ) hours notice, in writing, by any employee required to write examinations for any courses, as hereinbefore mentioned, such employee shall be entitled to a leave of absence, without pay, and without loss of senio- rity and without loss of benefits. ARTICLE 12 - LEAVE OF ABSENCE 12 .01 An employee may be allowed a leave of absence, without pay, for personal rea- sons, if: 12 .03 -Where the company has granted a leave-of- absence in excess of one ( 1 ) week, under 29 Article 12, Article 13 or Article 38 of this Agreement, the position may be filled by temporarily appointing the most senior part-time employee to fill the full-time position for the duration of the leave. 12 . 05 (a) UNION LEAVE - An employee shall be allowed leave of absence without pay for attendance at Union meetings/ . . . (b) Where an employee is elected or appointed to a full-time position with the Union . . . he shall be granted leave of absence without pay for the duration of such appointment 12.06 The company agrees that in all cases where an employee is granted leave of ab- sence without pay for a period exceeding four weeks, that the position will be filled by a temporary full-time posting. ARTICLE 13 - MATERNITY LEAVE 13.01 Maternity leave . . . shall be governed by The Employment Standards Act, and regula- tions thereto. Benefits coverage shall be maintained by the employer for such period of maternity covered by U.I.C. maternity benefits. ARTICLE 14 - PATERNITY LEAVE 14.01 An employee whose wife, or common-law wife is about to deliver a child shall be granted one day' s leave of absence, with pay, to attend the delivery. ARTICLE 38 - SICK LEAVE AND SICK LEAVE CREDITS 38:02 The parties agree that employees with monetary credits to their pre-1974 sick leave bank, when absent due to illness, shall cash those credits . . . in Art. 11.01 the parties used the term "full pay" , and in Art. 9 and 14 refer only to "with pay" . As one canon of construction, expressio unius, exclusio alterus, views the mention of "full pay" in Art. 11 as implying its exclusion in Art. 9 and 14, it may be concluded that by using the term 30 "with pay" rather than "full pay" the parties intended that the employee receiving Art. 9 and 14 leave was to receive less than full pay. Fortunately, that is a point I am not required to decide in this proceeding. By the same canon of construction, because the parties expressly stated in Art. 10.04 and 11 . 05 of "leave without pay" , and "but without loss of benefits or seniority" in Art. 10.04 and "and without loss of seniority and without loss of benefits" in Art. 11.05, it may be concluded that where the term "leave without pay" or "leave of absence without pay" is found, unmodified, that unmodified term implies the loss of both benefits or seniority. Maternity leave as described in Art. 13 specifies that the employer will maintain the bene- fits coverage. Art. 13 says that maternity leave will be governed by the Employment Standards Act. S. 42 (4) of the = states "seniority continues to accrue during pregnancy leave. . . " . It appears, then, that although the parties expressed their intentions somewhat differently in Art. 13, they intended Art. 13 maternity leave, Art. 10 ..04 court leave, and Art. 11.05 examination leave to have the same consequences regarding seniority and benefits. However, what they intended by "pay" in each of these articles i.e. whether they meant "wages" , or "payment" , is another matter. The parties stated in Art. 13 that maternity leave will be "governed by" the EmRl_oyment.. Standards Act. They did not state that it would be "defined by" that Art. They did not refer to Art. 12. 06 in Art. 13. Consequently, I conclude that by their reference to the Act, they meant that the em- ployee's entitlement e.g. duration of leave, source of re- placement of wages, effect on seniority and benefits, etc. , would be determined in conformity to whatever the Act pro- vided from time to time, subject to any greater benefit, if any, provided in the collective agreement. Neither the court leave in Art. 10.04, the "jail leave" under Art. 10.05, the examination/education leave in Art. 11. 05, nor "personal leave" under Art. 12.01 are covered by 31 any plan for the replacement of "wages" , e.g. an insurance benefit. Thus, I conclude that in Art. 10.04, 10 .05, 11.05 and 12 .01, in using the term "without pay" , the parties meant "wages" . That does not in itself exclude the possibility that for the purpose of Art. 12.06 they also intended the meaning "payment" . While on union leave "without pay" under Art. 12 .05 (a) or (b) , an employee might be eligible for payment from the union. That payment would not arise under any scheme or plan under the collective agreement. It seems probable that both parties would have recognized the likelihood that an employee on extended union leave would receive payment from the union. Thus, it seems likely that in Article 12.05, by "leave of absence without pay" the parties were also referring to "wages" paid by the employer. In Art. 9, regarding compassionate or bereavement leave, the collective agreement refers to "leave of absence, with pay" . The collective agreement provides no insurance or other scheme to replace the employee' s wages; the employer continues to pay the "wages" or "salary" of the employee despite his or her absence. In this context, "pay" means "wages" or "salary" . In Art. 14, regarding paternity leave, the parties contemplated a one day "leave of absence, with pay" . Again, as the collective agreement provides no insurance scheme or other scheme to replace the employee's wages, the employer pays the employee 's regular "wages" for the day. I therefore conclude that in Art. 9 and 14, the parties used the term "with pay" meaning "wages" . In Art. 38, sick leave credits constitute a "pay" or wage replacement scheme for employees "absent due to ill- ness" . The February 14, 1991 local Memorandum indicates that the parties agreed that each employee would receive 72 hours of sick leave credits under Art. 38.01 on the first of the month following their initial employment and thereafter on April 1 of each succeeding year of employment. Unused sick leave credits as of March 31 of any year are to be paid out. 32 Art. 40.01 indicates that full-time employees are entitled to coverage under the Welfare and Pension Benefit Plan on the first of the month after completion of 3 months and refers to Schedule "BB" , which indicates that the short-term disability benefit commences on the 4th day for sickness and on the 1st day for accident or hospitalization. Thus after 3 months of employment there appears to be a "pay" or "wage" replacement plan available for employees "absent due to illness" . From the first month of the month following the start of his/her full-time employment and until the end of the third month, a newly-hired full-time employee "absent due to illness" would receive up to 72 hours of "pay" or "wages" as a result of sick leave credits. Once those credits were used, if further sick leave was required, that portion of the leave would be "without pay" . The apparent intention is that in all cases, except for those hired within 3 months of the onset of the illness, an employee "absent due to illness" would be "absent with pay" in the form of either wages, sick credits, or short- or long-term disability benefits. The parties did not, however, refer to absence due to illness as "leave with pay" in their agreement or Memoranda. The language in Art. 38 is consequently of limited assistance in determining the meaning of leave of absence without pay in Art. 12 .06. I conclude then, that in Art. 9, 10, 11, and 14, when the parties used the terms "leave with pay" and "leave with- out pay" they were referring to "wages" or "salary" paid by the employer. It is only in the context of Art. 12 .06 that it is suggested that the meaning of "pay" or "without pay" extends beyond "wages" to include"payments" under wage re- placement plans such as Workers ' Compensation or Unemployment Insurance benefits. Although in some agreements "pay" has been construed as including all earned benefits, such inter- pretation has arisen from the particular language of the par- ticular agreement. 33 The Decision: Having reviewed all the provisions of this collective agreement and 1991 Memorandum, and particularly the articles employing the phrase "leave of absence" with the phrases "with pay" and "without pay" , I am unable to conclude that there is an ambiguity as to the meaning of "pay" or "without pay" . It is therefore not necessary to consider the evi- dence of past practice and the negotiating history, which was admitted subject to my determination as to whether there was indeed an ambiguity. I conclude that in the context of this agreement and the February 14, 1991 local Memorandum, by "leave of absence without pay" in Art. 12 .06, the parties meant a leave of ab- sence without "wages" paid directly by the employer. I con- clude on the language of the agreement and the Memorandum that they did not intend to exclude leaves of absence excee- ding 4 weeks where the employee on leave received payment(s ) from other sources, notwithstanding that the employer may have contributed in whole or in part to the premiums that funded a wage replacement scheme. I therefore conclude that the employer breached Art. 12.06 when it declined to place Ms. Hammond on a temporary full-time contract to replace Ms. Daudlin while she was on maternity leave. I am not persuaded by either party's arguments that either of them have made out the elements of an estoppel. The grievance therefore succeeds. I therefore direct the employer to pay Ms . Hammond the difference between her part-time earnings and the amount she would have earned had she been assigned to Ms. Daudline ' s full-time hours, with interest. I will remain seised with respect to implementation of this award. By way of a postscript, the evidence suggested that part-time employees may not always be aware of a vacancy 34 created by a full-time employee on a leave of absence without pay in excess of 4 weeks . In view of the parties ' mutual agreement not to physically post a notice of the vacancy left by a full-time employee on a leave without pay of 4 or more weeks, the union and the employer may wish to consider advis- ing one another, promptly, in writing, of the intention of any full-time employee to take such a leave of absence, as soon as either learns of it, so that each may advise the most senior part-time employee of the vacancy. Dated at Toronto this 9th day of November, 1995. Susan D. Kau ;Vice-Chair