HomeMy WebLinkAbout1986-1277 Vinall et al 93-07-21 ONTARIO EMPLOYES DE LA' COURONNE
CROWN EMPLOYEES DE L'ON TARIO
GRIEVANCE C,OMMI$SION DE
SETTLEMENT' REGLEMENT
BOARD DES GRIEFS
150 DUNDAS STREET WE$~ SUITE 2100, TORONTO, ONT~, M5G 1Z8 TE~PHONEIT~L~PHONE; (476) ~2~ t388
180, RUE OUNDAS QUEST, BUREAU 21~o TORONTO ~ONTARIO~, M5G
1270/86, 1276/86, 1277/86
IN THE MATTER OF ]tN ARBITI~ATION
Under'
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEU/%NCE SETTLEMENT BOARD
BETWEEN
OPSEU (Vinall' et al)
Grievor
_. - and -.
The Crown in Right of Ontario
(Ministry of Natural Resources)
EmPloyer
BEFORE 'O. Gray Vice-Chairperson
I. Thomson Member
J. Miles Member
FOR THE M. Webb
GRIEVOR Counsel
Gowling, Strathy & Henderson
Barristers & Solicitors
FOR THE D.-Costen
RESPONDENT Counsel
Legal Services Branch
Management Board of Cabinet
HEARING May 27, 1993
AWARD
The union alleges that the employer has breached the terms on which a
grievance by Roy Vinall was settled in 1988. It asks that We enforce the terms of that
settlement. The employer says that it has abided by the terms of the settlement. As
a preliminary matter, however, it objects that this Board has no jurisdiction to enforce
the terms of the settlement because they involve the provision Of training, a matter
which subsection 18(1) of the Crown Employees Collective Bargaining Act ("the Act~)
says may not be the subject of collective bargaining. This award deals with that
preliminary Objection. -
The Facts Alleged by the Union
Apart from references to correspondence received by the Grievance Settlement
Board (~GSB'), the background description which follows reflects union counsel's
opening statement. Parts of it may be in dispute. It is not in dispute that the parties
entered into the Memorandum of Settlement quoted below.
On October 6, 1986, Mr. Vinall and two other pilots employed by the employer
grieved that they had been improperly denied a position described as ~IFR - Remote
Sensing Pilot" which had been the subject of two job postings. The job involved flying
an aircraf~ described to us as a 'Navaho~ out of the Ministry's Malton base. The first
posting did not identify current proficiency on that aircraft as ·something applicants
had to have. Mr. Vinall did not have it. A more junior applicant did. Mr. Vinall was
interviewed. His score was almost as high as that of the junior applicant. Afar the
interviews, .the employer cancelled the job competition and reposted the' job'. The
second posting required current proficiency on the Navaho aircraft. The more junior
of the original applicants, who had that qualification, was awarded the job.
The three grievances were referred to the GSB for arbitration. Having earlier
had the hearing of the grievances adjourned sine die, in mid-1988 the parties executed
a written Memorandum of Seftlement in the ,following terms:
In the mstter of grievances (G.S.B.//1270/86, 1276/86 and 1277/86) betweer~
The Ontario Public Service Employees Union
(R. Vinall, L. Zinn, P. Crosby, Grievors)
-and-
The Crown in Right of Ontario
(Ministry of Natural Resources)
the parties are agreed to the following as a full and final.resolUtion.
1) The Ministry shall"provide' training, to each of the Grievors to a proficient
level, on the King Air in order of seniority.
2) The training shall begin on approximately October 1, 1988, following the
completion of the 215 prOgram, beginning with the most senior grievor.
Training for the other two grievors shall begin on approvingly the same
date in 1989 and 1990. Following completion of their training, each grievor
will be 'given reasonable flying time on the King Air.
3) Upon completion of their tr~inlng, the grievors agree to compete for King Air
Pilot vacancies as they arise. Such vacancies will be posted and conducted in
accordance with Article'4 of the Collective A~reement.
4) Should any or all of the Grievors be the successful candidate in any
competition described in//3, they agree to accept the position ~nd relocate as
necessary. Article 4.5 will apply.
5) The Union and the Grievors sb~]l immediately withdraw their grievances
and notify the Registrar ~of the GrievanCe Settlement Board that the matter
is resolved.
The above terms and conditions are agreed to without prejudice to the positions of
the parties and shall not be raised in any further or other disputes.
The "Air King' is another aircraft which was and is being flown out of'the Ministry's
base in Malton.
In September 1~88, the GSB was advised by' the union's courmel that tho three
grievances had been settled and that, in accordance With the settlement, the grievors
were withdrawing their grievances. In January 1993, the union wrote to the GSB as
follows:
The GSB did not issue an award in the above captioned matter as a Settlement was
reached.
A copy of the Memorandum of Settlement is enclosed.
It is now requested that this matter be scheduled for arbitration as the terms of the
Settlement have not been complied with and therefore the original grievances
remain u~_resolved.
Whatever may have been intended by that letter, the union does not now ask that this
Board entertain Mrl Vinall's original grievance. As we.noted at the outset, it asks that
we enforce the terms of the Memorandum of Settlement by which that grievance was
settled. -'
The Union's position is that the training and flying time provided for in the
Memorandum of Settlement are the training and flying time required to attain and
maintain the qualifications required of a pilot of an Air King aircraft under the
federal Department of Transport's Air Navigation Order, Series' 7, N~.~mber 3. It says
Mr. Vina]l received that training and flying time in 1989, 1990 and 1991. He is the
only one of the three grievors still in the bargaining unit. By letter dated November 6,
1992, the Ministry advised Mr. Vinall that it would no longer fund his "annual Air
King training' because of the "current fiscal environment'. He was also told that the
Ministry is
prepared to assure you that you will be interviewed for the next pilot vacancy at
Malton if future recruitment is required. Further, we are prepared to assure you
tlmt currency on a King Air will not be a job requirement nor will it be considered
is a factor in the interview process.
This assurance apparently plays a part in the argument the Ministry would make that
its refusal to provide ongoing training and flying time is not a breach of the
Memorandum of Settlement.
Enforcing.the terms of that memorand~.~m will require that we interpret them.
Argument
In the course of their argument, counsel referred to the following provisions of
the Act:
18.--(1) Every collective agreement shall be deemed to provide that it is the
exclusive function of the employer to m~rmge, which function, without limiting the
generality of the foregoing, includes the right to determine,
(a) employment, appointment, complement, organization, assignment,
discipline, dismissal, suspensio .n, work methods and procedures, kinds
and locations of equipment and classification of positions; and
Co) merit system, training and development, appraisal and superannu-
atiom the g~Verning principles of which are subject to review 15y the
employer with the bargaining agent,
and such matters will not be the subject of collective bargaining nor come within
the jurisdiction of a beard.
(2) In addition to any other rights of grievance under a collective
agreement, au employee, cl~irnirlg, .
(a) that his position has been'improperly classified;
(b) that he has been appraised contrary'to the governing principles
and standards; or
(c) that he has been disciplined or dismissed or .suspended from
employment without just cause,
'may process such matter in accordance with the grievance procedure provided in
the collective agreement, and faili~g final determination under such procedure, the
· matter may be processed in accordance with the procedure for final dete _rrn~nation
applicable under section 19.
19.--(1) Every collective agreement sb~!! be deemed to provide that in the
.event the parties are ~,~oble to effect a settlement of any differences between them
arising from the interpretation, application, sc]miuistration or alleged contravention
of the agreement, including any question as to whether a matter is arbitrable, such
matter may be referred for arbitration to the Grievance Settlement Board and the
Board after giving full opportunity to the parties to present their evidence and to ·
moke their submissions, sh~!~ decide the matter and its decision is final and
binding upon the parties and the employees covered by the agreement.
(6) Where a party or an employee has failed to comply 'with any of the
terms of the decision of the Grievance Settlement Board, any party or employee
affected by the decision may,'after the expiration of fourteen days from the date of
the release of the decision or the date provided in the decision for compliance,
whichever is later, file.in the~office Of the R~gistrar of the Supreme Court a copy
of the decision, exclusiv~ of the reasons therefor, whereupon the decision shall be
'entered in the same way as a judgment or order of that court and is enforceable as
such.
Counsel also referred to four decisions.of this Board: Sim arid Bain, 1387/86 (Draper),
Jansen, 888/89 (Watt'rs), Neamtz, 5i6/84 (Roberts) and Union .Grievance, 802/91
(Watters).
The award in Sim and Bain, supra, concerned a grievance which alleged that
the employer had failed to~comply with the written terms on which a previous
grievance had been settled. Notwithstanding the willingness of both parties to have
it deal with their dispute about the interpretation of their settlement agreement, .a.
panel of the Board refused to do so on the ground that, in its view, the dispute did not
fall within the statutory jurisdiction conferred on the GSB by the Act. This decision
was the subject of ~m application for judicial· review, to which reference will be made
later.
In Jansen, supra, another panel had a discharge, grievance before it. The union
claimed that the matter had been settled. The employer said it had not. Further, the
employer argued that the Board was without jurisdiction to consider whether a
settlement had been concluded, relying on the award in Sim and Bain, supra. The
panel ruled that it did have that jurisdiction:
In our judgment, we do possess the Jurisdiction to determine whether the parties
effected a settlement of the issueB in d.tspnte. We th~lc that this case is distinguish.
able from Sim and Bair~ There, both parties asked the Board'to interpret terms of
settlement which had been reduced to written form. The Board concluded that it
lacked the necessary authority to embark on an interpretation of the agreement.
In this instance, we are being asked a more fu~4~mental question, this being,
-.. - wheiher a settlement act~_~a_lly exists between these parties. In our minds, this is
a significantly d.i_~_erent issue. Indeed, the Board considers that this case is much
closer to the factual situation found in Cover, 256/50 (Kennedy) which was relied
on by the Union. It is apparent from a reading of the award that the Board there
was prepared to interpret written csmmunicatlons in an effort to find whether a
settlement had been reached. After e~mlning these communications, it held that
a settlement did exist. The Board, thei, efore, concluded that it would be improper
to entertain the merits of the dispute. In this regard, the award states at page four
(4): ,~
~There are numerous 'arbitral authorities to the effect that a grievance that' '
is settled, withdrawn or abandoned cannot be the subject matter of a
subsequent submission-to arbitratior~"
We are inclined to adopt an approach slmil~ to that employed in (~over. More
specifically, we conclude that our jurisdiction to proceed is found within section
19(1) of the Crown Employees Qo. llective Bargaining Act. Under that section, the
Board is empowered to determine, inter alia, whether a matter is arbitrable. In our
assessment, it is necessary for us to examine the facts in order to properly consider
whether these parties arrived at a binding agreement' following the preheating
meeting. If this question were to be answered in the affnnnative, this Board would
be deprived of the right to hear the grievance. Conversely, if the parties were not
ad idem, the grievance could go forward. The Employer would then be required to
commence its case and to show just cause for the discipline. A contrary finding
would, in our judgment, f/ixlermine the sanctity of settlements freely concluded as
it would permit parties to withdraw from such agreements with impunity. For ..
reasons which are obvious, that result would not provide for good labour .relations.
We are .consequently disinclined to adopt reasoning which could have that effect.
In Neamtz, supra, the union asked the Board to interpret the terms of an Order
it had earlier issued at the joint request of the parties, embodying an agreement the
parties had made in order to settle certain, grievances; The employer objected that the
Board was functus offic/o, and therefore without jurisdiction to do as the union asked.
One of the provisions of the parties' agreement and, thus, of the consent Order was
that
8. This settlement shall be made an Order of the Grievance Settlement Board
only for the purpose of enforcement of this settlement.
Having regard to that provision, the Board concluded that it did not have jurisdiction
to do as the union asked:
Considering the submissions of the parties in the light Of the unique facts of
this case, we must conclude that we do not have jurisdiction to clarify .any latent
ambiguities in the settlement agreement which was embodied in the instant
Consent Order. We have no doubt that by virtue of paragraph 8 of the Minutes of
Settlement, the parties agreed that the settlement would .be made an order of the
.. Board for a very limited purpose, i.e., the purpose of obtaining enforcement of the
terms of the settlement under Section 19(6) of the Crown Employees CollectiVe
Bargaining Act. They did not agree the Minutes of Settlement would become a
Board erder for all purposes, nor are we convinced that as a matter of law the act
of issuing the Consent Order transformed the Minutes of Settlement into an award
of the Board for all intents and purposes, including the purpose of clarifying the
language in which the parties cast their settlement. If this were so, it would stand
as a complete contradiction to paragraph 8, which, after all, formed part of the
Order.
If the parties had wished to place such ambigaities before the Board for its
determination~ they could have dono so by including appropriate language in their
Minutes of Settlement. As we have seen, the language they did choose to use
indicated precisely the opposite intent.
The' award in Union Grievance, supra, dealt with an objection by the employer
to the Board's jurisdiction to-entertain a grievance alleging that it had breached the'
' terms' of an agreement by which an earlier grievance had been settled. The settlement
agreement had not been made an order of the GSB. The employer argued that the
Board had' no jurisdiction to interpret a settlement and that the grievance was
inarbitrable under subsection 19(1) of the Act because it was not premised on breach
of specific articles in the collective agreement. The awards in Sim and Bain, Jansen
and Neamtz were cited.. With reference to. the award in Sim and Bain, supra, the
Board noted that
The Union subsequently filed au Application For Judicial Review dated October 14,
1988. The primary ground for asking for the intervention of the Divisional Court
was stated as follows:
the Grievance Settlement Board errored [sic] in declining to exercise its
jurisdiction under Section 19 of the Crown Employees Collective B0rgaining
ACt,, R.S.O. 1980, c. 108 to give a final and binding determin~ti°n to the
grievances of Patricia Sim and Douglas Bain.
The Union asked for an Order q~_~ashing the earlier decision of the Board and for
a further Order remitting the m~tter back for final and binding determination. The
endorsement of Mr. Justice Reid on the Application Record read:
.. Application is unopposed. The de~ision of the Grievance Settlement Board is
set aside and the matter remitted to the Board for a hearing of the grievance.
The Board in concluded that it had jurisdiction under subsection 19(1)of the Act
to resolve the parties' dispute about .whether the employer had complied with the
settlement, because it was a difference ,~which arose from the appIication,
administration or alleged violation of the collective'agreement:
The dispute between the parties initially arose from a complaint that the
Employer had improperly administered the provisions of Appendix 3, Schedule A
of the collective agreement. The grievance of September 11, 1989 was subsequently
resolved on March 8, 1991. The settlement 'roached on that date incorporated
earlier guidelines of March 14, 1990 that addressed, inter alia, the accumulation
and utilization of excess hours by. Schedule A employees. The Board, aflmr
reviewing the history of the dispute, concludes that the threshold issue on the
merits is whether the EmploYer has complied with the aforementioned settlement.
More specifically, did it change the guidelines prior to December 31, 1991 as
alleged. Such question~ of necessity, requires an interpretation of paragraph
number four (4) of the guidelines. In this regard, we do not accept the Employer's
assertion that the settlement was complied with as of the issuance of the
~. guidelines. Quite clearly, the settlement on its face contemplated that these
guideline~ would be in effect without change from April 15, 1991 to December
1991. The question of change cannot, therefore, be avoided. -
The Board has been persuaded that the ultimate difference between the
parties is directl~ r~la~d to the application, admim~ation or alleged contraven.
tion of the collective agreement, particularly Appendix 3, Schedule A thereof.
Section 19(1) of the Crown Emolovees Collective Bargaining Act makes the
Grievance Settlement Board the final arbiter of such disputes between the parties.
The Board by statute is authorized to m~ke a final and binding decision. There is
no question that the issue was properly before the Board by way of the' grievance
of September 11, 1989. We have not been convinced that jurisdiction was ousted or
exhausted as a consequence of the subsequent settlement~ Rather, we think that
juris&ction over the matter continues for purposes of ensuring that the settlement
is, in fact, complied with by both parties. Tkis role may require us to make a final
and binding decision on the threshold i~sue, as desm-ibed above. To be clear, we find
that the parties may return to the Board inthe event there is an allegation ofnen-
compliance.
Our decision on this aspect of the case promotes the labour relations objective
that settlement of grievances be encourage& Parties would not be inclined to enter
settlements if they could be breached with impunity without recourse to the
. Grievance Settlement Board. In a matter such as this, the parties could not resort
to,section 19(6) of the Crown Em~lovee~ Collective Bargaining Act as the Board did
not issue a decision that could be filed in the Supreme Court. Further, in view of
the settlement, it is unlikely that the Union could proceed with a fresh grievance
on the identical issue. Were the Employer correct, the Union here would be
'; required to go to the' courts of general jurisdiction in order to seek enforcement.
Quite apart from the possible effect of the Ri~ht~ of Labour Act, R.S.O. 1980,
Chapter 456, it would seem preferable, as a matter of policy, to have issues of the
present type dealt with by ~mi,dstrative tribunals having labour relations
expertise. This is especially so vis a vis the Grievance Settlement Board which
initially entertained the grievance and which by statute is compelled to render
final and bi:n_~,_'ug decision on outstanding differences between these parties.
-The Board found support for its conclusions in the result in the Divisional Court in
Sim and Bain, supra, despite the employer's argument that that result was premised
largely on the fact that there both parties wanted the Board to resolve their dispute:
Our decision is also consistent with ~irn and Bain. As stated previously, that case
raised an issue of compliance with a settlement. That question, which was also
before the Board by way of a second grievance, called for an interpretation of the
settlement. The Board declined to entertain the dispute. In its judgment, it lacked
the requisite jurisdiction under the Crown Ein~loyees Collective Bargaining Act.
The basis for the decision was placed squarely before the Divisional Court in the
Application For Judicial Review. We think it highly unlikely that' the Court would
have set aside the decision and remitted it back to the Board were it not of the
opinion the Board, in law, possessed the jurisdiction to undertake and complete the
tasl~ It is obvious that the Grievance Settlement Board is a creature of statute. It~
jurisdiction .cannot be enlarged by either the Court or the consent of the parties.
UltimAtely, on our review of Sim and Bairn we think the Divisional Cour~ has
determlued that this Board has the jurisdiction to hear a compliance issue
requiring an interpretation of terms of s~ttlement. This Chairperson's comments
in ~ansen relating to ~im and Bain were made without the benefit of the Divisional
Court's endorsement. Indeed, ~ was heard and released prior to the release
of that endorsement.
The Board also observed that the decision in Nearntz turned largely on the provision
in the 'parties' agreement that it was only to be made an order of the Board for
purpose of enforcement, which led the Board to conclude that the parties intended that
enforcement would be dealt with by the means contemplated in subsection 19(6) of the
Act.
Without acknowledging that it is correct, counsel for the employer argued that
the decision in Union Grievance, supra, is distinguishable because the relief sought
here is an order directing the employer to provide training. Because of subsection 18(1)
of the Act, 'training" could not be the subject of a collective agreement provision,
counsel submitted, and accordingly could not be the subject of a difference of the sort
contemplated by Subsection 19(1). He also argued that the wording of subsection 18(2)
of the Act makes 'it clear that the GSB does not have jurisdiction to entertain a
grievance about the Provision of training. He submitted that a settlement cannot give
the GSB that jurisdiction.
In answer to questions bY the chair, counsel for the employer said it was not .the
employer's position that the minutes of settlement Were unenforceable, but only that
they could not be enforced by the GSB. Asked, how the employer thought they could
be enforced, counsel first speculated about the possibility of an unfair labour practice
complaint to the Ontario Public Service Labour Relations Tribunal. Ultimately, he
stated that the Crown's position is that interpretation and enforcement of a settlement
agreement of this sort could be the subject of court proceedings.
Counsel for the emploYer noted that the settlement in question was made before
· the decision in Union Grievance, supra. He submitted that we should consider the
significance of the parties' decision whether to make their settlement an order of the -
Board or not in light of the jurisprudence as it then existed. He argued that the
parties'.failure to have the terms of their settlement incorporated into a Board order
should lead us to infer that they did not contemplate that a dispute about the level
and sufficiency of training provided pursuant to the Settlement would come back before
the Board.
Counsel for the union argued that the analysis in Union Grievance, supra, is
directly on point and cannot be distinguished as counsel for the employer suggests. She ·
submitted that most settlements in some way or other touch on management rights
and other subjects not addressed by the relevant collective agreement. She argued that
the Board has jurisdiction over the parties' dispute here because the dispute concerns
the terms on which the parties settled a grievance concerning the interpretation,
· application, administration or alleged contravention of the parties collective agreement
and, hence,, involves a difference ~arising from' the interpretation, application,
administration or alleged contraventio'n of the parties collective agreement. She denied
that the law on these points was clearly against the Board's having jurisdiction when
the settlement was made. She also submitted that our jurisdiction is not determined
by what the parties thought at the time.
There was no reference in argument to the fact that the allegation of non-
compliance with a grievance settlement was brought before us by requesting that a
hearing be convened with respect to the original grievance, rather than by processing
a fresh grievance through the grievance procedure.
Decision
In labour relations, as in other contexts, a resolution negotiated and agreed to
by the parties to 'a dispute is_preferable to one imposed on them through adjudication.
Grievance processes are intended to encourage and facilitate settlement. Parties to
labour relations disputes, are expected to pursue settlement before resorting to-
arbitration. The language of subsections 18(2) and 19(1) of the Act reflects that
expectation.
If settlements are to be encouraged, then they must also be enforced: Re Zehrs
Markets and Retail Clerks Union, Local 1977 (1984), 14 L.A.C. (3d) 379 (Barton) at 380.
In Re Canadian General-Tower Ltd. (Oakville DiVision) and United Rubber Workers,
Local 292 (1990), 12 L.A.C. (4th) 153, arbitrator Craven observed (at pages 155-156)
that
It is generally accepted that boards of arbitration have jurisd/ction to enforce
settlements reached during the grievance procedure, and that in exercising this
jurisdiction an arbitrator is to give effect to the parties' agreement~ without going
behind the terms of settlement to determine whether it was the "right' result in
the circumstances. The latter principle follows not only from the law of contracts,
but also f~om the sound industrial relations policy of encouraging the parties to
settle their own disputes: see generally, Crown E/ectr/c~ [19781 O.L.R.B. Rep. 344;
., Perfection Rug Co. Ltv~, [1984] O.L.R.B. Rep. 68; Corporation of Borough of Scar.
t borough and C.U.P.E., Loa 368 (unreported, May 23, 1978 (Brandt)); Re Corp. of
Borough of Etobivoke and EtobiWke Professional Firefighters Asst,, Loc. 1137
'. (1982), 5 L.A.C. (3d) 52 (Kenned,v); Re Stelco Inc. (Hilton Works) and U.S.W. (1989),
5 L.A.C. (4th) 284 (Haefling). I accept these propositions. Moreover, them is no
evidence before me concerning tha merits of Mr. Hearns' original grievant, nor
would such.evidence be relevant to my determination of this dispute.
Nevertheless, if the grievance settlement is to be enforced its ~term~ must be
interpreteck If, as the company argues, the settlement is couched in ambiguous
language, then that ambiguity must be resolved so that the real agreement can be
given effect. In this regard there is a crucial distinction to be drawn between
second-guessing the settlement in light or'the original dispute, which would
constitute unwonted arbi~al interference in the grievance procedure, and
interpreting the terms of settlement to give effect to the Parties' mutual intention,
which constitutes the proper exercise of the arbitral jurisdiction to enforce private
grievance settlements.
The arbitrator's jurisdiction to enforce the terms of a grievance settlement was
not in .dispute before arbitrator Craven in that case. It was in dispute, however, in one
of the cases he cited: Perfection Rug Co. Ltd., [19841 O.L.R.B. Rep. 68, 84 C.L.L.C.
¶16,017. There, the Ontario Labour Relations Board ("OLttB") was acting as a
grievance arbitration board-'under section 124 (now 126) of the Ontario Labour
Relations Act ("the LRA'), which provided that a party to a collective agreement in the
construction industry" ... may refer a grievance, concerning the interpretation,'
application, administration or alleged violation of the agreement, including any
question as to whether a matter is arbitrable, to the Board for final and binding
determination." The grievance referred to the OLRB in that matter alleged that the
employer had failed to comply fully with the terms on Which an earlier grievance had
been'settled. The employer argued that the OLRB had no authority under section 124
of the LRA to enforce a grievance settlement. After reviewing the arbitral
jurisprudence, the OLRB concluded that:
Whether raised inthe context of the original grievance (as in Suss Woodcraft Ltd.,
[[1983] O.L.R.B. Rep. April 600]) or of a second grievant. (such as in the present
case and in Ford Motor Company [(1952), 3 L.A.C, 1159 (Lang)]), an allegation that
a party to a collective agreement has failed to comply with the settlement of a
grievance constitutes an arbitrable question concerning the 'application" or
'a_~ministration' of the collective agreement, within the meaning of section 124(1)
of the Act.
The langUage of section 124 of the LRA was no broader than that' of subsection 19(1)
of the Crown Employee8 Collective Bargaining Act.
We agree with the'conclusion of%he award in Union Grievance, supra, although
we would not have assigned as much significance as that award did to the Divisional
Court's disposition of the unopposed application for judicial review of the award in Sim
and Bain. The award's assessment of the significance of that disposition depended, in
part, on the proposition that the arbitral jurisdiction of the GSB cannot be enlarged
beyond its statutory confines by the consent of the parties. We are not sure that that
is so. If it were, provisions in the parties' current collective agreement for expedited
arbitration by a single vice,hair of the GSB sitting aIone might be ineffective. In any
event, we agree that, with or without the parties' specific consent, the GSB has
jurigdiction under subsection 19(1) of the Act to resolve a dispute about whether or not
a party has complied with a grievance settlement. Such a dispute is a difference
"arising frpra' the application, administration or alleged violation of the collective
agreement.
We do not accept the employer's argument that because the parties did not have
their agreement' i.ncorporated into a Board order, they must have expected that
disputes about whether the training provided met the requirements of the agreement
would not be resolved by the GSB. The settlement preceded the decision in Sim and
Bain, supra. If the parties anticipated the possibility'of such disputes, it would have
been natural for them to expect that the GSB would be the forum in which any such
dispute would' be resolved, absent an existing GSB order which could be enforced
pursuant to subsection 19(6) of the Act. In any event, the parties did nothing to give
express contractual effect to their expectations, whatever those expectations may have
been. Nothing in the terms on which the parties agreed or in the circumstances in
which they agreed to them warrants our declining jurisdiction to resolve a dispute
about whether those terms been complied with. Our jurisdiction under section 19(1)
of the Act to interpret and enforce a grievance settlement is not contingent on the
parties' having expressly acknowledged it when making their settlement.
Are we without jurisdiction to. interpret and enforce the particular grievance
settlement in issue here because one of its terms involves training, a subject referred
to in subsection 18(1) of the Act? ,~
Subsection 18(1) of the Act does not expresslY limit the jurisdiction of the GSB
-- the reference to Va board~ at the end of the ~subsection is to an interest arbitration
board constituted under section 11. Nor, in our view, does the reference in subsection
18(2) of the Act to some but not all of. the subjects identified in subsection 18(1)
impliedly impose a restriction on what would otherwise be within the GSB's
jurisdiction by virtue of subsection 19(1).
The enforceability of-a grievance settlement cannot depend on whether the
terms of the settlement reflect what an arbitrator would have done or could have done
in response to'the original grievance. Nor can it depend on whether it would have -
been within an arbitrator's jurisdiction to impose the terms which tl~e parties
incorporated into the settlement. Limiting the enforceability of set~tlements in those
Ways would effectively negate one of the considerable attractions of dispute resolution
by negotiated settlement - that the parties are not confined, as an arbitrator would
be; in defining either the scope of the problem they wish to resolve or the nature of, an
appropriate response to it. Similarly, the enforceability of a grievance settlement
cannot depend on whether its terms could or would have been the subject or result o£
bargaining for a collective agreement. If settlements are to be encouraged, any lawful
provision of a settlement agreement must be enforceable, and enforceable in the same.
forum as any other such provision.
The employer does not say that subsection 18(1) prohibited it from entering into
an agreement with the union to provide training to an employee, nor that the
agreement is unenforceable because the subsection makes it unlawful. In our view, the
GSB has jurisdiction under subsection 19(1) of the Act to interpret and enforce any
lawful provision of an agreement by which the parties to a collective agreement have
settled a grievan, co, including the provisions in question here.
Accordingly, we are satisfied that we have jurisdiction to hear and determine
the parties' dispute on the merits. Our hearing for that purpose will commence on
August 23, 1993. ~
Dated at Toronto this 21 day of July, 1993.