HomeMy WebLinkAbout2013-0526.Robbins.15-05-12 DecisionCrown Employees
Grievance Settlement
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Commission de
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GSB#2013-0526, 2013-0777
UNION#2013-0164-0014, 2013-0164-0015
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Robbins) Union
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The Crown in Right of Ontario
(Liquor Control Board of Ontario) Employer
BEFORE Michael Lynk Vice-Chair
FOR THE UNION Val Patrick
Ontario Public Service Employees Union
Grievance Officer
FOR THE EMPLOYER Justin Diggle
Liquor Control Board of Ontario
Counsel
HEARING March 9, 2015
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Decision
I. Introduction
[1] This is an interim decision with respect to whether a grievance has been filed in an untimely
fashion. The Liquor Control Board of Ontario (the “Employer”) has asked the Grievance
Settlement Board to declare that the first of the two grievances filed by the Ontario Public
Service Employees Union (the “Union”) on behalf of Mr. John Robbins is out of time, and
that I should not exercise my statutory discretion to waive the governing time limits.
[2] At the time of his termination, Mr. Robbins was a casual employee of the Liquor Control
Board of Ontario. He had worked at its warehouse in London, Ontario since his hiring in
May 2011. Mr. Robbins is grieving two separate incidents of discipline. In December 2012,
he was suspended for 15 working days following allegations of carelessness and intentionally
reckless behaviour at work which purportedly breached the Employer’s health and safety
procedures and policies. Subsequently, the Employer terminated Mr. Robbins in April 2013,
following incidents in late February 2013 when he is alleged to have disobeyed work orders
from a superior, and to have also purportedly taken unscheduled and unapproved breaks
during the same work shift. Additionally, as part of the decision to terminate Mr. Robbins,
the Employer has alleged that Mr. Robbins disobeyed his supervisor’s direction regarding an
incident involving a warehouse transporter in mid-March 2013. In arriving at its decision to
terminate Mr. Robbins, the Employer relied in part upon the prior 15 day suspension issued
in December 2012.
[3] On 9 April 2013, Mr. Robbins and the Union filed two grievances, one contesting the 15 day
suspension, and the second challenging the subsequent termination. The Employer has taken
the position that Mr. Robbins’ 9 April 2013 grievance against the 15 day suspension is
several months out of time, and there are no justifiable reasons for waiving the time limits.
OPSEU maintains that the circumstances in this case justify the waiving of the time limits.
This ruling deals only with the Employer’s preliminary motion to dismiss the 15 day
suspension grievance as untimely.
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II. Evidence
[4] The only witness to give testimony at the hearings on the preliminary issue was Mr. Robbins.
The facts were largely uncontested.
[5] Mr. Robbins initially received a written Notice of Intended Discipline (NOID), dated 27
November 2012, which detailed an allegation of workplace misbehaviour involving him that
was said to have occurred on 26 November. (A NOID is a written notice created by the
Employer which initiates a disciplinary process.) Mr. Robbins subsequently attended a
discipline meeting on 5 December with management. He was accompanied by Mr. Dan Rath,
a local union steward.
[6] Following the 5 December meeting, the Employer decided to impose discipline on Mr.
Robins. By letter dated 7 December 2012 to him, the Employer detailed the results of its
investigation into his purported misbehaviour at the workplace during the November
incident. The letter then stated that Mr. Robbins was being suspended for 15 consecutive
working days, beginning with his scheduled shift on 10 December 2012 and ending after the
final suspended scheduled shift on 2 January 2013. The suspension letter was copied to Mr.
Greg Wilson, the local OPSEU president for the warehouse workers in London. The Union
did not challenge the Employer’s express assertion that I should presume that Mr. Wilson
received a copy of the letter. I shall proceed on that assumption, although little turns on this.
[7] Mr. Robbins’ first shift back at work following the suspension was 3 January 2013. He
testified in direct examination that, during that shift, he spoke with Mr. Dan Rath, a union
steward at the warehouse. He said that he asked Mr. Rath about the grievance process.
According to Mr. Robbins, Mr. Rath told him that he would have Mr. Mark McKerlie, the
chief union steward at the warehouse, contact him to initiate the paperwork for the grievance.
The following day, Mr. McKerlie provided Mr. Robbins with a grievance form, which Mr.
Robbins completed and returned to Mr. McKerlie on or about 4 January. Mr. Robbins did not
retain a copy of the grievance. He testified that, after 4 January, he did not have any further
contact with either of the stewards about his grievance. Mr. Robbins testified that he assumed
that the grievance had been filed and was proceeding through the process.
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[8] In late February 2013, Mr. Robbins was issued with another NOID by the Employer. This
NOID alleged that Mr. Robins was involved in workplace misbehaviour during an incident
on 21 February. With a union representative, Mr. Robbins met with the Employer on 14
March to discuss the allegations. He stated on direct examination that he did not recall any
discussion at this meeting about the 15 day suspension grievance. He also testified that he
was not called to any grievance meetings regarding the 15 day suspension throughout this
period after 4 January.
[9] Mr. Robins was subsequently issued a termination letter, dated 8 April 2013, arising out of
several incidents of purported misbehaviour in February and March. He recalled meeting
with Mr. Wilson, the local president, on 9 April, and signing a grievance form to challenge
his dismissal. In his testimony, he stated that Mr. Wilson told him during this meeting that
the union was going to re-grieve the 15 day suspension, and so Mr. Robbins also signed a
separate grievance on that day to challenge the December 2012 suspension. It was only on
that day, he stated, that he realized that the December suspension had not been formally
grieved by the Union.
[10] On cross examination, Mr. Robbins said that he met with Mr. Rath about grieving his 15 day
suspension in early January, at the time of his return to work. He stated that Mr. Rath
encouraged him to grieve his suspension. Subsequently, on or about 4 January 2013, Mr.
McKerlie brought a grievance form to Mr. Robbins for his signature. Mr. Robbins
acknowledged that he did not pay close attention to the form when he signed it, and he was
not provided with a copy of the signed grievance form. He also acknowledged that he did
not subsequently follow up with Mr. McKerlie or Mr. Rath with respect to the status of the
suspension grievance, nor did they subsequently approach him at any time to provide
information about the status or progress of the grievance.
[11] In response to a question that I asked, Mr. Robbins stated that when he met with Mr. Wilson
on 9 April 2013 to sign the two grievances, he was not shown the grievance form that he said
he had signed in early January with respect to the 15 day suspension. Mr. Robbins also said
that he did not ask for an explanation in April as to why the Union did not file the suspension
grievance in January.
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[12] None of the three local union officers who were directly or indirectly involved in Mr.
Robbins’ attempt to file a grievance in January 2013 against his 15 day suspension – Mr.
Rath, Mr. McKerlie and Mr. Wilson – were called by the Union to testify.
[13] In its reply to the suspension grievance, dated 10 April 2013, the Employer raised the
timeliness objection, taking the position that the grievance was out of time after 20 December
2012. There is no issue that the Employer’s objection was made in a timely fashion.
III. Statute and Collective Agreement
[14] There are several relevant provisions in the governing collective agreement that pertain to
this issue:
Preamble
The general purpose of the Agreement is to establish and continue harmonious relations
between the Employer and the employees covered by this Agreement and consistent
therewith to provide procedures for the prompt and just disposition of differences and
grievances.
Article 27.3 STAGE 1 (Complaint Stage)
(a) (i) An employee who has a complaint or a difference shall discuss the complaint or
difference with his/her supervisor, as designated by the Employer, within ten (10)
days of the employee first becoming aware of the circumstances giving rise to the
complaint or difference.
(ii) Unless otherwise agreed between the employee and his/her supervisor, a meeting
in respect of an employee’s complaint shall only be attended by the employee and
his/her supervisor.
(b) The supervisor shall consider the complaint or difference and give his/her response to
the employee within ten (10) days of the discussion.
(c) If the complaint or difference is not satisfactorily resolved by the supervisor, it may
be processed within an additional ten (10) days from the date of the supervisor’s
response or the expiration of the time limits set out in (b) above, in the following
manner.
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Article 27.4 STAGE 2
(a) The employee may file a grievance in writing with his/her supervisor specifying the
clause or clauses in this Agreement alleged to have been violated.
(b) The supervisor shall complete an investigation of the grievance and provide the
grievor with his/her written decision within fifteen (15) days of receiving the
grievance. The investigation may include a meeting with the employee affording
him/her an opportunity to be heard.
Article 27.10
(c) At any STAGE of the Grievance Procedure, the time limits imposed upon either
party may be extended, in writing, by mutual agreement.
Article 27.12
Where a grievance is not processed within the time allowed or has not been processed by
the employee or the Union within the time prescribed it shall be deemed to have been
withdrawn.
[15] The parties also accept that s. 48 (16) of the Ontario Labour Relations Act, 1995, SO 1995, c
1, Sch A, has been imported into the bargaining relationship of the parties through the
provisions in the Crown Employees Collective Bargaining Act, SO 1993, c 38. Section 48
(16) provides that an arbitrator has the jurisdiction to extend time limits in a collective
agreement, notwithstanding bargained language to the opposite effect, where reasonable
grounds for the extension exist, and where the opposing party will not be substantially
prejudiced by the extension:
Except where a collective agreement states that this subsection does not apply, an
arbitrator or arbitration board may extend the time for the taking of any step in
the grievance procedure under a collective agreement, despite the expiration of
the time, where the arbitrator or arbitration board is satisfied that there are
reasonable grounds for the extension and that the opposite party will not be
substantially prejudiced by the extension.
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IV. Arguments
Liquor Control Board of Ontario
[16] Mr. Diggle, for the Employer, submitted that the 9 April 2013 grievance challenging Mr.
Robbins’ 15 day suspicion, imposed in December 2012, should be dismissed because it is
significantly out of time. Mr. Diggle pointed to the mandatory language in the collective
agreement, to the fact that the grievance was filed more than three and a half months late, to
the fact that the grievance was handled in early January by experienced union officers who
should be very familiar with the time limits, and to the fact that no one from the union was
summoned as a witness to explain to the Grievance Settlement Board as to why a grievance
was not filed by 20 December 2012.
[17] The thrust of the Employer’s position is that the collective agreement, in Article 27.3(a)(i),
stipulates that an employee who has a complaint or difference shall initiate a discussion with
his or her supervisor “within 10 days of being aware of the circumstances that gave rise to
the complaint or difference”. Mr. Diggle stated that the clear meaning of this provision was
that the time limit for Mr. Robbins began ticking when he commenced the first day of his
suspension on 10 December 2012, with 20 December – 10 calendar days later – being the
final day to file a grievance.
[18] As well, Mr. Diggle pointed out that the parties had negotiated explicit language with respect
to a failure to abide by the stated time lines. Article 27.10(c) provides that the time limits
could be waived only by mutual agreement. In this present case, the Union had not sought an
agreement with the Employer to extend the time limits. As well, Article 27.12 expressly
states that a grievance that had not been processed within the negotiated time limits would be
deemed to have been withdrawn. According to Mr. Diggle, this is strong language for a
collective agreement, and must be kept closely in mind by a vice- chair when considering a
request to extend the time limits.
[19] As for the issue of prejudice incurred by the Employer, Mr. Diggle asserted that the incident
which gave rise to the suspension occurred in late November, and punishment was issued in
early December, but the grievance challenging the suspension was not filed until after the
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termination of Mr. Robbins, in early April. In determining the appropriate punishment for the
incidents in February and March 2013, the Employer relied upon the fact that the 15 day
suspension had not been grieved and was therefore a settled and completed matter.
[20] The Employer submitted a considerable number of cases as authority for its motion to
dismiss the suspension grievance: OPSEU v. Ontario (Ministry of Community Safety and
Correctional Services) (McClelland), [2013] O.G.S.B.A. No. 84 (Briggs); OPSEU v. Ontario
(Ministry of Community Safety and Correctional Services) (Mazara) (2012), 215 L.A.C. (4th)
336 (Gray); OPSEU v. Ontario (Ministry of Community Safety and Correctional Services)
(Liantzakis), [2011] O.G.S.B.A. No. 165 (Petryshen); British Columbia Public Service
Agency v. Professional Employees Assn. (Prodanuk), [2011] B.C.C.A.A.A. No. 151
(Germaine); West Fraser Electro/Mechanical Ltd. v. CEP, Local 1133 (Hunt) (2009), 188
L.A.C. (4th) 131 (Coleman); Vale Inco Ltd. v. USWA, Local 6500 (Cadotte), [2008] O.L.A.A.
No. 781 (Burkett); New Flyer Industries Ltd. v. CAW (Nault), [2002] M.G.A.D. No. 43
(Chapman); Ontario Liquor Board Employees’ Union v. Ontario (Liquor Control Board)
(Brennan), [2002] O.G.S.B.A. No. 27 (R. Brown); Cominco Ltd. v. USWA, Local 480
(Raymond) (2000), 87 L.A.C. (4th) 380 (Ready); Ontario Liquor Board Employees’ Union v.
Ontario (Liquor Control Board) (Gamble), [1998] O.G.S.B.A. No. 1635/96 (Gray); Helen
Henderson Care Centre and Service Employees Union, Local 183 (1992), 30 L.A.C. (4th)
150 (Emrich); Re Children’s Aid Society of Algoma and C.U.P.E., Local 1880, [1992]
O.L.A.A. No. 359 (Brent); Gabriel of Canada Ltd. and I.A.M., Local 1295 (1988), 34 L.A.C.
(3d) 42 (T. Jolliffe); Re Cassellholme Home for the Aged (District of Nipissing East) and
C.U.P.E., Local 146 (1982), 3 L.A.C. (3d) 377 (H.D. Brown); Greater Niagara General
Hospital v. O.N.A. (Pagonis) (1981), 1 L.A.C. (3d) 1 (Schiff); Re Toronto East General and
Orthopaedic Hospital Inc. and Service Employees Union, Local 204 (1980), 28 L.A.C. (2d)
74 (Palmer); Re City of Toronto and C.U.P.E., Local 43 (1977), 16 L.A.C. (2d) 123 (Abbott);
and Re Becker Milk Company Ltd. and Teamsters Union, Local 647 (1978), 19 L.A.C. (2d)
217 (Burkett). As well, it relied upon D. Brown & D. Beatty, Canadian Labour Arbitration
(Toronto: Canada Law Book, loose-leaf, Dec. 2014 update) (4th Ed.), para. 2:3128.
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OPSEU
[21] For the Union, Mr. Patrick submitted that the facts, properly considered, lead to the
conclusion that the Employer’s motion to dismiss the suspension grievance for lack of
timeliness should itself be dismissed.
[22] Mr. Patrick pointed to the preamble of the governing collective agreement. He noted that Mr.
Diggle had emphasized the term “prompt…disposition of differences and grievances”. He
observed that the full phrase states that the parties have agreed to provide the “prompt and
just disposition of differences and grievances.” The resolution of the Employer’s motion
must factor in whether it would be just to dismiss the suspension grievance on the basis of
timeliness in light of all the circumstances.
[23] The Union disagreed with the Employer as to when the clock starts ticking, as per the 10 day
time limit in Article 27.3. Mr. Patrick submitted that the clock is only activated in
disciplinary suspension circumstances when the penalty ends, not when the penalty begins. In
these present circumstances, Mr. Patrick argued that the clock started on 3 January 2013,
when Mr. Robbins resumed work after serving his 15 day suspension.
[24] Mr. Patrick pointed to the fact that the grievor was unsophisticated when it came to grievance
filing, and this lack of experience should not work against him with the stakes so high. Mr.
Robins had less than two years service with the Employer at the time of the suspension, he
had not encountered any progressive discipline before then, and he reasonably thought that,
through his union, the necessary steps had been taken in early January 2013 to initiate the
grievance against the suspension.
[25] As well, the Union emphasized that the express conditions in s. 48(16) – “reasonable grounds
for the extension and that the opposite party will not be substantially prejudiced by the
extension” – outweigh any language in the governing collective agreement and place a
substantial onus on the Employer to make its case for the dismissal of the grievance on
timeliness issues.
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[26] With respect to the issue of substantial prejudice on the Employer, Mr. Patrick submitted that
there is no evidence before me that, if the suspension grievance was permitted to be litigated
on its merits, the Employer would be disadvantaged through the waning of memory, the loss
of documents or the unavailability of witnesses. Consequently, there is no discernible
prejudice.
[27] The Union did not submit any caselaw authority to support its position. Rather, Mr. Patrick
critically reviewed the Employer’s submitted caselaw to distinguish their application to this
matter.
Liquor Control Board of Ontario -- Reply
[28] Mr. Diggle addressed four points in his reply. First, he emphasized that the language in the
governing collective agreement on the filing of grievances was mandatory, and not left as a
choice to the parties whether to honour or not. Second, he disagreed with the Union as to
when the clock starts in motion on the filing of a grievance. Mr. Diggle maintained that the
clock starts ticking when the discipline is imposed. In this matter, the relevant time would be
10 December 2012, when Mr. Robbins started the first day of his suspension.
[29] Mr. Diggle’s third point went to the Union’s argument that Mr. Robbins was a short-term
employee with little experience with the filing of grievances. Mr. Diggle observed that the
Union did not call any of the three local union officers as witnesses during the hearings on
the preliminary motion. The Union offered no explanation as to its failure to file the
suspension grievance in a timely fashion, and this should count heavily in my considerations
when deciding on the motion. As well, Mr. Diggle disagreed with the Union’s position that
the April 2013 decision to discharge Mr. Robbins was founded on the prior suspension. He
maintained that, while it played a role and was a contributing ground in the decision-making,
it was not the main reason for the termination.
[30] The fourth and final point made by the Employer in its reply arguments went to the issue of
prejudice. Mr. Diggle asserted that the prejudice present in this case goes to the right of the
Employer – a bargained right – to have grievances against its decisions filed and processed in
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a timely fashion. In particular, he maintained that respectful and productive industrial
relations requires that the application of discipline – a fundamental feature in industrial
relations – demands in many cases a solid, reliable, transparent and defensible record as a
building block. Allowing a 15 day suspension to go unchallenged for almost four months,
and then to initiate a grievance only when the Employer is subsequently put in a position to
impose more discipline, and therefore has to review the grievor’s file to assess the
appropriateness of the new discipline, can only add an unhelpful and unnecessary element of
uncertainty to the conduct of progressive industrial relations.
V. The Law
[31] The starting point for the determination of whether a legal decision-maker, operating under s.
48(16) of the Labour Relations Act, 1995, should exercise her or his jurisdiction to relieve
against an untimely filed or advanced grievance is the 1982 ruling by Arbitrator Schiff in
Greater Niagara General Hospital, supra. His award has become the touchstone for
assessing timeliness claims in Ontario. Building upon an earlier seminal award on timeliness
by Arbitrator Burkett in Re Becker Milk, supra, Arbitrator Schiff laid out six interrelated
factors to assess the worthiness of a request to relieve against the time limits in a collective
agreement so as to dismiss a grievance on the basis that it is untimely, and to not hear and
decide the matter on its merits:
i. The nature of the grievance – The more significant the issue is to
the parties – such as a termination or the imposition of serious
discipline, or a vital collective agreement interpretation – the
greater the weight that should be given to an extension. A matter of
less significance will be accorded less weight.
ii. Whether the delay occurred at the launch of the grievance or at
some later point in the process – If the delay occurred with a
failure to initiate the grievance within the timelines, the employer
will not learn what the grievor alleges nor have an opportunity to
secure its own position. A prejudice caused by the failure to adhere
to time limits may not be as serious to the employer if the delay
occurred later in the process.
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iii. Whether the grievor was responsible for the delay – A stronger
presumption against any timeliness relief would exist if the grievor
bore sole or primary responsibility for the delay. Notwithstanding
this, if the responsibility for the delay fell entirely or largely on the
union, this would not become a positive feature in favour of
granting the relief. Rather, it would more likely have the effect of
neutralizing the factor.
iv. The reason(s) for the delay – A finding of bad faith by the party
that failed to file or advance the grievance would be a considerable
mark against providing relief. Negligence, carelessness or
disregard for the time limits would be less unacceptable, but still a
matter of some concern.
v. The length of the delay – All things being equal, the longer the
delay, then the greater the onus on the union and/or the grievor for
providing a credible reason to explain the delay.
vi. Whether the employer could reasonably have assumed that the
grievance had been abandoned – Union inaction that lulls an
employer into a false sense of security may be given a weighty
factor. This goes to the prejudice that an employer may face: it
may well be lead to believe that no grievance is forthcoming or
that the matter has been implicitly withdrawn by the union, and it
may not take steps to protect its position, such as preserving
memory, protecting evidence or marshalling arguments.
[32] In addition to this very helpful list of factors from Greater Niagara Regional Hospital,
subsequent rulings on timeliness have issued some useful observations that have enriched the
analysis into this question:
• The sophistication of the grievor, and her or his familiarity with the grievance
process, can be an element to be considered. If the grievor is, or had been, a
local union officer, or had previously filed grievances, this may be a factor
against extending time limits: Donwood Institute and OPSEU (1997), 60
L.A.C. (4th) 367 (Brandt). Conversely, a grievor who had never filed a
grievance before, and who depended on the union for guidance, may result in
a more lenient approach towards timelines: Ontario (MCSCS) (Brennan),
supra.
• Arbitrators differ as to the significance of an initial failure to grieve
unchallenged prior discipline which was used to justify a subsequent
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termination, based on the principles of progressive discipline. Some
arbitrators have held that unchallenged prior discipline cannot be reopened
merely because the grievor is now facing termination based in part on the
prior record. There must be other, persuasive reasons to justify timeliness
relief: Ontario (MCSCS) (McClelland), supra. Other arbitrators have said that
unchallenged prior discipline which creates a ‘serious impact’ on the grievor
requires the employer to demonstrate ‘real prejudice’ in order to thwart the
operation of s. 48 (16). Real prejudice amounts to a course of action that
would not otherwise have been taken and it must be a course of action that
cannot be reversed without harm to the employer: Vale Inco Ltd, supra. This
latter observation is broadly consistent with the requirement in s. 48 (16) that
the prejudice to the employer has to be substantial.
• A three month delay is not a modest delay, but nor is it, by itself, an
intolerable length of time. While no hard-and-fast rule creating a bright red
line based on the length of the delay exists, or should exist, given the other
factors at play, requests for a time limit extension in this time range have been
turned down – Ontario (MCSCS) (McClelland); British Columbia Public
Service Agency, supra – and, conversely, have been allowed to proceed in
order to be heard on their merits: Liquor Control Board of Ontario (Brennan),
supra. To be sure, arbitrators have dismissed grievances when the timeliness
breaches had been shorter than three months – Helen Henderson Care Centre,
supra; and West Fraser Electro/Mechanical Ltd., supra – and permitted time
extensions when the breach far exceeded three months: Re City of Toronto
and CUPE, Local 43 (1990), 17 L.A.C. (4th) 420 (Springate); and Re Ferranti-
Packard Transformers Ltd. and USWA, Local 5788 (1993), 36 L.A.C. (4th)
307 (Haefling).
• Unions and employees owe a general obligation of due diligence to employers
and the industrial relations process in ensure the timely filing and
advancement of grievances: (Ontario (MCSCS) (Mazara). However, this must
be balanced with the long-standing industrial relations rule that, as much as
possible, workplace differences should be resolved on their substance rather
than on technical or procedural issues: Blouin Drywall Contractors Ltd. and
UBC (1975), 8 O.R. (2d) 103 (C.A.); Vale Inco Ltd.
• While the ultimate legal source governing the issue of timeliness in Ontario is
s. 48 (16), adjudicators should pay attention to the intentions of the parties, as
expressed by the language governing time limits in the collective agreement.
If the parties have chosen mandatory language, even if they have decided not
to preclude the operation of s. 48 (16), this should be a consideration in the
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decision-making: (Ontario (MCSCS) (Mazara); Liquor Control Board of
Ontario (Gamble), supra; Helen Henderson Care Centre.
VI. Decision and Reasons
[33] The first question for me to decide has to do with when the grievance clock starts to tick.
Although this question is not decisive in determining the ultimate issue before me, this was a
point of difference between the Employer and the Union, and it may be helpful to the parties
to have this matter clarified. Mr. Patrick for the Union has argued that, in our circumstances,
the clock remains dormant until the grievor had completed the discipline. In other words, Mr.
Robbins and the Union were not in breach of any collective agreement time limits until 10
calendar days after the last day of his served suspension. According to this view, the
grievance clock would only start in motion on 3 January 2013, and the grievance time limits
would have expired on 13 January. Mr. Diggle for the Employer has submitted that the clock
starts ticking in a discipline matter when the grievor starts to serve her or his punishment. In
this scenario, the grievance clock began on 10 December, when Mr. Robins served the first
day of his suspicion, and the grievance was due by 20 December.
[34] In Liquor Control Board of Ontario (Brennan), Vice-Chair Richard Brown read Article 27 to
say that the grievance starts ticking when the grievor becomes aware of the workplace
discipline, as per Article 27. In Brennan, the grievor, who initially received a three day
suspension, did not utilize the stage one informal complaint process. Therefore, the clock was
triggered when the grievor received his letter of suspicion, and expired 10 calendar days
later. I agree with Vice-Chair Brown’s reading of the collective agreement. (A similar
reading of the start-time for the timeliness clock is found in Liquor Control Board of Ontario
(Gamble)). In our case, no evidence was led as to when Mr. Robbins actually received the 7
December 2012 letter of discipline, so I will assume that he became aware on the same day
that he commenced serving his discipline, namely 10 December. No argument was made at
the hearing that the Union or Mr. Robbins sought to rely upon or utilize the stage one
informal complaint process. Accordingly, the time limits would have expired on 20
December. As a consequence, Mr. Robbins’ 9 April 2013 grievance against his 15 day
suspension was more than three and a half months late.
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[35] I now turn to the issue at hand. After applying the various relevant factors and considerations
to the facts of this case, the result is a near-draw between the merits of the arguments
submitted by the Employer and the Union. Favouring the Employer are the facts that the
delay occurred at the very start-point of the grievance process, leaving the Employer to
understandabl y assume that it would not have to defend its decision through the grievance
process; the lack of any explanation by the Union for the delay of three and a half months in
filing the grievance; the mandatory language on time limits in the collective agreement; and
the reliance by the Employer on the unchallenged suspension when it decided to
subsequently dismiss the grievor for a purported and unrelated series of misbehaviour
incidents at work.
[36] On the other hand, I acknowledge that the Union has relevant factors and considerations on
its side of the ledger as well. The grievance at hand involves a 15 day suspension, which,
short of termination, is about as serious as industrial discipline can become. The grievor was
not responsible for the lengthy delay in initiating the grievance. As well, he had no or little
prior experience in filing a grievance. On the evidence, Mr. Robbins had assumed,
reasonably, that his local union officers would follow through with their undertaking to
launch a grievance on his behalf in early January. (Parenthetically, I note that, had the
grievance been initiated at this time, it would also have been out-of-time under Article 27).
Additionally, the Employer has not made out a case that it would suffer any substantial
prejudice in any arbitral defence of its decision to impose the 15 day suspension on Mr.
Robbins, aside from the fact, mentioned above, that it had relied upon the unchallenged
suspension in its subsequent decision-making.
[37] I have carefully considered the competing factors and considerations provided in the
authorities presented to me. In particular, I have paid attention to the ruling by Vice-Chair
Brown in Liquor Control Board of Ontario (Brennan), which comes closest to the facts in
our case and which also involved a timeliness issue between the Employer and the Union. In
Brennan, the Employer imposed a three day suspension on the grievor. The grievor and the
Union did not file a grievance against the suspension for 11 ½ weeks after the expiry of the
time limits. The grievor was subsequently terminated, with the Employer relying in part upon
the unchallenged three-day suspension as part of the disciplinary record. The failure to file
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the suspension grievance in a timely fashion was found to be the responsibility of the Union
(due to a careless misunderstanding as to whether a grievance had been initially filed within
the time limits), rather than the grievor, who was unsophisticated with respect to the
grievance process. The Employer did not contend that it would be substantially prejudiced by
an extension.
[38] In the circumstances, Vice-Chair Brown exercised his statutory discretion and extended the
period of time for filing the grievance. I note that the three-day suspension in Brennan is
considerably shorter than the 15 day suspension in our present case. The mandatory
collective agreement language in Article 27 in Brennan is the same language that exists in
the current version of the agreement. The length of the delay in Brennan was about a month
shorter than our case, which is a notable, but not a large, difference. One pertinent distinction
between the cases is that the Union in Brennan presented an explanation for the delay, a
factor missing in our present case.
[39] The other authority that was cited to me involving the present parties is Liquor Control
Board of Ontario (Gamble), authored by Vice-Chair Owen Gray. Gamble is a thoroughly
reasoned ruling that is a model of analysis on the issue of timeliness. However, it can be
distinguished from our present case via one significant fact: the delay in filing the grievance
in Gamble was two years, compared to our three and a half months. Vice-Chair Gray held
that the length of the delay was simply too great, notwithstanding the lack of demonstrable
prejudice that would be suffered by the Employer, to warrant relief under s. 48 (16). He
stated that reasonable grounds to relieve against a delay of this length did not exist in
Gamble.
[40] Of the other authorities that were presented to me, I have found the following cases to be
particularly useful precedents when assessing the evidence of the case before me.
[41] Ontario (MCSCS) (McClelland) is a 2013 decision of the Grievance Settlement Board,
involving a three day suspension that was not grieved for three and a half months after the
time limits expired. A termination on other grounds subsequently followed. At the hearing,
the union urged Vice-Chair Briggs to extend the time limits, in part because the suspension
was being used as a building block for the termination. The Vice-Chair declined to exercise
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her jurisdiction. McClelland involved the very same length of time delay as our present case,
the same point of delay in the grievance process (i.e., the initial filing of the grievance), and
the same general discipline situation (i.e., an unchallenged suspension, later followed by a
termination that relied upon the suspension as part of the progressive discipline). The union
did offer an explanation for the delay in this case, but this was not accepted by the Vice-
Chair as amounting to reasonable grounds. However, McClelland is distinguishable from our
case because the length of the suspension was considerably smaller, and the grievor, who
bore primary responsibility for the delay, had previously filed six grievances and was very
familiar with the grievance process. In matters involving a substantial suspension that creates
a serious impact upon a grievor – such as a 15 day suspension – I am in agreement with
Arbitrator Burkett in Vale Inco Ltd. that, all other factors and considerations being equal, a
real prejudice should have to be shown by the employer in order to justify the denial of a
time limit extension where the time limit breach involved a relatively short or moderate
period of time.
[42] In Helen Henderson Care Centre, the time limit delay was 13 days, and occurred at the very
start of the grievance process. The collective agreement language on time limits was
mandatory. As with our case, there was no good explanation for the delay. The request for a
time limit extension was denied. However, the significant difference between Helen
Henderson and our case is the fact that the grievance in that matter involved pay rates, a
matter of importance in industrial relations, to be sure, but not at the same qualitative level as
a 15 day suspension.
[43] In Vale Inco Ltd., the union failed to grieve the imposition of a ‘fourth-step’ discipline, which
was subsequently relied upon by the employer several months later when it terminated the
employee. The grievance challenging the ‘fourth-step’ discipline was approximately 50 days
out of time, and was filed at the same time as the dismissal grievance. The employer
maintained that its reliance on the unchallenged discipline amounted to sufficient prejudice
such as to justify the denial of any time limit extension. The time limits language in the
collective agreement, while not mandatory, stipulated that grievances should be filed and
processed “without undue delay”. No real explanation was offered by the union for the delay,
beyond the fact that the matter had fallen through the cracks. In Vale Inco, Arbitrator Burkett
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allowed the time limits to be extended, ruling, at para. 17, that he was not satisfied that the
prejudice faced by the employer through its reliance on prior unchallenged discipline,
without more, constituted “a type of prejudice that ought to prevent relief from the time
limits in the filing of a grievance in respect of prior discipline.”
[44] With all of this in mind, I have decided to exercise my authority under s. 48 (16) and allow
the collective agreement time limits in this matter to be extended. I say this for two reasons.
In doing so, and particularly in light of the near-draw in the arguments presented to me, I
have kept in mind that the Employer bears the ultimate onus to establish its case on this
preliminary matter.
[45] First, the two fundamental factors that are provided for in s. 48 (16) – whether there are
reasonable grounds for an extension and whether the employer would be substantially
prejudiced by an extension – favour the granting of an extension of the time limits. The
reasonable grounds in this case include the length and seriousness of the industrial discipline
involved (i.e., 15 days), the non-involvement of the grievor in the delay, and the fact that the
length of the delay – while a matter of genuine concern at three and a half months – is within
a range that has been accepted, all other things being equal, in other comparable arbitration
decisions. As well, I am not persuaded that the Employer would be substantially prejudiced
by an extension. In particular, it is apparent that the Employer would not face difficulties in
presenting evidence and documents, summoning witnesses, or encountering decayed
memories if it would be required to justify its suspension decision before this Board.
[46] Second, I am very mindful of the various factors that support the Employer’s argument, yet
they have not persuaded me that I should refrain from applying my authority under s. 48 (16).
I have weighed these cumulative points that were compellingly advanced by Mr. Diggle: the
stage in the grievance process where the delay occurred; the reliance by the Employer on the
unchallenged suspension when it was deciding upon the subsequent termination; the decision
by the Union not to call any of the local officers to explain the delay; and the mandatory
language in the collective agreement. Ultimately, these factors, while significant, do not
outweigh the grounds for relieving against the time limits in this case. The fact that the delay
occurred at the very beginning of the process, and the fact that the Employer subsequently
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used the unchallenged grievance as part of its basis for Mr. Robbins’ termination go largely
to the issue of prejudice. I have found that the degree of prejudice faced by the Employer
would not substantially impair its ability to mount a proper defence of its suspension
decision. I have carefully considered the mandatory language on time limits in the collective
agreement but, at the end of the day, I find, as Vice-Chair Brown found in Brennan, that this
factor does not trump the other considerations leaning towards the exercise of the discretion
to extend the time limits. Finally, the decision by the Union to not call any of the local union
officers to explain why the suspension grievance was not filed in a timely fashion was
unhelpful to the Union’s case, but, on the scale of things, this did not decisively tip the scales
against an extension of the time limits. I say this because the totality of the evidence before
me, even with an adverse inference drawn against the Union as to why the suspension
grievance was not filed in January 2013, would still indicate that nothing more than
negligence or carelessness on the part of the Union was involved. As the caselaw that we
have reviewed indicates, this is a factor to consider, but not a decisive factor by itself.
[47] For all these reasons, the Employer’s preliminary motion to dismiss the 15 day suspension
grievance filed by the Union on behalf of Mr. Robbins on 9 April 2013 is denied. I will hear
Mr. Robbins’ suspension grievance on its merits, along with the termination grievance, on
dates already scheduled by the Board.
Dated at Toronto, Ontario this 12th day of May 2015.
Michael Lynk, Vice-Chair