HomeMy WebLinkAboutHuinink 14-08-22IN THE MATTER OF AN ARBITRATION
Pursuant to the Labour Relations Act, S.O. 1995
Between:
HAMILTON HEALTH SCIENCES CORPORATION
(the “Employer”)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
LOCAL 273
(the “Union”)
Re: Grievance of Kristi Huinink - Article 17.10 - Shift Change Pay
A W A R D
PAULA KNOPF - ARBITRATOR
APPEARANCES
For the Employer For the Union
Brent Labord, Counsel Jesse Gutman, Counsel
Arlene Papaioannou Debbie Teichgraf
Cheryl Malcolmson Mike Anzonvino
Marie Misiti Kristi Huinink
The hearing of this matter was held in Hamilton on July 13, 2014.
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This is a claim for compensation for a shift change that was imposed upon the Grievor
with less than 48 hours’ notice. This resulted in disruption to the Grievor and her family.
The Collective Agreement provides for payment at the rate of 1½ the regular hourly rate
if notice is not given 48 hours in advance, although exceptions to the entitlement to this
rare are contained in the clause. The Employer has denied the claim, asserting that the
facts of this case fit within one of the exceptions.
The Collective Agreement provides:
17.10 Changes in Schedules
(b) Posted Schedules
An employee’s schedule will be posted in a prominent location
within a department at least four (4) weeks in advance of the week
to which the schedule applies.
(c) The Hospital will endeavor to provide as much advance notice as is
practicable of a change in the posted schedule referred to in (b)
above. Changes to the posted schedule shall be brought to the
attention of the employee. Where an employee is not advised
within forty-eight (48) hours prior to the actual schedule change,
time and one half (1½) of the employee’s regular straight time
hourly rate will be paid for all hours worked on the new schedule
which differ from her originally scheduled hours. This provision
shall not apply where any changes in schedule arises from:
(i) the appointment of an employee to a permanent or
temporary vacancy, or
(ii) any change in schedule requested by an employee, or
(iii) any change in schedule resulting from the accommodation of
an employee modified work program, or
(iv) any addition or deletion of a shift from the posted schedule
referred to in (b) above.
The parties presented this case largely on the basis of the following “Agreed Statement
of Facts and Issue”:
The parties agree that Arbitrator Paula Knopf has jurisdiction in this matter. The
parties further agree that there are no preliminary issues with respect to this
dispute.
For the purposes of expediting the resolution of the arbitration in this matter, the
parties have mutually agreed to the following facts and statement of issue to be
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placed before the Arbitrator along with the parties’ legal arguments, to resolve
the issue in dispute. The parties agree that these facts are agreed upon solely
for the purpose of resolving the dispute in question.
A. THE PARTIES
1. Hamilton Health Sciences (“HHS” or the “Hospital”) is an independently
governed academic health science organization funded primarily through
transfer payments from the Province. HHS is governed by one board, has one
management structure and has approximately 1,100 beds.
2. HHS operates a number of locations including: Chedoke Hospital, Hamilton
General Hospital, Juravinski General Hospital, McMaster Children’s Hospital,
McMaster University Medical Centre, St. Peter’s Hospital, West Lincoln
Memorial and the Juravinski Cancer Centre. It provides tertiary, secondary and
ambulatory health care services to Hamilton as well as Central South and
Central West Ontario.
3. The Ontario Public Service Employees Union (“OPSEU” or the “Union”)
represents technologists and technicians in a bargaining unit covering both full-
time and part-time employees at HHS. OPSEU members at HHS are
represented by OPSEU Local 237.
4. The relevant collective agreement governing labour relations between HHS and
the Union [was filed in evidence].
B. GRIEVANCE
5. By grievance dated March 27, 2013, the Grievor, Kristi Huinink, a casual part-
time x-ray technologist, alleges a violation of Article 17.10(c) of the collective
agreement by having her shift of March 2, 2013 changed from day shift to night
shift with less than 48 hours’ notice and was not paid time and one-half her
regular rate for all hours worked on the night shift on March 2, 2013.
6. By correspondence dated July 3, 2013, the grievance was denied and the
Hospital asserts that Article 17.10(c)(iii) provides an exception in the
circumstances.
C. MATERIAL FACTS
7. At the Hamilton General site, there is a Diagnostic Imaging Department.
8. The Grievor is a casual part-time x-ray technologist employed at the Hamilton
General site.
9. Pursuant to Article 17.10(b) of the collective agreement, employees’ schedules
are posted four weeks in advance of the week to which the schedule applies.
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10. The schedules for the weeks of Saturday, February 23, 2013 to Friday, March 1,
2013 (week 9) and Saturday, March 2, 2013 to Friday, March 8, 2013 (week 10)
were each posted four weeks in advance.
11. (a) Pursuant to the posted schedules, the Grievor was scheduled to work 8:30
a.m. to 4:30 p.m. on both Saturday, March 2, 2013 and Sunday, March 3, 2013
(i.e. day shift).
(b) Pursuant to the posted schedules, Ms. A1, also a casual part-time x-ray
technologist, was scheduled to work midnight to 8:00 a.m. on both
Saturday, March 2, 2013 and Sunday, March 3, 2013 (i.e. night shift).
12. Ms. A suffered a workplace injury compensable under the Workplace Safety
Insurance Act in February, 2013 resulting in physical restrictions. At a joint
return to work meeting between the parties on February 27, 2013, it was agreed
that Ms. A’s restrictions precluded her from working the night shift for which she
was scheduled for March 2 and 3, 2013, due to the likely requirement which is
inherent to the night shift to lift/position/transfer patients. The joint return to
work meeting concluded that the employee could be accommodated as an x-ray
technologist by working day or evening shift as the level of staffing was higher
and assistance for positioning/transfers was available. [sic]
13. As part of the return to work plan accommodation as set out above, on February
27, 2013 a written request was made to all x-ray technologists scheduled to
work days or evenings on March 2 and/or 3, 2013 for a volunteer to switch shifts
with Ms. A to accommodate her restrictions. The request for volunteers also
stated that, in the absence of a volunteer, the accommodation switch of shifts
would be assigned to one of the staff.
14. As a result of there being no volunteers to switch shifts, by written notice dated
February 28, 2013, at 11:22 a.m., the Hospital changed the Grievor’s scheduled
shifts from day shifts to night shifts for March 2 and 3, 2014, and changed Ms.
A’s scheduled shifts from nights to days for March 2 and 3, 2013 to implement
the modified work plan accommodation.
15. There is no dispute that the selection of the Grievor, as opposed to other staff,
was made in good faith and for legitimate business reasons.
16. Both the Grievor and Ms. A worked the 7.5 hour changed shifts and neither
received 48 hours’ advance notice of their changed schedule for their respective
shifts worked on March 2, 2013. Both employees were paid straight time for all
hours worked on March 2, 2013.
1 Her name has been redacted for purposes of privacy protection.
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D. ISSUE
17. The parties agree that the sole issue to be decided by the Arbitrator is whether
the Hospital violated Article 17.10(c) by not paying the Grievor time and a half
for her hours worked on March 2, 2013. The Union does not assert that the
accommodated employee is entitled to time and a half under Article 17.10(c).
These agreed facts were supplemented by the evidence of the Grievor. She explained
that because she received only 36 hours’ notice of the change from her scheduled day
shift to the night shift, this had a disruptive effect upon her and her family. To protect
her privacy, I shall not recount the details of her family’s complicated schedule.
However, there was no challenge to her evidence that detailed the ways her carefully
arranged family life was negatively affected. As a result, she lost the opportunity to rest
as much as she would have liked before both the March 2 and 3 shifts. Nonetheless,
she worked both shifts and fulfilled her duties.
The Submissions of the Parties
The Submissions of the Union
The Union did not contest the Employer’s right to change the Grievor’s shift on short
notice or the fact that the change was triggered by the need to accommodate another
employee. However, the Union asserted that the Grievor is entitled to be compensated
for the disruption of her personal time pursuant to Article 17.10(c) because she was not
given 48 hours’ notice of the change to her schedule for March 2. To support the
concept of compensation in the event of a shift change, the Union relied upon Katoen
Natie Canada and U.F.C.W. Local 175, 54974 (ON LA) (Grey) (April 2, 2004); St. Clair
Chemical Ltd. and Oil, Chemical and Atomic Workers, Local 9-14, (1973) 5 L.A.C. (2d)
50 (H.D. Brown); Prince Rupert Regional Hospital (Health Labour Relations
Association) and H.E.U., (1993) 31 C.L.A.S. 144, 1993 CLB 13081 (Kelleher).
The Union also argued that Article 17.10 contains positive language requiring the
Employer to give employees as much notice as practical be of a shift change. The
Union stressed that the Employer was aware of the need to replace the injured
employee on February 27, 2014 and could or should have assigned someone to that
shift rather than letting 11 hours elapse waiting for a volunteer to step forward. The
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Union pointed out that if the Employer had assigned the Grievor to the shift as soon as
the need to fill it had been recognized, the Grievor would have had adequate notice of
her shift change and could have made arrangements to minimize the disruption to
herself and her family. The Union also criticized the Employer for only canvassing other
casual employees for volunteers, rather than soliciting volunteers who were full-time or
part-time employees. Because of this, the Union argued that the Employer failed in its
responsibility to give “as much notice as is practicable” of the shift change.
The Union also submitted that the exception to compensation in Article 17.10(iii) only
applies to the employee who is being accommodated, not the other employee, like the
Grievor, who is impacted by that accommodation. The Union described this as the
“domino effect” of an accommodation and argued that the clause should not be read to
disentitle such employees from the benefit of compensation. The Union stressed that
nothing in the Collective Agreement should be interpreted to wipe out the specific
benefit of a premium for short notice just because of an accommodation for another
employee. In support of this the Union referred to Overwaitea Food Group and
U.F.C.W., Local 1518, (1996) 55 L.A.C. (4th) 300 (Bird). The Union also stressed that
Article 17 be read “as a whole” and that it would require clear and specific language to
impose exceptions to compensation for short notice of a shift change.
By way of remedy, the Union requested a ruling indicating that Article 17.10(c)(iii)
exempts only the accommodated employee from the entitlement to extra pay in the
event of a shift change designed to facilitate the accommodation. In the alternative, the
Union asked for an award recognizing that the Grievor is entitled to be compensated at
the rate of 1½ times her regular rate because she was not given sufficient notice of the
change in her March 2 nd shift because the Employer could have made better efforts to
find a volunteer and/or could have actually scheduled her with 48 hours’ notice.
The Submissions of the Employer
The Employer stressed that Article 17 allows the Employer to change employees’
schedules on short notice, but provides a different rate of pay only if the notice is less
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than 48 hours and does not fall within the “exceptions to the exception” in Article
17.10(c). Turning specifically to Article 17.10(c)(iii), the Employer argued that this
“exception” removes the entitlement to extra pay if the shift change is the result of or
has been triggered by an “accommodation of an employee modified work program.”
The Employer asserts that this is what happened in this case.
The Employer stressed that this case arose in the context of a workplace injury
requiring accommodation of another employee that triggered the immediate need to
change the shift schedule. It was submitted that the Employer implemented a “very
prudent labour relations approach” to the situation by canvassing the casual staff for
volunteers before imposing a shift change on the Grievor and by giving employees
sufficient time to see if anyone would “step up” to fill the required shifts. Further, it was
said that the Employer’s actions were consistent with its management right “to schedule
work to be performed” (Article 29), as well as being in accordance with the responsibility
it shares with the Union and employees to accommodate disabilities, prevent
discrimination and facilitate the return to work of disabled employees, pursuant to their
obligations under the Human Rights Code and Articles 3.02, 3.04 and Memorandum of
Agreement August 15, 2012. In light of this, the Employer argued that the provisions
that trigger premiums for the failure to provide 48 hours’ notice of a shift change should
be construed narrowly. Conversely, it was said that Article 17.10(c)(iii) should be read
very broadly to allow that “any change . . . resulting from the accommodation of an
employee modified work program” applies to anyone affected by the change, not just
the employee being accommodated. The Employer submitted that if the parties had
intended Article 17.10(c)(iii) to apply only to the accommodated employee, they could
have signaled this by using the word “such employee” as they have done in other
provisions of the Collective Agreement or making that intention more clear. However,
the Employer argued that the “plain” meaning of the clause is that the parties created an
exception from entitlement to the premium rate when someone’s schedule is changed
on short notice because of the accommodation of another employee. This was said to
be consistent with the purpose of Article 17.10(c)(iii) and the parties’ obligations under
the Human Rights Code . It was also suggested that any other reading could result in
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discrimination against disabled employees. Essentially, the Employer argued that this
clause should be read to ensure that there is no cost to the Employer of an
accommodation and that employees should be prepared to accept the burden of
facilitating the needs of others in the bargaining unit. The Employer pointed to the
following cases, urging their interpretative approaches: Clean Harbors Canada Inc. and
C.E.P., (2012) 216 L.A.C. (4th) 276 (Knopf); Bayer Rubber Inc. and C.E.P. Local 914
(Hannaford), (1997) 65 L.A.C. (4th) 262 (Watters).
Finally, while acknowledging that the Grievor’s family and personal life was impacted by
the short notice of the shift change, it was stressed that she is a casual employee and
any difficulty she encountered has no legal impact on the interpretation or application of
the Collective Agreement. Reference was made to Thunder Bay Regional Hospital and
O.N.A. (Kirk) [2004] O.L.A.A. 144 (Randall). The Employer therefore asked that the
grievance be dismissed.
The Union’s Reply Submissions
Acknowledging that the Grievor is a casual employee, it was stressed that she is still
entitled to the protections and benefits of Article 17.10. The Union maintained that the
Employer is obligated to pay the consequences of its failure to give her at least 48
hours’ notice of the shift change. Further, while the Union accepted that it and
bargaining unit members share responsibilities with respect to accommodation of
injured workers, it also stressed that this does not override the rights under Article
17.10.
The Decision
It is helpful to begin by clarifying what is not in dispute. It is agreed that this Collective
Agreement allows this Employer to change scheduled shifts, even on short notice.
Further, the parties have agreed that the Grievor’s shift was changed as a result of a
joint back to work protocol crafted for another employee on February 27 and designed
to take effect on her next scheduled shift of March 2. This meant that the Employer had
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to staff the accommodated employee’s shift with another employee. The Employer first
tried to do this by calling for volunteers. When no one stepped up to fill that shift, the
Employer exercised its right to select and schedule the Grievor to fill the need, thereby
altering her schedule from the day to the night shift. The Union quite properly
acknowledged that this was a valid and bona fide exercise of management rights under
this Collective Agreement.
Further, it should also be noted that while the Employer stressed that the Grievor is a
casual employee who, by definition, is employed on a “relief or replacement basis” and
can be called in “as circumstances demand,” (Article 2.04), the parties also agreed that
casual employees are entitled to the rights and entitlements that are created in Article
17.10. Therefore, the casual nature of her employment status has no negative impact
on her rights in this case.
Next, it is important to focus upon the real issue in this case and avoid allowing these
facts to have implications beyond their own purview. There is no question that the
Employer and the Union share an obligation under the Human Rights Code and the
Collective Agreement to facilitate the accommodation of injured workers and that this
may also involve obligations on bargaining unit members to shoulder some of the
burden. However, nothing in the facts of this case or the interpretation of Article 17.10
should be read to imply that there should never be financial burden on an employer for
an accommodation or that an employee must forgo a contractual benefit in order to
implement an accommodation. There is no rule of interpretation that presumes that an
accommodation should have no financial impact. Similarly, there are situations where
employees are negatively impacted by accommodations of their colleagues, such as the
need to undertake greater duties, alterations to their schedules, to name but a few
examples. However, I must reject this Employer’s suggestion that the Union’s position
in this case could result in discrimination against injured workers or that the contract
should be interpreted to ensure that accommodations must be achieved without cost to
the Employer. Both propositions go beyond the reach of this case and are not
supported by this contract or any arbitral authority.
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Therefore, the only issue is whether the Grievor is entitled to extra compensation under
these circumstances. The answer to this lies in the wording of the Collective
Agreement.
Article 17 obligates the Employer to “endeavor to provide as much advance notice as
practicable of a change in the posted schedule.” The key here is that while the
Employer can change the schedule, it has promised to try to give as much notice “as is
practicable.” The only stipulated consequence for short notice is that if an employee is
not notified of the change within 48 hours, s/he is entitled to be paid at 1½ times his/her
regular rate of pay. As stated in Overwaitea Foods, supra, the Employer has the right to
change the employee’s schedule, by giving less than 48 hours’ notice, but there is a
“price attached to short notice.” In the case of the Grievor, whether the Employer could
or should have given her more notice than the 36 hours she did receive, the fact
remains that she did not get 48 hours’ notice of her shift change. If there were no
exceptions to the short-notice premium rate, the Grievor would be entitled to the extra
pay.
However, Article 17.10(c) must be read as a whole. It lists four exceptions to the
concept of extra pay for short notice, stating that “this provision” does not apply to any
changes in schedules under the circumstances listed in sub-paragraphs (i)-(iv). One of
those exceptions is where there is “any change in schedule resulting from the
accommodation of an employee modified work program.” The Union had argued that
this applies only to the accommodated employee’s change in schedule. That argument
cannot be accepted. First, the words must be given their plain and ordinary meaning.
Inferences can only be drawn where there is supporting language to ground the
proposition. This clause does not say ‘any change in the accommodated employee’s
schedule.’ Nor does it say “such employee’s schedule,” or of “the employee’s modified
work program.” Any of those wordings would support the notion that the exception
applies only to the accommodated employee. Instead, sub-paragraph (iii) simply states
that the right to the premium rate does not apply to circumstances that include any
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change in schedule “resulting from the accommodation of an employee modified work
program.” This must refer to changes in any employee’s schedule resulting from the
accommodation.
Two basic principles of contract interpretation are that the contract must be read as a
whole and that its terms are presumed to be consistent. These principles were
accepted by both parties in this case. Applying them to Article 17.10, one might look to
the exceptions to see if they only applied to shift changes triggered by the employee
requesting the premium rate. If that were the case, then the Union’s reading of sub-
paragraph (iii) would be consistent with such a pattern. However, the other three
exceptions in 17.10(c) refer to changes beyond those requested by an employee. The
Employer could trigger the additions or deletion of a shift or appointments to temporary
or permanent vacancies. Therefore, it cannot be said that the only exceptions to the
payment of the short-notice premiums are those brought about by the employee
seeking or needing the change of shift. Instead, it must be concluded that this
Collective Agreement has created several exceptions to the entitlement to the short-
notice premium, one of which is exempting the situations where the shift change has
resulted from the accommodation of an employee. This reading is consistent with the
Collective Agreement’s commitment to the facilitation of accommodations. It does
create an imposition upon the employee who gets short notice because his/her personal
life may be negatively affected and s/he will not receive the extra compensation that
would be payable if the shift change had been triggered for any reason other than the
listed exceptions in Article 17.10 (c) (i-iv).
But for the inclusion of Article 17.10 (c) (iii) in this Collective Agreement, the Grievor’s
case would have succeeded. In Overwaitea Food Group, supra, it was stressed that
“the duty to accommodate is not an eraser with which an employer can rub out
inconvenient provisions of a collective agreement”, (p. 311). Therefore, without Article
17.10 (c) (iii) the Employer could not draw upon the employee’s obligation to facilitate a
co-worker’s need for accommodation as a justification for the denial of the short-notice
premium. However, the inclusion of sub-paragraph (iii) must be given effect and
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recognized as the parties’ agreement to exempt the short-notice premium in
circumstances that fit within its language.
In the case of the Grievor, her scheduled shift was changed with less than 48 hours’
notice. However, this was as a result of the accommodation of an employee modified
work program. Under these circumstances, despite the personal difficulties the Grievor
faced because of the short notice, she falls squarely within the exception listed in Article
17.10(c)(iii). While it may be true that the Employer could have given her better notice
of the shift change, the failure to do so does not trigger any contractual right to greater
pay for the shift she had to work. As a result, the grievance must be dismissed.
Dated at Toronto this 22nd day of August, 2014.
____________________________
Paula Knopf - Arbitrator