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HomeMy WebLinkAbout1988-0020.Bleach & Ronkai.89-02-27 ONTARIO EMPLOYES DE LA COURONNE · . GROWN EMPLOYEES DE L'ONTARIO GRIEVANCE' C,OMMISSION DE SETTLEMENT REGLEMENT BOARD DES GRIEFS 18(7 DUNDAS STREET WEST, TORONTO, ONTARIO. M5G 1Z8- SUITE 2100 TELEPHONE/T~:Lf"PHONE 180, RUE DUNDAS OUEST,. TORONTO, (ONTARIO) MSG IZ8 - BUREAU 2100 (416) 598-0688 0020/88 IN THE MATTER OP AN ARBITRATION Under THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT Before THE GRIEVANCE SETTLEMENT BOARD Between: OPSEU (D. Bleach, Z. Ronka~) - and - The Crown ~n RiGht of Ontario (Minist~y of Co~ectional Services) Employer Before: J,D, McCamus VSce-Chairperson T, Kea~ney Member D. Wallace Member For the Griev01~: N. Wilson Counsel gow/inG & Henderson Barriste~s_~ Solicitors For the Employer: R.W. Little Hicks Morley Hamilton Stewart Storie Barristers & Hearings: September 12, 1988 DECISION This grievance arises from a dispute concerning the entitlement to lieu days of employees whose work assignment would have required them to work on a statutory holiday but who were unable to do so because of a compensable work related injury with respect to which they had made a successful Workers' Compensation Board claim. Prior to August 5, 1987, it was the Employer's practice to pay such employees only for the statutory holiday and not to grant them lieu days in addition. As a result of two decisions of the Grievance Settlement Board, however, Charbonneau (544/81) and McDermid (366/86), which ruled that this practice did not constitute a proper application of the Collective Agreement, the Employer's policy was changed, effective August 5, 1987 so as to ensure the granting of lieu days in such cases (Exhibit 3). There is, therefore, no issue between the parties at the present time with respect to the proper interpretation of the Collective Agreement. The issue that has to be resolved with respect to the two individual grievances in the present case relates to the question of time limits. A grievance brought on behalf of Mr. Bleach was filed on January 24, 1988, and claims for lieu days for work assignments on August 4, 1986, December 26, 1986 and January 1, 1987 (Exhibit 1). The grievance brought on behalf of Mr. Ronkai was filed on January 15, 1988 and relates to a claim for May 21,-1984. The Employer argues that these grievances have not been filed in timely fashion, and places reliance for this proposition on Article 27.2.1 of the agreement, which provides as follows: · An employee who believes he has a complaint or. difference 2 shall first discuss the complaint with his supervisor within twenty (20) days of first becoming aware of the complaint or difference. Article 27.2.2 in combination with article 27.3.1 provides that if the "complaint or difference is not satisfactorily resolved within seven days a grievance may be filed within ten days". Article 27.13 provides that "if a grievance is not processed within the time allowed...it shall be deemed to have been withdrawn" and the parties are in agreement in the present case that this has the effect of making the time limit set out in Article 27.2.1 mandatory. The central issue in the present case, then, rests on a determination of when the twenty day period set out in article 27.2.1 begins to r~n. The Employer's position, briefly stated, ~s that time begins to run once an employee is aware of the decision which he or she now wishes to dispute. In the present case, that would be the Employer's decision not to grant lieu days for the statutory holidays in issue, thus rendering the present grievances very substantially out of time. The Union argues, on the other hand, that time does not begin to run until the employee appreciates that the matter is one that is grievable, or potentially grievable, under the Collective Agreement. Counsel for both parties rely on previous decisions of the.Grievance Settlement Board to support these apparently conflicting propositions and have invited this panel of the Board, in effect, to choose between them. Before turning to a consideration of past jurisprudence on this point, however, it will be useful to briefly recount the circumstances in which the individual grievances have arisen and in which the individual grievors have sought redress through the grievance procedure. Mr. Ronkai sustained a compensable injury-to his knee in 1982 with respect to which surgery was necessary in 1982 and in 1984. Mr. Ronkai was off work for this purpose in May of 1984 and did not get a lieu day for his work assignment on May 21, 1984. Mr. Ronkai returned to work in early June and in due course noticed that he had not received a credit for this lieu day on the stub of his next pay cheque. Accordingly, he went to the Personnel Department and sgoke to Ms. Schuler about the matter. Though Ms. Schuler was herself a member of the bargaining unit, she was, as far as the evidence before this Board indicates, an appropriate person with whom to raise an inquiry of this kind. Ms. Schuler responded that he was not entitled to a credit in the circumstances. Mr. Ronkai replied that he believed that he had received such credits in past. Ms. Schuler answered that although that she did not think precisely the same circumstances had arisen in the past, if they had, the matter would simply be overlooked but the policy was one of not granting lieu days in oases of this kind. Mr. Ronkai made no further enquiries and accepted her view of the matter and there the matter stood until January of 1988. At that time, Mr. Ronkai had a discussion with a fellow em91oyee named MacMillan and in the course of their conversation MacMillan revealed that he had successfully grieved a lieu day entitlement in circumstances similar to Mr. Ronkai's. In fact, the grievance was settled by an agreement dated August 31, 1987 (Exhibit 4). Ronkai then raised the matter with his supervisor and, when advised that it was his view that it was'too late to pursue the matter, Ronkai spoke to the Union and'a grievance was filed shortly thereafter. The second grievor, Mr. Bleach, sustained a compensable injury in July and August of 1986. When he returned to work in September he claimed a lieu day for August 4, 1986. When he was not awarded a credit, he raised the matter with his supervisor who suggested that he speak to.Ms. Schuler. Bleach did so and Ms. Schuler offered the same advice that she had given to Ronkai. Mr. Bleach raised with her the case of Carol Walberg which he understood was one in which such a lieu day had been granted. Ms. Schuler responded that it was her understanding that the Employer had reneged on that arrangement and that the current policy was as she had explained it to Bleach. Mr. Bleach made no further enquiries with respect to the claim for August 4, 1986. Further, he made no enquiries on or about the time of his failure to receive .credit with respect to the statutory holidays on December 26, 1987 and January 1, 1988. Mr. Bleach's awareness of the change in policy came about as a result of a conversation with Ronkai in January of 1988, as a result of which he too spoke to the Union with the result that a grievance was filed. In summary, then, each grievor was aware of a negative decision being made with respect to a matter of interest at the time the decision was made and each grievor made enquiries at that time. It was only some years later, however, that they.each became aware that a grievance with respect to a similar decision effecting another employee had enjoyed success. Upon learning of this fact, Ronkai and then Bleach, in turn, promptly filed grievances. The Employer's position is that, for purposes of Article 27.2.1, the time began to run at the time each employee first became aware of the decision that credit would not be given for the lieu day in each case. The Union argues, however, that time did not run until, in Ronkai's case, the grievor had a conversation with MacMillan and in Bleach's case, the grievor had a conversation with Ronkai. In support of the view that time begins to run when the employee first becomes aware of an act or event which in some way ~dversely affects the employee, the Employer relied on three previous decisions of the Grievance Settlement Board, Lam_ and Ministrv of Transportation and Communications, 377/83 (Jolliffe); Goheen and Min~stk"v of Education 321/82 (Verity); Graham ~nd Ministry of Transportation, 0981/86 (Ratushny). The decision in Lam concerned a contested placement which had resulted from the relocation of a particular unit. The grievor had signed an agreement accepting reassignment and at some undetermined point in time thereafter had raised the matter with the Union with the eventual result that a grievance was filed eight months after the incident at issue. The Board noted that the applicable Article of the agreement, Article 24, was a complicated one and that it was probably for this reason that the grievor and others remained unaware that Article 24 might have some bearing on the situation 6 for some months. Nonetheless, the Board was of the view that the time limits were mandatory and that the Board could not exercise an equitable discretion to relieve against them. In Goheen the grievance concerned a claim for travel expenses which the Employer denied on the-basis ~hat-travel expenses were covered by an honorarium which had been paid to the grievor. The grievance was filed several months after the initial denial but the grievor attempted to rely on the fact that subsequent discussions with the Employer concerning the tax implications of the Employer's position with respect to the honorarium created an estoppel and precluded the Employer from relying on a strict interpretation of article 27.2.1. The Board rejected this submission on the basis that the subsequent discussions related only to matters of taxation and not to the question of denial and therefore did not prevent the running of time under Article 27. In Graham the claim related to an alleged failure to pay. appropriate amounts of overtime pay over a period of some five years or so. The grievor sought to avoid the application of Article 27.2.1 on the basis that he had only become aware of the possibility of a claim with respect to this matter as a result of a conversation with a fellow employee some three years after the events in question. The Board rejected this submission and dismissed the g~evance as untimely on the following basis at page 4: "Nor can we accept the proposition that section 27,2.1 only becomes operative when an employee subjectively "believes" that he has a complaint or difference. Again, no authority was cited to support this position. In our view, unless an 7 element of objectivity is read into this provision it could not serve its purpose of providing some finality and avoiding grievances based on situations which arose long in the past. Our situation does not involve circumstances where the employees were not aware of the facts upon which the grievance was based. He was aware at all times, of the hours and days which he was working. Nor does it involve any misconduct or misrepresentation on the part of the Employer. Rather, the employee became aware in 1986, for the first time, of the nature of the Schedule which applied to his position. We are of the view that lack of personal knowledge by an employee of a statutory provision, regulation or ter~ of the collective agreement cannot form the basis for avoiding the application of a mandatory time limit. The Employer contends that these three decisions establish what might be termed an "objective" test relating to the interpretation of Article 27.2.1. That is to say, the time limit will begin to run when the employee' is aware of the adverse or prejudicial conduct on the part of the Employer, whether or not the employee appreciated at that time that the matter was potentially grievable. For its part, the Union relies on two recent decisions of the Board in which the view has been taken that time may not begin to run under Article 27.2.1 until the employee "subjectively" realizes or believes that the prejudicial decision or conduct in question is potentially grievable= Mitchell and Ministry of Government Services, 1614/S5 and 1615/85 (Samuels); Pierre and Ministry of Correctional Services, 0492/86 (Verity). In Mitchell, the grievor had been on Long Term Income Protection (LTIP) for a period of time but it had been decided by the insurer that the benefits would cease as of July 22, 1985, thus rendering her a surplus employee subject to Article 24. In subsequent weeks, the Employer provided the grieuor with advice concerning her rights under Article 24 to be assigned to vacant positions under the certain circumstances. The gravamen of the complaint, however, was that the Employer did not adequately explain to the grievor that she had the right'to displace, in .certain circumstances, employees in lower paying positions. Although she had been told that she had."bumping rights", she was not given sufficient information in this. regard to understand what her situation was. The Board noted further that the grievor had been on LTIP as a result of depression and took the view that the prospect of losing her employment would have aggravated her emotional state and further compromised her ability to understand the options available to her. Shortly before the layoff was to occur, the grievor met an old acquaintance who advised her to speak to the Union about her situation. The grievor actually did so in the second week of January and it was only at this time, in the Board's view, that she was fully aware that the handling of her case might involve a breach of the Collective Agreement. The grievance, which was filed shortly after this meeting, would not have been timely if time had begun to run at the time at which she became aware of the Employer's decisions concerning her employment status. The Board held, however, that time would not begin to run until the grievor's meeting with the Union. The Board offered the following explanation for this holding at pages 6-7: "Now, with respect to the timeliness of the individual grievances, Article 27.2.1 establishes a time limit which does not begin to run until the employee first becomes aware of the complaint or difference. The words 'complaint or difference' refer to 'complaints or differences between the parties arising from the interpretation, application, administration 9 or alleged contravention of this Agreement'". (Article 27.1) In other words, the time does not begin to run until the employee is aware that there is a complaint or difference under the collective ~greement. Her complaint or difference in this sense is not being declared surplus, or being laid off, but her feeling that she has not been treated according to the collective_agreement. While we have some hesitation concerning her awareness of her rights under the collective agreement, on balance we find that, bearing in mind - her emotional state at the time, - the complication of the surplus procedures under Article 24, - the brief explanation of these procedures that she was given, - the fact that she wasn't in the workplace throughout the period, to benefit from the advice of friends, - the failure of the Ministry to explain fully to her the possibility and consequenoes of displacement (she needed to know the potential financial oonsequences in order to choose to displace another employee rather than wait for an assignment for a vacant position), she was not aware that ~he had a complaint or difference until she met with Mr. Stewart in the second week of January, 1986. We note as well that in this case the Employer had failed to provide notice of the impending layoff of the grievor to the Union as is required by Article 24.10. The purpose of this provision is obviously to provide an opportunity to the Union to provide helpful advice to an individual in such circumstances. The Employer's alleged failure to provide such notice was the subject of a separate grievance by the Union. In our view, it is perhaps relevant to the disposition made of the in~ividual grievance of the grievor that the arrangements put in place by the Agreement in order to ensure that the grievor in such a case is fully advised of his or her rights under the Collective Agreement were not followed. That is to say, the Collective Agreement, in apparent recognition of the gravity of the situation and the complexity of 10 the arrangements concerning it, attempts to secure that all employees in the grievor's position are given advice by the Union. Where an employee, as a result of the Employer's failure to provide notice, fails to get such advice, it is perhaps not surprising that a Board would find itself able to conclude that the time limits under Article 24 do not begin to run until such time as the employee does receive such advice. The grievance in Pierre arose from concerns relating to the exposure of a Correctional Officer to an inmate suffering from tuberculosis and subsequent testing and treatment procedures, once informed that a former inmate had an active case of T.B., the correctional centre in question arranged for skin testing and x- raying of certain staff, including the grievor. The testing took place in early 1985. The grievor had a positive skin test and her physician.was so advised on April 18, 1985. It was not until mid- November, 1985 that the grievor visited her physician, however, and was then advised to commence certain drug treatments. Although the grievor commenced treatment shortly thereafter, she was apparently concerned that she had not been told the results of either the skin tests or the x-ray procedure and she spoke to the Union president in November of 1987 regarding her concerns. The president was allegedly satisfied that the matter was a routine one and, in particular, not grievable. He did suggest, however, that the grievor see a lawyer. On February 25, 1986, the grievor, as a result of receiving unfavourable work appraisals, met with the Chief Steward. It was her view that her appraisals were linked to 11 her involvement with the health issue and she was advised to file a grievance. On March 4, 1986, a grievance was filed alleging that the Employer had failed to provide proper health and safety measures with respect to the above incident. Obviously, the grievance would be timely only if time began to run at the time of the grievor's conversation with the Chief Steward. The Board in the Pierre case followed what it viewed to be the subjective approach adopted in the Mitchell case. The Board stated at page 14 that "what is required on the part of the employee to comply with the mandatory time limit, is knowledge or awareness that there has been a violation or possible violation of the provisions of the Collective Agreement. Article 27.2.1 contemplates the knowledge on the part of the employee - a subjective concept." The Board went on to quote from the decision of Vice-Chairman Samuels in the Mitchell case. The Board also noted that a different test is appropriate in the context of Union grievances. Article 27.12.1 stipulates the triggering event as "the occurrence or origination of the circumstances giving rise to the grievance" and this, in the Board's view, was lanquage which is inconsistent with a subjective interpretation. In summary, then, this panel of the Board is confronted with opposing interpretations of the test to-be applied under Article 27.2.1. In such circumstances, in our view, it is incumbent upon a panel of the Board to consider carefully whether or not apparently contradictory lines of authority of previous panels are reconcilable. Of course, it will from time to time be the case 12 that inconsistent lines of authority do develop and a clear choice between them must be made. At the same time, however, the principle of granting deference to previous aecisions of the Board suggests that the possibility of effecting an appropriate reconciliation of such authorities be carefully considered before moving to a choice of this kind which carries with it the implication that some previous decisions of the Board were incorrectly decided. In our view, it will be some indication of the desirability of attempting a reconciliation if the results of the previous cases, if not their reasoning, appear to be generally satisfactory. In the present instance, it is our view that the results of the previous cases are indeed generally satisfactory. In our view, an objective approach to the interpretation of Article 27.2.1 ought to be adopted as a matter of general principle, provided that a subjective approach may be used in cases where that approach is more appropriate. The critical distinction to be drawn between cases in which the objective approach is appropriate and those where it is not rests on a determination as to whether or not the matter which is the subject of the "complaint or difference" under Article 27.2.1 is one which obviously raises issues related to the administration of the Collective Agreement. Thus, disputes with respect to travel expenses and overtime pay evidently relate to matters that would be provided for in the Collective Agreement. An employee who becomes aware of a "complaint or difference" concerning such a matter, should, in our view, be assumed to realize that this is a matter which he or she 13 could pursue through the dispute resolution procedures of the Collective Agreement. Thus, an employee who is disappointed by an Employer decision with respect to a matter of this kind must, whether or not he or she "subjectively" believes the matter to be potentially grievable, pursue the matter within the time frame stipulated in Article 27.2.1. Any other interpretation of the Agreement would be inconsistent, in our view, with the stipulation in Article 27.1 to the effect that "It is the intent of this agreement to adjust as quickly as possible to any complaints or differences between the parties arising from the' interpretation, application, administration or alleged 'contravention of this agreement..." and its underlying rationale. Were this interpretation not adopted as a general matter, the Employer could regularly find itself in the following circumstances. The Employer could adopt an interpretation of the Agreement and plan and administer its affairs, including their budgetary implications, on the assumption that this particular interpretation of the agreement is acceptable to the Union, as evidenced by the fact that it has not been the subject matter of a grievance. Several years, indeed, could pass on this basis only to have a grievance ultimately surface and reveal that the interpretation is not a proper one. If one adopts the "subjective" approach to Article 27.2.1 in such circumstances, the implication would be that all past conduct would be subject to further grievances on the theory that only after the first grievance succeeded did various individuals appreciate that there had been a violation or possible violation of the provisions of the Agreement. In theory, then, grievances relating to incidents, perhaps running back over a period of several years, could be the subject of timely grievances. This is a result which we view to be inconsistent with. the policy expressed in Article concerning finality and expedition in the resolution of disputes. Accordingly, we adopt the view that where obvious matters of contract administration are Concerned, an objective test should be adopted in the interpretation of Article 27.2.1. it follows from this that we view the previous Board decisions in Lam, Goheen and Graham as consistent with this approach. On the other hand, there may well be unusual circumstances in which a subjective approach of the kind utilized in Mitchell and Pierre is appropriate. Thus, where the nature of the problem is one which an employee may reasonably not have understood to be a matter covered by the Collective Agreement or relating to its administration, it may be appropriate to delay the running of time under Article 27.2.1 until such time as the-employee comes to appreciate that this is the case. In both Mitchell and Pierre, there were grounds on which the Board could have satisfied itself that the grievor in each case had initially reasonably failed to understand the potential applicability of the Collective Agreement to the situation at hand. In summary, then, it is our view that the requirement for the commencement of the running of time under Article 27.2.1 is that the employee has a "complaint or difference" with the Employer and 15 has reasonable grounds to believe, in the language of Article 27.1 that the complaint or difference is one which is "arising from the interpretation, application, administration or alleged contravention of this Agreement .... " Where the matter is one which the employee ought reasonably to understand to be a matter of contract administration, the test is an objective one and the time will begin running under Article 27.2.1 at the time when the employee becomes aware of the decision or act of the Employer which adversely or prejudicially affects the employee. Where, on the other hand, the decision or act is one with respect to which the~ employee can reasonably maintain that he or she did not understand that a matter of contract administration was involved, a subjective approach to the operation of Article 27.2.1 may, in our view, be utilized. The case for doing so in Mitchell, we would add, appears considerably strengthened by the alleged failure of the Employer in that case to provide notice to the Union in the manner required by the Collective Agreement to ensure that the employee in such a .situation would receive timely advice from the Union. It remains, then, to apply the foregoing analysis to the present circumstances. In our view, the dispute concerning lieu day credits raises issues which are evidently matters of contract administration. Accordingly, it is appropriate to consider the triggering event under Article 27.2.1 to be the awareness of the grievor in each case of the Employer decision with respect to the denial of lieu day credits. We note further that in each case the evidence indicates that the grievor in question was not only aware 16 of the negative decision made by the Employer, but protested the decision in some fashion to the Personnel Department. In each case, the grievor determined at that time to accept the Personnel Department's view of the matter rather than to pursue it further with their Union. Such circumstances, in our view, represent an obvious case for the application of the objective standard under Article 27.2.1 and it follows that.these agreements fail to comply with the time limits set out'in that Article. For the foregoing reasons, these grievances are hereby dismissed. DATED at Toronto, this 27th day of Webruary, 1989. .hn D. McCamus ~ce- ChaLrperson T. Kearney, Me~er D. Wallace, Me~er