HomeMy WebLinkAbout2013-3431.Policy.14-02-24 DecisionCrown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB#2013-3431
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Amalgamated Transit Union - Local 1587
(Policy) Union
- and -
The Crown in Right of Ontario
(Metrolinx - GO Transit) Employer
BEFORE Mary Lou Tims Vice-Chair
FOR THE UNION Katherine Rowen
Ursel Phillips Fellows Hopkinson LLP
Counsel
FOR THE EMPLOYER Amanda Hunter
Hicks Morley Hamilton Stewart Storie LLP
Counsel
HEARING February 19, 2014
- 2 -
Decision
[1] I have before me a policy grievance dated January 16, 2014 alleging that the Employer
violated the parties’ collective agreement and the Labour Relations Act, 1995 (“the Act”) in
denying the Union’s request for unpaid leave for members “to participate in 2014 contract
negotiations.”
[2] There were no objections regarding my jurisdiction or the arbitrability of the grievance.
[3] Union Counsel advised by way of background that the Union initially filed an unfair labour
practice complaint under the Act. Such complaint was withdrawn and the parties agreed that the
present dispute would be determined through an expedited arbitration process.
[4] The grievance arises under the parties’ 2011 – 2014 collective agreement. Article 5.6 is the
key provision and states as follows:
ARTICLE 5 – LEAVE – UNION ACTIVITIES
. . .
5.6 Leave of absence shall be granted to a member of the Union (exclusive of all full-
time union officials) with no loss of pay, vacation credits, seniority or benefits subject to
the following conditions:
(a) Not more than three (3) employees at any one time for any one set of
negotiations.
Not more than two (2) employees are absent on such leave (i.e.
negotiations) at the same time from a section;
(b) Not more than one (1) employee shall be permitted such leave for any
one set of interest arbitration or Union/Management meetings;
(c) a request must be made in writing and approved at least two (2) weeks
prior to the commencement of the date or dates for which leave is
requested, if possible.
The Employer may, in its discretion, grant a leave of absence without pay to three (3)
additional members of the Union for the purpose of participating in negotiations
(emphasis added) provided such leave does not interfere with the continuance of efficient
operations of the Employer. Any such leave shall be subject to the conditions
hereinbefore set out.
- 3 -
Any leaves of absence granted hereunder shall be without loss of vacation credits,
seniority or other benefits to the employees granted such leaves.
[5] The parties disagree on the proper interpretation of the words “participating in negotiations”
and specifically whether preparation for negotiations is encompassed therein.
[6] The Union asks me to find that “participating in negotiations” includes “preparing” for
negotiations.
[7] In the Employer’s submission, I should reject such assertion and should find that
“participating in negotiations” includes only attendance at “face to face” negotiation meetings
between the parties after formal notice to bargain has been given.
[8] In addition to addressing the issues necessary to determine the grievance before me, the
parties both also invited me to offer “guidance” to assist them in applying the disputed language
on a “go forward” basis.
[9] The parties did not call viva voce evidence, but agreed on the relevant facts underlying the
grievance. They filed and relied upon an Agreed Statement of Facts from which I quote as
follows:
1) Background and the Parties
1. The Applicant, Amalgamated Transit Union, Local 1587 (“Local 1587”) is a trade
union pursuant to the Labour Relations Act, 1995 and is the exclusive bargaining agent
for, amongst other groups, a bargaining unit of employees of GO Transit (“GO Transit”).
GO Transit, which is a division of Metrolinx, provides regional public transit service in
the Greater Toronto and Hamilton areas.
2. Local 1587’s bargaining unit at GO Transit is composed of approximately 1,856
employees, who work in a wide range of different positions and at various facilities
throughout the region.
3. Local 1587 and GO Transit have a mature bargaining relationship, and have concluded
collective agreements over numerous successive rounds of bargaining. The term of the
parties’ current collective agreement runs from June 2, 2011 to June 1, 2014.
2) The Union’s Preparations for Bargaining
4. The bargaining of a collective agreement with advantageous terms and conditions of
employment is one of the primary means by which Local 1587 represents its members.
In light of the size and complexity of the employer’s operations, as well as the size of the
- 4 -
bargaining unit, collective bargaining between the parties is a complicated, detailed and
time-consuming process.
5. In order to ensure appropriate representation of its members, through meaningful and
productive bargaining with the employer, Local 1587 typically undertakes extensive
preparations for contract negotiations. This preparation may include communication with
the membership, meetings of the bargaining committee to determine bargaining priorities
and strategy, and a variety of other confidential union activities.
6. Local 1587 has already begun preparations for negotiations for a renewal collective
agreement, which will likely commence in Spring 2014.
3) The Collective Agreement Union Leave Provisions Regarding Negotiations
. . .
4) Specific Facts Leading to the Dispute Between the Parties
8. On Friday October 18, 2013, Local 1587 President Dan Harris emailed David
Doherty, Human Resources Consultant at Metrolinx, with the following request:
Subject: PLURS – Catherine Borrens & Lesley Witt – UNION BUSINESS
Please make the necessary arrangements to have Catherine Borrens and Lesley Witt taken
off their work for October 30th and 31st, 2013.
9. Ms. Borrens and Ms. Witt are both Union Stewards. . . .
10. The acronym “PLUR” stands for “Paid Leave Union Reimbursed,” which means that
the employer will pay the member directly, and then bill the Union, which in turn
reimburses the employer for the union leave.
11. On the same day, October 18th, 2013, Mr. Doherty responded as follows:
“What is the nature of the union business? How does it fit within Article 5?”
12. In response to Mr. Doherty’s email, Mr. Harris responded that:
“The Union requires Ms. Borrens and Ms. Witt for contract preparations.”
13. On or about October 25, 2013, Local 1587 Vice-President Jim Boyd spoke to David
Doherty who advised that the employer was denying the leave request.
14. On or about October 28, 2013, Dan Harris spoke to Mr. Doherty on the telephone
and advised that on October 30th and 31st, 2013, Ms. Borrens and Ms. Witt would be
undertaking tasks related to bargaining preparation.
- 5 -
15. Mr. Doherty advised that he was denying the request for leave on the basis that such
leave was not for “actual negotiations” and was, therefore, not covered by article 5.6 of
the collective agreement.
16. Mr. Doherty did not indicate that workload, staffing or other operational demands
precluded the granting of the request.
17. Following the conversation, Mr. Harris phoned Catherine Borrens to advise that the
company would not release her from work on October 30th and 31st, 2013. Ms. Borrens
called Mr. Harris back on October 29, 2013 to advise him that her shift for October 30,
2013 had already been covered by management. Nonetheless, based on his conversation
with Mr. Doherty, Mr. Harris advised Ms. Borrens that she should work her shift on
October 30th, 2013 as originally scheduled.
[10] The parties stipulated as an additional fact that there are three members excused from their
duties to serve as full-time Union officials for this bargaining unit.
[11] Before turning to the submissions of the parties, I note two points. First, although the Union
characterized the leave in issue here as “unpaid” by the Employer, Employer Counsel noted that
article 5.6 provides that such leave is “without loss of vacation credits, seniority or other
benefits.” Subject to the Union’s objection that there was no evidentiary basis upon which to
base such assertion, the Employer also suggested that overtime costs could be incurred in
granting such leave. While Counsel did not regard this as material for purposes of deciding the
issue before me here, she clarified that the Employer does not view the granting of leave as cost
neutral.
[12] Second, although the Agreed Statement of Facts suggests that the Union understood the
leave requested to be “Paid Leave Union Reimbursed,” the Employer noted that article 5.6,
unlike certain other provisions of article 5, does not state that the Union will “reimburse the
Employer . . . for such employees’ wages.” Again, Counsel were both clear, however, that any
difference between the parties on this point need not be addressed here.
[13] The parties referred to the following provisions of the collective agreement in addition to
article 5.6 here in dispute:
ARTICLE 4 – GRIEVANCE PROCEDURE
. . .
4.11 Time spent during their normal working hours by Union representatives and
grievors in processing grievances in accordance with the terms of this Article shall be
- 6 -
without loss of regular wages or benefits up to and including Step 2 of the grievance
procedure. . . .
ARTICLE 5 – LEAVE – UNION ACTIVITIES
5.1 The Union shall notify the Employer in writing on or before July 1st in each election
year or whenever changes take place of the names of its representatives as follows:
officers, Bargaining Committee members, Union Management Committee members,
stewards, and health and safety representatives.
. . .
5.3 The Union/Management Committee shall meet once every two months. . . . Should
such meetings go beyond the employees’ normal paid hours, such further time will be
without pay.
. . .
5.4 (a) The Union shall have the use of bulletin boards . . . for the purpose of posting
notices relating to the Union’s business. . . .
5.7 Leave of absence without pay to attend Union conventions, seminars, grievance
arbitration, or mediation shall be granted to a member of the Union who actually
participates in such conventions, seminars, grievance arbitration, or mediation provided
that such leave does not unduly interfere with the continuance of efficient operations by
the Employer. However, any leaves of absence granted hereunder shall be compensated
by the Employer and shall be without loss of vacation credits, seniority, or other benefits
to the employee granted such leave. The Union agrees to reimburse the Employer every
two pay periods for such employees’ wages.
Such leave shall be subject to the following conditions:
(a) not more than three (3) employees at any one time shall be permitted such
leave;
(b) no one such leave shall extend beyond ten (10) working days;
(c) the maximum number of days granted hereunder shall not exceed sixty (60)
for each year of the contract, not including mediation or grievance arbitration;
(d) not more than two (2) employees are absent on any such leave at the same
time from a section;
(e) not more than one (1) employee for mediation or grievance arbitration; and
(f) a request must be made in writing and approved. . . . Such request shall state
the particulars of the function to be attended. . . .
5.8 Leave of absence without pay to attend Executive Board meetings shall be granted to
a member of the Union who actually participates in such Executive Board meetings,
provided that such leave does not unduly interfere with the continuance of efficient
operations by the Employer. . . .
- 7 -
Such leave shall be subject to the following conditions:
(i) No more than one (1) meeting per month;
(ii) no more than six (6) board members at any one time shall be permitted
such leave;
(iii) in January of each year, the Union shall provide the Employee Relations
Consultant with the schedule of such meetings. . . .
5.9 . . .
Specifically, while the Union Contract does not address access to facilities, the grievance
procedure . . . does allow for attendance of ‘a member of the Local Union Executive or
Union Steward at each step of the grievance procedure.’ Irrespective the full-time Union
incumbents will have other business to conduct from time to time and it is agreed that
such representative may have reasonable access to facilities and Union members.
However, it is expected that even such pre-determined access to GO Transit premises will
normally be preceded by notification of same. . . .
5.10 (a) Local 1587 Union Officers elected to occupy full-time Union positions acting
solely for Local 1587 shall be granted leaves of absence . . . .
(b) Where a Union official is elected or appointed to a Union term of office, a leave of
absence shall be granted without loss of seniority and without pay or benefits subject to
the aforementioned paragraph. . . .
ARTICLE 9 – CLASSIFICATION AND JOB EVALUATION PROCEDURE
. . .
9.4(2) Composition and Roles of Technical Committee
. . .
4. Leave of Absence
4.1 While representing the Union or Management at Technical Committee meetings,
employees shall be considered on an approved leave of absence with pay, provided that
meetings are held during their normal scheduled work day or hours on that day.
Members will not be on paid leave for any reason, if attendance is on their day off. No
payment of premiums or overtime shall be paid which would normally have been paid if
it had not been for the member’s attendance at the Technical Committee.
9.4(3) Composition & Roles of Steering Committee
. . .
5. Leave of Absence
- 8 -
5.1 While representing the Union or Management at Steering Committee Meetings,
employees shall be considered to be on an approved leave of absence with pay, provided
that meetings are held during their normal scheduled work day or hours on that day.
Members will not be on paid leave for any reason if attendance is on their off day. No
payment of premiums or overtime shall be paid which would normally have been paid if
it had not been for the member’s attendance at the Steering Committee Meeting.
. . .
ARTICLE 11 – HEALTH AND SAFETY
. . .
11.13 . . .
PAYMENT FOR COMMITTEE MEMBERS
A member of the JHSC shall be deemed to be at work while performing JHSC duties
prescribed herein . . . and shall be paid by the Employer . . . .
MEETING AGENDA
. . .
4. Worker Members of the JHSC shall be provided a minimum of one (1) hour
preparation time prior to each regularly scheduled meeting of the JHSC. . . .
ARTICLE 43 – TERM OF AGREEMENT
43.1 This agreement shall commence on the 2nd day of June 2011 and shall end at
midnight on the 1st day of June 2014 and shall continue thereafter from year to year
unless either party gives notice in writing to the other party during the last one hundred
and two (120) (sic) days of the term of this agreement of that party’s intention to
terminate or negotiate revisions thereto. . . .
[14] Union Counsel suggested that two issues must be addressed here. First, she argued that
article 5.6 should be interpreted in such a manner as to encompass preparation for negotiations.
Second, Counsel asked me to conclude that, on the evidence before me, the Employer failed to
exercise its discretion as required by the collective agreement.
[15] Turning to the first of the two issues, the Union took the position that the Employer’s
interpretation of the disputed language is unduly restrictive, unreasonable and incorrect at law,
- 9 -
and is intended to or has the effect of interfering with the Union’s ability to represent its
members.
[16] The Union relied upon the evidence that the bargaining of a collective agreement with
advantageous terms and conditions of employment is one of the “primary means” by which the
Union represents its members. It noted that this is a large bargaining unit and that collective
bargaining between the parties is “a complicated, detailed and time-consuming process.”
Counsel emphasized the evidence that the Union “typically undertakes extensive preparations”
for bargaining and that such preparation may encompass communication with members,
meetings of the bargaining committee and a variety of other “confidential union activities.” In
the Union’s submission, there can be no meaningful negotiations without such preparation.
[17] The Union argued that arbitrators generally favour a broad, liberal and purposive
construction of Union leave contractual provisions and that there is a general arbitral
“reluctance” to interpret such language in a manner that interferes with the Union’s ability to
fulfill its representational functions. In the Union’s submission, the broad approach that it urges
upon me is particularly warranted where the leave in issue is paid by the Union.
[18] Union Counsel reviewed and relied upon a number of authorities which she suggested
reflect the generally accepted arbitral approach to the interpretation of contractual provisions for
Union leave: United Automotive Workers and Kelvinator of Canada Ltd. (1968), 19 L.A.C. 307;
International Union of Machinists, Local 1246 and Franklin Manufacturing Co. (Canada) Ltd.
(1971), 23 L.A.C. 230; Leamington District Memorial Hospital and Service Employees’ Union,
Local 210, [1976] 13 L.A.C. (2d) 30; Children’s Aid Society of Huron County and Canadian
Union of Public Employees, Local 1427, [2003] O.L.A.A. No. 157; Kelowna (City) and
Canadian Union of Public Employees, Local 338, [1982] B.C.C.A.A.A. No. 2; ATCO Lumber
Ltd. and Industrial Wood and Allied Workers of Canada, Local 1-405, [2001] B.C.C. A.A.A. No.
231; and Corporation of the Borough of Etobicoke and Canadian Union of Public Employees,
Local 185, [1981] 30 L.A.C. (2d) 289.
[19] Union Counsel acknowledged that the contractual language considered in such cited
authorities differs from that before me, in that it provides for Union leave “with respect to a
- 10 -
Grievance,” or for such purposes as the “processing” or “handling” of grievances,” or “to attend
Union meetings and Union conventions.”
[20] Counsel argued, however, that what she characterized as a broad and liberal interpretative
approach applied by arbitrators therein is equally fitting in the circumstances before me. In the
Union’s submission, arbitrators recognize that Union representation of members through the
“handling” or “processing” of grievances is a “core Union function” and that contractual leave
provisions negotiated by the parties in relation to such role should be broadly construed. In the
Union’s further submission, when assessing the scope of contractual Union leave language
related to such Union activity, arbitrators “look at the whole activity” and refuse to draw rigid
distinctions between segments or phases of the activity involved. Counsel argued that the
negotiation of a collective agreement is also a “core Union function” and that leave provisions
associated with that role, should be similarly construed in a broad and purposive manner,
accepting that participation in negotiations necessarily encompasses preparation for negotiations.
[21] Counsel further suggested that the arbitrator in Leamington District Memorial Hospital,
supra, articulated a lower threshold for the Union to meet insofar as he upheld the grievance
before him on the basis that a Union official’s attendance at arbitration was “an aspect” of
“handling grievances” ( para 7). Although Counsel argued that article 5.6 construed in the broad
purposive manner which she suggested is reflected in the authorities supports the Union’s
position here, she asserted that preparation for negotiations must at the very least be properly
viewed as “an aspect” of “participating in negotiations.”
[22] While the Union suggested that the arbitral authorities addressed above are instructive in
setting out the accepted approach to assessing the scope of Union leave language, Counsel also
relied upon the decision in 544 Holdings Ltd. and United Food & Commercial Workers
International Union Local 1518, [2001] B.C.C.A.A.A. No. 277, a case which she suggested is
“on all fours” with the case before me. Article 19 (a) of the collective agreement there provided
in part that “employees . . . shall be given time off without pay in order to . . . participate in
negotiations involving the Employer.” The grievor was a member of the Union’s bargaining
committee. Bargaining between the parties commenced in April 2001, and further bargaining
sessions were scheduled for June and July 2001. The Union requested leave for the grievor to
attend the negotiation sessions scheduled for June, and such request was granted and booked.
- 11 -
The June bargaining dates were then cancelled, but the Union maintained its request for leave for
the grievor for those dates. The Employer denied such request, giving rise to the grievance. The
arbitrator found that “the union was entitled to persist in its request for time off, in order to have
the grievor assist in tasks reasonably related to negotiations.” (para 61)
[23] The arbitrator further commented as follows:
In summary, what happened was that Dean Jesperson (the grievor) was scheduled to be
off work for negotiations, pursuant to a request of the union. Leave was granted and his
time off was booked. Negotiations were then cancelled, but the union continued to make
its request for the leave. I find that this was a request for leave which prima facie, still
fell within the parameters of Section 19 (a) of the collective agreement. While
negotiations were cancelled, this was the time during which bargaining had already
started, and further dates were scheduled in July. It was not unreasonable for the union to
continue to wish to have the assistance of Mr. Jesperson with respect to the task of
negotiating with the employer, and as Mr. Archibald [Employer Counsel] conceded, there
are a number of activities which could fall broadly within the activities described as
‘participating in negotiations involving the employer’ other than actual attendance at the
bargaining sessions. (para 52)
[24] The Union asked me to follow this decision, noting that the language in issue there
incorporated a qualifier not before me, that time off was to be granted to participate in
negotiations “involving the Employer.” Counsel urged me to construe article 5.6 in the same
broad and purposive manner adopted by the arbitrator in 544 Holdings Ltd. and to find that
participating in negotiations encompasses preparing for same within the meaning of the language
before me.
[25] Union Counsel referred as well to the decision in Newfoundland and Labrador Health
Boards Assn. and Newfoundland Association of Public Employees, [2004] N.L.L.A.A. No. 42,
suggesting that the contrast between the contractual language in issue there and that before me
here is instructive. The collective agreement considered in Newfoundland and Labrador Health
provided that “leave with pay shall be awarded to employees who are members of the
Negotiating Committee while they are attending actual negotiating sessions….” In the Union’s
submission, this is the very sort of language required before the “rigid and narrow” interpretation
of the contractual language urged upon me by the Employer is justified.
[26] Turning to the second issue raised by the Union, Counsel argued that once the Union has
established that the “activity claimed” comes within the scope of article 5.6, the evidentiary onus
- 12 -
then shifts to the Employer to provide an explanation as to why the requested leaves were denied
and to demonstrate that such denial was reasonable. In the circumstances before me, I am asked
to find that the Employer failed to exercise its discretion in the manner required by the collective
agreement.
[27] The Union referred to and relied upon the following authorities: Sault Ste. Marie General
Hospital and S.E.I.U., Loc. 268, [1993] 36 L.A.C. (4th) 154; British Columbia (Workers’
Compensation Board) and Compensation Employees’ Union, [1997] B.C.C.A.A.A. No. 451; and
Board of Health of the Haliburton, Kawartha, Pine Ridge District Health Unit and Ontario
Nurses’ Association, Local 106, [1998] O.L.A.A. No. 83.
[28] It asserted that it is incumbent on the Employer in the exercise of its discretion under article
5.6 to address and consider individually each application for leave. Relying on the decision in
Board of Health, supra, it argued that the Employer cannot act “perfunctorily and without the
required diligence to permit an informed conclusion” as to whether granting a requested leave
would “interfere with the continuance of efficient operations of the Employer.”
[29] The Union commented as well on balancing of interests in the context of a request for
Union leave pursuant to the collective agreement. It urged me to accept and follow the decision
in Sault Ste. Marie General Hospital, supra, where the arbitrator stated as follows:
The case-law makes clear that an employer must deal with each application for a leave of
absence individually, and balance its interest in efficient operation against the specific
interest of the grievor. . . . Under general leave provisions found in many collective
agreements, this balancing must take into account the reasons asserted by the grievor for
needing the leave. However, under specific union leave provisions . . ., the purpose of
the leave of absence need not be weighed in the balance since the parties have already
found attendance at designated union functions to be a valid purpose. . . . (para 29)
[30] In the Union’s submission, once accepted that preparation for negotiations is included
within the scope of article 5.6, it is not open to the Employer to inquire into the specifics of the
Union’s intended preparation. The Union noted the evidence that preparation for negotiations
may include “a variety of confidential Union activities,” and relied upon the cited authorities as
recognizing the importance of the confidentiality of the Union’s work. While the Union
accepted that the Employer’s inquiry to the Union in the circumstances before me as referenced
in paragraph 11 of the Agreed Statement of Facts was appropriate, it emphasized that the
- 13 -
Employer is limited to seeking such confirmation that the requested leave is for the purpose set
out in the relevant contractual provision.
[31] Applying such principles to the present case, the Union noted that article 5.6 is a
discretionary provision, subject to the Employer’s right to preserve efficient operations. What is
key here, in the Union’s submission, is that there is no evidence of operational reasons being
advanced by the Employer in denying the requested leaves, and nor is there evidence of abuse of
the provision by the Union. The Union urged me to conclude that the denial of the requested
leaves here was clearly arbitrary and thus unacceptable. The Union asked me to find that the
Employer did not meet its evidentiary burden to provide an explanation as to why the requested
leaves were denied.
[32] The Union therefore asked me to declare that the Employer violated the collective
agreement in denying the Union’s October 2013 requests for leave for Ms. Borrens and Ms. Witt,
and to order the Employer to grant leaves requested by the Union for all members participating
in 2014 negotiations. Counsel stated that the Union did not seek a finding here that the
Employer violated the Act, although such remedial claim is set out in the grievance.
[33] On the evidence before me, leaves of absence were requested for two dates in October 2013
to prepare for negotiations which “will commence in Spring 2014.” In 554 Holdings Ltd., supra,
the arbitrator considered whether store visits could be regarded as participating in negotiations,
and commented as follows:
I think it could, especially if the dates of the visits coincide with the period when
negotiations are either about to commence or are ongoing. (para 78)
[34] The question of timing was raised in these proceedings although the Employer was clear
that the timing of the leaves sought was not a factor in its denial of such request. The Union
acknowledged the theoretical possibility that a request for leave to prepare for negotiations not
taking place until a point far into the future could raise issues that the parties would need to
address. Counsel was clear, however, that this is not the case here where bargaining was to take
place “in fairly short order” and where timing did not enter into the Employer’s decision to deny
the requested leaves. In the Union’s view, any potential issue regarding timing would be more
appropriately addressed if and when it should arise.
- 14 -
[35] The Employer was clear that it denied the leaves of absence requested in October 2013
because, in its view, the Union failed to meet its burden of proving entitlement to such leaves
under the collective agreement. In the Employer’s submission, “participating in negotiations” as
referenced in article 5.6 does not encompass preparation for negotiations. Accordingly, given
what Counsel characterized as such “good faith difference in opinion” between the parties as to
what article 5.6 means, it did not proceed to “the next step” contemplated by article 5.6 and did
not exercise its discretion and consider the Union’s request which it viewed as falling outside the
scope of the language in issue.
[36] Accordingly, while the Employer stated that it did not disagree with the general legal
principles articulated by the Union regarding the parties’ rights and obligations in dealing with a
request for leave within the scope of article 5.6, Counsel did not address these in detail.
[37] The Employer stated that the Union’s right to engage in Union activity on Employer time is
a negotiated right and that ultimately, I must determine whether the parties agreed through article
5.6 that a leave of absence may, subject to the terms of the provision, be granted for the purpose
of preparing for negotiations.
[38] Counsel emphasized that article 5.6 must be construed in the context of the parties’
collective agreement in its entirety, and she suggested that such contextual consideration of the
disputed provision should lead me to reject the broad interpretation of “participating in
negotiations” urged upon me by the Union.
[39] Counsel noted and reviewed in some detail a number of contractual provisions negotiated by
these parties, including those set out above. She suggested as a general proposition that the
parties have clearly addressed specific entitlements for Union leaves and for access to Employer
property, and have delineated in express terms, their agreement regarding the parameters of such
entitlements.
[40] The Employer further emphasized three points. First, pursuant to article 5.6, there are three
full-time Union officials dedicated to serving this bargaining unit.
[41] Second, review of contractual provisions reflects that performance of Union business is not
always paid, and indeed, is not paid by the Employer unless this is negotiated. By way of
- 15 -
example, article 5.3 provides that where Union/Management Committee meetings extend beyond
an employee’s normal paid hours, “such further time will be without pay.”
[42] Further, the Employer asserted that the parties have turned their minds to the specific scope
of entitlements negotiated. It referred to article 11.13 which provides in part that “Worker
Members of the JHSC shall be provided a minimum of one (1) hour preparation time prior to
each regularly scheduled meeting of the JHSC.” In the Employer’s submission, where the
parties have agreed that leave will be provided not only for attendance at meetings of the Joint
Health and Safety Committee but also for purposes of preparing for such meetings, they have
specifically so stated. The failure to so provide in article 5.6 is therefore notable in this light in
the Employer’s submission.
[43] When considering the disputed language in the context of the collective agreement as a
whole and more specifically in light of the fact that there are three persons excused from their
duties to act as full-time Union officials, that performing work for the Union is in some instances
unpaid, and that the parties have been specific in providing leave for preparation time, the
Employer urged me to reject the Union’s argument that “participating in negotiations”
contemplates anything beyond attendance at face to face bargaining meetings between the parties
after formal notice to bargain has been given.
[44] Counsel addressed the arbitral authorities upon which the Union relies. She noted that a
number of such cases address language relating to the “processing” or “handling” of grievances.
While the Employer accepted that such “vague” words have been broadly interpreted by
arbitrators, she argued that this does not assist the Union in advancing a liberal construction of
the words “participating in negotiations” not otherwise justified in the context of the present
collective agreement.
[45] The Employer commented specifically on the decision in 554 Holdings Ltd., supra., and
noted that the leaves of absence in issue there were sought only after formal collective
bargaining had in fact commenced, with further dates scheduled. The Employer emphasized as
well that it does not concede here that “there are a number of activities which could fall broadly
within the activities described as ‘participating in negotiations involving the employer’ other
than actual attendance at the bargaining sessions” as did the employer there.
- 16 -
[46] The Employer emphatically disputed the Union’s assertion that the requested leaves here
were denied arbitrarily and that such denial interfered with the Union’s ability to fulfill its
representational functions. The Employer objected to any such inference being drawn from its
denial of the requested leaves. In its submission, denial of requested Union leave based on a
good faith difference in opinion as to the scope of article 5.6 cannot be equated with an effort to
interfere with the Union’s representation of its members. On the evidence before me, the
Employer argued that there is no basis upon which I can find any such intent or any actual
interference with the Union’s ability to fulfill its responsibilities to its members through the
denial of the requested leaves. Indeed, if Ms. Borrens and Ms. Witt wished to assist the Union in
preparing for negotiations, the Employer did nothing to prevent them from doing so, but merely
declined to release them from their duties based on its good faith interpretation of the governing
contractual language.
[47] The Employer also addressed timing. Counsel was clear that this was not a factor in the
denial of the leaves of absence giving rise to the grievance before me, and that, in the
Employer’s view, preparation for negotiations, whenever it takes place, does not constitute
“participating in negotiations” within the meaning of article 5.6. Counsel referred to article 43.1
of the collective agreement permitting either party to give notice to bargain during “the last one
hundred and two (120) (sic) days of the term of this agreement.” As an alternative position only,
the Employer suggested that if I accept the Union’s position that article 5.6 encompasses
preparation for negotiations, that I should at the very least limit that finding to preparation in
which the Union engages within the last 102 or 120 days of the collective agreement after formal
notice to bargain has been given. On the facts before me, Counsel noted that the leaves sought by
the Union were outside of this time and indeed before dates for bargaining were set, unlike the
circumstances considered by the arbitrator in 554 Holdings Ltd..
[48] The Employer asked that I address this issue of timing, and if prepared to accept the
contractual interpretation urged upon me by the Union, determine at the very least whether
October 2013 preparation for bargaining was captured by article 5.6. The Employer noted the
Union’s suggestion that any future issues related to timing should be addressed only if and when
they arise. The Employer argued that such approach is flawed, however, insofar as the Union
maintains that the Employer has no right to information as to the nature of the preparation
- 17 -
engaged in, but can merely ask for confirmation that a given leave of absence is requested for
reasons contemplated by article 5.6. In the Employer’s submission, therefore, it is not at all clear
at what point on a “temporal continuum” the Employer might be able to deny a request for leave
when the Employer is limited in the information and clarification that it can demand from the
Union.
[49] The Union addressed in Reply the contractual provisions canvassed by the Employer and
suggested that a fair inference to be drawn from such language, is that where the parties intend to
limit or qualify entitlement to leave, they have specifically done so. In the Union’s submission,
it is therefore notable that under article 5.6, entitlement to leave to participate in negotiations was
not qualified so as to apply only to attendance at bargaining sessions with the Employer.
[50] The Union commented in particular on the parties’ agreement set out in article 11.13 that
“worker members” of the Health and Safety Committee are to be provided with a minimum of
one hour preparation time prior to Committee meetings. The Union suggested that such
language relating to the Union’s participation on a joint committee is not aptly compared to
article 5.6 which addresses a core function of the Union to represent its members in collective
bargaining. Rather, in the Union’s submission, the arbitral authorities construing the scope of
negotiated Union leave provisions associated with the performance of such core Union functions
are more instructive in considering the disputed language before me.
[51] The fundamental dispute between the parties here relates to the scope of article 5.6 of the
collective agreement, and specifically, to the meaning of the words “participating in
negotiations.”
[52] Such language is properly construed in the context of the parties’ collective agreement as a
whole. In considering the various contractual provisions relied upon before me, it is fair
comment to note that the parties have addressed with some specificity Union leave of various
types in a number of enumerated circumstances.
[53] As pointed out by the Employer, there are three full-time Union officials available to service
the bargaining unit, pursuant to article 5.6. Further, it is clear from the collective agreement that
performance of work for the Union is not in all instances paid. Most notable, in my view,
however, is the fact that the parties have at least in article 11.13 expressly and specifically
- 18 -
provided for leave for Union members of the Joint Health and Safety Committee for preparation
prior to Committee meetings.
[54] Article 5.6, in contrast, does not expressly speak to preparation for negotiations. Notably in
my view, however, neither does it expressly reference attendance at face to face meetings with
the Employer or at “actual negotiation sessions” as was the case in Newfoundland and Labrador
Health, supra..
[55] The arbitral authorities referred to by the Union are of assistance in considering the
language in issue. I have considered in particular the decision in 544 Holdings Ltd., that the
Union asserted is on “all fours” with the case before me here. The arbitrator there accepted that
the Union was entitled “to persist in its request for time off in order to have the grievor assist in
tasks reasonably related to negotiations” pursuant to contractual language providing for “time off
in order to participate in negotiations.” I note, however, that the employer there conceded that
there are “a number of activities which could fall broadly within the activities described as
‘participating in negotiations involving the employer’ other than actual attendance at the
bargaining sessions.” The Employer before me makes no such concession, and indeed, it is this
very issue upon which the parties disagree.
[56] I am nonetheless satisfied, based on the authorities before me, that arbitrators have broadly
and liberally construed provisions for Union leave, at least when they have related to the
“processing” and “handling” of grievances. While I note the Employer’s suggestion that such
“vague” language invites a broad interpretation, I found persuasive the Union’s argument that
arbitrators considering such language have found it appropriate to view such core Union activity
broadly and not in a fragmented manner.
[57] I accept the Union’s submission that the negotiation of a collective agreement for its
members must be similarly regarded as a critical and core Union function. The evidence before
me establishes that the collective agreement in issue here covers a large bargaining unit, and that
given the size of the bargaining unit, and the size and complexity of the Employer’s operations,
collective bargaining between the parties is a “complicated, detailed and time-consuming
process.” I further note the evidence that “in order to ensure appropriate representation of its
members” in negotiations, the Union “typically undertakes extensive preparations.”
- 19 -
[58] Having considered such evidence, the submissions of Counsel, the language of the
collective agreement before me, and the arbitral authorities relied upon by the parties, I am
persuaded that the words “participating in negotiations” within article 5.6 should be broadly
construed as encompassing not only attendance at face to face negotiation sessions between the
parties, but preparation for such meetings as well.
[59] The Employer was clear in these proceedings that it did not so view article 5.6 and did not
understand it to contemplate Union leave for the purpose of preparing for negotiations. It was on
this basis that it denied the requests for leave giving rise to this grievance. This is reflected in the
evidence before me that the Employer’s representative advised the Union that the request for
Union leave was denied because such leave was not, in the Employer’s view, for “actual
negotiations,” and did not in its view therefore come within the scope of article 5.6.
[60] I find that the grievance must be upheld on this basis, in that I accept the Union’s argument
that preparation for negotiations is, in all of the circumstances before me, encompassed in the
language of article 5.6 providing for leaves “for the purpose of participating in negotiations.”
Insofar as the Employer acted on the basis of what I respectfully find to be an unjustifiably
narrow reading of the applicable language, and denied the October 18, 2013 Union request for
leave for Ms. Borrens and Ms. Witt, I find that it breached article 5.6 of the collective agreement.
[61] The Union argued that once it established that the activity for which it claimed leave came
within the scope of article 5.6, that the Employer bore an evidentiary onus to then explain the
basis upon which the requested leave was denied. The Employer was clear that because it did
not view the Union’s request for leave as coming within article 5.6, it did not proceed to exercise
its discretion to consider the request.
[62] The Union is correct in asserting that there is no evidence before me suggestive of abuse of
Union leave under article 5.6. Further, there is no dispute that the Union was not advised that
workload, staffing or other operational demands precluded the granting of the requested leave,
and I acknowledge the evidence that Ms. Borrens understood that management had in fact
covered her shift on one of the days for which leave was requested.
- 20 -
[63] The Union asked me to find that such absence of evidence of abuse or of operational
difficulties underscores the arbitrariness of the Employer’s denial of the requested unpaid leaves
which the arbitral authorities have indicated is unacceptable. It urged me to conclude that such
denial was intended to or had the effect of interfering with the Union’s ability to represent its
members.
[64]The Employer acknowledged that it did not exercise its discretion under article 5.6 to
consider the leave request, but denied that it acted arbitrarily in doing so, asserting that its failure
to address the requests was based on what I have found to be a misapprehension of the scope of
the contractual language.
[65] I accept and find that once the Employer received a request for a leave of absence within the
scope of article 5.6, it was required to exercise its discretion and to consider the request. I
therefore find that the Employer breached article 5.6 in failing to do so when the Union
requested October 2013 leaves for Ms. Borrens and Ms. Witt to engage in tasks “related to
bargaining preparation.”
[66] I am not satisfied, however, that the Employer’s failure to exercise its discretion in
accordance with article 5.6 is properly viewed as arbitrary, but rather, reflected what I have
found to be its overly restrictive view of the scope of the contractual provision in issue.
[67] Further, in such circumstances and in the absence of evidence establishing an intention to
interfere with the Union’s representation of its members or actual interference with the Union’s
representational role, I am not prepared to find that the Employer intended to interfere or in fact
interfered with the Union’s representation of its members through the denial of the Union’s
request for leave.
[68] Accordingly, for all of these reasons, the grievance before me is upheld. I find that the
Employer breached article 5.6 of the collective agreement in denying the Union’s October 18,
2013 requests for leave for Ms. Borrens and Ms. Witt for October 30 and 31, 2013, and I so
declare. I order the Employer to apply article 5.6 in accordance with this decision.
[69] As noted, the parties invited me to also offer “guidance” extending beyond the findings
necessary to determine the grievance, to assist in the future application of article 5.6. It is on
- 21 -
such basis that I offer the following comments which are not part of my Order herein. The
Employer was clear that it did not consider preparation for negotiations as encompassed within
the scope of “participating in negotiations” as contemplated by the said provision. The timing of
the leaves requested did not factor into the Employer’s decision to deny the Union’s request.
That said, the parties acknowledged a certain “temporal continuum” and addressed in some
measure whether work performed beyond a certain time period would be regarded as preparation
for bargaining. The Employer advanced as an alternate position in these proceedings that work
done prior to notice to bargain and outside of the time period contemplated in article 43 cannot
be characterized as “preparation for negotiations.” It asked me to specifically address whether
October 2013 Union preparation for expected but unscheduled Spring 2014 bargaining was
properly regarded as falling within the scope of article 5.6. I accept the Union’s position that it
would not be appropriate for me to purport to address with specificity what, if any, temporal
considerations may be relevant in the application of article 5.6 and I would not be inclined in
any event to presume to set a “hard and fast rule” absent consideration of relevant surrounding
circumstances. I note the evidence before me that collective bargaining between the parties is
complicated, and that the Union engages in extensive preparations for it. Even if I were to
assume, without finding, that there could be a temporal limitation on preparation for negotiations
within the scope of article 5.6, I would not in the circumstances before me view the leaves
requested in October 2013 as falling outside the scope of article 5.6 on such basis.
[70] The Union addressed in some detail its view of the parties’ respective rights and obligations
in the application of article 5.6 once Union leave within the scope of that provision is requested.
In further response to the parties’ mutual request for “guidance,” I note my agreement with the
general principles articulated by the Union. Specifically, a request for leave within the scope of
article 5.6 must be individually addressed and considered by the Employer with what the
arbitrator in Board of Health, supra, described as “the required diligence to permit an informed
conclusion” as to whether such leave would “interfere with the continuance of efficient
operations of the Employer.” In considering a request for Union leave, it should be noted that
the parties have, through the language of article 5.6, recognized participation in negotiations as a
valid purpose for such leave. The validity of leave for the purpose contemplated by the said
provision need not therefore be considered in a balancing exercise by the Employer. I further
note the evidence before me that “a variety of confidential union activities” may form part of the
- 22 -
Union’s preparation for bargaining and accept as a general proposition that a request for Union
leave for purposes of preparing for bargaining does not open the door for the Employer to
demand details of the Union’s confidential bargaining preparation.
[71] I thank Counsel for their very helpful submissions and for their cooperation in ensuring that
this grievance would be addressed and determined in an efficient and expeditious manner.
Dated at Toronto, Ontario this 24th day of February 2014.
Mary Lou Tims, Vice-Chair