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HomeMy WebLinkAboutMerlino 14-05-28IN THE MATTER OF AN ARBITRATION BETWEEN: ONTARIO PUBLIC SERVICE EMPLOYEES UNION, LOCAL 244 (the "Union") SHERIDAN COLLEGE OF APPLIED ARTS AND TECHNOLOGY (the "College ") AND IN THE MATTER OF THE GRIEVANCES OF DENISE MERLINO: LAYOFF GRIEVANCE (OPSEU 42013- 0244 -0003) AND RETRAINING GRIEVANCE (OPSEU #2013 -0244- 0005) (ACADEMIC) BOARD OF ARBITRATION COUNSEL: For the Union Robert D. Howe, Chair Sherril Murray, Union Nominee Ann E. Burke, College Nominee Rehecca Stulberg Tor the College Daniel Michaluk P R E L I M I N A R Y A W A R D The hearing of this matter was originally scheduled to take place on December 4, 2013, but was adjourned to January 21, 2014, on the agreement of the parties. On that rescheduled date, counsel agreed that the College's preliminary objection should be heard in writing. In accordance with that agreement, an Agreed Statement of Facts for Preliminary Objection (the "Agreed Facts ") was filed on March 10, 2014, along with the College's submission on the preliminary objection, followed by the Union's submission (which was filed on April 1, 2014), and the College's reply submission (which was filed on April 14, 2014). For ease of reference, a copy of the Agreed Facts is appended to this award, along with copies of those written submissions. Also appended are copies of the lay -off grievance, the referral of that grievance to arbitration, and their attached lists. (The contents of the other tabs referred to in the Agreed Facts have not been appended.) The Lay -off Grievance Having duly considered the Agreed Facts and documents referred to therein, as well as the aforementioned written submissions and the cases to which they refer, we have concluded that the lay -off grievance must be dismissed, for the following reasons. Article 27.08 of the parties' collective agreement (the "Agreement ") provides as follows: 1 Lay-Off Grievances 27.08 A An employee claiming improper lay -off, contrary to the provisions of this Agreement, shall state in the grievance the positions occupied by full -time and non -full -time employees whom the employee claims entitlement to displace. The time limit referred to in 32.01 for presenting complaints shall apply from the date written notice of lay -off is given to the employee. 27.08 B If the grievance is processed through Step 2, the written referral to arbitration in 32.02 shall specify, from the positions originally designated in 27.08 A, two full -time positions, or positions occupied by two or more partial -load or part -time employees (the sum of whose duties will form one full -time position), who shall thereafter be the subject matter of the grievance and arbitration. The griever shall be entitled to arbitrate the grievance thereafter under only one of (i), (ii), (iii), (iv), (v), (vi), or (vii) of 27.06 A. The grievor seeks to arbitrate her lay -off grievance under Article 27.06A(iv), which provides: Failing placement under paragraph 27.06 A (iii), such employee shall be reassigned to displace two partial -load employees provided that: (a) the displacing employee has the competence, skill and experience to fulfill the requirements of the position concerned; and (b) each of the the partial -load employees being displaced has lesser months of service with the College as determined under Article 26, Partial -Load Employees, than such displacing employee's months of seniority; and (c) It is understood that the College retains the right to assign additional work to the employee, where warranted, subject to the limits prescribed by Article 11, Workload. Article 27.08A requires an employee claiming improper lay -off to "state in the grievance the positions occupied by 2 full -time and non -full -time employees whom the employee claims entitlement to displace ". Where, as in the instant case, the employee seeks to have such a grievance arbitrated under Article 27.06A(iv), Article 27.08B requires that the written referral to arbitration specify, from the positions originally designated in 27.08A, positions occupied by two or more partial -load employees (the sum of whose duties will form one full -time position), who shall thereafter be the subject matter of the grievance and arbitration. In OPSEU and George Brown College (Grievance of Giovanni de Simone: OPSEU #94A770/94A767), unreported award dated December 29, 1995, the majority of an arbitration board chaired by Arbitrator Burkett found the requirements of Articles 27.08A and B to be procedural provisions which could be waived. However, in the preponderance of awards under a succession of collective agreements governing academic staff, that approach has not been applied, and the identification requirements set forth in those provisions have consistently been found to be mandatory substantive requirements which cannot be waived: see, for example, Re Fanshawe College and O.P_S.E.U. (1987), 6 C.L.A.S. 6 (Weatherill); OPSEU and Canadore College (Grievance of Frank Mueck), unreported award dated December 12, 1996 (MacDowell); Re Fanshawe College and O.P.S.E.U. (1997), 48 C.L.A.S. 351 (Simmons), application for judicial review dismissed in Ontario Public Service Employees Uion v. Fanshawe College, [1998] O.J. 4243 (Div. Ct.); Re Seneca College of Applied Arts and Technology and O.P.S.E.U. 3 (1998), 51 C.L.A.S. 32 (H.D. Brown); Re Fanshawe College and O.P.S.E.U. (1999), 58 C.h.A.S. 228 (Kaplan); OPSEU and George Brown College (Grievance of G. Waffle), unreported award dated December 24, 1999 (Howe); and Sault College and OPSEU (Crievances of Jason Von Slack, unreported award dated March 30, 2014 (H.D. Brown) . As noted in a number of those cases, the contract language in question has been maintained for many years, without material change, over numerous rounds of bargaining. Had the parties wished to avoid that interpretation, they could have amended that language. However, this has not occurred. Although the parties have changed the wording from "persons" to "positions ", that change had no effect on the mandatory substantive nature of the provisions' requirements. In this regard reference may usefully be made to the following passage from Arbitrator Simmons' majority award in Re Fanshawe College and O. P. S. E. U., supra: [14] Accordingly, we are of the view that the Macdowell board in Canadore [OPSEU and Canadore College (Grievance of Frank Mueck), supra] is diapositive of the issue that is before us. In referring to the Shime decision of St. Lawrence College [St. Lawrence College and On tar'i o Public Service Employees Union (Brown) , unreported award dated February 27, 19781 and the Weatherill decision in Fanshawe College [Fanshawe College and O.P.S.E.U., supra] Arbitrator MacDowell in the Canadore College decision stated at p. 10: These are admittedly old cases. But they are precisely on point, no contrary authorities were cited to us, and the language in question has been maintained, without material change, since 1987, over several rounds of bargaining. Had the parties wished to change the contract language to avoid the interpretation given by 4 arbitrators Shime and Weatherill, they could easily have do so. But they did not. On the contrary. Article 27.08B, as currently framed, merely reinforces the mandatory thrust of Article 27.08A; because 27.08E narrows the number of positions which can ultimately be the subject of arbitral review. The matters that can proceed to arbitration are a subset of the positions identified in Article 27.08A - which makes it all the more important for the grievor to identify the field from which the arbitrable subset is selected. In other words, the current structure reinforces the interpretation advanced by arbitrators Shime and Weatherill ten years ago. [15] In the St. Lawrence College case the grievor claimed that he had been laid off contrary to the terms of the collective agreement and was met with the employer's response that the grievance did not specify the persons whom the grievor sought to displace. In the Fanshawe College case the board of arbitration had to consider the propriety of a layoff and once again there was a problem because the grievor had not specified the names of the individuals whom he sought to displace. Since the St. Lawrence and Fanshawe decisions were released the parties changed the wording from "persons" to "positions" and this change was in effect when the Canadore College decision was made. The MacDowell board was of the view the change was of no material effect. We agree. The parties' support staff collective agreement contains a provision (Article 18.6.2.1) which requires an employee claiming improper application of that agreement's lay -off provision to "state in the grievance the position(s) and name of the incumbent, if any, to which the employee claims entitlement." It further provides that if the grievance is not resolved, "the written referral to arbitration shall specify, from the position(s) originally designated, no more than four (4) positions which shall thereafter be the subject matter of the grievance and the arbitration." Arbitrations under that collective agreement 5 have found that this language, which is substantially similar to the language in the academic Agreement so far as this issue is concerned, also imposes mandatory substantive requirements which cannot be waived. See, for example, OPSEU and Mohawk College, unreported award dated March 4, 2003 (Thorne); and Re Centennial College of Applied Arts and Technology and O.P.S.E.U., Loc. 559 {Middleton), [2007] O.L.A.A. No. 180, in which Arbitrator M.G. Picher wrote, in part, as follows in his unanimous award: [20] Leaving aside the jurisprudence, if this were a matter of first impression, we would find it difficult to avoid the conclusion arrived at by Arbitrator Thorne [in OPSEU and Mohawk College, supra], namely that the impact of article 18.6.2.1 is essentially to define the parameters of the grievance and, to that extent, the jurisdiction of the board of arbitration. By the language of the provision itself it is those four positions "... which shall thereafter be the subject matter of the grievance and arbitation." [21] From a purposive point of view the provision is readily understandable. The College should know, clearly and well in advance, the precise positions which will be the subject of the arbitration of a layoff grievance. While it was obviously open to the parties to use directory language with respect to the obligation to identify positions, in a turn of phrase which is unusual within the provisions of a collective agreement, they opted for what we must recognize as essentially jurisdictional language. For reasons they best appreciate they made the identifying of the four positions the governing factor in "the subject matter of the grievance and the arbitration "_ With respect, given the language the parties adopted, we do not believe that the failure to identify the positions at the time of the referral to arbitration can be fairly characterized as a merely technical deficiency or a minor oversight which can be subsequently cured. very simply, having regard to the language used by the parties, without a proper referral to arbitration there cannot be any arbitration, as the subject matter of the arbitration would remain undefined. [22] Apart from the foregoing analysis, we are satisfied that counsel for the College is correct in his submission that the jurisprudence gives overwhelming support to the College's position.. In the academic bargaining unit, since 1986, the clear preponderance of arbitration awards has held that the substantive requirement to identify the positions which will be the subject of arbitration is a substantive requirement which cannot be waived, the failure of which deprives a board of arbitration of any jurisdiction to proceed. The application of that principle in a number of grievances since the award of Arbitrator Burkett in the George Brown College case in 1995, through the renewal of a number of collective agreements, compels this Board to the conclusion that the parties must be taken to have understood and accepted the mandatory nature of the parallel provisions found in the collective agreement governing academic staff. As indicated by Arbitrator Kaplan in the majority award in Re Fanshawe College and O.P.S.E.U., supra, "a position means an existing job, whether full -time or otherwise, not a collection of courses that could, when combined, create full-time employment ". In that case, the grievance was being arbitrated under Article 27.06A(i), which provides that "[a]n employee will be reassigned within the College to a vacant full -time position in lieu of being laid off if the employee has the competence, skill and experience to perform the requirements of a vacant position." Counsel for the Union submits that a different standard is applied to identifying positions for grievances under Article 27.06A(iv). In support of that submission, she relies upon Lambton College and OPSEU (Grievance of W. Sayers), unreported award dated October 25, 1989 (Swan). In that case, Mr. Sayers, who was a welding instructor, grieved that he had been improperly laid off and contended that certain teaching assignments should be taken away from three 7 employees who were teaching less than full -time and put together for him as a full -time job made up of pieces of teaching previously done by them. At the time of that case, the layoff provision in the applicable collective agreement was Article 8.05, which provided, in part, as follows in Paragraph (d): (d) failing placement under paragraph (c) above, such employee shall be re- assigned to displace a partial -load employee (as referred to in Appendix II) or a part -time employee upon acceptance of the identical employment conditions as the partial -load or part -time employee concerned provided that: (i) the displacing employee has the compentence, skill, and experience to fulfill the requirements of the position relatively equal to the employee being displaced; (ii) the partial -load or part -time employee being displaced has lesser months of service with the College as determined in both Appendix 11 and IV than such displacing employee's months of seniority; Also germane to that award was the following Letter of Agreement: Letter of Agreement dated April 7, 1986: Re: Displacement of Partial -Load Emnovees This will confirm the advice given in negotiations that it is the College's intention that failing placement of a full -time employee who has completed the probationary period under Paragraph (d) of Section 8.05, the College will give reasonable consideration to the written request of a full -time employee about to be laid off to continue a full -time assignment by displacing two or more partial -load or part -time employees and the employee shall set out: (a) the names of such partial -load or part -time employees, each of whom have lesser continuous service with the College. Upon receipt of such written request, the College will consider the feasibility thereof taking in account I such features as: (b) possible reduction in efficiency, quality of performance or adverse effect upon the program objectives; and (c) the relative competence, skill, experience and suitability as demonstrated with the College to fulfill the requirements of the positions concerned_ In the majority award, Arbitrator Swan indicated that once Mr. Sayers received notice of lay -off and thereby became aware that he had not been placed under paragraph 9.05(d), he was entitled to make a "written request" pursuant to that Letter of Agreement. He also indicated that the written request could be given in the form of a grievance, or even in the form of a written referral to arbitration specifying the two or more partial -load or part -time employees whose duties were to be combined. He further indicated that once this had been done, the College was obliged to give reasonable consideration to combining those positions to avoid the lay -off, taking into account such considerations as those set out in the Letter of Agreement. Since they were not in possession of sufficient evidence to permit them to come to any rational conclusion on whether Mr. Sayer had more continuous service with the College than one of the employees whom he sought to displace, the board of arbitration remitted that issue to the parties (and indicated that the matter would be scheduled for continuation of hearing at the request of either party). Nothing in that award, nor in the "obiter comments" included in Arbitrator Simmons' majority award in Re Fanshawe 9 College and O_P.S.E.U., supra, obliges a college to "cobble together" courses in order to create a full -time position for a grievor facing layoff. Those obiter comments (made at the request of the parties, in response to their question of whether the employer was "obligated to combine lesser than full -time assignments to a regular, full -time position ") merely indicate that if Ms. Zurowski (who was the grievor in those proceedings) had filed her grievance under section 27.06A(iv) or (v) instead of under section 27.06A(i), Arbitrator Swan's decision in the Lam -bton College case would have been more persuasive in their decision (which dismissed the grievance because the grievor sought to be reassigned to a vacant full -time position in lieu of being laid off, but did not mention in her grievance any position being sought). However, the combination or "cobbling" contemplated in those awards is not a combination of courses to make a full -time position. What each of them contemplated is a combination of partial -load or part -time positions to make a full -time position. For the sake of completeness, it should also be noted that the above- quoted Letter of Agreement dated April 7, 1986, is not appended to the parties' current Agreement_ A letter of understanding originally dated November 28, 1989 (and now dated September 10, 2012) containing somewhat similar language is appended, but it pertains to displacement of part -time employees and is not being relied upon by the Union in support of the grievor's lay -off grievance. 10 In St. Lawrence College and OPSEU (Grievance of M. McCabe), unreported award dated May 28, 1997 (McLaren), the board of arbitration declined to consider a "composite position" which totalled only 12 hours of teaching per week, because it was less than a full load of between 13 and 18 hours, and because Article 27.082 precludes a lay -off grievance from being arbitrated under more than one of parts (i) , (ii) , (iii) , (iv) , (v) , (vi) , (vii) , and (viii) of Article 27.08A. However, the board of arbitration did consider the other designated position, which was a full -time vacant position. Unless there are unusual circumstances, in determining the duties of a position for purposes of arbitrating lay -off grievances under Article 27.08 arbitrators have generally confined their consideration to the teaching duties of the incumbent or incumbents in the academic term in which the lay -off takes place: see OPSEU and Fanshawe College (Grievance of Leslie Dobos), unreported award dated June 4, 1998 (Burkett) ; OPSEU and George Brown College (Grievance of G. Waffle), supra; and the cases referred to therein. There is nothing in the Agreed Facts which warrants a departure from that approach. In the instant case, the College provided the grievor with a notice of lay -off on January 9, 2013. Consequently, the pertinent teaching duties are those performed by the incumbents during the 2013 winter academic term. In the instant case, the "Grievance list" appended to 11 the lay -off grievance includes what purport to he three positions. There are five names listed in the "Faculty Name" column for "Position 111: Melissa Piccinin, Nicol Guerra, and [Karren] Boothroyd, who are partial -load employees; Tahir Kahn, who is a part -time employee; and the grievor, Denise Merlino, who was a full -time instructor in the College's Esthetician Diploma Program prior to her lay -off. The Winter 2013 courses listed for those employees in "Position i" are nine hours of HEAL13271G (Wellness & Healthy Living) for Melissa Piccini, three hours of that course for Nicol Guerra, six hours of that course for Tahir Khan, and four hours of COSM16952 (Product Knowledge Skin and Nails) for Denise Merlino. No course is listed for Karren Boothroyd for that term. Thus, the teaching hours listed for "Position 1" for the Winter 2013 academic term total twenty-two. Since Tahir Khan is a part -time employee, those six hours presumably constitute his full teaching load for that term. (See Note A of Article 1.01, which stipulates that persons employed on a part -time basis "include persons who teach six hours per week or less ".) Article 26.01B defines a partial -load employee as "a teacher who teaches more than six and up to and including 12 hours per week on a regular basis ". Ms. Piccini's nine teaching hours fall within those parameters. However, it appears that she may have been teaching more than those nine hours that term, as "Position #2" on the list attached to the referral to arbitration attributes twelve additional hours to her in respect of another course (NUTRI19207G [Nutrition for 12 Well Being]) for that term. Moreover, the three teaching hours ascribed to Ms. Guerra on the list attached to the grievance do not fall within those parameters; she would have to have been teaching at least four more hours per week in order to fall within the purview of that definition. As another partial load employee, Karren Boothroyd would also presumably have been teaching at least seven hours per week during that term. The four hours listed for the grievor would also obviously have constituted only part of her workload as a full -time instructor during that academic term. It is evident from the foregoing analysis that "Position #1" on the grievance list is comprised of a grouping of selected courses which constitute only part of the teaching Toad of some of the named faculty members. The same is true of "Position #2" and "Position 43" on that list, and of both "Position #1" and "Position 42" on the list attached to the referral to arbitration. On the basis of the foregoing arbitral jurisprudence, those cobbled bundles of selected courses are clearly not "positions occupied by full -time and non- full -time employees ", within the meaning of Article 27.08A, nor are they "positions occupied by two or more partial -load or part -time employees (the sum of whose duties will form one full -time position) ", within the meaning of Article 27.08B. The list attached to the referral to arbitration is also non - compliant with the Article 27.08B requirement that the positions be specified "from the positions originally 13 designated in 27.08 A". Neither of the purported positions on that list appear on the grievance's list of purported positions. "Position #1" on the referral list includes the first three names from "Position #1" on the grievance list (Melissa Piccin, Nicol Guerra and Tahir Khan), but omits the remaining two names (Denise Merlino and Karren Boothroyd). It adds the name of Joanna Bond (which is the second name listed in "Position 43" on the grievance list), but does not list any course for her during the Winter 2013 academic term. "Position #2" on the referral list includes three of the names from "Position 42" on the grievance list (Jacqueline Fraser, Peter Papadogiannis, and Penny Biles) but omits the Winter 2013 courses listed on the grievance list for Ms. Fraser (six hours of HUMN16693G [Human Relations, The Interpersonal Experience]) and for Mr. Papadogiannis (three hours of HUMN16693 [Human Relations, The Interpersonal Experience]). It also omits Sipa Chansavang, which is the fourth name included in "Position #2" on the grievance list, and adds Melissa Piccinin, for whom it lists twelve hours of NUTRI19207G (Nutrition for Well Being). As indicated above, the failure to "state in the grievance the positions occupied by full -time and non - full -time employees whom the employee claims entitlement to displace ", and the failure in the written referral to arbitration to "specify, from the positions originally designated in 27.08 A, two full -time positions, or positions occupied by two or more partial -load or part -time employees 14 (the sum of whose duties will form one full -time position), who shall thereafter be the subject matter of the grievance and arbitration ", are not mere procedural deficiencies which can be waived. They are failures to comply with mandatory substantive requirements which can neither be waived nor cured by subsequent particulars (see Seneca College of Applied Arts and Technology and O. P. S. E. U. , supra) Counsel for the Union also relies upon Plouin Drywall Contractors Ltd. v. United Brotherhood of Carpenters and Joiners of America, Local 2486, [1975] O.J. No. 31 (Ont. C.A) , in support of her submission that the grievance should not be inarbitrable because of undue technicality. The judgment of the Court in the case, delivered by Brooke J.A., includes the following oft- quoted observations (in paragraphs 10 and 11): ... No doubt it is the practice that grievances be submitted in writing and that the dispute be clearly stated, but these cases should not be won or lost on the technicality of form, rather on the merits and as provided in the contract and so the dispute may be finally and fairly resolved with simplicity and dispatch. Certainly, the board is bound by the grievance before it but the grievance should be liberally construed so that the real complaint is dealt with and the appropriate remedy provided to give effect to the agreement provisions.... As noted by Arbitrator Swan in St, Lawrence College and OPSEU (Grievances of M. Robitaille), unreported award dated February 4, 1997, at pp. 7 -8, those observations have been referred to in a number of College cases which permit reference to be made in argument to provisions of the Agreement not expressly set out in the grievance, but which 15 preclude a completely different ground from being raised for the first time at arbitration: As I read the cases, no arbitrator under this collective agreement has asserted that only those provisions of the collective agreement expressly set out in the grievance may be referred to in argument. Virtually all of the cases where arbitrators have refused to consider what they find to be an amendment to the grievance deal with circumstances where a completely different ground is raised for the first time at arbitration, rather than merely a different collective agreement support for the same ground. While we respectfully agree with the approach set forth in Blouin Drywall and applied in the arbitral jurisprudence, it cannot be used to cure a substantive jurisdictional defect in a grievance, such as a failure to "state in the grievance the positions occupied by full -time and non- full -time employees whom the employee claims entitlement to displace ", as required by Article 17.08A, or a failure to "specify, from the positions originally designated in 27.08 A, two full -time positions, or positions occupied by two or more partial -load or part -time employees (the sum of whose duties will form one full -time position), who shall thereafter be the subject matter of the grievance and arbitration ", as required by Article 27.08B. As indicated above, the preponderance of awards under a succession of collective agreements has quite consistently found those requirements to be mandatory substantive requirements which cannot be waived. Thus, a failure to comply with them is not a mere technical deficiency or minor oversight which can be subsequently cured. As stated by Arbitrator M.G. Picher in above - quoted passage from Re Centennial College of Applied 16 Arts and Technology and O.P_S_E.U., Loc. 559 (Middleton), supra, "having regard to the language used by the parties, without a proper referral to arbitration there cannot be any arbitration." For the foregoing reasons, the grievor's lay -off grievance is hereby dismissed. The Retraining Grievance The retraining grievance alleges that the College contravened Articles 27.06, 28.01, and 28.04 of the Agreement. The relief sought is "that the lay -off notice be rescinded and that the retraining mentioned in the articles above begin immediately for current courses as well as any curricula under development ". There are two aspects to that grievance. The first is the Union's contention that the College violated Article 28.01 by failing to enhance the griever's employment stability by retraining her in the years prior to her layoff when it knew that enrollment in her program was in decline. The grievance's second aspect is the Union's contention that the College violated Article 27.06(iii)(c) by failing to provide the grievor with retraining after she received notice of layoff. Article 28.01 provides as follows: Article 28 EMPLOYMENT STABILITY 28.01 A The parties hereto subscribe to certain objectives and principles as follows: (i) that employment stability should. be 17 enhanced, within the resources available, through both long -term and short -term strategies; (ii) that such strategies should include, but not necessarily be limited to, planning, retraining, early retirement, alternative assignments, secandments, employee career counselling, job sharing and professional development; (iii) that data which are relevant to employment stability should be made available to both parties; (iv) that procedures should be in place to deal with situations that arise in which, notwithstanding the best offcrts of both parties, lay -offs and /or reductions in the number of employees who have completed the probationary period become necessary; and, (v) that resources should be made available to achieve, to the degree that it is feasible, these objectives and principles. 28.01 B The parties have agreed to the following provisions, in order to achieve, to the degree that it is feasible, the foregoing objectives and principles. The Union contends that the College failed to subscribe to those objectives and principles when it did not provide the griever with retraining during the years prior to her layoff when it knew that enrollment in her program was in decline. It also characterizes this failure to enhance the grievor's employment stability through retraining as an arbitrary, bad faith, and unreasonable exercise of the College's discretion under Article 28.01A. However, that provision does not create an arbitrable duty or discretion on the part of the College to provide retraining. After reciting the above - quoted objectives and principles, it sets forth the 19 provisions to which the parties have agreed in order to achieve (to the degree that it is feasible) those objectives and principles. Those provisions provide for the establishment of a joint College Employment Stability Committee (the "CESC") at each College to, among other things, recommend long -term and short -term strategies to enhance employment stability, which strategies may include retraining. Article 28.04, for example, provides in part as follows in this regard: The functions of the CESC shall include the making of recommendations with respect to long -term strategies to enhance employment stability, having regard to available resources. Activities may include, but not necessarily be restricted to: (iv) developing strategies including retraining, early retirement, alternate assigments, secondments, professional leaves, employee career couselling, job sharing, professional development, pre - retirement planning and voluntary transfer. It is clear from those provisions that, as contended on behalf of the College, the parties' joint commitment to enhance employment stability through both long -term and short -term strategies including retraining is to be actualized through the functioning of the CESC. Thus, the grievance is not arbitrable under Article 28.01 or Article 28.04, as neither of those provisions establish any right to retraining enforceable through the arbitration of an individual instructor's grievance. However, the grievance is arbitrable under Article 27.06A(viii)(c), which provides: 19 Failing placement under 27.06 A (viii) (a), such employee shall be laid off with written notice of not less than 90 calendar days. Such employee shall be granted release from all or part of the normally assigned duties, for this period of notice, for the purpose of engaging in retraining activities, where such release is feasible given the normal operational requirements facing the College. Where such release is not possible, the notice period shall be extended by up to 90 days to permit retraining and the employee shall maintain current salary and benefits for the duration of the notice period. The application of that provision to the circumstances of the instant case gives rise to a number of arguable issues, including: (1) whether (as contended on behalf of the Union) the College had an obligation to provide the griever with retraining after she received her notice of layoff and before the retraining grievance was filed, or whether (as contended on behalf of the the College) Article 27.06(viii)(c) only gives a right to release for the purpose of retraining, and does not grant the right to retraining asserted by the Union; (2) whether it was necessary for the griever to make a request that she be granted release for the purpose of engaging in retraining activities (as contended on behalf of the College), or whether an employee who is issued a notice of layoff has a right to be provided with retraining regardless of whether that employee asks for a release (as contended on behalf of the Union); (3) whether the absence of any mention of retraining in the notice of lay -off, which explicitly indicated that the grievor was expected to perform her regular duties during her notice period, has any bearing on the validity of the grievance (as asserted by Union counsel, but disputed by College counsel); and (4) whether the 20 College was obliged in the circumstances of this case to either accept one of the two retraining proposals created by the grievor after filing the grievance, or to suggest alternative training. We do not find it appropriate to decide any of those issues on the basis of the material currently before us in these proceedings. Thus, if the parties are unable to resolve the aforementioned second aspect of the grievance, it will be scheduled for continuation of hearing, at which evidence (if necessary) and further submissions may be presented. DATED at Burlington., Ontario, this 28th day of May, 2014. 4c D. Howe Chair T concur. "A. Burke" College Nominee Z dissent. "Sherril Murray" Union Nominee 21