HomeMy WebLinkAboutVenema 92-03-17H E A D N O T E
OPSEU #91F228
OPSEU LOCAL #110
OPSEU (Venema, L .) and Fanshawe College
Award dated March 17. 1992 (Bendel)
Other - Admission to College Programs - Normal Entrance and Admission Requirements
Benefits - Admission to college Programs - Normal Entrance and Admission Requirements
GRIEVANCE UPHE.LD: The grievor sought admission to a College program under Article 18.03 of the CMT
Academic Agreement. She met the program eligibility criteria, but was screened out in a competition process due to
the number of applicants. The majority concludes that Article 1 8.03 essentially exempts bargaining unit applicants
from the normal process: instead, they are simply required to establish that they meet the objective requirements for
the program . Thus, where a program is over subscribed, the employee does not have to compete with other
applicants, so long as she can establish that she meets those requirements which are "objective and constant factors,
ones that are fixed and easily ascertained".
The College was ordered to admit the grievor to the program for the following term.
Pamela A. Chapman
IN THE MATTER OF AN ARBITRATION
BETWEEN
Fanshawe College,
Employer,
- and -
Ontario Public Service Employees Union,
Union
BEFORE: Michael Bendel, Chair
Jacqueline G. Campbell, Employer Nominee
Brian Switzman, Union Nominee
APPEARANCES: For the Union:
Pamela Chapman, Counsel
Paddy Musson, Local President
Gary Fordyce, Chief Steward
Laura Venema, Grievor
For the Employer:
Barry Brown, Counsel
Patricia Kirkby, Dean, Health Sciences and Human
Services
Caroline Buchanan, Assistant Registrar
Gail Rozelle
Hearing held in London, Ontario, on January 13, 1992.
ARBITRAL AWARD
The grievance of Laura Venema raises the question of the proper interpretation of Article 18.03 of the collective
agreement, which reads as follows:
An employee in the bargaining unit may take, for a tuition fee of not more than $20.00, on the employee's own
time, (a) Ministry approved programs or courses, or (b) other programs or courses as mutually agreed,
which the College currently offers. The employee must meet the normal entrance and admission requirements.
Ms. Venema is a professor who teaches in the Dental Assistant Program. She is interested, for various reasons, in
taking the Dental Hygiene Program. In all respects, she meets the formal requirements for admission to that
program. In February 1991, she applied for admission for September 1991. However, over 1,000 applications were
received for the program, and enrollment was limited to 18 students. The employer uses a Grid to determine which
of the applicants receive offers of admission. The grievor's score on the Grid was not high enough, and she was not
offered admission to the program.
The grievor has been teaching in the Dental Assistant Program at the College since 1982. She had obtained a
Diploma in that program herself in 1977, and had worked in dentists' offices as a Dental Assistant in the interim.
The Dental Assistant Program is a one-year program to train students as Dental Assistants. Successful completion
of that program is a prerequisite for admission to the Dental Hygiene Program (although equivalences are
recognized). The Dental Hygiene Program is also a one-year program. The critical difference between the Dental
Assistant and the Dental Hygienist qualification is that the Dental Assistant is not trained or qualified to work in
patients' mouths. Their work extends to assisting the dentist in all other matters, such as radiography, sterilization of
instruments, preparation of materials, patient records, reception work and office management. The Dental
Hygienist, in addition to performing these duties, can use instruments to clean patients' teeth. The Dental Hygienist
qualification is a more prestigious one. It is the qualification to which many Dental Assistants aspire.
The College Calendar gives the following information on the Dental Hygiene Program:
PROGRAM ELIGIBILITY CRITERIA
REQUIRED ACADEMIC PREPARATION ONE OF
(a) Successful completion of a CAAT Dental Assistant program,
OR
(b) OSSD/SSGD or Mature applicant with Grade 11 or Grade 12 Biology and Grade 11 or Grade 12 Chemistry, or
the equivalent,
AND THE FOLLOWING
* Successful completion of the Healing Arts Radiation Protection (H.A.R.P.) Module.
* At least one year of full time work experience as a certified or certifiable Dental Assistant.
* Must provide proof of certification or eligibility for certification by the Ontario Dental Nurses and Assistants
Association.
It is not disputed that the grievor meets all of these requirements.
The Calendar goes on to give further details about admission to the Dental Hygiene Program:
RECOMMENDED ACADEMIC PREPARATION
* Grade 13/OAC Biology and/or Chemistry are highly recommended as a valuable preparation for success in this
program.
RECOMMENDED PERSONAL PREPARATION
* Students should develop personal responsibility, emotional maturity and decision making skills. The
ability to work independently without direct supervision is a definite asset. Above average interpersonal skills will
also complement the successful applicant.
APPLICANT SELECTION CRITERIA
Where the number of eligible applicants exceeds the available places in the program, the Applicant Selection
Criteria will be:
A. The General Selection Criteria applicable to all programs (See the "Admission to the College" section of this
publication).
B. Achievement in the academic Program Eligibility Criteria stated above.
C. Achievement in the RECOMMENDED ACADEMIC PREPARATION.
D. Assessment of personal suitability based on life experience as indicated by:
* Supplementary Form (only applicants who achieve a high score on their academic record will be assessed on their
Supplementary Form).
The practice followed by the College in admitting applicants to this program is as follows. First, it eliminates those
applicants who do not meet the Program Eligibility Criteria. Then, it ranks all remaining applicants according to a
Grid that gives credit for academic grades achieved in the required courses, and also for meeting the "recommended
academic preparation", i.e. Grade 13/OAC Biology and Chemistry. Finally, it examines the "personal suitability
based on life experience" of the top 75 remaining applicants, and makes offers of admission to those students,
starting from the top of the list. In the fall of 1991, the grievor failed to make the final list of 75 applicants.
Although she had Grade 13 Biology to her credit, she only had Grade 12 Chemistry. This, it seems, is the main
reason for no offer being made to her. A previous application, in the fall of 1990, was also rejected.
The parties' positions
The union's principal argument was that Article 18.03 entitled employees to admission provided they meet the
"normal entrance and admission requirements", which, for the Dental Hygiene Program, meant the Program
Eligibility Criteria quoted above. Article 18.03, according to the union, did not require qualified employees to
"compete" for places in over-subscribed programs with other applicants. The union noted that Article 18 is headed
"Professional Development Leave"; from this, it could be inferred that the purpose of Article 18.03 was not limited
to allowing employees to take courses for a nominal fee, but included guaranteeing that qualified employees would
in fact be admitted to programs.
The union's alternative argument was that the process for admitting applicants to the Dental Hygiene Program was
defective, in that it did not comply with certain requirements of the College's Calendar. In particular, the Calendar
states that "No Ontario Academic Course (OAC) or Grade 13 Course will be required" as a program eligibility
criterion or as an applicant selection criterion; this is said to be "in accordance with Ministry policy". Yet,
according to the union, the College was in fact ranking applicants according to whether they had Grade 13
Chemistry and Biology or not. In addition, the Calendar states that the Admissions Grid "will include all academic
and non-academic selection criteria". Yet, according to the union, the factor of "personal suitability based on life
experience" was only used in the case of the 75 students who ranked highest on the academic components of the
criteria. The union argued that the criteria used by the College could not be regarded as "normal" since they were
inconsistent with the Calendar.
The employer replied that the word "normal" in Article 18.03 did not mean "minimum". The collective agreement
provided that employees would gain admission to programs if they met the standards normally used to determine
admission. The normal approach, in the case of over-subscribed programs, involved the application of the Grid. The
employer conceded that there might be some ambiguity in the Calendar, resulting from different statements in the
document, but the procedure it followed was in general compliance with the Calendar. In any event, its procedure
was applied in the same way to all applicants and that procedure therefore constituted the "normal" one.
Reasons for decision
Employees are entitled, under Article 18.03, to "take... programs" if they "meet the normal entrance and admission
requirements". The question raised by the grievance is whether, in the case of an over-subscribed program, an
employee must compete with other applicants and be admitted to the program in order to be permitted to take it.
The language of Article 18.03, in our view, is quite clear. The Article does not require that employees submit an
application for admission, or that, procedurally, they be treated as other applicants. The agreement is limited to the
substantive aspects of the admission process: employees "must meet the normal entrance and admission
requirements". As far as process is concerned, the agreement does not require that the regular process be followed.
In our view, once an employee wishing to take a program demonstrates that he or she is qualified to do so, by
reason of meeting the entrance and admission requirements, the employer is bound to permit the employee to take
the program.
The fact that the normal admission process does not apply to employees has an important bearing on the meaning of
the term "normal entrance and admission requirements". These requirements must be limited to objective and
constant factors, ones that are fixed and easily ascertained. It cannot be intended to encompass criteria whose
application could only be determined through the normal admission process. It is obvious that whether or not a
particular applicant is admitted as a result of the normal admission process will depend on the strength of the
competition, which fluctuates from year to year and which could only be assessed through that process. We have
therefore concluded that the ranking of applicants for admission, by means of the Grid, while part of the normal
admission process, cannot have been intended to apply to employees wishing to take programs.
This conclusion is supported by the use of the verb "meet" in Article 18.03, which suggests that employees wishing
to take a program must attain a particular objective standard. According to Webster's New Collegiate Dictionary,
the word means (among other things) "to conform to esp. with exactitude and precision". The word is not a
particularly appropriate one to describe the phenomenon of competition that is a feature of the regular admissions
procedure.
It is not disputed that the grievor met the program eligibility criteria for the Dental Hygiene Program. In our view,
this means that she has "[met] the normal entrance and admission requirements". The employer violated the
collective agreement when it refused to allow her to take this program in the 1991-92 year.
The appropriate remedy, in our view, is the one sought by the grievor, namely that she be allowed to take this
program starting in the fall of 1992, and we so order.
DATED at Ottawa, Ontario, this 17th day of March 1992.
Michael Bendel,
Chair
concurI dissent
(dissent attached)Jacqueline G. Campbell,
Employer Nominee
I concur see
Brian Switzman,
Union Nominee
Dissent
I have reviewed the majority award of the Board and cannot concur with the decision.
In my opinion the question raised by the grievance is whether the language of Article 18.03 confers upon an
employee a privileged right to admission beyond that which may exist for other applicants.
The Board's decision is that the language of Article 18.03 does not require an employee to submit to the regular
process for admission if that employee meets the entrance and admission requirements for the program. The Board
further suggests that the Article does not require that an employee submit to the normal admission process.
The Union's position is that Article 18.03 guarantees admission where an employee meets minimum qualifications
as determined by the program eligibility criteria and that no comparison of employees was contemplated. The
Employer contends that Article 18.03 does not confer any privileged entrance and admission status to employees
but rather requires them to meet the same eligibility criteria and undergo the same evaluation process as for all
other applicants.
In my opinion, the use of the word "normal" rather than "minimum" supports the Employer's position. The evidence
before the Board was that the "normal" process for this and other oversubscribed programs involved both an
assessment against the program eligibility criteria and the applicant selection criteria.
The use of the word "normal" (defined in the Oxford Dictionary as "usual, regular, typical") is indicative that the
parties did not contemplate that bargaining unit employees were to be given privileged or guaranteed status in the
admission process but rather were to be treated in the same way as other applicants. The absence of wording to the
contrary only reinforces this position.
I would therefore have dismissed the grievance.