HomeMy WebLinkAboutTeskey 89-11-24
. J' 56 It 711
/"
L- L/!~
IN 1HE MATfER OF AN ARBITRATION (A)
BETWEEN:
ALGONQUIN COLLEGE
(the "College")
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(the "Union")
RE GRIEVANCE 88A791 - DEBBIE TESKEY
BOARD OF ARBITRATION: Pamela C. Picher - Cha~erson
Bob Gallivan - College ominee
Joe Herbert - Union Nominee
APPEARING FOR THE
COLLEGE: Stephen J. Shamie - Counsel
APPEARING FOR THE
UNION: Ross Wells - Counsel
Hearings in this matter were held in Ottawa on March 8 & September 28, 1989.
. .
- 2 -
AWARD
The Union maintains that the College breached the collective agreement
through the teaching load it assigned to Ms. Debbie Teskey as a sessional teacher in the
fall of 1987. Sessional teachers are not included in the bargaining unit. The Union
maintains that the College assigned Ms. Teskey an unreasonable teaching load in
contravention of article 4.05 of the agreement which provides as follows:
4.05 The parties agree that no College shall
circumvent the provision of this Article by
arranging for unreasonable teaching loads on the
part of persons who are excluded from or not
Included in the academic bargaining unit.
A. FACTS:
The Union called no evidence. The evidence presented by the College is not
in particular dispute and may be summarized as follows:
1. For approximately 11 weeks, from September to December of 1987, Ms. Teskey was
assigned a teaching load of 28 teaching contact hours. This was comprised of 4
teaching assignments, each 7 hours per week. Under the terms of the collective
agreement applicable to full-time teachers in the bargaining unit which attribute
additional workload hours for preparation, evaluation and feedback as well as
administrative and complementary functions, Ms. Teskey's 28 contact hours would
yield a total weekly workload of 63.5 hours. The College does not dispute that
these total workload hours are an approximately accurate reflection of the hours
Ms. Teskey probably worked during the 11 week period under review.
.
- 3 -
2. Through article 4, the collective agreement establishes maximum contact hours and
total maximum workload hours that may be assigned to full-time teachers in the
bargaining unit. The maximum weekly contact hours assignable to full-time
teachers in nursing is 18 (article 4.01 (9». The maximum total weekly workload
hours for teachers in nursing is 44 hours (article 4.01 (2)(a». The maximum
permissible overtime for such full-time teachers in the bargaining unit is an
additional 1 contact hour in any week and 3 additional total workload hours.
(article 4.01 (10)(a».
3. For her work assignment, Ms. Teskey was paid approximately $615.00 a week for
the 11 week period. It is common ground that for an attributed total workload of
63.5 hours per week, the hourly wage would be approximately $9.00.
4. The circumstances surrounding the appointment of Ms. Teskey were testified to by
Ms. Margaret McGee, the Acting Dean of the School of Health Sciences since
August 19, 1987, and Ms. Jane Wolfe, the Acting Chair of the Nursing Department
since August 17, 1987. The Nursing program utilized approximately 50 full-time
teachers in the 1987-1988 academic year and between 5 and 35 non full-time
teachers (including part-time, partial load and sessional teachers), depending on the
term. Mer assigning full teaching loads to the 50 full-time teachers, Ms. McGee,
for the 1987 fall semester, had approximately 36 further teaching assignments
which had to be filled. Due to the circumstances of the schedule, particularly as it
related to the provision of the clinical practice for the students, these 36 teaching
spots had to be assigned to non full-time staff. Four of these 36 assignments
were ultimately given to Ms. Teskey.
- 4 -
5. During the summer of 1987, Ms. Teskey called the Nursing Department to ask if
there were any available full-time teaching positions. She was advised by Ms.
Wolfe that although there were no vacant full-time positions, there were some
available non full-time positions such as sessional and part-time appointments. Ms.
Teskey stated that she was in need of money and wanted to work as many hours as
possible. In August she was initially given two teaching assignments of 7 hours
each, for a total of 14 contact hours.
6. The Nursing Department faced a staffing problem in the summer of 1987. The
Union does not argue that the College should have or could have created an
additional full-time position to fill any or all of the 36 teaching assignments it was
trying to fill with non full-time teachers in the fall term. The College had
considerable difficulty filling the last 13 spots which still remained open when Ms.
Wolfe took over from Mrs. McGee in mid August 1987. Ms. McGee commented that
because she had hired 10 additional full-time teachers for the 1986-1987 academic
year and 4 for 1987-1988, she had depleted somewhat her roster of non full-time
teachers. Once she exhausted her remaining roster of available and appropriate
non full-time teachers in August of 1987, she turned to applications for employment
that were on file. She then went to the files in the Human Resources Department
and outside employment agencies. Ms. Wolfe testified without contradiction that
through these and further means she was just able to fill the 36 outstanding
teaching spots before the start of classes in the fall term.
7. Ms. McGee initially offered Ms. Teskey 14 weekly contact hours which would cover
2 of the 36 teaching assignments. It is common to the testimony of both Ms.
- 5 -
McGee and Ms. Wolfe that they would have preferred to leave her teaching
assignment at that level and fill the remaining spots with other non full-time
teachers. However, as the commencement of the fall term drew closer and closer
and as the College continued to be unable to find enough qualified persons
available to fill all of the spots, Ms. McGee finally assigned 14 additional contact
hours to Ms. Teskey, for a total of 28.
8. Ms. Teskey willingly took on the additional assignment. No complaints were
received about the quality of her teaching and there is no suggestion that Ms.
Teskey had any difficulty satisfactorily completing her assigned work.
9. The Union does not dispute Ms. Wolfe's testimony that if Ms. Teskey had not been
assigned the additional 14 contact hours, the College would have been required to
cancel the clinical experience involved. She stated that that was not a feasible
option because the Ministry standards require students to have a certain number of
hours of clinical practice. Ms. Wolfe testified that the College was very close to
these minimums and that, in all likelihood, the minimums would not have been
attained if the affected clinical experience had been cancelled due to the lack of an
available instructor.
10. Ms. Wolfe testified that the fall of 1987 is the only occasion when she has been
required to assign one sessional teacher as many contact hours as Ms. Teskey had.
Since the fall of 1987 she has been able to find enough people who are qualified
and willing to assume the non full-time teaching assignments.
- 6 -
11. The Union does not dispute that despite concerted effort the College had difficulty
finding qualified teachers to fill the 36 non full-time teaching spots required for the
fall of 1987. It does argue, however, that if the College had offered more money,
in all likelihood, it would have been able to attract more teachers.
B. SUBMISSIONS:
1. Submission By The Union:
The Union does not argue in this case that for teaching assignments for
sessional teachers the College is strictly bound by the workload maxima established in
the collective agreement for full-time teachers in the bargaining unit. Moreover, the
Union accepts for the purposes of this case that the focus of attention for the purposes
of the application of article 4.05 should be the teaching contact hours as opposed to the
total workload hours.
The Union maintains that five factors indicate that a teaching load of 18 or
perhaps 19 contact hours (considering allowable overtime) is a reasonable teaching load
and that a teaching load in excess of that, to any appreciable degree, would be
unreasonable:
1. The establishment of the weekly maximum limit of 18 contact hours for
full-time teachers in the bargaining unit;
2. The fact that the additional hours which the collective agreement
attributes to a teacher's weekly hours of work for such matters as
- 7 -
preparation, evaluation and feedback and complementary or administrative
functions establish approximately a full week's work;
3. The prohibition against an overtime assignment of more than 1 contact
hour per week or 3 total workload hours a week;
4. The strict prohibition against probationary teachers being assigned either
contact hours or total workload hours in excess of the maxima; and
5. The evidence of Ms. McGee and Ms. Wolfe that Ms. Teskey was originally
assigned 14 weekly contact hours and that they would have preferred to
maintain that assignment.
Counsel for the Union emphasizes that the 28 weekly contact hours assigned to
Ms. Teskey in the fall of 1987 was a teaching load which exceeded the standard for
full-time teachers by approximately 50 per cent. The Union submits that wherever the
line may be between a reasonable and unreasonable teaching load for teachers who are
not in the bargaining unit, a load which is 50 per cent more than the full-time
allowable load clearly falls over the line and into unreasonableness.
Counsel for the Union argues that Ms. Teskey's willingness to work the 28
weekly contact hours is irrelevant to the assessment of reasonableness for the purposes
of article 4.05 of the agreement. Moreover, counsel emphasizes that the evidence
reveals that her desire was to earn the additional money that would result from the 28
contact hours and not to actually teach the added hours. In support of the irrelevance
of the willingness of a sessional teacher to teach contact hours in excess of the maxima
- 8 -
established for full-time teachers, counsel points to the following passage in Re
Cambrian College and O.P.S.E.U. Local 655 (Mr. Gibson), decision of Jane Devlin, dated
November 16, 1987 at p. 15:
We also agree with Ms. Farson that whether or not Mr.
Gibson was content with the workload is largely irrelevant.
Article 4.05 was designed to preclude the College from
assigning excessive or unreasonable teaching loads to non-
bargaining unit employees with potentially negative impact
on members of the bargaining unit. As a consequence, the
reasonableness of the teaching load can not, in our view,
be judged by whether the sessional employee is satisfied
with the hours assigned.
The Union does not challenge efforts made by the College to find additional
non full-time teachers. Counsel maintains, however, that a good faith effort on the
part of the College to avoid an excessive load for a sessional teacher is irrelevant.
Counsel argues that once it is established that the teaching load is unreasonable, the
assignment is prohibited under article 4.05 of the agreement, whether or not the College
tried its best to avoid the breach.
In the alternative, counsel for the Union submits that if the efforts of the
College are relevant then the Board should conclude that the College did not make
sufficient efforts because the per hour salary of approximately $9.00 fell well below a
competitive wage for the marketplace. Counsel argues that to set up as a defence to
an unreasonable teaching load the difficulty the College faced obtaining qualified
teachers, the onus rests with the College to show that it offered a competitive salary.
Counsel acknowledges that it called no evidence as to what nurses were being paid in
the marketplace at the relevant time. It maintains, though, that the Board can take
notice that $9.00 a hour was not attractive.
- 9 -
2. Submissions By The College:
Counsel for the Colleges argues that the limits set by the collective agreement
for the maximum permissible weekly contact hours and total workload hours for full-
time teachers in the bargaining unit are not determinative of the reasonableness of the
teaching load assigned to sessional teachers for the purposes of article 4.05 of the
collective agreement. Counsel maintains that if the parties had intended fixed numerical
hourly limits for the teaching loads for sessional teachers they would have so stated
instead of utilizing the more flexible standard of reasonableness.
Counsel for the College submits that reasonableness is a concept that requires
an examination of the surrounding circumstances. He further maintains that the onus
rests with the Union to establish the unreasonableness of the teaching load rather than
vice-versa and that this grievance should be dismissed on that basis alone. He argues
as well that a necessary ingredient to a breach of article 4.05 is the establishment by
the Union that the integrity of the bargaining unit is adversely affected by the assigned
teaching load. In support of these submissions, counsel relies on the decisions in Re
Cambrian College and O.P.S.E.U. (union &rievance #87X97), decision of E.E. Palmer dated
July 5, 1988); Fanshawe College and O.P.S.E.U. (union &rievance #83247. Mr. W.
Vanderlip), decision of Gail Brent dated February 1, 1984 and Fanshawe College and
O.P.S.E.U. (union grievance 83249. Ms. LUmoessien), decision of H.D. Brown, supr~
dated July 12, 1984.
Counsel for the Colleges further relies on the following statement at pp.14-15
of Re Fanshawe College (Ms. Umoessien), decision of H.D. Brown, to argue the relevance
- 10 -
for the assessment of reasonableness of Ms. Teskey's willingness to teach 28 contact
hours:
The Union points to the number of extra hours on the
form as assigned to Ms. Umoessien and submits that is an
unreasonable teaching load. There is no evidence to
support that bare presumption.
In some courses that amount of extra time in such a period
might be considered excessive in that it would be too
onerous a duty for the teacher and in others it would not
be so. The best judge of that is the teacher of the course
and if she agrees to the extra work, the reverse of the
Union's argument can be used, that it is not excessive on
its face because of that individual agreement. There is not
then sufficient facts.
(It is apparent that the weight accorded a teacher's willingness to work the hours in
dispute reflected in this Re Fanshawe College decision differs from the view set out in
Re Cambrian College, supr~ and relied on by the Union).
Counsel for the College maintains that the rate of pay offered Ms. Teskey is
wholly irrelevant to the issue of whether the College circumvented the workload
provisions of the agreement by assigning an unreasonable teaching load. Counsel
submits that in any event the fact that the College', has not encountered difficulty
attracting a sufficient number of non full-time teachers at any time other than the fall
of 1987 belies the significance of the rate of pay. There has been no substantial
change in the level of remuneration.
Counsel for the College submits that the full circumstances surrounding the
assignment of 28 weekly contact hours to Ms. Teskey establish that the College did not
"circumvent the [workload] provisions of [the collective agreement] by arranging for
- 11 -
unreasonable teaching loads on the part of persons who are ... not included in the
academic bargaining unit". The specific circumstances relied on by the College are:
1. The uncontested fact that the teachi~ spots filled by
Ms. Teskey could not be filled by a ll-time teacher
and thus did not threaten the integrity of the
bargaining uni t,
2. The concerted effort made by the College to find
qualified teachers to fill the spots so that it would
not have to assign Ms. Teskey more than her
originally scheduled 14 hours.
3. Ms. Teskey's willingness to work the 28 contact hours
and the lack of any complaints about the assignment.
4. The adverse result of not assigning the additional
hours which would have been the cancellation of the
clinical experience for the students involved and the
probability that that would have taken them below the
minimum standards set by the Ministry for the
required numbers of clinical hours for nursing
students.
5. The isolated nature of the augmented assignment as
evidenced by the fact that it lasted for less than one
full term and has not happened since.
Counsel argues that in all of these circumstances and, particularly the desperate
circumstances facing the College, the teaching load assigned to Ms. Teskey was not
unreasonable.
C. DECISION:
The issue of whether the College has circumvented the workload provisions of
the collective agreement as set out in article 4 by arranging for unreasonable teaching
loads on the part of persons who are not included in the bargaining unit is
determinable by an assessment of aU of the circumstances surrounding the assignment of
the teaching load under review. It is clear from the use of the phrase "unreasonable"
- 12 -
that the parties have not confined the College to the strict workload maxima applicable
to full-time teachers in the bargaining unit. The concept of unreasonableness is one
that carries flexibility and draws its definition in a specific situation from the
surrounding circumstances. It may be that the assignment of a load of 28 contact hours
would be an unreasonable teaching load in one set of surrounding circumstances but not
in another.
Having carefully reviewed all of the circumstances of the teaching load
assigned to Ms. Teskey, the Board cannot conclude that the College circumvented the
provisions of Article 4 by arranging for an unreasonable teaching load on the part of
Ms. Teskey.
The Union does not suggest that the teaching load assigned to Ms. Teskey
could have been given to a full-time teacher. Nor does it suggest any means by which
the integrity of the bargaining unit was put into jeopardy by the teaching load assigned
to Ms. Teskey. In addition, there is no evidence to suggest that Ms. Teskey had any
difficulty successfully performing her assigned load.
The evidence establishes that the College made concerted efforts to find
sufficient non full-time teachers to avoid assigning 28 teaching hours to Ms. Teskey.
The evidence does not suggest there was anything it could have done that it didn't do.
The option put forward by the Union for the College to resolve its problem was for the
College to raise the rate of pay it was offering sessional teachers to better attract
more non full-time teachers. The Board does not accept that the College's remuneration
of sessional teachers was in any way responsible for its problem finding non full-time
teachers to fill its 36 spots. There was no evidence to establish the going rate of pay
- 13 -
in the marketplace for persons who might qualify as sessional teachers in nursing.
Moreover, the fact that the College has not been faced with difficulty attracting
sessional teachers during any period other than the fall of 1987 strongly suggests that
the pay package offered by the College was not a deterrent or the cause of the
College's teacher shortage in the fall of 1987.
The maximum contact hours including overtime that may be assigned to a full-
time teacher in the bargaining unit is 19. Ms. Teskey was assigned 28 contact hours.
The College readily acknowledged that it would have preferred to maintain Ms. Teskey's
original assignment of 14 contact hours. However, the evidence is equally clear that
the College was faced with a crisis as it approached the start of classes in September
of 1987 because it was unable to find a qualified teacher to assume the additional 14
contact hours it assigned to Ms. Teskey. It is undisputed that but for assigning the
additional hours to Ms. Teskey, the only option left to the College would have been to
cancel the clinical courses. Moreover, the Union did not challenge the College's
evidence that to cancel the clinical experience for the students involved might well have
jeopardized their individual nursing programs because it might well have brought the
students below the minimum hours of clinical experience required by the Ministry. It is
not an exaggeration of the circumstances to characterize the situation facing the
College as an emergency, and we so find. The emergency nature of the situation is
further demonstrated by the fact that the teacher shortage occurred for only one
semester and has not happened since.
While in some circumstances the assignment of 28 contact hours may result in
an unreasonable teaching load, the Board is fully satisfied, on the basis of the totality
. -
,
- 14 -
of the factors outlined above, with particular regard to the emergency faced by the
College, that in this situation it did not result in an unreasonable teaching load.
On the basis of the foregoing, then, we concluded that the College did not
"circumvent the provisions of ... Article [4] by arranging for [an] unreasonable teaching
[load] on the part of ... [Ms. Teskey, a person] not included in the bargaining unit"
within the meaning of article 4.05 of the collective agreement.
Accordingly, for the reasons set out above the grievance is hereby dismissed.
DATED at Toronto this 24th day of Nove
Pamela C. Picher - Chair
I DISSENT (ATTACHED) "J oe Herbert"
--------------------------------------------
Union Nominee
I CONCUR "Bob Gallivan"
--------------------------------------------
College Nominee
DI
. I agree with the chairperson's depiction of the facts
in this case. I would go fUrther and indicate that if the test
to be applied is the reasonableness of the employer's conduct, I
could agree with her conclusions.
..
In my view, however, the test compelled by the
collective agreement is a different one and requires a different
result. Article 4.05 is structured in a manner which
necessitates a determination of whether the teaching load itself
. ~
- 15 -
is reasonable, rather than an assessment of the employer's
conduct.
'.
The term "unreasonable" is used as an adjective to
modify "teaching load" and the characteristics of the teaching
load (eg. the quantum) must be examined and the conclusion drawn
-
on that basis. Put differently, if the union were able to show
that the employer's conduct was unreasonable, is it then
unnecessary to demonstrate an unreasonable teaching load?
For these reasons, I would have found that Ms.
Teskey's teaching load was unreasonable in that it exceeded by
50% the full time limitations. Wherever the line is to be drawn,
Ms. Teskey's load surpassed it. I would have granted declaratory
relief.
DATED at Toronto thisi24th day of November, 1989.
"Joe Herbert"
I