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HomeMy WebLinkAboutTrottier Group 14-08-12BETWEEN IN THE MATTER OF AN ARBITRATION TIMMINS AND DISTRICT HOSPITAL and (the "Hospital") ONTARIO PUBLIC SERVICE EMPLOYEES UNION, LOCAL 643 (the "Union") PHARMACY TECHNICIAN GROUP GRIEVANCE DATED MAY 4, 2011 (2011-0643-003) Sale Arbitrator: John Stout APPEARANCES: For the Hospital: Geoff Jeffrey, Weaver Simmons LLP Mike Resetar, Chief Human Resources Officer Lorna Green, Manager Pharmacy For the Union: Michael Fisher, Raven Law Christine Trottier, Grievor Denis Chenier, OPSEU Staff Rep. Region 6 HEARING HELD IN TIMMINS, ONTARIO ON JULY 31, 2014 SEP 2 Z-014 S fr.S ., INTRODUCTION [1] 1 was appointed by the parties to hear and determine a group grievance dated May 4, 2011 (2011-0643-003) (the "grievance"). The grievance was filed by the Union on behalf of employees employed by the Hospital as "pharmacy technicians" (the "grievors"). According to the Union, the grievance arises from the Hospital's decision to require all existing pharmacy technicians to register with the Ontario College of Pharmacists, while only providing partial compensation for the educational expenses incurred for so doing. [2] The Hospital takes the position that they did not require the grievors to register with the Ontario College of Pharmacists and they have no obligation under the collective agreement to pay for the educational expenses associated with the registration. Instead, the Hospital asserts that the grievors are required to register by virtue of the requirements of the Pharmacy Act, 9991 S.O. 1991, Chapter 36 (as amended). BACKGROUND FACTS [3] The parties did not call any oral evidence. Instead, the parties provided me with a "Statement of Agreed Facts" (with attached exhibits). The Statement of Agreed Facts is set out below: 1. The parties agree that there are no objections to the jurisdiction of the arbitrator, Mr. Stout, to hear the matter, that there are no objections to the form or timeliness of the grievance, that the following facts are agreed to be accurate for the purpose of this hearing, and can be relied upon by the arbitrator in making his determination on this matter. 2. The Timmins and District Hospital ("Hospital") and the Ontario Public Service Employees Union ("OPSEU") are party to a collective agreement that includes central and local provisions. (Exhibit #1(a) and (b)) 3. OPSEU is the exclusive bargaining agent for all paramedical employees at the Hospital, including "pharmacy technicians." 4. Up until recently, pharmacy technicians were not regulated by the Ontario College of Pharmacists. A pharmacy technician learned the trade by a combination of education and/or work experience, working under a pharmacist's instruction, S. On December 3, 2010, amendments to the Pharmacy Act came into force that made pharmacy technicians a new class of registrant with the Ontario College of Pharmacists. According to subsection 10(1) of the Act, only members of the College can use the formal title "Pharmacy Technician". The Pharmacy Act is attached as Exhibit #2. 6. As a result, "Pharmacy Technician" became a protected title. Only those registered with the College can present themselves as Pharmacy Technicians. Other non -registered dispensary personnel have to use other designations, like pharmacy assistant. 7. Regulation 202/94 under the Pharmacy Act established a registration process for individuals already working as pharmacy technicians to become a regulated pharmacy technician. The steps for individuals already working in the profession, at the time of the amendments, are as follows: (a) Complete an evaluation exam, administered by the Pharmacy Examining Board of Canada, by January 1, 2012;1 (b) Complete an approved Bridging Education Program, which consists of four continuing education courses (about 150 hours in total), by January 1, 2015; (c) Complete the Pharmacy Technician Qualifying Examination, administered by the Pharmacy Examination Board of Canada, and offered twice a year; (d) Complete the Ontario College of Pharmacists' Jurisprudence Examination, offered four times a year. Regulation 202/94 is attached as Exhibit #3. 8. Due to the fact that Pharmacy Technicians were now regulated, the Ontario College of Pharmacists were able to amend the scope of practice for Pharmacy Technicians. Whereas before pharmacy technicians were responsible for all technical aspects of filling prescriptions under the direct supervision of pharmacists, the new scope of practice for Pharmacy Technicians gives them sole 1 Anyone who did not write or pass this exam by January 1, 2012, and who wants to proceed to registration has to graduate from a program accredited by the Canadian Council for the Accreditation of Pharmacy Programs. 3 responsibility over the same technical functions without direct supervision. 9. The Hospital currently employs 15 pharmacy technicians (16 positions) in the "Pharmacy Technician/Assistant" classification, included in the "Technician 3" wage group. Four have completed the registration process. Four others are expected to complete the registration process by January 1, 2015. And one is expected to complete the registration sometime after January 1, 2015. Six have decided not to register. 10. In December, 2009, before the amendments came into force, the Ontario Hospital Association sent out a circular advising its members, including Timmins and District Hospital, that, as a result of the amendments to the Pharmacy Act, they had a choice of three options: (a) Move to a Regulated Pharmacy Technician model; (b) Maintain their current practice (and rename the current pharmacy technicians to reflect a non -protected title); (c) Introduce a hybrid model which combines the use of regulated and non-regulated pharmacy staff. 11. The Hospital has chosen the first option.* 12. On or around December 17, 2010, the Hospital informed its pharmacy technicians of the new legislation and that it will require all staff working in the position of Pharmacy Technician to register with the Ontario College of Pharmacists by January 1, 2015. Pharmacy technicians were entitled to submit a claim for compensation under the Hospital's education policy. Pharmacy technicians were directed to inform themselves of the process and to comply with the established deadlines and other information available on the College of Pharmacists website. They were further advised that their "[f]ailure to take adequate steps to secure certification in a timely fashion could lead to remedial and/or disciplinary action and ultimately removal from the position" A copy of the letter of L. Green, Program Manager, Pharmacy, to C. Trottier, dated December 17, 2012, is enclosed as Exhibit #4 to the agreed facts. 13. The costs of the registration process are as follows: (a) Pharmacy Examining Board of Canada Evaluating Examination: $350; (b) Pre -registration: $130**; (c) Four Pharmacy Technician Bridging Program courses: fees vary from $200 to $400; however, three of the 4 courses may be completed by prior learning assessment, or challenge exams, which range from $90 to $150; (d) Jurisprudence Examination: $200; (e) Pharmacy Examination Board of Canada Qualifying Examination (combined practical and written exam): $1,275; (f) Application for a certificate of registration: $205**; These costs vary depending upon whether the exams are challenged and the training provider. "non -course related costs 14. The Hospital's Education Policy provides for the reimbursement of 2/3 of approved education expenses. In the case of the Pharmacy Technicians, this resulted in a reimbursement of approximately $1,800.00 for each Pharmacy Technician. The Hospital also provided up to two paid education days if one of the required exams occurred on a day that the employee was otherwise scheduled to work. Attached as Exhibit #5 is the Hospital's Education Assistance policy. 15. On May 4, 2011, OPSEU presented a group grievance, on behalf of the Pharmacy Technicians, pursuant to several sections of the collective agreement, with respect to the Hospital's decision to require all existing pharmacy technicians to register with the Ontario College of Pharmacists and for only providing partial compensation for the expenses incurred for doing so. The Group Grievance is attached as Exhibit #6. 16. Article 14.06 of the Collective Agreement provides as follows: 14.06 Education Leave Where the Hospital directs and the employee agrees to take an educational course to upgrade or acquire new employment qualifications such employee shall not lose regular pay because of necessary absence from work due to participation in such course. The Hospital shall pay the full cost of such course in advance. The Employee may apply to the Hospital for a reasonable advance to cover additional costs associated with the course, 17. On January 16, 2013, OPSEU filed a grievance on behalf of Gail Renaud, a Pharmacy Technician who completed the registration process and maintained that her position was improperly classified. A copy of this grievance is attached as Exhibit #7. R 18. On 25 July, 2013, the parties attempted, with the assistance of the arbitrator, to mediate a settlement to the grievance. These efforts, and those that followed in the two months following the mediation as between counsel, were not successful. A new hearing date was scheduled for 31 July, 2014. 19. As a result of the ongoing uncertainty with respect to those employees who had not taken steps, or sufficient steps, to achieve registration by the deadline, Mr, Jeffery sent a letter to Mr. Fisher on 12 December, 2013 indicating what steps would be taken with respect to these employees by the Hospital. A copy of this letter is attached as Exhibit #8 to these Agreed Facts. 20. In addition, the Hospital forwarded to the affected employees a letter indicating what the consequences would be of not meeting the deadline. A copy of the letter sent to Ms. Blais is attached as Exhibit #9 and is in the same form as those sent to the other affected employees. At the time of the letter, there were still 6 employees remaining who were not proceeding to registration. These affected employees were Natalie Komadina, Billie -Jo Hopkins, Helene Larouche, Lorna Wesley, Kim Blais and Shelley Boucher. 21. Five of the affected employees (other than Ms. Boucher) have grieved the Hospital's letter. A copy of these grievances are attached as Exhibit #10. This matter is to be heard by you following disposition of the group grievance. 22. The Hospital has recently been informed that a seventh employee, Amanda Rickard, has dropped out of the course and will accordingly not be registered by the deadline. She filed a grievance with respect to this issue on 23 July, 2014. This grievance is attached as Exhibit #11. All of which is agreed, this 31st day of July, 2014 in the City of Timmins. [41 In addition to the Statement of Agreed Facts, I was also provided with the following documents, which were marked as exhibits: • The current Job Description for the Position title "pharmacy technician" approved February 1990 and revised August 1994 • A letter from Mr. Jeffrey dated July 7, 2014 providing a response to the Union's request for particulars [5] The current job description does not indicate a requirement that an employee in the position of pharmacy technician be registered with the College of Pharmacists. Furthermore, the scope of practice under the current job description is not the same as provided for under the Pharmacy Act, 1991. In other words, the employees currently working under this job description work under the direction of a supervising pharmacist. [6] Mr. Jeffrey's letter of July 7, 2014 confirms that the Hospital has no current plans to eliminate the position of pharmacy technician. However, after December 31, 2014, the position will be subject to the provisions of the Pharmacy Act, 1991, which precludes the use of the title "pharmacy technician" by anyone who is not a member of the College of Pharmacists. It will therefore be a requirement of the position, commencing January 1, 2015, that the grievors be registered with the College of Pharmacists. SUBMISSIONS OF THE PARTIES [7] The Union argues that the Hospital made a conscious decision to move to a registered pharmacy technician model. The Union points out that the Hospital had other options, including "grandfathering" the current employees in a non -registered role (under a new title) working within the current scope of practice. (8] The Union emphasizes that the Pharmacy Act, 1991, does not require the Hospital to employ only registered pharmacy technicians. Rather, the Pharmacy Act, 1991, prohibits the use of the title of pharmacy technician by persons not registered with the College of Pharmacists. [9] According to the Union, the letter issued by the Hospital on December 10, 2010 advises the grievors that they are required by the Hospital to update their skills and become registered with the College of Pharmacists. The Union asserts that the December 17, 2010 letter clearly indicates that failure to register 7 could lead to "remedial and/or disciplinary action and ultimately removal from the position". In this regard, the Union submits that the grievors were compelled to upgrade their skills and register with the College of Pharmacists. In these circumstances, the Union argues that article 14.06 is engaged because the Hospital is requiring the grievors to take educational courses to upgrade and acquire a new employment qualification for their existing positions. [10] The Union directed my attention to the wage rates in the central provisions of the collective agreement. The Union points out that the grievors were in the Technician 3 wage group, which is applicable to Pharmacy Technician/Assistant classification. According to the Union, the Hospital is not compelled to use the title of "pharmacy technician". Rather, it is management exercising their right to call the grievors by this title and the Hospital could just as easily comply with the Pharmacy Act 1991, by renaming the existing position, without any other alteration to the job description. [11] The Union points out that once registered, the grievors shall be qualified to provide the Hospital with a greater scope of practice (i.e. they can work independently and not under the supervision of a pharmacist). [12] The Union acknowledges a number of arbitration awards and one Divisional Court decision, which have favoured other hospitals in somewhat similar situations. According to the Union, these awards are distinguishable from the current situation where the Hospital is requiring employees to register to maintain their existing positions. [13] The Union referenced the following awards during their argument: Thunder Bay Regional Hospital and O.P.S.E.U. (Payment of Course Costs), (2012) 111 C.L.A.S. 170 (Herlich); Joseph Brant Memorial and C.U.P.E, Local 1065, (2012) 112 C.L.A.S. 84 (Kaplan); Sensenbrenner Hospital and Service Employees International Union, Local 204 (Mercier) (2002), 115 L.A.C. (4th) 434 (Brent); Wexford Inc. and C.U.P.E., Local 3791, (2001), 96 L.A.C. (41h) 153 (Albertyn). [14] The Hospital argues that they are not requiring the grievors to be registered with the College of Pharmacists. Instead, the Hospital asserts that the Pharmacy Act, 1991 dictates that the grievors be registered. In order to be registered, the grievors are also required to take certain educational courses. In these circumstances, the Hospital argues that it is the Pharmacy Act, 1999 and not the Hospital that requires the additional education courses and qualifications. [15] The Hospital points out that pharmacy technicians are now required by legislation to be registered. The Hospital asserts that it is an offence under the Regulated Health Professions Act, 1991, S.0. 1991 c.8. for the Hospital to permit a non -registered employee to perform a controlled act.2 The Hospital suggests that they are compelled by the Regulated Health Professions Act, 1991, to advise employees that they must fulfill the requirements to be registered. The Hospital argues that it does not follow that they are actually requiring the grievors to take the educational courses and register. Instead, the Hospital submits that the requirement to take the educational courses and register is a legislative requirement. [16] The Hospital suggests that the Union is complicating a simple case. The Hospital argues that consistency in awards is important and I should follow the earlier awards addressing this issue. The Hospital submits that any difference in the facts in these earlier awards are so slight that they are nothing but a "distinction without a difference". [17] The Hospital also argues that the facts in this situation are closer to the award of arbitrator Brent in Sensenbrenner Hospital and Service Employees 2 See s. 27 and 42 Regulated Health Professions Act, 1991 prohibiting unauthorized performance of a controlled act and s. 3 and 4 of the Pharmacy Act, 1991. L•] International Union, Local 204 (Mercier), supra, which is an award that relied on a Divisional Court decision in Hotel Dieu Hospital v. Canadian Union of Public Employees, Local 1097 [1982] O.J. 226 (O.S.C. Div. Ct.). [18] The Hospital suggests that they have maintained the "status quo" by not changing the title of the current position. The Hospital asserts that the Pharmacy Act, 9991 mandates registration to use the term pharmacy technician and therefore the grievors are compelled by the legislation to take the educational courses and register. [19] The Hospital acknowledges that the grievors would prefer to be grandfathered. However, the Hospital asserts that it is their right and obligation to provide the highest level of service to the community that they serve. DECISION [20] After carefully considering the evidence and submissions of the parties, I find that the Hospital has violated article 14.06 of the collective agreement by not paying the full costs associated with educational courses required for being registered as a pharmacy technician. [21] 1 begin by acknowledging that two other prominent and well respected arbitrators have come to the opposite conclusion in somewhat similar circumstances. In this regard, it is useful to review these awards and point out why 1 view both awards as distinguishable. [22] The first and most relevant award is the Thunder Bay Regional Hospital and O.P.S.E.U. (Payment of Course Costs), supra, decision of arbitrator Herlich. Arbitrator Herlich considered the exact same central language that is before me in a somewhat similar, but not identical situation. The relevant portions of arbitrator Herlich's award are set out below: 10 25. The employer has not threatened to impose discipline on any of its employees who fail to pursue upgrading. Indeed, neither has their been a clear explicit direction issued by the employer. That, however, does not end the matter.... 28. Thus, in the cases we have focused on, it is possible to distinguish between circumstances where taking (or not taking) the training, upgrading or course in question will have an impact on the employee's existing position from those where the effect is likely to be felt in relation to some possible future position. I accept this as an important distinction in the treatment of cases such as the one at hand. And while there may be some diversity of adjudicative views on the point, I also accept that a factual context of compulsion which operates "within the terms of an employee's existing job" may amount to an employer direction within the meaning of the language like that found in the instant collective agreement. 29. Cases involving an employee's very job security in his/her existing position are to be distinguished from those involving upgrading or seeking additional qualifications for the purpose of securing a promotion or other assignment to a new position. Such a distinction is consistent with the principle that, absent any other collective agreement right or obligation, the responsibility for upgrading and training for the purposes of future job applications or promotions is that of the employee. 30. ...fihe employer in this case has determined to eliminate, or at least entirely vacate, the classification of Pharmacy Technician/Assistant. I also accept the employer's assertion that the process will culminate in the creation of a new classification, which will be an as yet unnamed classification of regulated Pharmacy Technician (within the meaning of the relevant legislation). 31. It is not difficult to understand why the incumbents may be of the view that their job security will be best served by undergoing the upgrading and, indeed, feel compelled to pursue that upgrading. It does not necessarily follow, however, that the employer is therefore directing them to complete it. There are undoubtedly job security concerns at play, but so long as their current positions continue to exist there is no reason to believe the current incumbents cannot and will not continue to occupy them. But the employer, as it is entitled to do, has determined to, ultimately, discontinue those positions. Thus, any entirely understandable perceived compulsion on the incumbents' part to do the upgrading is in 11 relation to the new, not to their existing classifications. Thus, while the fit may not be perfectly airtight, the present facts much more closely resemble those involving training to qualify for promotion than some newly imposed "requirement" to be met in order to maintain an existing position. [23] The second award is arbitrator Kaplan's decision in Joseph Brant Memorial and C.U.P.E, .Local 1065, supra. After reviewing the decision of arbitrator Herlich in Thunder Bay Regional Hospital and O.P. S.E. U. (Payment of Course Costs), supra, arbitrator Kaplan came to a similar conclusion based on somewhat different language but identical facts. The relevant portion of arbitrator Kaplans' award is set out below: 19. Having carefully considered the evidence and arguments of the parties, we are of the view that the employer is not required to pay the full amount of the bridging costs associated with receiving accreditation as a Pharmacy Technician. It is not required to do so because the affected employees are not required to take any courses by the employer. To be sure, they are required to take the courses and obtain the accreditation if they wish to become Pharmacy Technicians, but that is entirely up to them. The employer is entitled to discontinue positions — which may or may not be the end result in this case — and the parties have, in their collective agreement, set out employee and union rights when the employer chooses to do so. 20. It is quite clear that with College regulation and the enhanced scope of practice that the job has changed. Employees are not being required to take courses to maintain their existing positions. As Arbitrator Albertyn observed: "Only when, within an employee's existing job, the Employer requests, asks, commands, or compels an employee to undertake a course of study is the Employer liable ... (at 161, Wexford, emphasis not ours). In this case, the addition of more responsible duties and regulation by the College of Pharmacy makes the reclassification of the position inevitable. But that is a different matter for another day. What is to be decided in this case is whether the employer has required the affected employees to take the courses and obtain registration and the answer to these questions is that it has not. While the employer's May 26th memorandum might have detailed different employee options, including not taking the courses and posting to ensure employment continuity in the event of positron elimination, it having not done so it hardly a basis for concluding a collective agreement breach. 21. As just noted, no employee has been ordered or compelled or required to take the courses. The employees who are doing so have made 12 that decision because it will provide them with the necessary qualifications and accreditation to become regulated Pharmacy Technicians when the employer fully implements that model. That job will be a new job with, self- evidently, an expanded scope of practice. The interest in affected individuals in obtaining these new positions is self-evident, but it is not, to repeat, required by the employer as it would have to be to fall within that part of Article 12.08 under review in this case. 22. The fact that the employer, as it is legitimately entitled to do, has decided to change its model in offering certain pharmacy services does not constitute a requirement that employees obtain the requisite certification. Most important of all, any employee who chooses not to take the courses and obtain registration retains all of their other rights under the collective agreement. Accordingly, and for the foregoing reasons, we conclude that there is no obligation on the employer to pay the full amount of the bridging costs associated with receiving accreditation as a Pharmacy Technician. [241 1 do not in anyway disagree with either arbitrator's conclusion based on the facts that were before them. However, the facts before me are not identical to the facts in those two cases. The facts before me are that the grievors are being required to take the educational courses to become registered as pharmacy technicians for their existing positions. 1251 The Hospital's December 17, 2010 letter clearly states that the "Hospital will require all employees working in the position of Pharmacy Technician to take steps toward registration as required by the College to be fully registered by the College by 1 January, 2015." The Hospital acknowledged in their letter that certification would "increase" the grievor's qualifications. The Hospital also advised the grievors that "failure to take adequate steps to secure certification in a timely fashion could lead to remedial and/or disciplinary action and ultimately removal from the position". [261 In the matter before me, the Hospital is requiring the grievors acquire registration to maintain their existing positions. This is quite different from the situations before arbitrators Herlich and Kaplan, where the hospitals in those two cases were vacating the existing classification and creating a new classification. 13 [27] The fact that the grievors are being required to acquire registration for their existing jobs is precisely the distinction in the case law pointed out by arbitrator Herlich in paragraphs 27 and 28 of his award. Arbitrator Kaplan also accepts this distinction at paragraph 20 of his award, relying on Wexford Inc. and C. U. P. E., Local 3 79 1, supra. [28] In my view, the Hospital had a choice to make in this matter, which was the same choice confronting the hospitals in the matters before arbitrators Herlich and Kaplan. The choice was clearly set out in the December 2009 circular sent out by the Ontario Hospital Association. [29] The Hospital could have maintained their current practice and renamed the current non -registered pharmacy technicians to reflect a non -protected title.3 The Hospital could have also introduced a hybrid model combining regulated and non-regulated pharmacy staff. In both situations, the grievors could have continued to work in their existing positions performing exactly the same duties they are currently performing. [30] The Union suggests that the Hospital grandfather the existing employees. I take this suggestion to mean that the Hospital could have implemented a hybrid model, which would allow the grievors to remain in their current role but with a different title such as pharmacy assistant. This option was definitely available to the Hospital and would not in anyway run contrary to the collective agreement. [31] The Hospital could have also chosen to do what the hospitals in Joseph Brant Memorial and C.U.P.E, Local 1065, supra, and Thunder Bay Regional 3 Nothing prevents the Hospital from renaming the grievors' position as a pharmacy assistant, which is what occurred in the Joseph Brant and C.U.P.E 1065, supra, situation [see paragraph 13 of the agreed facts set out in paragraph 2 of arbitrator Kaplan's award.] 4 The grievors could remain being paid at the Technician 3 wage rate but be renamed pharmacy assistants. 14 Hospital and O.P,S.E.U. (Payment of Course Costs), supra, chose to do. That is move to a regulated pharmacy technician model by creating a new classification. [32] In this case, the Hospital chose none of the above options. Instead, the Hospital chose to keep the name of the current position (pharmacy technician), which is in the pharmacy technician/assistant classification included in the Technician 3 wage group. This has the effect of moving to a regulated pharmacy technician model. It also compels the existing employees to register with the College of Pharmacists, which permits them to have an expanded scope of practice. [33] The Hospital has the right, pursuant to management rights in Appendix "B", to make the choice of which model it wishes to adopt. The Hospital has decided that they only want to employ registered pharmacy technicians with a wider scope of practice. The Hospital made this decision because they say that they want to maintain the highest standards to serve their community. I do not question the Hospital's motives or the reasonableness of their decision. The Union, quite rightly acknowledged during argument that they could not point to any violation of the collective agreement for the Hospital's refusal to grandfather the grievors. [34] The Hospital asserts they are maintaining the "status quo". Quite frankly, I find this assertion somewhat disingenuous. The reality is that the Hospital, by maintaining the title of the position, has effectively increased the qualifications (needing to obtain the educational courses and registration) and increased the responsibilities of the position (no longer requiring direction from a supervising pharmacist). The status quo was been altered when the Hospital chose not to change the title of the grievors' position or create a new registered pharmacy technician classification in response to the new legislative requirements. In my view, altering the status quo is not limited to actions made by any one parry. Altering the status quo can also occur when a party takes no action in response to some outside force. That is precisely what occurred in this case. is [35] One might speculate that the Hospital's choice could trigger a re- classification, such as occurred in Joseph Brant Memorial and C.U.P.E, Local 1065, supra, and Thunder Bay Regional Hospital and O.P.S.E.U. (Payment of Course Costs), supra. However, in this case, the Hospital has chosen not to re- classify the position. [36] 1 acknowledge that a grievance has been filed by the Union challenging the current classification of an employee who has completed the additional educational requirements and become registered with the College of Pharmacists. However, that grievance remains outstanding and has not been decided. Instead, the parties have proceeded to have this grievance resolved prior to litigating the subsequent classification grievance. It would be improper for me to speculate on the outcome of this other grievance, In addition, there is no evidence before me that a new classification will be bargained during the current round of bargaining. [37] in these circumstances, the evidence is clear that the Hospital has directed the grievors to take the educational courses needed in order to be registered with the College of Pharmacists so that they may remain in their existing positions. This fact makes this situation distinguishable from the matters before arbitrators Herlich and Kaplan, [38] 1 now turn to consider the Divisional Court decision relied upon by the Hospital. In Hotel Dieu Hospital v. Canadian Union of Public Employees, Local 1097, supra, the Divisional Court quashed an award of a Board of Arbitration. The award involved a grievance alleging that a hospital violated a collective agreement by not providing an ambulance driver attendant with a paid leave of absence to take an emergency medical care examination. [39] The Divisional Court's decision in Hotel Dieu Hospital v. Canadian Union of Public Employees, Local 1097, supra, is clearly distinguishable based on the facts and the language in the collective agreement. 16 [401 In Hotel Dieu Hospital v. Canadian Union of Public Employees, Local 1097, supra, the employee in question was required by subsection 9(2) of the Ambulance Act, R.S.O. 1970, c.20 to pass an emergency medical care examination. The employee took the examination and then requested payment for the day of work he took off to write the examination. [411 The applicable collective agreement language provided as follows: "10.09 Education Leave If required by the Employer, an employee shall be entitled to a leave of absence with pay and without loss of seniority and benefits to write examinations to upgrade his employment qualifications". [421 The Board of Arbitration found as a fact that the employer did not require the employee to take the examination in the sense that it did not request or demand he do so. The Board instead found ambiguity in the language and considered the obligation of the employer under legislative regulations, which indicated that it would be unlawful to employ the employee if he failed to pass the examination. [431 The Divisional Court found the Board's decision to be unreasonable, stating the following at paragraph 8: "in our opinion, the language of Article 10.09 does not reasonably bear this interpretation. It is essentially a clear and simple provision to be applied where the hospital directs employees to take an examination including one under s. 9(2) of the regulations if the employer so directs. It is to have effect where the initiative is taken by the hospital and not by the employee." (emphasis added). [441 Thus the error of the Board of Arbitration was finding a violation of the collective agreement in a situation where the Board found that the employer did not direct or require the employee to take the examination. 17 [45] The situation in Hotel Dieu Hospital v. Canadian Union of Public Employees, Local 9097, supra, is completely different from the matter before me. In the matter before me, the Hospital directed the grievors to take the educational courses and obtain registration in order to remain in their existing positions. In addition, the Hospital in this matter could have avoided the necessity of the grievors taking the educational courses by continuing to employ the grievors in their existing positions and simply renaming the position to comply with the legislation. [46] Similarly, the Sensenbrenner Hospital and Service Employees International Union, Local 204 (Mercier), supra, award of arbitrator Brent is also distinguishable based on the facts. [47] The Sensenbrenner Hospital and Service Employees International Union, Local 204 (Mercier), supra, case, concerned a requirement under the Ambulance Act requiring that paramedics be certified as emergency medical care assistants. The language of the collective agreement was somewhat similar, but not exactly the same as the matter before me. The applicable language stated as follows: "Where employees are required by the Hospital to take courses to upgrade or acquire new employment qualifications, the Hospital shall pay the full costs associated with the courses." [48] The Ambulance Act prohibited the employment of an employee if they did not hold the qualification of an emergency medical care assistant. The hospital in the Sensenbrenner Hospital and Service Employees International Union, Local 204 (Mercier), supra, case did not have any option and it was the legislation that required the employee to take the course. Arbitrator Brent made the following finding at page 444: "The facts remain, though, that the requirements were those of the legislation and not those of the Hospital; and the grievor, although Os informed of the consequences of non -certification by the Hospital and assisted by the Hospital in arranging attendance at the course, was not directed or ordered by the Hospital to obtain his certification. In our view, in order for Article 15.02(c) 'to apply there must be Hospital initiative tantamount to a direction or order before it can be concluded that "employees are required by the Hospital'. Such was not the case here. This grievance is dismissed." [49] In the matter before me, the Hospital had a choice as to how it could comply with the legislative requirements. Instead of renaming the position, the Hospital chose to direct the grievors to take the courses and become registered with the College of Pharmacists. The December 17, 2010 letter was clearly a direction and an order that set out particular consequences, which included discipline. [50] 1 acknowledge that the Hospital clarified that the grievors would not be disciplined in a letter dated December 12, 2013. At the same time, the Hospital also clarified that the grievors would not be laid off and permitted to exercise their seniority rights. Instead, the grievors would be found to be no longer "qualified" for their positions and placed on an unpaid leave of absence for 24 months and thereafter deemed to be no longer employed. In my view, the Hospital took the initiative to increase the qualifications and scope of the work required by the grievors in their existing positions. [51] In this situation, I find as a fact that the Hospital also directed the employees to take the courses to become registered with the College of Pharmacists. [52] It was the Hospital's choice to maintain the current title of the existing position as a "pharmacy technician" under the Technician 3 wage group, while at the same time moving to a registered model with greater qualifications and a broader scope of practice. This choice by the Hospital has the consequences of requiring the grievors to take the educational courses and become registered with the College of Pharmacists. 19 [53] The Hospital could have made a different choice, like the other hospitals in the matters before arbitrators Herlich and Kaplan. As indicated earlier, the Hospital is entitled to make the choice that it made pursuant to management rights. I cannot criticize the Hospital for wanting to provide the highest level of service by employing only registered pharmacy technicians. However, the Hospital also has to live with the consequences of its' choice. In this case, the consequences are that the Hospital is required under article 14.06 of the collective agreement to pay for the educational courses they require the grievors to take in order to acquire the new qualification of being registered with the College of Pharmacists. [54] 1 agree with the Hospital's submission that consistency in decisions is very important. Consistency is particularly important when interpreting "central language" in the hospital sector. However, consistency in decision making does not mean an arbitrator should overlook relevant facts that make earlier decisions distinguishable. [55] Furthermore, in my view this award is consistent with reasoning found in all the awards provided to me by the parties. The outcome is only different because the facts in this matter are distinctly different and make those other decisions distinguishable. [56] Accordingly, for all the above noted reasons, I find that the Hospital has violated article 14.06 of the collective agreement. In accordance with the parties' request, 1 remain seized with respect to the remedy. Dated at Toronto this 12th day of August, 2014. John Stout - Arbitrator 20