HomeMy WebLinkAboutCrich et al 94-03-3093F600 CRICH ET AL VS FANSHAWE
IN THE MATTER OF AN ARBITRATION
BETWEEN:
ONTARIO COUNCIL OF REGENTS FOR COLLEGES OF APPLIED ARTS AND
TECHNOLOGY IN THE FORM OF FANSHAWE COLLEGE
(hereinafter called the "College")
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(FOR ACADEMIC EMPLOYEES)
(hereinafter called the "Union")
GRIEVANCES OF LOU NEWELL, COLLIN PATTERSON, FRANK HASTIE, FRED
FAAS, MORRIS HOOVER, ROSS CRICH, S. HUNT, AND JOSEPHINE PELLER
OPSEU FILE NOS. 93F600 - 93F606
(hereinafter called the " Grievors")
BOARD OF ARBITRATION: Richard H. McLaren
Jon McManus, Union Nominee
David Guptill, College Nominee
COUNSEL FOR THE COLLEGE: Barry Brown
COUNSEL FOR THE UNION: Chris Paliare
A HEARING IN RELATION TO THIS MATTER WAS HELD AT LONDON, ONTARIO, ON
FEBRUARY 4, 1994.
-2-
PRELIMINARY AWARD
There are eight (8) Grievors involved in these proceedings. In essence, the grievance for
each of them is in similar terms. The grievance of Mr. Lou Newell, dated June 23, 1993, is taken
to be representative of the other Grievors and reads as follows:
On November 1, 1991 the Joint Educational Qualifications Subcommittee voted on the
following motions:
(i) That all individuals possessing a B . A. and B. Ed. should get step 16 (maximum
salary progression)
(ii) That individuals with a Teaching Certificate, achieved as a result of 180 hours of
study, and therefore comparable to the In Service Training, have maximum Step
16.
On April 20, 1993 Arbitrator McLaren ruled that the two motions became actions of the
committee upon which the Colleges are required to act.
When I became aware of the above, I wrote to you in early June and requested that these
rulings be applied to me. The College's response was that they refused to do so. I can not
agree with this decision.
Therefore, I grieve the College is violating Article 14 and Appendix 2 et al of the Collective
Agreement. As remedy I seek that the College apply the rulings of the JEQS and Arbitrator
McLaren to me thus recognizing my qualifications as being maximum step qualifications. I seek
this retroactive to November 1, 1991, with interest.
The Counsel at the time of the commencement of the hearings in this matter agreed that
the grievances had been properly processed through the grievance procedure and that the matter
was properly before the Board of Arbitration. The first day of hearings was taken up with a
procedural argument with respect to res judicata and issue estoppel from the Union; and, a
preliminary jurisdictional point from the College. It is as a result of these submissions that the
present preliminary award is written.
On April 20, 1993, a Board of Arbitration issued a majority decision, comprised of the
present Chair and Union Nominee Mr. Jon McManus, in respect of a grievance filed between the
present parties to this proceeding in the grievance of Mr. Gary Fordyce. In that award a question
arose as to the implications of a meeting of the "Joint Educational Qualifications Subcommittee",
known as JEQS, and its impact on the Fordyce grievance. The majority of the Board of
Arbitration found at the bottom of page 15 and top of page 16 that:
...Therefore, as a matter of law, this Board of Arbitration ought to conclude that there was a
consensus, as the Committee has required in the past, in order for motions to be confirmed. The
Board also concludes that the meeting was properly established pursuant to the JEQS
Committee's own procedure, in view of its interpretation of the collective agreement. There was
a quorum present and it must be concluded, given the findings of law by this Board, that there
were two motions approved by the Committee, which must be considered as motions of the
JEQS Committee pursuant to Appendix 1, paragraph 4. Therefore, the College is unable to act as
it did in denying the grievance of the Grievor. The Board of Arbitration declares that there was a
motion of the Committee which entitled the Grievor to its benefits...
The parties were unable to agree as to the implementation of the majority award in respect
of the Fordyce grievance as it might affect anyone other than Mr. Fordyce. This resulted in the
further re-convening of that Board for the purpose of hearing evidence and argument with
respect to the remedies which ought to flow from the declaration made by the majority of the
Board in its award of April 20, 1993. A unanimous Supplementary Award as to the remedy was
issued in an award dated December 14, 1993.
Between the Supplementary Award and the majority declaratory award in the Fordyce
grievance the Grievors before this Board filed their grievances, all dated June 23,1993, or
thereabouts. The Grievors allege entitlement to the benefit of the rulings of the JEQS committee
found to have been made as a result of the meeting of November 1, 1991, which were recognized
and declared to exist by the arbitration decision of April 20, 1993.
The relevant provisions of the predecessor collective agreement as set out in the
Fordyce award at page 1 and 2 read as follows:
In Appendix 1 of the extended agreement under the heading "Guidelines", in paragraph 4
beginning at page 70, the collective agreement provides:
The parties agree to the establishment of a Joint Educational Qualifications
Subcommittee to consider and rule on further formal educational qualifications
for the purpose of maximum salary level identification under the salary scale.
Such Committee shall be composed of three (3) representatives of the Union and
the Council of Regents respectively and shall decide the Committee's procedures.
Any further qualification must be agreed to by the representatives of both the
Council of Regents and the Union and shall be in writing.
Pursuant to this provision and its predecessors there has been a JEQS Committee in
existence since June of 1975. It was formed "as an off-shoot of the C.A.A.T. Academic
Negotiating Teams". The interpretation the JEQS Committee placed upon the provision
in the Collective Agreement is found in its manual (Exhibit #5). In the closing paragraph
of its history at page 3 the Committee provides its interpretation of the Collective
Agreement provision under which it has operated over the years. It reads as follows:
"The JEQS meets on a regular basis to consider individual submissions.
Committee decisions are made only at meetings which are attended by a
minimum of two representatives of each party. Decisions are made on a
consensus basis and are final and binding."
(Exhibit #6 in this proceeding)
The provisions of the predecessor collective agreement expired on August 31, 1991. That
agreement was extended until a new collective agreement was assigned on November 9, 1992. In
the meantime, the JEQS met on November 1, 1991, during the extension period of the
predecessor collective agreement. The Fordyce grievance was filed under the extended collective
agreement on December 2, 1991. Therefore, the Fordyce award was issued in response to a
grievance filed under the predecessor collective agreement and relates to its interpretation and
application to the grievance.
The relevant provisions of the renewal collective agreement read as follows:
Article 14
SALARIES
14.03 A 4 Employees with the following qualifications shall be entitled to progress to the
maximum step on the salary schedule:
(i) A General Pass University degree plus a Bachelor of Education degree;
(ii) Three year CAAT Diploma or General Pass University Degree or
Certified Journeyman holding equivalent qualifications, plus a valid
Ontario Teacher's Certificate granted before 1992 or equivalent as may be
ruled on by Joint Educational Qualifications Subcommittee (JEQS);
(iii) A General Pass University Degree, plus a valid Ontario Guidance
Specialist's Certificate granted before 1992 or equivalent as may be ruled
on by the JEQS; or
(iv) The In-Service Teacher Training Program Certificate. As this is a unique
in-service College program, equivalencies are not considered.
APPENDIX II
JOINT EDUCATIONAL QUALIFICATIONS SUBCOMMITTEE
- the provisions of this Appendix are identical to those quoted from Appendix I of the
predecessor collective agreement and are not repeated here but set out above at p. 4.
As is noted in the Fordyce award at page 5/6 the first motion of the JEQS meeting of November
1, 1991, is now incorporated into the renewal agreement by the parties as a result of their
collective bargaining in clause ( i) of Article 14.03 A 4. The second motion of the JEQS is the
subject of clause (iv) of Article 14.03 A 4. Their motion made a Teaching Certificate comparable
to in-service training. The collective agreement in clause (iv) states that the in-service training is
unique and therefore no equivalencies are considered. The difference between the word
"comparable" and "equivalencies" is made much of in the argument of the Union.
In support of its position it is argued on behalf of the Union that the JEQS is an ad hoc
collective bargaining arm of the parties whose purpose is to determine comparable educational
qualifications amongst members of the bargaining unit to ensure some measure of uniformity
across the community college system in the province of Ontario. It is submitted that the
determination that there was a JEQS meeting on November 1, 1991, and what it decided is either
res judicata; or, issue estopped from being re-determined by this Board in this award. In essence
it is submitted that the College cannot add new or different evidence on these issues in these
proceedings. In support of the primary position of the Union reference was made to the following
case:
Re CUPE and Extendicare Health Services Inc. (1993), 14 O.R.
(3d) 66 (C.A.).
In support of the College's position in response to the Union's primary argument it is submitted
that the Fordyce award misconstrued a provision of the collective agreement and, therefore, its
interpretation is in error. Where this is the case the arbitral jurisprudence indicates that there is
no requirement that a subsequent Board of Arbitration must apply the prior decision particularly
where that subsequent Board of Arbitration is constituted under a different and revised collective
agreement. Therefore, the College can call appropriate evidence to argue this case unaffected by
any prior evidence and any prior proceeding because the matter is not res judicata. It can call
further new and different evidence in regard to the JEQS meeting of November 1, 1991 and is
not issue estopped. In support of these propositions reference was made in the submission of the
College to the following jurisprudence:
Isabelle v. Ont. Public Service Employees Union (1981), 122 D.L.R. (3d) 385 (Ont.
S.C.C.); Re Manitoba Food Union and Canada Safeway (1981), 120 D.L.R. (3d) 42
(Man.C.A.); Re Artcraft Engravers Ltd., 12 L.A.C. (4th) 363 (Brent, 1990); Re Steel Co.
of Canada Ltd. and U.S.W., 27 L.A.C. (2d) 252 ( McLaren, 1980); and, an unreported
decision between Loyalist College of Applied Arts and Technology and Ontario Public
Service Employees Union (For Academic Employees), chaired by Arbitrator Howe, in an
award dated January 26, 1994.
In support of its position the College also raised a preliminary point. It was submitted in
this preliminary aspect that the collective agreement was signed in November of 1992 and it
ended the continuing agreement under which the JEQS decision of November 1, 1991 was made.
It was submitted that the changed and revised collective agreement applied and not the
committee determinations of JEQS. In support of its preliminary position reference was made to
the following arbitration decisions:
Re Goodyear Canada Inc., 28 L.A.C. (2d) 196 ( Picher, 1980); Re Parkwood Hospital, 4
L.A.C. (3d) 215 (Weatherill, 1984); Re Romi (A Division of Ault Foods Ltd.), 25 L.A.C.
(3d) 377 (Weatherill, 1986); Re F.B.M. Distillery Co. Ltd., 31 L.A.C. (3d) 122 (Brown,
1987); Re Mack Canada Inc., 2 L.A.C. (4th) 304 (Burkett, 1988); Re International Nickel
Co. of Canada Ltd., 22 L.A.C. 286 ( Weatherill, 1970);and, an unreported decision
between St. Lawrence College of Applied Arts and Technology and Ontario Public
Service Employees Union, chaired by Arbitrator Burkett, in an award dated December
31, 1991.
In reply to the preliminary argument as to the jurisdiction of this Board, the Union
submitted that the College was attempting to shut down the Board's jurisdiction to determine the
matter under Article 14.03 A 4 (iv). It was further submitted that a distinction is to be drawn
between the language of the collective agreement which states entitlement to "progress" with no
"equivalencies" to the in-service teacher training programme and the JEQS motion, which
decides that an in-service teaching certificate is "comparable to the in-service program" and
therefore, "have a maximum of step 16" Therefore, the motion of JEQS deals with a different
subject matter than the collective agreement and is res judicata or issue estopped with respect to
this different determination. In the alternative, if the College is somehow correct in its position
on clause (iv) the Grievors are entitled to be paid as they now request as a result of the
November 1, 1991 determination of the JEQS. They had a vested right and Article 14.03 A 4
cannot take that away. All that is required is a determination in a retrospective order that they
were entitled to be paid as per the JEQS decision of November 1, 1991. In support of that
proposition, reference was made to the following cases:
Re Dayco (Canada) Ltd. (1993), 102 D.L.R. (4th) 609 (S.C.C.); and Re Regional
Municipality of Ottawa- Carleton, 16 L.A.C. (4th) 353 (Haefling, 1990).
DECISION
1. The Jurisdiction of this Board of Arbitration
These grievances were brought in June of 1993 under the current collective agreement which
was signed on November 9, 1992 and, not under that of the predecessor collective agreement
under which the Fordyce declaratory arbitration and supplementary remedial award were issued.
They were brought after the Fordyce award as a result of its existence. The basis for filing them
stems from the interpretation of a prior collective agreement by the Fordyce award. If the
Grievors are entitled to be paid as they allege; then their rights must arise under the present
collective agreement under which they filed the grievances and not under its predecessor and the
interpretations of it by way of the Fordyce award. They had the opportunity to have filed their
grievances under the predecessor collective agreement as did Mr. Fordyce. They chose not to do
so. They are, as a consequence, required to apply the current provisions of the collective
agreement in the determination of their grievances.
The Salary Schedule of the prior collective agreement provided:
APPENDIX 1
SALARY SCHEDULES
(Effective September 1, 1990)
(a) Professors and Counsellors and Librarians
The salary maxima are established in terms of relevant formal education levels and
equivalencies as listed below:
***
Step 16 58,710 Maximum Salary - 4 year Canadian University Degree or more;
C.G.A; P.Eng; C.A.; or C.M.A. (formerly R.I.A.); In-
Service Teacher Training Program Certificate
NOTE:Formal educational qualifications not specified above will be subject to evaluation
by the Joint Educational Qualifications Subcommittee.
***
(Exhibit #5)
At p. 29 of the current collective agreement the present applicable provision is found described
as "Maximum Salary Table". It provides:
"Maximum Step on the 4-year Canadian University salary schedule (maximum) Degree
or more; C.G.A.;P.Eng.; C.A.; C.M.A.(formerly R.I.A.)
A comparison of the applicable provisions reveals that the parties have radically restructured all
the collective agreement provisions relating to salaries. In so doing they have specifically deleted
the reference at Step 16 to the "In-service Teacher Training Program Certificate" reference in
Appendix 1 of the prior collective agreement. Instead they have inserted into the present
collective agreement Article 14.03 A 4.
Article 14.03 A 4 in clause ( i) provides for entitlement to progress to the maximum with
a "General Pass University degree plus a Bachelor of Education degree". The first motion of the
JEQS committee on November 1, 1991 read "...all individuals possessing a B.A. and a B.Ed.
should get step 16 (maximum salary progression)" (Exhibit #6 at p.5). Under Article 14.03 A 4
in clause (iv) the parties provided entitlement to progress to the maximum step on the salary
schedule for those employees with the "... In-Service Teacher Training Program Certificate". In
so providing they also stated that "As this is a unique in-service College program, equivalencies
are not considered" (emphasis that of this Board). The second motion of the JEQS committee on
November 1, 1991 read "That individuals with the teaching certificate, achieved as a result of
180 hours of study, and therefore comparable to in-service training, have maximum step 16".
The above examination of the salary table and the collective agreement article reveals
that the parties have by their collective bargaining chosen to incorporate, but not in identical
terms, the motion of the JEQS committee as a provision of the renewal collective agreement in
the form of Article 14.03 A 4 ( i). They also chose to reverse the JEQS committee in its second
motion when it determined that a teaching certificate achieved with 180 hours of study was
comparable to in-service training. The parties were completely free to act in the fashion in which
they have done. What is the effect of their actions?
The JEQS committee is merely an emanation of the parties. In the Fordyce award it was
described at p. 1 as:
It was formed 'as an off-shoot of the C.A.A.T. Academic Negotiating Teams'.
In the current collective agreement at p. 29 the "Maximum Salary Table" Article 14.03 A 1 (b)
the Note indicates:
Formal educational qualifications not specified above will be subject to evaluation by the
Joint Educational Qualifications Subcommittee, as described in Appendix II.
Appendix II is identical to a paragraph in the predecessor collective agreement in Appendix 1
under the heading "Guidelines" in paragraph 4 which is quoted in the Fordyce award at p. 1. The
JEQS committee is an emanation of the parties. As the Note to the Maximum Salary Table
indicates, it evaluates formal education qualifications where they have not been specified by the
parties themselves. It is an ongoing ad hoc extension of the parties bargaining which is
empowered to make final and binding decisions on qualifications where the parties have not
done so themselves in the collective agreement. It is an inferior body to them and is only
intended to have effect where the parties collective agreement is silent. The JEQS committee has
effect under a collective agreement to the extent it acts within its jurisdiction, which the Fordyce
award held it had done under the predecessor collective agreement. When the parties come to
bargain and choose to elevate one of its motions into the collective agreement they are
completely free to so act. They are also free to reverse the effect of an earlier motion. In either
case the motion no longer exists. Instead, there is a provision in the collective agreement
replacing the motion. The JEQS committee in effect fills in the gaps where required. It is not
empowered to amend the collective agreement by putting in place or continuing earlier motions
contradictory to the collective agreement.
The provision of the current collective agreement which would apply to the grievances is
clause (iv). For those who do not otherwise have entitlement under the preceding clauses of
14.03 A 4 they can achieve it by way of the "In-Service Teacher Training Programme
Certificate". However, if they have not achieved that qualification the clause goes on to provide
that "equivalencies are not considered". The second motion of the JEQS committee of November
1, 1991 would have permitted those individuals with a "...teaching certificate, achieved as a
result of 180 hours of study. . . " to be considered as a " . . . comparable to in-service training,
have maximum step 16". The second motion contradicts the language of the current collective
agreement. The current collective agreement achieves this contradiction by the use of different
language of no "equivalencies" rather than a specific comparable. Nevertheless, its effect is to
render the motion of the emanation of the parties' bargaining relationship nugatory in its impact
because the renewal collective agreement has a provision within it which deals with the subject,
albeit in slightly different language. The fact that the language is different in the collective
agreement from that of the JEQS committee motion is immaterial to the conclusions here
because it is the parties change as a result of the bargaining process which renders the earlier
motion nugatory. Therefore, it is unnecessary to compare the variations in language despite the
able argument of Union counsel as to the significance of those variations.
All of the foregoing means that the jurisdiction of this Board only goes to|interpreting and
applying the current collective agreement. The grievances were brought after the new collective
agreement was in place. The salary structure created in the new agreement had been the subject
of bargaining between the parties. The grievors had an interest in what occurred at the bargaining
table. A motion of the JEQS committee under the predecessor collective agreement which
contradicts that agreement cannot affect the interpretation or application of the current
agreement.
The situation which arises in this case is a variant of the Re International Nickel
Co. of Canada Ltd. and Re GoodYear Canada Inc. cases, supra In those cases it was held that an
employee could not bring a claim under an existing collective agreement by way of a claim to
entitlement arising under an expired agreement. It is submitted that this case is not subject to this
principle because it is either res judicata; issue estopped; or, there are vested rights so as to make
it a continuing grievance of an ongoing breach of the current agreement which is a recognised
exception to the principle just stated.
2. Res Judicata
The principle of res judicata as it applies in arbitration decisions was described by the
present Chair in the decision of Re Steel Co. of Canada, Ltd., supra, at p. 257:
... [ it] arises where a board is called upon to decide an issue that is identical to one
decided by an earlier arbitration board, involving the same parties and under the same or
an unaltered collective agreement...
As has already been discussed above the language of the current and predecessor agreements are
not identical. While the same parties are involved and the facts would appear to be identical the
agreement is a different one. The issue of whether the Grievors are being correctly paid under the
current collective agreement is not identical to the issue decided under the predecessor
agreement because the language has changed and the JEQS committee motions have been
inserted into the current agreement. The Fordyce award is dependent on the JEQS committee
motions. The current grievances are dependent upon an interpretation of the revised and different
current collective agreement. In the course of interpreting the collective agreement the Union
argues that the factual determinations as they relate to the JEQS committee cannot be
redetermined by this Board That is more in the fashion of an argument as to issue estoppel than
res judicata. The principles of res judicata do not apply to the present grievances. This is the case
regardless of the argument of the College that the Fordyce award is incorrect and ought not to be
followed. This line of reasoning only applies if res judicata is found to be applicable but
discretion will not be used to apply the principle because it is thought the prior decision was
manifestly wrong. That question of interpretation of the prior award does not have to be
determined here because the principle itself is found not to apply.
3. Issue Estoppel
The question of issue estoppel is fully discussed in a judgment of the Divisional Court in
Re Greater Niagara Transit Commission and Amalgamated Transit Union, Local 1582 (1987) 61
O.R. (2d) 565. The Commission had suspended an employee charged with theft from its fare
boxes and monies received for other purposes. The suspension was to remain in effect pending
the disposition of the criminal charges and/or further review. In statements to the police made
prior to the charges the employee admitted to having taken monies from the employer. The trial
judge in the criminal hearing excluded the statements pursuant to s. 24(2) of the Canadian
Charter of Rights and Freedoms because it infringed the accused's right in s. 10(b) to retain and
instruct counsel without delay. After the dismissal of the charges, the Commission dismissed the
employee. A board of arbitration was constituted in accordance with the terms of the collective
agreement with the present chairperson as its chair. A majority held that the employee ought to
be reinstated to employment although not necessarily to the particular job or any other one of
trust. It did so because the majority held that the evidence excluded by the trial judge was
inadmissible in the arbitration proceedings. That being the case there was insufficient evidence to
uphold the discharge. See Re Greater Niagara Transit Commission, 26 L.A.C. (3d)
1 (McLaren, 1986).
As a result of this decision an application for judicial review was made and granted.
In that decision it was said at p. 581:
There is one final matter of general principle which ought to be here mentioned ... As a
general rule, interlocutory findings of fact made in one proceeding, as for example a
criminal trial, do not engage the operation of the doctrine of issue estoppel in subsequent
proceedings, whether of the same or different type, between different parties, in view of
the absence of elements of finality and identity of issues critical to the operation of the
doctrine.
The court then noted that an arbitration board is not strictly confined in its reception of evidence
to admit only that which is receivable in a court of law because of the provisions of the Labour
Relations Act which confers discretionary powers to receive evidence whether admissible in a
court of law or not. Therefore, to treat the ruling in the criminal proceeding as determinative of
the admissibility issue as it emerges in the arbitration proceedings, is inimical to the underlying
principle and meaning of the evidentiary provision of the Labour Relations Act.
The Board of Arbitration in a subsequent decision admitted the evidence found
the grievor to have committed theft and upheld the discharge in a decision reported at 34 L.A.C.
(3d) 283 (McLaren, 1988).
The very able argument of the counsel for the Union amounts to the submission that the
College is estopped from relitigating the findings of fact as to the existence of a meeting of the
JEQS committee on November 1, 1991 and what motions were passed as a consequence. The
principles set out above require this Board to exercise its discretion to determine if the evidence
ought to be heard again concerning the JEQS committee and its meeting of November 1, 1991 or
determine that the issue is estopped from being relitigated. The submission is that public policy
of the justice system, and here of the arbitral system, requires that the matter be litigated fully
once and then not relitigated. While if these eight grievances were not heard together it might be
possible to apply issue estoppel in the seven arbitration hearings subsequent to the first hearing
and determination. However, that is a different situation than what is asserted to be estopped
here. In essence it is said that no other finding of fact as to the JEQS committee matters is to be
made than that contained in the Fordyce award. The Board has already determined that the
matter is not res judicata which means that the Board is not required to apply the prior Fordyce
decision to the issues before it. In view of the Board's disposition of the vested rights arguments
of the Union set out below; and the jurisdictional discussion above it is inappropriate for this
Board to apply issue estoppel to the findings of fact contained in the Fordyce award. It will,
therefore, in any further evidentiary proceedings in these grievances decline to exercise its
discretion to apply issue estoppel to the facts as to the JEQS committee matters as set out in the
Fordyce award.
4. Vested Rights from Predecessor Agreement
It is submitted by the Union that when the Fordyce award retrospectively declared that
there was a JEQS committee meeting and that it passed two motions on November 1, 1991 it had
the effect of establishing rights in the present Grievors. Their grievances are a claim under the
current collective agreement to enforce an entitlement arising under the prior agreement and
continuing to be violated under the current one.
On November 1, 1991, with the benefit of the Fordyce award, it could be said that the
present Grievors had entitlement to step 16 of the maximum salary progression. They did not
grieve under the predecessor collective agreement. The parties drafted revised language to deal
with the issue of equivalent or comparable qualifications to the In-service Teacher Training
Program Certificate in the current collective agreement. The JEQS committee motions under the
predecessor agreement were merely the actions of an emanation of the parties which they were
free to change in collective bargaining and did not in fact so do. In that bargaining process
resulting in the current agreement the claims the Grievors might have had under the predecessor
agreement were altered by action of the parties. For this Board to determine that they held vested
rights carrying forward under the collective agreement is to rewrite the collective agreement
contrary to the parties specific collective bargaining. There were no vested rights. The Grievors
had rights under the predecessor agreement which they did not pursue. It is too late for those
vested rights to be pursued under the revised current agreement.
This case is not like the cases cited to the Board by the Union where reference back to a
prior agreement is made in the process of determining a starting position for calculating things
such as seniority, pension rights, or vacation entitlement under a current agreement. The
employment relationship is a continuing one and from time to time it is necessary to review an
individual person's position under a prior agreement in order to determine either how to treat
them under the current agreement or determine entitlements under it. In that sense there can be
reference back to prior agreements. What is desired here is reference back to establish a right no
longer in existence under the current agreement because it was taken away in collective
bargaining. There can be no reference to the predecessor agreement in order to establish a claim
under the current one.
In so determining the Board rejects the alternative argument of the Union that the
grievors possessed vested rights under which they are entitled to be paid as per the JEQS
determination as of November 1, 1991. This Board is constituted under the current collective
agreement which it must interpret and apply to the grievances.
Conclusions
The Grievors' grievances are to be determined under the provisions of the current
collective agreement which is the only one this Board has jurisdiction to interpret and apply. In
so determining them the interpretation issues are not res judicata because of the Fordyce award.
To the extent that the JEQS committee was found as a fact to have met on November 1, 1991 and
to have passed two motions, these facts have been determined but are not estopped from being
redetermined in this proceeding to the extent that those facts may arise in resolving the present
grievances.
With the foregoing conclusions the matters giving rise to this preliminary award have
been disposed of. The grievances are to be determined under the current collective agreement
using the principles enunciated in this award. If the parties wish to proceed to have the
grievances heard they are to advise the Chairperson of this Board in writing of that desire within
thirty days of the date of this award. If no such advice is received it is ordered that the grievances
be dismissed because mere had been no violation of the collective agreement.
DATED AT LONDON, ONTARIO THIS 30th DAY OF MARCH, 1994.
Richard H. McLaren, C.Arb.
I dissent
See Attached Dissent
Signed "Jon McManus"
Jon McManus, Union Nominee
I concur
Signed "David Guptill"
David Guptill, College Nominee
DISSENT
I have had the opportunity of reviewing the award of the majority and with respect I must
dissent. My comments are restricted to the issue of vested rights from a predecessor agreement
and the application of the analysis from the Re Regional Municipality of Ottawa Carleton case
What the Fordyce award determined was that people in Mr. Fordyce's position (including the
present grievors) should have progressed to Step 16 on the salary grid as of November 1, 1991.
In other words, as a matter of law, as of that date these grievors should have been at Step 16.
In the Ottawa-Carleton case, the grievors were entitled to grieve their current vacation credits by
an examination of their incorrect treatment under past collective agreements. There was no
dispute that the employer was currently accruing vacation credits properly in accordance with the
collective agreement in respect of their current service. Rather, it was determined that the
grievors' total accrued service was incorrect because of past improper accruals. Further, this was
an appropriate subject matter for a grievance under the present collective agreement.
The majority here distinguishes the Ottawa-Carleton case on the basis that in Ottawa-Carleton,
the collective agreement language did not change. With respect, I must disagree. In our case, the
issue is not the application of the current collective agreement language to past periods. That
would be entirely inappropriate. Rather, the current collective agreement provides a current right
to have certain entitlements. In some cases, a current entitlement may be subject of the
accumulation of prior accruals, including accruals over periods of time covered by prior
collective agreements. In Ottawa-Carleton, it was the accrual of vacation credits. Here it is the
accrual of pay steps in the salary progression.
If the accruals were improperly calculated in the past, the current entitlement will also be in
error. To determine the correctness of past accruals, the standard to be applied must be the
collective agreement in force at the time the accrual occurred (or should have occurred).
Otherwise, the result is grossly unfair to the individual employee and the employer becomes the
beneficiary, in perpetuity, of failing to properly apply new pay increments.
It can not be disputed that as of November 1, 1991 the grievors should have been at the top step
of the pay grid. Based on the majority's analysis, the new collective agreement arguably removed
the ability of such persons to progress to the top step as of the date it came into force. However,
as a matter of law, the grievors already had the right to be at the top step. The grievors do not
seek to progress to the top step under this collective agreement. Rather this progression (or
accrual) was wrongfully denied them under the prior collective agreement. Because their current
place on the grid is simply a product of their past accruals, their correct current entitlement must
be at the top step.
The change in the collective agreement determines entitlement to progress on a prospective, not
a retrospective basis. The current collective agreement took away the right to progress to the top
step for persons who would have otherwise acquired this right after that date. But for the
wrongful conduct of the employer, these grievors should already have been at that step. Had that
progression been accrued correctly, these grievors would have been at the top step today. That is
their correct current entitlement under the current collective agreement. That is something which
they are entitled to grieve.
In the result, I would have dismissed the Employer's preliminary objection and allowed the
matter to proceed.
JON McMANUS